The Listing of Impairments (listings) designates medical conditions that are severe enough for SSA to consider a person to be disabled. We recently revised our listings for evaluating genitourinary disorders in December 2014. We update the listings on an ongoing basis, considering information from various sources including medical experts, advocates, adjudicators, and individuals with the impairment. As part of our continuing efforts to ensure the medical listings and related medical policy remain current, we would like your feedback on the effect of treatment on determining when genitourinary disorders are disabling under our disability programs. You can review the current listings for genitourinary disorders at: https://www.ssa.gov/disability/professionals/bluebook/6.00-Genitourinary-Adult.htm. For more information about peritoneal dialysis, see the National Institute of Diabetes and Digestive and Kidney Diseases page on Treatment Methods for Kidney Failure: Peritoneal Dialysis at: http://www.niddk.nih.gov/health-information/health-topics/kidney-disease/peritoneal-dialysis/Pages/facts.aspx.
Please see the issues below for your comment
Question Area 1
Background - Currently, we evaluate chronic kidney disease (CKD) under listings 6.03 (with chronic dialysis), 6.04 (with kidney transplant), and 6.05 (with impaired kidney function).
Question - Are there other criteria that SSA should use in these listings, or do you believe these listings should be structured differently?
Question Area 2
Background - Under listing 6.04, we consider you to be disabled for 1 year from the date you receive a kidney transplant. After that, we will evaluate your residual impairment(s) by considering your post-transplant function, any rejection episodes you have had, complications in other body systems, and any adverse effects related to ongoing treatment. Some individuals receive a kidney transplant simultaneously with another organ (for example, liver or pancreas).
Question - If someone has undergone a multiple-organ transplant, should the period we consider him or her to be disabled be one year? Or, are there differences in the recovery period, immunosuppressive treatment, or ongoing complications that would result in a longer period of disability?
Question Area 3
Background - Under our rules for evaluating CKD treated with dialysis, both hemodialysis and peritoneal dialysis satisfy the listing criterion. Peritoneal dialysis uses a dialyzing solution that is introduced into and removed from the abdomen (peritoneal cavity) either continuously or intermittently. The process of doing peritoneal dialysis is called an exchange, and most people usually complete 4 to 6 exchanges every day. There are two different methods for peritoneal dialysis – continuous ambulatory peritoneal dialysis (CAPD) and continuous cycler-assisted peritoneal dialysis (CCPD). The schedule for exchanges may be different depending on the type of peritoneal dialysis.
Question - Should we have different rules for evaluating the two types of peritoneal dialysis? Does the difference in the schedule of exchanges affect a person’s ability to work?
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