Missed ERISA deadline strips disability insurer of over $233,000

Cogdell filed a long-term disability claim in November 2022 under MITRE’s employee benefits plan, administered by Reliance Standard Life Insurance Company. Reliance denied the claim in January 2023, finding she did not meet the plan’s definition of “Totally Disabled.” After submitting additional medical records – with Reliance again standing by its denial – Cogdell filed a formal internal appeal in August 2023. 

Under the Employee Retirement Income Security Act, or ERISA, plan administrators have 45 days to respond to a disability appeal. An extension of up to 45 more days is available, but only if the administrator identifies a specific, unusual reason for needing more time and notifies the claimant in writing – within that initial 45-day window – of both that reason and the expected decision date. 

Reliance met neither requirement. Although its own nurse had reviewed Cogdell’s newly submitted documents and consulted another clinician within eight days of the appeal being filed, the file then sat completely idle for 27 days before it was even forwarded to the appeals department. When Reliance finally wrote to Cogdell in late September, it cited the need for an independent physician review – without explaining why that was an exceptional circumstance, and without providing a decision date. The 45-day deadline passed with no decision issued. 

Cogdell filed suit on October 3, two days after the deadline lapsed. Reliance upheld its denial 72 days after the appeal was filed – 25 days past the legal deadline. By then, the damage was done. 

The court found that by missing the deadline, Reliance had forfeited its right to have its decision treated with deference. Rather than asking whether Reliance had been reasonable, the court examined the claim entirely on its own terms. It found Cogdell was entitled to benefits and upheld an award of $210,769.49 in past-due benefits and $22,544.95 in prejudgment interest, plus post-judgment interest.