3.6.3.05 Guidelines to the Rules for Applying the Impairment Tables
This topic provides guidance on the Social Security (Tables for the Assessment of Work-related Impairment for Disability Support Pension) Determination 2011 (the Determination) Part 2 which sets out rules that are to be complied with in applying the Tables. This topic has headings emphasising significant principles and concepts underpinning provisions contained in that part of the Determination. It also provides guidance on the concepts and practical application of the DSP eligibility criteria contained in the SSAct.
This topic does not restate the definitions contained in Part 1 of the Determination. These definitions should be accessed directly from the Determination.
This topic covers:
Act reference: Social Security (Tables for the Assessment of Work-related Impairment for Disability Support Pension) Determination 2011 Part 1 - Preliminary, Part 2 - Rules for applying the Impairment Tables
(A) Purpose & design of the Tables
Unless otherwise authorised by law, the Tables are used to determine whether a person whose qualification for DSP is being considered, meets a qualifying impairment threshold stipulated in the SSAct. This determination is made by assessing the level of functional impact of a person's impairment and assigning an impairment rating corresponding to the identified level of impact.
To qualify for DSP, a person must have, among other things, a physical, intellectual or psychiatric impairment assessed as attracting an impairment rating of 20 points or more under the Tables.
A person must also have a CITW - that is the person must be unable, because of the impairment, to do any work of at least 15 hours per week independently of a POS in the next 2 years, or be re-skilled for such work within the next 2 years. To meet the CITW requirements, a person whose impairment is not severe, must have also participated in a POS.
Impairment & continuing inability to work
The determination of an impairment rating and the assessment of CITW are 2 distinct assessments based on 2 different DSP qualification criteria. When assessing qualification for DSP, the requirement for the person to have an impairment rating of at least 20 points under the Tables and the requirement that the person has a CITW, are of equal importance.
Note: For DSP qualification, both the minimum qualifying impairment threshold of 20 points and CITW criteria must be met and are of equal importance.
Achieving an impairment rating of least 20 points does not mean that the person qualifies for DSP but merely indicates that the impairment-related qualification criterion has been satisfied.
Achieving this rating does not mean the person will be unable to do any work of at least 15 hours per week in the next 2 years, either. What it does mean is that the person's impairment may have a significant functional impact in many work situations but depending on the person's individual circumstances, coping mechanisms and reasonable adjustments, that person may still be able to do work.
Example 1: A person is assessed as having an impairment rating of 20 points under Table 14 - Functions of the Skin because they have severe difficulties performing tasks involving exposure to sunlight due to heightened sensitivity resulting from extensive skin grafts to their upper limbs. Also, the person is not able to wear clothing required in their workplace because of sensitivity of their hands, such as protective gloves. While this person must avoid exposure to sunlight and cannot wear gloves or other protective equipment on their hands, they may be able to do work that does not involve such exposure or protective equipment. For instance, the person may be able to perform clerical tasks and have their desk placed away from the windows.
Example 2: A person has sustained brain and spinal injuries in a motor vehicle accident. The person's impairments are assessed at 10 points under Table 4 - Spinal Function (as they can drive a car for at least 30 minutes but are unable to bend forward to pick up light objects placed at knee height) and at 10 points under Table 7 - Brain Function (as they have difficulty solving some day to day problems and may need help on this from time to time). The person therefore meets the minimum impairment threshold of 20 points and is clearly unable to do work that requires lifting objects and solving certain problems on their own. However, the person may be able to undertake work that does not involve lifting and which requires routine, repetitive tasks such as processing simple forms or data entry.
Sustainability of work
In assessing capacity for work, it is expected that a person will be capable of reliably performing work on a sustainable basis, that is, for a reasonable period of time without requiring excessive sick leave or work absences. In this context, a reasonable period of time generally means 26 weeks and work means work in open, unsupported employment. Sick leave or absences of one month or more (in total) taken in any given 26 week period are considered excessive.
It should be noted that a number of Tables (including but not limited to Table 1 - Functions requiring Physical Exertion and Stamina, Table 3 - Lower Limb Function or Table 7 - Brain Function) contain specific references to periods of sustained effort in relation to certain activities or tasks (e.g. sustaining appropriate exercise for 30 minutes, standing unaided for 10 minutes etc.). These references should not be confused with the concept of the overall work sustainability mentioned above.
|Summary of key qualification requirements for DSP (as per SSAct)|
The person has a physical, intellectual or psychiatric impairment, and
the person's impairment is 20 points or more under the Impairment Tables, and
the person has a CITW, or
the person is participating in the supported wage system.
CITW means that:
Severe impairment means that the person has an assessed impairment of 20 points or more under the Impairment Tables, of which 20 points or more are assigned under a single Table.
A reviewed 2008-2011 DSP starter means a person who meets all the following conditions:
Active participation in a POS is assessed under provisions of the Social Security (Requirements and Guidelines - Active Participation for Disability Support Pension) Determination 2014.
Independently of a POS means that the person:
POS means a program that is designed to assist persons to prepare for, find or maintain work and is funded (wholly or partly) by the Commonwealth or is of a type similar to such a program.
Work means work that is for at least 15 hours per week, at or above the relevant minimum wage and that exists (anywhere) in Australia, even if not within the person's locally accessible labour market, regardless of whether vacancies exist.
Conceptual design model of the Tables
The Tables are function-based rather than diagnosis-based in that they focus on assessing impact of impairment on normal functions as they relate to work performance and assigning a rating consistent with the identified level of such an impact. As such, the Tables do not just assess a person's medical conditions, the person's overall health status or a loss or abnormality of psychological, physiological or anatomical structure.
The basis for understanding the concept and design of the Tables as being function-based rather than condition or diagnosis-based, lies in a distinction between the concepts of medical conditions and impairments.
Note 1: A medical condition is a disease, injury or abnormality of a body system or structure as diagnosed by an appropriately qualified medical practitioner.
Note 2: Impairment can be described as a sum of effects or impacts of a person's medical condition has on the person's ability to function in relation to work.
If the difference between a condition and impairment is not appreciated, then inappropriate selection of Tables, double counting of impairment or assigning ratings to temporary impairments are more likely to occur.
The same condition will not always result in the same level of impairment. Inappropriate assessments may result from assuming that individuals with the same condition will have the same level of impairment.
