MEMORANDUM OPINION AND ORDER

KATHERINE P. NELSON, Magistrate Judge.

Plaintiff Kimberly D. Williams brought this action under 42 U.S.C. § 405(g) seeking judicial review of a final decision of the Defendant Commissioner of Social Security ("the Commissioner") denying her application for a period of disability and disability insurance benefits ("DIB") under Title II of the Social Security Act, 42 U.S.C. § 401, et seq. Upon consideration of the parties' briefs (Docs. 13, 14) and those portions of the administrative record (Doc. 12) (hereinafter cited as "(R. [page number(s) in lower-right corner of transcript])") relevant to the issues raised, the Court finds that the Commissioner's final decision is due to be AFFIRMED under sentence four of § 405(g).1

I. Background

On September 24, 2014, Williams filed an application for a period of disability and DIB with the Social Security Administration ("SSA"), alleging disability beginning August 1, 2014.2 After her application was initially denied, Williams requested a hearing before an Administrative Law Judge ("ALJ") with the SSA's Office of Disability Adjudication and Review. The hearing was held on March 2, 2016. On June 23, 2016, the ALJ issued an unfavorable decision on Williams's application, finding her not disabled under the Social Security Act and thus not entitled to benefits. (See R. 16-37).

The Commissioner's decision on Williams's application became final when the Appeals Council for the Office of Disability Adjudication and Review denied her request for review of the ALJ's decision on June 29, 2017. (R. 1-5). Williams subsequently filed this action under § 405(g) for judicial review of the Commissioner's final decision. See 42 U.S.C. § 405(g) ("Any individual, after any final decision of the Commissioner of Social Security made after a hearing to which he was a party, irrespective of the amount in controversy, may obtain a review of such decision by a civil action commenced within sixty days after the mailing to him of notice of such decision or within such further time as the Commissioner of Social Security may allow."); Ingram v. Comm'r of Soc. Sec. Admin., 496 F.3d 1253, 1262 (11th Cir. 2007) ("The settled law of this Circuit is that a court may review, under sentence four of section 405(g), a denial of review by the Appeals Council.").

II. Standards of Review

"In Social Security appeals, [the Court] must determine whether the Commissioner's decision is "`supported by substantial evidence and based on proper legal standards. Substantial evidence is more than a scintilla and is such relevant evidence as a reasonable person would accept as adequate to support a conclusion."'" Winschel v. Comm'r of Soc. Sec., 631 F.3d 1176, 1178 (11th Cir. 2011) (quoting Crawford v. Comm'r of Soc. Sec., 363 F.3d 1155, 1158 (11th Cir. 2004) (per curiam) (internal citation omitted) (quoting Lewis v. Callahan, 125 F.3d 1436, 1439 (11th Cir. 1997))). However, the Court "`may not decide the facts anew, reweigh the evidence, or substitute our judgment for that of the [Commissioner].'" Id. (quoting Phillips v. Barnhart, 357 F.3d 1232, 1240 n.8 (11th Cir. 2004) (alteration in original) (quoting Bloodsworth v. Heckler, 703 F.2d 1233, 1239 (11th Cir. 1983))). "`Even if the evidence preponderates against the [Commissioner]'s factual findings, [the Court] must affirm if the decision reached is supported by substantial evidence.'" Ingram, 496 F.3d at 1260 (quoting Martin v. Sullivan, 894 F.2d 1520, 1529 (11th Cir. 1990)).

"Yet, within this narrowly circumscribed role, [courts] do not act as automatons. [The Court] must scrutinize the record as a whole to determine if the decision reached is reasonable and supported by substantial evidence[.]" Bloodsworth, 703 F.2d at 1239 (citations and quotation omitted). See also Owens v. Heckler, 748 F.2d 1511, 1516 (11th Cir. 1984) (per curiam) ("We are neither to conduct a de novo proceeding, nor to rubber stamp the administrative decisions that come before us. Rather, our function is to ensure that the decision was based on a reasonable and consistently applied standard, and was carefully considered in light of all the relevant facts.").3 "In determining whether substantial evidence exists, [a court] must . . . tak[e] into account evidence favorable as well as unfavorable to the [Commissioner's] decision." Chester v. Bowen, 792 F.2d 129, 131 (11th Cir. 1986).

