Winning Isn't Easy: Long Term Disability ERISA Claims

Episode 36: ME/CFS, The Common Reasons Disability Insurance Claims Get Denied, How The Carrier Reacts To These Claims, And How The Mishandling Of These Claims Can Inform The Future Of Long-Term COVID-19 Disability Claims

October 05, 2021 Nancy L. Cavey
Winning Isn't Easy: Long Term Disability ERISA Claims
Episode 36: ME/CFS, The Common Reasons Disability Insurance Claims Get Denied, How The Carrier Reacts To These Claims, And How The Mishandling Of These Claims Can Inform The Future Of Long-Term COVID-19 Disability Claims
Transcript
Nancy L. Cavey:

I'm Nancy Cavey national ERISA and individual disability attorney welcomed a winning isn't easy . Before we get started, I've got to give you a legal disclaimer. The Florida bar association says, I have to tell you that this isn't legal advice, but nothing will ever prevent me from giving you easy to understand information and an overview of the disability insurance world, the games, the carriers play and what you need to know to get the disability benefits you deserve. So off we go, do you have any CFS syndrome? If so today's podcast is for you. If not, I still think there are lessons that you can learn from this podcast. Today. I'm going to talk about four things. The first thing is going to be MEC CFS syndrome and the eight common reasons why MEC CFS claims get denied to evidence examinations and carrier reactions to ME CFS syndrome. Part one evidence examinations, carrier reactions to M PCFS fatigue syndrome part two. And in conclusion, ME CFS and his relationship to COVID-19 disability claims, we've got a lot to cover, but before we do that, we're going to take a quick break.

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Nancy L. Cavey:

We'll go back to winning isn't easy, ready to get started. Let's first talk about ME CFS , any eight common reasons why these claims get denied, but before we get started, I think we need to understand what the disease is and its symptoms ME , uh, which is also known as chronic fatigue syndrome is according to the Mayo clinic at disease characterized by profound fatigue, sleep abnormalities, pain, and other symptoms that are made worse by exertion. It occurs more commonly in women. And unfortunately the cause of this condition is unknown, but it can include environmental agenda. Genetic factors. Now one of the characteristic symptoms of ME CFS is fatigue over six months and that fatigue often worsens with activity, but it doesn't improve with rest. There are according to the Mayo clinic, over 200,000 cases reported each year. Now I'm going to be discussing , uh, how the product enterovirus infection or CE is possibly to ME CFS. According to ME a pedia though, normally only capable of acute infections under certain conditions. These enteroviruses can create chronic infections and the ongoing , uh, enterovirus infections can be found in ME CFS cases and even several other chronic illnesses, including a dilated cardiomyopathy and type one diabetes. Now, we need to also understand that the disability carriers don't understand these enteroviruses much less the ME CFS , and that can complicate a disability insurance claim, the carriers approval of a claim. So let's talk about the eight reasons that disability carriers will use to justify a claim denial of MECFS claims or even chronic enterovirus infection claims the disability insurance companies like first Unum have a laundry list of defenses. They'll commonly raise in a disability insurance claim regarding , um, uh, CFS, chronic Andrew infections and myalgic encephalomyelitis. Um, they'll employ medical peer review providers to create these defenses. I call these medical providers liar for hires. There's big money to be made by providing these medical opinions in big money made and saved by disability cares . They no longer have to pay your disability , um , benefits. So the role of the medical peer review provider is important for you to understand, because these are the people who are going to create the reasons that will justify the claims denial. They're hoping at some point that your treating physician won't support your claim where they'll get tired of filling out forms or tired of being harassed by the disability insurance company and when that doesn't work or when the disability of a definition of disability changes or when the carrier is just flat out, tired of playing your claim, the games will begin. And so what they'll do is they're going to assign a nurse case manager or a peer review physician to determine your quote unquote, correct restrictions and limitations so that they can justify a denial of your benefits. The medical provider is either an onsite physician employed by the disability care known as a medical director, or there are medical providers who have signed up with disability review companies to do medical reviews, to supplement their income. Either way. These doctors are jelling, nothing more than hired guns. And that's where I call them liar for hire medical peer review providers. Now it's common for the hired gun to contact your physician and seek a better understanding of their medical opinions, which is a code word for, we want to convince you that your opinion's wrong or that you have no justification for your opinion. Uh, and that , uh, w our opinion, your restrictions or limitations are really correct doctor right now, obviously the whole purpose of this is to ultimately create evidence in quote in quotes , uh , to establish that you're capable of working. All right, so now we've laid the , uh , the base for this. We understand what ME CFS is. We understand , uh , how the disability carriers are going to use these liar for