Example: Two individuals with the same condition, 'below knee amputation of the left leg' may not necessarily be assigned the same impairment ratings under Table 3 - Lower Limb Function, even though they share the same diagnosis. This is because it is their functional ability rather than their condition that is assessed.
Note: The Tables are function-based - they are used to assess functional impact of impairments resulting from medical conditions.
Consistent with the function-based approach, the Tables describe functional activities, abilities, symptoms and limitations that must be taken into consideration when assessing the level of impact of impairments.
Each individual Table contains a set of instructions to be followed when applying that specific Table. Typically, these instructions, which are set out in the introduction to each Table:
- specify body functions to which that Table should be applied,
- specify which practitioner can diagnose,
- instruct that self-report of symptoms (by the person who is being assessed) must be supported by corroborating evidence, and
- provide examples of corroborating evidence that can be taken into account when applying that Table, who can provide it and, where appropriate, an indication of conditions commonly associated with an impairment assessable under that Table.
Scaling system & descriptors
The Tables have been designed to be consistent where possible with the World Health Organisation International Classification of Functioning, Disability and Health (WHO ICF), 2001.
Each Table contains descriptors which describe the level of functional impact of the impairment assessed under that Table. The level of impact is described in the first line of each descriptor by reference to specific examples of functional activities, abilities, symptoms and limitations that are contained in the descriptor.
While the Tables are designed to assess the level of a person's impairment in relation to their capacity to perform work-related tasks and activities, the Tables acknowledge that some people being assessed for DSP purposes may have no work history and experience. This is addressed by including references to general activities of daily living in the descriptors.
Each individual descriptor specifies how it is to be met. For example, a descriptor may state that either at least one of the functional activities, abilities, symptoms or limitations must apply, or that at least 2 of them must apply, or that most of them must apply.
Additionally, individual activities, abilities, symptoms and limitations may contain terms such as occasionally, frequently, often, sometimes, regularly etc. In some Tables, these terms may be further defined by references to the corresponding periods of sustained effort.
Example: Table 15 - Functions of Consciousness under 5 points, defines rare episodes as occurring no more than twice per year, and under 30 points frequent episodes are defined as occurring at least once each week.
Note 1: For the purpose of applying the Tables, most means more than 50%. For instance: if there are 3 examples in the descriptor, most means 2; if there are 4 examples, most means 3; if there are 6, most means 4 etc.
Note 2: Unless specifically defined in individual Tables (e.g. Table 15), terms, such as occasionally, frequently, often, sometimes, regularly etc., have their natural meaning. Please refer to (G) Assigning an impairment rating for more explanation on the significance of these terms in the context of the hierarchy of descriptors.
In all Tables, each level of functional impact has a corresponding rating expressed in points in accordance with a consistent, generic scale that has been adapted from the WHO ICF.
This generic scale is as follows:
- no functional impact - 0 points,
- mild functional impact - 5 points,
- moderate functional impact - 10 points,
- severe functional impact - 20 points,
- extreme functional impact - 30 points.
Act reference: Social Security (Tables for the Assessment of Work-related Impairment for Disability Support Pension) Determination 2011 section 5 Purpose and design of the Tables, Table 1 - Functions requiring Physical Exertion and Stamina, Table 3 - Lower Limb Function, Table 4 - Spinal Function, Table 7 - Brain Function, Table 14 - Functions of the Skin, Table 15 - Functions of Consciousness
(B) Applying the Tables
Assessing functional capacity
Consistent with the function-based design of the Tables, a person's impairment must be assessed on the basis of the person's abilities and not what the person chooses to do, or not to do, or what the person is accustomed to having another person do for them.
Example: The fact that a person's partner performs certain household activities, does not mean that the person is unable to perform them. It is inappropriate to determine that a person cannot perform certain tasks or activities solely on the basis of self-report of the situation in their household. This is because that specific situation may be merely a result of the domestic arrangements or reflect other factors such as family or cultural tradition.
Note: A determination that the person cannot perform certain activities must always be based on an objective assessment of that person's potential capability to do those things. The Tables require corroborating evidence of the person's impairment.
Explanation: When assessing functional impairment, rather than asking 'Does this person vacuum floors or mow the lawns at their place?', one should consider 'Can this person perform these tasks and what level of functional limitation, if any, do they have when attempting these tasks?'.
Permanency of conditions & impairments
The Tables can only be applied after a person's medical history has been considered.
In deciding whether the Tables should be applied, the following should be considered:
- whether a person has a permanent medical condition,
- whether this condition has an impact on the person's ability to function (impairment), and
- whether the condition and the impairment are both considered permanent.
The information to enable these considerations can be obtained from medical records provided by a person (see (C) Information that must be taken into account in applying the Tables).
Explanation: The medical condition and the resulting impairment can both be regarded as permanent and the Tables should be applied, if in light of the available medical evidence, it is determined that:
- the person's medical condition is fully diagnosed, treated and stabilised, and more likely than not to persist for more than 2 years (permanent), and
- this condition results in an impact on the person's ability to function (impairment), and
- the impact of this impairment is expected to persist for more than 2 years without functional improvement
Note: The Tables can only be applied if the medical condition and the resulting impairment are both considered permanent for DSP purposes.
For DSP purposes, permanent medical condition does not mean a condition that is lifelong or incurable. For DSP, a condition is permanent if it has been:
- fully diagnosed by an appropriately qualified medical practitioner (this includes an appropriate specialist), and
- fully treated, and
- fully stabilised, and
- is more likely than not, in light of available evidence to persist for more than 2 years.
The above criteria, in particular the criteria related to treatment and stability of medical conditions, are interrelated and should not be considered in isolation from one another.
Explanation: Whether a condition has been fully treated or not, must be considered when determining whether the condition is fully stabilised. Therefore, some of the examples of conditions that may be considered as fully treated (provided under fully diagnosed and fully treated below) are also reasonable indications of the condition's stability.
An impairment that results from a specific condition can only be considered permanent if it is more likely than not, in light of the available evidence, to persist for more than 2 years.
Example: A person may have been diagnosed with a fractured Tibia, which impairs their ability to use their leg. Although this condition has been diagnosed by an appropriately qualified medical practitioner, it is not considered fully treated or stabilised and is not expected to persist for more than 2 years. Therefore, the condition cannot be considered permanent for DSP and an impairment rating cannot be assigned.
Impairments that are not permanent are not to be assessed under the Tables and cannot be assigned an impairment rating. It is possible for a medical condition causing impairment to last for more than 2 years but the impact of the resulting impairment to improve or even cease within 2 years.
