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Post by bartleby on Sept 6, 2014 12:08:39 GMT -5
Hamster, I don't know what you are referring to. All I said was that the Agency has removed all management discretion in matters involving telework. Why are you trying to bust my chops? Further, if you think the PD change is nothing to worry about, you need to pull your head out of the sand or out of managements a**.
The message I received said: Judges -
In June 2011, we began capping the number of cases assigned to ALJs. In FY15 we will cap the number of cases assigned to ALJs at 720 cases per year. This means that starting in October 2014, we will assign no more than 60 cases to ALJs per month.
I welcome your comments or questions.
Debbie
Debra Bice
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Post by bartleby on Sept 8, 2014 11:04:06 GMT -5
Hamster, for you, this is from one of our Union Regional personnel:
I have just returned from the August agency judicial training in Baltimore and leave visiting family and friends. Below is a speech that Judge Rita Eppler gave at the July agency judicial training on the APA and Professionalism. She received a standing ovation at the end of her speech. Deputy Commissioner Sklar banned her from delivering the same speech at the August training. The speech deals with the one of the most important legal issues federal administrative law judges face every day: the relationship between the Administrative Protection Act, agency hearings and what agency policy must an ALJ follow. Judge Eppler argued that a judge acting in her or his decision-making capacity (conducting hearings) must only follow agency policy that has been promulgated in accordance with the APA rulemaking procedures, which at a minimum requires publication and an opportunity to comment. This is the long standing position of the American Bar Association. It is not the position of Deputy Commissioner Sklar and CALJ Bice. Judge Eppler opined below that Deputy Commissioner Sklar and CALJ Bice attempted to remove all references to the APA from the new SSA ALJ position description. Her opinion was confirmed by the General Counsel of OPM in a letter to Congressman Cummings, (D-MD 7), Ranking Member of the House Oversight and Government Reform Committee, which was discussed in an email last month. A Word version of the speech is attached at the end. [The high-lighting is mine.]
APA and Professionalism
Judicial Training July 31, 2014
First, I want to apologize on behalf of Marilyn Zahm, who planned to present remarks here today, a death in her family prevented her from being here. I will do my best to fill in for her. Second, I want to state in full disclosure that my comments here are as a result of my experience serving as the National Grievance Chair for the Association of Administrative Law Judges. I feel it is my duty to present the information to help you protect yourselves.
To start with we need some history for perspective on this topic. The Administrative Procedure Act (APA) was passed by Congress after World War II to rectify adjudicatory problems that had festered for some time in various federal agencies. [The Act at 5 U.S.C. §500 et. sec. became law in 1946.] It seems that agencies had been meddling in the matters pending before their Administrative Law Judges, seeking to control – or at least heavily shape - the outcome of litigation. After much investigation and debate, Congress enacted the APA, enshrining into law the principles that the adjudicatory and prosecutorial functions of an agency must remain separate, that federal agencies must be transparent about the policy they intend to implement (and afford the public an opportunity to comment before enacting such policies), and that Administrative Law Judges have certain powers in connection with the taking of evidence at on-the-record hearings.
ALJs possess a degree of independence since the enactment of the APA. The APA provides that certain separations of functions must be observed to protect the ALJ from improper pressures from agency investigators and prosecutors. ALJs are selected through a special process overseen by the Office of Personnel Management (OPM). ALJs pay is set by statute and OPM regulations. Any attempt by an agency to suspend or remove an ALJ requires a formal hearing at the Merit Systems Protection Board [MSPB]. ALJs are also exempt from the performance appraisal requirements applicable to almost all other Federal employees under the Civil Service Reform Act.
The powers enumerated in the APA with regard to Administrative Law Judges include the ability to:
• Administer oaths and affirmations; • Issue subpoenas authorized by law; • Rule on offers of proof and receive relevant evidence; • Take depositions or have depositions taken when the ends of justice would be served; • Regulate the course of the hearing; • Hold conferences for the settlement or simplification of the issues by consent of the parties or by the use of alternative means of dispute resolution; • Dispose of procedure requests or similar matters and make or recommend decisions; and • Take other action authorized by agency rule.
What does all this mean to us, as a practical matter?
It means that the federal administrative adjudicatory system is supposed to have integrity and not be a tool of bureaucrats. It means that the Social Security Administration has no business directing or unduly influencing the outcome of cases before its Administrative Law Judges. It also means that the Agency is required to enact policy through the Notice of Proposed Rulemaking Procedure.
