VCU 5/10/04 WEBCAST Present: BARC PART II - JOHN COBURN Captioning Provided By: Caption First, Inc. *** >> TERI BLANKENSHIP: Hi and welcome to our webcast today. We're at Virginia Commonwealth University, and I'm Teri Blankenship. Thanks for joining us today. Today's webcast is sponsored by Virginia Commonwealth University Benefits Assistance and Resource Center this is a webcast series on understanding SSA overpayments and continuing disability reviews, and the role of the benefits specialist and PABSS advocates. Today we'll be covering Part II of the series, overviewing of continuing disability review. For people who didn't join us for our first part, there are a couple of technical items I want to cover with you. First of all, today's webcast is captioned, so if you want to use that feature, there's a captioning link on your webcast page. Also, today's webcast will be archived for you and we'll e-mail you the user name and password by tomorrow. Today's PowerPoint presentation is also available for you on the webcast page. Following today's webcast, we'll have a live chatroom session and I'll tell you a little bit more about that at the end of the webcast. John Coburn is our presenter today for this series. He is a consultant for Virginia Commonwealth University's Benefits Assistance and Resource Center, and an attorney at Health and Disability Advocates, which is a national policy and advocacy organization for people with disabilities. In part I, John gave us an overview of the SSA work-related overpayments and today in part II of this series, John will be giving an overview of continuing disability reviews. John? >> JOHN COBURN: Thank you. Good afternoon. This afternoon, we're going to take some time to go through the continuing disability review process. The continuing review process, just as the overpayment process was, can be a very scary situation for individuals who are currently or were receiving -- who are currently receiving Social Security beneficiaries. Why does Social Security conduct CDRs? First, they're required by law to do so, to evaluate an individual's impairment from time to time to determine if the individual is still eligible for payments based on disability. This is a requirement of the law. This is required so that they can maintain programmatic integrity and assure that the individuals who are on benefits are eligible for benefits. One of -- part of the good news in the conducting of CDRs is that the CDRs result in unfavorable decisions in very few cases. Most individuals who go through the CDR process we're going to talk about today do keep their benefits afterwards. What is the role of the PABSS or the BPAO in the continuing disability review process? Again, just like in overpayments, the PABSS and the BPAO can be an important source of information and support to individuals who are going through this process. Oftentimes, you all, in doing the important work that you do, are the first person that an individual calls when they have problems with SSA, and that is because in the past you've done great work for them, explained things to them, and they trust you. And so you can have an extremely important role if the individual gets a notice of a continuing disability review, in explaining that process to them and making them more comfortable with the process. The PABSS can represent individuals in CDR appeals where an unfavorable decision on the CDR is based on a SGA determination. This means PABSS is now allowed to take those cases where an individual was taken off of benefits because of earning over SGA, and there is some indication that this termination is incorrect. PABSS can take those cases now, and that's a current change and some PABSS across the country will be representing individuals in these circumstances. In all other circumstances, the PABSS and the BPAO can offer support and counsel. As I said, you are often the front-line individual that a person on Social Security trusts with their work-related issues and their Social Security issues, so after today's presentation, when you get a better sense of what the continuing disability review process is, you'll be able to counsel and support those individuals and help them through this process and make it a less painful process for people to go through. You can also be the person that helps assist individuals in cooperating with SSA. One of the worst things that an individual who is going through the continuing disability review process can do is try to hide from it or ignore notices, those types of things. So you can help make sure that that individual is cooperating with SSA, because one sure-fire way to lose and get an unfavorable CDR determination is to not cooperate with SSA. And finally, as the PABSS and the BPAO, you can inform individuals of their rights and, in particular, important filing deadlines so that individuals don't miss those and are good self-advocates. When are CDRs conducted? CDRs are conducted under the regulations in several different circumstances. The first one is the diary dates. As you all probably know through your training when you had to learn about who got tickets and who didn't get tickets, everybody who is in the Social Security system has a diaried date, based on their disability and some other factors. And they're diaried as either medical improvement expected, medical improvement possible, or medical improvement