MDW Mess

     From a recent report by Social Security's Office of Inspector General:

Objective 

To determine the effectiveness of the Social Security Administration’s (SSA) controls for resolving high-priority requests sent via the modernized development worksheet (MDW) process.

Background 

Because SSA’s processing centers (PC), teleservice centers, and field offices have different processing roles and systems access, SSA employees are often required to contact other offices to request case processing assistance. Employees use MDWs, manually designated as either routine or high priority, to send requests for action to other field offices or PCs. Per SSA policy, high-priority MDW requests should be limited to situations that involve awards and disallowance of claims; start- and stop- payment actions; appeals; congressional inquiries; and public-relations issues. According to SSA’s policy, employees should follow up on unresolved high-priority requests after 20 calendar days. 

From SSA’s Processing Center Action Control System, we identified 121,376 benefit records with high- priority MDWs pending at PCs as of January 28, 2020. Of these, 82,439 (68 percent) had MDWs that were pending for at least 60 days. We reviewed a random sample of 100 benefit records with high-priority MDWs pending at least 60 days.

Findings 

SSA does not have effective controls for resolving high-priority requests sent via the MDW process. As a result, SSA made improper or delayed payments and inflated PC backlogs, which impeded efforts to improve customer service. For 51 of the 100 sampled benefit records, SSA did not resolve the high-priority MDWs or resolved them longer than 60 days after field office and teleservice center employees sent them to the PCs. ...

For the remaining 49 benefit records, employees (1) resolved the high-priority MDWs but did not clear them or (2) made incorrect inputs on MDW requests. We estimate SSA’s management information was inflated by over 40,000 high-priority MDWs, which further decreased the effectiveness of the MDW process. ...

     So much to unpack here. Note that the systems used by the payment centers, teleservice centers and field offices don't really talk with each other very well so Social Security had to come up with the MDW process but that's not really working so well. It sounds like the system has almost completely broken down if it ever worked to begin with. Even when the MDWs are "resolved", often there are errors in the "resolution." And, oh yes, note the special treatment for "public relations issues."

     This isn't a video game. Real people suffer lengthy delays in the payment of benefits owed them. Many of these problems never get resolved without frequent external pressure from attorneys representing claimants.

How Did This Get Published?

      The Center for Retirement Research at Boston College has posted a "working paper" by Cody Tuttle and Riley Wilson on The Impact of Claimant Representation Fee Schedules on the Disability Applicant Process and Recipient Outcomes. Tuttle and Wilson seek to prove the hypothesis that after the maximum fee that can be charged by an attorney for representing a Social Security claimant was increased in 2002 and 2009 that attorneys delayed their clients' cases so that they could draw the now higher maximum attorney fee. The two had one big problem. While they had data showing that wait times had increased in general they didn't have data that distinguished represented from unrepresented claimants. They "solved" this problem by assuming that the overall increase in average wait times was solely due to a large increase in wait times just for unrepresented claimants with the unrepresented claimants suffering no such delays. I would call this a whopping leap of faith. The researchers noted that the country was in recession both in 2002 and 2009 and wondered whether that might have something to do with it. The possibility that things were going on specifically at Social Security that caused increased backlogs for represented and unrepresented claimants alike appears to have not occurred to them. Actually, things were going on at Social Security in both those years. You can take a look at a GAO study from 2002 and a New York Times piece from the same year on increasing backlog problems at the agency. Here are some stats from 2009 showing wild increases in backlogs in that year. You can understand why backlogs might have been increasing in those years by looking at the chart above. Click on it to view full size. Note that in 2002 and 2009 claims were increasing a lot faster than awards. Why would that be? Awards were trailing because of increased backlogs.

     How did a "working paper" this shoddy get published? Was this nonsense peer reviewed by anyone?

