Sandra Cracknell and Secretary, Department of Social Services
[2014] AATA 910
•5 December 2014
[2014] AATA 910
Division GENERAL ADMINISTRATIVE DIVISION File Number(s)
2014/2943
Re
Sandra Cracknell
APPLICANT
And
Secretary, Department of Social Services
RESPONDENT
DECISION
Tribunal Senior Member CR Walsh
Date 5 December 2014 Place Perth
The Tribunal affirms the decision under review.
..(Sgd) CR Walsh...........................
Senior Member CR Walsh
CATCHWORDS
Social Security – disability support pension – the applicant’s impairments (being fibromyalgia, and depression and tendonitis) were not fully diagnosed, treated and stabilised on the date she claimed DSP, or within 13 weeks thereafter – applicant’s impairments did not attract 20 points or more under the “Impairment Tables” – decision under review affirmed
LEGISLATION
Social Security Act 1991 – s 94(1)(a) – s 94(1)(b) – s 94(1)(c)
Social Security (Administration) Act 1999 – clause 4 of Part 2 of Schedule 2
Social Security (Tables for the Assessment of Work-related Impairment for Disability Support Pension) Determination 2011 – s 6(1) - s 6(2) - s 6(3) – s 6(4) – s 6(5) – s 6(6) – s 6(7) – Table 1 Table 5
CASES
Bobera and Secretary, Department of Families, Housing, Community Services and Indigenous Affairs [2012] AATA 922
Fanning and Secretary, Department of Social Services [2014] AATA 447
Swanson and Secretary, Department of Families, Housing, Community Services and Indigenous Affairs [2009] AATA 606
REASONS FOR DECISION
Senior Member CR Walsh
5 December 2014
INTRODUCTION
Ms Cracknell seeks a review of a decision of the Social Security Appeals Tribunal (SSAT), dated 20 May 2014, which affirmed the decision of a Centrelink Authorised Review Officer (ARO), dated 5 February 2014, to reject Ms Cracknell’s claim for Disability Support Pension (DSP) on the basis that she did not satisfy all of the requirements for qualification for DSP, in s 94 of the Social Security Act 1991 (SSA), on the date she claimed DSP or within 13 weeks thereafter.[1]
[1] The ARO’s decision affirmed an earlier decision of a Centrelink officer, dated 27 March 2013.
The SSAT decided that Ms Cracknell had “impairments” arising from fibromyalgia and depression (and, therefore, she satisfied s 94(1)(a) of the SSA) but that those impairments did not attract 20 points or more under the “Tables for Assessment of Work Related Impairment” (Impairment Tables) in the Social Security (Tables for the Assessment of Work-related Impairment for Disability Support Pension) Determination 2011 (Impairment Determination) on the date she claimed DSP or within 13 weeks thereafter, as required by s 94(1)(b) of the SSA, as the impairments were not fully diagnosed, treated and stabilised at that time.
FACTUAL PROCEDURAL BACKGROUND
On 25 June 2012, Ms Cracknell attended an Employment Services Assessment (ESA) at Centrelink. At the ESA, Ms Cracknell was assessed by a Registered Occupational Therapist (ESA Assessor). A summary of the ESA’s Assessor’s report is provided below under the heading “Relevant medical evidence” (First ESA Report).
Ms Cracknell attended another ESA at Centrelink on 10 January 2013 where she was again assessed by an ESA Assessor who was a Registered Occupational Therapist. A summary of the ESA Assessor’s report on this assessment is provided below under the heading “Relevant medical evidence” (Second ESA Report).
By Medicare “Claim for Disability Support Pension or Sickness Allowance” form, dated 14 February 2013 (which form was lodged with Centrelink on 18 February 2013), Ms Cracknell claimed DSP from Centrelink (DSP Claim).
In the DSP Claim, Ms Cracknell listed “Fibromyalgia” as her “disabilities, illnesses or injuries”, for which she required medication (being ENDEP and pain killers) and that the medication made her drowsy, she was in pain constantly, had headaches and incurable fatigue.
On 26 February 2013, Cracknel participated in a “Job Capacity Assessment” (JCA), by video conference, with a Registered Occupational Therapist (JCA Assessor). A summary of the JCA Assessor’s “Job Capacity Assessment Report”, dated 26 February 2013 (JCA Report), is provided below under the heading “Relevant medical evidence”.
