I've been hearing for some time that an NPRM is coming to make changes to the listings for mental impairments. The link from Charles' blog is the first stage in issuing an NPRM. Oddly, the details of the agenda cite the linked 2003 notice, http://edocket.access.gpo.gov/2003/pdf/03-6278.pdf as part of the process of amending the rules, even though the comment period on this advanced notice of an NPRM expired five years ago.
It is safe to assume the proposed changes to the listings are going to create a firestorm.
The linked book was cited in the 2003 advance notice of an NPRM, and may be useful in trying to guess at what will be be in the NPRM when it is published:
http://books.nap.edu/openbook.php?record_id=10295
EDIT: I went back and reviewed some of the book (which I do recommend) I linked above. Assuming that SSA pays heed to the recommendations, there are several changes I would anticipate in the NPRM as it relates to the listings on mental retardation. One of those changes would be an emphasis on composite scores in determining whether the IQ score meets a listing. Another change would be an emphasis on testing instruments to determine deficits in adaptive functioning.
Quote:
Recommendation: Standardized adaptive behavior instruments should be used to determine limitations in adaptive functioning. In general, the cutoff scores for adaptive behavior should be one standard deviation below the mean in two adaptive behavior areas or one and one-half standard deviations below the mean in one adaptive behavior area.
Adaptive behavior measures should be used whenever possible, but only when there is an instrument that matches the client’s characteristics and when an appropriate third-party respondent is available.
A client can be determined to have a significant limitation in adaptive functioning even with scores that do not meet the above criteria IF there is compelling evidence of adaptive behavior deficits that significantly impair performance of expected behaviors.
Recommendation: Revisions should be made in the adaptive behavior areas or domains emphasized in SSA regulations to conform to factor analysis results. The following areas by age should be adopted by SSA:
Infancy/early childhood (approximate ages birth to 4): motor/ mobility, social, communication, daily living skills (self-help).
Childhood (approximate ages 5 to 17): motor/mobility, social, communication/functional academic skills, daily living skills.
Adolescence/adulthood (approximate ages 18 and older): motor/mobility, social, communication/practical cognitive skills, daily living skills, work skills/work-related behaviors.
Current science also suggests that several measures of adaptive behavior tap into these domains. These measures have excellent psychometric properties, with reliabilities of about .90. Also, current measures also evidence strong validity, as described in the chapter. The committee has identified several measures that would be useful in disability determination for mental retardation.
I bought a copy some years back. Not the cheapest book around.
On balance, the book was more interesting for the kinds of debate we engage in here than it was for the often cruder questions that come up in cases. What’s more, at least by my layperson’s reading, the book was almost entirely focused on mental retardationin children. There wasn’t a lot of stuff relevant to adults who manage to accumulate significant work histories.
The book has a section about correlations between IQ scores and adaptive functioning. I don’t have the book at the office any more. But my memory, the book discusses this in terms of “Monte Carlo” statistical trials. Or some such. I was never sure I understood all of this. _________________ I've posted this in my private capacity. What I post might be wrong. Probably, it IS wrong. Any errors are my own. Please don't infer any SSA approval for what I post.
Joined: 13 May 2004 Posts: 1196 Location: Cincinnati OH
Posted: Wed Jun 04, 2008 04:04 pm Post subject:
Here's one reference to Monte Carlo from the book. The reference also indicates why SSA may be very attracted to the idea of requiring proof of deficits in at least two adaptive behavior areas.
Quote:
At the request of the committee, Thompson (2001) ran a series of Monte Carlo simulations to address this effect. She found that the number of adaptive behavior domains on which deficits must be shown had a marked effect on identification rates, with more individuals being identified as having mental retardation if only a single adaptive behavior domain had to meet a defined cutoff score than if two or more domains had to meet a cutoff score. Furthermore, the number of domains on which deficits could be measured had a modest but significant effect on identification rates: more individuals will be diagnosed as having mental retardation if deficits can be found in 1 or 2 out of 9 or 10 domains, than if deficits are found in 1 or 2 of only 4 domains of adaptive behavior. In other words, it is easier to qualify for a diagnosis of mental retardation if there are more domains in which deficits can be shown.
Joined: 13 May 2004 Posts: 25 Location: St. Louis, Missouri
Posted: Thu Jun 19, 2008 02:57 am Post subject:
MikeWalters wrote:
Here's one reference to Monte Carlo from the book. The reference also indicates why SSA may be very attracted to the idea of requiring proof of deficits in at least two adaptive behavior areas.
