The passage discusses the conflict of interest inherent in administrative reviews under the Employee Retirement Income Security Act (ERISA). ERISA governs claims relating to employer-provided health, disability, and other benefits. The author notes confusion around ERISA's application and coverage, which has led to litigation. Specifically, the author worked on a case where a healthcare administrator had previously approved coverage for breast reduction surgery three times but then denied it, raising issues around whether the administrator was precluded from denial. On appeal, the court had to determine if the administrator abused its discretion given the plan granted discretionary authority.