Articles from prior issues of The Advocate

January/February, 1999

Social Security Disability Redesign
Full Process Model
November 23, 1998

THE NATIONAL ASSOCIATION OF DISABILITY Examiners (NADE) welcomes the opportunity to provide comment regarding the proposed national implementation of the Full Process Model (FPM) of disability adjudication as developed by the Social Security Disability Process Redesign Team (DPRT). The Full Process Model incorporates the Single Decision Maker concept where DDS Medical Consultant sign-off on cases would not be required, the Pre-Decision Interview, elimination of the reconsideration level of appeal, and the addition of the Adjudication Officer.

Disability Redesign was introduced in 1994 as a road map for the re-engineering of the disability program in a way that would be more cost effective to SSA and more beneficial to the claimant applying for disability benefits. At the time the concept of redesign was introduced, receipts of initial disability claims were increasing annually and the time required to process each claim was also increasing dramatically. This was especially true at the Office of Hearings and Appeals (OHA) where the majority of claimants appealing to this level waited in excess of a year or longer before having their case heard by an Administrative Law Judge. Combined with the DDS processing time for the initial and reconsideration claim, plus the necessary time needed to file an appeal, many claimants were
waiting two years or more to receive a hearing. Such a timeframe, and the disparity between the allowance rates of the state DDSs and OHA, were seen as indicators of poor customer service. Disability redesign was the Social Security Administration’s answer to public and congressional criticism of the existing process and SSA issued bold public proclamations that it would design a disability program for the 21st century that would utilize 21st century technology and provide “world class service.“ NADE endorsed these proclamations to improve customer service and we have provided 100% cooperation with SSA's efforts to achieve this idealistic goal, although, on occasion, we have expressed our concerns about certain aspects of achieving this goal.

In the past six years, the dynamics of the disability program have changed. Initial case receipts have declined while the number of CDR claims being sent to the state DDSs for review have increased significantly. With the significant assistance provided by the state DDSs and other components of the disability program, OHA has been able to decrease its backlog of cases. The intervening years have witnessed a significant growth in the complexity of the disability program as new rules and procedures, many of which have been mandated by court decisions and legislative directives, have been implemented at all levels of the disability process. As a result of court decisions, congressional legislation and directives from the Commissioner, the state DDSs have processed special caseloads, including the DA&A and childhood cases, and re-reviewed the latter. The DDSs have also witnessed dramatic transformations in their personnel as they have sought to hire new examiners to keep up with anticipated workloads and replace more experienced examiners who have chosen to seek employment elsewhere as the ever increasing stresses of continued employment in disability adjudication take their toll. The result of this new hiring by the DDSs and the retirements/resignations of more experienced staff personnel has been that the state DDSs now face a critical shortage of experienced staff just as even more programmatic changes are expected to be introduced. Nationwide, SSA has reported that the state DDSs now face the reality that 40% of their adjudicative staff have less than two years of experience. The two years is a critical number since it has long been advocated by those close to the disability program that it takes a minimum of two years for a new disability examiner to become proficient at the job.

Against this backdrop of increasing program complexity; a major shift in experienced personnel within the state DDSs; a continuing backlog of cases in OHA; a continuing focus within SSA on increasing the number of CDRs processed annually by the DDSs; the Social Security Administration has attempted to redesign the way it will adjudicate disability claims in the 21st century. This was, and continues to be, a monumental task. NADE is grateful to have been recognized as a major stakeholder in this process and to have been given an opportunity to share the expertise reflected by our understanding of disability program requirements and our years of experience with applying those requirements to make critical decisions which impact on the lives of the disabled.

NADE has repeatedly stated that changes are needed in the disability program. Clearly, in terms of customer service, the current process has become too complex for the average citizen to understand. On the surface, it makes very little sense for a claimant to have to go through four levels of appeal before reaching a “final” decision. We support the efforts of the Redesign Team to streamline the process and have supported testing of the various pilots. We have great respect for the DPRT staff and their professionalism and commitment to improved customer service. We look forward to continuing our working relationship with the DPRT staff in the future as SSA and the DDSs continue their efforts to explore new ways of doing business. The objectives of Disability Redesign are simple.

The new process would:

Be customer-friendly

Lower waiting times Result in appropriate allowances being made earlier in the process

Result in greater efficiency in administration costs

Produce a satisfying work environment for employees


NADE believes these objectives are very basic and necessary for the potential success of a redesigned disability program.

