Comparing and Contrasting Medical Tips in ERISA and Social Security Disability

Welcome to Season 4, Episode 26 of Winning Isn't Easy. In this episode, we'll dive into the complicated topic of "Comparing and Contrasting Medical Tips in ERISA and Social Security Disability." 

Host Nancy L. Cavey, a seasoned attorney with extensive experience in disability claims, discusses the various medical tips that apply to ERISA disability claims, and Social Security disability claims. One might think that the approach to treating and documenting medical conditions, and how they factor into claims, would be the same for any disability case. However, that isn't necessarily the case. While there may be comparable similarities, there are also contrasting medical tips to be aware of in ERISA disability claims, versus Social Security disability claims. Your host, Nancy L. Cavey, will walk through these tips.

In this episode, we'll cover the following topics:

1 - Comparing and Contrasting Your Obligation to Get Medical Treatment in an ERISA Disability Claim and a Social Security Disability Claim

2 - What Are the Five Things You Must Do That Will Help You Stay On Claim and Be Paid in Your ERISA Disability Claim?

3 - What Are the Five Factors That Must Be Met before Social Security Must Give Your Treating Doctor’s Opinions Controlling Weight in Your Social Security Disability Claim?

Whether you're a claimant, or simply seeking valuable insights into the disability claims landscape, this episode provides essential guidance to help you succeed in your journey. Don't miss it.


Resources Mentioned In This Episode:

LINK TO ROBBED OF YOUR PEACE OF MIND: https://caveylaw.com/get-free-reports/get-disability-book/

LINK TO THE DISABILITY INSURANCE CLAIM SURVIVAL GUIDE FOR PROFESSIONALS: https://caveylaw.com/get-free-reports/disability-insurance-claim-survival-guide-professionals/

FREE CONSULT LINK: https://caveylaw.com/contact-us/


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Please remember that the content shared is for informational purposes only, and should not replace personalized legal advice or guidance from qualified professionals.

Transcript

Speaker A [00:00:11]:
 Hey, I'm Nancy Cavey, national individual disability and Arista disability attorney. Welcome to Winning isn't easy before we get started, I've got to give you a legal disclaimer. This podcast is not legal advice. The Florida Bar association says I have to tell you that. So now I've said it, I want to let you know that nothing will ever prevent me from giving you an easy to understand overview of the disability insurance world, games the carriers play, and what you need to know to get the disability benefits you deserve. So off we go. Today I'm going to be comparing and contrasting the obligations of receiving medical treatment in an ERISA and Social Security disability claim. And I'm going to be walking you through the five medically based tips and factors that I think are important for you to stay on track in your claim, regardless of whether or not it's ERISA or Social Security disability.
 
 Speaker A [00:01:10]:
 So in essence, what I'm going to be talking about first is comparing and contrasting your obligation to get medical treatment in an arrested disability claim at a Social Security disability claim. Second, I'm going to talk about what are the five things that you have to do to stay on claim and be paid in your ERISA disability claim? And then lastly, what are the five factors that have to be met before the Social Security Administration has to give your treating physicians opinions controlling weight in your Social Security disability claim? Got it? Now, before we dive into this topic, which I think is very important because most people who have an ERISA claim also have a Social Security claim, let's just, you know, take a break and then we're going to come back and dive into this, get out some note paper because I'm going to be giving you some very important tips and food for thought. All right, see you in a minute.
 
 Speaker B [00:02:07]:
 Have you been robbed of your peace of mind from your disability insurance carrier? You owe it to yourself to get a copy of robbed of your peace of mind, which provides you with everything you need to know about the long term disability claim process. Request your free copy of the book@kvlaw.com today.
 
 Speaker A [00:02:26]:
 Welcome back. Let's talk about comparing and contrasting your obligation to get medical treatment in an ERISA disability claim with your obligation in a Social Security disability claim. Now, before we took our break, I alluded to the fact that many ERISA insurance policies or plans require that you get reasonable and appropriate medical treatment as a condition of continuing to get your monthly long term disability benefits. Now, additionally, these policies require that you apply for Social Security disability benefits. So we have two obligations that you have on a contractual basis that if you don't comply with, gives potentially the disability insurance carrier an easy win because they can deny your claim for breach of those obligations, contractual obligations before they even get to the question of whether or not you meet the standard of disability. So is the obligation to get medical treatment in an ERISA case the same as it is in a Social Security disability claim? Now I'm going to start out by talking about Social Security, because Social Security will rarely deny a claim on the basis that the applicant failed to follow prescribed treatment and therefore is not disabled. But poor compliance with medical instructions will be used by claims examiners at the initial application and the request for reconsideration level and even judges, when they're making credibility determinations. That credibility determination based on your non compliance with medical treatment can result in claims denials.
 
