ERISA Group Life Insurance Claims Guide (2026)

Employer group life insurance from a private-sector job is often covered by ERISA, which means the plan documents and ERISA claim rules control the process. If your loved one had coverage through work, start with the Summary Plan Description, any Certificate of Insurance, prior W-2s showing Box 12 Code C, and the employer's Form 5500 filing.

This guide explains how those pieces fit together after a death. It is general information for families handling an estate settlement, not legal advice.

Start with the plan documents

Private-sector employer group life insurance is usually an ERISA-covered "employee welfare benefit plan." ERISA is the federal Employee Retirement Income Security Act. For families, the practical point is simple: the plan's written terms matter, state-law remedies are largely preempted, and claims and appeals have to follow ERISA's process.

Governmental plans are different. Federal FEGLI coverage, for example, is not an ERISA plan and has its own claim path through the Office of Federal Employees' Group Life Insurance.

For an employer group life claim, ask HR, Benefits, or the plan administrator for:

• The current Summary Plan Description, often called the SPD
• Any separate Certificate of Insurance, or COI, issued by the insurer
• Any riders, amendments, or claim procedure documents
• The plan number and employer EIN
• The most recent Form 5500, if one is available

Make the request in writing and keep a copy. If later you need to appeal a denial, your paper trail matters.

What the SPD should tell you

The SPD is the plain-language document that explains the plan for participants and beneficiaries. For welfare plans, including group life plans, the SPD must include key information, such as:

• Plan administrator contact details
• Plan name, employer EIN, and plan number
• Who is eligible for benefits
• How benefits are described
• Circumstances that can cause loss or denial of benefits
• Claims and appeals procedures
• Time limits that apply to claims and appeals

Ask for the SPD first because it tells you where to file the claim and what proof the plan requires. Some plans send life insurance claims to the plan administrator. Others send them straight to the insurer or another claims fiduciary.

If the SPD is missing, request it in writing. ERISA §104(b)(4) requires administrators to furnish plan documents after a written request. Civil penalties under ERISA §502(c)(1) may apply for failures to provide documents, and the dollar amounts are adjusted each year for inflation.

Keep:

• A copy of your request
• Proof of mailing, email delivery, or portal submission
• Any response from HR, Benefits, the plan administrator, or the insurer
• Notes from phone calls, including the date, name, and what was said

How ERISA life insurance claims work

Follow the SPD exactly. The deadlines, proof requirements, and filing address can affect the claim.

The first step is to identify the proper claimant. For death benefits, this is usually the named beneficiary. For related benefits, such as conversion, accidental death, or disability Waiver-of-Premium, the SPD defines who may file.

After that, file the initial claim where the SPD directs. For non-health, non-disability welfare claims like life insurance, a benefit decision is generally due within a reasonable period, no later than 90 days after the claim is received. The plan may take one 90-day extension for special circumstances. If the claim is denied, the denial must explain the reasons and describe the appeal process.

If you appeal, do it by the deadline in the SPD or denial letter. ERISA requires a "full and fair review." Most welfare plans must decide appeals within 60 days, though extensions are allowed in limited cases and committee or board timelines may apply.

The appeal stage is where families should send all the evidence they have. Courts often review the administrative record as it existed when the plan decided the appeal. That means you should not wait to submit payroll deductions, enrollment confirmations, Evidence of Insurability approvals, HR emails, or other proof.

The documents to gather before filing

Before submitting the claim, gather anything that can show coverage, eligibility, beneficiary status, and premium payment history.

Useful records include:

• Certified death certificate
• SPD
• Certificate of Insurance
• Enrollment forms
• Beneficiary designation forms
• Prior W-2s, especially any showing Box 12 Code C
• Pay stubs showing premium deductions
• HR or benefits emails
• Evidence of Insurability submissions or approvals
• Any denial, lapse, conversion, or portability notices

If you are also handling bank accounts, debts, a house, or court papers, it can help to put the insurance claim in the same estate file as the rest of the records. For a broader first-month checklist, see Sunset's guide to the executor's first 30 days.

Using Form 5500 and EFAST2 to identify the plan

Form 5500 filings can help you identify the plan sponsor, plan number, and some administrative contacts. They can also help you find the insurer when the plan is insured.

