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Joint Comment – Opposition to Proposed SSA Rulemaking Regarding Continuing Disability Reviews

Emilia Sicilia January 31, 2020

RE: Notice of Proposed Rulemaking on Rules Regarding the Frequency and Notice of Continuing Disability Reviews, 84 Fed. Reg. 36588 (November 18, 2019), Docket No. SSA-2018-0026

As Co-coordinators of the Disability Advocacy Program (DAP), Empire Justice Center and Legal Services NYC 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.

We endorse the extensive and thorough comments submitted by the National Organization of Social Security Claimants Representatives (NOSSCR) and other organizations cited below who oppose these proposed regulations.

The proposed rules are published with practically no information to justify the changes, or to explain how they are to be applied. We agree with the comments submitted today from Community Legal Services (CLS) that object to the NPRM’s reliance on “SSA’s Mysterious ‘Predictive Model’” as the basis for the proposed changes to the CDR diary categories. As noted by CLS, “[t]he omission of details regarding this predictive model is glaring.” The NPRM offers no information whatsoever about it.

 

Read the full comment letter here: Joint Comment – Opposition to Proposed SSA Rulemaking Regarding Continuing Disability Reviews.

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