Establishing Eligibility for SSI for Chronically Homeless People. 2. the Challenge of Establishing Supplemental Security Income


To qualify for SSI on the basis of disability, one must be able to document a diagnosis that fits into one of SSA’s medical listings of impairments. Further, a person must have had the condition associated with the diagnosis for at least a year or be anticipated to have it for at least a year (duration). In addition, the condition must meet SSA’s definition of disability, and this is the hardest eligibility criterion to prove. SSA defines a disabled adult as:

“…an individual [age 18 or older] who is unable to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months….”

(42 U.S.C. §1382c(a)(3)(A); 42 U.S.C. §423(d)(1)(A))


“…one must have a severe impairment(s) that makes you unable to do your past relevant work or any other substantial gainful activity that exists in the national economy.”

20 CFR 404.1505(a)

“Disability” is a legal and administrative term rather than a medical one. SSA determines that a person is impaired enough to qualify for benefits based on medical evidence, against the standard that the person is not able to “engage in substantial gainful activity” (i.e., to work and make $1010 or more per month in 2012; $1690 if blind). SSI eligibility is documented by medical records, doctors’ statements based on medical records, and other evidence about a claimant’s impairment(s), restrictions, daily activities, and efforts to work, including statements by the claimant him or herself.

Physical conditions are the easiest to document--if one is a paraplegic, the diagnosis is clear, as is duration. However, disability may still be in question, as many paraplegics work and support themselves.

Most doctors are trained to diagnose and treat the condition but not to consider or document differing levels of functional impairment that might lead SSA to determine that a person cannot work. Having two or more conditions complicates the issue further: individually, neither may cause serious impairment, but their combined impact may be considered an acceptable basis for eligibility.

Mental conditions and impairments are less straightforward than physical conditions, in part because of the inherent difficulties of diagnosing accurately and in part because the conditions themselves are often cyclical, with periods when the person may function well and others when functioning is severely impaired. As described below, substance use conditions raise even more difficult issues. The chronically homeless applicant for SSI typically has multiple health conditions: some form of mental illness, some level of substance use, and some physical ailments or conditions. Therefore he or she has issues with all three criteria: diagnosis, duration, and disability. It can be challenging to document how long a person’s incapacity due to the combination of these conditions has lasted or is expected to last, and to establish disability if no single condition does so definitively.

Documenting impairment is not a simple process for anyone, and being homeless makes it even harder. Homeless people have more problems assembling the documentation needed to complete their applications, and state Disability Determination Services (DDS) have more difficulty reaching homeless people to obtain needed additional information.5 A recent guide to help clinicians assist their patients to apply for SSI describes the problem (Post et al., 2007, p. 2):

Local studies…suggest that homeless disability claimants are denied benefits at significantly higher rates than other claimants, often for failure to negotiate the arduous application process rather than for lack of severe medical impairments that meet SSA disability criteria. A review of disability claims submitted to the Disability Determination Services in Boston from July 2002 to September 2004 revealed that SSI/SSDI denials were 2.3 times more common than approvals for homeless people, while denials for housed claimants were only 1.5 times more common than approvals (O’Connell et al., 2007, footnote 6, p.9). An earlier study by the Homeless Subcommittee of the Massachusetts DDS Advisory Committee had found that over one-third of unsuccessful disability claims submitted by homeless persons (over a nine-month period in 1998-99) were denied for lack of sufficient medical evidence or failure to keep appointments for a consultative examination (Post, 2001, 61).

Before turning to strategies being developed in local communities to help chronically homeless people enroll in SSI, we look briefly at some of the issues just described: obtaining the information needed to establish eligibility, the adequacy of medical records for establishing eligibility, and the issue of disabilities related to drug addiction and alcoholism (DA&A).

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