Disability Denial Remanded to Anthem for Analysis of Claimant’s Job Duties
Author: Attorney Gregory Dell
Although this Virginia Federal ERISA long term disability case was not handled by our disability insurance lawyers, it is an example of how Anthem denies disability benefits by asserting claimants are not disabled from performing their job duties without ever determining or analyzing what those job duties are.
In the case of Wyant v. Anthem Life Insurance Company, Anthem denied long term disability benefits to Wyant deciding that she could perform her job duties without ever evaluating what those job duties entailed. After working for 17 years at Gala Industries as a documentation assistant, plaintiff applied for short term disability benefits and stopped working. She suffered from diabetes, depression, myalgia, neuropathy, macular edema and other medical problems. Her application for short term disability benefits was granted, but when she applied for long term disability benefits, her application was denied.
In analyzing whether or not the plaintiff was disabled from performing the material and substantial duties of her job as a documentation assistant, Anthem commissioned three specialists to review her extensive medical file: A neurologist, ophthalmologist and clinical psychologist. All opined she was not disabled and that there were “no significant restrictions or limitations that would preclude Wyant from working as a document assistant at Gala Industries.”
The problem was that not one of the reviewing doctors ever mentioned the job duties they had determined she could perform. Even so, based on this review of medical records, Anthem denied her administrative appeal and she filed this ERISA lawsuit.
Federal District Court’s Remand Order
Although Anthem argued to the court that it had taken a reasoned approach to the analysis of plaintiffs claim for long term disability benefits, the district court disagreed. Instead, the court agreed with the plaintiff that she had presented evidence of “multiple medical conditions, eleven years of documentation, and a long list of potent prescription medications supporting her disability claim…”.
The court found Anthem abused its discretion when it denied her benefits, finding she was not disabled from performing her duties as a documentation assistant. The court noted that none of the reviewing physicians made any attempt to connect her medical conditions with her employment.
In fact, her job description was totally missing from any analysis and from any of the reports of those who concluded that she could perform the duties without ever analyzing what those duties were. The court held, “This omission leaves the court unable to perform an informed and meaningful review, renders Anthem’s decision fundamentally flawed, and constitutes an abuse of discretion.” The court remanded to Anthem to conduct an analysis consistent with the court’s opinion.
If you are having problems with your claim for disability benefits or have any questions about the process, feel free to call our Disability Attorneys Dell & Schaefer for a consultation.
Read about more Anthem disability claim cases on this page.