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DOL Proposes to Bring ERISA Disability Denials in Line with the ACA
Proskauer's ERISA Practice CenterLink to more items from this source
[Guidance Overview]
Dec. 3, 2015

"Plans should consider the effect of this proposal on their arrangements with claims administrators and third-party vendors.... [M]any claims administrators contract with outside vendors to identify factors that warrant rescinding disability coverage. Coupled with other provisions in the Proposed Rule, the outside vendor's determination may constitute an adverse benefit determination and the information it considered in rendering its determination may have to be produced to the claimant."

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