CCD Letter On Office Closure Problems

     From a letter sent by the Consortium for Citizens with Disabilties (CCD), the major umbrella group of organizations involved in helping those with disabilities, to Social Security Commissioner Andrew Saul:

... Please publish field office phone numbers more prominently. Currently, the national 800 number is in two much more visible spots ... and the local number ... is more difficult to find on the field office locator tool. With wait times on the 800 number exceeding 90 minutes, allowing people to more easily contact their local offices is critical to improving customer service. ...

We have requested, and understand that the Office of Disability Operations is considering, creating a web page on ssa.gov indicating the daily operating status of all state agencies (DDSs). We assume that SSA is already aware of whether DDSs are completely closed, having all employees telework, or operating under a different arrangement; allowing claimants, representatives, advocates, and others to access this information would be helpful as well.With many DDSs completely closed, it is difficult for DDS staff to obtain evidence submitted by mail or fax, and to generate CDs with claimants’ records to inform claimants and their representatives. Unfortunately, SSA has not yet provided claimants or representatives with the ability to view their electronic files or upload evidence electronically. SSA should prioritize these IT modernizations so that the agency can more efficiently process disability claims at the initial and reconsideration levels....

We appreciate that the Office of Disability Operations created an email address for representatives to send documents to the Representative Call Center (RCC). However, it would be useful for SSA to have similar email addresses for representatives to send documents to the Program Service Centers (PSCs) since the RCC email address cannot be used for any other unit or module. The PSCs often need documentation, such as information about workers’ compensation benefits, to effectuate decisions. With field offices closed, it is more important than ever for PSCs to have adequate channels of communications.  ...

OHO issued a Chief Judge’s Bulletin (CJB) regarding procedures during the pandemic on April 3, 2020. However, the Bulletin has not been published with other CJBs at https://secure.ssa.gov/apps10/reference.nsf/instructiontypecode!openview&restricttocategory=CJB. Advocates were told in the same phone call that the April 3 CJB was both too general to be of use to claimants and representatives and too “sensitive” to be publicly released. This strains credulity.  ...

Finally, some representatives have been told that OHO could not send any of the barcodes used as cover sheets when faxing documents to claimants’ electronic files and which contain information used to upload documents electronically. If accurate, OHO must find a way for claimants and representatives to submit evidence, requests for on the record decisions and critical case designation, and other important documents to the claims file. If not, SSA should explain how representatives can request bar codes for cases where they’ve recently been appointed or the ALJ hearing request has just been made. ...

The Appeals Council receives many documents and requests for review by fax; they use actual fax machines rather than a fax-to-computer system, and this is now a problem because the machines are out of paper and their memories appear to be full. We are encouraging claimants and representatives to use SSA’s iAppeals system whenever possible and mail if necessary, but claimants who are unaware of these options may be sending their requests for review into a technological void. We urge you to have the Appeals Council devise a way to accept faxed documents, ideally using a desktop faxing system so that staff do not have to manually load paper into fax machines and scan the faxes they receive. ...

     Isn't it obvious that it's inappropriate for an agency to issue secret instructions to ALJs on how they should handle cases? I don't think there's something nefarious going on here; just the age-old bureaucratic penchant for pointless secretiveness.