This paper provides more context: www.urban.org/research/pub...
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9/ Policymakers, advocates, and researchers should pay close attention. The rule is likely to have profound policy and human consequences and could reshape disability policy for years to come.

8/ Many denied older workers may turn to early retirement benefits—cutting lifetime retirement income by up to 30%.

7/ In a hypothetical 10% cut scenario, 📉 500,000 people could lose access by the end of 10 years, as well as 80,000 widows and children and another 250,000 who lose eligibility for part of the period. $82B in reduced benefits and ripple effects on Medicare & Medicaid

6/ The impact could be huge: 📉 Up to 20% fewer SSDI applicants could qualify and up to 30% fewer older workers could qualify

5/ SSA is also reconsidering how age, education, and work experience factor into disability decisions. This could disproportionately impact older workers.

4/ BUT implementation matters. SSA must decide how to interpret ORS data—like whether enough jobs exist at certain skill levels. Policy direction on this will determine if people gain or lose eligibility.

3/ SSA plans to replace the Dictionary of Occupational Titles with the Occupational Requirements Survey from BLS. This modernizes the data and has bipartisan support.

2/ The rule has 3 major components: 🔹 Replacing outdated job data 🔹 Implementing new occupational data 🔹 Changing how age (and other factors) affect eligibility.

1/ SSA’s proposed rule could reduce disability benefit eligibility for hundreds of thousands of Americans—especially older workers. This makes it a Social Security retirement issue too.

SSA needs to study these developments and analyze claim decisions. The changes may well be explainable but SSA has yet to acknowledge the issue. And SSA is operating with far fewer staff who have responsibility to analyze and improve the programs.

3rd, Disability adjudicators are more productive, as expected. SSA experienced very high turnover among adjudicators after the pandemic. SSA estimated a temporary 20% drop in productivity as new staff are trained. This underscores the importance of retaining government staff.

2nd, SSA is denying more initial claims. Even as initial decisions have increased by 159,000 for the fiscal year the number of approved claims is flat at about 812,000 with the average approval rate dropping from 38.3% to 36.0%.

1st, New applications for disability benefits are down by 7% this fiscal year (-163,000). While not unusual, this development is concerning if it is in response to very long waits for eligibility decisions and other factors discouraging claims.

See Kathleen Romig's great thread on yesterday's WH Social Security press release.

Janet was at Treasury and I was at OMB when the Bush Administration tested this policy. The evaluation of the test showed high proportions of eligibles were deterred from applying and high administrative costs for IRS. Including this policy in reconciliation is a travesty.