ERISA Group Life Claim Deadlines and Appeals (2026)

ERISA group life insurance claims usually must be decided within 90 days after a complete claim is filed. If the plan properly sends a written extension notice before that deadline, it can take one extra 90-day extension, and appeals usually follow a 60-day appeal window with a 60-day decision deadline.

Those clocks come from 29 CFR 2560.503-1, the federal claims procedure rule that applies to many employer group life plans. This guide explains the timing, what to request from HR or the insurer, how conversion and portability can affect coverage, and what to do if a claim is denied. It is informational, not legal advice.

What counts as an ERISA group life claim

A group life insurance claim under an employer welfare plan is usually handled under ERISA's general benefit claim rules. These are the rules for a claim for benefits under a welfare plan that is not a group health plan or a disability claim.

For group life insurance, the plan administrator must issue an initial claim decision within 90 days. The plan can take one 90-day extension for special circumstances, but only if it sends a proper written notice on time. See 29 CFR 2560.503-1(f)(1) and (g).

For appeals, the plan must give you at least 60 days to appeal. It must decide the appeal within 60 days, with one 60-day extension allowed for special circumstances if the extension is noticed on time. See 29 CFR 2560.503-1(h)(2)(i) and (i)(1)(i).

The main sources are the regulation itself and U.S. Department of Labor Employee Benefits Security Administration guidance: 29 CFR 2560.503-1 full text and DOL EBSA claims procedure guidance.

ERISA group life claim and appeal timeline

The table below assumes a typical insured group life plan. It does not cover disability claims or group health claims. In the table, "plan" means the ERISA plan, which is often insured and administered day to day by the carrier. These are outside deadlines. A plan can decide earlier.

Day	Trigger or event	Plan deadline	Your action	Authority
0	You submit a complete claim package, including proof of death plus required employer or carrier forms.	No deadline yet.	File according to the SPD and claim form instructions. Keep proof that the claim was received.	29 CFR 2560.503-1(f)(1)
1 to 90	Initial claim is under review.	Decision due as soon as reasonably possible, but no later than Day 90.	Answer requests promptly and track the calendar.	29 CFR 2560.503-1(f)(1)
By Day 90	If special circumstances require more time, the plan must send a written extension notice before Day 90 stating the reasons and a decision date.	One extension only, for up to 90 more days, for a total of no more than 180 days.	If you receive an extension letter, calendar the new stated decision date.	29 CFR 2560.503-1(f)(1)
By Day 180	Final date for the initial decision if there was a proper extension.	An adverse benefit determination, or ABD, triggers appeal rights.	Save the ABD notice. It must include reasons, plan provisions, and review rights.	29 CFR 2560.503-1(g)
ABD plus 0	Appeal window opens.	No plan deadline yet.	Calendar your appeal deadline. You have at least 60 days to appeal.	29 CFR 2560.503-1(h)(2)(i)
ABD plus 60 days or less	Last day under the federal minimum appeal window. Check your SPD because some plans give more time.	No plan deadline yet.	File the appeal in writing. Request the claim file and relevant documents, free of charge.	29 CFR 2560.503-1(h)(2)(iii)
Appeal plus 60 days or less	Plan must decide the appeal within 60 days.	Written decision due.	If special circumstances exist, the plan may extend once, for up to 60 more days, with a timely extension notice.	29 CFR 2560.503-1(i)(1)(i)
Missed deadline by plan	The plan fails to follow the regulation's timelines or procedures.	No plan deadline.	You are generally deemed to have exhausted internal remedies and may proceed to court.	29 CFR 2560.503-1(l); DOL FAQ Q-F2

One timing detail can confuse families. The regulation expressly pauses certain timelines when additional information is requested for group health pre-service or post-service claims and disability claims. That tolling language does not apply to the general 90-day life claim rule in 29 CFR 2560.503-1(f)(1). See 29 CFR 2560.503-1(f)(4).

Start with the SPD and claim instructions

The Summary Plan Description, usually called the SPD, is the document that tells you how the plan is supposed to work. If you are handling the estate settlement after a death, ask HR or the plan administrator for the SPD, the certificate, and any claim forms as early as you can.

Under 29 CFR 2520.102-3(s), the SPD must include the plan's claims and appeals procedures, applicable time limits, and remedies for denied claims. A plan may provide the claims procedures in a separate document if the SPD clearly says so. You can also review the LII text for 29 CFR 2520.102-3.

