Articles from prior issues of The Advocate

September/October, 1997

NADE Correspondence

Ms. Sue C. Davis
Director
Disability Process Redesign Team
6401 Security Boulevard
Suite 500
Baltimore, MD 21235

RE: Test of the Single Decisionmaker Model, Report

Dear Ms. Davis;

NADE agrees with the DPRTs recommendation to proceed to the next step in the development of the SDM model, i.e., setting up pre-implementation pilots in interested states. We are in general agreement with the findings of the SDM model test report and believe that these findings justify continued testing. The SDM concept encompasses an idea for which NADE has long advocated, that of providing medical support for decision makers if needed, as when difficult medical issues are involved, while eliminating routine, or pro forma, medical assessment when it does not add value in the form of greater decisional accuracy. We oppose, however, artificial limitations being imposed and urge you to seek statutory and regulatory changes to expand the concept to all type cases and impairments. Those concerns that we do have relate to limitations imposed by a testing environment. Preliminary results tend to demonstrate the efficacy of the SDM position in an un-reengineered setting. If, or when, the SDM protocol is incorporated into the DCM position, test results that have not measured the impact of the combined pressures of face-to-face contact with the claimant and AO and ALJ reversals will be largely irrelevant. For this reason, any conclusion regarding the SDM’s efficiency must remain tentative. Thank you for the opportunity to provide these comments. We appreciate the positive tone of the DPRT’s report. But, while we realize that the ancillary documents that accompanied your report are not material to it in all aspects, we would like to comment on one aspect of one of those documents. We are puzzled by a comment in OPIR’s report and concerned by potential interpretations of it. In their recommendations, on page iv of the executive summary, under the heading, “DDS quality culture,” OPIR states: “The DEs who participated in the test had an OPIR disability quality branch review of every case processed. In order to achieve the acceptable performance observed by SDMs during the test, the DDSs should be required to establish a quality culture....”(Emphasis provided). It is not clear what relationship OPIR intends to suggest between the content of the first sentence and that of the second; however, it seems reasonable to infer that they are, perhaps, suggesting that the DQB review is actually responsible for the high level of examiner performance (rather than merely report it) and if the high level is to be maintained, absent 100% OPIR review, that alternative mechanisms must be implemented to replace the referenced review. We can only hope that this was not intended. If, however, it was, it clearly represents a rather prominent occurrence of the post hoc propter hoc fallacy commonly illustrated by reference to the rooster who believes his daily crowing causes the sun to rise. In addition to being puzzled by OPIR’s meaning in the quoted text, we also find that we cannot reconcile their conclusion that it will be necessary to “establish” a quality culture in the DDS with decades of OPIR reports that demonstrate a high level of accuracy in DDS decision making, a level of achievement not matched by other components whose quality has only recently been subjected to review. Most importantly, however, the recommendation does not seem to be supported by any of the data contained in the report. Overall, there is little difference between the quality of SDM decisions and other DDS decisions - both are fairly high. Since OPIR is specifically constituted as a data collection and interpretation component, it particularly concerns us to see them issue such arbitrary conclusions. Again, thank you for the opportunity to comment. We commend the DPRT on its report. Sincerely,

Susan R. LaMorte
President