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Social Security disability attorneys or representatives are often not familiar with some of the civil rights laws and other remedies which may be available to their clients, beyond, or in lieu of, Social Security disability benefits, and which may result in additional or alternative sources of financial proceeds for their clients. Also, as Social Security disability claims have greatly increased due to the lagging economy, client advocates may encounter many persons who will not meet the stringent Social Security disability standards, but may be able to qualify for other relief. This article will explore some of these laws and remedies.

Due to the complexity of some of the remedies and the intricate interaction between them, which often require balancing and negotiation, it will be beneficial to client advocates to establish a relationship with one or more attorneys who practice in the areas of law noted below if they do not, in order to determine if other remedies may exist for their clients. As many of these additional remedies have stringent time deadlines, inquiries should be made as quickly as possible to other counsel as to whether a client has additional remedies and the viability of pursuing them. Indeed, failure of an attorney or a representative to consider these remedies may be the source of a professional liability issue depending on the outcome of a client's case.

An applicant for Social Security disability benefits frequently has a history, such as his medical conditions or work history, which has brought him to the position of applying for this type of benefit, which requires that he is deemed unable to perform substantial gainful work for a minimum of twelve (12) months or he has a condition that will result in death. That history often involves his employment situation and the nature of that situation can serve as the basis for additional remedies. Therefore, a thorough interview with a potential client should determine:

• Whether that person suffered an injury at the workplace;
• Whether his employer terminated him as a result of suffering the injury after the employer was informed that it was a work-related injury;
• Whether the injury, work-related or not, still permitted him to work for his employer with a reasonable accommodation by the employer. The courts' interpretation of "reasonable accommodation" is discussed below;
• Whether the employer refused to make the reasonable accommodation and instead laid off or terminated the employee;
• Whether the employee, who formerly did not have any or few performance problems, suddenly received discipline or write-ups after the injury;
• Whether the employer should have been aware that the employee was suffering from physical or mental problems, and instead of helping him manage those problems, terminated him, laid him off, or eliminated his position;
• Whether the employee had available to him short and/or long-term disability benefits, some type of retirement disability or union benefits for which he could apply.

THE AMERICANS WITH DISABILITY ACT AND ITS AMENDMENTS
Significant legislation has been enacted to protect employees who have been injured in and out of the workplace and who are suffering from an illness. The Americans with Disabilities Act of 1990 (hereinafter "ADA") was intended to "provide a clear and comprehensive national mandate for the elimination of discrimination against individuals with disabilities." 42 U.S.C.A. 禮12101 et seq. The Act applies to employers with 15 or more employees and prohibits discrimination against qualified individuals on the basis of a disability in regard to job application procedures, hiring, advancement, termination, compensation or job training. See 42 U.S.C. 禮12112(a).

In the years since the Act's passage into law, the U.S. Supreme Court has handed down specific opinions which have curtailed the reach of the ADA and have greatly limited the definition of a disability under the ADA. Large clusters of people, initially covered by the ADA, have been shut out from the intended far-reaching protections as a result of those court opinions. The result has put a heavy burden of proving a disability on the plaintiff, which was clearly against Congress' intent. See Sutton v. United Airlines, Inc., 527 U.S. 471 (1999) and its companion cases and in Toyota Motor Manufacturing, Kentucky, Inc. v. Williams, 534 U.S. 184 (2002). As a result of these Supreme Court cases, lower courts have found that individuals with a range of substantially limiting impairments are not people with disabilities.

In order to rectify this situation, Congress passed the Americans with Disabilities Act Amendments Act (hereinafter "ADAAA"), which became effective on January 1, 2009. The ADAAA greatly broadens the relevant definitions of the ADA and gives renewed hope to disabled individuals who are ready, willing and able to work with a reasonable accommodation. The Act's new language also enlarged the definition to include a larger array of individuals who are "regarded as" having a disability. Additionally, mitigating factors are no longer assessed in the evaluation of an individual as disabled.

If one has a client who lost his job due to a negative job action and who is covered by the newly expanded ADAAA, but had no recourse but to initiate a Social Security disability claim, either because his condition worsened or because he could not locate another job with his disabilities, he will be required to file a claim with a government agency at the local, state or federal level in order to protect his rights and preserve his right to bring later litigation, if necessary. That government agency may hold a fact-finding conference or a mediation, depending on the agency's practice, and while the matter is at the agency level it may be settled without resorting to litigation. Bear in mind that the ADA claim can proceed independently and concurrent to the Social Security disability claim.

Employers are required by the ADAAA to reasonably accommodate those employees known to have a disability to allow for the fulfillment of essential job functions. However, these employers will not be required to make accommodations which will cause an undue hardship. Under U.S.C. 禮12111(9), those reasonable accommodations include, but are not limited to, (1) making existing facilities used by employees readily accessible to and usable by individuals with disabilities, (2) job restructuring, (3) modification of equipment or devices, (4) appropriate adjustment or modifications of examinations, training materials or policies, and (5) the provision of qualified readers or interpreters.

It is the employee's responsibility to inform his employer that an accommodation is necessary in order for that employee to fulfill his essential job functions. It is also important to know that the new amendments make it clear that employees who are simply "regarded as" having a disability are not eligible for the aforementioned accommodations. Once the eligible employee requests an accommodation, an interactive process with the employer regarding the appropriate accommodations will begin. U.S.C. 禮12111(10) enumerates factors that would cause an undue hardship on the employer when accommodating an employee and are thus not mandated under the law. That list includes: (1) the nature and cost of the accommodation, (2) the overall financial resources of the facility or facilities, (3) the overall size of the business and (4) the type of operation.

It is also significant to note that simply because an employee's doctor sends a note to the employer limiting the employee's ability to work, requesting time off for the employee, requesting reduced hours, or asking that the employee be assigned to light duty, the employer is not necessarily governed by the doctor's request. Legions of employees have been terminated because an employer either did not feel the need to honor a doctor's request or seized upon the doctor's request to terminate an employee because, according to the doctor, the employee cannot do the job as required. An employee would be wise to seek legal help, if possible, in negotiating a disability accommodation from an employer.

