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Articles from prior issues of The Advocate

November/December 2001


Ken Nibali Addresses NADE National Training Conference
by Sherry Blythe, Great Plains Regional Director

KEN NIBALI, ASSOCIATE COMMISSIONER FOR Disability in the Social Security Administration spoke to NADE members about the many and complex issues now facing the Social Security Administration at the recent NADE Training Conference in Austin, Texas. With the tragic events of September 11th, big issues in Baltimore include anthrax, SSA mail, Cipro, and the business of getting back to normal. The Social Security Administration has a new commissioner, Jo Anne Barnhart. She will be making decisions on the issues now pending. She has previous experience in SSA's Office of Assistance and has been a member of the Social Security Advisory Board.

The DDS Workload Performance Report shows four goals for fiscal year 2002. The first goal is DDS Initial Pendings set for 678,317 cases in FY 2002. This goal for pending cases is an increase of 16,500 over the FY 2001 goal. The second goal for DDS CDRs shows a decrease to 864,000 cases, down from FY2001 of 872,000. Actual FY 2001 CDR production was at 884, 048 cases. The third goal deals with initial processing time. The FY 2002 target for processing time is 115 days, the same as FY 2000. Target goal for processing time in FY 1999 was 100 days and FY 2001 was 120 days. Actual processing time for FY 2001 was 106 days including processing times from Prototype States that rolled out in October, 1999. Data regarding accuracy is the fourth goal and has been set at 97.0 percent since FY 1999. Actual accuracy has dropped from 96.7 percent in FY 1999 to 96.0 percent in FY 2001. Mr. Nibali noted that one of the benefits of high DDS quality is that as quality of cases goes up, there are less cases going to OHA. He added that Prototype States are making a recovery with productivity.

DDS budget concerns include management of medical costs which represent 27 percent of the DDS Budget for FY 2002. From the FY 1995 to FY 1999, consultative examination rates increased from approximately 37 percent of cases to almost 45 percent of cases. In FY 2001, the CE rate dropped to approximately 41 percent.

Mr. Nibali discussed the Office of Management and Budget requirements for FY 2003. Priority management issues include: (1) Implementing Ticket to Work; (2) Updating the Medical Listings; and (3) Identifying a budget-neutral disability claim process. Performance measures of these issues include: (1) Reducing processing times for initial disability claims and appeals; and (2) Reducing unit costs for initial disability claims and appeals. To summarize, SSA needs to decrease processing time and do the process cheaper.

In discussing the Office of Disability Integrated Disability Plan for all components of SSA, Mr. Nibali pointed to Disability Program Improvements. These include: (1) Providing efficient, accurate, timely, and consistent decision making; and (2) Helping the disabled to return to work. This process includes five components. The first component is to Continue Current Process Initiatives including: (1) evaluating and making decisions on Prototype; (2) evaluating and refining the HPI process; (3) continuing AC improvements; (4) reviewing and piloting disability quality process changes; and (5) continuing Process Unification, One-SSA initiatives. The second component involves Supporting Return to Work Initiatives including implementing Ticket to Work.

Component number three is Pursuing Near-Term Operating Efficiencies and Policy Changes with Program Direction. These include: (1) Updating the medical listings, (2) Continuing short-term workgroups to develop operational initiatives and process policy changes to achieve quality decisions with less work; (3) Develop proposals to address disability affordability and administrative feasibility; and (4) Align operating policies with congressional intent.

The fourth component deals with Refocus of eDIB and other automation including the development and implementation of a business plan for eDIB, effective use of automation, and accelerated development of the Title 2 disability application and 3368 for on-line Internet use.

The final component is to Establish a Joint OP/OD policy steering committee to recommend fundamental policy changes which involve identifying and supporting policy directions; and identifying possible legislative and regulatory changes to improve the disability program in the mid to long range.

Over the next two years, the Listings of Impairments will be re-written. These re-writes will involve each body system and they will be staged so that the listings do not all roll out at once. The goal is to keep the re-written listings straight forward and without adding more function that would increase workloads. The Musculoskeletal Listings will soon be finalized and will be followed by the Digestive, Skin, DAA-Mental and Endocrine Systems.

The Prototype rollout currently involves ten states and makes up 25 percent of the national workload. The benefits from Prototype include: (1) Quality is strong; (2) As many or more claimants are paid in one step as previously were paid in two (initial and reconsideration); and (3) If cases are appealed after DDS denial, they get to OHA faster.