Blast E-Mail To SSA Employees

 From: ^Human Resources Internal Communications <Human.Resources.Internal.Communications@ssa.gov> 

Sent: Monday, September 27, 2021 7:20 AM

To: ^Human Resources Internal Communications <Human.Resources.Internal.Communications@ssa.gov>

Subject: COVID-19 Vaccination Mandate

MESSAGE TO ALL SSA EMPLOYEES:

In accordance with the President’s Executive Order on Requiring Coronavirus Disease 2019 Vaccination for Federal Employees, all employees must be fully vaccinated (i.e., receive a single dose vaccine or the second shot of a two-dose vaccine, excluding booster shots) by November 22.  Employees must therefore have received their final vaccine dose by November 8.  Two of the three vaccines being administered in the US have two-dose regimens.  Therefore, employees will need to start vaccination by the following dates in order to be fully vaccinated by the November 22 deadline:

	Moderna	Pfizer-BioNTech	Johnson & Johnson
First Shot	Oct. 11, 2021	Oct. 18, 2021	Nov. 8, 2021
Second Shot	Nov. 8, 2021	Nov. 8, 2021	n/a
Fully Vaccinated	Nov. 22, 2021	Nov. 22, 2021	Nov. 22, 2021

All employees will be required to provide documented proof of vaccination (e.g., a copy of the record of immunization from a health care provider or pharmacy, COVID-19 Vaccination Record Card, medical records documenting the vaccination, immunization records from a public health or state immunization information system, etc.).  Employees should take steps now to schedule a vaccination if they have not already done so or preserve their proof of vaccination if already vaccinated.  Please do not email your vaccine documentation to your supervisor.  Additional instructions will follow concerning collection of your documentation.  Employees will receive duty time of up to 4 hours per vaccination shot (up to 8 hours total for two-shot vaccines) rather than administrative leave to complete the vaccination process; other policies concerning administrative leave for vaccination reactions and to take family members for vaccination will continue unchanged.

At this time, we have discontinued the SSA Vaccination Attestation survey and removed access to the survey link.   

Employees who are unable to be vaccinated for medical reasons may request a reasonable accommodation with appropriate medical evidence including showing why they cannot be vaccinated.  Employees may request a reasonable accommodation through the Reasonable Accommodation (RA) Wizard,  from their supervisor via email using SSA Form 501­, or orally and supervisors will enter the request into the RA Wizard.  Employees may also request a religious accommodation from their supervisor.  Supervisors must consult with OGC concerning religious accommodation requests.  Employees who fail to comply with the vaccination requirement by the deadline or apply for and receive an accommodation will be subject to discipline up to and including termination. 

Thank you.

Haldiman Wins Award

 

     Sylviane Haldiman,  Social Security's Associate Deputy Commissioner for the Office of Systems, has been announced as a Pathfinder award winner by Government Executive. The Pathfinder award goes to those who "bring the best information technology solutions available into the federal sphere."

Raising Full Retirement Age Is A Bad Idea

     From Are Older Workers Capable Of Working Longer by Laura D. Quinby and Gal Wettstein, published by the Center for Retirement Research at Boston College:

Disability-free life expectancy had been rising continuously in the United States until 2010, suggesting working longer as a solution for those financially unprepared for retirement. However, recent developments suggest improvements in working life expectancy have stalled, especially for minorities and those with less education. This paper uses data from the National Vital Statistics System, the American Community Survey, and the National Health Interview Survey to assess how recent trends in institutionalization, physical impediments to work, and mortality have affected working life expectancy for men and women age 50, by race and education.

The paper found that:

• The capacity to work to older ages is still increasing for high-education individuals and low-education Black women.
• However, no progress has been observed for low-education whites of all genders and Black men.
• As a result, large shares of those still working at age 62 will be incapable of working even two more years.

The policy implications of the findings are:

• Raising Social Security eligibility ages may reduce the financial security of large segments of the population.
• These impacts will be particularly pronounced for Black men and low-education white individuals of all genders. ...

Updated Government Shutdown Plan

      Here’s Social Security’s newly updated plan for a government shutdown. There would be no immediate disruption for the public but, still, let’s hope this doesn’t need to be used.

Social Security Unlikely To Be Much Affected By Possible Government Shutdown

      There is talk of a partial government shutdown beginning on October 1. I hope this doesn't come to pass but if it does there should be little immediate impact at Social Security. Below is Social Security's government shutdown plan from the last time this issue came up. The plan could have been updated a bit since then but I strongly doubt that there's been a major change.

     Click on each thumbnail to view the page full size.

It's A Start

     Senator Sherrod Brown, whose Senate Finance Subcommittee held a hearing yesterday on the outdated SSI program, is saying that "at a minimum" the budget reconciliation bill now pending in the Senate "will include his proposal to raise the asset limit for SSI beneficiaries."

