michigan bar ssa newsletter

8/8/2019 Michigan Bar SSA Newsletter

http://slidepdf.com/reader/full/michigan-bar-ssa-newsletter 1/12

Cardiac Listing

This was a very informative seminar which was a basic primer on the anatomy and physiology of the

heart and then discussed the specific cardiac listings

in layman terms. Following are a few highlights of tha

informative presentation.

There are four chambers to the

heart with the top chambers called

the right and left atriums and the

bottom chambers called the right

and left ventricles. The right side

of the heart takes in blood through

the atrium and out through the right

ventricle to the lungs to be oxygen-ated. The left side of the heart

muscle is three times as strong as

the right since it takes the oxygen-

ated blood from the lungs and

pumps it to the rest of the body.

The pressure on the left side of the

heart is lower than the right side of the heart where the

blood is pumped to the lungs.

Left heart failure is where the left ventricle is unable

to pump the blood to the body adequately. Shortness

Editor’s Note:

Lewis Seward was

kind enough to

provide the fol-

lowing summary

of the seminars

and events from

the NOSSCR con-

ference that took

place in San Di-

ego, CA in April.

By Carl A. Anderson

ANDERSON, ANDERSON

& ASSOCIATES

Detroit, MI

Section Council Member

and Newsletter Editor

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At last year’s annual section meeting, the Honorable Mar-

tin Magid, Chief ALJ for the Detroit OHA, stated that hewas particularly pleased with the performance of the Senior

Attorney Program in his office. From my discussions with

many of my colleagues, I can safely say that Judge Magid is

not alone in his admiration for the program.

Under the program, OHA staff attorneys search through

the OHA docket of pending cases, looking for claimants

whose case may be paid on the record and for whom ahearing would be unnecessary. If further development of the

case is needed to support a favorable decision, the staff at-

torneys are empowered to obtain such additional evidence.

When there is sufficient evidence in the record, the staff at-

torneys issue favorable decisions. It should be noted, how-CCoonnt

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99

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2

Evan A. Zagoria

PROVIZER &

PHILLIPS, P.C.

Southfield, MI

I hope you enjoy this first issue of our Sectionnewsletter.

This newsletter will keep you better informed

of Section activities, hopefully with more warn

ing. Elsewhere, you will find dates of the Annua

Meeting in Lansing and future general section

meetings. We have managed to avoid a direc

conflict with the Workers’ Compensation Sec-

tion, as many of our members are in both. This

meeting will include the election of officers and

council members. We want to encourage as

many members as possible to become activelyinvolved in the Section. If you are interested in

serving on the Council or a committee, please

call or write.

Commissioner Apfel was recently in Detroit

with Congressman Sander Levin as part of loca

round tables on the issue of future funding of

SSA into the next century. I was present on be-

half of the Section. I would anticipate more of

these being held nationwide, perhaps not all with

participation by SSA management. Presiden

Clinton and Congress are trying to develop some public consensus as to which of the various strat-

egies are more (or less) acceptable and desir-

able. Do not be afraid to air your views, particu-

larly with our experience with SSA.

Regarding regulatory news, SSA seems to be

backing away from revising the rules on th

Workers’ Compensation offset. I sense their con-

cern is more related to the cost to the states

OFFICERS

Chairperson

Evan A. Zagoria

Southfield

Chairperson-Elect

Deanna J. Lee-Kaniowski

Southfield

SecretaryDiane M. Kwitoski

Pontiac

Treasurer

Edward M. WaudPetosky

C OUNCILM EMBERS

Carl A. Anderson

Detroit

David B. Newman

Berkley

Lewis M. Seward

Bay City

Thomas M. Stellard

Grand Rapids

Marsha E. WoodsLansing

C OMMISSIONERL IAISON

Reginald M. Turner Detroit

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3

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employers and insurance companies rather

than concern for their clients. The Repre-

sentative Rules of Conduct will be going

through final internal approvals and sign-

offs in late May, early June. Nancy Shor, at

the NOSSCR conference in San Diego, had

not been advised of their content. A repre-

sentative from SSA in San Diego told me

that the final draft will be more to our liking

than the original draft. Hopefully, this will

be more than wishful thinking on his part.

Lately, SSA’s proposals on user fees do not

seem likely to be attached to other pending

legislation.

