Disability Determination - 'Outsource' to Physician?

For retirement plans that provide a benefit due to disability (e.g., accelerated vesting, earlier distribution than otherwise available) ...many employers would prefer to avoid the new disability claims Regulation, if possible, but may not find it practical to leave the determination to the SSA or an LTD carrier.  What your thoughts on whether the following would work. Amend the plan to provide that a licensed physician will make the disability determination; the physician would be presented with the Plan's definition and would have to certify the individual satisfies that particular definition. Plan Administrator will not take any action other than confirming that the certification has been signed by a physician. In this scenario, is the Plan Administrator sufficiently removed from the determination process such that the disability claims Regulation does not apply? There are several related issues. Does the answer differ if the plan provides that the physician must be acceptable to the Plan Administrator (a common term and one that is often preferred by employers)--meaning would this approach work but only if the Plan Administrator has no discretion as to the physician? Does it matter if the plan is a qualified plan or a non-qualified plan (both are subject to the claims Regulations)? Some plans use this approach if the sole reason for a disability determination is whether there is a disability for purposes of a "qualified distribution" for Roth purposes; however, that is essentially a tax issue, not a Plan benefit issue, so the fact that it works in that scenario may or may not have relevance for the broader question. Thanks in advance.

While I don't give you any advice, I invite you to consider this question:

If one imagines a possibility that the physician might "certify" a plan-defined disability for anything fewer than 100% of the claims, who will do the work of the explanations and other claims-procedure steps the employer/administrator prefers to avoid?

Good point...although who does the work of explanations/claims procedures steps when the Social Security Administration is the entity making the decision? (sincere question, not sarcasm)

What some employer/administrators don't like about the recent claims-procedure rule is a duty to explain a claim denial that varies from another's decision or view.  If an employee-benefit plan's provision and procedure is to follow a Social Security decision, that burden doesn't apply.

I know that Fidelity is taking this approach with their prototype document.