Require Equal Disability and Insurance Recognition for Functional Neurological Disorder
The Issue
To the United States Congress, the Social Security Administration, the U.S. Departments of Labor and Health and Human Services, and state insurance regulators:
We call for stronger and more consistent recognition of Functional Neurological Disorder (FND) and fibromyalgia in disability determinations, workplace protections, health programs, and private disability and critical-illness insurance.
Functional Neurological Disorder (FND) is a genuine neurological disorder that can affect movement, sensation, speech, vision, cognition, and a person’s ability to function independently. Symptoms can include weakness or paralysis, non-epileptic seizures, tremors, difficulty walking, pain, fatigue, and cognitive problems.
Fibromyalgia is a medically recognized chronic disorder that can cause widespread pain, severe fatigue, sleep disturbances, cognitive difficulties, and substantial limitations in daily activities.
For some people, these conditions produce limitations comparable in severity to those caused by multiple sclerosis, stroke, epilepsy, and other recognized neurological or systemic disorders. Nevertheless, people with FND or fibromyalgia frequently report that their symptoms are misunderstood, minimized, or evaluated inconsistently when they apply for disability benefits or insurance coverage.
A condition should not be disregarded merely because its symptoms may fluctuate, conventional testing does not fully measure its effects, or the person sometimes appears well during a brief appointment. Disability decisions should consider whether a person can function reliably, safely, repeatedly, and on a sustained basis not simply whether the person can perform an activity once.
WHAT WE ARE ASKING FOR
We ask Congress and the responsible federal and state agencies to take the following actions:
Establish specific Social Security guidance for FND.
The Social Security Administration should issue a Social Security Ruling or comparable national policy explaining how FND can be established as a medically determinable impairment and how related functional limitations must be evaluated.
The guidance should recognize appropriate evidence from neurologists and other qualified professionals, positive clinical signs used to diagnose FND, treatment history, symptom frequency and duration, medication effects, and documented limitations involving mobility, communication, concentration, stamina, attendance, and activities of daily living.
Strengthen and consistently apply fibromyalgia protections.
The Social Security Administration already recognizes fibromyalgia as a potentially medically determinable impairment under Social Security Ruling 12-2p. However, recognition on paper does not always produce consistent decisions.
SSA should improve training, quality review, and accountability so adjudicators apply SSR 12-2p consistently. A person’s claim should not be rejected simply because fibromyalgia symptoms are variable or because laboratory and imaging tests do not measure the full severity of pain, fatigue, cognitive difficulties, or reduced stamina.
Create a clear disability-evaluation framework.
SSA should determine, with input from medical specialists and disability organizations, whether FND and fibromyalgia require dedicated entries in the Listing of Impairments or another equally effective evaluation framework.
Until then, SSA should provide clear instructions for determining medical equivalence and residual functional capacity. Evaluators must consider the combined effects of all medically determinable impairments and whether the claimant can sustain full-time work on a regular and continuing basis.
Require fair and timely private disability-insurance reviews.
The Department of Labor and state insurance regulators should strengthen standards governing employer-sponsored and individually purchased disability policies.
Insurers should be required to:
• Use reviewers with appropriate knowledge of FND, fibromyalgia, and chronic neurological or pain disorders.
• Evaluate documented functional limitations rather than relying only on the absence of traditional laboratory or imaging findings.
• Consider the combined effects of multiple conditions.
• Explain denials in clear and specific language.
• Identify the evidence considered and the policy provisions applied.
• Provide a meaningful opportunity to appeal.
• Complete reviews and appeals within enforceable time limits.
• Avoid unreasonable or repetitive demands for evidence that is not medically appropriate for the condition.
These protections should reinforce the requirement for a full and fair review under the Employee Retirement Income Security Act for covered benefit plans and establish comparable protections for policies regulated under state law.
Improve critical-illness and related insurance transparency.
Critical-illness policies often cover only specifically named diagnoses. Regulators should require insurers to state clearly whether FND and fibromyalgia are included or excluded and should prevent advertising that could mislead consumers about the scope of coverage.
Congress and regulators should also examine standards for optional coverage when FND or fibromyalgia causes catastrophic, long-term functional impairment comparable to conditions already covered by a policy. Comparable severity deserves a comparable opportunity for protection.
Enforce existing disability-rights laws.
The Americans with Disabilities Act and Section 504 of the Rehabilitation Act protect qualified people whose impairments substantially limit major life activities. These protections can apply to people with FND or fibromyalgia when the legal criteria are met.
Government agencies should provide education and enforcement guidance so employers, public programs, and covered organizations understand that episodic, fluctuating, and non-visible disabilities can still require reasonable accommodations and protection from discrimination.
Include affected communities and specialists in policymaking.