One of the pilot studies tested by the Redesign Team and for which NADE is now being asked to provide input as to its projected national implementation, is the Full Process Model (FPM). This Model has a dramatic impact on the way the state DDSs do business and a somewhat lesser impact on the way OHA does business. The Full Process Model claims to streamline the current 4-level adjudicative process to 2 levels and provides an earlier opportunity for claimants to interact with the disability decision maker.

At the DDS level, the model calls for:

The creation of an entity known as the Single Decision Maker (SDM)

The implementation of the Pre-Decision Interview (PDI),

Elimination of the reconsideration level of appeal.

At the OHA level, the model calls for:

The creation of the Adjudication Officer (AO)

The elimination of the Appeals Council request for review as an appeals level.


The Redesign Team has been piloting these concepts and compiling data on the various pieces that comprise the Full Process Model. While the data from the DDS end of the FPM is nearly 100% complete, this is not the case from the OHA end, even though cases selected for inclusion were given priority so that DPRT could have some data to provide to the stakeholder groups. To date, the data appears to show that the FPM has a similar initial allowance rate as the current process that uses an initial and reconsideration level of adjudication. While some allowances are allowed earlier in the FPM than they are in the current process, most denials will take longer than with the current initial level of adjudication.

NADE takes great pride in our having cooperated fully with SSA's redesign pilot studies and we are now prepared to offer our conclusions regarding the test data and the potential success of the Full Process Model. The Honorable Kenneth S. Apfel, Commissioner of SSA, stated at the meeting on November 5, “We need to make decisions and we need to make them quickly. The status quo won’t go.” NADE strongly concurs with this statement. We firmly believe the time has come to make decisions and to move on. Our analysis of the FPM and our experience with the disability process has convinced us that certain pieces of the FPM do
improve customer service, while other pieces of the FPM do not. We have concerns regarding many of the projections made in the model, particularly those that emphasize that the cost savings from the elimination of the reconsideration step in the current process will pay for the implementation of the other pieces of the FPM and that the appeal rate in the FPM from the initial level to OHA will result in only a 5% increase in the number of cases going to OHA. Also, we believe that the AO position more closely resembles a reconsideration and the Full Process Model simply appears to take this intermediate level of appeal from the DDS and transfers it to OHA, where costs of adjudicating cases are considerably higher.

NADE believes that the following process would result in a much more cost effective way of doing business and would provide the claimant with the best customer service:

Increased emphasis by all components of the disability process on process unification and a commitment from SSA to provide consistent, ongoing cross training for all components of the disability process. This was a top priority item in the report issued by the Social Security Advisory Board and NADE strongly concurs with this recommendation.

Implement the Single Decision Maker at the initial level of adjudication. This has been shown by DPRTs test data to provide improved customer service and allows the DDS Medical Consultants to focus their time, energy and greater medical expertise on those cases that present more complex situations. NADE would like to emphasize, however, that adjudicators develop at different rates insofar as their skills at processing cases and their understanding of the disability program is concerned. Less experienced adjudicators may tend to rely more on the greater expertise of the Medical Consultant and may require additional training and mentoring until they become proficient and comfortable in the use of their job skills. There is near universal endorsement of the SDM from all member components of our association.

Implement expanded use of detailed rationales at the initial level but otherwise leave this level of adjudication the way it is since it provides the claimant with a decision on his or her claim in a more timely manner than is projected with the FPM. We believe that the claimant’s initial experience with the disability process more often than not shapes his or her opinion of the whole disability process. Therefore, we believe that it is important to get an accurate decision to the claimant as quickly as possible. The current process, with increased emphasis on process unification and inclusion of the rationale process, does this and does it faster than the Full Process Model. The additional emphasis on process unification and adding the rationale is projected to add only minutes to the time required
to process each initial claim, rather than days, weeks or even months as is currently projected in the Full Process Model. It is important that SSA make a commitment for the resources that will be needed by the DDSs for the additional time required to write rationales. There is near universal support throughout our membership for the implementation of rationales.

Keep the current reconsideration level of appeal but this step should be enhanced. While NADE has serious concerns about the financial impact of the Pre-Decision Interview (PDI), we would suggest that the PDI could be implemented at the reconsideration level of appeal. This will enhance this appeal step, provide the claimant with a better understanding of the reason their claim was denied and, hopefully, reduce the appeal rate to OHA.

Eliminate the Adjudication Officer.
SSA's own pilot studies indicate this is not cost effective and adds little, if anything, in the way of improved customer service.

