While working at Regal-Beloit Corporation, William Davis participated in the company’s long-term disability plan, which is administered by Unum Life Insurance Company of America. After Regal-Beloit fired Davis, he sought benefits under the plan. Unum awarded Davis benefits for a mental disability but denied benefits for a physical disability. Davis sued. The district court denied summary judgment to Unum and the plan and partially granted summary judgment to Davis, remanding the matter for further administrative proceedings. Dissatisfied with his partial victory, Davis appealed. Unum and the plan then cross-appealed. Concluding that the district court misapplied the governing arbitrary-and-capricious standard, we reverse and remand, with instructions for the district court to enter judgment in favor of Unum and the plan.
I.
Regal-Beloit Corporation, an industrial machinery manufacturer, hired William Davis as a regional sales manager in February 1999. In January 2000, Regal-Beloit terminated him due to poor job performance. He was fifty-five at the time. During his brief term, Davis participated in the Regal-Beloit Corporation Long Term Disability Plan (“the plan”). The plan’s administrator is Unum Life Insurance Company of America.
Under this plan, the maximum period for which a claimant can receive disability benefits varies based upon a number of factors, including whether the disability is physical or mental in nature. Generally, for physical disabilities arising before age sixty, benefit payments continue until the *572 claimant turns sixty-five. To reach that maximum, the claimant must meet the plan’s definition of “disabled” throughout the period. During the first twenty-four months of benefit payments, the term disabled means that a sickness or injury limits the claimant’s performance of his “regular occupation.” After twenty-four months of payments, however, the standard becomes more difficult for the claimant to meet. The plan then defines disabled as being “unable to perform the duties of any gainful occupation for which [the claimant is] reasonably fitted by education, training or experience.” Further, separate from these provisions, there is a different time limitation for “disabilities due to mental illness.” These benefits are capped at twenty-four months.
After Davis’s termination, he searched for new positions and landed several interviews. Nevertheless, in July 2000, some six months after leaving Regal-Beloit, Davis remained unemployed and submitted a disability claim under the plan. On the initial form, Davis claimed to be disabled due to severe depression, memory loss, joint pain, and a stroke. He further stated that his condition prevented him from driving, lifting, and walking.
In a follow-up telephone interview, nonetheless, Davis stated that he was not restricted or limited as the result of any physical ailment; rather, he said the only reason that he was unable to work was his mental condition. According to Davis, he could not work because of depression, mood swings, forgetfulness, an inability to concentrate, and an inability to perform multiple tasks at the same time. Davis said he was homebound, adding that he did not drive at all, not even to the local market. Surveillance evidence obtained less than a month after this interview, however, showed Davis driving vehicles, refueling a vehicle, and engaging in routine outdoor chores.
Davis’s doctors backed up his claims of a disabling mental illness. According to Davis’s attending physician and internist, Alan Reich, M.D., the primary diagnosis was major depression. On the initial form submitted with Davis’s claim, Dr. Reich listed the symptoms as indecisiveness, forgetfulness, and difficulty concentrating. Dr. Reich also noted that Davis had no cardiac limitations but had some back and hip pain. This summary from Dr. Reich came after several other doctors had examined Davis in 2000. These doctors largely gave Davis a clean bill of physical health, but some noted psychiatric problems. For instance, Davis’s urologist, Gordon Gluckman, M.D., found no recurrence of Davis’s 1992 bout with prostate cancer and said Davis was “doing well.” Further, Davis’s neurologist, Barry Levy, M.D., in conjunction with a psychologist, Joshua Barras, Ph.D., found that depression was the source of Davis’s problems and recommended psychiatric treatment. It is worth noting that, according to Dr. Levy, Davis was “very unhappy” with Drs. Levy’s and Barras’s opinions. Further, while Davis’s disability claim was pending, Davis believed that he had a stroke, but Drs. Reich and Levy had reasons to question that belief. Particularly, Dr. Levy, in discussing the “suspected stroke,” stated that “nonphysiologic features are present and suggest a psychogenic component.” In other words, Davis’s problem was not physical but mental.
For its part, Unum responded to the claim by consulting Robert Buchanan, M.D., a psychiatrist who worked at Unum — i.e., an “in-house doctor.” The importance of this phrase will become apparent below. After reviewing Davis’s medical file, Dr. Buchanan generally concurred with the findings of Davis’s doctors, stat *573 ing that Davis had “significant impairment from depression.” In December 2000, Unum then approved Davis’s disability-claim pursuant to the plan’s mental disability coverage. Unum paid Davis benefits retroactive to July 2000 and continued to pay him benefits until Davis reached the plan’s twenty-four month limitation for mental disability benefits in July 2002.
