There are a variety of thyroid disorders, all of which can vary in severity. Like most impairments, Social Security will consider the severity of your thyroid disorder as they evaluate your case.
Social Security has numerous “listings,” or sets of medical criteria, for certain impairments. If someone has an impairment which satisfies the medical criteria, they are presumed to be disabled. Listing 13.09 applies to the thyroid gland, but only covers carcinomas and does not contain any criteria related to other thyroid dysfunction.
Does Thyroid Cancer Qualify for Social Security Benefits?
Many people have experienced concerns regarding thyroid cancer/carcinomas. If a medical professional notes a thyroid nodule during an examination, the professionals can send someone for further testing. This is relatively common. Doctors do this to rule out the possibility that the nodule is a malignant carcinoma. Fortunately, most represent benign disease. Sometimes, however, the nodules can represent a carcinoma. Even if doctors make such a finding, someone is not automatically qualified for disability under Listing 13.09. If the carcinoma is not anaplastic (the relatively rare, most aggressive thyroid cancer) and has not metastasized beyond the regional lymph nodes, a thyroid cancer will be evaluated like other thyroid disorders – Social Security will consider its effects on your "residual functional capacity". Social Security considers someone disabled when their functional capacity does not allow for full-time work.
Social Security Benefits for Hasimoto's Disease
Hashimoto’s disease is considered an auto-immune thyroid condition. The body’s immune system attacks the thyroid gland, leading to inflammation which can result in hypothyroidism (reduced thyroid function). Social Security has listings for several autoimmune disorders in section 14.00 of the listings. There is no specific listing for Hashimoto’s, but if someone seeking disability has this disease, Social Security should consider whether it equals one of the autoimmune listings.
An impairment equals a listing when it creates functional limitations equivalent in severity to the criteria of the listing. For example, the listing for lupus (14.02) provides that someone with lupus should be considered disabled if the disease affects two or more of their body systems, creates fatigue and malaise, and creates “marked” (or particularly severe) difficulty in the performance of daily living activities.
A Social Security judge can only find that someone is disabled because they have an impairment that equals a listing if a medical expert has provided such an opinion. A skilled Social Security representative will know when to request a medical expert so that this kind of opinion can be elicited. This kind of request would be seem to be appropriate in a situation in which someone’s Hashimoto’s disease prevents them from working full-time. Because there is no specific listing for Hashimoto’s, it can only equal another listing. Hashimoto’s can certainly create the fatigue and malaise identified in Listing 14.02. It can also affect multiple body systems. For example, it can affect the musculoskeletal system, causing aches and weakness, or it can affect the mental system, resulting in depression and/or memory loss. If these symptoms significantly interfere with someone’s ability to handle household tasks, care for themselves, leave the home to shop, or carry out other daily living activities, a medical expert may testify that the Hashimoto’s disease equals a listing and a judge would be likely to adopt this opinion to support a finding of disability.
Social Security Benefits for Graves' Disease
Graves’ disease is similar to Hashimoto’s in that it is also an autoimmune thyroid disorder, can affect multiple body systems, and can result in fatigue and malaise which interfere with daily living activities. As opposed to Hashimoto’s, however, Grave’s disease involves an over-production of thyroid hormones, or hyperthyroidism. Nonetheless, because of the similarities between these two diseases, it could also be helpful to seek a medical expert who could offer an opinion as to whether someone’s Graves’ disease equals a listing. However, even if an impairment doesn’t meet or equal a listing, Social Security should consider someone’s impairments and whether they allow for full-time work. If not, they should be considered disabled. As an example of how this process works, we can consider Graves’ disease.
Graves’ disease can result in multiple symptoms, each of which should be accounted for as the judge prepares a finding regarding someone’s Residual Functional Capacity or RFC. This is the important conclusion a judge reaches about the most someone can do in spite of their impairments. Graves’ disease can cause anxiety and irritability which would warrant limitations in the extent to which someone could perform work with high stress levels or engage in interaction with the general public. The disease can cause hand tremors which limit how much fine and gross manipulation someone can do. Heat sensitivity and an increase in perspiration are signs of Graves’ disease; these symptoms support including environmental limitations in the RFC, such as a need to avoid concentrated exposure to extreme heat and humidity. Sometimes Graves’ sufferers have a need for frequent bowel movements. This symptom supports a conclusion that someone may need to be near a bathroom and/or have elective bathroom access. A judge considering a Social Security case will consider the combined effects of someone’s limitations and determine if there is any work available to someone with all of the limitations. If not, the person should be considered disabled.
Social Security Benefits for Hyperthyrodism
Hypothyroidism—whether caused by an autoimmune response, atrophy of the thyroid gland, or something else which may not even be specified in the medical records—is a common condition and frequently appears in the medical file of someone seeking disability. Like diabetes, hypothyroidism in an endocrine disorder and therefore should be considered like diabetes when listings are considered. The listing for diabetes indicates that the effect of the diabetes on the body’s other systems should be considered, with an analysis of the relevant listings for these other systems. For example, if someone’s diabetes caused kidney disease, the kidney dysfunction should be evaluated under Listing 6.03. By analogy, if someone experienced extremely low thyroid levels which resulted in heart failure, the residual cardiovascular dysfunction could be considered under Listing 4.02, for chronic heart failure. After the listing analysis, hypothyroidism should be considered like any other impairment: the limitations caused by it should be included in the RFC, and the judge should compare this with the requirements of work to make the ultimate decision in the case.
Our Social Security Attorneys Can Help Your Claim
While thyroid disorders can be treatable, they cause or correlate with other health problems which can be very problematic. Whether a thyroid disorder is the primary cause of your limitations or one of many, you are welcome to call the Social Security attorneys of Keller & Keller to discuss your situation.