Eliminate the Appeals Council Request for Review as an appeals level.
The AC review adds little to the process in terms of improved claimant service and is difficult of the claimant to understand. The decision of the Administrative Law Judge should be the final one for the agency. An increased emphasis on Process Unification and an improved QA review should eliminate the need for any further review by the Appeals Council.

Revise the current Quality Assurance system to ensure that all components in the disability process receive fair and meaningful feedback. All SSA disability decision-makers should be subjected to centralized QA review at the same rate and proportion of their allowance/denial decisions. This would help ensure that process unification is being applied.

NADE believes that the above process would provide improved customer service and do so in a more cost effective and more timely manner than is proposed by the Full Process Model. Our reasoning is outlined below.

First and foremost, as we stated at the meeting on November 5, Process Unification must remain a critical piece of the puzzle. It is our opinion that process unification could be one of the major success stories of redesign. We support SSA’s ongoing efforts to bring consistency in evaluation and decision making to the disability program. We have been somewhat disappointed at what we consider to be the general lack of consistent application of the principles of process unification and SSA’s general lack of commitment to continued cross training between the various components of the disability process. We were very pleased to observe that this is one of the top priority items outlined in the report submitted by the Social Security Advisory Board (please refer to page 19 of the August,
1998 report entitled, "How SSA’s Disability Programs Can Be Improved"). The Advisory Board declared, “The most important step SSA can take to improve consistency and fairness in the disability determination process is to develop and implement an on-going joint training program for all of the 15,000 disability adjudicators, including employees of State disability determination agencies (DDSs), Administrative Law Judges (ALJs) and others in the Office of Hearings and Appeals (OHA), and the quality assessment staff who judge the accuracy of decisions made by others in the decision making process.” The Advisory Board further stated, “We urge the Commissioner to make a strong ongoing training program a centerpiece of the agency’s effort to improve accuracy, consistency, and
fairness of the disability determination process, and to see that the necessary resources are provided to carry it out.” NADE strongly concurs with this recommendation. Without such ongoing joint training, we believe that any effort to redesign the disability program will not succeed. NADE also firmly believes in the continuation of the Intercomponent Policy Group to develop initiatives focusing on the uniform application of the laws, regulations, and rulings of SSA. Our members have voiced strong support for the need for SSA to encourage a closer working relationship between all components of the disability program.

NADE strongly endorses the utilization of the Single Decision Maker (SDM). We believe that this concept meets the objectives of redesign. We urge caution, however, in allowing inexperienced disability adjudicators to serve in this capacity. As we have stated previously, it has been advocated by those whose knowledge of program requirements gives them the expertise to voice such an opinion, that it takes a minimum of two years for a disability adjudicator to become proficient at their job. Therefore, the less experienced adjudicators may rely more on input from the Medical Consultant than more experienced adjudicators. Also, they may need additional training and mentoring. We do believe, however, that the SDM concept does allow adjudicators to take action on those claims for which they are trained and reserves Medical Consultant time for those more medically complex cases where their greater medical knowledge will enhance the DDS adjudication of the claim. We believe that by freeing these consultants from the requirement that they spend much of their time signing off on cases, then they will be much more available to provide needed in depth analysis in complex case situations. This makes better use of the consultants’ expertise and allows them to work more closely with training of adjudicators and other doctors on the medical aspects of the disability program.

NADE endorses the expanded use of rationales at the initial level of adjudication. We fully believe that the requirement to fully explain the decision will provide better service to the claimant and will allow subsequent reviewers to more fully understand the process that went into making the decision. Rationales represent key development and processing improvements needed for quality decision making. Rationales also meet the requirements of SSA’s own regulations and rulings. We support the elimination of the personalized denial notice as being redundant and would support mailing a copy of the rationale to the claimant with the denial notice. It is imperative that SSA make a commitment to provide the necessary resources and training before full implementation is launched. SSA
must recognize that additional time will be necessary for the rationale process, time that must be reflected in lower caseloads and lowered expectations from SSA regarding DDS’s PPWY. NADE strongly opposes the use of "canned" rationales as we believe use of such provides a disservice to the claimant and to SSA. NADE does believe that the claimant, the public, and subsequent reviewers are entitled to a clear explanation of how the decision was reached to deny benefits.

