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.
Proposed 14.00 listings
This is comment on Proposed Rule
Revised Medical Criteria for Evaluating Immune System Disorders
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