In most cases, denials of ERISA plan benefits by administrators who have been granted discretionary authority to interpret and apply the plan are reviewed under an abuse of discretion standard, and may only be reversed if the denial was arbitrary and capricious. Such deference, however, is not without limits, and there are circumstances in which
Benefit Claims
District Court Dismisses Class Action Seeking Wilderness Therapy Benefits
By Sydney Juliano & Jennifer Rigterink on
A federal district court rebuffed putative class claims alleging that Cigna Health and Life Insurance Co. and two of the plans it administered violated the Mental Health Parity and Addiction Equity Act of 2008 (“MHPAEA”) by denying coverage for wilderness therapy. S.F. v. CIGNA Health & Life Ins. Co., 2024 WL 1912359 (D. Utah…
Sixth Circuit Concludes Lack of Proper Delegation Means Benefits Department Did Not Have Discretionary Authority to Decide Claims
By Jennifer Rigterink & Sydney Juliano on
A recent Sixth Circuit decision emphasizes the importance of maintaining correct benefit plan delegations to avoid tussles over the correct standard of review for benefit claims. In this case, the Sixth Circuit concluded that no deference was owed to a claim decision made by a company’s benefits department because the plan document neither named the benefits department as the entity with discretionary authority to decide claims nor permitted the benefits committee to delegate its discretionary authority to the benefits department. The case is Laake v. Benefits Committee, Western & Southern Financial Group Co. Flexible Benefits Plan et al., 68 F.4th 984 (6th Cir. 2023).
Sixth Circuit Rules Retiree Healthcare Benefits Claim Is Not Arbitrable
By Russell Hirschhorn & Kyle Hansen on
The Sixth Circuit, in a split decision, held that a dispute between a union and an employer regarding retiree healthcare benefits was not arbitrable because the issue of retiree healthcare benefits was not encompassed within the collective bargaining agreement’s (CBA’s) grievance procedures.
The United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied-Industrial and Service Workers…