not expected. And we're going to go over in more detail what each of those mean. But those diary dates will come up, and individuals will be subjected to CDRs. The second circumstance where a person could be subjected to a CDR is that SSA needs current medical or other reports to see if the disability continues. This can occur when there's advances in medical technology and how disabilities are -- how medical evidence and testing, diagnostic procedures, when those improve and are better able to give a sense of what an individual can do as far as substantial gainful activities. When those types of advances in medical technology happen, individuals who would benefit from those can be subjected to CDRs. This, I don't think, is done very often. Another situation where CDRs are conducted is when the consumer returns to work and successfully completes his trial work period. As you know from your benefits planning and PABSS work, individuals are, at this point, subjected to what are called work CDRs, but also consumers could be subjected to what are called medical CDRs, and this is if the Ticket To Work and Work Incentives Improvement Act exceptions do not apply. And we're going to get into those in a few minutes. Substantial earnings are reported to the wage record. Again, this can trigger a CDR, but the TWWIIA exception we're going to go over applies to this as well. Consumer tells SSA that he or she has recovered and returned to work. This can also trigger a CDR, if a TWWIIA exception does not apply. VR says services are now completed and you are able to work is another situation where CDRs can be conducted or SSA receives a report of no disability and return to work from a person who knows the individual's physical or mental condition. This would be when a third party reports to Social Security that someone is no longer disabled or that person is working full time, that can trigger a CDR. Also, when SSA receives evidence that raises questions as to whether the disability continues. Again, this could be reported by a third party or some other source that raises some sort of question as to whether or not the person continues to have a disability that meets the standards to continue to receive benefits. Also, CDRs are conducted when there's a vocational reexamination diary debt that's been set -- diary date that's been set in the recipient's case or for low birth weight infants, a CDR is always conducted as of their 1st birthday. What are the TWWIIA CDR protections? These are new protections that just recently came into effect throughout the country. The first one -- and both of these you all should be well aware of. The first one is, there's no CDR for individuals whose ticket is assigned and in use. We know from our training as a BPAO and the PABSS, that when an individual assigns their ticket, if their diary date comes up, that diary date is looked over because their ticket is in use. And then the second thing that the TWWIIA legislation did was stop the work activity -- the CDRs where work activity by the individual was -- excuse me, the work activity of the individual caused the CDR. As many of us who have been in this field for a long time know, that when individuals used to go back to work and be fairly successful, that might trigger a CDR for that individual. The TWWIIA protection helps make a new work incentive where, if you're a SSDI beneficiary for at least 24 months, it will not trigger the medical CDR, as it used to in the past. What we're going to concentrate on today -- which is the most common CDR -- is the CDR that comes as a result of your diary date. Every individual's case falls into one of three categories as we mentioned before: The medical improvement expected, the medical improvement possibility, and the medical improvement not expected. As you all probably already know, individuals are not necessarily aware -- it does not come in their decision letter -- what their diary date is, and it's not something that's commonly known by individuals who are in the system. The diary category can be changed as well during a continuing disability review, so whatever diary date and whatever diary category an individual is in, that's not static. When they go through the CDR process, it could be changed, they could decide that they want to review it more frequently or less frequently. The first category is medical improvement expected. And you'll remember -- you've learned about these categories before through training. These are the individuals who did not originally get tickets in the system until they had their first CDR. And their CDRs are scheduled every 6 to 18 months, and this is for individuals who are expected to recover. Sometimes when an individual receives a favorable decision from the ALJ, the ALJ will diary them as medical improvement expected and in their written favorable decision set a date for their disability to be reviewed. Examples of medical improvement expected categories are individuals who have fractures or they have a surgery planned that is expected to result in their recovery. The second category, on the other end of the spectrum, is the medical improvement not expected. In these situations, the CDR is scheduled every 5 to 7 years, and the disabling conditions is static or progressively disabling. People get medical improvement not expected diary dates based on their age, the impairment consequences, the