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C.D. Cal- Conflicting Medical Opinions and Occupational Analysis

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  • C.D. Cal- Conflicting Medical Opinions and Occupational Analysis

    In a recent decision from the Central District of California, the court expounds upon two main issues: the conflicting medical opinions of either party, and vocational analysis practices.The court first takes up the fairly common issue of conflicting medical opinions.

    [I]t is well understood that ERISA does not require a plan administrator to accord greater weight to a claimant’s treating physician. See, e.g., Black & Decker Disability Plan v. Nord, 538 U.S. 822, 832, 834 (2003) (“[I]f a consultant engaged by a plan may have an ‘incentive’ to make a finding of ‘not disabled,’ so a treating physician, in a close case, may favor a finding of ‘disabled . . .’ [therefore] courts have no warrant to require administrators automatically to accord special weight to the opinions of a claimant’s physician”). Otherwise, the cases yield some common-sense guidance for assessing conflicting medical opinion evidence. In Shaw v. Life Ins. Co. of N. Am., 144 F. Supp. 3d 1114 (C.D. Cal. 2012), the Court succinctly stated them as follows: the “credibility of physicians’ opinions turns only on whether they report subjective complaints or objective medical evidence of disability, but on (1) the extent of the patient’s treatment history, (2) the doctor’s specialization or lack thereof, and (3) how much detail the doctor provides supporting his or her conclusions.” Shaw, 144 F. Supp. 3d at 1129.
    Ultimately, the court found the opinions of MetLife's physicians to be unpersuasive, and accorded more weight to those of the Plaintiff's doctors. Next, the court took up the issue of vocational analysis, and found that MetLife's handling did not meet the requirements as outlined under ERISA.

    MetLife’s handling of Plaintiff’s claim with respect to its vocational analysis invites skepticism. According to the claim activity log in the Administrative Record, MetLife’s claim specialist drafted and submitted her recommendation for denial on September 11, 2014. (AR 582.) However, MetLife did not complete a vocational analysis until September 18, 2014. (AR 588-89.) MetLife then issued a denial of Plaintiff’s claim later that same day. (AR 594.) This awkward timeline suggests that MetLife’s may have failed to consider any vocational analysis in making its decision to deny Plaintiff’s LTD benefits and therefore falls short of the “reasoned and deliberative fashion” required under ERISA. Salz, 380 Fed. Appx. at 724.
    The full opinion is attached below
    Attached Files