In Glenn, the U.S. Supreme Court addressed two issues: (i) whether a plan administrator’s dual roles as decider and payor of employee benefit claims create a conflict of interest; and (ii) how such a conflict of interest should be factored into a court’s review of the plan’s benefit claim determination. The Court expanded on its nearly 20-year-old decision in Firestone Tire & Rubber Co. v. Bruch and ruled that a third-party administrator, as well as an employer (as Firestone had ruled), has a conflict of interest if it both decides and pays claims. Furthermore, the Court held that this conflict of interest will be “weighed as a ‘factor’ in determining whether there was an abuse of discretion” by the plan administrator in evaluating the benefit claim. In reaching its conclusions, the Court noted that a conflict of interest may be more of a factor in a court’s review of a plan administrator’s benefit determination when “circumstances suggest a higher likelihood that it affected the benefits decision,” but less so “where the administrator has taken active steps to reduce potential bias and promote accuracy.” Accordingly, in light of the Court’s decision, you should consider reviewing the structure of your health plan’s benefit determination procedures (including those of your service providers) in order to assess what may need to be changed in order to “reduce potential bias and promote accuracy.”