PUBLIC SUBMISSION

As of: February 15, 2009
Tracking No. 8070f9f4
Comments Due: October 14, 2008

Docket: SSA-2008-0016
Revised Medical Criteria for Evaluating Hearing Loss

Comment On: SSA-2008-0016-0001
Revised Medical Criteria for Evaluating Hearing Loss

Document: SSA-2008-0016-0002
Comment from Page, Sue , Maryland Disability Determination Services


Submitter Information

Name: Sue  Page
Address:

MN, 

Organization: Maryland Disability Determination Services
Government Agency Type: State

General Comment

The proposed revisions to SSA hearing listings better reflect current medical
terminology, practices, and treatment. Particularly noteworthy are the evaluation
criteria for cochlear implants and the elimination of the requirement to use hearing
aids for audiometric testing. Additionally, the proposed revisions for evaluating
hearing impairments in children are much more realistic than the current listings.

Below are some specific comments/questions:

1. The section on word recognition for persons not fluent in English is good in
theory, but it may be difficult provide the testing in practice.

2. The section that discusses the timing of the otologic examination and the
audiometric testing is unclear. The beginning segment indicates that they should
be done within two months of each other. Later reference indicates that once there
is a MDI, a repeat otologic examination is not necessary.

3.The requirement for an otoscopic exam within two months of audiometric testing
is appropriate if the DDS is purchasing a consultative examination. How will this
apply, however, to medical evidence of record - will audiometrics be acceptable
without a recent otoscopic exam?

4. The comment referring to redesignating current listing 2.00B2 for vertigo
associated disorders and loss of speech, because these conditions are not
always associated with a hearing loss, could be better defined and enhanced to
provide clearer guidance.

Thank you for the opportunity to provide comments.