Kernrechtsfrage
Whether free legal representation had to be granted in the IV administrative procedure under Art. 37(4) ATSG.
Extrahierter Entscheid
No. The case was not unusually complex, and the claimant’s language and administrative difficulties did not make counsel necessary.
Extrahierte Begründung
Art. 37(4) ATSG requires strict cumulative conditions and a particularly strong need for counsel. A polydisciplinary medical assessment and a dispute over its evidentiary value were treated as an ordinary IV case; the claimant could rely on non-lawyer support or advisory services.