On 27 March 2013, a Centrelink officer rejected the DSP Claim on the basis that Ms Cracknell did not have an impairment which attracted a rating of 20 points or more under the Impairment Tables (Original Decision).
Ms Cracknell subsequently requested an internal review of the Original Decision by a Centrelink ARO and, on 5 February 2014, the ARO affirmed the Original Decision (ARO Decision). The ARO found that Ms Cracknell’s medical condition of Fibromyalgia was “permanent” and fully diagnosed, treated and stabilised and assigned 10 points to the condition under Table 1 of the Impairment Tables on the basis that it would have a “moderate” functional impact upon functions requiring physical exertion and stamina. However, since Ms Cracknell did not have an impairment rating of 20 points or more (and did not have a continuing inability to work) the ARO found that Ms Cracknell did not qualify for DSP.
On 24 March 2014, Ms Cracknell applied to the SSAT for a review of the ARO Decision.
On 20 May 2014, the SSAT affirmed the ARO Decision (SSAT Decision). However, in so doing, the SSAT found that Ms Cracknell’s condition of fibromyalgia was not fully treated and fully stabilised at the Relevant Period and that Ms Cracknell’s medical conditions (of fibromyalgia and depression) attracted “nil” impairment points and, therefore, she did not satisfy s 94(1)(b) of the SSA.
On 10 June 2014, Ms Cracknell applied to this Tribunal for a review of the SSAT Decision.
ANALYSIS
Relevant period
A person’s qualification for DSP is required to be assessed based on his or her relevant impairment as at the date that the person claims DSP, or within 13 weeks of that date: see clause 4(1) of Part 2 of Schedule 2 to the Social Security (Administration) Act 1999. [2]
[2] Swanson and Secretary, Department of Families, Housing, Community Services and Indigenous Affairs [2009] AATA 606 at [7] to [8] and Fanning and Secretary, Department of Social Services [2014] AATA 447 at [33], which was cited with approval in Bobera and Secretary, Department of Families, Housing, Community Services and Indigenous Affairs [2012] AATA 922
Consequently, Ms Cracknell’s qualification for DSP is to be assessed based on her impairments in the period from 18 February 2013 (being the date the DSP Claim was lodged at Centrelink) to 20 May 2013 (being 13 weeks after the date of the DSP Claim) (Relevant Period).
Qualification for DSP – s 94 of the SSA
The requirements for qualification for DSP are set out in s 94 of the SSA, which states:
94 Qualification for disability support pension
(1) A person is qualified for disability support pension if:
(a) the person has a physical, intellectual or psychiatric impairment; and
(b)the person’s impairment is of 20 points or more under the Impairment Tables; and
(c) one of the following applies:
(i) the person has a continuing inability to work;
(ii)the Health Secretary has informed the Secretary that the person is participating in the supported wage system administered by the Health Department, stating the period for which the person is to participate in the system; and
[Emphasis added]
Impairment – s 94(1)(a) of the SSA
The term “impairment” is not defined in the SSA. However, s 3 of the Impairment Determination defines “impairment” to mean:
A loss of functional capacity affecting a person’s ability to work that results from the person’s condition.
It is common ground that Ms Cracknell suffered a physical “impairment” (being fibromyalgia) and a psychiatric “impairment” (being depression) at the Relevant Period and, therefore, satisfied s 94(1)(a) of the SSA.
Impairments attract 20 points or more under the Impairment Tables – s 94(1)(b)
What is in dispute, and what the Tribunal must consider, is whether in the Relevant Period Ms Cracknell’s impairments attracted 20 points or more under the Impairment Tables, as required by s 94(1)(b) of the SSA. If “yes”, the Tribunal must then consider whether Ms Cracknell had a “continuing inability to work” within the meaning and for the purposes of s 94(1)(c) of the SSA.
The Impairment Tables are function based, rather than diagnosis based and describe functional activities, abilities, symptoms and limitations. They are designed to assign ratings to determine the level of functional impact of impairments and not to assess conditions. The Impairment Determination provides that a person’s impairment is to be assessed on the basis of what the person can, or could do, not on the basis of what the person chooses to do or what others do for the person: s 6(1) of the Impairment Determination
Section 6 (2) and (3) of the Impairment Determination provide that an impairment rating can only be allocated to an impairment, for the purposes of satisfying s 94(1)(b) of the SSA, after the person’s medical history has been considered and if:
(i)the condition causing the impairment is “permanent”; and
(ii)the impairment that results from that condition is more likely than not, in light of available evidence, to persist for more than 2 years: see s 6(3) of the Impairment Determination.