NADE also endorses utilization of the Pre-Decision Interview (PDI). The intent of the PDI is to ensure that all pertinent evidence is in the file and to increase the claimant’s understanding of the disability process and the program requirements for disability. It is also meant to give the claimant the opportunity to make additional points on his or her behalf. While we endorse the concept of the PDI, we also have some very real concerns about how this entity will be implemented. To date, SSA has not committed its position with regard to how this concept will be implemented. In the pilot study, use of the PDI did apparently have an impact on the allowance rate and the appeal rate. A small percentage of claims (3.2%) were approved after the PDI that would have been denied otherwise and the
pilot study forecast an 8% decline in the appeal rate. In the FPM, 56% of claimants offered the PDI took advantage of the opportunity and 6% of these talked face-to-face with the disability decision maker. NADE would offer the opinion that both of these figures will be much higher in the real world of disability adjudication. We believe that more claimants will accept the offer of the PDI and many more will request a face-to-face interview. Our belief is that once PDIs are in effect at the initial level, claimant representatives will increase their media campaigns to become involved in the process much earlier than most of them do in the current process. Also, if allowed a face-to-face interview, claimants are much more likely to seek legal representation earlier in the process, especially for purpose of the PDI. Legal representation at the PDI may substantially increase the processing time at this level.

It is not clear how many PDIs are expected to be face-to-face interviews and we have not seen any estimates regarding the projected costs for face-to-face interviews. If disability adjudicators are to be expected to travel to conduct face-to-face interviews, then travel expenses will be enormous, both in per diem costs and travel time if adjudicators must leave the DDS to conduct the PDI. Who will pay these costs? How will the DDSs be able to handle the increased demand for face-to-face interviews? Many DDSs are still poorly equipped at the present to handle their current hearings workload. Where will they find space to handle the PDIs? There are security concerns that must be addressed and which will have a financial impact on the process. A whole workday can easily be lost while an
adjudicator travels across the state to conduct one face-to-face PDI. NADE believes that the estimates of the time required to conduct these PDIs will greatly expand and will have a tremendous impact on DDS workloads. It will be necessary for SSA to lower its expectations regarding DDS PPWY. Until SSA makes a commitment with regard to the logistics of how PDIs will be conducted, who will pay the expected costs of claimant and/or adjudicator travel and the training expenses that will be necessary for the adjudicator, the state DDSs will continue to have very real concerns about the impact of the PDI on their financial and manpower resources.

What about the costs of training adjudicators to conduct PDIs? NADE firmly believes that it is foolhardy to believe that the PDI will continue to remain the informal interview that it was apparently envisioned to be unless regulatory language is expressly written to ensure this. Once the PDI is implemented, we believe the demand for increased face-to-face interviews will increase and so will claimant legal representation. DDSs across the country have hired new adjudicators for years with little thought given to an individual’s “people”’ skills. SSA will have to work closely with the state DDSs to emphasize the need for consistent and thorough training in conducting interviews. It will probably be necessary for all disability adjudicators to receive training similar to that which is currently provided to disability hearing officers. Interview skills and the ability to present a positive image for SSA will be of critical importance to the program. Without more thought being given to how the PDI will work, we have to express great concern for the potential impact it may have on the public’s trust in the disability program. NADE strongly urges that DDSs be given the latitude to have only selected, experienced and trained adjudicators conduct the PDls. By necessity, we believe that adjudicators who conduct PDls will require the same training that is currently provided to disability hearing officers. PDIs will evolve into more formalized hearings unless the regulations are written to require only telephone interviews. If face-to-face interviews are permitted, and claimants are allowed to bring legal representation, then the disability adjudicator will require the necessary training and skills to handle these types of hearings. Inexperienced adjudicators should not be required to conduct PDIs until they have demonstrated a sufficient knowledge of the program and the diplomatic skills that will be necessary to handle such interviews. SSA should provide the necessary training to equip current adjudicators with these skills.

The PDI will add considerable length to processing time. While the FPM model, which has the PDI being implemented at the initial level of adjudication, forecasts an additional 26 days that would be added to the DDS processing time for denials (11 days are added for allowances), we believe that these timeframes will increase substantially over time as more and more claimants request the PDI (especially the face-to-face PDI) and as the claimant representatives become much more involved earlier in the process. Because of the additional time and financial resources that will be needed to conduct the PDI and the fact that most DDSs utilize their less experienced personnel to adjudicate initial claims, we oppose the implementation of the PDI at the initial level of adjudication but we
do feel that the PDI has merit at the reconsideration level.

