Articles from prior issues of The Advocate

May/June, 1996

Correspondence

March 26, 1996

The Honorable Jim Bunning
Chairman
Social Security Subcommittee
B-316 Rayburn House Office Building
Washington, DC 20515

Dear Representative Bunning,

Thank you for giving NADE the opportunity to comment on Commissioner Chater’s response to your questions about the accelerated DCM pilot. Although we plan to provide more detailed feedback on specific issues in the near future our initial impression is that several of her responses were vague, incomplete and somewhat difficult to understand.

In response to your first question the Commissioner specifically states that these pilots do not implement the full range of DCM duties and that this will be “... an incremental approach which would add duties over time.” It is hard to imagine how this admittedly incomplete, continuously changing process can provide any meaningful data about “... the efficiency of the DCM process, examine the impact on program costs and assess the accuracy of medical determinations and payments decisions” and “...also gather information regarding customer satisfaction.” (1)

Additionally, we do not feel the responses adequately address the potential administrative and program costs associated with redesign. Two very significant aspects of the DCM duties, those which would presumably make the process more understandable to the claimant and reduce the number of handoffs--the single decision maker and the predecision interview--will not be added to the pilots until they have been “...thoroughly tested as a part of the Disability Models Tests.” (4) Without these, on what basis does SSA propose to “...gather information regarding claimant satisfaction”? And, as these are also presumed to be, “The DCM duties most likely to impact on program costs ...” (4), how can the pilots accurately “...examine the impact on program costs” (1) of the DCM position?

Although it is noted that “...there are many aspects to the DCM that are not dependent upon the technology improvements...”(6), there are many other equally significant enablers, once considered essential to the redesigned process, which are also not in place. These include the simplified decision methodology, consistent direction and training to all adjudicators, enhanced and targeted collection and development of medical evidence, and a single, comprehensive quality review process across all levels. We believe that these enablers, especially process unification, and the issue of ALJ reversal rates, must be dealt with before proceeding with DCM pilots.

NADE wishes to support redesign initiatives that will enhance customer satisfaction and create efficiencies but it is difficult to comment on a process which has not been developed. Many of our members and several of our chapters, have expressed serious concerns regarding the DCM and the ADCM concepts. The questions they have raised are, by now, quite familiar and many appear in your letter to the Commissioner. We wish to remain open and withhold comment until we have the information necessary to offer constructive suggestions. Still, the burden of proof is on SSA and we do not feel that this burden has been adequately addressed. We would hope that any plans to pilot the accelerated DCM would not proceed until the DCM workgroup completes their task, that product has been thoroughly and objectively reviewed and the methodology for evaluating the pilot has been developed.

Although these are consistently described as pilots there is some concern among our members that they are actually implementation phases. In other situations SSA has conducted “pilots” with the express purpose of validating to OMB’s satisfaction the viability and cost effectiveness of a process. We are concerned that these same preconceptions will prevail when the ADCM pilots are evaluated. And we are also concerned that if the pilots are carried out on the scale proposed we will not be able to rebuild the process if they ultimately prove unsuccessful.

Again, thank you for requesting our input.

Sincerely,

Larry DeVantier
NADE President

cc: NADE Board