Dear Mr. Apfel:

On behalf of the National Association of Disability Examiners (NADE), we support your decision to move forward with implementation of a number of redesign efforts. While it has been a long and sometimes difficult road getting here, I think we have all learned a lot along the way about what works, doesn’t work and what might work in the disability program.

We met with John Dyer, Ken Nibali, Sue Davis and Stanford Ross during our mid-year board meeting and had an opportunity to explore some of the thinking behind the decisions and to discuss the expectations with which you are approaching implementation. We strongly support the idea that elimination of the reconsideration be done in a prototypical situation in which 20% of the workload or less is affected. We stand ready and request the opportunity to serve on planning committees put together by SSA for the purpose of reviewing data and developing the implementation process. And, as always, we promise to provide feedback on the progress of the implementation and the indicators of either success or failure.

Our position papers have made clear our opposition to the elimination of the reconsideration step but, again, we support the approach you’ve chosen. We agree that this is the wisest approach to implementation given the decision to do away with this step in the process.

We were impressed by the commitment expressed by Mr. Dyer and the others to provide DDSs with the resources needed to assure that Disability Adjudicators will be given training to improve their skill and ability to perform the Pre-Decision Interview and to act as Single-Decision-Makers. NADE provides professional development training of all types in the disability program and we stand ready to provide or to assist in training in these areas.

We agree with your decision to eliminate the Adjudication Officer and to apply what has been learned from the pilots to improve the current Hearings process. We think this will result in improved productivity as well as consistency and quality.

NADE is not yet convinced that the Disability Claims Manager is a viable alternative in increasingly complex field, but we are pleased with the attitude of the participants toward what they learned about the work of other components. With you, we will wait and see what develops from this and from the disability work units in processing centers.

Thank you once again for giving us the opportunity to meet with your key staff in this area to discuss the decisions and directions for the disability program. We remain ready and eager to assist in improving the disability program in any way we can.

Sincerely,

Jeffrey H. Price
NADE President

cc: NADE Board of Directors John Dyer, Principal Deputy Commissioner Ken Nibali, Associate Commissioner for Disability Sue Davis, DPRT Director