Medical Conditions: Somatoform Disorder

Hall v. State Compensation Insurance Fund [1/13/99] 1999 MTWCC 3 In the DSM-IV, the common features of Somatoform Disorders include physical symptoms suggestive of a general medical condition but not explained by a general medical condition, by the direct effects of a substance, or by another mental disorder; symptoms causing clinical distress; and indication the symptoms are not under conscious control of the patient. Claimant with accepted OD arising from workplace exposure to common office chemicals, diagnosed with somatoform disorder by credible occupational medicine physician, was entitled to continued TTD benefits until she reached MMI on somatoform disorder.
Coates v. Liberty Northwest Ins. Corp. [11/18/96] 1996 MTWCC 71 Although pain expert diagnosed somatoform disorder following back injury, WCC found claimant was purposefully exaggerating her complaints and alleged disability in order to obtain benefits. Further TTD denied.
Klein v. Liberty Northwest Ins. Corp. [3/4/97] 1997 MTWCC 7 An employer and insurer take a claimant as they find her, with regard to both preexisting physical and emotional conditions. See Houts v. Kare-Mor, 257 Mont. 65, 68, 847 P.2d 701, 703 (1992).
Peterson v. State Comp. Ins. Fund [11/23/94] 1994 MTWCC 105 Although the 1987 Legislature amended the definition of compensable injuries to exclude mental conditions “arising from (a) emotional or mental stress; or (b) a non physical stimulus or activity,” mental conditions remain compensable when caused or aggravated by physical injuries meeting the statutory definition of compensable industrial injury. Where persuasive psychiatric evidence indicated that claimant suffered from depression or a somatoform disorder caused by his physical injury, he is entitled to ongoing temporary total disability benefits as long as he is disabled by the resulting mental condition, but those benefits are conditioned on him following reasonable medical and psychological advice. Given medical evidence, including evidence that claimant improved previously when on psychiatric medication, a psychiatric referral is appropriate if not essential.