Chanced to visit my local 01 FFL late last week. He told me he has been informed by our "local" ATF "agent" that under threat of losing her job and pension she no longer has any discretion for infractions - even those that amount to very minor errors, mistakes, or oversights resulting in no-harm. She told him that the next (and first) mistake he makes may be his last and this is all the result of an edict from "on-high" and applies to all FFLs everywhere.

My FFL has always been very fastidious and always triple checks any paperwork I turn in. He's an ex-LEO, very bright, and detail-oriented. He has never had so much as a warning on any kind of infraction. Local ATF agent was virtually apologetic according to him but it's making him nervous I could tell.

Have those of you in possession of a 01 FFL been informed of anything like this? I am a lowly C&R FFL holder and hence do no transfers but have heard nothing "officially" about zero tolerance of any mistakes. Guess I always imagined there isn't, and shouldn't be, any wiggle room but is the removal of the local agent's discretionary power new?

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Ordnung muss sein
SWHF #789

the obvious object is to make gun ownership or transactions very difficult or next to impossible

Clinton made the rules for having an FFL much harder and eliminated many thousand FFL holders. Just an effort to eliminate more FFL holders so there will be less places to obtain legal firearms.

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Bill

13% budget increase for ATF

Post #19

Lots of Alphabet Agency apologists in that thread, but it's pretty obvious that the pressure is on if you're doing business in the firearms industry.

If you can't make the guns illegal, just make it as hard as possible to get one.

We are from the government, and we are here to help you.

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Made it, Ma! Top of the world!

My guess is the agent was letting too many small infractions go.

I think its likely she was not in the infraction range of other agents.

My guess is that someone is putting pressure on the ATF to help with their anti gun agenda.

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protocalldesign.com

Yes, any inspection/audit of an FFL is now ZERO TOLERANCE effective now. I have spent hours going over my bookwork and 4473 forms for any small errors. Agents do still have a very slight tolerance on certain errors.

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Super Snooper

One big issue for folks that work in law enforcement is that people only want laws enforced against others.

Do your job and no one likes you; don't do your job and no one respects you.

WHEN A FELON'S NOT ENGAGED IN HIS EMPLOYMENT (his employment)
OR MATURING HIS FELONIOUS LITTLE PLANS (little plans)
HIS CAPACITY FOR INNOCENT ENJOYMENT (-cent enjoyment)
IS JUST AS GREAT AS ANY HONEST MAN'S (honest mans)

OUR FEELINGS WE WITH DIFFICULTY SMOTHER (-culty smother)
WHEN CONSTABULARY DUTY'S TO BE DONE (to be done)
AH, TAKE ONE CONSIDERATION WITH ANOTHER (with another)
A POLICEMAN'S LOT IS NOT A HAPPY ONE

AHHH
WHEN CONSTABULARY DUTY'S TO BE DONE, TO BE DONE,
A POLICEMAN'S LOT IS NOT A HAPPY ONE.

WHEN THE ENTERPRISING BURGLARS NOT A'BURGLING (not a'burgling)
WHEN THE CUT THROAT ISN'T OCCUPIED IN CRIME (-pied in crime)
HE LOVES TO HEAR THE LITTLE BROOK A'GURGLING (brook a'gurgling)
AND LISTEN TO THE MERRY VILLAGE CHIME (village chime)

WHEN THE COSTER'S FINISHED JUMPING ON HIS MOTHER (on his mother)
HE LOVES TO LIE A'BASKING IN THE SUN (in the sun)
AH, TAKE ONE CONSIDERATION WITH ANOTHER (with another)
A POLICEMAN'S LOT IS NOT A HAPPY ONE

AHHH
WHEN CONSTABULARY DUTY'S TO BE DONE, TO BE DONE,
A POLICEMAN'S LOT IS NOT A HAPPY ONE (happy one).

The Gala Ensemble - A Policeman's Lot Is Not A Happy One - YouTube

A Policeman's Lot Is Not A Happy One - YouTube

I have no problem with the basic premise of Zero Tolerance. FFL dealers are supposed to be audited/inspected every 3 to 5 years. Many of you know how many years I've had an FFL. Inspections? Audits? Guess.
AFT, if you are reading this, where ya been?