Does this mean we are free agents? Or, as one judge vociferously argued, that we have equity jurisdiction and can do whatever seems fair to us? No – it does not.
We have an obligation to follow the law, regulations and rulings in doing our job. However, where the Association of Administrative Law Judges (AALJ) disagrees with the Agency is in whether we are bound by policy that is not embodied in the regulations and rulings – policies such as those set out in HALLEX, POMS, or some memo. Since these policies are not subject to the APA Rulemaking procedure, they can be, and often are, changed at the whim of the Agency.
I want to address three areas of concern, all of which touch on the APA:
First: The new Position Description;
Second: In Line Quality Review and Focused Review; and
Third: Our obligation to do our job properly.
Regarding the first issue, the new Position Description (PD); it is exceedingly troubling what the Agency did with our position description. First, if you have not already done so, every judge must read their new PD and I would strongly recommend you also go to the AALJ web site and read the side-by-side comparison that highlights all the changes to the PD.
Again, a bit of background is in order. Unbeknownst to the AALJ or the HOCALJ Association, Commissioner Astrue initiated significant changes to the ALJ position description. The AALJ has filed a Freedom of Information Request and has pieced together what has happened from the documents we received. Let me first mention, however, that the majority of the documents we received were heavily redacted, so clearly we do not have the whole story. In the interests of transparency, I call upon the Agency to release the entire file. In the meantime, this is what we do know:
• In February 2012, the Agency, likely in Deputy Commissioner Sklar’s office, had already ginned up a new ALJ PD – with an attached HOCALJ PD – and began the internal process to get it ready to submit to OPM for approval. By January 2013, the PD was ready and was sent over to OPM.
• We do not know what was in that initial PD, except that OPM objected to certain aspects of it. After some back and forth that produced Agency revisions, (again, all of this was redacted) OPM signed off on the new PD in late November 2013 and sent its approval over to the Agency on December 2, 2013.
• Thereafter, the agency gave a copy of the new PD to the AALJ, characterizing it as: “merely an update that embodied current procedure.”
However, nothing could be further from the truth. The 1994 PD stated that the ALJ was subject to only such administrative supervision “as may be required in the course of general office management.” “Duties and responsibilities” in the new PD are no longer prescribed as “under the provisions of Title II and XVI” but now are “under the direction and supervision of the Hearing Office Chief Administrative Law Judge …” The new PD now subordinates the ALJ to the HOCALJ, who is authorized to provide “guidance” in adjudicatory matters.
This would be problematic enough alone. But, given that the fact that the Agency now regularly promotes ALJs to the position of HOCALJ, when they are still relatively inexperienced and still new to the position, often without significant adjudicatory experience, this move is even more troubling.
A few comments made by HOCALJs and brought to the attention of the AALJ include:
• Reports that an ALJ did not need to read the whole file; she only needed to check the RFCs of the treating sources with the opinions of the CEs and, if they were consistent, then adopt them.
• In another case Judges were told that they should read a file only to the point where they could pay a case, and then stop and do so.
• In another case a HOCALJ told a judge to take testimony from an ME despite the fact that the claimant wanted an adjournment to obtain representation.
• As many of you have probably heard, there was also advice that included using an egg timer and when it ran out, it was time to go on to the next case, regardless of whether the judge had completed a proper review of the evidence.
Relying on guidance from a HOCALJ, particularly one who is an inexperienced Judge, is dangerous. An effective method to deal with such misplaced guidance is to ask the HOCALJ to put it in writing to you and then you will consider it. Once the burden shifts to the HOCALJ, I find that he or she is often reluctant to put himself or herself on the line (although they have no trouble putting you on the line).
While the Administrative Procedure Act (APA) is still referenced in Section I of the new PD; in both Sections II and III all references to the APA have been removed and have been replaced with language that the Judge must “adjudicate cases consistent with Commissioners regulation’s, rulings and statements of policy.” If all this was not bad enough, the new PD now refer to us as “incumbents” rather than “Administrative Law Judges.”
This new language describes hearings as conducted, not under the APA, but under “the agency’s regulations, rulings, policy statements, and other interpretations of the law.” Of great concern is the fact that the Agency’s policies and interpretations of the law are not subject to federal rulemaking procedures. Policy can change from one Presidential Administration to the next; from one Commissioner to the next; or for that matter from one month to the next.