The SPD must identify the plan administrator and where claims and appeals should be sent. See 29 CFR 2520.102-3. In many employer plans, the employer is the plan administrator, while the insurer may act as claims fiduciary.

If the plan fails to establish or follow reasonable procedures, you generally do not have to keep going through internal appeals and may sue under ERISA §502(a). See 29 CFR 2560.503-1(l) and the DOL guidance linked above.

What to include in the first group life claim

A group life claim often starts with the insurer's claim form, but families should think beyond the form. Missing coverage records, payroll details, or beneficiary documents can lead to delay or denial.

Common documents include:

• Certified death certificate.
• Employer or plan administrator statement confirming coverage, last day worked, class, amount, any AD&D riders, and premium status.
• Beneficiary designation forms and any change forms.
• Enrollment forms.
• SPD and certificate.
• Evidence related to edge cases, such as termination letters, COBRA letters, conversion notices, portability notices, payroll records, leave status, waiver-of-premium disability determinations, accident reports, and medical examiner reports for AD&D.

If you are still gathering death certificates, this guide may help: How to Order a Death Certificate: How Many You Need. If the policy is employer-provided and you are not sure who to contact, Sunset also has a related guide on how to claim employer life insurance after death.

Conversion and portability after coverage ends

Many group life certificates include conversion or portability rights. These clauses matter when the person died after employment ended, while on leave, after a class change, or soon after coverage was reduced.

Many group life certificates provide the following:

• Conversion: The right to convert all or part of terminated or reduced group life coverage to an individual policy without evidence of insurability if the insurer receives the application and premium within at least 31 days after group coverage ends. If death occurs during that 31-day conversion period, the death benefit is typically payable even if the person did not apply. See the Interstate Insurance Product Regulation Commission model standards, including Group Term Life Policy Standards, which address an "at least 31 days" conversion period, payment when death occurs within the conversion period, and notice and extension mechanics.
• Notice extensions: Model standards often extend the practical conversion window when required notices are late, for example, up to 60 days beyond the conversion period after notice. See the Insurance Compact standards cited above.
• Portability compared with conversion: Portability generally continues group coverage, often term coverage, and may keep some riders. Conversion generally creates a new individual policy, often whole life coverage, at individual rates and usually excludes some riders. For a practical comparison, see Penn State HR's conversion vs. portability explainer. That is only an example, and the certificate controls.
• Federal examples: These are not ERISA-wide rules, but program documents like FEGLI reflect common market mechanics, including a 31-day extension of coverage and conversion effective after the extension. See the Federal Register FEGLI rules.

If employment or eligibility ended, calendar the 31-day conversion and portability deadlines and keep proof of whether required notices were sent. If the death happened near a termination of coverage, review the "death during conversion period" clause right away.

Beneficiary designations and divorce

ERISA generally requires administrators to pay benefits according to the plan documents. That can surprise families after a divorce.

State "revocation-on-divorce" statutes are preempted for ERISA plans. If a participant did not update the beneficiary after divorce, the named beneficiary may still receive the benefit. See Egelhoff v. Egelhoff, 532 U.S. 141 (2001), where the Supreme Court held that a state revocation statute was preempted, and Kennedy v. Plan Administrator for DuPont, 555 U.S. 285 (2009), where the plan documents rule governed despite a divorce decree that did not meet QDRO requirements.

For a broader explanation of beneficiary issues, see Life Insurance Beneficiary Rules: What Families Need to Know After a Death.

Appeal checklist for a denied ERISA group life claim

If you receive an adverse benefit determination, read it carefully before drafting the appeal. The denial should tell you the reasons, the plan provisions relied on, what information may be needed, and how to ask for review. See 29 CFR 2560.503-1(g).

Use this checklist:

• Confirm the denial date and how the plan counts the appeal deadline.
• Check the SPD. The federal minimum appeal window is 60 days from receipt of the denial, but some plans allow more. See 29 CFR 2560.503-1(h)(2)(i).
• Request the complete claim file and all "relevant" documents free of charge, including policies, certificates, guidelines, notes, and logs. See 29 CFR 2560.503-1(h)(2)(iii).
• Identify every denial reason and answer each one with references to the policy and records.
• Submit missing forms, such as an employer statement, affidavits on beneficiary intent if relevant, payroll and HR records, and medical or coroner documentation for AD&D disputes.
• Preserve evidence of late notices or missed deadlines, which may support deemed exhaustion under 29 CFR 2560.503-1(l).

