NOSSCR continues to actively monitor all of Social Security’s regulatory activities in the Federal Register. This month we submitted official comments on the Temporary Final Rule (TFR) allowing flexibility in the “close proximity of time” standard as it applies to the musculoskeletal Listings. Originally, all medical criteria for those Listings had to be documented within a 4-month period. Covid-era changes extended that timeframe to 12 months, and this TFR extends that extension until May 11, 2029 (though this week’s corresponding Emergency Message revision indicates that the agency may revisit this extension prior to that date).

While NOSSCR applauds this extension, we took this opportunity to once again urge the agency to make these changes permanent. As we argue below, the American healthcare system is not currently designed to provide the needed documentation within a 4-month period; thus, if the Listings revert to that standard, the agency will be missing claimants who do clearly meet the Listing-level criteria but who simply aren’t able to obtain the needed documentation fast enough.

NOSSCR also commented this month on the agency’s burden estimate regarding the time required for application submission. We continued our ongoing advocacy for electronic signature improvements. Read our comments below.