Court Discusses Weight Given to Treating Provider Opinions in Claims for Social Security Disability Benefits in a Massachusetts Case

A person suffering from disabilities that prevent the person from holding gainful employment may be eligible for Social Security Disability Benefits. While physical disabilities preclude many recipients of Social Security Disability Benefits from working, mental disabilities can impair a person’s ability to work as well, and evidence regarding mental impairments should not be disregarded. This was discussed in a recent Massachusetts case in which the court overturned the final decision of the Social Security Administration Commissioner on the grounds the decision was not supported by substantial evidence under the Social Security Act. If you are suffering from a mental impairment, you should speak to a trusted Massachusetts Social Security Disability attorney to discuss what benefits you may be eligible to obtain.

Factual Background

It is alleged that the plaintiff filed for Social Security Disability Benefits in July 2016, due to physical and mental disabilities. His application was denied and after a subsequent hearing, the denial was affirmed. The plaintiff then filed a motion to reverse the Social Security Administration Commissioner’s final decision, while the Commissioner filed a motion to affirm the final decision. Upon review, the court granted the plaintiff’s motion and remanded the case for further proceedings.

Evidence of Mental Health Conditions

On appeal, the plaintiff argued that the Commissioner failed to consider important evidence regarding the plaintiff’s mental health issues prior to affirming the denial of the plaintiff’s application for benefits. While the court found that several of the plaintiff’s arguments fell short, the court agreed that the hearing officer improperly discounted the opinions of the plaintiff’s treating provider.

Specifically, the officer stated that the provider did not meaningfully discuss the plaintiff’s specific functional capacity or establish a disability as defined by the Social Security Administration. The court found this reasoning to be insufficient to discount the opinion of the plaintiff’s treating provider, however. Rather, the court noted that under the standard that applied at the time the plaintiff applied for benefits, a hearing officer must set forth good reasons for the weight he gives an opinion of a claimant’s treating provider.

Further, the court noted that generally, a treating provider’s opinion on the severity or nature of a claimant’s impairments is given controlling weight unless it is not supported by progress notes or laboratory findings. Thus, if a hearing officer decides not to grant a treating provider’s opinion controlling weight, the officer must provide specific reasons for doing so. In the subject case, however, the officer merely stated his conclusions that he would not accord the plaintiff’s treating provider much weight, without setting forth the basis of his decision. As such, the court found that the hearing officer erred in discounting the plaintiff’s treating provider’s opinion, and remanded the case for further proceedings.

Speak with a Capable Massachusetts Attorney

If you cannot work due to a physical or mental impairment, it is in your best interest to speak with a capable Massachusetts Social Security Disability attorney to discuss what benefits you may be able to seek. The experienced attorneys of the Law Office of James K. Meehan have the skills and resources to assist you in your pursuit of benefits, and we will work diligently on your behalf. We can be reached at 508-822-6600 or via our form online to set up a meeting.