Will a Short Term Disability Claim Approval Mean My Longer Term Claim Will be Approved? A Case Study
Will long term disability insurance claims be approved if a short term disability claim and/or a Social Security claim has been previously approved for the same condition? It may seem logical to assume that the long term claim will be approved, especially if the underlying disabling condition is one that is chronic and degenerative; however, this is not always the case.
One such example is the case of Artz v. Hartford[1]. Here, Donald Artz worked as al electric distribution controller. As part of his job, he worked 12-hour days three days a week, alternating between the day shift and the night shift. He was diagnosed with multiple sclerosis (MS) in 1998 but was able to continue working until early 2020, when he became unable to work his schedule due to increasing fatigue (a well-known symptom of MS). He was granted short term disability (under a policy also administered by Hartford). He was also granted Social Security disability benefits in April 2020. Despite this, Hartford denied his claim for long term disability benefits.
This denial was based on several factors, including that Artz’s own providers had conflicting opinions on how much (or whether) Artz could work. Hartford hired independent physicians to perform paper-only file reviews, and these providers determined that Artz could work up to 8 hours a day, during a regular day shift. While Artz pointed out that he was required to work 12 hours a day for his employer (in fact, he had requested a reduction to 8-hour days and his employer had refused), Hartford determined that this was a job duty specific to his employer, not an “essential duty” in the general workplace. In this scenario, Artz’s Hartford policy specifically said that the definition of his occupation was how his job was defined in the “general workplace” not a specific job being performed for a specific employer or at a specific location.
In light of these facts, the Court, although sympathetic to Artz, upheld Hartford’s denial. They pointed to the fact that, first, Artz had not provided Hartford with his Social Security approval records, despite being invited to do so. Further, even if they had been provided, the Court explained that Hartford’s decision hinged on the interpretation of the terms in the “plan at issue” rather than what the Social Security Administration had used as a basis for their determination. In regards to the short term disability approval, the Court explained that administrators (such as Hartford) are able to seek and consider new information and change their mind. Here, new information included the opinions of the consulting physicians.
In summation, a short term disability policy or Social Security approval will not necessarily mean that a long term disability claim will be approved. Even after the approval of other benefits based on a disabling condition, it is important to have a strong ongoing claim – including supporting records of disability and proof of restrictions and limitations that prevent you from working at your occupation. If you are considering filing a long term disability insurance claim, please feel free to reach out to one of our attorneys directly.
Every claim is unique and the discussion above is only a limited summary of the court’s ruling in this case. If you are concerned that your insurer is not evaluating your claim under the proper standard, an experienced disability insurance attorney can help you assess the situation and determine what options, if any, are available.
[1] Artz v. Hartford Life & Accident Ins. Co., No. 23-2269, 2024 WL 1986000 (7th Cir. May 6, 2024).
