Skip to main content

Social Security Administration Awards Disability Benefits Based On Claimant's Fibromyalgia

On January 11, 2016, Administrative Law Judge Richard J. Ortiz-Valero entered a decision awarding disability insurance benefits and finding that due to her fibromyalgia the claimant was disabled under sections 216(i) and 223(d) of the Social Security Act.  The decision is significant in that fibromyalgia is not a "listed" impairment under the Social Security Administration's regulations.

These regulations, 20 C.F.R. Part 404, Subpart P, Appendix 1, list many of the most readily diagnosed medical conditions and their symptoms which can reach a severity which is considered disabling.  In the usual case, in order to award benefits the Social Security Administration must determine that the claimant's impairment is of a severity to meet or medically equal the criteria of a "listed" impairment.

This claimant's condition had been diagnosed by several physicians as fibromyalgia ("FM").  FM affects the muscles and soft tissues.  Symptoms include chronic muscle pain, fatigue, sleep problems and painful "tender points." Fibromyalgia Center: Symptoms, Treatments, Causes, Tests, and ...

CDC estimates that as many as 15 million people may suffer from this condition.

Even though it is not a "listed" disease, the Social Security Administration has issued guidelines on how it will determine whether a claimant's FM is a disabling impairment qualifying the claimant for benefits.  SSR 12-2p  Essentially the claimant's "residual functional capacity" must be evaluated i.e. her ability to do physical and mental work activities on a sustained basis, despite limitations from her impairment.

In order to show that the claimant was disabled in this care we used the SSR 12-p guidelines to formulate a questionnaire which we sent to each of the physicians who had treated the claimant.
Among other things the questionnaire included a diagram of the eighteen (18) trigger points shown in the SSR 12-2p guidelines.  We asked the physician to describe at how many trigger points the claimant usually experienced pain.  The questionnaire also provided for an evaluation of the various activities - walking, lifting, bending, etc. - the claimant could perform so that her functional capacity could be determined.

The Administrative Law Judge determined that the claimant's residual functional capacity was less than that needed to perform her past relevant work activities and precluded other work as well.  As a result the ALJ found her to be disabled and qualified for benefits.

Comments

Popular posts from this blog

Attorney's Fees Awarded for Collecting FLSA Settlement

United States District Judge William P. Dimitrouleas entered an order in an overtime case under the Fair Labor Standards Act awarding an employee plaintiff additional attorney's fees incurred in collecting his back pay settlement.   The order clarifies the law in the Southern District of Florida regarding whether additional post-settlement collection fees are appropriate in the situation where an employer has failed to comply in full with payment obligations under a mediated settlement . Download the Court's order here. Legal advice and assistance in recovering unpaid overtime compensation at mccoyesquire.com

More About OSHA's Whistleblower Program

OSHA is beefing up its whistleblower protection program. OSHA Assistant Secretary acknowledged that protection from retaliation is essential to effective enforcement. More about what is covered and who to contact at http://www.whistleblowers.gov/ Dr. David Michaels, new OSHA head appointed by President Obama stressed that leadership at the United States Department of Labor “profoundly understands the cornerstone position that whistleblower protections have in the foundation of a strong worker protection program.” Legal advice and assistance at mccoyesquire.com

OSHA Protects Workers Who Object to Unsafe Working Conditions

Section 11(c) of the Occupational Safety and Health Act protects employees from reprisals for exercising their rights under the Act, including their right to complain about unsafe or unhealthy working conditions. It provides in general that no person shall discharge or in any manner discriminate against any employee because the employee has: (a) Filed any complaint under or related to the Act; (b) Instituted or caused to be instituted any proceeding under or related to the Act; (c) Testified or is about to testify in any proceeding under the Act or related to the Act; or (d) Exercised on his own behalf or on behalf of others any right afforded by the Act. An employee who believes that he has been discriminated against in violation of section 11(c) of the Act may, within 30 days after such violation occurs, lodge a complaint with the Secretary of Labor alleging such violation. The Secretary shall then cause appropriate investigation to be made. If, as a result of such investi...