Signature No Longer Required On One Form

     From Emergency Message EM-23054:

This emergency message (EM) notifies technicians that we no longer require a signature on any version of the SSA-455 [a Continuing Disability Review form sent to claimants]...

SSA recently received OMB [Office of Management and Budget, whose pro forma OK is required before changing forms] approval to discontinue the requirement for a signature on the CDR Mailer form SSA-455 and SSA-455-OCR-SM. The latest inForm Library version of the SSA-455 has been updated to remove the signature box. ...

     If we can dispense with the signature requirement on this form, can't we dispense with some other signature requirements or at least verification of electronic signatures? There's a lot of field office time wasted on this.

I Think This Is Mostly Aimed At You, Social Security

    From a blog post by the Office of Management and Budget (OMB), which is part of the White House:

Long forms, long lines, and lots of documents – these are the hurdles that can make it difficult and frustrating for individuals and communities to access government programs and services.

Today, the Office of Management and Budget (OMB) is taking action to cut down on these “administrative burdens” by issuing new guidance for Federal agencies to help them better understand, identify, and reduce the burdens people experience when accessing public benefits programs. The guidance outlines how agencies should apply the Paperwork Reduction Act of 1995 (PRA), which governs how Federal agencies collect information, including the forms and paperwork people have to fill out when accessing government programs. ...

The memo directs Federal agencies in two key areas:

• Identifying administrative burdens. The PRA already requires agencies to document, analyze, and justify the information they collect on each form and gather public input on these points. This memo calls on Federal agencies to further engage with the public to fully understand their experience when applying for or submitting information to a benefits program. The memo also directs agencies to consider how other burdens in the process impose time, financial, and psychological costs on people.

• Reducing administrative burdens. The guidance also instructs agencies to consider policy, communication, technological, and design reforms that can make it easier for the public to access services. While there are no one-size-fits-all answers because of the unique purposes and populations served by each program, the memo encourages agencies to follow leading practices to reduce the challenges we already know make it harder for people to access services. ...
  

Advance Designation Of Rep Payee Form Leaks Out

      Social Security has a form to make an advance designation of representative payee but for reasons unknown to me they won’t release the form to the public. What good does it do to have the form but not release it to the public? However, a wills and estates law firm has gotten a copy and posted it online. 

Going Online To Schedule Appointments To File Claims

      Under the Paperwork Reduction Act Social Security must post notices when it develops new forms requiring information from the public. This is from such a notice posted today in the Federal Register:

... SSA developed an online tool to allow internet users to request an appointment to file an application for benefits and to establish a protective filing date with SSA. The electronic protective filing tool will allow individuals to submit information for the appointment request using a computing device, such as a personal computer or handheld (mobile) device instead of calling SSA by phone or visiting an FO [Field Office]. The tool will be available to potential claimants, as well as those individuals assisting them ...

[T]he system will ask the individual to tell us whether they are answering these questions about themselves, or about another person. To do so, the system will present several options for individual to select from the categories of individuals who, under current regulations, can establish a protective filing date. The next screens ask for basic information about the individual who will be claiming benefits, or requesting SSI payments. Additionally, the tool will collect the name, phone number, and email address (optional) of the person submitting the information, if that person is different than the person who will be claiming benefits or SSI payments. Once the system collects the data, it gives the individual the opportunity to review the information provided and electronically sign and submit the form. The system then transmits the information into eLAS [?] and establishes a protective filing date. ...

     The notice does not say when this might come into effect. The agency estimates that only 21,250 of these forms will be completed annually, which sounds awfully low.

Criticism For Social Security Form

      The Paperwork Reduction Act allows the public to comment on new or revised forms used by federal agencies. The Consortium for Citizens with Disabilities (CCD), the major umbrella group for non-profits advocating for the disabled, has submitted seven pages of comments to Social Security on a new revision of form SSA-454-BK, which is used when disability benefits recipients are subjected to continuing disability reviews. Here are a few excerpts:

SSA grossly underestimates the burden that responding to SSA-454-BK places on claimants and the public when it suggests the average burden is 60 minutes. [These estimates are required by the Paperwork Reduction Act.] Anecdotally, we believe that if you consider the complete time burden spent by the claimant and third parties to review SSA-454-BK, collect documentation, complete and transmit this form, it would take an average of 15-20 hours. This would include:

• times spent by the claimant receiving and reviewing the letter;
• time spent by assisters (neighbors, family, community assisters and sometimes SSA claims representatives) helping the claimant understand the SSA-454-BK form, and the steps required to respond (particularly in cases where SSA knows the claimant has intellectual, cognitive, behavioral or language deficits);
• time spent to collect information or documentation needed to complete the form;
• time spent by medical, behavioral health, and other providers furnishing documentation and or fielding specific questions necessary to complete the form;
• time spent securing assistance from advocates or lawyers;
• time spent to actually complete form;
• and the time required to transmit the SSA-454-BK to SSA. ...

Just completing the SSA-454-BK form is burdensome in and of itself. It is 15 pages long and requires multiple stamps to be mailed back to SSA. It requires beneficiaries to write short essays in response to questions, report all the medication they take and all of the medical treatment and providers they attend, and all of their daily activities. For adults and children with disabilities, this is usually a huge amount of information. ...

We recommend SSA take steps to reduce the burden on claimants by truncating and streamlining the SSA-454-BK. Specific consideration should be paid to the utility to each piece of information solicited as well as the burden it places on the claimant. Although detailed medical information is no doubt useful to evaluating ongoing disability claims, some of this information is not absolutely necessary to adjudicating the claim but may place a large burden on the responder. ...

     On the whole, I find Social Security's forms to be terribly drafted. They are usually poorly organized, too long, confusing and ask for more information than is needed. They seem to be created with little input from the Social Security employees who have to read the forms and with zero regard for the public which has to struggle with the forms. I am glad that CCD is giving some much-needed attention to this dark corner at Social Security.