[Federal Register Volume 59, Number 180 (Monday, September 19, 1994)]
[Unknown Section]
[Page 0]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 94-22491]


[[Page Unknown]]

[Federal Register: September 19, 1994]


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DEPARTMENT OF HEALTH AND HUMAN SERVICES
 

Process Reengineering Program; Disability Reengineering Project 
Plan

Agency: Social Security Administration, HHS.

Action: Announcement of the plan for a new disability claim process.

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SUMMARY: The Social Security Administration (SSA) announces a plan to 
redesign the claim process for Social Security Disability Insurance and 
Supplemental Security Income (SSI) disability benefits. This notice 
contains the plan, as well as background information. The aim of the 
plan is to achieve dramatic improvements in service to claimants filing 
for disability benefits and restore public confidence in SSA's 
disability programs.

FOR ADDITIONAL COPIES CONTACT: Social Security Administration, PO Box 
17052, Baltimore, MD 21235, (410) 966-8255. The plan is available in 
alternative formats for visually impaired individuals. Please use this 
same telephone number to request a copy of the plan in an alternative 
format.

SUPPLEMENTARY INFORMATION:

Background--What is the Process Reengineering Program?

    SSA began an Agency-wide program of Process Reengineering in the 
summer of 1993. The Process Reengineering Program is one way that SSA 
is seeking to improve its overall delivery of service to the public.
    The Process Reengineering Program essentially asks the question, 
``If SSA had the opportunity today to design its processes, what would 
they look like?'' In other words, ``how would we design a process if we 
were starting over?'' The Programs objective is to fundamentally 
rethink and radically redesign SSA's processes to achieve dramatic 
improvements in critical measures of performance such as quality of 
service, speed and efficiency. The ultimate goal is to achieve 
dramatically improved levels of service from the customer's perspective 
while enriching and improving the work lives of employees.
    The Process Reengineering Program is the culmination of an 
investigation by SSA of the reengineering efforts conducted by private 
companies, public organizations, academic institutions, and consulting 
firms with ``hands on'' experience. The positive findings from that 
investigation, combined with concerns about the impact of current and 
projected workloads, led SSA to conclude that a disability claims 
process reengineering effort was critical to its objectives of 
providing world-class service to the public and restoring public 
confidence in its disability programs.
    Based on analysis of what has worked best in other organizations, 
SSA developed a customized reengineering methodology. This methodology 
used a team approach (composed of SSA and State Disability 
Determination Service (DDS) employees) and combined a strong customer 
focus with classic management analysis techniques to intensely review a 
single business process. While the reengineering team was comprised of 
employees who were knowledgeable about the current disability process, 
the methodology focused heavily on obtaining the views of a broad 
segment of individuals, groups and organizations involved both 
internally and externally to the process.

What Does the Disability Reengineering Project Address?

    Despite the outstanding efforts of SSA and State DDS employees 
throughout the country, the Agency continues to have difficulty 
providing a satisfactory level of service to claimants filing for 
disability benefits. The steps in the current disability process have 
not changed in any important way since the beginning of the Disability 
Insurance program in the 1950s. Yet, case loads, types of disabilities, 
and the demographic characteristics of individuals with disabilities 
who are potentially eligible for benefits have changed radically.
    The State DDSs make the initial decisions about whether an 
applicant for Disability Insurance or SSI benefits is disabled. In 
Fiscal Year (FY) 1995, it is estimated that SSA will forward 2.9 
million initial disability claims to the DDSs for disability 
determinations--a 69 percent increase over FY 1990 levels. Similarly, 
the number of requests for an administrative law judge hearing on 
denied claims is expected to increase to 542,000, a 75 percent increase 
over FY 1990 levels. Recent management initiatives to improve service 
through resource reallocations and productivity enhancements have not 
been sufficient to deal successfully with the workload demands and it 
is expected that disability processing times and backlogs will continue 
to grow under the present process.
    The result is that many claimants have to wait much too long at 
each stage of the process. SSA and State DDS employees are working 
longer and harder, while becoming increasingly frustrated about their 
inability to provide the type of service the public deserves.
    For these reasons, the first SSA reengineering project focused on 
the process of filing for benefits--beginning with the initial claim 
and continuing through the payment of benefits or the final 
administrative appeal--under both the Disability Insurance program and 
the disability portion of the SSI program.
    The parameters set for this first project restricted the team from 
proposing any changes to the statutory definition of disability or the 
amount of benefits for which individuals are eligible. The project also 
did not address vocational rehabilitation, work incentives or 
continuing disability reviews as these issues are being addressed by 
SSA in other ways.

How Was the Disability Process Reengineering Project Accomplished?

    The Disability Process Reengineering Project began in October 1993 
when a team of 18 Federal and State employees came together for the 
purpose of reengineering the initial and administrative appeals system 
for determining an individual's entitlement to Disability Insurance and 
SSI disability payments. After completing their initial tasks of 
analyzing the current process, obtaining process improvement 
recommendations from over 3,600 individuals and groups internal and 
external to the disability claim process, benchmarking with public and 
private sector organizations to identify ``best practices,'' and 
modeling theoretical processes via computer, the team presented an 
initial proposal on March 31, 1994. (A copy of this proposal was 
published in the Federal Register, Vol. 59, No. 73, on Friday, April 
15, 1994.) The team distributed the proposal widely throughout SSA, the 
State DDSs, and to interested public and private individuals and 
organizations and asked the audience for reactions to the proposal, 
items of concern, and additional ideas for improvement.
    During the comment period that began on April 1, 1994, and ended on 
June 14, 1994, the team received over 6,000 written responses from SSA 
and DDS employees, employee unions, professional associations, members 
of the public, claimant representatives, physicians, State governors, 
claimant advocacy groups, Federal entities, and other interested 
parties. Members of the team read and analyzed every one of the 
comments so that no idea, reaction or nuance would be overlooked. Group 
employee feedback discussions were held in over 80 sites across the 
country to facilitate dialogue with almost 2,000 SSA and DDS employees. 
In addition, team members conducted briefings and spoke with more than 
3,000 individuals about their reactions to the proposal during this 
period. A public forum was also held in Washington, D.C. A summary of 
the comments received is provided in Appendix III of the attached plan.
    After considering all comments, the team reviewed the breadth of 
the initial proposal to determine concepts that needed to be revised, 
language that needed to be clarified, and details that needed to be 
added. On June 30, 1994, the team submitted its revised proposal to the 
Commissioner of Social Security. Subsequently, after careful 
consideration, on September 7, 1994, the Commissioner released SSA's 
Plan for a New Disability Claim Process. Accepting all of the concepts 
contained in the team's June 30 revised proposal as SSA's plan, the 
Commissioner released the redesign plan with the understanding that 
certain concepts (primarily aspects of the simplified disability 
methodology) would require extensive research and testing before 
determining how quickly they could be implemented.

What Service Improvements Does the Plan for a New Disability Claim 
Process Offer?

    The Commissioner established five primary objectives against which 
SSA will measure the success of a redesigned disability claim process:

-- The process is user friendly for claimants and those who assist 
them;
-- The right decision is made the first time;
-- Decisions are made and effectuated quickly;
-- The process is efficient; and
-- Employees find the work satisfying.

    By focusing on these objectives, the redesigned process replaces an 
existing process that is slow, labor-intensive, and paper reliant with 
a seamless claim process that makes better use of technology, 
eliminates fragmentation and duplication, promotes more flexible use of 
resources, and results in dramatic improvements in public service. With 
the redesign plan, SSA has embarked on an era of change that will 
revitalize and streamline the way it delivers disability claim service 
to the public to achieve greater quality, speed and efficiency.
    Specific customer focused improvements that the plan will offer 
include a process that will:
     Be a user-friendly, more accessible and customer focused 
process, that ensures benefits are paid to all eligible individuals as 
quickly as possible. Case processing times will be cut in half once the 
new process is fully implemented;
     Provide complete and accurate consumer-oriented 
information to applicants throughout the process and allow individuals 
who are able to be full partners in the processing of their claim;
     Utilize modern technology and highly skilled and trained 
employees to deliver high-quality service in an accountable, cost-
efficient manner;
     Implement a comprehensive quality assurance program that 
continually strives to improve operational excellence and the level of 
service that disability applicants receive; and
     Use education and training opportunities to enrich 
employees jobs, increase their job satisfaction and quality of work 
life.
    A detailed description of the redesigned disability claim process 
is included in the attached plan.

What Happens Next?

    SSA will move quickly to begin implementing the redesigned 
disability claim process. Some new process features, involving research 
and changes to regulations and computer systems, necessitate a phased-
in approach. Other new process features can be implemented in the near-
term and, when combined with special short-term initiatives to address 
case backlogs, will result in better service for individuals currently 
filing for disability benefits. The goal is to make near-term, visible 
improvements while at the same time building for long-term results.
    SSA will make an unprecedented effort to conduct a full and open 
dialogue with both SSA and non-SSA audiences as the Agency moves 
through the implementation phase. The Agency will use all appropriate 
modes of communication to ensure that necessary information about 
implementation activities is regularly and widely disseminated and will 
develop appropriate feedback channels to permit the meaningful exchange 
of information.

    Dated: September 7, 1994.
Rhoda M. G. Davis,
Director, Process Reengineering Program.

Message From the Commissioner

Social Security Administration's Plan for a New Disability Claim 
Process

    It was 10 months ago that I challenged this Agency to restore 
public confidence in its programs, provide world-class service to its 
customers, and ensure a nurturing environment for its employees. While 
there is much left to be done to meet these goals, I am proud to say 
that with the release of this document we have reached a major 
milestone toward meeting the challenges I set forth.
    This document lays the foundation for the new disability claim 
process. It is a solid foundation upon which to build--it provides a 
broad description of the new process, with the detailed elements of the 
process to be developed.
    The new design gives us the opportunity to develop relationships 
with the public and our employees that are based on open communication, 
partnership, and the belief that our customers need to be provided as 
much information as possible about the process and the program. I 
believe this new design holds the potential to provide the world-class 
service I pledged to furnish the American people--it will be user-
friendly, it will ensure the right decision is made the first time, it 
will allow decisions to be made and effectuated quickly, and it will be 
an efficient process. Just as importantly, the new design will also 
provide our employees with a nurturing environment through empowerment, 
education, challenge, career opportunity, and professionalism.
    As the discussions about our reengineering effort and the future of 
the disability claim process evolved, I listened to the issues and 
opinions and the hopes and fears that have been expressed. I heard from 
SSA and State employees, the public, members of Congress, 
representatives of other Federal agencies, State officials, union 
representatives, and various experts in the disability field. I believe 
that everyone wants something better for the American people. I am 
convinced that we must be bold in our efforts. Therefore, I have chosen 
to accept the recommendations of the Agency's Disability Process 
Reengineering Team which were presented to me on June 30, 1994, with 
the full understanding that certain aspects of the decisional 
methodology will require extensive research and testing to determine 
whether they can be implemented. Because those aspects of decisional 
methodology that deal with functional assessment, baseline of work, and 
the evaluation of age require much study and deliberation with experts 
and consumers, we are making no conclusions about their ultimate place 
in the disability process. Our implementation plans include the 
research needed to begin in this area. As more is known, we will 
reevaluate our planning assumptions. Until then, the concept of a 
single person as the disability claim manager for all cases cannot be 
fully implemented. Instead, we will seek ways of working in teams to 
provide claimants with the level of service they seek.
    The cost of redesigning our disability claim process will not be 
inexpensive; however, the tangible savings will be worth the 
investment. The workyear savings will allow us to use current staff to 
accomplish other pressing workloads and activities of the Agency while 
avoiding new hiring to replace all those who retire or otherwise leave 
on their own accord. Thus, we will be able to do our part to reduce the 
Federal workforce overall. Additionally, with these savings will come 
such intangibles as improved customer service, an empowered and better 
trained workforce, and increased public confidence in the process.
    It is now time for us to move forward with concrete actions to 
begin the actual redesign of the way we do business in our disability 
programs. On July 12, 1994, I announced that Charles A. (Chuck) Jones, 
the Director of the Michigan Disability Determination Service, had 
accepted the challenge of managing the implementation of SSA's plan to 
reengineer the disability process. In that role, he will be responsible 
for the overall leadership and coordination of the redesign 
implementation. He will establish timelines and priorities and will 
provide direction to component efforts as well as to task management 
teams. As Implementation Manager, Chuck will report directly to me and 
the Principal Deputy Commissioner.
    During the discussions of the Team's proposal, I heard several 
consistent underlying themes about how our new design should be 
implemented: we must unify the process; we need enabling information 
technology; we need to ensure the safety of employees; we must 
continuously deliver effective training; we must retain the existing 
Federal/State relationship; and we must develop a simpler methodology 
for making disability decisions. I am absolutely committed to turning 
these needs into realities as we move ahead. Some will not be easy, and 
all will take time and money; however, all will need to be addressed if 
we are to achieve the successful outcome of the redesign.
    As implementation plans are developed and task teams are brought 
together, we will continue to assess all related activities against the 
five primary objectives of our redesigned process:

--making the process ``user friendly'' for claimants and those who 
assist them;
--making the right decision the first time;
--making the decision as quickly as possible;
--making the process efficient; and
--making the work satisfying for employees.

    However, this work will not be done in isolation-- internally, we 
will continue to seek advice on these issues from our Advisory Group, 
comprised of SSA and DDS executives and union and association leaders. 
Externally, we will continue to publicly inform all who are interested 
and create opportunities for dialogue and consultation.
    Special thanks are extended to the Disability Process Reengineering 
Team whose recommendations are the result of an unprecedented endeavor 
for this Agency, and I dare say for most Federal agencies. The Team's 
thousands of hours of interviews, research, analysis, computer 
modeling, feedback sessions, and revisions have created a daring image 
for us of what can be if we truly seek to provide world-class service. 
We must accept their challenge and begin the arduous task of bringing 
to reality what is now only a concept.
    The next few years will be challenging for all of us as we build 
our redesigned process, but that will not be a new experience for those 
of you who are employees of SSA and the State DDSs. You have been 
called upon in the past to rise to the occasion and have always more 
than met the challenge; your flexibility, resourcefulness, 
professionalism, and just plain hard work are legendary. Now more than 
ever, I will need you to be bold and help build a better future for 
those who seek our services.
Shirley S. Chater,
Commissioner of Social Security.

Case for Action

Overview

    SSA and the State Disability Determination Services (DDSs) have 
always striven to provide high-quality, responsive service to the 
public. In recent years, the disability insurance (DI) and Supplemental 
Security Income (SSI) claims workload has been the Agency's most 
challenging problem. SSA has been faced with unprecedented workload 
increases in both the DI and SSI programs which have severely strained 
its resources. Despite improvements in productivity by employees in 
field offices, DDSs, hearing offices, the Appeals Council and the 
processing centers over the last several years, SSA has had difficulty 
providing a satisfactory level of service to claimants for disability 
benefits. SSA recognizes that, in an era of spending limitations and 
competing social spending priorities, placing more and more resources 
into the current process is not a viable alternative.
    Additionally, demographic changes in the general population and in 
the SSA claimant population present challenges as well as opportunities 
as SSA strives to provide world-class service to its customers. Despite 
the workload and demographic changes, however, the procedures for 
processing disability claims have not changed in any important way 
since the beginning of the DI program in the 1950's and many of the 
Agency's current practices are based, in large part, on procedures 
begun 40 years ago. Disability process changes that have evolved over 
time tend to reflect small, incremental improvements designed to 
address various pieces of the overall process. It has become 
increasingly clear that incremental improvements are no longer 
sufficient to achieve the level of service that will make a substantial 
difference to disability claimants. Thus, SSA needs a longer-term 
strategy for addressing service delivery problems in the disability 
claim process.

Workload and Operations Trends

    Over the last several years, as workloads have increased 
dramatically, the disability process has been placed under increasing 
stress. The upward trend in the number of claims and the number of 
beneficiaries awarded is reflected as follows:

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    The increase in workload has occurred concurrently with significant 
downsizing activity in SSA and staffing fluctuations in the State DDSs.

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    Even with the downsizing, the total costs for processing initial 
disability and appeals determinations (excluding the costs for 
processing the Sullivan v. Zebley court case) remain enormous--more 
than half of the total administrative costs (including DDS costs) for 
SSA in Fiscal Year (FY) 1993 were devoted to this task.

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    Despite these funds, and despite directing a larger percentage of 
the SSA resources toward disability initial claims and appeals 
processing in recent years, average processing times for initial 
claims, as well as appeals, have escalated dramatically since 1988.

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    The high workload level is expected to continue and will adversely 
affect SSA's ability to timely process initial disability claims and 
appeals. Recent management initiatives to improve service through 
resource reallocations and productivity enhancements have not been 
sufficient to deal successfully with the workload demands and it is 
expected that disability processing times and backlogs will continue to 
grow under the present process. In FY 1995, it is estimated that 2.9 
million initial disability claims will be forwarded to DDSs for 
disability determinations--a 69 percent increase over FY 1990 levels. 
Similarly, in FY 1995, annual requests for administrative law judge 
(ALJ) hearings will rise to 542,000, a 75 percent increase over FY 1990 
levels. The average time to process an initial disability claim (the 
combined average for both DI and SSI claims) is expected to rise to 154 
days in FY 1995; the average time from ALJ hearing request to decision 
is expected to rise to 342 days in the same period.

Demographic Trends

    American society has changed dramatically since the DI program 
began in the 1950s. This is reflected in an increased demand for SSA's 
services, changes in the characteristics of claimants seeking benefits, 
and new complexities in claim-related workloads and processes.
    The demographic character of the SSA disability claimant population 
has changed as well. The enactment of the SSI program in the 1970's 
added individuals who have limited or no work histories, increased the 
number of individuals filing based on disabilities such as mental 
impairments, and provided for eligibility of disabled children. 
Additionally, the requirements of the SSI program added complex and 
time consuming development of non-disability eligibility factors such 
as income, resources and living arrangements. The 1990 U.S. Supreme 
Court decision, Sullivan v. Zebley, resulted in increased claims for 
children; children comprised 21 percent of all SSI claims in 1992, up 
from 11 percent in 1988. Homeless individuals and others with special 
needs have strained the delivery system. These claimants require 
significant intervention and assistance to navigate the disability 
claim process.
    A trend in the general population which is reflected in SSA's 
disability claimant population is the increased number of people in the 
United States for whom English is not the native language. Recent 
national Census data indicate that 1 in 7 people speak a language other 
than English in the home; this is an increase of almost 38 percent in 
the last 10 years. SSA will need to accommodate the special 
communication needs of these claimants in its ongoing claimant contacts 
and in public information vehicles.
    Forty percent of claimants filing for disability benefits and 
polled in a recent SSA survey had filed for or received benefits from 
Aid to Families with Dependent Children, welfare or social services 
within the past year. Approximately three-fourths of them were granted 
this assistance and three-fourths of those grantees were still 
receiving assistance when they applied for disability benefits. SSA has 
the opportunity to develop productive relationships with these social 
service entities to improve the processing of disability claims for 
mutual customers.
    Technological advances such as personal computers, facsimile 
machines, electronic mail, and videoconferencing are increasingly 
available to our claimants, their representatives, medical providers 
and other third parties involved in the disability process. SSA can 
take advantage of these capabilities to offer expanded service options 
and to modernize the ways it interacts with providers of claims-related 
information and evidence.