 Speaker A [00:04:04]:
 So why is that? Well, many times claims examiners or the judge will reason that you must not be as disabled as you claim you are. Otherwise you would have followed the prescribed treatment and they will find that you're not believable. In other words, if you're in so much pain and you can't work, then you would have been compliant with the medical treatment and therefore the judge will say, I just don't believe you or I'm not going to give significant weight to your complaints. Now, the Social Security Administration has regulations that will address that issue. In fact, there is Social Security ruling 96 seven PKD and it deals with a failure to prescribe to follow prescribed medical treatment. And it suggests that your statement about your symptoms and your functionality can be less credible if the level of frequency of treatments is inconsistent with the level of your complaints, or if the medical reports or records show that you're not following the treatment as prescribed and there are no good reasons for this failure. The ruling suggests that a Ydezenhe, a claims adjudicator or a judge shouldn't draw any inferences about your symptoms and functionality without first considering any explanation that you might offer or any other information in the case record that would explain this infrequent or irregular medical visits or the failure to comply with treatment. Social Security Regulation 9067 P requires that the claims examiner ask if there's some good reasons why you haven't been seeking that medical treatment.
 
 Speaker A [00:05:33]:
 So what are those acceptable reasons for not being fully compliant in a Social Security case? Well, one of the reasons is that your daily activities of life are so structured by you to minimize your symptoms. So in other words, you are moderating or just doing things. If you will, in a way that's structured to minimize your symptoms. So, for example, you may not be cleaning the house every day. In fact, you may only be able to wipe down the kitchen counters. And the fact that you are modifying your activity, your daily activity, to minimize your symptoms is a factor. Now, also another reason. What might be is the symptoms may not be severe enough to prevent you from seeking ongoing medical treatment because you can relieve those symptoms with over the counter medication.
 
 Speaker A [00:06:27]:
 I'll tell you, I don't like that particular rationale because then the judges will say, well, my goodness, if your symptoms can be relieved with over the counter medication, then you ought to be able to work. Another reason might be that you're not taking the prescription medication because the side effects are less tolerable than the symptoms. In other words, the medication might make you sick, it might make you drowsy, it may make you feel worse than your actual symptoms. And that's something, of course, obviously would have to be in your medical records. And of course, one of the common reasons I hear is that you can't afford the treatment or you may not have access to free or low cost medical services. That might be the case. But I think again, in your medical records, you should be documenting the fact that you don't have insurance or the difficulty you're having paying for the medical treatment that you're getting, and as a result, you're rationing your care. In other words, you're not seeing the documentation doctor as frequently because you would rather save that money to spend it on the medication the doctor's prescribing.
 
 Speaker A [00:07:29]:
 Another good reason is that you may have been advised that there's no further effective treatment that can be prescribed that would benefit them. Now, that's a good reason and a bad reason. What I mean by that, if, for example, you have a spine issue and you have been prescribed physical therapy, but you can no longer afford the physical therapy, it would be helpful that you are getting physical therapy at home. In other words, you're doing home exercises. And even if you may be getting minimal benefit from it, I will tell you that judges expect that you are doing some sort of self care, if you will, to help minimize your symptoms. And of course, another reason might be that the treatment might be contrary to the teaching and tenants of your particular religion, or you may have undergone multiple surgeries without success and you're reluctant to undergo repeat surgeries. That's one that does resonate with the judges. And again, just because the treatment has been recommended, the surgery has been recommended, the judge doesn't necessarily or Salis Creek expect that you will have that surgery, but they do expect in the medical records an explanation as to why you don't want the surgery or repeat surgery and what treatment you are in fact getting that helps modulate or reduce your pain.
 
