In April 2021 Social Security released an emergency message to staff about how to consider COVID-19 impairments as it relates to a disability claim. As has been reported, many people who contracted COVID-19 suffer both short-term impairments as well as more long-term impairments. The people who suffer long-term effects of COVID-19 have been referred to as Long Haulers. As part of the evaluation process, Social Security will consider the impairment and determine the impairment’s severity and duration to determine if it meets disability rules. Below is an explanation from Social Security of how it will consider COVID-19 cases.
- Establishing and coding a medically determinable impairment (MDI)
We need objective medical evidence from an acceptable medical source (AMS) to establish the existence of an MDI for COVID-19, including long-term effects of COVID-19, which means signs, laboratory findings, or both (DI 24501.020A). We establish an MDI for COVID-19 when evidence from an AMS indicates:
- A report of a positive viral test for SARS-CoV-2,
- A diagnostic test with findings consistent with COVID-19 (e.g., chest x-ray with lung abnormalities, etc.), or
- A diagnosis of COVID-19 with signs consistent with COVID-19 (e.g., fever, cough, etc.).
- Severity
If a person has an established MDI of COVID-19, determine if the MDI is both severe and meets the duration requirement (DI 22001.001D.2). For CDRs, follow existing policy for severity (DI 28005.015A.6). In addition, a person may develop a new MDI(s) or experience worsening of an existing MDI(s) resulting from COVID-19. Follow existing policy to assess the severity of COVID-19, one or more new MDIs caused by COVID-19, or any other MDI(s) that has worsened because of COVID-19 (DI 24505.001 and DI 24505.005). Reminder, we must develop evidence for any change in severity at each level of appeal.
- Duration
Duration in the disability context refers to the period of time during which a person is continuously unable to engage in substantial gainful activity (SGA) because of one or more MDIs. A person’s MDI(s) must last or be expected to last for a continuous period of at least 12 months unless we expect the MDI(s) to result in death (DI 25505.025D). We measure duration from the first date the MDI(s) prevented SGA through the date the MDI(s) no longer prevented (or is no longer expected to prevent) SGA or ends in death.
If a person’s MDI(s) results in death, the duration requirement is met. Remember, we cannot combine two or more unrelated MDIs to meet the duration requirement (DI 25505.030A.1). However, if COVID-19 causes a new MDI(s) or worsens an existing MDI(s), we consider these MDIs related.
COVID-19 presents initially as an acute illness. If a person recovers from acute COVID-19 with no residual symptoms, limitations, or restrictions, we generally would not expect COVID-19 to meet the duration requirement.
Some people may have symptoms associated with COVID-19 that last for months or even longer after recovery from acute illness. In these cases, COVID-19 may meet the duration requirement when a person develops:
- Long-term effects of COVID-19,
- One or more new MDIs caused by COVID-19, or
- Any existing MDI(s) have worsened because of COVID-19.