It is not uncommon for employers to begin plotting for an employee's termination shortly after they are informed, formally or informally, of the employee's illness. Red herrings often used by employers to terminate or alternatively force an employee to resign include giving an employee a series of baseless poor performance evaluations, job restructuring rendering the affected employee's position nonessential, suddenly changing absence policies, or engaging in poor treatment of an employee which encourages his resignation.

THE REHABILITATION ACT

The Rehabilitation Act Title V entitled "Nondiscrimination under Federal Grants and Programs" 29 U.S.C.A. 禮 720 et seq. protects those with disabilities from discrimination on the basis of those disabilities in programs organized by or receiving money from the federal government. The standards for determining employment discrimination under the Rehabilitation Act are the same as those used in Title I of the Americans with Disabilities Act described above.

THE PREGNANCY DISCRIMINATION ACT
The two primary laws that protect women during pregnancy are the Pregnancy Discrimination Act and the Family Medical Leave Act ("FMLA"). An amendment to Title VII of the Civil Rights Act of 1964, the Pregnancy Discrimination Act was established in 1978. The Act requires employers with 15 or more employees to treat employees with pregnancy-related conditions in the same manner required by law as those with other health conditions. For example, if an employee with a serious medical condition is permitted to take leave or work a modified schedule under FMLA, the pregnant woman will be afforded the same options. The Act also prevents an employer from firing or refusing to hire a woman based on her pregnancy or ability to take maternity leave. In that same light, an employee cannot lose credit accrued for seniority or retirement benefits during her leave. Lastly, an employer is required to keep the job open and maintain health care benefits as though the woman was on sick or disability leave.

Pregnant women also rely heavily on FMLA. As previously discussed, expecting and new mothers can take up to 12 weeks off within a 12 month period to care for the birth of their child. One key distinction between FMLA and the Pregnancy Discrimination Act is that FMLA only applies to employers of 50 employees or more. Moreover, the employee must have worked either one full year or 1250 hours to request FMLA leave.

THE AGE DISCRIMINATION IN EMPLOYMENT ACT

The Age Discrimination in Employment Act of 1967 ("ADEA") protects those employees over the age of 40 from workplace discrimination based on age. 29 U.S.C. 禮 621 et seq. It applies to employers with 20 or more employees, state, local and federal governments, and employment agencies and labor organization. Under this Act, it is unlawful for employers to discriminate against employees or job applicants with respect to any term, condition, or privilege of employment, including hiring, firing, promotion, layoff, compensation, job assignments and training. As with the ADAAA, this Act also makes retaliation relating to the aforementioned unlawful.

Although an employee can be asked to waive their rights under the ADEA when signing a severance agreement, a clearly established protocol must be followed. The agreement must be (1) in writing and understandable; (2) specifically refer to ADEA rights; (3) not waive rights or claims that may arise in the future; (4) offer valuable consideration; (5) advise the employee in writing to consult with an attorney prior to execution of the waiver; (6) allow for 21 days in which the employee can consider the agreement; and (7) allow for 7 days within which the employee can revoke the agreement after signing it. Consider this protocol if a severance agreement concludes one's client's disability matter.

THE FAMILY MEDICAL LEAVE ACT

The Family Medical Leave Act, (P.L. 103-3, 107 Stat. 6) ("FMLA") was enacted on February 5, 2003 for the purpose of helping people who were stressed about trying to balance the competing demands of work and family life. The FMLA allows an employee to take up to 12 weeks of unpaid leave in a 12 month period for the birth or adoption of a child, to care for a family member, or to tend to his own serious health problems. The employee has three options from which to choose when deciding how to take time off. He can take the entire 12 weeks at once, take leave as needed following proper procedures, or he can simply work a reduced schedule. Note that FMLA time off may be combined with paid time off and employers generally have an option of requiring that employees use up their sick/vacation/personal time prior to using FMLA time. Employers have the burden of providing employees with information, notice and guidance about FMLA requirements.

It is important that any FMLA documents completed by the client and their doctors be reviewed by an attorney if possible. Moreover, an attorney or representative should ensure that the FMLA documents conform or are at least considered when applying for other types of disability. Often these documents will have different or contradicting onset dates, diagnoses, prognoses, or levels of severity of condition which will complicate the Social Security disability application procedure. The FMLA leave documents can be of assistance and provide documentary support in a Social Security disability claim.

The Department of Labor's Wage and Hour Division published a Final Rule under the FMLA in January 2008 which became effective on January 16, 2009, and an updated set of regulations by the Department of Labor were published. The FMLA benefits provided to military families (referred to as military caregiver leave and covered service-member leave) greatly expand the usual 12 weeks of FMLA leave up to 26 workweeks of leave in a single 12 month period to care for a covered service member with a serious illness or injury incurred in the line of duty on active duty. Also, the time spent performing light-duty work doesn't count against the 12 week FMLA leave. The regulations provide added guidance of what a "serious health condition" is.

Implementation of the ADA and the FMLA sometimes cause friction between an employer's right to know about an employee's condition and an employee's right to keep his medical conditions private. Relying on a medical treatment source for this information is not suggested, as doctors have been known to tell patients they are not required to reveal any information about their medical conditions, when that is not always the case, which can result in an employee's termination for refusal to divulge information an employer has a right to know.

Generally, the information that must be revealed by an employee or his medical treatment sources under the FMLA must be enough to permit the employer to know how to best accommodate an employee, or to provide the information on Department of Labor Form WH-380E, which is a certificate of health care provider for an employee's serious health condition. This information, requested from a doctor, includes, among other things, the beginning date of the condition, dates treated for the condition, probable duration of condition, medication prescribed, treatments, referrals made to other health care providers, and whether an employee can perform certain job functions.

Employees on FMLA must follow an employer's usual and customary procedures for reporting an absence, barring an usual circumstance. Further, an employer's direct supervisor cannot contact health care providers and cannot ask for additional information beyond that required on the certification form, as the Health Insurance Portability and Accountability Act ("HIPPA") is invoked to limit this information. There are also provisions for certification of ongoing conditions and fitness for duty certifications.

