David Camp, NOSSCR Senior Policy Advisor & General Counsel

The Social Security disability advocacy community is small but passionate—filled with diverse perspectives and strong voices. But our power lies in unity. While we may disagree on messaging, priorities, and strategies, when we unite for a common goal, real progress is possible. Collaboration yields positive change for our profession and the claimants we serve.

As you hopefully saw in our emailed message this morning, on behalf of NOSSCR and our growing coalition, I spoke with Commissioner Bisignano yesterday and he asked me to tell you that he never intended to launch any disruptive regulatory package, as it is not on his list of priorities as Commissioner. What this means is that, for now, SSA does not plan to move forward with regulations addressing the grids, vocational rules, age criteria, or other sweeping updates to RFC determinations and steps 4 and 5 as we’ve been discussing.

While we await formal changes to the unified agenda, please understand that this is not a “win” or a “loss.” The work of SSA’s policy component in maintaining current disability regulatory policy—especially given the outdated DOT and years of payments from SSA to DOL for updated vocational surveys—won’t end. SSR 24-3p is a good example—the component parts of any regulatory package will continue to be released in all the various ways SSA guides adjudicators.

Whether combined into one “MegaReg” now or later, or gradually released through sub-regulatory updates—NOSSCR and our coalitions will work to advocate and help SSA get this right. We’ve been doing this since the DOT became obsolete decades ago, and our work continues.

On December 8, we plan to gather with others in our coalition to discuss where we go next. We will soon provide more details about this summit, including a virtual option for our members to join the conversation. We hope to leave that meeting with some exciting and positive developments that we will, of course, share with all of you. Thank you for supporting any and all of the various organizations in our community. Together we can effect meaningful change.