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A recent case in the Eighth Circuit makes clear that plan documents, and what they say, are important. We know this, but sometimes, especially in welfare benefit plans, the particulars aren’t always spelled out. ERISA plans often require participants to exhaust internal claim procedures before they can take the plan, or its fiduciaries, to court. In this Eighth Circuit case, the claim denial letter to a life insurance beneficiary required exhaustion, but the plan document didn’t. ERISA requires that the terms of an employee benefit plan be committed to written plan documents so that plan participants, by reviewing those documents, can learn their rights and obligations under the plan. So said the court, too.
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