HIVMA submitted comments to the Social
Security Administration (SSA) regarding the September 2010
report, “HIV and Disability: Updating the Social Security Listings,”
published by the Institute of Medicine (IOM) in response to a request from the
SSA for guidance on updating the listings covering HIV. HIVMA has been actively
involved in the SSA process to review the medical criteria for evaluating immune
system disorders since the process was initiated in 2003.
HIVMA supports the IOM recommendations, but
urges that the final rule-making include guidance to ensure effective
implementation of the revised disability determination process and to fully
capture individuals who are disabled due to HIV disease.
We strongly agree with the IOM Committee that
any changes to the disability criteria must only be applied to new applicants.
We suggest expanding upon the functional capacity measures to include a
measure for multiple HIV-related hospitalizations in one year as an example of
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