If your benefits were approved without much of a fight for the first two years, and then got cut off right around your two-year mark, it's not because your health got better. It's because your policy's definition of "disabled" changed underneath you.
Most long-term disability policies run on two different tests, not one. For roughly the first 24 months, you only have to prove you can't do your job — insurers call this the "own occupation" standard. After that, the bar jumps: you have to prove you can't do any job you're reasonably qualified for based on your education and experience. That's the "any occupation" standard, and it's where a huge share of long-term claims get terminated, even when nothing about the person's condition has changed.
What Changed: The Own Occupation to Any Occupation Switch
"Own occupation" means the insurer has to show you can still perform the material duties of the specific job you held when you became disabled — not a lighter version of it, not a desk job you've never done. "Any occupation" drops that bar considerably. Now the insurer only has to show you're capable of some gainful job that exists in the national economy, reasonably suited to your education, training, and experience.
A surgeon with nerve damage in her hand clearly can't operate. But can she review medical records from a desk? Under an any-occupation standard, that question — not her ability to practice surgery — becomes the one that decides her claim.
Not every policy works this way. Some private, individually purchased own-occupation policies are written to keep that definition for the full benefit period, with no switch at all. If you're not sure which kind of policy you hold, your Summary Plan Description will say.
When Does the Definition Actually Change?
Most group LTD policies switch at 24 months of benefit payments, though some use 12-, 18-, or 36-month windows — the exact number lives in your Summary Plan Description, not in any federal statute. The insurer isn't required to warn you when the switch is coming. Many claimants find out only when a letter arrives referencing the new standard, often paired with a request for updated medical records or a scheduled Independent Medical Examination.
That timing isn't random. Insurers frequently schedule IMEs and vocational reviews in the months leading up to the switch specifically because a fresh medical opinion, dated close to the any-occupation transition, carries more weight in their file than records from a year earlier.
How Insurers Test Whether You Can Work "Any Occupation"
The any-occupation determination isn't a gut call — insurers build a file designed to support denial before the transition even arrives. Three tools show up in almost every case:
- Functional Capacity Evaluations measure what your body can physically do: how long you can sit, stand, lift, and concentrate over a full workday. Insurers use FCE results to argue you can handle sedentary work, even when the reason you can't do your old job has nothing to do with sitting versus standing.
- Transferable Skills Analyses take your resume and run it through a database of job titles, looking for any occupation — anywhere in the country, not just near you — that your education and experience theoretically qualify you for. The insurer doesn't have to prove that job is actually hiring, or that you could get hired at your age and with your medical restrictions. It only has to identify that the job exists.
- Labor market surveys back up the transferable skills analysis with data showing those job titles exist in meaningful numbers somewhere in the U.S. economy. This is often the weakest link in an insurer's case — the identified jobs frequently exceed the claimant's actual physical restrictions once you compare the job description against the FCE line by line.
Why the Same Claim Can Get Approved, Then Denied
In insurance law, we've seen this play out directly in suits against Cigna and its disability subsidiary LINA, whose group disability business — along with the rest of Cigna's group life and disability book — now operates under New York Life following a 2020 acquisition. In one case, a claimant's short-term benefits were denied under the easier own-occupation test, and a court found that denial unreasonable. But when her long-term benefits came up under the tougher any-occupation standard, the same court sided with the insurer. Same person, same medical condition — two different outcomes, because two different legal standards applied.
A separate federal appeals decision reinforced how steep that any-occupation bar is: the burden falls on the claimant to prove disability under the new standard. The insurer doesn't have to disprove anything — it's on you and your attorney to build a record strong enough to meet it. We break down both of these cases, along with the regulatory history behind LINA's claims-handling practices, in our full look at Cigna/LINA's disability claim tactics.
The pattern isn't unique to one carrier. A claim that sailed through the own-occupation period gets flagged for review right before month 24, medical evidence gets re-characterized as "subjective" or "self-reported," and a transferable skills analysis lands in the file listing jobs the claimant has never done and, often, couldn't physically perform.
