05/28/09 Roundtable Discussion re SSA Backlog

[inquisitive]

As posted on GovernmentExecutive.com --

Recession is exacerbating Social Security claims backlog, panelists say

By Alex M. Parker [e-mail] May 28, 2009

The economic downturn, inadequate funding and red tape are at the core of an increasing backlog of Social Security disability cases, panelists said during a roundtable discussion in Washington on Thursday.

The government has tried for years to reduce the number of cases awaiting review from administrative law judges, but the recession is a significant setback, said Alan Cohen, senior budget adviser for the Senate Finance Committee.

"Initial claims are going to skyrocket in 2010," he said during the forum, organized by the Association of Administration Law Judges. "The tsunami hasn't hit the administrative law judges here."

At issue are cases where a claim has been rejected at the state level and is sent to Social Security Administration ALJs. Currently, there are about 750,000 cases pending, according to Cohen. SSA has set a goal of reducing the pile of pending cases to 466,000 by 2013 -- a step SSA Commissioner Michael Astrue has told lawmakers would decrease average processing times from 500 to 270 days.

"You just need the money to properly administer the program," said Kathryn Olson, staff director for the House Ways and Means Subcommittee on Social Security. "Too much pressure to crank out cases really does undermine the integrity of the process."

Cohen said SSA's core budget is headed for an increase of about 10 percent from fiscal 2009 to fiscal 2010, which could help tackle the expected wave of claims. SSA obtained $500 million from the economic stimulus package to address the backlog.

Patrick Augustine, an ALJ and former SSA regional chief judge in Boston and Denver, said bureaucracy is another issue. "Someone needs to convene a work task force, and needs to basically look at the piecemeal fashion of the rulings that have stacked new requirements on the system and the process, and have made it more time-consuming," he said.

He noted that a variety of missteps -- some of which he claimed were innocent or inconsequential types of mistakes -- could trigger an "automatic remand," or a referral from SSA's Appeals Council to hear the case again.

Augustine also said technology intended to speed claims processing -- such as computerized case files -- could slow things down if it wasn't working properly. "There were times my judges were mopping the halls because the computer system is down," Augustine said. Computerized files sometimes take longer to read, he added, especially if all the judge is looking for is the summary of a complex medical document.

Some panelists said SSA's plan to reduce the backlog by 2013 was forcing judges to take on too many cases.

"I am truly stunned by the suggestion that administrative law judges should review 500 to 700 cases per year," said U.S. Magistrate Judge Jillyn Schulze, referring to an expectation set by Chief Administrative Judge Frank A. Cristaudo in a 2008 letter to administrative law judges. "That is truly unconscionable."

But Augustine said while he agreed there was a limit to how much a single judge should be expected to accomplish, he also thought there should be a minimum requirement.

"It's hard for me to justify a judge that does 200 to 220 cases a year," he said.

Marilyn Zahm, an administrative law judge, suggested in a presentation that the government rethink the idea of a non-adversarial system, which leaves it up to the judges to do much of the fact-finding for the cases. She said if attorneys for the government and claimants could discuss cases before a hearing, then they would be able to avoid the hearing altogether.

[morgullord]

Judge Zahm might want to find out what the senior attorneys in her office have been doing for the last few years.

[mango]

morgullord is correct. The senior attorneys are taking care of most of what might otherwise be on the record decisions, but I agree with Zahm that SSA should rethink the non adversarial aspect of the process. As it stands, no one is looking out for the system and the interests of the American people. Yes judges are supposed to, but is it realistic? If the Gov't were represented, someone could intervene on those cases handed down by judges hearing in excess of 1000 cases per year. That is one of the really big problems with the system. If you are a claimant's rep, you know you got a good chance for a pay day if you get the right judge no matter the merrits of the case. Get the judge paying 97.5% of his cases and you get a $6,000 pay day; get another judge and maybe only a 50% chance of a payday. With odds like that, it is better than playing the loto. This is why the back log. Attorneys have no incentive to screen cases and no one is appealing those cases that are being paid that should not be.

We not only should rethink the non adversarial process, but should also rethink the review process. It should be looking at those cases issued by judges with incredibly high pay rates and hearing in excess of 1000 cases per year ( or maybe over the 700 number set by the administration). It would also be very helpful as a judge to have a published body of SSA law that could help in deciding cases. Appeals counsel decisions are not binding, published or available to anyone but those involved in that particular case. Thus there is little to guide new judges or judges encountering new or novel issues.

