If a claimant presents new and material evidence that is chronologically relevant “after the ALJ's decision, the Appeals Council must consider whether ‘there is a reasonable probability that the additional evidence would change the outcome of the decision.'” Id. (quoting 20 C.F.R. § 404.970(a)(5)); see also Bailey v. Soc. Sec. Admin., Comm'r, No. 22-11531, 2023 WL 4553880, at *1 (11th Cir. July 17, 2023). Where the Appeals Council denies review of an ALJ's decision, “no detailed explanation of its decision or a discussion of the additional evidence” is necessary.
Comm'r, 791 Fed.Appx. 871, 876 (11th Cir. 2019) (citing 20 C.F.R. § 416.1470(a)(5)). “Evidence is material if there is a reasonable probability that the evidence would change the administrative result[.]” Bailey v. Soc. Sec. Admin., Comm'r, No. 22-11531, 2023 WL 4553880, at *1 (11th Cir. July 17, 2023) (citing Hargress v. Soc. Sec. Admin., Comm'r, 883 F.3d 1302, 1308 (11th Cir. 2018)). “[W]hether evidence meets the new, material, and chronologically relevant standard is a question of law subject to [] de novo review.” Washington, 806 F.3d at 1321.
The Eleventh Circuit has found no error under similar circumstances. See Bailey v. Soc. Sec. Admin., Comm'r, No. 22-11531, 2023 WL 4553880, at *3 (11th Cir. July 17, 2023) (“Regarding the source statements from Dr. Khusro and Dr. Nichols, these opinions were also unlikely to change the outcome of the decision because they were not supported by and/or consistent with the medical evidence.