DSI New Decisional Software

Some excerpts from the minutes of recent Executive Committee meetings of the National Council of Social Security Management Associations (NCSSMA) (emphasis added):

The DDS’s will have new software that will walk them through the decision making process [under DSI] to improve accuracy and consistency. They believe that the cases will initially take them longer due to the learning curve of the new software. It will probably not take less time but will standardize and upgrade the quality of the product...

Now the first appeal level is the federal reviewing officials (FEDRO) that will be centralized in Falls Church, VA. ... This level of appeal is expected to take the same amount of time as a reconsideration takes now. However, due to the quality of the decision making using the new software, the expectation is that allowance will be identified sooner keeping some cases out of ODAR (formally [sic] OHA). If the FEDRO disagrees with anything that the DDS documented, they have to document point by point what the changes are. The changes will be sent to the DDS so that they can see where issues are being overturned...

The judges have to follow the same process using similar software as DDS and the FEDRO.

There have been indications all along that Social Security intended to use some new software for the DSI experiment. It was unclear though whether this was merely sofware designed to keep track of cases or whether it was more substantive, software that would potentially have an effect upon how the case was decided. The material above makes it fairly clear that this new software is substantive. This raises at least a couple of issues. First, will it work? SSA has a history of trying to implement software that did not work and had to be abandoned. If that happens, DSI is likely to die quickly. Second, to what extent will the new software influence the outcome by making it harder for ROs and ALJs to overturn prior decisions? It sounds from the description above that this is the intended result. At the initial level all that DDS must do is to make a decision. At the RO or ALJ level, there must be "point by point" documentation to justify overturning the prior decision. This could easily make the ALJ hearing something other than a de novo proceeding.

This also adds a new abbreviation -- FEDRO. That name makes anyone who has traveled much on I-95 think of South of the Border.