9th Circuit Faults Retiree Plan’s Disclosure of Lifetime Maximum
HR Daily Advisor
OCTOBER 3, 2017
Background. Because the SMMs were not cumulative, nor was the 96-page SPD amended to reflect them, a plan beneficiary would have to read the relevant SPD section plus each SMM to learn the current language for a given benefit provision. The case is King v. Blue Cross & Blue Shield of Ill., 15-55880 (9th Cir. 15-55880 (9th Cir.
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