hire doctors. So what are the common reasons for the claims denial denial? Number one is there's no objective evidence of the diagnosis. They're of course going to say, it's all in your head, or it's, you know, something you're making up, or you just could not be in as much pain as you a complainer. Now, physicians will routinely rely on the complaints of patients and rendering opinions regarding the diagnosis and restrictions and what they're going to be arguing. The disability carrier is going to be arguing is that objective evidence is medically necessary in every case. Uh , and that can be difficult if not impossible to prove in cases like CFS, fibromyalgia, migraines, even mental health impairments. There generally isn't objective evidence to confirm these conditions, but the good news at least, is that courts across the country have repeatedly criticized and reversed denials based on a claimed , uh , lack of objective basis of the diagnosis. Denial reason. Number two, there's no objective evidence for the restrictions and limitations assigned by the treating physician or your doctor is improperly relying on your subjective complaints. This is a defense that has some traction with some courts. They want to see an objective basis for the restrictions and limitations assigned by your doctor now, because courts do uphold denials based on this argument. I think as a matter of proof, you get what's called a functional capacity evaluation, a cardiopulmonary exercise test, or a comprehensive neuropsychological evaluation. The courts will recognize these tests as an objective faces for the assignment of restrictions and limitations. All right , denial reason. Number of rape. There is no correlation between the findings , uh , to substantiate your reported complaints. So in other words, the medical reviewer is going to criticize the treating physician's records on the basis that there's an absence of correlating findings or studies that will substantiate your reported complaints or the level of your report or complaints, and often to get there, the medical review reviewer will cherry pick the medical records and ignore objective findings that explain or consistent with a disabling symptoms, denial, reason, number four, and absence of functional impairment. Now, that reason always amazes me because if you look at the disability policy, do you see functional impairment as a definition of disability, rarely do you see a definition of impairment, much less functional impairment. You won't see either of those words used in a disability insurance policy. And the worst thing I think is that the pure review doctor doesn't even define what they think functional impairment is, or the standard that they use to determine whether or not there is a functional impairment. I think that's a bogus reason for denial, but it's a common one. All right. Denial reason, five unremarkable lab findings are diagnostic studies. Now these liar fire peer review doctors will often equate normal laboratory findings or diagnostic studies as evidence that there is no impairment. Well, w you don't expect to see positive laboratory or diagnostic findings in cases of MD CFS. These medical conditions generally are not established to objective medical evidence, such as diagnostic studies or testing. I mean, just think about it. Is there a test that will prove that you have a migraine? Well, if you have a brain CT scan and there was a tumor, then that may be the basis for the reason for the migraine, but that, that is an example of another medical condition, where there are either no lab findings or unremarkable diagnostic studies that doesn't negate the diagnosis of migraines, much less the diagnosis of ME CFS. So think about that argument in relationship to perhaps a migraine claim. Now, unfortunately, that doesn't prevent them from hanging their hat on that to justify claims, denial, denial, number reason, number six is there's medical improvement. So on the flip side of this, the medical reviewer will comment that recent office notes reflect overall impair or improvement. And then they'll jump to the conclusion one that there is an improvement and two , that that level of improvement allows you to work. But what is improvement and is that improvement temporary, or is it permanent? Is it enough to permit you to return to work? Of course, the peer reviewer prior provider never considers or answers those questions. Then I are reason number seven is that the level of care isn't enough is your head spinning yet the medical reviewer will often comment that the lack of escalating care or medication is inconsistent with a level of reported impairment, pain or fatigue. And as a result, you magically are capable of working. Now, of course, they peer review provider hasn't commented on the care that you've gotten , uh , and your lack of improvement as a result of that care, nonetheless, they are going to criticize the level of care and use that as a reason to deny your claim. Then I are reason number eight, there are no side effects from medication, and therefore you ought to be able to work. Now that of course , um, is not always true medications like Benadryls Zoloft, lorazepam, Adderall, Lyrica , um, a whole stable of medications are used in ME CFS cases, and they have reported side effects. Now what the peer review provider will do a scan of the medical records, looking for medication side effects. And if they don't find any, they're going to opine that there are no medication side effects. Now that may not always be true. And quite frankly , um, you know, the doctor probably told you when they prescribed the medication that they would be, there would be side effects. And so you're not necessarily