tag:blogger.com,1999:blog-19246708.post1923918453801192841..comments2024-03-29T02:05:50.350-04:00Comments on Social Security News: A 12 Minute Test For Mental Or Cognitive Disability?Unknownnoreply@blogger.comBlogger3125tag:blogger.com,1999:blog-19246708.post-66780180232428169122009-10-15T23:24:06.119-04:002009-10-15T23:24:06.119-04:00Thanks for raising an alarm Charles! SSA will not ...Thanks for raising an alarm Charles! SSA will not likely go for any of these recommendations beyond the DOT replacement.Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-19246708.post-66663136334238877572009-10-15T20:29:57.113-04:002009-10-15T20:29:57.113-04:00They didn't propose to discard the mental RFC ...They didn't propose to discard the mental RFC assessment altogether, but they did consider the 4 categories and 20 abilities rated on the SSA-4734-SUP form, which is the current "conceptual model." Exactly how job demands are going to be rated reliably based on that form's constraints is beyond me. As they very prominently noted, "We must first decide what abilities to assess before we decide how to assess them." They recommended overall a somewhat different 4 categories with 15 abilities for evaluation.<br /><br />It was noted in the report that "it is impossible to parse psychological abilities that are essential for work into completely orthogonal dimensions", which would appear to include Dr. Schretlen's proposed <i>g</i>, and also included recommendations 2 and 3, which were on page 74 of that PDF. They did however, state that job complexity could be rated on a neurocognitive basis, but complexity alone was not the only demand to be rated.<br /><br />I also think it was a bit disingenuous to not include the rest of the paragraph from the TSA subcommittee. <i>The OIS should provide a platform from which SSA can develop and test revisions to its disability process and policies as the OIS data are obtained. Statistical analyses of OIS data and applied research will provide empirical bases for policy evolution that may result in proposed policy revisions that will be developed according to the Administrative Procedures Act (APA).</i> I read this as stating that they are expected to obtain data on which SSA can change its policies regarding vocational evaluation, which seems more consistent with what the Mental Cognitive Subcommittee is doing.<br /><br />I'm not saying the report is perfect, and my observations could be incorrect, but I feel you're raising an alarm over what amounts to nothing here.Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-19246708.post-11588320881397392762009-10-15T12:56:35.983-04:002009-10-15T12:56:35.983-04:00What you said, Mr. Charles T. :)What you said, Mr. Charles T. :)Nancy Ortiznoreply@blogger.com