Covid Litigation

      From a press release issued by Justice In Aging, an organization which "uses the power of law to fight senior poverty":

... The Social Security Administration issued an interim rule in August 2020, due to the national emergency, that was intended to create an easier process to “waive”—forgive—certain penalties SSA imposed related to ineligibility during the early months of the pandemic. However, the agency didn’t effectively inform people that the simplified waiver process even existed, and the waiver only covered the first six months of this ongoing pandemic—before the deadly winter wave of COVID-19 cases. If an individual was lucky enough to learn of the existence of the simplified waiver, their problems didn’t end there. For example, the individuals named in the lawsuit faced problems like being told to contact a specific person at a specific phone number, yet not being able to reach anyone or leave a message; and being told to make an appointment to request the simplified waiver, only to be told that there are actually no appointments available.  

“This lawsuit aims to address the concerns of vulnerable citizens who rely on benefits from the Social Security Administration in order to survive,” said Sheila S. Boston, partner at Arnold & Porter. “Using the rule of law, we will hold Social Security accountable for amending its pandemic response to ensure that thousands of impacted individuals receive their benefits and information related to those benefits in a timely manner.” ...

SSI Is 5% Of SSA Payments But Takes 35% Of SSA's Budget To Administer

 

Senator Sherrod Brown

    From Ted Knutson writing for Forbes:

Social Security’s Supplemental Security Income program (SSI) is forcing millions to live in poverty, Senator Sherrod Brown (D-OH) charged today.

Convening the first Senate hearing on SSI in the Senate Finance Committee since 1998, Brown asserted millions of disabled and older Americans are living well below the poverty line as the program’s eligibility rules haven’t been updated in decades:

“They’re punished if they try to save for an emergency.”

“They’re punished if they try to find a part-time job.”

“They’re punished if they accept food or shelter from generous family and community members.”

“They’re even punished if they’re married.”...

As evidence of the difficulty the Social Security Administration has managing the program, [a witness from the Government Accountability Office] said SSI benefits make up only 5 percent of SSA payments, but it requires 35 percent of the agency’s budget to administer. ...

Senate Hearing On SSI Today

      Here's the witness list for today's Senate Finance Committee hearing at 2:45 on Policy Options for Improving SSI: 

• Elizabeth Curda , Director, Education, Workforce, and Income Security, United States Government Accountability Office 
• Stephen G. Evangelista, Deputy Commissioner for Retirement and Disability Policy, Social Security Administration 
• Mia Ives-Rublee, Director, Disability Justice Initiative, Center for American Progress 
• Kathleen Romig, Senior Policy Analyst, Center on Budget and Policy Priorities
  

How Common Is Work From Home?

      What percent of the working population is working from home these days? People who are working from home generally think it's a fairly high number -- at least 40%. The reality is that in August only 13.4% of Americans who work were working from home. An article in The Atlantic deals with this issue of perception versus reality when it comes to work during the pandemic.

     Almost all Social Security employees are working from home now. Many have somehow convinced themselves that this situation will last many, many months into the future, perhaps forever.  This is unrealistic. All Social Security employees who want to keep their jobs must soon be vaccinated. I can think of no rational reason for Social Security employees to keep working from home after this happens. The risk just isn't there. We can talk about when and how we allow claimants back in field offices but the idea that it's acceptable, even during the pandemic, for vaccinated Social Security employees who only work around other vaccinated employees to keep working from home 100% of the time is not something the public will tolerate.

     Let me be blunt. Andrew Saul was mean to Social Security employees. So what? He's gone. Social Security employees don't get special treatment in perpetuity as recompense for Saul's behavior. Social Security employees should receive the same sort of treatment that workers generally receive. To get personal, I'm back in my office. Why are Social Security employees so special that they can't be back in their offices? As I've asked before, does anyone really think that Social Security employees are cowering at home, never venturing out to socialize or eat in restaurants?

    The happy talk posted here, probably by union shills, that productivity has gone up during the pandemic might be true for a few individuals but overall it's an absurd claim. Service has declined dramatically during the pandemic. Lack of overtime can only explain some of this. If nothing else, we all know that many Social Security employees lack broadband internet access at home. Almost none of them have dual monitors. Who finds working on a laptop to be as convenient as working on a desktop? There's no way to avoid it. Service has declined broadly and work from home is a major reason. If anyone has proof that there's been any improvement in productivity at Social Security show us the numbers. Otherwise, I'm not buying it. I'm on the receiving end of Social Security's service. I know what's happened.