Section 6(4) of the Impairment Determination states that a condition is “permanent” if:
(a)the condition has been “fully diagnosed” by an appropriately qualified medical practitioner;
(b)the condition has been “fully treated”;
(c)the condition has been “fully stabilised”; and
(d)the condition is more likely than not, in light of available evidence, to persist for more than 2 years.
The phrases “fully diagnosed” and “fully treated” are defined in s 6(5) of the Impairment Determination as follows:
Fully diagnosed and fully treated
(5) In determining whether a condition has been fully diagnosed by an appropriately qualified medical practitioner and whether it has been fully treated for the purposes of paragraph 6(4)(a) and (b), the following is to be considered:
(a)whether there is corroborating evidence of the condition, and
(b)what treatment or rehabilitation has occurred in relation to the condition, and
(c)whether treatment is continuing or is planned in the next 2 years. [Emphasis added]
The phrase “fully stabilised” is defined in s 6(6) of the Impairment Determination as follows:
Fully stabilised
(6) For the purposes of paragraph 6(4)(c) and subsection 11(4) a condition is fully stabilised if:
(a)either the person has undertaken reasonable treatment for the condition and any further reasonable treatment is unlikely to result in significant functional improvement to a level enabling the person to undertake work in the next 2 years; or
(b)the person has not undertaken reasonable treatment for the condition and:
(i) significant functional improvement to a level enabling the person to undertake work in the next 2 years is not expected to result, even if the person undertakes reasonable treatment; or
(ii) there is a medical or other compelling reason for the person not to undertake reasonable treatment. [Emphasis added]
The phrase “reasonable treatment” is defined for the purposes of s 6(6) of the Impairment Determination in s 6(7) of the Impairment Determination as follows:
Reasonable treatment
(7) For the purposes of subsection 6(6), reasonable treatment is treatment that:
(a)is available at a location reasonably accessible to the person; and
(b)is at a reasonable cost; and
(c)can reliably be expected to result in a substantial improvement in functional capacity; and
(d)is regularly undertaken or performed; and
(e)has a high success rate; and
(f)carries a low risk to the person. [Emphasis added]
Relevant medical evidence
The following medical evidence is relevant to the DSP Claim as it relates to Ms Cracknell’s impairments in the Relevant Period. Any medical evidence provided by Ms Cracknell concerning her impairments which is dated after the Relevant Period (for example, the letter from Dr J G Hughes to Dr J Thein dated, 16 September 2013, regarding Ms Cracknell’s condition of fibromyalgia), is irrelevant to this application and cannot be considered by the Tribunal: see paragraphs 13 and 14 above.
Dr Zilm Medical Certificate
In a Centrelink Medical Certificate, dated 14 June 2012, Dr Damien Zilm diagnosed Ms Cracknell with “R forearm tendonitis” and stated that Ms Cracknell would be unfit for work for the period from 7 June 2012 to 28 June 2012 (Dr Zilm Medical Certificate).
First ESA Report
In the First ESA Report, the ESA Assessor stated that Ms Cracknell had the temporary medical condition “Synovitis, Tenosynovitis & OOS” which had been verified by medical evidence and made the following “Remarks” concerning that condition:
R Forearm tendonitis. Onset late 2011 but flared up in April 2011. Was working 50+ hours per week and has reduced hours. Been referred to TO and has apt 26.6.12. Uses panadeine forte and voltarin gel. Immobilised R forearm for 2 weeks with tape.
In the First ESA Report, the ESA Assessor also stated that Ms Cracknell had the medical condition “Lower Limb Deficiencies” which had an expected duration of 7 June 2012 to 31 August 2012 and made the following “Remarks” regarding that condition:
Reports tendonitis in arches both feet. Having steroid injection in both feet 25.6.12. Has been referred for physio and orthotics. Mobilises feet in morning by rolling sole foot over deodorant.
First Dr Hayes Letter
A letter from Dr Hayes to the Boulder Medical Centre, dated 4 December 2012, suggests that as at that date, the condition thought to be inflammatory arthritis had not yet been fully diagnosed, fully treated and fully stabilised (First Dr Hayes Letter). The clinical findings were said to be “by no means convincing”, a trial of medication was commenced and further blood tests were scheduled.
