Section 501.3 (e): Comment from Donald Streeting, SSA, DCHR, OPE, CPSPM

While we agree with the intent to make the filing of an appeal uniform, we strongly recommend that it be 90 days instead of the proposed 180 days. Ninety days is more than sufficient time to file a claim in light of multi-media technological advances and overnight delivery. To needlessly extend the time limit 3 more months merely delays a final resolution and further overburdens an already overburdened system. Ninety days is more than ample time for a claimant to submit an appeal, worldwide. For those who are unable to meet the 90-day deadline, provisions have been provided for "compelling circumstances". Additionally, we strongly recommend providing a clear statement that the ECAB decision is final and binding. The appeal process already provides unlimited reconsiderations before it reaches the ECAB level of appeal.