ERISA: When Can Plan Administrators Get Into Trouble By Deciding A Disability Claim Too Quickly?

ERISA plan administrators are constantly pressured by claimants to render decisions quickly.... This is especially true with short term disability claims.

You already know that ERISA regulations require that disability claim benefit decisions be made "within a reasonable time but not later than 45 days after receipt of the claim." 29 CFR § 2560.503-1. This period may be extended "for up to 30 days" twice, under certain circumstances.

So, what does "within a reasonable time but not later than 45 days" really mean? 

Can one get into trouble by deciding a claim too quickly?  Yes!  "Slowing down is sometimes the best way to speed up."

Here's the case of Speca v. Aetna Life Ins. Co., 2019 WL 3754210 (D. Nev. August 8, 2019)(Initial claim denial made within 14 days of claim submission: "Defendant should have—at a minimum—waited a few more days to gather medical records before denying Plaintiff's initial claim.")