Child listing 111.09, the RFC form, and how SSA evaluates speech disorders

Last updated 2026-07-10

What is SSA Listing 111.09 and which children does it cover?

Listing 111.09 covers communication disorders in children caused by a central nervous system abnormality, specifically aphasia (loss or impairment of language) and dysarthria (motor speech impairment from neurological damage). To qualify, the disorder has to be severe enough to persist despite treatment and must have lasted, or be expected to last, at least 12 continuous months. It sits in Part B of SSA's Blue Book, the childhood listings, under the neurological category that starts at 111.00. ^[1]

Aphasia means the child has real trouble understanding or producing language, well past a simple speech delay. Dysarthria means the child's speech muscles don't work right because of a neurological problem like cerebral palsy or a stroke. A child with a mild articulation issue or stuttering that isn't tied to a CNS condition won't meet this listing.

Here's the part parents miss. The problem has to trace back to the brain or nervous system. Speech that's delayed for other reasons gets evaluated somewhere else.

Children evaluated under 111.09 are almost always under 18 and applying for Supplemental Security Income (SSI), because SSDI needs work credits that children don't have. If you want the difference between the two programs, start with our What Is SSI? Supplemental Security Income Explained overview.

One structural note worth keeping in mind: Listing 111.09 borrows medical standards from Listing 11.09, the adult communication disorder listing. Reading both helps when you're deciding what records to gather.

What exactly does Listing 111.09 require to qualify?

Listing 111.09 requires a documented communication disorder (aphasia or dysarthria) resulting from a central nervous system abnormality, with findings consistent with that neurological origin. SSA also wants the condition to cause marked limitations in age-appropriate cognitive or communicative function, or in the child's ability to complete age-appropriate activities of daily living. ^[1]

The word "marked" carries the weight. SSA defines a marked limitation as one that seriously interferes with functioning. It's more than moderate but doesn't have to be extreme. A child who can talk but whose speech is largely unintelligible to unfamiliar adults, or who can't join classroom conversations, is usually in marked territory.

Children get evaluated differently from adults. For a child, the question isn't whether they can work. It's whether the impairment causes marked or extreme limits in the six "domains of functioning": acquiring and using information; attending and completing tasks; interacting and relating with others; moving about and manipulating objects; caring for yourself; and health and physical well-being. ^[2] A communication disorder hits the first and third domains hardest.

To meet or equal 111.09, a child generally needs marked limitations in at least two domains, or an extreme limitation in one. The record also has to show the condition comes from a CNS abnormality, not from a structural speech problem, hearing loss, or a general developmental delay by itself.

What is the child RFC form and how does it apply to Listing 111.09 cases?

The child RFC (Residual Functional Capacity) assessment is what SSA's medical or psychological consultant completes when a child's impairment doesn't meet or equal a Blue Book listing but still causes significant functional limits. For a 111.09 case, if SSA decides the listing isn't fully met, they move to this analysis. ^[3]

The child version isn't a single standardized paper form the way the adult RFC forms are. SSA uses the childhood domain framework from its regulations at 20 CFR 416.926a to document how the child functions in each of the six domains. The state Disability Determination Services examiner and consulting physician rate each domain as no limitation, less than marked, marked, or extreme. ^[2]

What do examiners actually look at? They compare what the child can do against other kids the same age without the impairment. They look at how the condition affects school performance and behavior, whether the child needs extra help or extra time, and what teachers, parents, and therapists report. A speech-language pathologist's evaluation carries real weight here because it gives SSA numbers (percentile ranks on standardized tests, intelligibility scores) instead of just a narrative.

Think of the child RFC as the safety net. Even when SSA says the listing isn't technically met, strong functional evidence showing marked or extreme limitations in two or more domains can still win approval. SSA calls this a "functional equivalence" finding, and its POMS section DI 25225.020 covers how that determination gets made. ^[4]

If you're trying to organize records and figure out where your child's case stands, the DisabilityFiled guided intake tool walks through the domain-by-domain information SSA needs, so nothing slips through the cracks.

What medical evidence does SSA need for a Listing 111.09 claim?