SSA, the Department of Labor, HHS, Congress, and insurance regulators should consult neurologists, rheumatologists, pain specialists, rehabilitation professionals, researchers, disability advocates, and people living with these conditions.
Policy should be based on current medical knowledge and the real functional effects of these disorders—not stigma, outdated assumptions, or the mistaken belief that symptoms are unimportant when routine testing is normal.
Improve professional education and public reporting.
Federal agencies should support training for disability adjudicators, insurance reviewers, vocational experts, and health professionals. Agencies should also collect and publish appropriate, privacy-protected information about outcomes, appeals, processing times, and reversals involving FND and fibromyalgia.
Transparency would help identify inconsistent practices and determine where additional guidance is needed.
FAIR RECOGNITION—NOT AUTOMATIC APPROVAL
This petition does not ask for automatic benefits based solely on a diagnosis. Disability programs must evaluate credible medical evidence, severity, duration, and functional limitations in each case.
We are asking for something fair and achievable: people with properly documented FND or fibromyalgia must receive the same serious, informed, timely, and evidence-based consideration provided to people with other potentially disabling medical disorders.
No claimant should be denied because an evaluator lacks training about the condition. No person should have to overcome stigma before the evidence is considered. No insurer or government agency should substitute assumptions about an illness for an individualized assessment of the person’s ability to function.
CALL TO ACTION
We urge Congress to hold hearings and sponsor legislation where statutory changes are needed. We urge SSA to develop FND-specific national guidance and strengthen implementation of its existing fibromyalgia ruling. We urge the Departments of Labor and Health and Human Services and state insurance regulators to establish fair, transparent, and medically informed standards.
Please sign this petition to support equal recognition, consistent evaluation, meaningful appeal rights, and fair access to disability and insurance protections for people living with Functional Neurological Disorder and fibromyalgia.
Recognition is not special treatment. It is equal treatment based on medical evidence and real functional limitations.
SUPPORTING INFORMATION AND EXISTING LAW
• Social Security Administration: Fibromyalgia Evaluation Policy—SSR 12-2p
https://www.ssa.gov/OP_Home/rulings/di/01/SSR2012-02-di-01.html
• Social Security Administration: Disability Evaluation Under Social Security (“Blue Book”)
https://www.ssa.gov/disability/professionals/bluebook/
• U.S. Department of Justice: Americans with Disabilities Act
https://www.ada.gov/
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The Issue
To the United States Congress, the Social Security Administration, the U.S. Departments of Labor and Health and Human Services, and state insurance regulators:
We call for stronger and more consistent recognition of Functional Neurological Disorder (FND) and fibromyalgia in disability determinations, workplace protections, health programs, and private disability and critical-illness insurance.
Functional Neurological Disorder (FND) is a genuine neurological disorder that can affect movement, sensation, speech, vision, cognition, and a person’s ability to function independently. Symptoms can include weakness or paralysis, non-epileptic seizures, tremors, difficulty walking, pain, fatigue, and cognitive problems.
Fibromyalgia is a medically recognized chronic disorder that can cause widespread pain, severe fatigue, sleep disturbances, cognitive difficulties, and substantial limitations in daily activities.
For some people, these conditions produce limitations comparable in severity to those caused by multiple sclerosis, stroke, epilepsy, and other recognized neurological or systemic disorders. Nevertheless, people with FND or fibromyalgia frequently report that their symptoms are misunderstood, minimized, or evaluated inconsistently when they apply for disability benefits or insurance coverage.
A condition should not be disregarded merely because its symptoms may fluctuate, conventional testing does not fully measure its effects, or the person sometimes appears well during a brief appointment. Disability decisions should consider whether a person can function reliably, safely, repeatedly, and on a sustained basis not simply whether the person can perform an activity once.
WHAT WE ARE ASKING FOR
We ask Congress and the responsible federal and state agencies to take the following actions:
Establish specific Social Security guidance for FND.
The Social Security Administration should issue a Social Security Ruling or comparable national policy explaining how FND can be established as a medically determinable impairment and how related functional limitations must be evaluated.
The guidance should recognize appropriate evidence from neurologists and other qualified professionals, positive clinical signs used to diagnose FND, treatment history, symptom frequency and duration, medication effects, and documented limitations involving mobility, communication, concentration, stamina, attendance, and activities of daily living.
Strengthen and consistently apply fibromyalgia protections.
The Social Security Administration already recognizes fibromyalgia as a potentially medically determinable impairment under Social Security Ruling 12-2p. However, recognition on paper does not always produce consistent decisions.
SSA should improve training, quality review, and accountability so adjudicators apply SSR 12-2p consistently. A person’s claim should not be rejected simply because fibromyalgia symptoms are variable or because laboratory and imaging tests do not measure the full severity of pain, fatigue, cognitive difficulties, or reduced stamina.