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Super Snooper

After careful consideration...I have come to the following conclusion: FFL's aint running the corner lemonade stand, they are selling guns...to potentially horrible people with nothing but the worse of intentions. Are the rules and procedures they have to follow ambiguous and/or subjective? I have never heard anyone claim they are. So, if nothing else this will force sloppy record keepers to clean up. Anyone pushing the envelope and taking chances should be purged from the industry. The FFL's remaining, crossing T's and dotting I's can charge more and enjoy the reduction in competition.

Could be just the variation in geography, workload, or agent's personality but my FFL stands for an annual audit, every single year he tells me, and one or two "drop-ins" by the local agent annually. He's had no difficulties but has now been served notice that the smallest of errors or omissions may result in his FFL being revoked.

This "zero tolerance first strike and you're out" is what I'm curious about. I appreciate pawngal's info on receiving what sounds like the same info as my FFL. "Yes, any inspection/audit of an FFL is now ZERO TOLERANCE effective now. I have spent hours going over my bookwork and 4473 forms for any small errors. Agents do still have a very slight tolerance on certain errors."

I deal frequently with regulatory agencies and their personnel; though the BATFE is generally not among them. Most state and federal regulators have "some" discretion when it comes to "incident reporting." If BATFE has formally ordered their agents/inspectors they cannot exercise discretion - that's news.

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Ordnung muss sein
SWHF #789

Thank you Rodan! This was the info I was looking for and it makes sense it's already been covered on the Forum. This is a good click through article and very informative. Thanks!

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Ordnung muss sein
SWHF #789

In the North End of Columbus, is a large FFL gun store. In the 80's they told me a slow day was 400 transfers!

I noticed they were audited more and more frequently by the ATF/BATF&E. I ask a friend that worked there what was up? They had become the #7 dealership in the nation for guns used in a crime! and 75% of those guns came from one cabinet! (think cheap!)

PawnGal sells guns, but they must not be in her shop very often tracking down who bought which gun used in a fatal robbery, or drive by, or murder.

Ivan

Close to never!

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Super Snooper

I did regulatory reviews and enforcement for 12 years, and liaised with the data unit as a program subject matter expert who also knew data.

Your thoughts are a superb example of performance management gone horribly wrong.

She may also just be a very good agent who:
- has a good rapport with the FFLs in her area who are willing to proactively surface any questions on gray areas;
- has the ability to effectively teach and provide technical assistance to prevent problems; and
- drops in often enough to ensure any new staff are up to speed and or aware of why accuracy and careful QA processes are important and also ensure that veteran staff don’t become complacent.

In that environment finding fewer errors during formal reviews is not just very desirable but also inevitable. It should be the goal.

Instead, I often saw poor performance management similar to what you suggest where fewer findings during reviews were seen as evidence of being “too easy” or not thorough enough during reviews.

Paradoxically, reviewers who found too may infractions were discouraged from doing so as it made the agency look bad when too many infractions were found. In short, there’s often a narrow envelope of desired occurrences of findings. It pretty well dooms regulatory enforcement to some level of mediocrity and removes the incentive to actually improve performance in the field.

It sounds like ATF is just moving that envelope all the way to the right and wanting its agents to lean hard on FFLs to find cause to reduce the number of FFLs, under the guise of ensuring that guns are not sold to prohibited individuals.

That’s evidence of another regulatory problem. If the ATF bases it’s own performance metrics and goals on reducing actual sales to prohibited individuals and straw purchases, it would be required to ensure its agents actually worked more collaboratively and effectively with FFLs. That involves all kinds of qualitative methods and measures and it requires hiring and properly training agents that have strong soft skills who can accurately assess, read people well, community well and provide useful field based technical assistance to improve how FFLs attains and maintain compliance to reduce sales to prohibited individuals.

But it will never be perfect as people with no criminal records but criminal intent will still legally buy a gun, and people with criminal records will still be get one now and then from a scrupulous FFL because some police department or court system failed to properly upload a conviction.

So…the ATF takes the easier route of zero tolerance. It won’t reduce the guns getting into prohibited hands but it will let them revoke more FFLs and make it look like they are reducing the ability for criminals to get guns.

