Sjögren’s Syndrome

Sjögren’s syndrome is set out in Listing 14.10 of the Listing of Impairments. Sjögren’s syndrome was identified in 1933 by Henrik Sjogren, an ophthalmologist from Sweden. Sjögren’s is an autoimmune disease which mainly affects the tear gland (the lacrimal gland) and the saliva gland (the salivary gland). The most common symptoms of Sjögren’s include dry eye and dry mouth. Fatigue or pain with swelling of the joints are also common symptoms. At times other symptoms may arise such as difficulty swallowing (dysphagia); eye damage; dental issues and difficulty speaking for long periods of time. The normal victims of Sjögren’s syndrome are women in their 50s and 60s.

A diagnosis of Sjögren’s is made by lab and eye tests together with preforming a physical examination and taking a medical history. Sjögren’s may be either primary (meaning that there are no other autoimmune disorders present) or secondary (meaning that there are additional autoimmune disorders present).

To qualify for Social Security disability under Listing 14.10, the person who has been diagnosed with Sjögren’s must prove that the Sjögren’s is involved with 2 or more body systems or organs. (The organ systems in the body include: integumentary, muscular, skeletal, nervous, circulatory, lymphatic, respiratory, endocrine, urinary/excretory, reproductive and digestive.) Only one body system needs to be impacted to at least a moderate degree. In addition, the Sjögren’s must cause 2 or more of the following symptoms: severe fatigue, loss of weight, malaise or fever.

What if there are not 2 or more body systems involved with the Sjögren’s? Listing 14.10 does provide an alternate method to meet the Listing 14.10. That alternate method still requires that at least 2 symptoms (such as severe fatigue, loss of weight, malaise or fever) be present. The signs of the Sjögren’s must be recurrent. In addition, there must be present at a marked level one of the following: limitations of daily activities; limitations regarding social functioning and/or limitations in either completing tasks in a timely manner or problems with persistence, concentration or pace. (The term “marked limitation” has a special meaning in Social Security disability cases. It is understood to mean that the limitation “seriously” impacts functioning. Unfortunately, the term “seriously” is not defined. Whether the limitation has a serious impact is a medical judgment.)

In my experience, a “marked limitation” is difficult to prove. Many clients who have been diagnosed with Sjögren’s syndrome normally have the syndrome with other autoimmune issues such as lupus or rheumatoid arthritis. My clients usually have Sjögren’s syndrome which involves at least 2 body or organs.

Even if a person with Sjögren’s syndrome does not meet or equal Listing 14.10, it is still possible for that person to be awarded Social Security disability by showing how the effects of the Sjögren’s limit the abilities of the person to perform his or her past relevant work (work which was performed in the past 15 years). The person must also show how the Sjögren’s has limited the person’s abilities to do any other work in the national economy.

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