[Propmaster]

May 31, 2009 10:05:02 GMT -5 mango said:

morgullord is correct. The senior attorneys are taking care of most of what might otherwise be on the record decisions, but I agree with Zahm that SSA should rethink the non adversarial aspect of the process. As it stands, no one is looking out for the system and the interests of the American people. Yes judges are supposed to, but is it realistic? If the Gov't were represented, someone could intervene on those cases handed down by judges hearing in excess of 1000 cases per year. That is one of the really big problems with the system. If you are a claimant's rep, you know you got a good chance for a pay day if you get the right judge no matter the merrits of the case. Get the judge paying 97.5% of his cases and you get a $6,000 pay day; get another judge and maybe only a 50% chance of a payday. With odds like that, it is better than playing the loto. This is why the back log. Attorneys have no incentive to screen cases and no one is appealing those cases that are being paid that should not be.

We not only should rethink the non adversarial process, but should also rethink the review process. It should be looking at those cases issued by judges with incredibly high pay rates and hearing in excess of 1000 cases per year ( or maybe over the 700 number set by the administration). It would also be very helpful as a judge to have a published body of SSA law that could help in deciding cases. Appeals counsel decisions are not binding, published or available to anyone but those involved in that particular case. Thus there is little to guide new judges or judges encountering new or novel issues.

I'm afraid I respectfully dissent in part with the above.

First of all, the judge is not supposed to be "looking out for the system and the interests of the American people." Congress makes the law and sets up the system. Congress decides the definition of disability and the criteria uner which an individual is entitled to or eligible for benefits (Titles II or XVI respectively). The ALJ is supposed to adduce the facts and apply the regulations. Maintaining the integrity of the system is NOT within an individual ALJ's duties.

Obviously, I am not defending the award rates of individual judges. I believe it IS possible to do 700-1000 cases per year if you are reviewing your cases for OTRs because SAs are not getting to them. It probably is a sign of a laxity for most judges, however; but Belman reviews (targeted reviews of ALJs with certain award rates) have long been considered violations of judicial independence and are forbidden.

I would also point out that there is a minimal ability of effectuating components to submit cases for re-review, and it IS done.

The cost to represent the government in HUNDREDS of THOUSANDS of cases would be enormous. Don't forget, your theory would significantly reduce OTR decisions, leading to more and longer hearings. Most of the ALJs with 97% pay rates are not going to be dissuaded by an agency partisan anyway, which makes it a WASTE. And in unrepped cases, it would force the ALJ to be on the side of the claimant, or else the claimant will go away feeling REALLY abused by the system.

You said, "someone could intervene on those cases handed down by judges hearing in excess of 1000 cases per year." I like the theory that, by keeping production down, we will need even more ALJs, because it will give me a chance to be appointed in the massive hire of 800 more judges.

But in seriousness, what you really want is some kind of check on the ALJ. The money you are talking about spending on representing the goverment could USEFULLY be spent in bolstering the ability of the Appeals Council to review cases or, even better, funding the timely continuing disability reviews of beneficiaries. Government representation is not going to change the decision rates unless you strip an ALJ's power, which, again, requires Congress.

By the way, representatives DO screen cases. Most 97% ALJs are paying a goodly number of unrepped cases OTR. Reps are also often involved in the process long before a specific ALJ is assigned. It is far more likely that reps will avoid judges with low award rates than that they can somehow seek out ALJs with high award rates. [P.S. a 50% chance at a $6,000 payday is still good odds for the amount of time required - that equates to about $300 per hour for the average ten hour case.]

And, by the way, a "$6,000 payday" requires $24,000 in back benefits. For SSI, that's three+ years of back pay. In my area, cases are never that old. (And keep in mind that this money is from the claimant, not the government.) If you think $6,000 checks just roll in all day when you're a rep, you obviously aren't one. (Plus, the lotto doesn't require the payment of overhead for three years while you see if you're going to win).

All that being said, your overall point is well taken, and I don't dispute the point of your frustration. I think it is a symptm, though, and a not a cause of the backlog. If a judge had to do only 300 cases beore he ran out for the year because there was so much efficiency and no backlog, I am SURE almost all judges would spend more time and take more care with their decisions.

[newalj]

May 28, 2009 18:09:14 GMT -5 inquisitive said:

"There were times my judges were mopping the halls because the computer system is down," Augustine said.

