Articles from prior issues of The Advocate

May/June, 1996

Correspondence

Mr. Chuck Jones
Director
Disability Process Redesign
440 Altmeyer Building
Baltimore, MD

Dear Mr. Jones;

THE OKLAHOMA ASSOCIATION OF DISABILITY Examiners (OKADE) has serious concerns about the value of some of the procedures which have been implemented regarding the use of the 6-part Modular Disability Folder (MDF). The Oklahoma state agency was one of two state agencies participating in the 1994 Pilot Study of the MDF. It appears to us that the statistics and logic used to justify the way MER is to be arranged is flawed. These procedures unnecessarily increase processing time and decrease PPWY at the DDS level. Also, they fail to save the rearrangement time in OHA to the degree suggested.

The Study was conducted in the Dallas region by the Oklahoma and New Mexico state agencies. The conclusions concerning the efficiency of filing the MER in treatment date order in all Reconsideration denials are not based upon fact. The study compared the time spent associating MER and developing the two part folders versus the MDFs. The results are useful only in determining the advantage of the MDF over the old two part folder. It was not an appropriate study to test the choices of arrangement of the medical evidence within the MDF itself.

The study, as reported in the July 31, 1995 memorandum signed by Noel Wall, Richard Mueller and Dave Crawford, stated that the OHA saved approximately 90 minutes per folder in using the MDF with the MER already arranged in treatment date order. This figure was arrived at in comparison with the old two part folder which included not only medical information, but all DO paperwork, queries, OHA forms, etc., all in the same area. It was not just the medical evidence that the OHA had to wade through and rearrange. In the new MDFs everything is in its own section. Since the medical evidence is already separated, the OHA does not have to rearrange the entire folder, only one small section. The remainder of the evidentiary and non-evidentiary papers in the MDF are already separated and compartmentalized when received by OHA. Given the adoption of the MDF, there is no way of knowing how much time, if any, is being saved by having the State Agencies rearrange the medical evidence in treatment date order until a proper and relevant investigation is conducted.

The report of 7/31/95 also stated that the MDF would reduce DDS processing time an average of 5.4 minutes per folder. Pilot study participants in both state agencies feel based on their experience during the study, that arranging or rearranging the medical evidence into treatment date order from date of receipt order results in an increase in processing time at that level. Participants in this agency uniformly expressed shock and disbelief when informed of the savings as reported in the study. A large and more appropriately focused study is needed to determine the actual time differential, either better or worse, between filing MER in the MDFs according to date received and filing according to date of treatment.

The fact that the current procedures require ALL Reconsideration denials to have the MER filed according to treatment date order further negates whatever savings, if any, are realized using these procedures, since not all Reconsideration denials are appealed to the Hearing level. Those cases which are not appealed are costing the DDSs unnecessary time and/or expense, in those instances in which extra clerical have to be hired to do the job of making sure the MER is arranged appropriately. A further consideration should be given to those state agencies which are under hiring freezes or similar constraints which preclude having anyone other than the examiners themselves be responsible for all this unneeded rearrangement of the MER, thereby affecting processing time and production.

We believe the problem should be best addressed by conducting a study of time spent or saved filing the MER in treatment date order versus in date of receipt order, using only MDF in the sample. A compilation of these results should be compared to a study of the time spent in OHA rearranging MER in their cases, again using only the MDF, from date of receipt order to date of treatment order.

We think the results will show no savings in using the current procedures and will in fact show a savings when the procedures are revised in such a way that only those Reconsideration denials which are appealed to OHA need the MER arranged in treatment date order. We further believe you will find that it would take OHA no longer than it would the state agency to arrange MER in the order they desire if it has originally been filed in date of receipt order.

We urge you to consider this matter and request that the appropriate personnel in the Office of Workforce Analysis be apprised of our concerns, as well.

Scott Rader
President, Oklahoma Association of Disability Examiners