However, the "substantial evidence" "standard of review applies only to findings of fact. No similar presumption of validity attaches to the [Commissioner]'s conclusions of law, including determination of the proper standards to be applied in reviewing claims." MacGregor v. Bowen, 786 F.2d 1050, 1053 (11th Cir. 1986) (quotation omitted). Accord, e.g., Wiggins v. Schweiker, 679 F.2d 1387, 1389 (11th Cir. 1982) ("Our standard of review for appeals from the administrative denials of Social Security benefits dictates that `(t)he findings of the Secretary as to any fact, if supported by substantial evidence, shall be conclusive. . . .' 42 U.S.C.A. s 405(g) . . . As is plain from the statutory language, this deferential standard of review is applicable only to findings of fact made by the Secretary, and it is well established that no similar presumption of validity attaches to the Secretary's conclusions of law, including determination of the proper standards to be applied in reviewing claims." (some quotation marks omitted)). This Court "conduct[s] `an exacting examination' of these factors." Miles v. Chater, 84 F.3d 1397, 1400 (11th Cir. 1996) (per curiam) (quoting Martin v. Sullivan, 894 F.2d 1520, 1529 (11th Cir. 1990)). "`The [Commissioner]'s failure to apply the correct law or to provide the reviewing court with sufficient reasoning for determining that the proper legal analysis has been conducted mandates reversal.'" Ingram, 496 F.3d at 1260 (quoting Cornelius v. Sullivan, 936 F.2d 1143, 1145-46 (11th Cir. 1991)). Accord Keeton v. Dep't of Health & Human Servs., 21 F.3d 1064, 1066 (11th Cir. 1994).

In sum, courts "review the Commissioner's factual findings with deference and the Commissioner's legal conclusions with close scrutiny." Doughty v. Apfel, 245 F.3d 1274, 1278 (11th Cir. 2001). See also Moore v. Barnhart, 405 F.3d 1208, 1211 (11th Cir. 2005) (per curiam) ("In Social Security appeals, we review de novo the legal principles upon which the Commissioner's decision is based. Chester v. Bowen, 792 F.2d 129, 131 (11th Cir. 1986). However, we review the resulting decision only to determine whether it is supported by substantial evidence. Crawford v. Comm'r of Soc. Sec., 363 F.3d 1155, 1158-59 (11th Cir. 2004).").

Thornton v. Comm'r, Soc. Sec. Admin., 597 F. App'x 604, 609 (11th Cir. 2015) (per curiam) (unpublished).4

Winschel, 631 F.3d at 1178 (citing 20 C.F.R. §§ 404.1520(a)(4)(i)-(v), 416.920(a)(4)(i)-(v); Phillips, 357 F.3d at 1237-39).5

"These regulations place a very heavy burden on the claimant to demonstrate both a qualifying disability and an inability to perform past relevant work." Moore, 405 F.3d at 1211 (citing Spencer v. Heckler, 765 F.2d 1090, 1093 (11th Cir. 1985)). "In determining whether the claimant has satisfied this initial burden, the examiner must consider four factors: (1) objective medical facts or clinical findings; (2) the diagnoses of examining physicians; (3) evidence of pain; and (4) the claimant's age, education, and work history." Jones v. Bowen, 810 F.2d 1001, 1005 (11th Cir. 1986) (per curiam) (citing Tieniber v. Heckler, 720 F.2d 1251, 1253 (11th Cir. 1983) (per curiam)). "These factors must be considered both singly and in combination. Presence or absence of a single factor is not, in itself, conclusive." Bloodsworth, 703 F.2d at 1240 (citations omitted).

