Documents not submitted during the administrative review are not part of the adminstrative record

In Kearney v. Aetna Life Insurance Company, Civil Action No. 13-548-SDD-RLB (M.D. La. Apr. 22, 2014) Aetna provided what it claims was the complete administrative record to the Plaintiff. Plaintiff responded by filing a motion and attaching to the administrative record medical records it claims should be part of the administrative record. Aetna's appeal personnel attached an affidavit to Aetna's response in opposition to Plaintiff's motion to supplement the administrative record.

Decision in Cob Clearinghouse v. Aetna US Healthcare

"COB Clearinghouse Corporation, also known as Digital Healthcare, Inc., Plaintiff-Appellant, v. Aetna U.S. Healthcare, Inc.; Great West Life and Annuity Insurance Co.; Blue Cross & Blue Shield of Kansas City; Connecticut General Life Insurance Company" 


Agent of employer has no standing to sue under ERISA.


Full-text of the opinion

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