It is important for us all to remember that SSVE work IS Forensic, and that most everything in VE Forensics IS/traces back to SSVE and CFRs. Anything and everything which comes up at SSA/SSVE or becomes a standard in SSA/SSVE will surely become a standard, or at very least an issue, a question or a challenge in any other venue Forensic case. Why would it not?. Anything the US Government does/expects carries phenomenal cache and weight (particularly when it relates to the world's largest disability program and court system) will logically be a yardstick/barometer of how things will be viewed in other forensic cases.
Both Forensic and SSVE ought to make formal statements, but they should be more similar than different.
Scott T. Stipe, MA, CRC, CDMS, IPEC, D/ABVE
Scott Stipe & Associates, Inc.
Original Message:
Sent: 09-30-2023 12:51
From: Michelle Aliff
Subject: SSA Proposes changes to Past Relevant Work
HI all:
So, yes, I think that everyone should comment. I think we all have "skin" in this game, professionally and personally. My suggestion would be in comments to ensure you provide factual basis for why you agree or disagree. I would not just say, hey this is dumb and has no support. Or I agree with this change. Be professional and intentional with your comments. We are the experts in this whole thing after all.
While yes, we don't have to follow the hard and fast rules of SSA, they do still impact us in forensics. I practice in SSA as well as Forensics. One of my biggest concerns is the inference drawn between collection cycles and the erosion of skills. The data collection cycles weren't meant to necessarily address the erosion of skills. In fact the data referred to in the proposed changes doesn't even cover skills in the current releases. The announcement discusses ORS without saying ORS. ORS did collect information on tasks and such, however it has yet to be analyzed. The DOT hasn't been updated in nearly 50 years, so there is not current information to be found there to address skills and their decay factor. There is simply a limited to no foundation for the 5 years.
I am also unclear as to how SSA believes that this will decrease the initial processing time. I see they say it will save hours, but I am unclear how that will translate into decreased initial decision time. As it stands now, many areas are over 200 days to process an initial decision. Some are around 150 days to process the initial decision.
I have other thoughts, but I am certain no one wants to read all that right now!
IARP SSVE will be authoring an official statement/public opinion. We may partner with other organizations as well. At this point, it was just released so we don't have the lay of the land of who supports and who does not. We will be in the next week or so gather that information.
I do think a public comment from the Forensic section would be awesome. As a note, to be on letter head that will need to work through the Forensic section board. As a humble note, I wouldn't simply tell the Forensic board to write it. I would suggest that perhaps some members volunteer to help with that. I wouldn't want to drop something on another board, because I dislike when that happens to SSVE board.
I hope everyone has a most fabulous weekend!
Michelle Aliff Ph.D, CRC, CVE
Vocational Consultant
(503) 516-9863 (phone)
(817) 796-1478 (fax)
The information contained in this transmission may contain privileged and confidential information, including patient information protected by federal and state privacy laws. It is intended only for the use of the person(s) named above. If you are not the intended recipient, you are hereby notified that any review, dissemination, distribution or duplication of this communication is strictly prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message.
Original Message:
Sent: 9/30/2023 12:13:00 PM
From: Robert J. Pare'
Subject: RE: SSA Proposes changes to Past Relevant Work
Circling back to my original post on this, I am adding that the private sector has not- in most cases- recognized the 15-year rule as a fast and sound criterion for examining one's transferable skills and current day labor market appropriateness. Imo, any number of years for such across the board is at best capricious. The proposal for "5 years" may present an opportunity for SSA to examine their entire premise on this point.
I am curious as to IARP's sense and ability to make a statement as coming from the Association itself, and/or from the Forensic Section in particular, in addition to some of its members.
As noted by Lisa Anderson, at a minimum, we are all taxpayers who will pay for the vast new number of claimants who would benefit from this capricious "rule," rather than on the merit of truly disabling conditions within the labor market.
