Use the clockwork drill to develop this skill. 8 against Tennessee. Mr. 16Business warm on sales tax vote, breathing fir

Angeles. EWU: The player of the game yesterday? That would be Gubrud, who set single game school records in passing yards and total offense.

Therefore ain no invite. Researchers at Boston University have found evidence of CTE in 96 percent of the NFL players’ brains they examined. Because, as Robert just mentioned or alluded to, basically, two thirds of the NFL black players. One of those was identifying which team got measurably worse this offseason.

In other words, we thought we should have gone right to the question of what should be the big renovation or a new facility. “We have high expectations because we’ve been as engaged with the league as we ever have been in terms of what the results are going to be,” Magnus said at the 2017 CAA World Congress of Sports, per Sports Business Daily.

The director of an NFL team scouting department can earn as much as $275,000.. October 1995 OJ Simpson was found not guilty of the murders of Nicole Brown and Ron Goldman in 1994; OJ was later found guilty of manslaughter in a civil trial.. This year’s number one pick was California quarterback Jared Goff, who won’t have to move very far, after being selected by the Los Angeles Rams..

Injuries have been an issue with defensive tackle Kyle Williams (left knee) set to miss his third game and safety Aaron Williams sidelined until at least December with a neck injury. 7 or better in nine of Brees’ 11 seasons in New Orleans? One of the two outliers to that trend was in 2006, when Reggie Bush arrived as the No.

He finished 25 of 52 for 312 yards and touchdowns of 45 yards to Golden Tate, 22 yards each to Marvin Jones and Darren Fells.. At least one more start is likely up for grabs, and Polk is the best bet to get it after seemingly unseating Alfred Blue in the Texans’ pecking order for carries.

NFL teams might then be interested in you as a defensive coach.Play in the NFL. But it hasn’t all gone smoothly. On Oct. After January is over, mid February, March is definitely off season. And the fear of what they could mean.. If Nessa really did post this tweet, basket jersey it’s hard to see how the tweet would be helpful to Kaepernick and could very well slam the door on him joining the Ravens.

He previously had been late for team meetings and, most interestingly, made news this month after he said on social media his pit bull had been dognapped allegedly by gun centric gangsta rapper Boogotti Kasino for a purported $20,000 ransom.. Sports Illustrated once estimated that 78 percent of NFL players end up broke youth hockey jerseys or under financial stress after they retire.

Send your stats and videos directly to the UFC matchmakers who arrange the matches. Meanwhile, Myles Jack probably overshared when he admitted to the New York Post that he his degenerative knee problems may require surgery one day, and that likely prompted his freefall out of the first round Thursday.

RB JAMAAL CHARLES had 103 scrimmage yards (55 rush, 48 rec.) with TD catch in his last meeting (9/15/13 with KC). In Tennessee, both the Titans and Seattle Seahawks remained inside through the anthem.. Does Diaco strike you as a Chatty McChatterson about his recruiting comings and goings.

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The athlete platform is dynamic and the reach is one the Raiders acknowledge through their community work.. Radio disc j

of the zone. And now I just bought your jersey.’ It’s like, ‘All right, buddy. He works full time and often gets several hours of overtime a week, boosting his weekly take home pay significantly..

But it’s Beth and we’ve always known she was going to do this.”. Making it into a professional team is difficult, due to the number of women all competing for the same chance to shine. Small business owners, in particular, may find this to be useful.WHAT IS UNLAWFUL HARASSMENT?Many of us have heard about, observed, or been the victim of rude and degrading conduct by another person.

“Medical experts have not recommended making a change or revisiting our collectively bargained policy and approach [between the NFL and NFL Players Association] related to marijuana, and our position on its use remains consistent with federal law and workplace policies across the country,” states Brian McCarthy, a spokesman for the NFL..

Thomas has the potential to become the best defender from this draft class and a future all pro.. Those taxing yards are not the strong suit of starter Justin Forsett, so as long as Taliaferro is back in the lineup at home against Cincinnati he practiced through a foot injury this week he’s a decent enough bet to poach another score.

And when I lowered my head, he jammed my head, and it kind of, like, jammed my spinal cord. What an embarrassment for Mayor Don Iveson and the entire City of Edmonton group. “Divisive comments like these demonstrate an unfortunate lack of respect for the NFL, our great game and all of our players, and a failure to understand the overwhelming force for good our clubs and players represent in our communities.”.