NADE firmly believes that allowing the claimant to have more personal contact with the disability decision maker will provide the claimant with a better understanding of the disability process. However, we would like to point out that nearly 50% of the claimants who are denied at the initial level do not pursue their appeal rights. Therefore, it is not cost effective to implement the PDI at this level and SSA loses nothing in the way of customer service by not implementing the PDI at this level. Those claimants who pursue their appeal rights will receive an opportunity to submit additional evidence and receive a clear explanation for the reasoning behind the decision on their claim at the newly enhanced reconsideration level. If handled incorrectly, the PDI has great potential for adding
job security to SSA’s litigation staff. However, we believe that the PDI, if handled by an experienced and well trained adjudicator, could provide the claimant with a clear perception of how his or her claim was adjudicated, the program’s requirements and the exact reasoning why the claimant did not meet those requirements. This will provide the claimant with a positive impression of the disability program and enhance the public’s confidence in the integrity of the program and its ability to provide excellent customer service.

NADE opposes the elimination of the reconsideration level of appeal. We recognize that the FPM would result in an increase in the number of cases flowing to OHA. This is a problem since OHA has not shown that they can handle these additional cases. The Adjudication Officer, which apparently was designed to provide some cushion for OHA, and which we believe is just another name for the reconsideration step, has not shown that it can be effective, either in terms of the costs of doing business, or with improving customer service. The AO does not provide a realistic alternative to reconsideration. NADE believes that if the reconsideration level of appeal is eliminated, OHA would be overburdened with cases very quickly. This would add to the pending backlog and also lengthen
the already extended time that will elapse before a claimant can receive a hearing before the ALJ. SSA will necessarily have to take remedial steps to alleviate this problem, most likely by the creation of new positions in OHA that would, in effect, serve as an intermediate level of appeal. Whether these positions would be called AO or reconsideration or any other name, it would still be implementing an intermediate appeal step. Reconsideration by any other name is still reconsideration. However, if SSA does proceed with the elimination of the reconsideration step, we urge that SSA plan now for the anticipated number of appeals to OHA, rather than having to later implement emergency stop-gap measures to a crisis situation.

SSA has indicated that they are relying on the administrative cost savings from the elimination of reconsideration to pay for the expected increased costs made necessary by the expanded use of the rationale and the PDI. NADE firmly believes that the costs of these additional labor intensive steps will far exceed the cost savings realized from the elimination of the reconsideration level of appeal and SSA will have to look elsewhere to obtain the additional financial resources that will be required. Since the Commissioner has indicated that no additional resources should be expected, this will pose a significant problem for SSA.

As it is currently utilized, the reconsideration level of appeal is often perceived as a necessary evil, an appeals step that serves virtually no purpose but to add additional time and frustration to the claimant and presents a negative impression with regards to SSA’s attempts to improve customer service. We believe that a strengthened reconsideration level of appeal will produce greater administrative cost savings and better customer service than is realized by the current process or the FPM. Our recommendation would be that the initial level of adjudication be maintained as it is, with the addition of the rationale, and the PDI be added at the reconsideration level, which would then be made a more viable appeals level. An enhanced reconsideration level of appeal would continue to serve as a screening step for OHA, reducing the number of cases appealed to OHA, if the current 8% decline in the appeals rate attributed to use of the PDI were to continue. Implementation of the PDI at this level of adjudication would have the greatest chance for making a positive impact on the disability program since the state DDSs, almost without exception, utilize their more experienced personnel to adjudicate the reconsideration claims. This would solve one of our concerns that using inexperienced adjudicators could result in improper handling of the PDI process and leave the claimant and the public with a poor perception of the
disability program. Also, since 50% of those claimants denied at the initial level of adjudication currently do not appeal their claim to the reconsideration level, then there will be cost savings realized by not conducting PDIs on cases where the claimants do not intend to pursue their appeal rights. The PDI would also eliminate the need for a detailed rationale at the reconsideration level. It might be prudent to test this proposal to see if it would actually result in a REAL reduction in the number of cases appealed to OHA since the FPM forecasts an additional 5% more cases (or nearly 25,000 cases) arriving at OHA than they receive under the current process. Since OHA has not demonstrated that they are capable of handling the additional caseload anticipated by the FPM, is it wise to
proceed with a model that increases their workload? NADE believes that the state DDSs fear that an overburdened OHA will resort to greater use of the informal remand process. Again, NADE would express the opinion that greater use of the informal remand process is just another name for reconsideration.

