Michael Adams Looks at “Meaningful Dialogue” Standard for Communicating a Denial of Benefits
Byline featured in DRI For the Defense Magazine
In The News | 1 min read
Apr 3, 2026
Hinshaw partner Michael Adams authored an article featured in the March issue of the DRI’s For The Defense Magazine, in which he examines the fiduciary duty of an employee benefit plan or its administrator to communicate a denial of benefits consistent with ERISA’s requirements.
Michael notes that courts are increasingly overturning otherwise substantively correct benefit denials because the plan administrator failed to provide a full and fair review of the denial through “meaningful dialogue” with the claimant.
His article consists of four parts. First, he outlines the ERISA’s full-and-fair-review requirement, which gives rise to the “meaningful dialogue” standard. Second, he examines how recent decisions, in particular DK v United Behavioral Health, 67 F. 4th 1224 (10th Cir. 2023), cert. denied 144 S. Ct. 808 (2024), have interpreted the “meaningful dialogue” standard when evaluating whether denial notices comply with ERISA. Third, Michael assesses whether DK and similar cases represent as dramatic a shift as some commentators have suggested. Finally, he offers practical tips to plan administrators for drafting denial notices that satisfy ERISA’s requirements, in light of recent court decisions.
Related People
Featured Insights

Webinar
Nov 12, 2026
Michael Adams Presents on Navigating Ethics in the Digital Age

Event
Nov 12, 2026
Cathy Mulrow-Peattie Discusses AI and Supply Chain Cybersecurity

Healthcare Alert
Nov 11, 2026
Illinois Enacts 340B Contract Pharmacy Protections: 7 Steps Covered Entities Should Take

In The News
Nov 10, 2026
Brian Turetsky Examines How NYC’s Proposed POWER Act Could Expand Private UDAAP Claims

In The News
Nov 9, 2026
Kate Schnake Examines Unlawful Discrimination vs. Legitimate Advocacy in Jury Selection

Press Release
Nov 6, 2026
Hinshaw Recognized by the LCLD as a 2026 Compass Award Winner and Top Performer

Consumer Crossroads: Where Financial Services and Litigation Intersect
Nov 5, 2026
FDIC Proposes State Bank Preemption Parity Rule Regarding Host State Laws

Press Release
Nov 5, 2026
Hinshaw Named Among the Nation's Leading Law Firms in Best Law Firms® 2027

Webinar
Oct 29, 2026
Carol Rooney Presents on Building a Career in Appellate Practice

In The News
Oct 28, 2026
James Ferrara Comments in The New York Times on Stalled Boca Raton Luxury Condo Project



