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Social Security Re-Opens Comment Period on Changes to the Mental Impairment Listings

December 2, 2010

Last week, the Social Security Administration (SSA) announced that it is taking additional comments (through December 9, 2010) on its proposed rules revising the “Mental Impairment Listings” that are used to assess eligibility for disability benefits (both SSI and SSDI).  This shift was due to the large volume of comments the agency received from mental health advocates regarding the role of standardized tests that claims adjudicators can use to assess work-related impairments.  NAMI raised concerns about this issue in comments submitted to SSA last month.  Click here to view NAMI’s comments. In the announcement from SSA re-opening the comment period, SSA made several important clarifications about the scope of the proposed changes to the Mental Impairment Listings: 

  1. That standardized tests are not required as part of a claim for SSI or SSDI eligibility and all claimants are allowed to base their claim for benefits based solely on medical evidence, and
  2. That such tests will not be imposed on current SSI and SSDI beneficiaries that qualified under the current listings as part of a “Continuing Disability Review”.

You can view the SSA announcement at:

Take Action

With the comment period re-opened, NAMI will be submitting additional comments to Social Security.  If advocates wish to submit their own supplemental comments, they are encouraged to do so.  NAMI has developed the following model comments.

Comments can be submitted by fax at 410-966-2830 or on-line at

Make sure you reference Docket No. SSA-2007-0101 in submitting your comments.

Related Files

NAMI's Additional Comments to the SSA on Mental Impairment Listings (Word Document)