![](media/image1.wmf)Georgina Huskey, President

12533 Allin Street\
Los Angeles, CA 90066\
310.827.3922

Made4nade@yahoo.com

May 16, 2008

## 

## Commissioner of Social Security

# PO Box 17703

Baltimore, Maryland 21235-7703

Dear Commissioner Astrue:

The National Association of Disability Examiners (NADE) welcomes this
opportunity to offer comments on the Notice of Proposed Rulemaking
(NPRM) that outlined the proposed revisions in the Listing of
Impairments with regard to the evaluation of immune system disorders.

NADE is a professional association whose mission is to advance the art
and science of disability evaluation. Our membership base includes
members that represent a broad perspective of interests regarding the
Social Security and Supplemental Security Income (SSI) disability
programs. While a majority of our members are employed in state
Disability Determination Service (DDS) offices, and are directly
involved in processing claims for Social Security and Supplemental
Security Income (SSI) disability benefits, our membership also includes
personnel from Social Security's Central, Regional, and Field Offices,
attorneys, claimant advocates and physicians. We believe that the
diversity of our membership, combined with our "hands on" experience,
which we believe provides us with a unique understanding of the
challenges and opportunities facing the Social Security and SSI
disability programs today.

SSA proposes to amend the regulations in 20 CFR, Part 404 to revise the
criteria we use to evaluate immune system disorders, found in sections
14.00 and 114.00 of the Listing of Impairments in appendix1 to subpart P
of part 404 of the regulations (the listings). NADE fully supports the
proposed revisions and the need for such revisions, considering the
amount of time that has elapsed since these listings were last updated.

With specific regard to the proposed expansion of the time frame in the
HIV listings for the evaluation of episodic events that would
demonstrate disease severity, NADE believes that consideration should
also be given to a similar expansion of these time frames for other
diseases that have similar episodic events, such as rheumatoid arthritis
and lupus. The same concept of recurrent manifestations of a severe
disease process is present in these impairments also and the evaluation
of similar impairments would benefit from a similar expansion of these
time frames. We believe further expansion of these time frames to other
impairments would permit the DDSs to allow more severely ill claimants
much faster in the process and would preclude the need for numerous
appeals and/or subsequent applications. This would increase the quality
and timeliness of our customer service.

NADE supports the use of clearer language in these revisions. We believe
that language that is clear and precise improves the timeliness and
accuracy of adjudicators in their ability to process these claims.
Throughout the proposed revisions, we noted there were many cosmetic
changes included that reflect updates in medical terminology and/or
updates in the manner in which these claims are, and can be,
adjudicated. Such proposed revisions include the elimination of the
phrase, "must have lasted for 12 months," apparently because the use of
such terminology is redundant and obviously unnecessary; and changing
the term, "Arthritides," throughout the listing to the more commonly
used term, "Arthritis." Other cosmetic changes include minor editorial
changes. NADE supports these changes.

We support the addition of new listings for Sjogren's Syndrome in the
adult listings and Raynaud's Phenomenom is the childhood listings. NADE
also supports additional specific changes in the listings which we
believe will greatly improve the ability of adjudicators to make
accurate and timely decisions on disability claims.

In listing 14.00 F.3.b.(i) CHANGE: "Supportive evidence may include:
fever, dyspnea, hypoxia, CD4 count below 200, and no evidence of
bacterial pneumonia." - TO - "Supportive evidence may include: fever,
progressive exertional dyspnea, tachypnea, tachycardia, nonproductive
cough, chest discomfort, weight loss, chills, hemoptysis, hypoxemia with
an increased alveolar-arterial oxygen gradient, respiratory alkalosis,
impaired diffusing capacity, increased serum LDH level, CD4 count below
200, and no evidence of bacterial or viral pneumonia.

In listing 14.08, Bacterial Infections, NADE supports the expansion of
this list to include the following additional infections: Shigella
bacteremia, recurrent or resistant to treatment; Bartonellosis,
recurrent or resistant to treatment; Shigellosis (bacillary dystentery),
recurrent or resistant to treatment; Salmonellosis, recurrent or
resistant to treatment; Campylobacteriosis, recurrent or resistant to
treatment; Legionellosis, recurrent or resistant to treatment;
Listeriosis, at a site other than the GI tract or lymph nodes;
Clostridium difficile colitis, recurrent or resistant to treatment; and
Bacillary angiomatosis.

In listing 14.08 C, Protozoan or Helminthic Infections, this list can be
expanded to include the following additional infections: Amebiasis,
resistant to treatment; Giardiasis, resistant to treatment, Visceral,
cutaneous or mucocutaneous leishmaniasis; Schistosomiasis;
Opisthorchiasis; Ancylostomiasis, extra-intestinal (e.g., cutaneous
larva migrans); Angiostrongyliasis, extra-intestinal (e.g., cerebral
angiostrongyliasis); Echinococcosis; Cysticerocosis, extra-intestinal,
(e.g., visceral cysticerocosis or neurocysticerocosis; Trichinellosis,
extra-intestinal (e.g., systemic trichinellosis or neurotrichinellosis;
Toxocariasis, extra-intestinal (e.g., visceral larva migrans, or larva
migrans; and Malaria, resistant to treatment.

We appreciate this opportunity to provide comments on this NPRM and look
forward to further discussion involving the vocational aspects of the
Social Security disability program.

Sincerely,

### **Georgina Huskey**

Georgina Huskey