Example: In the case of a person who has been diagnosed with osteoarthritis or degenerative joint disease of the knee, the condition is considered permanent and is likely to deteriorate with age. It will certainly persist for at least 2 years. However, its corresponding impairment may not necessarily be considered 'permanent' for DSP purposes as this depends on whether, and if so how, the person's level of function is expected to change within the next 2 years. For instance, if it is assessed that the impairment will significantly improve or cease (e.g. through medication, lifestyle changes or surgical intervention) within the next 2 years, this impairment is not considered permanent for DSP purposes and the Tables are not to be applied.
Fully diagnosed & fully treated
In determining whether a medical condition has been fully diagnosed, an examination and analysis of diagnostic information is required. The relevant diagnostic information is normally available in medical records provided by the claimant and from other corroborating evidence.
To be valid for DSP purposes, diagnosis of a medical condition must be made by an appropriately qualified medical practitioner, however, for the purpose of Table 9 - Intellectual Function, an assessment of the condition must be made by an appropriately qualified psychologist.
Note: Appropriately qualified medical practitioner means a medical practitioner whose qualifications and practice are relevant to diagnosing a particular condition.
Example: A medical practitioner who solely practices psychiatry would not be regarded as an appropriately qualified medical practitioner to diagnose conditions resulting in impairments assessed under Table 2 - Upper Limb Function.
The introduction to some Tables instructs that the diagnosis made by an appropriately qualified medical practitioner must be supported by evidence from another health professional.
The reason for this is to ensure that the person has received the necessary diagnostic input and associated treatment considerations. In these instances it is sufficient to consider clear indications that this has occurred where this information is contained within the medical records provided by the claimant or, where necessary, verbal confirmation of this by the medical practitioner at follow up, which must be clearly documented by the assessor.
Explanation 1: Table 5 - Mental Health Function requires that the diagnosis must be made by an appropriately qualified medical practitioner (including a psychiatrist) with evidence from a clinical psychologist (if the diagnosis has not been made by a psychiatrist), or in limited circumstances, a paediatrician (see 220.127.116.11 Guidelines to Table 5-Mental Health Function).
Explanation 2: Table 11 - Hearing and other Functions of the Ear requires that the diagnosis must be supported by evidence from an audiologist or Ear, Nose and Throat (ENT) specialist.
Explanation 3: Table 12 - Visual Function requires that the diagnosis must be supported by evidence from an ophthalmologist.
The introduction to each Table also contains examples of the types of valid corroborating evidence and about the types of health professionals who can provide it.
In determining whether a condition has been fully treated, the following factors should be considered:
- the nature and effectiveness of past treatment,
- the expected outcome of current treatment,
- any plans for further treatment, and
- whether past, current or future treatment can be considered reasonable.
A condition is considered fully treated if, based on the above considerations, it is determined that the person has received all reasonable treatment or rehabilitation for the condition. Treatment includes medical treatment and other appropriate therapy (e.g. physiotherapy) involving rehabilitation aimed at restoring mental or physical function, but usually does not extend to rehabilitation involving specific vocational programmes. It should also be considered whether treatment is still continuing or is planned in the next 2 years. This is because the stability of a condition may depend on whether reasonable treatment has been undertaken, is being undertaken, or is planned to be undertaken.
Example 1: A person's non-terminal cancer that is still being treated by chemotherapy and for which prognosis is uncertain, would not normally be regarded as fully treated.
Example 2: A person has been diagnosed with degenerative joint disease with symptoms of knee pain but has not yet received any treatment as they are on a waiting list for a knee replacement. The condition causes functional impairment and treatment is anticipated to significantly improve the impairment. The condition normally would not be considered fully treated. However, if the waiting list or the waiting list plus rehabilitation is 2 years or longer their condition may be considered fully treated.
Example 3: A person with severe osteoarthritis in the knee is scheduled to undergo joint replacement surgery within the next 2 years which could result in significant improvement of their level of mobility and overall function. The condition should not be regarded as fully treated.
Note: In some circumstances, however, a condition may be considered as fully treated even if the treatment is still continuing or is planned.
This may apply where it is clear that a person's functional capacity will not improve within the next 2 years even if the person continues to receive appropriate reasonable treatment.
Example: A person with severe burns may need to undertake a series of skin grafts and other treatment spread over more than 2 years but due to the severity of the burns, no significant functional improvement is expected within the next 2 years. This condition can be considered as fully treated.
For a condition to be considered fully stabilised, it must be established whether a person has undertaken reasonable treatment for the condition and what the prospects are for any significant functional improvement to occur in the next 2 years.
The condition can be regarded as fully stabilised if the person has undertaken reasonable treatment for the condition and it is considered that any further reasonable treatment is unlikely to result in significant functional improvement in the next 2 years. In this context, significant improvement is improvement that will enable the person to undertake work in the next 2 years.
The condition can also be considered fully stabilised where a person has not undertaken reasonable treatment and either:
- significant functional improvement to a level enabling the person to undertake work in the next 2 years is not expected to result even if the person undertakes reasonable treatment, or
- there is a medical or other compelling reason for the person not to undertake reasonable treatment.
In assessing stability of medical conditions, it is therefore required to consider the prognosis for improvement within the next 2 years in light of factors such as the history of the condition, response to treatment and the expected rate of recovery. The information necessary to establish prognosis and stability of conditions can be obtained from medical records provided by the claimant. Any valid corroborating evidence as stipulated in the introduction to each Table should also be consulted.
Explanation: If the available medical evidence indicates that the medical condition is likely to persist for more than 2 years but the prognostic information indicates that significant functional improvement within the next 2 years is likely, the condition is not to be considered as fully stabilised.
Where the available medical evidence indicates that the condition is likely to fluctuate, deteriorate or remain unchanged, it needs to be considered whether all reasonable treatment has been undertaken before it can be concluded that the condition is not fully stabilised.
Explanation 1: A fluctuating condition with intermittent episodes of exacerbation (e.g. bipolar affective disorder) may be considered fully stabilised if the person is receiving reasonable medical treatment and the person's overall functional impact is unlikely to improve significantly within the next 2 years.
Explanation 2: An intermittent condition (e.g. epilepsy) would not be considered fully stabilised if further medical treatment can significantly improve the person's control of the condition and reduce the frequency of episodes, for instance by improving treatment compliance, adjusting dosage or type of medication to reduce side-effects or improve therapeutic effect.
