The Office of Management and Budget (OMB), which is part of the White House, has just approved a set of amendments to Social Security's mental impairment listings. The notice says that changes were made in the amendments while they were under review.
OMB had approved a set of amendments to the mental impairment listings in the waning days of the George W. Bush Administration but Social Security Commissioner Michael Astrue declined to publish that set. We have no way of knowing how that set of amendments differed from the set just approved by OMB. We have no way of knowing what changes were made in the proposal while it was pending at OMB this time. In fact, we have no way of knowing what is in this set until it is published in the Federal Register.
Amendments to the mental impairment listings are potentially quite controversial. These listings have a greater effect than any other listings. Mental illness is among the most important causes for disability. Mental illness remains a controversial topic with the public, many of whom regard it as largely imaginary. Over the decades that I have been involved with Social Security, I have seen the agency take somewhat extreme positions on the evaluation of mental disability.
I should know better than to make predictions but I will do so anyway. I predict that Social Security will make it dramatically more difficult to be found disabled as a result of mental retardation. I have never understood why, but this group has been at the top of Social Security's hit list for about a decade. I also predict that Social Security will make it more difficult for adults to be found disabled as a result of bipolar disorder and dramatically more difficult for children to be found disabled as a result of bipolar disorder. Maybe, they will propose to make it less difficult for schizophrenics to be found disabled. They ought to. They may try to slip in something to alter the standards for determining disability for those who have both a substance abuse disorder and another mental disorder. Anything along that line would be extraordinarily controversial and might not withstand judicial review. One safe prediction is that the preamble to the proposed mental impairment listings will be very, very long.
Expect that these proposed changes will appear in the Federal Register soon, perhaps next week. The public will have an opportunity to comment. Social Security must consider these comments and again obtain OMB approval before this proposal can be made official.
OMB had approved a set of amendments to the mental impairment listings in the waning days of the George W. Bush Administration but Social Security Commissioner Michael Astrue declined to publish that set. We have no way of knowing how that set of amendments differed from the set just approved by OMB. We have no way of knowing what changes were made in the proposal while it was pending at OMB this time. In fact, we have no way of knowing what is in this set until it is published in the Federal Register.
Amendments to the mental impairment listings are potentially quite controversial. These listings have a greater effect than any other listings. Mental illness is among the most important causes for disability. Mental illness remains a controversial topic with the public, many of whom regard it as largely imaginary. Over the decades that I have been involved with Social Security, I have seen the agency take somewhat extreme positions on the evaluation of mental disability.
I should know better than to make predictions but I will do so anyway. I predict that Social Security will make it dramatically more difficult to be found disabled as a result of mental retardation. I have never understood why, but this group has been at the top of Social Security's hit list for about a decade. I also predict that Social Security will make it more difficult for adults to be found disabled as a result of bipolar disorder and dramatically more difficult for children to be found disabled as a result of bipolar disorder. Maybe, they will propose to make it less difficult for schizophrenics to be found disabled. They ought to. They may try to slip in something to alter the standards for determining disability for those who have both a substance abuse disorder and another mental disorder. Anything along that line would be extraordinarily controversial and might not withstand judicial review. One safe prediction is that the preamble to the proposed mental impairment listings will be very, very long.
Expect that these proposed changes will appear in the Federal Register soon, perhaps next week. The public will have an opportunity to comment. Social Security must consider these comments and again obtain OMB approval before this proposal can be made official.
2 comments:
I disagree with your premise on mental retardation. You write "it will make it more difficult to be found disabled." I would submit that there are many people found disabled who could perform low skilled work and that the current standards need to be tweaked to allow for that.
The Listings are there for administrative convenience. Essentially, they are there because those who meet the Listings are almost always to be found disabled at steps four or five. If that is not the case, the Listings should be revised to reflect reality.
Language, please!
People are not "schizophrenic," as an identity of existence. They "have schizophrenia," as a medical diagnosis.
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