When an LTD Carrier Changes Its Vocational Rationale on Appeal

Vocational evidence can determine whether a long-term disability claimant meets a plan’s definition of disability. When an insurance carrier changes its description of a claimant’s occupation during an administrative appeal, that change may affect the analysis. A recent federal decision involving Sun Life shows why a carrier must explain its reasoning when it relies on a different vocational assessment.

In Schuyler v. Sun Life Assurance Company of Canada, the claimant sought benefits under an ERISA long-term disability plan for Benco Dental employees. Sun Life denied the claimant’s 2019 claim and 2020 administrative appeal under the plan’s Regular Occupation standard. It never reached the Any Occupation standard.

The vocational evidence changed significantly between the initial claim decision and the appeal. Sun Life’s first vocational expert, Timothy Andenmatten, stated that the claimant’s Territory Sales Representative occupation required six hours of standing or walking during an eight-hour workday. During the appeal, another Sun Life vocational expert, Julie Finnegan, described the same occupation as requiring only occasional standing or walking, or roughly 2.5 hours per day.

That difference mattered because Sun Life’s medical consultant found that the claimant could stand or walk for no more than four total hours and no more than 30 minutes at a time. The first vocational description called for six hours of standing or walking, while the appeal-stage description called for roughly 2.5 hours.

The court held that Sun Life’s appeal denial did not explain why it credited Finnegan’s assessment over Andenmatten’s. That omission violated 29 C.F.R. § 2560.503-1(j)(6)(i)(B), and the court found that the violation was not harmless.

The practical lesson is that an ERISA administrative appeal should compare the vocational evidence across each stage of the claim. If the carrier changes the physical demands assigned to an occupation, the claimant can identify the change, explain why it affects the disability analysis, and ask the carrier to address the competing evidence directly. An unexplained reliance on a newer opinion may leave a change in the carrier’s rationale unaddressed.

The court applied de novo review, but it did not award benefits. It denied both parties’ cross-motions because factual disputes remained. The court remanded the claim to Sun Life for renewed consideration of the full record, including new evidence and a favorable 2022 Social Security Administration disability determination, and stayed the case. It awarded no benefits, fees, costs, or interest.

Schuyler also shows why vocational evidence deserves the same careful review as medical evidence. A carrier’s description of an occupation can shape how it evaluates a claimant’s restrictions. The Social Security determination was one part of the full record Sun Life was directed to reconsider; the court did not treat it as establishing entitlement to ERISA benefits.

This article provides general information and is not legal advice. If you have questions about an ERISA long-term disability claim or administrative appeal, you may schedule a consultation with Feden Law Group: https://calendly.com/nfeden-fedenlawgroup/initial-consultation-with-attorney.

Case: Schuyler v. Sun Life Assurance Company of Canada, No. 20-CV-10905 (RA), 2026 U.S. Dist. LEXIS 213074, 2026 WL 2823712 (S.D.N.Y. Sept. 18, 2026) (Abrams, J.).

Public case note: https://www.yourerisawatch.com/2026/09/second-circuit-holds-providers-have-no-private-right-of-action-under-no-surprises-act/