The Sixth Circuit Court of Appeals recently decided Autran v. Procter & Gamble Health & Long-Term Disability Benefit Plan, No. 20-6432, __F.4th__, 2022 WL 557825 (6th Cir. Feb. 24, 2022), a case involving a denied claim for total-disability benefits. Plaintiff-Appellant Dr. Jean-Philippe Autran worked successfully as a research scientist with Procter & Gamble until an aortic aneurysm caused decreased mental acuity and a seizure disorder which led to his eventual disability from work. He applied for total-disability benefits under the Defendant Procter & Gamble Health and Long-Term Disability Plan, which the Procter & Gamble Disability Committee initially approved in 2012. The Plan defines “Total Disability” to require a participant to have a mental or physical condition that is considered totally disabling by the medical profession. It also requires serious limitations of “such severity as to require care in a hospital or restriction to the immediate confines of the home.” The claimant must also provide objective evidence of the disability.
After a few years, the Committee revisited its decision to award Autran total-disability benefits and switched him to partial-disability benefits. After Autran was approved for Social Security disability benefits, he appealed the partial-disability classification, and the Trustees changed their decision and again found him totally disabled. Shortly thereafter, the Committee terminated Autran’s claim after he failed to attend two independent examinations scheduled for him. After he appealed, the Committee had Autran evaluated, including a lengthy neuropsychological evaluation and independent medical examination. Based on the outcome of the exams, the Committee found that Autran did not meet the requirement for total-disability but that he met the criteria for partial-disability benefits and paid him the remaining 19 weeks of partial-disability benefits. Autran filed suit against the Committee under ERISA § 502(a)(1)(B) seeking reinstatement of his total-disability benefits claim. The district court entered judgment in favor of the Plan and Autran appealed.
Regarding the standard of review of the Plan’s decision, the parties agreed that the Plan gives discretionary authority to the Committee to decide claims for benefits. As such, the court reviews the Committee’s decision for abuse of discretion. A plan administrator’s decision will be upheld if it is substantively and procedurally reasonable. The court found that the Committee’s decision satisfies the deferential substantive and procedural standards. Substantively, the record contained more than adequate evidence for the Committee to conclude that Autran did not meet the total-disability definition. The neuropsychological evaluation consisting of 17 tests showed substantial malingering on Autran’s part but that he still performed within normal limits. The independent medical examination involved a three-hour interview during which the doctor found no evidence of significant cognitive deficits. Autran could undertake most activities of daily living and could still work in some capacity, including translating a book and writing a screenplay. A supplemental file review also concluded that Autran could work part time.
Procedurally, the court found that the Committee engaged in reasoned decision making. It considered all the records and relied primarily on “high-quality evaluations.” The Committee also confronted the contrary SSA award, which was based on a different standard of disability. The court considered and rejected Autran’s six procedural reasons for why the Committee erred. First, the Committee did not arbitrarily change course where its decision relied on new information that the Trustees did not have when it approved his total-disability claim two years earlier. The Committee could rationally conclude that Autran’s ability to work reinforced its conclusion that he did not meet the Plan’s stringent total-disability definition. Second, the Committee did not arbitrarily fail to consider the whole record. Objective evidence did not support his treating doctor’s opinion. His doctor’s examinations generally revealed normal findings. Though his doctor noted Autran’s reports of difficulties, his doctor did not observe the symptoms himself. Third, the Committee did not wrongly depart from the Social Security Administration’s decision. The Committee considered the decision and gave rational reasons for rejecting it. SSA adhered to a treating physician rule when it approved Autran’s claim, whereas the Committee did not need to give more weight to Autran’s treating physicians. And, the SSA did not have the same evidence before it when it found Autran disabled. Fourth, the Committee did not need to identify a job that Autran could perform. An administrator does not need to identify a job that a claimant could perform if the objective medical evidence shows that the claimant does not have a health condition that prevents work. Fifth, the Committee did not wrongly ignore the side effects of Autran’s medications. There is no objective evidence reinforcing his claim that his medications were causing side effects. Lastly, there is no evidence showing that the Committee’s conflict of interest affected its decision. The Committee receives training to ensure it does not take the company’s financial interests into account when resolving claims and the administrators ensure that independent doctors who evaluate claims receive the same pay no matter what their findings. The Committee also used a new doctor with each new evaluation they did of his claim. The court affirmed the decision of the district court in favor of the Plan.
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