COLA Projection

     The Social Security cost of living adjustment announcement is coming up next month. Here’s a prediction that it will come in at 6% or 6.1%.

Not So Easy

      Think it’s easy to get Social Security disability benefit? Think there are lots of cheaters drawing those benefits? You’re not alone. You’re not right; not at all, but you’re not alone in your mistaken opinions as Tom Margenau details.

Coming Down To The Wire

     The Subcommittee on Social Security, Pensions, and Family Policy of the Senate Finance Committee has scheduled a hearing for September 21 at 2:45 on "Policy Options for Improving SSI." 

     We're coming down to the wire on whether SSI reform will end up in the Budget Reconciliation bill. It seems unlikely that SSI reform will be in the House of Representatives' version of the bill. Senator Sherrod Brown, who is Chairman of the Subcommittee holding the hearing, is trying hard to get some SSI provisions in the Senate version of this bill. This hearing must be part of that effort. 

     There's no draft of the Senate version that's available to the public now. I would infer that Brown must expect that inclusion of SSI reform will still be up in the air as of September 21. 

     For complicated reasons that I won't try to explain, there's a deadline of September 26 on passing this bill. It's conceivable that could be extended but it might be difficult.

Social Security Seeks Return To Work Ideas

      From a notice that the Social Security Administration is posting in the Federal Register tomorrow: 

... Through this notice, we are soliciting suggestions for potential policy changes and services related to supporting DI [Disability Insurance] beneficiaries, SSI recipients, and disability program applicants in their efforts to return to, remaining in, or enter the labor force. We are also soliciting suggestions for other potential demonstrations. Responses to this request may inform our decisions about future demonstrations and how to design such projects. ...

Scammer Pleads Guilty In Houston

      From a press release:

A 37-year-old Indian citizen who was illegally residing in Houston has entered a guilty plea to conspiracy to commit mail fraud, announced Acting U.S. Attorney Jennifer B. Lowery.

Between April and October 2019, Waseem Maknojiya was involved in a telemarketing scheme via Indian call centers to extort money from victims in the United States. Maknojiya acted as a runner in these schemes, using aliases and fake identification documents to pick up more than 70 parcels containing cash the scheme’s victims had mailed.  ...

This Argument Seems Strong To Me

     From the Supreme Court amicus brief of the American Bar Association in U.S. v. Vaello-Madero, the case presenting the question of whether it is constitutional to deny SSI benefits to American citizens who reside in Puerto Rico:  

... As a threshold issue, all of the government’s justifications for the SSI law start from the premise that it has legitimate interests in treating Puerto Rico differently because of its territorial status. ...     

However, “[i]t is well settled that the Equal Protection Clause ‘protects persons, not groups.’” Engquist v. Or. Dep’t of Agric., 553 U.S. 591, 597 (2008) (citing Adarand Constructors, Inc. v. Peña, 515 U.S. 200, 227  (1995)). The “persons” whose equal-protection rights are implicated in this case are the particular Puerto Rico residents such as Mr. Vaello-Madero who would otherwise qualify for SSI, which is only a subset of Puerto Rico residents as a “group” or “jurisdiction.” The government’s justifications for the law must supply a rational basis for treating these particular individuals differently than similarly situated individuals who do qualify for SSI because they reside elsewhere. But because the government only focuses on how all Puerto Rico residents can be treated as a group, it fundamentally fails to provide a rational basis for discriminating against Mr. Vaello-Madero and similarly situated individuals who happen to reside in Puerto Rico. ...

Covid-19 Poll

 

bike trails

OIG Threatens Employee Discipline Over Productivity During Pandemic

      From Government Executive:

... The Social Security Administration’s inspector general office has in recent months conducted surveys of computer logs and telephone records of its employees, aiming to ensure its employees were engaging in work activities at the proper times. The probes have resulted in employee discipline, including firings, according to SSA IG staff.  ...

In a message to employees in July on "reentry planning" obtained by Government Executive, [Gail] Ennis [Social Security's Inspector General] announced to employees she had requested an assessment of the workforce's remote work productivity. She noted the agency found, as a general matter, the IG's office remained consistently productive and had "demonstrated an ability to produce meaningful results" in extraordinary circumstances brought on by the COVID-19 pandemic. She said the "vast majority" of employees worked the hours they said they did and "met their obligations as public servants."

