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Court Holds that Benefit Denial Letters Must Disclose Limitations Period for Judicial Review

The Third Circuit U.S. Court of Appeals, in Mirza v. Insurance Administrator of America, Inc., recently held that a notice of benefit denial under ERISA must include a statement of any time limits for filing a claim for judicial review in order for such limits to be enforceable under ERISA. The claimant exhausted the internal appeals process under the employer?ÇÖs group health plan and received a final benefit denial letter from the claims administrator. Although the letter included a statement of the claimant?ÇÖs right to bring a civil action under Section 502 of ERISA, the letter did not mention the plan?ÇÖs one-year limitations period for filing a lawsuit. The federal district court dismissed the lawsuit as being time-barred because notice of the limitations period was contained in the plan?ÇÖs summary plan description (?Ç£SPD?Ç¥). In reversing, the Third Circuit held that regardless of whether the claimant had notice of the plan?ÇÖs limitations period from the SPD, ERISA?ÇÖs claims regulations require a final benefit denial notice to disclose the plan?ÇÖs applicable time limits for bringing suit. Given the Sixth Circuit?ÇÖs similar decision in the recent case of Moyer v. Metropolitan Life Ins. Co., ERISA plan administrators and claims fiduciaries should ensure that any time limits for judicial review imposed by an ERISA plan are included in any final benefit denial notices.

A copy of Mirza v. Insurance Administrator of America, Inc. is available here.

The lawyers of our Employee Benefits and Executive Compensation Practice Group are readily able to assist companies on a nationwide basis with implementing sophisticated benefit plans and providing answers to their most challenging compensation issues. Additionally, our lawyers are well aware of the daily employee benefits challenges facing companies of all sizes and are capable of helping in-house lawyers and human resources personnel with the day-to-day advice and guidance necessary to properly administer employee benefits plans.

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