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Social Security Weighs Major Changes to Disability Rules

Advocates say regulations could affect hundreds of thousands of older adults sidelined from work by illness or injury


older adults work on laptops in front of a background of a social security card
AARP (Getty Images,3)

Potential changes in how the Social Security Administration (SSA) evaluates disability claims could deny benefits to hundreds of thousands of people and disproportionately affect older adults, according to a new study.

The September analysis by the Urban Institute, a Washington, D.C.–based think tank, reports that the SSA is drafting rule changes that could lessen the weight the agency gives to age in considering applications for Social Security Disability Insurance (SSDI) and Supplemental Security Income (SSI). Those are the two Social Security–administered benefits for people whose ability to work is limited by a severe medical condition.

The SSA considers a bevy of factors in determining whether to grant or deny a disability claim, including the availability of jobs that a particular applicant might be able to perform and how well that person might be able to adapt to other jobs based on age, education and other factors.

If the SSA gives age less weight, older people would be less likely to qualify, says Jack Smalligan, a senior policy fellow at the Urban Institute and the author of the new report.

The SSA filed federal paperwork earlier this year signaling its intent to propose new rules on disability determinations that it said would make the process more efficient. Those draft rules have not yet been published, but Smalligan says he based his analysis on changes to the disability process that were considered during the first Trump administration, as reported by news outlets at the time.

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He found that if those changes were implemented, eligibility for SSDI among new applicants could decrease by as much as 20 percent overall and up to 30 percent for workers ages 50-plus. (The study says the impact on eligibility for SSI, which also has financial criteria, was unclear.)

Policies that reduce SSDI eligibility by just 10 percent would result in about 750,000 fewer people receiving benefits for all or part of the next decade, including about 80,000 widowed spouses and children receiving benefits on the record of a late partner or parent, according to the report.

That would represent “the largest cut to the Social Security disability program in the history of the program,” says Rebecca Vallas, CEO of the National Academy of Social Insurance, which funded the Urban Institute report. “Just the sheer scale of how many older workers would be affected is incredibly alarming.”

Details still pending

So far, the SSA has not published any planned rule changes, only a notification to the federal Office of Information and Regulatory Affairs that it will be “proposing improvements to the disability adjudication process.” Barton Mackey, an SSA spokesperson, says assessment of potential impacts from those changes is premature.

“Speculation on any proposed rule prior to it being published as part of the standard review process only serves to misguide public discourse and stoke fear in those who rely on disability benefits for economic stability,” he says.

“Once a proposal is fully developed, it will be shared publicly through the standard rulemaking process, with a public comment period,” Mackey adds. “As with any rulemaking, we will consider and analyze public comments before deciding whether to finalize the rule.”

The SSA regulatory filing states that the new rules aim to “ensure our disability program remains current and can be more efficiently administered” and that they will help “serve our customers and preserve the [Social Security] trust funds.”

The two trust funds, one for retirement and survivor benefits and the other for disability benefits, hold surplus revenue that Social Security uses to meet its annual payment obligations. SSA actuaries project that under current law the retirement and survivors fund could run short as soon as late 2032.

While the disability fund is on a stronger financial footing, in the past Congress has shifted money from one fund to address shortfalls in the other, meaning savings on disability benefits could be put toward closing the overall gap. Smalligan’s analysis found that over 10 years, a 10 percent reduction in eligible disability claimants could reduce the total amount of benefits Social Security pays out by $82 billion.

In addition to addressing age, the SSA is expected to replace the decades-old directory of jobs used in decisions about who qualifies for disability with occupational data from the U.S. Bureau of Labor Statistics. The current list is widely viewed by advocates and policy analysts as badly outdated, and replacing it has “bipartisan support,” the Urban Institute report notes.

Taken together, the changes “will involve nuanced judgments about how education and past work experience affect an individual’s ability to work given their age, and whether enough jobs are available that match the individual’s functional capabilities,” the report says.

Changing job landscape

Currently, the SSA divides disability applicants into age classifications to help assess their ability to adjust to other work: “younger person” (under 50), “closely approaching advanced age” (50-54), “advanced age” (55-plus) and “closely approaching retirement age” (60-plus).

Mark Warshawsky, who as an SSA deputy commissioner during the first Trump administration spearheaded its efforts to overhaul disability policies, defended the potential changes in an Oct. 22 post on the website of the American Enterprise Institute, where he is now a senior fellow.

The job listings “omit entirely the mental requirements for work and many newer job categories, particularly in the service and technology sectors. They also fail to reflect the general trend toward less strenuous physical work across all sectors,” Warshawsky wrote.

He went on: “The rules embody the view that middle-age workers (denominated as ‘closely approaching advanced age’ at 50) cannot adjust to new types of jobs, especially if they have modest educations, performed only physical labor and are unskilled — even when new work is available that is sedentary and requires little training.”

Bill Sweeney, AARP’s senior vice president of government affairs, says AARP is “watching this very closely” and will weigh in once the SSA unveils a formal proposal.

“If it’s a threat, we will take that seriously,” he says. “This is AARP’s population, and we’re very concerned about making it harder to get help when they need it.”

Sweeney also says that there is “no question that some of the job categories are outdated” but that any new age rules must rely on “clear justifications and solid evidence to make sure older workers are protected” in decisions on benefits.

“If you’re 58 years old and a roofer and you get hurt, the idea that people can work an office job as a disabled construction worker or a roofer needs to be grounded in the reality of people’s lives,” he says.

Smalligan says he worries that if more older adults are denied Social Security disability benefits, they might claim retirement benefits at the minimum age of 62. That means accepting a benefit up to 30 percent lower than what they’d get by claiming at full retirement age (67 for people born in 1960 and after).

SSDI payments, regardless of when you start them, are based on your full retirement age benefit amount, and they automatically convert to a retirement benefit when you reach full retirement age.

“These older workers denied disability may be in a position where they’re between a rock and a hard place to take early retirement because they don’t have a choice,” says attorney Amy Marinacci, a Social Security specialist with the nonprofit Legal Council for Health Justice, based in Chicago. “Then it’s a 30 percent reduction in benefits for life.”

Denial rate rising

In the meantime, advocates already see a downward trend in SSDI and SSI benefit claims and awards.

A separate Urban Institute analysis of state-level data, also conducted by Smalligan, found that 163,000 fewer disability applications were submitted to Social Security in the first 10 months of the fiscal year 2025 than over the same period a year earlier, a 7 percent decline.

The SSA processed 8 percent more initial disability claims in 2025, reducing a backlog the agency says reached a record 1.2 million cases last year. But the share of claims approved fell by nearly 3 percentage points, from 38.7 percent in fiscal year 2024 to an average of 36 percent, a drop the Urban Institute study terms “sharper than usual.”

The report calls on the SSA to analyze claims data to assess why applications are down and denials up, but it notes that the agency’s push this year to shrink its workforce may have removed "many of the staff who would have been responsible for analyzing these potentially concerning trends.”

As for the prospective disability proposal, Kathleen Romig, director of Social Security and disability policy at the Center on Budget and Policy Priorities, says it’s unclear when SSA may unveil any new rules. She says advocates had anticipated a release by the end of the year, but the timetable could be upended by the government shutdown.

Once the rule is published, it will be subject to a public comment period, where individuals and advocacy groups can weigh in. “That’s a lengthy process, especially for a rule that gets a lot of comments,” says Romig. “A rule like this is high profile and will raise a lot of comments.”

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