From the newsletter of the National Council of Social Security Management Associations (NCSSMA):
Over the past decade, attorney and third party requests have increased at an alarming rate. Managers from all over the country are facing tough decisions as they struggle to maneuver valuable office resources and keep up with the steady stream of paper flowing from their fax machines and mailrooms....
According to a recent survey conducted by NCSSMA, offices are spending an hour and a half or more per day just sorting the influx of paper claims, appeals, 1695/1696s, and FOIA requests.
In addition, one-third of the paper received by fax and mail consists of duplicates or second requests. As stated by one frustrated Dallas Region manager: “The majority of the time, forms are submitted electronically, faxed, and then mailed to the field office. Not only do we receive them twice, but most often three times.”
Another issue challenging field offices is incomplete forms. A large majority of survey respondents said that only half the claims filed by third parties are fully completed, with a third needing more information in order to proceed with the application process. ...
According to a recent survey conducted by NCSSMA, offices are spending an hour and a half or more per day just sorting the influx of paper claims, appeals, 1695/1696s, and FOIA requests.Let me give an explanation for at least some of the duplicates. Things get lost at Social Security. That really bothers Social Security attorneys. To cover themselves, they submit duplicates.
We need more reliable systems.
he reason they are getting second and third requests is that they fail to respond to the first and second.
ReplyDeleteOccasionally we have to file paper appeals due to system limitations issues on SSA's end. Its not uncommon for these to not be loaded into the system for a month or two without any acknowledgement of receipt. So if we call the field office to confirm receipt, they say they don't show it in the system so we end up submitting a second, and sometimes a third time. Its a very poor system.
Agree w above. As a representative who files electronically and practices in the Dallas Region, I think a lot of this is the agency’s problem. SSA requires a paper 827 with original signature, then, they send one to the claimant regardless of how quickly I mail the form (certified, day of filing). Many FO SSA staff are new or burned out; they do not know how to handle electronic claims with onset or work issues. SSA realized this and began bringing in Rehired Annuitants or Service Representatives. Many CRs, not most but many, ignore or seriously delay new claims. Recently I filed a reconsideration appeal with onset issues. The CR sent the claim to the DDS who reversed the initial decision and allowed the case. This took 45 days during which time the CR and Field Office refused to respond to any of my communication. I had to fax the medical to DDS who could not speak with me because the FO had not sent my 1696. Fact is that most, not all, representatives who file for claimants expedite the process and decrease the paperwork. If representatives are faxing passively aggressively, they should be reported. SSA FOs should conduct representative outreach meetings (this used to happen, and in the Dallas Region). I cannot count the number of times I have read the GN or POMS to a representative, explaining work issues, dire need, homeless, onset, overpay, etc. It is ignored and I have to fax to a FO Manager. I think SSA has done a good job rolling out electronic filing but complaining about third party, representatives slowing things down is a ruse for their staff problems.
ReplyDeletePerfect example of unnecessary redundancy by SSA occurred with our today, and as 2:45PM this stuff is mainly SSA's fault. We filed an appeal earlier this week and uploaded the 1696, fee agreement, 1695, and 827 through the new method online. We received a call today from a CR asking that we fax the documents to her as she hasn't been trained on how to download what we attached.
ReplyDeleteThe suits in Baltimore are coming up with changes but they are doing nothing to train the CRs who have to deal with this chnages.
I'm a FO supervisor in the Dallas Region. The issue we experience from primarily large firms (Myler, Cardon, Thomas Klint, Citizens Disability) are the faxing of volumes of documents (1696, 1695, fee agreement, signature page of the SSA-16 (another issue completely), the 8001, etc.) and then mailing them a few days later. This causes duplicate work for the FO. When we receive the fax we must query the records and give to the appropriate CR. Then we must repeat the whole process again when we receive the same package in the mail.
ReplyDeleteThere's also the issue of getting second and third requests for 1695 confirmations when a query of the Online Retrieval System shows we already sent the notice. Then there are the full page status requests, asking for everything under the sun. And of course the appointed rep forms that come in only to find after extensive query reviews that there's no claim, appeal, or appointment pending! Or how about the poorly complete 8000/8001s? Marriage questions answered "no" when the iClaim shows "yes." Incomplete resources and income information. Or with the third party iClaims...waiting months for the claimant or rep to send us the signed application, but being inundated with faxes, letters, and angry phone calls from rep staffs asking for status. So yeah...better systems would be nice. What may be nicer is these large firms getting a clue as to what's going on and easing up on the paperwork.
The problem exists on both sides - the "national firms" are ever becoming a major problem, as are the 3rd party litigation firms who use SSA as their own personal databases. On the SSA side, the agency also has plenty of problems, to the point where it shouldn't be pointing fingers. Lots of offices routinely don't do what they are supposed to, at no penalty.
ReplyDeleteHowever, the real cause of this on the SSA side is SSA's systems development.
Over the decades, SSA developed a lot of in-house solutions for problems that didn't have commercial solutions at the time. Even when viable commercial solutions became available, SSA continued to stick with its own solutions because they were "good enough" to get the job done without having to invest in new technologies.