The Current Process

    The procedures in the current process have not changed in any 
significant way since the DI program began in the 1950s, a time when 
caseloads, demographic characteristics of claimants, types of 
disabilities, and available technology were radically different. In the 
1970s, Congress federalized State programs of cash assistance to the 
aged, blind and disabled into the SSI program and added this to the 
responsibilities of SSA. SSA adopted the DI disability determination 
procedures for SSI blind and disabled claims.

Slow, Manual Process

    In the current process, a disability claim passes through from 1 to 
4 decisional paths to receive a favorable decision. The initial claim, 
reconsideration, ALJ hearing and Appeals Council review levels all 
involve multi-step uniform procedures for evidence collection, review, 
and decisionmaking.

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    The process starts at the initial level when an individual first 
applies for DI and/or SSI benefits on the basis of a disabling physical 
or mental condition. An individual calls the national toll-free 
telephone number and is referred to a local SSA field office or visits 
or calls one of 1,300 local field offices to apply for benefits. Field 
office personnel assist with application completion, obtain detailed 
medical and vocational history and screen nonmedical eligibility 
factors. Field office personnel forward the claim to 1 of 54 State DDSs 
where medical evidence is developed and a final decision is made 
regarding the existence of a medically determinable impairment which 
meets the definition of disability. The decision is made by an 
adjudicative team consisting of a disability specialist and a program 
physician.
    After possible quality assurance review in the DDS or in the SSA 
regional Disability Quality Branch, the claim is returned to the field 
office; denials are retained pending possible appeal. In FY 1993, 39 
percent of initial claims were allowed and sent to 1 of 7 processing 
centers (which include the Office of Disability and International 
Operations and the 6 Program Service Centers) for final processing and 
storage, as well as adjudication of claims for dependents. Allowed SSI 
claims remain in the field office for payment effectuation and folder 
retention. A sample of these are reviewed after payment for 
nondisability quality assurance. According to SSA's computer-based 
processing time measurements, an initial claim currently takes an 
average of about 100 days to process from the time of filing until a 
decision is made. However, from the claimant's perspective, a better 
understanding of how long the process takes comes from a 1993 study 
conducted by SSAs Office of Workforce Analysis, which showed that an 
average claimant waits up to 155 days from the initial contact with SSA 
until receiving an initial claim decision notice. During this period, 
16 to 26 employees will handle the claim.
    The claimant may request reconsideration of the initial decision 
within 60 days of receiving the denial notice. In FY 1993, claimants 
requested reconsideration in 48 percent of denied claims. Local field 
office personnel receive the reconsideration request, update necessary 
information, and forward the claim file to the DDS for review, possible 
medical development, and a medical decision. The reconsideration 
decision is made by a different adjudicative team than the one that 
made the initial determination.
    After possible quality assurance review in the DDS or in the 
regional Disability Quality Branch, about 14 percent of these claims 
are returned to the field office for payment and forwarding to a 
processing center; the remaining denials are forwarded to the field 
office for retention, pending possible further appeal. According to 
SSAs computer-based processing time reports, the average 
reconsideration takes about 50 days--however, according to the Office 
of Workforce Analysis study, a claimant has now been involved with the 
disability process for roughly 8 months from the initial contact with 
SSA, and up to 36 different employees could have handled the claim.
    A claimant can request a hearing before an ALJ within 60 days of 
receiving an unfavorable reconsideration decision. In FY 1993, 
claimants requested an ALJ hearing in about 75 percent of all 
reconsideration denials. By this time, a claimant has usually retained 
an attorney or other representative to assist in pursuing the claim for 
benefits. About 75 percent of all claimants retain a representative at 
the hearing level. Local field office personnel receive the request for 
hearing and forward it with the claim file to one of 132 local SSA 
hearings offices. Hearing office personnel review the file for possible 
additional development, conduct a hearing, and render a decision.
    DI claims allowed at the hearing level are sent to a processing 
center for payment effectuation and adjudication of claims for 
dependents, and storage. Allowed SSI claims are returned to the local 
field office for income and resource development, and payment. Denied 
claims are forwarded to the Appeals Council for retention pending a 
possible request for review. According to computer-based reports, the 
hearing process takes about 265 days. However, according to the Office 
of Workforce Analysis study, a claimant has been dealing with SSA for 
over a year and a half at this point in the process.
    If dissatisfied with the hearing decision, a claimant (or 
representative) may request Appeals Council review within 60 days of 
receiving the ALJ decision. In FY 1993, about 23 percent of hearing 
decisions were unfavorable. The Appeals Council considers about 18 
percent of all ALJ dispositions, including cases it reviews on its own 
motion. Requests for Appeals Council review are typically received 
directly from the claimant's representative. The Appeals Council may 
deny or dismiss a request for review, issue a decision, or remand the 
claim to an ALJ. The Appeals Council remands claims to the ALJ level 
about 27 percent of the time for subsequent development and decision. 
Denied claims, representing about 70 percent of the Appeals Council 
dispositions, are held in the Appeals Council for possible appeal to 
Federal District court. Allowed claims are sent to a processing center 
or field office for further action as in hearing cases. According to 
processing time reports, this part of the process takes on average 
about 100 days; however, according to the Office of Workforce Analysis 
study, a claimant has spent almost 2 years dealing with SSA since 
initially contacting the Agency.
    At least part of the processing time results from the time added as 
the claim moves from one employee or facility to another (handoffs), 
and waits at each employee's workstation to be handled (queues). As 
workloads increase, the amount of time a claim waits at each processing 
point grows.
    ``Task time'' is the time employees actually devote to working 
directly on a claim, rather than the total amount of time it takes for 
a claimant to receive a final decision. Based on the Office of 
Workforce Analysis study, a claimant can wait as long as 155 days from 
the first contact with SSA until receiving an initial claim decision 
notice--of which only 13 hours of this is actual task time. The same 
study reveals a claimant can wait as long as 550 days from that initial 
contact through receipt of the hearing decision notice--of which only 
32 hours is actual task time.

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Complex, Confusing Process

    Many applicants enter the SSA disability process uninformed about 
the process itself and the definition of disability. They are unaware 
of the criteria for establishing disability and the evidence they will 
be required to submit. Even third parties and advocate organizations, 
often more knowledgeable than the general public about SSA procedures, 
experience difficulty obtaining meaningful information about the status 
of their clients claims, finding that they often are transferred from 
one employee to another.
    Disability claimants face a ``one size fits all'' approach to the 
intake and processing of their claim, finding themselves answering 
questions they believe are intrusive and irrelevant to their claim. 
Front-line employees currently devote hours to completing forms and 
obtaining information which may not be necessary for a finding of 
disability. Claimants often do not understand what happens to the claim 
after initial contact with SSA and view multiple requests for medical 
information with annoyance. Often claimants do not understand how the 
decision was made and, therefore, believe that it was reached 
arbitrarily. If the claim is approved, whether at the initial or 
appellate level, claimants and their representatives, as well as front-
line employees, are concerned about the complicated procedures and 
length of time it takes to effectuate payment and entitle eligible 
dependents.
    SSA employees, claimants, and other interested parties all agree 
that the current process takes too long to provide applicants a 
decision, and leaves them confused about who has responsibility for 
their claim, and puzzled about the status of their claim during various 
points in the process. Additionally, nearly all believe that many 
claimants can and should assume more responsibility for submitting 
evidence and pursuing their claim.
    Most view the reconsideration step as little more than a rubber 
stamp of the initial determination, creating additional work for 
employees and yet another bureaucratic obstacle for claimants and their 
representatives. Some believe a face-to-face interview with the 
decisionmaker is vital to reaching a fair, accurate determination; 
others believe just as strongly that the decision should be reached on 
the basis of a paper review, and that a face-to-face interview can lead 
to subjective decisions that are not based on objective criteria. 
Quality reviews and Appeals Council reviews are often mentioned as 
areas where opportunities exist for streamlining and improving the 
current process.
    Claimants and their representatives have learned their chances for 
a favorable decision improve if they appeal their claim to an ALJ. The 
public, in particular, believes that it is necessary to hire an 
attorney to maneuver through the appeals process, and voices resentment 
at having to do so. Higher allowance rates at the ALJ level lead to the 
perception that different adjudicative standards apply at the initial 
and appeals levels. A variety of factors may be contributing to this. 
The facts of many cases change over time as a claimants condition 
changes. ALJs often have access to information not considered at lower 
levels in the process because earlier decisionmakers are not as likely 
to have face-to-face interaction with the claimant.

Contributors to Complexity

    The collection of medical evidence presents problems as the case is 
developed, accounting for a considerable portion of the total time 
involved in disability claim processing. Health care providers who are 
a claimants treating source often do not understand the requirements 
for establishing disability, and find medical evidence request forms 
confusing and repetitive. They believe that evidence requests burden 
them with far too much paperwork and offer far too little in the way of 
compensation for the time invested. Adjudicators often find that 
evidence is primarily treatment-oriented and fails to provide either 
the highly specialized clinical findings or the functional information 
that is required by the regulations. To compensate for poor or missing 
medical evidence, DDSs purchase consultative examinations, devoting 
substantial resources to scheduling, purchasing, and processing these 
examinations.
    Once the medical evidence has been collected, the methodology used 
by disability decisionmakers is complex and controversial. The current 
sequential evaluation process, which was originally designed to 
identify and evaluate cases in a simple, rapid and consistent fashion 
has grown increasingly complex as the result of court decisions and 
changes in medical technology. This complexity has, in turn, 
contributed to the increasing difficulty and fragmentation in other 
portions of the disability process, including intake, evidence 
collection, and appeals.
    For example, the Listings of Impairments was originally designed to 
highlight readily identifiable disabling impairments. Many of the 
Listings have since evolved into complex and highly detailed diagnostic 
requirements, demanding specialized medical evidence that may not be 
readily available from treating sources. Some, but not all, of the 
Listings consider the functional consequences of an impairment; however 
functional considerations vary significantly among the Listings. 
Additionally, in assessing an individuals functional abilities at the 
later steps in the sequential evaluation, adjudicators collect and 
analyze evidence from a multitude of different, and often conflicting, 
sources including: objective clinical and laboratory findings; treating 
source opinions and other third-party statements considered to be 
consistent with the objective evidence; and the individuals description 
of his or her limitations. The development of extensive medical 
evidence in every case impedes timely and efficient decisionmaking. The 
varying approaches to assessing a claimants functional ability that are 
required at different steps in the sequential evaluation, along with 
the nature and types of evidence that adjudicators may rely on to 
assess function often lead to different interpretations of the same 
evidence by different adjudicators. Vocational rules originally 
designed to provide a structured approach to decisionmaking have grown 
increasingly complex, leading to varying interpretations and 
inconsistent decisions.

Fragmented Process

    The fragmented nature of the disability process is driven by and 
exacerbated by the fragmentation in SSA's policy making and policy 
issuance mechanisms. Policy making authority rests in several 
organizations with few effective tools for ensuring consistent guidance 
to all disability decisionmakers. Different vehicles exist for 
conveying policy and procedural guidance to decisionmakers at different 
levels in the process. While the standards for disability 
decisionmaking are uniform, they are expressed in different wording in 
the various policy vehicles.
    Training on disability is not delivered in a consistent manner, nor 
is it provided simultaneously to disability decisionmakers across or 
among levels in the process. Mechanisms for reviewing application of 
policy among levels of the process are fragmented and inconsistent. 
Review of DDS decisions is heavily weighted toward allowances; no 
systematic quality assurance program is in place for hearing decisions 
although the opportunity for feedback from the Appeals Council or from 
the courts is heavily weighted toward denials.
    The organizational fragmentation of the disability process creates 
the perception that no one is in charge of it. SSA measures the process 
from the perspective of the component organizations involved, rather 
than the perspective of the claimant. Multiple organizations (field 
offices, DDSs, hearings offices, Appeals Council operations, and 
processing centers) have jurisdiction over the claim at various points 
in time, with each line of authority managing toward its own goals 
without responsibility to the overall outcome of the process. 
Additionally, the impact of one components work product on other 
components is not measured, further contributing to the fragmentation 
of the process. Each component's narrow responsibilities reinforce a 
lack of understanding among component employees of the roles and 
responsibilities of other employees in different components.

The Need for a Redesigned Disability Claim Process

    Concerns about the Agency's business processes generally, and the 
quality of service in the disability claim process in particular, led 
SSA leadership to the conclusion that a disability process 
reengineering effort was critical to the SSA goal of providing world-
class service to its customers. The National Performance Review, headed 
by the Vice President, directed improvement of the SSA disability 
process as a key service initiative for the Federal government.
    Leading private sector organizations have used process 
reengineering to identify and quickly put in place dramatic 
improvements in their operations. The objective of a reengineering 
review is to fundamentally rethink and radically redesign a business 
process from start to finish, so that it becomes many times more 
efficient and, as a result, significantly improves service to the 
organization's customers. By focusing on the disability claim process 
as a single business process, SSA hoped to cut across the 
organizational lines and multiple components that handle the many 
pieces of the disability process.

Redesign Technique

    A project team composed of 18 Federal and State employees, under 
the direction of an SSA senior executive, assembled at SSA Headquarters 
in October 1993 to conduct the disability claim process reengineering 
review. With the guidance of an Executive Steering Committee the Team 
was challenged to fundamentally rethink the way SSA processes 
disability claims. The Team's initial findings and proposal, issued in 
March 1994, for a redesigned disability claim process were widely 
shared during a 60-day public comment period. Based on the comments 
received, the Team presented a revised proposal to the Commissioner of 
Social Security on June 30, 1994. After extensive consultation with 
individuals and organizations in the internal and external disability 
community, the Commissioner accepted the Team's recommendations for a 
redesigned disability process. A summary of the methodology used to 
redesign the disability claim process is included in Appendix I.

New Process Goals and Expectations

    The Commissioner established five primary objectives against which 
SSA will measure the success of a redesigned disability claim process:

--The process is user friendly for claimants and those who assist them;
--The right decision is made the first time;
--Decisions are made and effectuated quickly;
--The process is efficient; and
--Employees find the work satisfying.

    By focusing on these objectives, the redesigned process replaces an 
existing process that is slow, labor-intensive, and paper reliant with 
a seamless claim process that makes better use of technology, 
eliminates fragmentation and duplication, promotes more flexible use of 
resources, and results in dramatic improvements in public service. With 
the redesigned process, SSA has embarked on an era of change that will 
revitalize and streamline the way it delivers disability claim services 
to the public to achieve greater quality, accuracy, speed and 
efficiency. A detailed description of the redesigned disability claim 
process is presented in the following section.

Description of the New Process

Overview

    Claimants for disability benefits under the new process will be 
provided a full explanation of SSA's programs and processes at the 
initial contact with SSA. Claimants will be offered a range of options 
for filing a claim and conferring with decisionmakers, using various 
modes of technology to interact with SSA. Claimants, who are able to do 
so, along with third parties and representatives who act on their 
behalf, will assist in the development of their claims, deal with a 
single contact point in the Agency, and have the right to a personal 
interview with decisionmakers at each level of the process. The number 
of steps will be consolidated and the issues on appeal will be focused. 
If the claim is approved, the effectuation of payment to the claimant, 
eligible dependents and the representative will be streamlined.

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    The new process will result in correct decisions at the earliest 
possible point in the process. A correct disability decision is one 
that appropriately considers whether an individual does or does not 
meet the factors of entitlement for disability as defined by SSA's 
statute, regulations, rulings and policies. Correct decisions in the 
new process depend on: a simplified decision methodology that provides 
a common frame of reference for deciding disability at all levels of 
the process; consistent direction and training to all adjudicators; 
enhanced and targeted collection and development of medical evidence; 
an automated and integrated claim processing system that will assist 
adjudicators in evidence gathering, analysis and decisionmaking; and a 
single, comprehensive quality review process across all levels. The 
goal of the new process is to guide all adjudicators at all levels of 
the process, who will be using the same standards for decisionmaking, 
to making correct decisions in an easier, faster, and more cost-
effective manner.
    A disability claim manager will handle most aspects of the 
disability claim at the initial level, thus eliminating many steps 
caused by numerous employees handling discrete parts of the claim 
(handoffs) and the time lost as the claim waits at each employee's 
workstation to be handled (queues). This will reduce the time needed to 
rework files and redevelop information from the same evidentiary 
sources. Levels of appeal will be combined and improved, reducing the 
need to redevelop nonmedical eligibility factors after a favorable 
decision because less time will have elapsed since initial filing.
    The new process will enable the current work force to handle an 
increased number of claims, freeing the most highly specialized staff 
(physicians and ALJs) to work on those cases and tasks that make the 
best use of their talents, and targeting expenditures for medical 
evidence to those areas most useful in determining disability.
    Employees will perform a wider range of functions, using their 
skills to their full potential, enabling them to meet the needs of 
claimants and minimize unnecessary rework. The new process will 
facilitate employees' ability to do the total job by providing 
technology and the training and support to use that technology. [For 
ease of reference, references in this plan to ``SSA'' or ``employees'' 
include both Federal and State employees who participate in the 
disability process.]

Process Entry and Intake

Customized Intake and Entry

    The disability claim entry and intake processes will reflect the 
SSA commitment to providing world-class service to the public. The 
hallmarks of the process will be accessible, personal service that 
ensures timely and accurate decisions. SSA will work to make potential 
claimants better informed about the disability process and fully 
prepare them to participate in it. Every effort will be made to provide 
services to meet the needs of culturally diverse, non-English speaking 
claimants. SSA will also be flexible in providing modes of access to 
the claim process that best meet the needs of claimants and the third 
parties and representatives who act on their behalf. SSA will provide 
claimants with a single point of contact for all disability claim-
related business. Finally, SSA will ensure that the disability 
decisionmaking process promotes timely and accurate decisions.