Key ERISA timing points to copy into your calendar:

• Initial claim decision: due as soon as reasonably possible and no later than 90 days. One written extension of up to 90 more days is allowed only if sent before Day 90, with special circumstances and a decision date. See 29 CFR 2560.503-1(f)(1).
• Appeal filing window: at least 60 days from receipt of the denial. Your SPD may allow more. See 29 CFR 2560.503-1(h)(2)(i).
• Appeal decision: due within 60 days. One written extension of up to 60 more days is allowed if sent before Day 60, with special circumstances and a decision date. See 29 CFR 2560.503-1(i)(1)(i).
• Missed deadlines or procedural failures: you are generally deemed to have exhausted internal remedies and may proceed to court. See 29 CFR 2560.503-1(l) and DOL FAQ Q-F2.
• Tolling: the express tolling language in 29 CFR 2560.503-1(f)(4) applies to group health pre-service and post-service claims and disability claims, not to the general 90-day life claim rule.

Appeal letter template

Copy this letter, fill in the bracketed fields, and send it according to the SPD instructions. Keep proof of delivery.

```text

[Your Name]

[Address]

[City, State ZIP]

[Phone] | [Email]

[Date]

Appeals Department

[Plan Name / Plan Number]

[Insurer/Claims Fiduciary Name]

[Address]

Re: ERISA Appeal of Adverse Benefit Determination

Claimant/Decedent: [Name] | Policy/Group: [ID] | Claim #: [#]

Date of Denial (ABD): [MM/DD/YYYY]

To Whom It May Concern:

I hereby appeal the adverse benefit determination issued on [date] regarding the group life insurance claim for [decedent]. This is a timely appeal under 29 CFR 2560.503-1(h).

Request for claim file and relevant documents

Please provide, at no charge, the complete claim file and all "relevant" documents, records, policies/certificates, guidelines, administrative procedures, internal notes/logs, and any statements of additional material or information necessary to perfect the claim. See 29 CFR 2560.503-1(h)(2)(iii).

Standard, reasons, and evidence

The denial cites: [quote or summarize each reason]. I dispute these for the following reasons, with citations to the policy and record:

1) [Reason #1 rebuttal with page/section cites]

2) [Reason #2 rebuttal]

3) [Add as needed]

I am enclosing the following additional evidence: [list documents: beneficiary forms, employer statement, payroll/coverage records, conversion/portability notices, medical/coroner reports for AD&D, affidavits, etc.]

Procedural rights and timeline

Please confirm the appeal decision date. Under 29 CFR 2560.503-1(i)(1)(i), a decision is due within 60 days of this appeal. Any extension must be noticed in writing before day 60, describe the special circumstances, and specify the new decision date. If the plan fails to follow ERISA claims-procedure requirements, I understand internal remedies are deemed exhausted. See 29 CFR 2560.503-1(l).

Relief requested

Please reverse the denial and approve benefits of $[amount] plus any applicable interest. If you decline to reverse, please provide a final written decision that includes the specific reasons, plan provisions relied upon, information needed to perfect the claim, and notice of further rights.

Sincerely,

[Your Name]

[Relationship to Decedent]

[Attachments]

```

Scripts for HR and the insurer

These scripts are meant to help you ask for the right records without having to start from a blank page. Replace the bracketed parts with your details.

To HR or the plan administrator for coverage verification:

Hello, I'm [name], the [beneficiary/executor] for [decedent]. Please confirm in writing: (1) the ERISA plan name and plan number, (2) the plan administrator and claims fiduciary, (3) whether group life coverage was in force on [date of death], (4) coverage amount and class, (5) any AD&D/waiver-of-premium riders, and (6) where to send claims and appeals. Please also provide the SPD and certificate at no charge. Thank you.

To the insurer for claim status and deadlines:

Hello, I'm following up on Claim #[number] for [decedent]. The claim was received on [date]. Under 29 CFR 2560.503-1(f)(1), the plan must decide within 90 days unless a written extension is sent before Day 90, identifying special circumstances and a decision date. Please confirm your target decision date or send the required extension notice.

To the insurer for an appeal and file request:

I appeal the adverse benefit determination dated [date]. Please acknowledge receipt and provide the complete claim file and all documents, records, rules, and guidelines relevant to the claim at no charge, per 29 CFR 2560.503-1(h)(2)(iii). I will submit additional evidence within my appeal window.