Meanwhile, Davis began seeing a new primary doctor in February 2001, Michael Raymond, M.D. Dr. Raymond, an internist, immediately keyed in on Davis’s physical complaints, including problems walking and standing. Dr. Raymond also referred Davis to a new neurologist, Steven Meyers, M.D. Dr. Meyers found that Davis “cannot stand or walk for any distance” and concluded that Davis was “permanently disabled” due to lumbar spinal stenosis (a narrowing of the spinal canal in the lower back) and the aftereffects of childhood polio. However, according to Dr. Meyers, diagnostic testing revealed that Davis did not actually have a condition known as post-polio syndrome (progressive muscle weakness, muscle and joint pain, fatigue, etc.).
In May 2001, Davis then supplemented his existing file at Unum with the opinions of Drs. Raymond and Meyers. Davis thus began a sustained effort to obtain the more generous (i.e., longer lasting) physical disability benefits under the plan. Unum then had an orthopedic surgeon, Joseph Thomas, M.D., and an internist, Steven Feagin, M.D., review Davis’s updated file. Both worked in-house at Unum. Based upon their assessments of the medical evidence, Unum notified Davis in December 2001 that his eligibility remained unchanged and that his benefits were still due to expire in July 2002.
Davis then retained counsel and submitted more information from Dr. Raymond related to spinal stenosis and other physical ailments. Despite Dr. Meyers ruling out post-polio syndrome, Dr. Raymond’s papers still listed post-polio syndrome as a reason to support Davis’s disability claim. Dr. Raymond further concluded Davis should be restricted from walking, lifting, bending, carrying, and climbing. It is noteworthy, however, that in this submission, Dr. Raymond stated that Davis had no functional limitations as the result of a cardiac condition.
On Unum’s behalf, Dr. Thomas reviewed the new data and found that it supported a diagnosis of spinal stenosis. However, Dr. Thomas concluded that, although Davis could not stand or walk for prolonged periods, he was still able to perform sedentary work. George Fluter, M.D., a doctor of physical medicine and rehabilitation at Unum, concurred, stating that Davis was not precluded from sedentary activities. Dr. Feagin also revisited the file and found no limitations based upon Davis’s diabetes, hypertension, sleep apnea, cardiac condition, and other physical complaints, all of which were successfully treated or being treated. Additionally, according to David Goldsmith, Ph.D., a clinical psychologist at Unum, Davis’s depressive disorder remained and his file indicated that Davis’s “perceived” cognitive problems were only psychiatric in nature. Finally, Kelly Marsiano, M.Ed., a vocational rehabilitation specialist at Unum, identified several sedentary occupations that Davis could, in light of his physical capacity, educational background (two years of college), and employment history, perform. Unum then determined that Davis failed to meet the standard for physical disability benefits beyond twenty-four months — that is, he was riot unable to perform the duties of any gainful occupation for which he was reasonably fitted. Unum thus denied his physical disability claim in December 2002.
*574 Davis appealed, supplementing his claim with a letter from Dr. Raymond. In the letter, Dr. Raymond opined that Davis was incapable of active employment, not even a sedentary position. To this end, Dr. Raymond added carpal tunnel syndrome (previously unmentioned) to Davis’s growing list of physical complaints, and, despite earlier findings in the record, Dr. Raymond’s list surprisingly still included prostate cancer, post-polio syndrome, and coronary artery disease. According to Dr. Raymond, it was “difficult, if not impossible, for Mr. Davis to sit, stand or walk for any prolonged timeframes [sic].” Dr. Raymond also cited to a hypoglycemic episode (decrease of blood sugar) related to Davis’s diabetes, which necessitated hospitalization in February 2003. Dr. Raymond, however, did not attach any new medical data to support the assertions in his letter. Dr. Fluter reviewed the letter, noting the obvious absence of supporting documentation, and consequently held to his opinion that Davis could engage in sedentary work. Unum then affirmed its denial but offered Davis the opportunity to submit additional records.