The new PD also adds that “when an incumbent determines that a material issue in a case involves a determination of federal, state, local or foreign law on which the Agency has not issued an opinion, the incumbent ensures that the issue is referred to the Agency’s Office of General Counsel (OGC) so the Agency can make a decision on the issue.”
This new PD strongly implies substantive decisional review, and harkens back to the ill-advised “Bellmon Review,” with its attendant attempt to substantively influence judicial outcomes. In AALJ v. Heckler, 594 F. Supp. 1132 (D.D.C. 1984) the United States District Court for the D.C. [in 1984] noted that “ALJs with allowance rates of 70% or higher were to have 100% of their allowance decisions reviewed for accuracy.” The District Court found “that defendants' [the SSA’s] unremitting focus on allowance rates in the individual ALJ portion of the Bellmon Review Program created an untenable atmosphere of tension and unfairness which violated the spirit of the APA, if no specific provision thereof. Defendants' insensitivity to that degree of decisional independence the APA affords to Administrative Law Judges and the injudicious use of phrases such as "targeting," "goals," and "behavior modification," could have tended to corrupt the ability of Administrative Law Judges to exercise that independence in the vital cases that they decide.”
The language in the new PD portends this same result, as the parameters of the terms “guidance,” and “proper” application of “the agency’s policies and agency’s interpretation of the law” are undefined and subject to abuse. HOCALJs “guidance” to a Judge in a particular case potentially portends “guidance” as to interpretation of the law and application of the facts to the law – which are fundamental to the APA and the hallmarks of independent judicial decision-making.
In addition, the Agency is warning Judges in New Judge Training to tailor their adjudications to stay “within the norms” or “not to be outliers.” Just what percentage is to be considered “within the norms” is unknown or how far from the mean does a Judge have to be to be considered an “outlier.” What is acceptable today, might be considered an outlier in the near future. Further concern is how this could influence a Judge’s decision-making, if he or she feels that they have already issued too many favorable or unfavorable cases, in a given period of time. This too is a very troubling development and portends to impact on judicial decision-making.
Another very important, relatively new type of inroad, into our decision-making is what the agency is calling: “In Line Quality Review.” This is a review of decisions by a group of attorneys, done after the drafts are completed, but before the Judge has been given the opportunity to review the drafts.
What we are told by the Agency is that “In Line Quality Review” is simply a program to review the work of the writers, to make sure that they are doing their jobs properly. Specifically, this is being done to look for compliance with E-Business Process and errors (for training issues and to allow errors in decisions to be fixed prior to being closed out).
Well, maybe the purpose of the program, as described by the Agency is laudable; and maybe that was the original objective. But the program is not being operated that way. Numerous examples have already been brought to the attention of the AALJ where an attorney “advisor” has decided that the judge did not do a good job. In one case, the attorney criticized the granting of benefits, asserting that the judge should not have believed the claimant’s testimony. Another attorney did not like the findings of the judge with regard to the way he expressed the RFC. In both cases, the judge was pressured to make changes.
Isn’t this precisely what the APA was supposed to prevent? Doesn’t this undermine the integrity of the system? Can a claimant believe that they are getting a fair hearing and due process when the agency enables an attorney to be a check on the Judge? And why would anyone think that all of these Quality Review attorneys have better judgment than a judge?
Do Judges make mistakes? Of course they do. It would be impossible to work with the volume of cases we do and not make mistakes. But rather than hire people to second guess us, or try to force us into the little boxes that the agency has decided, at this particular point in time are in vogue, why not simply give us the tools and time to do the job right?
None of us would make nearly as many mistakes if we were given the time needed to adjudicate our cases. However, the Agency has determined that all any of us should need is two and a half hours to adjudicate a case, with for example a record of 500 to 1000 pages, multiple (half a dozen) severe impairments, five to ten years’ worth of medical information, multiple different medical source statements from several treating physicians, and testimony from a medical expert who tells us he cannot evaluate the effects of numerous of the severe impairments as they are outside his area of expertise. To cover everything that is wrong with this scenario would take way more than the ½ hour I have been allotted to speak here today. This issue is the subject of litigation that the AALJ is pursuing in the federal courts and the arbitration arenas. [If you want more information go to the web site or see me later.]
