Agencies have an amazing ability to be inquisitive, especially into those areas which really do not concern them. Often, Agencies will insist that, despite all of the relevant, pertinent, and desired medical documentation already having been attached to a Federal Disability Retirement application under FERS or CSRS, the applicant/Federal employee “must” sign the Standard Form 3112C (“Physician’s Statement) , which becomes superfluous and irrelevant. They insist that the Office of Personnel Management (OPM) “requires” the form, which is an erroneous statement. OPM has never required a signed SF 3112C so long as the Federal Disability Retirement application is accompanied by sufficient medical documentation to support the application. Sometimes, the insistence by the Agency is merely based upon ignorance; other times, it is based upon an administrative and bureaucratic inflexibility to longstanding “procedures” which the Human Resources personnel cannot adapt to, or change, because “this is the way we’ve been doing it for X number of years”. Still, there is a suspicion that in some instances, the “requirement” of SF 3112C is because of a more nefarious reason: The Agency wants full access to all medical records, notes, treatment notes, etc.
Robert R. McGill, Esquire