 Speaker A [00:08:54]:
 Now, another reason, and I hear this all the time, is that the treatment might be significant and could result in your death, like open heart surgery. Now that's a very risky surgery. Organ transplants are risky surgeries. So if there is a significant risk involved with the medical procedure, again, that can be a good reason for not getting that treatment. But you've got to document that. And of course, if the treatment involves something like amputation, the Social Security Administration isn't going to require that you have an amputation. And one of the final reasons would be that the impact of having treatment could result in greater impairment. So what do I mean by that? So let's say you've got cataracts in one eye, let's say the right eye, and you're blind in the left.
 
 Speaker A [00:09:46]:
 If you have a surgery on that cataract that's not successful, you would obviously be blind. So again, these are just some of the few reasons that the social administration or the judge will look at and potentially excuse either the lack of treatment or the frequency of the treatment. But I'll tell you, if the claims examiner or the judge finds that there's no credible explanation as to why you're not compliant, you're going to see, as I said, a claims denial based on a lack of your credibility. Those denials are really hard to appeal, particularly one in which the judge has found that you the nature of your symptoms, the intensity of your symptoms, the frequency of your symptoms is just not consistent or is the result of your non compliance and then ultimately says, I just don't believe the applicant. Now on the other hand, if there's a credible explanation as to why you are not compliant, that should be addressed in your medical records. Just because you say this or that doesn't necessarily mean that the judge is going to accept what you have to say about what your doctor said. So make sure that your doctor is documenting the reasons why you may not be compliant with medical care that will help with that particular issue. Now, will the ERISA disability carrier take the same approach? Heck no.
 
 Speaker A [00:11:09]:
 Disability insurance claims are month to month, and therefore the disability carrier expects that you'll be getting medical care with a frequency and a level of care consistent with your claimed disability. So let's compare and contrast. Daily activities are structured to minimize your symptoms. And so what the carrier is going to say, again, much like Social Security, if you can minimize your daily activities or structure them in such a fashion that reduces your pain, you can work. Symptoms may not be severe enough to prompt you to get ongoing medical treatment or attention, or it can be relieved with over the counter medication. No treatment is a violation of the terms of many disability insurance policies or plans, even if the symptoms can be relieved with over the counter medication and they'll say, well, no reason why you can't work. The applicant may not take prescribed medication because the side effects are less tolerable. Now, the carrier may suggest that there's other medication that you could take that has no or little side effects that would allow you to work.
 
 Speaker A [00:12:10]:
 And I see that often if you're having that particular issue, you want to make sure it's addressed with your doctor, and your doctor is doing different trials of medication, noting to the degree to which that medication may or may not have been successful. The other reason, applicant may not be able to afford treatment or doesn't have access to low cost care. Carrier is going to say, too bad, so sad. The policy requires that you get medical treatment. So go get the medical treatment. If you got to go to the health department, well, we'll consider it, but if you get no medical treatment, we definitely will deny this claim since you're non compliant. How about the argument that you've been advised that there's no further effective treatment that could be, that can be prescribed that will benefit you? The carrier's argument is there's always some form of treatment that you should be getting, even if it doesn't necessarily benefit you. And I know that sounds crazy, sort of goes back to the you should be doing something approach to treatment.
 
 Speaker A [00:13:09]:
 So see the doctor once every couple months. Tell them what you've been doing in terms of activities of daily living, the way you've tried to modulate your activity, the fact that you're still having pain, and the fact that you're still trying to be compliant with their recommendations, including home exercise care. But again, that's a slippery slope. I've never had this arise in the context of an ERISA case, the argument that the treatment is contrary to the teaching or tenets of an individual's religion. But I would presume that the carrier would say that we're notwithstanding the tenets of your religion, you still have an obligation to get treatment, and there is certainly an alternate alternative to that treatment that would not violate your religious teachings or the tenets of your religion. The applicant may have undergone surgery with unsuccessful results and you're reluctant to undergo surgery. Well, that will only go so far. I mean, the courts recognize that you don't have to have surgery.
 
