"The case ... highlights the need to focus on whether a claimant has a disabling condition and not merely a diagnosis within the benefit waiting period under the Policy.... Further, the reasoning of this case provides a strong basis for a Plan to argue to the reviewing court that it can only look to a claimant's condition during the benefit waiting period, and not the claimant's condition beyond, even though it may have worsened into a disabling condition during the administrative review, but after the elimination period." [Calkin v. United States Life Ins. Co., No. 20-0035 (S.D. TX., Apr. 29, 2021)]

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