Disability Articles By Attorney Scott Davis


Scott E. Davis is a social security and long-term disability insurance attorney in Scottsdale, Arizona. The majority of his disability practice is devoted to representing individuals with FMS and/or CFIDS.  Scott has extensive experience in handling FMS/CFIDS cases and does represent individuals throughout the United States.  In most cases he charges a fee only if his client obtains benefits.  He invites your questions and inquiries regarding representation at (480) 367-1601, or via email: harris.davis@azbar.org

CFS
Obtaining Disability Benefits. . .David versus Goliath?
FMS


Anyone who has gone to battle with the Social Security Administration in an attempt to obtain disability benefits knows how frustrating that exercise can be.  Those individuals with a primary diagnosis of Chronic Fatigue and Immune Dysfunction Syndrome (CFIDS), have been especially exasperated due to the arbitrary nature and lack of uniformity of decision making by the Administration.  Take heart, help has arrived!

Like the cavalry charging over the hill, Social Security Ruling SSR 99-2p can help save the day. Or, if the claim was not prepared for battle from its inception, can seal its fate.

On April 30, 1999, the Social Security Administration published Social Security Ruling 99-2p: Title II and XVI: Evaluating Cases Involving Chronic Fatigue Syndrome.  This new ruling "ensures that all adjudicators will use the same policies and procedures in evaluating disability claims involving CFS, and provides a consolidated statement of these policies and procedures."

The Ruling has removed the discretionary and capricious decision making that had been the modus operandi of the Administration when dealing with Chronic Fatigue.  The Ruling details several examples of medical signs and laboratory findings which, for purposes of Social Security Disability, establish the existence of a medically determinable impairment "for individuals with CFS."

 The same guidelines that can be used to help win a claim provides a blueprint for the Administration to deny a claim as well.  Properly documenting your case, always the hallmark of winning a social security disability case, has become that much more important.
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Obtaining Disability Benefits. . .David versus Goliath?


Remember the epic battle between David and Goliath.  On paper, David clearly had no chance to win, fortunately his heart and soul did not know it and with determination, persistence and divine intervention he prevailed!  Ever wonder what might have happened if he was aware of his predicament?  Would he have fought or ran the other way?

Every day at the Social Security Administration (SSA), seemingly epic battles between disability  claimants and SSA  are fought.  The Bounty?  Disability  benefits. 

The battle unfolds like this: you become unable to work due to a physical and/or mental illness and apply  for disability benefits.   After all, you've paid into the system all these years for this exact situation.   Heck, even your doctor says you can't work.  You figure it is simply a matter of completing paperwork and time until you begin receiving benefits. . .but for now you are starting to experience financial problems. 

As the months go by without an answer, you reassure yourself this must be a simple case and the delay is "due to government bureaucracy."  After several more months your frustration grows, you call SSA and get no answers, or worse, the ones you get are all different!  The bureaucrats you spoke with were rude and put off  by your phone call.  You remind yourself SSA is on your side.  It's job is to help people like yourself by  paying disability benefits, right?  But. . .you begin to feel like David. 

The Big Day. . .

You finally receive an envelope from SSA, tear it open to find a benefit check and instead read: We have Denied  your claim for disability benefits as our trained staff and medical doctors have determined you are not disabled under our laws." 

You're angered, frustrated, scared, intimidated and now overwhelmed by the thought of fighting Goliath. . .the Federal Government.

Pages into the decision it mentions appeal rights, but the decision seemed so final and left you with no hope.  You do not know the law, the system and even if it is worth it or how to fight.  Your alone and defeated. . .exactly how SSA wants you to feel!

As a disability attorney I meet with clients everyday who tell me this same story.  Fortunately, those clients took the bold step of appealing the denial and fighting for benefits. 

What should you do. . .Persevere!

75% of all disability applicants initially will be denied benefits!  Half of those denied will give up and not appeal the denial!  However, 53% of the applicants who persevere to a hearing before an Administrative Law Judge obtain benefits!
 Now you understand how the system works, it is designed to deny benefits to as many people as  possible.  SSA denies initial applications because it knows 50% of the people will give up and not appeal!  But for those who persevere and appeal the denials, the majority is eventually granted benefits.

Understanding the System

1.  Initial application - Every claim for disability benefits begins with the initial application. 75% of all applicants are denied at this step.  SSA looks for a reason to deny benefits.  The decision is based on forms you completed and medical records, you won't meet with anyone involved in making the decision.  It is surprising when anyone wins at this step.  Don't quit--You must appeal a denial within 60 days.

2.  Reconsideration - The second step in the system but the results are worse.  82% of all applicants are denied at this level.  SSA reviews your file again and issues a denial, unfortunately it may take months to receive.  At this step, only 50% of the original applicants are still in the system, the rest gave up.  Appeal the denial immediately.

Up to this point in the system you have been a social security number and a file. 

