From a recently issued section of Social Security's Program Operations Manual Series (POMS):
The RPC [Request for Program Consultation] website [http://ssahost.ba.ssa.gov/erpc/index.aspx] is supported by database management software that captures and maintains RPC data entered by the Disability Determination Services (DDS) and the Office of Disability Programs (ODP) users on the DDS RPC and ODP RPC Resolution templates.The RPC database creates a repository of policy issues that can be used as a reference by all adjudicative components.
Of course, the link to the RPC website only works if you are on Social Security's network. We have a "repository" of Social Security policy decisions to be used by all parts of the Social Security Administration, but the public cannot access it. Does something sound odd about that?
6 comments:
Those "RPC resolutions" are about disputes between the various DDS's and the SSA quality review component that assess DDS work product. So if the quality review component says "you got it wrong" and DDS asserts "no we didn't," the fact-specific resolution ends up available only to insiders. Insiders who consult this resource get this warning:
"RPC resolutions are not policy guidance. Each RPC resolution is based on the unique facts and discussion questions raised by each case. If you wish to cite authoritative policy guidance, please cite regulations, SSRs, POMS, etc."
If Mr. Hall wants to bitch about unpublished SSA materials—and my sense is that he is quite devoted to this activity—then he ought to aim his complaints at SSA's Q&A's. I will say no more.
Mr hall,it's your right to complain,contrary to the above opinion.This country is lacking,obviously in government because of republicans.
There is a legitimate need for internal discussion of policy disputes and consultation with SSA policy experts for informal advice that is not published or interpreted as Agency policy.
Again with this incessant agency-bashing based on ignorance.
Every organization--including I suspect even your office--has an internal network and an external network. The fact that something is on the internal network only means it is not linked to the Internet--it does not mean that the agency is trying to "hide" something from the public. In fact, most of what is on the internal network is also on the Internet site. It is just that by having an internal network (an Intranet) employees can access information more easily that they could if they have to go out on the web and compete with Internet traffic.
The other purpose of the Intranet is to communicate to employees information that is only of use/interest to them--such as personnel procedures and the like.
You seriously need to stop imagining conspiracies under every rock. It is bad for your mental health and the understanding of your readers.
I can think of a couple reasons why these aren't accessible to the public.
The first would be that they make the state agencies look bad. Really bad actually. The types of fundamental errors being made over and over again on certain relatively complex case issues, which are predominantly caused by a severe shortage of experienced disability examiners and productivity demands which are far too high to properly analyze a case. Also to a lesser degree it would reflect poorly on the OQP reviewing component who often make just as absurd decisions, and the resolutions can often be summed up along the lines of "you're both way off".
A second issue could be related to confidentiality, given that these are live cases filled with many personal details, although all identifying information is stripped from the summaries and the only available way to find the cases is the EDCS case number, which is probably not relevant outside of SSA's network.
Having read a large of number of these myself, they are fascinating and certainly informative for someone primarily interested in DDS issues.
Legal reps should applaud such "secret laws." The examiners that are trying feverishly to allow claims, are lining the legal reps' pocket books as an unfortunate indirect consequence of trying to get the disabled a few bucks to try to survive with every month.
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