attachment to labor market, and other factors, as well as their actual medical conditions. And examples of medical improvement not expected include Parkinson's disease that meets the listing, the amputation of a leg at a hip, and an AIDS diagnosis. So this is sort of on the opposite end of the spectrum from the medical improvement expected and these are individuals -- although everyone has to have severe impairments -- the most severe impairments in the system. They're only going to review those cases every 5 to 7 years. The big category in the middle is medical improvement possible. In these situations, the CDR is scheduled every 3 years. Here, they sort of take a middle definition, where improvement cannot be predicted but severity is not at the level that is considered permanent. So this is a big category in the middle for individuals, and here are the examples of individuals in the medical improvement possible category: Hyperthyroidism, regional enteritis, and chronic ulcerative colitis. Once an individual is put into one of those three categories, they're placed into the system. There is something called statistical profiling that goes on with these diary CDRs. Everyone in the system is categorized, again, in one of two categories. The first is the high level of medical recovery, and the second is the low probability of medical recovery. So first, individuals are initially spread out into medical improvement possible -- or medical improvement possible, medical improvement expected and medical improvement not expected. Then once they're in the system, they're again categorized in these two different statistical profilings: The high level of medical recovery and the low probability of medical recovery. This statistical profiling is done by computer and is done automatically, and it takes into consideration each year -- and it's done once a year. It considers the age, the impairment, the length of the time the individual's been in disability status, the basis for the original determination, data on prior CDRs, and recent earnings. All of those different things are taken into account in a computer program to come up with whether the person falls into high probability or low probability. This helps SSA in the process for determining who will actually receive a full CDR. Not all individuals receive a full CDR when their diary date comes up. Again, they're categorized three ways, then they're categorized two ways, and then some individuals are given full CDRs and some individuals are not. Those individuals in the low probability of medical recovery, they get what is called the mailer form. This is no longer than two pages of questions, and the individual has to fill this out and return it to Social Security. And only about 2.5% of the cases from this process are referred to the full CDR that we're going to go over later, so a lot of people are taken out of the process through this mailer form and through the low probability of medical recovery, and never actually get to the point where they get the full CDR. Also, some individuals are referred on -- some of that 2.5% are referred on to the local office, and then the local office has some work it goes through, and some people are -- of that 2.5% are discontinued at the local level, and don't get the full CDR. In the 97.5% of the cases where the CDR is deferred, that deferral is not considered a CDR. This is important for a few different purposes, one of which is: This does not count as a favorable decision if a CDR comes up later. We have in the CDR system something that's called the comparison points. When we go through all of the different questions that are asked when a person goes through a CDR, it's all based on comparing today to a past reference point. If an individual goes through the mailer form and does not receive a CDR, that is not considered the last favorable decision. It goes back to the prior decision. So that's why that's important to know that this is not a CDR. If they fill out the two-page form and they don't go to full CDR, that's not considered the comparison point if a CDR later comes up. For those individuals in the higher likelihood of medical improvement, they're subjected to the automated direct release system. This system entails a phone call from SSA and a mailing of a large multi-page questionnaire and a full CDR is conducted. So this is how Social Security sort of screens people through the process. You have the up-front process of three different categories of diary. Then you have the second determination of whether you're high or low probability. And then once you're determined in that, the low probability goes through a screening test that screens most of those individuals out, but the high probability individuals go through this automatic -- automated direct release system and they will have a full CDR conducted. Let's get into what happens when a full CDR is conducted. Before we go into the actual sequential evaluation and through a lot of examples, there are some important definitions that you need to know up front to understand that. One of the things in the CDR process that is often looked at is medical improvement. And this is defined as any decrease in severity of the impairment that was present at the time of the most recent favorable decision. Fairly straightforward and simple. Another thing that often comes up is residual capacity. And