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  • ACOEM Comments to Social Security Administration Regarding ICF

    March 1, 2013

    Office of Regulations
    Social Security Administration
    107 Altmeyer Building
    6401 Security Blvd.
    Baltimore, MD 21235-6401

    Re: Docket No. SSA-2012-0007

    To Whom It May Concern:

    The American College of Occupational and Environmental Medicine (ACOEM) is pleased to respond to the Social Security Administration’s request for comment on the appropriate federal direction on capturing data on functioning. We also will take this opportunity to comment on the use of the WHO ICF as a standard for coding functional capacity.

    ACOEM strongly supports the recording of functional status. In comments submitted to the National Coordinator for Health Information Technology, we said: “ACOEM strongly supports the inclusion of “disability status” in the electronic health record, though we prefer the term Functional Status or Workability. Workability and social functional status is a key ingredient of a healthy and productive nation.”

    ACOEM firmly supports the concept of awarding disability benefits based on function rather than disease or diagnosis. The functional assessment should be based on ability to work as well as the measures of strength, range of motion, etc. ACOEM has long held that this approach is appropriate for workers compensation and return to work, but is also applicable to conditions that are not work-related.

    We strongly support the use of the basic ICF model in the review of SSA procedures. This model is being explored by other countries for its application in disability settings and was the basis for the American Medical Association (AMA) Guides to the Evaluation of Permanent Impairment, 6th Edition.1,2 The ICF model reflects a biopsychosocial approach, which is an integral part of the ACOEM practice guidelines.3

    This approach appears to have contributed to decreasing both disability and medical costs in at least one state workers compensation program. Further research will be necessary to create models based on the ICF sufficient for use in primary care.1 We recommend that if SSA adapts the ICF, that it include the domains of function related to home, work and social functioning, as well as the measurement of behavioral and attitudinal factors, as these are more often more important than medical factors in determining disability risk. Measurement of these ICF domains should help point the way toward rehabilitative services to mitigate or reverse work disability.

    ACOEM wishes to contribute to innovative approaches by SSA. As occupational medicine physicians, we understand the importance of evaluating function, both to assess the effectiveness of medical treatment and determine employability. We are interested in contributing to any research projects focusing on disability and the ICF model.

    ACOEM represents more than 4,000 physicians and other health care professionals specializing in the field of occupational and environmental medicine. ACOEM members are knowledgeable and capable of treating job-related diseases, recognizing and resolving workplace hazards, instituting rehabilitation methods, and providing well-managed care. The occupational physician seeks to mitigate life and work disruption due to illness or injury, whether related to work, lifestyle, genes or aging, and we support the lawful and accurate administration of benefits. Areas of expertise include work disability prevention, management of functional recovery and the stay-at-work/return-to-work process, and evaluation of work ability and impairment.

    Thank you for your consideration of our comments. We are eager to continue a dialogue with the Social Security Administration. Please do not hesitate to contact me or Pat O’Connor, ACOEM’s Director of Government Affairs at 202-223-6222, should you have any questions.

    Sincerely,

    Karl Auerbach, MD, MS, MBA, FACOEM
    President
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    1Albert V, Coutu MF, Durand MJ. (2012) Internal consistency and construct validity of the Revised Illness Perception Questionnaire adapted for work disability following a musculoskeletal disorder. Disability & Rehabilitation, Early Online, 1-9. DOI: 10.3109/09638288.2012.702849.
    2Saltychev M, Kinnunen A, Laimi K. (2013). Vocational rehabilitation evaluation and the International Classification of Functioning, Disability, and Health (ICF).
    3Bruns D, Mueller K, Warren PA. (2012). Biopsychosocial law, health care reform, and the control of medical inflation in Colorado. Rehabilitation Psychology, 57(2), 87-91. DOI: 10.1037/a0028623.