Although the Affordable Care Act prohibits health insurance denials on account of pre-existing conditions, the ACA is inapplicable to disability insurance.A recent federal court case from Massachusetts, Holzman v. Hartford Life & Accident Insurance Co., 2019 WL 181527 (D. Mass., Jan. 14, 2019), examined whether a claim for disability benefits fell within a pre-existing condition exclusion and reached a surprising conclusion.In Holzman, the policy covering the plaintiff, William Holzman, defined a “pre-existing …