 Speaker A [00:14:11]:
 You can't be forced to have surgery. But even the courts will expect that you're getting some form of conservative care in the form of therapies, medications or injections. The argument that the treatment might have significant complications is one that the courts do recognize. But again, the courts are going to expect that you exhaust all conservative treatment or they'll say you are non compliant with the terms of the policy. Well, how about the amputation issue, for example? I think the carrier would accept that explanation. But again, they're still going to expect conservative treatment, including injections and the use of pain medication and therapy. How about that argument that the consequences of a surgical procedure could be catastrophic? You know, you have that cataract surgery and if you lose the vision in that eye, you're blind. Well, I see the carriers twist that one around and they'll say, aren't you sure there are some aren't assistive devices that would help you, for example, with your vision? Again, if you find yourself in any of these situations where you've got a question about what your policy says, about the nature of the medical care, the frequency or duration, and you're faced with these practical problems, you need the advice of an experienced or risked disability attorney because the carrier or plan can be very inflexible when it comes to that requirement.
 
 Speaker A [00:15:36]:
 Many times I'm trying to negotiate a compromise, if you will, with the carrier about what it is our client is expected to get under the terms of the policy and what realistically they can get in view of some of these complications. Now that was a lot of information. I'm going to take a break and let you digest that and we'll be back in a second. Welcome back to winning isn't easy. So what are the five things that you must do that will help you stay on claim and be paid in your ERISA disability claim? Well, I want to say congratulations if your disability carrier plan has approved your claim and you've gotten your first check, but now you're wondering how you're going to stay on claim and continue to be paid to, I want to talk with you about the five things that you have to do that will help you continue to get your benefits. One, you need to continue to get regular medical treatment and be compliant with that treatment. Under the terms of your ERISA policy or plan, you are required to get regular medical treatment and be compliant with your doctor's recommendations. They don't really care if you're having financial difficulties and they can't afford to see the doctor or get all the prescriptions.
 
 Speaker A [00:17:04]:
 Under the terms of your policy or plan, you're required to get appropriate and reasonable medical treatment. If you don't, that failure in and of itself can be the basis of the denial, notwithstanding the fact that they are paying you your disability benefits. Now, the next thing that you want to do is to give your doctor an accurate and complete history of your symptoms and limitations and how they're impacting your ability to function in terms of your activities of daily living. In my view, your medical record should be telling a story of your symptoms and your functionality. And it might be, for example, that you have back pain that prevents you from sitting and as a result you've got to alternate sitting and standing. It might be that you have difficulty standing at the kitchen sink, you know, doing dishes because of your back or your leg pain, and you have to use a stool to sit on while you're doing the dishes. You might be unable to vacuum and as a result you've got a wrong that your cat or dog rides around while the ramba is doing its thing. You got to make sure that the records are telling that story.
 
 Speaker A [00:18:12]:
 The third thing you need to do is keep your lawyer updated about your medical appointments. Why? Well, as a risked disability attorney who is whose job it is to try to keep you on claim and diary, I want to get your medical records and I want to submit them to the carrier. Now, many times I will find that disability carriers or plans are really unsympathetic with the time it takes to get your medical records. And I will tell you it can take four to six weeks sometimes to get medical records. So the quicker you let your lawyer know that you're seeing a provider, the quicker they can get that medical record request out and keep track of it. That way, when the carrier or plan demands your records, we can quickly comply with that request. Number four, if the disability carrier or plan asks you to fill out disability forms, contact your attorney immediately. Now, just because the carrier plan said, oh, we're going to pay doesn't mean that they're going to continue to pay and doesn't mean that they're going to stop continuing to ask for information or stop looking for a reason to deny your claim.
 
 Speaker A [00:19:17]:
 You're going to be asked to complete these activity of daily living forms. And you know, I think these forms are traps. That's why when my clients are getting their disability benefits, we're looking at the activity of daily living forms and the medical records to see whether or not they're consistent. Is what you're telling your doctor consistent with what you're reporting on the ADL form about your activities? Now I will tell you, this is where carriers and plans are sneaky. They don't always tell your lawyer that they're asking for this information. So don't think that we know because they're trying to sandbag us so they can screw you. So what I want you to do, and you should be doing with your lawyer, if you have one, is to make sure that your lawyer knows that you're getting the form, complete the form and then have your lawyer review the form. You can make all sorts of innocuous mistakes on these forms that can result in a claim denial or termination.
 