Davis then supplied Unum with the hospital records of his hypoglycemic attack. The hospital records revealed that, the evening before the incident, Davis forgot to take his insulin at the scheduled time. In the morning, he then took two full doses of insulin. In addition, he did not eat breakfast. Dr. Fluter found that this occurrence of hypoglycemia was associated with the confluence of these missteps. Dr. Fluter concluded: “It would be unlikely for [Davis] to experience significant hypoglycemia with attention to proper dosing and administration of his diabetic treatment medications and to proper dietary management. This occurrence would not preclude performance of sedentary level activities.” With that, the administrative case was closed. Unum issued its final decision, upholding its denial of physical disability benefits, in August 2003.
Within days, Davis sued Unum and the plan. The suit, brought under the Employee Retirement Income Security Act (“ERISA”), alleged wrongful denial of benefits pursuant to 29 U.S.C. § 1132(a)(1)(B). The parties filed cross-motions for summary judgment. The district court denied Unum and the plan summary judgment and partially granted Davis summary judgment. The district court faulted Unum for using only in-house doctors who perform “a mere paper review” of Davis’s claims and who did not explain their conclusions to the district court’s satisfaction. The district court, nevertheless, did not order Unum to award Davis physical disability benefits. Rather, the district court remanded the case back for Unum to correct the deficiencies identified by the district court in its opinion. 1 Displeased, Davis appealed, seeking an outright reversal of Unum’s denial and a full award of physical disability benefits. Unum and the plan then cross-appealed, contesting the district court’s denial of summary judgment.
II.
Our review of the district court’s summary judgment decisions is de novo.
See Sisto v. Ameritech Sickness & Accident Disability Benefit Plan,
A.
When, as here, the terms of an employee benefit plan afford the plan administrator broad discretion to interpret the plan and determine benefit eligibility, judicial review of the administrator’s decision to deny benefits is limited to the arbitrary-and-capricious standard.
See id.
The district court ostensibly applied this deferential standard, but Davis challenges its applicability in this case. He, however, does not dispute the plan’s language. Rather, he contends that, due to a conflict of interest, Unum was biased against him and should not be afforded any deference. This is a difficult road for Davis because the existence of potential bias, a potential conflict, is not enough to dislodge our ordinary arbitrary-and-capricious review.
See Dougherty v. Ind. Bell Tel. Co.,
The source of Davis’s argument is Unum’s in-house doctors. However, whether a doctor is in-house or not is an irrelevant distinction in this context. To start, plan administrators have a duty to all plan participants and beneficiaries to investigate claims and make sure to avoid paying benefits to claimants who are not entitled to receive them.
See Dougherty,
Had Unum given its doctors some specific stake in the outcome of Davis’s case, such as paying the doctors more if Davis’s claim were denied, then Davis would have an argument; however, Davis has not shown that the doctors in this case had any specific incentive to derail his claim.
See Leipzig v. AIG Life Ins. Co.,
B.
Under this standard, then, we will uphold Unum’s denial of benefits so long as that decision has “rational support in the record.”
Leipzig,
The question before us, then, is whether there is rational support in the record for Unum’s determination that Davis was not disabled to the extent that he was unable to perform the duties of any gainful occupation for which he was reasonably fitted. Based upon the extensive record, summarized in our background section above, we can easily answer this question in the affirmative. The expert opinions of Drs. Thomas, Feagin, Fluter, and Goldsmith adequately established that Davis could perform sedentary activities, and the vocational specialist identified several sedentary jobs for Davis. That is rational support. This evidence makes it “possible” for Unum “to offer a reasoned explanation” for its decision to deny benefits, and, under the arbitrary-and-capricious standard, we must respect Unum’s judgment.
Semien v. Life Ins. Co. of N. Am.,
Nevertheless, Davis argues, and the district court ruled, that Unum should not rely on this evidence for a variety of reasons, each of which we reject. Primarily, the district court (in a vein similar to that of Davis’s conflict-of-interest argument above) penalized Unum for relying on in-house doctors, implying that in-house doctors inherently lack objectivity. However, again, Unum’s in-house doctors were every bit as capable as outside doctors to evaluate the medical information in the file and provide independent expert medical opinions. The singular fact of working in-house does not disqualify a doctor from rendering an independent opinion any more than does paying an outside doctor to do the same, and neither the district court nor Davis go so far as to suggest that Unum could not hire a doctor to check the veracity and genuineness of Davis’s claim and his doctors’ opinions. Nor could they.
