Social Security can't possibly have a specific intention in publishing this request since the current Commissioner of Social Security leaves office in less than three weeks and no one knows who will succeed him. So what might this portend? Australia has recently gone through a process to incorporate the ICF into its disability determination. Take a look at what the Aussies ended up with. It involves a lot of vague terms such as mild, moderate, severe and extreme that have proven to be be indefinable in U.S. disability determination. (U.S. Social Security defines "moderate" as more than "mild" and less than "severe" and "severe" as more than "moderate" and less than "extreme.") The Aussie system also involves a point system -- as in 5 points for mild, 10 points for moderate, 20 points for severe and 30 points for extreme. Apparently, there is some explicit consideration of work capacity as well as consideration of the labor market at some point.
What happened in Australia was probably far from inevitable once the decision was made to use the ICF. My very, very early impression is that ICF does not dictate any process for determining disability; it looks like an empty glass into which you can pour whatever you want.
If Social Security wants to completely redo determination of disability, ICF would be a way of doing it. Whether the change would be for the better or worse would be determined as we go along. At least, we're likely to have a Democrat as Commissioner of Social Security for the next six years.
The ICF would also be a great way of telling Congress that wonderful changes are on the way -- and, by the way, Congress, could you allow interfund borrowing so the Disability Trust Fund doesn't run out of money before we get these wonderful changes in effect? Those of you who remember former Commissioner Barnhart may recall how her wonderful "plan" kept Congress off her back about those awful hearing backlogs for six years. Introduction of her "plan" always seemed just around the corner. In the end, Barnhart introduced her "plan" as she was about to leave office. Barnhart's "plan" turned out to be worthless and was quickly abandoned by her successor. I doubt this came as a surprise or disappointment to Barnhart. Her "plan" was probably a success in her eyes since it had achieved its goal of keeping Congress off her back. My rule is to beware of any plan that a public official is just
starting to implement as he or she is leaving office. If the public
official really had a great idea, he or she would have implemented it
long before leaving office. Still, the ICF could be a useful tool to help persuade Congress to allow interfund borrowing.
The SSA has been grappling with the difficult process of assessing function for a long time. Consideration of the ICF is not a new idea and the recent request for comments has nothing to do with the current commissioner's pending departure.
ReplyDeleteRegarding Jo Anne Barnhart's Disability Service Improvement (DSI) initiative, this is not as simple as described. The goal of DSI was to improve the disability process by shortening the decision time and paying benefits earlier in the process. It was a failure due to the cost involved. For those of us who working in the disability program during Ms. Barnhart’s tenure, she will likely be remembered for her efforts to successfully move the agency to a fully electronic disability case process. This is the most significant contribution to the agency in many years (if not decades).
It seems that Mr. Hall relishes viewing the world through a "blue is good and red is evil" paradigm. However, the truth is that most of us are various shades of purple and we are all working toward the same goal of providing the best possible service to the American public. To suggest otherwise is an insult to dedicated public servants and diminishes Mr. Hall’s credibility.