3.  Request for Hearing before Administrative Law Judge - Congratulations! You have persevered in the system and now have a good chance to win benefits.  53% of all claimants win at this stage! 

Why?  Primarily because your claim is entitled to a de novo or new review by a Judge who knows the law and does not work for SSA.  Also, you get to testify before the Judge about your inability to work and she/he assesses your credibility.  Finally, hopefully you have obtained opinions from your doctors about your inability to work. 

You must win your case at the hearing stage; if you do not, you can appeal but your claim will be tied up perhaps for years with the likelihood of success dramatically reduced.

Increase your odds of Winning

Now that you have an understanding of how the system works, here are some tips on how you can  maximize your chance for success.

1.  Appeal every Denial - It bears repeating, DO NOT QUIT after receiving a denial.  Now you understand you must get to a hearing.  Up to that point SSA and the odds are overwhelmingly against you - receiving a denial may be cause to celebrate because you’re a step closer to a hearing.

2.  Retain a Disability Attorney - Retaining an attorney who specializes in disability law should substantially increase your odds of winning.  Most claimants have no idea what they need to prove to win their case.  Practically all disability attorneys work on a contingency fee - you only pay a fee if you win your case.  Also, Federal law sets the maximum amount the fee can be in your case.  An attorney will develop your case by obtaining the necessary medical and vocational records and opinions from your doctors that are critical in proving disability. 

3.  Completing Social Security Forms - You will complete a dizzying array of forms requesting all sorts of information.  Be honest and very brief when completing forms.  You won't win your case with the information you give on the forms but you could lose it.

4.  Involve your Treating Physician - Your treating physician is critical to success.  Judges give a treating physician's opinion regarding a patient’s disability tremendous weight.  If your physician is not sympathetic to your claim you may want to make a change to one who is.

The purpose of this article is to convey hope that you can win your case and obtain benefits with perseverance and knowledge of the system.  Please do not give up. . . appeal and keep fighting!
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Disability Benefits, Fibromyalgia and CFIDS: 
What you don't know could be fatal to your claim!


In my last article I analogized obtaining social security disability benefits based on any disease or ailment to the epic battle between David and Goliath.  Unfortunately, obtaining disability benefits based on fibromyalgia (FMS) and/or CFIDS sometimes can be similar to David versus Godzilla. 
Why?. . in part due to a lack of education at the social security administration (SSA) and human bias against claimants who appear to be "healthy" compared to those afflicted with a more understood and obviously disabling diagnosis. Indeed, I must confess that three years ago I had never heard of fibromyalgia. 

However, the good news is FMS and CFIDS claimants can and do obtain benefits with  proper preparation of their case coupled with an understanding of how the system may view them. 

TAKE A DEEP BREATH AND RELAX!!!  Before you call SSA to give up, please read on, as this article will give you important (maybe critical) information to use in your pursuit of disability benefits.

As a disability attorney who concentrates on representing those with FMS and/or CFIDS, I find two things interesting about my clients; most are very educated about their disease(s) while others have never heard of a tender point.  Second, almost all have great difficulty explaining to family, friends and other people (they could care less about!) that even though they appear "healthy," in fact, the diseases have left them debilitated.  Many feel as if their disease and the resulting limitations are often not taken seriously.  Undoubtedly, every client has experienced the look of disbelief and a raised eyebrow from another person when trying to tell him or her the diseases has literally ruined their life.

Thus, similar to the real world, it is not surprising that at the SSA the problems of education and bias can be alive and well.  This reality is of paramount importance.  Why?. . Because it should dictate how one proves they are disabled.  Please understand I am not saying SSA discriminates, intentional or otherwise against FMS and/or CFIDS claimants; but rather that your claim (especially if under 50 years old) may be viewed by SSA or an administrative law judge (ALJ) with a raised eyebrow.

FMS and/or CFIDS are no strangers to SSA and ALJs who decide whether you are disabled; however, that doesn't mean they understand or appreciate the diseases.  In what may be considered the landmark FMS disability case, Preston v. Secretary of Health and Human Services, 854 F.2d 815 (6th Cir. 1988), a Federal Court of Appeal unknowingly provided a framework within which SSA and ALJs should evaluate FMS (and logically CFIDS) disability claims. 

In May 1997, 9 years later after working at bureaucratic breakneck speed, a Regional Chief Judge issued a memorandum to other ALJs which provided a framework to follow at a disability hearing before a diagnosis of FMS is accepted.  Although the following will focus on FMS I believe it can also apply to CFIDS.  Ignoring these factors could be fatal to your claim.  They are as follows:

1. Was the diagnosis made by a rheumatologist or other specialist familiar with FMS?

I am always surprised (and skeptical) when a person calls or comes to meet with me and says they have FMS and/or CFIDS but it was not a rheumatologist or other specialist who made the diagnosis.  Other medical doctors can and do make the diagnosis of FMS, but many use the terms FMS/CFIDS generically and more as a description of a patients' symptoms rather than making the diagnosis following the American College of Rheumatology's (ACR) 1990 Criteria for Fibromyalgia or using the CFIDS Centers for Disease Control criteria.