If, in Steps One through Four of the five-step evaluation, a claimant proves that he or she has a qualifying disability and cannot do his or her past relevant work, it then becomes the Commissioner's burden, at Step Five, to prove that the claimant is capable—given his or her age, education, and work history—of engaging in another kind of substantial gainful employment that exists in the national economy. Jones v. Apfel, 190 F.3d 1224, 1228 (11th Cir. 1999); Sryock v. Heckler, 764 F.2d 834, 836 (11th Cir. 1985). Finally, although the "claimant bears the burden of demonstrating the inability to return to [his or] her past relevant work, the Commissioner of Social Security has an obligation to develop a full and fair record." Shnorr v. Bowen, 816 F.2d 578, 581 (11th Cir. 1987). See also Ellison v. Barnhart, 355 F.3d 1272, 1276 (11th Cir. 2003) (per curiam) ("It is well-established that the ALJ has a basic duty to develop a full and fair record. Nevertheless, the claimant bears the burden of proving that he is disabled, and, consequently, he is responsible for producing evidence in support of his claim." (citations omitted)). "This is an onerous task, as the ALJ must scrupulously and conscientiously probe into, inquire of, and explore for all relevant facts. In determining whether a claimant is disabled, the ALJ must consider the evidence as a whole." Henry v. Comm'r of Soc. Sec., 802 F.3d 1264, 1267 (11th Cir. 2015) (per curiam) (citation and quotation omitted).

When the ALJ denies benefits and the Appeals Council denies review of that decision, the Court "review[s] the ALJ's decision as the Commissioner's final decision." Doughty, 245 F.3d at 1278. But "when a claimant properly presents new evidence to the Appeals Council, a reviewing court must consider whether that new evidence renders the denial of benefits erroneous." Ingram, 496 F.3d at 1262. Nevertheless, "when the [Appeals Council] has denied review, [the Court] will look only to the evidence actually presented to the ALJ in determining whether the ALJ's decision is supported by substantial evidence." Falge v. Apfel, 150 F.3d 1320, 1323 (11th Cir. 1998).

III. Summary of the ALJ's Decision

At Step One, the ALJ determined that Williams met the applicable insured status requirements through December 31, 2017, and that she had not engaged in substantial gainful activity since the alleged disability onset date, August 1, 2014. (R. 21). At Step Two, the ALJ determined that Williams had the following severe impairments: fibromyalgia, inflammatory arthritis, obesity, degenerative disc disease post fusion, status post left knee arthroscopy, asthma, chronic pain syndrome, depression, and anxiety disorder. (R. 21-22). At Step Three, the ALJ found that Williams did not have an impairment or combination of impairments that met or equaled the severity of one of the specified impairments in the relevant Listing of Impairments. (R. 22-24).

Phillips, 357 F.3d at 1238-39 (footnote omitted).

The ALJ determined that Williams had the RFC "to perform light work as defined in 20 CFR 404.1567(b)[6] except that she is able to stand/walk four hours total in an eight hour workday[;] should never climb ladders, ropes, or scaffolds[;] can climb ramps and stairs[; can] balance, stoop, kneel, crouch, and crawl occasionally[;] can have no exposure to unprotected heights or hazardous machinery[; and] is limited to simple and routine tasks, with occasional changes in work setting and occasional interaction with the public. " (R. 25-35).

Based on this RFC, the ALJ determined that Williams was unable to perform any past relevant work. (R. 35). At Step Five, after considering testimony from a vocational expert, the ALJ found that there exist significant numbers of jobs in the national economy that Williams can perform given her RFC, age, education, and work experience. (R. 36-37). Thus, the ALJ found that Johnson was not disabled under the Social Security Act. (R. 37).

IV. Analysis

Williams raises four claims of reversible error. For purposes of flow, the undersigned will address them in a different order than Williams has presented them.

