EVALUATING MEDICAL OPINIONS: SOCIAL SECURITY DISABILITY BENEFITS CLAIM

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Steheli's Social Security Application

Melonie Staheli, seeking disability benefits , applied on April 5, 2018, stating that her disability began on March 28, 2018. However, her initial benefit application and subsequent reconsideration were both denied by the Social Security Administration (SSA). Determined to fight for her social security benefit, Staheli requested a hearing before an administrative law judge (ALJ).

Staheli's disability and social security claims struggle began in March 2015 when she suffered a stroke that left her with debilitating symptoms such as headaches, memory loss, and vision problems. In addition to these physical challenges, Staheli was diagnosed with various mental health issues, including anxiety, depression, bipolar disorder, and attention deficit hyperactivity disorder.

Denial of Disability Benefits

Despite her difficult circumstances, first disability determination services denied her benefit claim during the disability determination process. Then the ALJ, utilizing the five-step sequential evaluation process outlined in the Social Security Act, concluded that Staheli did not meet the criteria for disability. The ALJ determined that Staheli possessed the residual functional capacity (RFC), despite her medical condition to perform a wide range of work, although with some nonexertional limitations. Consequently, the ALJ asserted that there were suitable job opportunities in the national economy that Staheli could undertake, leading to the denial of her social security disability insurance claim.

Staheli, however, disputed the ALJ's denial of her social security benefit, arguing that the ALJ failed to properly evaluate the opinion of Dr. James M. Ottesen, a psychologist, regarding her work-related limitations. Additionally, she contends that the ALJ neglected to address the test results obtained by Dr. Ottesen and Dr. Chris Anderson, which indicated that she scored below the tenth percentile in areas such as full-scale IQ, working memory, and processing speed.

Proper Disability Evaluation

To assess Staheli's social security claim accurately, it is essential to consider the revised procedures for evaluating medical opinions as outlined in 20 C.F.R. § 404.1520c. Dr. Ottesen's assessment revealed that Staheli's prognosis for completing on-the-job training and maintaining full-time employment was "fair to good," but with specific conditions. Notably, Dr. Ottesen recommended that Staheli receive extensive supervision and support at work.

However, the Social Security Administration's ALJ did not classify Dr. Ottesen's recommendations as a medical opinion due to their failure to meet the regulatory criteria. According to the ALJ, Dr. Ottesen's statements were too general and did not provide a clear opinion on Staheli's abilities despite her impairments. Staheli argues that the ALJ's treatment of Dr. Ottesen's report as compared to Dr. Anderson's report is inconsistent, but the ALJ's evaluation of Dr. Anderson's report was justified and did not necessitate further explanation.

Staheli's claim of prejudice resulting from the ALJ's choices lacked support. The ALJ did not selectively choose evidence but instead dismissed Dr. Anderson's opinion as unpersuasive. While Staheli insists that the ALJ should have evaluated the objective medical evidence provided by Dr. Ottesen and Dr. Anderson, the ALJ did address her IQ scores. However, the ALJ did not specifically acknowledge the doctors' statements highlighting that the test scores placed Staheli below the tenth percentile for working memory, processing speed, and full-scale IQ.

Indication of Disability

Staheli emphasizes the importance of the tenth percentile figure as outlined in the Dictionary of Occupational Titles (DOT), which states that jobs identified by the ALJ cannot be performed by the bottom ten percent of the population in terms of general learning aptitude. However, the Third Circuit has already dismissed a similar argument, clarifying that aptitude levels are not within the purview of the DOT.

In conclusion, the ALJ's RFC assessment adequately accounted for the implications of Staheli's low IQ scores. While Staheli continues to contest the ALJ's decisions, the process of evaluating her Social Security claim necessitates careful consideration of all medical opinions and objective evidence relative to her disability.

How can we help?

What should you do if you find yourself on the wrong end of a Social Security disability benefits denial?  First, review the reasons for the denial and be sure to preserve your rights to a review and appeal.  Our law firm can help you secure the benefit you earned, so give us a call.