Making Program Information Available

    SSA will make available to the general public comprehensive 
information packets about the DI and SSI disability programs. [For ease 
of reference, references in this plan to the SSI Disability Program 
include the Program for those who are blind.] The packets will include 
information about the purpose of the disability programs; the 
definition of disability; the basic requirements of the programs; a 
description of the adjudication process; the types of evidence needed 
to establish disability; and the claimant's role in pursuing a claim. 
The packets may be customized locally to include referral information 
about other programs and resources for legal representation. The goal 
is to target the information to likely beneficiaries and to ensure that 
potential claimants and other groups involved in the disability process 
have a better understanding of SSA disability programs, their medical 
and nonmedical requirements, and the nature of the decisionmaking 
process. This should result in reduction of general inquiries from 
members of the public unfamiliar with SSA disability programs and 
increase the number of claimants who enter the disability process 
knowledgeable and prepared to assume responsibility for pursuing their 
claims.
    SSA will make disability information packets commonly available in 
the community, both at facilities frequented by the general public 
(libraries, neighborhood resource centers, post offices, the Department 
of Veterans Affairs offices, and other Federal government 
installations) and at facilities frequented by potential claimants 
(hospitals, clinics, other health care providers, schools, employer 
personnel offices, State public assistance offices, insurance 
companies, and advocacy groups or third-party organizations that assist 
individuals in pursuing disability claims). SSA studies have shown that 
claimants frequently rely on advice from their physicians and from 
State public assistance personnel in deciding whether to file a claim 
for disability benefits. Therefore, SSA will make a special effort to 
target its public information activities at these and other known 
sources of referrals for claims. SSA will also make the disability 
information packets available electronically.
    In addition to comprehensive program information, the packets will 
describe the types of information that a claimant will need to have 
readily available when the individual files a claim. It will also 
contain two basic forms: The first, designed for completion by the 
claimant, will include general identifying information and will serve 
as the claimant's starter application for benefits; the second, 
designed for completion by the treating source(s), will request 
specific medical information about a claimant's alleged impairments. 
SSA will encourage claimants who are able to do so to review the 
information in the packet and have the basic forms completed prior to 
telephoning or visiting an SSA office to apply for disability benefits. 
Claimants will be encouraged to immediately submit starter applications 
to protect the filing dates for benefits. The starter application will 
serve as a claim for both programs, but it will include a disclaimer 
should the claimant want to preclude filing for benefits based on need 
(i.e., SSI).

Claimants Will Choose Mode of Entry

    The disability claim entry process will be multi-faceted, allowing 
claimants and third parties and representatives who assist them the 
maximum flexibility in deciding how they will participate in the 
process. Claimants may choose to enter the disability claim process by 
telephoning the SSA toll-free number, electronically, by mail, or by 
telephoning or visiting a local office. Claimants may also rely on 
third parties to provide them assistance in dealing with SSA. Finally, 
claimants may formally appoint representatives to act on their behalf 
in dealing with SSA. SSA field managers will also have the flexibility 
to tailor the various service options to their local conditions, 
considering the needs of client populations, individual claimants, and 
the availability of third parties who are capable of contributing to 
the application process.
    If an individual submits a starter application by mail or 
electronically, SSA will contact the claimant to schedule an 
appointment for a claim intake interview or, at the claimant's option, 
conduct an immediate intake interview by telephone.
    If an individual telephones SSA to inquire about disability 
benefits, the SSA contact will explain the requirements of the 
disability program, including the SSA definition of disability, and 
provide a general explanation of evidence requirements. The SSA contact 
will determine whether the individual has the disability information 
packet, and mail it or advise the claimant regarding possible means of 
electronic access. If an individual indicates a desire to file a claim 
at that time, the SSA contact will complete the starter application 
available on-line as part of the automated claim processing system to 
protect the claimant's filing date and schedule an appointment for a 
claim intake interview. The interview may be in person or by telephone 
at the claimant's option. If the individual has no medical treating 
sources, the SSA contact will annotate this information within the on-
line claim record.
    If a claimant visits an SSA office, the SSA contact will refer the 
claimant for an immediate claim intake interview or, at the claimant's 
option, complete the starter application and schedule a future 
appointment for an intake interview.
    In all cases, appointments for claim intake interviews will be made 
available within a reasonable time period, generally 3 to 5 working 
days, but no later than two weeks.
    Local management will determine how to best accommodate claimants' 
needs in learning about the disability process and completing a claim 
intake interview. Depending on an individual's circumstances, such 
accommodation may involve: Referral to the nearest location for 
obtaining a disability information packet which can then be mailed in; 
an immediate telephone or in-person interview; arranging for an on-site 
visit from an SSA representative; or referral to appropriate third 
parties who can provide assistance. Additionally, depending on the 
nature of the individual's disability, SSA may encourage the individual 
to file in person when it appears that a face-to-face interview will 
assist in the proper claim intake and development; however, face- to-
face interviews will not be required in every claim. Face-to-face 
interviews, when considered necessary by either the claimant or SSA, 
can also be accomplished via videoconferencing. In any case, SSA will 
make every reasonable effort to meet the needs of the claimant in 
completing the application process. Every effort will be made to 
provide services to members of the public who have limited knowledge of 
English.
    Similarly, local managers will modify the claim entry and intake 
process to provide maximum flexibility for representatives who act on 
behalf of claimants or third parties who can assist claimants in 
completing the application process. Such accommodations may include, 
but are not limited to: (1) Using automated means to interact with SSA 
to protect a claimant's date of filing (e.g., telephone, fax, or E-
mail); (2) providing appointment slots for third parties to accompany 
claimants to interviews or to provide assistance during telephone 
claims on a claimant's behalf; (3) out-stationing SSA personnel at a 
third-party location to obtain applications and/or medical evidence, 
when appropriate; and (4) providing ``open appointment'' scheduling to 
permit claimants to contact SSA within a flexible band of time. 
Interested third parties will be encouraged to participate in the 
development of claims.
    Local managers will also conduct outreach efforts that are designed 
to meet the needs of hard-to-reach populations or assist those 
individuals unable to access the SSA claim process without considerable 
intervention. As appropriate, outreach efforts may be facilitated 
through videoconferencing, teleconferencing or other electronic methods 
of obtaining and processing claim information to provide timely service 
despite claimants' geographic or social isolation.

Disability Claim Manager

    A disability claim manager will have responsibility for the 
complete processing of an initial disability claim. The disability 
claim manager will be a highly-trained individual who is well-versed in 
both the medical and nonmedical aspects of the disability programs and 
has the necessary knowledge, skills, and abilities to conduct personal 
interviews, develop evidentiary records, and adjudicate disability 
claims to payment. However, the disability claim manager will also be 
able to call on other SSA resources, including medical and technical 
support personnel, to provide advice and assistance in the claim 
process.
    Disability claim managers will rely on an automated claim 
processing system that will permit them to: Gather and store claim 
information; develop both medical and nonmedical evidence; share 
necessary facts in a claim with medical consultants and specialists in 
nonmedical or technical issues; analyze evidence and prepare well-
rationalized decisions on both medical and nonmedical issues; and 
produce clear and understandable notices that accurately convey all 
necessary information to claimants. In making decisions, disability 
claim managers will use a simplified decision methodology that 
effectively streamlines evidence collection, and will rely on standards 
for decisionmaking that are used at all levels of the process.
    The disability claim manager will be the focal point for claimant 
contacts throughout the claim intake and adjudication process. The 
disability claim manager will explain the disability programs to the 
claimant, including the definition of disability and how SSA determines 
if a claimant meets disability requirements. The disability claim 
manager will also convey what the claimant will be asked to do 
throughout the process; what the claimant may expect from SSA during 
this process, including anticipated timeframes for decision; and how 
the claimant can interact with the disability claim manager to obtain 
more information or assistance. The disability claim manager will 
advise the claimant regarding the right to representation and provide 
the appropriate referral sources for representation. The disability 
claim manager will also advise the claimant regarding community 
resources, including the names of organizations that could help the 
claimant pursue the claim. The goal will be to give the claimant access 
to the decisionmaker and allow for ongoing, meaningful dialogue between 
the claimant and the disability claim manager.

Scope of Duties

    The broad scope of the disability claim manager's duties and 
responsibilities, as outlined above and discussed in more detail in the 
following sections, presupposes a well-trained, skilled, and highly 
motivated workforce that has the program tools and technological 
support to issue quality decisions. Although disability claim managers 
will work exclusively within the disability programs, they will perform 
multiple tasks instead of singular activities, enabling them to 
experience the direct relationship between their actions and the final 
product. Varying levels of job complexity provide the opportunity for 
personal development, growth, and learning.
    In carrying out their duties and responsibilities, disability claim 
managers will work in a team environment with internal medical and 
nonmedical experts, who provide advice and assistance for complex case 
adjudication, as well as technical and other clerical personnel who may 
handle more routine aspects of case development and payment 
effectuation. Where disability team members cannot be physically co-
located, they can share information via the automated claim processing 
system and remain in communication using telephones or 
videoconferencing. Each disability team member will have at least a 
basic familiarity with all the steps in the process and an 
understanding of how he or she complements another's efforts; team 
members will be able to draw upon each other's expertise on complex 
issues.
    In this team environment, and with the proper training, program 
tools (a simplified decision methodology and one set of standards for 
decisionmaking) and technological support, one individual should be 
able to handle the duties and responsibilities of the disability claim 
manager. An individual employee as the disability claim manager is 
basic to the objective of a single point of Agency contact for 
claimants.
    However, in the near term, it may be necessary to consider whether 
the duties of a disability claim manager may be more appropriately 
carried out by more than one individual and, therefore, whether it is 
necessary to expand the ``disability team'' described above to include 
additional employees. Claim complexity, customer service needs, and 
service area location may dictate a need for flexibility in delineating 
the specific duties of the individuals who comprise the members of the 
disability team. In the near term, apprentice positions will be 
developed in which employees perform one or more duties of the 
disability claim manager while gaining experience and qualifying for 
greater responsibility. As the program tools and technological support, 
which are the underpinnings of the new process, are fully implemented, 
it is envisioned that team duties and positions will be modified and 
consolidated as necessary to fully realize the goal of an individual 
employee as disability claim manager.

Process Flexibility

    The disability claim manager will conduct a thorough screening of 
the claimant's medical and nonmedical eligibility factors. If the 
claimant appears ineligible for either disability program based on the 
claimant's allegations and evidence presented or available at the time 
of the claim intake interview, the disability claim manager will 
explain this to the claimant. However, the decision regarding whether 
to file an application will be the claimant's alone and the disability 
claim manager will not discourage a claimant from filing an 
application. If the claimant decides not to file a claim, the 
disability claim manager will follow existing procedures for closing 
out an oral inquiry.
    If the claimant decides to file, the disability claim manager will 
complete appropriate application screens from the automated and fully 
integrated (DI and SSI) claim processing and decision support system. 
Impairment-specific questions will assist the disability claim manager 
in obtaining information that is relevant and necessary to a disability 
decision. Based on the claimant's statements and the evidence that is 
available at the interview, the disability claim manager will determine 
the most effective way to process the claim. If the evidence is 
sufficient to decide the claim, the disability claim manager will take 
necessary action to issue a decision and, if necessary, effectuate 
payment. The disability claim manager will determine what additional 
evidence is required to adjudicate the claim and will take steps to 
obtain that evidence. Such steps may include asking the claimant to 
obtain further medical or nonmedical evidence if the claimant is able 
to do so, requesting medical evidence directly from treating sources, 
or ordering further medical evaluations. As in the current process, SSA 
will pay for the reasonable cost of providing existing medical 
evidence. If the claimant has a formal representative, the 
representative will have the responsibility to develop medical and 
nonmedical evidence.
    The disability claim manager will decide whether to defer 
nonmedical development (e.g., requesting SSI income and resource 
information, or developing DI dependents' claims) or do it 
simultaneously with development of the medical aspects of the claim. In 
making this decision, the disability claim manager will take into 
account the type of disability alleged, evidence and other information 
presented by the claimant, and other relevant circumstances, e.g., 
terminal illness, homelessness or difficulty in recontacting the 
claimant. Because the disability claim manager maintains ownership of 
the claim throughout the initial decision-making process, the 
disability claim manager will be in the best position to choose the 
most efficient and effective manner of providing claimants with timely 
and accurate decisions while meeting claimants' individual service 
needs.
    Although the disability claim manager will be responsible for the 
adjudication of an initial claim, the disability claim manager will 
call in other staff resources, as necessary. With respect to disability 
decisionmaking, the disability claim manager will, in appropriate 
circumstances, refer claims to medical consultants to obtain expert 
advice and opinion. SSA will develop guidelines to assist the 
disability claim manager in determining when expert medical advice is 
appropriate. Similarly, other staff resources will be called upon for 
technical support in terms of certain claimant contacts and status 
reports; development of nondisability issues including auxiliary claims 
or representative payee issues; and payment effectuation. However, the 
disability claim manager will make final decisions on both the medical 
and nonmedical aspects of the disability claim.

Claimant Partnership

    Throughout the disability claim process, SSA will encourage 
claimants to be full partners in the processing of their claims. Many 
claimants are able to obtain the documentation necessary to develop 
their record, either on their own or with the assistance of a third 
party. Others have substantial difficulty doing so, and may have no 
third party to assist them. Given the range of claimant capabilities, 
SSA will retain ultimate responsibility for development of claims when 
claimants are not formally represented.
    To the extent that they are able, claimants and their families and 
other personal support networks will actively participate in the 
development of evidence to substantiate their claim for disability 
benefits. SSA will provide assistance and/or engage third-party 
resources, when necessary and appropriate. SSA will keep claimants 
informed of the status of their claims, advise claimants regarding what 
additional evidence may be necessary, and inform claimants what, if 
anything, they can do to facilitate the process.
    At the completion of the claim intake interview, the disability 
claim manager will issue a receipt to the claimant that will identify 
what to expect from SSA and the anticipated timeframes. It will also 
identify what further evidence or information the claimant has agreed 
to obtain. Finally, it will provide the name and telephone number of 
the disability claim manager for any questions or comments which the 
claimant may have, including any difficulty in obtaining the 
information the claimant agreed to obtain.

Third Parties

    Certain third-party organizations may be willing to provide a 
complete disability application package to SSA. Based on local 
managements assessment of service area needs and the availability of 
qualified organizations, SSA will recognize third-party organizations 
who are capable of providing a complete application package, including 
appropriate application forms and medical evidence necessary to 
adjudicate a disability claim. In such claims, SSA will permit the 
third party to identify potential claimants, screen for medical and 
nonmedical criteria, and contact SSA to protect the filing date. The 
third party will interview the claimant; complete all applications and 
related forms; obtain completed treating source statements; and obtain 
additional medical evaluations, when appropriate. Using procedures 
agreed on with local management, the third party will submit claims for 
adjudication by a disability claim manager. SSA will monitor such third 
parties to ensure that quality service is provided to claimants and to 
prevent fraud. SSA may establish rules, standards, and procedures for 
third-party interaction with claimants and SSA. Third parties may be 
required to undergo periodic program, procedural or software training, 
and may be required to meet standards for staffing and automation 
support. In individual cases, disability claim managers may elect to 
contact the claimant for the purpose of verifying identity or other 
claim-related issues, as appropriate. SSA will also perform ongoing 
document verification on a sample basis to assure the integrity of 
claims submitted by third parties. The automated claim processing 
system will facilitate effective monitoring of the claim-taking and 
evidence submission practices of third parties by permitting random 
and/or targeted selection of claim files involving specific third 
parties or specific types of evidence.

Personal Interview With Claimant

    When the evidence does not support an allowance, the disability 
claim manager will issue a predecision notice advising the claimant of 
what evidence has been considered and providing the opportunity to 
submit further evidence, if any, and/or the opportunity for a personal 
interview within 10 calendar days. The predecision notice will further 
advise the claimant that if he or she does not submit evidence or 
request a personal interview within the 10 days, the claim will be 
decided based on the evidence of record. If the claimant requests a 
personal interview, the disability claim manager will conduct the 
interview in person, by videoconference, or by telephone, as the 
disability claim manager determines is appropriate under the 
circumstances. In appropriate circumstances, this predecision interview 
may be held concurrently with the initial intake interview. If the 
claimant identifies further available evidence, the disability claim 
manager will advise the claimant to obtain the evidence if the claimant 
is able to do so or, as necessary, assist the claimant in obtaining it. 
The claimant will be advised of the specified timeframes for submitting 
additional evidence.
    In preparing the predecision notice, the disability claim manager 
will rely on existing information available on-line as part of the 
automated claim processing and decision support system. As part of the 
evidence gathering process, the disability claim manager will have 
previously analyzed all the medical and non-medical information 
gathered, and entered the pertinent data into the electronic claim 
record. The decision support system will use the accumulated data in 
the electronic record to assist the disability claim manager in 
producing the predecision notice.

``Statement of the Claim''

    The initial disability determination will use a statement of the 
claim'' approach. The statement of the claim will set forth the issues 
in the claim, the relevant facts, the evidence considered, including 
any evidence or information obtained as a result of the predecision 
notice, and the rationale in support of the determination. The 
statement of the claim not only reflects SSAs commitment to fully 
explaining the basis for its action but also recognizes that claimants 
need clear information about the basis for the determination to make an 
informed decision regarding further appeal.
    As with the predecision notice, much of the information that will 
provide the basis for the statement of the claim will be available on-
line as part of the automated claim processing and decision support 
system. Adjudicators will create the statement of the claim and 
whatever supplementary information is necessary for a legally 
sufficient notice to the claimant based on the information in the 
decision support system. For allowance decisions, the statement of the 
claim will be more abbreviated than for denial decisions; however, it 
will contain sufficient information to facilitate quality assurance 
reviews and/or continuing disability reviews. The statement of the 
claim will be part of the on-line claim record and will be available to 
other adjudicators as the basis and rationale for the Agencys action, 
if the claimant seeks further administrative review.
    In making initial disability determinations, disability claim 
managers will rely on standards for decisionmaking that are used at all 
levels of the process. SSA will develop a single presentation of all 
substantive policies used in the determination of eligibility for 
benefits and all decisionmakers will be bound by these same policies. 
These policies will be published in accordance with the Administrative 
Procedure Act. Expert systems will be developed to facilitate the 
development and delivery of disability policy as an integrated part of 
the automated claim processing system.

Disability Decision Methodology

Promoting Consistent, Equitable, and Timely Decisions

    SSA must have a structured approach to disability decisionmaking 
that takes into consideration the large number of claims (2.7 million 
initial disability decisions in FY 1994) and still provides a basis for 
consistent, equitable decisionmaking by adjudicators at each level. The 
approach must be simple to administer, facilitate consistent 
application of the rules at each level, and provide accurate results. 
It must also be perceived by the public as straightforward, 
understandable and fair. Finally, the approach must facilitate the 
issuance of timely decisions.
    As described further below, the goal of the new decisionmaking 
approach is to focus decisionmaking on the functional consequences of 
an individual's medically determinable impairment(s). The new process 
will assess an individual's functional ability, assess it once in the 
process, do it directly rather than indirectly, and rely on 
standardized functional assessment instruments to do so. By focusing on 
function, the new approach will permit both providers of medical 
evidence and adjudicators at all levels of the process to use a 
consistent frame of reference for deciding disability, regardless of 
the diagnosis. It will also facilitate evidence collection by lessening 
the need for voluminous medical records and, instead, look at the 
consequences of medical findings, i.e., function. Ultimately, 
adjudicators will make correct decisions in an easier, faster, and more 
cost-effective manner.
    The cornerstone of the new approach is, of course, the statutory 
definition of disability. Under the statute, disability (for adults) 
means the:

    ``. . .inability to engage in any substantial gainful activity 
by reason of any medically determinable physical or mental 
impairment which can be expected to result in death or which has 
lasted or can be expected to last for a continuous period of not 
less than 12 months. . .An individual shall be determined to be 
under a disability only if his physical or mental impairment or 
impairments are of such severity that he is not only unable to do 
his previous work but cannot, considering his age, education, and 
work experience, engage in any other kind of substantial gainful 
work which exists in the national economy. . .'' (Sec. 223(d) of the 
Social Security Act).

