"Rejecting a plan participant's claims that plan documents should specifically list in-network providers, the 7th U.S. Circuit Court of Appeals held that a plan clearly providing information on how to check for provider status was sufficient to escape benefits-denial and fiduciary-breach claims.... [T]he court also rejected an argument that call center representatives did not confirm provider status, finding that such poor communication does not per se create a fiduciary violation. [But] the appeals court raised the possibility of higher statutory penalties arising from the plan's violation of ERISA disclosure requirements." [Killian v. Concert Health Plan (7th Cir., April 19, 2012).]