What is an attending physician statement (APS)? A field guide for underwriting and disability claims

Ask a life underwriter and a group LTD examiner what an APS is and you get 2 answers, both right. Mixing them up costs time: a chart sent when the carrier wanted the form, or a broker promising the doctor "just fills out a form" when the underwriter has ordered 6 years of records.

In both, the insurer knows nothing until paper arrives, and everything slow about an APS sits in that gap.

The vocabulary you need for the claims side

Restriction

What the patient should not do, because doing it risks harm. "No lifting over 10 lb" is a restriction. It is a medical instruction.

Limitation

What the patient cannot do, because of the condition. "Can sit 30 minutes at a time" is a limitation. It is a statement of capacity.

Material duties

The core tasks of an occupation as the policy defines them, usually the occupation as performed in the national economy rather than at 1 employer.

Own occupation

The period in which the claimant is disabled if unable to perform the material duties of their own occupation. The policy sets its length.

Any occupation

The later period in which the claimant must be unable to perform any gainful occupation for which they are reasonably fitted by education, training or experience, again as the policy words it.

Elimination period

The waiting period between the date disability begins and the date benefits start. The onset date on the APS starts this clock.

Objective findings

Evidence that does not depend on the patient's report: imaging, test results, measured range of motion, reflexes, observed signs.

An underwriting APS has no fixed form. It is whatever the office copies, and its value depends on what the request asked for. A good request names the period and the parts: office notes, problem list, medication list, lab and imaging reports, consult letters, and hospital discharge summaries held in the chart. Without that list, some offices send the last visit only, and the file goes back for a second request.

A claims APS is a form, and its fields are the same across most carriers even when the layout differs. The mock below is a hypothetical physician section for a lumbar disc claim. Each pin marks a field where claims are won, lost or sent back for clarification.

What an underwriting APS usually holds

• Problem list and diagnoses, with the date each first appears. Items the applicant did not disclose surface here.
• Medications and every dose change. A second or third agent added for blood pressure or diabetes tells the underwriter how well the condition is controlled.
• Vitals and build at each visit: blood pressure, height, weight, BMI.
• Labs: A1c, lipids, liver and kidney function, PSA, urine protein, each with a date.
• Imaging, cardiac testing, pathology and consult letters, which also name providers the applicant forgot to list.
• Social history: tobacco, nicotine, alcohol, drug use, and any counseling to quit.
• Plan lines: "recheck in 3 months", "refer to cardiology", "patient declined colonoscopy". These are the lines underwriters miss when they skim.

Most life and disability insurers are not HIPAA covered entities. The physician's office is. So the rule that governs an APS request is the one that governs the office: it cannot send protected health information to an insurer for underwriting or claims without a valid authorization from the patient.

"Except as otherwise permitted or required by this subchapter, a covered entity may not use or disclose protected health information without an authorization that is valid under this section."

That is why the application and the claim form each carry an authorization page. A defective one is a quiet cause of a late APS: the records office returns the request, and nobody tells the underwriter for a week or 2.

What makes an authorization valid

Section 164.508(c) lists 6 core elements and 3 required statements. An authorization missing any of them is defective under 164.508(b)(2), and so is one that has expired, has been revoked, or contains information the office knows to be false.

3 rules insurers and claimant attorneys trip over

Psychotherapy notes need their own authorization. Under 164.508(a)(2), a covered entity needs a specific authorization for psychotherapy notes, and under 164.508(b)(3)(ii) that authorization can only be combined with another psychotherapy notes authorization. The chart's ordinary mental health content (diagnoses, medications, visit dates, treatment summaries) comes with a general authorization. The therapist's separate process notes do not.

Revocation has an insurance exception. A patient can revoke an authorization in writing at any time, except to the extent the office already relied on it, or, under 164.508(b)(5)(ii), where the authorization was obtained as a condition of obtaining insurance coverage and other law gives the insurer the right to contest a claim under the policy or the policy itself. The exception protects the insurer's right to contest the policy or a claim. How far it reaches in a given dispute is a question for counsel.

The claimant can get the records faster than the insurer. A patient's own request under the right of access at 45 CFR 164.524 must be acted on within 30 days, with 1 extension of up to 30 days and a written reason. No such clock applies to an insurer's authorized request. Claimant attorneys who request the chart themselves, then submit it with a completed APS, control both the timing and the completeness of the file.

