A. Purpose
B. Background
This emergency message (EM) announces an upcoming change in the business process for all instructions designated as sensitive at the time of the publication request.
On October 1, 2020, agency stakeholders met to discuss how we apply the sensitive designation to policy instructions. Following the discussion, we developed a draft proposal to improve the application of the sensitive policy designation.C. Proposal
For each publication, an AC signoff sheet is already required. To ensure the sensitive designation is appropriate, we will be modifying the AC-Level Signoff Document to require a more stringent review and added justification for applying the designation.
And here's the signoff sheet:
Section A – This signoff is for:
A Sensitive Instruction (these instructions are for internal SSA use only – if being designated as a sensitive instruction, what criteria does it meet? please check appropriate box below, highlight that specific section in your attachment and complete the ‘Background’ section below following this determination)
☐ Descriptions of internal security controls and override instructions in claims processes
☐ Instructions which explain to employees what steps they must take to effectuate or redirect a payment or to override an internal control feature; or
☐ Instructions designed to detect fraudulent documents and actions
Background/Justification:
Hmmm..this seems like the opposite to me, meaning more things would be labeled as sensitive, mainly because of the first bullet. There are a lot of instructions that are issued because there is a change in process; it doesn't make it sensitive or secret, it just means there is a change that technicians need to be aware of and the POMS re-write hasn't been completed yet. This makes it seem like you have to label all changes as sensitive, regardless of the content, if you are "overriding instructions in claims processing".
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