Articles from prior issues of The Advocate

July/August, 1996

Correspondence

Date: June 7, 1996

From: National Association of Disability Examiners

Subject: DCM Workgroup Product -- Response

To: Director, Disability Process Redesign Team

NADE recognizes that the DCM Workgroup Report is the product of countless hours of discussion and a great deal of work. We also realize that the Workgroup did not have the option of deciding whether to test, but only how the DCM concept should be tested. Within the parameters established and using the Commissioner’s five primary objectives as a guide, most issues were considered and addressed. NADE commends the Workgroup for this achievement. However, we have significant concerns about the DCM as a concept, the size and scope of the proposed pilot and the evaluation process.

Our concerns about the DCM concept and the decision to pilot this without the required enablers have been communicated previously. Beyond stating that those concerns have not been addressed, there is no point in reiterating them at this time. Rather, we will address concerns we have about the DCM pilot process outlined in the Workgroup report.

One of our primary concerns is the size of the proposed pilot. During this period of escalating workloads and impossible time frames it does not seem prudent to expend scarce resources to start a pilot of the DCM position that would remove 150 CRs from productivity for up to 34 weeks and 150 DEs for up to 6.5 weeks of training with additional lost productivity for the first year due to learning period for Phase I. Supervisors, trainers, coaches and clerical staff would also be removed from productivity during this period. This loss would be further increased during the proposed Phase II and Phase III.

Quoting from page 16 of the Workgroup report. “...although much can be learned from these pilots, since they will be implemented in advance of the enablers and other critical aspects of the redesigned process, caution must be exercised when interpreting the data that these pilots will produce.” If “caution must be exercised” it does not make sense to have the pilots start with such large numbers, then substantially increase those numbers in Phase II and III based on the data in Phase I. This also makes it appear more like a roll-out than a pilot. Smaller numbers initially, for shorter periods with increasing complexity added to the position as enablers are perfected, makes more sense than increasing to 1500 DCMs based on data that we are cautioned may be invalid or incorrect. If there are sufficient resources available to pilot the DCM concept, NADE proposes a smaller pilot, involving no more than 60 federal and 60 state DCMs. This pilot should run for no more than 18 months with an option to renew for an additional 18 months.

In addition to our concerns about the size of the pilot, we question the evaluation criteria and the evaluation process. SSA has a history of establishing pilots to test new methods and/or proposals and declaring the pilot successful regardless of what the results show. Because of the significant risks involved in changing the one part of the disability process that has worked the best over the years, it is essential that definitive and measurable parameters be established to determine the success or failure of this pilot. In addition, it is essential that an unbiased, third party be enlisted to review and evaluate the findings of the internal SSA review of DCM decisions and the DCM process and prepare a report on success or failure. The third party should be able to pull a random sample of the decisions after the 100% OPIR review, both allowances and denials and an equal number from both state and federal DCM sites.

Further, we do not understand the evaluation criteria which has been proposed or why “threshold” levels have been established for “critical” outcomes. We find it disturbing that success is measured not by improved claimant satisfaction or accuracy, but by no decline in accuracy or claimant satisfaction. Given the stated resource impact, success of the project must require substantial improvements in service, not just an approximation of the status quo. Outcomes which would ordinarily be considered failures are labeled as successes. For example, it would be reasonable to consider a neutral program cost as an indicator of success, if offset by a significant increase in claimant satisfaction. However, in the Workgroup report a success would be declared if program cost was neutral and there was no significant decline in customer satisfaction (i.e., a decline in customer satisfaction would still be considered a success.)

We note that the DCMs in the pilot study “...should not be expected to do other work not associated with the pilot work” (page 16). This must also be true for the control group. If not, any data obtained would be seriously skewed and unreliable.

Although the Workgroup report states, “We are not comparing federal DCMs to state DCMs but are comparing the process now in place with the new process....”, we wonder how much real data is available to make such a comparison. For example, we are not aware of any current, reliable, objective data regarding claimants’ present level of satisfaction with the disability program. Without such data how can an increase or decrease in claimant satisfaction be determined? Additionally, claimant satisfaction must be measured after the decision has been reached and the claimant has been notified of the decision. Those surveyed should include equal numbers if those allowed and denied, inner city, rural and suburban claimants and those with third party/advocate assistance as well as individuals filing on their own.

Finally, any anticipated legislative or regulatory changes should be postponed until Phase I has been completed and the results independently evaluated.