Social Security has published some changes to its Program Operations Manual Series (POMS) that may explain the proposed regulatory changes it recently sent over to the Office of Management and Budget (OMB) for approval. The POMS change has the title, "Expedited Vocational Assessment at Steps 4 and 5 of Sequential Evaluation." The proposed change sent over to OMB has the title, "Expedited Vocational Assessment Under the Sequential Evaluation Process" so it sounds like these are the same thing. Why is Social Security already implementing a rule when it just asked OMB to approve a proposed rule?
2 comments:
A modest proposal (for those devoid of a sense of humor, this is not intended seriously). Have DDS review cases only through Step 3. If the claimant doesn't meet a listing,. let them deny the claim. That's all DDs does now anyway, so stop pretending that actual vocation analysis takes place. Steps 4 and 5 could only be accessed at the ALJ level. This would save billions in adjudication costs at the DDS level.
From a DDS perspective, I can say that Steps 4 and 5 are taken very seriously, and except for grid-allowances, Step 5 is a nuisance and wastes valuable time for the claimant, legal reps, third-parties, DDS, SSA, and ALJs. SSA did something here very valuable to your precious time.
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