Comment from Riden MD, David, East Tennessee Children's Hospital

Document ID: SSA-2009-0038-0006
Document Type: Public Submission
Agency: Social Security Administration
Received Date: March 18 2013, at 12:00 AM Eastern Daylight Time
Date Posted: March 20 2013, at 12:00 AM Eastern Standard Time
Comment Start Date: February 4 2013, at 12:00 AM Eastern Standard Time
Comment Due Date: April 5 2013, at 11:59 PM Eastern Standard Time
Tracking Number: 1jx-849y-3jvy
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re: GU Disorders and disability - I agree to an extent with your criteria regarding childhood GU disorders ( ectopic ureters, valves, Eagle-Barrett ( aka Prune Belly Syndrome)- but it seems to be surgery based with surgery criteria ( 3 surgeries at least 30 days apart over 12 months) Many of these children I would consider disabled by their conditions, but many would not necessarily need 3 surgeries within 12 months. Valves, for instance, may only need one surgery, but then may meet criteria in the category of CKD ( chronic kidney disease) - and yes, I would agrre with the disability period of one year would help us figure out resolving versus more chronic disability. for instance, children with spina bifida have multiple anomolies in various areas ( neurologic, orthopedic, urologic) and may meets multiple surgery criteria but not in the individual areas ( ie not 3 urologic surgeries, but a neurosurgical one, a urologic one, and a urologic one) Is the criteria the number of surgeries as a "threshold" for level of disability for consideration for SS benefits - or- would one surgery with other urologic "medical criteria" like neuropathic bladder, hydronephrosis, need for daily antibiotics, UTI's ( hospitalization) or need for intermittant clean catheterization fit? As a separate category within this section of disorders,, I can understand the requirement for 3 surgeries - but given how we manage these disorders I would suggest lengthening the criteria to 24 months with 3 surgeries with a 1 year disability period after with subsequent re-evaluation. Hopefully a 24 months period with not require substantial re-working of other regulations or rules but for congenital urologic issues I believe it is appropriate

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Comment from Riden MD, David, East Tennessee Children's Hospital
Public Submission    Posted: 03/20/2013     ID: SSA-2009-0038-0006

Apr 05,2013 11:59 PM ET
comment from Treadwell, Muriel IN
Public Submission    Posted: 04/05/2013     ID: SSA-2009-0038-0009

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Comment from Deibler, Doug, PA Disability Determination Service (DDS)
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Comment from Wilson, Rhonda J., FL DDS
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Comment from National Association of Disability Examiners
Public Submission    Posted: 04/12/2013     ID: SSA-2009-0038-0011

Apr 05,2013 11:59 PM ET