 Speaker A [00:20:16]:
 Now, many lawyers, myself, including, charge a monitoring fee to manage the forms and deal with a disability carrier. I think it is worth the monitoring fee to have the attorney keeping your claim on track. Number five, as I've said, keep in contact with your attorney. Now, you don't have to call me or your attorney every time you see a doctor, but you should let your attorney know if any of the following is happening. If you start seeing a new doctor, if you've been seen in the emergency room, if you've been hospitalized, if there's been a change in your medical condition so that you've either gotten worse or better, you move or you change phone numbers. You return to work, you stop work. You're contacted by somebody from the disability carrier plan. You get a notice that you've been scheduled for a not so not so independent medical examination or functional capacity evaluation.
 
 Speaker A [00:21:12]:
 You get a notice from the disability carrier plan that you are not disabled and you only have 180 days in which to appeal. You get forms from the carrier or the plan to fill out. You get correspondence from the carrier or the plan that you don't understand. You can see that it takes teamwork not only to get your benefits, but to stay on claim and get the disability benefits you bought. Getting those five things will help you have financial peace of mind. Let's take a break.
 
 Speaker B [00:21:41]:
 Are you a professional with questions about your individual disability policy? You need the disability insurance claim survival guide for professionals. This book gives you a comprehensive understanding of your disability policy with tips and to dos regarding your disability application that will assist you in submitting a winning disability application. This is one you won't want to miss for the next 24 hours. We are giving away free copies of the disability insurance claims survival guide for professionals. Order yours today@disabilityclaimsforprofessionals.com.
 
 Speaker A [00:22:14]:
 Dot welcome back to winning isn't easy what are the five factors that must be met before the Social Security Administration must give your treating physician's opinion controlling weight in your Social Security claim now, as I've said before many times, people who have ERISA disability policies or plans are required to apply for their Social Security disability benefits. Why carrier has the right to reduce your benefits by the receipt of your Social Security benefits and potentially that of your children. The carrier is going to use this sort of as a whipsaw. And what do I mean by that? The carrier may ask to look at your Social Security disability claims file, ultimately, so they'll get all the medical records that are in that claims file. And of course, they're getting your medical records as you are getting treatment in your ERISA disability claim. And much like an ERISA, there is no treating physician rule in a Social Security case. However, the opinions of your physicians are crucial to the success of your claim and can influence how your risk of disability claim is handled by the carrier or plan. Now, what I think the most important thing you can do is have your doctor complete a residual functional capacity form as part of an ERISA disability claim.
 
 Speaker A [00:23:41]:
 Your doctor is going to be asked to fill out attending physician statement forms, and if you've seen those, they don't ask the right questions. Social Security lawyers such as myself have developed residual functional capacity forms based on specific medical conditions. And guess what? Those forms ask the right questions about the nature of your symptoms, the severity of your symptoms, the diagnosis, the prognosis, and what you can still do from a physical, mental standpoint or a cognitive standpoint despite your impairments. That's what's crucial, both, in my view, in an ERISA disability claim and in a Social Security disability claim. Under the Social Security regulations, the medical opinion of your physician about the nature and severity of your impairment is entitled to deference and may be even given controlling weight. So what is controlling weight? Is this a diet issue? No. The Social Security Administration and a Social Security judge, if you get that far, are going to review your medical records and the opinions of physicians to determine whether they should be given controlling weight. Well, who else is involved in this case? Social Security, much like the disability carrier, will have medical reviewers who will review the records never see you, though.
 
 Speaker A [00:24:56]:
 That can happen in both an ERISA case and a Social Security case. But the question becomes, if you've got Social Security medical reviewers. You may have a Social Security consulting exam, and you've got the treating physician who gets controlling weight. What opinion is going to be the ultimate outcome or influencer in your decision? And again, this is akin a bit to the analysis in an ERISA case. So there are five factors that the Social Security administration considers. One, is the doctor considered to be an acceptable medical source? What's that? Well, not all doctors are qualified to give an opinion under Social Security rules. An acceptable medical source is a physician, psychologist, podiatrist, optometrist, a qualified speech language pathologist. But guess who isn't? Chiropractors.
 
