SSA has released an Advanced Notice of Proposed Rulemaking seeking comments about the vocational factors (age, education, and work experience) used in the adult disability determination process. Please find NOSSCR’s comments and instructions on how to submit your own below.
NOSSCR’s comments are based on longer comments that will be submitted by the Consortium for Citizens With Disabilities’ Social Security Task Force; NOSSCR staff worked with other CCD member organizations to develop those comments and NOSSCR has signed on to them as well.
NOSSCR members and others can use NOSSCR’s comments as a base for submitting comments of their own. Comments can be submitted through Monday, December 14, 2015 at http://www.regulations.gov.
– When considering changes to Social Security policy, administrative efficiency is important. However, the primary concern must be creating policies that work for claimants and beneficiaries, many of whom have limitations that make applying for disability benefits a challenge. Individualized assessments are critical.
– Any changes must be based on evidence; that evidence cannot simply look at the population as a whole but must focus on individuals with severe impairments, since they are the ones being considered at Step 5 of the sequential evaluation process.
– The Grids should not be changed.
– Although the ANPRM specifically stated that it was not looking for comments on the Dictionary of Occupational Titles, NOSSCR agrees with the need to update it.