One of the goals of my service as Sec-

tion Chair was to obtain some relief as to

the fees we incur to purchase medical

records. Certain legislation on this issue has

been drafted and will soon be introduced, if

it has not already. Once we receive more

formal details as to the bill’s number, com-

mittee, etc., we will keep you advised, as

well as to discuss potential avenues for lob-

bying. In the short term, I have just reached

an agreement with the Smart Corporation

to limit its fees in records for a Social Se-

curity disability claim to $25. I await formalconfirmation of this from the Smart Corpo-

ration, which I will provide to the member-

ship. Keep in mind it will also take Smart

some time to disseminate these new guide-

lines to its workers at each facility. Errone-

ous invoices could likely be repriced. Upon

receipt of this formal approval from Smart,

I will contact HCC and others to see if they

will be willing to provide records for the

same fee. If you have lists of various copy

services you would like me to deal with,

please provide me a copy of an invoice or

other identifying information to enable me

to start negotiations. This arrangement is

not a final solution, but it is a step in the

right direction.

I welcome your comments and sugges-

tions.

Annual Meeting

and Seminar

September 16, 1998

Lansing

Introduction to

Social Security Law

October 16, 1998

Detroit

(Details to be announced)

Winter Meeting

January 22, 1999

Lansing

Spring Meeting

March 26, 1999

Lansing

Summer Meeting

June 4, 1999

Lansing



5

ever, that staff attorneys do not issue unfavorable decisions.If, after additional development, the record does not sup-

port a disability finding, the case is placed back on the docket

to be scheduled for a hearing before an ALJ.

Personally, I have found the Senior Attorney Program to

be an unqualified success. On many occasions, I have re-

ceived notification that a claimant’s case was being reviewed

by a staff attorney. Often, after some small development, anupdated doctor’s report or an agreement to amend an onset

date, I would receive a favorable decision.

It now appears that we are witnessing the end of this suc-

cessful program in favor of another, far less promising, initia-

tive. The current program is scheduled to end on June 30,

1998. Although it appears that the program will be extended

for an additional nine months, through March 31, 1999, SSAhas planned many changes that will certainly diminish its ef-

fectiveness.

The most significant change is the drastic reduction in the

number of senior attorneys in the program. Nationwide, cur-

rently there are approximately 494 senior attorney positions.

SSA proposes to reduce that number to 309. Locally, the

loss of senior attorney positions is staggering. In the Detroit

OHA, for example, there are currently nine senior attor-neys. Under the new proposal, this number would be re-

duced to two. It appears that Lansing and Flint OHA’s will

have only two senior attorney positions, while the Oak Park

OHA will have two - three positions, and Grand Rapids will

have only one. Under the program as modified, senior attor-neys would do senior attorney work 100% of the time. They

would be expected to review and develop 75 cases per

month, and they would issue at least 20 senior attorney de-

cisions per month. The Regional Chief ALJ will select who

fills the slots, based on merit.

The deleterious effect that these changes will have upon

the Senior Attorney Program is obvious. In places like theDetroit OHA, two people will now be asked to do the work

that was previously performed by nine. Accordingly, many

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1

1 meritorious cases will be missed, and many more unneces-sary hearings will be scheduled. Many senior attorneys wil

also face a demotion from GS-13 to GS-12, thereby losing

thousands of dollars in pay each year. A corresponding nega-

tive effect on OHA morale and work product can be an

ticipated.

These proposed changes to the Senior Attorney Program

are not that surprising, however, as the program has alwaysfaced significant opposition. In some OHA’s the program

was never fully implemented, as the redirection of personnel

reduced the number of attorneys available for ALJ decision

drafting, and the issuance of senior attorney decisions took

some “easy” cases away from ALJ’s. Moreover, the Adju-dication Officer (AO) Project, which has produced fewer

favorable decisions, and, in many cases, has resulted in an-

other needless step on the way to a hearing, is favored over

the Senior Attorney Program by some policy makers withinSSA. It has been said that some opponents of the SeniorAttorney program would like to see no senior attorneys in

offices that also have the AO Project. Additionally, sources

both inside and close to SSA have indicated that the Dis-

ability Process Redesign Team desires to avoid competition

between the Senior Attorney Program and the AO Project

by shutting down the Senior Attorney Program altogether. Itis anticipated that the AO Project will be implemented na-

tionwide sometime after March 31, 1999.

It is my understanding that the entire motivation behind process redesign is the elimination of wasteful, unnecessary

aspects of the disability determination system. It is difficult

then to understand how the implementation of a needless

and wasteful project, at the expense of a beneficial and productive initiative, effectuates that goal. If ALJ hearings

are too costly, then SSA should take steps to ensure that

unnecessary hearings are avoided. Accordingly, the Senior

Attorney Program is a step in the right direction.

As claimant representatives, we should not allow this pro-

gram to be sacrificed without a fight. I would strongly urgeany and all Social Security disability attorneys to contac

their Congressman and Senators with letters of support.



