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Fourth Circuit: When Is a Plan Administrator Obligated to Obtain Medical Records?
Lane Powell PC 
Jan. 5, 2015
"This is an expanding trend in the circuits. When the record does not refute the claimant's alleged disability, and [the plan administrator is] on notice of a treater who may have information related to the claim, either: [1] obtain a release and secure the 'readily-available' records, or [2] alert the claimant of what specific records are missing." [Harrison v. Wells Fargo Bank, No. 13-2379 (4th Cir. Dec. 5, 2014)]
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