a. First and Second Claims of Error — Medical Opinions

Evidence considered by the Commissioner in making a disability determination may include medical opinions. See 20 C.F.R. §§ 404.1527(a)(2), 416.927(a)(2). "`Medical opinions are statements from physicians and psychologists or other acceptable medical sources that reflect judgments about the nature and severity of [the claimant's] impairment(s), including [the claimant's] symptoms, diagnosis and prognosis, what [the claimant] can still do despite impairment(s), and [the claimant's] physical or mental restrictions.'" Winschel, 631 F.3d at 1178-79 (quoting 20 C.F.R. §§ 404.1527(a)(2), 416.927(a)(2)). "There are three tiers of medical opinion sources: (1) treating physicians; (2) nontreating, examining physicians; and (3) nontreating, nonexamining physicians." Himes v. Comm'r of Soc. Sec., 585 F. App'x 758, 762 (11th Cir. 2014) (per curiam) (unpublished) (citing 20 C.F.R. §§ 404.1527(c)(1)-(2), 416.927(c)(1)-(2)). "In assessing medical opinions, the ALJ must consider a number of factors in determining how much weight to give to each medical opinion, including (1) whether the physician has examined the claimant; (2) the length, nature, and extent of a treating physician's relationship with the claimant; (3) the medical evidence and explanation supporting the physician's opinion; (4) how consistent the physician's opinion is with the record as a whole; and (5) the physician's specialization. These factors apply to both examining and non-examining physicians." Eyre v. Comm'r, Soc. Sec. Admin., 586 F. App'x 521, 523 (11th Cir. 2014) (per curiam) (unpublished) (internal citations and quotation marks omitted) (citing 20 C.F.R. §§ 404.1527(c) & (e), 416.927(c) & (e)). While "the ALJ is not required to explicitly address each of those factors[,]" Lawton v. Comm'r of Soc. Sec., 431 F. App'x 830, 833 (11th Cir. 2011) (per curiam) (unpublished), "the ALJ must state with particularity the weight given to different medical opinions and the reasons therefor." Winschel, 631 F.3d at 1179.

Williams's first and second claims of error collectively assert that the ALJ reversibly erred in assigning greater weight to the opinions of two non-examining physicians than the opinions of Williams's treating physicians.7 It is true that "[t]he opinions of nonexamining, reviewing physicians, . . . when contrary to those of the examining physicians, are entitled to little weight, and standing alone do not constitute substantial evidence." Sharfarz v. Bowen, 825 F.2d 278, 280 (11th Cir. 1987) (per curiam). As such, "[t]he good cause required before the treating physicians' opinions may be accorded little weight is not provided by the report of a nonexamining physician where it contradicts the report of the treating physician." Lamb v. Bowen, 847 F.2d 698, 703 (11th Cir. 1988).

However, "the ALJ may reject any medical opinion if the evidence supports a contrary finding." Sharfarz, 825 F.2d at 280. Thus, "[i]f an ALJ has shown good cause to reject the opinion of a treating or examining physician, the ALJ may then properly rely on the opinion of a non-examining medical source if it is consistent with the objective evidence of record." Ethridge v. Berryhill, No. 1:16CV788-WC, 2017 WL 4780619, at *5 (M.D. Ala. Oct. 23, 2017) (Capel, M.J.) (citing cases).8 Accordingly, Williams is wrong to the extent she argues the ALJ was required as a matter of law to adopt her treating physicians' opinions over those of the non-examining physicians.9

Williams next argues that the ALJ should have given controlling weight to the opinions of the treating physicians, Drs. Tao Chen and Juan Ronderos, because they are supported by the record.10 "Absent `good cause,' an ALJ is to give the medical opinions of treating physicians `substantial or considerable weight.'" Winschel, 631 F.3d at 1179 (quoting Lewis, 125 F.3d at 1440). "Good cause exists `when the: (1) treating physician's opinion was not bolstered by the evidence; (2) evidence supported a contrary finding; or (3) treating physician's opinion was conclusory or inconsistent with the doctor's own medical records.' With good cause, an ALJ may disregard a treating physician's opinion, but he `must clearly articulate [the] reasons' for doing so." Winschel, 631 F.3d at 1179 (quoting Phillips, 357 F.3d at 1240-41) (internal citation omitted).11 See also, e.g., Bloodsworth, 703 F.2d at 1240 ("[T]he opinion of a treating physician may be rejected when it is so brief and conclusory that it lacks persuasive weight or where it is unsubstantiated by any clinical or laboratory findings.").