• Expiration date checked against today's dateThe top cause of a returned request.
• Recipient class covers everyone who will see the recordsVendor, carrier, reinsurer, administrator.
• Purpose matches the requestUnderwriting, claims, or both.
• Signature, date, and authority of any representativePower of attorney or guardianship named.
• Revocation, conditioning and redisclosure statements present164.508(c)(2).
• Psychotherapy notes requested separately, if at all164.508(a)(2) and (b)(3)(ii).
• Provider name, practice, address and fax verifiedA request to the wrong office is lost time, not a denial.

0 of 7 checked

State law can add stricter conditions for HIV status, substance use treatment, genetic testing and mental health records, and federal rules for substance use disorder programs sit on top of HIPAA. Your compliance team owns those rules; the checklist above is only the HIPAA floor.

In underwriting, APS retrieval is often the slowest step in a fully underwritten case, and it drives placement: applicants who wait too long buy elsewhere or not at all. In claims, it drives the ERISA clock. Either way, most of the delay is logistics, not medicine.

The expensive failure is the loop from step 5 back to step 1: a consult letter names a cardiologist nobody listed, and the case waits for a second APS.

What the ERISA clock does with a late APS

For an employer-sponsored disability plan, the clock starts when the claim is filed under the plan's procedures, "without regard to whether all the information necessary to make a benefit determination accompanies the filing" (29 CFR 2560.503-1(f)(4)). The plan has 45 days. It can extend twice by up to 30 days, but only for matters beyond its control, and only with a notice sent before the current period runs out that explains the standards for entitlement, the unresolved issues, and the additional information needed (f)(3).

When the extension is needed because the claimant has not supplied information, the claimant gets at least 45 days to provide it, and the decision clock is tolled from the date the notice is sent until the claimant responds (f)(4). A treating physician who has not returned the APS is the most common reason a claims file needs that notice. The practical consequence for claimant attorneys: an APS delivered with the claim, complete and consistent with the notes, keeps the plan on its 45 day clock.

An underwriting APS answers 2 questions. Does the chart agree with the application, the exam and the database checks? And what does the chart show that none of those could? The second question is where the rating comes from, and it is answered by trends and plan lines more than by the problem list.

A reading order that catches what skimming misses

1. Inventory first. Count pages, list every provider and date range, and mark duplicates. A 400 page APS with 150 duplicate pages is a 250 page APS, and the duplicates hide the 1 page that differs.
2. Problem list and first-documented dates. For each diagnosis, find the first visit that names it. The application asks "have you ever been diagnosed", and the answer depends on that date.
3. Medications over time. Build a dated list with doses. A drug started and stopped within 2 months, a third blood pressure agent, insulin added to oral agents: each tells you more about control than the diagnosis does.
4. Build, blood pressure and labs as trends. Put every reading in a table by date. One high reading is noise; 6 rising readings are a finding.
5. Plan lines and open items. Every "recheck", "refer", "order" and "follow up in" line gets a status: done, not done, or unknown. Open items are where postponements come from.
6. Adherence and behavior. "Patient did not return", "ran out of medication", "declined", "no-show", "counseled on tobacco". These lines change offers and are the easiest to miss.
7. Named providers. Every consult letter, referral and outside result names someone. Check each against the application and the retrieval order.
8. Discrepancies last. Only now compare chart and application line by line. Doing it first makes you read the chart to confirm the application, which is the wrong direction.

The 5 things underwriters look for

The trend table

What the summary hands the underwriter

3 discrepancies with the application (diabetes on metformin, a tobacco note, an unlisted cardiologist), 1 treatment lapse, 1 open sleep study and 1 same-day conflict between assessment and problem list, each with its page.

What the summary does not do is say what any of this is worth. What to order, ask or rate is the underwriter's call against the carrier's manual. The summary's job is that none of the 6 items is missed and each can be checked in 10 seconds.