Wow, I'm surprised that his judges were willing to mop the halls during their downtime. In our office we are only asked to tidy the toilet with a bowl brush after flushing. (true story)

Good luck to everyone waiting!!!! Hope you're mopping and brushing soon.

[mango]

Propmaster Said "I'm afraid I respectfully dissent in part with the above.

First of all, the judge is not supposed to be "looking out for the system and the interests of the American people." Congress makes the law and sets up the system. Congress decides the definition of disability and the criteria uner which an individual is entitled to or eligible for benefits (Titles II or XVI respectively). The ALJ is supposed to adduce the facts and apply the regulations. Maintaining the integrity of the system is NOT within an individual ALJ's duties."

I would disagree here. All judges, whether ALJs, Article III or what ever are tasked with a balancing act. They do look out for the interests of the parties. Just as the ALJ at ODAR is charged to assist the unrepresented claimant, he/she is also looking out for the interests of the people. This is found in his/her responsibility to find the facts and apply the law. In doing so, he/she IS looking out for the interests of the parties to the action and the US Government and the people of the US are the other party of interest. A judge that is not taking the time to develop the case, review the file, find the facts and apply the law is not doing his/her job.

The cost of the Gov't representation would be off set by the savings in not paying those that are not disabled and, presumably some of them returning to the work force. While some reps might be screening their cases, I certainly don't see much of it. I will spare the examples, but there are cases that come up that are clearly frivolous.

I do agree that expanding the review of those on disability at a reasonable rate and time as well as enhancing the ability and requirement of the appeals counsel to look at favorable decisions would go a long way to correct the problem of judges paying inappropriate cases.

As to timing, we are still working on 850 day old cases, so big paydays are the norm.

As to the ALJ over-achievers, in discussions with some of the new judges I met at training and some of the info on the web as well as the IG rpt, some are encouraged and are scheduling 70 hearings a month. Others are hearing well in excess of the 700 cases set as the high end goal by the CALJ. They are working in the NHC and other offices. That is an extraordinary number of cases. Those 70/month cases are not OTR, but actual hearings as the ALJs do not engage in ARPR and, I suspect, very little file review as there just is not time. There are also many offices around the nation that do not do ARPR. Cases are set for hearing and the ALJ takes an initial look just before the hearing so there is really no opportunity for OTRs.

I know it is very controversial, but those that are hearing over a 1000 cases per year and paying 97.5% may not be executing their responsibilities. If they are not doing their job, they should not be serving as ALJs. It hurts all of us.

[Propmaster]

Mango:

I agree with your final paragraph completely. Needless to say, that also goes for the ALJs hearing 50 cases a year.

You said, "The cost of the Gov't representation would be off set by the savings in not paying those that are not disabled and, presumably some of them returning to the work force."

I do not understand the savings. Why does having a government rep lead to cases not being paid? Can they veto the ALJ's decision? Are ALJs accidentally paying poor cases and this would make them pay attention? I don't see a lot of judges who are eager to listen to what other SSA employees have to say about how they should decide cases. It sounds to me like you are paying another salary to a person in every hearing with almost no change in outcome - a net loss, not to mention the longer hearings and, thus, greater backlog or more employees (each of whom has a salary, etc.).

For example, I've seen ALJs "forced" to pay a case by unexpected ME testimony, but I've never seen ME testimony torpedo a case a judge wanted to pay. I still think your real issue is getting ALJ decisions overturned, and that is not accomplished by adversarial hearings.

Speaking of which...

You said, "While some reps might be screening their cases, I certainly don't see much of it. I will spare the examples, but there are cases that come up that are clearly frivolous."

I have no doubt that there is a subset of attorneys that enter into SSA cases, either because they do very few or because they are just sloppy, and then wait to see what happens without evaluating the case. However, most specialty practitioners screen their cases at some point prior to the hearing. Nevertheless, I think this is again tangential to your actual point.

You initially raised this issue with the idea that attorneys were putting forward frivolous (or at least meritless) claims, which put a burden on the system. I disagree. The meritless claims are coming. You see them all the time in unrepped cases, too. I find it hard to believe that you consider there to be a notable number of people turned down at reconsideration who would not have apealed except that an attorney/rep found them and helped/told them to appeal. If you have a meritless claim, it is MORE efficient IMHO to have an attorney. Unless your opinion is that ALJs don't have to develop the record (they do in my Circuit), a lot more time and money is spent by ODAR and DDS developing unrepped cases than is spent in repped ones. It is certainly easier to make an unfavorable decision stick when a claimant is represented.

