St. Louis Record

Monday, September 16, 2019

Ascension Health granted summary judgment in dispute over long-term disability benefits

Federal Court

By Charmaine Little | Aug 9, 2019


U.S. District Court Chief Magistrate Judge Nannette A. Baker

ST. LOUIS – Ascension Health Inc. prevailed in its motion for summary judgment in a case filed by a medical assistant over allegations that she was wrongfully denied benefits. 

U.S Magistrate Judge Nannette A. Baker of the U.S. District Court for the Eastern District of Missouri’s Eastern Division sided with Ascension on June 24.

The ruling states plaintiff Ayana Powers-Taylor worked as a medical assistant at Pensacola, Florida’s Sacred Health Heart System. Ascension served as the sponsor and administrator for the self-funded long-term disability plan that eligible employees of Sacred Heart were entitled to. At the same time, Ascension tasked Sedgwick Claims Management Services Inc. as the claims administrator.

Powers-Taylor sued after she was denied benefits following an injury in 2015. She had a hysterectomy and suffered complications from the surgery. Because of that, she was put on short-term disability. 

Baker reiterated that Sedgwick was the decision maker to determine if an employee was eligible for benefits based on the plan. Baker evaluated whether Sedgwick abused its discretion in denying Powers-Taylor benefits and decided that it didn’t.

“The administrative record clearly shows that defendant and Sedgwick carefully considered all the medical evidence and opinions offered by plaintiff and did not act in in arbitrary manner when determining the outcome of plaintiff’s claim,” Baker wrote.

Sedgwick had already green-lighted Powers-Taylor’s claim for long-term disability benefits on April 5, 2015, and that was good until April 4, 2017. Powers-Taylor was then given the responsibility of proving that she should have benefits beyond that 24-month benchmark. She had to show that she couldn’t physically perform the work or service that she was qualified for previously.

Baker noted that upon evaluating if Powers-Taylor was eligible for more benefits, a third-party consultant, Genex Services, conducted a transferrable skills analysis (TSA), which included a functional capacity evaluation (FCE), her skills, characteristics and vocational training she received that would determine the jobs and responsibilities Powers-Taylor could fulfill with her background but also took her physical limitations into account.

The TSA determined that Powers-Taylor was capable of doing multiple jobs such as hospital admitting clerk, appointment clerk, telephone operator and receptionist, all with salaries similar to the position she previously held. Considering this evaluation, Sedgwick ruled that Powers-Taylor wasn’t disabled, and denied the benefits.

Powers-Taylor challenged the ruling and said Sedgwick misunderstood the results of the FCE.

"This argument would seem to suggest that defendant relied on only the FCE in denying the plaintiff’s claim, and the record clearly indicates that was not the case,” Baker wrote.

But even if the FCE was misinterpreted, Baker said there were other factors that were considered when Sedgwick denied her request for continued benefits. Amid Powers-Taylor’s many appeals, four other physician advisers also determined that she wasn’t disabled after April 4, 2017.

Baker dismissed the complaint with prejudice.

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