"While the court ... acknowledged that administrators are entitled to flexibility in administering benefits, the Second Circuit concluded the need for flexibility cannot outweigh the purpose of the regulation to limit the number of appeals a claimant must pursue. Hence, the court determined that Hartford was obligated to decide McQuillin's entitlement to benefits within 45 days of his appeal submission, and the failure to do so rendered the duty to appeal exhausted after 45 days elapsed without a benefit determination." [McQuillin v. Hartford Life and Accident Ins. Co., No. 21-1514 (2d Cir. Jun. 7, 2022)]

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