Merry Christmas!

Regs On Submission Of Evidence Approved

     The Office of Management and Budget (OMB) has cleared Social Security's proposed "Program Uniformity" regulations. Social Security says these will address:

1) the time-frame for notifying claimants of a hearing date;
2) the information in our hearing notices;
3) the period when we require claimants to inform us about or submit written evidence, written statements, objections to the issues, and subpoena requests;
4) what constitutes the official record; and
5) the manner in which the Appeals Council considers additional evidence.

     Expect these to appear in the Federal Register shortly and to become effective before inauguration day. And to respond to a question someone raised, no, you won't be able to see the final version of this until Social Security sends it over to the Office of Federal Register.

Great Ideas Coming Out Of The CBO

     I don't know who's idea it was but the Congressional Budget Office (CBO) included two proposals for Social Security Disability Insurance Benefits among its "Options for Reducing the Deficit" -- eliminating eligibility for disability benefits for those 62 and older and requiring claimants to have worked 16 of the past 24 quarters before becoming disabled. The age 62 idea would save $17.4 billion over ten years. The 16/24 idea would save $44.5 billion over ten years. That sounds like small potatoes to me considering the political flak the GOP would take for adopting either but I'm not a Republican looking for ways to pay for a huge tax cut for the wealthiest Americans. By the way, neither idea is new. I think I first heard of the 16/24 idea in the late 1970s and it probably wasn't new then! Also, by the way, the CBO works for whoever controls Congress.
     The CBO also included proposals to eliminate Supplemental Security Income benefits for children, reduce Social Security benefits for new recipients, raise full retirement age and reduce the Social Security Cost of Living Adjustment (COLA).

A Sign Of What's To Come?

     Just before the House adjourned for Christmas, Sam Johnson, the Chairman of the House Social Security Subcommittee, introduced a bill that would make major cuts in Social Security benefits. Many media outlets have picked up on this as a harbinger of what's to come in the next Congress.

     Before the election, many Congressional Republicans privately expressed grave concerns about Donald Trump's integrity, knowledge, and temperament. They worried about the Russian attempt to influence the election. The gravest concern of these Republican members of Congress seemed to be that Trump isn't a true conservative. However, almost none of these Republicans spoke up publicly because Trump is popular with Republican voters. Now, some people are expecting these profiles in courage to march in lockstep to enact Social Security cuts that would be highly unpopular with Republicans and Democrats alike, when it would be completely predictable that Donald Trump would pull the rug out from under them?

Online Tools For Deciding When To Claim Benefits

     Social Security's Office of Research, Statistics and Policy Analysis has produced A Comparison of Free Online Tools for Individuals Deciding When to Claim Social Security Benefits. The study compares the free online tools provided by the Social Security Administration itself, the Consumer Finance Protection Bureau, the Center for Retirement Research at Boston College, the American Association of Retired Persons, Financial Engines and Bankrate. The bottom line is that each has its advantages and disadvantages.

You Heard It Here First

     The Washington Post has picked up on the story about declining service at Social Security field offices. I posted about this yesterday. I'll keep saying it. Come January 20, the GOP is the 100% owner of the terrible service at Social Security. I expect far more media attention to these problems.

Final Regs On Attorney Conduct Sent To OMB

     Social Security has sent a set of proposed final reguluations to regulate the conduct of attorneys and others who represent claimants before the agency to the Office of Management and Budget (OMB) for approval. OMB has little time to act on this. The final regulations would need to be in the Federal Register by December 20 to come into effect while Barack Obama is still President.

DCPS Coming Out Slowly

     Social Security has been developing the Disability Case Processing System (DCPS) for some time. It is supposed to replace piecemeal legacy systems now used in handling disability claims pending at the initial and reconsideration levels. The agency's Office of Inspector General (OIG) recently issued a report on DCPS. Here are some excerpts (footnotes omitted):

In May 2016, SSA estimated the first release of DCPS would be available in December 2016 —at a cost of less than $38 million — and would support initial claims and reconsiderations. However, while SSA now expects the actual development costs for the December 2016 release to be about $36.6 million, the release will only include functionality needed to support a limited number of cases . SSA will need to make further investments in the product before it will support initial claims and reconsiderations. ...

SSA previously planned to make DCPS Release 1 available by December 2016 with functionality that would enable users to proce ss both initial claims and reconsiderations. However, as of the date of our report, the Agency planned to make available to three participating DDSs in December 2016 what it refers to as an “ Early -Adopter Release” version of DCPS. The Early-Adopter Release will not include all of the DCPS Core functionality that SSA previously planned for Release 1. Instead, it will only enable users in participating DDSs to process those cases involving the most severely disabled who meet the Agency’s criteria for expedited review —Quick Disability Determinations and Compassionate Allowances.

SSA expects to make the Early Adopter-Release software available to the Delaware, Maine, and Ohio DDSs. However , the participating DDSs will only be able to use the DCPS pre-release software for a small percent of their workloads. Those DDSs would need to continue using their legacy systems to process other workloads -- such as non-expedited disabled adult cases, disabled child cases, and continuing disability review -- until the requisite functionality is developed and made available in subsequent release.