The ALJ gave Dr. Chen's opinion "little weight" because he "did not provide a detailed explanation for his assessment," and because evidence, including Williams's activities of daily living, supported a contrary finding, with the ALJ noting specific examples. (See R. 33-34). All of these reasons are "good cause" to reject a treating physician's opinion. See Winschel, 631 F.3d at 1179; Crow v. Comm'r, Soc. Sec. Admin., 571 F. App'x 802, 806 (11th Cir. 2014) (per curiam) (unpublished) ("[E]vidence of Crow's daily activities also provided good cause to discount his treating physician's opinion." (citing Phillips, 357 F.3d at 1241)). The ALJ gave the "various opinions" of Dr. Ronderos "partial weight" because "they are temporary and postoperative recovery instructions not intended to be reflective of a long-term limitation," noting that "Dr. Ronderos released the claimant to follow up as needed with no recommendation for long term or permanent restrictions." (R. 34). In other words, the ALJ found that Dr. Ronderos's own treatment records did not support giving long-term effect to his opinions. This too was good cause. Winschel, 631 F.3d at 1179. Williams fails to acknowledge the ALJ's stated reasons for discounting the treating physicians' opinions and has made no showing why they are not supported by the record. At most, Williams cites some other evidence in the record bolstering those opinions.12 However, "[w]here our limited review precludes re-weighing the evidence anew, Miles v. Chater, 84 F.3d 1397, 1400 (11th Cir.1996), and as the ALJ articulated specific reasons for failing to give [the treating physicians'] opinion[s] controlling weight," the Court "find[s] no reversible error." Moore, 405 F.3d at 1212.

Finally, Williams argues that the ALJ should not have relied on the non-examining physicians' opinions because they "were made at a time when all medical evidence was not of record" and were thus "unsupported" and "premature." (Doc. 13 at 8).13 However, the ALJ thoroughly summarized the record evidence in her decision and explained that she gave "great weight" to the non-examiner opinions because they were largely consistent with that evidence. (See R. 32-33). Thus, the ALJ adequately demonstrated that she considered other evidence in conjunction with the non-examiner opinions in reaching her RFC,14 and Williams does not argue that this other evidence was insubstantial. Thus, she has failed to show reversible error in the ALJ's reliance on the non-examiner opinions.15

Accordingly, the Court OVERRULES Williams's first and second claims of error.

b. Fourth Claim of Error — VE Testimony

At Step Five, the ALJ, relying on the testimony of a vocational expert, found that Williams could perform the jobs of food prep work, mail clerk, and "folder, textile, or laundry," considering her age, education, work experience, and RFC, and that such jobs exist in significant numbers in the national economy. (R. 36). In her fourth claim of error, Williams asserts that the RFC "precludes the performance" of those jobs because the RFC limited Williams to standing and walking only four hours in an eight-hour workday, while the Dictionary of Occupational Titles (DOT) lists each of those jobs as entailing "significant standing/walking." (Doc. 13 at 13). Thus, she claims, the VE's testimony is inconsistent the DOT and therefore not substantial evidence satisfying the Commissioner's Step Five Burden.

Even if the VE's testimony is inconsistent with the DOT, however, it is settled law in this circuit that "when the VE's testimony conflicts with the DOT, the VE's testimony `trumps' the DOT." Jones v. Apfel, 190 F.3d 1224, 1229-30 (11th Cir. 1999).16 To the extent SSR 00-4p or the SSA's Production and Operations Management Society (POMS) might provide otherwise, as Williams asserts, neither of those documents permits this Court to disregard this clear precedent.17 Because Williams has failed to show reversible error in the ALJ's reliance on the VE's testimony at Step Five,18 her fourth claim of error is OVERRULED.

c. Third Claim of Error — New Evidence to Appeals Council

Washington v. Soc. Sec. Admin., Com'r, 806 F.3d 1317, 1320 (11th Cir. 2015) (per curiam).