UNDERWRITING APS SUMMARY
Applicant: [NAME]   Policy/case no.: [NUMBER]   Product: [TERM / UL / DI / LTC]
Provider(s) in this APS: [PRACTICE, PHYSICIAN, DATES OF SERVICE COVERED]
Pages received: [N]   Unique after duplicates removed: [N]   Date received: [DATE]
Request period asked for: [FROM] to [TO]   Period actually produced: [FROM] to [TO]

1. DIAGNOSES (first documented date, current status, page)
   [DIAGNOSIS] | first noted [DATE] p. [X] | status [ACTIVE/RESOLVED/UNCLEAR] p. [X]

2. MEDICATIONS (drug, dose, start, changes, stop, page)
   [DRUG DOSE] | start [DATE] p. [X] | change [DATE, NEW DOSE] p. [X]

3. VITALS, BUILD AND LABS (date order)
   Date | BP | Height/Weight/BMI | [A1c] | [Lipids] | [Creatinine/eGFR] | [LFTs] | page

4. TESTS AND IMAGING (ordered, resulted, abnormal findings)
   [TEST] ordered [DATE] p. [X] | result [DATE, FINDING] p. [X] or NO RESULT IN FILE

5. OPEN ITEMS (orders, referrals, rechecks with no documented completion)
   [ITEM] | ordered/recommended [DATE] p. [X] | status: NOT FOUND IN RECORDS PRODUCED

6. ADHERENCE AND BEHAVIOR (quote the chart)
   "[EXACT WORDS]" [DATE] p. [X]
   Tobacco/nicotine: "[EXACT WORDS]" [DATE] p. [X]
   Alcohol/drugs: "[EXACT WORDS]" [DATE] p. [X]

7. PROVIDERS NAMED IN THE CHART
   [PROVIDER, SPECIALTY] | named on p. [X] | on application? [YES/NO] | ordered? [YES/NO]

8. CHART VS APPLICATION
   Application says: "[ANSWER]" | Chart shows: "[ENTRY]" [DATE] p. [X]

9. INTERNAL CONFLICTS IN THE CHART
   [ENTRY A] p. [X] vs [ENTRY B] p. [Y]

Prepared by: [NAME]   Date: [DATE]
Facts only. No rating, class or recommendation. Every line cited to a page.

Conflicts are the normal state of a medical record: stale problem lists, templated exams, a specialist and a generalist using different words, a claims form that says more than the notes. The mistake is to resolve a conflict silently by picking the entry you like. The fix is a fixed path that ends in either a documented choice or a specific question.

Conflicts you will see again and again

Most private-employer group LTD and STD plans are ERISA plans, governed by the Department of Labor's claims procedure regulation at 29 CFR 2560.503-1. Government and most church plans are outside ERISA, and individual disability policies follow state claim rules instead. For an ERISA plan, the regulation shapes when the APS must arrive, what the plan must say about it, and what the claimant may see.

What changed for claims filed after April 1, 2018

The Department of Labor amended the regulation for disability claims, and paragraph (p)(3) applies the new paragraphs to claims filed after April 1, 2018. The changes that touch the APS most directly:

• Impartiality. Under (b)(7), decisions about hiring, pay, termination or promotion of a claims adjudicator or medical or vocational expert "must not be made based upon the likelihood that the individual will support the denial of benefits."
• Denial notices must engage with the treating physician. Under (g)(1)(vii)(A), a disability denial must discuss the decision, including the basis for disagreeing with or not following the views of the claimant's treating health care professionals, the plan's own medical and vocational experts, and any Social Security determination the claimant presented.
• Internal criteria disclosed. Under (g)(1)(vii)(C), the notice must give the internal rules, guidelines or protocols relied on, or say that none exist.
• New evidence and new rationales shared before the appeal decision. Under (h)(4)(i) and (ii), the plan must give the claimant, free of charge, any new or additional evidence or rationale considered on appeal, early enough to respond.
• Deemed exhaustion. Under (l)(2)(i), if the plan fails to strictly adhere to the regulation, the claimant is deemed to have exhausted administrative remedies and may sue, subject to the narrow exception in (l)(2)(ii).

"A discussion of the decision, including an explanation of the basis for disagreeing with or not following: (i) The views presented by the claimant to the plan of health care professionals treating the claimant and vocational professionals who evaluated the claimant"

No treating physician rule, but no ignoring the APS either

In Black and Decker Disability Plan v. Nord, 538 U.S. 822 (2003), a unanimous Supreme Court held that ERISA does not require plan administrators to give special deference to treating physicians' opinions, and that courts may not impose a special burden of explanation when an administrator credits reliable evidence that conflicts with one. The Court drew the limit in the same passage:

"Plan administrators may not arbitrarily refuse to credit a claimant's reliable evidence, including the opinions of a treating physician."

Read together with the 2018 notice rule, the practical position is plain. A treating physician's APS does not win by being from the treating physician. It wins by being reliable: specific, supported by findings, and consistent with the chart. A plan that disagrees has to say why, in writing.

