April 10, 1997
Ms. Shirley S. Chater
Commissioner of Social Security
PO Box 1585
Baltimore, MD 21235
Dear Commissioner Chater:
On behalf of the National Association of Social Workers (NASW) and our 155,000 members, I want to express my grave concern with the Interim Final Rules for the children’s Supplemental Security Income (SSI) program as promulgated in the February 11, 1997 Federal Register.
Given the great latitude that was given to the Social Security Administration by Congress to design the implementation of the childhood SSI provisions under P.L. 104-193, the agency’s response is both punitive and prescriptive. The impact of the SSI eligibility changes could be devastating, especially for families with children who have mental, emotional, or behavioral disorders. It is these children and their families who are disproportionately affected by the new rules due to the elimination of the Individual Functional Assessment and the removal of the references to "maladaptive behavior". Our specific concerns include the following:
- The new standard is too restrictive and will disqualify far too many children with significant impairments.
- The new standard is too complex and requires extensive medical documentation.
- The new standard does not provide a realistic way to assess children’s functional limitations.
- The new standard may exclude certain categories of childhood impairments.
There is an urgent need to increase and improve the provision of services to vulnerable groups of children, such as children with disabilities. A significant body of research supports NASW’s position that early intervention for children with all types of disabilities benefits their later abilities to succeed socially, educationally, and economically. To state it simply, health is academic. Children who are deprived of basic needs are unable to benefit fully from their educational opportunities. Children who are hungry, sick, or worried about their families cannot achieve as well in school as students who are free of these cares. Thus, their ability to make future contributions to our society is hindered, sometimes irrevocably. Moreover, the short term financial savings cannot offset the social and economic costs to our nation that increase exponentially when necessary supports and interventions are postponed or denied.
In a nation that claims to nurture the full potential of its children and youths, how can we deprive a selected group of children the very assistance that will enable them to participate more fully in normal daily activities?
Thank you for your consideration.
Sincerely,
Josephine Nieves, MSW, PhD
Executive Director
If you have questions, send them to: ckaplan@naswdc.org