Anthony Shelley comments on the adjustments that federal appeals courts have had to make regarding the standards for reviewing determinations by health insurers and other employee benefit administrators, based on the U.S. Supreme Court's decision in Metropolitan Life Insurance Co. v. Glenn. Shelley says he viewed the landscape after the Glenn ruling as improved and simplified from the defense perspective. “Glenn held that de novo review is never appropriate and that potential conflicts are to be considered as just one factor. Well before Glenn was decided, however, most plan administrators already had procedures in place to separate payment and adjudication functions and thereby minimize potential conflicts,” Shelley says.