Back in the '70's the ATF shut down several local small gun shops. They did it in conjunction with the IRS. If any quarterly tax payments were even slightly late, they shut you down.

About 20 years ago I bought a gun at a medium sized shop. When doing the 4473, the owner stood watch over me like a hawk. I could not type XX for the state, it had to be spelled out in full words (even though the block only allowed 2 letters). Also, my address could not say Rd. It had to say ROAD.

He told me the local agent was cracking down.

With all my old friends now out of business, mostly all I have left is cabellas, and don't know anyone there.

Last week I was talking to a retired gun Smith who also does some reloading. I don't know which license he has but he was telling me pretty much the same thing as the OP stated.

A shop, I do not frequent, in a nearby town shut his doors volunteerily because he was not the best at his paperwork trail according to this guy. He had been warned about it but paperwork apparently is not his Forte.

The guy I was talking to said he has a person that calls on him around once in 4 years or so and explained some requirements for having paperwork for retired and active duty soldiers, it sounded pretty ticky tacky to me.

He said they are not messing around and giving many chances and keep adding little regs here and there that they have to keep up on. Why would anyone be surprised by this?

I had to scrub my 1st response. About 7 or 8 years ago I bought a Colt's 6920 from the local WalMart. Filled out the electronic 4473 as instructed, it was checked by the counterman and their own "QC program" and away I went. Got a call maybe a week later to come back to the store because I "entered" St Cloud instead of Saint Cloud. Their program auto corrected. I went back and fixed it, all was well. Some of the BS started back-a-ways. Joe

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Wisdom chases me; I'm faster

Look at all the bootlickers in this thread.
Just wait until the same standard visits you in the form of an IRS audit, or something "problematic" you posted on an internet forum. And your neighbors will say, "Well, there must have been some other circumstance we aren't aware of. If you haven't done anything wrong you have nothing to fear." as they close their blinds and cower in the dark every time a black SUV drives down their street.

Wow! Less coffee, maybe?

I acquired a FFL in '76 or '77 that I used to help local customers of my gas station/novelty/convenience store. When the ATF agent made his initial visit, he did a thorough explanation of the rules, looked over my building, made a suggestion on storage, then went away. Never saw another one and sent in my license and records in '79 or very early '80.

During the ATF visit, the agent mentioned that if I had not had an actual business location (that was not my home), my application would have been rejected. He said they were reducing the number of licensees just using an easy-to-obtain FFL to avoid local purchase/possession regs.

This thread reminds me of a sweet elderly lady customer from years ago. Nice lady, but definitely a little nuts. She kept tin foil taped to the front of her oven door...evidently the government had surveillance equipment planted in there to spy on her.

Working together to achieve a common goal? Oh, dear me, NO! Not enough governance and enforcement going on for certain people in that plan.

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Release the Kraken

Not since they tapped into your flat screen TV.

[QUOTE=BB57;141541252]I did regulatory reviews and enforcement for 12 years, and liaised with the data unit as a program subject matter expert who also knew data.

Your thoughts are a superb example of performance management gone horribly wrong.

She may also just be a very good agent who:
- has a good rapport with the FFLs in her area who are willing to proactively surface any questions on gray areas;
- has the ability to effectively teach and provide technical assistance to prevent problems; and
- drops in often enough to ensure any new staff are up to speed and or aware of why accuracy and careful QA processes are important and also ensure that veteran staff don’t become complacent.




I took it as the higher ups were possibly being too lazy to even ask or analogize why. Many jobs seem to judge by the masses.

I spoke with a state policeman who told me that part of his performance is judged on the amount of violations given. Also a local officer who runs a speed trap right next to my house had a similar thing to say and added how much police presence on my street is gauged on how many violators come by per hour.

Both officers do have discretion who to just warn.

If i had to guess at another probability, it would be an auditor looking at numbers of enforcement in a data base. Being reasonable or working towards compliance of a minor infraction likely isn't one of the possibilities when filling in a data base.

Then when someone at a much higher level wants to demonstrate how much they are "cracking down", all they have to do is recite numbers from the data base. Not enough enforcement numbers from a specific individual invites scrutiny of an individual enforcement officer. To increase the numbers in a data base, remove any "discretionary enforcement" .