Quote:
At the request of the committee, Thompson (2001) ran a series of Monte Carlo simulations to address this effect. She found that the number of adaptive behavior domains on which deficits must be shown had a marked effect on identification rates, with more individuals being identified as having mental retardation if only a single adaptive behavior domain had to meet a defined cutoff score than if two or more domains had to meet a cutoff score. Furthermore, the number of domains on which deficits could be measured had a modest but significant effect on identification rates: more individuals will be diagnosed as having mental retardation if deficits can be found in 1 or 2 out of 9 or 10 domains, than if deficits are found in 1 or 2 of only 4 domains of adaptive behavior. In other words, it is easier to qualify for a diagnosis of mental retardation if there are more domains in which deficits can be shown.
Is it just me, or was there really any reason to do "simulations" to figure this out. Does it take science to deduce that more categories to qualify in makes it easier to qualify, or that requiring more criteris to be satisfied makes it less likely? Scientists are strange.
Things are a little more complicated than your post suggests. No, actually things are a lot more complicated than that. The complications that will most likely affect the professional lives of the Connect audience have to do with relationships between tests of cognitive functioning and measures of adaptive functioning. The current listings don't address this in any meaningful way. In the past SSA has largely dodged the question. I will venture a soft prediction that the new NPRM might well say something this, something that's relevant to listing 12.05C.
I've had to hurry these comments. I apologize for not giving page sites.
The National Research Council committee is not recommending any change in criteria for adaptive functioning that would operate to reduce the population of eligible claimants. Rather the opposite:
Quote:
The use of a stringent adaptive behavior cutoff like that used for intellectual functioning would sharply reduce the number of people with IQs below 70 eligible to be considered for a diagnosis of mental retardation. On the basis of the committee’s knowledge of individuals with mental retardation as well as the relevant research literature, this outcome is undesirable.
The thing to keep in mind for this is that the NRC was almost entirely concerned with children. Because there is currently NO regulatory standard for deficits in adaptive functioning for 12.05C ANY standard will be fraught with considerable possibility for change.
So what's this all about? On my layperson's understanding it has to do with correlation—or the lack of correlation—between IQ scores and deficits in adaptive functioning.
The NRC committee claims there is a "broad consensus throughout the developed world" that the basic features for any concept of mental retardation include both intellectual functioning and adaptive behavior. But "cutoff scores for measures of general intellectual functioning are better established than the cutoff scores for measures of adaptive behavior." This is much more a problem at the upper end of the range of mental retardation. Down at the lower end, correlation is tight. In fact:
Quote:
In their review of research, Meyers et al. (1979) found that for young children functioning far below average, the results of intellectual functioning and adaptive behavior measures were nearly identical. In fact, for extremely low levels of functioning on both types of test, nearly the same items are used on measures of adaptive and intellectual functioning, providing a ready explanation for the nearly perfect relationship.
It's at the upper range that the Monte Carlo simulations come in:
Quote:
Monte Carlo simulations, conducted to estimate the probable effects of varying adaptive cutoff scores, yielded results indicating the classification agreement often was rather low using the best of the currently available adaptive behavior measures.
I still can't claim to understand what kind of statistical creature a "Monte Carlo simulation" happens to be. I don't think this ignorance stands in the way of understanding that for the kind of adult claims that are a staple of ODAR adjudication, disputes over deficits in adaptive functioning are common. I think the ALJs are all over the place for this. I think the courts are all over the place for this. And I think the DDS nonexamining consultants tend to be no damn use at all for understanding how to sort out mild mental retardation from borderline intellectual functioning.
I have no idea whether the authors of the NPRM share this opinion. I really don't think that all of 12.05 are going to go away. For a very many cases, the various sections of 12.05 are precisely the sort of administrative convenience that the DDSs need, most especially for SSI child applications.
Beyond this, I have no speculations that I am willing to share just right now. _________________ I've posted this in my private capacity. What I post might be wrong. Probably, it IS wrong. Any errors are my own. Please don't infer any SSA approval for what I post.
You can post new topics in this forum You can reply to topics in this forum You cannot edit your posts in this forum You cannot delete your posts in this forum You cannot vote in polls in this forum
Traverlaw, Traver Law, Traver Law Offices, S.C., Traver & Traver, S.C.,
Traverlaw.com, SSAConnect,
Attorneys for the disabled and disadvantaged in all areas of Social Security
disability law, http://traverlaw.com,
http://ssaconnect.com, Connect, SSA Connect, Think Bigger,
Social Security Advice Connect, Social Security Disability Advice Connect,
"Social Security Disability Advocacy, Debate, and Professional News,"
the yellow and orange swoosh image, and the square favicon.ico image,
are trademarks and service marks of Attorney David F. Traver.
For information the about use of this copyrighted and trademarked material call
262-594-2096.
CONNECT
FAQ
Search
Register
Log in
