Mealey's (February 5, 2018, 2:23 PM EST) -- SAN FRANCISCO — De novo review applies to an insurer’s denial of coverage for mental health treatments under the Employee Retirement Income Security Act because the California Insurance Code treats health insurance as a form of disability insurance and bars discretionary clauses, a federal judge in the state held Jan. 31 (Mahlon D., et al. v. Cigna Health and Life Insurance Co., No. 16-7230, N.D. Calif., 2018 U.S. Dist. LEXIS 16332)....