FECA AND FELA CLAIMS AS OPTIONS FOR FEDERAL EMPLOYEES

The Federal Employees Compensation Act ("FECA"), 5 U.S.C.A. 禮 8101 et seq., provides federal employees with compensation benefits for work-related injuries or illnesses. Administered by the Department of Labor's Office of Workers' Compensation Programs, all claims generally must be brought within three years of the date of injury. The federal employee will continue to receive compensation benefits as long as they remain totally or partially disabled. The federal employee will receive two-thirds or three-fourths of their salary at the time of the injury depending on whether the employee has dependents.

Another piece of federal legislation that attorneys who handle disability matters should be familiar with is Federal Employers' Liability Act ("FELA"). 45 U.S.C.A. 禮 51 et seq. This Act was initially meant to protect the rights of railway workers who were injured while at work in this country. Since its enactment, FELA has been greatly expanded. There is a three year statute of limitations from the date of the injury. Generally the statute begins running when the employee knew or should have known of the existence of the injury and that the FELA statute of limitations is triggered in an occupational injury case when the injured worker knew or should have known: 1) of the existence of the injury; and 2) that workplace exposure was a cause

SHORT AND LONG-TERM TERM DISABILITY POLICIES AND ERISA

Clients frequently are not aware that they are entitled to make a claim which entitles them to receive some form of some short and/or long-term disability payments as a general benefit of their employment, membership in a union or because they have opted to receive additional benefits paid for through payroll deductions. Employees may also have disability coverage they have purchased privately.

However, simply because this type of benefit exists does not mean that it is easily procured. Disability insurance carriers may be reluctant to approve clients for benefits, particularly long-term disability benefits, and if they are approved, carriers often attempt to terminate the employee prematurely. Employees are sometimes lulled into thinking that because they have received short-term disability benefits easily that receiving long-term disability benefits will also be an easy process. Moreover, if an employee is receiving long-term disability benefits, this normally indicates that the injury is not work-related, because a worker's compensation claim would ensue instead.

Insurance disability carriers tend to have little respect for the fact that a claimant has been awarded Social Security disability benefits prior to or even after an ALJ's decision, and this type of award does not have significant impact on a carrier's decision to award long-term disability benefits. However, a detailed decision by an ALJ judge, the Appeal's Council or a court, will usually be helpful in a long-term disability claim. In the event that a client suffers from physical and mental impairments, because many policies limit the number of years of benefits for mental impairments, carriers may seize on a decision and allege that the mental impairments take priority over the physical impairments, so one should use care in emphasizing the nature of the disability claimed.

Most insurance carriers require that a successful applicant for long-term disability benefits apply for Social Security disability benefits, and if that claim is successful, those benefits will be offset against any amount paid to the applicant under long-term disability coverage, after the deduction of any attorney's fees. If that claim is not successful, it should not impact on private disability insurance benefits.

There are several levels of administrative appeal in the long-term disability denial process and insurance carriers frequently extend the administrative process as long as possible, hoping to wear out the applicant. It is important that each stage of the administrative process be followed, and that any and all medical evidence is submitted to the insurance carrier during the administrative process. This is because there is case law which states that evidence submitted after the administrative process cannot be introduced if a denial is later litigated under The Employee Retirement Income Security Act of 1974 ("ERISA"), found in the U.S. Code beginning at 29 U.S.C. 禮1001.

ERISA is a federal law which mandates minimum standards for most voluntarily established pension and health plans in private industry. The result is additional protection for individuals with covered plans. Long-term disability appeals are included in the health care plans covered by ERISA. Being familiar with ERISA is particularly important when dealing with denials of long-term disability benefits in that this federal law preempts the vast majority of state and local laws pertaining to similar subject matter.

ERISA dictates an administrative process which must be fulfilled in its entirety before the employee obtains the right to sue. The administrative processes differ from policy to policy but the common thread running through every policy is that stringent timelines must be followed in order to safeguard the claim. ERISA also provides for an internal appeal process. Once this process is complete, a lawsuit can be brought.

UNEMPLOYMENT INSURANCE BENEFITS

Although there may be risks if a claimant applies for both unemployment insurance ("UI") benefits and Social Security disability benefits contemporaneously, for those who don't have a financial choice, one is not precluded from filing for both benefits contemporaneously. In order to receive UI benefits, one must assert that he is ready, willing and able to work but cannot find employment. Conversely, to file for Social Security disability benefits one must show that his medical condition prevents him from working in his previous position or any other field and he is not currently seeking employment.

Although there appears to be an inherent conflict in these positions, in Cleveland v. Policy Management Systems Corp, 526 U.S. 795 (1999) the U.S. Supreme Court held that: (1) claims for Social Security Disability Insurance (SSDI) benefits and for ADA damages did not inherently conflict, and (2) an employee was entitled to an opportunity to explain any discrepancy between her statement in pursuing SSDI benefits that she was totally disabled and her ADA claim that she could perform essential functions of her job. A similar analysis can be applied to the receipt of UI benefits where one alleges an ability to do some type of work.

Administrative law judges may not look favorably upon Social Security disability claims where the employee is receiving UI benefits, but they should consider a claimant's application for and/or receipt of UI benefits as only one of the statutory factors adversely impacting the claimant's credibility in assessing the ability to work, and it should be considered as part of the five step sequential evaluation process and the totality of circumstances.

Holding oneself out as being able to work is not the same as being able to work and perform substantial gainful activity. Also, a mere desire to work is not proof of the ability to work, because many employers will not hire someone with a myriad of medical problems, despite that person being willing to make a work attempt.

A November 15, 2006 Memorandum from Chief Judge Frank A. Cristaudo to Regional Chief Judges and Regional Office Management Teams, states that "[t]his is a reminder that the receipt of unemployment insurance benefits does not preclude the receipt of Social Security disability benefits. The receipt of unemployment benefits is only one of many factors that must be considered in determining whether the claimant is disabled. See 20 CFR 404.1512(b) and 416.912(b)." The Memorandum states that Social Security Ruling 00-1c incorporates Cleveland. A long line of Appeal's Council and ALJ Decisions prior to Cleveland support this analysis, which requires consideration of all of the evidence and the totality of circumstances, making the ability to receive both types of benefits possible.