Ennis added, however, that not all employees performed so admirably. 

“Regretfully, some employees did not, and they will be held accountable for their conduct,” she said. ...

One employee estimated that nearly two-dozen employees are facing potential discipline. That would represent about 7% of the IG’s Office of Investigations workforce. ...

     Note that the discussion here is about Inspector General employees specifically, not Social Security employees generally.

Man Indicted For Threatening To Blow Up Social Security Offices

Social Security office in Lubbock

     From KLBK:

A man was indicted on federal charges Wednesday and accused of threatening to blow up the Social Security Administration buildings in Lubbock [TX] and Hobbs, New Mexico, according to court documents.

Michael Wayne Nietfield, was indicted on three counts of interstate threatening communications and three counts of attempting to interfere with the Social Security Administration.

According to court documents, on July 1, Nietfield threatened that he would go to his nearest SSA building – located in Lubbock – and “blow it up.” He also said he was “going to be in jail for what he is about to do.”    

The next day he threatened to bomb the SSA building in Hobbs and ordered the manager to evacuate the office, according to court documents.

That same day, Nietfield threatened the Lubbock SSA building again.

According to court documents, he said if he didn’t get a response, “you better call them and clear them [sic] offices, cause I’m blowing these sons of b****** up.”

Students Go Hungry Because Of Social Security Backlog

   From The Spectrum, a student publication at the University of Buffalo (emphasis added):

Despite leaving her dorm 30 minutes before her lecture to get breakfast at 8:30 a.m., freshman biomedical sciences major Dina Dahhan had to settle for a partly frozen Smucker’s Uncrustables sandwich from the vending machine. 

That’s because the long lines at various eateries in the Atrium would have made her late for class. 

Dahhan isn’t the only student who has been forced to make unorthodox meal choices this past week. The national labor shortage has made it difficult for Campus Dining and Shops to meet student demand, resulting in the temporary closure of Atrium eateries, Hubies and The Bowl. The long wait times and limited hours are making it difficult for students to use their meal plans — despite the price increase on all student meal plans over the summer.   ...

CDS attributes the congestion to the national labor shortage, but also to a backlog from the Social Security Administration, which processes paperwork required for international students to work in the U.S. International students make up a large part of CDS’s workforce, so once the paperwork is pushed through, CDS hopes more food services will be available.  ...

SSA No Longer Insisting On Seeing Original Identity Documents

      From Emergency Message EM-21056: 

... While mail continues to offer an additional channel for the public to communicate with us, you must discourage customers from mailing important documents that they should keep secure and maintain in their possession, such as driver’s licenses, passports, or immigration documents. If they prefer, customers may choose to mail us secondary evidence of identity and less sensitive material. ...

Vaello-Madero Scheduled For Oral Argument On November 9

      The Supreme Court has revised its November argument calendar and added U.S. v. Vaello-Madero on November 9. Vaello-Madero presents the issue of whether it is constitutional to deny SSI benefits to U.S. citizens who reside in Puerto Rico.

     By the way, many amicus briefs have been filed already in this case. Every one supports the argument that it is unconstitutional to deny SSI to Puerto Rican residents.

    Also, by the way, the Supreme Court is going back to in person oral arguments for its October term. Will Justice Thomas go back to his silent ways?

White House Draft Of CR Contains No Additional Money For SSA

      The federal fiscal year (FY) ends on September 30 each year. Each year Congress fails to complete regular appropriations bills by that deadline so it must pass continuing resolutions (CRs) that enable government agencies to  continue to spend at the rate of the prior appropriation. The CRs generally contain special provisions allowing additional spending under the CRs for urgent needs.

    The White House has released its draft CR for this year. It contains additional funding for disasters and for Afghan refugee resettlement but no additional funding for the Social Security Administration. Of course, Congress gets a say in this. There was an earlier supplemental appropriation bill. The original Senate draft of that bill included an extra $150 million for Social Security. That was removed in negotiations. Could that return in the CR? We'll see.

SSI Disappointment

      The Chairman of the House Ways and Means Committee, which has jurisdiction over SSI, has announced that on September 9 and 10 his Committee will mark up a bill to be part of the budget reconciliation bill that Democrats hope to pass this month.  The announcement includes a description of what will be in the draft bill. I see no mention of SSI. This may be amended in committee but I doubt it will happen.