Standard of review sits on top of all this. Under Firestone Tire and Rubber Co. v. Bruch, 489 U.S. 101 (1989), a court reviews a denial de novo unless the plan gives the administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the plan's terms, in which case review is deferential. Some states void discretionary clauses in insured policies: California Insurance Code section 10110.6, for example, does so for life and disability coverage of California residents. Whether a court will look at evidence the administrator never saw depends on the standard of review and the circuit, so an APS that never reached the claim file may never be read by the judge.

Claims examiners and reviewing physicians read hundreds of APS forms. They sort them fast, and the sort turns on 3 things: are there objective findings, are the restrictions specific and time-limited, and do the office notes say the same thing. A form that fails any 1 invites a peer review.

1. Objective findings, dated

Many group policies require objective medical evidence, and every reviewing physician looks for it first. That means imaging with a date and a finding that fits the symptoms, test results (EMG, echocardiogram, pulmonary function, neuropsychological testing), and measured exam findings: degrees of motion, strength graded on a scale, reflexes, observed gait. For conditions with few imaging findings (fibromyalgia, migraine, many psychiatric conditions), the evidence is observations across visits, treatment intensity, standardized test scores and specialist evaluations. "Patient reports" is the phrase that weakens a form most.

2. Restrictions that can be measured against a job

A restriction is only useful if a vocational reviewer can compare it to the material duties of an occupation. Many LTD policies, and most vocational reviewers, borrow the exertional levels Social Security uses:

Source: 20 CFR 404.1567(a) to (d). A restriction written in these terms ("lift 10 lb occasionally, sit 4 hours in an 8 hour day") translates directly into an exertional level. "Light duty" does not, because it means different things to different employers. Sitting tolerance deserves special attention: a person who cannot sit most of the day may not be able to do sedentary work, which is where many any-occupation disputes end up.

3. Consistency with the chart

A common reason a treating physician's APS loses weight is a mismatch with the physician's own notes. Templated exam text is often the cause: an EHR that defaults to "no acute distress, normal gait, full range of motion" makes the notes say something the physician did not observe. Ambient AI scribes that draft notes from the visit conversation add a new version of the same problem, because a note can be fluent and still omit the measurements a claim needs. Check the form against the last 3 notes before it goes out.

Own occupation, then any occupation

The policy sets the length of the own-occupation period and the wording of both tests, so read the policy before reading the APS. The change date is a predictable denial point in an LTD claim, and the APS that carried the claim for the first period often cannot carry it for the second. Plan the updated APS months before the change date, not after the termination letter.

Round 1: the form that says too little

The claim is filed on 03/20/2026 with an APS from the primary care physician. Diagnosis: "low back pain, M54.50." Objective findings: "see notes." Restrictions: "no work." Expected return: "unknown." The notes include a positive straight leg raise on 02/03 and a 03/10 exam section reading "normal gait, full ROM, neuro intact", a template default that contradicts the same note's history.

The examiner has 45 days. Denying now would mean explaining, under (g)(1)(vii)(A), why the treating physician's view was not followed, and the only reason would be that the physician did not explain it. A clarification letter that quotes the conflict and asks for numbers is the better move. The plan sends an extension notice under (f)(3) naming the information needed, and the claimant has at least 45 days to provide it.

The examiner can now check each finding against its page (MRI p. 22; straight leg raise on pp. 3, 11 and 29), compare the limits with medium work, diary a recertification for 05/15, and ask for the surgical consult report now rather than in May.

Month 20: the any-occupation change

Suppose the claimant has surgery, improves, and plateaus with a 20 lb lifting limit and no sitting restriction. That profile rules out medium work and supports the own-occupation claim through month 24, but it fits the light and sedentary definitions in 20 CFR 404.1567. Unless the chart documents something that limits sedentary work (sitting tolerance, medication side effects, time off task, absences for treatment), the any-occupation review will likely find jobs within the restrictions. Claimant counsel who see this coming at month 18 ask the physician to address those capacities, with findings, before month 24.

[DATE]

[PHYSICIAN NAME], [CREDENTIALS]
[PRACTICE NAME, ADDRESS, FAX]

Re: [PATIENT NAME], DOB [DATE]
    [Claim no. / Our file no.]: [NUMBER]
    Authorization enclosed, signed [DATE]

Dear Dr. [NAME]:

[Your patient has a claim for disability benefits / We represent your patient in a
claim for disability benefits.] The claim turns on what your patient can and cannot
do at work, and your records are the main evidence. We are asking for specifics so
that your opinion can be given full weight.

