SSA Invites Comments on Proposed Changes to Medical Evidence Rules

On September 9th, the Social Security Administration (SSA) published proposed revisions on their medical evidence rules in the Federal Register, including the proposal to expand the list of Acceptable Medical Sources to include Advanced Practice Registered Nurses (APRNs). SSA invites the public to comment on the proposed changes before November 8th. This is your chance to learn about the proposed changes and have your voice heard!

Why are they proposing these changes?
The proposed revisions reflect changes in national healthcare trends of how people are receiving care and simplifies SSA’s rules for evaluating medical evidence. SSA recognizes that low-income individuals and those experiencing homelessness experience delays in disability application processing due to receiving care from practitioners other than physicians and psychologists. As a result, the individuals we serve through SOAR often have to attend costly consultative exams.
 
What are the key proposals that might affect our SOAR programs?
  1. SSA proposes to add APRNs and other licensed advanced practice nurses with similar titles to the list of Acceptable Medical Sources, along with licensed audiologists for establishing hearing loss.
    1. This changes the current practice of requiring the applicant’s diagnoses to be made by a physician or psychologist
  2. SSA is particularly interested in public comments about adding Physician Assistants (PAs) and other licensed professionals, such as licensed clinical social workers, should also be added to the list of Acceptable Medical Sources.
    1. Note: PAs and LCSWs are not included as Acceptable Medical Sources in the current proposal, but comments about their inclusion in future changes are encouraged
  3. When reviewing and “weighing” medical evidence, SSA proposes that they will no longer give any specific or “controlling weight” to any prior administrative medical finding or medical opinion, including from an individual’s own healthcare providers. Instead, they will emphasize supportability and consistency as the most important factors for considering the value and persuasiveness of the evidence, in order to rely more on the content and less on the source of the medical opinion.
    1. The SOAR Medical Summary Report can be an important tool in documenting how an applicant has consistent and sustained symptoms/functional impairments, even when they have been evaluated by multiple providers
 
Who can comment on this proposal?
Anyone! Have thoughts about these changes? See below on how to have your voice heard!
 
Submit comments on the proposed policy changes to SSA by November 8th
SSA has three methods by which you can submit comments. For all methods, specify that you are writing in response to Docket No. SSA-2012-0035:
  1. Internet: SSA strongly recommends that you submit your comments via the Internet.  Please visit the Federal eRulemaking portal at http://www.regulations.gov.  Use the ``Search'' function to find docket number SSA-2012-0035.  The system will issue a tracking number to confirm your submission.  You will not be able to view your comment immediately because they must post each comment manually.  It may take up to a week for your comment to be viewable.
  2. Fax: Fax comments to (410) 966-2830.
  3. Mail: Mail your comments to the Office of Regulations and Reports Clearance, Social Security Administration, 3100 West High Rise Building, 6401 Security Boulevard, Baltimore, Maryland 21235-6401.
 
We appreciate the passion and dedication of our SOAR providers and encourage you to participate in this open comment period. If you have questions about these proposed policy changes, please reach out to soar@prainc.com.