Courts strive to enforce the terms of benefit plans in order to ensure their efficient operation.However, there are times when the provisions of benefit plans make no sense under the circumstances; and Waskiewicz v. Unicare Life and Health Ins. Co., 2015 WL 5751585 (6th Cir. October 2, 2015) illustrates one of those circumstances. 

In Waskiewicz, a product design engineer for Fort Motor Company was unable to submit a timely claim for disability benefits due to her severe mental illness.  On account of the late submission, Ford’s claim administrator denied the claim, and a federal court upheld that denial.  However, a federal appellate court disagreed and ordered the plan to consider the claim.

The court found: “While [the plaintiff] did not comply with the notification deadlines outlined in Section 4.02 of the Plan, that failure is not surprising given that she was suffering from severe mental illness and was unable to comply due to the very disability for which she sought coverage.”The court thus deemed the denial “inconsistent with the spirit of employer-provided health care benefits generally and with this Plan specifically.” 

Although the court’s opinion was unsupported by citations to precedent, it was well-rooted in logic and common sense. It is encouraging to see a court give recognition to ERISA’s purpose and exercise its power to redress an obvious wrong.

Related Articles

How Do I Know if My Benefit Plan Is Self-Funded?

How Do I Know if My Benefit Plan Is Self-Funded?

When the term “self-funded” is used in relation to employer-sponsored benefit plans, the term usually refers to what are known as “welfare” benefits. ERISA does not use the term “welfare” to mean public assistance. Instead, the term relates to benefits provided for the employee’s welfare; and is defined by the statute to mean […]

What Is ERISA?

What Is ERISA?

ERISA, an acronym for the Employee Retirement Income Security Act of 1974,1 is one of the most important federal laws ever passed by Congress, but hardly anyone knows what it is or what it does. […]

ERISA Ruling Shows Lax Enrollment Practices Can Be Costly

ERISA Ruling Shows Lax Enrollment Practices Can Be Costly

A life insurance decision issued by the U.S. Court of Appeals for the Eighth Circuit may be summed up by quoting a single sentence from the opinion: “Misleading an [Employee Retirement Income Security Act]-plan participant has consequences.” Skelton v. Reliance Standard Life Insurance Co.[1] teaches how lax benefit enrollment practices can be costly. […]

How Can I Tell If My Benefit Plan Is Governed by ERISA?

How Can I Tell If My Benefit Plan Is Governed by ERISA?

ERISA is an acronym for the federal Employee Retirement Income Security Act of 1974. Most people have never heard of ERISA, but its comprehensiveness impacts the vast majority of American workers and their dependents. The original intent behind ERISA’s enactment was to remedy pension plan abuses; however, just prior to Congress’ passage of the ERISA law, the scope […]