Articles from prior issues of The Advocate

May/June, 1996

Wisconsin Association of Disability Examiners Position on The Disability Claim Manager

THE WISCONSIN ASSOCIATION OF DISABILITY Examiners (WADE) has had several concerns about the logic, practicality and effectiveness of the proposed Disability Claim Manager (DCM) position. Our concerns summarized below represent the views of our chapter, and not necessarily those of our national organization, NADE. We believe that this proposal does not, in fact, simplify the current process in any significant way. We believe that a great number of the “improvements” stated in the proposal could be made under the existing system with little or no extra cost, or are already being done in many states under their own initiatives. We believe that the DCM position, as proposed, cannot function unless several tools described in the proposal are in place, and to move toward the DCM goals without these tools in place leaves the disability program vulnerable to the concerns expressed in the past to SSA and to Congress.

The list of tasks that the DCM will perform is essentially a list of what is being done today by the combined expertise of the District Office (DO) and the Disability Determination Service (DDS). As the tasks required in the job are not significantly changed, what simplification is expected by having one individual perform all of these tasks is questionable. In addition, several new expectations are being added to the position, including the mandatory predecision notice, with the possible supplementary interview, the referrals to representation sources and community resources, and the monitoring of third party organizations.

Throughout the document, references are made to working in a “team environment” as well as having the DCM job duties being performed by more than one person. References are also made to individuals doing the proposed DCM duties who will have familiarity with all the steps of the process. While there is a reference to today’s workers performing “singular activities,” an analysis of what we do shows that we are doing several complex tasks which take months of training to master, while a more complex job could be impossible to perform effectively.

Another concern related to having one person being responsible for all aspects of a claim is that this includes the entire life of the claim, as District Offices are well aware today. The work on a disability claim does not end with an allowance decision - further work may be required, at intervals, for years.

Putting greater reliance on the claimant or third party representative for the application and development of a claim is not necessarily a guarantee of simplification of the process. Claimants rarely have ready access to their entire necessary medical records, or fail to supply complete records. Our current experience with third-party representatives shows that they can be helpful in procuring information, but can seldom get records any faster than the DDS. Our experience also shows that some representatives will provide incomplete, biased or incorrect medical information. The current proposal calls for the DCM to monitor the activities of these representatives. Any reasonable monitoring program will require verifying the information provided, which will in turn require duplicating the effort of the representatives.

One of the goals of the DCM is to give the claimant access to the decision maker. This laudable goal has already been reached in many states. Disability examiners in Wisconsin frequently contact their claimants, and claimants contact the examiners. The claimants generally know they are talking to a disability examiner, the person who makes the decision on their claim. The examiners frequently explain just what they are doing and what the claimant could do to help. It is unclear how the DCM proposal will differ from current practice. The plan admits that in the near term, “the duties of a disability claim manager may be more appropriately carried out by more than one individual.” This too is already being done, with local District Offices working on one aspect of claims and the efficiently centralized DDSs doing the disability determination as described in the plan. It appears that, in the near term, the main effect of the proposal will be primarily to reassign tasks and responsibilities, resulting in a need for revised procedures and additional training while not generating additional efficiencies. An alternative might be to establish and/or improve teamwork between our present DOs and DDSs.

Examiners could do several of the additional tasks in the proposal without replacing the present system, with merely an okay from SSA. For example, examiners could easily refer claimants to community resources, if we had the information on available resources. We could refer people to third parties, if we knew who they were. We could start monitoring the integrity of the information we already receive from third parties, once allowed to develop monitoring procedures. We could provide “anticipated timeframes” for reaching a completed disability decision (we already provide unofficial estimates in some cases). These tasks do not rely on the existence of a DCM nor the automated claims processing system, and they are things we could implement now.

The new automated claim processing system is supposed to permit a DCM to be able to perform all non-medical and medical actions necessary to make decisions on claims. The development of this system has been in the works for several years now. In the past, some of our members reviewed parts of the system while under development and provided comments. We have not seen any recent developments or revised prototypes. It appears unlikely that widespread deployment will occur or be possible for several years.

It is not clear that the automated claims processing system will provide better tools for making determinations. Computer systems excel in retrieving information, but only information from primary sources, (except where the medical providers use--and use correctly--the computer system.) Once paper data is received, additional time will be required for someone to enter the medical data into the computer, and if that data is supposed to indicate probable determinations, someone will have to make those determinations when entering the data. Computerization can also make the rules and guidelines for making decisions readily available but, at least in Wisconsin, that portion already exists. Finally, standardized computerized decision charts and checklists can assist with technical aspects of case completion, but they cannot replace the analysis and thought required in the decision making process as a whole.

The simplified decision methodology called for is not in place. This, it is said, “will rely on standards for decision making that are used at all levels of the process.” A standard decision-making process is a laudable goal, and would solve many problems even under the existing system. Under the DCM proposal, it is absolutely critical. However, we would note that the different environments in which examiners and ALJs must operate may make such a system impossible. We strongly support the goal for consistent decision making at all levels, but feel that the DCM is hardly vital for this.

Our professional lives are deeply involved in this work, and we all have made commitments to the SS program. We strongly support the goals of solving any existing problems and improving the program. However, we believe that improvements must be demonstrable and defensible. Furthermore, changes must be tested: there is too much at stake to risk the program on potentially flawed solutions. Therefore, SSA must develop benchmarks showing where the current system does not meet the needs of its clients, and how much improvement is desired. Anecdotes are not enough. Then the DCM, or alternative changes, need to be tested to see whether they actually result in improvements in these benchmarks. At the same time, the costs of the proposed changes need to be accurately assessed. If the DCM or other changes result in real improvements, at a reasonable cost, they should be implemented. Based on what we have seen to date, however, we are very concerned that the DCM proposal may result in a significant fall in service, while costing more to implement and manage.