The term 'stability' as used for DSP purposes has a specific meaning. In this context stabilised does not mean stable in the usual sense of the word.
While a condition may not be stable in the usual sense of the word because the level of impairment resulting from that condition is continuing to change (deteriorate), it may still be considered fully stabilised for DSP purposes.
Explanation: This may occur where the prognosis is poor and no functional improvement is expected within the next 2 years. This situation may apply to a condition where active treatment is no longer effective or is no longer indicated.
In some situations, a condition may be considered fully stabilised even though it could be argued that the condition has not been fully treated and therefore functional improvement would, theoretically, be possible. This is particularly so in relation to conditions resulting in impairments affecting mental health function.
Example: A person has a major depressive disorder which remains poorly controlled after 5 years of treatment with various types of antidepressant medications and other appropriate treatment. There is evidence that the person's response to the medications and other treatment they tried has been poor. There are a few medications the person has not yet tried. Therefore functional improvement is, theoretically, possible with a change of medication. However, given the history of poor response to previous treatment, prognosis for a positive response to the untried medications is poor. In this situation it may be reasonable to consider the condition as fully stabilised. This example can also apply to other conditions and their impairments affecting mental health function.
Note: It may be inappropriate to consider a mental health condition as 'not fully stabilised' based solely on the fact that a change of medication is possible. A thorough examination of the clinical history of the condition, response to previous treatment and prognosis for improvement or otherwise with a new medication must be undertaken.
In other situations, even though significant improvement in functional ability is expected to occur over time, a condition may be considered fully stabilised if such improvement is unlikely to occur within the next 2 years. This may apply to conditions the history of which suggests slow, gradual improvement or with very severe injuries where recovery is expected to be quite prolonged.
Example 1: A person with severe burns is willing to receive reasonable treatment by agreeing to undergo a series of skin grafts but it is clear that significant functional improvement to a level enabling the person to undertake work in the next 2 years is not expected to result because the planned treatment and recovery times will span more than 2 years. In this case, the condition may be regarded as fully stabilised for DSP purposes.
Example 2: When significant improvement takes longer than 2 years because a treatment procedure has to be delayed for some time (see also 'Reasonable treatment and compelling reasons for not undertaking reasonable treatment' for information about waiting lists), the condition may be considered as fully stabilised.
Reasonable treatment & compelling reasons for not undertaking reasonable treatment
To be considered reasonable, treatments must be evidence-based with scientific, peer-reviewed research findings to support the use of the treatment for specified medical conditions (i.e. alternative or complementary medicine or treatments without such research evidence are not considered to be reasonable treatment for DSP purposes). Off-label use of medications (i.e. medications used without a prescription or not in accordance with a prescription from a qualified medical practitioner) is also not considered to be reasonable treatment for DSP purposes. The Health Professional Advisory Unit (HPAU) should be consulted where clarification is required.
For DSP purposes, reasonable treatment means:
- treatment that is available at a location reasonably accessible to the person at a reasonable cost.
- Explanation: It would not be reasonable to expect a person to undergo prohibitively expensive treatment, or treatment that is only available in another country in order to satisfy the permanence criteria.
- treatment or procedure that is of a type regularly undertaken or performed.
- Explanation: Treatments that are experimental in nature or not yet widely accepted or performed by the general medical community would not be considered reasonable.
- treatment that has a high success rate and where substantial improvement can be reliably expected.
- Explanation: It would be inappropriate to consider impairment as being temporary solely because the person has not undertaken a treatment that has a poor success rate or that is likely to result in only marginal functional improvement.
- treatment that is of a low risk nature.
- Explanation: A person may decide against undertaking a certain treatment because it has serious associated risks, for instance major surgical procedure or unavoidable and significant side effects, as may occur with some types of chemotherapy.
If the person has not received or is not able to receive treatment within reasonable timeframes due to issues such as extended waiting lists, evidence should be obtained, for example a document from the relevant hospital or other relevant authority, setting out waiting times for the treatment or the date of the treatment. In cases of long waiting lists, it may be appropriate to consider a condition as stabilised.
Example: A person may be advised by their treating orthopaedic specialist that they require a hip replacement which will significantly improve their level of mobility. However, they are advised by their hospital that the waiting list for the surgery is between 18 to 24 months. Taking into account the recovery and rehabilitation period that may be required after such a surgical procedure, it may be reasonable in this circumstance to consider the person's condition to be stabilised.
Note: Waiting list should be considered when assessing whether a medical condition is stabilised.
It is assumed that a person will generally wish to pursue any reasonable treatment that will improve or alleviate their condition. However, people cannot be expected to undergo treatment that is not reasonable. Treatment will not be considered reasonable if it is not based on the best medical information available.
There may be medical or other compelling and acceptable reasons for not proceeding with reasonable treatment, including where the person:
- has religious or cultural beliefs prohibiting treatment (e.g. blood transfusions),
- lacks insight or the ability to make appropriate judgements due to their medical condition and are unlikely to comply with treatment (e.g. a person with a severe psychotic illness or dementia).
In those cases where significant functional improvement is not expected or where there is a medical or other compelling reason for a person not to pursue further treatment, it may be reasonable to consider the condition stabilised. The person's views (the subjective test) and all available information on treatment options, risks etc. (the objective test) must be considered by the assessor in such situations.
If a person has not had reasonable treatment due to factors that are not of a compelling nature (e.g. lack of personal motivation that is not due to their medical condition), then their condition would not be considered permanent for DSP purposes, as it is not fully treated and stabilised. Consequently, the Tables must not be applied and the impairment rating must not be assigned. In such situations, the following needs to be evaluated and documented:
- what reasonable treatment is feasible and what is the probable outcome of treatment,
- what are the risks and side effects of the treatment,
- why the treatment is considered reasonable, and
- what are the person's reasons for choosing not to undertake this treatment.
Assessing impairments with no or negligible functional impact
Subsection 6(8) of the Determination states that the presence of a diagnosed condition does not necessarily mean that there will be an impairment resulting in a functional impact. Where a condition is considered permanent and fully diagnosed, treated and stabilised but results in no or negligible functional loss, the impairment is to be assessed as having no functional impact. A rating of zero should be assigned under the Table most relevant to the area of function most commonly affected by the condition.
