The Role of the Global Assessment of Functioning Score in Social Security Disability Cases - Dawdy v. Astrue
In a recent post, we explained a Social Security case in New York City in which the reviewing court looked at a disability claimant's Global Assessment of Functioning (GAF) score in part to determine the severity of the claimant's mental impairment. It's easy to lose sight of this tool in a shed full of strange sounding Social Security acronyms - ALJ, VE, RFC, etc. - but, for claimants seeking to prove they are eligible for disability benefits due to a mental impairment, the GAF score can make or break a claim. So, what exactly is GAF and what's all the hubbub about? The District Court for the Northern District of Iowa explains in Dawdy v. Astrue.
Plaintiff Robert Dawdy filed a claim for Social Security disability benefits, asserting that he's unable to work due to seizures and an unidentified mental impairment. Plaintiff, who holds a general equivalency diploma (GED) and previously worked as a restaurant cook and telephone solicitor, appeared at an administrative hearing before an SSA Administrative Law Judge (ALJ) after the SSA initially denied his claim. The ALJ found that Plaintiff is not disabled for benefits purposes because he can still perform certain jobs available in the national economy. The SSA's Appeals Council denied Plaintiff's request that it review the ALJ's decision.
On appeal, however, a District Court magistrate recommended that the court reverse the ALJ's decision and remand the case for further proceedings. Specifically, the magistrate found that the ALJ neglected to take Plaintiff's GAF score into account in considering his claim and that this error alone was sufficient to justify reversal.
In adopting the magistrate's recommendation, the court explained that a GAF score rates a person's psychological, social and occupational functioning based on a scale divided into ten ranges of functioning. The psychologist scored Plaintiff's GAF at 45, a rating that indicates "serious symptoms or any serious impairment in social, occupational or school functioning." Furthermore, a vocational expert (VE), a vocation rehabilitation professional that provides advice to an ALJ regarding a claimant's ability to perform any type of work activity, testified at the hearing that a person with a GAF score of 45 would not be able to sustain employment.
Nevertheless, according to the court, the ALJ failed to address this evidence in rendering her decision. "The ALJ is not free to ignore medical evidence but rather must consider the whole record," the court noted. As a result, it reversed the ALJ's decision and remanded the case for further proceedings.