going to report to the doctor, anything abnormal, because the doctor told you that you would normally have those kinds of problems yet because there's no medication side effects noted in the records. The peer review doctor is then going to say, well, since there are no medication side effects noted , um, you know , that can't impact the person's ability work, and therefore they can work because they're getting a good result. Or if there are medication side effects, they'll say, well, they don't rise to the level of impairment warranting , any restrictions, limitations. In other words, they're playing both sides of this game. What's important here is that that's not the standard of disability and they will purposely fail to address the known side effects caused by combinations of medications, much less the medications that are being prescribed. So that's another common reason for denial. Now let's take a quick break before we head into our next section. And while we do that, think about those eight reasons, has your claim been denied because of any of those eight reasons, Welcome back to winning. Isn't easy. This is an episode chock full of information, and we're going to keep on going. Let's talk about the evidence examination and carrier's reaction to MECFS claims part one. Now I've talked about the objective evidence of your diagnosis issue. ME CFS generally has no universally agreed upon diagnostic criteria. Um, and whether the disability carriers will use is an outdated CDC definition. And according to that definition, you have to have significantly lowered ability to participate in activities that were routine before the onset of the condition and persisting for more than six months physical or mental activity that causes worsening of symptoms that would not have happened before sleep disturbance, a constellation of symptoms that can't be explained by any other clinical diagnosis. Now, then they're going to be looking at some other factors they're to be looking at whether or not you have difficulty with thinking and memory worsening problems with sitting or standing muscle pain, joint pain, or headache, pain, tender lymph nodes in the neck, or armpits night sweats or sensitivity to foods, odors chemicals, or noise. Now they're also going to be applying this objective evidence test to restrictions or limitations. So they're going to cherry pick the medical records to see whether or not you have any of these complaints. And then they're going to look for the objective evidence of restrictions, limitations. Where's that evidence going to come from? Well, it potentially can come from the statements that you make to the disability carrier on a phone call or a phone call check-in , uh, it can be found in the statements that you make on your activity of daily living forms. It can be coming from statements of your supervisors or coworkers. It can be coming from supportive medical records from your physician. It can also come from the APS statement that you will get from your physician, or even a social security disability forms such as a residual functional capacity form for ME CFS. It can come from a functional capacity evaluation to see pet exam, neurocognitive testing, and independent , uh, examination , uh, and a vocational report. And maybe even a social security decision. You gotta be careful about that because of mental health issues. So those are sources that either you can submit or they'll be looking for for not only an objective basis of the diagnosis, but objective basis of the restrictions and limitations. Now I've talked before about the importance of a CT pet examination in MECFS case Y well, as I've told you before, they're going to argue that there is no objective basis for the diagnosis, not withstanding the fact that ME CFS can't be established through objective medical evidence of course, are generally not impressed with that argument at all. Uh , but as I said before, the next argument that they're going to make is that your records don't support a level of impairment that would prevent you from , uh , uh , being entitled to your benefits because you can't do the mutual and substantial duties of your own occupation or any other occupation. So the way to solve that is to get a C pet exam, because that C pet exam can objectively measure fatigue and other symptoms that can interfere with your ability to work. But you need to understand that there are two types of see pet exams. There's a one day and a two day, and there are advantages and disadvantages to each, regardless of which one you get, they can be hard to obtain because there are very few facilities that will perform these. Now the one day, see pet could be obtained by cardiac from a cardiologist or an exercise physiologist. I'm leery about testing done by a cardiologist, because quite frankly, they're not as sympathetic as to why you're getting the testing. Uh, as , uh , as , uh , an exercise physiologist, the exercise physiologists I think is better qualified , uh , because they understand the impact of exercise and fatigue , uh , on a person's ability to , uh, work , um, from the person's totality of the, of their situation. We're cardiologists will just sort of tend to focus on potentially fatigue issues and not deal with the other issues such as pain or dysfunction , um, the impact of other medical conditions. So I prefer , uh , a C pet exam done by an exercise , um , a physiologist, but the problem with a one day see pet exam is that it rarely addresses the major problem in , uh , ME CFS cases, which is the post exertional malaise. That's why I think you're probably better off getting the more expensive two day CT pet. It can, as I said, be difficult to find one , uh , and you may have to go to New York, Washington state, California, even Florida, where testing can be done. And I understand that adds to the expense. So you probably should be consulting with an experienced Nerissa disability attorney , uh , before you do the see pet exam, because they can tell you who to use and explain to you why you might need a one day or a two day exam. Now, the, there are situations where my clients will have a two day see pet exam scheduled , um, but they don't pass the first day. And as a result, we don't have to do the second day, but if you pass the first day that we definitely need the second day, because we want to document the fatigue and cognitive issues. Now, what is the disability carriers, common response to a CT pet exam? Um, they were quite frankly, looked for ways to discredit the exam. And the first way they will do is do it as they say, well, it's not time relevant because it doesn't address the functionality at the time of claim was denied. And I don't really think that courts buy that argument as being part, because this is the way carriers do IMS all the time after the time cases have been denied. So you can't argue that out of both sides of your mouth. Now, if that doesn't work, what they're going to argue is that the C pet exam was not supported by the physical examination conducted by the treating physicians, the level of treatment provided, or the nature of the treatment recommendations. I always want to get my treating physician to sign off on the see pet exam results. And now the last argument they're going to make is that the seabed is not objective evidence of impairment because it's based on subjective information supplied by the policy holder. And I don't think that that argument goes quite frankly, very far with the courts who have recognized , uh , the sea pet exam as the gold standard examination or study to document the existence of ME CFS, but also the level of restrictions and limitations. Got it. All right. Let's take a quick break. Before we come back and talk about part two of evidence examination and carrier reactions to ME CFS syndrome claims,

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Nancy L. Cavey:

Well , go back to winning isn't easy evidence, examination, and carrier reactions to ME CFS, fatigue syndrome claims part two. Now, what are the games that a disability carrier is going to play is that you really have a psychiatric impairment and you don't have a claim based on ME CFS. So as a result, we're only going to limit the , uh, paying your benefits , uh, for two years. Now, let me give you an example of how this works. Uh , and this is the case of Tam versus first Unum life insurance company. It's a California case. And I think it explains and illustrates how disability carriers will play this game. Uh, Ms. Tam was a software engineer and she suffered from ME CFS. She applied for it. She was granted her short-term disability benefits after undergoing a carrier IME that amazingly found that she was severely impaired. The ME, the IME noted that she was depressed, anxious and tearful during the IME and the IME concluded that she had major depression, secondary to MEC CFS . So she then applied for long-term disability benefits. What did first UNUM do? Well, first Unum made it clear that she was not disabled by her mental health conditions. They were looking for a way to deny this claim any way they could. So she asked Unum to review her claim only from her physical conditions. And then you , and as always had the claim reviewed by four physicians. One was an occupational medicine doctor. Another was an internist and neither was qualified to evaluate her medical conditions. And that's a common tactic. They'll use the wrong kind of doctor now, not withstanding her request. Unum had a psychiatrist, Dr. [inaudible] review the case, although he didn't examine her, he noted her history of mental health treatment, her prescriptions , uh, and , um, her psychological issues. And Dr. [inaudible] commented that her symptom, complaints, particular fatigue and cognitive dysfunction were common in psychiatric illnesses. And in fact, that's true, but he went off on a tangent and a tangent that resulted in, in , uh , in the denial. Uh, clarity said, look, I looked at her medical records in our infectious infectious medicine doctors make no comment of any psychiatric concerns, conditions, or impairments. Well, that was wrong. Uh, and what the company did. And what is common is they'll cherry pick the medical records , uh, to, to again, create a reason for denial. Now, clarity also disagree with the medical opinions provided by the short-term disability providers , psychiatric IME. So in other words, clarity disagreed with uniforms, IME doctor, and that's a common ploy to where , uh, there'll be a disagreement about an experts . And under the terms of the disability policy, the carrier gets to pick who they believe and who are they going to believe? Not, not the favorable psychiatric or physical IME they pick, but the peer review doctor who , uh, you know, the liar for hire who is going to say, well, no , no, no. That doctor was really wrong. Now for unknown reasons, Unum retained another psychiatrist to review her claim. The infamous stewardship go and Shipko is well-known in the ERISA world. I'll just say, Google him. And look at the cases he's been involved in. And you can get a clue as to what , uh, Dr. Shipko is about. Now. Shipko did not examine her. And of course disagreed with the IME doctor. And as a result, Unum denied her a claim. So Tam said, well , um , I'm Michael Stanford, this, and she submitted additional testing, including a neuropsychological evaluation to document her