Some advocates delay the date of onset of the condition in a Social Security disability claim paving the way for a client to receive UI benefits for a period of time. However, the Social Security disability process can be quite lengthy, and may not always be successful for claimants, so it may be desirable for them to have a stream of income pending the Social Security disability process. UI benefits are not offset by Social Security disability and therefore can serve as additional funds for claimants during the Social Security disability application process.

THE PUBLIC POLICY EXCEPTION AS APPLIED TO EMPLOYEES AT WILL AND EMPLOYEES WITH WORKER'S COMPENSATION CLAIMS

Since 1891, Pennsylvania common law held that in the absence of a specific statutory or contractual restriction, an at-will employment relationship could be terminated by either the employer or the employee at any time, for a good reason, a bad reason or no reason at all. Henry v. Pittsburgh & Lake Erie Railroad Co., 139 Pa. 289, 21 A. 157 (1891). It was not until almost 100 years later that this holding was reevaluated in Geary v. United States Steel Corporation, 456 Pa. 171, 319 A.2d 174 (1974). In Geary, an employee was terminated for warning his fellow coworkers of the valid dangers posed by the new product the company was manufacturing. Interpreting Geary, Yaindl v. Ingersoll-Rand Co. held "when the discharge of an employee at will threaten public policy, the employee may have a cause of action against the employer for wrongful discharge." 281 Pa.Super. 560, 422 A.2d 611, 617 (1980).
Some states may have statutory or common law making it a violation to terminate an employee who has been injured during the course of employment. In Pennsylvania, for example, the courts have established a narrow exception to the standard employment at will doctrine which permits employers to terminate their employees for minimal reasons, stating that it is a violation of public policy to terminate an employee who initiates a claim of worker's compensation. Rothrock v. Rothrock Motor Sales, Inc., 810 A.2d 114 (Pa.Super. 2002). However, this is often a difficult standard to meet and employers often ignore this exception, taking the risk that an injured employee will not have the substantial resources necessary to sue the employer for violation of the policy.

In September 2009, a record setting consent degree was entered into between Sears, Roebuck and Co. and former employees who were allegedly discriminated against when Sears maintained an inflexible workers' compensation leave exhaustion policy and terminated employees rather than providing them with reasonable accommodations for their disabilities in violation of the ADA. The case was docketed as EEOC v. Sears Roebuck & Co., N.D. Ill. No. 04 C 7282. The Chicago based U.S. Equal Employment Opportunity Commission declared that the class action lawsuit it had initiated would be settled for $6.2 million with additional remedial relief. Many attorneys in the workers compensation field believe that this settlement will lead to important changes in how companies structure their leave policies.

However, the Pennsylvania public policy exception to the employment at-will doctrine will not apply where a statutory remedy is available. For example, an employee who was terminated based on race, color, religion, national origin, or sex is entitled to file under Title VII and similar state statutes, although he may be permitted to raise the exception as an ancillary state claim.

SEVERANCE AGREEMENTS IN LIEU OF COURT PROCEEDINGS

Another helpful tactic which should be considered if Social Security disability standards cannot be met but an employee must leave his position because he can't perform his job duties due to some disability and/or his employer can't reasonably accommodate his disability, is negotiating a severance agreement to include additional funds for a client and/or lengthen his entitlement to health insurance benefits. The agreement will be enforceable so long as the scope is reasonable, no laws are violated, consideration is present and the agreement is knowingly and voluntarily entered into.

Employers are oftentimes willing to enter into a severance agreement to avoid the lengthy discrimination agency or litigation process. It may be far more cost effective for an employer to give these concessions early in the negotiation process. It is important to exhaust all other remedies discussed earlier if a severance agreement is to be signed because standard severance agreements terminate the employee's right to sue the employer for any actions that took place during a certain time frame, with the possible exception of worker's compensation claims, depending on state law.

CONCLUSION

It is not unusual to have a client suffering from a job-related injury or illness who would have been able to continue to work given a reasonable accommodation under the ADAAA or following a FMLA leave. Instead, many employers terminate, lay off, or force these employees to resign in violation of the law and the public policy exception to the employee-at-will doctrine and the aforementioned statutes, depending on state law. That client, in addition to the receipt of Social Security disability benefits, could potentially receive worker's compensation benefits, short and/or long term disability benefits, retirement disability and/or a settlement from an employer due to alleged violations of one of the civil rights acts or policies. Note that there may be financial offsets from receipt of more than one of these types of benefits. Also, a negotiated severance agreement or settlement may include severance pay, extension of insurance benefits and attorney's fees and costs for a client.

In conclusion, there is no doubt, as outlined by the various remedies above, that the disability field of law is often confusing as it requires interaction with various laws and policies which often have not only varying, but conflicting, burdens of proof. However, a practitioner who is at a minimum familiar with other possible remedies can be of great help to his client. Also, this help may result in additional sources of income to the client and to the practitioner who undertakes these additional claims or refers them to other attorneys and is able to collect referral fees depending on state guidelines.

Most people will have some questions about what to expect during pregnancy. Many of the questions and worries concern the health and safe arrival of the new baby. However, information is power in a time like this and through these tips, you can gather a wealth of information that will give you the power to take proper care of yourself, your child and your future as a family.

While pregnant, your body should be supported, while you sleep. There are pillows available that are made to cradle the pregnant belly for comfort and support when sleeping. If you do not have one, you can use a regular pillow for support. Sleeping with a soft pillow between your knees and another under your stomach is usually the most preferred way to sleep while pregnant.

Be sure to get your name on the list right away for prenatal classes, since these groups tend to fill up quickly. Once you know you are pregnant, get signed up. Your doctor and your hospital are great resources for finding information about classes that are available to you. If a tour of your birthing hospital isn't included, book one separately.