------------------------------
Bob Paré, MS, CRC, LRC, CDMS, FVE, ABVE/D
rpare@consultativerehab.com
Mt. Laurel, NJ. Tel: 609-531-2529
Original Message:
Sent: 09-30-2023 11:54
From: Lisa Anderson
Subject: SSA Proposes changes to Past Relevant Work
I encourage people to respond even if they are not currently providing expert testimony for SSA. We are able to provide our input utilizing our years of experience and knowledge relative to vocational work. Some initial thoughts are that we do not discount someone's education even though it is more than five years since completion and potential employers consider someone's work history of more than five years when hiring. As a taxpayer supporting SSA, I believe we all can provide our input in regard to the proposed changes.
Thank you Michelle for sharing this information.
Lisa
Lisa H. Anderson, MS, CRC, CVE, CLCP, IPEC, ABVE/D Rehabilitation Consultant/Vocational Expert/Life Care Planner CaseVantage, Inc. Mailing Address: 255 Rivertown Shops Drive, Suite 102, PMB 116 Jacksonville, Florida 32259 P: 904.476.7413 F: 855.834.4830 www.casevantageinc.com
|
This e-mail and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. This message contains confidential information and is intended only for the individual names. If you are not the names addresses you should not disseminate, distribute, or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. If you are not the intended recipient you are notified that disclosing, copying or distributing or taking any action in reliance of the contents of this information is strictly prohibited.
Original Message:
Sent: 9/29/2023 8:49:00 PM
From: Scott T. Stipe
Subject: RE: SSA Proposes changes to Past Relevant Work
Why is SSA motivated to radically increase awards? Artificially ignoring skills developed in skilled or semi-skilled work performed over five years would not only be illogical to any vocational expert, HR Professional, employer (or even to a lay person), but will only surely increase disability awards. When something sounds crazy it is sometimes crazy like a fox.
------------------------------
Scott T. Stipe, MA, CRC, CDMS, IPEC, D/ABVE
Certified Rehabilitation Counselor
Board Certified Vocational Expert
Scott Stipe & Associates, Inc.
DBA Career Directions Northwest
4110 SE Hawthorne Blvd
#188
Portland, Oregon, 97214
(503)234-4484
(503)234-4126 fax
email: sstipe@careerdirectionsnw.com
website: www.careerdirectionsnw.com
Original Message:
Sent: 09-29-2023 10:07
From: Jeffrey B. Barrett MEd CAP CRC CCM CVE
Subject: SSA Proposes changes to Past Relevant Work
Somebody's bright idea? We are using a resource that has been out of development for decades. It is already difficult to determine if a claimant is actually qualified by training and experience for a technical or skilled occupation. With a five year history few of the claimants with skilled or technical occupations would show qualification without additional testimony. Then of course, while technical occupations change and develop significantly over 5 years, few unskilled and semi-skilled occupations change so much that qualifications also change, e.g. Cashiers?
I tried to leave a comment on-line. There is another challenge for us. What more can I say?
Best regards,
Jeff Barrett, M.Ed., CAP. CRC, CVE, CCM
Options Plus
optionsplusinc.com
954-929-9694
The contents of this e-mail message and any attachments are confidential and are intended solely for the addressee. The information contained herein may be privileged and confidential. If you have received this transmission in error, any use, reproduction or dissemination of this transmission is strictly prohibited. If you are not the intended recipient, please immediately notify the sender by e-mail reply, do not produce copies of this transmission or any attachments, and delete this message and its attachments, if any.
Original Message:
Sent: 9/28/2023 10:26:00 AM
From: Michelle Aliff
Subject: SSA Proposes changes to Past Relevant Work
Good morning everyone:
SSA is proposing changes to the definition of past relevant work, from 15 years to 5 years. Below is the link and there are directions on how to comment. I encourage everyone to provide comments. Do remember comments are public and will be published.
https://www.federalregister.gov/public-inspection/2023-21557/intermediate-improvement-to-the-disability-adjudication-process-including-how-we-consider-past-work
------------------------------
Michelle Aliff
Ph.D, CRC, CVE
michelle.aliff@gmail.com
[Keller], TX United States
------------------------------