Four-Step Evaluation Process for Adults

    The new decisionmaking approach is the foundation on which SSA will 
base the claim intake process and evidence collection. The focus will 
be, first, to document the medical basis for concluding that an 
individual has a medically determinable physical or mental impairment. 
Second, once the evidence establishes a medically determinable 
impairment(s), decisionmakers will, in most cases, use additional 
medical findings to determine the link between the disease or 
impairment and the loss of function.
    The disability decision methodology will consist of four steps that 
flow from the statutory definition of disability. They are:
    Step 1--Is the individual engaging in substantial gainful activity?
    If yes, deny.
    If no, continue to Step 2.
    Step 2--Does the individual have a medically determinable physical 
or mental impairment?
    If no, deny.
    If yes, continue to Step 3.*
    Step 3--Does the individual have an impairment included in the 
Index of Disabling Impairments i.e., an impairment that clearly 
restricts functional ability to a degree that the individual is unable 
to engage in substantial gainful activity without measuring the 
individual's functional ability?
    If yes, allow.*
    If no, continue to Step 4.
    Step 4--Does the individual have the functional ability to perform 
substantial gainful activity?
    If yes, deny.
    If no, allow.*

    *An impairment must meet the duration requirement of the 
statute; a denial is appropriate for any impairment that will not be 
disabling for 12 months.
Step 1--Engaging in Substantial Gainful Activity
    Any individual who is engaging in substantial gainful activity will 
not be found disabled regardless of the severity of the individual's 
physical or mental impairments. Under the new approach, SSA will 
simplify the monetary guidelines for determining whether an individual 
who is an employee (except those filing for benefits based on 
blindness) is engaging in substantial gainful activity. In making this 
determination, SSA will evaluate the work activity based on the 
earnings level that is comparable to the upper earnings limit in the 
current process (i.e., $500). A single earnings level will simplify the 
evidentiary development necessary to evaluate work activity and 
establish the appropriate onset date of disability. Additionally, SSA 
will continue to exclude impairment-related work expenses in evaluating 
whether an individual's earnings constitute substantial gainful 
activity. SSA will continue to evaluate whether work activity is done 
under special conditions and/or is subsidized. Finally, SSA will 
continue to use separate earnings criteria to evaluate the work 
activity of blind individuals in the DI program as in the current 
process.
Step 2--Medically Determinable Impairment
    Because the statute requires that disability be the result of a 
medically determinable physical or mental impairment, the absence of a 
medically determinable impairment will justify a finding that the 
individual is not disabled. Under the new approach, decisionmakers will 
consider whether an individual has a medically determinable impairment 
or combination of impairments, but will no longer impose a threshold 
``severity'' requirement. Rather, the threshold inquiry will be whether 
the individual has a medically determinable physical or mental 
impairment or combination of impairments. To establish the presence of 
a medically determinable impairment, evidence must show an impairment 
that results from anatomical, physiological, or psychological 
abnormalities which are demonstrable by medically acceptable clinical 
and laboratory diagnostic techniques.
    Decisionmakers will continue to evaluate the existence of a 
medically determinable impairment based on a weighing of all evidence 
that is collected, recognizing that neither symptoms nor opinions of 
treating physicians alone will support a finding that the individual 
has a medically determinable impairment or combination of impairments. 
There must be medical signs and findings established by medically 
acceptable clinical or laboratory diagnostic techniques which show the 
existence of a physical or mental impairment or combination of 
impairments. Depending on the nature of an individual's alleged 
impairment(s), SSA will consider the extent to which medical personnel 
other than physicians can provide evidence of a medically determinable 
impairment.
    There will be an exception to the requirement that evidence include 
medically acceptable clinical and/or laboratory diagnostic techniques. 
This will occur when, even if SSA accepted all of the individual's 
allegations as true, SSA still could not establish a period of 
disability; under these circumstances, SSA will not require evidence to 
establish the existence of a medically determinable impairment. For 
instance, if an individual describes a condition as one that will 
clearly not meet the 12-month duration requirement, (e.g., a simple 
fracture), SSA will deny the claim on the basis that even if the 
allegations were medically documented, SSA could not establish a period 
of disability.
Step 3--Index of Disabling Impairments
    If an individual has a medically determinable physical or mental 
impairment documented by medically acceptable clinical and laboratory 
techniques, and the impairment will meet the duration requirement, the 
decisionmaker will compare the individual's impairment(s) against an 
index of severely disabling impairments. The index will describe 
impairments so severely debilitating that, when documented, can be 
presumed to equal a loss of functional ability to perform substantial 
gainful activity without assessing the individual's functional ability. 
The index will be consistent with the statutory definition of 
disability by limiting the presumption of inability to perform 
substantial gainful activity, without considering age, education and 
previous work, to a relatively small number of claims with the most 
severe disabilities. Individual functional ability will be assessed in 
all other cases in a consistent manner at Step 4 in the process.
    Because the index will permit severely disabling impairments to be 
identified quickly and easily, it will only consist of descriptions of 
specific impairments and the medical findings that are used to 
substantiate the existence and severity of the particular disease 
entity. The medical findings in the index will be as nontechnical as 
possible and will exclude such things as calibration or standardization 
requirements for specific tests and/or detailed test results (e.g., 
pulmonary function studies or electrocardiogram tracings). The index 
will be easy to understand and simple enough so that laypersons will be 
able to understand what is required to demonstrate a disabling 
impairment in the index. Additionally, SSA will draw no conclusions 
about the effect of an individual's impairments on his or her ability 
to function merely because an individual's impairment(s) does not meet 
the criteria in the index. Finally, SSA will no longer need the concept 
of ``medical equivalence'' in relation to the index. Because 
impairments included in the index are presumed to limit functional 
ability so as to preclude substantial gainful activity without 
reference to an individual's age, education and previous work, a 
combination of impairments, or an impairment closely related to one 
that is in the index, would be found disabling when an individual's 
functional ability is assessed. Therefore, rules for determining 
equivalence for impairments in the index will not be necessary.
Step 4--Ability to Engage in Any Substantial Gainful Activity
    The majority of disability claims will be evaluated using a 
standardized approach to measuring functional ability to perform 
substantial gainful activity. This standardized approach will 
realistically measure an individual's functional ability to do the 
principal dimensions of work and task performance. The approach will be 
known and accepted in the medical community. It will be universally 
used by public and private disability programs in which benefits are 
based on the ability to perform work-related duties. Standardizing the 
approach to assessing individual functional ability will facilitate 
consistent decisions regardless of the professional training of the 
decisionmakers in the disability process.
    In using a standardized approach to measuring functional ability, 
SSA will be assessing the individual's physical and mental abilities to 
perform work-related activities. Individualized assessments of 
functional ability will also consider the effects of the individual's 
education. Once the individualized assessment of functional ability is 
made, the individual's age will determine whether his or her functional 
ability is compared against the demands of the individual's previous 
work or against a ``baseline'' of occupational demands. The baseline 
will describe a range of work-related functions that represent work 
that exists in significant numbers in the national economy that does 
not require prior skills or formal job training.

Standardized Measure of Functional Ability

    SSA will develop, with the assistance of the medical and advocacy 
community and other outside experts from public and private disability 
programs, standardized instruments or protocols which can be used to 
measure an individual's functional ability. These standardized measures 
of functional ability will be linked to clinical and laboratory 
findings to the extent that SSA needs to document the existence of a 
medically determinable impairment or combination of impairments. 
However, extensive development of all available clinical and laboratory 
findings will not always be necessary in evaluating an individual's 
functional ability to perform basic work activities.
    Functional assessment instruments will be designed to measure, as 
objectively as possible, an individuals abilities to perform a baseline 
of occupational demands that includes the principal dimensions of work 
and task performance, including primary physical, psychological, and 
cognitive processes. Examples of task performance include, but are not 
limited to: physical capabilities, such as sitting, standing, walking, 
lifting, pushing, pulling; mental capabilities, such as understanding, 
carrying out, and remembering simple instructions; using judgment; 
responding appropriately to supervisors and co-workers in usual work 
situations; and responding appropriately to changes in the routine work 
setting; and postural and environmental limitations. To the extent that 
current regulations already set forth guidelines for evaluating an 
individual's ability to perform certain of these tasks, they will be 
utilized in the new process.
    Functional assessment instruments will be designed to realistically 
assess an individuals abilities to perform a baseline of occupational 
demands. To the extent possible, objective measures of function will be 
developed. However, a realistic and individualized assessment of 
function may require, in addition to objective measures of function, a 
standardized means or standardized tools for collecting information 
regarding an individuals perceptions of his or her functioning, the 
effect of symptoms, including pain, and the individuals activities of 
daily living. Functional assessment instruments may also require 
impairment-specific measures to account for the episodic nature of 
certain impairments or to meet a more general need for longitudinal 
information.
    SSA will be primarily responsible for documenting functional 
ability using the standardized functional assessments. In the near 
term, SSA will solicit information on which to base a functional 
assessment from treating medical sources, other nonmedical sources, and 
from claimants in a manner that is similar to the current process. In 
the future, the standardized functional assessments will be widely 
available and accepted so that functional assessments may be performed 
by a variety of medical sources, including treating sources. The SSA 
goal will be to develop functional assessment instruments that are 
standardized, that accurately measure an individuals functional 
abilities and that are universally accepted by the public, the advocacy 
community, and health care professionals. Ultimately, documenting 
functional ability will become the routine practice of physicians and 
other health care professionals, such that a functional assessment with 
history and descriptive medical findings will become an accepted 
component of a standard medical report.
    Disability insurance payers have incentives to participate in the 
research necessary to develop standardized functional assessments and 
some private insurers have already expressed interest in working with 
SSA in this effort. Standardized functional assessments will not only 
provide SSA with the functional information necessary to make 
disability decisions; functional measurements will also assist in 
developing provider reimbursement levels relating to rehabilitation and 
in assuring quality in rehabilitation programs by permitting assessment 
of the relationship between rehabilitative interventions and outcomes. 
Ultimately, the use of the same functional assessment measurements by 
both SSA and medical insurance payers will facilitate the cooperation 
and participation of the medical community in developing, refining, and 
implementing them.

Baseline Occupational Demands

    SSA will use the results of the standardized functional assessment 
in conjunction with a new standard that SSA will develop to describe 
basic physical and mental demands of a baseline of work that represents 
substantial gainful activity and that exists in significant numbers in 
the national economy.
    To develop the new approach, SSA will conduct research and will 
work in conjunction with outside experts and consumers to specifically 
identify the activities that comprise a baseline of occupational 
demands needed to perform substantial gainful activity. The baseline 
will describe a range of work-related functions that represent work 
that exists in significant numbers in the national economy. In 
establishing the work-related functions that comprise an appropriate 
baseline of occupational demands, SSA will ensure that: 1) the 
functional activities are a realistic reflection of the demands of 
occupations that exist in significant numbers in the national economy; 
and 2) the occupations are those that can be performed in the absence 
of prior skills or formal job training.
    The Department of Labors Advisory Panel for the Dictionary of 
Occupational Titles (DOT) has made recommendations for developing a new 
DOT by 1996 which will be a data base system that collects, produces, 
and maintains accurate, reliable, and valid information on all 
occupations in the national economy. This new system will provide 
comprehensive occupational data that includes, but is not limited to: 
physical demands of work; sensory/perceptual requirements; cognitive 
job demands; physical working conditions; and job characteristics such 
as pace or intensity of work, and the scope of interactions with 
others. The development of a national data base with detailed 
occupational information should assist SSA in conducting the initial 
research necessary to identify a baseline of occupational demands that 
represents work existing in significant numbers in the national 
economy. It should also provide a mechanism to ensure that the baseline 
of occupational demands remains current and reflects changes in the 
national economy over time.

Effect of Education

    The statute recognizes that education may play a role in an 
individual's ability to perform substantial gainful activity. 
Experience demonstrates that educational level alone, i.e., the 
numerical grade level that an individual has attained, may not be a 
good indicator of ability to function. For example, completion of a 
certain educational level in the remote past, without any practical 
application of that education in recent work activity, has no positive 
effect on an individual's ability to perform substantial gainful 
activity. Similarly, completion of a certain grade level does not 
necessarily represent mastery of the subject matter.
    In relying on standardized functional assessments, SSA will be 
measuring an individual's ability to perform the principal dimensions 
of work and task performance, including primary physical, 
psychological, and cognitive processes, and the positive effects of 
education will be appropriately reflected in the assessment of an 
individual's cognitive abilities. Thus, evaluation of a claimant's 
educational level will be done as an integral part of establishing the 
functional ability of that individual. The baseline of occupational 
demands will not reference prior skills or significant formal job 
training.
    The issue of whether literacy and/or specific communication or 
language skills will be a factor in disability evaluation depends on 
the extent to which such skills are occupational demands of work 
existing in significant numbers in the national economy. In conducting 
the necessary research to identify the occupational demands of baseline 
work that represents work existing in significant numbers in the 
national economy, SSA will need to consider whether literacy or 
specific communication and language skills are required as occupational 
demands.

Effect of Age

    The effect of aging on the ability to perform substantial gainful 
work is very difficult to measure, especially in the context of today's 
world when individuals are living longer than preceding generations. 
Despite this change, the demographic characteristics of those preceding 
generations continue to provide the framework for disability 
decisionmaking because SSA's approach for deciding disability has 
changed little since the inception of the DI program.
    The statute recognizes that age should be considered in assessing 
disability on the assumption that the ability to make a vocational 
adjustment to work other than work an individual has previously done 
may become more difficult with age. In determining the impact of age, 
recognition should be given to the changes that occur with each 
succeeding generation. Accordingly, in the new process, SSA will 
establish an age criterion in relation to the full retirement age. The 
full retirement age will gradually increase over time, based on the 
recognition that succeeding generations can expect to remain in the 
workforce for longer periods than the preceding generation.
    In applying age criterion under the new process, an individual who 
falls within the prescribed number of years preceding the full 
retirement age will be considered as nearing full retirement age.'' In 
establishing what the prescribed number of years should be, SSA will 
conduct research and consult with outside experts on the relationship 
between age and an individual's ability to make vocational adjustments 
to work other than work the individual has done in the recent past.
    SSA will rely on the age of the individual in relation to the full 
retirement age to decide which of two decision paths to follow as 
described in the next two sections.

Individuals Not Nearing Full Retirement Age

    For an individual who is not nearing full retirement age, SSA will 
compare the individual's functional abilities against the functional 
demands of the baseline work. The ability to perform the baseline work 
will represent a realistic opportunity to perform substantial gainful 
activity that exists in significant numbers in the national economy and 
a finding of disability will not be appropriate.
    However, anyone who cannot perform the baseline work will be 
considered unable to engage in substantial gainful activity, and a 
finding of disability will be justified. The range of work represented 
by less than the baseline will be considered so narrow that despite any 
other favorable factors, such as young age or higher education or 
training, an individual would not be expected to have a realistic 
opportunity to perform substantial gainful work in the national 
economy.
    For individuals who are not nearing full retirement age, the 
ability or inability to perform previous work is not a significant 
factor. These individuals should be capable of making a vocational 
adjustment to other work, as long as they are functionally capable of 
performing the baseline work.

Individuals Nearing Full Retirement Age

    For individuals who are nearing full retirement age, SSA will 
compare the individuals functional abilities against the functional 
demands of the individuals previous work. Individuals nearing full 
retirement age can not be expected to make a vocational adjustment to 
work other than work they have performed in the recent past. However, 
consistent with the statute, if an individual, even one nearing full 
retirement age, is capable of performing his or her previous work, SSA 
will find that the individual is not disabled.
    For those individuals who have no previous work, SSA will compare 
the individuals functional ability to the range of work-related 
functions that represent work that exists in significant numbers in the 
national economy, i.e., baseline work, and a finding of not disabled 
will be appropriate if the individual is capable of performing the 
baseline work. In such claims, when the fact that the individual has no 
previous work is not related to the existence of his or her 
impairment(s), a finding of disability will not be appropriate if the 
individual retains the functional ability to perform a range of work-
related functions that represent work that exists in significant 
numbers in the national economy. In contrast, those individuals who 
have significant functional limitations caused by a medically 
determinable impairment and lack of education would not be able to 
perform a range of work-related functions that represent work existing 
in significant numbers in the economy. Such individuals would be found 
disabled, as they are today.

Medical Consultant Expertise

    SSA will continue to rely on medical consultants to provide expert 
advice and opinion regarding medical questions and issues that will 
arise in deciding disability claims. Disability adjudicators at all 
levels of the administrative review process will call on the services 
of medical consultants to interpret medical evidence, analyze specific 
medical questions, and provide expert opinions on existence, severity 
and functional consequences of medically determinable impairments. 
Additionally, on a national basis, SSA may identify specific types of 
issues that may require a medical opinion. If a medical consultant is 
called on to offer expert advice and opinion, the medical consultant 
will provide a written analysis of the issues and rationale in support 
of his or her opinion. The written analysis will be included in the 
record and will be considered with the other medical evidence of record 
by disability adjudicators at all levels of administrative review. 
Additionally, medical consultants will assist in the training of other 
consultants and disability adjudicators; contact other health care 
professionals to resolve medical questions on specific claims; carry 
out public relations and training with the medical community; and 
participate in the quality assurance program.

Childhood Disability Methodology

    As with adults, SSA must have a structured approach to disability 
decisionmaking in childhood claims that takes into consideration the 
relatively large number of claims and still provides a basis for 
consistent, equitable decisionmaking by adjudicators at all levels of 
administrative review. The approach for childhood claims must also 
derive from the statute. Under the statute, ``an individual will be 
considered to be disabled for purposes of this title if he is unable to 
engage in any substantial gainful activity by reason of any medically 
determinable physical or mental impairment which can be expected to 
result in death or which has lasted or can be expected to last for a 
continuous period of not less than 12 months (or in the case of a child 
under the age of 18, if he suffers from any medically determinable 
physical or mental impairment of comparable severity).'' 
Sec. 1614(a)(3)(A) of the Social Security Act)
    Of course, any decision approach for childhood claims must be 
consistent with the Supreme Courts interpretation of this statutory 
language in Sullivan v. Zebley, 493 U.S. 521 (1990).