In its order denying Williams's request for review of the ALJ's decision, the Appeals Council explained that the additional evidence she submitted to it — 14 pages of "medical records from Sacred Heart Medical Group dated March 15, 2016 through May 4, 2016" (R. 2; see also R. 44-57) — "does not show a reasonable probability that it would change the outcome of the decision" (i.e., that the new evidence was not "material"19); therefore, the Appeals Council "did not consider and exhibit this evidence." (R. 2). When, as here, "`the Appeals Council refuses to consider new evidence submitted to it and denies review, that decision is . . . subject to judicial review. . . .'" Washington, 806 F.3d at 1320 (quoting Keeton v. Dep't of Health & Human Servs., 21 F.3d 1064, 1066 (11th Cir. 1994)). "[W]hether evidence meets the new, material, and chronologically relevant standard is a question of law subject to our de novo review." Id. at 1321 (quotation omitted). Therefore, "when the Appeals Council erroneously refuses to consider evidence, it commits legal error and remand is appropriate." Id.20

In arguing that the additional evidence she submitted to the Appeals Council is material, Williams directs attention to the following portion of the ALJ's decision, which immediately follows the ALJ's discussion of Dr. Ronderos's opinions:

(R. 34). Williams appears to suggest that the new evidence corroborates the nurse practitioner's "lumbar failed back surgery" notation. While the undersigned agrees, Williams fails to convince the undersigned that the Appeals Council erred in finding the new evidence to be immaterial.

The new evidence consists of treatment notes from four visits with the Sacred Heart Medical Group in 2016. At the first, occurring March 15, 2016, Dr. Ronderos documented Williams's complaints of pain in her back, buttocks, and lower extremities. (R. 53). After noting "normal" findings on physical exam, Dr. Ronderos set Williams for surgery to remove a left pedicle screw (discovered through a lumbosacral spine CT) and imposed certain working restrictions: "unable to work for: 3-6 weeks[;] no maximum lifting over 20 pounds[;] alternate sitting/standing, may walk short distances." (R. 55). At the second visit, occurring March 29, 2016, Dr. Ronderos again documented "normal" physical exam findings, reiterated that Williams was set for surgery for "removal [of] Left sided hardware," and stated she would be "unable to work for: 4 weeks." (R. 51-52). He also assessed Williams with "failed back syndrome" and "low back pain." (R. 51).

At the third visit, occurring April 13, 2016, ten days following Williams's surgery, examiner Kevin Hites noted that Williams was "healing well" and that she "will keep her follow up appt." (R. 47-48). Hites also assessed her with "low back pain." (R. 48). At the last visit, on May 4, 2016, Dr. Ronderos again documented "normal" physical exam findings, and assessed "low back pain," "failed back syndrome," and "hyperlipidemia." (R. 46). Dr. Ronderos also noted there were "no surgical options available for" Williams and discharged her from care, recommending that she "continue with current medications as prescribed" by her physicians and opining that her "pain can be addressed with conservative measures at this time." (R. 46).

The ALJ made clear that her decision to specially address the nurse practitioner's April 2015 notation of "lumbar failed back surgery," and to treat it as a possible medical opinion, was made out of an abundance of caution because the ALJ could find no objective record evidence to corroborate that diagnosis. While the new evidence submitted to the Appeals Council does provide the corroboration that was lacking with the ALJ, it also shows that the ALJ need not have specially addressed the nurse practitioner's notation as a medical opinion. Moreover, the new evidence consistently documented "normal" physical findings, and as with Dr. Ronderos's 2015 opinions that the ALJ addressed in her decision, they provided "temporary and postoperative recovery instructions not intended to be reflective of a long-term limitation." (R. 34). Finally, the new evidence is consistent with the ALJ's finding that "[t]he objective findings documented by Dr. Ronderos at post-surgical examinations" and Williams's post-surgery activities of daily living "strongly suggests her back surgery is not `failed.'" (R. 34).

Williams has not shown that there is a reasonable possibility the evidence submitted to the Appeals Council would have changed the ALJ's decision. Accordingly, the Appeals Council did not err in declining to consider it, and the Court OVERRULES Williams's third claim of error. Having overruled all claims of error raised, the Court therefore finds that the Commissioner's final decision denying Williams benefits is due to be AFFIRMED.

V. Conclusion

In accordance with the foregoing analysis, it is ORDERED that the Commissioner's decision Williams's application for a period of disability and DIB, made final by the Appeals Council's denial of review on June 29, 2017, is AFFIRMED under sentence four of 42 U.S.C. § 405(g).

Final judgment shall issue separately in accordance with this order and Federal Rule of Civil Procedure 58.

DONE and ORDERED