It is important that a pregnant woman stays away from stress, as much as she can. Not only can stress cause a variety of different problems in a woman, but it can also cause the baby to become stressed. Studies clearly show that stress can contribute to pre-term labor and birth.

Your doctor should be alerted to any symptoms you are experiencing, including exceptionally swollen feet. While this may just be a normal side effect of pregnancy, it's a possible symptom of preeclampsia, a condition that causes high blood pressure in pregnant women. In order to have a healthy, normal birth, you should have this condition treated immediately.

Use a doula to assist you during your delivery. "Doula" is the name given a support specialist who helps a mother through her pregnancy. She may help the mother as she creates a birthing plan, work with her to facilitate a natural birth, or simply offer emotional support.

When you become pregnant and go see the OBGYN, you will be given a prenatal vitamin. Take your vitamin at the same time each day, usual with a meal to prevent nausea. The prenatal vitamin supplements your diet with a variety of vitamins and minerals that are essential for the healthy development of your baby.

Protein is extremely important during pregnancy. This is essential to having your baby grow healthy, and it's good for you too. To keep this protein in your diet eat foods like sunflower seeds, peanuts, beans, eggs, chicken, tofu and even hamburger meat.

Pregnant women are advised to wear sports bras. They offer the breasts extra support and may relieve some of the pregnancy aches and pains. On addition, you will want to wear looser undergarments in the stomach and waist areas. This could keep the blood from circulating and bringing oxygen to the baby.

It is a wise idea to be tested for any potential sexually transmitted diseases when you are pregnant. STD's can be detrimental to the health of you and your unborn baby if they are left untreated. Most tests for STDs are done with a blood, urine or pap smear sample. If you do have a sexually transmitted disease, you may need to have a C-section to protect your child.

You must notify your doctor if you notice extensive vaginal discharge during pregnancy. You could have a vaginal infection, which is common during pregnancy. However, if it isn't treated, it can become a serious problem.

When you are pregnant, you must avoid all alcohol. When a woman drinks during her pregnancy, the alcohol will pass through her placenta directly to her unborn fetus. Therefore, when pregnant or when trying to get pregnant, it is advisable you refrain from alcohol. Drinking while pregnant can cause physical or mental problems to the developing baby and also increases the risk of miscarriage or premature birth.

You should begin to massage your stomach near the end of the second trimester. You can use your bed or the couch as a massage table; use whichever one feels more comfortable. Support your back with a couple of pillows. Instead of lotion, apply oil onto your belly, and massage lightly. Breathe deeply to the sounds of some soothing music as you gently massage. Doing these things maintains your calm and soothes your baby.

Take some time out for yourself. Once your baby arrives you entire focus will be on caring for him or her, and any time to pamper yourself will be very limited. You should take care of yourself by doing things you enjoy. Whether you'd prefer to do solitary activities, like engaging in a favorite hobby or do things with friends, participate in your favorite activities as much as possible while you still can. It will help you feel better, and the baby will too.

If you are pregnant and you get an illness or eat a food that causes diarrhea, be sure that you drink plenty of fluids. While diarrhea can lead to dehydration, this is especially dangerous for women who are pregnant and may require hospitalization.

Reduce the amount of caffeine your drink during pregnancy. Caffeine can cause many problems during pregnancy. For the best health during your pregnancy for you and your baby, avoid caffeinated drinks and foods.

Women in the third trimester of pregnancy should always sleep on their left side. By sleeping on the left side the fetus gets the greatest blood supply, and you also get a good blood flow to the kidneys and uterus. Do not sleep your back, as it's not a good way to get blood flowing.

Many moms-to-be aren't fully sure of the best way to take care of themselves during pregnancy. As society gains more knowledge on the subject, what's best practice tends to change. However, if you bring to bear the sensible advice in this article, you will have made a major contribution to your health, your baby's health, and the enjoyment of your pregnancy.

The present working conditions include long working hours which is one of the main causes of stress and other issues. Most of us sit for long hours which create several feet problems due to lack of leg movements and blood circulation. It is recommended to exercise on a daily basis but not all of us have enough time for exercising. This is one of the main reasons why foot care products are introduced these days.

Here are some details about few foot care products:

Compression stockings and support hosiery

Compression stockings and compression support hosiery are known to be one of the best remedies for foot problems. They help in regulating blood circulation in the lower part of the body. Nowadays, you will find that these stockings are available in different styles, colours and shapes. Thus, you can buy the one which suits your needs.

Compression stockings and compression support hosiery are designed in such a way that they apply appropriate pressure on the legs. This pressure helps the blood to circulate in your legs properly.

Diabetic socks for men and women

Nowadays, many people suffer from diabetes. And one of the common problems faced by diabetic patients is diabetic foot. To solve these conditions,diabetic socks have been introduced in the market. These socks are designed in such a way that they control the moisture in the foot area which decreases the risk of infection in the feet.

Maternity support hose

Wearing a maternity support hose is necessary to take care of your body during pregnancy. A maternity support hose helps in resolving blood circulation problems in your legs. In addition to this, it helps in reducing swellings and also prevents several future varicose veins.

Thus, the above mentioned foot products help in keeping you fit in several situations.

Big, Bold, and Beautiful: How to Look Hot During Pregnancy

If you think "looking hot during pregnancy" is slightly oxymoronic--save those insufferable summer months when you can't seem to cool down for the life of you--you're not alone.

Many a pregnant woman has felt awkward, unattractive, and, well, large. However, simply by learning a few tricks, and with just a little effort, you can look and feel like that hot mama-to-be that you are.

Looking hot during pregnancy starts with learning to take care of yourself. Although some women treat it as such, pregnancy should not be a license to "let yourself go," eat whatever you want, and stop caring what you look like. "But I'm taking my prenatal vitamins and avoiding my daily shot of vodka," you may protest. And while that's all well and good, there is so much more involved with self-care during pregnancy.