Four-Step Evaluation Process for Children

    The disability decision methodology for childhood claims will 
consist of four steps that are based on the statutory definition of 
disability. As with adults, the approach is one that provides accurate 
decisions that can be achieved efficiently and cost-effectively, 
primarily by ensuring that documentation requirements are directed 
toward the ultimate finding of disability. To the extent possible, the 
approach for childhood claims should mirror the adult approach. The 
four steps are:
    Step 1--Is the child engaging in substantial gainful activity?
    If yes, deny.
    If no, continue to Step 2.
    Step 2--Does the child have a medically determinable physical or 
mental impairment?
    If no, deny.
    If yes, continue to Step 3.*
    Step 3--Does the child have an impairment that is included in the 
Index of Disabling Impairments?
    If yes, allow.*
    If no, continue to Step 4.
    Step 4--Does the child have an impairment(s) of comparable severity 
to an impairment(s) that would prevent an adult from engaging in 
substantial gainful activity?
    If yes, allow.*
    If no, deny.

    *An impairment must meet the duration requirement of the 
statute; a denial is appropriate for any impairment that will not be 
disabling for 12 months.
Step 1--Engaging in Substantial Gainful Activity
    Any child who is engaging in substantial gainful activity will not 
be found disabled regardless of the severity of his or her physical or 
mental impairments. The guidelines for determining whether a child is 
engaging in substantial gainful activity will be identical to the 
guidelines for adults. Although the issue of work activity will arise 
infrequently in childhood claims, the step is warranted for two 
reasons: 1) the approach for adults and children should be as similar 
as possible; and 2) as a child approaches age 18, it is increasingly 
likely that work activity may be an issue.
Step 2--Medically Determinable Impairment
    Because the statute requires that disability be the result of a 
medically determinable physical or mental impairment or combination of 
impairments, the absence of a medically determinable impairment will 
justify a finding that a child is not disabled. To establish the 
presence of a medically determinable impairment or combination of 
impairments, evidence must show an impairment that results from 
anatomical, physiological, or psychological abnormalities which are 
demonstrable by medically acceptable clinical and laboratory diagnostic 
techniques.
    The same guidelines and rules that apply for adults will apply 
equally for children. SSA will continue to evaluate the existence of a 
medically determinable impairment based on a weighing of all evidence 
that is collected, recognizing that neither symptoms nor opinions of 
treating physicians alone will support a finding of disability.
    SSA will use the same exception for evidence collection in 
childhood claims that will be applied in adult claims. If a child has a 
medically determinable physical or mental impairment that is not an 
exception to further development, SSA will then evaluate whether the 
impairment(s) is included in the index of disabling impairments.
Step 3--Index of Disabling Impairments
    If a child has a medically determinable physical or mental 
impairment or combination of impairments documented by medically 
acceptable clinical and laboratory techniques and the impairment(s) 
will meet the duration requirement, SSA will compare the child's 
impairment(s) against an index of disabling impairments.
    As with adults, the index for childhood claims will function to 
quickly identify severely disabling impairments. The index will 
describe impairments so severely debilitating that the impairment is of 
comparable severity to an impairment that would prevent an adult from 
engaging in substantial gainful activity without assessing the child's 
functional ability. As with adults, individual functional ability in 
childhood claims will be assessed in a consistent manner at Step 4 in 
the process.
    The index for childhood claims will consist of descriptions of 
specific impairments and the medical findings that are used to 
substantiate the existence and severity of the particular disease 
entity. The medical findings in the index will be as nontechnical as 
possible and will be simple enough so that laypersons will be able to 
understand what is required to substantiate a disabling impairment in 
the index. As with adults, SSA will draw no conclusions about the 
effect of a child's impairments on his or her ability to function 
merely because a child's impairment(s) is not included in the index. 
Additionally, SSA will no longer use the concept of ``medical 
equivalence'' or functional equivalence in relation to the childhood 
index.
Step 4--Comparable Severity to an Impairment(s) That Would Prevent an 
Adult From Engaging in Substantial Gainful Activity
    Consistent with the approach for adult claims, SSA will develop, 
with the assistance of the medical community and educational experts, 
standardized instruments which can be used to measure a child's 
functional ability. These standardized measures of functional ability 
will be linked to clinical and laboratory findings to the extent that 
SSA needs to document the existence of a medically determinable 
impairment or combination of impairments. The functional assessment 
instruments will be designed to measure, as objectively as possible, a 
child's ability to function independently, appropriately, and 
effectively in an age-appropriate manner. Ultimately, the course of 
documenting and developing for functional abilities in childhood claims 
will, to the extent possible, mirror the adult approach. However, SSA 
will consider whether it is appropriate to defer the development of 
standardized functional assessment instruments for use in childhood 
claims until it gains experience in the development, refinement and use 
of such instruments for adults.
    SSA will use the results of the standardized functional assessments 
to determine whether a child has impairment(s) of comparable severity 
to an impairment(s) that would prevent an adult from engaging in 
substantial gainful activity, as in the current process.

Medical Evidence Development

Timely and Accurate Decisions

    SSA's ability to provide timely and accurate disability decisions 
depends to a significant degree on the quality of medical evidence it 
can obtain and the speed with which it can obtain it. The medical 
evidence collection process accounts for a considerable portion of the 
total time involved in processing disability claims.
    The new process will eliminate multiple, repetitive requests for 
information from health care providers. Health care providers will be 
relieved of requests for information that burden them with far too much 
paperwork and will be compensated for the time invested in providing 
information.

Core Diagnostic and Functional Information Focus

    The goals of the evidence collection process will be to focus 
requests for evidence on the critical diagnostic and functional 
assessment information necessary for a disability decision and to form 
a new partnership with the sources of this information so that it can 
be obtained in the most efficient, cost-effective manner. Medical 
evidence development will be driven by the four-step approach used to 
decide disability. Two of the core elements of that approach are: (1) 
identifying an individual's medically determinable impairments 
(including those that meet the Index of Disabling Impairments 
criteria); and (2) assessing the functional consequences of those 
impairments. The decisionmaker will develop medical evidence that is 
sufficient to satisfy the core elements but target evidentiary 
development to obtain only the evidence necessary to reach an accurate 
decision on the ultimate question of disability.

Treating Source Preference

    SSA will give primary emphasis to obtaining medical information 
from treating sources that provides brief, but specific, diagnostic 
information regarding an individual's medically determinable 
impairments and the functional consequences of those impairments. 
Treating source statements will include diagnostic information about a 
claimant's impairments, the clinical and laboratory findings which 
provide the basis for the diagnosis, onset and duration, response to 
treatment, and the functional limitations that can reasonably be linked 
to the clinical and laboratory findings. Depending on the nature and 
extent of an individual's impairments and treating sources, statements 
from multiple medical sources may be appropriate. Once the standardized 
measurement criteria described earlier are widely available, a 
standardized functional assessment available from a treating source 
will be accepted as probative evidence. Treating sources or another 
examining source may perform the standardized functional assessment at 
SSA's expense.

Standardized Request Form

    SSA will develop a standardized form which effectively tailors a 
request for evidence to the specific diagnostic and functional 
assessment information necessary to make a disability decision. Such 
information includes but is not limited to diagnostic information about 
a claimant's impairments, the clinical and laboratory findings which 
provide the basis for the diagnosis, onset and duration, response to 
treatment, and the functional limitations that can reasonably be linked 
to the clinical and laboratory findings. Treating sources will be 
encouraged to submit such information electronically. Standardizing 
requests for evidence in this manner will facilitate the participation 
of claimants, representatives and third parties in the evidence 
collection process.
    The form will permit treating sources to provide necessary 
diagnostic and functional assessment information in summary form on a 
single document. In appropriate circumstances, SSA will accept a 
treating source's statements on the standardized form as to history and 
diagnosis, the clinical and laboratory findings which provide the basis 
for the diagnosis, onset and duration, response to treatment, and the 
functional limitations that can reasonably be linked to the clinical 
and laboratory findings, without resorting to the traditional, 
wholesale procurement of actual medical records. In completing 
standardized forms, treating sources will certify that they have in 
their possession the medical documentation referred to in the statement 
and that said documentation will be promptly submitted at the request 
of SSA. The certification approach does not relieve treating sources 
from providing objective evidence in support of their diagnoses and 
opinions; rather it is designed to streamline the collection of 
necessary evidence. The approach is also consistent with evidence 
collection methods used by private disability insurance carriers, which 
request specific medical records in individual claims, when necessary 
and appropriate to the individual circumstances, or at random as part 
of a quality assurance program.
    Treating source completion of the standardized forms will be 
monitored to prevent fraud. Decisionmakers will verify treating source 
statements by obtaining underlying medical records when appropriate. 
The automated claim processing system will facilitate effective 
monitoring of the evidence submission practices of individual treating 
sources by permitting random and/or targeted selection of claim files 
involving that treating source for quality assurance and program 
integrity reviews.

Treating Source Incentives

    As in the current process, SSA will pay for the reasonable cost of 
providing existing medical evidence. SSA will acknowledge the value of 
treating source information by establishing a national fee 
reimbursement schedule for medical evidence. The fee reimbursement 
schedule will utilize a sliding-scale mechanism to reward the early 
submission of medical information; additionally, the sliding scale will 
be adjusted to reflect the quality of the evidence received. A 
national, sliding-scale fee schedule will provide incentives for 
treating sources to cooperate in the evidentiary development process 
and invest quality time to provide medical certifications on behalf of 
their patients.
    SSA will provide resources to focus professional educational 
efforts and medical relations outreach at the local and/or regional 
level to ensure that treating sources are given up-to-date information 
on program requirements and made aware of specific evidentiary needs or 
problems as they arise in the adjudication process. SSA will conduct 
educational outreach on the national level on an ongoing basis with the 
medical community to provide a better understanding of the SSA 
disability programs, the medical and functional requirements for 
eligibility, and the best ways to provide medical information needed 
for decisionmaking.

Consultative Examination

    If a claimant has no treating source, or a treating source is 
unable or unwilling to provide the necessary evidence, or there is 
conflict in the evidence that can not be resolved through evidence from 
treating sources, the decisionmaker will refer the claimant for an 
appropriate consultative examination. Because the standardized 
measurement criteria for assessing function will be widely available, 
consulting sources will be able to perform functional assessments that, 
in the absence of adequate treating source information or where there 
are unresolved conflicts in the evidence, will be considered probative 
evidence. Depending on the service area, SSA will consider contracting 
with large health care providers to furnish consultative examinations 
for a specified geographic location.
    As part of an ongoing training and medical relations program, SSA 
will ensure that providers of consultative examinations are provided 
adequate training on disability requirements. Those medical providers 
who conduct consultative examinations for SSA will also need ongoing 
training regarding changes in the disability program. SSA will prepare 
training programs for this audience which will utilize written, 
audiotape, videotape, and computerized training methods.

Administrative Appeals Process

Simple, Accessible Process

    To eliminate the public perception that multiple, mandatory appeal 
steps are obstacles to receiving timely, fair, and accurate decisions, 
SSA will reduce the number of mandatory appeals steps in the 
administrative process. Streamlining the appeals process will not only 
promote more timely decisions but also ensure that claimants do not 
inappropriately withdraw from the claim process based on a perception 
that it is too difficult or time-consuming to pursue their appeal 
rights.
    Claimants will be able to fully participate in the administrative 
appeals process with or without a representative. SSA will ensure that 
claimants are fully advised of their right to representation and SSA 
will routinely provide the appropriate referral sources for 
representation. SSA will also encourage the early participation of a 
representative when the claimant has appointed one and will give the 
representative responsibility for developing evidence necessary to 
decide a claim. However, the decision whether to appoint a 
representative must remain with the claimant and SSA will neither 
encourage nor discourage claimants in seeking representation.
    The administrative appeals process will instill public confidence 
in the integrity of the system. To instill such confidence, SSA will 
provide an initial decisionmaking process that is thorough and results 
in fully developed records with fair and accurate decisions. 
Additionally, the claimant will be given the basis of a decision in 
clear and understandable language. Finally, SSA will ensure that its 
policies have been consistently applied at all levels of administrative 
review.
    As noted previously, the initial disability determination will use 
a ``statement of the claim'' approach which will set forth the issues 
in the claim, the relevant facts, the evidence considered, including 
any evidence or information obtained as a result of the predecision 
notice, and the rationale in support of the determination. The 
statement of the claim will be part of the on-line claim record and 
will stand as the basis and rationale for the Agency's action, if the 
claimant seeks further administrative review. SSA will standardize 
claim file preparation and assembly, including the use of appropriate 
electronic records, at all levels of administrative process until such 
time as the claims record is fully electronic.

First Appeal Level

    Because the initial determination will be the result of a process 
that ensures fully developed evidentiary records and ample opportunity 
for the claimant to personally present additional evidence prior to an 
adverse determination, there will be no need for any intermediate 
appeal (e.g., reconsideration) prior to the ALJ hearing. If the 
claimant disagrees with the initial determination, the claimant may, 
within 60 days of receiving notice, request an ALJ hearing.

Adjudication Officer

    When a claimant requests an ALJ hearing, an adjudication officer 
will conduct an interview in person, by telephone, or by 
videoconference, and become the primary point of contact for the 
claimant. The adjudication officer will have the same knowledge, skills 
and abilities as the adjudicators who decide claims initially. The 
adjudication officer will also have specialized knowledge regarding 
hearings procedures. The adjudication officer will be the focal point 
for all prehearing activities but will work closely with the ALJ, 
medical consultants and the disability claim manager, when appropriate.
    The adjudication officer will provide the claimant an in-depth 
understanding of the hearing process, with particular focus on the 
right to representation. To prevent delays caused by a lack of 
understanding of this right, the adjudication officer will again 
provide the appropriate referral sources for representation; give the 
claimant, where appropriate, copies of necessary claim file documents 
to facilitate the appointment of a representative; and encourage the 
claimant to decide about the need for and choice of a representative as 
soon as is practical. The adjudication officer will be available to 
answer the claimant's questions and concerns regarding the hearing 
process.
    The adjudication officer will also identify the issues in dispute 
and whether there is a need for additional evidence. If the claimant 
has a representative, the representative will have the responsibility 
to develop evidence. If the claimant has a representative, the 
adjudication officer will also conduct informal conferences with the 
representative, in person or by telephone, to identify the issues in 
dispute and prepare written stipulations as to those issues not in 
dispute. If the claimant submits additional evidence, the adjudication 
officer may refer the claim for further medical consultation and 
opinion, as appropriate.
    The adjudication officer will have full authority to issue a 
revised favorable decision if the evidence so warrants. This will 
ensure that allowance decisions are expedited and not delayed until a 
formal hearing before an ALJ. If the adjudication officer issues a 
favorable decision, the adjudication officer will refer the claim to a 
disability claim manager to effectuate payment.
    The adjudication officer will consult with the ALJ during the 
course of prehearing activities, as necessary and appropriate to the 
circumstances in the claim. As a preliminary matter, the adjudication 
officer will also routinely schedule a date for the hearing that is a 
standard number of days after the hearing request. Standardizing the 
hearing date process will facilitate claimant understanding and reduce 
the possibility of non-appearance at the hearing. It will also enable 
representatives to plan their schedules when taking on a case. The 
adjudication officer may exercise discretion in establishing an earlier 
or later hearing date depending on the individual circumstances and the 
ALJ's calendar. Electronic access to ALJs' calendars, as established by 
individual ALJs, will facilitate timely and appropriate scheduling of 
hearings. The adjudication officer will refer the prepared record to an 
ALJ only after all evidentiary development is complete and the claimant 
or a representative agrees that the claim is ready to be heard.
    The ALJ will retain the authority and ability to develop the 
record. However, use of an adjudication officer realigns most, if not 
all, prehearing activities so that the burden of ensuring their 
completion rests with other members of the adjudicative team. With 
completely developed claims before them, ALJs will be able to 
concentrate their efforts on conducting more hearings and rendering 
decisions faster.

Hearing Proceedings

    The ALJ hearing will be a de novo proceeding in which the ALJ 
considers and weighs the evidence and reaches a new decision. A de novo 
hearing is consistent with the role of an ALJ envisioned under the 
Administrative Procedure Act. Under that scheme, the ALJ is an 
independent decisionmaker who must apply an agency's governing statute, 
regulations and policies, but who is not subject to advance direction 
and control by the agency with respect to the decisional outcome in any 
individual claim. ALJs are independent triers of fact who perform their 
evidentiary factfinding function free from agency influence. At the 
same time, the Administrative Procedure Act ensures that an ALJ's 
decision is subject to later review by the agency, thus giving the 
agency full authority over policy. Policy responsibility remains 
exclusively with the agency while the public has assurance that the 
facts are found by an official who is not subject to agency influence.
    A hearing before an ALJ will remain an informal adjudicatory 
proceeding as it is under the current process. The claimant will have 
the right to be represented by an attorney or a non-attorney with the 
decision regarding representation made by the claimant alone. An 
informal, nonadversarial proceeding is consistent with the public's 
strong preference for a simple, accessible hearing process that 
permits, but does not require, a representative. An informal process 
facilitates the earlier and faster resolution of the issues in dispute, 
thus promoting more timely decisions.
    As an independent factfinder in a nonadversarial proceeding, the 
ALJ will still have a role in protecting both SSA interests and the 
claimants interests, particularly when the claimant is unrepresented. 
However, an improved initial determination process with its focus on 
early and comprehensive evidentiary development, predecision notices 
and opportunity for personal interviews, fully rationalized initial 
decisions, and prehearing analysis of contested issues should ensure 
that the Agency position is fully explored and presented to the ALJ. 
Moreover, the primary burden of compiling an evidentiary record will be 
shifted to the representative--if one is appointed--or to the claimant 
(when able to do so), with assistance (when necessary) from SSA 
personnel. This will permit the ALJ, in most circumstances, to close 
the record at the conclusion of the oral hearing, deliberate on the 
issues, and render prompt decisions.
    In making disability decisions, ALJs will rely on the same 
standards for decisionmaking that are used by the disability claim 
managers and adjudication officers. Adjudication officers and other 
decision writers will assist ALJs in preparing hearing decisions, using 
the same decision support system that supports the preparation of 
initial disability determinations. A simplified disability decisional 
methodology, in conjunction with the use of prehearing stipulations 
that frame the issues in dispute, will result in shorter, more focused 
hearing decisions. If the ALJ issues a favorable decision, he or she 
will refer the claim to a disability claim manager to effectuate 
payment.