Another additional type of inroad into our independence is what the agency is calling “Focused Reviews.” This is a review done by the Office of Appellate Operations (OAO) where a random sample of decisions that have already been issued are reviewed. Decisions are scrutinized to determine if there are patterns of misapplication of the law, rules and policies. This is used to then subject Judges to training and follow up to determine if the training “was successful” (or to determine if they are now doing what they should be doing).
Again, while the objective for this review may well be pure, the potential for mischief is great. This is a potent tool in the hands of the bureaucrats. A hatchet job can be done on any judge. Any decision can be picked apart and things found to be criticized. And Judges can be chosen to undergo a focused review for nefarious reasons – because the plaintiff bar does not like the judge, because of a low pay rate, because they have a disability, because they are a union official, because the RCALJ wants to get rid of the judge. The Judges that have been selected for focused review, at least at this point in time, have not been randomly chosen. The Agency has not been transparent about all of the reasons why particular Judges have been chosen to undergo these reviews. We urge the Agency to provide the AALJ with the information we requested about this program.
The integrity of the system rests with us. I cannot stress enough that if the oath of office we all took, when first becoming Judges, means anything; it means that we must all have the integrity to stand up for what is right and provide Due Process of Law for each and every claimant that appears before us.
In the past, when the backlog was the paramount concern, the Agency pushed us to pay cases so that the cases could be moved quickly and without using much in the way of resources. We were encouraged to issue bench decisions that were often times hand written, and did not contain much of any substance for review. Those Judges who complied with the mandate, to push extraordinarily large numbers of cases out, including Judges that issued numbers that were well beyond any reasonable number of cases that could be heard and decided, were known as the good Judges – even, the heroes in the office. Additional cases were funneled to them and they received extra writing and clerical resources because they were “productive.” It was even referred to as “maximizing talent.” Management not only knew full well how these Judges were accomplishing deciding these large number of cases and how they were doing their job, the Agency approved. The Agency even rewarded the Hearing Office staff that supported these Judges, with bonuses.
I have mixed feelings about this situation. On the one hand, I think that these Judges should have resisted and followed the regulations and rulings. On the other hand, they were doing what the agency wanted them to do – the aim of the agency was to get rid of as many cases as possible in as short a time as possible and “meet the goals.” And, funneling money to the poorest segment of the population is not a bad aim, and maybe even is considered legitimate public policy; since there are not enough jobs in the economy for the number of potential workers, and since it is harder for those with impairments to get and keep jobs. If that is what we are doing, let’s be honest about it. And, then let’s get rid of all those pesky regulations that slow us down. And then, why do we need Judges at all?
When it comes right down to it, the Agency has encouraged Judges to push out the work and then put the blame on the Judges for doing what they were encouraged to do. When the rock was turned over and what had been going on came to light and Congressional inquiries began, there was much scurrying for cover. All of a sudden we started hearing how management could not control the Judges, how they did not have any tools, how it takes a million dollars to get rid of even one bad judge.
So, here we are. Left with a system whose integrity is questioned and whose Managers are more than willing to blame Judges for their own bad management and make us pay for their sins.
It is up to us to try to salvage the system. And the best way to do that is to do your job with integrity. Resist any attempts that would require you to cut corners. Read the evidence, which means more than just skimming or getting the “Gestalt” of the case file. Make sure that all records have been submitted. If needed send interrogatories to make sure that you have supportable opinions. Do not move cases that should not be moved. Do not sign decisions that are badly written. Most important of all, is to give the claimants a full and fair Due Process hearing.
Refuse to be bought off by telework. I know it is tempting to try to schedule the numbers the Agency has demanded, to retain the right to telework. But if you are scheduling more cases than you can reasonably adjudicate you may well be setting yourself up for far more serious problems than not being allowed to work at home.
Do not schedule more cases than you can properly adjudicate.
As Grievance Chair, I can tell you that many of the Judges that get themselves into a bind with the Agency, and wind up down a road that involves discipline, start out with trying to adjudicate more cases than they can handle. If you schedule more cases than you can handle and you do your job ethically, then there are bound to be cases that will pileup or backups that will occur at one status or another in the process. If you move too many cases to hearing and do not have enough time to decide them, they will wind up piling up in ALPO, which has its own unique set of problems. When a judge has to go back days, weeks or even months later and try to recall and reconstruct the hearing and decision-making process this often makes the effort needed to resolve the case even harder and more time consuming. Alternatively, the cases will pile up in EDIT and will get older and older as the claimant waits for a decision. Any of these backups of cases beyond the “bench marks” can and will cause the Agency to issue directives to move cases by a specific date or give specific reasons why each individual case cannot be timely moved in accordance with the directive. This scenario is playing out in many Hearing Offices around the country.
