Turna v. Mayo Clinic

Background

Tarlochan S. Turna, M.D. worked as a full-time physician at the Mayo Clinic Health System in Cannon Falls, Minnesota. After he reduced his work schedule because of health effects from Parkinson’s disease, he began receiving short-term disability benefits and later qualified for long-term disability benefits under Mayo’s employee welfare benefit plan.

The plan calculated long-term disability benefits using a participant’s “annual salary,” defined as basic salary when disability began and the qualifying period started, based on regularly scheduled hours. The plan excluded bonuses, incentive pay, commissions, overtime pay, shift pay, and other extra compensation. Turna received a monthly long-term disability benefit beginning in September 2016, but he argued that Mayo had undercalculated his pre-disability annual salary. Mayo used a figure of $298,579.84, later referred to in the record as $298,579.80. Turna argued that his regularly scheduled work and compensation supported a substantially higher figure.

Mayo denied Turna’s two levels of administrative appeal. Turna then sued under the Employee Retirement Income Security Act, a federal law governing employee benefit plans, seeking unpaid benefits and related relief. Both sides moved for summary judgment, which is a decision based on the record when the material facts do not require a trial. Mayo alternatively asked the court to send the claim back to the plan administrator.

Standard of Review

The plan gave Mayo discretion to decide benefit eligibility and benefit amounts. The court therefore reviewed Mayo’s decision for abuse of discretion, meaning whether the administrator’s interpretation and application of the plan were unreasonable under the governing standards.

The court explained that it had to consider whether Mayo’s interpretation of the plan was reasonable and whether substantial evidence supported Mayo’s application of that interpretation to Turna’s circumstances. Substantial evidence means more than a slight amount of evidence but less than the greater weight of the evidence.

Plan Interpretation

The court found that Mayo’s interpretation of the plan’s “Amount of Benefit” provision was not reasonable. Mayo did not clearly define “basic salary,” “regularly scheduled hours,” or the categories of compensation excluded from annual salary. Mayo’s decisions generally treated compensation for work beyond a 1.0 full-time-equivalent schedule as excluded, but they did not consistently explain which exclusion applied or how the excluded categories differed.

The court reasoned that treating all compensation beyond regularly scheduled hours as excluded would make the plan’s specific exclusions—such as overtime pay, shift pay, and other extra compensation—meaningless. The plan required both an assessment of whether compensation was for work beyond regularly scheduled hours and an assessment of whether it fell within an excluded category.

The court also noted that Mayo twice relied on a revised version of the plan that did not apply to Turna’s claim. That version changed “annual salary” to “Annual Benefit Salary” and added language stating that basic salary was “as determined by your employer.” The court could not determine how much this mistaken reliance affected Mayo’s final decision, but it considered the error relevant to the reasonableness of the decision.

Evidence Supporting the Benefit Calculation

The court separately found that the evidence Mayo relied on did not substantially support the $298,579.80 annual-salary figure. Mayo primarily relied on a July 1, 2015 compensation notice and an untitled document identifying 1,728 hours as equivalent to a full-time position for a hospitalist in a critical access hospital.

The compensation notice did not describe the $298,579.80 figure as “basic salary” under the plan or explain how the figure related to the plan’s benefit calculation. It listed hospitalist day and weekend shifts but did not list compensation for emergency-department shifts, even though the notice stated that compensation was based on expected emergency or hospitalist shifts. It also referred to a quarterly adjustment for actual shifts worked without explaining whether that additional compensation counted toward annual salary under the plan.

The second document had no identified author, title, date, or purpose. Although it identified 1,728 hours by reducing 2,080 hours for vacation, continuing medical education, and holidays, Mayo did not provide enough explanation connecting that document to Turna’s claim or showing that it justified the benefit calculation.

Disposition

The court concluded that Mayo had used an unreasonable interpretation of the plan and had not supported its benefit determination with sufficient evidence. Because it remained unclear what amount of benefits Turna was entitled to receive, the court determined that remand to the administrator was appropriate rather than awarding Turna a specific benefit amount.

The court ordered:

- Turna’s motion for summary judgment was DENIED. - Mayo’s motion for summary judgment or, alternatively, remand was DENIED IN PART and GRANTED IN PART. - Mayo’s motion was denied to the extent it sought summary judgment and granted to the extent it sought remand. - The matter was REMANDED to Mayo for administrative proceedings to determine the amount of Turna’s benefit consistently with the opinion and order. - The court retained jurisdiction over the matter.

Judge Eric C. Tostrud signed the opinion and order on April 16, 2019.