Create a clear disability-evaluation framework.
SSA should determine, with input from medical specialists and disability organizations, whether FND and fibromyalgia require dedicated entries in the Listing of Impairments or another equally effective evaluation framework.
Until then, SSA should provide clear instructions for determining medical equivalence and residual functional capacity. Evaluators must consider the combined effects of all medically determinable impairments and whether the claimant can sustain full-time work on a regular and continuing basis.
Require fair and timely private disability-insurance reviews.
The Department of Labor and state insurance regulators should strengthen standards governing employer-sponsored and individually purchased disability policies.
Insurers should be required to:
• Use reviewers with appropriate knowledge of FND, fibromyalgia, and chronic neurological or pain disorders.
• Evaluate documented functional limitations rather than relying only on the absence of traditional laboratory or imaging findings.
• Consider the combined effects of multiple conditions.
• Explain denials in clear and specific language.
• Identify the evidence considered and the policy provisions applied.
• Provide a meaningful opportunity to appeal.
• Complete reviews and appeals within enforceable time limits.
• Avoid unreasonable or repetitive demands for evidence that is not medically appropriate for the condition.
These protections should reinforce the requirement for a full and fair review under the Employee Retirement Income Security Act for covered benefit plans and establish comparable protections for policies regulated under state law.
Improve critical-illness and related insurance transparency.
Critical-illness policies often cover only specifically named diagnoses. Regulators should require insurers to state clearly whether FND and fibromyalgia are included or excluded and should prevent advertising that could mislead consumers about the scope of coverage.
Congress and regulators should also examine standards for optional coverage when FND or fibromyalgia causes catastrophic, long-term functional impairment comparable to conditions already covered by a policy. Comparable severity deserves a comparable opportunity for protection.
Enforce existing disability-rights laws.
The Americans with Disabilities Act and Section 504 of the Rehabilitation Act protect qualified people whose impairments substantially limit major life activities. These protections can apply to people with FND or fibromyalgia when the legal criteria are met.
Government agencies should provide education and enforcement guidance so employers, public programs, and covered organizations understand that episodic, fluctuating, and non-visible disabilities can still require reasonable accommodations and protection from discrimination.
Include affected communities and specialists in policymaking.
SSA, the Department of Labor, HHS, Congress, and insurance regulators should consult neurologists, rheumatologists, pain specialists, rehabilitation professionals, researchers, disability advocates, and people living with these conditions.
Policy should be based on current medical knowledge and the real functional effects of these disorders—not stigma, outdated assumptions, or the mistaken belief that symptoms are unimportant when routine testing is normal.
Improve professional education and public reporting.
Federal agencies should support training for disability adjudicators, insurance reviewers, vocational experts, and health professionals. Agencies should also collect and publish appropriate, privacy-protected information about outcomes, appeals, processing times, and reversals involving FND and fibromyalgia.
Transparency would help identify inconsistent practices and determine where additional guidance is needed.
FAIR RECOGNITION—NOT AUTOMATIC APPROVAL
This petition does not ask for automatic benefits based solely on a diagnosis. Disability programs must evaluate credible medical evidence, severity, duration, and functional limitations in each case.
We are asking for something fair and achievable: people with properly documented FND or fibromyalgia must receive the same serious, informed, timely, and evidence-based consideration provided to people with other potentially disabling medical disorders.
No claimant should be denied because an evaluator lacks training about the condition. No person should have to overcome stigma before the evidence is considered. No insurer or government agency should substitute assumptions about an illness for an individualized assessment of the person’s ability to function.
CALL TO ACTION
We urge Congress to hold hearings and sponsor legislation where statutory changes are needed. We urge SSA to develop FND-specific national guidance and strengthen implementation of its existing fibromyalgia ruling. We urge the Departments of Labor and Health and Human Services and state insurance regulators to establish fair, transparent, and medically informed standards.
Please sign this petition to support equal recognition, consistent evaluation, meaningful appeal rights, and fair access to disability and insurance protections for people living with Functional Neurological Disorder and fibromyalgia.
Recognition is not special treatment. It is equal treatment based on medical evidence and real functional limitations.
SUPPORTING INFORMATION AND EXISTING LAW
• Social Security Administration: Fibromyalgia Evaluation Policy—SSR 12-2p
https://www.ssa.gov/OP_Home/rulings/di/01/SSR2012-02-di-01.html
• Social Security Administration: Disability Evaluation Under Social Security (“Blue Book”)
https://www.ssa.gov/disability/professionals/bluebook/
• U.S. Department of Justice: Americans with Disabilities Act
https://www.ada.gov/
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Petition created on September 17, 2026