TN 6 (07-23)

DI 25230.010 Section II, Functional Equivalence

A. Procedure - introduction

Complete Section II in every case in which functional equivalence is at issue; e.g., the child's impairment or combination of impairments is severe and does not meet or medically equal the listings, unless one of the examples in DI 25225.060 applies.

NOTE: A duration denial (Disposition 6) cannot be made without consideration of functional equivalence.

The adjudication team must consider all relevant factors and evidence in the case record as discussed in DI 25210.001 and outlined in Section IC of the SSA-538. Consider the following questions about whether the child's activities are typical of other children the same age who do not have impairment(s) and if a medically determinable impairment(s) affects their ability to function:

  • What activities is the child able to perform?

  • What activities is the child not able to perform?

  • Which of the child's activities are limited or restricted compared to other children the same age who do not have impairments?

  • Where does the child have difficulty with activities at home, in childcare, at school, or in the community?

  • Does the child have difficulty independently initiating, sustaining, or completing activities?

  • What kind of help does the child need to do activities, how much help is needed, and how often is it needed?

Written answers for each of these questions are not required. But it is necessary to know the answers to get a clear picture of the child's functioning and to evaluate their limitations. If a child has more than one impairment, no one of which is “severe,” or no one of which meets, medically equals, or functionally equals the listings, look comprehensively at the interactive and cumulative effects of all of the child's impairments on their day-to-day functioning, see DI 25225.010.

Look first at the child's activities and whether they are limited or restricted in any way. When assessing the child's functional limitations, decide which domains are affected by the child's impairment(s). Any activity may involve the integrated use of many abilities and skills. And limitations in one area may affect the child's functioning in other areas. Therefore, any single limitation may be the result of the interactive and cumulative effects of one or more impairments, while any given impairment may have effects in more than one domain. Thus, it is important to assess the limitations due to single or multiple impairments in all affected domains.

B. Procedure – IIA. Domain evaluations

In Section IIA, describe and evaluate the child's functioning in each of the six domains, explaining how evidence in the case record was evaluated. Consider the medical findings and opinions from the child's treating and other medical sources about the child's limitations and restrictions. Identify the signs, symptoms, and laboratory findings pertinent to the child"s impairment(s), including relevant test results, clinician interpretations, and informed professional observations. Include information from the child's parents, teachers, caregivers, school personnel, and others who reported on the child's day-to-day functioning at home, in childcare, at school, and in the community to determine how the child's functioning is affected during all of their activities. Identify the kinds of treatment the child receives and how it affects their functioning. The 6 domains and the activities to be considered in each domain are. For full descriptions of the domains, see DI 25225.025:

  • Acquiring and Using Information – How well the child acquires or learns information, and how well the child uses the learned information

  • Attending and Completing Tasks – How well the child is able to focus and maintain attention, and begin, carry through, and finish activities, including the pace at which the child performs activities and the ease in changing activities

  • Interacting and Relating with Others – How well the child initiates and sustains emotional connections with others, develops and uses the language of their community, cooperates with others, complies with rules, responds to criticism, and respects and takes care of the possessions of others

  • Moving About and Manipulating Objects – How the child moves their body from one place to another and how the child manipulates things (also referred to as gross and fine motor skills)

  • Caring for Yourself – How well the child maintains a healthy emotional and physical state, including getting physical and emotional wants and needs met in appropriate ways; how the child copes with stress and changes in the environment; and whether the child cares for own health, possessions, and living area

  • Health and Physical Well-Being – The cumulative physical effects of physical or mental impairments and their associated treatments or therapies on the child's functioning not considered in the Moving about and Manipulating Objects domain

When a child has more than one impairment, more than one specialist may evaluate aspects of the child's functioning, although one consultant must take overall responsibility for the findings as a whole. The evaluation by each consultant should be entered and clearly identified in Section II. Check only one box in each domain that describes the child's overall degree of functional limitation.

C. Procedure - IIB Conclusion

Complete the first box in Section IIB if the child has marked limitations in two domains or the second box if the child has an extreme limitation in one domain to indicate that the child's impairment functionally equals the listings. The definitions of “marked” and “extreme” are fully outlined on the SSA-538. For the complete definitions and related material, particularly a discussion of how we consider test scores, see DI 25225.020.

If the child's impairment or combination of impairments does not functionally equal the listings, check the third box.

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DI 25230.010 - Section II, Functional Equivalence - 07/27/2023
Batch run: 07/27/2023