Example: Medical records provided by the claimant list hypertension as one of the diagnosed conditions. On assessment, it is determined that this condition has been successfully treated with medication over the last 5 years, is stable and the prognosis for ongoing positive response to treatment is good. The medical records provided by the claimant do not indicate any restriction on activities. It would be reasonable to consider that this condition is permanent and fully diagnosed, treated and stabilised. Therefore the Tables must be applied and an impairment rating of zero should be allocated under Table 1-Functions requiring Physical Exertion and Stamina.
The allocation of zero points does not necessarily mean that there is no functional impact whatsoever - it may mean that the level of impact is such that the impairment rating of 5 points is not met.
Example: A DSP claimant was diagnosed with hypertension 5 years ago. The condition has been treated with appropriate medication and the person's response to the medication has been generally good, however, from time to time the person suffers from minor side-effects of the medication. For example, when they get up to a standing position too quickly, they experience dizziness. Therefore, the condition and its treatment have some impact on the person's general ability to function but the overall functional impact in relation to work can be considered as negligible or none and does not meet the 5-point descriptor. In this case, an impairment rating of zero should be allocated under Table 1 - Functions requiring Physical Exertion and Stamina.
Assessing functional impact of pain
There is no longer a Table specifically dealing with pain.
Acute pain is a symptom that may result in a short-term loss of functional capacity in more than one area of the body.
Chronic pain can be a medical condition and where it has been fully diagnosed, fully treated and fully stabilised, any resulting impairment should be assessed using the Table that is relevant to the function affected.
Chronic pain can also be a symptom of a permanent condition. Where a person experiences chronic pain as a result of a permanent condition, such as rheumatoid arthritis, chronic pain is not a separate diagnosis but rather a symptom of the underlying autoimmune disorder.
Where a permanent condition results in chronic pain, the first step is to consider the functional impact as outlined in the medical evidence, for example, does it impact spinal function, upper or lower limb function, concentration and memory or physical exertion and stamina (fatigue).
The next step is to determine which Impairment Table/s apply to the impact while avoiding double-counting of the impairment. Selecting Tables for chronic pain:
- where chronic pain does not impact physical exertion and stamina there will be no need to consider the use of Table 1-Functions requiring Physical Exertion and Stamina,
- where chronic pain does impact physical exertion and stamina and this is adequately assessed by another selected Table, there will be no need to consider the use of Table 1- Functions requiring Physical Exertion and Stamina,
- where chronic pain impacts physical exertion and stamina (i.e. results in fatigue symptoms) and this is not adequately assessed by another Table, Table 1- Functions requiring Physical Exertion and Stamina may need to be considered, while ensuring that the level of impairment is not overstated.
The following scenarios show how the Tables should be applied when assessing chronic pain to avoid double counting:
- if a person experiences chronic pain as a result of a permanent condition and this pain impacts the person in a particular area of the body such as the upper limbs, the relevant Table should be used to assess the impact of the condition (e.g. Table 2-Upper Limb Function). A rating under the body area Tables includes consideration of the impact of pain and fatigue on the person's ability to undertake activities within the descriptor,
- if a person experiences chronic pain as a result of a permanent condition and this pain impacts multiple areas of the body, more than one body area Table may be used to assess the impact of the condition (e.g. Table 2-Upper Limb Function, Table 3-Lower Limb Function and/or Table 4-Spinal Function) as long as the overall level of impairment is not overstated/double counted. A rating under these Tables includes consideration of the impact of pain and fatigue on the person's ability to undertake activities within the descriptor,
- for systemic conditions that affect one or more areas resulting in chronic pain (such as rheumatoid arthritis) impacts on activities requiring physical exertion and stamina should be assessed under Table 1- Functions requiring Physical Exertion and Stamina. Table 1 includes assessment of the impact of pain and fatigue on a person's mobility and capacity to undertake daily activities,
- where a person's concentration and/or memory is also impacted by chronic pain, consideration should be given to whether an additional rating under Table 7-Brain Function is also required,
- where a person experiences chronic pain that results in fatigue and another Table adequately assesses these impacts, Table 1 should not be used as well e.g. Table 10-Digestive and Reproductive Function or Table 14-Functions of the Skin only should be used.
Example 1: A person with stabilised permanent condition that results in chronic lower back pain should be assessed using Table 4 - Spinal Function. The functional impact of the person's impairment on the person's ability to bend, move their trunk and remain seated would be assessed in accordance with the descriptors in that Table. In determining the level of impairment, consideration should be given to the impact of pain resulting from the back condition on the person's ability to undertake activities within the descriptor, e.g. the person cannot bend or move their trunk on a repetitive basis due to the chronic pain they experience on doing so.
Example 2: A person with chronic pain which impairs their ability to use their arms, and their legs should be assessed using Table 2 - Upper Limb Function and Table 3 - Lower Limb Function. The functional impact of the chronic pain on their ability to pick up, handle or manipulate objects for example, would be assessed using the Table 2 descriptors, while the impact of the chronic pain on their ability to walk, stand or use stairs for example, would be assessed using the Table 3 descriptors.
Example 3: A 55 year old woman has severe deteriorating rheumatoid arthritis. Medication provides limited relief and the doctor has stated she experiences associated chronic pain and fatigue. This condition is systemic in nature and the woman experiences persistent fatigue, chronic inflammation of her joints with swelling, heat and pain, as well as muscle weakness and difficulty sleeping. Medical evidence states that due to fatigue and pain the woman is unable to perform any light day to day household activities and would not be able to perform clerical or sedentary work tasks for a shift of 3 hours.
The condition is considered fully diagnosed, treated and stabilised and under Table 1- Functions requiring Physical Exertion and Stamina, the woman would receive an impairment rating of 20 points as the impact on her ability to function is severe. Under the 20-point descriptor the woman would meet (1) (a) (iv) and (1) (b). To avoid double counting ratings under Table 2-Upper Limb Function and Table 3-Lower Limb Function are not given as Table 1 includes assessment of mobility and capacity to undertake daily activities.
Example 4: A 58 year old man has a permanent, degenerative lumbar spine condition and experiences chronic low back pain. He has had multidisciplinary treatment for chronic pain and continues to experience symptoms and is prescribed opiates to manage ongoing pain. Medical evidence states he has reduced tolerance for all physical tasks due to the pain he experiences and he has moderately impaired concentration as a result of the chronic pain. He can undertake self-care activities but requires assistance with all domestic tasks, including light tasks due to endurance and stamina deficits. He can bend to just below knee level. This condition impacts on his physical exertion, spinal movements and cognitive function.