First Dr Thein Medical Report
In a Centrelink Medical Report, dated 21 December 2012 (and filed on 28 December 2012), Dr Kyaw Thein (Ms Cracknell’s GP/Treating Doctor) reported that Ms Cracknell had a “presumptive” diagnosis of “inflammatory arthritis”, with a date of onset of March 2012, the underlying cause of which was still under investigation (First Dr Thein Medical Report).
The First Dr Thein Medical Report said that the condition started out with pain in Ms Cracknell’s right wrist which spread to her knees, ankles and shoulders and that she currently experienced multiple joint pain and swelling associated with the condition. The First Dr Thein Report identified Ms Cracknell’s “Future/planned treatment” for the condition as “Methotrexate”.
Second ESA Report
In the Second ESA Report, the ESA Assessor stated that Ms Cracknell had the “Permanent” medical condition of “Arthritis” which had been verified by medical evidence. The ESA Assessor made the following “Remarks” in relation to this condition:
Client has a presumptive diagnosis of inflammatory arthritis as reported in the TDR. Past treatments: Analgesics. Current treatments: Medication, specialist reviews. FDTS is not assessed for the purpose of this assessment.
Second Dr Thein Medical Report
In a Centrelink Medical Report, dated 18 February 2013, Dr Thein reported that Ms Cracknell had a confirmed diagnosis of fibromyalgia following a review by a rheumatologist on 11 February 2013. The Second Dr Thein Medical Report listed “Future/planned treatment” for this condition as “Conservative, Endep” and that the condition caused Ms Cracknell generalised aches and pain an joint pain and affected her ability to sit, stand and move (Second Dr Thein Medical Report).
No other medical conditions were listed in the Second Dr Thein Medical Report.
Second Dr Hayes Letter
In a letter from Dr Hayes to the Boulder Medical Centre, dated 25 February 2013, Dr Hayes suggests that he “tend[s] to feel that [Ms Cracknell’s] pain syndrome is most likely ‘Fibromyalgia Syndrome’ ”. This letter also confirms that Dr Hayes changed Ms Cracknell’s treatment to Endep at around this time.
JCA Report
In the JCA Report (dated 26 February 2013), the JCA Assessor found that Ms Cracknell had the “permanent” medical condition of “Fibromyalgia” that was verified by medical evidence as “Fully Diagnosed, Fully Treated and Fully Stabilised” and recommended an impairment rating for the condition of 10 points under Table 1 of the Impairment Tables.
In the JCA Report, the JCA Assessor made the following general “Remarks” regarding Ms Cracknell’s condition of fibromyalgia:
Diagnosed by rheumatologist on 17.2.13. Onset March 2013. Previously had though was inflammatory arthritis. Medication has been changed to endep 25mg daily. Symptoms of generalized multiple joint pain and aches with weakness and lethargy. Specialist has recommended hydro therapy and light exercise up to 30mins 3x weekly. [Emphasis added]
The JCA Assessor noted the following regarding the “Functional impact” of Ms Cracknell’s condition of fibromyalgia in the JCA Report:
Generalised aches and pain that travel over whole body. Her sons now do majority of housework. If goes and walks around supermarket comes home and rests afterwards. Her sons do most of the driving as she says it is painful to drive. Gets up has breakfast does dishes and then has to have a rest, checks letter box, might have bath as heat helps her pain. Might then sweep floor and have another rest. Says she used to be very thorough housekeeper and regularly see her friends but this no longer occurs. Tends to stay home. Endep is now giving her better sleep at night. Feels constantly exhausted and rest does not relieve this.
Dr Kemp Medical Certificate
In a Medical Certificate, dated 19 March 2013, Dr John Kemp, confirmed that Ms Cracknell had been diagnosed with “Major depression with psychotic features”, the date of onset was noted as January 2014, with her symptoms including paranoid delusion, low mood, agitation, poor concentration and poor sleep which were likely to affect her ability to work or study for more than 24 months (Dr Kemp Medical Certificate).
Other medical evidence - Tendonitis
Various other reports provided by Ms Cracknell (for example, a Emergency Department Discharge Letter, dated 27 July 2012, Medical Certificates, dated 14 June 2012, Consultation Notes, dated 14 June 2012, and Clinical Notes, dated 31 July 2012) suggest that, in mid-2012, Ms Cracknell suffered from tendonitis to her right forearm.