for those of you who have been working in the SSA system for a long time, you'll recognize this terminology from the initial determination stages. Residual capacity is what a person can still do, despite an impairment. This is often talked about in terms of the grid format, in initial determination. If impairment does not meet or equal the listing, you go to the grid. And SSA looks at the residual capacity to see if you can still do past work or, with your age, education and work experience, any other work. Sometimes these residual capacity determinations you will see are going on in the CDR process. Medical improvement related to the ability to do work. It's important to note that in the CDR process, when we talk about medical improvement, that medical improvement has to be related to ability to do work. It involves a decrease in severity of the impairment and that decrease is related to an increase in residual functional capacity, so there are individuals who may have medical improvement, but that medical improvement cannot be connected to an increased improvement in the ability to do work or related to their ability to do work, and that's taken into account in the CDR process, and those individuals probably will not have their benefits terminated. Again, the MI not related to the ability to do work is the opposite: A decrease in severity of the impairment but no increase in residual functional capacity. Before we get into the actual decisional tree of CDR, which can be incredibly confusing, I'd like to start out with what we call the five automatic unfavorables. These are the five situations where, before we even get into any analysis under the full CDR, the individual's benefit -- will have an unfavorable CDR determination. The first, if it's determined that a provider -- prior decision was fraudulently obtained. Second, the individual does not cooperate with SSA. And again, this relates back to your role as the BPAO and the PABSS. You can help assure that that individual continues to cooperate with SSA so they didn't become one of the five automatic unfavorable decisions. SSA cannot find the individual. Again, you can be encouraging the individual to keep up with Social Security, giving current information, answering their questions, filling out their forms, because people will receive an unfavorable decision if they do not -- if SSA cannot find them. And in the case of not finding them, they'll suspend the benefits until they can find them. The individual fails to follow treatment expected to restore ability to engage in SGA is another unfavorable. And then finally -- and you know this from your work as benefits planners and PABSS -- if you're currently engaged in SGA and you've completed your trial work period and your extended period of eligibility, as we know, you are no longer eligible for benefits outside of those two, trial work period and the extended period of eligibility. That's something that you advise people on every day. The CDR sequential evaluation has these five automatic unfavorables within it. I like to separate those out at the beginning, to make it less complicated, because if an individual falls into one of those five categories, they're automatically going to get an unfavorable decision. The sequential evaluation is not the same as the initial eligibility standard. There has to, in most cases, be medical improvement and the tree follows a different way of determining whether or not the decision is going to be favorable. Again, it results in very few unfavorable decisions, and individuals -- although the CDR process is very scary, you can be advising individuals that it is not an automatic that their benefits are going to stop, that in very few cases are there unfavorable decisions. Another important thing that you can be advising as the PABSS and the BPAO, as we know from the diary dates, is making individuals understand that this is a natural part of receiving benefits from Social Security. This is something that everybody has to go through. It's not because -- necessarily because you're working, if it's a diary date, but it's something that is put into place for all individuals to go through this process as needed when they're receiving benefits. And that it is something that they are not being -- they're not being picked on or they're not being singled out, but this is a natural part of the process. The CDR sequential evaluation process is extremely confusing. If you are the type of person that likes to look up regulations and read through regulations, you can read through those regulations. On first glance, in reading through them, you see that it does not follow a nice Step 1, Step 2, Step 3, Step 4. Rather, it does things like Step 2, go on to Step 5, go back to Step 3. It's a decisional tree that makes loops, goes around, and almost sort of collapses into itself. So that's why I think it's best to learn the entire CDR process by just working your way through the tree in different situations. If you do, you will find that there's really 15 scenarios in the CDR process -- 15 possible scenarios -- for coming up with decisions. I've laid those out in the PowerPoint, and you'll begin to see a pattern and you'll begin to understand the flow of how the sequential evaluation process goes. But I think it's simplest to learn the sequential process by just utilizing examples. For those of you who are