Headaches can be very debilitating and even prevent a person from working full-time. As debilitating as headaches can be, it is difficult to prove to the Social Security Administration (“SSA”) that they make you disabled because there is no way to objectively measure how severe your headaches are or even that you have them. In 2019, SSA issued Social Security Ruling 19-4p (“Ruling) to clarify how headaches should be evaluated.
What kind of headaches does this Ruling apply to?
First, the Ruling applies to primary headache disorders. Primary headache disorders are migraines, tension headaches, or trigeminal neuralgia. They are called primary headache disorders because there is no underlying disease or injury causing the headache. There are also secondary headaches disorders. A secondary headache disorder is a headache that is the symptom of another condition like a neck injury or sinus issues. If you have a secondary headache disorder, this Ruling still provides some guidance, but they are not the main focus of this Ruling. It is also possible to have both primary and secondary headaches.
How can I show a diagnosis of a primary headache disorder?
For SSA to consider your headaches a primary headache disorder, they must be diagnosed by a medical provider who has reviewed your medical and headache history. This should include a review of your specific headache symptoms. Your provider may perform a physical and neurological examination. Often with headache disorders, testing such as an MRI or a CT scan of the head is done to see if your headaches are the result of another condition. Even if these tests are negative, they are still important because they rule out other causes for your headaches. The Ruling makes clear that positive imaging is not necessary to diagnose a primary headache disorder. It is important that the treatment notes from your provider are consistent with a primary headache disorder, so they should contain not only your report of symptoms, but any pain behaviors your medical provider may have observed such as difficulty concentrating, need for a dark room, neck stiffness, or tremors. Also, while not required, your case will be stronger if you headaches are evaluated and treated by a specialist such as a neurologist.
How can I show the severity of a primary headache disorder?
Your medical records need to document any symptoms such as difficulty concentrating, light sensitivity, sound sensitivity, or nausea that accompany your headaches. SSA will also want to understand how often you have headaches, how long they last, and how they affect your ability to perform work-related limitations. Particularly with headaches, work-related limitations may include absences from work, difficulty maintaining a schedule, or difficulty focusing and concentrating. We also need to understand if you have sensitivities to noise or light that may make it difficult to work in some environments. It is important that you discuss any limitations related to your headaches not only in your statements to SSA, but also in discussions with your medial provider. A headache journal that documents all of this information can be very helpful, especially if it is shared with your doctor.
When describing your headaches to SSA it is important to discuss issues such as headache frequency, accompanying symptoms, and how long it takes you to recover from a headache. SSA also wants to know what medications you have tried or are currently using for your headaches. Treatment notes should show if these medications are effective or not. They should also show if you have any side-effects from the medications. SSA will consider if your headaches improve with medication or if there are reasons you cannot use medications or follow-through with recommended treatment. Consistency and supportability between your reported headache symptoms and the medical evidence will be key in SSA’s evaluation of your claim.
What can I do right now?
- Keep a headache diary. This allows you to help the Agency understand how often you experience headaches, what kind of symptoms your headaches cause, and how long it takes you to recover. A headache diary allows you to also document any activities you had to miss due to your headaches.
- Communicate with your provider as to the frequency and severity of your headaches. As is discussed above, SSA will not simply take your word for the frequency and severity of your headaches. They also want to see this reflected in the medical record. Make your doctor aware of not only the frequency of your headaches, but also your accompanying symptoms, and any reactions to medications.
- Stay compliant with medication and treatment. If you are not willing to take medications or otherwise comply with your provider’s recommended treatment for your headaches, please let us know why. A failure to follow through with recommended treatment can be seen as an indication that your headaches are not as severe as you say. We want to make sure SSA understands your specific situation.
- If possible, undergo any testing recommended by your provider. As discussed above, SSA will be looking to see if your headaches are actually due to other conditions. Always let us know if you are unable to undergo any recommended testing due to issues such as finances.
Remember not everyone experiences headaches the same way or has the same symptoms, it is important for us to help SSA understand the specific way you are affected by your headaches. SSR 19-4p, helps clarify how a disability claim that includes headaches should be evaluated.