LTD Benefits Policy Reinstated Retroactively - SHRM
Takeaway: This case highlights the importance of ensuring that disability benefits decisions are rooted in a close reading and application of governing plan documents and claims procedures. Here, the court's decision was based primarily on Unum's failure to focus on the disabling symptoms the plaintiff actually experienced, contrary to the policy's "plain language." Instead, Unum concluded that because the plaintiff's symptoms were atypical, they were not real. In so doing, the court concluded that Unum inappropriately deviated from the policy.
The decision also cautions plan administrators to take a holistic rather than academic view of disability claims. The court credited conclusions drawn from in-person examinations over those from paper-only reviews because the claimant's actual providers were "better position[ed] to evaluate" symptoms than "reviewers who never evaluated her in person." Because the uncontroverted evidence demonstrated that the plaintiff struggled with written and verbal communication and the use of computer screens, the court found she could not perform a job requiring those things.
The U.S. District Court for the District of Minnesota ordered the administrator of a long-term disability (LTD) benefits policy to reinstate retroactively a former employee's benefits and pay her attorney fees, thereby rejecting a decision terminating benefits three years earlier.
The court held that, when the policy required the existence of a "disability" to be...
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