Listing 11.02 in 2026: How SSA Evaluates Epilepsy, the Once-a-Month and Once-a-Week Seizure Frequency Rules, the 3-Month Observation Window, and the Adherence-to-Treatment Standard That Wins at Step 3

By Anthony Albert, Benefits Research Director · Updated June 13, 2026 · 14 min read

Epilepsy claims fail more often than they should, and almost always for the same reasons. Seizure logs aren't kept. Medication compliance isn't documented. The seizure-type description is missing. The claimant counts seizures the wrong way, and the adjudicator counts a different way.

The rules under Listing 11.02 are tight but predictable. If your seizure history, your nephrologist (we mean neurologist) notes, and your medication records match the right frequency thresholds, this is one of the most winnable listings in the entire Blue Book. If they don't, you get denied even when your epilepsy is obviously disabling.

This guide walks through all four paths under 11.02, the counting rules under 11.00H4, the adherence standard under 11.00C, and what your neurologist needs to write down for SSA to grant your claim.

The four paths under 11.02

Listing 11.02 reads: "Epilepsy, documented by a detailed description of a typical seizure and characterized by A, B, C, or D." You only need to meet one path.

Paths A and B are the pure-frequency wins. Paths C and D let you qualify with a lower seizure count if you also have a marked limitation in physical functioning, understanding/remembering/applying information, interacting with others, concentrating/persisting/maintaining pace, or adapting/managing oneself.

What "generalized tonic-clonic" means

Per 11.00H1a, generalized tonic-clonic seizures are characterized by:

• loss of consciousness,
• a tonic phase (sudden muscle tensing, postural control lost),
• followed by a clonic phase (rapid cycles of muscle contraction and relaxation, also called convulsions),
• often tongue biting, incontinence, or injury from falling.

This is what most people picture when they hear "seizure." Older terminology is "grand mal."

What "dyscognitive" means

Per 11.00H1b, dyscognitive seizures (formerly called complex partial) involve:

• alteration of consciousness without convulsions or loss of muscle control,
• blank staring, change of facial expression,
• automatisms (lip smacking, chewing or swallowing, repetitive simple actions, gestures, verbal utterances).

If a dyscognitive seizure progresses into a generalized tonic-clonic, SSA counts it as one tonic-clonic event under 11.00H4c.

The adherence-to-treatment standard under 11.00C

This is what kills more 11.02 claims than any other rule. Per 11.00C, "despite adherence to prescribed treatment" means you have taken medication or followed other treatment procedures as prescribed by a physician for three consecutive months and your impairment continues to meet the other listing requirements despite that treatment.

In practical terms: if you've only been on lamotrigine, levetiracetam, valproate, oxcarbazepine, or any other anti-seizure med for 2 months, your seizures don't count yet. You have to hit the 3-month adherence floor before the seizure clock starts.

What "good reason" for non-adherence looks like

Per 11.00H4e, SSA does not count seizures during periods when you weren't following prescribed treatment without good reason. But SSA recognizes good reasons, including:

• treatment is very risky for you due to its consequences or unusual nature (such as severe side effects, a black-box warning that doesn't fit your case),
• you can't afford prescribed treatment that you are willing to accept, but no free community resources are available,
• physical, mental, educational, or communicative limitations (including language barriers) prevent compliance.

SSA cross-references 20 CFR 404.1530(c) and 416.930(c) for the good-cause framework. This is the same framework that applies to SSR 18-3p failure-to-follow-treatment denials.

How SSA counts seizures under 11.00H4

The counting rules are mechanical. Get them wrong and your claim drops a path:

1. The clock doesn't start until one month after you began prescribed treatment. If you started keppra on January 15, the earliest day SSA will count is February 15.
2. Multiple seizures in a 24-hour period count as one seizure. If you have three tonic-clonics in one afternoon, that's still just one for purposes of the monthly count.
3. Status epilepticus counts as one seizure. Even if a continuous series of seizures lasts 4 hours without return to consciousness, it's one event for counting.
4. A dyscognitive that progresses into a tonic-clonic counts as one tonic-clonic. Not two events. Not a dyscognitive plus a tonic-clonic.
5. Seizures during non-adherence without good reason don't count.
6. Psychogenic non-epileptic seizures and pseudoseizures don't count. Those are evaluated under the mental disorders body system 12.00 (which we covered in our mental health listings deep-dive).