Discretionary enforcement can also be based on workload, as in like everyone else ya only have time to pay attention to the more serious items.

So enforcement is going to be swift and severe? Is that like fast and furious?

I dealt with the BATF back in the late 90s. Gave me a song and dance about revoking my license because I didn't have a letter from the zoning board saying I could have a gun shop in my location. At that point I had been in business 27 years. We had a little discussion tween him me and his boss They renewed it. I kept it for another year and a half when I developed esophageal cancer. I surrendered my license mainly because I was sick. But they were trying to drive people out of the firearm business for political reasons. Here we go again...It's really ALL about politics folks. The very liberal antis want to make guns and people that sell and own them pariahs. These days where we have instant background checks there are very few criminals that slip through the cracks at gun shops. Now completely honest people who buy guns or give guns to prohibited people through ignorance or ill intent do happen. I once bought a shotgun from a person I felt should not have one...mainly to keep one of the low life friends he hung around with from acquiring it. He was not at that time prohibited...but was an occasional weed user. His "girlfriend" did get him in trouble a year or 2 later. She told the police I supplied him with a shotgun. I had to prove I hadn't. I still had that 870 I liberated from him. The police actually followed up on where he bought the gun. I even had a receipt for the shotgun when I bought it from him. Otherwise I could have been considered as a supplier to a person who later became a prohibited person. BTW...that girlfriend who was the instigator of the problems skated when she sold out 3 others she implicated. reminds me of Red
Flag laws

Are the other Alphabets under the curious eye of the ATf going to endure the same strict 'One Strike and You're Out' Policy.

I seriously doubt it.


I had an 01FFL for 50+ yrs.
I didn't feel good about letting it go, but felt it was time.
Now these couple of yrs later, I know I made the right move.

Back a few years ago I bought a Walther ppk from the Academy store east of us and did the 4473 form and handed them my CCL so they never called the ATF and came home. I got a letter from them to come back and finish the paper work. I had said on the form that I as born in Colville town ship in Benton county Ar. 0n 1/16//40. I got my birth certificate out and went back over there to show them, they said you must show a town, I said in 1940 there was no town closer than six miles to us. I said that I used to hold a FFL and I was not going to lie and say was born in Rogers. Nothing would do for them unless I said that so I did, these folks are IDIOTS and should not be in business. By the way I was born at home on the farm. Jeff

Just wait until those 87,000 new armed IRS agents start auditing the little people.
Perilous time we live in friends and it ain't going to get better anytime soon.

I always thought having a business "Location" and regular posted hours was a requirement for an 01.

A friend recently remarried and his wife wanted to move. When he tried to change the address of his business they wouldn't allow it. He is now out of business.

Dunno. And that was 46 years ago.

This is a requirement, yes. Depending on where you live it can be your home address (that's what I have since 2012).

I moved my business from OK to TX and had no issues. Have an address and fill out the change of address form. They treat lit like a new application though (interview, inspection, etc.), but if your location is fine there's really no reason to be out of business!

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Jorge

There is a local shop who insists on that. And this was a few years ago. PITA IMHO.

Since I don't buy guns there anymore, it's not a problem anymore.

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BTDT, Got The T-Shirt

Last year the ATF posted 5 violations (feel free to Google), that if willful, resulted in Zero Tolerance for the FFL:

1. Transferring a firearm to a prohibited person
2. Failing to conduct a required background check
3. Falsifying records, such as a firearm transaction form
4. Failing to respond to a trace request
5. Refusing to permit ATF to conduct an inspection

Notice the "willful" portion. If these are "willful," they are not minor in my opinion.

Those in bureaucracy and those on the receiving end are both likely to misinterpret or see guidance beyond what the ATF stated.

Of course, there may also be even newer guidance to their Zero Tolerance plan to which I am unaware.

The elephant in the room now is What is considered Willful? Changes made to the 4473 or omissions on the 4473. Is it willful if the date is incorrect? Or an error on the firearms serial number?
Another in addition to the 5 listed I have been told is:
Failure to submit Form 3310.4, Multiple Handgun Sales to the ATF within 24 hours.

