Proposed Changes To Skin Disorder Listing

Social Security’s listing of impairments is the standard by which the agency considers disability claims. A variety of medical conditions are listed in this system and each listing has specific criteria which has to be met to determine the severity of the condition and whether it meets the standard for disability benefits. Social Security recently announced it was proposing changes to one of its listings regarding skin disorder. Below is an overview of the current skin disorder listing followed by some changes Social Security is looking to implement.

Skin Disorder

  1. What skin disorders do we evaluate with these listings?

We use these listings to evaluate skin disorders that may result from hereditary, congenital, or acquired pathological processes. The kinds of impairments covered by these listings are: Ichthyosis, bullous diseases, chronic infections of the skin or mucous membranes, dermatitis, hidradenitis suppurativa, genetic photosensitivity disorders, and burns.

  1. What documentation do we need?

When we evaluate the existence and severity of your skin disorder, we generally need information about the onset, duration, frequency of flare-ups, and prognosis of your skin disorder; the location, size, and appearance of lesions; and, when applicable, history of exposure to toxins, allergens, or irritants, familial incidence, seasonal variation, stress factors, and your ability to function outside of a highly protective environment. To confirm the diagnosis, we may need laboratory findings (for example, results of a biopsy obtained independently of Social Security disability evaluation or blood tests) or evidence from other medically acceptable methods consistent with the prevailing state of medical knowledge and clinical practice.

  1. How do we assess the severity of your skin disorder(s)?

We generally base our assessment of severity on the extent of your skin lesions, the frequency of flare-ups of your skin lesions, how your symptoms (including pain) limit you, the extent of your treatment, and how your treatment affects you.

Summary of Changes

We propose to revise the criteria in the Listing of Impairments (listings) that we use to evaluate claims involving digestive and skin disorders in adults and children under titles II and XVI of the Social Security Act (Act). The proposed revisions reflect our adjudicative experience, advances in medical knowledge, and comments we received from experts and the public in response to two advance notices of proposed rulemaking (ANPRM).

What revisions are we proposing for skin disorders?

We propose to:

  • Revise and reorganize the introductory text to provide guidance for using the revised criteria in listings;
  • Remove and reserve current adult listings 8.02 (Ichthyosis), 8.03 (Bullous disease), 8.04 (Chronic infections of the skin or mucous membranes), 8.05 (Dermatitis), and 8.06 (Hidradenitis suppurativa) and consolidate the current criteria into one listing for chronic conditions of the skin or mucous membranes (proposed 8.09), and remove and reserve current child listings 108.02 (Ichthyosis), 108.03 (Bullous disease), 108.04 (Chronic infections of the skin or mucous membranes), 108.05 (Dermatitis), and 108.06 (Hidradenitis suppurativa) and consolidate the current criteria into one listing for chronic conditions of the skin or mucous membranes (proposed 108.09), to strengthen adjudicative ease and more efficiently capture adults and children with skin disorders of listing level severity;
  • Include limitations of physical functioning we use to assess impairment severity, which are explained in current 8.00C and 108.00C (How do we assess the severity of your skin disorder(s)?), in the listing criteria for adult listings 8.07B (Other genetic photosensitivity disorders), 8.08 (Burns), and 8.09 (Chronic conditions of the skin or mucous membranes) and child listings 108.07B (Other genetic photosensitivity disorders), 108.08 (Burns), and 108.09 (Chronic conditions of the skin or mucous membranes); and Keep in mind that this is only a proposal of changes, Social Security will accept comments and feedback on these changes, but it also has to consider the comments before it can adopt a final version of these rules. Anyone is allowed to comment on this proposal.