Key legal question
Whether the lack of a formal prior-notice procedure required remittal for a new administrative hearing.
Extracted holding
No remittal was required because the insured had effectively been able to comment on the planned refusal after receiving the reasoned letter, so there was no material denial of hearing rights.
Extracted reasoning
The office’s letter of 9 January 2018 contained the reasons for refusal and invited the insured to request an appealable decision; through counsel, he did so without addressing the reasons. This amounted in substance to a prior-notice procedure.