The Seventh Circuit did not feel that the new Glenn standard made a difference in the outcome of this long-term disability case–Jenkins v. Price Waterhouse Long Term Disability Plan. However, the court did, in a footnote, issue a warning about “independent medical examinations”:
. . . [W]e don’t want the phrase independent medical examination to pass without a comment. IMEs are designed to turn a spotlight on claims that are exaggerated or downright fraudulent. They are advertised as, and often passed off as, completely neutral examinations by disinterested medical professionals. But that is not always the case, especially when the professionals bill is paid by an insurance company (or a self-insured employer) with an interest in receiving a report that minimizes, or discounts, a disability claim. How much an IME professional is paid, and how often he or she is used, are certainly important considerations that bear on what weight should be attached to their reports.