We all know that ERISA disability claimants must exhaust administrative remedies before bringing a suit. Exhausting administrative remedies typically includes seeking an internal appeal.

But…what is required in the claimant’s letter to the Plan to constitute an “appeal”?

Here’s a new case on the issue: Reindl v. Hartford Life and Accident Insurance Co.,[PDF] __ F.Supp. 2d __ (E. D. Missouri March 21, 2012) (Claimant’s letter to Plan with the following language did not constitute an appeal: “We will be reviewing the records and obtaining additional medical information for my client’s appeal of the decision to terminate her Long Term Disability.”)

Please see full article below for more information.