The Guides to Social Policy Law is a collection of publications designed to assist decision makers administering social policy law. The information contained in this publication is intended only as a guide to relevant legislation/policy. The information is accurate as at the date listed at the bottom of the page, but may be subject to change. To discuss individual circumstances please contact Services Australia.

3.6.3.120 Guidelines to Table 12 - Visual Function

Summary

Table 12 is used to assess the functional impact of a condition when performing activities involving visual function.

Conditions causing impairment commonly assessed using Table 12

These include but are not limited to:

  • congenital visual impairment
  • diabetic retinopathy
  • glaucoma
  • retinitis pigmentosa
  • brain tumours
  • macular degeneration, and
  • cataracts

Diagnosis & evidence

The diagnosis of the condition must be made by an appropriately qualified medical practitioner with corroborating evidence from an ophthalmologist, optometrist, neurosurgeon or neurologist.

If a person uses any visual aids, such as glasses or contact lenses, they must be assessed on their ability to undertake activities listed in Table 12 while using any aids that they have and usually use.

In determining whether the person has received reasonable treatment for their impairment, consideration is to be given to the aids and equipment or other assistive devices they have and usually use. For example, if a person would benefit significantly from spectacles or contact lenses but chooses not to use them, consideration is to be given to whether they have received reasonable treatment and if their impairment can be considered reasonably treated and stabilised.

Where severe or extreme loss of visual function is evident or suspected, it must be recommended to the person that they undergo an assessment by a qualified ophthalmologist to determine whether they meet the criteria for permanent blindness (3.6.2.20) as per SSAct section 95.

A PERSON'S SELF-REPORTED SYMPTOMS MUST NOT BE SOLELY RELIED UPON in determining functional impacts of the person's condition (impairment). There must be corroborating medical evidence of a person's impairment.

Examples of corroborating evidence for the purposes of this Table include, but are not limited to:

  • a report from the person’s treating doctor
  • a report from a medical specialist (such as, ophthalmologist, ophthalmic surgeon) confirming diagnosis of conditions associated with vision impairment (such as, diabetic retinopathy, brain tumours, glaucoma, retinitis pigmentosa, macular degeneration, cataracts or congenital visual impairment)
  • results of vision assessments (such as, assessments done by an optometrist).

Act reference: SSAct section 95 Qualification for DSP - permanent blindness

Social Security (Tables for the Assessment of Work-related Impairment for Disability Support Pension) Determination 2023 Table 12 - Visual Function

Policy reference: SS Guide 3.6.2.20 Manifest grants & rejections for DSP, 3.6.2.40 Assessment of blindness for DSP, 3.6.3.03 Guidelines to the rules for applying the Impairment Tables - information that must be taken into account in applying the Tables, 3.6.3.05 Guidelines to the rules for applying the Impairment Tables - use of aids, equipment & assistive technology

Interpretation & application of relevant terms

Day-to-day activities - refers to the usual activities a person would expect to undertake during the normal course of their day. This will vary from individual to individual but may involve things, such as household duties (for example, cooking or cleaning), commuting to and from work, and undertaking work tasks.

The 5, 10, 20 and 30-point descriptors in Table 12 use the term 'assistance'. Assistance is defined in the instrument as assistance from another person, rather than any aids, equipment or assistive technology the person may use, unless specified otherwise (3.6.3.05).

Explanation: This interpretation of the term 'assistance' has been adopted in a number of decisions, including by the Federal Court in Secretary, Department of Social Services v Doherty (2022) FCA 1242.

Policy reference: SS Guide 3.6.3.05 Guidelines to the rules for applying the Impairment Tables - use of aids, equipment & assistive technology.

Determining the level of functional impact - rules

When establishing whether a person’s impairment causes no or minimal (0 points), mild (5 points), moderate (10 points), severe (20 points) or extreme (30 points) functional impact, each descriptor and all its paragraphs for an impairment rating level in the Table must be read as a whole.

The structure of the Tables requires that, in assessing the level of functional impact, a comparison must be made of all the descriptors for each level of impairment. This does not necessarily mean all descriptors must be met, but all must be considered to determine which descriptors apply to the person’s impairment.

The 30-point impairment rating allows for assessment of people who are not considered permanently blind but have an extreme level of vision impairment, which impacts their ability to mobilise and perform their daily activities.

