SSA Revises Criteria for Evaluating Mental Disorders

Revised Medical Criteria for Evaluating Mental Disorders

On September 26^th the Social Security Administration (SSA) published new rules updating how they will evaluate mental health conditions. SSA has not fully revised the Listings for mental disorders since 1990 and proposed these rule changes in November 2010. The new rules reflect advances in medical knowledge, public comments from the 2010 proposal, and updates contained in the Diagnostic and Statistical Manual of Mental Disorders, Fifth Edition (DSM-5).

Updates to the Listings

• The titles of the listings will be updated to reflect the terms the American Psychological Association uses to describe the categories of mental disorders in the DSM-5.

• Three new adult listings will be added: 12.11 Neurodevelopmental disorders (conditions characterized by an onset in childhood/adolescence); 12.13 Eating disorders; and 12.15 Trauma- and stressor-related disorders (e.g. PTSD).

• The listing for substance addiction disorders (12.09) will be removed, as individuals cannot be approved solely based on a substance use disorder and this listing only refers to medical criteria in other listings. The rules about materiality of co-occurring substance use disorders remain the same.

Changes to the Four Areas of Functioning

• The new four areas of functioning will be: 1) Understand, remember, or apply information; 2) Interact with others; 3) Concentrate, persist, or maintain pace; and 4) Adapt or manage oneself.

• Activities of daily living (ADLs) will no longer be a separate category, and SSA will be viewing ADLs as a primary source of information about all four of the areas of functioning. For instance, difficulties in an ADL task may result from difficulty in understanding what to do, trouble concentrating on the task at hand, being unable to engage in the task around others, or becoming so frustrated in the task that the person loses self-control in the situation.

• Similarly, episodes of decompensation will also no longer be a separate area of functioning; however, SSA will continue to consider exacerbations and remissions in the applicant’s conditions in the context of how they affect the applicant’s ability to function on a regular and continuing basis, defined as 8 hours a day, 5 days a week, or an equivalent work schedule.

• SSA will add clarification that the greatest degree of limitation in any part of areas 1, 3, or 4 will be the degree of limitation for that whole area of functioning. For example, if an applicant has “marked” limitations in ability to concentrate, but “mild” limitations in ability to persist or pace, the applicant will receive a “marked” rating for area 3 of functioning.

Updated Criteria for the Evaluation of Intellectual Disorders

• The revised criteria will be very similar to the DSM-5 definition for intellectual disability and focuses on three main elements: significant limitations in general intellectual functioning, significant deficits in adaptive functioning, and evidence that the disorder began before age 22.

• For individuals who are able to take a standardized intelligence test, the revised criteria requires the applicant to have either a full scale IQ score of 70 or below, or a full scale IQ score of 71 through 75 accompanied by a verbal or performance IQ score of 70 or below. This listing will no longer have categories for IQ scores lower than 70, as they will be encompassed in this definition.

• The new listing 12.11 for neurodevelopmental disorders will identify claimants with cognitive impairments that result in marked or extreme functional limitations but do not satisfy the criteria for intellectual disorders.

New Emphasis on the Importance of Social Workers, Case Managers, and Outreach Workers

• SSA explicitly recognizes that individuals experiencing homelessness may have difficulty in providing longitudinal evidence.

• Community service providers may have evidence of the effects of mental illness on an applicant’s functioning even if the applicant has not had an ongoing relationship with the medical community or is not currently receiving treatment.

• This is what SOAR providers do best!