In Holcomb v. Unum Life Ins. Co., 578 F.3d 1187 (August 11, 2009), the Tenth Circuit commented that theGlenn decision abrogated the Tenth Circuit’s previous approach to evaluating conflicts of interest in which it shifted the burden to the administrator to establish by substantial evidence that the denial of benefits was not arbitrary and capricious when evidence of a conflict was presented. Applying the Glenn “combination of factors” analysis, the Tenth Circuit concluded that the insurer did not abuse its discretion, and in fact, that the insurer took steps to reduce its inherent bias by hiring independent physicians and furnished them with all necessary information.