The Social Security Administration (SSA) has the ability under current mandates and regulations to test new review procedures and other potential program-wide updates to Social Security Disability (SSD) and Supplemental Security Income (SSI). The administration also has the ability to establish appropriate testing criteria for obtaining effective measurements regarding potential system-wide changes and the viability of their implementation throughout the entire disability program. Criteria includes the geographic testing regions and the time frame for testing procedural adjustments.
In June 2012, the SSA announced formally in the Federal Register (77 Fed. Reg. 35464) that it would be extending the testing period for two alternative models for disability determination. Understanding the alternative models requires one first understands the standard procedures utilized by the Disability Determination Services (DDS) in deciding eligibility for SSD and SSI benefit. The system-wide procedures are summarized as follows.
- DDS review of eligibility, in consultation with a DDS contracted physician or “medical expert”
- Reconsideration of any claim denied following the submission of additional documentation or the completion of a medical assessment with a DDS contracted physician.
- An appeal hearing with a presiding ALJ.
The two alternative models currently being tested were implemented by the SSA at different times and in different locations. Each alters the standard methods used by the DDS offices in the assessment of randomly selected applicants’ eligibility for SSD and SSI benefits.
The Single Decision-Maker Test
The first alternative model is known as the “single decision-maker test” and provides DDS staff the authority to approve or deny an applicant in most cases without seeking the input of a psychological or medical consultant. Under this test, DDS staff simply compare the medical documentation contained in an application with the SSA’s “Blue Book” definition of the disability and make a determination solely based on that comparison. This test eliminates the medical expert evaluation of substantiating documentation from the eligibility review process entirely.
The recent Federal Register announcement from the SSA communicated the single decision-maker test has been underway for some time and that the time frame for testing has been extended. The geographic regions in which the test is being conducted, the original date of the test’s implementation, and the extent or number of applications being reviewed under the testing procedures was not detailed in the notice. Instead, the SSA simply announced that it has been testing the process and will continue to do so until September 2013. At that time, if the SSA decides to extend the timeframe for testing again, another announcement will be made within the Federal Register.
The Prototype Test
The second alternative disability determination model the SSA is currently testing is known as the “prototype test”. This test was originally initiated in August of 1999 and has been extended annually since that date.
Under test procedures, a single decision-maker with the DDS determines initial eligibility under the same guidelines as those used in the single decision-maker test. The prototype test additionally eliminates the reconsideration review step entirely from the overall eligibility determination process. Applications initially denied benefits proceed directly to the appeal hearing stage instead.
The prototype test is currently being conducted in ten states: Alabama, Alaska, California, Colorado, Louisiana, Michigan, Missouri, New Hampshire, New York and Pennsylvania. The SSA’s Federal Register announcement extended the testing period in these same states through September 2013. If further extensions are required, the SSA will issue a formal entry and announcement within the Federal Register at that time.
