Nov 20, 2014

Does This Line Keep Going Up And Up?

From a recent report by Social Security's Office of Inspector General

Nov 19, 2014

Budget Cuts Opposed

     From Joe Davidson's column in the Washington Post:
In advance of feared Republican budget cuts, Social Security advocates gathered on Capitol Hill to ward off more hits to a basic federal program that serves nearly all American families. ...
[S]ervice reductions have been a reality for years, with Congress providing less money than President Obama requested. ...
From fiscal year 2011 through 2013, the Social Security Administration received $2.7 billion less than Obama requested, followed by a small increase in 2014, according to a Senate Special Committee on Aging report.
“The three previous years of low funding, combined with a wave of retirements and a hiring freeze that has been in place since 2010, led to a reduction in staffing throughout SSA’s operations,” the report said.
Staffing reductions mean service reductions. The notion of doing more with less only goes so far and that is not far enough to maintain service without cuts.
Citing data from the National Council of Social Security Management Associations, the committee said field-office staffing dropped 14 percent from 2011 to 2014. ...
Good luck to Social Security clients requesting a hearing after being denied benefits. They’ll need a great deal of patience. There are about 1 million cases in the hearing backlog. SSA estimates it will take an average, not a maximum, of 435 calendar days for those clients to get a decision.
“Shameful” is the word acting SSA commissioner, Carolyn Colvin, had for the backlog.
Colvin, whom Obama has nominated to be the full time commissioner, said, “I’ve had to make some very, very difficult decisions.”
Reduced funding prevented the agency from hiring administrative law judges who conduct the hearings. That led, Colvin said, to “a situation I find not acceptable.”
The agency lost 12,000 employees it could not replace. How do you manage a field office now staffed with two or three employees instead of the eight to 12 who once worked there, she asked. Her answer: “It’s almost impossible.”
 She assured the advocates that “there is no grand plan to close down field offices” and she has “absolutely no intention” of using technology to replace workers — particular concerns of Mikulski and the American Federation of Government Employees (AFGE), whose members staff them. ...

I Don't Like This Press Release

     From a press release issued by the Republican majority on the House Ways and Means Committee: 
Last week, Social Security Administration (SSA) Inspector General (IG) Patrick P. O’Carroll, Jr., released a further response to the June 2014 letter sent by Ways and Means Subcommittee on Social Security Chairman Sam Johnson (R-TX), requesting a full and immediate investigation into the SSA’s mismanagement and failed implementation of the $300 million Disability Case Processing System (DCPS) ... Chairman Johnson issued the following statement:
“The news is not good for taxpayers based on reports received so far regarding Social Security’s failed implementation of a new disability case processing system. After spending close to $300 million, with efforts led by a team of multiple leaders using 46 vendors, Social Security spent almost $800,000 of hard-earned taxpayer dollars to pay an independent contractor to tell them they should have had one person in charge of the project. Worse, no one was fired and taxpayers will not get any of their misspent money back. It also raised questions about Social Security’s lack of transparency and more troubling efforts to possibly conceal information from the IG. Going forward, I will continue to hold the Commissioner fully accountable as she takes steps to right this wrong for taxpayers.”
Results of a criminal investigation regarding the implementation of DCPS are still pending.
     Criminal investigation? Give me a break. Read the actual IG report rather than just the press release. Nothing like that is suggested. Everybody knew that development and implementation of DCPS was going to be extraordinarily difficult since what it is replacing is a highly fragmented mess that developed over decades. Realistically, could DCPS have been managed better? Can it be better managed now? Maybe. I don't know. It's always easy to look back with 20/20 hindsight and say that mistakes were made along the way. That doesn't mean that the people who made those mistakes are fools or knaves. They just did the best they could under the circumstances. The idea that there is anything criminal seems absurd on its face. The IG report suggests nothing like that.
     Would DCPS have happened differently had John McCain or Mitt Romney been elected President? Probably not. Would this press release have been issued if there was a Republican president? Of course, not. The public isn't paying attention to DCPS. There's nothing here or likely to come out that would create any political advantage to either party.
     Can't we just get on with governing? Can't Republicans in Congress just do ordinary oversight (and ordinary second guessing) without this sort of press release? This sort of thing can't be good for day to day working relationships between Committee members, their staffs and Social Security officials.

Nov 18, 2014

Outreach To The Homeless Looks Successful, But ...

