Proposed Redesigned Decision Process

SSA has stated that the redesigned disability decision process should

  • be simple to administer;

  • facilitate consistent application of rules at each decision level;

  • provide accurate and timely decisions; and

  • be perceived by the public as straightforward, understandable, and fair.

The goal of the new decision process was to focus decision making on the functional consequences of an individual’s medically determinable impairment(s) (SSA, 1994a). Although the presence of a medically determinable impairment would remain the central requirement for eligibility as required by law, the redesigned process would focus directly, rather than indirectly, on the applicant’s functional ability to work and would rely on standardized instruments for measuring functional capacity to reach decisions. Medical and technological advances and societal perceptions about the work capacity of a person with disabilities appear to support a shift in emphasis from the current focus on disease conditions and medical impairments to that of functional inability. For example, people with disabilities are able to function today with personal assistants and assistive devices.

SSA assumed that under this proposed decision process, the majority of disability claims would be evaluated using a standardized approach to measuring functional ability to perform substantial gainful activity. Standardizing the approach to assessing individual functional ability would facilitate consistent decisions regardless of the professional training of the decision makers in the decision process. The new disability decision process, as envisioned by SSA, would assess a person’s functional ability once, relying on objective, standardized, functional assessment instruments. SSA believed that focusing decisions on the functional consequences of a person’s medical impairments would permit physicians and others who provide medical evidence, as well as decision makers, to use a consistent frame of reference for determining disability, regardless of the diagnosis and would facilitate evidence collection by reducing the need for developing extensive medical records (SSA, 1994a).

In the proposed plan, decision makers would consider whether a person has a medically determinable impairment(s), but would no longer impose a threshold “severity” requirement. Instead, they would compare the individual’s impairment(s) against an “Index of Severely Disabling Impairments.” The Index would replace the Listings of Medical Impair-

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