Public Comments of the National Association of Social Workers To the Social Security Administration

October 3, 2006

The National Association of Social Workers (NASW) is pleased to submit comments to the Social Security Administration (SSA) regarding its revised rules for Medical Criteria for Evaluating Immune System Disorders. Founded in 1955, NASW seeks to enhance the well-being of individuals, families and communities through its work and advocacy. 
NASW has long advocated for the client’s rights, self-determination and client-centered care. We applaud the efforts to update the listings of immune system disorder disabilities. 

It is estimated that one in three people will, at some point during their lives, acquire a disability.   Disabilities vary widely and include physical, sensory, and cognitive impairments, as well as mental, physical and chronic illness.   The proposed guidelines are a step in the right direction in redefining disability. As you know, as Americans age and as new research leads to medical discoveries, there are more disorders that can lead to disability, more treatments that can result in debilitating impairments, and a greater likelihood that people will live longer with disability. Therefore, NASW strongly advocates for the inclusion of fatigue, pain and other functional impairment language in the proposed rules. 

It is important to note that disease and function have a cumulative effect on disability. 
Social Work Speaks, the preeminent document for social work policy and practice decisions, states that NASW supports comprehensive services delivery systems based on a case management model that includes access to suitable and affordable housing and health care, adult and child foster care, home health care, nursing home care, legal services and transportation. An individual’s major life activities include functions such as caring for one’s self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, working, and participating in community activities.  Immune System Disorders can have a profound and lasting impact on functional impairment. Therefore, it is our recommendation that the SSA think in the broadest possible terms when defining the guidelines and resources necessary to ensure that client/patient self-determination and autonomy is at the core of all definitions or service expansions to the current SSA regulations.

Again, thank you for this opportunity to comment on behalf of our 150,000 social worker members and those we serve in the disability community.