process, inescapably involving some interpretive judgment about capacity for work (GAO, 1994; Hu et al., 1997). At a minimum, making such decisions requires clinical determination of the extent of a claimant’s physical, mental, or sensory impairments; analysis of the degree to which such impairments limit the claimant’s functional capacity relevant to work roles; and consideration of the interaction of the claimant’s physical, mental, or sensory impairments with the person’s age, education, and work experience to provide an overall picture of the claimant’s future capacity for any sort of work. Finally the disability decision process requires a means for comparing those capacities with the capacities demanded by work roles in all jobs in the national economy that provide substantial gainful activity (SGA) earnings level.
While many of the factual determinations are relatively straightforward, others range from the difficult to the nearly impossible. For instance, while measures of visual acuity are reasonably well understood and can be readily translated into sensory limitations, the measurement of pain and its effect on function is much less amenable to objective determination. The real demands of jobs in the national economy are constantly shifting in ways that make straightforward measures of functional capacity problematic guides to a worker’s true capacity for success in the workplace. Therefore, it is impossible to know precisely the extent of imperfection in the determination of disability, as evidenced by the lack of agreement observed in an examination of rater reliability as measured by the variations within and between states in the allowance rates by examiners (Gallicchio and Bye, 1980; DHHS, 1982). SSA has been struggling with these issues for more than 40 years in the face of high volumes of claims for adjudication (millions of claims per year decided by more than 10,000 adjudicators at various levels of the process) and high levels of legal challenge and political oversight.
The standards for evaluating disability claims are specified in SSA’s implementing regulations (20 Code of Federal Regulation, parts 404 and 416, subparts P and I) and in written guidelines. These regulations and guidelines describe a sequential process for determining whether or not a claimant meets the statutory definition of disability.
The purpose of developing the sequential decision process is to provide an operationally efficient definition of disability with a degree of objectivity that can be replicated with uniformity throughout the country. SSA’s overall objective is to adjudicate claims as consistently, expeditiously, and cost-effectively as possible. As described briefly in Chapter 1,