If you learn one piece of information from this article, let it be this: It is critical your diagnosis is either made or confirmed by a rheumatologist or specialist.  If not, you risk having SSA and/or an ALJ rejecting the diagnosis altogether, which could be fatal to your claim.  Whether or not you (or your diagnosing doctor) agree with SSA's position, it is senseless to try to fight the system.  Addressing this issue is always my first priority in representing a FMS/CFIDS client.

Second, if a rheumatologist has not made the diagnosis, find one (a.s.a.p.!) who is board certified and sympathetic to your diagnosis and disability claim.  Eventually, you or your attorney will need to obtain opinions from him/her regarding how the diagnosis was made along with your inability to work.  An unsupportive and/or uncooperative rheumatologist (or any treating physician for that matter!) can create real and sometimes insurmountable obstacles to winning your case.  Why?. . . because you can bet SSA will  have its own doctor who will tell the ALJ you are able to work.  How do you find a supportive doctor? FMS/CFIDS support groups are a good place to find a referral. 

2. Whether the claimant's physician(s) systematically attempted to eliminate other diseases before making the diagnosis of FMS?

A frequently heard comment made by non FMS specialists, SSA case workers and even federal courts is that "FMS is a diagnosis made by exclusion of other diseases."  Of course, the implication is that doctors really don't know how to diagnose FMS and that somehow invalidates the fact the disease exists.  Such a belief shows unfamiliarity with the ACR 1990 criteria for diagnosis.  However, it reinforces why a specialist should make the diagnosis after a physical exam (finding and documenting tender points) and blood work excludes other rheumatic diseases which may share symptoms with or mimic FMS/CFIDS.  That process provides validity to the diagnosis. 

3. Whether the patient's complaints are typical for the disease?

This question is usually answered by reviewing the patient's medical records and comparing them to the ACR criteria.  Hopefully, the medical records provide detail regarding the patient's symptoms or complaints.  FMS/CFIDS specialists almost always document the defining symptoms.  For FMS patients it is also critical that a physical examination was performed confirming the existence and location of the classic tender points.  Without documentation, the diagnosis may be subject to attack. 

 4. Whether the claimant was referred to physical therapy or a pain clinic for treatment,  whether pain medication was prescribed for mild or severe pain and whether the  claimant received pain relief through injections into focal tender points?

The "exhaustion of remedies requirement."  I always counsel clients to undergo and at least try any treatment the specialist prescribes, including non-traditional treatment.  Why?  Because you do not want to be at a hearing before an ALJ who is wondering whether your condition would be as severe if you had followed your own doctors' instructions.  Moreover, SSA's doctor will usually tell the ALJ that your symptoms would improve (of course, allowing you to work) if you would undergo some type of treatment.  Don't give the ALJ an open door to deny your claim. 

Exhausting each type of prescribed treatment is good for your health and your disability case.  After doing so, your testimony will be more credible because nothing exists (including an injection!) to alleviate the severity of your symptoms.  Moreover, the severity of your condition will be supported by the fact that you have tried everything to find relief. 

Trying to stay within the framework provided by the Preston case should increase your odds of winning and avoid any unfortunate surprises.

Additional tips to keep in mind:

Involve your treating physician!  Tell your doctor as soon as possible you have filed a disability claim.  If he/she is lukewarm to the idea, try to find another doctor.  Unfortunately, there are many doctors who could care less about a patient's legal issues.  Do not get stuck with one!  As an attorney, nothing is more frustrating than a doctor with no backbone or worse, he/she refuses to be involved at all. 

Medical records can be your best or worst friend!  It is your job to be a very detailed historian with your doctor regarding the severity, frequency and nature of your pain, fatigue and other symptoms.  I tell clients to convey information regarding pain, fatigue, sleeplessness, flare ups, days spent in bed, inability to do simple daily activities and brain fog problems.  Tell the doctor you want the information in your records.

Hire an attorney who has experience handling FMS/CFIDS cases!  During initial meetings with FMS/CFIDS clients I sometimes say to myself  "If I didn't know better, I'd say this 40 year old woman looks perfectly capable of working!."  It is only through an understanding of the diseases and talking to clients that I realize they will pay for the trip to my office for the next couple of days!   Through understanding comes compassion and the ability to convey the effect the diseases have on a client's life to SSA or a judge.  Your attorney should at least be familiar with the 1990 ACR and/or CDC criteria and be able to talk intelligently with your doctor.

Remember: people obtain disability benefits every day based on FMS/CFIDS.  Do not quit! Keep fighting!  Use this article as the cornerstone to preparing and hopefully winning your case. 
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Last Updated on: 11/07/2002

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