 Speaker A [00:25:48]:
 Nurse practitioners, audiologists, pas therapists, acupuncturists, nutritionists, nitropaths. Those are just some examples of medical providers whose opinion has no weight at all in the context of a Social Security case, and for the most part, little weight other than that of a chiropractor and a PA in an arrested disability claim. Now, if you have a case, for example, where you've got a back injury and you're treating with a chiropractor, the ERISA carrier or plan will accept the chiropractor's opinions. In the context of the Social Security case, that physician's opinion doesn't carry any weight at all. So obviously you want to make sure you're seeing the right doctor. Now, number two, is the doctor a treating source? If they saw you for a one time evaluation, if they didn't treat you, then they're not going to be considered to be a treating source. Number two, the doctor's opinion about your nature and severity of your impairment, your symptoms, your diagnosis and prognosis is crucial, in my view, in both an ERISA disability case and a Social Security disability case. But much like an ERISA case, the Social Security Administration doesn't really care if your doctor says that you're disabled and you can't work, because in the ERISA context, the standard is, are you unable to do your own occupation or any occupation? And in the Social Security case, the standard is whether or not you meet the five step sequential evaluation.
 
 Speaker A [00:27:23]:
 And in both instances, the ERISA plan or policy, and Social Security is the ultimate decider of that particular question. So whether the doctor says you're disabled or not is irrelevant. What's important is the restrictions and limitations. Now, the fourth factor is whether or not your doctor's opinion is well supported. And I find that this is applicable in both the risks of disability and Social Security cases. They're going to review the doctor's opinion to see whether or not, it's supported by medically acceptable clinical, laboratory and diagnostic studies. They're going to look at your medical records and determine whether or not your records support the limitations assigned by the doctor, whether that's consistent with your daily activity report to the doctor, and then all of this. As to whether it's consistent, does it paint the same picture? The treating physician's opinion is not inconsistent with substantial evidence is another factor.
 
 Speaker A [00:28:18]:
 What does that mean? Well, what it means in English is that the medical opinion need not be consistent with all other evidence as long as it's. As no other substantial evidence contradicts it or conflicts with it. That's not what happens, of course, in an ERISA disability case, because they want substantial evidence all the time, every day, 24 hours, seven days a week. See, in the context of Social Security cases, that doctors opinions will be rejected because of this inconsistent, or that there is, quote, other substantial evidence that contradicts the treating physicians opinions, like operative report findings or MRI findings. So you need to understand that these five rules are obviously applicable in Social Security case, but they do sort of play out in the context of an ERISA case. So what happens in a Social Security case if the opinion of the treating physician doesn't meet this test? Well, even if the Social Security Administration or the judge doesn't give your treating doctors opinion controlling weight, they have to weigh that opinion using other Social Security regulations because Social Security has recognized the special status of a treating physician and say that they should be given greater weight even when they're unsupported or contradicted as compared to a physician who never saw you. So, in other words, if you have an opinion of a peer review doctor, Social Security doctor who's reviewed the medical records never saw you. But then you have a doctor who saw you, but whose findings may not be as significant as what the peer review doctor says are in your records, then these regulations say, okay, well, even though the opinion of the treating physician isn't necessarily materially supported, as much as we'd like, we're going to give it weight, and we can give it greater weight than the peer review doctor who never saw you.
 
 Speaker A [00:30:20]:
 Now, that's a game that I think that is a whipsaw at every level of a Social Security case. And you can imagine if a judge decides they want to deny the case, what they will do is reject the treating physician's opinion based on materiality and substance and accept the opinion of a peer reviewed doctor who never saw you. And again, I find that approach to be similar to ERISA disability cases. Now, you need to also understand that we do try to attack those so security state agency doctors I just tried a case today where my client has back problems, neck problems, wrist problems, chronic fatigue problems, and the state the doctor was a urologist. Well, there's no relationship between what a urologist treats and any of the complaints that my clients had, but this urologist said my client could do sedentary work, which had resulted in a claims denial. Obviously, at the hearing, I'm objecting to this state agency doctor as not being competent and his opinions not supported based on the medical records. So you can see again, this is a game that Social Security will play and ERISA disability carriers or plans will play. I hope that you've enjoyed this week's episode.
 
 Speaker A [00:31:44]:
 It's been chock full of medical information that I think is really important for you to understand, not only in the context of your Social Security claim, but your ERISA disability claim. Please like this page, leave a review, share it with your family and friends, and please subscribe to this podcast. That way you'll be notified every time a new episode comes out. Tune in next week for another insightful episode of winning isn't easy.