Interstitial Cystitis: New Social Security Ruling (SSR 15-1p)
This SSR replaces SSR 02-2p which was created in 2002 (for those unfamiliar with Social Security Rulings, always look to the first two numbers to determine the year the Ruling became effective)
The new SSR defines Interstitial Cystitis (IC) as “a complex genitourinary disorder involving recurring pain or discomfort in the bladder and pelvic region.” The intent of this SSR was to not merely encompass IC but also “painful bladder syndrome” and “bladder pain syndrome.” The Ruling acknowledges that these disorders often occur more frequently in women than men and co-occur with other disorders such as chronic fatigue syndrome, fibromyalgia, irritable bowel syndrome, vulvodynia, chronic headaches, inflammatory bowel disease, Sjogren’s syndrome, systemic lupus erythematosus, and endometriosis. Like chronic fatigue syndrome, it is diagnosed in part by excluding other illnesses. Among the diagnostics used to exclude other illnesses are: urinalysis, urine culture, cystoscopy, bladder wall and urethra biopsy, distention of the bladder under anesthesia, and culturing of prostate secretions. Treatment may not work for everyone and consists mostly of attempts to control symptoms.
Like chronic fatigue syndrome, which has historically been perceived by SSA adjudicators as failing to meet the requirements for a medically determinable impairment under the regulations, SSR 15-1p (like the CFS Ruling 14-1p (which replaced SSR 99-2p)) was an effort to guide adjudicators to understand when IC or the disorders falling under its umbrella, is indeed a medically determinable impairment (MDI) under the regulations.
Under SSR 15-1p, an IC claimant must provide the following to establish that he/she suffers from a medically determinable impairment:
- Medical information about the IC must be provided by licensed physicians (either an MD or a DO) (But remember that medical sources who are not MDs or DOs can supply medical records and other information to buttress the claimant’s credibility. For example, if the claimant was unaware that the IC related back pain was from IC, and attempted treatment with a chiropractor, those records are considered very helpful despite the fact that chiropractors are not an acceptable medical source under the regulations. The same is true of statements by family and friends of the claimant who can provide statements of the functional limitations and complaints of the claimant that they have witnessed)
- The licensed physician providing the information to SSA must do so after a physical exam, review of the medical records, and following testing to rule out other disorders
- The patient must also have reported symptoms which include the following:
- Urinary frequency and urgency
- Pain in the bladder, pelvis, genitals, thighs or back
- Tenderness on physical exam
- Sexual dysfunction
- Sleep problems including chronic fatigue and tiredness
- Medical signs
- (such as stiffening, pinpoint bleeding or patches of broken skin on the bladder wall following a cystoscopy with bladder distention)
- Urinalysis that shows sterile cultures while symptoms persist
- A positive potassium sensitivity test
- Or accumulation of antiproliferative factor in the urine
Depression or anxiety symptoms secondary to IC must be properly documented to establish an MDI in that regard.
Like SSR 14-1p, the examples provided for signs and symptoms which can be used to establish the existence of an MDI under SSR 15-1p is not intended to be all inclusive. Acceptable medical sources can establish the existence of IC by utilizing other acceptable diagnostic techniques.
And just like all other assessments by SSA, remember to focus on the functional limitations the claimant experiences from IC (and any other medical conditions the claimant suffers from) which prevent her/him from working not simply in the jobs he/she had in the 15 years prior to disability onset, but in any jobs in the national economy.
The claimant must also remember that, like all disability claims, the claimant must establish that the IC (and any other disability suffered) has prevented or will prevent the claimant from working for at least 12 continuous months.
Please call us if you have any questions about pursuing an IC or any other disability case with the Social Security Administration, a Long Term Disability Insurance Company or government disability pension.