They get over after midnight. Have to look at their whole debt structure. And on it went until the snow practically started falling.Look, no one has ever questioned Peterson work ethic, desire to play or dedication to his teammates, who worshiped the ground he trampled and universally closed ranks around him during his 2014 child abuse scandal.His legacy as a three time rushing champion, 2012 NFL most valuable player and likely hall of famer is secure in Minnesota.No other player has channeled loss and internalized real or imagined skepticism into such raging production.

We can give our fans three hours of a break but we all know what the focus is and what it should be. He tells reporters that he will keep it low key during the draft, and probably watch a Yankees game, though he is wearing a Cleveland Indians hat while he says it..

She never complained. Style Shooter Shooter Media Gallery 16 hours ago Watch Patriots vs Steelers live stream game 2015 free online September 10 NFL. The argument for the state being so generous with the Saints and Pelicans is that the teams attract so many visitors to Louisiana, particularly New Orleans.

Had to. He sacked Matt Ryan twice, was a wall against the run and overpowered right guard Wes Schweitzer. Business is so good that they use garbage cans to hold the cash they collect from reviews at hobby conventions. I just ask them a lot of questions about the offense, about how the quarterbacks like things here.

Once I got down there I thought, ‘This is something I could get into.’ I did everything from be a ballboy to help with administrative tasks. This allows Allan to study passing routes, rushing tendencies, which receivers are pulled and which running backs are favored.

Specifically, drivers will be able to use two lanes from 20th St. In advance of CTV’s highly anticipated fall premieres, Canada’s most watched entertainment news program, ETALK, delivers an exclusive look at the upcoming series cheap basketball team uniforms in CTV’s BIG FALL PREVIEW airing Friday, Sept.

(An officer said a defiant Simon told him, “I own Eunice!”) He was drafted four days later by the Seahawks; the charges were dropped in December. I’m trying to figure out why the Bills are still getting no respect. Some kickers wear a different kind of shoe on their plant foot for more stability.

JOEY BOSA: The Chargers’ rookie defensive end had a nice NFL debut with two sacks and three tackles for losses in 27 snaps. Es la misma razn por la que fall en no condenar al supremacista blanco David Duke durante la campaa. After starring for the Rams for four nba basketball uniform seasons, Jones was selected by Calgary in the second round (16th overall) of the 2013 CFL draft.

His readiness isn’t outstanding but his ceiling is. In addition, players may have difficulty with flexibility and movement as they grow older.. When Dansby starts his 13th season, only seven Auburn players will have spent more time in the NFL than he has.

Except as may be required by Canadian securities laws, we do not undertake any obligation to update or revise any forward looking statements contained in this press release, whether as a result of new information, future events or otherwise.. It not a mountain.

A great feeling to see these kids smile. Yearly salaries range from $23,000 with benefits to as much as $65,000. National anthem before an NFL football game against the Jacksonville Jaguars at Wembley Stadium in London, Sunday Sept. That what motivates me each and every day to get better..

Whether it’s hype from the fans needing a new record that requires drugs to achieve, or it’s the NFL jockeying for more excitement and more money coming in, we’ve changed to an unhealthy direction and all the money in the world can’t disguise it.. Everywhere you look, all you could behold was Eagles merchandise.

Coach Tom Coughlin could be deploying a true committee that leans week to week on riding the hot hand.. With a new contract and roughly the same support around him, the lone exception being a healthy Ameer Abdullah, Stafford shouldn’t be expected to change his stripes much in 2017.

Hellraiser is a series of films wherein a demon named Pinhead butchers people with hook chains and rips the flesh off of helpless victims to resculpt them into mind bending horrorbeasts. The Sports Xchange Frank Cooney, The Sports Xchange NFL Analysis: Projecting 2014 breakout players Every season players emerge from the shadows of anonymity, or something less than stardom, and play so well they demand to be considered among the best in the league.

There is no salary for reality show contestants, but there are perks associated with certain shows.Stipends and Prize WinningsAlthough there is not always a cash prize, some reality competition shows offer a cash prize for the winners and a weekly stipend for all contestants.

But Kirk Cousins was just 5 for 12 for 69 yards, no TDs and one INT when Jim Schwartz sent extra rushers. Extremely happy that the 1991 team got in and just as happy that Marvin got in. Tishomingo Inn Motel 609 W. You are who we think you are. Support and criticism came from fields well beyond the gridiron, including NASCAR, the NBA, MLB, activists, journalists, entertainers and politicians..

