RE: Notice of Proposed Rulemaking on Hearings Held by Administrative Appeals Judges of the Appeals Council, 84 Fed. Reg. 70080 (December 20, 2019), Docket No. SSA-2017-0073
As Co-coordinators of New York State’s Disability Advocacy Program (DAP), Legal Services NYC and Empire Justice Center work with advocates throughout New York State who provide similar services, in particular advocates who are funded by the State of New York under the DAP grant to represent low-income claimants who have been denied disability benefits. We submit these comments on behalf of the New York DAP providers.
Overall, we do not recommend that SSA proceed to adopt the proposed rules. The NPRM raises significant issues with respect to the Administrative Procedures Act and other due process concerns, and it fails to offer sufficient – or sometimes no—justification for the proposed changes. We agree with the comment submitted by the National Organization of Social Security Claimants’ Representatives (NOSSCR), which also recommends that SSA rescind this NPRM and consider other options.
Read full comment letter here: Joint Comment Letter – Opposition to Proposed SSA Rulemaking on Hearings Held by Administrative Appeals Judges