Importance of Maintaining Treatment While Receiving Long-Term Disability Benefits

Employees in Chicago and the rest of Illinois with claims for long-term disability insurance benefits rarely are aware of a clause in the insurance policy that requires you be under appropriate care and treatment for your condition to receive disability benefits. This is not typically an issue when a claimant first makes a claim for long-term disability benefits, as they are trying to treat the condition and get better. But sometimes after somebody has been on claim and receiving benefits, they pause the treatment for a number of reasons. So what happens when you are on claim and pause treatment? A recent court decision showed an unfortunate result for the claimant.

In Rieger v. Reliance Standard Life Insurance Co., No. 23- 3714, 2024 WL 4664180 (D.N.J. Nov. 4, 2024), Rieger ceased working for Allergan, Inc. due to severe chronic migraines, complaining of more than 15 migraine days per month lasting more than 4 hours each. Reliance Standard Life Insurance Company approved the claim for long-term disability insurance benefits. But less than a year later, Reliance Standard terminated Rieger’s disability benefits, contending his condition improved. It highlighted that between October 2021 and February 2022, Rieger paused getting treatment, despite his medical records showing no change in his condition from the time he was approved for long-term disability benefits. After Rieger unsuccessfully appealed, he sued Reliance Standard under ERISA § 502(a).

The United States District Court for the District of New Jersey considered cross motions for summary judgment, affording deference to Reliance Standard under the arbitrary and capricious standard of review, and ruled in Reliance Standard’s favor. Though the court noted the medical records indicated no change to Rieger’s symptoms, it was persuaded that Rieger’s condition must have improved because he paused getting treatment for it. The Court thus concluded that Reliance Standard’s decision finding Rieger not disabled any longer was not arbitrary and capricious.

If you have a claim for long-term disability benefits, call an experienced ERISA long-term disability lawyer right away. Even if you are receiving benefits, a knowledgeable ERISA long-term disability lawyer can help you keep those benefits in pay status.