6

of breath is a classic complaint of left heart failure. Left heart

failure is usually caused by hypertension. To meet a listing for

hypertension you must have end organ damage. The reason

there is end organ damage due to uncontrolled hypertension is

that the organs cannot take the increased blood pressure.

Right heart failure is generally caused by an underlying dis-

ease of the lungs themselves. Since the right side of the hearttakes in blood and pumps it to the lungs, the blood is less oxy-

genated and the heart enlarges to pump higher

volumes of blood to the lungs under the

theory that increased quantity in lower oxy-

genated blood will meet the demands of the

body. However, as the heart muscle enlarges

due to being overworked, it reaches a point

where it loses its efficiency in pumping. The

heart actually becomes less effective and

you become more short of breath.

The classic ankle edema is caused by both

left and right heart failure. This is due to the

venous pressure from the heart which liter-

ally forces fluid out of the vessels and into

the tissues.

Myocardial ischemia is a lack of oxygen in the heart tissue. It

may be short-term which would cause heart pain or long-term

which could produce death of the heart tissue. Angina means

pain. Angina pectoris means chest pain.

“Syndrome X” is caused when a patient has exertional chest

pain but does not have any positive findings on an arteriogram

or even an EKG. It is caused by vessels that are occluded that

are too small to be identified on angiography.

Murmurs are caused where a valve is stenotic (narrowed)

causing a turbulent flow of the blood or when the valve does

not close effectively, again causing a turbulent flow.

The doctor warned that many EKGs are misread. If you sus-

pected a client has heart problems with a normal EKG, you

should send the client to another hopefully more experienced

cardiologist.

Another problem is that on treadmill EKGs, you must have a

good baseline EKG, i.e., the EKG must be run while the patient

is standing and then when the patient is hyperventilating.

In the treadmill EKGs, the listing requires that there must be

changes in the EKG at five mets or less. One met (metabolic

equivalent) is laying still. Two to three mets is usual household

chores and five mets is more vigorous household chores. A

positive finding on a treadmill is the appearance of a flat or

down sloping S-T depression of one millimeter or more. I never

did understand what this meant until the seminar when the doctor

went over the basic reading of an EKG. The S-T segment is the

pause after the heart beats.

Echocardiograms show heart size. The LV diastolic diameter

in an echocardiogram is the diameter of the left ventricle. The

larger the diastolic diameter, the larger the heart is. The listing

calls for an LV diameter greater than 55 millimeters (5.5 centi-

meters).

The ejection fraction is the percent of contractility of the lef

ventricle. A normal ejection fraction is 50 percent to 60 per-cent. A weak heart muscle contracts less and therefore, that is

the reason why a 30 percent ejection frac-

tion is the benchmark for meeting a listing.

Another way to check the size of the hear

is with a chest x-ray. The ratio of the heart

relative to the thoracic cavity should be .5

or less.

Regarding blood vessels that supply the

heart muscle itself, there are three times

more vessels on the left side of the heart (the

stronger side) than the right side. The doc-tor indicated that if the left main is occluded

it is easier to meet a listing since this is a very

serious occlusion. The left main branches to the left anterior

descending and left circumflex and these two then branch off

into literally hundreds of smaller vessels.

Robert B. Chevalier, M.D., has been an expert in cardiology

and has also worked on a part-time basis for DDS. He is cur-

rently semiretired and works as a consultative physician for

the San Diego OHA. He said he would be happy to review any

stress tests, EKG or any cardiac-related question. He can be

reached through Steven R. Jacobs, an attorney belonging to NOSSCR in Indiana, who keeps in contact with him.

Functional Capacity Evaluations and Pain

The speaker discussed the work tolerance testing to deter-

mine the functional capacity. He pointed out something that we

have known for a long time—that these tests do not accurately

reflect the RFC of a client. These RFCs are standardized through

out the country. One of the standards is that if a person can lift

a maximum of 80 pounds, they extrapolate to report that the

person can lift 25 percent of this, i.e., 20 pounds, on a frequen

basis and 50 percent (40 pounds) on an occasional basis.

When testing a sit/stand option for an eight-hour period, they

have the patient stand for 33 minutes. If the person can stand

for the entire 33 minutes, that means the person can be on thei

feet for an entire eight-hour shift. If they can only stand for 15

minutes, that is extrapolated to mean that they can stand for

four hours out of an eight-hour workday. They do the same

thing with sitting, using the same extrapolated results. The tes

for sitting is that you sit in a chair and you are not allowed to

squirm.