cognitive problems. Well, what have you seen them do? Well, Unum had their file reviewed by a fifth doctor, Dr. Norris, Dr. Norris specializes in family medicine, occupational medicine, and aerospace medicine. He didn't examine her. Of course he has no experience or training in our underlying medical conditions, nor is he neuros a neuropsychologist. So what did Norris do? Nora said, oh , it's not time relevant. I'm going to throw this out. And her denial was upheld. Um, because Unum said she could do the duties of a regular occupation. And fortunately Tam went into federal court and the judge was not impressed by the Unum denial, not withstanding the fact that there were five peer review doctors, the judge criticized union for using doctors that weren't competent or qualified, or to address her multiple medical conditions. And he noted that Clarion Shipko focused on the psychiatric S aspects of her condition, even though that wasn't the basis of her claim. And the judge commented that peer review providers conducted by units , physicians mis-characterized or ignored the evidence in the record, citing the errors made by Claudia. And Chipko now this is is common, but the court went on and criticize units demand that Tanem submit objective evidence of a medical condition characterized by a subjective complaint of fatigue and pain, and also , uh, criticized units rejection of the neuropsychological evaluation, which address the impact of the DCFS on her cognitive abilities. Um, the course of look, we think this information is time relevant. These tests should have been considered in combination with all the medical records and the court noted that there wasn't any basis for challenging her credibility. You'd have never had an undergo, an IME, never questioned or honesty or integrity had a doctor physically examine her , uh , and determine whether or not she , um, was malingering or faking on her , uh, examination. And fortunately, and, and congratulations to Ms. Tam, they awarded her benefits and the , um , court noted that the testing was a valid and credible measure of her medical conditions. So we need to understand that we have the burden of proof in every claim, including an ME CFS claim. And there are ways again, to address these issues with , um, the support of a treating physician who will fill out the residual functional capacity form , uh, the strength of your medical records based on your history of your complaints and problems with functionality , uh, a C pad exam, an FCE, and even a neuropsychological exam. We really do want to create a body of medical and vocational evidence that establishes that you can't perform the material and substantial duties of your own occupation. So you can see that these cases are, can be hard to develop, and you really, in my opinion, need the , uh, the experience , uh , and support of a Rissa disability attorney who can help review your medical records, review the policy and develop not only the medical with the vocational evidence that will establish that you objectively have ME CFS, that you have objective restrictions, limitations that prevent you from performing your own or any occupation and take apart , uh, with a sledgehammer, all the bogus defense reasons the carriers will use to deny a claim. All right , let's take a break. Welcome back to winning isn't easy MEC CFS claims and their relationship to COVID-19 disability claims. Now, why am I bringing this up? I'm bringing this up because COVID-19 and ME CFS are different diseases, but the symptoms can overlap. And I will find that insurance companies tend to treat claims made by suffer, suffers of both diseases. Very similar. Now, many people who fortunately have had COVID have gone on to develop long-term COVID-19 symptoms, they're called COVID long haulers. This name can trivialize the symptoms, which need to be , uh , not only recognized and diagnosed but properly treated. And I think this is much like what happened to those who were ultimately diagnosed with ME CFS many years ago. Dr. Fowchee has said that the long holler syndrome is really real and is quite extensive much like , uh , in the early days of ME CFS. Uh, the disease is real and is quite extensive , uh , but it took a long time for the medical community to recognize ME CFS and worse. It took disability carriers even longer to recognize ME CFS as disabling. Now, what they always argue is that there isn't any specific diagnosis for the persistent symptoms of ME CFS. And they do that in COVID cases. They'll say there's no specific diagnosis for the persistent symptoms of COVID-19. They never really got for quite some time, the disabling symptoms of ME CFS and that's happening in COVID-19 cases. There don't get the disabling symptoms of COVID-19 and much likely back in the early days of MECFS and even continuing today, this is the way carrier plays on the subjective nature of ME CFS. And they're doing that in COVID-19 claims. So I think that if you have a COVID-19 claim that you can look to how ME CFS claims were handled for guidance. And I think that there are four issues, there are four issues , um, much like ME CFS claims . So what I'm saying is also applicable to MECFS claims issue. One is that the carriers like to deny or contest claims because the lack of objective diagnosis now, one of the leading medical specialist in ME CFS told me recently that their practice expects to see an increase in misdiagnosed patients because physicians don't know how to deal with COVID-19 claims. They don't know how to diagnose the symptoms. Uh, they don't know how to , um, uh, develop treatment for these symptoms. And as a result , uh , much like ME CFS, there is generally not one physician who handles all