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Super Snooper

A home adress is fine for an FFL business IF the local Zoning allows it.
That was the big change in the Clinton era that made a lot of FFL's go out of business.

As far as Hours of Operation.
Thise are to allow the BATFE to do walk in compliance checks w/o notice.
They could care less how oftn you are open to the public. Don't do any business and go out of business, thats fine with them. Your renewal must show the number of Transfers done in the last 3 yrs.

The compliance with local Zoning Laws was one thing that has caused more FFL's to close initially when that was first enforced ('96?) and continues to be the hardest thing to be in compliance with.
BATFE re-checked Zoning Compliance on every Compliance Check they did with me over the yrs after they started enforcing it looking for any changes in local law.
Businesses in a residential zoned district, especially firearms related are often prohibited.
Fire and Security & Storage Law compliance as well as signage, parking, lighting, insurance requirements, compliance with Americans w/Disabilities Act can quickly doom someones efforts to do even a small, discreate firearms related business in a home.

Sometimes the person seeking the license must also apply for a Zoning Variance for the FFL licensed operation. Going door to door around the neighborhood explaining your intentions. Then having to appear and plead your case befor the Zoning Board and those neighbors can have their Yes or No say about it.

It all depends on the locality and their local laws.

The .gov could do a RIF (reduction in force) down to 1789 levels, say maybe 200 employees (the politicians ain't nothing like an "employee"). Print money, raise forces in wartime, yep 200. .gov does nothing well but blames that on lack of funds (our money). Siccing 87,000 more bots with guns to terrorize the American people, just more "non-solutions, of which we already got a surplus. Joe

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Wisdom chases me; I'm faster

[quote=paplinker;141541381]Umm, yeah. No such thing as "quotas", right? Just demerits and punishment for those who don't write the "appropriate" number of citations.

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Send lawyers, guns & money...

Just like my dad. His birth certificate said 6/8/1939 and "Ellington Missouri" - even though he was born on the family farm 15 miles outside the Ellington city limits. Their mailing address was a rural route delivered out of the Ellington PO, so Ellington is what was on his birth certificate. Ah, the good old days!

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Send lawyers, guns & money...

It’s complicated but there is sadly a big grain of truth in this.

On the one hand the 87,000 FTEs proposed are not just agents but also support staff, assistants, IT, HR, etc. The actual percentage of people in a federal agency who end up on the pointy end of the stick is a lot smaller than you’d think. Plus the IRS is down about 20,000 people compared to 15 years ago, and the proposed FTEs also include hiring approval for upcoming attrition, in addition to backfilling positions that have been vacant for years and even decades.

And to be honest we lose a lot of tax revenue to cheats who don’t pay their fair share. I don’t have any sympathy for them.


—-


On the other hand, government is government and government in general has more than its fair share of corruption, due to money, influence and power that uses the congress critters it’s purchased to lean on agencies to look the other way when big money or big states are involved.

A couple examples:

I was brought into a federal agency under the a Bush administration because I had extensive field experience and there was a plan to improve performance in the programs that agency over saw. I worked directly with 7 states as their federal liaison and conducted annual and periodic on-site reviews of state level agencies in a total of 13 states.

One of my liaison states was North Dakota and a state director there (long since retired now) got in a budget crunch through bad planning and poor fiscal forecasting. In fact, I’d led a review there about 9 months prior and warned him he was headed for a fiscal cliff and needed to make changes immediately. He didn’t listen. At this point he saw the problem wanted to reduce services. But the statute and regs are pretty clear that you can’t just bail on what you’ve started as jobs are lost and there is a huge impact on tax paying citizens at the community level. I explained how it worked, and why. Then I provided technical assistance regarding his options, etc and put the response in a formal letter. I then took it to the division director for her signature. Rather than being a rubber stamp she said my response and interpretation of the law was wrong.

She reached into a filing cabinet and produced a letter she’d written to New York in response to the same issue - bad planning and poor fiscal forecasting leading to a massive budget problem and the state wanting to cut services in an illegal manner, and she basically told them that was fine.

