Social Security’s Mental Health Proposal

In its 75 years of existence, the Social Security Administration (SSA) has worked to provide benefits and support for the more vulnerable populations in our nation. This past year, the SSA has proposed a number of changes geared at making disability claim processing more fair and efficient. However, in November 2010, the SSA reopened public comment regarding its previously proposed regulation, Revised Medical Criteria for Evaluating Mental Disorders, because of concerns voiced by mental health advocacy groups.

Under the Revised Medical Criteria for Evaluating Mental Disorders, the SSA sought to update criteria for eligibility under Titles II and XVI of the Social Security Act so that applications will be evaluated based on accurate and current diagnostic measures, assessment strategies and knowledge of the disability. While many stakeholders in the mental health community applaud some of the positive changes proposed, several are concerned that a minor change, regarding use of standardized tests, could restrict eligibility for some.

During the rule's original comment period, several mental health advocacy groups and individuals voiced concern that the new rules will require evaluators to focus on standardized tests to make disability determinations. This emphasis could result in claims of evaluators giving more weight to standardized tests and less weight to observations, psychologist notes and psychiatrist's recommendations in determining a person's ability to work.

On Nov. 17, 2010, the SSA sought to clarify public confusion about the new rules and related concerns. While some think that the debate hinges on semantics, the ultimate impact can mean the difference between denial and acceptance of claims. In making these changes, the SSA hopes to have the adult criteria match the juvenile criteria for determining mental health disability benefits. With the standardization of criteria, disability benefits can be more consistently evaluated. Mental health advocates would argue that the absence of testing standards for some disabilities could make this requirement inequitable for those with special mental health conditions.

With its unique mission of providing support to our nation's most vulnerable populations, the SSA cannot overlook its obligation to process claims efficiently and fairly. With millions receiving disability benefits each year, an updated standard could save public dollars and provide services for those who truly need them.