NADE strongly opposes any attempt to proceed with national implementation of the Adjudication Officer (AO). SSA’s own statistical data has indicated that this position is not cost effective and does little toward achieving the desired goal of improved customer service. In the FPM, the AO fully develops the record in preparation for the hearing by the ALJ and maintains authority to allow the case if fully supported by the evidence in the file. Cases that cannot be allowed on a fully favorable basis are then forwarded to the ALJ for a formal hearing. Currently, the pilot studies show that the AO processes an average of one case per day, a poor trade when compared to a reconsideration adjudicator who processes three cases per day and can both allow or deny the claim. The AO also
requires much greater staff support than is presently required by the reconsideration adjudicator. Many NADE members who currently serve in an AO position have reported that there is low morale, poorly defined job duties, little professional recognition from OHA or claimant’s legal representatives, inadequate staff support, inadequate logistical support, etc. NADE believes that there will be cost savings realized from a lowered appeal rate if PDI is implemented at the reconsideration level of adjudication and with the elimination of the AO position. This anticipated cost savings resulting from fewer cases being appealed to OHA may be sufficient to provide the needed financial resources to continue the enhanced reconsideration level of appeal. Fewer cases being appealed to OHA would
eventually allow them to eliminate their backlog and proceed to hold hearings on appealed cases more expeditiously. Thus, the claimant is better served by less time needed to receive a hearing. NADE firmly believes that the enhanced reconsideration level of appeal is more cost effective and provides a more positive impact on the disability program than the AO position.

NADE supports the elimination of the Appeals Council Request for Review as an appeals step. This would reduce the number of appeal levels from the current four to three, including an enhanced intermediate appeal level. The process would resemble the nation’s current judiciary system where there is an intermediate appeal level which separates the trial court from the Supreme Court. The Appeals Council Request for Review does not provide a meaningful level of appeal that meets the criteria established by the Redesign Team. NADE urges that SSA revise its current quality assurance process to make this system more equitable and to allow more meaningful feedback to the various components of the disability program. NADE is on record as stressing the need for greater consistency in the QA process and we outlined our concerns to SSA’s Associate Commissioner for Disability in a letter dated August 27, 1998. We believe that SSA must make a decision to apply a preponderance of evidence review standard rather than substantial evidence review standard. Consistency in evaluation and decision making in the disability program is expected just as much by those who make the decisions as by those who receive our decisions. We appreciate SSA's response to our concerns and look forward to working together to investigate possible remedies. We do believe that SSA took a giant step forward in August, 1998, when it began
conducting reviews of a limited number of favorable decisions made by OHA. Although not specifically a QA issue, we would also encourage ongoing medical training for Administrative Law Judges. We would like to emphasize that allowance and denial decisions should be reviewed by a centralized QA component in direct proportion to their share of the workload. We believe that the current process, which places a heavy emphasis on quality review of DDS allowance decisions and OHA denial decisions is neither fair nor consistent.

In conclusion, NADE believes that a greater emphasis on process unification by all components in the disability process will increase the number of appropriate allowances being achieved earlier in the process and will continue to bring greater consistency between the DDS and OHA components. This will lead to more cases being allowed earlier in the process without the unnecessary delays demonstrated in the Full Process Model. The expanded use of detailed rationales will provide the claimant and any subsequent reviewer with a clear understanding of how the decision was reached. An enhanced reconsideration level of appeal, using the PDI, will lead to more allowances at this level and provide the claimant with an opportunity to have personal contact with the adjudicator who
will decide his or her claim. It will also provide the claimant with a much better understanding of the disability process. With a projected increase in the allowance rate at the reconsideration level resulting from implementation of the PDI and with fewer appeals of denied claims also resulting from implementation of the PDI (SSA forecasted an 8% decline in appeals with utilization of the PDI and we believe that this figure will be even higher if the PDI is implemented at the reconsideration level), then fewer cases would arrive in OHA than do so now under the current process and especially as projected under the Full Process Model. This should permit OHA to improve their timeframes for conducting hearings. Thusly, the objectives of Redesign will have been achieved.

We appreciate the opportunity to provide these comments. As always, we look forward to working with the staff at DPRT and SSA to continue the ongoing process of self examination to ensure that the disability program of the 21st century is operated in the most cost efficient manner possible that also provides the best customer service.

Questions regarding NADE’s position on the Full Process Model should be directed to our current President, Jeff Price at 1-800-443-9359.

Media interest should be directed to our media spokesperson, Tom Christopher at (608) 266-7128.