However, now SSA's solutions are breaking down. They can't handle the volumes needed for current business processes. The agency then wastes time and money hand over fist pasting layers of stuff over the top of existing architectures that were kludges at best to begin with. Something doesn't work?? Well, the SSA way is to not fix it and instead just label it as an "exception" (i.e. more manual processing that nobody has time for).
Upper management simply can't (and refuses to) grasp that all these new systems have killed employee productivity. Offices can't possibly get all the work done because they spend hours and hours and hours and hours and hours doing redundant keying of the same data in multiple places with lots of manual actions. You have to fax reams of documents, resulting in queues at the fax machines. The agency responds by designing more kludges.
Those 1695 acknowledgement letters reps want? Every single one of them has to be manually prepared as none of SSA's systems will generate them. Fax bar codes - manually created. You get the picture.
The problems on this side also echo the agency's problems with claims processing and post entitlement processing as the same issues exist there. The processing systems are breaking down, and there aren't enough people to do the manual actions necessary to fix things. It has gotten to the point where some of the PSCs (Great Lakes, Southeastern, and Mid America come to mind) now have huge backlogs of things that can't be fixed due to antiquated processing software.
SSA is pretty much doomed. If you look at IRS and VA now, this is what is coming for SSA in the next 10 years.
With the new iappeals release (3/14/15) you can attach the 1696, fee agreement and other supporting documents to the online appeal so everything comes at once. Using the automation tools for importing iappeals, the process for adding rep information is far more streamlined if we get the whole package at once as opposed to piecemeal after the appeal is filed. IMHO, the 1695 should be eliminated at this point. If you're registered, we've got that information, if you're not, no direct payment, no 1695 anyway. It just means another notice to generate, another bar code to generate, just to send back or destroy. There is a system that generates the acknowledgement letter with just a couple clicks, but we could still do without the form altogether.
ReplyDeleteThe answer to stopping/reducing the duplicate forms is the SSA-L1697. GN03910.040.A.last paragraph was written for this very purpose.
ReplyDelete"When you receive appointment documentation (Form SSA-1696 or equivalent writing) from a representative, you must send the representative an acknowledgement of appointment receipt (SSA-L1697-U3), see GN 03910.090 Exhibit 3. In addition you must acknowledge receipt of any material not directly related to the appointment of the representative. Such materials includes: any appeals requests forms, such as, SSA-561 (Request for Reconsideration) see GN 03102.225, SSA-61 (Request for Review by a Federal Reviewing Official) see AM-06173, HA-501 (Request for Hearing by Administrative Law Judge), see GN 03103.020, HA-520 (Request for Review of Hearing), see GN 03104.200 or equivalent). To acknowledge receipt of Form SSA-1696 or equivalent writing and any material not directly related to the appointment, date stamp, copy, and return all material along with the acknowledgement of appointment receipt notice (SSA-L1697-U3) to the representative with a copy to the claimant."
When I arrived at my FO, it had a 6-feet pile of duplicate forms. Once we got our CRs trained to send out the L1697 and return the forms back to the senders, our duplicate forms pile went down to 1- to 2-feet.
Yes, it takes a little more time out of the CRs to generate the L1697 for the form sender and send a copy of it to the claimant, but that extra 5-10 minutes to generate the L1697 greatly puts a big reduction dent in the 1.5 hrs/day of sorting the influx of duplicates, because the purpose of the L1697 is to tell the form sender that their forms have been received.
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ReplyDeleteI am in New Orleans (Dallas Region) 2 of our field offices routinely do not sent the 1695 back to our office. Or maybe they are sent and routinely lost in the mail. So we have to send the requests 2 or 3 times. SSA create its own problem when they started require extra paperwork (re 1695) Probably this problem could be solved quickly if SSA would fax the forms to the offices versus mailing them. Cheaper, securer and they would have a confirmation sheet to add to their record.
ReplyDeleteThe real question is why is SSA involved in the fee process or fee agreement process between the attorney and the claimants? Enabling an outside party to collect a fee from a claimant is not a core mission of the Agency. I did not sign up to be the paralegal or the collection agency for attorneys. As we tell our children - you can do that yourself.
ReplyDeleteoh 8:30, you must not work at ODAR. if you did, you'd already know that about 30% of everyone's job is bending over backwards to make sure the reps are accommodated to their satisfaction.
ReplyDeleteAt 8:30pm. SSA wouldn't have to be involved. SSA can pay everything to the claimant every single time, and let the attorneys pursue the claimants for their money. Less work for SSA. And if there's any fee agreement problem (which would be every time) between the claimant and the attorney, take it up with court, not SSA. Don't run crying to SSA to help resolve the issue.
ReplyDeleteI still don't understand why half the forms I mail to Social Security doesn't make it to the file. We track all packages to SSA. I send our appointment of rep and all other required paperwork within 3 days of signing it with the client.
ReplyDeleteAt least half the time we have to call to follow up and SSA claims not to receive it. And many times, they have SOME of the documents but not all of them. Since I personally check the package before it is sent, I know everything was there when it left the office.
I am glad that we can now electronically submit documents to SSA on appeal. It is a good first step. Someday I hope that we will be able to view the file and upload directly like we do when it is at ODAR. Would save SSA a lot of staff time.