The descriptors in each Table follow an incremental hierarchy, which is expressed among other things, by the use of terms indicating increasing levels of difficulty in performing certain activities. These levels are expressed as: no or minimal difficulty, mild difficulty, moderate difficulty, severe difficulty and extreme difficulty. Some Tables also represent an increase in frequency of symptoms, which is reflective of the impairment rating level.

When determining a person's limitations in relation to conducting 'work tasks', consideration must be given to a person's ability to undertake the task, regardless of whether or not it is part of work they do or have done previously. 'Work' is taken to refer to any work that exists in Australia, even if not within the person’s locally accessible labour market.

An assessment starts by considering the descriptors for 0 points, and if a person has more than 'no or minimal functional impact', the descriptors for 5 points are then considered, and so on for the descriptors for higher impairment levels. When it is determined that the person meets all the required descriptors for a certain impairment rating level, but does not meet all the required descriptors for the next impairment rating level, the appropriate impairment rating applicable to the person's circumstances will be the rating at which all the required descriptors are met.

Where several descriptors must apply for a rating the word 'and' links the descriptor. However, one of several descriptors may be sufficient for that rating when the word 'or' links the descriptors. In other cases, a prescribed number of descriptors may be required for that rating to apply (for example, ‘the person has moderate difficulty carrying out at least 4 of the following’).

Note 1: Individual descriptors or their parts must not be applied in isolation from one another.

In determining whether the required descriptors for a specific impairment level are met or not, ALL the descriptors for that level must be considered and applied as set out in the descriptor. NO descriptors or their parts are to be disregarded.

Note 2: The descriptors must be applied sequentially to allocate an impairment rating - the incremental hierarchy of descriptors MUST NOT be ignored. As mentioned above, the assessment process involves applying the 0-point descriptors first and continuing to apply the descriptors for higher impairment levels, until all the required descriptors for a certain impairment rating level are met.

Note 3: If the person's impairment does not meet all required descriptors for a certain impairment level, the person's impairment cannot be rated at that level or at any higher level.

Explanation: Where a person meets the required descriptors for 5 points but does not meet the required descriptors for 10 points, the correct impairment rating is 5 points. Their impairment CANNOT be assessed as moderate, severe or extreme for the purposes of DSP and 10, 20 or 30 points cannot be allocated.

Determination of the descriptor that best fits the person's impairment level must be based on the available medical evidence including the person's medical history, investigation results and clinical findings. A person's self-reported symptoms must not be solely relied on. An impairment rating must not be applied unless the person's self-reported functional impacts are consistent with and supported by the medical evidence available.

In determining the level of functional impact, care should be taken to distinguish between activities that the person does not do as opposed to activities that they have difficulty performing because of their impairment.

An activity listed under a descriptor cannot be taken as being able to be performed if it can only be performed once or rarely - the person needs to be able to usually perform such activity whenever they would normally attempt it or be required to perform it. Where an activity is usually required to be performed repetitively, a person who can only perform such activity once and is then unable to perform the activity again when required will be taken to be unable to perform this activity. Equally, where an activity is normally undertaken infrequently (for example, only once per day or once per week), a person who can perform that activity once per day or once per week, is not unable to perform the activity merely because they are unable to perform the activity repetitively or with greater frequency than would normally be required.

Consideration should be given to the fact that 2 people with the same level of vision loss can have different levels of independence and skills. Assumptions must not be made based solely on the clinical level of visual loss the person has.

A single impairment rating under Table 12 is to be determined, regardless of whether one or both eyes suffer vision loss.

When assessing episodic or fluctuating impairments and conditions, a rating must be assigned which reflects the overall functional impact of those impairments, taking into account the severity, duration and frequency of the episodes or fluctuations as appropriate (see 3.6.3.08 ‘Assessing impairments caused by episodic or fluctuating medical conditions’).

Act reference: Social Security (Tables for the Assessment of Work-related Impairment for Disability Support Pension) Determination 2023 section 13(2) In deciding whether an impairment has no …, section 13(1)(c) a rating must not be assigned …, Table 12 – Visual Function

Policy reference: SS Guide 3.6.3.02 Guidelines to the rules for applying the Impairment Tables - applying the Tables, 3.6.3.03 Guidelines to the rules for applying the Impairment Tables - information that must be taken into account in applying the Tables, 3.6.3.08 Guidelines to the rules for applying the Impairment Tables – assigning an impairment rating

Impairment Ratings for Table 12

0-point impairment rating level

The 0-point descriptor requires that the person have NO OR MINIMAL functional impact on activities involving visual function.

