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May 8, 2012

DSM Coming In May 2013 -- What About Proposed New Psychiatric Listings?

     The 5th edition of the Diagnostic and Statistical Manual (DSM-5) is due out in May 2013. Many of my readers are now going "Huh? What's that?" The DSM is the Bible of psychiatry. It is an essential tool for the diagnosis of mental illness. Indeed, psychiatry was revolutionized by the advent of the DSM. Psychiatric illness is a major basis for awarding Social Security disability benefits. The DSM has had a huge impact upon disability determination at Social Security. While it is impossible to now predict what effect it will have, the DSM-5 is almost certain to be of considerable importance to Social Security. If you have an interest in disability determination at Social Security but are not involved in it on a day to day basis, just take it from someone who is, a new edition of the DSM is a big deal for Social Security.
     Social Security has been working on new Listings of impairments, that is regulations defining which disability claims based upon psychiatric conditions require quick approval, for more than four years. Social Security got a proposal approved by the Office of Management and Budget (OMB) in the waning days of the George W. Bush administration but never published it.  (No doubt, it would have been published if McCain had won.) After Barack Obama took office, the agency went back to the drawing board and got a new proposal approved by OMB to be published for notice and comment. This proposal was highly controversial. The comments are all in. At least in theory, Social Security could send final regulations over to OMB for approval at any time. Will Michael Astrue try to finalize proposed psychiatric listings while he is still Commissioner of Social Security -- before DSM-5 comes out? Astrue's term ends in January 2013. I was surprised that OMB approved publication of the proposal. Would OMB approve final regulations that contained the controversial elements of the proposal? Would Astrue want the proposed Listings without the controversial elements? Is it already getting too close to the election for controversial regulations? Would OMB approve anything important proposed by a lame duck Republican Commissioner of Social Security?

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