"The representative never told Mr. Killian whether the services were in-network or out-of-network or whether there would be any limits to coverage. Mr. Killian took this as authorization for the procedure, and his wife underwent the surgery.... The Seventh Circuit has spoken that ERISA fiduciaries must take affirmative steps to disclose negative coverage information, even if such information is not specifically requested or inquired by the beneficiary -- otherwise, the fiduciaries may be liable for consequential damages." [Killian v. Concert Health Plan, No. 11-1112 (7th Cir. Nov. 7, 2013)]