The evidence requirements for 111.09 are specific, and the first one trips up most families: SSA must see documentation of the central nervous system abnormality causing the communication disorder. That usually means one or more of these: MRI or CT imaging of the brain; neurologist records naming the diagnosis and its neurological basis; a history of stroke, traumatic brain injury, CNS infection, or brain tumor in the child's records. ^[1]

SSA also needs a speech and language evaluation from a qualified professional, usually a licensed speech-language pathologist. The strongest reports include standardized test scores (like the Clinical Evaluation of Language Fundamentals, or CELF), intelligibility ratings, and a description of how the child's communication stacks up against age norms. A report that just says "the child has poor speech," with no test data, won't carry the claim.

School records matter more than most parents realize. An Individualized Education Program (IEP) documenting the disability classification, speech therapy services, and the school's read on functional limits is powerful backup. Teachers and school speech therapists see the child across settings, which is exactly what SSA is trying to picture.

Submit the rest too: therapy session notes, medication logs if the child takes anticonvulsants or other CNS drugs, and any hospitalizations tied to the underlying neurological condition. SSA can request records itself, but waiting on that adds weeks or months. Send everything yourself with the initial application.

The Childhood Disability Evaluation Form (SSA-538) is the internal form SSA's consulting physicians use to rate the domains. You won't fill it out, but knowing it exists tells you what the examiner is hunting for. ^[3]

How does SSA rate the six domains of functioning for a child with a communication disorder?

SSA rates all six domains, but a communication disorder rarely spreads evenly across them. Here's how each one tends to apply to a child with aphasia or dysarthria.

Acquiring and using information. This is almost always the most affected domain. Aphasia directly hits a child's ability to understand spoken or written language and to express thoughts. Dysarthria can limit answering questions, joining class, or producing written work if the motor impairment reaches beyond speech. Testing from school psychologists and speech pathologists is your strongest evidence here.

Attending and completing tasks. A child who can't communicate well often gets frustrated and checks out. If therapy notes or teacher reports describe a child who gives up quickly, gets overwhelmed, or can't follow multi-step spoken directions, this domain may reach marked.

Interacting and relating with others. Severely impaired speech lands directly here. A child who's largely unintelligible will struggle to form age-appropriate friendships, join group activities, or relate to teachers and peers normally. Descriptions from parents and teachers about the child's social interactions matter a lot.

Moving about and manipulating objects. For a pure communication disorder with no motor involvement, this domain may be untouched. But many children with dysarthria also have cerebral palsy or another motor condition, and then this domain should be documented too.

Caring for yourself. Some children with severe aphasia can't follow basic self-care instructions or communicate their own needs. If that fits, spell it out with specifics.

Health and physical well-being. This one covers the overall drag of treatment, hospitalizations, and the condition's course. A child with frequent medical appointments, easy fatigue from neurological disease, or repeated hospitalizations may show limits here.

SSA records each rating on the SSA-538 form. ^[3] Marked in two domains, or extreme in one, equals a finding of "functional equivalence" to a listed impairment. That means the child qualifies even without meeting the listing itself. ^[2]

What are the most common reasons SSA denies a child's Listing 111.09 claim?

Denials on a 111.09 claim almost always trace back to one of three problems, and all three are fixable.

First, missing neurological documentation. SSA has to see that the communication disorder has a CNS basis. If the only records come from a speech therapist with no neurologist's diagnosis, SSA can find the listing's medical criteria unmet. Get the neurologist involved and make sure the diagnosis ties the speech disorder to the neurological condition.

Second, vague functional evidence. A report saying a child "struggles to communicate" gives the examiner nothing to rate. SSA needs test scores, percentile rankings, and specific descriptions of how the child functions across settings. Without that detail, there's nothing concrete to call marked or extreme.

Third, duration. The impairment has to have lasted, or be expected to last, at least 12 months. For a child who had a stroke and is recovering fast, SSA may decide the condition doesn't meet the duration rule if the record shows big improvement. Document the current functional level honestly and get the treating neurologist to comment on the expected path forward.

Around 63% of initial disability applications are denied nationally, and children's SSI claims for medical reasons follow similar patterns. ^[5] Plenty of those denials get overturned at reconsideration or the ALJ hearing once better evidence lands in the file. If you've been denied, an ssdi lawyer who handles childhood SSI claims can help organize the appeal record.

