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SSA Signals Possible Changes To Vocational Guidelines (GRID Rules) In SSDI Program

2015 September 14
by Steve Perrigo

The Social Security Administration (SSA) has filed a notice in the Federal Register as an information gathering step while they examine the vocational factors of age, education and work experience in the adult disability determination process. The deadline to respond is Friday, Nov. 13. The SSA also would publish a notice of proposed rulemaking in the Federal Register with any specific proposals, allowing for public response.

The Advance Notice of Proposed Rulemaking (ANPRM) indicates the SSA plans to make revisions to these guidelines. The notice outlines advances in technology and changes in workforce demographics since the current regulations were adopted in 1978 as factors in the filing.

The number of disabled workers’ claims allowed based on medical and vocational factors has increased since 2008, reaching about 54.7 percent of allowances in 2012, according to SSA data.

Recent Congressional hearings, policy meetings and forums have highlighted the role of medical-vocational factors. Some groups have recommended revisions to these guidelines, sometimes called “grid rules,” as part of reforms to the Social Security Disability Insurance (SSDI) program. The program is under scrutiny as the Disability Insurance (DI) Trust Fund nears exhaustion of its funding reserves next year.

One example is a report by Mark J. Warshawsky and Ross Marchand with the Mercatus Center released this spring entitled, “Modernizing the SSDI Eligibility Criteria: A Reform Proposal That Eliminates the Outdated Medical-Vocational Grid.” The 40-page study outlines changes in the nature of work and U.S. demographics, among other information.

U.S. Rep. Sam Johnson and Sen. Orrin Hatch also jointly introduced legislation (H.R. 1800 and S. 1194), Guiding Responsible and Improved Disability Decisions Act of 2015, or the GRIDD Act of 2015, that would require the SSA to update the medical-vocational guidelines.

This ANPRM specifically focuses only on vocational factors, with the SSA asking the public to provide research and data. One tool specifically cited as outside the scope of this notice is the Dictionary of Occupational Titles, which the SSA said is “because we are working with the Bureau of Labor Statistics (BLS) to test the collection of updated occupational information that we intend to use to develop a new occupational information system.”

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