Alan Nussbaum Comment

Publication Date
April 9, 2013

It appears my prior comments were ignored.The appeals council at the moment does nothing for the most part except hold a denial for a year or more and affirm the an ALJ's denial.Our federal courts in Arkansas are extremely conservative and affirm most denial as does the 8th Circuit Court of Appeals.If you wanted true reform you would abolish the local district offices and let disability determination take an appliication and make a determination abolish reconsideration and have an adversarial hearing, abolish the appeals council and let the courts make a determination.The government will keep the ALJ from wearing two hats both to protect the trust and be fair to the claimant.This is a conflict of interest and you could have uniform decisions. You are headed in the wrong direction.The Appeals Council serves no useful purpose.Hearings should be adversarial.