Under Table 1- Functions requiring Physical Exertion and Stamina, the man would receive an impairment rating of 20 points as the impact on his ability to undertake activities requiring physical exertion is severe. Under the 20-point descriptor the man would meet (1) (a)(iv) and (1) (b). Given the moderate impact of chronic pain on his cognitive function, under Table 7-Brain Function, the man would also receive a rating of 10 points. Under the 10-point descriptor he would meet (1) (b). To avoid double counting, a rating under Table 4-Spinal Function is not given as the rating under Table 1 captures the overall physical impairment.
Example 5: A 45 year old man has permanent inflammatory bowel disease. Medical evidence indicates that as a result of this condition he experiences chronic digestive pain which results in persistent and debilitating fatigue. He has difficulty concentrating on tasks due to the pain and fatigue and his concentration is interrupted each hour as a result. He has to take 3 or 4 days leave from work each month as a result of the condition.
Under Table 10-Digestive and Reproductive Function, the man would receive an impairment rating of 20 points as the impact on his ability to undertake work related activities is severely impacted by the symptoms of the digestive condition. Under the 20-point descriptor he would meet (1) (a) and (d). As the descriptors under Table 10 capture the impact of pain on fatigue and on the person's ability to concentrate, additional ratings under Table 1 and/or Table 7 would be double-counting in this case.
These examples are not exhaustive - it should be remembered that chronic pain may affect a number of different body functions. If a person experiences chronic pain that falls outside these scenarios and it is unclear how this should be rated to avoid double counting, the claim should be discussed with the Health Professional Advisory Unit.
Act reference: Social Security (Tables for the Assessment of Work-related Impairment for Disability Support Pension) Determination 2011 Part 2 - Rules for applying the Impairment Tables, section 6 Applying the Tables, Table 2 - Upper Limb Function, Table 3 - Lower Limb Function, Table 4 - Spinal Function, Table 5 - Mental Health Function, Table 9 - Intellectual Function, Table 11 - Hearing and other Functions of the Ear, Table 12 - Visual Function
(C) Information that must be taken into account in applying the Tables
The following information must be taken into account in applying the Tables:
- the information provided by health professionals specified in the relevant Table,
- any additional medical or work capacity information that may be available, and
- any information that is required to be taken into account under the Tables, including as specified in the introduction to each Table.
Generally, people claiming DSP must provide their medical records in support of their claim. The medical records should include details of:
- the diagnosis of the person's medical condition, including date of onset and whether the diagnosis is confirmed,
- clinical features including history and symptoms,
- past, present and future/planned treatment, including periods of hospitalisation,
- compliance with recommended treatment,
- impact of the condition on the person's ability to function, including whether this impact is long term or temporary, and the expected effect of the condition on the person's ability to function in the next 2 years (prognosis),
- any impact on life expectancy as a result of the medical condition, and
- supporting information such as X-Rays, specialist reports, hospital records, or pathology test results.
Medical records provided by the claimant are the primary source of evidence used in determining whether the person's medical condition and its resulting impairment are permanent for DSP purposes and, consequently, whether the impairment arising from this condition can be assigned a rating under the Tables.
The person claiming DSP is responsible for obtaining all relevant medical evidence in support of their claim or payment continuation. Where the person indicates that they have a medical condition that is not included in their medical evidence, they should be asked to provide medical evidence detailing the diagnosis, treatment and prognosis of the condition. This may involve requesting the person to obtain further information from the person's treating doctor or another doctor or specialist.
Generally, medical evidence from the previous 2 years should be used, however, if the medical evidence is not recent, it may still be useful depending on the person's condition and whether the information is representative of the person's current level of impairment.
Explanation: Medical evidence that is older than 2 years may still be of value if the condition remains unchanged since the time the evidence was issued - for instance a condition has been present from birth or early childhood, or is never likely to change (e.g. amputation of a limb).
While such older evidence may be useful for the purposes of confirming diagnoses of medical conditions, it may not fully reflect the current level of impact of such conditions on the person's ability to function.
Example: Since the time the evidence was issued, an amputee may have acquired a prosthesis and learned how to use it which resulted in improved functional abilities.
Where the nature or the severity of a condition is unclear, arrangements should be made for further investigation of the condition before undertaking an assessment of the functional impact of the condition on the person's capacity to work. This could include the claimant providing further information, or the person's treating doctor can be contacted for clarification.
At an assessment, a person may be asked to demonstrate abilities specified in the relevant Tables. This can only be done where:
- the assessor is qualified and competent to assess abilities of this nature (e.g. a physiotherapist assessing movement), and
- the requested task/function/ability is unlikely to cause the person pain, discomfort or undue emotional distress, and
- there are no medical or psychological contraindications (e.g. acute pain), and
- the ability can be demonstrated in the assessment setting.
People living in remote areas
JCAs, DMAs and payment decisions informed by these assessments must be based on the best available medical evidence. In the case of people from remote areas who may have limited access to doctors, a community nurse can assist in collating their medical evidence, which should generally be based on clinical notes from a GP (the diagnosis must have been made by an appropriately qualified medical practitioner). In these cases it may be possible for the job capacity assessor or GCD to form an opinion regarding the person's medical qualification on the basis of available evidence. This will only apply if the medical condition has been diagnosed, treated and stabilised to the extent that an impairment rating can be assigned.
Explanation: People living in remote areas may have limited access to medical services and may find it difficult to obtain medical evidence in relation to their condition/s.
Act reference: Social Security (Tables for the Assessment of Work-related Impairment for Disability Support Pension) Determination 2011 section 7 Information that must be taken into account in applying the Tables
(D) Information that must not be taken into account in applying the Tables
In assessing impairment, self-report of symptoms alone cannot be taken into account unless there is corroborating evidence of the person's impairment. In most instances this would be included in medical evidence provided by the claimant. Examples of the corroborating evidence that may be taken into account and who can validly provide it, are set out in the introduction to each Table.
Additional evidence may include, but is not limited to reports or letters from the person's treating doctor/s or specialists, reports from previous examinations or assessments (e.g. job capacity assessment), results of diagnostic tests (e.g. X-Rays), reports from other health professionals (e.g. psychologists, physiotherapists, exercise physiologists or social workers) or reports from other sources such as mental health workers or drug and alcohol counsellors.
Impairment ratings should reflect the level of work-related impairment due to the medical conditions and not due to non-medical factors.
