The SSA has issued notice of SSR 19-4p, which provides guidance
on how the agency establishes that a person has a medically determinable
impairment (MDI) of a primary headache disorder and how it evaluates
primary headache disorders in disability claims under Titles II and
XVI of the Social Security Act. The notice became effective on August
In this SSR, the SSA explains how it establishes a primary headache
disorder as a medically determinable impairment and how it evaluates
claims involving primary headache disorders. Question 1, below, explains
what primary headache disorders are. Question 2 explains how the medical
community diagnoses primary headache disorders. Questions 3, 4, 5,
and 6 provide the ICHD-3 diagnostic criteria for four common types
of primary headache disorders. Question 7 explains how the SSA establishes
a primary headache disorder as an MDI. Questions 8 and 9 address how
the agency evaluates primary headache disorders in the sequential
evaluation process. (Although this SSR only provides information about
four common types of primary headache disorders, diagnostic criteria
for other types of primary headache disorders can be found in the
What are primary headache disorders?
How does the medical community diagnose a primary headache
What are the ICHD-3 diagnostic criteria for migraine with
What are the ICHD-3 diagnostic criteria for migraine without
What are the ICHD-3 diagnostic criteria for chronic tension-type
What are the ICHD-3 diagnostic criteria for cluster headache
(a type of trigeminal autonomic cephalalgias)?
How does the SSA establish a primary headache disorder
as an MDI?
How does the SSA evaluate an MDI of a primary headache
disorder under the Listing of Impairments?
The SSA also considers the extent to which the person's impairment-related
symptoms are consistent with the evidence in the record. For example,
symptoms of a primary headache disorder, such as photophobia, may
cause a person to have difficulty sustaining attention and concentration.
Consistency and supportability between reported symptoms and objective
medical evidence is key in assessing the RFC.
For further information, contact Cheryl A. Williams, Office of
Medical Policy, Social Security Administration, 6401 Security Boulevard,
Baltimore, Maryland 21235-6401, (410) 965- 1020. See 84 Fed.
Reg. 44667, August 26, 2019.
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