Social Security has published in the Federal Register Notices of Proposed Rule-Making (NPRMs) for new Listings for genitourinary and respiratory system disorders and also a notice of a final rule establishing a new Listing for congenital disorders that affect multiple body systems. The National Association of Disability Examiners (NADE) had expressed concern when the multiple body system Listing was proposed. NADE believed that the new Listing would establish a significant and unrealistic barrier that would prevent many persons with Down Syndrome from qualifying for disability benefits. However, NADE was the only commenter on this proposal. I hope that ARC carefully reviewed this and that NADE was wrong. ARC gave Commissioner Astrue a big award. They wouldn't have done that if Astrue was about to dramatically harm people with Down Syndrome, would they? Would Social Security really want to deny benefits to people with Down Syndrome? I hope not.
4 comments:
Charles,
You keep talking about Astrue's initiatives, whether that concerns proposed rule making or procedural matters such as the secret ALJ business. As Commissioner, Astrue is a manager, pretty much a figurehead manager. He is not the one coming up with all of these ideas, good or bad. The last agenda-driven Commissioner we had was Dorcas Hardy. All, I repeat ALL of the initiatives you attribute to Astrue have come out of the SES. Do you really think Astrue got into the minutiae of therse individual Lastings? Of course not. Whether a Commissioner is Republican or Democrat or neither matters not a whit when it comes to what the machinery of the bureaucracy cranks out.
I agree with the first comment. Bravo!
As a retired SSA manager, I've concluded that it doesn't matter who is COSS, Astrue included. COSS is at the mercy of an entrenched SES at SSA, too many of them more interested in furthering (or protecting)their own careers rather than in doing what's best for SSA.
Once Astrue leaves office, I pray he will write an expose of his experiences at SSA and how some of his most forward-thinking initiatives were thwarted by the SES. I also hope he has the courage to give specific examples and name names. That would be a legacy!
Completely agree with this statement: COSS is at the mercy of an entrenched SES at SSA, too many of them more interested in furthering (or protecting)their own careers rather than in doing what's best for SSA."
I would add that it's not just SES. Employees above the GS15 level in Baltimore and Falls Church operate with the primary interest of protecting their own careers. SSA is an agency that benefits those entrenched career managers far more than it benefits the public they are supposed to serve.
Name names, please.
I am not convinced that most CoSS have that much of an agenda {beyond moving on to another job & avoiding problems that cause phone calls from the White-house staff or Congressional staff).
Dorcas Hardy tried to do something, but unfortunately was mostly wrong, ill informed, and undermined at several levels.
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