The Social Security Administration recently released a 2008 study of consultative medical examinations (CEs) performed by Comprehensive Occupational Medical Services (COMS), a contractor. Not all, but many, disability claimants are sent to these exams conducted at Social Security's expense. I have no idea why Social Security took so long to release this. Here are a few findings from the study:
- The mean Quality Rating (QR) of the CE’s reviewed was 2.97 within a range of 1-5: “1” represents an unsatisfactory and unredeemable CE Report and “5” a superbly documented, consistent, and logical report. This finding implies that the majority of CE Reports reviewed were sufficient to provide the DDS with enough clinical information to make an informed claim decision, but were deficient in the amount of clinical detail provided. The common deficiencies noted included: an inadequate history of present illness(es), failure to note medications or medication dosages, an absent or incomplete review of systems, omissions of important details of the physical findings, most commonly involving the musculoskeletal or neurological body systems, and an absent or qualitative medical source statement (MSS).
- Medical evidence of record (MER) was often not forwarded to CE providers. On the other hand, when MER was forwarded, it was unusual to find in CE Reports an adequate description of what items of MER were reviewed by the CE provider. COMS did not find any current policy or regulatory guidance requiring the inclusion of such information in CE Reports.
- The mean QR for CE’s associated with allowance decisions was statistically higher than for denials.
- COMS found that about 25% of X-Rays purchased by DDS’s as part of the CE process were probably unnecessary. Also, most purchased X-Rays, even when apparently indicated based on other CE findings or MER, do not demonstrate important pathological findings for SSA purposes.
- A consistent theme expressed by the DDS’s is that it is difficult at current fee levels to recruit and (retain) CE providers, especially specialists.