Final Decision of the Secretary

    Under the new process, if a claimant is dissatisfied with the ALJ's 
decision, the claimant's next level of appeal will be to Federal 
district court. A claimant's request for Appeals Council review will no 
longer be a prerequisite to seeking judicial review.
    As under the current process, the Appeals Council will continue to 
have a role in ensuring that claims subject to judicial review have 
properly prepared records and that the Federal courts only consider 
claims where appellate review is warranted. Accordingly, the Appeals 
Council, working with Agency counsel, will evaluate all claims in which 
a civil action has been filed and decide, within a fixed time limit 
whether it wishes to defend the ALJ's decision as the final decision of 
the Secretary. If the Appeals Council reviews a claim on its own 
motion, it will seek voluntary remand from the court for the purpose of 
affirming, reversing or remanding the ALJ's decision. The Secretary's 
authority for seeking voluntary remand prior to the Secretary's filing 
of an answer to the civil action is currently provided for in 
Sec. 205(g) of the Act. Favorable Appeals Council decisions will be 
returned to the disability claim manager to effectuate payment. The 
number of civil actions requiring substantive action by the Appeals 
Council will be relatively small because, in the new process, ALJ 
decisions will be the result of a fully developed evidentiary record 
where the factual and legal issues have been focused for final 
resolution.
    Additionally, the Appeals Council will have a role in a 
comprehensive quality assurance system. As part of the in-line review 
component of this system, which is described in greater detail below, 
the Appeals Council will conduct its own motion reviews of ALJ 
decisions (both allowances and denials) and dismissals prior to 
effectuation. If the Appeals Council decides to review a claim on its 
own motion, the Appeals Council may affirm, reverse or remand the ALJ's 
decision, or vacate the dismissal. The Appeals Council's review will be 
limited to the record that was before the ALJ.
    The Agency will establish appropriate mechanisms to respond to 
claimant allegations of ALJ misconduct or bias. To the extent that the 
allegations of ALJ misconduct may affect the final decision in a claim, 
the Agency will consider whether an appropriate mechanism includes some 
form of final Agency review at the claimant's request.

Quality Assurance

System of Agency Accountability

    SSA will be accountable to the public, the ultimate judge of the 
quality of SSA service, and will strive to consistently meet or exceed 
the public's expectations. SSA will have a comprehensive quality 
assurance program that defines its quality standards, continually 
communicates them to employees in a clear and consistent manner, and 
provides employees with the means to achieve them.
    The quality assurance program will have three primary components: 
1) substantial resources to ensure that the right decision is made the 
first time; 2) comprehensive and systematic reviews of the quality of 
the decisionmaking process at all levels; and 3) measures of customer 
satisfaction against the SSA standards for service.

Investment in Employees

    SSA's ability to ensure that the right decision is made the first 
time depends on a well-trained, skilled, and highly motivated workforce 
that has the program tools and technological support to issue quality 
decisions.
    SSA will make an investment in comprehensive employee training to 
ensure that all employees have the necessary knowledge and skills to 
perform the duties of their positions. SSA will develop national 
training programs for initial job training and orientation as well as 
continuing education to maintain job knowledge and skills. Such 
training will include general communication skills and how to deal 
effectively with the public generally, and disability claimants in 
particular. National training programs will also address changes to 
program policy. Consistent program policy training will be provided to 
disability decisionmakers at all levels of the process.
    In addition to initial program training, continuing education 
opportunities will be made available to employees to enhance current 
performance or career development. These opportunities may be in the 
form of self-help instruction packages, videotapes, satellite 
broadcasts, or non-SSA training or educational opportunities. SSA will 
ensure that employees are given sufficient time and opportunity to 
complete the required continuing education. Employee feedback on the 
value of these continuing education opportunities, including the 
quality of training materials, methods, and instructors, will be used 
to continually improve training programs.
    In addition to formal program training, SSA will rely on a targeted 
system of in-line quality reviews and monitoring of adjudicative 
practices for all employees. The elements include a mentoring process 
for new employees, peer review for experienced employees and management 
oversight at key points in the adjudicative process. SSA will create 
mechanisms that facilitate peer discussions of difficult claims or 
issues. Quality reviewers and policy makers will participate in these 
types of discussions. Peer reviews and mentoring will not only promote 
timely and accurate development of disability claims, but will also 
foster a spirit of teamwork. They will also promote earlier 
identification and resolution of problems with policy or procedures. 
Managers will be expected to oversee the adjudication process. They 
will conduct spot checks at key points in the adjudication process or 
perform special reviews based on profiles of error-prone claims. The 
goal of these reviews is to provide immediate, constructive feedback on 
identified errors to reduce or eliminate their possible recurrence. 
Payment errors on claims detected during in-line reviews will be 
corrected before a claimant is notified of the decision.
    As noted previously, under the Administrative Procedure Act, the 
ALJ is an independent decisionmaker who must apply an agency's 
governing statute, regulations and policies, but who is not subject to 
advance direction and control by the agency with respect to the 
decisional outcome in any individual claim. Accordingly, a system of 
peer review, mentoring and management oversight in advance of the ALJ's 
decisionmaking is inappropriate. However, the ALJ decision may be 
subject to final agency review. Therefore, as part of the in-line 
quality assurance process, ALJ decisions (both allowances and denials) 
and dismissals will be subject to review by the Appeals Council on its 
own motion prior to effectuation of the ALJ's decision or dismissal.
    Several key features previously described in this plan are critical 
to ensuring that adjudicators have the necessary program tools to issue 
accurate decisions. A single presentation of all substantive policies 
used in determining eligibility for benefits must be in place. 
Additionally, an automated and integrated claim processing system will 
provide the necessary technological support for adjudicators at all 
levels of the administrative process. Expert systems will be developed 
to integrate disability policy into the claim processing system. Among 
other things, the claim processing system will facilitate claims 
taking, evidence development, and the preparation of accurate notices 
and decisions by providing on-line editing capacity to identify errors 
in advance and decision support software to assist in analysis and 
decisionmaking. The processing system will help to identify errors of 
both procedure and substance, and also support routine analysis to aid 
in avoiding future similar errors. An on-line technical review will 
occur each time information is added to the electronic record.
    Comprehensive employee education and an in-line review system will 
build quality into the system of adjudication with the goal of error 
prevention. SSA must monitor that quality on a systematic, national 
basis. Accordingly, all employees (including ALJs) will be subject to 
and receive continuous feedback from comprehensive end-of-line reviews 
as described in the following section.

End-of-Line Reviews

    A second necessary component of quality assurance is an integrated 
system of national postadjudicative monitoring to ensure the integrity 
of the administrative process and to promote national uniformity in the 
adjudication of disability claims at all levels of the process. This 
system of quality measurement will include comprehensive reviews of the 
whole adjudicatory process. At a minimum, a comprehensive end-of-line 
quality measurement system must: be statistically valid; review both 
allowances and denials in equal proportion; review the entire 
disability claim process, both the medical and nonmedical aspects; and 
review claims decided at all levels of the adjudicatory process.
    These end-of-line reviews will focus on whether correct decisions 
were made at the earliest possible point in the process. This type of 
review will not be aimed at correcting errors in individual claims but, 
rather, will be the means to oversee, monitor and provide feedback on 
the application of Agency policies at all levels of decisionmaking. 
However, erroneous decisions detected during end-of-line reviews will 
be subject to existing reopening regulations. Reliance on an integrated 
claim processing system will facilitate the selection of a 
statistically valid sample of claims at all levels of the process for 
this review.
    An integrated claim processing system will permit the selection of 
other postadjudicative samples of claims as SSA deems necessary to 
effectively test new operational procedures or monitor specific 
procedures in the administrative process; oversee the implementation of 
new program policy regulations and initiatives; and monitor both 
internal and external claims development practices to prevent fraud.
    SSA will use the results from these end-of-line reviews to identify 
areas for improvement in policies, processes or employee education and 
training. SSA will also use the results to profile error-prone claims 
with the goal of preventing errors at the front end.

Customer Satisfaction Surveys

    A final component of quality assurance is measuring customer 
satisfaction. To measure whether SSA has met or exceeded the public's 
service expectations, SSA must measure the public's level of 
satisfaction with the level of service SSA provides. Customer surveys 
(including feedback cards) and periodic focus groups will be the most 
frequently used methods of determining the public's views on the 
quality of SSA service. SSA will also survey representatives and third 
parties who provide assistance or act on claimants' behalf in dealing 
with SSA. Survey results will be communicated to staff on a timely 
basis, both as Agency feedback and individual feedback, along with any 
plans to address identified problems.
    SSA will also seek employee feedback on how well SSA has met their 
expectations. Employee feedback will be sought on a wide array of 
issues including Agency goals and performance indicators, training and 
mentoring needs, and the quality of operating instructions. Although 
formal mechanisms will be used to obtain feedback periodically, each 
employee will be encouraged to provide continuous feedback on how to 
make improvements in the process.

Measurements and Management Information

Service Perspective

    SSA's measures of performances will be revised to assess the 
performance of the Agency as a whole in providing service to claimants 
for disability benefits. Management information regarding the 
contributions at each step in the process to the final product, as well 
as to the work product passed on to other steps will be available. For 
example, current component processing time measures will be replaced by 
a measure of time from the first point of contact with SSA until final 
claimant notification. Meaningful, timely management information will 
be facilitated by a seamless claim processing system with a common 
database that is used by all individuals who contribute to each step in 
the process.
    Other measures, such as cost, productivity, pending workload, and 
accuracy will be developed or revised to assess the performance of the 
Agency as a whole and the participants in the process who contribute to 
this performance. Measurements for public awareness, as well as 
claimant and employee satisfaction, will add to this assessment.
    Management information will be current and accessible from an 
intelligent workstation. In addition to routine, published national 
reports generated from the management information system, other reports 
needed by national or local entities, or individual employees will be 
preformatted and system-generated on demand. Managers and employees 
will have the flexibility to change parameters and to access the full 
data base, permitting comparisons of performance and trends analysis. 
The management information system will also permit customized, ad hoc 
reports for special studies or immediate special purpose activities 
with access to the full data base. Tools including user-friendly report 
generator software and statistical forecasting and modeling 
applications will be available on the intelligent workstation to assist 
users in the data analysis.

New Process Enablers

    Reengineering is dependent on a number of key factors that provide 
the framework for the new process design. Each of these ``enablers'' is 
an essential element in the new disability process.

Process Unification

    Under the Social Security Act, the Secretary is granted broad 
authority to promulgate regulations to govern the disability 
determination process. In addition to regulations, SSA publishes: 1) 
Social Security Rulings, which are precedential court decisions and 
policy statements or interpretations that SSA has adopted as binding 
policy, and 2) Acquiescence Rulings, which explain how a decision by a 
U.S. Court of Appeals will be applied when the court's holding is at 
variance with the Agency's interpretation of a provision of the statute 
or regulations. ALJs and the Appeals Council rely on the regulations 
and rulings in making disability decisions. However, guidance for 
decisionmakers at the initial and reconsideration levels is provided in 
a series of administrative publications, including: 1) the Program 
Operations Manual System instructions which provide the substance of 
the statute, regulations, and rulings in a structured format and 2) 
other administrative issuances which clarify or elaborate specific 
policy issues. The use of different source documents by adjudicators 
fosters the perception that different policy standards are being 
applied at different levels of decisionmaking in the disability claim 
process.
    To ensure that SSA provides consistent direction to all 
adjudicators regarding the standards for decisionmaking, SSA will 
develop a single presentation of all substantive policies used in the 
determination of eligibility for benefits. These policies will be 
published in accordance with the Administrative Procedures Act and all 
decisionmakers will be bound by these same policies.

Public and Professional Education

    Public and professional education is essential to ensure that 
individuals and other groups involved in the disability process have a 
proper understanding of SSA disability programs, their medical and 
nonmedical requirements, and the nature of the decisionmaking process.
    SSA will make information widely available for the general 
population with the goal of reducing general inquiries from members of 
the public unfamiliar with SSA disability programs and increasing the 
number of claimants who enter the disability process knowledgeable and 
prepared to assume responsibility for pursuing their claims. Pamphlets, 
factsheets, posters, videos, information on diskettes and on computer 
bulletin board systems will be developed and presented in a simple, 
straightforward and understandable manner. Information will be 
available in many languages and dialects and will accommodate vision 
and hearing impaired individuals.
    SSA will work with national and local groups involved in the 
disability programs to develop direct lines of communications. These 
efforts will be aimed not only at providing information but also at 
creating ongoing organizational relationships to maintain a dialogue 
about the disability process.
    SSA will also conduct educational outreach with the medical 
community to provide them with a better understanding of the SSA 
disability programs, the medical and functional requirements for 
eligibility, and the best ways to provide medical information needed 
for decisionmaking. In addition to the use of printed materials, SSA 
will arrange briefings and training sessions in association with 
medical organizations and societies at the local, State and national 
levels, as well as through hospital staff meetings. Those medical 
providers who conduct consultative examinations for SSA will need 
ongoing training regarding changes in the disability program. SSA will 
prepare training programs for this audience which will utilize written, 
audiotape, videotape, and computerized training methods.
    SSA will conduct outreach efforts with the legal community, to 
ensure that information about the disability programs is widely 
available to the organized bar and the Federal judiciary. Policy 
documents, regularly updated electronically, and rules of 
representation will be available at forums sponsored by the organized 
bar and in initial orientation and continuing legal education programs 
designed for Federal judges.

Claimant Partnership

    SSA's interaction with claimants will focus on enabling their 
participation in the process. SSA will also work with third parties, 
such as family members and community-based organizations, to provide 
additional claimant support.
    Understandable public information materials and comprehensive 
information packets will be widely available. Explanations of the 
programs, the decisionmaking process, and claimant responsibilities 
will be widely available and furnished at the point individuals first 
make contact with SSA. Claimants, who are able to do so, will be asked 
to do more to facilitate development of supporting information, 
particularly with respect to medical evidence. To encourage the release 
of evidence by treating medical sources, SSA will network with the 
treating source community to overcome the lack of understanding and 
possible resistance to providing patient information. SSA will 
encourage private insurers and public agencies that refer claimants to 
SSA as a condition of receiving other benefits to provide medical 
evidence for these individuals.
    SSA will develop ongoing relationships with community organizations 
to ensure that competent third-party resources are available to assist 
the claimants. Examples of resources that SSA will help develop 
include: transportation and escort services for indigent claimants and 
those who experience difficulty in getting to consultative 
examinations; enhancement of medical provider capacity to identify 
potentially eligible patients, secure claims and provide medical 
evidence; and software with compatible format design which will allow 
direct input of claim-related information to SSA. SSA will have an 
ongoing demonstration program that provides funds for truly innovative 
projects that test models for national implementation.
    In order to expedite the referral of potentially eligible 
individuals, SSA will develop productive working relationships with 
Federal, State and local programs that serve individuals with 
disabilities. Other programs will be able to use SSA-developed 
decisional support systems to evaluate potentially eligible persons 
prior to referral and to transfer information to SSA through compatible 
databases. Local managers will be encouraged to develop and maintain 
appropriate working relationships with local Federal, State and third-
party resources.
    Active participation by claimants, supported by SSA's efforts and 
the contributions of third parties will result in a fundamental shift 
in claimant expectations and satisfaction with the SSA disability 
process. From the SSA perspective, the results will be better service 
to customers through timely, fully supported decisions rendered at all 
decisional levels; better use of SSA resources focused on helping those 
who need assistance; and greater public confidence in the disability 
adjudication process.

Workforce Maximization

    Teamwork and workforce empowerment are fundamental ingredients in 
the new process. In carrying out their duties and responsibilities, 
adjudicators will work in a team environment with internal medical and 
nonmedical experts, who provide advice and assistance for complex case 
adjudication, as well as with technical and other clerical personnel 
who may handle more routine aspects of case development and payment 
effectuation. The disability claim manager will be the focal point at 
the initial claim level, assisted by technical and medical support 
staff. The adjudication officer will be the focal point at the 
prehearing level, relying on technical and medical support staff, as 
well as interacting with the disability claim manager and the ALJ, as 
necessary. The ALJ will be the focal point at the hearing level, 
receiving support from technical and medical support staff, and also 
interacting with the adjudication officer and disability claim manager, 
as necessary.
    Each team member will have at least a basic familiarity with all 
the steps in the process and an understanding of how he/she complements 
another's efforts. Team members will be knowledgeable but will also be 
able to draw upon each other's expertise on complex issues. 
Communication among team members will encourage consistent application 
of disability policy. Improved automated systems will enable members of 
the team to work together using a shared data base even when they are 
not co-located. Handoffs, rework, and non-value steps will be 
significantly reduced and fewer employees will be involved in 
shepherding each claim through the process.
    Employees will perform multiple tasks instead of singular 
activities, thus their roles will expand to encompass more of the 
``whole'' job. This will enable employees to experience the direct 
relationship between their actions and the final product. Adequate 
resources and sufficient training and mentoring will allow employees to 
acquire the skills they need to process claims from intake through 
adjudication. Employees will feel more of a sense of ownership for the 
services they perform as a member of a team focused on serving 
claimants.
    The new process will rely heavily on increased employee 
empowerment, applying information technology and using professional 
judgment to complete tasks more effectively and efficiently without 
constant checking, direction and micro-management. Recognition and 
reward processes will be revised to emphasize contributions to team 
outcomes and acquisition of knowledge bases. Continuous quality 
improvement activities will foster ongoing incremental process change.

Representatives: New Rules and Standards of Conduct

    The Social Security Act and regulations have long recognized the 
representational rights of claimants and have provided an 
administrative framework designed to ensure that claimants will have 
access to the legal community and others in the pursuit of their 
claims. Representatives currently have the option for authorization of 
fees through two procedures: 1) the fee petition method, whereby the 
representative presents an itemization of services rendered and time 
expended, and SSA determines a reasonable fee; and 2) the fee agreement 
method, whereby the claimant and representative agree to a fee of 25 
percent of the retroactive benefits due or $4,000, whichever is less.
    Focus groups of claimants and the general public have indicated 
that the disability program is too complex to understand and the 
process too fragmented and difficult for them to navigate alone. While 
many claimants resent having to pay a representative to establish 
entitlement to government-sponsored benefits, they feel that they have 
no choice if they want to be successful in this pursuit. Although the 
current regulations provide protection for claimants from fee abuses, 
these rules fall short of assuring claimants that the representatives 
they retain are qualified and will adequately represent their 
interests.
    In the new process, SSA will continue to have a responsibility for 
monitoring representational activity and for safeguarding the interests 
of claimants. The new process will establish rules of representation 
and standards of conduct to ensure that representatives fulfill their 
responsibilities and serve the needs of the claimants they represent. 
These new rules will, among other things, ensure that claimants receive 
competent representation; establish a code of professional conduct for 
representatives in all matters before SSA; and provide sanctions 
against representatives, including suspension and disqualification from 
appearing before the Agency in a representative capacity, for violating 
the rules of representation and standards of conduct. Without 
disturbing the statutory intent of facilitating claimant access to 
representatives, the simplified and user-friendly new process may well 
result in more claimants pursuing their claims without representation. 
However, the issue of representation will remain a matter of a 
claimant's personal choice. The new rules and standards of conduct 
provide the framework for assuring that representatives claimants 
retain will be qualified, will have the obligation to fully develop the 
record on their behalf, will adequately represent their interests, and 
will be accountable for misconduct or dereliction of duty.
    SSA will also conduct outreach efforts with the legal community, to 
ensure that information about the disability programs is widely 
available to the organized bar and the Federal judiciary. Policy 
documents, regularly updated electronically, and rules of 
representation will be available at forums sponsored by the organized 
bar and in initial orientation and continuing legal education programs 
designed for Federal judges.

