Comments on revisions to Social Security Administration criteria for evaluating neurological disorders

The APA Practice Directorate, along with input from Divisions 38 and 40, addressed a proposed disability determination question.

On April 28, the American Psychological Association (APA) Practice Directorate, with assistance from Div. 38 (Health Psychology) and Div. 40 (Clinical Neuropsychology) submitted comments to the Social Security Administration (SSA) on proposed revisions to the medical criteria used for evaluating neurological disorders. 

In February the SSA proposed revised criteria for the Listings of Impairment (listings) for section 11.00, neurological disorders. The listings detail requirements for when the SSA should judge a medical condition to be disabling, and are used to evaluate claims for disability benefits under the Social Security disability insurance program or payments under the supplemental security income program. 

While noting that Div. 38 called the revised listings an incremental improvement, APA Practice submitted additional information from Div. 40 addressing the disability determination question of proposed section 11.00G: How do we [the SSA] evaluate a combination of functional limitations under these listings? 

The Practice Directorate’s letter noted that while a neurological evaluation may reveal a defined neurological disease, the determination of how much the disease impacts social functioning and daily living activities relies on self-report methods. Under the current methods, a neurological consultative examiner records a claimant’s self-reported statements but has no outside confirmation to determine whether the claimant’s functional limitation is as severe as reported. 

In cases where the course of the disease is not expected to be as severe, or for which treatment is expected to ameliorate symptoms, it was suggested that SSA conduct a determination of the validity of the claim for disability. Claimants in these cases would have both a neurologic examination to determine the nature and course of the neurologic disease, and a psychological consultative examination to determine functional limitations and the validity of the claim. 

The Practice Directorate will continue to monitor the Federal Register for any future notices regarding the SSA’s next steps that could impact practitioners.