"This case is a cause for concern for ERISA disability plan administrators that take into account SSDI benefit determinations in deciding benefit claims but do not affirmatively seek out those determinations or SSA medical records where the claimant fails to provide them.... [H]aving involved itself in Melech's SSDI process by requiring her to file under the SSA's program, LINA created an affirmative obligation on itself to specifically ask Melech to supply her SSDI paperwork (or even, as the court suggested, go directly to the SSA to request her file)." [Melech v. Life Insurance Co. of North America, No. 12-14999 (11th Cir. Jan. 6, 2014)]