How is a child's case different from an adult's at the RFC stage?

The adult RFC asks one question: what work-related activities can this person still do? The adult forms (SSA-4734-F4-SUP for physical, or the mental RFC) rate functions like lifting, sitting, standing, and concentration. Examiners then match that RFC against the demands of jobs in the national economy. ^[6]

None of that applies to children. A child on SSI isn't measured against a job market. Instead SSA asks: does this child function like other children the same age? The six-domain framework replaces the vocational grid completely. That's why the "child RFC" is really a domain-rating assessment, not a form that maps to a job. ^[2]

Because there's no vocational step for children, the functional equivalence route matters more. An adult denied at step five (can do other work) has lost. A child denied at the listing step still has a second path: showing that the combination of limits across domains functionally equals a listing. Only children get that second path.

There's another difference. SSA compares the child to peers, not to adult standards. A 7-year-old with aphasia isn't expected to function like a 7-year-old without any impairment. SSA asks whether the gap between the child's real functioning and typical age functioning is wide enough to be marked or extreme. That's why developmental context, grade level, and age-normed test scores carry so much weight.

Our overview of What Counts as a Disability? The SSA's Definition Explained takes a wider look at how SSA defines disability across age groups.

What happens at the SSA hearing if a 111.09 case is denied initially and at reconsideration?

If a child's claim is denied at the initial level and again at reconsideration, the family can request a hearing before an Administrative Law Judge (ALJ). The request has to be filed within 60 days of receiving the reconsideration denial, plus 5 days SSA allows for mailing. ^[7]

At the hearing, the judge reviews all the medical and school records and usually lets the parent or guardian (and a representative, if there is one) testify about the child's daily functioning. The child usually doesn't have to testify. The parent's account of what the child can and can't do in real life is often the most persuasive thing in the room.

SSA doesn't use a vocational expert in childhood cases the way it does for adults, because there's no vocational step. The whole hearing turns on medical and functional evidence. Bring updated treatment records, a fresh speech-language pathology report, and a current IEP. Judges have reversed initial denials on evidence that simply wasn't in the file the first time around.

The hearing is also the right moment to argue functional equivalence when the listing is close but not fully met. A short written brief laying out how the child's limits in each domain add up to marked in two, or extreme in one, helps the judge structure the analysis.

Wait times for ALJ hearings swing hard by hearing office. SSA has reported national average processing around 14 months in recent years, though that number moves with staffing and backlog. ^[5] File appeals fast. Don't wait out the clock.

What does SSA's functional equivalence standard mean for a 111.09 case in practice?

Functional equivalence is how SSA approves children who don't technically meet a listing but whose combined impairments are just as disabling. The legal authority is 20 CFR 416.926a, which sets out the six-domain framework and the marked/extreme rating scale. ^[2]

For a 111.09 case, this is often the real path to approval. Here's why. A child may have a genuine CNS-based communication disorder that's clearly disabling, but the neurological imaging reads borderline, or the treating physician's notes don't use the exact diagnostic language SSA wants. The listing may not be technically met. But if the functional evidence shows marked limitations in acquiring and using information and in interacting and relating with others, the child can still be found disabled.

SSA's POMS DI 25225.020 explains how the six domains get assessed and how the final call is made. ^[4] POMS is SSA's internal policy guidance, not law, but ALJs follow it closely.

Documenting functional equivalence means building a record that shows the child's limits across settings (home, school, community) and across sources (parents, teachers, therapists, physicians). SSA's regulations say no single piece of evidence controls the decision and that the agency weighs all relevant information in the record. Consistent descriptions of limitation from everyone who works with the child make the functional equivalence argument much harder to brush aside.

How much does a child get in SSI if approved for a communication disorder?

A child's SSI is based on the federal benefit rate (FBR), which for 2025 is $967 per month for an individual. ^[8] But for children, the actual check can shrink because of parental income and resources, through a process SSA calls "deeming." The more a parent earns, the more SSA trims the child's payment. ^[9]

Deeming rules are a maze. SSA runs a formula that weighs the number of children in the household who don't get SSI, the parents' earned and unearned income, and allowable deductions. Low-income families may land close to the full FBR. Higher-income families may get a partial benefit, or nothing at all, even when the child is medically approved.