Use the Department of Labor's public EFAST2 Filing Search:

1. Go to the DOL's Form 5500 page and open the "Form 5500 Filing Search."
2. Search by employer name, EIN, or plan number.
3. Download the latest filing and attachments.
4. Look for Schedule A if insured benefits are listed, because it may name the carrier.
5. Use the sponsor address or contact information to direct SPD and records requests or to confirm the right claim address.

Form 5500 can point you to the plan, but it does not by itself prove the person had active coverage on the date of death. Eligibility, effective dates, benefit amounts, and exclusions come from the SPD, COI, and claim record.

W-2 Box 12 Code C can be a coverage clue

W-2 Box 12 Code C means the employer reported the taxable cost of group-term life insurance over $50,000. This is often called imputed income.

If you see Code C on prior W-2s, it is a strong clue that the employee had employer-provided group life coverage at that time. It is not proof that coverage was active on the date of death.

To confirm coverage, check:

• Whether the employee was still eligible under the SPD
• Whether coverage had an effective date that included the date of death
• Whether the amount required Evidence of Insurability
• Whether EOI was approved, denied, or never completed
• Whether premiums were being deducted from pay
• Whether coverage ended, converted, or continued after employment stopped

If you do not have prior W-2s, ask payroll for copies. A short written request is enough: ask for W-2s for the relevant years showing Box 12 Code C, because you are trying to confirm employer group life coverage.

Evidence of Insurability problems

Many employer group life plans have a guaranteed issue amount. Coverage above that limit, or coverage elected after the first enrollment window, may require Evidence of Insurability, often shortened to EOI.

EOI can include health questions or other proof required by the insurer. If EOI was required but was never submitted or approved, the insurer may deny supplemental coverage.

Families should still gather the full record. Federal enforcement and litigation often focus on fiduciary failures in enrollment and EOI administration, including cases where premiums were taken without getting or confirming required EOI.

Look for:

• Enrollment confirmation screens or emails
• Benefit election summaries
• EOI forms or online submissions
• EOI approval or denial letters
• Payroll deductions for supplemental life coverage
• HR emails stating that coverage was active
• Annual open enrollment records

Helpful definitional guidance on how employers administer EOI and when it is required in group settings can also be found in university HR benefit explanations. The plan terms still control, but those resources can help families understand common market practices.

If a claim is denied because of EOI, raise the relevant enrollment facts in the appeal. Include the payroll records, HR communications, and any proof that the employee thought coverage was in place.

Waiver-of-Premium is treated as a disability claim

Some group life plans have a Waiver-of-Premium feature. This can continue life insurance coverage without premiums if the participant meets the plan's disability standard.

If the plan conditions premium waiver on proof of disability, the claim is treated as a disability claim under ERISA's claims-procedure rule. Disability claims have stricter timelines and content requirements for denial letters than ordinary life insurance benefit claims.

Review the SPD and COI for:

• The plan's disability definition
• Proof standards
• Medical record requirements
• Filing deadlines
• Where to send the Waiver-of-Premium claim
• How appeals work

Industry-wide uniform standards show typical triggers for Waiver-of-Premium claims, but your plan governs. If a WOP dispute affects whether life coverage stayed in force, gather disability records, employer leave records, premium notices, and any communications about continuing coverage.

FEGLI is not an ERISA plan

Federal employees and retirees may have life insurance through FEGLI, the Federal Employees' Group Life Insurance program. FEGLI is a federal program, not an ERISA plan.

FEGLI claims go to the Office of Federal Employees' Group Life Insurance, known as OFEGLI. OFEGLI is administered by MetLife and follows Office of Personnel Management instructions.

FEGLI claims use FE-6 and FE-6 DEP forms. Use the OPM FEGLI pages for reporting a death, claim forms, and status checks. OFEGLI mail, fax, and contact details are published by OPM and MetLife.

If you are not sure whether the decedent's coverage was ERISA or governmental, check:

• Whether the employer was a private-sector employer, federal employer, state employer, local government, or public school employer
• Whether there is an SPD
• Whether there is a Form 5500 filing
• Whether claim forms refer to OFEGLI, OPM, MetLife, or another carrier

For federal coverage details, Sunset also has a guide to FEGLI and SGLI claims.

