SSR 19-4p Social Security Ruling on Headache Disorders

  • Regulation No. : SSR 19-4p

  • Tags : headaches, headache disorders, migraine, cluster headaches, tension headaches, epilepsy

  • Key Takeaways : Headache disorders are not listed in the SSA Impairment Listing but can be recognized by the SSA as a medically determinable impairment (MDI); only primary headache disorders can be considered an MDI and not headache disorders with a separate underlying cause; comparisons to disorders with similar symptoms can be considered when determining whether a primary headache disorder impedes a person's residual functional capacity (RFC).

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The Social Security Administration (SSA) recognizes the condition of primary headache disorders and that they can be considered a medically determinable impairment for the purposes of collecting Social Security Disability Insurance (SSDI). The SSA issued Social Security Regulation SSR 19-4p to show how claims for primary headache disorders are evaluated by the Agency. The regulation also details how primary headache disorders can be established as a medically determinable impairment (MDI) which could qualify a person for disability benefits.

This regulation relies on the International Classification of Headache Disorders 3rd Edition (ICHD-3) released by the Headache Classification Committee of the International Headache Society. The SSA uses these guidelines to make a determination whether the headache disorder can be considered a disability that limits a person’s ability to engage in basic work activities. The SSA will not make a finding of disability based on reported symptoms alone. To evaluate the claim for a headache disorder the regulation sets up an analysis that is in a format of 9 questions and answers.

The first question lays out a definition of common primary headaches including include migraines, tension-type headaches, and trigeminal autonomic cephalalgias, otherwise known as cluster headaches. Question 2 asks how the medical community diagnoses primary headache disorders, part of which includes ruling out other possible causes of the headaches. To determine a primary headache disorder the physician will consider an individual's full medical and headache history as well as conducting a physical and neurological exam. This may include imaging scans such as MRIs and CTs but they are not required for a diagnosis of primary headache disorder.

Questions 3 and 4 discuss the criteria for diagnosing migraine headaches. They lay out the symptoms for the condition which includes the degree of severity and how long the symptoms last. This includes migraines with an aura which may have symptoms temporarily affecting vision or speech. Migraines without an aura can include symptoms such as nausea or sensitivity to light.

The criteria for chronic tension headaches are discussed in Question 5 in which the symptoms occur 15 days out of the month for a period of at least 3 months. In some cases the symptoms last days at a time. Among the criteria for a determination of chronic tension headache symptoms are pain that can be mild to moderate in intensity and a pressing or tightening feeling as opposed to a pulsing feeling. The pain in chronic tension headaches is not affected by routine physical activities and also may include symptoms such a nausea and sensitivity to light.

Question 6 is regarding trigeminal autonomic cephalalgias (cluster headaches). The symptoms can be severe to very severe in intensity and may include agitation or restlessness. The pain can last from 15 minutes up to 3 hours. Other symptoms would include some of the following: conjunctivitis (red eye), nasal congestion, puffy eyes, or facial sweating, drooping eyelids, or constricted pupils.

Question 7 discusses how only primary headache disorders can be considered a medically determinable impairment (MDI). Secondary headache disorders that are a result of another underlying condition can not qualify as an MDI for a headache disorder. This is not to say that the underlying or causative issues would not be considered an MDI, but it would be for those conditions in and of themselves if they meet the criteria. The evaluation for primary headache disorders include a medical physician's diagnosis, observation of an occurrence by a medical professional, lab tests, and how the patient responds to treatment.

Question 8 addresses the fact that while primary headache disorder is not listed in the SSA's Listing of Impairments, the condition alone or combined with another condition can equal a listing and qualify an individual for SSDI benefits. The condition most closely related is epilepsy. The severity and duration of the primary headache condition are compared to an epilepsy diagnosis including the symptoms, severity of the events, frequency the of the events, and how the symptoms limit or interfere with an individual's daily activities.

Lastly, Question 9 addresses instances in which the a person's primary headache disorder, alone or in combination with another condition, does not equal a listing for an MDI. In these cases, the SSA can still consider the person's residual functional capacity (RFC). The RFC is the most a person can be expected to do given an impairment and the symptoms. The SSA will look at the person's particular symptoms of a primary headache disorder, using photophobia (sensitivity to light) as an example, and how the severity, frequency, and duration could impede a person's to ability to sustain attention and concentration. Such evidentiary considerations can be used in determining an individual's ability to engage in gainful activity.

If you are experience frequent headaches that make it difficult to perform on the job or even cause you to miss work, it is recommended that you see a doctor right away. And while medical treatment is the most immediate concern, if your headaches are interfering with your ability to make a living, you may want to consider filing for SSDI benefits. The process of applying for benefits can be complicated and time consuming so in such cases, it would also be recommended that you contact a lawyer experienced with disability benefits.