McGhee, a senior vice president with Bank of America, sought short-term disability benefits under an ERISA-regulated plan administered by Aetna. McGhee claimed that he was unable to perform the essential functions of his occupation due to severe anxiety, depression, and post-traumatic stress disorder.
Aetna denied the claim and informed McGhee that he had not provided sufficient clinical information to show that he was unable to perform the duties of his occupation. McGhee appealed and submitted additional medical information, and Aetna upheld the denial of his claim.
The district court reviewed Aetna's claim decision under an abuse of discretion standard. The court found that Aetna processed McGhee's initial claim fairly and clearly informed him of the type of medical evidence it needed in order to approve STD benefits.
With respect to McGhee's appeal, the court noted that Aetna considered all of the medical evidence submitted by McGhee, solicited a peer review, and communicated with McGhee's treating physicians.
The court concluded that Aetna's review was reasonable, principled, and deliberate. The court further found that Aetna's decision to deny STD benefits because McGhee had failed to provide objective medical evidence of disability was supported by substantial evidence. Accordingly, the court granted summary judgment for Aetna.
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