Ben. Plan, 370 F.3d 869, 875 (9th Cir.2004); Saffle v. Sierra Pac. Power Co. Bargaining Unit Long Term Disability Income Plan, 85 F.3d 455, 458 (9th Cir.1996). Graeber waived his argument that the district court erred by failing to expand the administrative record because he did not develop the argument in his opening brief. See Entertainment Research Group, Inc. v. Genesis Creative Group, Inc., 122 F.3d 1211, 1217 (9th Cir.1997) (stating that this court reviews only issues that are argued specifically and distinctly in a party’s opening brief). Even if the issue was not waived, however, the district court appropriately refused to expand the administrative record because VPA did not have a conflict of interest or commit flagrant procedural violations. See Abatie, 458 F.3d at 970 (<HOLDING>). Finally, the district court did not abuse its
holding that it is appropriate to remand to the plan administrator when the administrative record is incomplete holding that review of a partial and truncated record by the district court was error and case remanded for review on the entire administrative record holding that while a district court generally may review only the administrative record in determining whether a plan administrator abused its discretion the district court may expand the scope of the record as needed to assess a conflict of interest or flagrant procedural violations holding that the district court is limited to considering the administrative record in reviewing the denial of benefits under an erisa plan holding that in its review of the irs exercise of discretion the court is limited to a review of the administrative record