better learners through conception of how the tree is, I can re- -- you can look through the regulations. Those might be helpful. But in general, for those of you who learn better by conception, we're asking a couple of different questions. The first question that's asked for the DI beneficiary is always SGA. And that's why I put that in the five automatic unfavorables. But we're also -- the CDR process also asks about whether or not you meet or equal a listing. Then it goes into medical improvement. But it has exceptions to medical improvement, and then if you do have medical improvement or you have exceptions to medical improvement, they're going to look at whether or not it's related to -- your medical improvement is related to work, and if they can't -- if they can find medical improvement and they can find it's related to work, or you fall under one of these exceptions, then SSA is going to look at do you have any disabilities. And once they determine if you have any disability, they have to go through almost the initial eligibility sequential evaluation again. Is that a severe impairment? Does that impairment cause you to not be able to do your past work? Does that impairment cause you to not be able to do any work? In order to get to the favorable or unfavorable decision at the end. Like I said, for those of you who like to learn by example, which I think is the majority of people as the best way to get the flow going with the decisional tree, I think we should go through all the different possible scenarios in the -- in the CDR process that individuals go through. Let's start with the easiest one, and we'll work our way down the decisional tree. The first question that they're going to ask is if the individual has an impairment that meets or equals a listing. If the individual does, they're going to have a favorable decision. That's the end of the process. That's why we've put it as No. 1, because it's the easiest. Let's say that an individual does not have an impairment that meets or equals the listing. The next question we're going to ask is: Has there been medical improvement? Let's say that there's been no medical improvement. The next question they're going to ask is if the medical improvement exceptions apply. And we're going to go over those briefly in a moment. If their impairment doesn't meet or equal a listing, there's been no medical improvement, and the medical improvement exceptions do not apply, again, we have a favorable decision. Let's go through the medical improvement exceptions. The first one is substantial evidence shows that you have undergone vocational therapy related to your ability to work. So for those individuals who have not had any medical improvement, if that individual has undergone vocational therapy related to their ability to work, that individual is subjected to the medical improvement exception, and we have to move on in the decisional tree. Substantial evidence shows the individual is a beneficiary of advances in medical or vocational therapy or technology related to the ability to work. Again, if they find this, that's a medical improvement exception and we have to continue down the decisional tree. If substantial evidence shows that based on new or improved diagnostic or evaluative techniques, the impairment is not as disabling as was con -- considered at the time of the most recent favorable decision, this is a medical improvement exception and we have to go on in the decisional tree. If substantial evidence demonstrates any prior disability decision was in error, even if you've had no medical improvement, we have to continue down the decisional tree. And then finally, for the SSDI beneficiary -- and this is our -- one of our five automatic favorable – unfavorables, if the individual is currently engaged in SGA and has completed the trial work period and extended period of eligibility. Actually, for SSDI beneficiaries, this will take you out of the decisional tree, and you will have an unfavorable decision. So we've gone through the medical improvement exceptions. What happens when one of these applies? If an individual does not meet the listing, there's been no medical improvement, but they have medical improvement -- one of the medical improvement exceptions does apply, SSA is next going to look at the level of impairment. If there's no severe impairment, then the individual is going to receive an unfavorable decision. Again, working our way down the decisional tree, if they have not met a listing, if there's been no medical improvement but we've got a medical improvement exception that applies and we do find that there's a severe impairment, the next question we need to ask is: Can the individual do past work? If the individual can do past work, they get an unfavorable decision. Scenario No. 5, you can start to see the flow of the pattern of the questions that we're asking. They don't meet a listing, there's no medical improvement, the medical improvement exception applies again, there's a severe impairment but they cannot do their past work. We're going to ask: Can they do any other work? If they can do other work, they get an unfavorable decision. No. 6, again, we have no listing, no medical improvement, medical improvement exception applies. We look to see if there's been a severe impairment -- if there's any severe impairment. We find that there is. We find that they cannot