MANNER AND CONTENT OF NOTIFICATION OF BENEFIT DETERMINATION Non-Disability Benefit Claims A Claimant shall be provided with written notification of any Adverse Benefit Determination. The notification shall set forth, in a manner calculated to be understood by the claimant, the following: 1. The specific reason or reasons for the adverse determination; 2. Reference to the specific plan/policy provisions on which the determination 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. A description of the review procedures and the time limits applicable to such procedures, including a statement of the claimant’s right to bring a civil action under section 502(a) of the Employee Retirement Income Security Act of 1974 as amended ("ERISA") (where applicable), following an Adverse Benefit Determination on Review. Disability Benefit Claims A claimant shall be provided with written notification of any Adverse Benefit Determination. The notification shall be set forth, in a manner calculated to be understood by the claimant, the following: 1. The specific reason or reasons for the adverse determination; 2. Reference to the specific plan/policy provisions on which the determination 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; 4. A description of the review procedures and the time limits applicable to such procedures, including a statement of the claimant’s right to bring a civil action under section 502(a) of the Employee Retirement Income Security Act of 1974 as amended ("ERISA") (where applicable), following an Adverse Benefit Determination on Review; and 5. A discussion of the decision, including an explanation of the basis for disagreeing with or not following: a) The views presented by the claimant to the plan of health care professionals treating the claimant and vocational professionals who evaluated the claimant; b) The views of medical or vocational experts whose advice was obtained on behalf of the plan in connection with a claimant’s Adverse Benefit Determination, without regard to whether the advice was relied upon in making the benefit determination; and c) A disability determination regarding the claimant presented by the claimant to the plan made by the Social Security Administration; 6. Either the specific internal rules, guidelines, protocols, standards or other similar criteria of the plan relied upon in making the adverse determination, or, alternatively, a statement that such rules, guidelines, protocols, standards or other similar criteria of the plan do not exist; 7. A statement that the claimant is entitled to receive, upon request and free of charge, reasonable access to, and copies of, all documents, records, and other information relevant (defined below) to a claim for benefits; and 8. The notification shall be provided in a Culturally and Linguistically Appropriate (defined below) manner. APPEALS OF ADVERSE BENEFIT DETERMINATIONS Appeals of Adverse Benefit Determinations may be submitted in accordance with the following procedures to: Reliance Standard Life Insurance Company Quality Review Unit P.O. Box 8330 Philadelphia, PA 19101-8330 Non-Disability Benefit Claims 1. Claimants (or their authorized representatives) must appeal within 60 days following their receipt of a notification of an Adverse Benefit Determination, and only one appeal is allowed; 2. Claimants shall be provided with the opportunity to submit written comments, documents, records, and/or other information relating to the claim for benefits in conjunction with their timely appeal; 3. Claimants shall be provided, upon request and free of charge, reasonable access to, and copies of, all documents, records, and other information relevant to the claimant’s claim for benefits; 4. The review on (timely) appeal shall take into account all comments, documents, records, and other information submitted by the claimant relating to the claim, without regard to whether such information was submitted or considered in the initial benefit determination; 5. No deference to the initial Adverse Benefit Determination shall be afforded upon appeal;

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