disability - mental disability - complete history - pre-application/onset hospitalizations
Patel v. Colvin – ED Pa. – October 13, 2016
Plaintiff stated that her disability began on May 1, 2010, and filed the application on August 5, 2011.33 In assessing Plaintiff’s treatment record, the ALJ stated that records before the application date of August 5, 2011, were “not from the relevant period.”
With regard to Plaintiff’s hospitalizations, the ALJ noted which hospitalizations preceded the “alleged onset date”and apparently discounted them on this basis. This was error.
The regulations specifically acknowledge the importance of a comprehensive view of a claimant’s condition over a significant period of time i.e. the need for longitudinal evidence.
More specifically, the regulations state that a “complete medical history,” means “the records of your medical source(s) covering at least the 12 months preceding the month in which you file your application.”
This is particularly relevant in this case, where Plaintiff alleged an onset date of May 1, 2010, and the hospitalizations occurred after that date, with most occurring within one year of the application date. Of particular concern is the ALJ’s apparent discounting of Plaintiff’s lengthy hospitalization from July 21, 2011 through August 24, 2011, at the time of Plaintiff’s application.
In addition, it appears that the ALJ applied a mechanical assessment of Plaintiff’s medical records, focusing on whether a hospitalization lasted more than two weeks and seemingly discounting or rejecting as irrelevant any that did not, without regard to whether “the duration and functional effects of the episodes are of equal severity and may be used to substitute for the listed finding” as required by the regulations.