Your patient's occupation is [TITLE]. As classified for this claim, its material
duties include: [e.g., lifting up to 50 lb, climbing ladders, kneeling, driving
between sites, sitting up to X hours]. [For any-occupation review: the question is
whether your patient can perform sedentary or light work on a sustained basis.]

1. DIAGNOSIS. Please confirm the diagnosis and ICD-10 code you treat, and the date
   you first made it.

2. OBJECTIVE FINDINGS. Please list the examination findings, imaging and test
   results that support your restrictions, with dates. [Your note of [DATE] (p. [X])
   records "[QUOTE]". Your note of [DATE] (p. [Y]) records "[QUOTE]". Please tell us
   which reflects your examination on [DATE].]

3. RESTRICTIONS AND LIMITATIONS. In an 8 hour workday, please state:
   a. Lift/carry: occasionally ____ lb; frequently ____ lb
   b. Sit ____ min at a time; ____ hours total
   c. Stand ____ min at a time; ____ hours total
   d. Walk ____ min at a time; ____ hours total
   e. Bend / kneel / climb / reach overhead: never / occasionally / frequently
   f. Need to lie down or raise legs during the day? Yes / No. If yes, how often.
   g. Expected absences for treatment or symptoms: ____ days per month
   h. Time off task beyond normal breaks: ____ % of the workday
   i. Cognitive or concentration limits from the condition or medication: ____
   For each item, please name the finding or observation it rests on.

4. DURATION. From what date do these restrictions apply, and through what date?
   When will you next reassess?

5. RETURN TO WORK. Can your patient perform the duties listed above? If not now, when
   do you expect to reassess? Could your patient perform [sedentary / light] work
   with the restrictions in item 3?

Please attach your office notes from [DATE] to present, and any imaging, test and
consult reports you hold. If any statement in your notes needs correction, please
make it as a dated addendum rather than an edit to the original note.

Please reply by [DATE] to [FAX/EMAIL/ADDRESS].

Sincerely,
[NAME, TITLE, ORGANIZATION, PHONE]
Enclosures: authorization; [claim form APS section]; [job description]

APS work splits into reading and judging. Reading means finding every lab value, plan line, restriction and named provider across hundreds of faxed pages. Judging means rating a risk or deciding a claim. AI in life insurance underwriting and AI for insurance claims are useful for the first half and should stay out of the second.

What a large language model does well on an APS

• Extraction at volume. Clinical NLP pulls vitals, labs, medications and dose changes into dated tables, the step that takes a person hours on a 300 page chart.
• Finding the lines people skim past. "Did not return", "declined", "ran out of", "recheck in 3 months", a tobacco note in the social history.
• Restrictions across visits. An AI medical chronology that lists each stated restriction with its date and source shows where the claims form and the notes part ways.

Where it fails

• OCR on faxes. Optical character recognition can read 6.1 as 8.1 on a faxed lab, or 140/88 as 146/88. A misread value is worse than a missing one.
• Handwritten notes. Older charts and specialist letters still need a person who knows the abbreviations.
• Copy-forward text. A templated "neuro intact" repeated across visits looks like a finding to a model, as it does to a hurried reader.
• Hallucination. Ask generative AI "does this claimant qualify?" and it may write a confident answer the record does not support. A tool that fills gaps is the wrong tool for a file whose gaps are the point.
• Judgment. No model knows the carrier's manual, the plan's definition of disability, or what a discrepancy means for this applicant.

Page-level citations and a human in the loop

An AI medical records summary is only usable if every line opens the page it came from. An underwriter who can click from a summary line to the APS page it came from can clear or reject that line in seconds. That is what grounded, page-level citations buy, and the human-in-the-loop review is where the decision gets made. Courts make the stakes concrete: in Mata v. Avianca, Inc. (S.D.N.Y. 2023), lawyers were sanctioned under Rule 11 for filing case citations a chatbot had fabricated. The same duty to verify applies to a restrictions summary a claimant's attorney puts into an ERISA appeal, or an APS summary an underwriter relies on.