A few tips in this department include drinking lots of water, eating healthy as much as possible (with the odd treat here and there, of course), exercising moderately (walking, swimming, prenatal yoga), and maintaining your hair and makeup regimen. As your skin stretches during pregnancy, take good care of it with a good prenatal moisturizing lotion like cocoa butter.

Next, in order to claim that "big, bold, and beautiful" label as yours, you need to take advantage of what the pregnancy hormone gods have given you. Your fingernails will likely grow faster around month four--splurge on a manicure! You will also be the proud owner of a full and fabulous head of hair (since pregnancy hormones slow down hair loss), so work this to your advantage. And don't forget that wonderful, where-did-you-come-from cleavage that you now have to show off.

Finally, you must learn to dress the part. Stop dreading that inevitable maternity clothes shopping trip. By knowing what to look for--and, of course, what to avoid--you'll be on your way to looking pregnant and sexy. First, look at your assets, and what you (or your man) find most attractive--breasts? Belly? Arms? Legs? Back?--and find cute and trendy apparel that flaunts them accordingly.

It's best to avoid buying plus-size clothing. They won't fit or look right. Wear your regular clothes as long as possible and then head straight to the maternity department. If everything looks plain, out-of-style, frumpy, or huge, consider shopping online, where you'll find a ton of hot, attractive, and sexy clothes for the mom-to-be.

This is an important question that all pregnant women should know the answer to. During pregnancy, a woman's body undergoes many physiological and endocrinological changes as the baby inside the womb begins to grow and develop. Due to these changes, the pregnant mother experiences various forms of misalignments in her joints and/or spine, that could result in one or a combination of, the following:

- A growing, prominent curve of the back
- Enlargement of the abdomen
- Pelvic changes
- Postural changes

These changes in the pregnant woman's body could result in them experiencing difficulty attaining proper balance and alignment. Hence, chiropractic care helps correct these conditions and enables the development for better posture that puts less stress on the pregnant body. Importantly, the misalignment of a pregnant woman's pelvis could limit the baby's development inside the womb.

Is Chiropractic Care During Pregnancy Safe?

All licensed chiropractors are trained about using chiropractic procedures on pregnant women. There are chiropractic professionals who specialize in treatments for prenatal and postnatal care individually. Hence, these professionals are trained and are required to direct their specialization to ensure the safety of both baby and mother.

Chiropractors who treat pregnant women must adjust the intensity of their treatment procedures depending on the condition and in what stage of their gestation period the woman is in. Many times, chiropractors will recommend a regimen of stretching and exercise in order to ensure optimum health for the pregnant woman.

Chiropractic Benefits for The Pregnant Woman

Before women undergo labor, it is highly recommended that she undergo chiropractic care as it assists in many ways throughout her pregnancy and delivery.

It assists in the following:

- It helps to achieve a healthier pregnancy.

- It enables the patient to achieve good control over their symptoms and/or conditions associated with pregnancy.

- It enables the patient to have an expeditious and effective delivery.

- It enables relief from pain on the neck, back, or joints which get tremendous strain during pregnancy.

- It enables women to avoid the possibility of undergoing cesarean section.

Chiropractic Effects During Labor

In addition to the benefits for prenatal conditions mentioned above, chiropractic care offers great benefits during the actual labor and delivery of the baby, especially in terms of pain management. A more successful delivery is possible upon receiving chiropractic care.

Duration of Labor

When the human body undergoes extremely stressful situations, such as in the delivery of a baby, the balance level and adaptability of the pregnant body is crucial. Most women who have to undergo Cesarean section during delivery are due to the body's inability to cope with the normal stress of delivery. Most of the time, when a woman is not strong enough to deliver a baby normally, it is the result of a misalignment of the pelvis. This slows down the descent of the fetus towards the birth canal. A limited range of motion is also a culprit that affects a woman's ability to labor efficiently. Hence, getting chiropractic adjustments during pregnancy enables a woman to address the above problems and significantly reduce her time in labor.

The Fetal Position

Another component that impacts labor time is the positioning of the fetus. Chiropractic treatments will help to adjust and place the fetus for proper movement through the birth canal. Many health experts also believe that chiropractic treatments help avoid the acquisition of any form of back conditions.

Pregnancy and depression are closely linked to one another. Depression during pregnancy is difficult to avoid due to various hormonal and other changes taking place in a woman's body. Depression can be dangerous to the health of both the fetus and the mother. Pregnancy marks a time when women tend to undergo extreme highs and lows of emotion. The emotions of pregnant women tend to be highly varying, moving from the feelings of extreme elation to that of depression. Keeping the negative effects of the depression during pregnancy in mind, medical professionals alert expecting mothers from being gripped by depression.

What Causes Depression During Pregnancy?

The medical experts have been closely studying the relation between pregnancy and depression and how to keep pregnant women at safe distance from worries, anxieties, negative feelings etc. Becoming pregnant gives rise to a variety of feelings, but there are also those hormonal changes, which are inevitable during pregnancy. These hormonal changes result in drastic mood swings from happiness to the extreme grief to anger. Medications and several birth control pills taken prior to pregnancy interfere with ovulation and tend to generate bio-chemic alterations in a women's body, thereby contributing to increased levels of depression during pregnancy. Most women find strive to find ways in which depression can be eradicated during pregnancy.

Depression in pregnancy results from the hormonal secretion in the mother's body which is required to support the development of baby. There are several external factors which lead pregnant women to feel depressed. other These factors can be the levels of stress arising from health matters, finances required to support the pregnancy treatment and the baby after delivery, other kids, relationship with the spouse and other family members, previous experience of infertility etc. The symptoms of depression during pregnancy is marked by an frequently feeling low, helpless, neglected and insecure about how her loved ones feel about her. Women tend to be tearful, short tempered and feel irritated. Expecting mothers are found to travel between highs and lows of moods and their energy levels are directed in response to the changes in mood. Women in pregnancy and depression can also feel extremely restless and feel like hurting their babies, even themselves. Risks of suicides also happen to increase among women during this phase.

