Posted: Mon Feb 08, 2010 09:44 pm Post subject: DAA and self-medication
This is the third and possibly the last in series of posts about DAA, following comments about disentanglement and periods of abstinence. It's good to pause at this point to call attention to the disclaimer below. These are private-capacity comments. No one ought to confuse them with official SSA statements.
The abiding theme of the things I have posted about so far—the DAA teletype, POMS, multiple internal memos—is that a determination that DAA is material is possible "only when the evidence establishes" the extent of the limitations that would exist were DAA to stop. When there are co-existing mental impairments, evidence about the level of functioning during periods of abstinence is the obvious candidate for the best basis of disentangling DAA-related limitations. Although as internal SSA instructions have pointed out, even here there can be complications, as for when the periods of abstinence are in the kinds of structured settings (detox, rehab) that might attenuate the non-DAA related symptoms.
The most recent policy statement I can find about all this points out that periods of abstinence are not the only means by which an adjudicator might disentangle. From the same 4/09 policy statement I have been quoting, there is this:
Quote:
If there is no evidence from a period of nonuse, it is sometimes possible to determine whether the person would be disabled if the DAA were to stop; for example, based on medical evidence that shows a worsening of a co-occurring impairment(s) only during periods of acute intoxication, and evidence showing what impairment-related limitations remain after the acute effects of intoxication subside.
I read this to be about this not uncommon situation: ongoing DAA marked by intermittent binges that correlate with symptoms provoking psychiatric admissions, sometimes involuntary. In this circumstance, it is the pattern of correlation that might qualify under the heading of "when the evidence establishes" the extent of limitations were DAA to stop. But even here there are potential complications. So the very next paragraph in the 4/09 memo is this, about self-medication (MC/PC=medical consultant/psychological consultant):
Quote:
We also caution that adjudicators should be careful not to overlook the common situation in which an individual with a serious mental disorder (such as bipolar disorder or schizophrenia) is “self-medicating”. Evidence showing worsening of a co-occurring mental disorder during periods of intoxication may not be demonstrating that DAA is material; rather, it may be demonstrating the frequency with which the person is experiencing exacerbations of the co-occurring mental disorder. There is no clearcut guidance we can give for making this determination. In this case, the MC/PC’s professional knowledge and judgment, together with the specific facts of the case, will be especially important.
_________________ 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.
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