California Physicians’ Service v. Harlick

Issue: (1) Whether the doctrine of waiver applies when an ERISA plan administrator denies a claim for benefits on the ground that the ERISA plan does not provide coverage, and later wants to assert or investigate a ground for denial not stated in the initial denial letter; and (2) whether, if the doctrine of waiver can be applied generally in the above context, it applies in the specific instance where the ERISA plan did not have sufficient facts to have asserted the additional basis for denial when it denied the claim.