Posted: Fri Sep 19, 2008 07:39 pm Post subject: Upcoming, for the WC aficianado
Am I right in remembering that the Connect audience includes more than one WC aficionado? If yes, then you guys should see below for something that's due out for POMS later this month:
Quote:
DI 52100 (Workers’ Compensation/Public Disability Benefit (WC/PDB) Offset) is a new chapter and consists of 15 subchapters. It is a complete rewrite, update, and reorganization of the instructions formerly located in DI 52001.
I understand there's be no new policy. You guys have fun, now. _________________ I've posted this in my private capacity. What I post might be wrong. Probably, it IS wrong. Any errors are my own. Please don't infer any SSA approval for what I post.
JOA, I'm an old Administrative Judge from many years ago in Mississippi. I'm sure they have screwed it up just like OHA and ODAR have. When I was there, like OHA in the early days, it was fun, and professional. Not anymore from what I hear. Nobody cares anymore.
Joined: 03 Jul 2004 Posts: 41 Location: Cherry Hill, NJ
Posted: Thu Sep 25, 2008 03:41 pm Post subject: New POMS and WC
Any idea when we might expect the new POMS?
If there's nothing new, why the rewrite? It seems to me that the problems with the WC offset is in the execution, not the instructions. All that is required to do it correctly is to make it a slightly higher priority than repainting the stripes in the parking lot. The folks doing the work need some help, not rewriting the POMS.
Two questions and some comments. Here are my responses:
1. Soon. I think.
2. I don't know, unless it was for improve clarity. Bear in mind that sometimes policy changes sneak in as "clarifications."
3. Hmmm. Do you really think that there's enough staff devoted to things like POMS rewrites so that reallocating staff would make a difference for case processing? _________________ I've posted this in my private capacity. What I post might be wrong. Probably, it IS wrong. Any errors are my own. Please don't infer any SSA approval for what I post.
Two questions and some comments. Here are my responses:
1. Soon. I think.
2. I don't know, unless it was for improve clarity. Bear in mind that sometimes policy changes sneak in as "clarifications."
3. Hmmm. Do you really think that there's enough staff devoted to things like POMS rewrites so that reallocating staff would make a difference for case processing?
There is supposed to be an actual formal training IVT on the new POMS (for some reason, I was thinking within the next week or so), so I suppose its not beyond the realm of possibility that some new policy changes could have snuck in there.
Personally, I'm not holding my breath for much of an improvement.
WC is a mess. It will always be a mess. They can write and reorganize the policy until the eve of judgment day and it still will be an unmitigated disaster of a mess. _________________
Joined: 03 Jul 2004 Posts: 41 Location: Cherry Hill, NJ
Posted: Fri Sep 26, 2008 01:49 am Post subject:
Yeah, the dreaded "clarification"......this is what we have always said, we are now just saying it better....OR, this is what we meant to say but it was always what we were thinking....OR, we don't like the way what we said before actually works so we are going to say it this way now and if it represents a change in the way we do things, it's just your imagination.
As to the allocation of resources, what do you think it took to rewrite the 15 WC offset chapters? I'm guessing three or four people for about a year...what's that about 8000 person hours, not counting the series of meetings where the big shots came up with the idea of the rewrite, the series of meetings where the proposal was explained and discussed, the supervisory reviews of the proposed drafts, and then the revisions and final reviews. That's probably a minimum another 1000 hours. IF they did it right, they would have had to review 52 WC statutes to see if there were any individual state changes, but they probably didn't, trusting that trial and error will shake out any such changes.
How many wc offsets can be done with 9000 person hours? They can be tedious but they really are only fourth grade math. SO a BIG picture guy might say that several hundred to several thousand offset calculations that could have been done aren't that many in the grand scheme, but to those several hundred or thousand people it is a big, big deal.
I can't wait to read the new and improved instructions.
I don't know enough about head-to-tail staffing ratios to respond in any useful way to RP's comments. But at a guess, RP might be overestimating the amount of time that went into drafting and redrafting, and underestimating the amount of time that went into comments on the various drafts.
I once had a chance to dip my toe into policy writing. I didn't like the water. Seemed like everything took forever. Lots of chewing. Not much swallowing. Yuck. _________________ I've posted this in my private capacity. What I post might be wrong. Probably, it IS wrong. Any errors are my own. Please don't infer any SSA approval for what I post.
Joined: 13 May 2004 Posts: 740 Location: Federal Hill, Baltimore, MD
Posted: Thu Oct 02, 2008 12:39 pm Post subject:
Well put, JOA. I missed the joy of writing POMS instructions, but did write some regulations. There's a bit more swallowing there, but plenty of chewing and re-chewing. The word cud comes to mind. And no, I doubt RP's staffing guess is accurate; most likely one person did it, and two gazillion reviewed and nit-picked that poor soul's efforts.
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