DDS Doctors and Disability Determination Services
According to an audit performed by the SSA inspector general's office, the state-level DDS (disability determination services) agency in Alabama that processes social security disability and SSI disability claims has an...issue. DDS managers seem to be pressuring medical consultants to increase the number of allowances they make. Not a big surprise to me since I used to work as a disability examiner at a DDS and I've blogged about this issue many times over the years. Ok, let's define some terminology first.
What is DDS? As I stated, this is where decisions on SSD and SSI claims get made, at least at the disability application and reconsideration appeal level. DDS is where disability examiners are based, and disability examiners are the specialists (in some states, their title is actually "specialist") that gather medical records and evaluate such records in conjunction with a claimant's vocational factors (age, education, work history and job skills) to arrive at a decision.
What is a medical consultant? A medical consultant is a doctor who works at DDS. Now, as the President often states, let's be clear: DDS medical consultants are not the doctors who conduct social security medical exams (known as CE, or consultative exams). Those doctors are private practice physicians who perform exams on a contract basis. Medical consultants actually work in the same processing units as disability examiners and their job, officially, is to provide consultation to examiners who are deciding claims.
In theory, the examiner reviews the claim and makes a decision. But, in actuality, in most cases (I say most because some examiners are single decision makers and can largely act on their own) the examiner must get the medical consultant a.k.a. DDS doctor to sign off on the case before the decision has any weight to it. So, who really makes the decision? If you're honest about the process, you have to say that it's the DDS doctor, the medical consultant who makes the decision.
Ah, but there's another wrinkle to it. DDS doctors (medical consultants) work in case processing units with examiners. And those units have managers. And those managers have managers of their own. And this entire hierarchy of management at a state's DDS agency likes to look good. For this reason, DDS upper management typically exerts influence over DDS lower management (the unit supervisors). For what purpose? To achieve better statistics, i.e. to look better.
In this type of system, how do you (DDS management) get yourself to look better? By bringing your statistics into conformity, into line, with what the social security administration wants at any given moment (more approvals, more denials, faster claim processing, etc).
In the past, of course, the effect of this rather spineless system has been that DDS managers have exerted influence over DDS doctors to put a downward pressure on the number of denials issued by case processing units. Now, however, it seems that the last few years of backlogs, at all levels of the system, has resulted in agency pressure to get more cases through the system faster, with an increased emphasis on approvals.
Of course, this is a good thing for claimants. However, the motivation behind this probably has a lot to do with some forecasting. With bad economic times, disability claims go up. With an aging population, disability claims go up. And the backlogs in the disability claim system are already huge.
In my opinion, though, the results of this audit only highlight even more the need for a certain piece of reform in the social security disability system, which is this: the state DDS agencies need to be removed from the control of the individual states. In other words, the entire system needs to be federalized, from top to bottom. It is simply the only way to enforce uniformity throughout the "national" disability benefit system. In fact, if the system had already been federalized, then the ridiculous scenarios in some states, where disability examiners were furloughed due to budget shortfalls (Why ridiculous? Because the states do not pay the salaries of examiners; this is a cost paid by the federal government) would not have been able to occur.
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