Comment from Fernandez, Lisbeth, School Social Work

I am writing because I am concerned about the proposed use of standardized tests to measure the functioning of people with serious mental illnesses. Unfortunately, this is a flawed approach, with no scientific basis. A person's ability to function is complex. SSA should drop all reference to standardized tests in the mental illness sections of the proposed mental impairment listings, especially the requirements for people to score so low on such tests in order to qualify for benefits. Under the proposed rule, every year thousands of people who cannot work would be unable to qualify for federal disability benefits. Thank you.