ALJ made its findings of disability and medical improvement in a single decision, there was no “most recent favorable medical decision” for comparison. The Commissioner’s regulations have no direct application in these circumstances and thus do not neatly prescribe an appropriate baseline. We nevertheless agree with the parties that the thrust of the Commissioner’s regulations applies in closed period cases. Congress enacted the medical improvement standard as a safeguard against the arbitrary termination of benefits. See Pickett v. Bowen, 833 F.2d 288, 292 (11th Cir. 1987). As other circuits have explained, Congress intended this safeguard to apply to all claimants, including those who receive benefits in closed period cases. See Waters v. Barnhart, 276 F.3d 716, 719 (5th Cir. 2002) (<HOLDING>); Shepherd v. Apfel, 184 F.3d 1196, 1200 (10th
recognizing the circuit split and applying the subjective standard as more stringent without deciding which standard applies holding that the preponderance of the evidence standard applies to  523 claims holding teague applies to capital cases holding the medical improvement standard applies to closed period cases holding  3582 proceeding is criminal in nature and tenday appeal period applies and collecting cases