She had not run her proposed response across any of the program experienced people in the office and clearly didn’t have a clue. We argued and she decided to put me in my place by calling office of general counsel. We speaker phoned a call with their head attorney. My boss made her case and the attorney then spent a couple minutes explaining what she was correct. However I then added a few things my boss had either left out or wasn’t aware of in the first place. The attorney said “oh…that changes everything and spent about 10 minutes lecturing my boss on why I was right.

Victory right? Well no. After the call she explained that why I ,any be right the agency was not going to change its stance on the issue as the agency would look bad if it changed its position. People might think the agency was not competently running the program. She directed me to edit the letter to conform with her prior letter and send it out.

I pointed out people in the field already knew the agency was not competently running the program, and that actually revising guidance to reflect best practice and how the program should be run would be viewed as a very positive change.

She didn’t care, she said consistency was more important, even if that meant being consistently wrong.

But it wasn’t about the program at all and only tangentially about agency face saving. It was about a big state with a large congressional delegation with a couple heavy hitter senators who could and would lean on the agency if NY didn’t get its way.

I made it clear she’d have to send the letter out under her signature as I would not sign off on something that was so clearly illegal - per our own OGC.

The letter to ND went out under her signature. I advised the ND director to ignore it, but he was under political pressure to do what he’d proposed, particularly with a letter saying he could do it. I told him it wouldn’t matter, his agency would be sued, and lose. He did it anyway, got sued in 77 separate cases and lost them all, having to provide the contracted funds anyway, costing the agency a huge amount in legal fees, looming bad in the process and cascading his budget problem from that year into an even larger budget issue the following year.

But the federal agency was “consistent”. That’s the government we all pay for.



In a other example a review I was in in CA uncovered $12 million in mis appropriated funds (along with a whole host of other issues and counterproductive activities that gutted program performance and increased costs). In essence CA was using program funds to fund things that should have been the responsibility of other people or agencies and was harming the federal (taxpayer) interest.

That $12 million that should have been returned to the federal treasure was eventually, several years later, negotiated down to $35,000. Almost none of the other program irregularities, data manipulation, or inefficiencies were addressed. Again that”s because CA was a big state, contributed about 20% of the total national program’s performance and swung a big congressional club.


——-


So…regardless of the actual intent, when push comes to shove, that bulked up IRS agency isn’t going to spend much time doing large and complex audits on millionaires and billionaires or large corporations with armies of tax accountants to push back on the IRS. They are instead going to spend more time going after the little guys. Probably not the “under $75K little guys” but certainly people and couples making not too much more than that who itemized deductions - and are likely to file their own returns.

My one and only audit experience resulted in the IRS claiming I’d underpaid by about $5K. My accountant got involved to represent me - part of the deal in paying him for the return in the first place.

He was very conservative accountant who knew I didn’t want to risk my security clearance, job, etc, saving a few bucks in taxes so as the audit drama played out it became clear to all involved that the IRS actually owned me about $600. That was a problem for the auditor as he could not go back to his cubical with a net loss on the audit, so he found no I regularities in the return.

There’s no way they’ll go after the big fish, they’ll just increase the audits on the little fish. File your own taxes? You might want to think about using a tax accountant. It’ll be $200-$400 out of pocket but you’ll be better covered.

I'd rather see 87,000 social security disability investigators than 87,000 IRS personnel.

I expect the taxpayers are losing a lot more to disability fraud than they are to folks underpaying on taxes....

That seems to be a local issue then, not a fed problem. I guess we've been blessed doing this in OK and TX, where it appears that people still have some common sense.

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Jorge

This. The "fix" in Las Vegas was to make the licensing of a firearms business very expensive, which is why the most successful stores are in North Las Vegas and Henderson.

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Release the Kraken

That whole system is broken.

How it works now is that state level staff do the eligibility determination and in most states those are not so well educated low wage people who compared words in the medical documentation to medical conditions in a row of books they call “the list”. Basically they use word matching and they deny about 80% of claims up front.

They then force the person applying to spend 2-3 years proving there is nothing they can do, before they finally get to the stage in the appeal process with a face to face with someone. About 80% of them are then approved at that point.

Then, after spending 2-3 “proving” they are unable to work, and in the process convincing themselves they can’t work, and getting a lump sum back payment back to their date of initial application/eligibility they are referred to the state/federal Vocational Rehabilitation program that is supposed to get them back to work.