do their past work and they cannot do other work. Then, the individual will have a favorable decision. The next scenario, let's get into the scenarios where there has been medical improvement, because this is not the end of the story. We have to make our way, again, down the decisional tree. If the individual does not meet a listing, there's been medical improvement but that medical improvement is not related to the ability to work and there's no medical improvement exceptions, they'll get a favorable decision. No. 8, if there's no listing, no medical improvement, the medical improvement exceptions do not -- medical improvement is not related to work, the medical improvement exceptions apply and there's no severe impairment, we have an unfavorable decision. If there has been no listing, medical improvement, it's not related to work, the medical improvement exception applies, there's a severe impairment and you can do your past work, you get an unfavorable decision. Keep going down the decisional tree. There's no listing, there's medical improvement, it's not related to work but the medical exception rules apply, there's a severe impairment, you cannot do past work, but you can do other work, you're going to get an unfavorable decision. If you don't meet a listing, there's medical improvement, it's not related to your ability to do work, the medical improvement exceptions that we've gone through -- one of those -- applies, we find you have a severe impairment, you cannot do your past work, you cannot do other work, you get a favorable decision. Let's get into some easier ones, where there's been medical improvement related to work. And there's been no medical improvement exceptions that apply. If you have no listing, there's medical improvement, it's related to the ability to do work and there's no severe impairment, you get an unfavorable decision. If you have that severe impairment, but you can do your past work, you're going to get an unfavorable decision. If you have that severe impairment, you cannot do your past work and you can do other work, you're going to get an unfavorable decision. And finally, you have the severe -- you have medical improvement, it's related to the ability to work, there's a severe impairment, you cannot do your past work, you cannot do your other work, you're going to get a favorable decision. Now, I know we went through those very quickly, and probably you didn't get a chance to really think them through. What I would suggest that you do, after this broadcast and after the questions, is take some time to read through those scenarios again and you'll begin to understand how the decisional tree works. A lot of that is repetitive, I know, and a lot of it at this point may not seem to be jibing much in your head, but it will if you just look through and look through the pattern of what we do in the CDR process. You're looking for medical improvement. First, you're looking to see if they meet a listing. If they do, you're okay. If they don't, we look at medical improvement, but then we have several exceptions to medical improvement. Even if there is medical improvement, then look to see if it's related to your work. If it's not related to your work, then you may be okay. Again, though, the exceptions come into account. And then, if there's been medical improvement and it's related to your work, SSA wants to make sure, before they say that you're no longer entitled to benefits, that there's not some other severe impairment that causes you to not be able to do your current work or your past work, so they do almost an entire eligibility determination again. And so I've laid those out because when we're working with individuals, you can look to and see what kind of situations the individuals are in, or what they're going to need to prove in the CDR process by laying out those 15 examples. Those 15 examples are it. Everybody fits into one of those 15, and you can determine whether it's a favorable -- and SSA determines whether it's a favorable or unfavorable decision. So for those individuals advocating on their own behalf, that can be used as a key to help them reach a favorable decision. What kind of evidence they need to come up with to demonstrate their continuing eligibility for Social Security. After SSA goes through this entire process and makes a decision, the individual will receive the written decision. If they disagree with that decision, they have 60 days to file a request for reconsideration. Again, this is similar to what we learned in overpayments last week. It's similar to the initial eligibility determination. You file your appeal by filing a request for reconsideration. And then it follows the regular appeals process, the administrative law judge, the appeals council, and the federal court. This is a very important thing for you to be telling clients who get unfavorable decisions. They can continue to receive benefits pending an appeal, but the individual must affirmatively request that the benefits continue, so that's one thing that you can tell individuals if they do get unfavorable CDRs and they are appealing, to make sure when they go in, that if they want to, that they request that the benefits continue while this appeal is pending. And the benefits can continue through the ALJ decision. So this is a little different from the overpayment process we talked about last week, where they