these symptoms, nor is there a hard diagnosis for the symptoms and as a result, unfortunately, I think it's going to be a long journey for some COVID , uh, long haul or survivors to deal with this particular problem, much like it was in the early days of MEC issue. Number two is the subjective nature of the symptoms and the subjective medical condition limitation, and a policy now CFS and COVID-19 symptoms and complaints. Can't always be objectively measured. There are some disability policies that have provisions called subjective medical condition limitations. Um, they will limit the period of time in which you get benefits. The clause will generally say that if you have symptoms associated with body pain, fatigue , uh , cognitive issues, that we're only going to pay , um, benefits for two years. Now, that can be an issue, particularly I think if , uh, the symptoms are the manifestation of an objective medical condition like ME CFS or , um, COVID-19 because I think that they are a poorly written subjective , uh , medical condition limitation opens the doors for an argument that benefits should be paid because those subjective symptoms are based or are the manifestation of an objective diagnosis, but they're also more broadly written subjective medical condition limitations that say, look, we're only gonna pay two years of benefits for medical conditions, characterized by pain, muscle joint pain , um , headaches , uh, MEC , Fs COVID-19, et cetera, et cetera. So they'll actually name the disease. In addition to the symptoms that of course can be problematic. And that might in fact be a valid limitation. There are again, reasons why you might want to have , uh , an FCE or a cardiac pulmonary function tests to document the objective basis of the symptoms and , um , how they impact your ability to function. Well , that really is going to be a product in my view of the subjective medical condition clause. If there is one in your policy, now another issue, number three is the metal nervous condition limitation. There are also mental nervous condition limitations in policies that can limit the payment of benefits to two years. If a psychiatric illness is the cause of the disability, there are policies that are broadly written much like the subjective medical condition limitation that says if your medical condition contributes ever so slightly to your disability, your benefits are limited to just two years. I call this the Monty Python , um, wafer thin limitation in mental nervous conditions. Now, unfortunately it's common for COVID-19 , uh , and MECFS suffers to have the cognitive issues and carriers will misclassify those as psychiatric in nature on purpose to try to apply the mental nervous condition limitation. And then of course, issue number four in both MECFS cases and COVID-19 cases, our treatment issues, policies require that you get recognized treatment and that you comply with that treatment program. There is generally no recognized treatment protocol to address COVID long call hall suffers problems, particularly since COVID-19 is ha has multi-symptom impact. So you can have problems with your heart, your lungs, your vascular system, neurological system. You can have cognitive issues , uh, and the lack of treatment protocol , uh , or one-stop doctor, if you will, to treat the , those problems , uh, can play into the hands of a disability care. Who's looking for a reason to deny a claim. Uh , so we need to understand that there's just a host of reasons that these claims are going to be potentially , uh, denied both based on , um, the subjective nature of the condition, the lack of objective findings , um, policy term limitations , uh, and, and treatment issues. If you have any questions about your rights to long-term disability benefits as a result of ME , uh, CF, or COVID-19 the, this is an area where you really do need the assistance of an experienced disability attorney. Um, I think that there are some lessons that you can be, can be learned from contested MECFS claims that apply to COVID-19 claims. Um, the first is that unlike ME CFS, it's hard to pretend or argue that you didn't have COVID-19. Um, I think the other lesson is that research into the basis of ME CFS could be the starting point to begin understanding what has happened in the case of COVID long haulers. But I will tell you again, that the treatment diagnosis , uh, and handling of MECFS claims , uh, is going to be the model that disability carriers are using. In fact, I'm seeing it right now , uh, to deny , uh, these , uh, COVID 19 long-term , uh, long haul claims. So , um, and I think that, that the other point I want to make is that unlike MECFS COVID-19 , uh, will cause pulmonary gastroenterological neurological and vascular issues. And these cases, I think are a bit more complex than an ME CFS case. I know that sounds amazing, but I think that disability carriers are going to want to see , uh , specialty , uh, evaluations, treatments, and opinions. Uh , if you have pulmonary gastroenterological neurological or vascular issues that are going to be addressed as part of a disability claim, having handled many ME CFS, COVID 19 claims. I understand that these claims are complicated , uh, and this is not an area where I think that you should be handling your claim by yourself. So I hope that you have learned , uh, not only information about ME CFS , but that you've learned how the COVID-19 claims are going to be handled. I hope you have enjoyed this week's episode. If you liked this podcast, consider liking our page, leaving a review, or sharing it with your friends or family. And remember our podcast comes out weekly. So stay tuned for next week's episode of winning isn't easy. Thanks.