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7

The bottom line is that these Work Tolerance Tests are not an

exact science. The best functional capacity evaluation is where

the person is tested over a two-day period. Quite often, a claimant

is sore the next day or unusually fatigued. Since most tests are

only three hours for one day, the speaker encouraged the attor-

ney to have the patient return the next day to physical therapy

so that the claimant’s fatigue or pain is adequately documented.

An anesthesiologist then talked about pain management con-

trol. Chronic pain is defined as pain that lasts more than six

months. He explained that there is a social, emotional and fi-

nancial consequence of chronic pain.

A dermatome is an area of body enervated by that particular

nerve. For instance, the thumb is one dermatome. The pinky is

another dermatome and the three middle fingers are a third

dermatome. He explained in the “olden days” when patients

complained about glove-like pain in their hand they were not

telling the truth because the hand involves three different der-

matomes. However, science has found that it is not that un-

usual to have more than one dermatome affected. Radiculopathyis pain in one or more of the dermatomes.

RSD is now called Chronic Regional Pain Syndrome. The

usual treatment is nerve blocks. One of the symptoms of CRPS

is allodynia. This is a non-painful stimulus that is perceived as

painful by the person. The example is just running your hand

over an area that causes intense pain. He said that typically

many of these patients will complain that they cannot even

stand to have covers on certain areas when in bed because of

the pain that it causes.

In morphine pumps, the doctor pointed out that you only

need one percent of the morphine that you normally need orally.In other words, if you need 100 milligrams to control your pain

orally, by a morphine pump you only need one milligram. With

a morphine pump it is programmed by the doctor, therefore,

the patient cannot normally control the amount of morphine

injected (unless they are cancer patients). Morphine pumps cost

between $15,000 and $20,000.

Mechanical Back Syndrome is pain in the lower back lasting

over six months. Facets in the spine are to prevent the spinal

column from rotating too far.

Recent Circuit Court Decisions

A claimant’s burden at Step 2 (the severe impairment step)

has been described as “de minimus.” Hawkins v Chater , 113

F3d 1162, 1169 (10th Cir 1997), quoting Williams v Bowen,

844 F2d 748, 751 (10th Cir 1988). If the claimant makes a de

minimus showing of medical severity, the ALJ must proceed to

the next step of the sequential evaluation process.

The RFC is not just the ability to lift weights occasionally,

rather it is the ability to perform the requisite physical activities

on a daily basis “in the sometimes competitive and stressful

conditions in which real people work in the real world.” Ingram

v Chater , 107 F3d 598, 604 (8th Cir 1997), citing McCov v

Schweiker , 683 F2d 1138, 1147 (8th Cir 1982). A good case on

retrospective opinion of an onset date is Likes v Callahan , which

ruled that retrospective medical opinions which are not cor

roborated by contemporaneous medical reports but which are

corroborated by lay evidence relating back to a past period of

disability, can support a finding of a past impairment. (There is

also a SSR on this which is either 88 or 8320).

One way to get a case remanded is to look at whether the

ALJ in his hypothetical asked for simple jobs. If your client can

only do simple jobs, according to the DOT regulations, they

cannot do the full range of the classification of work, i.e., sed

entary, light, etc. That is because simple jobs are listed on the

DOT as Level 1 jobs. The thing to do is to check the jobs that

the VE lists to determine whether they are Level 1 jobs or Leve

2 jobs. A case on this is Lucv v Chater , 113 F3d 905, 909 (8th

Cir 1997), which said that while a Level 1 reasoning ability

requires the ability to understand and carry out simple instructions, a Level 2 reasoning ability requires the ability to under-

stand and carry out detailed instructions. Since the evidence of

record demonstrated the claimant could only “follow simple

instructions,” he could not perform sedentary jobs with a rea-

soning level of 2.

In the evaluation of the 12.05 listing (mental retardation with

IQ of 70 or less), the second prong is met “when the claimant

has a physical or additional mental impairment that has more

than a slight or minimal effect on his ability to perform work.”Sird v Chater , 103 F3d 401, 403 (8th Cir 1997), quoting Cook

v Bowen, 797 F2d 687 (8th Cir 1986). Hawkins v Chater , 113

F3d 1162, 1165 (10th Cir 1997), gives the Commissioner “broadlatitude in ordering consultative examinations when there is a

direct conflict in the medical evidence which needs resolution

or when the medical evidence is inconclusive.”

Non-Disability Factors

This seminar talked about the disability benefits for children

widows, family maximum, etc. In a DAC claim, I did not real-

ize that once the claimant married, they would lose their ben

efits unless they were married to another disabled person. In a

widow’s claim, you do not have to be “legally” married to re-

ceive widow’s benefits. Social Security looks at the law of the

particular state where the widow lives. The test is whether the

widow (whether married or not) would receive a portion of the

intestate share of the spouse’s estate. If so, the widow will be

entitled to widow benefits.

