For applicants who pursue Social Security disability claims based on mental health impairments, Global Assessment of Functioning (GAF) scores can play an important role. GAF scores are made by treating providers who perform Diagnostical and Statistical Manual of Mental Disorders (DSM-IV-TR) assessments.
Courts have held that Social Security must consider GAF scores when evaluating a claimant’s mental health impairments. For example, the Eighth Circuit has discussed the necessity of an administrative law judge to “consider a claimant’s total GAF score history.” Pate-Fires v. Astrue, 564 F.3d 935, 944 (8th Cir. 2009) (citing Colon v. Barnhart, 424 F.Supp.2d 805, 813-14 (E.D.Pa. 2006)). Courts have also held that a history of low GAF scores is indicative of an inability to work. In Brueggemann v. Barnhart, the vocational expert testified that a claimant with a GAF score of 50 could not work. Brueggemann v. Barnhart, 348 F.3d 689, 695 (8th Cir. 2003). Other courts have made similar rulings. See, e.g., Cruse v. U.S. Dep’t of Health & Human Servs., 49 F.3d 614, 618 (10th Cir. 1995) (holding that the ALJ’s conclusion that a claimant was not disabled was not supported by substantial evidence where the ALJ misinterpreted or ignored the claimant’s psychiatric assessment rating indicating the claimant had marked mental impairment, which would substantially impair his ability to work); Golubchick v. Barnhart, No. CV-03-3362, 2004 WL 1790188, at *7 (E.D.N.Y. Aug 9, 2004) (emphasizing a medical expert’s testimony that a GAF score below 50 is generally incompatible with the ability to work); Mook v. Barnhart, No. 02-2347, 2004 WL 955327, at *6 (D.Kan. April 26, 2004) (noting a VE’s testimony that a claimant’s GAF score of 50 would eliminate any possible jobs in the national economy).
Despite these court rulings, many administrative law judges are unfamiliar with GAF scores and the implication they have on the disability process. An experienced advocate like the attorneys at Greeman Toomey can help educate the judge on GAF scores and the implications they have for your case. Contact us at 1-877-332-3252 or at www.greemantoomey.com today.