start recouping before -- or during the ALJ decision stage. When it comes to CDRs, individuals can keep the status quo through a decision from the ALJ, but they must request, when they file a request for reconsideration, and again when they file a request for an ALJ hearing, that those benefits continue. This request has a very short time line on it. 10 days. Individuals have to get their request in for pending -- for benefits to continue within the 10 days. And then unfortunately, if in the end the unfavorable decision is upheld, that individual will be charged with an overpayment. So people need to be aware that that could result, if in the end the continuing disability decision is unfavorable. Many of you are already familiar with the Section 301 exceptions in the continuing disability review so I'll just mention that briefly. Section 301 allows benefits to continue despite medical improvement, but the individual must be participating in an approved vocational rehab program and this participation must increase the likelihood that the person will be permanently removed from the rolls. So what Section 301 does, if there has been medical improvement and an unfavorable decision, the benefits will continue, despite that, while they participate in the rehab program. Of course the individual must have begun the program prior to the disability cessation. Individuals can't subsequently, after getting a bad CDR determination, unfavorable CDR determination, decide to sign up for a voc rehab program to have their benefits continue. One last issue that I want to mention that I think is an emerging issue that's coming up frequently and know those of you who are listening who are in round 3 states, you may not be as familiar with this yet, but our round 1 and round 2 states, this issue probably has emerged, and so I want to mention it just so that everybody knows that it's coming and can be looking out for it if it hasn't already occurred, and this has to do with the CDR protection and the ticket assignment. The CDR begins on the date of the notice that states that SSA is going to begin to review the disability case, so when an individual gets a notice of a CDR with a date on it, that's when it's considered to begin. For ticket assignment, the ticket is assigned when the EN submits it and it's received by Maximus. Here is the problem that we've seen out amongst -- particularly in 1st round and 2nd round states. Sometimes there's a time LAN between the handing over of the ticket and the actual receipt by Maximus. So in other words, sometimes individuals will hand their tickets in to the voc -- the state voc rehab or the EN and believe that their ticket has been assigned, but that particular counselor or staff person has yet to go through the process of assigning that ticket and handing it in to Maximus. Sometimes what can happen is, during that lag time an individual could receive their CDR notification. Now, that individual personally believes that they've assigned their ticket, but Maximus and the EN have not done their part -- or Maximus -- well, actually Maximus hasn't received it yet but the EN hasn't done their part yet to make sure that that's ticket assigned. This is why we want to encourage consumers to follow up with the EN and make sure that that EN, that ticket is not just sitting in a file somewhere. That it's actually being assigned. PABSS in particular parts of the countries have been very successful in resolving these close-call issues, where an individual believes that they assign their ticket so they have the CDR protection, but the EN has not yet assigned the ticket with Maximus during that lag time. So I encourage all of you BPAOs to refer those types of cases to your PABSS so that they can resolve this issue of when the ticket is actually assigned and when the CDR actually begins. Some of the PABSS around this country have been extremely successful in assisting individuals in getting those CDR cases terminated because the tickets should have been assigned. But I want to make you all aware of that so you're encouraging your consumers to make sure the EN assigns the ticket and if you do find a consumer in that situation where they get notice of a CDR that they thought they assigned their ticket, that's a perfect case to go over to the PABSS project to work with SSA and with Maximus to resolve when the CDR actually began and when the ticket was actually assigned. At this point, I'm done with my presentation, and will take questions through the e-mail about the CDR issues for the next half hour. >> TERI BLANKENSHIP: Thank you, John. Well, we hope that you found this webcast helpful, and now it's time for our live chat session. And this is where you can submit your questions to John and there's a link to the chatroom on the webcast page. That will take you to a new web page where you'll see the chatroom. And give that a couple of seconds to pull up in your browser. Once you've done that, you should see a text field at the bottom of the chatroom where you can type in your questions and then hit your "enter" key which will submit the questions to John. If for some reason you can't submit your question today in the chatroom, you can e-mail John your questions throughout the week, and we'll have his e-mail address on the web page. Thanks again for joining us, and we'll join you in the chatroom in just a few minutes. (Webcast ended)