ERISA appeal deadlines are one of the most unforgiving aspects of group life insurance claims.
Miss one deadline and the case may be over before it ever starts. No jury. No discovery. No second chances.
Insurers know this. They design denial letters and appeal processes to exploit it.
The most dangerous misconception
Many beneficiaries believe an appeal is optional.
It is not.
In most ERISA governed life insurance plans, you must exhaust administrative appeals before filing a lawsuit. If you do not, the court can dismiss the case outright, even if the denial was wrong.
That dismissal is permanent.
Where the deadline usually comes from
Most ERISA group life policies allow between 60 and 180 days to file an appeal. The exact deadline is usually buried in one of three places:
The denial letter
The summary plan description
The master policy
Insurers often cite the shortest deadline available.
Beneficiaries often assume the clock starts later than it does.
When the clock actually starts
The appeal clock almost always begins on the date of the denial letter, not the date you received it.
Mail delays do not usually matter.
Email delivery does not pause deadlines.
Waiting for documents does not extend the clock.
Insurers rarely warn beneficiaries about this.
The document delay trap
One of the most common ERISA traps looks harmless at first.
The beneficiary requests:
The policy
The claim file
Medical records
Underwriting materials
The insurer responds slowly or not at all.
Meanwhile, the appeal deadline keeps running.
By the time documents arrive, there may not be enough time left to submit a meaningful appeal.
Insurers then argue that the appeal was incomplete or waived.
Extensions are not guaranteed
Some insurers offer extensions. Some do not.
Even when extensions are granted, they are often informal and poorly documented. Relying on a phone call or vague email is risky.
Unless an extension is clearly confirmed in writing, beneficiaries should assume the original deadline controls.
Why “placeholder” appeals are dangerous
Submitting a short appeal just to meet the deadline feels safe.
It is not.
Under ERISA, the administrative record usually closes at the end of the appeal process. Courts often prohibit new evidence later.
A rushed appeal that fails to submit key records, arguments, or rebuttals can permanently lock in the insurer’s version of events.
This is one of the most common ways strong cases are lost.
Multiple denial letters create confusion on purpose
Insurers sometimes issue:
An initial denial
A clarification letter
A partial approval
A second denial
A final determination
Beneficiaries often assume the deadline resets.
It usually does not.
Unless the insurer explicitly states that a new appeal period has begun, courts often treat the first denial as controlling.
Silence does not stop the deadline
Insurer silence after a denial does not toll the appeal period.
No response to emails
No returned phone calls
No status updates
None of this pauses the clock.
Silence is often strategic.
Employer involvement adds another layer of risk
In group life claims, employers often act as intermediaries.
HR may say:
The insurer is still reviewing
The appeal can wait
Documents are being gathered
Coverage issues are being resolved internally
None of these statements change ERISA deadlines unless confirmed by the insurer in writing.
Relying on employer assurances is a frequent and costly mistake.
Why insurers prefer deadline based wins
Deadline defenses are powerful.
They allow insurers to:
Avoid discussing the merits
Avoid discovery
Avoid explaining their reasoning
Avoid defending underwriting decisions
Courts enforce ERISA deadlines strictly, even when the outcome feels harsh.
What beneficiaries should do immediately after a denial
Time matters more than anything else.
The first steps should include:
Identifying the exact appeal deadline
Requesting the complete claim file immediately
Reviewing the policy and plan documents
Preserving proof of communications
Planning an appeal that fully develops the record
Waiting almost always favors the insurer.
How deadline traps are defeated
Deadline traps are avoided, not fixed later.
Successful cases treat the appeal as the most important phase of the entire claim. That is where evidence is submitted, narratives are framed, and insurer conduct is challenged.
Once that window closes, options shrink fast.