Answers to 3 questions
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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For Evaluating Genitourinary Disorders, Question Area 2 regarding consideration of a period of disability greater than 1 year for claimants that have had multiple organ transplants, i.e. kidney and liver, etc., the bigger question should be, for any claimant that have had multiple organ transplants, should they be consider disabled for longer than 1 year? For Example, the heart and lung are sometimes transplanted together. ...more »
Question 1 No changes are needed at this time because the structure and listings criteria for evaluating chronic kidney disease addresses most types of kidney dysfunction. Question 2 A 1 year recovery period is sufficient from either a single or multiple transplants. Transplant(s) failure is likely to occurs within this timeframe. If failure does occur, impairment severity may be assessed under other Genitourinary ...more »
No changes are needed at this time because the structure and listings criteria for evaluating chronic kidney disease addresses most types of kidney dysfunction.
Whatever the type of peritoneal dialysis is used, the associated symptoms would be the same. The choice is determined by the patient's membrane transporter, a "High" transporter being more suited for CCPD and "Low" transporter does better with CAPD. Therefore the side effects may not be different in either case. Ability to work may not be different in these cases. Evidence shows only a few people would be able to function ...more »
We find that 1 year is sufficient period of time for a claimant to recover from either a single or multiple transplants. If the transplants are going to fail, this will happen sooner rather than later. If there is failure, other listings in the Genitourinary listing can be satisfied in order to continue the claimant and allow.
Question # 1. At this time no changes are needed as the listing covers almost all possible kidney dysfunction issues.
I have no comment regarding Question area #1. Question #2: The patient should be considered "disabled" until the transplant surgeon personally expresses in writing the patient is ready to return to work. Sweeping generalizations, such as assuming one year of recovery is adequate are naive and downright wrong. Simultaneous heart/kidney transplantation, for example, requires a much longer recovery than simply the same ...more »
There are several questions requesting comment. In regards to the first question, the main changes I would suggest for consideration are that eGFR be allowed to be calculated by the DDS Examiner/MC team just as occurs for VF efficiencies and other listings, where calculations are made available in the SSA Tools (such as with CLD Score for Adults/Children) for chronic liver disease as well as VF calculations using Humphreys ...more »
It is our suggestion that an additional listing be considered and worded similar to 14.02A and 14.02B adapted for chronic kidney disease related complications, despite prescribed treatment: 1. Involvement of two or more organ/body systems to at least a moderate level of severity, 2. Repeated manifestations of chronic kidney disease with marked level of functional limitation, and 3. Include guidelines about side effects ...more »