One interesting fact is that Social Security is not obligated to

pay child’s benefits unless they are specifically notified (usu

ally on the application) that the claimant is claiming children’

benefits. If the claimant fails to list all of the children (whether

intentional or not) the child is out of luck. Further, if the child



8

or spouse of the claimant (usually ex-spouse of the claimant)

discovers this fact, and notifies Social Security, Social Security

is not obligated to pay any retro benefits from the onset of the

disability except for six months from when the dependent child

put Social Security on notice. If a disabled adult child has per-

formed SGA, the speaker believes that this would deep-six the

DAC claim. The speaker also talked about correcting the earn-

ings record. You have three years, three months and 15 days

after the close of the taxable year to correct the earnings records.

However, if the earnings records are specifically wages, and

you can prove your wages, there is no statute of limitations.

If the husband and wife own a business but the earnings are

reported in only one party, what do you do when the couple

divorces and the person without any reported earnings becomes

disabled? Social Security allows you to reallocate your wages

so that the divorced spouse who is disabled (and who initially

did not have any reported earnings) can obtain quarters of credit

for Title II. This is merely a shifting of earnings from one party

to the other. Further, there is a one year statute of limitations onthis.

Therefore, just because your spouse did not take a wage,

this does not mean that that person cannot obtain Title II ben-

efits.

The exception to the 20/40 rule is that if a person is 30 years

old or younger, you only need half of the quarters required

compared to someone over 30 years old. You can get Title II

benefits from as little as six quarters of credit.

Trends in Social Security Disability

Tom Bush, as the President of NOSSCR as well as the Chief Judge at the Appeals Council and the Associate Commissioner

of OHA (second to Apfel), spoke about the upcoming trends in

Social Security. The message was that with a decreased num-

ber of filings and decreased time in waiting for a hearing, attor-

ney fees are also going to be decreased. Further, there has been

an increase in favorable decisions at DDS at the first level which

is one of the goals of the process unification to have more

uniform decisions and to eliminate cases that should have been

approved at the first level.

The percentage of cases for favorable decisions by ALJs has

decreased too. In fact, in 1995 it was 65 percent and only two

years later in 1997 it was 54 percent and I am sure it is still

steadily declining.

There are 14,000 employees at OCO (originally ODIO). They

are becoming more automated in order to process claims faster.

It is interesting to note that 900 of the 1,400 district offices

now have a direct phone line to OCO.

The processing time at OCO has decreased from 30 days in

1997 (when they processed 462,000 claims) to 28 days now

where they project that they will process 500,000 claims. Fur-

ther, they are streamlining their process and hope to decrease

the steps to process a case from 14 down to six.

It is very important, we were told, that when we get paid, we

need to check the Social Security number on the check to make

sure that it matches the Social Security number of the claim-

ant. Apparently, if there is a keypunch error by Social Security

and they enter the wrong number, there will be two checksgenerated for attorney fees.

The OCO is also planning to be completely paperless by the

year 2,000. They receive over 100,000 pieces of mail each

week. The game plan is to scan all of these documents into a

computer so that things such as a Birth Certificate or 1696 can

be easily pulled up on the computer without having to actually

physically search a file.

Because the trend for process unification is to have uniform

decisions throughout all levels, it is important that we represen

the claimants at the earliest possible level. We should never

discourage claimants from seeking representation until “theyhave been denied two times.” The goal by DDS is to have more

people be granted at the DDS level which is apparently more

cost-effective and less time-consuming than at the OHA level

The Chief ALJ at OHA indicated that because we are living in

a balanced budget world, you are going to see a tightening

down of the number of cases that are paid. He believes tha

despite this, his main goal is that justice will be served on all of

the cases that are adjudicated. He defined justice (when he was

a general practitioner) as when he won the case and indicated

that when he lost the case, justice was circumvented.

There are currently 437,000 cases pending at the AppealsCouncil with the average waiting time at 18 months now. He

said that they are going toward computer automation but did

not discuss exactly what he meant by that. He said that all of

the ALJs will be getting lap-top computers.

One of the attorneys at the seminar who spoke indicated tha

one of his friends who is an ALJ, was sent down to the Ap-

peals Council on a temporary basis to help push some of the

decisions up. He indicated that he had just about enough time

to check for grammatical errors (less than five minutes) for

each decision that was written by a staff person. In other words

apparently the staff person writes up the decision and the ALJ

has very little input other than just to give a cursory review of

the decision and the memo that was generated as the basis for

the decision. The ALJ did not look at the file unless it was

recommended for remand or reversal. He said that the ALJs

are required to push out literally hundreds of decisions a week

Consultative Examinations

Are you turning the lemon into lemonade?

