The most recent edition of the Social Security Bulletin, the Social Security Administration's scholarly journal, contains an article titled Vocational Factors in Disability Claim Assessment: A Comparative Survey of 11 Countries by David Raines and Tony Notaro. Basically, they find what you might expect -- significant differences among the countries. Here's a table from the piece.
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Here's the authors' summary of how the U.S. compares to other countries:
...[W]e note the following significant differences between U.S. disability programs and those of most of the other sampled countries:
We also note the following significant attributes that the U.S. disability programs share with those of other countries:
- U.S. programs do not extend eligibility to claimants with partial and/or temporary disabilities;
- Workers in many other countries receive sickness benefits for 1 year or longer before becoming eligible to claim long-term disability benefits;
- Although SSA assesses residual work capacity in the later stages of the five-step U.S. process, many of the other countries conduct their assessment in the initial determination phase; and
- Several other countries involve the claimant's employer in the assessment process.
- The assessment is carried out in sequential steps (although agencies in other countries do not always spell out those steps quite as definitively as does SSA); and
- Medical experts are consulted to confirm diagnoses and evaluate disablement....
To briefly summarize our findings on each VF [Vocational Factor], we observe that:
Age is not used in the disability determination processes of most of the countries we survey. The use of age as an explicit factor in determining whether certain claimants are disabled (as in step 5 of the U.S. sequential evaluation process) is rare. However, age is considered in determining eligibility for certain sickness and partial- or long-term disability programs. In general, advancing age is thought to increase the likelihood of disablement, and therefore increase the claimant's chance to receive a benefit. Sweden uses age in determining program eligibility and Australia uses age in deciding the frequency of reassessment for disability benefit eligibility.
Education is generally not directly considered during disability determination. The United States is the most notable exception, directly considering education in step 5 of its sequential evaluation process. Likewise, Denmark and the Netherlands consider education in determining the claimant's ability to perform other work in the general economy. In the same way, formal schooling or training may suggest a claimant's ability to undertake available vocational or rehabilitative options or employment opportunities.
Work experience is considered in the disability determination processes in each of the surveyed countries. Work experience is a central factor in assessing a claimant's transferable skills, which in turn constitute a central component of the RFC assessment that drives many disability assessment procedures.
5 comments:
The report saying SSA assesses "residual work capacity" in the later stages of the five-step sequential evaluation process is different than other countries that conduct their assessment in the initial determination phase is confusing. One, "residual work capacity" is not a thing. They are referring to RFC, past/alternative work findings, or some combination of all three. Two, unless the claim is denied at the first two steps, or awarded at the third step, RFC and past work findings ARE made at the initial determination phase. Alternative work findings are made at the fifth step, again at the initial determination phase. Or at least meant to be. DDS has a frustrating habit of skipping step 4 and step 5 findings are usually weak at best.
Australia using age as a factor in determining reevaluation sounds like a great idea. Currently, my understanding is SSA doesn't really have set guidelines on how often reevaluation should occur, just going with what the adjudicator says is reasonable. As to most countries not using education as a factor, that's odd. That seems like one of the more logical factors to consider. Curious if that might be a result of the shift from unskilled economy to skilled/service economy in the US. Then again, that trend seems likely to also have occurred in the other countries surveyed. The idea of a short-term program is intriguing. It would address the concern as to the 12-month duration limit, and it would likely shift the focus of ticket-to-work.
We see many comparisons between countries on disability programs, but I do not recall seeing any stats on claimant/agency staff ratio. Some of these countries we are comparing, Like Denmark, Finland, Ireland have populations for the country that is less than the city of New York and just more than LA or Chicago. It makes me wonder if they have a higher ratio of agency workers to claimant as well.
Has something like this been posted in the past or can you point me to some articles like that, google wasn't doing good on a search for the info.
Anon 9:50 Great point.
I read somewhere Canada has like 20-30 ALJs total evaluating disability claims. The U.S. regularly has over 1500. Really hard to compare any 1 nation to the U.S. Maybe they could compare the U.S. to China or Russia.
It does seem like the more British countries like Australia, U.S., Great Britain, and Canada seem to have the more stringent disability programs. Would like to see the disability numbers in more liberal countries like Spain, Italy or Greece. I would bet they are more lax and probably have more people on it than maybe deserve it.
@2:59
Canada has over 70 equivalents of ALJs. That sounds low, but Canada has only a little over 10% of US population. Still, that's roughly two times the judges after accounting for population. Canada's system is pretty similar. It requires insured status, be under retirement age, and be incapable of "substantially gainful work" as a result of a medical impairment. "Substantially gainful work" is defined as work which would pay a salary or wages equal to maximum annual amount of the disability pension. That's $55,900 canadian, which is $41,586.54 in USD for 2018; $3465.54 per month. That's nearly triple SGA. So it's actually a more forgiving system by far, at least vocationally. Medically, I suppose that would come down to the doctoring community in Canada. The structure of the two systems look pretty similar.
How many of the other countries have Claimant Representatives that receive payment from past due benefits?
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