Letter to Hon. Kilolo Kijakazi, Acting Commissioner Social Security Administration - Larson, Davis Urge SSA to Address Long COVID and Request Update

Letter

Dear Acting Commissioner Kijakazi:
We write to request an update on the Social Security Administration's (SSA's) efforts to understand the long-term health effects of COVID-19 (long COVID) and to ensure accurate, timely, and equitable evaluation of SSA disability claims involving long COVID. As outlined in our questions, this update should include information specific to people of color and individuals with pre-existing medical conditions, who have been especially hard-hit by COVID-19.
As our nation enters the pandemic's third year, it is evident that a significant share of patients will experience long-term medical problems even after they recover from an initial COVID-19 infection. Long COVID can impact physical and mental functioning and may include fatigue, difficulty thinking or concentrating, difficulty breathing, heart palpitations, dizziness, and other symptoms. Some patients experience lasting damage to the heart, lungs, kidneys, skin, and brain. Symptoms of long COVID can persist from the initial infection, worsen over time, or even emerge or reoccur months after an initial illness. Researchers still have much to learn about long COVID -- including how to define and diagnose it, what puts people at risk, how symptoms evolve over time, and how to best treat patients -- and the state of science is rapidly evolving.
According to recent news reports, SSA has received about 23,000 disability applications that reference COVID-19 since the start of the pandemic -- a number that will likely grow as COVID- 19 persists. A diagnosis of COVID-19 will not by itself make an individual eligible for Social Security or Supplemental Security Income (SSI) disability benefits. To qualify for SSA disability benefits, individuals must have severe medical impairments that are long-lasting (for a year or
Acting Commissioner Kijakazi March 24, 2022
Page 2
longer) and substantially limit their ability to support themselves through work. As with other complex disorders where there is not a single test or laboratory finding to confirm the presence of a work-limiting impairment, SSA remains obligated to fairly and thoroughly evaluate cases of long COVID by considering all symptoms and evidence of functional impairment.
We are confident that you agree that SSA must be able to determine long COVID claims accurately and in a timely manner. Many individuals with long COVID are struggling to pay for medical bills, keep a roof over their heads, put food on the table, and pay for other basics. If these individuals meet SSA's eligibility standards, timely access to disability benefits can provide invaluable financial support.
SSA should also understand and address the consequences of longstanding and persistent health inequities -- including the impact such inequities may have on COVID-19 outcomes, and how health inequities may create systemic barriers in access to Social Security and SSI benefits. For example, rates of COVID-19 infection have been disproportionately high among people of color, who are also more likely to have underlying health conditions such as diabetes. People of color also disproportionately face barriers to accessing quality medical care, and as a result may find it more difficult to secure the medical documentation needed for SSA to correctly evaluate a disability claim.
We are confident that you share our concerns, and we appreciate SSA's work under your leadership to understand and address long COVID. We are particularly pleased that SSA has acted on our letter of June 25, 2020, in which we urged the agency to work with the National Academies of Sciences, Engineering, and Medicine to monitor emerging medical research on long COVID and evaluate the implications for SSA's disability programs. We also appreciate that SSA is tracking cases where applicants have indicated a prior COVID-19 infection and has issued emergency instructions to staff on evaluating cases with COVID-19.
We write to request information on additional steps SSA is taking to understand long COVID and to ensure proper review of long COVID disability claims. Specifically:
1. Are the news reports that SSA has received approximately 23,000 applications referencing COVID-19, since the start of the pandemic, accurate? How many applications for Social Security, SSI or both has SSA received that reference impairment due to long COVID? How many of these initial applications have been approved or denied, and how many are pending? How many individuals are appealing an initial denial of their claim involving long COVID?
2. What steps has SSA taken to ensure that claims involving long COVID are correctly and fairly evaluated, such as providing guidance and training for examiners and ALJs; conducting case studies and in-depth quality review analyses of long COVID claims; and other quality assurance strategies based on claims received or adjudicated to date? What additional steps is SSA planning?
3. What steps has SSA taken to ensure that claims involving long COVID are processed in a timely manner, and do not take longer to adjudicate compared to overall processing

Acting Commissioner Kijakazi March 24, 2022
Page 3
times? What additional steps is SSA planning?
4. What steps has SSA taken to understand the rapidly evolving medical research on long
COVID, its effects on individuals' capacity for work, and implications for SSA disability determinations? What initial findings, if any, has SSA identified? What additional information is SSA seeking, and how?
5. What steps has SSA taken to understand how racial inequities and other health inequities influence outcomes following a COVID-19 infection, and to identify and remove any related systemic barriers in access to benefits for individuals with long COVID? What initial findings, if any, has SSA identified? What additional information is SSA seeking?
In closing, Social Security and SSI are particularly important for people with pre-existing health conditions, people of color, and many older workers who are more likely to lack savings or private insurance to fall back on if they experience a severe, life-changing disability. We appreciate SSA's work under your leadership to understand and address challenges related to proper evaluation of claims involving long COVID in its disability programs. Please provide the requested information by April 7, 2022.

Source