I strongly suggest that you cut back on the number of hearings you schedule if you cannot properly adjudicate what you are scheduling. I know this runs contrary to what you are being urged; but preserving your judicial integrity must be your first priority. Treat each case independently; give each case the time and effort deserved by the American public we took an oath of office to serve. In short, do not be bullied into doing an inferior job. We are not paid enough to sell our souls.
More in depth analysis on many of the topics I have tried to cover today are included in papers on the AALJ web site and I would encourage you all to access the site and read some of the documents including for example: The Real Issue - Are SSA Judges becoming Pawns of the Agency, and the AALJ newsletters.
Before I end I need to make a quick pitch, for all of you that can, to attend the Annual AALJ conference that will be held in Savannah Georgia on October 7-9th. Thank you.
[Judge Rita Eppler]
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Post by chessparent on Sept 8, 2014 13:42:44 GMT -5
She had me until she suggested that a Judge had been "pressured" to make a change to a decision by an attorney "adviser." As an insider, and "adviser," I found that kind of laughable.
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Post by redryder on Sept 8, 2014 15:08:58 GMT -5
Issuegirl: The provision regarding the 2 hour report period if called back is found in Article 15 of the contract. Per the AALJ website, this is one of the provisions that was implemented after the contract issues went to impasse. It is not subject to ratification. You can and should seek advice from the union rep regarding how this is being interpreted, but given that this was negotiated and has now been implemented, it does not appear either management or the union have any wiggle room.
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Post by redryder on Sept 8, 2014 15:17:16 GMT -5
One quick piece of advice for SSA ALJs and candidates: Whenever you have a question about your work condition, you need to remember that this is not like the private sector. We are represented by a union that has negotiated a contract that binds us all. It is in your best interests to read that contract and learn what is in it. When you have a question about a work condition, start with that contract. Frequently the answer is there. Like what is the basis for the 2 hour report for call back? Or why can't a judge who works 4 10-hour days work at home? What are the rules on credit hours? Our contract spells out these details and many more. Don't run afoul of or be buffaloed by management because of your ignorance of the contract.
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Post by prescient on Sept 8, 2014 16:16:07 GMT -5
She had me until she suggested that a Judge had been "pressured" to make a change to a decision by an attorney "adviser." As an insider, and "adviser," I found that kind of laughable. She's referring to the feedback that the in-line quality review attorneys are providing. I have spoken with friends in several offices, and most are in agreement that the "recommendations" that QA provides are treated as gospel, and must be incorporated into the decision before it can be signed.
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Post by bartleby on Sept 8, 2014 16:53:31 GMT -5
The problem is, is that we do not have a contract in place. It has not been voted on by the Corps. The Agency wants to pretend that we have a contract, but the Union does not believe so. There is still great contention over the matter and there is a great possibility that we will revert back to the prior contract. The Agency did not live up to agreements made with the Union. I think the Union conference next month will be very enlightening to many. Read the latest AALJ Union Newsletter for confirmation of this.
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Post by hamster on Sept 8, 2014 18:32:32 GMT -5
Woosh! Pop! (Sound of releasing vacuum.)
Bartleby--Yes, I was able to extricate my head from where I've been keeping it, at least for long enough to make a few observations.
I don't like being called an "incumbent" in the new PD. Still, I am paid as an ALJ, get called "judge," wear a black robe, and have the honor of presiding over disability hearings. It's like the old saying, "if it looks like a duck and quacks like a duck." So, even if some bureaucrat calls me an "incumbent," that's OK. Because I know what I am--and I'm an ALJ with qualified decisional independence.
I am concerned when I hear stories--truth? myth?--about some ALJs feeling "pressured" to pay a case, or to not read a file, or to use an egg timer even when not cooking an egg (I like mine over easy, by the way). I am concerned when I hear similar stories about ALJs being "bossed around" by attorney advisors. But whereas I have a middling concern about the person doing the bossing or ordering or pressuring--which I personally have never seen in two offices over the past 32 months, my real concern lies elsewhere.
