More than 21,000 CHN supporters have submitted comments to the Social Security Administration in opposition to a proposal that could cause one million Americans to lose Social Security disability benefits. CHN Executive Director Deborah Weinstein submitted comments on CHN’s behalf before the midnight deadline last Friday, Jan. 31. You can view her comments here and read more about the issue here.

Among CHN’s arguments:

• The Social Security Administration is proposing to greatly increase the number and frequency of disability reviews it completes on people who have been approved for Social Security Disability benefits (adding 2.6 million reviews over 10 years). More Continuing Disability Reviews, (CDRs) mean more terminations.
• The rule would require millions of people with serious health conditions to undergo more frequent reviews of their medical conditions, but there is no evidence that conditions will have improved enough to allow them to work with adequate earnings.
• People with serious conditions will lose assistance because of the difficulty of complying with all the review requirements, not because their health has significantly improved.
• The vast majority of people whose benefits are terminated do not go back to gainful or steady work.
• The proposed rule does not adequately consider the ways multiple impairments can make it more difficult to show improvement.
• Children with disabilities will be more likely to be terminated under this proposal.
• The new proposed category for disability reviews (Medical Improvement Likely) does not make clear what conditions will be included or how frequently the reviews should be conducted.Here too, the rule is impermissibly arbitrary and vague in creating this new category, and on this basis should be withdrawn.
• The proposed rule will cause even more delays in processing applications or reviewing continued eligibility.
• It is extremely disappointing that the Social Security Administration would go back to the failed approach of setting up even more roadblocks for continued receipt of benefits, knowing from past experience that the consequences will be devastating.  Based on past experience, a million people could be subjected to termination of benefits, despite their years of work and failing health.