NATIONAL ASSOCIATION OF DISABILITY EXAMINERS
NADE is a professional association whose purpose is to promote the art and science of disability evaluation. Our members have a unique understanding of the problems facing the Social Security program at this time and a strong commitment to maintaining a meaningful and viable disability program. Although the majority of our members are employed in the state Disability Determination Service (DDS) agencies, our membership also includes Social Security claims representatives, physicians, psychologists, attorneys, advocates and other professionals who work with, and are interested in, the evaluation of disability claims. We believe the diversity of our membership, as well as our experience working directly with the Social Security and SSI disability programs, allows us to address problems from a practical and realistic viewpoint. We understand the impact these programs have on the lives of disabled individuals and their families. We also recognize that the compelling needs of these individuals must be met within a framework of fiscal responsibility.
The perspective from which NADE views SSA’s readiness for handling the impending workload is unique. We acknowledge that SSA has been focused on the future of the Disability Programs. We have expressed support for exploring measures that may improve customer service, reduce program costs, and increase employee satisfaction. Many of the proposals look good on paper but the reality of testing and implementation has taken its toll on DDS resources. Without adequate additional resources to implement and/or test the initiatives, DDSs have had to rely on the limited number of experienced employees and current budgets. The remainder has been stretched to operational limits in order to handle the usual daily workloads and has resulted in an unusually high number of turnovers in many state agencies. Front line workers are reluctant to consider the future of the Agency Programs, as they are unable to handle the current levels of stress they are now working under. The increasingly rapid turnover of case processing staff and the continuing loss of experienced personnel will have a significant impact on the quality of service delivery that the DDS’s can provide and the public deserves. This potential adverse effect on service delivery is an important issue for NADE, for the DDSs, and this Committee.
The reduction in the number of Field Office personnel and the increase in the number of telephone claims have had a negative impact on the completeness of these initial applications received in the DDSs. Disability adjudicators are forced to spend additional time re-contacting the claimants to adequately complete the applications. This has had a positive impact on quality of the decision-making process but a negative impact on processing time and the time adjudicators have to spend on other duties.
On April 1, 1994 the Social Security Administration issued its Plan for A New Disability Claim Process. The five primary objectives of this plan were:
· Making the process “user friendly ” for claimants and those who assist them · Making the right decision the first time · Making the decision as quickly as possible · Making the process efficient · Making the work satisfying for employees.
In March 1999, following five years of piloting various elements of the Redesign Plan, the Commissioner announced his decision to begin implementation of a new process, which combined several key elements of the original plan. These included: · A single decision maker · Pre-decision interview (now known as a Claimant Conference) · Expanded explanations · Elimination of the reconsideration level of appeal · Improvements in the Hearing process
Beginning with initial claims filed on or after October 1, 1999, this new process was to be prototyped in 10 state DDSs and would include 20% of the total initial disability claim workload.
NADE had previously expressed concern about the negative impact on OHA workloads as a result of eliminating the Reconsideration step from the appeals process. We did not believe the full impact imposed by this new process in terms of processing time and examiner responsibilities, had been adequately evaluated. For that reason we were pleased that it was being prototyped rather than being rolled out nationally.
We are now five months into the new process. Although it is too early to know with certainty, preliminary anecdotal evidence suggests that this new process neither increases customer satisfaction nor improves employee morale. Results of the prototype must be evaluated very carefully and objectively before national rollout of the new process. Also, before this new process can be successfully rolled out, DDSs must begin to hire and train adequate staff to handle this workload. This hiring and training of new staff, and the necessary retraining of current staff, must begin immediately if the DDS’s are expected to be in a position to successfully handle the workload. What we are seeing instead is the continued loss of experienced staff and, because of Federal and State budget reductions, the inability to hire and properly train replacements.
It is commonly recognized that it takes at least two years for a disability examiner to become proficient. This time is likely to increase as the complexity of the process and the increasing diversity of our customer base increases. While nationwide the number of disability examiners with less than 2 years of experience has increased, the DDSs are also faced with a large percentage of staff reaching retirement age. When SSA began administering the SSI program in 1973, most DDSs hired large numbers of examiners to handle that workload. These employees are now reaching retirement age. As this pool of experience is lost it will become more difficult for the DDSs to train and mentor new examiners.
NADE has consistently urged that SSA’s administrative budget, like its program budget, be removed from the cap on discretionary spending. We concur with the views expressed by the Social Security Advisory Board that: “… SSA’s staffing resources have declined significantly over the last 2 decades, while the agency’s workload has increased and become more complex. The agency’s tight resource constraints limit its capacity to respond to these growing workloads.” This is as true in the DDSs as it is in the Field Offices. Additional staff is needed to handle the increasingly complex workload.
The Social Security Administration has announced their intention to revise and update a number of the medical listings. While it is important that the criteria used to establish disability be updated, this again impacts resources. As presented to this Association these changes in the listings- including an increased emphasis on credibility and functionality-will require substantial training and will significantly increase the demands on adjudicators. The time necessary for an examiner to address issues like credibility and functionality will increase the time adjudicators will spend on each case. While this should increase the quality of our decision-making, it will decrease the time available to spend on other cases. Adjudicators will necessarily have to assume smaller caseloads. This will result in an increased need for additional staff in the DDSs.
Many of SSA’s administrative costs (salary, maintenance, etc.) are fixed or rising. Therefore, in order to meet the current budget limitations on administrative costs, the DDSs are being asked to reduce medical expenditures. Accurate medical decisions require quality medical evidence. Both program costs and public service are negatively impacted if spending for administrative costs is not sufficient to ensure accurate decisions. Program costs will increase if claims are allowed inappropriately and public service will decline if claims are denied inappropriately.
SSA has launched initiatives to improve the quality and retrieval of the medical evidence of record (MER) and/ or the purchase of consultative examinations (CEs) necessary to the adjudicative process. However, the DDSs are not sufficiently staffed to implement these essential outreach and training activities. We are unable to undertake the actions necessary to improve the quality of medical evidence as current resources are not sufficient for effective outreach to the medical community and preclude the desirable monitoring of CE providers. Staff shortages require that all resources be directed to adjudicative positions. Again, NADE acknowledges the need for these improvements but recognizes the inability for DDSs to implement due to the shortfall of available resources.
In conclusion, NADE would offer the comment that the ability of SSA and the DDSs to successfully meet the challenges of the future workload is contingent on many features, some of which we have described in this testimony. This Committee has already heard from a variety of witnesses and will hear from others. NADE is very grateful for this opportunity to share some of our concerns. SSA’s workloads are projected to increase and the Disability workload alone is expected to increase by 47% over the next ten years. Because of the increasing complexity of the disability workload and the continuing changes that are made in the program itself, SSA and the DDSs must begin today to prepare for this tremendous challenge. If we are to begin, we must be allowed the tools and resources to do so.
Mr. Chairman, Honorable Members of Congress, thank you for your consideration of these issues.