Medications Helpful To Reduce Depression During Pregnancy

There are several drugs are available to reduce the chances of being caught by depression during pregnancy. There are anti-depressant drugs such as Valium, Xanax, Prozac, and similar drugs of the Selective Serotonin Reuptake Inhibitors (SSRI) family of drugs that can be taken before pregnancy to avoid depression. These medications are known to influence the neurotransmitters of the brain and change some particular signals.

These drugs have been shown to lead patient's brain to function in different manner to oppose depression and affect mood changes. There are negative side effects of these drugs that are perceived through adverse effect on the growth of fetus in terms of breathing problems, malformation of cardiac organs and many more. Therefore, look for natural remedies through proper nutrition and meditation, and take adequate rests to weaken the connection between your pregnancy and depression.

As women, it is important for us to be in touch with our own bodies. The way we feel and the way our body reacts to things and situations actually reveal something about the state of our hormones. Hormonal imbalance is the cause of many women's health problems. Being able to spot the changes in our body, therefore, is of the utmost importance so that we can seek the necessary treatment or medical help.

Hence, these are the top 3 signs that indicate something is wrong with your hormone system:

You're Always Under the Weather

Depression is one of the most common symptoms of a woman's hormone imbalance. If you are always feeling tired and lethargic even after getting the required hours of sleep, or feeling particularly anxious or down for no particular reason, you may be suffering from depression.

Sleep Does Not Come Easy

A sudden onslaught of insomnia is a sure sign that something is wrong with your hormone system. If you have never had problems with sleeping and then all of sudden you are staying awake till the wee hours of the morning, it's time to seek your doctor's advice.

You're Losing Hair

Combing your hair and noticing strands and strands stuck between the teeth of the comb, or clumps that have fallen onto the floor is not a good sign. The two female hormones, i.e. estrogen and progesterone may be out of sync with each other, thereby causing this hair loss condition.

Ignorance is bliss, but it's going to cause you a lot of unnecessary discomfort and anxiety if you do not recognize these top three symptoms of hormone imbalance and find the appropriate help and treatment for the problem.

There are actually many more signs and symptoms that indicate this pervasive health problem in women. And thanks to the efforts of women's health care professionals, these type of information have been compiled and made easily accessible to every discerning woman.

So, in conclusion, these three signs indicating a possible hormone imbalance should be what all women ought to be on the lookout for: depression; sleeping difficulty; and hair loss.

Depression during pregnancy refers to the stress or strain which is caused due to the increase of hormone level in a woman's body resulting in mood swings , in particular the two main female hormones-estrogen and progesterone causemood swings during pregnancy. This is not a disease but a normal problem which can be treated through extra love, care and protection.

Is depression more common in women than in men?
Yes. Women are twice as likely as men to experience depression. The reason for this is unknown, but changes in a woman's hormone levels may be related to depression.

What are the symptoms of depression in women during pregnancy ?

If you're depressed, you may have some of these symptoms nearly every day, all day, for 2 weeks or longer:
- Feeling sad, hopeless and having frequent crying spells
- Feeling guilty, helpless or worthless
- Thinking about death or suicide
- Sleeping too much, or having problems sleeping
- Loss of appetite and unintended weight loss or gain
- Feeling very tired all the time
- Having trouble paying attention and making decisions
- Having aches and pains that don't get better with treatment
- Feeling restless, irritated and easily annoyed
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What causes depression in women during pregnancy ?
Depression seems to be related to a chemical imbalance in the brain that makes it hard for the cells to communicate with one another for example the improper level of serotonin in the brain can cause mood swings. Depression can also be hereditary, which means it runs in families.

In the days following the birth of a baby, it is common for some mothers to have mood swings. They may feel a little depressed, have a hard time concentrating, lose their appetite or find that they can't sleep well even when the baby is asleep.

How is depression during pregnancy is treated?
Depression can be treated with counseling, medicine or both. It's also important to take good care of yourself, to exercise regularly and to eat healthy foods. See the health tips below. Counseling alone may help if the depression isn't severe.

Some do's and don'ts when you're depressed
- Always ensure to talk with your loved ones, friends and family to avoid the feeling of isolation. Always seek the advice from your family doctor.
- Exercise balances the hormone and avoid mood swings. Example the level of serotonin in the brain can cause mood swings and can be balanced by doing yoga, aerobics etc.,
- Remember not to blame yourself for your depression. You didn't cause it.
- Suppress the discouraged feeling by keeping positive sign boards and try to do meditation to clear your depression.
- Do eat balanced meals and healthy food.
- Do get enough sleep. Some women sleep more during depression.
- Do take your medicine and/or go to counseling as often as your doctor tells you to. Avoid self medication.

Does depression affect my unborn baby?

Yes. It has been proved by many research that depression can affect the growth of the fetus. Mothers-to-be who are depressed during pregnancy are more likely to have babies sleep problem during their 18th month says O'Connor a research expert.

In his recent research, O'Connor says, follow others' research showing that mothers who report being stressed during pregnancy have children with higher rates of behavioral problems, as well as hyperactivity and anxiety.

In getting pregnant, you just don't think about which sex positions will help you conceive effectively and successfully. More than body positions, you also need to pay attention to the physical condition of your body. You need to know how to prepare it in order to become pregnant.

First, you need to be attentive with what you eat. What you need are foods that can increase levels of fertility. Nutritious and balanced meals will not only be good in slimming down your waistline. These meals will also influence your menstrual cycle, ovulation and eggs. Foods that can help enhance fertility are unsaturated fats like olive oil, avocados and nuts. Eating such foods can help prepare the body for an imminent pregnancy.

Pay attention to your health problems that might be an obstacle or issue in pregnancy. Thyroid diseases, diabetes, ovarian syndrome, etc. can greatly affect the chances of conceiving. Natural treatments for these conditions must be considered. You should discuss with your doctor how the prescribed medications will affect your chances of getting pregnant healthily. Diseases that are sexually transmitted may also hinder pregnancy chances. STDs can make the fallopian tube blocked due to probable scarring.