On the other hand, I think characterizing a vast number of cases as "frivolous" is a bit . . . cynical? Each case is a person. That person believes (possibly wrongly) that they are entitled or eligible for benefits. Maybe they're grasping at straws and don't really expect to win. But they expect to have their case thoroughly reviewed. I agree that ALJs that are not ensuring complete review of a case are not doing their job. I don't think that blame can be shifted to claimants or their attorneys. If cases are getting paid, an advocate should help their clients get paid. Again, I consider these symptoms, not causes.

And finally, you said "the US Government and the people of the US are the other party of interest." I still disagree with this.

This is a non-adversarial system. Not just because there is no government rep, but because it is an informal, inquisitional system. When the government takes any action, the "interests" of the US and the People are contained in the rules that are (or should be) followed. When someone applies for a gun permit, should the government have a rep to protect the people's interest in avoiding misuse of the weapon? When the government allows import of trade goods, should a government rep also be arguing against letting the goods in, in order to protect domestic manufacturers? When I take the driving test for a license, should a government rep be in the car to argue to the test examiner that I should be prohibited from driving in the interest of public safety? Or should we trust the rules put in place to authorize the individuals concerned to carry out these tasks?

This (SSA law) is a statute and a body of regulations that defines who is eligible for benefits. A person who meets that sandard can get the benefits. There is no balancing test over whether this person is worthy in the eyes of the public. There is no ALJ function to determine whether this particular person merits a payout from the trust fund. The ALJ function is to apply the regulatory and statutory definition of disability to an individual before them. The People of the United States are not in the hearing room and have no place in the ALJ's head. That's not unbiased decision-making.

If someone wants to represent the People, they do it by making or changing policy or regulations, or by lobbying (or joining) Congress. Each claimant deserves unifrom application of the laws. When judges can't or won't do that, they are failing, no matter what their pay or denial rates are. When judges do do that, even if the decisions seem "wrong," they are doing their jobs.

[counselor95]

The Agency is moving right along with one of its proposals to deal with the backlog. The proposed regulation that the Agency set the time and place of hearing has moved into a final phase, apparently, and is on track to become a reg next month (per the Unified agenda of SSA regs which was made available yesterday). The current reg states that the ALJ shall set the time and place of hearing; the ALJ does so when the ALJ considers the case is fully developed and ready for a hearing.

Once the Agency starts setting the hearing, it appears the ALJ will no longer have the authority to decide when development is complete. This is a major change which will affect all ALJs, despite the Agency's attempt to downplay it as only for the ALJs who are not scheduling "sufficient" hearings. The language of the proposed reg does not mention or quantify "sufficient" nor does it take into account the myriad variables of workload (such as how many clerks are available to workup cases or when the representatives are available). That's a slippery slope; what is "sufficient" numbers of scheduling this year may not be "sufficient" next year. The proposed reg states that it will have major economic effect, presumably by getting more cases heard.

As Mango said, there is a limit to the number of cases which can be read/comprehended/analyzed by an ALJ. Too many scheduled, and no one gets due process; one might as well flip a coin to decide. For those who are not yet ALJs, remember that there are no "law clerks" in regular Hearing Offices to provide factual summaries or analyses of medical evidence, so the ALJ must do it him/her/self-- and it generally works better to know what's in the evidece before conducting the hearing.

Query, also, whether ALJs will be told they are in violation of law if they persist in insisting the record be developed before hearings. Developing the record can takes months; e.g., a consultative examination can easily take 3 months.

At least one of the National Hearing Centers is already setting the hearings for their ALJs, and telling the ALJs when to show up. Those who are not ALJs may think that is minor, but it is not because this job requires a lot of emotional and mental energy, sometimes physical energy, and getting to set hearings is one perk which helps make up for the hard work. It also allows an ALJ to participate in family life, such as attending school functions for a child, and to schedule other matters of living.

[lawmaker]

Jun 2, 2009 20:39:11 GMT -5 counselor95 said:

The Agency is moving right along with one of its proposals to deal with the backlog. The proposed regulation that the Agency set the time and place of hearing has moved into a final phase, apparently, and is on track to become a reg next month (per the Unified agenda of SSA regs which was made available yesterday). The current reg states that the ALJ shall set the time and place of hearing; the ALJ does so when the ALJ considers the case is fully developed and ready for a hearing.