Data from the SSA Interim Evaluation Report of 7/26/2001 (incomplete data) shows: (1) Initial allowance rates are higher; (2) Quality of decisions is good; (3) Initial processing time has increased; (4) Claimant conference rate is at 64.4 percent; and (5) Customer satisfaction is as good or better than the current process.

Prototype PPWY for FY 2001 through 8/31/01 was 228, while Non-Prototype States were at 277. Prototype Weeks Work Pending for the same time period was at 13.4 while Non-Prototype States were at 11.9. DDS allowance rates for Prototype States for FY 2001 through 8/31/01 were at 43 percent while Non-Prototype initial allowance rates were at 39 percent and initial and reconsideration allowance rates were at 43 percent. Prototype Processing time for FY 2001 through 8/31/01 was at 101 days while Non-Prototype States were at 88 days. Accuracy rates were higher for Prototype States at 94.5 percent with Non-Prototype States were at 93.7 percent.

Mr. Nibali discussed the major issues facing the Prototype Process including program costs resulting from an increase of ultimate allowance rate. With an allowance rate increase of several percentage points comes a significant increase in benefit costs. Secondly, there are increased administrative costs because some Prototype states are having difficulties with workloads under the new process and there is an increase in the number of appeals going to OHA. What is the current status of Prototype? Mr. Nibali told NADE members that final decisions about Prototype rollout to the remaining states will be reserved until more complete data is available. The FY 2002 budget submission does not show any further rollout beyond the current ten Prototype states. The new commissioner, Jo Anne Barnhart, will be involved in the Prototype decision making process.

This year, Mr. Nibali assembled the 30-Day Work Group that was made up of members from the Office of Disability, Regional Office, DDS, NCDDD, OHA, and the Field Offices. The group’s charge was to identify and implement changes to disability processing that enable a quality product with greater efficiency. The group’s recommendations include:

• Eliminate Goldmann requirement

• Implement revised RFC form developed by the Tri-Regional Workgroup

• Do not add function to the Listings

• Institute a balanced definition of Quality in pilot regions

• Public Information Campaign • Institute intake enhancements

• Revise rules for failure to cooper- ate and claimant responsibility

• Provide interim assistance for DDSs

• Permit step 4/5 alternative process

• Extend SDM to other states now

• Reduce the 15 year work history

• Change Policy -assessment of credibility -objective medical basis for symptoms -weight and explanation of TSO -materiality of evidence

Currently, the software for elimination of the Goldmann requirement is on the Internet and available for the DDSs. The revised RFC form (designed for Prototype) is now on hold pending clarification of the Prototype issue and further rollout. Instituting intake enhancements includes a better 3368 package coming in the DDS door from the Field Offices. The components of SSA are working on the group’s recommendations.

Mr. Nibali discussed the future of SSA and the electronic world, eDIB. The goal for eDIB is to create a fully paperless disability business process by (1) incorporating existing systems into a fully electronic business process; (2) creating a data repository to electronically store disability case information; and (3) enabling SSA production and DDS legacy systems to exchange information. One of the first steps to a fully electronic business process would involve the Online SSA-3368. An image of the 3368 would be placed on the Internet site and would include help screens. The second step would include online completion of the 3368 and the third step would be propagation into eDIB.

On September 25, 2001, Mr. Nibali’s office assembled a Certification Workgroup that met for two days. This group included Sue Heflin, now Past President of NADE, Kay Welch, NADE Mid-Atlantic Regional Director, DDS administrators, staff from DQB, Office of Training, Office of Disability, Payment Service Center, and the Disability Training Team. This group was asked to discuss the feasibility of establishing a certification process for disability adjudicators. The goal of certification is to help achieve greater consistency and fairness in decision-making across all states through more uniform expectations for adjudicators’ knowledge, skills and abilities. Significant issues they considered included: Federal regulations, State personnel regulations, State and Federal unions, possible EEOC issues, initial and ongoing costs, variance in DE pay rates, and wide degree of support. Initial steps that SSA can take include: performing job analyses for both DEs and MCs, developing mandatory national DE initial training, developing a national refresher training based on such indicators as DQB returns, developing mandatory national training for new medical consultants, and including federal as well as state employees.

Mr. Nibali covered a great deal of information regarding the present and future of SSA, DDSs and NADE. He continues to be a strong supporter of NADE. He supports the national and regional training conferences and appreciates the support the DDS Administrators give to NADE and its members.

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