“A team that is going to run the football no matter what front you get, no matter how many guys you have up there trying to stop it. Now, she works out in her pool, walks with a trainer and eats much healthier than she once did. Ravens ‘a dream come true’.

I posted an image to Instagram in the midst jersey football shirts of that emotion that I shouldn’t have and immediately removed it. Zinke says in his memo to Trump that there are billion tons of coal and large oil deposits within its boundaries. “It does include typical GI symptoms like diarrhea, bloating, and abdominal pain, but it really can affect quality of life beyond just that,” she says.

The Tennessee Titans fans are the best in the NFL. Petersburg Times that “playing an NBA mascot is the most coveted job in the sports mascot industry because of the creative, high flying showmanship and the corresponding higher salaries that come with the NBA gigs.” Raymond adds that starting salaries for NBA mascots are in the $40,000 to $45,000 range and that 80 percent of the NBA teams hire full time mascots..

He was part of a stellar draft class led by AP Defensive Player of the Year Khalil Mack and third round guard Gabe Jackson, who have been key to Oakland’s turnaround.. On one hand, sports isErin’s greatest passion. Can Ezekiel Elliott and Co. His 1,590 yards rushing were second best.

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Has 2 INTs, incl. If you can’t make it to the fights, Combate Cl will stream live on ESPN3 and the ESPN app.. Mike Fasol

But we have to stick together as people!! Unity.

With that said, the fortunes of the Ravens will once again be placed on Flacco, for if he takes the steps forward in his development, so will Baltimore. A PSA test that falls outside a specific range considered normal does not always mean cancer and it does not dictate the type of treatment you receive.

There still are probably yet to be discovered genetic and environmental factors that could be contributing as well.”. Argument here is that the NFL could later enforce the suspension. He doubts the government will get involved and try to regulate football like mens football shirts sale it does boxing after a recent study showed that more than 100 former NFL players had chronic traumatic encephalopathy.

1. And of course, they’re also the hardest tickets to snag. Today, by contrast, the inept Niners are but a pesky fly the Seahawks have to swat away a couple of times a year, which they did handily on Sunday in a 38 17 rout at CenturyLink Field. Would be too confusing to many of the voters and that would not be fair to do to them.

He completed 9 of 11 third down passes against the Redskins for 148 yards, two TDs, no INTs and one sack (158.3 rating). The offensive line should be better off this season, returning all 5 starters from unit that had 4 players in new positions a year ago.

King: I’ve read all those people and I respect their work, and I do my own work as best that I can. The National Football League is extremely competitive, so players must compete hard to keep their jobs against new players entering the league every year.

There is no known treatment for CTE, not least because there’s no test that can point it out in the living it’s detected in post mortem brain scans. Marcus Peters, CB, Kansas City. And Conor McGregor.. Members of Xbox Live were partnered with similar players through Microsoft’s TrueSkill Ranking system, which was based on skill level and game preferences.

That’s at least one potential lesson from this past weekend’s NFL draft. At its worst, the NFL is a controlling and conniving league. Truth is, no single act connects these two names together. Steklenski and Kantor used to share a common resistance to, well, using more resistance.

For the top board, center the swivel hinge where the boards connect. The region also plays host to four major sports teams: a NFL, NBA, MLB and NHL team. Sessions said. But Stephon Tuitt dodged that degree of damage and is expected to play again this season after the Pittsburgh Steelers defensive lineman suffered a biceps injury in the opener, just a day after signing a six year extension worth more than $60 million..

10, Parkey made four field goals, including a 54 yarder with 65 seconds remaining in Miami’s 19 17 victory.. After years of working, they ultimately obtained their target of getting to the Super Bowl. Just don hit me in the knee, that life threatening.

He ran his campaign on hate. To Benjamin Franklin Parkway and 24th St. Another year, another football season has come and gone. Artis Payne was inactive for that contest and for Week 1 due largely to his inability to play special teams, putting Whittaker in position to gobble up carries in last week’s win over San Francisco.

In the past few years, teams have added salad bars, juicers, and plant based superfoods like kale, quinoa, almond butter, and whole wheat pasta to their cafeterias, alongside the bacon cheeseburgers and meatball subs. There were no thunderstorms in the area..

The irony is that Trump just gave more attention and credibility to Kaepernick defiance by admonishing the NFL new group of protesters. (knee), WR Andre Caldwell (quadriceps), TE Vernon Davis (concussion), WR Bennie Fowler (ankle), RB Ronnie Hillman (foot).