There are problems with that model. By this time, the person has convinced themself that they can’t work, and they also have a fat wad of money in the bank, with no real incentive to work. The receptionist in the VR office hands them an application and once they apply, the VR counselor has to process the application based on the functional limitation related to employment caused by their disability, their need for VR services, and their ability to benefit from VR services.

The VR counselor knows it’s not going to work, but they get pressure to make the person eligible and the person on SSDI feels pressured to work with VR. They end up wasting a lot of money and staff time over the next year or two, and maybe burn a few prospective employers before the VR counselor closes the case unsuccessfully.

I did VR Counseling fairly early in my career and when a I ran an office, my approach was to have the receptionist send them to me before taking an application. I explained what we did, how we could help them get a job and get back into meaningful self supporting employment. I also explained that there really were no consequences for refusing to apply and that I could see what maybe work didn’t look like their thing at the moment given thet they’d just spent 2-3 years fighting the Social Security administration to prove the couldn’t work. I told them if they decided not to apply that’s fine, but in the future if they decide the small amount they get from SSDI isn’t enough to support themselves or they get bored sitting at home, or feel useless because they don’t have a job that they know where to find ke and I hand them a card.

Now…that sounds like I was enabling slackers, but it worked in the long term. Within a year almost all of 5em would come back highly motivated to work and out office would get the vast majority of them back to work full time in a job that was compatible with their disability and functional limitations.

The kicker was that after a couple years our receptionist/regional office snitch went to a training where it was mentioned we were supposed to take applications for all SDDI referrals amd she ratted my process out to my regional manager who then came down on me for “talking people out of applying”. My response was look at the data.

Since I’d been doing this a couple years by that time, we were seeing the performance payoff on the backend. Our office had just as many active SSDI cases as any other office, but we also had the highest success rate in the state for SSDI client. The state average success rate was was around 10% compared to our 85% - and the folks we could not get to work truly we’re not Abel to work. Our case service costs in these folks were also 2/3rds les than other offices.

I never heard another word about it. It’s nice that they left me alone, but it’s unfortunate they didn’t dive in and replicate the model state wide, and then use the statewide date to push it out nationally. But the state leadership didn’t want to go against the guidance coming from the poorly run federal agency overseeing the State/federal VR program.


In the bigger picture, we do SSDI eligibility wrong. We should remove disability determination from SSA entirely and instead properly fund the state VR program and send SSDI applications to VR up front. Eligibility for SSDI would then be based on the person not being able to engage jn suitable employment consistent with their interests, abilities and limitations after receiving services from a highly qualified VR counselor.

We’d see the SSDI recipient numbers drop by about 85% and wed save an enormous amount of money wasted on SSDI recipients who can work. We’d also be be focusing money wasted on eligibility and appeals instead focused on getting people who can work back to work.


That’s how government should work. We should be focused on a full employment model that puts and keeps people to work at livable family sustaining wages. And, while we should also provide social safety nets we should be limiting it to the small percentage of people who really don’t have any other alternative.

At the same time it can be done, and is more effective, when you do it without coercion and shaming, as most people can be motivated to do things that in the end give them more pride and more self control. You just have to rig the game so they play it to get things that are in their personal, and our public and national interests.

I'm staggered that you weren't squashed like a bug for exposing the faults in the system. One thing we share with the old Soviets is that criticism of the system from those inside it, even when justified, brings consequences.

The way the Western world gets around this is to employ consultants to bring you the facts on how badly you are screwing up. When the facts are presented one of two things happens:

1) The criticism is accepted on the basis of "Yeah, maybe we got too close to the subject". On really good days change even takes place.

2) The criticism is rejected because "the consultants did not understand the subtleties of the culture". That reads "we are all stubborn control freaks here and will never admit we are doing it wrong" to anyone with two brain cells to rub together.

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Release the Kraken

The 87,000 IRS employees are over a 10 year period. That probably does not even cover attrition.

The IRS Special Agents that are actually armed number about 2,200, which is far fewer than in years past. They have been around since 1919...so, nothing new there.

This is all a distortion of facts.

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