When Disability Isn’t Disputed, Why Can LTD Benefits Still End?
For someone receiving long-term disability benefits, a request for financial records may seem disconnected from the central question: Can I work? But some disability plans make financial information part of the eligibility determination. Ignoring that distinction—or leaving a dispute about the requested records unresolved—can put benefits at risk.
The Eleventh Circuit’s unpublished decision in Pankey v. Aetna Life Insurance Co., No. 25-11338, 2026 U.S. App. LEXIS 27431 (Sept. 3, 2026), illustrates that problem. As an unpublished opinion, it is not binding precedent. The court affirmed a judgment for Aetna even though the claimant’s physical disability was undisputed.
The dispute centered on proof, not hearing loss
Pankey had severe hearing loss and first received benefits in 2011. His claim had moved beyond the plan’s initial 24-month period into its “any reasonable occupation” phase.
Aetna issued the group policy, while Hartford administered claims. The court used “Aetna” to refer to conduct by either company; Hartford was not a party to the appeal.
The administrator repeatedly sought updated financial records and a claimant questionnaire. Pankey raised concerns about confidentiality and maintained that certain income came from passive investments. Older materials he submitted did not resolve the administrator’s requests for current information.
Benefits ended in July 2022, and the administrator upheld that decision on administrative appeal in March 2023.
Why the plan language mattered
The court’s reasoning depended on this plan’s financial eligibility component, proof requirements, and grant of discretion to the administrator. Applying arbitrary-and-capricious review, the court concluded that the requests for updated information were reasonable under those provisions.
The opinion describes seven requests over nearly two years. It also notes an accommodation allowing K-1 forms instead of personal tax returns.
This unpublished decision does not establish an unrestricted right for every insurer to demand every financial record. Its significance lies in the connection between the particular plan terms, the information requested, and the documented claims process. Pankey’s undisputed physical limitations did not eliminate the separate proof obligations the court found applicable.
What claimants can take from this decision
Connect each request to the plan. Ask which eligibility provision, income definition, or proof requirement makes the requested information relevant. Understanding that connection can help identify what evidence addresses the administrator’s concern.
Respond in writing and document the exchange. If a request is unclear, burdensome, or raises confidentiality concerns, explain the issue and ask what alternative documentation the administrator will accept. Keep copies of submissions, questions, responses, and delivery confirmations.
Explain disputed income with supporting evidence. If money comes from passive investments rather than work, identify that distinction clearly and provide documentation that supports it. Do not assume an administrator will draw the same conclusion from older records.
Use the administrative appeal to address the stated reasons. An appeal should confront the administrator’s explanation for ending benefits, including asserted gaps in financial proof. Medical evidence remains important, but it may not answer every issue identified in the denial.
Feden Law Group handles disability appeals nationwide. If benefits have ended after a dispute over requested records, schedule an initial consultation to discuss the plan language, correspondence, and appeal record.
This article provides general information, not legal advice. Reading it does not create an attorney-client relationship.