Choosing a tool for APS and claim file review

Legal AI tools, AI document review platforms and agentic AI systems that promise to run a whole claim workflow all compete for this work. Rank requirements in this order:

Medrecords AI is medical record review software. You upload the APS or the claim file you already have. It does not order an APS, contact a physician's office or retrieve records.

Its flags are signals, not verdicts. A flag that says an ordered sleep study has no result tells an underwriter where to look; what that means for the offer is the underwriter's decision. Security is SOC 2 and HIPAA with a BAA. See APS medical summaries, life and disability underwriting and ERISA disability claim file review.

What is an APS in life insurance?

An attending physician statement is a copy of the applicant's medical records from a treating provider, requested by the insurer with the applicant's signed HIPAA authorization. Underwriters use it to check the application and to see trends, open workups and adherence that an exam cannot show.

How long does an APS take?

It depends on the provider's office, the accuracy of the provider details, and whether the first production is complete. No federal deadline applies to an insurer's authorized request. A patient's own access request under 45 CFR 164.524 must be answered within 30 days, with 1 extension of up to 30 days.

What is an attending physician statement for a disability claim?

A form the treating physician completes on diagnosis, onset date, objective findings, restrictions and limitations, prognosis and expected return to work. The claims team compares it with the office notes and the material duties of the occupation.

Does an ERISA plan have to follow my doctor's APS?

No special deference is required. The Supreme Court held in Black and Decker Disability Plan v. Nord (2003) that ERISA imposes no treating physician rule, but also that administrators "may not arbitrarily refuse to credit" reliable evidence from a treating physician. For claims filed after April 1, 2018, a denial must explain the basis for disagreeing with the treating physician's views.

Does an APS include psychotherapy notes?

Not with a general authorization. Psychotherapy notes need a separate, specific authorization under 45 CFR 164.508(a)(2). Mental health diagnoses, medications and treatment records in the ordinary chart are included.

Can AI summarize an attending physician statement?

Yes, for the reading part. AI medical record review tools extract vitals, labs, medications, restrictions and open orders into dated, cited tables. OCR errors on faxes, handwriting and copy-forward text still need a person to check each cited page, and no tool should assign a rating or decide a claim.

Is it HIPAA compliant to upload an APS to an AI tool?

Only if the vendor signs a business associate agreement and protects the records under the HIPAA Security Rule. Consumer chatbots without a BAA are not appropriate for applicant or claimant records. Ask for a SOC 2 report and a written commitment that your data does not train the model.

Can ChatGPT read an APS for an LTD claim or appeal?

A general chatbot can summarize text, but without page-level citations its output cannot be checked, and it may fill gaps with plausible statements the record does not contain. In an ERISA appeal, every fact you submit should trace to a page in the claim file.

Does AI make underwriting or claim decisions?

It should not, and Medrecords AI does not. It organizes, cites and flags what is in the file. The underwriter rates against the carrier's manual and the claims examiner decides under the policy.

Regulations, the Nord syllabus and the Firestone opinion were checked against primary sources in September 2026, and quoted text is verbatim. Carrier underwriting manuals are proprietary and are not quoted or summarized. The mock APS, the term life case, the LTD case and the time ledger are hypothetical. Product facts come from this site's product pages. Nothing here is legal, medical or underwriting advice.

• 29 CFR 2560.503-1, ERISA claims procedure: (b)(7), (f)(3), (f)(4), (g)(1)(vii) and (viii), (h)(2)(iii), (h)(3), (h)(4), (i)(1), (i)(3), (l)(2), (m)(4), (p)(3).
• 45 CFR 164.508, HIPAA authorizations: (a)(1), (a)(2), (b)(2) to (b)(5), (c)(1) and (c)(2).
• 45 CFR 164.524(b)(2), the 30 day access deadline and its 1 extension.
• 20 CFR 404.1567, sedentary, light, medium and heavy work.
• Black and Decker Disability Plan v. Nord, 538 U.S. 822 (2003), syllabus; the United States amicus brief filed in the case.
• HHS sample business associate agreement provisions.
• Firestone Tire and Rubber Co. v. Bruch, 489 U.S. 101 (1989), on the de novo and deferential standards of review; California Insurance Code section 10110.6, voiding discretionary clauses; Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023): Rule 11 sanctions for fabricated AI-generated case citations.

Related guides: medical source statements and RFC, how to get medical records for a lawsuit, medical abbreviations for legal professionals, HIPAA-compliant AI record review, and long-term disability record review.