Comment on SSA-2007-0065-0001

The KY DDS would like to offer the following comments in regard to the Proposed Rulemaking for Revised Medical Criteria for Evaluating Functional Limitations Due to Digestive Disorders: In terms of the listings it appears that some digestive disorders seem to fall through the cracks. An example of this is chronic pancreatitis. When these types of conditions are assessed with a PRFC the impact of treatment on function and/or ability to sustain a 40 hour work week is often overlooked. For this reason is seems that functional information should be a very important element when we are documenting these conditions. The addition of a functional digestive listing could insure that individuals with severe digestive disorders that do not meet or equal a listing would be allowed disability instead of being denied. The impact of any disorder on function is somewhat subjective. It would seem that one way to address this would be to assess function in a manner similar to that used when assessing how mental conditions affect function. In order to meet the functional digestive listing the claimant must have both the A portion of the listing, a medically established digestive disorder, and the B criteria impacting two or more areas of function such as marked restriction of activities of daily living; marked difficulty maintaining social functioning; marked difficulties in maintaining concentration, persistence, and pace; etc.).