Tenth Circuit Affirms Short Term Disability Benefits
AT&T Umbrella Benefit Plan No. 1 (the “Plan”) suffered a reversal of the Plan administrator’s denial of short-term disability benefits to an employee and awarded him benefits for twenty-six weeks—the maximum period allowed under the Plan. The employee, who suffered from multiple medical conditions, applied for short-term disability benefits after working as an IT consultant. The Plan required him to provide a medical, psychiatric or psychological opinion, based on a test performed according to generally accepted principles of the health care profession, to support the disability claim. It did not require objective evidence to substantiate the disability. After providing the requisite documents, the employer’s physician declared his disability was not supported and denied benefits. The Tenth Circuit affirmed the district court’s findings that the Plan’s denial was arbitrary and capricious. It viewed the Plan’s determination the employee could perform the cognitive requirements entailed in his job was not based on sufficient evidence for a reasonable person to accept a denial of his short term disability benefits.