You must also be able to lessen the amount of stress your body experiences. Stress can greatly interfere with the brain, which also controls and directs the ovaries to produce eggs on a monthly basis. Chronic stress can affect the menstruation cycle, ovulation phases and the egg hatching. There are lots of techniques that will help you reduce stress and increase your fertility levels.

Avoid unhealthy habits like smoking. Smoking per se does not only affect the mother and her baby during pregnancy. This cigarette habit can also have an immense impact prior to pregnancy. The blood vessels, including those leading to the ovaries, become constricted. This then results to quick loss of eggs. Early infertility can be caused by smoking.

Take folate or folic acid to prepare you for pregnancy. Folate can be difficult to obtain from your diet alone so taking folate supplements will be necessary. Taking folic acid will also help prevent defects in the neural tube such as Spina Bifda that is known to be among the common birth defects. Folate must be taken three months before conception. About 400ug of folate is recommended until the 12th week of being pregnant. Folate can be obtained from foods such as broccoli, spinach, asparagus, berries, beef and bran flakes.

Staying fit is also another great preparation for getting pregnant. Exercising will do much in improving fertility, but only if done appropriately. The body needs to be healthy in order to be prepared for conception. Exercise will promote proper blood circulation to all parts of the body, including your reproductive system. Exercise can also help reduce stress from every day events. It will help you to achieve better sleep, giving your body sufficient time to recover and recharge. Nevertheless, exercising more than how much you should can also degrade fertility. Running over 20 miles within a week can cause irregular menstrual cycles. If your present fitness workout is interfering with your menstruation, you need to lessen it and promote regular menstruation and higher level of fertility.

Vitamins to take when trying to get pregnant are important. Are there any vitamins to help one increase the probability of fertility and get pregnant? The American Pregnancy Association suggest that those who are trying to get pregnant should, at least three months prior, change the diet and also boost their vitamins consumption to ensure their bodies are as healthy as possible which in turn might have a positive affect on infertility.

Despite of the pros and cons reports of the dangers of skin upon over exposure to the sun causing skin cancer have made many people wary of spending too much time in the sun. However, it is the fact of the matter that human beings need the sun's rays for health and wellness and, believe it or not, play a part in lowering cholesterol levels and blood pressure.

It is important therefore that we shouldn't all get a sun phobia as the sun does plays a vital part in both our physical and mental welfare and a certain amount of time spent in the sun will do us a lot more good than harm.

Naturally, when the skin is exposed to ample sunlight, stimulated by UV radiation, the body makes vitamin D3, the biologically active form of vitamin D. 90 per cent of vitamin D in the body is produced by the skin.

However, the use of sunscreen blocks the ultraviolet radiation necessary needed to manufacture Vitamin D.

How much sunlight one's need? Well, by no means are you advised to sunbathe to the point of burning. It is best to sunbathe in the morning because there is much more beneficial ultraviolet rays in the morning, and by the time day hits, avoid the exposure of the sun as it has changed to be primarily infrared rays which is very hot and fierce to the skin.

If you're fair skinned, experts say going outside for 10-15 minutes in the midday sun-in shorts and a tank top with no sunscreen-will give you enough radiation to produce about 10,000 international units of the vitamin D. While Dark-skinned individuals may need up to three times as much as the skin has less ability to absorb UV-B rays.

"Enjoying the sun safely while taking care not to burn should help people strike a balance between making enough vitamin D and avoiding a higher risk of skin cancer," said Jessica Harris of Cancer Research UK.

Up until recently, the role of Vitamin D was primarily recognized for building strong bones and teeth. Scientists have also discovered the importance of Vitamin D to every organ and cell in the body - not just for bones and teeth. Scientists are beginning to link Vitamin D deficiencies with many health conditions, including depression, heart disease, insomnia, an overactive immune system, cancer of the pancreas, colon, breast and prostate as well as a vital vitamin that has been touted as being beneficial to improving fertility rates in both men and women.

Female Fertility and the Sun

Vitamins To Get Pregnant - Vitamin D - also appears to play a role in how estrogen acts in the uterus, particularly in regard to development of the lining. In fact when vitamin D levels are low, your uterus may not develop a lining sufficient enough to hold on to your embryo - which in turn frequently leads to very early stage miscarriage.

Astonishingly, Yale University School of Medicine study of 67 women who had problems conceiving and found that 93% of infertile women had overt vitamin-D deficiency and only a mere 7% had normal Vitamin D levels.

Nearly 40% of the women who had ovulatory dysfunction also had a clinical deficiency in Vitamin D. Therefore, it is easy to understand how important Vitamin D is to a woman's fertility. The correct amount of sex hormones in your body is vital to your overall well-being, otherwise you may suffer PMS, PCOS, and sadly, infertility.

"Of note, not a single patient with either ovulatory disturbance or polycystic ovary syndrome demonstrated normal Vitamin D levels; 39 per cent of those with ovulatory disturbance and 38 per cent of those with PCOS had serum 25OHD levels consistent with deficiency." quoted Dr Lubna Pal - the Director of the Program for Polycystic Ovarian Syndrome (PCOS) at the Yale Fertility Center.

Male Fertility and The Sun

Vitamins To Get Pregnant - Vitamin D - levels has shown significant positive correlation with the testoterone levels according to one of the study by Researchers at Medical University of Graz in Austria. The levels of the male sex hormone testosterone in men's blood rise accordingly with doses of Vitamin D.

It was found that men with at least 30 nanograms of vitamin D in every milliliter of blood had much highest levels of circulating or biologically active male sexual hormone - testoterone - than those with less. An hour of sunshine can boost a man's testosterone levels by 69 percent as well as men's Sex drive.

Testosterone is the most important male sexual hormone, mainly responsible for the development of the sex organs, the formation and maintenance of the typical male sexual characteristics, sperm production and the controlling of male desire.

In conclusion, it is obvious to understand how sun and how important Vitamin D is to both male and female fertility. The correct amount of sex hormones in your body is vital to your overall well-being, otherwise you may suffer PMS, PCOS, low sperm count and sadly, infertility. Hence, couples struggling to conceive should consider getting out in the sunshine more often.