ET, pricing is more fluid and depends on individual match ups, market size and household penetration. He’s an old school tough guy. EST, FOX. Touchdowns are big points, but aren’t very easy to come by. Ratliff is out for three games. Steelers vs New England Patriots live NFL.

And I never will never.. Wise, a rookie, has impressed this summer. However, they need to receive your attention as a 1/8th ad in a paper costs around $500, and they need that money back before turning a profit. Hooker would be a fantastic addition..

Angle was bad, and I played it too flat. If a player has no faith in the pool cue, his performance is likely to suffer. The suit claimed the team and the league deprived 4 year old Avielle Hernandez of the companionship of her father.The NFL said last month that it would “vigorously” contest the lawsuit, saying it would face “significant legal issues from the start.League spokesman Joe Lockhart said “any attempt to paint Aaron Hernandez as a victim” is wrong.Hernandez had Stage 3 out of 4 CTE, usually found in a 67 year old man.

There’s plenty of time to whip into shape. It won have anything to do with throwing a touchdown. Second round pick Mackensie Alexander didn fare much better and also didn make a single start.. Has a history of engaging in racially fraught battles, from spending years promoting the false story that Barack Obama, the nation first black president, was not born in the United States, to his campaign promise to temporarily ban Muslims from the United States.

Sports commentators are almost exclusively men, and the first woman reporter who did an interview in a locker room caused a huge controversy.. “Just because it might not be popular with the viewer at home doesn’t mean we’re not going to cover it,” he said.

Penn Sate The Nittany Lions junior and first round pick in the 2018 NFL draft ran for just 56 yards against Indiana. Star Wars actor Mark Hamill referred to Trump’sinfamous remark about the Charlottesville protestors which included neo Nazis and white supremacists as “very good people” while Ellen DeGeneres tweeted: “As a football fan, I am proud of the NFL players today. best place to buy nfl jerseys

But I think Wendell on 3rd down specifically, Corey, as well, they’re going to have to step up and assume that role. Did not ask any follow up questions about those alleged concussions.. The merchandise bled into virtually every state, leading to more than 60 search warrants and dozens of arrests..

Following on an unlikely drive in the final minute of play, Wilson and co. “There is no tax break at the NFL for revenue earned from things like ticket sales or jersey sales or corporate sponsorships or television money,” says Jeremy Spector, outside tax counsel for the NFL and a partner at Covington and Burling LLP..

And, you know, for us, we’re not going to be divided by anything said by anyone. Most likely destination for further legal challenges from players union attorneys representing Elliott is with the Southern District of New York. Kelsey Casselbury has a Bachelor of Arts in journalism from Penn State University Park and formal education in fitness and nutrition.

That was the physical distance, of course, when Bussert first moved to New York to work for the Elias Sports Bureau in 1974 after graduating from Illinois with his master’s in journalism and working short stints at the Danville Commercial News, The News Gazette and the now defunct Urbana Courier.

There also are efforts across the NFL to raise relief money.. Meanwhile, the Orange County Register quietly decided to scrap because enough people were offended, and left it at that. References The National Football League: 2013 NFL Postseason Media Guide CNBC: What Players Get Paid for Winning the Super Bowl Christian Science Monitor: Who Were Super Bowl’s Big Financial Winners? Not the Players.

It also did not offer to compensate over 200 players who were adversely affected in 2010 by a change in the free agency rules. But there are evaluators who question why he had only five interceptions in three college seasons, and wonder whether his versatility at Florida State could work against him..

The Bears placed Kevin White on injured reserve Tuesday, a setback for both the oft injured wide receiver and an offense in need of playmakers. David Johnson is out the foreseeable future, and Carson Palmer not the player he used to be. 12, 2017″ > >How Kevin White career compares to other receivers drafted in 2015A broken shoulder blade has put injury prone Bears receiver Kevin White season in doubt.

Sherman has been listed on the injury report each week this season, first with a thigh injury and then with a hamstring injury. The Danish born kicker then played for the Giants, Chiefs and Vikings before returning to Atlanta in 2006. Only teams with more appearances are Pittsburgh and San Francisco (15), and Dallas (14).

In 2009, no executives earned an increase in base pay and their bonuses were smaller than in the previous year, according to an NFL memo acquired by Sports Business Daily.. The newest Fit adds an extra dose of style and attitude with the addition of an aggressive aero form front underbody spoiler and rear diffuser with orange pinstriping, side underbody spoilers, 16 inch aluminum alloy wheels with gloss black finish and chrome exhaust finisher.