Once the Agency starts setting the hearing, it appears the ALJ will no longer have the authority to decide when development is complete. This is a major change which will affect all ALJs, despite the Agency's attempt to downplay it as only for the ALJs who are not scheduling "sufficient" hearings. The language of the proposed reg does not mention or quantify "sufficient" nor does it take into account the myriad variables of workload (such as how many clerks are available to workup cases or when the representatives are available). That's a slippery slope; what is "sufficient" numbers of scheduling this year may not be "sufficient" next year. The proposed reg states that it will have major economic effect, presumably by getting more cases heard.

As Mango said, there is a limit to the number of cases which can be read/comprehended/analyzed by an ALJ. Too many scheduled, and no one gets due process; one might as well flip a coin to decide. For those who are not yet ALJs, remember that there are no "law clerks" in regular Hearing Offices to provide factual summaries or analyses of medical evidence, so the ALJ must do it him/her/self-- and it generally works better to know what's in the evidece before conducting the hearing.

Query, also, whether ALJs will be told they are in violation of law if they persist in insisting the record be developed before hearings. Developing the record can takes months; e.g., a consultative examination can easily take 3 months.

At least one of the National Hearing Centers is already setting the hearings for their ALJs, and telling the ALJs when to show up. Those who are not ALJs may think that is minor, but it is not because this job requires a lot of emotional and mental energy, sometimes physical energy, and getting to set hearings is one perk which helps make up for the hard work. It also allows an ALJ to participate in family life, such as attending school functions for a child, and to schedule other matters of living.

What does it say about post hearing development that the alj feels is necessary to create a full and fair record. This sounds poorly thought out if it is as you say. Because, then, when post hearing development is completed, it has to be proffered, and that often results in a subsequent hearing. Which is the claimant's due process right at present and not something the alj can deny unless, presumably he intends to issue fully favorable. Don't tell me that something in that new reg will suspend claimant's right to post hearing development supplemental hearing?
Don't tell me they haven't thought about the fact that only the hearing may happen earlier. That net processing time won't change and may grow when aljs are forced into subsequent hearings they might have avoided if used at the front. !!!

[civilserpent]

It seems to me that the way reps are paid adds to the backlog. As Propmaster noted, the longer a claimant waits for a favorable decision, the more money the rep makes. I had a interesting personal situation recently. My brother (kidney/bladder cancer with bladderectomey) files for benefits and was denied in Jan. 09. In early February, I filed a request for hearing, with a brief pointing out that he was disabled on the grids. (I do not work for SSA or ODAR). I also included a RFC form signed by treating physician to show his exertional/non-exertional limitations. On Feb. 25, we received a fully favorable OTR. Of course, I waived a fee. There would be many more favorables OTR if reps actually worked a little, and did not have an incentive to wait.

[decadealj]

I fear the centralized scheduling is the final straw in the ALJ having any control or authority to schedule a case. In many regions, it has been years since an ALJ controlled anything except the dates he would be available for hearings. In our region the RCJ forfieted any control over the scheduling process to management years ago. So the ALJ is caught in a bind- justice delayed is justice denied over what is sufficient enough to make the call. A 15 minute CE as the only evidence in the last two years or trying to really coax reluctant physicians to document/justify their opinions when many fear malpractice suits over whatever they do. I am now convinced that the only way to really reform the system is to provide representation to all claimants and eliminate the private BAR altogether (other than as contract employees of the goverrnent). I for one am sick of commercials by representatives who will never appear at a hearing and some of the paralegals they send to justify their fee often snatch defeat from the jaws of victory- the claimant would be better off not represented. In my jurisdiction, 4 of the 6 best representatives are legal aid attorneys or paralegals. Bless them- ther are so overworked yet passionate in representing their clients. Heaven only knows what they could do with even "public defender" level funding and the ability to really develop the record prior to the hearing. Since I am on a roll, thanks to the Supreme Court for authorizing attorney advertising- along with pharmacy ads on television, our economy will be bankrupt absent real reform in a decade.

[mango]

propmaster;

The savings are in unpaid benefits. When the Gov't is paying people that are not working, the gov't looses out on tax payments, looses the funds given to the claimant, and most likely picks up the expense of medicare at some point. That is what I reference.