See Dougherty,
The district court and Davis also fault Unum for relying on “a mere paper review,” lamenting the fact that Unum’s doctors did not personally examine Davis or speak with his doctors. However, neither the district court nor Davis has cited, and our research has not disclosed, any authority that generally prohibits the commonplace practice of doctors arriving at professional opinions after reviewing medical files. In such file reviews, doctors are fully able to evaluate medical information, balance the objective data against the subjective opinions of the treating physicians, and render an expert opinion without direct consultation. It is reasonable, therefore, for an administrator to rely on its doctors’ assessments of the file and to save the plan the financial burden of conducting repetitive tests and examinations.
See Dougherty,
This was not a situation, moreover, in which the administrator’s doctors were completely at odds with the claimant’s doctors and the medical evidence. For example, Unum’s Dr. Feagin found that the results of medical testing indicated that Davis did not have post-polio syndrome. While Davis’s Dr. Raymond clung to an opposite conclusion, Dr. Feagin’s view was in line with the clinical findings of Dr. Meyers, Davis’s second neurologist. Similarly, Davis’s first neurologist, Dr. Levy, attributed Davis’s perceived physical ailments to his psychiatric condition, and Dr. Reich, Davis’s first treating physician, largely indicated that Davis was mentally disabled. The consensus view of Unum’s doctors that Davis was not physically incapable of performing sedentary activities is not inconsistent with the views of Davis’s first set of doctors (with whom Davis expressed dissatisfaction and replaced).
Interestingly, Dr. Raymond, who is the focal point of Davis’s case, never took account of Dr. Levy’s conclusion that psychiatric problems were the source of Davis’s physical symptoms. Such an omission, not lost on Unum, weakens Dr. Raymond’s reliability.
See Shyman v. Unum Life Ins. Co.,
In this light, these examples and others in the record show Dr. Raymond more as an advocate than a doctor rendering objective opinions.
Cf. Leipzig,
The final point to address is the explanations supporting the denial, which the district court and Davis conclude are insufficient. The dispute here is not about the adequacy of Unum’s explanations, as the plan administrator, for the denial. Nor could it be. Unum’s denial letters to Davis sufficiently detailed Unum’s reasoning.
See Herman v. Cent. States, Se. & Sw. Areas Pension Fund,
It is enough, in situations such as this, for the doctors to review the file and render a professional, medical opinion. The record here unequivocally demonstrates that Unum’s doctors reviewed the data supplied by Davis. The district court admitted as much in stating, “In their review of the file, Unum’s in-house doctors did discuss [Davis’s] medical testing and (implicitly) suggested that the objective results did not indicate that [Davis] cannot perform sedentary work.” The Unum doctors’ conclusions, however, were not simply “implicit.” 2 For example, there was nothing implicit or vague about Dr. Fluter’s aforementioned conclusion regarding Davis’s hypoglycemia. It was explicit and compelling. Further, to the extent that other conclusions were summary, we again see no grounds here for mandating that doctors draft lengthy, lawyer-like opinions.
Bottom line, the record contains rational support for Unum’s denial of physical disability benefits. In concluding otherwise — and penalizing Unum for relying on in-house doctors who reviewed the file and gave doctor-like explanations for their conclusions — the district court went beyond the bounds of arbitrary-and-capricious review. On this record, it is not “downright unreasonable” to find that Davis was not unable to perform the duties of any gainful occupation for which he was reasonably fitted. We will thus uphold Unum’s denial of long-term disability benefits under the arbitrary-and-capricious standard. Further, because Unum and the plan are entitled to summary judgment, there is no need for us to discuss Davis’s challenge to the district court’s remand for further administrative proceedings.
III.
The correct standard to review Unum’s denial of benefits in this case is the arbitrary-and-capricious standard. There is no evidence of conflict or bias that would necessitate a less- deferential level of review. Furthermore, as with Unum’s grant of mental disability benefits (which lasted twenty-four months), Unum’s denial of long-term physical disability benefits has rational support in the record. Therefore, under the arbitrary-and-capricious standard, we will not disturb Unum’s decision. Accordingly, the judgment of the district court is Reversed, and the case is Remanded with instructions for the district court to enter judgment in favor of Unum and the plan.
Notes
. Although the district court remanded the case for further administrative proceedings, the district court did not reserve an opportunity to hear the results of those proceedings or otherwise postpone its final adjudication of the suit. Thus, for purposes of 28 U.S.C. § 1291, the district court terminated the suit, and we have jurisdiction to hear this appeal.
See Perlman v. Swiss Bank Corp. Comprehensive Disability Protection Plan,
. Several of Unum's in-house doctors submitted detailed recitations of their medical evaluations rather than forms with checked boxes and cryptic comments.