erisa-disability-appeal-building-your-administrative-record">MetLife ERISA Disability Appeal: Building Your Administrative Record

If your MetLife disability claim is governed by ERISA — as nearly all employer-sponsored disability plans are — your administrative appeal is not just a second chance to convince MetLife to pay. It is the foundation of your entire legal case. Every piece of evidence that might matter in court must be in the administrative record before MetLife issues its final appeal decision. Understanding this is the most important insight in disability law.

Why the Administrative Record Is Everything

Under ERISA, when a claimant files suit in federal court after an adverse appeal decision, the court generally reviews only the record that was before the plan administrator at the time of the final decision. Courts applying the abuse of discretion standard do not hold trials. They do not hear new testimony or consider new medical evidence that wasn't in the appeal record. They evaluate whether MetLife's decision was reasonable based on what it had before it.

This means:

• Everything goes into your appeal — medical records, physician letters, vocational opinions, personal statements, research articles, rebuttal arguments
• You cannot save evidence for litigation
• Your appeal letter is addressed both to MetLife's appeal reviewers and, ultimately, to a federal judge

Build your administrative record as if you are building a legal case, because you are.

Step 1: Request Your Complete Claim File

Within 30 days of receiving MetLife's denial letter, send a written request for your complete claim file. Under 29 C.F.R. § 2560.503-1(h)(2)(iii), MetLife must provide:

• All documents, records, and other information relevant to your claim
• The specific plan provisions relied upon in the denial
• Any internal guidelines, protocols, or criteria applied
• The identity of any medical or vocational experts consulted (and their credentials)

Review the file thoroughly. Look for:

• Opinions by MetLife's reviewing physicians: Are they based on a file review only, without examination? Do they selectively quote or mischaracterize your treating physician's records?
• Vocational analysis: What jobs were identified? What limitations were used as the input for the analysis?
• Surveillance summaries: What does MetLife claim the footage shows?
• Internal notes: Case handler communications may reveal how MetLife approached your claim

Step 2: Identify Every Flaw in MetLife's Reasoning

Your appeal must address every stated reason for denial. Create a point-by-point rebuttal:

• If MetLife said there is insufficient objective evidence of functional limitation, submit objective evidence — imaging, laboratory testing, neuropsychological evaluation, functional testing.
• If MetLife's reviewer characterized your condition incorrectly, have your treating physician write a specific letter identifying and correcting each mischaracterization.
• If the vocational analyst identified jobs you cannot perform given your actual limitations, obtain an independent vocational expert report that demonstrates this.
• If MetLife ignored your SSDI award, submit the award documentation and cite the legal obligation to address it.

Step 3: Develop New Evidence

The administrative appeal is your opportunity to supplement the record with evidence that was not in your initial claim file. This commonly includes:

Updated RFC from treating physician: Your doctor's detailed assessment of your current functional limitations — sitting, standing, walking, lifting, concentrating, sustaining pace — with the clinical basis for each limitation.

Independent Medical Examination: Unlike MetLife's IME, an IME you arrange with an independent physician who examines you and reviews your full record can provide a powerful rebuttal to MetLife's paper review.

Neuropsychological testing: For cognitive, psychological, or neurological claims, objective testing provides quantitative support for limitations that MetLife's reviewers cannot simply dismiss.

Independent vocational expert report: A vocational expert who applies your actual functional limitations — including non-exertional limitations — to the current labor market and demonstrates no competitive employment exists.

Medical literature: Peer-reviewed articles establishing the functional consequences of your diagnosis can support your claim and rebut MetLife reviewers who minimize your condition.

Step 4: Invoke the 2016 DOL Regulations

Under regulations finalized in 2016 (effective April 2018), MetLife must:

1. Provide you with any new evidence it generates during the appeal (new medical reviews, updated vocational analyses) before issuing a final decision
2. Give you a reasonable opportunity to respond to that evidence

If MetLife generates a new physician review during the appeal process and issues a final decision without first sharing that review with you, it has violated the DOL regulations. This procedural violation can support reversal or at minimum create grounds for a favorable court ruling on the standard of review.

Step 5: Address MetLife's Conflict of Interest

In MetLife v. Glenn (2008), the Supreme Court held that MetLife's structural conflict of interest — it both decides claims and pays benefits from its own assets — must be weighed by courts when reviewing its decisions. In your appeal letter, state explicitly that MetLife's conflict of interest is noted and that you expect a de novo-style review that gives full and fair consideration to your treating physician's opinions and your independent evidence.

If MetLife continues to rely on its own reviewers over your treating physicians despite the weight of evidence in your favor, the conflict of interest analysis becomes even more significant in subsequent litigation.

Step 6: Note Your Rights for Litigation

Close your appeal with a statement reserving all rights under ERISA and applicable law, including:

• The right to External Independent Review: Complete Guide" class="auto-link">external review under applicable state law or the plan
• The right to file suit under ERISA § 502(a) upon exhaustion of administrative remedies
• The right to seek attorney fees under ERISA § 502(g) if you prevail

Key cases to reference in your appeal letter:

• MetLife v. Glenn (2008): Conflict of interest standard
• Firestone Tire & Rubber Co. v. Bruch (1989): ERISA review standard; established that conflict of interest is relevant
• Black & Decker Disability Plan v. Nord (2003): MetLife must give adequate reasons for rejecting treating physician opinions

Filing Your MetLife ERISA Appeal

MetLife Disability P.O. Box 14590 Lexington, KY 40512

Send via certified mail, return receipt requested. Your deadline is 180 days from the denial letter in most ERISA plans — verify in your denial letter and plan documents.

When to Engage an ERISA Attorney

For any significant LTD denial, engaging an ERISA disability attorney — most work on contingency — before or during the appeal significantly improves outcomes. An experienced ERISA attorney knows how to structure the administrative record for maximum effect in potential litigation.

Fight Back With ClaimBack

ClaimBack guides you through the ERISA appeal process against MetLife — from claim file request to final submission of a complete, litigation-ready appeal record.

Start your MetLife ERISA appeal today

Related Reading

• How to Write an Insurance Appeal Letter
• Internal vs. External Insurance Appeal
• Common Reasons Insurance Claims Are Denied