Information Technology

    Information technology will be a vital element in the new 
disability claim process. To the fullest extent possible, SSA will take 
advantage of the ``Information Highway'' and those technological 
advances that can improve the disability process and help provide 
world-class service. The new process will rely on seamless, electronic 
processing of disability claims from the first contact with the 
claimant to the final decision, including all levels of administrative 
appeal. Existing Agency design plans for Intelligent Workstation/Local 
Area Network (IWS/LAN) and a Modernized Disability System will provide 
an integrated system and the electronic connectivity necessary to 
support the new disability process.
    In a seamless electronic environment, all employees will use the 
same hardware, the same claim assignment and scheduling software, the 
same decision support software, the same case control system, the same 
fiscal and accounting software, the same integrated quality assurance 
functionality, and the same management information system throughout 
all stages of the process. In this environment, data will need to be 
input and validated once and multiple employees may access a single 
claim record simultaneously.
    Information technology will be applied to enhance access to 
services by claimants, their representatives, and other third parties. 
Claimants will be able to conduct business with SSA via telephone, 
self-help workstations, kiosks, videoconferencing, and electronic data 
transfer at SSA facilities and other satellite locations. SSA will 
conduct forums and produce video and computer-based training materials 
for third parties who wish to participate in assisting claimants to 
file applications and gather medical evidence. Wherever possible, 
physicians and health care organizations, advocates, community 
counseling services, and other professionals who regularly provide 
assistance to SSA claimants will be supplied with SSA software to 
electronically complete Agency forms. Data will be transferred to SSA 
using agreed upon methods. SSA will allow authorized representatives 
appropriate access to electronic claim folders. Paper versions of 
treating source forms will be designed so that the data can be read by 
scanning equipment into SSA claim processing systems. A single vendor 
payment system will be used to pay certain evidence providers for 
information which they provide SSA. To further paperless processing, 
SSA will adopt a ``signature on file'' policy for the claimant's 
evidence release authorization to eliminate routing of paper medical 
release forms.
    The ability of decisionmakers to conduct thorough interviews and 
evidence evaluation, and timely and accurate claim adjudication is 
predicated on the implementation of the functionality provided by the 
IWS/LAN hardware and software components, and the decision support 
features of the Modernized Disability System. Expert system software 
will be included in SSA claim processing systems to assist disability 
decisionmakers in the analysis and evaluation of complex eligibility 
factors, and to ensure that the correct procedures for disability 
evaluation are followed. While conducting interviews, disability 
decisionmakers will rely on decision support features that ask 
impairment-specific questions. The decision support system will use the 
accumulated data of the electronic record to assist in the preparation 
of the predecision notice, the statement of the claim, and decisions 
rendered on appeal. Where disability decision team members cannot be 
physically co-located, they can remain in communication by using two-
way TV and other videoconferencing technologies. Disability policy will 
be developed and stored in a format that can be integrated into 
computer systems as the source of context-sensitive help screens and 
decision-support messages.
    Quality assurance features fully supported by the Modernized 
Disability System will be integrated throughout the new process. For 
example, the national end-of-line quality review sample will be 
electronically selected and automatically routed to appropriate staff. 
In-line programmatic quality assurance, enhanced by the use of decision 
support systems, will be programmed into the computer applications and 
will help to identify errors of both oversight and substance, and also 
support routine analysis to aid in avoiding future similar errors. An 
on-line technical review will occur each time information is added to 
the electronic record.
    Quality assurance and productivity measures will be incorporated in 
a new, total-process management information system. Meaningful, timely 
management information for the disability process is dependent on a 
seamless data processing system used by all components which affords a 
common case control system and a common data base. SSA's claim 
processing systems integrated on an Agency-wide IWS/LAN platform will 
provide this seamless environment.

Cost and Benefits

Introduction

    SSA's strategy of coming to closure on an ideal, high-level 
disability process design before undertaking detailed operational and 
implementation planning has been consistent from the beginning of the 
reengineering project. Although this project management approach served 
SSA well, it has made the very necessary task of cost/benefit 
projections unusually challenging. The following cost/benefit forecasts 
will need to evolve as implementation details are developed. The 
administrative cost numbers presented here cannot be applied to SSA's 
administrative budget without further analysis.
    SSA will move forward on all aspects of the process redesign plan; 
however, because of the extensive research and development required for 
implementation of the simplified disability determination methodology, 
we have not considered the effect of this redesign feature in our cost/
benefit planning. In addition, because the ability of a single employee 
to master the disability claim manager position is dependent on full 
adoption of a simplified disability determination methodology, the 
impact from that process redesign feature has also been separated out 
from our cost/benefit planning at this time.

Service Improvements

    Service to the public, as defined by average processing time, would 
improve dramatically--from around 150 days to pay an initial disability 
claim today to 60 days after implementation of the new process. Hearing 
processing time would also improve from about 550 days to 225 days. 
These figures were derived from running a computer simulation model of 
the new process.

Program Costs

    Under the supposition that SSA's current initial claim and 
administrative appeal process leads to correct disability 
determinations within the proper universe of people today, and because 
SSA is not proposing any changes in the statutory definition of 
disability, the redesigned process in and of itself would have no long-
term effect on program outlays.

Administrative Costs and Savings

    The project life period for implementing disability reengineering 
is from October 1, 1994 to September 30, 2000. However, the full 
benefits from the redesigned process will not be realized until 
September 30, 2001.
    Cumulative administrative costs during the life of the project are 
estimated at $148 million. The largest percentage of these costs will 
be directed to special workforce training on the new process--a 
critical enabler if the redesign plan is to work. The redesign will not 
require additional investments in information technology spending over 
current SSA plans.
    Cumulative administrative savings through FY 2001 are estimated at 
$852 million. The bulk of these savings will come from more efficient 
use of Federal and State workyears to process the anticipated 
disability initial claim and appeal workloads during the project life 
period. This savings estimate does not factor in Agency resource needs 
for working existing backlogged disability cases.
    Subtracting cumulative administrative costs of $148 million from 
cumulative savings of $852 million will result in a pay back to the 
government of $704 million through FY 2001.
    Ongoing administrative cost savings will be over $305 million 
annually, beginning in FY 2001. This figure includes spending increases 
for enhanced employee education, better office security, and expanded 
claimant services.
    The administrative cost savings associated with this project--$704 
million during the implementation period, and $305 million annually, 
thereafter--will allow the Agency to reallocate existing resources to 
give more attention to other important workloads.
    SSA's workforce profile, with respect to disability process 
workloads, would include at least the same number of professional 
positions currently employed at the federal and state level. However, 
the overall design, if fully implemented with all the process 
enablers--especially enhanced automation--would require fewer clerical 
and support positions to handle projected workloads.

Conclusion

    SSA is committed to implementing a new disability determination 
process that will deliver significantly improved service to the public, 
remain neutral with respect to program dollar outlays, and will be more 
efficient to administer.
    Administrative cost savings from the process will allow the Agency 
to reallocate resources to give increased attention to other important 
workloads.
    However, the redesigned process cannot be implemented without the 
full funding, development, and installation of a new case processing 
computer system. In addition, unless SSA invests substantially more 
funds for research and development of the simplified disability 
determination methodology, the full benefits of the redesigned 
process--including better public service and the potential for even 
greater long-term administrative efficiencies--will not be possible.

Implementation Strategy

Overview

    The disability process redesign is a high-level process description 
that provides a broad vision of how a new process would work but leaves 
operational, organizational, and other details for later development 
and implementation. SSA must now begin to transition from the high-
level analysis into this latter phase. As SSA implements the new 
process, the five objectives of the redesign effort must continually be 
kept in the forefront of implementation planning, execution and 
assessment: the process will be user-friendly for claimants and those 
who assist them; the right decision will be made the first time; 
decisions will be made and effectuated quickly; the process will be 
efficient; and the new process will provide employees with a satisfying 
work environment. The success of the new process must be measured 
against these objectives and emphasis must continually be on overall 
measurement from the customer's perspective, and not individual 
component results. Implementing a process of the magnitude of the new 
disability claim process will require a strategy that is comprehensive, 
creative, and inclusive. The following provides a general framework for 
how implementation activity will proceed.

Implementation Framework

    Planning for the implementation of the new process vision requires 
a comprehensive approach that moves forward on multiple fronts 
simultaneously. Although the new process will not be fully implemented 
until FY 2001, SSA must start on October 1, 1994 (the beginning of FY 
1995), to initiate activities, changes and improvements that will 
establish the plan and pace for the long-term full implementation of 
the new process. The goal is to make near-term, visible improvements 
while at the same time building for long-term results.

Multiple Track Approach

    Immediate or near-term implementation activities are those that can 
begin in FY 1995 and will be fully implemented nationwide by the end of 
FY 1996, or for which the research and development or site testing can 
be initiated within the next two fiscal years. These activities include 
streamlining and simplification initiatives or other procedural 
elements of the new process that can be implemented using existing 
administrative or regulatory discretion. They also include client-
service activities associated with improving the claimant's access and 
entry into the disability claim process; the development and site 
testing of options for streamlining parts of the administrative appeals 
process; the provision of consistent training and direction to 
disability decisionmakers; and the establishment of new measures and 
the testing of new quality assurance mechanisms. Additionally, because 
the decision methodology associated with the new process depends on 
significant amounts of research, consultation, development and 
refinement, SSA must identify the specific research needs, develop the 
appropriate scope of work and award research contracts as near-term 
activities.
    Long-range implementation items are those requiring extensive 
research and development that could not be tested fully before FY 1999 
or could not be fully implemented nationwide before FY 2001. These 
activities are those associated with the full development, testing and 
refinement of a new decision methodology. They also include the 
implementation of advanced technology enhancements that provide a 
single, fully-integrated disability claim processing system which 
supports paperless claim processing and provides interactive 
capabilities for claimants and those who assist them, and for providers 
of evidentiary information.
    The remaining mid-term items or activities are those elements of 
the new process that can be developed and tested in FYs 1997 and 1998 
and/or fully implemented nationwide by FY 1998. Mid-term activities 
would include such items as the phased testing and implementation of 
new service options; full development, testing and implementation of a 
streamlined appeals process; the testing of more advanced technology 
enhancements; and the activities associated with developing the 
decision methodology based on the results of research efforts completed 
by the end of the near term.

Flexibility and Testing

    SSA recognizes that full implementation of the new process vision 
is an iterative process that requires development, testing, additional 
information gathering and possible modification of process changes as 
they are implemented. Although SSA is committed to moving forward 
quickly to begin implementing the new process, SSA has embraced an 
equally strong commitment to rigorous testing and refinement of process 
changes before they are fully or permanently implemented. Testing may 
include, but is not limited to, geographic or time-limited site 
testing, using ``laboratory'' settings, or relying on specific case 
studies. Formalized testing is most appropriate for process changes 
that depend on longer-term research and development, phased 
implementation or major organizational change. In selecting sites for 
initial implementation activity, SSA will take advantage of the 
interest and capability of different offices, states, or regions to 
demonstrate the viability of immediate improvements or identify early 
successes in improved service or efficiency. Implementation sites will, 
of course, be provided with the necessary resources to support their 
efforts.
    Even with extensive testing, the nature of public policy 
formulation, as well as sound management principles, dictate that SSA 
remain flexible in developing, refining and implementing the specific 
elements of the new process vision. Ultimately, if the results of the 
iterative process necessitate modifications to the process vision, SSA 
is prepared to make those modifications. SSA is committed to change, 
not for its own sake, but because it is necessary to meet present and 
future challenges as it strives to provide high-quality, responsive, 
world-class service to its customers.

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Employees Will Make Change Happen

    Overall leadership, control, and coordination of all implementation 
activities are vested in the Implementation Manager, who will report to 
the Commissioner and Principal Deputy Commissioner. As part of these 
responsibilities, the Implementation Manager, with the assistance of a 
support team, will establish implementation priorities, develop 
specific timelines, and provide oversight to ensure that implementation 
decisions are consistent with the new process visions and the five 
process objectives.
    Although the Implementation Manager will be the focal point for all 
implementation activities, it is the employees and organizational 
components in the SSA and DDS communities who will make the new 
disability claim process a reality. Front-line employees will be asked 
to directly participate in the development, testing and implementation 
of process changes. They will also provide feedback on the 
effectiveness of the these changes. Task management teams will be 
chartered to address specific implementation issues and their duration 
will depend on the nature of their issue. For example, task teams that 
might be expected to require a longer-term existence are those dealing 
with decision methodology or organizational readiness and change 
management. The task teams will bring together staff from the affected 
SSA and DDS components to provide the necessary guidance for actual 
implementation action by organizational components. Central office 
components, working with their Regional office counterparts, will be 
responsible for ensuring that necessary implementation actions are 
effectuated.
    SSA will rely on an internal Advisory Group, comprised of SSA 
executives and union and association leaders to provide advice and 
guidance on implementation activities and facilitate communication 
about implementation plans.

Non-SSA Experts and Interested Parties

    SSA will use an inclusive process that seeks input from a variety 
of non-SSA communities including, but not limited to, disability 
advocates, physicians, other health care and rehabilitation providers, 
and the private disability and health insurers. The goal of this 
inclusive process is to foster creative relationships with non-SSA 
experts so that SSA can have access to specialized expertise and advice 
as implementation activities progress.

Open Lines of Communication

    SSA's unprecedented effort to establish new and beneficial 
communication channels during the various phases of the disability 
claim process redesign lays the groundwork for continued communication 
during implementation. The internal and external contacts and the 
avenues of communication established during the public dialogue period 
will continue and will be an integral part of the implementation 
process. SSA will continue open lines of communication about 
implementation of the new process with individuals and organizations 
who have a stake in the disability process, including front-line 
employees, representatives from Federal and State employee unions and 
associations, other Federal agencies, the Congress, the judiciary, and 
disability advocates. SSA will use all appropriate avenues of 
communication, including written materials, telecommunications, and 
personal briefings, to ensure that necessary information about 
implementation activities is regularly and widely disseminated and to 
develop appropriate feedback channels. Additionally, SSA will explore 
new opportunities and means of communicating with both internal and 
external audiences to permit meaningful exchanges of information.

Appendix I: Methodology

Business Process Reengineering

    The Process Reengineering Program is the culmination of a rigorous 
SSA investigation of the reengineering efforts and methodologies of 
those companies, public organizations, academic institutions, and 
consulting firms with the most ``hands on'' experience in this field. 
The positive findings from this detailed review, combined with concerns 
about existing business processes within SSA and the quality of SSA 
service to the public, led management to the conclusion that a process 
reengineering effort was critical to the SSA objective of providing 
``world-class'' administration and service.
    Based largely on analysis of what has worked best in the private 
and public sectors, a customized reengineering methodology was 
developed within SSA. It uses a reengineering team approach that 
combines a strong ``customer'' focus with classic management analysis 
techniques, and computer modeling and simulation, to intensely review a 
single business process. The objective is not to make small, 
incremental improvements in the various pieces of the process, but to 
redesign it as a whole, from start to finish, so that it becomes many 
times more efficient and, in so doing, significantly improves SSA 
service to the public.
    A senior SSA manager was selected to serve as Director of the 
Process Reengineering Program. The Director leads all SSA process 
reengineering efforts, is the primary liaison with the Commissioner and 
Executive Staff, nominates topics for examination, chairs project 
steering committees, and directs a small professional staff and 
revolving group of managers/consultants.
    SSA uses special, multi-disciplinary teams of individuals to 
conduct reengineering analyses and identify the best ways to redesign 
and significantly improve processes. Teams are comprised of outstanding 
employees, all of whom are subject matter experts in operational, 
programmatic, policy, systems, administrative, and other areas relevant 
to the business process.
    Reengineering teams focus on identifying those procedural and 
policy changes to the process that will: make it more claimant and 
service oriented; greatly increase productivity and process speed; take 
advantage of opportunities offered by new technology; and improve the 
empowerment and professional enrichment of the employees who are part 
of the process. Although teams follow the same basic reengineering 
protocol, continual customization is both expected and encouraged.

Disability Process Reengineering Project

    An Executive Steering Committee was formed to meet on a regular 
basis to provide advice to the Commissioner on development of the 
disability reengineering process change proposal, and to ensure that 
support occurred at the highest levels of the Agency. The Executive 
Steering Committee established the following parameters and 
expectations for the project which are driven by targets set forth in 
the Agency Strategic Plan and based on percentages of service and/or 
productivity:

Parameters and Expectations for Reengineering the Disability 
Determination Process (9/15/93)

Definition of Process
    The ``process'' to be reengineered is the initial and 
administrative appeals system for determining an individual's 
entitlement to Social Security and Supplemental Security Income 
disability payments. It includes all actions from an individual's 
initial contact with SSA through payment effectuation or final 
administrative denial. The system for determining whether an individual 
continues to be entitled to receive disability payments is not part of 
this ``process.''
    Rationale: The process to be reengineered must be defined broadly 
to increase the opportunity for improvement. The continuing disability 
review system is not included because it is conceptually and 
practically distinct from the initial disability determination process.
Parameters
    Every aspect of the process except the statutory definition of 
disability, individual benefit amounts, the use of an administrative 
law judge as the presiding officer for administrative hearings, and 
vocational rehabilitation for beneficiaries, is within the scope of 
this reengineering effort. However, analysis and ideas for change 
should proceed and be presented on two tracks: improvements achievable 
without changes in statute or regulations and innovations that may 
require such change.
    Rationale: The timing of legislative or regulatory change is beyond 
SSA's control. Such change could not reasonably be expected to be 
implemented in less than 2 years. However, limiting the reengineering 
effort to aspects of the process not requiring change in statute or 
regulations was rejected as limiting too greatly the possibility of 
major improvement/innovation in the process. The two-track approach 
provides for both shorter term incremental improvements and longer 
term, more radical change.
Expectations
    1. Unless otherwise specified here, the recommendations for change 
should be consistent with the goals and objectives set forth in the 
Agency Strategic Plan.
    2. Recommendations for change, taken as a whole, should not cause 
changes in benefit outlays unless as a necessary result of improvements 
in service, such as more timely processing and payment of claims.
    3. Process changes should improve service and/or productivity, on a 
combined basis, by at least 25 percent by the end of FY 1997 over 
levels projected in the FY 1994 budget (it would require about an 
additional $500 million currently to realize such improvement) and 
decisional accuracy should not decrease. By FY 2000 additional actions, 
including any necessary statutory and regulatory changes, should 
provide a further 25 percent improvement.
    The Executive Steering Committee facilitated ongoing communications 
between components and the Team, and communicated the need and reason 
for reengineering the disability process. They were familiar with the 
current process problems and were kept apprised of research completed 
by the Team. In February, the Executive Steering Committee was expanded 
to include the Presidents of the American Federation of Government 
Employees, the National Federation of Federal Employees, and the 
National Treasury Employees Union locals, councils and chapters 
representing SSA employees; and the Presidents of the SSA and State 
Disability Determination Services (DDS) professional and management 
associations recognized by SSA as having an interest in disability 
issues. A list of Executive Steering Committee members appears at the 
end of this appendix.
    The 18 members of the Disability Reengineering Team, all of whom 
are SSA or State DDS employees, have varied and extensive backgrounds 
in all aspects of the disability program. A list of Team members 
appears at the end of this chapter. Team members attended a high 
quality, intensive 3-day SSA reengineering methodology training 
session, and completed extensive reading assignments on reengineering. 
Some Team members visited organizations who had reengineered their 
business processes to learn about successes as well as opportunities 
for improvement. The Team used the following methods to obtain the 
information necessary to develop a redesigned disability process.

