ACTION ALERT: SUBMIT COMMENTS TO SSA TO OPPOSE NEW CONTINUING DISABILITY REVIEW RULES The Social Security Administration (SSA) has proposed new rules for people who get disability benefits that would require complicated paperwork more often and could put the benefits for thousands of people with disabilities at risk. The proposed rule would apply to both Supplemental Security Income (SSI) and Social Security Disability Insurance (SSDI) recipients and would increase the number and frequency of Continuing Disability Reviews (CDRs). SSA is accepting comments from the public about this proposed change until January 31, 2020. While we understand the need to prevent fraud, we recognize that many people with disabilities, including Down syndrome, will be negatively impacted by this new system. We need you to submit comments to let SSA know why this rule is harmful to people with disabilities and will make an already-complicated benefits system even more convoluted and confusing, leading to loss of benefits which are a critical lifeline to so many people. Background When a person is determined to be “disabled” by the Social Security Administration (SSA), they are required to undergo Continuing Disability Reviews (CDRs) to ensure they continue to qualify for benefits. This process is extremely time-consuming and complicated, and often takes people with disabilities, their families, and other support personnel weeks to gather required information and ensure that all paperwork is correct. Even a minor error on CDR forms can put SSI, SSDI and even Medicaid benefits at risk. If SSA determines someone no longer meets their criteria for disability – and are not “disabled” or “disabled enough” anymore, their benefits are terminated. Unfortunately, SSA sometimes makes errors in these reviews, forcing people with disabilities and their families to hire outside evaluators and lawyers to restore their benefits. The frequency of CDRs depends on what SSA considers a person’s likelihood of “medical improvement” to be. Even people who fall into the Medical Improvement Not Expected (MINE) category, in which many people with Down syndrome would likely be, will have to go through the CDR process at a more frequent rate (every six years instead of every seven years). Furthermore, SSA estimates that this proposal would cost them an estimated $1.8 billion in increased administrative costs. Furthermore, SSA estimates that this proposal would cost them an estimated $1.8 billion in increased administrative costs. SSA also estimates $2.8 billion in savings. These anticipated “savings” are the result of $2.8billion in benefit cuts to SSI and SSDI. SSA also estimates $2.8 billion in savings. These anticipated “savings” are the result of $2.8 billion in benefit cuts to SSI and SSD. The proposed rules will make an already stressful process more burdensome for people with disabilities and their families. How to Submit Comments Comments can be submitted online through the Federal eRulemaking Portal (preferred), by fax, or by mail. · Federal eRulemaking Portal: You may submit electronic comments at https://www.regulations.gov/document?D=SSA-2018-0026-0001 or by going to regulations.gov and searching for Docket number SSA-2018-0026. Click on “Comment Now” and you can type your comments into the comment box or upload a document. · Fax: You can fax your comments to (410) 966-2830. · Mail: You may mail comments to the Office of Regulations and Reports Clearance, Social Security Administration, 3100 West High Rise Building, 6401 Security Boulevard, Baltimore, Maryland 21235-6401. · Every comment counts! Help us let SSA know that this rule is NOT supported by the disability community. · Comments submitted are public. Do not list your social security number or confidential medical information. If you want to submit comments anonymously, make sure to enter “Anonymous” in the name field. · There is no length requirement for comments. If you only submit 2-3 sentences about why you oppose this rule, that comment will be registered. Ideas to Include in Comments [Feel free to use this exact language if you’d like and try to add at least one personal anecdote].
- I am writing to oppose the Social Security Administration’s proposed rule that would change the frequency of Continuing Disability Reviews for many people. This proposed rule would harm many people, and I urge the Social Security Administration to withdraw it.
- Getting disability benefits is extremely difficult and complicated [You could share how difficult it was to get approved in the first place, how long it took, etc.]
- Continuing Disability Reviews (CDRs) are also very complex and burdensome for many people with disabilities. Making people with disabilities go through these reviews more frequently is very likely to push people off their much-needed benefits and will create longer delays for everyone [You could discuss how difficult and burdensome it is to obtain CDRs. For example, do you have to take off work for appointments? Have your past CDRs been erroneously rejected? If so, how did you fix them and what was the process?]
- The proposed rule is dangerous in that it puts over two million people with disabilities at risk of losing critical, life-saving benefits. This rule should not go forward. I urge the Social Security Administration to withdraw this proposed rule.
Thank you for taking the time to submit comments on this important issue! The NDSC Policy & Advocacy Team We encourage you to stay engaged in our advocacy efforts by: (1) Registering for NDSC Action Alerts- click "Quick Sign Up" (https://www.ndsccenter.org/political-advocacy/take-action-stay-informed/); (2) Subscribing to the NDSC Policy & Advocacy Newsline (https://www.ndsccenter.org/about-ndsc/news-and-blog); (3) Joining our national grassroots advocacy program, the National Down Syndrome Advocacy Coalition (https://www.ndsccenter.org/political-advocacy/national-down-syndrome-advocacy-coalition/​) and (4) "liking" NDSC Policy & Advocacy on social media (https://www.facebook.com/dsadvocates/and https://twitter.com/ndscpolicyupdates). |