This was one of the best presentations at the San Diego semi



9

nar. It talked about what to do when a CE was scheduled. One

of the first things is to find out why it was scheduled. If the

reason is simply that DDS wants another opinion, you can cite

42 USC 423(D) which states that the Commissioner of Social

Security shall make every reasonable effort to obtain from the

individual’s treating physician all medical evidence including

diagnostic testing necessary in order to properly make a deter-

mination prior to evaluating medical evidence obtained from

any other source on a consultative basis.

In other words, if Social Security simply wants another opin-

ion because the one that has already been provided by your

attending physician shows that the claimant is disabled, they

are not allowed to request another CE.

The speaker talked about the importance of keeping a track

record on all CEs to determine whether it is one in which you

want to call DDS and obtain another CE or one in which you

can reasonably live with.

The treating physician is always the preferred source for aCE (20 CFR 404.151 9(H)). Therefore, when a CE is ordered,

if the claimant’s attending physician will perform a CE, you

have statutory authority to have this physician do the CE in-

stead of the one picked by Social Security.

You can ask for a change in the CE by contacting DDS. Do

not be afraid to do so. I routinely do so in psychological cases

when a case is referred to Dr. Talasila and Dr. Cappone in

Saginaw. I do not mind Dr. Plummer, although I do not think

he does a very in-depth evaluation.

The speaker also stressed that we should do a better job

preparing our clients for the CE. She said we should make surethat the claimant talks about all of their impairments without

exaggerating or sugarcoating. They should take all of their aids

to the CE, i.e., cane or eyeglasses. We should also describe the

nature of the CE, i.e., what the doctors put a claimant through

during a typical physical exam or a psychological evaluation.

One interesting point is that the speaker indicated we should

write to the CE in advance to do three things:

1. Send any pertinent evidence.

2. Summarize the evidence that you sent.

3. Give the CE a theory of your case.

Hopefully, the CE will review your brief letter that accompa-

nies the evidence to “get them up to speed” on the impairments

the claimant has. Further, it puts the doctor on notice that you

will be looking at his report and he may be less inclined to run

roughshod over your client.

The speaker talked about a couple ALJs who were upset

with the attorney by contacting the CE indicating that by giv-

ing their “spin” on the case it is not unethical to contact the CE.

The Appeals Council believes that providing the CE with re-

ports and framing it in the terms of the attorney’s “spin” on

how that claimant should be disabled is not unethical.

We talked briefly about subpoenaing the CE at the hearing. If

the CE does not show up at the hearing, you can move to strike

the report. However, as you know, in this circuit it is very

difficult, if not impossible, to have the ALJ sign the Subpoena

for the CE to attend the hearing.

The speaker talked about advising the client to refuse to at

tend the CE. This should be done when:

♦ There is enough evidence from the treating source al-

ready in the file.

♦ You have reasonable belief that the scheduled CE will

only hurt your case.

The rationale for refusing your client to attend a CE is that:

n The CE is premature since the regulations allow you to

recontact the treating physician for additional informa-

tion or clarification per 404.1512(E) which states:

“When the evidence we receive from your treating phy

sician or psychologist is inadequate for us to determine

whether you are disabled, we will need additional infor

mation to reach a determination or a decision. To obtain

the information we will take the following actions:

“1. We will first recontact your treating physician or

psychologist or other medical source to determin

whether the additional evidence we need is readily

available. We will seek additional evidence or clarifi

cation from your medical source when the report

from your medical source contains a conflict or am- biguity that must be resolved, the report does no

contain all the necessary information, or does no

appear to be based on medically acceptable clinica

or laboratory diagnostic techniques.”

n If you get a letter from the claimant’s attending physi-

cian outlining his objection to the CE.

The speaker talked about having a case dismissed when she

advised her client to refuse a CE. The Appeals Council said tha

this was an improper dismissal remanding it back to the ALJ.

Winning at the Appeals Council

The speaker indicated that you have to determine whether it

is easier for you to win at the Appeals Council or at the Distric

Court. Obviously, if it is very difficult to win a case at Distric

Court you want to put all of your effort into winning or re-

manding at the Appeals Council.

Federal Court is an appropriate forum to bring a case where

you have the law on your side or you have strong medical. The

Appeals Council is a better forum for technical issues.

The speaker at the Appeals Council reminded us you are writing



10

to a non-attorney who does not understand the technical as-

pects of the law. He said do not bother wasting your time citing

case law. The only thing that these people know are the SSRs.

