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Social Security’s Compassionate Allowance Initiative Needs Improvements, the U.S. Government Accountability Office Says

Social Security Compassionate AllowanceProviders of medical record review for attorneys know how important it is to expedite disability claims for people diagnosed with severe and terminal illnesses so that they can quickly obtain the benefits due. The Social Security Administration (SSA) created the Compassionate Allowance Initiative (CAL) to speed up the claims process for those claimants who have been diagnosed with one of 225 diseases including ALS, early onset Alzheimer’s, and certain stages of cancer. Now, Nancy A.Berryhill, Acting Commissioner of Social Security has announced three new Compassionate Allowance conditions – CACH – Vanishing White Matter Disease-Infantile and Childhood Onset Forms, Congenital Myotonic Dystrophy, and Kleefstra Syndrome.

Typically, disability benefits may take months or even years before an approval. However, CAL claimants only need prove a diagnosis. According to the SSA, around 500,000 people with severe disabilities have been approved through the compassionate allowance program. The SSA utilizes cutting-edge technology to easily identify potential compassionate allowances and quickly make decisions. For disability cases that are not covered by the CAL program, Social Security’s Health IT program brings the efficiency and speed of electronic medical records to expedite the disability determination process. EHRs or electronic health records have made the process of medical records review easier, with medical records retrieval becoming simpler because of the EHR’s sharing capability. Though Social Security claims that its disability determination is as quick as possible, the much needed benefits often do not reach the claimants on time. A 2016 study conducted by the Office of the Inspector General on the program found that 25% of applicants in the sample group died within 3 months of applying. The study found that applicants were approved in an average of 47 days. But claimants do not receive the first benefit check until the sixth month after approval. Apart from this waiting period, the proverbial red tape is also a stumbling block in the way to obtaining the due benefits.

The U.S. Government Accountability Office (GAO) was asked to conduct a study on the SSA’s Compassionate Allowance Initiative, which was publicly released on September 6, 2017. This study highlighted the improvements needed to make expedited processing of disability claims more consistent and accurate. Here are the findings of that study.

  • Instead of a formal process for identifying CAL conditions, SSA has in recent years relied on advocates for people with certain diseases and disorders to bring conditions to its attention.
  • This however, posed the risk of overlooking disabling conditions for people who have no advocates. This could lead to individuals with those conditions not receiving expedited claims processing.
  • The SSA doesn’t have consistent, clear criteria for designating conditions for potential inclusion under CAL. This is inconsistent with federal internal control standards, and would lead to external stakeholders lacking important information about how to recommend conditions for inclusion on the Compassionate Allowance list.
  • Another issue is in connection with the software SSA relies on to expedite CAL claims. This software searches for keywords in claims, and if the claimants include misspelled/incorrect information in their claims, the software may be obstructed in its ability to flag all claimants with CAL conditions; or it may flag claimants for CAL processing that should not be flagged.
  • Social Security Compassionate AllowanceThough the SSA has guidance for DDS (disability determination services) staff to manually correct errors made by the software, there is no clear guidance regarding when such corrections should be made. The result – DDS staff may continue to take actions that are not timely; or even hinder expedited processing for appropriate claims.
  • Nearly one-third of the impairment summaries regarding CAL conditions developed by the SSA are 5 or more years old. Experts feel that these summaries should be updated every one to three years or else the SSA could be at risk of making disability determinations on the basis of medically outdated information.
  • The SSA does not leverage the data it gathers to assess the accuracy and consistency of CAL adjudication decisions. Without regular analysis of available data, the accuracy and consistency of CAL decision-making could be compromised.

Based on these findings, the GAO made recommendations including the following:

  • The SSA should develop a process to systematically gather data on potential CAL conditions
  • Communicate the criteria for designating those conditions
  • Clarify guidance regarding manual corrections on CAL claims
  • Update CAL impairment summaries
  • Use available data to ensure accurate, consistent decision-making

The SSA has agreed with the GAO’s recommendations so that they can improve the Compassionate Allowance Program and ensure that the benefits are made available to the claimants who need it immediately.

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