Against Tennessee, the Dolphins were two of 13 on third down conversions. “With so many families reliant on the health care exchange across our state, I am extremely disappointed in the decision by several insurers to pull out of Indiana’s Exchange.

Despite all of those openings at QB, and plenty of bad play at the position, Kaepernick remains unemployed. The NFL has unwittingly allowed itself to become the biggest platform in America’s summer of discontent, pitting certain minority groups against the police and their supporters..

He’s also eligible for the practice squad again and the Redskins might not need a fourth RB.. Why weren’t the players disciplined for not following NFL rules? Because initially their pocket books and revenues weren’t hurt. He said congrats and it’s just the start, which it is..

They lost 23 3 to Carolina and 49ers offense struggled with quarterback Brian Hoyer threw for 193 yards and the offense posted 217 yards of offense. However, those referees with the most experience still earn more than a comparable referee with less time served..

I implore Trump to cease military ad spending with the NFL Stop providing Air Force flyovers Stop providing Armed Service color/honor guards Remove any tax breaks the NFL recieves Remove the NFL Anti Trust protection[ In many cases taxpayers contribute to cost of stadiums and hold notes on those loans demand immediate repayment ]Please copy my comment and spread it everywhereReply I printed the list of those companies who support the effort to express publicly hate for the people, the nation, the flag, the National Anthem, the military, the law enforcement personnel, and the President of the United States of America.

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This task is of particular importance in the NFL because the league has a salary cap for its teams. This means that rega

years ago, will likely get the boot after this season.Frost, of course, is a Nebraska born legend and former national championship winning quarterback for the ‘Huskers.

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Social Security Disability helps people who work

People with disabilities are challenged with both overcoming barriers and with convincing others that those barriers do not define them.

That’s why we wanted to mark this October’s National Disability Employment Awareness Month by reminding you that Social Security is an earned benefit for millions of disabled individuals, and we can assist them in going back to work.

The Social Security disability insurance program, or SSDI, is perhaps the most misunderstood program of Social Security. Some people may think that SSDI recipients have never worked and are taking advantage of the system by receiving money for minor impairments.

Nothing could be further from the truth. First, anyone who qualifies for SSDI must have worked enough to pay into the system and be “insured.” Second, Social Security has some of the strictest requirements in the world for disability benefits. To qualify, a person must not only have an impairment that will last one year or more, or result in death, but they must be unable to perform any substantial work.

Consequently, Social Security disability beneficiaries are some of the most severely impaired people in the country, and they greatly depend on their benefits. You can learn more by visiting the Faces and Facts website at At the website, you will find many personal stories of those who have benefitted from Social Security when they needed it most.

We also have incentives that give beneficiaries with disabilities — who are able — the opportunity to return to work. These work incentives include continued cash benefits for a period of time while you work, continued Medicare or Medicaid coverage, and help with education, training and rehabilitation to start a new line of work. In some cases, we may even be able to deduct certain impairment-related work expenses from your countable income, making it possible to earn more and also remain eligible to receive benefits. Examples of these expenses are wheelchairs, transportation costs, and specialized equipment needed for work.

Social Security also offers the Ticket to Work program, which gives participants a “ticket” to go back to work while keeping their disability benefits. This program is free and voluntary. Ticket to Work gives access to an employment network, which offers assistance with job searches and placement, and vocational rehabilitation and training.

Those who enroll find the Ticket to Work program makes it easier to explore whether going back to work is right for them. Some even find that they are able to eventually get back to work and earn far more than the disability payments they once received.

Visit for more information on the Ticket to Work program and work incentives. Or call 866-968-7842 (TDD 866-833-2967).

Article Source: By Brian Hewitt Special to the Tribune-Star

Posted: Saturday, October 24, 2015 6:00 pm

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Social Security Q&A: What Happens to Disability Benefits at Retirement Age? | Valley News

Question: If I get Social Security disability benefits and I reach full retirement age, will I then receive retirement benefits?

Source: Social Security Q&A: What Happens to Disability Benefits at Retirement Age? | Valley News

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How You Qualify For Social Security Disability Benefits

To qualify for Social Security disability benefits, you must first have worked in jobs covered by Social Security. Then you must have a medical condition that meets Social Security’s definition of disability. In general, we pay monthly cash benefits to people who are unable to work for a year or more because of a disability.

