Scarinci Hollenbeck, LLC, LLCScarinci Hollenbeck, LLC, LLC

Firm Insights

Modified Statutes in Issuing a ERISA Benefit Denial Letter

Author: Scarinci Hollenbeck, LLC

Date: September 14, 2015

Key Contacts

Back

The Third Circuit Court of Appeals recently held that any benefit denial letter sent by ERISA plan administrators must expressly state contractual time limits for bringing suit. The ruling in Mirza v. Insurance Administrator of America is in line with prior decisions by the First and Sixth Circuits.

The Third Circuit Court of Appeals recently held that any benefit denial letter sent by ERISA plan administrators must expressly state contractual time limits for bringing suit. The ruling in Mirza v. Insurance Administrator of America is in line with prior decisions by the First and Sixth Circuits.

ERISA benefit denial letter

The Legal Background

The Employee Retirement Income Security Act of 1974 (ERISA) provides that a participant or beneficiary may bring a civil action “to recover benefits due to him under the terms of his plan.” upon their receipt of a denial letter. However, since ERISA does not set forth a specific statute of limitations, courts normally will apply the statute of limitations from the most analogous state-law claim, e.g. breach of contract. Of course, in normal contract circumstances, the parties are permitted to contractually agree to a shorter limitations period so long as it is not unreasonable.

The Department of Labor regulations implementing ERISA apply as they define fiduciary responsibility in the context of claim resolution such as when a plan administrator denies a request for benefits. In such case, the denial must set forth a “description of the plan’s review procedures and the time limits applicable to such procedures, including a statement of the claimant’s right to bring a civil action.” 29 C.F.R. § 2560.503–1(g)(1)(iv).

The Facts of the Case

The ERISA plan at issue stated that “no legal action may be commenced or maintained to recover benefits under the Plan more than 12 months after the final review/appeal decision by the Plan Administrator has been rendered.” In the world of health insurance, such shortened periods to resolve claims have become a common way of limiting benefits. Dr. Neville Mirza received his final denial letter on August 12, 2010, but did not file suit until March 8, 2012. The denial letter advised him of his right to judicial review, but it did not mention the short time limit for doing so. The district court dismissed the suit, finding that Mirza’s claim was time-barred.

The Court’s Decision

The Third Circuit held that plan administrators must affirmatively inform claimants of plan-imposed deadlines for judicial review in their benefit denial letter. Accordingly, it concluded that the defendants’ violated their fiduciary obligations by failing to include the plan-imposed one-year time limit in the letter denying Mirza’s request for benefits.

The Third Circuit noted that the two other federal courts of appeal considering the issue reached the same conclusion. In light of its decision, the court further held that the appropriate remedy was to set aside the plan’s contractual time limit and apply New Jersey’s six-year deadline for breach of contract.

No Aspect of the advertisement has been approved by the Supreme Court. Results may vary depending on your particular facts and legal circumstances.

Scarinci Hollenbeck, LLC, LLC

Related Posts

See all
How Intellectual Property Valuation Will Impact Business Transactions post image

How Intellectual Property Valuation Will Impact Business Transactions

Intellectual property valuation determines the monetary value of a business’s IP assets, and it drives outcomes in licensing deals, joint ventures, mergers and acquisitions, financing, and ownership disputes. The most valuable assets of a business are often the things that cannot be seen or touched: a proprietary process, a copyrighted work, brand recognition, or the […]

Author: Jay McDaniel

Link to post with title - "How Intellectual Property Valuation Will Impact Business Transactions"
Data Center, Dark Fiber, and Lit Services Agreements in New Jersey: Key Terms and Legal Pitfalls post image

Data Center, Dark Fiber, and Lit Services Agreements in New Jersey: Key Terms and Legal Pitfalls

For New Jersey data center owners and operators, a service agreement may look routine when it is signed. The network is functioning, the vendor is meeting its installation schedule, and the parties have agreed on pricing and performance specifications. The provisions that seem most important at that stage are often the technical ones. That changes […]

Author: George McGowan

Link to post with title - "Data Center, Dark Fiber, and Lit Services Agreements in New Jersey: Key Terms and Legal Pitfalls"
Fort Monmouth Redevelopment and the Transformation of Monmouth County Real Estate post image

Fort Monmouth Redevelopment and the Transformation of Monmouth County Real Estate

The Fort Monmouth redevelopment has entered its execution phase, and it is repositioning the broader Monmouth County real estate market. When Netflix and the Fort Monmouth Economic Revitalization Authority closed on the 292-acre Mega Parcel in December 2025, the transaction did more than hand over a deed. It marked the moment Fort Monmouth stopped being […]

Author: Donald M. Pepe

Link to post with title - "Fort Monmouth Redevelopment and the Transformation of Monmouth County Real Estate"
Local Zoning and Land Use Rules Every New Jersey Rental Property Owner Should Understand post image

Local Zoning and Land Use Rules Every New Jersey Rental Property Owner Should Understand

Owning a residential rental property in New Jersey involves more than finding tenants and collecting rent. Property owners must comply with a combination of state laws, municipal ordinances, building and housing codes, and zoning and land use regulations. These requirements can affect everything from the number of dwelling units permitted at a property to whether […]

Author: Donald M. Pepe

Link to post with title - "Local Zoning and Land Use Rules Every New Jersey Rental Property Owner Should Understand"
Real Estate Litigation Explained: Top 5 Disputes and How to Avoid Them post image

Real Estate Litigation Explained: Top 5 Disputes and How to Avoid Them

The five most common real estate disputes are breach of contract claims, landlord-tenant conflicts, zoning and land use disagreements, construction claims, and boundary disputes. Understanding why each arises, and taking preventive steps early, can help property owners, tenants, developers, and investors avoid costly litigation. Key Takeaways: Real estate transactions are complex endeavors involving numerous parties […]

Author: Paul Grossman

Link to post with title - "Real Estate Litigation Explained: Top 5 Disputes and How to Avoid Them"
When a Child Turns 18: The Gap in Your Family’s Estate Plan post image

When a Child Turns 18: The Gap in Your Family’s Estate Plan

Once a child turns 18, parents lose the automatic legal authority to make medical and financial decisions on their behalf, even if the child still lives at home or remains on the family’s insurance. Three documents close that gap: a durable power of attorney, a health care proxy or directive, and a HIPAA authorization. For […]

Author: George McGowan

Link to post with title - "When a Child Turns 18: The Gap in Your Family’s Estate Plan"

No Aspect of the advertisement has been approved by the Supreme Court. Results may vary depending on your particular facts and legal circumstances.

Sign up to get the latest from our attorneys!

Explore What Matters Most to You.

Consider subscribing to our Firm Insights mailing list by clicking the button below so you can keep up to date with the firm`s latest articles covering various legal topics.

Stay informed and inspired with the latest updates, insights, and events from Scarinci Hollenbeck. Our resource library provides valuable content across a range of categories to keep you connected and ahead of the curve.

Let`s get in touch!

* The use of the Internet or this form for communication with the firm or any individual member of the firm does not establish an attorney-client relationship. Confidential or time-sensitive information should not be sent through this form. By providing a telephone number and submitting this form you are consenting to be contacted by SMS text message. Message & data rates may apply. Message frequency may vary. You can reply STOP to opt-out of further messaging.
“If you would like to submit a file, please email it directly to info@sh-law.com.

Sign up to get the latest from the Scarinci Hollenbeck, LLC attorneys!