Does ERISA Cover My Church-Affiliated Disability Insurance Plan?
If you work for a religiously affiliated organization, different rules may apply to your disability insurance claim. ERISA does not cover many church plans due to an exception in the law, so it’s important to understand whether your plan qualifies as a church plan before you proceed with a claim.
To learn more about church plans and your long-term disability claim, keep reading.
What Is a Church-Affiliated Disability or Benefit Plan?
Ever since the Employee Retirement Income Security Act (ERISA) was created in 1974, the law has exempted church-affiliated benefit plans from its requirements. However, the definition of what qualifies as a church plan has changed over the years.
In 2017, the Supreme Court issued its unanimous Advocate Health Care Network v. Stapleton decision, which changed the definition of a church-affiliated benefit plan for ERISA. The new definition includes pension, disability, and other defined benefit plans created or maintained by:
- Churches and other religious organizations
- Church-controlled or church-associated organizations whose principal purpose is the administration and funding of a plan for church employees (both clergy and laypeople)
Note that the law does not require that a church or religious organization created the plan — only that such an organization maintains or runs the plan.
Church-affiliated plans aren’t just for people who work directly for religious organizations. You may also have a church-affiliated disability plan if you work for a hospital, social services agency, school, charity, or other business that is connected to a religious denomination.
Identifying a church plan isn’t always straightforward. Your disability insurance lawyer will need to evaluate the plan’s operations in the context of tax, labor, and benefit plan laws.
What Happens if My Disability Plan Is Exempt From ERISA?
Being exempt from ERISA is not necessarily a bad thing. While federal law provides powerful protections for ERISA plan beneficiaries, those protections come with very strict procedures for claims and appeals. For example, in an ERISA appeal, you cannot demand a jury trial, and there are limits on when you can submit evidence supporting your claim.
If your disability insurance plan is exempt from ERISA, state law applies to your claims. That means you:
- Do not have to complete an in-house administrative appeal with the insurance company before filing a lawsuit.
- Can request a jury trial.
- Can demand additional statutory damages if the insurance company acted in bad faith.
- Can present new evidence throughout the litigation process.
Bring These 3 Pieces of Information to Your Meeting With a Disability Insurance Lawyer
If you think that you may be a beneficiary of a church plan, be prepared to answer a lot of questions at your initial meeting with a disability insurance lawyer. We don’t expect you to know all the answers, but the more information you can provide, the better.
You can help us get to work on your claim faster if you bring the following items:
1. Your Plan Documents
Disability insurance policies are contractual, so you are bound by the terms outlined in your plan document and summary plan description (SPD). Before you file a claim for disability insurance benefits, it’s always a good idea to get copies of these documents since they will help you understand your plan’s exact requirements and procedures.
2. Any Information You Have About Your Organization’s Board and Funding
Your attorney will want detailed information about your church-affiliated organization’s operations, funding, and board structure. This information will help us determine whether your organization has a church plan as defined by law.
If you don’t have information about your organization readily available, that’s okay — we can help you gather it. However, if you have easy access to information about your organization’s corporate structure and operations, please bring it with you.
3. Any Correspondence From the Insurance Company or Your Employer
If you have any letters or notices from your employer or your disability insurance plan, bring these documents with you to your initial consultation. They can help your lawyer understand the insurance company’s reasons for denying your claim as well as the timelines that apply to your appeal.
Looking for Personalized Advice From an Insurance Lawyer?
Bryant Legal Group: Standing Up for Employees of Church-Affiliated Organizations
Bryant Legal Group is one of Illinois’ premier disability insurance law firms. We have a long history of successfully handling disability claims for employees of church-affiliated hospitals, medical groups, and other organizations.
If you can no longer work due to injuries, illnesses, or chronic medical conditions, contact our office today. We’ll listen to your story and help you understand your options for compensation.
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