“The Employee Benefits Security Agency (EBSA) of the DOL plans to publish new claims procedures…for adjudicating disability benefits…. Procedures would need to be designed to ensure independence and impartiality of the persons making the decision…. Denial notices would be required to provide a full discussion of the basis for denial and the standards behind the decision…. Claimants would need to be given access to their entire claim file and permitted to present evidence and testimony during the review process.” (Jackson Lewis)