For this reason, unless specifically required under the Tables, the impact of non-medical factors should not generally be taken into account when assessing a person's impairment. Individual Tables may contain descriptors that may take account of certain non-medical factors but they represent an exception rather than the rule.
Example: Table 1 - Functions requiring Physical Exertion and Stamina, contains a reference to an ability to undertake exercise appropriate to the person's age e.g. reduced stamina or loss of flexibility.
Note: Some Tables provide for certain non-medical factors to be taken into account.
If a specific Table does not include considerations of non-medical factors, then such factors must be disregarded, that is, an impairment rating must not be influenced or adjusted because of these factors. In such cases, the following must not be taken into account in assessing impairment:
- the availability of suitable work in the person's local community,
- English language proficiency,
- level of education,
- literacy and numeracy skills,
- work skills and experience,
- social or domestic situation,
- level of motivation not associated with a medical condition,
- religious or cultural factors.
Example: A non-English speaking person who is fluent in another language and does not have a medical condition affecting their communication function should not receive a rating under Table 8 - Communication Function just because they have difficulties communicating in English. Table 8 measures impacts on communication in the language that the person most commonly uses.
Medically-related factors should not be disregarded. For example, a person who is poorly motivated for work may or may not have a medical basis to their lack of motivation depending on whether it is an effect of an underlying medical condition such as depression.
Act reference: Social Security (Tables for the Assessment of Work-related Impairment for Disability Support Pension) Determination 2011 section 8 Information that must not be taken into account in applying the Tables, Table 1 - Functions requiring Physical Exertion and Stamina, Table 8 - Communication Function
(E) Use of aids, equipment & assistive technology
The Tables have a consistent requirement that a person's impairment is to be assessed when the person is using or wearing any aids, equipment or assistive technology that the person has (in their possession) and usually uses.
In cases where a person may need a certain aid, equipment or assistive technology but states that they are unable to access it or does not have it or usually use it, then they are to be assessed without it. However, when considering any lack of appropriate aids including affordability, accessibility etc. this needs to be considered in line with reasonable treatment as defined in Part 2 of the Tables.
Some of the Tables specify a particular impairment rating when such assistance is used.
Example: A person's impairment attracts 20 points under Table 8 - Communication Function, where the person uses an electronic communication device (which produces electronic speech) and needs to use this technology to communicate with others in places such as shops, workplace, education or training facilities and is unable to be understood without this device.
Use of the term 'assistance' within the Tables
The term assistance is used in numerous descriptors within various Impairment Tables. In all of these cases assistance means from another person, rather than any aids, equipment or assistive technology the person has and usually uses.
Given that a person's impairment is to be assessed when the person is using or wearing any aids, equipment or assistive technology they have and usually use, any further assistance would be from another person.
Example 1: Table 1 - Functions requiring Physical Exertion and Stamina uses the term assistance in the 20- and 30-point descriptors. To meet these descriptors a person would require assistance from another person to undertake the activities listed in the descriptors, even while using a wheelchair or other mobility device they have and usually use.
Example 2: Table 2 - Upper Limb Function uses the term assistance in the 20-point descriptor at (1) (e) 'the person has severe difficulty turning the pages of a book without assistance'. To meet this point, the person would have severe difficulty turning the pages of a book without assistance from another person, even with any assistive technology they have and usually use.
Act reference: Social Security (Tables for the Assessment of Work-related Impairment for Disability Support Pension) Determination 2011 section 9 Use of aids, equipment and assistive technology, Table 1-Functions requiring Physical Exertion and Stamina, Table 2 - Upper Limb Function, Table 8 - Communication Function
(F) Selecting the applicable Table & assessing impairments
Once it has been determined that the person has a permanent physical, intellectual or psychiatric impairment, the appropriate Table/s can be selected.
Table selection depends on the function affected and is made as follows:
- identify the function affected/identify the loss of function,
- refer to the appropriate Table related to the area of function,
- identify the correct rating.
When identifying the loss of function consideration should be given to the ongoing side effects of medication when the impact of the side effects is not expected to significantly improve.
Example: Epilepsy that is controlled through medication may have a mild functional impact from loss of consciousness. However, the side effects of medication required to control seizures may have a moderate functional impact on the person's memory and may result in the person often forgeting to complete regular daily tasks or misplacing items and needing occasional assistance with day to day activities. In this case, the person may receive 5 points under Table 15-Functions of Consciousness and 10 points under Table 7-Brain Function.
The Table specific to the impairment being rated must always be applied to that impairment unless the instructions in that Table specify otherwise.
Example: The introduction to Table 8 - Communication Function specifically instructs that if the person uses recognised sign language or other non-verbal communication method as a result of hearing loss only, the person's communication function is to be assessed using Table 11 - Hearing and other Functions of the Ear.
Rating multiple impairments resulting from a single condition
The number of conditions does not always correspond to the number of impairments.
A single medical condition may result in multiple functional impairments which can be assigned ratings from more than one Table.
Note: Where a single medical condition causes multiple impairments, these impairments should be assessed on all relevant Tables.
Example: A person who has had a cerebrovascular accident (CVA or stroke) may be assigned an impairment rating of zero or have an impairment rating assigned from a number of different Tables depending on what permanent residual effects of stroke they suffer. If they have recovered completely from their stroke and no longer experience any significant impairment, then a rating of zero is applicable regardless of what effects they suffered initially.
When using more than one Table to assess multiple impairments resulting from a single medical condition, care must be taken to ensure that the different Tables are being used to assess separate functional impairments and not the same functional impairment.
Note: The same impairment must not be assigned an impairment rating under more than one Table.
Below are examples of multiple Table use. Please refer to 3.6.3.07 for more details under these examples.
Stroke: A person who has suffered a stroke (cerebrovascular accident or CVA) may have functional impairments in a number of areas depending on which part/s of the brain were damaged.
Diabetes: A person with poorly controlled diabetes mellitus may experience a range of functional impairments.
HIV: A person living with HIV (PLHIV) may present with a range of associated diseases and a spectrum of functional impairments.
When the impairment is assessed using more than one Table, the overall impact of the person's impairments is represented by a combined point score.
Rating a common/combined impairment resulting from multiple conditions
Two or more medical conditions may result in a common impairment. Because the Tables are function-based and not condition-based, where this occurs, only one relevant Table should be applied and a single impairment rating assigned to reflect the combined impairment. It would be inappropriate to assign a separate impairment rating for each medical condition as this would result in the same impairment being assessed more than once (double counting).
