Key Takeaways:
- Social Security may use school records when evaluating how a child functions across six domains.
- Form SSA-5665 gathers a teacher’s observations about the child’s functioning at school.
- IEPs, evaluations, attendance records, and behavior reports may provide useful evidence.
- A Massachusetts disability lawyer can help identify relevant school records and explain how they support the claim.
When a new school year begins, parents often review IEPs, schedule meetings, and receive updated information about how their child is functioning in the classroom. A Massachusetts disability lawyer can help families determine which of those school records may support a child’s Supplemental Security Income (SSI) claim and whether additional information should be requested from teachers or school officials.
Medical evidence remains essential, but SSA also considers school records and observations from teachers and others familiar with the child’s day-to-day functioning. IEPs, evaluation reports, attendance records, and teacher questionnaires may help show how a child’s condition affects learning, concentration, behavior, self-care, mobility, and physical well-being.
Table of Contents
- How SSA Evaluates Disability in Children
- The Teacher Questionnaire (Form SSA-5665)
- School Records That Show a Child’s Educational Needs
- Attendance Records and Behavioral Incident Reports
- Conditions Where School Evidence May Be Especially Useful
- Gathering School Evidence for an SSI Claim
- Working With a Boston Disability Lawyer on a Child's SSI Claim
How SSA Evaluates Disability in Children
Social Security does not use the same five-step process for children that it uses for adults. For a child under age 18, SSA determines whether the child has a medically determinable physical or mental impairment, or a combination of impairments, that causes marked and severe functional limitations and has lasted or is expected to last continuously for at least 12 months or result in death.
After determining that the child has a severe impairment or combination of impairments, SSA considers whether the condition meets, medically equals, or functionally equals a listed impairment. Functional equivalence is evaluated across six domains:
- Acquiring and using information
- Attending and completing tasks
- Interacting and relating with others
- Moving about and manipulating objects
- Caring for yourself
- Health and physical well-being
To functionally equal the listings, a child generally must have a marked limitation in at least two domains or an extreme limitation in one domain.
Because children spend substantial time at school, school records may provide useful observations about several domains, including learning, completing tasks, interacting with others, and, when relevant, self-care or physical functioning. School records may show how a child performs over time, what support the child receives, and whether functioning differs across classes or school settings.
The Teacher Questionnaire (Form SSA-5665)
SSA’s Teacher Questionnaire, Form SSA-5665, gathers observations about how a child functions in school. Because teachers and other school professionals may observe the child during assignments, transitions, and social situations, the form can provide school-based information that complements the medical and other evidence in the claim.
What the Teacher Questionnaire Asks
Form SSA-5665 asks about the child’s activities and functioning in areas that correspond closely to SSA’s six domains. These include acquiring and using information, attending and completing tasks, interacting and relating with others, moving about and manipulating objects, caring for oneself, and health and physical well-being.
The person completing the form is also asked to compare the child’s functioning with that of same-age children who do not have impairments. Specific examples, such as difficulty staying on task, needing repeated instructions, requiring extra supervision, or struggling with peers, can help SSA understand how the child functions during the school day.
Who Should Complete Form SSA-5665
The questionnaire should be completed by a school professional with enough direct experience to provide informed observations. Depending on the child’s educational history and program, that may be a current or former classroom teacher, special education teacher, resource-room instructor, or another school professional with direct knowledge of the child’s functioning.
SSA or Disability Determination Services may request the questionnaire directly from the school. A parent or attorney may contact the office handling the claim to determine whether SSA or DDS has requested a questionnaire and whether information from a particular teacher or school professional would assist the review.
How the Questionnaire Supports the SSI Claim
A detailed Teacher Questionnaire may help SSA:
- Understand how the child functions during instruction, transitions, and social activities
- Compare school observations with information from parents, medical providers, and other sources
- Identify accommodations, individual support, modified assignments, or curriculum modifications
- Evaluate the child’s functioning in comparison with same-age children who do not have impairments
The form does not establish SSI eligibility by itself. It provides school-based evidence that SSA can consider with medical records, educational plans, evaluations, and other information in the claim.
School Records That Show a Child’s Educational Needs
Different school records provide different types of evidence about a child’s academic performance, daily functioning, and need for support. When available, IEPs, 504 plans, and school evaluations can provide complementary information about how the child functions in the classroom and what assistance the school provides.
