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Sixth Circuit Applies Futility Exception to Enforce Consistency in Claims Review
Health Plan Law 
Oct. 31, 2006
Excerpt: In Dozier v. Sun Life Assur. Co. of Canada, the Sixth Circuit precluded a life and disability carrier from requiring exhaustion of administrative remedies when the grounds for one claim denial was substantially similar (and in fact, more stringent) than the claim for the second benefit.
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