The First Circuit recently held, in line with other circuits, that the statute of limitations for a claim of underpayment of long-term disability benefits does not accrue with each monthly benefit payment made, but instead accrues at the time the underpayment is made known to the participant when he receives his first “miscalculated” benefit award. See Riley v. Metro. Life Ins. Co., 2014 WL 814742 (1st Cir. Mar. 4, 2014). In so ruling, the Court rejected Plaintiff Robert Riley’s argument that the long-term disability plan should be treated as “an installment contract” allowing for a separate causes of action each time an alleged underpayment was made. The Court reasoned that allowing a beneficiary to challenge alleged underpayments each time a payment was made would not serve ERISA’s policy of “predictability,” among other reasons, because it would undermine the plan’s reliance on actuarially calculated benefit payments, which is essential to the administration of the plan.
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