Here's some excerpts from the NCSSMA comments:
We do not believe this [using online, self-service delivery as Social Security's primary service channel] is a realistic achievement. In order for online services to be our primary service channel, the majority, if not all, of our services would need to be available online. The agency still has too many obstacles to overcome for this to be a reality. This may be a vision for 20-25 years from now, but not a realistic vision for 2025. ...
Online services do not work for our most vulnerable clients. The vision should take into account how we will provide service to those individuals in rural areas where access to online services is still non-existent. We have seen little change in rural area services over the last decade. What will rural areas look like in 10 years and how does the agency satisfy their needs?
In order for online self-service delivery to be feasible at any time in the future, program simplification must take place. SSA programs are very complex and require highly trained and skilled technicians. Most program simplification requires legislative action and the agency has not been overly successful in the last several years in achieving program simplification. ...
It appears SSA is following IRS down the path of very little direct service. This means the public will be potentially paying third parties to explain complex rules. ...
Much of the above [plan] would describe a vision appropriate to SSA as an organization administering the Retirement Survivors and Health Insurance (RSHI) programs. However, the reality of Disability and SSI is one of growing numbers of people who are ill-equipped to do “virtual business” with us due to language, education, physical and mental barriers, as well as programs requiring ongoing stewardship review. It would be an impressive triumph of technology and efficiency to continue to provide service with the existing workforce numbers and community-based infrastructure as this population increases. Significantly reducing our community presence and/or workforce would adversely impact the vision to deliver high quality services. ...
Congress does not support most of the reductions in our physical infrastructure now and it is unlikely this will change by 2025. ...
From a philosophical perspective, it seems that this vision plan allows technology to dictate public service instead of envisioning what public service we want and the public wants and using technology to provide that service. Technology is a tool for humanity to use as we see fit and for our purposes. We control technology; technology should not control us.
By the way, the comments were made on an NAPA form. NCSSMA's name isn't at the top or bottom of the form but I assure you that these are NCSSMA's comments.
Both union and front line management personnel are in agreement that this is a bad plan. How are upper Social Security managers reacting to this? What about the Regional Commissioners? What about Nancy Berryhill, the Deputy Commissioner, Operations? What about Erik Jones, the Associate Commissioner for the Office of Public Services and Operations Support? And, of course, what about the Acting Commissioner? Are they leading or just holding up a finger in the wind, figuring they'll be gone before anything is ever implemented?