Individualized Education Programs
An Individualized Education Program (IEP) documents a child’s eligibility for special education services and describes the child’s current performance, educational needs, goals, services, and accommodations. Although an IEP does not establish eligibility for SSI, it may provide relevant evidence about the child’s functioning.
An IEP typically includes:
- The child's current levels of academic and functional performance
- Measurable annual goals addressing the child’s educational needs
- Special education and related services that the school provides
- Accommodations and modifications required for the child to access the curriculum
- Transition services and postsecondary goals, when required, based on the student’s age
504 Plans
A 504 plan may document accommodations or services provided because a physical or mental impairment substantially limits one or more major life activities.
Depending on the student, the underlying impairment may substantially limit learning, concentrating, communicating, mobility, or another major life activity, and the plan identifies the accommodations or services the school will provide. Accommodations may include extended time, preferential seating, breaks, assistive technology, or health-related supports.
Both 504 plans and IEPs may help SSA understand what supports the school provides and how the child functions with those supports in place.
School Evaluations
Triennial evaluations and initial eligibility evaluations may also provide useful evidence. Depending on the reason for the evaluation, school assessments may include cognitive or achievement testing, behavioral observations, rating scales, language testing, or measures of adaptive functioning.
Attendance Records and Behavioral Incident Reports
Two categories of school records that parents often overlook are attendance logs and behavioral or incident reports.
School Attendance
Attendance records may support the claim when they show frequent disability-related absences, early dismissals, or missed instructional time, particularly when the reasons are documented by medical or school records. Records showing the frequency and reasons for missed school may help SSA assess the practical effects of the child’s condition and treatment.
Incident Reports
Behavioral and incident reports may document events such as emotional outbursts, physical interventions, removal from class, safety concerns, or conflicts with peers. When the records connect these events to the child’s symptoms or limitations, they may provide specific examples of difficulties with self-regulation, interaction, task completion, or safety.
This information may be particularly relevant for children with autism, ADHD, trauma-related symptoms, or other behavioral and emotional conditions.
Conditions Where School Evidence May Be Especially Useful
School records may be especially useful for conditions whose effects on learning, behavior, concentration, communication, or social interaction are regularly observed in educational settings. These include:
- Attention-deficit/hyperactivity disorder (ADHD)
- Autism spectrum disorder
- Learning disabilities, intellectual disabilities, and processing disorders
- Anxiety, depression, PTSD, and other childhood mental health conditions
- Epilepsy, traumatic brain injury, and other neurological conditions that affect school attendance or functioning
A medical appointment may provide only a brief view of the child’s functioning, while school records may describe patterns observed repeatedly in academic and social settings. Records created over multiple grading periods or school years may provide a broader view of the child’s functioning than a single appointment.
Gathering School Evidence for an SSI Claim
Parents can request relevant records at any point before or during an SSI claim. The start of a school year may be a useful reminder to obtain updated plans, evaluations, progress reports, and contact information for current teachers.
Whether the family is preparing an initial claim or responding to a denial, relevant records may include:
- The most recent IEP or 504 Plan, including all attachments and evaluation summaries
- Recent school evaluations and any earlier evaluations that remain relevant to the child’s condition or developmental history
- Attendance records covering the period relevant to the claim, including explanations for disability-related absences when available
- Any behavioral intervention plans or incident documentation
- Progress reports and report cards that show performance relative to grade-level expectations
- Contact information for teachers or specialists familiar with the child, along with a completed Form SSA-5665, when one has been requested or obtained
FERPA generally gives parents the right to inspect and review their child’s education records within a reasonable time, but no later than 45 days after the school receives the request; state law may require access sooner. FERPA does not always require the school to provide copies, although copies may be required when circumstances would otherwise prevent meaningful access.
Working With a Boston Disability Lawyer on a Child's SSI Claim
A child’s SSI claim requires medical evidence as well as detailed information about how the child functions at home, at school, and in the community. Keefe Disability Law represents Massachusetts families in child SSI claims and understands how teacher observations, educational plans, and school evaluations may fit into SSA’s functional analysis.
We can help identify relevant records, coordinate requests for school information when appropriate, and explain how the evidence relates to the areas of functioning SSA evaluates.
Because school records and teacher responses may take time to obtain, families should begin gathering relevant evidence as early as reasonably possible. Families may also submit relevant updated evaluations, educational plans, and teacher observations while the claim or appeal is pending.