Difference Between Chronic Pain and Chronic Pain Syndrome in Long-Term Disability Claims

Employees in Chicago with claims for long-term disability insurance frequently suffer from chronic pain which can be caused by numerous different medical conditions, including spine disorders, various types of arthritis, etc. Some long-term disability plans place 24-month limitations on benefits due to a Chronic Pain Syndrome, or Fibromyalgia. But does having chronic pain mean you have Chronic Pain Syndrome? A recent case addressed this issue.

In Laake v. Benefits Committee, No. 21-4178, 2003 WL 3559602 (6^th Cir. May 19, 2023), the long-term disability plan contained a 24-month limitation for disabilities due to, among other things, Chronic Pain Syndrome. Laake suffered from atypical inflammatory arthritis, causing chronic pain. She ceased working due to this arthritis and claimed long-term disability benefits, which the plan administrator approved. But it terminated benefits after 24 months, invoking the plan’s 24-month limitation for Chronic Pain Syndrome. After unsuccessfully appealing the denial, Laake sued under ERISA § 502(a).

The United States Court of Appeals for the Sixth Circuit affirmed the district court ruling awarding Laake benefits. The court explained both denial letters cited the disabling symptoms as chronic pain, but never contended Laake had Chronic Pain Syndrome, though the plan administrator applied the Chronic Pain Syndrome limitation to deny further benefits. The court explained that the Chronic Pain Syndrome limitation appeared with a laundry list of other conditions for which benefits were limited, all appearing in the DSM-IV, suggesting it is a psychological condition. But none of the evidence showed Laake’s chronic pain was a result of any psychological condition, but instead the direct result of her atypical inflammatory arthritis. The court thus affirmed a ruling in Laake’s favor and upheld awarding her benefits.

If you have a claim for long-term disability benefits, contact an experienced ERISA long-term disability attorney today.