The Social Security Administration (SSA) published two rulings in the Federal Register on June 2, 2014. Social Security Ruling (SSR) 14-2p provides guidance on how the agency evaluates diabetes mellitus (DM) in claims for disability benefits, and SSR 14-3p does the same for endocrine disorders other than DM. Social Security Rulings (SSR) are decisions by SSA based on analysis of legal or administrative decisions, or other interpretations of the law of regulations. SSRs do not have the same legal effect as statutes, regulations, or case law, but they are binding upon all components of SSA. Therefore, SSA decision-makers are required to follow the guidance and instructions in SSRs in administering SSA’s benefit programs. Both SSRs had an effective date of June 2, 2014.
On April 8, 2011, SSA removed endocrine disorders, including DM, from the Listing of Impairments (listings) based on the premise that the disorders as described there “no longer accurately identified people who are disabled.” The listings are impairments considered so severe that if an individual meets or equals the medical criteria set forth in a listed impairment, they would qualify for disability benefits from SSA. When SSA rescinded the listed impairments for endocrine disorders, they asserted they would still consider the disorders a potential cause of disability and would issue further guidance on analyzing claims based on endocrine disorders. Hence, SSRs 14-2p and 14-3p.
SSR 14-2p describes the different types of DM (Type 1 and Type 2), hyperglycemia, hypoglycemia, and the medical complications that can result from DM, such as retinopathy, cardiovascular disease, nephropathy, and neuropathy. The ruling sets forth that DM will be analyzed in the five step sequential evaluation process to make a determination of whether someone is disabled. In essence, a determination must be found whether the medically determinable DM is “severe” (has a significant impact on the claimant’s ability to do work activity), whether the DM, alone or in combination with other conditions meets or medically equals one of the listed impairments, and if not, the impact the limitations have on the claimants ability to do their past work or other work considering their age, education and work history.
SSR 14-3p addresses the endocrine disorders other than DM, such as pituitary gland disorders, thyroid gland disorders, adrenal gland disorders, pancreatic disorders, and gonadal disorders. The ruling then sets forth evaluation criteria for adults with these disorders, very similar to the assessment to be given to DM as outlined above. Both rulings also set forth an analysis of the determining disability in children with endocrine disorders.
This is the second and third ruling this year, following SSR 14-1p which addressed how chronic fatigue syndrome is assessed in the disability determination process