Resource limits apply too. A child, plus the household members SSA deems, can't hold more than $2,000 in countable resources. That limit hasn't moved since 1989, though there have been legislative proposals to raise it. ^[8]

Approval for SSI usually opens Medicaid eligibility in most states, which can matter as much as the cash for a child who needs ongoing therapy, neurologist visits, and evaluations.

Item	2025 Figure
Federal SSI benefit rate (individual)	$967/month
SSI resource limit (individual)	$2,000
SSI resource limit (couple)	$3,000
Approximate denial rate at initial level	~63%
Average months to ALJ hearing	~14 months

What should parents do right now to build the strongest possible case?

Start with the neurologist. If the child hasn't been seen by a pediatric neurologist who has documented the CNS basis of the communication disorder, that's the first gap to close. SSA needs a clear neurological diagnosis linked to the speech problem.

Get a formal speech-language pathology evaluation with standardized testing. Ask for percentile scores, not pass/fail. The lower the score against age norms, the clearer the functional limitation.

Request the child's current IEP and any school psychological evaluations. School records often hold domain-specific detail that maps straight onto SSA's six-domain framework.

Write down daily life. Keep a one-page log for a few weeks: what the child can and can't communicate, the situations where communication breaks down, the emotional and behavioral fallout when it does. That becomes parent testimony and can go in as a third-party function report.

File the SSI application at your local SSA office or online at SSA.gov as soon as you can. SSI doesn't pay for any period before the application date (aside from the filing month), so every week of delay costs money. ^[8]

If you want help organizing the medical and functional information before or during the application, DisabilityFiled's guided intake process walks through SSA's domain framework step by step, so you have a running record of what you've gathered and what's still missing.

For the full picture of the application, our ssdi application guide (it covers SSI too) explains each step from start to finish.

Frequently asked questions

Does Listing 111.09 apply to children with autism who also have speech delays?

Listing 111.09 requires a communication disorder caused by a central nervous system abnormality, like aphasia or dysarthria. Autism-related speech delays are usually evaluated under Listing 112.10 (Autism Spectrum Disorder) instead. But if a child with autism also has a documented neurological communication disorder, 111.09 could apply alongside or instead of 112.10, depending on the medical evidence.

What is the difference between aphasia and dysarthria for SSA purposes?

Aphasia is a language disorder: the child has trouble understanding or producing language itself, usually from brain damage in language-processing areas. Dysarthria is a motor speech disorder where the brain can't properly control the muscles used to speak. Both qualify under Listing 111.09, but they need different documentation. Aphasia needs language testing; dysarthria needs neurological and motor speech assessment.

Can a child qualify under Listing 111.09 if they use augmentative and alternative communication (AAC) devices?

Yes. Using an AAC device doesn't mean the condition is no longer disabling. SSA evaluates how the child functions with the device and whether the underlying disorder still causes marked or extreme limitations. If anything, an AAC device in use is strong evidence that natural speech is severely impaired. Document the device use, the training it took, and the limits that remain even with it.

How long does a child's SSI claim for a communication disorder typically take?

Initial decisions usually take 3 to 6 months. If you're denied and appeal through reconsideration, add another 3 to 6 months. If the case goes to an ALJ hearing, SSA has reported average waits around 14 months nationally, though this swings by state and office. Total time from application to ALJ decision can top two years for contested cases.

Does the child RFC form get sent to the family to fill out?

No. The childhood functional assessment (using SSA Form SSA-538) is an internal SSA document completed by the DDS medical consultant. Parents do fill out a third-party function report describing what the child can and can't do, and that report feeds into the SSA-538 analysis. Submitting a detailed, specific parent function report is one of the most useful things a family can do.

What if the child's neurologist and the SSA consulting doctor disagree?

Under current rules (post-2017), SSA no longer gives automatic deference to treating sources, but it still has to weigh the length and depth of the treating relationship, the consistency of the opinion with the record, and the doctor's specialization. A well-documented opinion from a treating pediatric neurologist carries real weight, especially at the ALJ level.

Can a child be approved for SSI based on a communication disorder even if they attend regular school?

