I have continued to study the House and Senate versions of the appropriations bill that is supposed to cover Social Security for Fiscal Year (FY) 2012, which began on October 1. I now realize that, as some readers had tried to explain to me, the House Bill is actually better for Social Security than the Senate bill. It gives Social Security a bit more money. I'll not bore you with the details of my confusion. I've said many time that appropriations bills confuse me. If you've ever tried to read one you know why but you may not understand why I was stubborn about it. I don't understand that either.
A more important point is that both bills would hurt service to people filing claims with Social Security. The Senate bill gives the agency about $11 billion plus $896 million which must be spent only on continuing disability reviews and SSI redeterminations (which I will call program integrity). The House bill gives the agency about $11.25 billion plus $896 million for program integrity. The comparable figure for FY 2011, which just ended, was $11.4 billion which could be used however the agency chose. Certainly, some of the FY 2011 appropriation was spent on program integrity but far, far less than $896 million. For everything other than program integrity, Social Security had $11.4 billion to spend in FY 2011 but would have only $11 billion to $11.2 billion in FY 2012 if one of these two bills is adopted. Social Security could and would use creative accounting to stuff as much overhead as possible into the program integrity category but however you cut it, the operating funds for taking and adjudicating new claims will be tight, especially when you consider that new claims continue to increase at Social Security and that the agency is already committed to expensive technology purchases and to the building of an expensive new national computing center.
The likelihood that there will be a huge increase in program integrity work while the processing of new claims suffers would bother me less if I thought that Social Security could spend that $896 million efficiently. The program integrity work certainly needs doing. I just think we're heading into a confused, wasteful crash program. Let's use a crude method of evaluating this. Social Security has estimated that for every $25 million less than the fiscal year 2011 budget they get that they will have to furlough all their employees for a day. By this measure, the $896 million for program integrity amounts to about 36 work days for Social Security's entire staff. Since there are only about 250 workdays in an entire year, we are talking about devoting something like 14% of Social Security's workdays to program integrity. That would be up from, I'll guess here, something less than 5%. That is a huge change.
The first part of this program integrity work is SSI redeterminations, making sure that SSI recipients are still poor enough to qualify for benefits. SSI income and resources rules are highly technical. If you don't think the rules are that technical, look back at this week's Quiz. It presented a simple straightforward SSI resources question, one that comes up fairly frequently. Only 12% of those taking the quiz got it right. Social Security only has so many SSI specialists. There is only so much overtime they can work. Some employees who are currently doing something other than SSI are going to get pulled off their current duties, hurriedly trained and put to work doing SSI redeterminations. Otherwise, Social Security won't be able to spend the money and those employees are going to get furloughed. These newbies are going to make mistakes. The poor claimants who get shortchanged will not have anyone representing them because there are few attorneys in private practice who know enough about SSI to represent them and because there is little way for the attorneys who do to make any money representing these people. The employees converted to doing SSI redeterminations will be unavailable to do what they had been doing previously, which has mostly been handling new claims. Those are going to pile up.
Things are a bit better with the other part, continuing disability reviews (CDRs). This work is mostly done at the state Disability Determination Services. Their disability examiners should already be trained to handle the CDRs; at least I hope they are. Unfortunately, there is one major bottleneck. Once someone is cut off, they can appeal. The first level appeal requires a hearing not by an ALJ but by a DDS hearing officer. There are precious few of these hearing officers, nowhere near enough to handle the flood of terminations that may be headed their way. This is going to be a serious bottleneck. There will be no quick solution. These cases could get dumped on ALJs but that makes the backlog of cases awaiting hearing before ALJs worse.
The likelihood that there will be a huge increase in program integrity work while the processing of new claims suffers would bother me less if I thought that Social Security could spend that $896 million efficiently. The program integrity work certainly needs doing. I just think we're heading into a confused, wasteful crash program. Let's use a crude method of evaluating this. Social Security has estimated that for every $25 million less than the fiscal year 2011 budget they get that they will have to furlough all their employees for a day. By this measure, the $896 million for program integrity amounts to about 36 work days for Social Security's entire staff. Since there are only about 250 workdays in an entire year, we are talking about devoting something like 14% of Social Security's workdays to program integrity. That would be up from, I'll guess here, something less than 5%. That is a huge change.
The first part of this program integrity work is SSI redeterminations, making sure that SSI recipients are still poor enough to qualify for benefits. SSI income and resources rules are highly technical. If you don't think the rules are that technical, look back at this week's Quiz. It presented a simple straightforward SSI resources question, one that comes up fairly frequently. Only 12% of those taking the quiz got it right. Social Security only has so many SSI specialists. There is only so much overtime they can work. Some employees who are currently doing something other than SSI are going to get pulled off their current duties, hurriedly trained and put to work doing SSI redeterminations. Otherwise, Social Security won't be able to spend the money and those employees are going to get furloughed. These newbies are going to make mistakes. The poor claimants who get shortchanged will not have anyone representing them because there are few attorneys in private practice who know enough about SSI to represent them and because there is little way for the attorneys who do to make any money representing these people. The employees converted to doing SSI redeterminations will be unavailable to do what they had been doing previously, which has mostly been handling new claims. Those are going to pile up.
Things are a bit better with the other part, continuing disability reviews (CDRs). This work is mostly done at the state Disability Determination Services. Their disability examiners should already be trained to handle the CDRs; at least I hope they are. Unfortunately, there is one major bottleneck. Once someone is cut off, they can appeal. The first level appeal requires a hearing not by an ALJ but by a DDS hearing officer. There are precious few of these hearing officers, nowhere near enough to handle the flood of terminations that may be headed their way. This is going to be a serious bottleneck. There will be no quick solution. These cases could get dumped on ALJs but that makes the backlog of cases awaiting hearing before ALJs worse.
4 comments:
I can't speak for SSA nationwide. In my urban California office, we have 8 T2 CR's and 18 T16 CR's and a waiting room with more T16 claimants than T2 claimants. To adjudicate a T16 claim, the CR's have to know all those non-medical, technical rules. We have to know what decision to make about the jointly owned house in order to pay the initial claim. Since the agency is pushing Internet claims and disability reports, very little field office time is spent on discussing someone's medical condition during the claim process. We spend most of our time already resolving income, resource, and living arrangement issues. Ramping up the redeterminations will force us to do a more formal review and move staff resources around, so claim processing time may suffer since there will be no new employees. And doing redeterminations always results in increased overpayments because of all the unreported issues (and there will be many unreported issues). And that creates more appeals and waiver requests on overpayments which will also use up employee resources. But we already know how to do redeterminations.
You need to look at the SSA funding in the greater context of the Labor-HHS appropriations bill. Every other agency and program was cut significantly - Labor Dept by 20 percent, all of the funding for the Administration's health care reform law is zeroed-out. This House proposal is a political tactic, setting up the Senate Democrats and the White House to choose between funding the unpopular "Obamacare" reforms or Social Security programs.
These House numbers will not be enacted.
i just dont understand mr. hall's premise. in a zero sum world there will always be some tradeoff in priorities. but would you rather the agency never get extra money to handle long dormant work? the goal of all this is to reign in overpayments. of course there will be growing pains. but the solution is not to keep things exactly as they are.
Another freaking Card Center is opening on the 17th, but money is tight at SSA. What BS
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