For this rating to be assigned, all descriptors at (1)(a), (b), (c) and (d) must be met.

5-point impairment rating level

The 5-point descriptor requires that the person have a MILD functional impact on activities involving visual function.

For this rating to be assigned, the person must meet at least one of the descriptors (1)(a), (1)(b), (1) (c), (1)(d), or (1)(e).

10-point impairment rating level

The 10-point descriptor requires that the person have a MODERATE functional impact on activities involving visual function.

For this rating to be assigned, the person must meet descriptors (1)(a), and (1)(b) and at least one of descriptors (1)(c)(i), (ii) or (iii), as well as both descriptors (2)(a) and (2)(b).

20-point impairment rating level

The 20-point descriptor requires that the person have a SEVERE functional impact on activities involving visual function.

For this rating to be assigned, the person must meet descriptors (1)(a), and (1)(b), and either descriptor (1)(c)(i) or (ii), and (1)(d) .

30-point impairment rating level

The 30-point descriptor requires that the person have an EXTREME functional impact on activities involving visual function.

For this rating to be assigned, the person must not be considered permanently blind, and meet both descriptors (1)(a) and (1)(b).

Where permanent blindness is suspected, the person should be considered against the criteria for permanent blindness (3.6.2.20) as per SSAct section 95.

Act reference: SSAct section 95 Qualification for DSP - permanent blindness

Social Security (Tables for the Assessment of Work-related Impairment for Disability Support Pension) Determination 2023 Table 12 - Visual Function

Policy Reference: SS Guide 3.6.2.20 Manifest grants & rejections for DSP, 3.6.2.40 Assessment of blindness for DSP

Avoiding double counting

Double counting of impairments must be avoided (see 3.6.3.06 ‘Rating multiple conditions with common impairments & double counting’).

Example: A person has moderate difficulties seeing people’s faces and picking up on visual facial cues to know whether they have been understood during conversations. Where this impact has already been considered when assessing the person’s functional impairments under Table 12, an additional rating on Table 8 – Communication function should not be applied.

Policy reference: SS Guide 3.6.3.06 Guidelines to the rules for applying the Impairment Tables - selecting the applicable Table & assessing impairments, 3.6.3.80 Guidelines to Table 8 - Communication Function.

Examples of Table 12 assessment

Example: A 50-year old person was diagnosed with glaucoma several years ago. They have undergone surgery for this condition which has slowed down the progression of the disease but medical evidence states that their current symptoms will not improve and will eventually get worse. This person has lost much of their peripheral vision and has very limited vision to the sides when looking straight ahead. They have difficulty seeing bus route numbers and reading normal sized print. They are not able to drive but do regularly use public transport independently. The person sometimes needs to ask someone to inform them of the numbers of approaching buses. They use special computer software to magnify computer screen displays and read text on screen out loud.

The condition is considered diagnosed, reasonably treated and stabilised. Under Table 12, this person would be assigned an impairment rating of 10 points due to the moderate functional impact the condition has on their ability to function. Under the 10-point descriptor this person would meet (1)(a), (1)(b) and(1)(c)(i) as well as (2)(a) and (2)(b).

Impairments that should not be assessed using Table 12

Care should be taken when assessing impairment in vision which is not due to functions of the eye or visual tracts. The assessment should be undertaken on the table which best represents the functional impairment of the individual.

For example, cases of 'functional blindness', where there is no identified anatomical or physiological abnormality of the eyes, optic nerves, visual tracts or occipital lobes of the brain. Consideration should be given to whether this condition may be rated under Table 5 - Mental Health Function and/or Table 12, if the condition is determined to be diagnosed, reasonably treated and stabilised. The HPAU can be contacted for further information or clarification.

Act reference: Social Security (Tables for the Assessment of Work-related Impairment for Disability Support Pension) Determination 2023 Table 5 – Mental Health Function, Table 12 - Visual Function

Policy reference: SS Guide 3.6.3.02 Guidelines to the rules for applying the Impairment Tables - applying the Tables, 3.6.3.50 Guidelines to Table 5 - Mental Health Function

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