Agency Self-Evaluation Under Section 504 of the Rehabilitation Act of 1973
Section 504 Self-Evaluation Rehabilitation Act of 1973
2011-08-17 2011-09-21 2011-11-17
SSA-2011-0035-0002 SSA-2011-0035-0004 SSA-2011-0035-0008
04:00:00 04:00:00 05:00:00
https://api.regulations.gov/v4/comments/SSA-2011-0035-0002 https://api.regulations.gov/v4/comments/SSA-2011-0035-0004 https://api.regulations.gov/v4/comments/SSA-2011-0035-0008
Ramon Larisa Joan
Joseph md Cummings Durocher
Letters from Social SEcurity to mentally disabled cllients shoud be in simple understandable English, not legalese.Their right to have an advocate should be clearly stated. A real telephone number (not a calling center), with  HUMAN being at the othere end should ber provideed.Obtuse regulations like the TRial Work Period should be adequately explained along with the necessary statutory authorization for such rules. The Disability Rights Education and Defense Fund (DREDF), founded in 1979, is a leading national cross-disability law and policy center that advances the civil and human rights of all people with disabilities through legal advocacy, training, education, and public policy and legislative development.  As an organization that protects the civil rights of individuals with disabilities in pursuit of benefits provided by SSA, we are aware that SSAs website is not fully accessible.  For example, SSA provides information about its online forms and publications, http://www.socialsecurity.gov/online/, and lists forms that can be submitted online, but does not separately list forms that are fillable, though some are.  SSA should provide all forms that are downloadable in fillable format and make it clear that the forms are available in this accessible format.  Notably, SSAs SSI application should be available online and in fillable format, like its application for social security benefits.  SSA has recently revamped its website and should take steps necessary to ensure that it meets accessibility requirements.   As an independent federal agency committed to disability policy leadership since 1978, the National Council on Disability (NCD) is pleased to offer brief comments during the Social Security Section 504 Self-Evaluation. Participation in this opportunity is consistent with NCDs mission to be a trusted advisor to the President; Congress; federal entities, state, tribal, and local governments and community and private sector entities. NCD recognizes efforts that the Social Security Administration (SSA) has made to comply with Section 504 of the Rehabilitation Act of 1973 (Section 504), as amended. To continue positive steps under that law and promote nondiscriminatory practices in response to several areas of concerns highlighted by members of the public, NCD encourages SSA to include within its self-evaluation some actions that can be incorporated in SSAs strategic plan. At the same time, focus is needed on changing the fragmented nature of service and support delivery systems that also are plagues with uneven access for many people with disabilities. An earlier NCD report  highlights ongoing needs across federal agencies for program, service, support, and systems reform to address variables such as age, gender, ethnicity, disability category and use of federal programs. Reform efforts need to consider the countrys changing demographics, different eligibility criteria, rising need, and other diversity aspects of disability. In this vein and based on input from members of the public, three recommendations are offered to SSA during the Section 504 self-evaluation agency as follows.Recommendation 1: Developing Universal Standards. NCD suggests that SSA should give consideration to identifying and implementing steps that can lead to universal standards of conduct for application across all SSA locations. A thorough review of various SSA settlements, consent decrees, court orders and related complaint resolutions can be used as a starting point. Consideration 