In fact, they know them much better than the ALJs. There-

fore, you want to focus on these. Also, another ripe area is to

look at inconsistencies within the decision itself, i.e., anyplace

where the Judge contradicts himself either in the written deci-

sion or comparing his written decision with his PRTF.

One of the most common issues to prevail in District Court

is a failure by the ALJ to articulate his reasons for the denial.

If a person is close to 50 years old and the ALJ says that the

claimant can only do sedentary work once the person turns 50

(in the cases pending at the Appeals Council), you have a strong

argument that the claimant is now disabled since they have

turned 50 years old using res judicata principals.

A shortcut to winning in a District Court case is to:

n Document that the claimant cannot perform their past

relevant work.

n Then argue that there is no explanation as to the ALJ’s

RFC, usually a light RFC or greater. This way, you do

not even reach the treating physician rule, the credibility

issues, the grids, or impairment listings, etc.

The remaining part of the seminar dealt with the 1996 SSRs.

It was again emphasized at this seminar (as well as the one in

Chicago) how important it is to know the 1996 rulings. He

highlighted some of the most important gems from the SSRs

which are as follows:

1. SSR 96-2p: “For a medical opinion to be well-supported

by medically acceptable clinical and laboratory diagnostic

techniques, it is not necessary that the opinion be fully sup-

ported by such evidence.”

The evidence does not have to be consistent with all other

evidence as long as there is no other substantial evidence in

the case record that contradicts or conflicts with the opinion.

In many cases, a treating source’s medical opinion will be

entitled to the greatest weight and should be adopted, even if

it does not meet the test for controlling weight.

In some cases, a treating source’s medical opinion will be

given controlling weight.

2. SSR 96-4p: You can use this rule to keep the case in the

grids or get it out of the grids if you believe the claimant

meets a listing. An individual’s symptoms, however, can cause

limitations or restrictions that are classified as exertional, non-

exertional or a combination of both. For example, pain can

result in an exertional limitation if it limits the ability to per-

form one of the strength activities, i.e., lifting, or a non-

exertional limitation if it limits the ability to perform non-

strength activities, i.e., fingering or concentrating.

3. SSR 96-5p: Medical sources (such as CEs) may provide

opinions that the individual is limited to sedentary, light, etc.

work or similar statements that appear to use the terms set

out in the regulations and rulings to describe the exertional

levels of maximum sustained work capability.

The adjudicators must not assume that a medical source us-

ing terms such as, sedentary and light is aware of our definitions of these terms. The judgment regarding the extent to

which an individual is able to perform exertional ranges of

work goes beyond medical judgment regarding what an indi-

vidual can still do and is a finding that may be dispositive o

the issue of disability. In other words, if the CE indicates tha

the claimant can perform “light work” do they mean the legal

standard of light work or do they just mean that the person

can do a very minimal exertional type of work. The claimant’s

attorney is allowed to send interrogatories to the medical

source to determine whether they understand the statutory

definition of light work.

OHA has specific requirements for recontacting treatingsources. The regulations state that “because treating source

evidence is important, if the evidence does not support a

treating source’s opinion on any issue reserved by the

Commissioner, i.e., whether the person is disabled, and

the adjudicator cannot ascertain the basis of the opinion

from the case record, the adjudicator must make every

reasonable effort to recontact the source for clarifica-

tion of the reasons for the opinion.”

4. SSR 96-7p: This is one of the more common reasons that

a case is remanded by the Appeals Council. This is the cred

ibility ruling. In a footnote it states: “The adjudicator mustdevelop evidence regarding the possibility of a medically de

terminable mental impairment when the record contains in

formation to suggest that such an impairment exists, and the

individual alleges pain or other symptoms, but the medical

signs and laboratory findings do not substantiate any physi-

cal impairment capable of producing the pain or other symp-

tom. In other words, the ALJ must look at the emotional

factors regarding pain.”

This ruling lists the seven factors that the adjudicator “must

consider in addition to the objective medical evidence when

assessing the credibility of the individual’s statements.” Rarely

does the decision ever state the factors. Further, the rulingindicates that it is not sufficient to make a conclusory state-

ment, that the individual’s allegations have been considered

or that the allegations are not credible. It is also not enough

for the adjudicator simply to recite the factors that are de-

scribed in the regulations for evaluating symptoms.



