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Apr 1, 2011

Proposed Psychiatric Listings Changes Remain Controversial

From UBM Medica Psychiatric Times (emphasis added):

Mental health groups are fighting the Social Security Administration (SSA) over the agency’s proposed changes to disability requirements for mental disorders. The requirements for adults and children, which can vary, were last modified in 1986 and 1990, respectively, and they are respectively based on the now outdated DSM-III and DSM-III-R [Diagnostic and Statistical Manual III Edition, Revised].

There have been differences of opinion, too, with the Mental Health Liaison Group (MHLG), which is composed of advocacy groups and professionals—physicians and non-physicians—who treat people with psychiatric disorders. The MHLG could not agree on a common response to the changes the SSA announced last August in a proposed rule. The American Psychiatric Association (APA) argued against use of the Psychiatric Review Technique by adjudicators to determine functional shortcomings because of mental problems. Some members of the MHLG supported use of that. ...

Much of the controversy stemming from the August proposed rule deals with paragraph B, which contains 4 mental abilities. Under the proposed rule, an individual could show a marked limitation of 2 abilities or an extreme limitation of 1 ability to qualify as mentally disabled. These are the abilities to understand, remember, and apply information; interact with others; concentrate, persist, and maintain pace; and manage oneself.

In what was considered a major policy change, the proposed rule stated that SSA adjudicators could use standardized tests to determine paragraph B limitations for adults. Tests were already approved for use in child determinations. However, the SSA did not specify what tests it had in mind, and mental health groups uniformly complained that no such tests existed. Mark Lassiter, press officer at the SSA, asked for detailed e-mailed questions on the testing issue, but he did not respond to them. ...

The APA, a longtime member of the MHLG, assailed continued use of the Psychiatric Review Technique. “The APA finds this scale to be unanchored, allowing wide latitude for subjective interpretation of what qualifies as a ‘marked’ or ‘extreme’ level of functional impairment,” said James Scully, MD, who is CEO and medical director of the APA. “Without more specific guidance for assigning functional limitations on this scale, which is not currently contained in the proposed rule, we believe use of the five-point scale could bring a false level of precision to determining functional impairment.”

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