Briefings

    Members of the Team received extensive briefings from staff in all 
SSA components that work with any aspect of the disability process 
including experts in SSA policy, quality assurance, management 
information, operational, and appellate processes. Dr. Frank S. Bloch, 
Professor of Law and Director of the Clinical Education Center at 
Vanderbilt, briefed the Team on the results of his study comparing 
disability programs and processes of the United States, Canada, and 
Western Europe. His work encompasses eligibility requirements and 
program goals, benefit award structure and short-term benefits, 
administrative organization, and procedures for claim processing and 
appeals.

Scan Visits

    The Team's conducted extensive fact-finding visits and interviews 
with members of the disability community. Team members visited 421 
locations in 33 States and conducted over 3,600 interviews. Almost 
2,900 of these involved front-line employees, managers and executives. 
The Team conducted an additional 111 interviews by telephone. The Team 
also interviewed over 750 parties external to SSA for their views. They 
also publicized surface/electronic mail addresses and fax and voice 
telephone numbers for those who were not contacted or had additional 
information to provide.
    Individuals and groups both internal and external to the process 
were interviewed for ideas about a new process. The Team solicited a 
wide spectrum of opinions about problems with the current disability 
process and directions for redesign. In addition to individuals in the 
SSA and DDS communities, the team talked to a wide variety of externals 
including physicians, health maintenance organizations and hospital 
officials, disability advocates, attorneys, professional association 
groups, Federal judges, other Federal agencies, and Congressional 
staffs.
    Prior to site visits and contacts, Team members provided 
individuals and organizations with general information about the 
reengineering effort, key research areas, and some unconventional ideas 
about the disability process so that the interviewees would have an 
opportunity to think about process issues. The Team encouraged 
interviewees to provide open and honest opinions, suggestions, and 
ideas. The interviews provided useful insights into the problems 
confronting the disability program and recommendations for solving 
these problems.

Focus Groups

    A series of 12 focus groups were held throughout the country to 
obtain input from members of our claimant population and the general 
public regarding their experiences with and expectations of the SSA 
disability process. The focus groups provided the Team valuable 
information about claimants' expectations and preferences, as well as 
concerns about the current process. The following is a list of the 
focus group sites and composition.

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Benchmarking

    ``Internal benchmarking'' refers to the identification and 
understanding of site-specific best practices that currently exist 
within the Agency and is focused on the improvement and standardization 
of internal operations. The Team completed this phase of benchmarking 
by reviewing lists of sites engaging in ``best practices'' which were 
submitted by various SSA components, and visiting or telephoning as 
many of these SSA and DDS offices as possible.
    ``External benchmarking'' is essentially the same, except the 
search for best practices and proven process innovations is expanded to 
comparable companies and organizations outside of SSA. It is focused 
outside the organization and is concerned with the relative performance 
of one specific function or process. The table below identifies the 
companies/organizations the Team used as benchmarking partners.

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Process Analysis

    The Team utilized a document prepared by the SSA Office of 
Workforce Analysis in April 1993 which outlines the ``as-is'' 
disability claim and appeal processes of SSA. The document contains a 
description of claim processing tasks performed by line-employees in 
the seven operational components that deal with the disability claim 
process. Team members also collected, reviewed, and researched an 
extensive amount of existing procedural guides, laws/regulations, 
studies conducted by internal and external components, processing time 
and quality management information, workflows, cost data, etc.

Computer Modeling

    Computer models are close representations of work processes that, 
if properly constructed, allow for better understanding, testing or 
forecasting, and study. Team members worked with modeling professionals 
in SSA to build the models used to predict the operation of a 
redesigned process. A model was built to represent both the current and 
proposed processes. The model helped the Team assess the best features 
and performance of the new disability process; to better judge the 
magnitude of change from one process to another; and to do some ``what-
if-nothing-changes'' analysis to get a feel for the impact of 
inactivity. A summary of the model assumption and results appears in 
Appendix II.

Release of Initial Team Proposal

    The product of the Team's effort was a redesign proposal that was 
presented to the Commissioner and Executive Steering Committee on March 
31, 1994. The proposal provided the Team's view of the best process 
improvement and process innovation ideas. The proposal is a high-level 
concept that provides a broad understanding of how a redesigned process 
would work but leaves operational, organizational, and other details 
for later development.
    The Team distributed the proposal as widely as possible throughout 
SSA, the State DDSs, and to interested public and private individuals 
and organizations with the goal of seeking reactions, items of concern 
and additional ideas for improvement. Copies of a shorter 25-page 
version of the Proposal were distributed to all SSA and DDS employees 
in early April 1994. Copies of the complete 132-page Proposal and 
Background Report were also distributed to each SSA DDS facility in 
sufficient numbers to make it easily available to staff. A 30-minute 
videotape containing remarks by Commissioner Chater and a presentation 
of the proposal by members of the Reengineering Team was distributed 
for use in all SSA and DDS facilities. Group feedback discussions with 
SSA and DDS employees were held in all ten regions and in SSA 
headquarters components. A survey was distributed to each SSA and DDS 
employee to assist employees in providing comments.
    The Proposal and Background Report was published in the Federal 
Register on April 15, 1994 (59 FR 18188). A 60-day comment period was 
established to invite public comment on the proposal. A public hearing 
on the proposal was held in Washington, DC on May 16, 1994. Team 
members conducted extensive briefings on the proposal with interested 
parties, including employee unions, professional association groups, 
disability advocates, the legal community, other Federal agencies, and 
Congressional staffs.
    During the comment period that ended on June 14, 1994, the Team 
received over 6,000 written responses from all interested parties. The 
Team reviewed and analyzed each comment received. A summary of the 
comments is included in Appendix III. In response to reactions received 
during the comment period, the Team made changes to the original 
proposal and submitted a revised proposal to the Commissioner and the 
Executive Steering Committee on June 30, 1994.
    After extensive consultation with the members of the Executive 
Steering Committee, SSA senior staff, representatives from employee 
unions and associations, disability advocates and others, the 
Commissioner accepted the Team's recommendations for a redesigned 
disability process.

Reengineering Design Partners

Director, SSA Process Reengineering Program
Rhoda Davis--Office of the Commissioner, Baltimore, MD
Disability Process Reengineering Team
William Anderson--Office of Disability, Baltimore, MD
Mary Ann Bennett--Office of Budget, Baltimore, MD
Bryant Chase--Office of the Deputy Commissioner for Systems, Baltimore, 
MD
Kayla Clark--Office of Hearings and Appeals, Seattle, WA
Judith Cohen--Office of Supplemental Security Income, Baltimore, MD
Judge Alfred Costanzo, Jr.--Office of Hearings and Appeals, Pittsburgh, 
PA
Kelly Croft--Office of Workforce Analysis, Baltimore, MD
Mary Fischer Doyle--Office of Hearings and Appeals, Falls Church, VA
Virginia Lighthizer--Chicago Region, Detroit Conner Branch Office, 
Detroit, MI
Rebecca Manship--Disability Determination Service, Sacramento, CA
Mary Meiss--Office of Hearings and Appeals, Philadelphia, PA
Michael Moynihan--Office of Disability and International Operations, 
Baltimore, MD
Donna Mukogawa--Office of the Regional Commissioner, Chicago, IL
William Newton, Jr.--Office of Disability and International Operations, 
Baltimore, MD
Ralph Perez--Atlanta Region, Miami South District Office, Miami, FL
Dr. Nancie Schweikert--Disability Determination Section, Nashville, TN
Ronald Sribnik--Office of Regulations, Baltimore, MD
Sharon Withers--Philadelphia Region, Welch District Office, Welch, WV
Process Reengineering Program Executive Steering Committee
Shirley Chater--Commissioner, SSA
Lawrence Thompson--Principal Deputy Commissioner, SSA
Rhoda Davis--Director, Process Reengineering Program, SSA
Dennis Brown--Moderator, Association of OHA Analysts
Bruce Bucklinger--President, OHA Managers' Association
Robert Burgess--President, National Association of Disability Examiners
Mary Chatel--President, National Council of Social Security Management 
Associations, Inc.
Herbert Collender--President, SSA/AFGE National Council of Payment 
Center Locals (Council 109)
Renato DiPentima--Deputy Commissioner for Systems, SSA John Dyer--
Deputy Commissioner for Finance, Assessment and Management, SSA
Richard Eisinger--Senior Executive Officer, SSA
George Failla--Director, Office of Information Resources Management, 
SSA
Gilbert Fisher--Assistant Deputy Commissioner for Programs, SSA
Howard Foard--Assistant Deputy Commissioner for Policy and External 
Affairs, SSA
Hilton Friend--Acting Associate Commissioner for Disability, SSA
John Gage--President, SSA/AFGE SSA Headquarters (Local 1923)
Randolph Gaines--Acting Associate General Counsel, SSA
Robert Green--SSA Regional Commissioner, Boston
Joseph Gribbin--Associate Commissioner for Program and Integrity 
Reviews, SSA
James Hill--President, National Treasury Employees Union (Chapter 224)
Arthur Johnson--Chief Spokesperson, SSA/AFGE General Committee
Charles Jones--Director, Michigan Disability Determination Services
David Knoll--President, SSA National Federation of Federal Employees 
Council of Consolidated Locals
Demos Kuchulis--President, National Association of Senior Social 
Security Attorneys
Antonia Lenane--Chief Policy Officer, SSA
Huldah Lieberman--Assistant Deputy Commissioner for Operations, SSA
Rose Lucas--President, SSA/AFGE National Council of Data Operations 
Centers (Council 221)
James Marshall--President, SSA/AFGE National Council of SSA/OHA Locals 
(Council 215)
Larry Massanari--SSA Regional Commissioner, Philadelphia
Francis O'Byrne--President, Association of Administrative Law Judges, 
Inc.
Ruth Pierce--Deputy Commissioner for Human Resources, SSA
Daniel Skoler--Associate Commissioner for Hearings and Appeals, SSA
Witold Skwierczynski--President, SSA/AFGE National Council of SSA Field 
Operations Locals (Council 220)
Earl Tucker--President, SSA/AFGE National Council of Social Security 
Regional Offices, Program Integrity Review (Council 224)
Janice Warden--Deputy Commissioner for Operations, SSA
Andrew Young--Deputy Commissioner for Programs, SSA
Additional Support from:
Dominic Fulgieri--Implementation Planning Staff, Baltimore, MD
Rosanne Hanratty--Implementation Planning Staff, Baltimore, MD
Kathleen Jones--Implementation Planning Staff, Baltimore, MD
Linda Kaboolian--Kennedy School of Government, Harvard University, 
Cambridge, MA
Miriam Kahn--Process Reengineering Staff, Baltimore, MD
Becky Klepper--Implementation Planning Staff, Baltimore, MD
Kenneth Nibali--Process Reengineering Staff, Baltimore, MD
Leonard Ross--Office of Workforce Analysis, Baltimore, MD
John Shaddix--Office of Telecommunications, Baltimore, MD
Carolyn Shearin-Jones--Implementation Planning Staff, Baltimore, MD
Sandi Sweeney--Process Reengineering Staff, Baltimore, MD
Wendy Tayback--Implementation Planning Staff, Baltimore, MD
Latesha Taylor--Process Reengineering Staff, Baltimore, MD
Linda Thibodeaux--Process Reengineering Staff, Baltimore, MD

Appendix II: Model Results

Summary Information

    The Team worked with modeling professionals in the SSA Office of 
Workforce Analysis (OWA) to build computer representations of both the 
current and the redesigned disability processes. The computer model was 
built using FORTRAN programming language. Data based on assumptions, 
task times and lapse times were input into the model. In making 
assumptions, the team relied on historical data to the extent that such 
information was available. The Team also relied on an April 1993 OWA 
study that outlines the current disability claim process, including all 
administrative appeals, and describes the tasks performed by line-
employees in the seven operational components that are involved with 
the disability claim process.
    Using a computer model allowed the Team to assess the impact of 
changing from one process to another. Although the model did not 
generate an actual visual simulation of either the current or the 
redesigned process, the model did generate comparative data about the 
relative impact of specific features and expected performance. The 
sections that follow provide key comparative information regarding 
overall processing times and employee work investment based on the 
model results.

Overall Processing Times

    Under the redesigned process, the time from a claimant's first 
contact with SSA until issuance of a final initial decision will be 
reduced from an average of 155 days (as cited in the OWA study) to less 
than 40 days. Available employees will be able to process a greater 
number of claims and devote more time to each claimant, thus providing 
more personalized service. The time from a claimant's first contact 
with SSA until issuance of a hearing decision will be reduced from an 
average of a year and a half (as cited in the OWA study) to 
approximately 5 months.

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Employee Work Investment

    The table below provides a comparison of the number of different 
employees that are likely to make some work investment in a claim at 
each decisional level in the current and redesigned processes. The 
following abbreviations were used in describing the types of employees 
involved at each level.

AAJ--Administrative Appeals Judge
AC--Appeals Council
ALJ--Administrative Law Judge
AO--Adjudication Officer
CA--Claims Authorizer
CR--Claims Representative
DCM--Disability Claim Manager
DDS--Disability Determination Service
DE--Disability Examiner
DW--Decision Writer
FO--Field Office
HAA--Hearing and Appeals Analyst
HO--Hearing Office
MC--Medical Consultant
MG--Management
OPIR--Office of Program & Integrity Reviews
PSC--Program Service Center
QA--Quality Analyst
SA--Staff Attorney
Sup--Support Staff
TA--Technical Assistant
TECH--FO Technician
TSC--Teleservice Center
TSR--TCS Representative

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Assumptions, Task Times and Lapse Times

    Listed below are key assumptions, task times and lapse times that 
the Team used to model the redesigned process. The task times are shown 
in minutes and represent the estimated time it will take an employee to 
complete the described task. For each task time entry, three task time 
numbers are shown. The middle number represents the most common task 
time, while the first and last number represent the low and high 
extremes for that task. The lapse times are shown in work days, rather 
than calendar days, and represent the number of days between actions or 
tasks.

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Appendix III: Summary of Comments on Reengineering Proposal

Overview

    During the comment period that began on April 1, 1994 and ended on 
June 14, 1994, the Team received over 6,000 written responses from SSA 
and DDS employees, employee unions, professional associations, members 
of the public, claimant representatives, physicians, State governors, 
claimant advocate groups, Federal components, and other interested 
parties. Fifty-three percent of the written responses came from SSA 
employees, 21% came from DDS employees, and 26% came from individuals 
and organizations external to the SSA/DDS community. Members of the 
Team read, analyzed, and collated every one of those 6,210 comments so 
that no idea, reaction, or nuance would be overlooked.
    For the commenters who presented written reactions to the overall 
proposal, 52% were favorable to the overall concept, 39% were 
unfavorable, and 9% were neutral. Approximately 10% of these commenters 
believed no reengineering was needed. Beyond the request for written 
comments, additional means of gauging reaction to the proposal were 
also employed: group employee feedback discussions were held in over 80 
sites across the country with almost 2,000 SSA and DDS employees 
participating; a public meeting was held in Washington, D.C.; and Team 
members conducted briefings and spoke with more than 3,000 individuals 
and organizations about the proposal during the comment period.
    There was a very mixed reaction to the proposal. Very few verbal or 
written responses were totally favorable or unfavorable toward the 
proposal--those liking it had concerns about some elements while those 
generally disliking it found portions which they believed would be 
improvements over the current process. Many commenters, regardless of 
expressing praise or concern, addressed very limited aspects of the 
proposal without providing a reaction to the overall proposal.

Profile

    The comments expressed can be categorized as follows:

--SSA received widespread praise for taking on the task of redesigning 
the disability claim process. The prevalent belief was that dramatic 
improvements are needed to provide better service and handle workloads 
more effectively. Whether fully supporting the proposal or not, most 
commenters expressed concern that the system is broken and that only 
radical redesign will solve the problems that currently exist.
--The most popular concepts were (listed from most to least frequently 
mentioned):

     Elimination of the reconsideration step;
     The disability claim manager as single Agency point of 
contact in the initial claim;
     A single presentation of substantive policies for all 
decision makers;
     Encouragement of the claimant to be a partner in the 
development of the claim;
     Elimination of the mandatory Appeals Council review step;
     Increased reliance on the use of information technology;
     Increased public awareness and education about program 
requirements;
     Evidence development tailored to claimant circumstances;
     Disability claim managers empowered with full 
decisionmaking authority; and
     The general aspects of the proposed disability 
methodology.

--The greatest concerns centered around (listed from most to least 
frequently mentioned):

     Personal safety of disability claim managers;
     Ability of one person to fulfill the disability claim 
manager role;
     Pre-denial personal interview with disability claim 
manager;
     The general aspects of the proposed disability 
methodology;
     Encouragement of the claimant to be a partner in the 
development of the claim;
     The disability claim manager as single Agency point of 
contact in the initial claim;
     Development and use of an Index of Disabling Impairments;
     Use of standardized forms to request evidence from 
treating sources;
     Reliance on treating source certification of existing 
evidence; and
     Potential bias of disability claim managers.

--Many of the responses centered around how the proposal would be 
implemented and what organizational changes would be needed to make the 
new process work.
--There were concerns about whether the proposal would meet the 
objective of not increasing or decreasing program costs with fairly 
divided opinions about whether the new disability methodology would 
allow or deny more claims than the current methodology. Reliance on 
treating sources as preferred sources of medical evidence and personal 
bias resulting from disability claim manager face-to-face meetings with 
claimants were often cited as the reason for the belief that there will 
be an overall increase in allowed claims. The new four-step evaluation 
process was cited as the most common reason for the belief that there 
will be an overall increase in denied claims.

[FR Doc. 94-22491 Filed 9-16-94; 8:45 am]
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