Note: Double counting is not allowed and must be avoided.
Example 1: The presence of both heart disease and chronic lung disease may each contribute to difficulties a person may have with breathing and to reduced effort tolerance. The overall loss of function however, is a common and combined effect of the 2 conditions that impact on function requiring physical exertion and stamina. Therefore, to avoid double counting, only one impairment rating should be assigned using Table 1 - Functions requiring Physical Exertion and Stamina.
Example 2: A person diagnosed with peripheral vascular disease suffers from calf pain on walking a certain distance (intermittent claudication) and also suffers significant right knee symptoms due to osteoarthritis. There is also permanent impairment from chronic ligamentous instability affecting the left ankle. Although the person suffers from 3 distinct medical conditions affecting both legs, it would be inappropriate to apply 3 separate impairment ratings as the conditions all result in the same impairment affecting lower limb function. In this case, only one rating from Table 2 - Lower Limb Function should be applied.
Other situations where double counting may occur
Double counting can occur when more than one Table is applied to assess a single impairment resulting from a single medical condition.
This situation tends to occur when a single medical condition is inappropriately assessed as causing an additional functional impairment.
Example: The presence of mental confusion due to cognitive impairment may suggest an additional impairment of communication function. However, if the speech centre of the brain is undamaged, then it is considered that the overall impairment is a single (cognitive) impairment which should be rated under Table 7 - Brain Function. Double counting would result if an additional rating is provided from Table 8 - Communication Function.
Note: Double counting can also occur when there is an 'either-or' choice between Tables under which a particular impairment could potentially be assessed but a rating is inappropriately assigned instead from both Tables.
To minimise the risk of double counting in such situations, certain Tables contain instructions on how to avoid it.
Example 1: Table 4 - Spinal Function instructs that this Table's descriptors are to be met only from spinal conditions and that restrictions on overhead activities resulting from shoulder conditions should be rated under Table 2 - Upper Limb Function.
Example 2: Similarly, Table 7 - Brain Function instructs that a person with autism spectrum disorder who does not have a low IQ should be assessed under this Table but it also instructs that Table 7 should not be used when a person has an impairment of intellectual function already assessed under Table 9 - Intellectual Function (unless the person has an additional medical condition affecting neurological or cognitive function). Conversely, Table 9 - Intellectual Function instructs that a person with autism spectrum disorder, fragile X syndrome and foetal alcohol spectrum disorder who also has a low IQ should be assessed under this Table.
Act reference: Social Security (Tables for the Assessment of Work-related Impairment for Disability Support Pension) Determination 2011 section 10 Selecting the applicable Table and assessing impairments, Table 1 - Functions requiring Physical Exertion and Stamina, Table 4 - Spinal Function, Table 7 - Brain Function Table 8 - Communication Function, Table 9 - Intellectual Function
(G) Assigning an impairment rating
The following rules must be applied in assigning impairment ratings:
- impairment ratings can only be assigned in accordance with the rating points in each Table, and
- ratings cannot be assigned in excess of the maximum rating specified in each Table, and
- if an impairment rating is considered as falling between 2 ratings, the lower of the 2 ratings is to be assigned and the higher rating must not be assigned unless all the descriptors required for that rating are fully met.
Example: Where a person with a permanent medical condition resulting in functional impairment due to excessive use of alcohol (Table 6 - Functioning related to Alcohol, Drug and Other Substance Use) meets most descriptors corresponding to an impairment rating of 10 points but also satisfies the 20-point descriptor of neglecting personal care, hygiene, nutrition and general health, a rating of 10 points must be assigned rather than 20 points as the person does not meet most of the descriptors at the 20 points rating.
When more than one impairment rating is assigned, the point values of separate ratings are added together to obtain the total work-related impairment.
Hierarchy of descriptors
It should be emphasised that the descriptors in each Table are interlinked in that they follow a consistent, incremental hierarchy which is denoted, among other things, by the application of terms such as occasionally, frequently, often, sometimes, regularly etc.
Therefore, in deciding whether an impairment has no, mild, moderate, severe or extreme functional impact, all the descriptors in a specific Table should be read and compared before a decision is made to apply an appropriate impairment rating.
Descriptors involving performing activities
When assessing whether a person can perform a certain activity described in the descriptor, the descriptor will only apply if the person can do that activity on a repetitive or habitual basis and not only once or rarely.
Example: If, under Table 2, a person is assessed as to whether they can unscrew a lid of a soft drink bottle, the relevant descriptor is met only where the person is generally unable to do that activity whenever they attempt it.
Where a person performs a certain activity because they have to i.e. they need assistance but do not have anyone to assist them, consideration should be given to the impact of any subsequent symptoms experienced as a result of performing that activity. A person may push themselves to perform the activity, despite the significant impact of doing so.
Example: A person requires assistance from another person to walk around a supermarket, due to the impact of rheumatoid arthritis on their ability to use their lower limbs. The person does not have anyone available to assist them with this each week and so the person undertakes the shopping without assistance. As a result of undertaking this activity, the person experiences severe pain and fatigue and cannot walk any significant distance for the rest of the day. In this case, under Table 3, 20-point descriptor, the person should be considered unable to walk around a supermarket without assistance.
Assessing impairments caused by episodic or fluctuating medical conditions
Many medical conditions follow an episodic or fluctuating pattern. When assessing impairment caused by such conditions, a number of factors need to be taken into account. Consideration should be given to the severity, duration and frequency of the episodes or fluctuations and what is the overall functional impact the impairment/s. An impairment rating must then be assigned that reflects this overall functional impact.
A number of Tables that deal with functions that may be affected by conditions that often follow fluctuating or episodic patterns contain specific instructions that alert an assessor to the fact that the signs and symptoms of specific impairments may vary over time and that the person's presentation on the day of assessment should not solely be relied upon.
Note: In order to ensure that people with conditions resulting in impairments affecting mental health function and brain function are not disadvantaged, the introductions to Tables 5 and 7 contain specific instructions about how to assess such impairments, including how to deal with their episodic or fluctuating presentation.
No functional impairment resulting from a condition
Please refer to the discussion in (B) under 'Assessing impairments with no or negligible functional impact'.
Act reference: Social Security (Tables for the Assessment of Work-related Impairment for Disability Support Pension) Determination 2011 section 11 Assigning an impairment rating, Table 6 - Functioning related to Alcohol, Drug and Other Substance Use