11

1 001-00 THRU 028-24 (410) 966-2930 (410) 966-2933 (410) 966-2916

2 028-25 THRU 057-26 (410) 966-2958 (410) 966-4591 (410) 966-2946

3 057-27 THRU 086-46 (410) 966-2986 (410) 966-4592 (410) 966-2973

4 086-47 THRU 117-18 (410) 966-2721 (410) 966-0884 (410) 966-2706

5 117-19 THRU 145-26 (410) 966-2753 (410) 966-4594 (410) 966-2739

6 145-27 THRU 171-22 (410) 966-2783 (410) 966-4328 (410) 966-2768

7 171-23 THRU 197-52 (410) 966-2861 (410) 966-1527 (410) 966-64658 197-53 THRU 219-30 (410) 966-6471 (410) 966-0490 (410) 966-6469

9 219-31 THRU 230-50 (410) 966-6513 (410) 966-3023 (410) 966-6472

10 230-51 THRU 236-98 (410) 966-1662 (410) 966-5260 (410) 966-1648

11 236-99 THRU 245-98 (410) 966-1691 (410) 966-5261 (410) 966-1676

12 245-99 THRU 253-90 (410) 966-2628 (410) 966-5262 (410) 966-2614

13 253-91 THRU 261-95 (410) 966-3415 (410) 966-0621 (410) 966-3400

14 261-96 THRU 272-38 (410) 966-3436 (410) 966-5264 (410) 966-3430

15 272-39 THRU 293-32 (410) 966-3474 (410) 966-5265 (410) 966-3460

16 293-33 THRU 312-22 (410) 966-2521 (410) 966-5267 (410) 966-2507

17 312-23 THRU 334-58 (410) 966-2551 (410) 966-5273 (410) 966-2536

18 334-59 THRU 360-26 (410) 966-2581 (410) 966-5274 (410) 966-2565

19 360-27 THRU 378-48 (410) 966-2375 (410) 966-1398 (410) 966-2362

20 378-49 THRU 396-62 (410) 966-2404 (410) 966-2386 (410) 966-2391

21 396-63 THRU 406-23 (410) 966-2433 (410) 966-2382 (410) 966-2419

22 406-24 THRU 414-62 (410) 966-3933 (410) 966-5644 (410) 966-3919

23 414-63 THRU 424-34 (410) 996-3962 (410) 966-1537 (410) 966-3948

24 424-35 THRU 431-45 (410) 996-3992 (410) 966-1542 (410) 966-3978

25 431-46 THRU 439-41 (410) 966-2223 (410) 966-0244 (410) 966-2209

26 439-42 THRU 456-25 (410) 966-2251 (410) 966-5570 (410) 966-2238

27 456-26 THRU 468-26 (410) 966-2280 (410) 966-1775 (410) 966-2267

28 468-27 THRU 489-22 (410) 966-2839 (410) 966-0229 (410) 966-2824

29 489-23 THRU 506-38 (410) 966-2870 (410) 966-4656 (410) 966-3123

30 506-39 THRU 524-29 (410) 966-2903 (410) 966-4341 (410) 966-2885

31 524-30 THRU 537-42 (410) 966-3051 (410) 966-4658 (410) 966-3037

32 537-43 THRU 550-29 (410) 966-3016 (410) 966-1867 (410) 966-3002

33 550-30 THRU 559-82 (410) 966-3080 (410) 966-1873 (410) 966-3066

34 559-83 THRU 571-99 (410) 966-2483 (410) 966-4650 (410) 966-2467

35 572-00 THRU 582-69 (410) 966-4111 (410) 966-4652 (410) 966-2497

36 582-70 THRU 728-14 (410) 966-4140 (410) 966-4651 (410) 966-4126

Editor’s Note: For those of you who have been having difficulty getting your attorneys fees on Title II cases and do not know whom

to call, below is a list of the Module telephone numbers from ODIO. The numbers are sorted according to the first three digits of the

claimant’s Social Security Number. Often, the faxing of a 1696 form (Appointment of Representative Form) or a fee agreement will

clear up any payment problems. Our thanks to Thomas M. Stellard for providing the list.

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OODDIIOODDIIOODDIIOODDIIOODDIIOO MMoodduullee TTOO MMoodduullee TTOO MMoodduullee TTOO MMoodduullee TTOO MMoodduullee TTeelleepphhoonnee NNuummbbeerrsseelleepphhoonnee NNuummbbeerrsseelleepphhoonnee NNuummbbeerrsseelleepphhoonnee NNuummbbeerrsseelleepphhoonnee NNuummbbeerrss

OODDIIOODDIIOODDIIOODDIIOODDIIOO MMoodduullee TTOO MMoodduullee TTOO MMoodduullee TTOO MMoodduullee TTOO MMoodduullee TTeelleepphhoonnee NNuummbbeerrsseelleepphhoonnee NNuummbbeerrsseelleepphhoonnee NNuummbbeerrsseelleepphhoonnee NNuummbbeerrsseelleepphhoonnee NNuummbbeerrss

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