#NoSocialSecurityCuts

What's Happening?

The Social Security Administration has proposed a new rule that would change the way it decides if SSDI and SSI beneficiaries are 'disabled enough' to continue receiving disability benefits.

Social Security makes disabled people receiving Social Security disability go through, what it calls, "continuing disability reviews" (CDRs). A CDR is basically a 'are you still disabled enough' audit. Social Security is proposing a dramatic increase to the number of CDRs it conducts.

There are two different kinds of CDR we care about:

  • mailer
  • full medical review (FMR) 

Over the next 10 years, Social Security estimates there would be an additional 1.1 million FMRs & 1.5 mailer CDRs. Those 2.6 million additional CDRs will cost Social Security $1.8 Billion dollars to process. 

If this proposal is implemented, we're facing $2.6 Billion in cuts to the disability safety net over the next decade.

At a minimum, hundreds and hundreds of thousands of people will be kicked off of Social Security disability benefits.

What can we do? 

We can submit official comments. There's an official commenting window that's open until 1/31/20. When we organize commenting campaigns like this, our hope is not to change the administration's position.

We comment for two reasons: 

  • First, Social Security must read and respond to comments before it can implement a final rule. We comment to buy time – every day we delay this rule is a day a disabled person who would otherwise be on the streets has a roof over their head.
  • Second, we comment to prepare for the lawsuit. When Social Security implements this rule, it will be challenged in court. (Our lawyers will make arguments based in a federal law called the Administrative Procedure Act.) The better the commenting record, the stronger their arguments will be.

Comments from SSDI and SSI recipients will be especially useful, particularly comments from people who have been through a CDR.

Who Am I & Why Should You Listen To Me?

I'm Matthew Cortland (on twitter at @mattbc) – a disabled, chronically ill, healthcare and disability rights lawyer. My graduate training is in law and in public health. As an attorney, I'm trained to work with regulatory materials (read, understand, comment on). Over the last few years, I've helped lead commenting campaigns opposing attacks on the disability community by the Trump administration.

And I am, myself, an SSI beneficiary.

How To Comment:

Where to submit comments:
Comments can be submitted at this regulations.gov link.

When is the deadline:
Comments must be submitted by 1/31/20 at 11:59PM eastern. 

How to comment anonymously:
If you are a current SSDI or SSI beneficiary, or are waiting on a decision of a SSDI or SSI application, I strongly urge you to submit a comment anonymously.

This is a screenshot of the commenting website, where it asks for First Name and Last Name. If you click in either box, a tooltip pops up saying "Enter your name or if you prefer not to be identified this field will subsequently populate with 'Anonymous." I strongly suggest you go with "Anonymous" for your last name, at least.


How to submit a longer comment:
The regulations.gov web-form only allows comments of up to 5000 characters. If you'd like to submit a longer comment, you can upload a PDF that contains your full, longer, comment.



How to help me fine-tune this campaign:

If you use this guide to submit a comment, please include "#NoSocialSecurityCuts" somewhere in your comment – I'd suggest at the very end. This will help me continue to fine-tune the campaign so we're as effective as possible and collate comments for the lawyers who will file suit.



If you receive SSDI or SSI and HAVE gone through a Continuing Disability Review:

• tell Social Security whether you went through a mailer CDR or a full medical review CDR; 

• tell Social Security how difficult the CDR process was for you:

• explain, in as much specific detail as you are comfortable with, why it was difficult;  
    
• tell Social Security if any of your disabilities made the CDR process more difficult;
    
• tell Social Security how long it took you to complete the CDR paperwork;
    
• tell Social Security about any difficulties you had completing the CDR paperwork;
    
• tell Social Security how long it took you to do anything else you had to do for the CDR, and any difficulty you had 


This is what a mailer CDR form looks like:




This is what the first two pages of the full-medical review form looks like (the full form is 13 pages long):


If you receive SSDI or SSI and have NOT gone through a Continuing Disability Review:

• tell Social Security how difficult applying for disability was for you;

• explain, in as much specific detail as you are comfortable with, why it was difficult;              

• tell Social Security if any of your disabilities made the process of dealing with Social Security more difficult;        
  
• tell Social Security how long it took you to complete the application paperwork;
           
• tell Social Security about any difficulties you had completing the applicaiton paperwork;

• tell Social Security how long it took you to do anything else you had to do for the application and any difficulty you had.

Commenters who have any impairments on this list will be especially helpful if they describe the ways the disabilit(ies) they have make dealing with Social Security difficult (either applying, or going through a CDR). 


Adults with:

  • depressive, bipolar, and related disorders
  • anxiety related disorders
  • impulse control disorders
  • eating disorders
  • lymphoma
  • leukemia
  • Human immunodeficiency virus (HIV) 
  • Oppositional Defiant Disorder
  • Speech disorders/Loss of voice
  • Fractures of upper or lower limb(s)
  • Attention-Deficit Hyperactivity Disorder
  • bone marrow or stem cell transplantation
  • soft tissue cancers of the head and neck treated with multimodal therapy
  • multiple myeloma with bone marrow or stem cell transplantation
  • breast cancer with secondary lymphodema
  • disorder of muscle, ligament, and fascia
  • lung cancer in the superior sulcus with multimodal therapy
  • cancer of the testes 
  • open wound(s) of upper or lower limb(s)
  • sprains and strains

 
If you have questions, you can ask them here or find me on twitter, @mattbc

#NoSocialSecurityCuts


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