Proposed 14.00 listings

Document ID: SSA-2006-0070-0013
Document Type: Public Submission
Agency: Social Security Administration
Received Date: August 07 2006, at 03:46 PM Eastern Daylight Time
Date Posted: 
Comment Start Date: 
Comment Due Date: October 3 2006, at 11:59 PM Eastern Standard Time
Tracking Number: 801cec30
View Document:  View as format xml

View Comment

Three changes strike me as potentially problematic. The first and most important is the recurrent definition of significant constitutional symptoms as any two of malaise, fatigue, fever and involuntary weight loss. This means that two subjective symptoms - fatigue and malaise-will do. Fatigue and malaise generally go together anyway, and are exceedingly common in the general population, as well as in the majority of the depressed. They are poor discriminators of severity. I would propose that fatigue/malaise be one constitutional symptom rather than two. Much as I appreciate the attention to feet, I think that the new citation of toe contractures under the scleroderma listing should be more specific, to bring it into comparison with the next three examples of contracture and atrophy. Ordinary hammer toes are common in both the general population and in scleroderma patients. Hammer toes are, though, contractures, even though only the most severe represent significant incapacity. Finally, I think that the term dorsolumbar ankylosis on the spondylitis listing should make explicit that this is dorsal and lumbar, not either one, as this is what represents the impairment described. I would also not emphasize vision so much in this listing, making it sound like that is the biggest functional deficit.

Related Comments

    View All
Total: 50
PID
Public Submission    Posted:     ID: SSA-2006-0070-0002

Oct 03,2006 11:59 PM ET
Sj[ouml]gren's syndrome (114.10)
Public Submission    Posted:     ID: SSA-2006-0070-0003

Oct 03,2006 11:59 PM ET
IMMUNE SYSTEM IMPAIRMENTS
Public Submission    Posted:     ID: SSA-2006-0070-0004

Oct 03,2006 11:59 PM ET
regarding primary immune deficiencis
Public Submission    Posted:     ID: SSA-2006-0070-0005

Oct 03,2006 11:59 PM ET
Revised Medical Criteria for Evaluating Immune System Disorders
Public Submission    Posted:     ID: SSA-2006-0070-0007

Oct 03,2006 11:59 PM ET