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Regarding SSA Call for Comments

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.

Find NOSSCR’s full comments submitted to the SSA here [PDF] or here [Word]. A brief summary of NOSSCR’s comments is below.

– 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.

    • Age is an important vocational factor because research shows that mortality, the prevalence of work-limiting impairments, and challenges with learning new tasks all increase with age. Changes to population-level life expectancy are not a good reason to raise age categories in the Grids, since living longer does not necessarily change how long individuals can work.  There are also significant disparities in life expectancy based on gender, race, income, and education.
    • Education, literacy, and prior work experience are important determinants of an individual’s ability to work and to adapt to different kinds of work.
    • Given rapid changes in workplace technology, SSA should examine whether 15 years is still an appropriate figure for determining which work is past relevant work experience. However, while changes in workplace technology, assistive devices, and the Americans with Disabilities Act have made some jobs easier for some people, this is not universal and should not be used to change the Grids.

– 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.

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