Experts the plan must disclose
Your plan's claims procedures must identify every medical or vocational expert whose advice it obtained, whether or not it relied on their opinion.
The regulation requires the plan to provide "the identification of medical or vocational experts whose advice was obtained on behalf of the plan in connection with a claimant's adverse benefit determination, without regard to whether the advice was relied upon in making the benefit determination." That last clause matters: the plan cannot leave a consultant off the list just because it decided not to rely on that person's opinion. The paragraph carrying this requirement, (h)(3)(iv), sits under a heading reading "Group health plans", so it reaches your disability claim by a second step: (h)(4) requires a disability plan's claims procedures to comply "in addition to complying with the requirements of paragraphs (h)(2)(ii) through (iv) and (h)(3)(i) through (v) of this section," and (h)(3)(iv) is inside that range.
This disclosure can surface a reviewer your denial letter never mentions, for example a file reviewer who found you disabled but was overruled, or a vocational consultant whose report undercut the medical reviewer's conclusion. Request this identification in writing alongside your complete claim file request if your denial letter does not already name every expert involved. The same regulation separately requires the consulting professional for a medical-judgment denial to be someone who was not involved in the original decision; see who reviews your internal appeal for that independence requirement in full.
Why the denial letter may not name everyone
A denial letter that only cites the reviewer it ultimately relied on can look more airtight than the file actually is. If an earlier reviewer's opinion supported your claim and was overridden, or if a vocational consultant's report was more favorable than the letter suggests, that context is not something the letter has to volunteer. The regulation gives you a way to ask for it: request the identification of every expert whose advice was obtained, not just the one the letter quotes.
What to do once you have the names
Once you know who was actually consulted, request their underlying reports as part of your complete claim file, not just a summary of their conclusions. Compare what each expert actually wrote against what the denial letter says they found, since a mismatch between the underlying report and the letter's characterization of it is worth raising directly in your appeal. Those underlying reports fall within the regulation's broader definition of what counts as relevant evidence, not only the material the denial letter quotes.
Sources
29 CFR 2560.503-1(h)(3)(iv) for the identification requirement, read together with (h)(4), which is what applies (h)(3)(i) through (v) to a plan providing disability benefits. Checked 2026-09-16 against the govinfo structured XML of the section.