a written claim to the plan administrator, the claimant will not receive an administrative review and therefore is precluded from filing a civil action. Second, the claimant must ensure that all administrative remedies have been exhausted. Id. This means that a plan participant must have first appealed his/her claim for an appropriate administrative review, as enumerated in the benefit plan, before he or she can bring a civil suit. The plan administrator usually conducts these administrative reviews through an internal review process. However, there is one exception to the rule of exhaustion of administrative review. Complete exhaustion of an administrative review is not necessary if the claimant can demonstrate that the participant was not informed as to the administrative claims process or if the claimant can show that the exhaustion will be futile.An administrative appeal is allowed if a beneficiary is denied a claim, which he or she believes is covered under the benefit plan, and the claimant has received a denial notice. When the plan administrator denies a claim, the administrator must meet certain requirement in his or her denial notice. The denial notice must contain four specific statements: (1) the specific reason for the denial; (2) a specific reference to pertinent plan provisions on which the denial is based; (3) a description of any additional material or information necessary for the claimant to perfect the claim and an explanation of why such material or information is necessary; and (4) appropriate information as to the steps to be taken if the participant or beneficiary wishes to submit his or her claim for review. 29 U.S.C. 1002. If the administrator does not provide a denial notice that includes the above four requirements, the claimant is deemed to have been denied a “full and fair review” and may seek to vacate the benefit denial. Halpin v. W.W. Grainger, 962 F.2d 685 (7th Cir. 1992). After...