Yes. Attending regular school doesn't automatically mean the child isn't disabled. If the child needs significant accommodations, a special education classification, a dedicated aide, or a modified curriculum, SSA considers all of it. An IEP with a speech-language disability classification in a mainstream setting is supportive evidence, not evidence against the claim.

What is the SSA-538 form and who completes it?

The SSA-538 is the Childhood Disability Evaluation Form used internally by SSA's Disability Determination Services. A DDS medical or psychological consultant completes it after reviewing all the evidence in the file, rating the child's functioning in each of the six developmental domains. Families never see it during the initial process, but it can be obtained through a records request if the case goes to appeal.

Does a child need to be completely unable to speak to qualify under Listing 111.09?

No. The standard is a marked or extreme limitation in functioning, not total inability to speak. A child whose speech is significantly below age norms, largely unintelligible to unfamiliar listeners, or insufficient for age-appropriate communication at school and socially can qualify even with some speech. The key is documented, measurable, significant impairment against same-age peers.

What happens to SSI benefits when the child turns 18?

At 18, SSA runs an "age-18 redetermination" using adult disability standards. The case is reviewed as if it were a new adult claim, applying adult listings and RFC rules. Many young adults lose benefits at this review if the evidence doesn't support an adult disability finding. Preparing well before 18, with updated medical records and functional evidence, matters for families who want benefits to continue. ^[10]

Can a family hire a lawyer or advocate for a child's 111.09 SSI claim?

Yes, and for complex cases it usually makes sense. Disability attorneys and non-attorney representatives typically work on contingency, taking 25% of back pay up to a $7,200 cap set by SSA as of 2024. They don't charge if the claim is denied. For a childhood claim built on detailed neurological evidence and domain-by-domain arguments, an experienced representative can meaningfully improve the odds at the ALJ stage. ^[12]

Is there a faster path for children with very severe communication disorders?

SSA's Compassionate Allowances program speeds up decisions for conditions that almost always qualify. Most communication disorders alone aren't on the list, but the underlying condition causing them might be. A child with a brain tumor or certain rare neurological conditions may qualify for expedited review. Check SSA's current list, and see our overview of the social security compassionate allowances expansion. ^[11]

Sources

1. SSA Blue Book, Listing 111.09, Childhood Neurological Disorders: Listing 111.09 covers communication disorders (aphasia and dysarthria) caused by CNS abnormalities in children under age 18
2. SSA, 20 CFR 416.926a, Functional Equivalence for Children: SSA evaluates childhood disability using six domains of functioning and requires marked limitations in two domains or extreme in one for functional equivalence
3. SSA, Form SSA-538, Childhood Disability Evaluation Form: SSA-538 is the internal form DDS consultants use to rate each of the six childhood domains
4. SSA POMS DI 25225.020, Functional Equivalence Determination for Children: POMS DI 25225.020 describes how SSA applies the six-domain framework and documents functional equivalence findings
5. SSA Office of the Inspector General, Disability Claims Processing Times Report: Approximately 63% of initial disability applications are denied nationally; average ALJ hearing processing times have reached approximately 14 months
6. SSA, Disability Evaluation Under Social Security (Adult RFC guidance): Adult RFC uses physical and mental function forms measuring work-related abilities; children use the domain framework instead
7. SSA, How to Appeal a Decision (60-day appeal rule): Appeals must be filed within 60 days of receiving a denial notice, plus 5 days for mailing
8. SSA, SSI Spotlight on Benefits for Children, 2025: The 2025 federal SSI benefit rate is $967 per month; the individual resource limit is $2,000
9. SSA, Understanding the SSI Deeming Rules for Children: Parental income and resources are deemed to a child SSI recipient, reducing or eliminating the monthly payment depending on household income
10. SSA, Age-18 Redetermination Guidance: At age 18, SSA redetermines eligibility using adult disability standards rather than the childhood domain framework
11. SSA, Compassionate Allowances Program: SSA's Compassionate Allowances program expedites decisions for conditions that almost always qualify for disability benefits
12. SSA, Fee Agreements for Representatives, 2024: Disability representatives are paid 25% of back pay up to a $7,200 maximum cap as of 2024