Benefits usually continue until you are able to work again on a regular basis. There are also a number of special rules, called “work incentives,” that provide continued benefits and health care coverage to help you make the transition back to work.

If you are receiving Social Security disability benefits when you reach full retirement age, your disability benefits automatically convert to retirement benefits, but the amount remains the same.

Article Source: Social Security Administration

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Social Security: a woman’s perspective

Regardless of whether you’re a man or a woman, Social Security will not — and was never designed to — provide all of the income you’ll need to live comfortably during retirement. At best, your income from Social Security will supplement your other sources.

If you are factoring Social Security into your retirement plan, you should learn all you can about how to enhance your benefits, and how much income you may need from other sources, to be financially comfortable during your retirement years.

For women, however, there are some unique factors to consider in the equation.

With longer life expectancies than men, women tend to live more years in retirement and have a greater chance of exhausting other sources of income.

Because Social Security generally has annual cost-of-living adjustments, you have an inflation-protected benefit for as long as you live. For women, those increases are vital since women generally live longer than men.

In addition, Social Security provides dependent benefits to spouses, divorced spouses, elderly widows and widows with young children.

While Social Security is neutral with respect to gender (individuals with identical earnings histories are treated with the same in terms of benefits), the following 2012 numbers released by the Social Security Administration Office of Research and Statistics highlight how demographic characteristics of women compare with the entire population.

Women reaching age 65 need to prepare for approximately 21.4 more years of living expenses. Men live an average of 19.1 more years.

Women make up 56 percent of all Social Security beneficiaries age 62 and older and approximately 67 percent of beneficiaries age 85 and older.

The average annual Social Security income received by women 65 years and older was $12,520 compared to $16,398 for men.

For unmarried women age 65 and older (including widows), Social Security composed 50.4 percent of their total income. In contrast, only 35.9 percent of unmarried elderly men’s income and 30.2 percent of elderly couples’ income came from Social Security.

Of all elderly unmarried women receiving Social Security benefits, 49.6 percent relied on Social Security for 90 percent or more of their income.

Only 22 percent of unmarried women age 65 or older were receiving their own private pensions, compared with 27.7 percent of unmarried men.

Of the women who were employed full time, 55 percent participated in an employer-sponsored public- and private-sector plan compared to 52.3 percent of men.

While participation in employer-sponsored retirement plans is increasing for women in today’s workforce, women generally received lower pension benefits than men due to their relatively lower earnings.

Probably none of this comes as a surprise, considering women earning less and spending more time out of the work force than men.

On average, women spend 12 years out of the work force caring for others. Women also are more likely to work at small companies that lack employer-sponsored benefit programs and hold part-time rather than full-time positions.

Looking at the whole picture, you can see how these factors might tend to significantly affect women’s Social Security benefits and any retirement plan or pension plan benefits they may have accrued.

So how do women offset this gap? Get a retirement plan in place so Social Security benefits can be an income supplement and not a mainstay.

To help you determine a retirement strategy that is appropriate for your personal financial situation, talk with your financial adviser.

This article was written by Wells Fargo Advisors and provided courtesy of Dustin Schofield, vice president of The Schofield Group Investment Management in St. George at 435-674-3601 or

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What are the requirements for receiving disabled widow’s benefits?

You may be able to get disabled widow(er)’s benefits at age 50 if your disability must have started before age 60 and within seven years of the latest of the following dates: the month the worker died; the last month you were entitled to survivors benefits on the worker’s record as a parent caring for a surviving minor child; the month your previous entitlement to disabled widow(er)’s benefits ended because your disability ended.

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Top Ten Mistakes Social Security Makes on Your Disability Case That Get Your Case Remanded

Because only one-quarter to one-third of disability applications are approved at the initial level, a successful disability claim usually requires more than one appeal. While many disability applicants win their cases after a hearing in front of an administrative law judge (ALJ), some are again denied. If you receive an “unfavorable” decision (a denial) or a “partially favorable” decision from the ALJ, you have 60 days from the date of the denial notice to request an appeal from the Appeals Council. (A partially favorable decision grants you disability benefits, but the retroactive payments don’t go back to when you say you first became disabled.)

Before you file an appeal with the Appeals Council, you must carefully examine the ALJ decision and look for errors of fact or law. If you can craft a persuasive argument as to why the ALJ’s decision was not supported by substantial evidence, you’ll have a decent chance at getting the Appeals Council to remand (send back) your case to the ALJ for a new hearing. (While the Appeals Council may reverse the ALJ outright and award benefits itself, this happens so infrequently that it’s barely worth mentioning. In reality, a favorable Appeals Council decision usually involves sending your case back for a new hearing, with special instructions to the ALJ.)

