Geddes and Secretary, Department of Social Services (Social services second review)

This matter concerned an appeal by Mr Geddes against a decision affirming the rejection of his application for a Disability Support Pension (DSP). The dispute centred on whether Mr Geddes' impairments, specifically left shoulder instability and right wrist osteoarthritis, met the threshold for a DSP under the *Social Security Act 1991* (Cth). The case was heard by Mrs J C Kelly, Senior Member, of the Administrative Appeals Tribunal.

The primary legal issue before the Tribunal was whether Mr Geddes' impairments resulted in a functional impairment rating of 20 points or more under the *Social Security (Tables for the Assessment of Work-related Impairment for Disability Support Pension) Determination 2011* (the Impairment Tables), specifically Table 2 concerning Upper Limb Function. This required determining if his conditions were fully diagnosed, treated, and stabilised, and if they prevented him from working at least 15 hours per week.

The Tribunal considered extensive medical evidence, including reports from orthopaedic surgeons and specialist assessors. While acknowledging Mr Geddes' significant pain and functional limitations, particularly the frequent dislocations of his left shoulder, the Tribunal accepted the findings of the Job Capacity Assessment Reports. These reports, consistent across multiple assessments, concluded that Mr Geddes' left shoulder and right wrist conditions resulted in a single functional impairment rated at 10 points under Table 2. The Tribunal applied clauses 10(5) and 10(6) of the Impairment Tables, which mandate a single rating where multiple conditions cause a common or combined impairment, finding this approach appropriate in Mr Geddes' case.

Consequently, the Tribunal affirmed the reviewable decision, finding that Mr Geddes did not satisfy section 94(1)(b) of the *Social Security Act 1991* as his assessed functional impairment rating was below the required 20 points.