"The Ninth Circuit Court of Appeals recently applied a searching analysis under the abuse of discretion standard of review -- one that takes into account all circumstances and will not uphold denial simply if there is a single reasonable basis to deny benefits -- even where there was no finding that a conflict of interest existed.... The court emphasized that it will not uphold a claims decision simply because it is supported by 'any reasonable basis,' as the court had [previously] held ... In addition, the Ninth Circuit suggested that the admission of extrinsic evidence -- even where the abuse of discretion standard applies -- may be appropriate in ERISA cases where the administrative record is not sufficient." [Pacific Shores Hospital v. United Behavioral Health, No. 12-55210 (9th Cir. Aug. 20, 2014)]

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