The remand rate at the Appeals Council was as high as 40% just a few years ago, but it has declined recently. As of February 2012, the rate stood at 22%, a number which still indicates that it’s entirely possible to win an Appeals Council case if the facts and law are on your side.

Pointing out mistakes made by the ALJ can increase your chances of getting a remand. What kinds of mistakes should you look for when reading your ALJ decision? Here are some common grounds for remand cited by the Appeals Council having to do with improper consideration of your limitations, although there are many others.

Insufficient Weight Given to the Treating Physician’s Opinion

The most common reason for the Appeals Council to remand a case is that the ALJ failed to give adequate weight to the opinion of the applicant’s treating physician. If the doctor or mental health professional who regularly treats you has completed a Medical Source Statement or Residual Functional Capacity (RFC) form indicating that you have substantial work-related limitations, and the ALJ didn’t give a good deal of consideration to these limitations, you may have solid grounds for appeal.

Under Social Security regulations, ALJs are required to identify and explain what weight they gave all medical source (doctor) opinions. If your ALJ gave your doctor’s opinion something less than “controlling” weight, find out why. If the reasons don’t stand up to scrutiny, you or your lawyer should mention this in your letter to the Appeals Council.

RFC Not Supported By Substantial Evidence

Every ALJ decision contains an assessment of your RFC, or the most you can do despite your impairments. If you’re suffering from depression, anxiety, and knee pain, for example, the ALJ may decide you’re limited to jobs with only occasional interaction with co-workers, no contact with the general public, and only two hours of standing per day.

Your RFC is incredibly important because it helps determine whether there are jobs that exist in the United States that you can perform. The ALJ cannot ignore limitations that are in your medical file and say that you can do more than your doctor’s notes or medical evidence indicates you can do. If the ALJ’s assessment of your RFC is not supported by the medical evidence, you should make that argument to the Appeals Council.

Vocational Expert Testimony Not Based on Correct RFC

Pay attention to the testimony of the Vocational Expert (VE) at your hearing, and particularly note the details of the hypothetical questions that the ALJ asks the VE. Here’s an example of a hypothetical question a judge might ask: “What jobs, if any, could a person of the same age, education, and with the same work history as the claimant be able to do if he or she could lift no more than 10 pounds on a regular basis, could stand no more than two hours per day, and could not have contact with the general public?”

It often happens that the ALJ will fail to include certain elements or limitations of your RFC in her hypothetical questions to the VE about whether a person could work. For example, the ALJ might neglect to ask about a hypothetical person who can have only occasional interaction with co-workers. The unfortunate result is that the VE will identify certain jobs that a hypothetical person could do, but your RFC is more restrictive than the hypothetical individual’s.

You have an absolute right to request a copy of the hearing audio, and you should consider listening to it in the course of preparing your appeal. If no VE testified at your hearing, this may be grounds for appeal itself, if you could show that you suffered from a severe non-exertional (that is, non-strength-related) impairment.

Impairment Erroneously Classified as “Non-Severe”

At Step Two of Social Security’s five-step process for deciding disability cases, Social Security determines which of your impairments are severe and non-severe. As defined by Social Security, a severe impairment is one that “significantly limits an individual’s physical or mental abilities to perform basic work activities.” Non-severe impairments are slight abnormalities causing only a minimal effect on basic work activities. In practice, the bar for what’s considered “severe” is set rather low. If the medical evidence in your case shows that one or more of your impairments is limiting basic work activities (like walking, standing, focusing, following directions), the impairment should be considered severe.

ALJ Didn’t Consider Both Severe and Non-Severe Impairments

Even if one of your impairments was properly labeled non-severe, the ALJ needs to consider its effect on your ability to work. A Social Security regulation requires the ALJ to consider the restrictions and limitations caused by all of your impairments, even those that are non-severe. For example, if the ALJ finds that you suffer from anxiety but that it’s non-severe, you still may be prevented from performing certain types of jobs, such as those that require frequent interaction with the general public. When combined with your other physical or mental limitations, this limitations may prevent you from doing your past job or limit the number of other types of jobs that you could do.

There are many other grounds for appealing your decision to the Appeals Council. To find remandable issues in your case, check with an experienced disability attorney in your area, and read on to the next page to find out about errors judges make concerning credibility, summarizing your testimony, not developing the evidence in your case, and more.

