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Jun 30, 2024

Commissioner Doesn't Like Agency Notices


     From an interview that Social Security Commissioner Martin O'Malley recently gave to NPR:

The notices that we send out, I have described them as Mad Libs written by mad lawyers that confuse, they scare, and most people have a difficult time understanding what many of these notices even say.

13 comments:

  1. Hard to disagree. Most are poorly written. Maybe he'll listen to public facing workers to improve things. The management types at SSA need to be rehomed.

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    1. Awful…needless use of the passive voice, an addiction to past participles, too wordy, too much deference for boilerplate paragraphs where it is not required.

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  2. I can't disagree the notices suck but I've watched notice staff struggle to come up with paragraphs that make sense without coming up with a zillion variants that make coding for a notice a ball of snakes. Automated notices must exist as there isn't the manpower to create unique one off notices but there is a granularity issue, a simple language issue and often a legal issue on word choice and usage.

    No one would disagree notices suck but the agency has been trying to find the magic bullet on this for decades because it's not a simple solution.

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    1. How about plain, simple Engish?

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  3. There is not a quick fix for this. A lot of notices need to be pre-written. I remember the agency sending out a reminder last year to do better in the manual fill ins because so many people write so poorly that the public thought real notices were fake. But streamlining the jargon and complicated wording to plain language would help us understand what we are reading. Its a tough challenge.

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  4. In particular overpayment cases produce absolutely indecipherable messages that not only are not in English, they provide next to no useful information as to why a person was overpaid and the amount of the overpayment.

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  5. I remember trying in person to explain an SSI overpayment to someone when it involved RMA, periods of excess resources and others of excess income due to work and trying to explain the calculations. Other CRs might have understood but a member of the public? Understanding how it happened was not simple, explaining it clearly well nigh impossible. Simple situations work OK, but throw in a mix and match set of changes and I'm pretty sure nothing said in writing would work for all people all of the time.

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  6. There should be a letter writer Cadre with the proper language skills AND program knowledge. They should be given adequate time to research and draft then. Unreasonable quotas are destroying this Agency.

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    1. Good luck with that. I’ve dealt with some of the egos during the drafting stage. Oh my! If you mention something, make an edit, clarify, or even put the active voice in play, some take it as a personal affront rather than an overdue edit to an ossified boilerplate.

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  7. And appeal paragraphs attached to every notice, regardless of whether or not it was adverse.

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  8. @12:22pm,

    Exactly.

    Since OCO/PC started using those "bot" systems to do SFCRs for overpayments, no overpayment letter explains ANYTHING anymore beyond "You are overpaid because we paid you $X, while you were actually only due $Y".

    The BAs just copy and paste the automated results that are generated into the notices. Often those numbers go years and years into the past, even back to initial entitlement. The results generated are thus nonsensical to the public. It isn't even really possible to compare the paid vs what was supposedly payable because the two sections don't include matching payment dates to allow the claimant to compare amounts.

    I've gotten to the point where I encourage EVERY single claimant to appeal if we can't figure out exactly how the overpayment happened in an explainable manner as I simply don't have enough time to try to make that mess understandable to them. If enough of them appeal to the ALJs, the ALJs will eventually revolt and the agency will have to do something about it.

    @6:25pm,
    Because the majority of notices are generated by SSA's automated systems, the presence of the appeals language is required if there is the possibility of an adverse action (the computers simply aren't smart enough to determine whether an appealable adverse event has occurred or not).

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  9. I was in OGC during the government-wide effort to change government-ese to common sense prose. I think the effort began about 1972. The only thing I remember changing, if I am correct, is that all the "bureaus" became "offices," e.g. OFFICE of Hearings and Appeals. I actually liked Bureau. Reminded me for some reason of The Third Man and Peter Lorre.

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  10. Love life in the field - hurry up and call all those numbers, answer the GI line, etc etc oh btw make sure you get all those CFRs and the language perfect in those SSI non-med recon notices.

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