To HR about conversion or portability after coverage ends:

Please confirm whether conversion or portability rights applied when [participant]'s coverage ended on [date], and provide proof and dates of any required conversion/portability notices. Note that many certificates provide at least a 31-day conversion period and require written notice; late notice can extend rights. Please send the certificate language.

Common group life denial reasons

Many denials fall into a few patterns. The right response depends on the policy, the SPD, and the claim file.

Coverage not in force. The insurer may say premiums were missed, the person was in an ineligible class, or employment ended before death. Ask for payroll records, HR records, premium records, and the conversion or portability language. Review any "death during conversion period" clause.

Beneficiary dispute. There may be competing claims or an old beneficiary form. For ERISA plans, the plan documents rule from Egelhoff and Kennedy can control who is paid.

AD&D exclusion. Accidental death and dismemberment disputes may involve illness, intoxication, crime, policy definitions, accident reports, toxicology, or medical examiner records. Compare the denial to the exact policy wording and submit counter-evidence where available.

Waiver-of-premium dispute. If coverage depended on a disability waiver, confirm the disability standards and dates. Gather medical records and SSDI records if they matter to the claim.

Finding employer life insurance policies after a death

If you know the employer and insurer, start there. If you do not know whether a policy exists, the search can be harder, especially when the person had several employers, retired years ago, or kept poor records.

The NAIC Life Insurance Policy Locator is often misunderstood. You submit a request with the decedent's information. NAIC forwards that death information to participating insurance carriers. It is a notification to carriers, not a database you can search.

Each carrier checks its own records. If a carrier finds a matching policy, the carrier contacts the listed beneficiary directly at the address the carrier has on file for that beneficiary. NAIC never tells the person who submitted the request whether a match was found. There is no match or no-match answer, no results page, and no confirmation either way.

That means hearing nothing does not prove there was no policy. If the requester is not the listed beneficiary, the beneficiary address on file is out of date, or the beneficiary has moved or died, the notice can go nowhere and the requester may never learn that a policy existed.

Sunset's approach is different. Sunset searches 2,300+ financial institutions to find accounts and assets, including life insurance leads where available, and tells the family where a policy was found so they can claim it. Sunset can also help with life insurance search and claims support through its life insurance search and claims support. The source page notes that this support is free to families, SOC 2 Type II, and that typical insurer verification is 2 to 3 business days once documents are submitted.

Sunset also generates state- and county-specific probate packets, refers families to a local probate attorney when counsel is needed, and can help open an FDIC-insured estate account. Sunset's family product is funded through our bank partnership. The estate does not pay Sunset, and all assets go to the beneficiaries and heirs. Sunset has helped 15,000+ families settle estates.

FAQ

How long does an ERISA plan have to decide a group life claim?

For a group life claim under the general ERISA timing rule, the plan must decide as soon as reasonably possible and no later than 90 days. It may take one 90-day extension if special circumstances require more time and the plan sends a written extension notice before Day 90. See 29 CFR 2560.503-1(f)(1).

How long do I have to appeal a denied group life claim?

You have at least 60 days from receipt of the adverse benefit determination. Your SPD may give you more time, so check the plan documents before you file. See 29 CFR 2560.503-1(h)(2)(i).

Does the ERISA clock pause if the insurer asks for more information?

The regulation's express tolling language applies to group health pre-service and post-service claims and disability claims. It does not apply to the general 90-day life claim rule in 29 CFR 2560.503-1(f)(1). See 29 CFR 2560.503-1(f)(4).

What happens if the plan misses an ERISA deadline?

You are generally deemed to have exhausted internal remedies and may file suit under ERISA §502(a). See 29 CFR 2560.503-1(l) and DOL FAQ Q-F2.

What is the group life conversion period if employment ended before death?

Many certificates give at least 31 days to convert terminated or reduced group life coverage to an individual policy without evidence of insurability. If death occurs during that 31-day conversion period, the death benefit is typically payable even if no application was submitted. Notice issues can extend the practical conversion window, such as up to 60 days beyond the conversion period after notice under model standards. See the Insurance Compact group term life standards cited above.

If you are trying to find or claim life insurance while also handling probate, Sunset can help search for policies and other assets, prepare probate paperwork, and point you to local counsel when needed.