Articles from prior issues of The Advocate

January/February 2000

nade
December 4, 1999

The Honorable Kenneth S. Apfel
Commissioner
Social Security Administration
500 E Street SW, Suite 850
Washington DC 20254

Dear Mr. Apfel:

On behalf of the National Association of Disability Examiners (NADE), I want to thank you for maintaining an open door policy and allowing us to provide input on issues we believe are critical to the disability program and directly affect the disability professional represented by this organization.

As we mentioned in our letter supporting your decision to move forward with implementation of some aspects of the redesign, we are ready, willing and eager to assist in the evaluation of redesign. To that end, our members review information as it is developed and distributed and provide input.

A report was recently released by the Office of Quality Assurance and Performance Assessment detailing the results of a survey of customers whose claims were processed through the Full Process Model (FPM). The data relates specifically to the Pre-Decision Interview (PDI) now known as the Claimant Conference (CC), and NADE believes the results are critical indicators of the potential success of the prototype. We would like to compare the results to the predictions in the redesign planning documents.

The prediction was that implementing the CC would result in 1) a higher initial allowance rate; 2) more customer satisfaction and confidence in the system; and 3) fewer requests for hearing. Unfortunately, the results are not consistent with these expectations. Yes, the initial allowance rate for the disability analysts doing the FPM did go up. But, the satisfaction of the claimant stayed the same for those who were allowed and went down in several critical areas for those denied.

Those that had Claimant Conferences were very critical of the competence of the disability analyst. That of course results in less trust and confidence rather than more. Most people, who were denied, reported a lower level of understanding of the process than in the past. Finally, and this one affects long term financial security, of those denied, 15% more claimants filed an appeal to OHA after having a CC than those denied before the CC was initiated.

Unfortunately, these early results show that the public is less confident in the fairness of the system, less sure of how the system works, and more inclined to pursue a hearing. this has huge workload implications for OHA and may result in a lot more people on the rolls. At the NADE National Training conference in Denver, both John Dyer, Principal Deputy Commissioner, and Ken Nibali, Associate Commissioner for Disability, implied that the prototype is step one of a national roll-out and not a proving ground to determine whether this particular aspect of redesign will work in the real world. Although NADE strongly supports any effort to educate the public about the disability program, it appears an “after the fact” approach, such as the claimant conference, isn’t working too well. Perhaps the claimant conferences should be reserved for discussion of the findings for both decision and documentation.

NADE is concerned about these early results and we urge your continued attention to the results coming from the prototype states. We too will be watching and pointing out positive or negative results as we see them.

Thank you once again for giving us the opportunity to provide you with input on these critical issues. We look forward to discussing with you and your staff the redesign efforts and outcomes as more information is available. We remain ready and eager to assist in improving the disability program in any way we can.

Sincerely,

Terri Spurgeon NADE President

cc: NADE Board of Directors William A. Halter, Principal Deputy Commissioner John Dyer, SSA Executive Staff