When I say frivolous I am talking about the claim and not the claimant. I don't think I have seen a claimant yet that did not have some problems. Often times they are very serious, but not necessarily disabling under the law. At times the disabling problem occurred well after DLI so are not disabling under SSA law, there are no records during the relevant time period to support the claim, etc. It is not to say the individual sitting there does not have challenges; only that someone versed in SSA law knows those challenges are not compensable.

I guess we should agree to disagree on whether a judge has a duty to look out for the other side. The laws and regulations are set up to do that and by following the law, the judge (just like the gun salesmen following firearms regulations when selling a gun and the gov't inspectors at ICE are looking at those goods coming in to keep out those items that are prohibited) is looking out for the interests of the American people. Those judges that are simply paying cases or are not taking the time to review a record and hold a full and fair hearing are not following the law and not looking out for the American people. Conversely, someone refusing to pay a case that otherwise should be paid is not looking out for the American people as the system was set up to assist individuals that meet the definition of disabled under SSA law.

I don't know that I ever mentioned a balancing test as to whether someone was deserving or worthy. The balancing is weighing the evidence, finding the facts, and applying the law to those facts to reach a decision; keeping in mind the claimant has a burden on the first 4 steps of the sequential evaluation and the Gov't on the 5th.

On an unrelated issue, but one receiving some discussion above, the agency has not implemented the proposed rule to schedule cases. The CALJ at the last training all but said it was dead. I think he did not say it was dead because the commissioner must do that. Those at the NHC are setting their schedules, but some are asking the staff to set a very high number of hearings per month. This is a matter of choice.

Interestingly the CALJ has made several public statements backing away from the 500-700 cases goal. I say backing away in the since that he is stating that it is a goal that he would like people to work toward, but that it is not a standard and no one should be graded, counseled etc based on meeting or not meeting the goal.

[counselor95]

Mango,
The proposed reg for the Agency to set the time and place of hearing is not dead. What follows comes from the Unified Agenda for regulations as of June 1, 2009 (note the final action date of July 2009 and the complete absence of any qualifiers as to under what circumstances the Agency will set the hearing):

" RIN Data
SSA RIN: 0960-AG61 Publication ID: Spring 2009

Title: Setting the Time and Place for a Hearing Before an Administrative Law Judge (3481F)
Abstract: We will amend our rules to clarify that the agency is responsible for setting the time and place for a hearing before an administrative law judge (ALJ). Consistent with our regulations at other levels of the administrative process, we plan to use “we” or “us” in the rules addressing the scheduling of hearings. These changes will ensure greater flexibility in scheduling both in person and video teleconference hearings, increase efficiency in the hearing process, and reduce the number of pending hearings. The number of cases awaiting a hearing has reached historic proportions, and efforts toward greater efficiency are critical to addressing this problem.
Agency: Social Security Administration(SSA) Priority: Economically Significant
RIN Status: Previously published in the Unified Agenda Agenda Stage of Rulemaking: Final Rule Stage
Major: Yes Unfunded Mandates: No
CFR Citation: 20 CFR 404.932; 20 CFR 404.936; 20 CFR 404.938; 20 CFR 404.950; 20 CFR 416.1432; 20 CFR 416.1436; 20 CFR 416.1438; 20 CFR 416.1450(b)
Legal Authority: 42 USC 401(j); 42 USC 404(f); 42 USC 405(a); 42 USC 405(b); 42 USC 405(d) to 405(h); 42 USC 405(j); 42 USC 405 note; 42 USC 421; 42 USC 421 note; 42 USC 423(i); 42 USC 425; 42 USC 902(a)(5); 42 USC 902 note; 42 USC 1383; 42 USC 1383b

Legal Deadline: None

Timetable:
Action Date FR Cite
NPRM 11/10/2008 73 FR 66564
NPRM Comment Period End 01/09/2009
Final Action 07/00/2009

Regulatory Flexibility Analysis Required: No Government Levels Affected: None
Small Entities Affected: No Federalism: No
Included in the Regulatory Plan: Yes
Public Comment URL: www.regulations.gov
RIN Data Printed in the FR: No
Agency Contact:
Brent Hillman
Social Insurance Specialist
Social Security Administration
Office of Disability Adjudication and Review, 5107 Leesburg Pike,
Falls Church, VA 22041-3260
Phone:[phone]

Pamela Kultgen
Assistant Regional Counsel
Social Security Administration
Office of the General Counsel, 601 E. 125th Street,
Kansas City, MO 64106
Phone:[phone] "