     The Senate Finance Committee may have different priorities. If so, the differences will have to be worked out.

Hearing Office Average Processing Time Continues To Rise

     The report shown below was obtained from Social Security by the National Organization of Social Security Claimants Representatives (NOSSCR) and published in its newsletter, which is not available online to non-members. It contains basic operating statistics for Social Security's Office of Hearings Operations (OHO). 

     Note that the average processing time jumped from 301 days at the end of last year to 351 days as of July. I posted about this last month and received responses basically saying "What's the problem? The total number pending is down." Who outside Social Security cares what the total number pending is? What people outside the agency care about is how long it takes to get a hearing and a decision. Even though fewer appeals are being filed, it's taking longer and longer to get a hearing and a decision. That's important. There are a multitude of problems at Social Security. This is one of them. Like many of those problems, this one is going to get worse. There is a huge backlog of cases stuck at the initial and reconsideration levels. Those backlogs will eventually be worked down, leading to more appeals. Everyone expects an avalanche of disability claims once the field offices reopen.

Click on image to view full size

 

Happy Labor Day!

 

Is OASIS Still Around?

 

    Social Security used to publish an employee magazine called OASIS. Is OASIS still being published?

     Extra points if you know why it was/is named OASIS.

Note That It Was An IRS Form In 1950

 

How Are The Trust Funds Invested?

    

     Have you ever wondered about how the Social Security trust funds are invested? Probably you know they're invested in U.S. government bonds but you wonder about the mechanics. Here are all your answers in a report by the Congressional Research Service. 

     By the way, if you don't like the idea of the Trust Funds being invested in government bonds, how would you have them invested? Are you comfortable with the U.S. government owning trillions of dollars in corporate stocks and bonds? Isn't that more than a little socialistic? How would the government decide what to buy and sell? How would it vote on elections of corporate boards of directors? What happens when the markets go down in value?

"Long Covid" And Social Security

Wuhan, China

      Many wonder what effects the Covid-19 pandemic will have on Social Security's disability programs. Will there be many "long Covid" disability claims? The Lancet, one of the most important medical journals in the world, has published a study based upon Covid survivors in Wuhan, China, where Covid-19 was first detected. The survivors were followed up at six and twelve months and compared to similar individuals who had not had Covid.

     At twelve months 49% of the Covid survivors were reporting symptoms. Shortness of breath was reported in 30% at twelve months. Interestingly, 26% were reporting depression or anxiety. Covid survivors were reporting more problems with mobility as well as pain or discomfort that those who had not had Covid. Of those patients who had been working prior to Covid, 88% had returned to work twelve months out. The study concluded that the survivors had a good physical and functional recovery but their health status was still lower than that of similar individuals who had not suffered from Covid.

A Deeper Dive Into The Trustees Report

      From the Social Security Trustees Report:

... The changes in policy for the Deferred Actions for Childhood Arrivals program discussed in III.B, which affect the Social Security program in the first ten years primarily by increasing payroll tax income, increased the tenth year OASI trust fund ratio by 1 percentage point. Changes in demographic assumptions over the short-range period, primarily increased mortality due to the COVID-19 pandemic, increased the projected tenth year trust fund ratio for OASI by 6 percentage points. .

     In case you're having trouble following the verbiage, this says that DACA is helping the Trust Funds modestly because DACA members will be paying taxes, as is, sadly, Covid-19 because of the excess deaths. Contrary to right wing fairy tales, immigration is always good for the Trust Funds. On the whole, immigrants pay taxes for many years before they draw Social Security benefits. What's hard to understand about that? The Trust funds are projected to be depleted a bit earlier despite the effects of DACA and Covid-19 because of "several changes in economic data and assumptions."

     More specifically as to mortality, the report says that:

... Preliminary data for 2020 show that while the effects of the pandemic led to significantly higher death rates for those aged 15 and older, the death rates for those under age 15 were significantly lower, though not quite to the same degree. Thus, for ages 15 and over, death rates are assumed to increase above what would have been projected in the absence of the pandemic by 16.4 percent for 2020, 15 percent for 2021, 4 percent for 2022, and 1 percent for 2023. ...

    As best I can tell the Trustees make no assumption about long Covid disability claims. I don't know how they could. It's all speculative at this point.