Whether the appellant's right to be heard was violated by limited access to file materials and lack of prior written statement opportunity.
Any procedural defect did not require remittal because the appellant failed to show a concrete need for further submissions or evidence; with regard to the disputed points, a remand would have been futile.
The court held that hearing rights are formal, but a remittal is unnecessary where no practical benefit would arise and the party's own procedural conduct shows the relevant facts were no longer contested. Only the missing amount-related file review remained relevant, and that portion had been addressed.