Inaugural NDC Post Meeting Comment Forum

Factors and methods for considering ability to function

The National Association of Disability Representatives (NADR) strongly agrees with Lisa Ekman's statement during the Coalition meeting on September 24th that evaluation of function must be determined through an individualized assessment. The grids, which allow for consideration of pain, fatigue and mental and cognitive impairments, are appropriate and should continue to be used in determining an individual's functional capacity.


A standardized tool to assess function might assist a healthcare professional in assessing function, but it should never replace or reverse the assessment of a health care provider who has an ongoing relationship with the claimant.


We note that many conditions that lead claimants to apply for disability benefits are episodic in nature. A assessment of such a claimant on a day that he or she is fairly symptom-free may yield a very different result from one conducted a few days later when the claimant's symptoms are present. Also, any assessment tool must take into account the impact of multiple impairments.


NADR also agrees that, while great advances have been made in life expectancy in the United States, those gains have not been realized across the board. Uneducated, unskilled laborers have not seen their life expectancy increase at the same rate as white-collar workers. The grids as they currently exist are appropriate for evaluating the work capacity of a 52-year-old individual whose only work experience is with jobs that are require little skill and are physically demanding.


NADR supports efforts such as those described by Steven Ortega of CIGNA to support private-insurance clients in returning to work. We also believe that CIGNA's experience reducing claim loads among Social Security disability examiners and increasing vocational rehabilitation and medical staff would likely if applied to SSA would likely speed up and improve the disability determination process. However, we find it unlikely in the current budget environment that Congress would provide sufficient administrative resources to replicate CIGNA's model for either facilitating return to work or evaluating claims.


NADR agrees with Amy Vercillo of the IARP that, while SSA's efforts to work with the Bureau of Labor Statistics to create an Occupational Information System that would be updated every six months is a positive step, using this newly developed OIS to look at the demands of light and sedentary unskilled jobs will be a problem. As Ms. Vercillo pointed out, a job assembling airplanes and a job assembling electronic components make very different demands on an individual's functional capacity. But both will be included in the single category of "assembler" as the OIS currently is envisioned. We agree that SSA should explore ways to provide more specific data on light and sedentary unskilled jobs.


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Idea No. 55