If you’ve received an unfavorable or partially favorable decision after your disability hearing, you should examine the Administrative Law Judge’s decision for factual or legal errors. If you find a significant mistake that could change the outcome of your case, you should appeal your case to the next step, the Appeals Council.

Some of the most common errors made by Social Security include failing to afford proper weight to your treating doctor’s opinion, assigning you an incorrect Residual Functional Capacity (RFC), or asking incomplete questions of the Vocational Expert (VE). (Read about those errors in the first page of this article, on common mistakes made by Social Security judges.)

Here are several more mistakes ALJs make in their decisions that you can appeal to the Appeals Council, all having to do with when the judge improperly ignores or discounts available evidence.

ALJ Didn’t Give Specific Reasons for Not Finding You Believable

The ALJ is required to make a determination (“finding”) of your credibility and to use specific reasons in explaining that finding in his or her decision. For instance, if an ALJ finds that an applicant’s testimony is not believable, a conclusory statement such as “the claimant’s allegations are not credible” or “the claimant’s allegations are unsupported by objective medical evidence” is insufficient. The ALJ needs to be more specific; for example, “The claimant repeatedly made inconsistent statements about his use of alcohol.” The Appeals Council generally gives wide latitude to ALJs in determining whether an applicant is credible, but only when ALJs provide reasoned explanations of their findings.

ALJ’s Discussion of Your Testimony Left Out Important Information

The ALJ is not permitted to mischaracterize or inaccurately summarize your hearing testimony in his or her decision, although this happens with surprising regularity. For example, if you state at the hearing that your friend takes you grocery shopping once per month, but you need to use a motorized cart while at the store and can’t unload your groceries due to pain, the ALJ should not summarize your testimony by saying, “The claimant stated she is able to go grocery shopping.” Request the audio recording of your hearing to compare what you actually said with what the ALJ claims you said.

ALJ’s Decision Didn’t Discuss Serious Side Effects of Your Medication

Social Security regulations require the ALJ to consider the type, dosage, effectiveness, and side effects of all of a claimant’s medications. If, for example, you take pain medication that causes you nausea and fatigue, the ALJ should discuss these side effects and how they would affect your ability to work. The limitations caused by these side effects should be a part of your RFC and should at least be mentioned in the judge’s decision.

ALJ Discounted Observations of Non-Physician Medical Professionals

Social Security splits medical professionals into two categories: “acceptable” medical sources (physicians, psychologists) and “other” medical sources, which include therapists, counselors, chiropractors, and nurses. While these “other” sources may not establish the existence of a medically determinable impairment (this basically means they can’t provide a diagnosis of the condition that could be causing your symptoms), these other sources may provide information and opinions about the severity of your impairment. The ALJ cannot improperly discount the opinions or observations of these non-physician medical sources and is required to explain the weight given to them. Failure to do so can result in the Appeals Council sending your case back to the ALJ for a new decision.

ALJ Did Not Develop Your Medical Record

ALJs are required to make sure there is enough evidence in your record to fairly decide the case. Unlike a regular court case, where each side is responsible for finding their own evidence and presenting it, the U.S. Supreme Court has held that Social Security proceedings are not “adversarial,” but “inquisitorial,” meaning that the ALJ has a duty to investigate the facts and develop the evidence supporting and opposing your case. If the medical evidence in your case is unclear or insufficient to allow the judge to make a fully informed decision, the ALJ may need to re-contact your physician or send you for a consultative examination with one of Social Security’s doctors.

For instance, there is often some indication in an applicant’s file of a low IQ (such as past special education classes or reported difficulty reading and writing), but no recent IQ test results. Because a low IQ can extremely important in a disability case, the ALJ may be required to send you for an intelligence test before deciding your case. Failure to do so can be “reversible error.”

Sorting Through Errors

Remember that ALJ decisions almost always contain some error of fact or law that can be argued to the Appeals Council. Social Security regulations and the reviewing federal courts require a great deal of specificity and accuracy in ALJ decisions, and it’s a good bet that if an error can be made, it has been made by an ALJ at some point in time. Your chances at the Appeals Council will be improved substantially if you focus on specific, non-trivial mistakes of law and fact, especially those related to your doctor’s opinions, your RFC, and the VE’s testimony.

Before trying to handle an appeal to the Appeals Council or federal court on your own, consult with an experienced disability attorney to get advice on what mistakes the ALJ might have made in your case.

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