"Although the court persuasively rejected the 'substantial compliance' doctrine, this ruling will undoubtedly trigger further litigation as to the meaning of 'inadvertent and harmless' noncompliance. The court could also have gone much further because the harm here is one that is typical (and frustrating) in health care -- summary denials lacking any explanation.... Obtaining a comprehensible explanation for a denial so that it can be effectively challenged is hard enough, but obtaining the so-called administrative record is often impossible." [Halo v. Yale Health Plan, No. 14-4055 (2d Cir. Apr. 12, 2016)]  MORE >>