     The abstract of an article in the most recent issue of the Social Security Bulletin (emphasis added): 
This study uses administrative data to evaluate the outcomes of the disability applications submitted to the Social Security Administration (SSA) through the Benefits Entitlement Services Team (B.E.S.T) Demonstration Project and to determine if the project successfully increased access to Supplemental Security Income (SSI) payments and/or Disability Insurance (DI) benefits for individuals experiencing homelessness. B.E.S.T—a unique partnership between the Los Angeles County Department of Health Services, SSA, and the California Disability Determination Services—was a collaborative effort to locate homeless adults and assist them in applying for SSI payments and/or DI benefits. B.E.S.T facilitated the completion of SSI and DI applications, including the compilation of all forms and medical evidence needed to submit the completed applications to SSA. The findings show that B.E.S.T contributed to increased access to disability benefits for applicants. Relative to other disability cases, the B.E.S.T cases had high allowance rates and short processing times.
     The thing that concerns me is the degree of selectivity in the B.E.S.T. program. The article indicates that B.E.S.T. applicants had a 90% rate of success! There's no way of achieving that sort of "success" in this or any other population without being incredibly selective. In a law practice setting, I'd call it wildly overselective. Considering the frequency that homeless claimants are "lost to followup", as physicians put it, B.E.S.T. couldn't have just been insisting on gold plated cases. They must have been demanding platinum plated cases.
     This begs the question of what success means when you're trying to help homeless people.

Nov 17, 2014

OIG Report On ALJs With High Allowance And Disposition Rates

     The Office of Inspector General (OIG) report on "outlier" Administrative Law Judges (ALJs) who have unusually high rates of approving disability claims and who also dispose of many cases is out.
     I have to repeat what I said in response to the press reports that this was coming: 
  • Where did OIG find the gold standard for determining who is and who isn't disabled?
  • Will OIG share this gold standard with the rest of Social Security? The agency has been seeking this gold standard for more than 50 years. 
     The OIG report gives essentially no information about the gold standard they found. It's not clear who administered this gold standard. What sort of training and experience did those people have?
     Of course, I and others keep wondering when OIG will take a look at ALJs with low allowance rates.

On Average Each Social Security Employee Responsible For Administering $45.5 Million Each Year

     The National Academy of Social Security (NASI) recently computed the amount of Medicare and Medicaid benefits per employee of the Center for Medicare and Medicaid Services (CMS). I don't see that NASI has done a similar computation for Social Security. Let's give it a try. In 2013, Social Security paid out $2,764,431 million in retirement, survivors and disability benefits and $53,900 million in Supplemental Security Income (including state supplementation), for a total of $2,818,331 million in benefits. As of December 2013, Social Security had 61,957 employees. If my math is correct, that means that each Social Security employee was responsible for $45.5 million that year. 
     Given the vast sums of benefit payments that Social Security must administer, does the agency have enough employees to get the job done in an cost effective way? Does the agency have enough employees to provide adequate public service?

Nov 16, 2014

Options For Future Changes To Social Security

     From a survey conducted by Greenwald and Associates for the National Academy of Social Insurance (NASI) in June 2014:

Nov 15, 2014

Inspector General To Issue Report On ALJs Who Approve Many Disability Claims

     From the Wall Street Journal:
A large number of Social Security disability cases approved by certain judges lacked “a well-supported rationale” for awarding benefits, the agency’s inspector general will say in a new report, potentially drawing renewed scrutiny to a program that grew sharply during the economic downturn. 
The Social Security Administration’s inspector general plans next week to issue a report that looks at benefits paid by administrative law judges who had both decided an unusually large number of cases and awarded an unusually high number of benefits. 
The agency determined there were 44 judges over seven years who met that criteria, a number that represented just 4% of the agency’s judicial corps. ... 
It examined 275 instances when those judges awarded benefits and found that just 31 of the cases were “properly processed.” Another 216 of the cases “had quality issues,” and 28 “had missing information that prevented us from reviewing the file,” according to the report. 
The inspector general concluded that 38 of the 275 cases should have ultimately been denied. It used these findings to determine that the agency “improperly allowed disability benefits on approximately 24,900 cases, resulting in questionable costs of about $2 billion.”
     Could someone explain to me how Social Security's Office of Inspector General came by the gold standard for judging who is and who isn't disabled?  I know that the rest of Social Security would love to see that gold standard. They've been looking for it for more than 60 years but they just can't seem to find it.