Comment from Marshall, Patti, Disability Determination Services

This is in response to the ICF – notice of Publication e-mail dated 1/4/13. This ICF classification system will obviously save SSA considerable rewrite time in how they currently classify impairments within the Listings and will provide additional standardization. However, the way this is set up, the rating of severity will come from either the claimant or the TP, and based on the kind of information we get now, it’s likely the rating will be either severe or complete impairment in many cases. This will make credibility and evaluation/weighing of opinion evidence even more important and likely more difficult than it is currently. SSA will also have to provide definitions and guidance for what mild, moderate, severe, and complete mean within the program and what level typically results in allowance. They may not want to go that far, but if they want to use a classification system like this, they might as well use it to the fullest extent. It will likely be difficult to get this routinely from Treating Physicians but it is likely that every Attorney that goes before an ALJ will have one or more of these completed and submitted. That could result in more of a shift in allowances from the DDS to ODAR in the midst of SSA’s attempt to go the other way. Thank you for the opportunity to comment on the proposal. Patti Marshall | Disability Program Manager Disability Determinations Service Idaho Department of Labor 1505 N McKinney St | Boise, ID 83704