On 9/26/16, the Social Security Administration (SSA) released a revision to their public rules that goes into effect 1/17/17. In this revision, SSA clarifies that counselors and social workers are qualified to provide diagnostic records to SSA related to disability cases. These additions and revisions include:
(1) SSA rejected comments from medical organizations that sought to clarify that counselors, social workers, and other non-physician healthcare providers should not be able to provide diagnostic records for disability. SSA clarified, "We did not adopt the recommendations. Our recognition of non-physician health care providers as other medical sources of evidence is not a new rule; see §§ 404.1513(d) and 416.913(d). The list of these other medical sources in our regulations is not all-inclusive, and our mention of licensed clinical social workers and clinical mental health counselors in final 12.00C2 is appropriate, given their roles in the treatment of people with mental disorders in both private and public settings. We believe that these other medical professionals—because they typically see patients regularly—are important sources of the evidence we need to assess the severity of a person’s mental disorder and the resulting limitations in the person’s mental disorder and the resulting limitations in the person’s functioning" (p. 66142).
(2) SSA clarified that social workers and counselors can provide diagnostic records relevant to mental disorders:
"Evidence from medical sources. We will consider all relevant medical evidence about your disorder from your physician, psychologist, and other medical sources, which include health care providers such as physician assistants, psychiatric nurse practitioners, licensed clinical social workers, and clinical mental health counselors. Evidence from your medical sources may include:
a. Your reported symptoms.
b. Your medical, psychiatric, and psychological history.
c. The results of physical or mental status examinations, structured clinical interviews, psychiatric or psychological rating scales, measures of adaptive functioning, or other clinical findings.
d. Psychological testing, imaging results, or other laboratory findings.
e. Your diagnosis.
f. The type, dosage, and beneficial effects of medications you take.
g. The type, frequency, duration, and beneficial effects of therapy you receive.
h. Side effects of medication or other treatment that limit your ability to function.
i. Your clinical course, including changes in your medication, therapy, or other treatment, and the time required for therapeutic effectiveness.
j. Observations and descriptions of how you function during examinations or therapy.
k. Information about sensory, motor, or speech abnormalities, or about your cultural background (for example, language or customs) that may affect an evaluation of your mental disorder.
l. The expected duration of your symptoms and signs and their effects on your functioning, both currently and in the future.
A statement from the American Mental Health Counselors Association focused on the ability of mental health counselors to test for and diagnose intellectual disorders: "The ability to diagnosis someone with an intellectual disability (IQ, learning etc.) is within the purview of a licensed clinical mental health counselor, if they may administer intellectual aptitude exams. Manyclinical mental health counselors have been trained or can be trained to administer and interpret such exams, as it is usually a course of psychological tests and assessments specific to clinical mental health counseling. Ethically, it is incumbent upon a licensed professional who administers the test that he or she is trained and received supervision in their use."
