As we announced in
September, the Social Security Administration (SSA) invited comments on proposed changes to how they evaluate medical evidence, including adding Advanced Practice Registered Nurses (APRNs) as acceptable medical sources. We are excited to announce that SSA published the
Final Rule in the Federal Register this morning,
which will go into effect for any applications filed on or after March 27, 2017.
What key information do I need to know about the changes?
1. SSA will include APRNs, Physician Assistants, and audiologists as acceptable medical sources (AMS), which means that medical evidence from these sources can be used to establish a medically determinable physical or mental impairment.
(Step 2 of the sequential evaluation!)
a. The APRN category includes four types of medical sources: Certified Nurse Midwife, Nurse Practitioner, Certified Registered Nurse Anesthetist, and Clinical Nurse Specialist.
b. SSA received comments about adding Licensed Clinical Social Workers (LCSWs) as AMS, but will not be including them in this rule as SSA is still investigating national consistency in licensing requirements.
2. Medical Summary Reports that are co-signed by an AMS and discuss an applicant's limitations in functioning will be considered a "medical opinion."
a. The DDS adjudicator will still review and consider MSRs that are not co-signed by an AMS; however, adjudicators only need to provide an explanation about their decision for medical evidence and medical opinions that come from AMS and non-AMS medical sources.
3. SSA will be removing the current "treating source" rule, which gives more weight to evidence from AMS providers who have an ongoing treatment relationship with the applicant.
a. This change recognizes that individuals often receive treatment from multiple providers and that many primary treatment providers do not meet the criteria for an AMS.
b. SSA emphasizes that the two most important factors for determining the persuasiveness of medical opinions are consistency and supportability in the records.
c. The new rules focus more on the content of medical opinions and less on weighing treating relationships against each other, so there will not be a hierarchy or "controlling weight" in consideration of evidence from medical sources.
What next steps should we be taking?
1. Remember that these rules will only be applied to applications filed on or after March 27, 2017.
2. Reach out to APRNs and Physician Assistants in your community who are providing treatment to individuals experiencing homelessness to bring them into your SOAR efforts! Talk with them about the disability process, your role, and how they can help by providing evaluations and signing Medical Summary Reports.
3. Continue your great work in utilizing the SOAR model to help end homelessness!
If you have questions on this, please contact Jen Elder, National Policy and Partnerships Coordinator, at jelder@prainc.com.
