Articles from prior issues of The Advocate

July/August 2001

NADE Position Paper Regarding Certification of Disability Examiners by SSA

Executive Summary
June 15, 2001

Members of the National Association of Disability Examiners (NADE) have had an opportunity to carefully review the proposal from the Social Security Administration regarding the potential of providing certification of disability examiners in the DDSs. NADE has long advocated the concept of providing certification of disability examiners and has, in fact, done so for the past 25 years. The certification process offered through NADE is based on training and at least three years of progressive experience. An applicant must also be a NADE member.

NADE is preparing to revise its certification criteria to limit it to a period of three years and that anyone certified by the Association would have to apply for recertification every three years. Applicants for recertification would have to demonstrate that they have completed a prescribed minimum number of additional training hours beyond those required for their initial certification. This requirement for ongoing training and the need for recertification will be new to the NADE certification program if it is approved by the membership. We invite SSA to examine NADE’s certification program as a more practical model.

As the professional association representing disability examiners, we do have reservations about the certification proposal outlined in the report from the Chauncey Group. We were extremely disappointed that the Chauncey Group did not contact this Association while they were preparing their study, even though officials at SSA had urged them to do so.

A NADE poll of DDS Administrators in the spring of 2000 found that nearly 90% indicated that a certification program would not make any difference in their ability to hire, promote or otherwise reward any employee who became certified. In the face of such evidence NADE questions the wisdom of SSA investing significant funds in such a program. The Chauncey report admits that there has been no strong support for a certification program and, in fact, declares, perhaps self-servingly, that SSA will encounter major obstacles in implementing any certification plan. The certification proposal is overly ambitious, it is too complex, and there has been little, if any, stakeholder input.

Approximately half of all disability examiners in the nation have less that two years of experience because of retirements and an ever-increasing turnover rate. It is generally accepted that two years of experience is necessary as the very minimum for a disability examiner to gain sufficient program knowledge and work skills to become proficient in their job. It should be alarming to everyone connected with the disability program that so few disability examiners currently have this level of experience. Rather than addressing a need for certification through some sort of standardized testing, we believe that SSA should be addressing the need for experience in the disability program. We believe a certification program, similar to the one offered by NADE, that emphasizes training and experience is a more practical model.

Chauncey is an outside consultant who has a significant personal stake in the project. This fact is made obvious by the report’s conclusion that despite “show stoppers,” including potential lack of peer level support, they believe that certification is feasible. The report’s conclusion in this area is unlikely to resonate with credibility for any of the potential stakeholders.

NADE also questions why the focus has been only on disability examiner certification? Why are other decision-makers excluded? What manner of certification will be required of the personnel in the regional and central offices that review the decisions of the certified disability examiner?

The job of the disability examiner is a highly nuanced medical and legal profession. The Disability Examiner’s job is one that is best characterized as a hands on job requiring telephone skills, writing ability, highly sophisticated interactive capacities, and many other skills – none of which are going to be easily demonstrated in a certification test.

The Chauncey Group admits that their research was limited and, even though they claim it was sufficient, this level of research is certainly laughable to knowledgeable stakeholders and seriously undermines the credibility of the entire report.

SSA has announced that the test, when developed, would be piloted by six disability examiners picked by SSA. This is an incredible underestimation of an instrument that will be applied to thousands of individuals.

In conclusion, NADE asserts that there is no evidence of support for the certification process envisioned by the Chauncey Group. This certification initiative may actually detract from an already diminishing pool of potential job applicants and make the process of attracting and retaining a well-qualified and well-trained staff even more difficult. The certification program envisioned in the Chauncey proposal will remain an exercise far removed from the prerequisites of acquiring and retaining a reliable workforce.

We would invite SSA to examine the certification process offered by NADE and already in place as a meaningful way of achieving their desired purpose at a minimal cost. The certification program offered by NADE recognizes training and experience as the basis for certification and not some meaningless test that accounts for neither. Our certification program recognizes the political realities and practicalities of today’s DDS community. NADE does not have a financial interest in SSA’s pursuit of certification. We will not seek to be the certifying body for a certification program envisioned in the Chauncey proposal.

NADE strongly believes that our Association and representatives from the National Council of Disability Determination Directors (NCDDD) should be included at the discussion tables for all future meetings regarding certification. We believe that SSA, if it pursues the certification initiative, must make a commitment that, it will use certification as a means to require states to offer additional incentives to disability examiners who do become certified. However, we believe that SSA should reconsider its certification push at this time and take a step back on the proposal and await the outcomes of the many factors that may affect the issue but which have not been fully understood at this time.

(The full text can be viewed at nade.org, click on position papers.)