One of the most overlooked causes of a denied group life insurance claim is an employer’s failure to track an employee’s FMLA return to work date. When an employee goes out on FMLA leave, their eligibility for group life insurance often depends on whether they return to work within a specific timeframe. If the employer fails to document the return date, miscalculates it, or never updates the insurer, the insurer may deny the claim by arguing that coverage ended during leave.
Families are blindsided because the insured believed they were protected, continued paying premiums, and relied on the employer to handle all FMLA and benefits administration. Instead, the employer’s administrative error becomes the basis for a denial.
This guide explains how FMLA return to work tracking errors happen, how insurers use them to deny claims, and how beneficiaries can challenge these denials.
Why FMLA Return to Work Dates Matter
Under many group life insurance policies, coverage continues during FMLA leave only if:
• The employee returns to work within the approved leave period • Premiums are paid during leave • The employer properly reports the leave and return date • The employee remains eligible under the plan’s active work rules
If the employer fails to track or report the return date, the insurer may assume the employee never returned and treat the coverage as terminated.
How Employers Fail to Track Return Dates
FMLA administration is complex, and employers frequently make mistakes. Common failures include:
• Not recording the employee’s actual return date • Miscalculating the end of the FMLA period • Failing to notify the insurer that the employee returned • Treating the employee as inactive in HR systems even after return • Allowing payroll systems to mark the employee as on leave indefinitely • Not updating benefits eligibility after return • Failing to collect or remit premiums during leave
These errors often go unnoticed until a claim is filed.
How Insurers Use These Errors to Deny Claims
When a claim is submitted, insurers review HR records, payroll data, and leave documentation. If anything suggests the employee did not return from FMLA leave, insurers may argue:
• The employee never returned to active work • Coverage ended at the end of the FMLA period • Premiums were not paid during leave • The employee was no longer eligible for group coverage • The employer failed to reinstate coverage after return • The employee needed to reapply or complete evidence of insurability
Insurers rely heavily on employer records, even when those records are incomplete or inaccurate.
Why These Denials Are Often Improper
FMLA return to work errors are almost always employer mistakes, not employee failures. Under ERISA, employees cannot lose coverage because the employer mishandled leave administration.
Here are the most common reasons these denials collapse.
The employee actually returned to work
If the employee worked even one day after FMLA leave, coverage may have been reinstated automatically.
The employer failed to update HR and payroll systems
Administrative errors cannot be used to void coverage.
Premiums were paid or deducted
If premiums continued, the insurer cannot claim the policy lapsed.
The employer failed to notify the employee of any required steps
Employees cannot comply with requirements they were never told about.
The insurer relied on incomplete or incorrect records
Insurers must investigate inconsistencies rather than blindly accept employer errors.
How Beneficiaries Can Challenge These Denials
These denials are highly challengeable because they depend on employer documentation, which is often flawed.
Request the complete claim file
This reveals what the insurer relied on and whether the employer provided conflicting information.
Obtain FMLA records from the employer
Look for:
• Leave approval letters • Return to work certifications • Timesheets • Work schedules • Supervisor communications
These documents often prove the employee returned.
Review payroll records
If the employee was paid after the alleged return date, they were active.
Examine premium deductions
Premiums deducted after return undermine the denial.
Compare HR system entries to actual work activity
HR systems often contain outdated or incorrect leave codes.
When the Denial Becomes Bad Faith
A denial may cross into bad faith when the insurer:
• Ignores evidence of return to work • Relies solely on flawed HR records • Fails to investigate payroll or timesheets • Treats administrative errors as grounds to void coverage • Miscalculates FMLA timelines • Delays the claim while seeking unnecessary documents
These behaviors can support additional damages.
Why Families Should Not Give Up
FMLA return to work tracking errors are one of the most common and most challengeable reasons for a denied life insurance claim. Employers frequently mishandle leave administration, and insurers rely on those mistakes to avoid paying benefits. When the facts are examined, many of these denials collapse.
Families should not accept a denial based on FMLA return to work issues without a thorough review.