Record supports denial of long-term disability benefits

Aetna did not abuse its discretion in denying an employee’s request for long-term disability benefits following a car accident. Although the employee initially received short-term benefits, subsequent examinations by both treating and independent medical professionals concluded she was capable of working in her sedentary job as a financial analyst.

Background

Plaintiff was formerly employed by Booz Allen Hamilton as an IP business operations lead. This sedentary job required her to provide financial analysis and work with a computer. While employed, she participated in a long-term disability plan which is insured by Aetna and governed by The Employee Retirement Income Security Act of 1974, or ERISA. Plaintiff now alleges that she is entitled to long-term disability benefits under the plan after suffering injuries in a car accident. Aetna has denied her claim.

Plaintiff and defendant filed motions for summary judgment.

Standard

An administrator’s denial of benefits is reviewed under an abuse-of-discretion standard when the ERISA plan confers discretionary authority upon the administrator. The policy in this case provides Aetna with discretionary authority to determine whether eligible employees are entitled to benefits and to construe the policy and other plan terms. Because the policy language grants Aetna full discretionary authority over both eligibility determinations and interpretation of applicable terms, Aetna’s denial of plaintiff’s claim is reviewed under an abuse-of-discretion standard.

Merits

The court finds that Aetna’s decision was supported by substantial evidence in the record and is reasonable in light of that evidence. The record reflects that both treating and independent medical professionals had concluded that plaintiff was capable of working in her usual occupation. Further, examination records and objective tests confirmed that plaintiff was not suffering from any condition that would limit her ability to work.

Defendants acknowledge, and the record reflects, that plaintiff experienced symptoms resulting from the February 2017 accident. Due to her headaches, neck and back pain, plaintiff received short-term disability benefits for the time-period she was unable to work. However, subsequent tests indicated that plaintiff’s symptoms were not serious enough to prevent her from working as of the start of the long-term-disability period.

Although they recommended that plaintiff take some time off after her accident, plaintiff’s treating physicians believed she could work as early as June 2017. They agreed she certainly was ready to work by August 2017. Given this evidence, Aetna’s decision that plaintiff did not meet the policy definition of disability was reasonable. Additionally, this decision is supported by the conclusions of several independent, Board-certified reviewers.

Defendant’s motion for summary judgment granted.

Thomas v. Aetna Life Insurance Company, Case No. 19-cv-611, Jan. 31, 2020. EDVA at Alexandria (Hilton). VLW 020-3-065. 11 pp.