In the Consultation Notes, dated 14 June 2012, it was also noted that Ms Cracknell was expected to have a poor outcome in relation to her condition of tendonitis because she was reluctant to take advice, was not using the recommended gel and did not like to take “losec” when she should do so. Further, the Clinical Notes, dated 31 July 2012, suggest that after Ms Cracknell presented to the emergency department, tried Tramadol, which helped her, and that she had plans to see a specialist on 8 August 2012.
Ms Cracknell’s impairments
(i) Fibromyalgia
Table 1 of the Impairment Determination, titled “Functions requiring Physical Exertion and Stamina”, is the Impairment Table used to assign an impairment rating where a person has a permanent condition resulting in functional impairment when performing activities requiring physical exertion or stamina. The “Introduction” to Table 1 provides that the diagnosis of the condition must be made by an appropriately qualified medical practitioner, self-report of symptoms alone is insufficient and there must be corroborating evidence of the person’s impairment.
As stated, the JCA Report and the ARO Decision both concluded that Ms Cracknell’s medical condition fibromyalgia was “permanent” and fully diagnosed, treated and stabilised and assigned it a rating of 10 points under Table 1 of the Impairment Tables. However, the SSAT disagreed and found that Ms Cracknell’s fibromyalgia, whilst “fully diagnosed”, was not “fully treated” and “fully stabilised” at the Relevant Period such that that no points could be assigned to this condition under the Impairment Tables.
10 points can be assigned to a permanent condition under Table 1 of the Impairment Tables if the condition results in a “moderate” functional impact on activities requiring physical exertion or stamina. Table 1 provides that this will be the case if:
(1) The person:
(a)Experiences frequent symptoms (e.g. shortness of breath, fatigue, cardiac pain) when performing day to day activities around the home and community and, due to these symptoms, the person:
(i)is unable to walk (or mobilise in a wheelchair) far outside the home and needs to drive or get other transport to local shops or community facilities; or
(ii)has difficulty performing day to day household activities (e.g. changing the sheets on a bed or sweeping paths); and
(b) is able to:
(i)use public transport and walk (or mobilise in a wheelchair) around a shopping centre or supermarket; and
(ii)perform work-related tasks of a clerical, sedentary or stationery nature (that is, tasks not requiring a high level of physical exertion). [Emphasis added]
20 points can be assigned to a permanent condition under Table 1 of the Impairment Tables if the condition results in a “severe” functional impact on activities requiring physical exertion or stamina. Table 1, provides that this will be the case where:
(1) The person:
(a)usually experiences symptoms (e.g. shortness of breath, fatigue, cardiac pain) when performing light physical activities and, due to these symptoms, the person is unable to:
(i)walk (or mobilise in a wheelchair) around a shopping centre or supermarket without assistance; or
(ii)walk (or mobilise in a wheelchair) from the carpark into a shopping centre or supermarket without assistance; or
(iii) use public transport without assistance; or
(iv)perform light day to day household activities (e.g. folding and putting away laundry or light gardening); and
(b)has or is likely to have difficulty sustaining work-related tasks of a clerical, sedentary or stationery nature for a continuous shift of at least 3 hours.
In circumstances where Ms Cracknell’s prescribed medication for her condition of fibromyalgia had changed just days before the start of the Relevant Period, and the prescribed medication was a reasonable treatment for the condition, it cannot be said that Ms Cracknell’s condition of fibromyalgia was “fully treated” and “fully stabilised” at the Relevant Period. Further, there is no evidence that the treatment recommended by the JCA Assessor in the JCA Report (i.e. “hydro therapy and light exercise up to 30mins 3x weekly”) had been undertaken by Ms Cracknell by the conclusion of the Relevant Period.
Based on the relevant medical evidence, Ms Cracknell’s physical impairment of fibromyalgia was “fully diagnosed” but not “fully treated” and “fully stabilised” at the Relevant Period. Consequently, this impairment was not “permanent” at the Relevant Period (as defined in s 6(4) of the Impairment Determination) and, therefore, could not be allocated an impairment rating under Table 1 of the Impairment Tables for the purposes of s 94(1)(b) of the SSA.