Why the NAIC locator may not answer an employer group life question

Families often hear about the NAIC Life Insurance Policy Locator after a death. It can be useful, but it does not work like a search engine and it does not give the requester an answer.

You submit a request with the decedent's information. NAIC forwards that death information to participating insurance carriers. This 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 that 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 mean there was no policy. If the requester is not the listed beneficiary, if the beneficiary address on file is out of date, or if the beneficiary has moved or died, the notice can go nowhere and the requester may never learn a policy existed.

This is different from Sunset's approach. Sunset searches 2,500+ financial institutions to find accounts and assets, tells the family where a policy was found, and helps them claim it instead of leaving them waiting on a notice that may never arrive. For more on policy claims after a death, see Sunset's guide on how to claim life insurance.

A step-by-step ERISA group life claim plan

Use this checklist to keep the claim organized.

1. Collect core records. Start with the death certificate, SPD, COI, enrollment records, beneficiary forms, prior W-2s, and pay stubs.
2. Confirm the plan and insurer. Use the SPD, COI, or EFAST2 Form 5500 materials to confirm the claim address and claims fiduciary.
3. Request missing documents in writing. If needed, ask the plan administrator for the SPD under ERISA §104(b)(4), and keep proof of delivery.
4. Submit the initial claim. Include every required proof listed in the SPD or claim form.
5. Track the decision period. For non-health, non-disability welfare claims like life insurance, the decision is generally due within a reasonable period, no later than 90 days after receipt, with one 90-day extension for special circumstances.
6. If denied, request the claim file. Ask for the complete claim file and the documents used to make the decision.
7. Appeal on time. Use the SPD and denial letter to confirm the appeal deadline and where to send it.
8. Build the administrative record. Send all evidence during the appeal, including EOI approvals, payroll deductions, HR emails, W-2s, and enrollment confirmations.
9. For Waiver-of-Premium disputes, apply the disability claim rules. Review the SPD and COI for proof standards, definitions, and deadlines.
10. If you still disagree after a final denial, discuss possible ERISA §502(a) remedies with counsel.

How Sunset can help with the rest of the estate

Employer life insurance can be only one part of the estate work after a death. Families may also need to find bank accounts, retirement accounts, unclaimed property, debts, home records, and court forms.

Sunset can help families organize the process. Sunset searches 2,500+ financial institutions to find accounts and assets, generates state- and county-specific probate packets, and can refer families to a local probate attorney when counsel is needed. Sunset also supports transfers and estate account setup through an FDIC-insured estate account.

Any Sunset fee counts as an estate administration expense the executor can reimburse from the estate, and all assets go to the beneficiaries and heirs. Sunset has helped 15,000+ families settle estates.

FAQ

Is employer group life insurance covered by ERISA?

Private-sector employer group life insurance is generally an ERISA-covered employee welfare benefit plan. Governmental plans, including the federal FEGLI program, are excluded from ERISA and follow different rules.

Can Form 5500 prove that my loved one had coverage?

Form 5500 can identify the plan sponsor, plan number, and sometimes the insurer or contract through Schedule A. It does not prove the employee was eligible or covered on the date of death. For that, use the SPD, COI, enrollment records, payroll records, and claim file.

What does W-2 Box 12 Code C mean for life insurance?

W-2 Box 12 Code C means the employer reported taxable cost of group-term life insurance over $50,000. It is a strong clue that employer group life coverage existed at that time, but it does not prove coverage was active when the employee died.

What if the employer took premiums but EOI was never approved?

Gather payroll deductions, enrollment confirmations, EOI submissions, HR emails, and benefit election records. If the insurer denies the supplemental coverage, raise those facts in the ERISA appeal. Federal enforcement and litigation often examine fiduciary duties around EOI and eligibility administration.

Where do FEGLI claims go after a federal employee dies?

FEGLI claims go to OFEGLI, the Office of Federal Employees' Group Life Insurance, administered by MetLife. Follow OPM instructions and use FE-6 or FE-6 DEP forms.

If you are trying to find life insurance, confirm employer benefits, or organize the estate after a death, Sunset can help you search for assets, prepare probate paperwork, and move the next steps forward.