The detailed seizure description requirement

Per 11.00H2, SSA requires at least one detailed description of your seizures from someone, preferably a medical professional, who has actually observed at least one of your typical seizures. If you have more than one type, you need a description of each type.

This trips up a lot of claimants. Your own description of a tonic-clonic is helpful but not enough by itself, because you were unconscious during the event. The descriptive narrative has to come from a witness: a paramedic, an ER doctor, a spouse who has watched it happen, or a co-worker. If you live alone and your only seizures happen in your sleep, an EEG-confirmed event or a video EEG capture from a neurology clinic admission can serve.

What SSA doesn't require

Per 11.00H3 and 11.00H5, SSA does not require:

• serum drug levels (and SSA will not purchase them),
• EEG test results (and SSA will not purchase them).

If those results are in your medical records, SSA will look at them. But missing serum levels or a normal EEG is not by itself a reason to deny. Many people with documented seizures have entirely normal EEGs between events.

The paragraph C and D marked limitation paths

If your seizure frequency is too low to meet 11.02A or B but you still have significant disability, you can win under 11.02C or D by combining a lower seizure rate with a marked limitation in one functional area.

The five functional areas (11.00G3)

"Marked" means serious limitation: more than moderate but less than extreme. It must interfere seriously with your ability to function independently, appropriately, effectively, and on a sustained basis. SSA uses the same paragraph B framework as the mental disorder listings under 12.00.

Worked example 1: California / 11.02A / tonic-clonic monthly

Worked example 2: Texas / 11.02D / dyscognitive plus marked CPP limitation

What if your seizures are pseudoseizures or PNES

Per 11.00H1 and 11.00H4f, psychogenic non-epileptic seizures (PNES) and pseudoseizures are not evaluated under 11.02. They go under 12.00 mental disorders, typically as somatic symptom disorder (12.07) or conversion disorder.

This sounds bad but it isn't necessarily a loss. PNES can absolutely be disabling under 12.07 if you can show marked limitations in the paragraph B mental functional areas. The path is different but the outcome can be the same.

A subset of patients have both. Per the SSA guidance, SSA evaluates the epileptic seizures under 11.02 and the PNES under 12.00 in parallel. The combination often pushes a borderline claim across the line.

What if you don't meet any 11.02 path

You go to Steps 4 and 5. Per 20 CFR 404.1545, SSA assesses your residual functional capacity. For epilepsy that doesn't meet 11.02, the RFC restrictions that win cases include:

• no exposure to unprotected heights,
• no operation of motor vehicles, heavy machinery, or moving conveyances,
• no exposure to open flames, large bodies of water, or hazardous chemicals,
• frequent absences (typically 2 to 4 per month for postictal recovery and clinic visits),
• off-task time exceeding 15 percent (postictal confusion, drug side effects),
• simple, routine tasks only (for cognitive slowing from anti-epileptic drugs).

Most past relevant work involving driving, machinery, manufacturing, construction, or healthcare gets eliminated at Step 4. At Step 5, when the vocational expert testifies, the off-task and absence restrictions usually eliminate all competitive work. We covered the function-by-function RFC mechanics in our SSR 96-8p RFC assessment article.

Other 11.00 listings to know

If you have a combination of epilepsy plus another 11.00 condition, you can stack toward medical equivalence under 20 CFR 404.1526, which we walked through in our medical equivalence article.

How to put a 11.02 claim together

1. Start a written seizure log immediately. Date, time, duration, witness, what happened, post-event recovery.
2. Get a detailed description of at least one typical seizure into the medical record from a witness (spouse, paramedic, ER physician, neurology clinic staff).
3. Maintain medication adherence for at least 3 consecutive months before relying on the listing.
4. Get your neurologist to write a treatment summary that lists every anti-seizure med you've tried, the dates, the side effects, and the current regimen.
5. Pull all ER and hospital records for seizure-related visits in the last 12 to 18 months.
6. If your seizure frequency is too low for 11.02A or B, get a neuropsych eval to document a marked limitation in one functional area for 11.02C or D.
7. If you have PNES along with epilepsy, get a mental health evaluation that addresses 12.07 in parallel.
8. File the SSDI application online at SSA.gov or by phone at 1-800-772-1213.

Frequently asked questions