(ii) Depression
Table 5 of the Impairment Determination, titled “Mental Health Function”, is the Impairment Table used to assign an impairment rating to an impairment where a person has a permanent condition resulting in functional impairment due to a mental health condition. The “Introduction” to Table 5 of the Impairment Tables contains the following mandatory requirement:
· The diagnosis of the condition [i.e. the mental health condition] must be made by an appropriately qualified medical practitioner (this includes a psychiatrist) with evidence from a clinical psychologist (if the diagnosis has not been made by a psychiatrist).
· Self-report of symptoms alone is insufficient.
· There must be corroborating evidence of the person’s impairment.
Whilst the Dr Kemp Medical Certificate confirms that Ms Cracknell has been diagnosed with “Major depression with psychotic features”, the date of onset was stated as being January 2014. This is well outside the Relevant Period. As such, Ms Cracknell’s depression was not “fully diagnosed” at the Relevant Period.
There is no medical evidence that indicates that, at the Relevant Period, Ms Cracknell:
·had been diagnosed with depression by an appropriately qualified medical practitioner;
·had undertaken any treatment for her depression; or
·had been given a prognosis that suggested that even with treatment, she was unlikely to experience any significant functional improvement in her depression within 2 years.
Further, Ms Cracknell does not appear to have commenced any anti-depressant medication until February 2013 (when it was prescribed in relation to her fibromyalgia), and there is no evidence that Ms Cracknell had, at the Relevant Period, undertaken any psychological counselling.
Accordingly, the Tribunal finds that Ms Cracknell’s depression was not “fully diagnosed”, “fully treated” and “fully stabilised” at the Relevant Period such that no impairment rating can be assigned for this impairment under Table 5 of the Impairment Tables.
(iii) Tendonitis
There is no medical evidence establishing that Ms Cracknell’s tendonitis was a “permanent condition” for the purposes of s 6(4) of the Impairment Determination at the Relevant Period. That is, the available evidence does not establish that Ms Cracknell’s tendonitis was “fully diagnosed”, “fully treated” and “fully stabilised” at the Relevant Period. Consequently, Ms Cracknell’s tendonitis cannot be assigned an impairment rating under the Impairment Tables.
In reaching this conclusion, the Tribunal notes, that, in addition to the medical evidence set out in paragraphs 39 and 40 above, that in the First ESA Report the ESA Assessor recorded “Synovitis, Tenosynovitis and OOS” as a “temporary medical condition” and in both the First Dr Thein Medical Report and the Second Dr Thein Medical Report, Dr Thein did not record that Ms Cracknell suffers from tendonitis.
(iv) Conclusion on impairment ratings
For the above reasons, at the Relevant Period: (i) whilst Ms Cracknells’ fibromyalgia had been “fully diagnosed” it had not “fully treated” and “fully stabilised”; (ii) Ms Cracknells’ depression had not been “fully diagnosed”, “fully treated” and “fully stabilised”; and (iii) Ms Cracknell’s tendonitis was not “fully diagnosed”, “fully treated” and “fully stabilised”. As such, none of Ms Cracknell’s impairments can be assigned an impairment rating under the Impairment Tables at the Relevant Period.
It follows that, in the Relevant Period, Ms Cracknell did not satisfy s 94(1)(b) of the SSA, which requires that a person’s impairment(s) be assigned an impairment rating of 20 points or more. Consequently, the DSP Claim must fail.
Continuing inability to work
Since the Tribunal finds that none of Ms Cracknell’s impairments could be assigned an impairment rating of 20 points or more under the Impairment Tables at the Relevant Period, it is unnecessary for it to consider whether Ms Cracknell has a “continuing inability to work”, within the meaning and for the purposes of s 94(1)(c) of the SSA, or if she satisfies the other requirements for qualification for DSP, in s 94 of the SSA, at the Relevant Period.
DECISION
For the above reasons, the Tribunal affirms the SSAT Decision.
58. I certify that the preceding 57 (fifty seven) paragraphs are a true copy of the reasons for the decision herein of Senior Member CR Walsh. …(Sgd) T Freeman.....
Dated 5 December 2014
Date of hearing
Date Final Submissions received
12 November 2014
1 December 2014
Representative for the Applicant Self Representative for the Respondent Ms A Ladhams Solicitors for the Respondent Australian Government Solicitor
Key Legal Topics
Areas of Law
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Social Security Law
Legal Concepts
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Qualification for Disability Support Pension
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Impairment Tables
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Continuing Inability to Work
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