What to Do Before (or Right After) Your Definition Changes
You don't have to wait for the denial letter to start preparing, and if the letter already arrived, you're not out of options — you just need to move.
Ask your plan administrator, in writing, exactly when your policy's definition changes. Request your full Summary Plan Description if you haven't already; the any-occupation language is often buried in a section most claimants never read until it's used against them. And if you're scheduled for an IME or asked to complete new paperwork in the months before your transition date, treat it as what it is: evidence-gathering for a harder standard, not a routine check-in.
Strong medical documentation matters more here than at any other point in your claim. That means records that speak directly to functional limitations — what you can't do for a full workday, not just your diagnosis — from a treating physician who understands what an any-occupation review looks like. Keeping a disability journal throughout this period gives your doctor and your attorney something concrete to work from.
The Coverage Window: Why Timing Is Everything
A long-term disability attorney reviewing your file before the switch can request the vocational analysis in advance, challenge a transferable skills report that ignores your actual restrictions, and build the appeal record while the definition is still working in your favor. Once a denial letter arrives citing the any-occupation standard, you're on the clock — ERISA appeals typically must be filed within 180 days, and the administrative record closes fast.
What Your Any-Occupation Appeal Needs to Include
Your appeal has to do more than say the denial was wrong — it has to build a competing record inside the strict window your policy gives you. Start with updated medical records that speak directly to the any-occupation standard: functional limitations for a full workday, not just your diagnosis. Request the transferable skills analysis and labor market survey the insurer relied on, then have your physician or a vocational expert respond specifically to the job titles listed — not just the diagnosis in general. File everything in writing before your 180-day deadline; ERISA appeals are decided on the paper record, so anything left out never gets considered.
Frequently Asked Questions
Why was my long-term disability claim denied after 24 months?
Most group LTD policies switch from an "own occupation" definition to a stricter "any occupation" definition around the 24-month mark. Claims that were approved under the easier standard often get terminated at this transition, even when the claimant's condition hasn't changed.
What's the difference between "own occupation" and "any occupation" disability?
"Own occupation" means the insurer has to prove you can't perform your specific job. "Any occupation" means the insurer only has to show you're capable of some job that exists in the national economy and fits your education, training, and experience — regardless of whether that job is realistically available to you.
Can an insurance company change the definition of disability on my claim?
Yes, but only in the way already written into your policy. Most group LTD plans are designed from the start with a built-in switch from own occupation to any occupation at a set point, usually 24 months. It's not a new decision the insurer makes — it's a term of your policy taking effect.
How long does the "own occupation" period usually last?
Most policies apply the own-occupation standard for the first 24 months of benefits, though some use 12-, 18-, or 36-month windows. The exact timing is set in your Summary Plan Description.
What is a transferable skills analysis?
It's a vocational review insurers use during an any-occupation determination. It matches your education, training, and work history against a database of job titles to argue you're capable of some occupation other than your own — even if that job isn't realistically available to you given your age, location, or restrictions.
Does getting approved for Social Security disability protect my LTD benefits after 24 months?
Not automatically. Courts have upheld LTD denials even after a claimant was approved for SSDI, when the insurer's own medical and vocational evidence supported the denial. The two programs use different standards, and an SSDI approval doesn't bind your LTD insurer's decision.
Do all disability policies switch to an any-occupation standard?
No. Some private, individually purchased own-occupation policies keep that definition for the full benefit period, with no switch to any-occupation at all. Check your policy or ask an attorney to review it if you're not sure which type you have.
How long do I have to appeal an any-occupation denial?
For most ERISA-governed group LTD plans, you typically have 180 days from the date of the denial letter to file your appeal. Missing that window can permanently forfeit your right to challenge the decision.
Don't Let the Definition Change Catch You Off Guard
Sandstone Law Group's experienced ERISA and long-term disability attorneys know how insurers build any-occupation denial files before claimants ever see a letter. Nationwide, we help claimants challenge transferable skills analyses that ignore real medical restrictions and push back before the 180-day appeal window closes. Call (602) 615-0050 or contact us online for a free case evaluation.