My real concern lies with the spineless, gutless ALJ who completely supposedly abdicated his or her decisional independence and professional judgment by succumbing! Frankly, I don't believe it actually happened. But if it did--the ALJ Corps should jettison those weak-kneed ALJs who have so miserably failed to do their jobs. That is where your concern should be focused, too, IMHO, Bart.
And let's say that DC Sklar in fact did not like the speech and prohibited our colleague from giving it at the next training session. So what? Class ends at 4:30 or 5:00, so she can give it to the gathering when it's not "company time." I think this is no big deal. Besides, not all ALJs belong to the Union--it would smack of a federal endorsement to a captive audience if the speech were given on official time.
Oh, BTW: I do belong to the Union; my AC agree rate is above 95% for decisions and at 100% for dismissals; my HOCALJ and HOD are very professional and pleasant; and I am NOT going to meet goal this year--I'll probably be around 460ish. No big deal.
I am treated with courtesy and professionalism as an ALJ--every day. I know that I have essentially unfettered decisional independence--every day. I know that the Agency and my colleagues want me to demonstrate integrity--every day.
So, again: The sky is not falling! (And I was just kidding about where my head's been. It's screwed on tight, the air is fresh, and I can see to the horizon.)
Best, Hamster
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Post by redryder on Sept 9, 2014 15:36:01 GMT -5
Bartleby: Look at the AALJ website. There are articles that have been enacted by virtue of the federal impasse process. There are others that require ratification. The article re: telework is one that does not require ratification as it was the result of impasse. While the union may argue those articles requiring ratification cannot be currently enforced, that is not true of the remainder.
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Post by bartleby on Sept 9, 2014 16:17:25 GMT -5
Redryder, the question is whether or not you can have part of a contract or not. The Union's position is that the Agency has not lived up to certain agreements along the way. The Agency has not acted with clean hands throughout this process. The Union is still fighting this matter.
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Post by privateatty on Sept 9, 2014 19:03:27 GMT -5
The vast majority of those reading this are concerned only with SSA and thus the almost opposing viewpoints espoused by my brethern hamster and bartleby. But the circle is wider.
And that wider circle encompasses all ALJs and the Art. I Courts we preside over. SSA/ODAR/Puzzle Palace makes a mistake when they attempt to sever the ties between the ALJs of ODAR and the APA. Just like the poet Donne wrote so many years ago, "...no man is an island..."--and no Judge is either. What the plotters at OGC-SSA and Puzzle Palace fail to understand is that this issue of the PD is a whole lot bigger than their limited vision. Granted, hamster has a point when he says that the sky is not falling and there have been no draconian attempts to usurp judicial independence. However, as hamster as so eloquently noted, he doesn't like being called an "incumbent". The Office is the issue and its ability to deliver due process--not the game of one upsmanship that both sides seem wedded to.
Folks at OGC/SSA, hamster is whom you want on your side. Lose him and the war is already lost.
I'm watching, and I am comforted that so many of you are too.
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Post by atlasta on Sept 12, 2014 22:32:42 GMT -5
How can an ethical Judge be pressured into a decision? Get some backbone!
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Post by bartleby on Sept 13, 2014 8:46:25 GMT -5
Atlasta, Bless your heart... How can an ethical Agency arbitrarily change a Judge's position description to move that Judge from being an independent Judge to being an employee that now falls under annual review? How can an ethical Agency keep issuing conflicting and contradictory reg's, policies, directives, etc? While some of us have too much backbone according to the Agency, many cave and roll with the good times.. It is a very distressful situation. The Agency likes to think of us as hearing officials or incumbents and not Judges. They have little to no faith that we are capable of doing the right thing if left to our own devices. Hence, Frank Boroweic's book, The Social Security Administration, an Agency at War with Itself. A history of the fighting between the Agency and Judge Corps for the past 25-35 years, available at Amazon.
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Post by extang on Sept 13, 2014 12:57:32 GMT -5
Your HOCALJ may be the most delightful person in the world. However, if you are an ALJ, you would be foolish to ignore the fact that Regional Office and Central Office of ODAR, not to mention the SSA bureaucrats outside ODAR, hate and despise you and are your enemies. That's the management you need to worry about, not the possibly quite friendly local management [although of course there's also plenty of local management that is not friendly at all].
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