The "Representative Survey on the Participation of People with Disabilities" (Participation Survey), commissioned by the German Federal Ministry of Labour and Social Affairs, aims to work in conjunction with participation reporting to assess the social participation of people with disabilities. Both the participation reporting and the Participation Survey claim to operationalize impairment and disability in accordance with the International Classification of Functioning, Disability and Health (ICF) of the World Health Organization (WHO). A critical analysis of the measurement concept reveals methodological problems: 1) The measurement concept is not consistently ICF-oriented because it does not clearly conceptualize impairments, does not adequately take into consideration environmental factors in the determination of disability and sees impairment as causal for disability. 2) Distinction made between impairment and disability is mainly pragmatic, without any coherent conceptual justification. 3) The chosen operationalization cannot ensure the desired international comparability. In order to achieve a stronger ICF orientation and better international comparability, it is proposed in this study to integrate the "Model Disability Survey", developed by the WHO and the World Bank, into the German Participation Survey's data collection tools. An alternative measurement proposal, which can be implemented with the available data, is to categorize groups solely according to the severity of impairment, forgoing the a priori distinction between impairment and disability. This approach embraces the fundamental idea of the ICF, which views disability as a situational rather than a personal characteristic.