Lessons from a Child’s Asthma SSI Case

When handling children's disability claims, the SSA’s Listing of Impairments (20 C.F.R. Pt. 404, Subpt. P, Appx. 1) is our first checkpoint. But what happens when a child doesn’t quite meet the listing? Mattison ex rel. K.A. v. Astrue from 2013 is a case that reminds us how the SSA evaluates childhood disability.

K.A., a minor with severe asthma, applied for SSI benefits. The ALJ found her condition did not meet the criteria for Listing 103.03 (asthma), despite claims of frequent exacerbations and reliance on medication. Instead, the ALJ applied the functional equivalence test under 20 C.F.R. § 416.926a, which evaluates six domains of functioning (acquiring and using information, attending and completing tasks, interacting and relating with others, moving about and manipulating objects, caring for self, health and physical well-being)

A child is considered disabled if they have a marked limitation in two domains or an extreme limitation in one. Here, the ALJ found a marked impairment only in health and physical well-being, but not in any other domain.

Insights:

✔ K.A.’s FEV1 values (a key measure in asthma cases) exceeded the listing level when on medication. The court emphasized that “impairments that are effectively controlled by medication are not disabling” (citing Warre v. Comm'r of Soc. Sec. Admin., 439 F.3d 1001, 1006 (9th Cir. 2006)).

✔ The claimant argued that additional medical evidence should have been obtained, but the court ruled that the ALJ’s failure to do so was harmless because the new records “did not show a disabling impairment that persisted for a continuous period of at least 12 months” (citing 20 C.F.R. §§ 404.1509, 416.909).

✔ The ALJ acknowledged K.A. had difficulty with physical exertion, but there was no evidence of limitations in gross or fine motor function. The court reasoned that “limitations based on respiratory impairment fall squarely within the domain for health and physical well-being” rather than affecting multiple domains.

✔ The claimant’s school health aide described K.A.'s asthma as debilitating, but school records showed she functioned well in most areas. The court affirmed that “even if the ALJ should have given the health aide's statement greater weight, the error was harmless” because it would not have changed the outcome (citing Molina v. Astrue, 674 F.3d 1104, 1115 (9th Cir. 2012)).

The court denied the child’s SSI benefits and affirmed the ALJ’s decision.

Mattison highlights the uphill battle in child disability cases where medical records don’t quite fit SSA’s strict definitions. As attorneys, we need to think beyond diagnoses and focus on functional limitations across multiple domains.

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