The WHO ICF And Social Security

     Social Security has published today in the Federal Register a request for comments from other government agencies on how it might incorporate the World Health Organization's (WHO's) International Classification of Functioning, Disability and Health (ICF).
     Social Security can't possibly have a specific intention in publishing this request since the current Commissioner of Social Security leaves office in less than three weeks and no one knows who will succeed him. So what might this portend? Australia has recently gone through a process to incorporate the ICF into its disability determination. Take a look at what the Aussies ended up with. It involves a lot of vague terms such as mild, moderate, severe and extreme that have proven to be be indefinable in U.S. disability determination. (U.S. Social Security defines "moderate" as more than "mild" and less than "severe" and "severe" as more than "moderate" and less than "extreme.") The Aussie system also involves a point system -- as in 5 points for mild, 10 points for moderate, 20 points for severe and 30 points for extreme. Apparently, there is some explicit consideration of work capacity as well as consideration of the labor market at some point. 

     What happened in Australia was probably far from inevitable once the decision was made to use the ICF. My very, very early impression is that ICF does not dictate any process for determining disability; it looks like an empty glass into which you can pour whatever you want.

     If Social Security wants to completely redo determination of disability, ICF would be a way of doing it. Whether the change would be for the better or worse would be determined as we go along. At least, we're likely to have a Democrat as Commissioner of Social Security for the next six years.

     The ICF would also be a great way of telling Congress that wonderful changes are on the way -- and, by the way, Congress, could you allow interfund borrowing so the Disability Trust Fund doesn't run out of money before we get these wonderful changes in effect? Those of you who remember former Commissioner Barnhart may recall how her wonderful "plan" kept Congress off her back about those awful hearing backlogs for six years. Introduction of her "plan" always seemed just around the corner. In the end, Barnhart introduced her "plan" as she was about to leave office. Barnhart's "plan" turned out to be worthless and was quickly abandoned by her successor. I doubt this came as a surprise or disappointment to Barnhart. Her "plan" was probably a success in her eyes since it had achieved its goal of keeping Congress off her back. My rule is to beware of any plan that a public official is just starting to implement as he or she is leaving office. If the public official really had a great idea, he or she would have implemented it long before leaving office. Still, the ICF could be a useful tool to help persuade Congress to allow interfund borrowing.

I Don't Know Where This Is Headed

     From a notice that Social Security is having published in the Federal Register on January 2:

We are seeking information and comments from other Federal agencies' regarding their intention to use the WHO ICF[World Health Organization International Classification of Functioning, Disability and Health] as a standard for coding functional capacity with broad potential for application to the business processes of other Federal agencies and researchers throughout the world. We invite other interested Federal agencies involved in disability monitoring to collaborate with us to evaluate an ICF-based standard for coding functional capacity in Federal disability programs. We also invite interested public and private parties to comment on appropriate Federal direction on capturing data on functioning. ...

The WHO ICF is a classification of health and health-related domains, including a list of body functions and a list of domains of activity and participation (see www.who.int/classification/icf/en/). The ICF for Children and Youth (ICF-CY) is a derived version of the ICF designed to record characteristics of the developing child and the influence of environments surrounding the child. The ICF and the ICF-CY reflect WHO’s framework for measuring health and disability at both individual and population levels. ...

We are studying several uses for ICF coding. We could use it, for example, to describe function in activities of daily living, to describe residual functional capacity (to satisfy a specific set of disability criteria), or to develop a compendium of job descriptions that includes mental and physical functional requirements.

     You can order your copy of the ICF for $50.