Get the State Attorney Generals involved. If cease and desist letters don't open their eyes maybe a few subpoenas will. Don't give up, there are people watching.

Can you please file any additional complaints that you have with the CRCC. I have feeling the CRCC is going to want another shot at this menace. They need a complaint and the documents to act.

Can you provide a list of email addresses for regulators and agencies so that a mass email campaign can get the word out? I get the impression the Insurers are using CRC's as loaded guns to execute claimants and the body overseeing these experts has no control. I see a crisis that needs to be addressed by regulators.

This site is opening one very big can of worms.........

1. The records of the Ethics Committee regarding complaints are confidential except as provided herein. a. All information concerning complaints against Certificants shall be confidential except that the Committee may disclose such information when compelled by a validly issued subpoena or when otherwise required by law or valid court order.

Thank you so much for all of the helpful and informative comments. This web site will strive to be fair while seeking change. Regarding recent CRCC actions please see "Recent Updates" on the home page. Does anyone believe the insurance industry learned a lesson from the UP claim settlement? Same nonsense, different victim. Visitors and contributions (even if anonymous) to this site are on the rise for the following reasons - 1. Interest in "change" for the public good 2. helping the little guy/gal 3. Fighting for the integrity of one's profession 4. search engines 5. a distrust of the insurance industry. Thanks again. This web site and awareness campaign is back in full swing.

After reading this material it is very easy to see how the insurance companies can manipulate the DOL ERISA claim procedure 29 CFR 2560.503-1 to save themselves mammoth sums of money. Using so called experts to justify questionable actions the claim denial/appeal process is used to wean out claimants w/o the resources to maintain the battle. Looking forward to the further updates.

The site should reevaluate it's position on the home page regarding CRCC Complaints in ERISA. The CRCC ethics committee has numerous tools to help folks wronged by certificants. For example, the case posted on the homepage probably generated Cease and Desist orders, advisory opinions, letters of instruction and suspensions. The CRCC will not allow certificants and their employers to devalue the Code of Ethics or the profession. Good luck.

The CRCC does have a tool at their disposal when an ethical violation is difficult to find. It is called a "Letter of Instruction". The letter of instruction is a type of disposition status adopted in 1997. It does not involve a judgment that there was an ethical violation. Rather, it represents instructive advice to the certificant to clarify and improve the best standard of ethical practice.

Thanks for the information. I learned a lot about the process and my rights.

Where are the regulators? This type of "expert" rope-a-dope with the claimant is ridiculous. It is easy to see the millions ($) upon millions ($) the Insurers can save themselves deploying these tactics. Why are counselors letting themselves be played like this? They know damn well one-sided input creates one-sided output. All rehabilitation counseling education programs teach that.

After looking at those documents I wanted to puke. The Insurer and the VE's collectively distorted every possible 50/50 to create a conclusion that could have just as easily been interpreted the other way. That is not a coincidence. Disappointing is all I can say.

WOW!!! I'm not sure who to point the finger at - the insurer or the vocational experts. It's all bad for the claimant. That is an ugly case.

I can not believe three CRC's had the documents and could not figure out the correct DOT occupation corresponding topast work experience. A real injustice. In my opinion this case stinks and the client got a raw deal.

Can you put the documents related to case study online before the expert analysis? I would like the opportunity to review the material before seeing the expert analysis to draw my own conclusion.

Thanks for the helpful and thoughtful comments. This awareness cmpaign is in its infancy. Regarding the S of Understanding, it is only useful if the CRCC enforces it. Regarding ethical advisories and whether they are incorporated in the Code, it is unclear like many of the gray areas being exploited for personal enrichment. Social Security does have "standards" for TSA's while ERISA does not. Without standards you are looking at junk science that is easily manipulated to produce outcomes.

It is not clear if a violation of an ethical "advisory" is the same as a violation of the Code. The Code does not technically incorporate the advisories. There is still too much latitude for funny business with all the money that is being paid by the insurers. Keep up the good work. I'm glad someone is asking questions. P.S.- I think Sleister wrote an article regarding ERISA and VE's.

I am a corporate recruiter. There is no way the subject individual in Case Study One is employable in a management or supervisory position given the circumstances. Especially the heavy doses of narcotics. Any Rehabilitation Counselor proffering the nonsense in the questioned TSA needs a healthy dose of reality.

The CRCC has no reason to fear the Insurance Industry when it disciplines one of its Rehabilitation Counselors. The CRCC should take a firm stand with the power it is granted in the CRCC Application. The "Statement of Understanding" contains the following: By submission of this application for certification, I specifically waive any right that I may have to seek an external review of any decision, including but not limited to judicial review by CRCC to grant or not to grant, to revoke, suspend, or otherwise affect certification, and/or to impose discipline and otherwise enforce its Code. I specifically release CRCC from any claim that I now have or may in the future have against it for any decision that it has made or will make involving my right to certification and my adherence to the Code... I further agree to indemnify and pay CRCC any costs, including attorneyâ??s fees, which it may incur in the defense of its rights as outlined in this agreement. The provisions contained in this application do not preclude an action under state or federal law nor are they applicable to the extent prohibited by such laws.

How long does it take for the CRCC to respond to a complaint? Will they ever render a TSA invalid? What is the point of filing a complaint in an ERISA case?

Why aren't there specific standards for doing transferable skills analysis like Social Security? It seems any result can be produced for the right sum of money in non Social Security cases. That is not right.

Bravo!!!! Excellent site.

Found your site doing research. I agree that rehabilitation counselors working for the Insurance Industry must be held to the same standard as the rest. The goals of the Code do not mesh with the profit motives of the Insurance Industry.

The TSA in the case study would not produce the TSA results following any material from Growick, Dunn, Field & Field, Simon,Skilltran,OASYS, O*NET. JMHO

Dr. Field, Thank you for your comment however the "who" has been answered below in the Guestbook. There is no pay, just some folks that witnessed the harm that occurs when CRC's let themselves be the pawns of the Insurance Industry behind a veil of "objectivity" in ERISA claims. Please help us out if we are so wrong: Regarding the accusation of "misinformation" can you please provide specifics. We will remove same if you are found to be correct. Regarding the CRCC can you please provide a public link to the names of the members. TheTSAScam asked numerous questions in the "case study" section of the site and would appreciate your insight. Please note that Dunn and Growick's article was not the only material studied, surely you are familiar with "How to Conduct Comprehensive Transferable Skills Analysis (TSA) in Vocational Rehabilitation (VR): The Human Services Outcomes (HSO) Approach --Steven E. Simon, Ph.D. , C.R.C, C.L.C.P . You will note your name is prominently mentioned in the footnotes and references. We look forward to your comments and specifics on "misinformation".

It's time to face the elephant in the room.

Your website, like many others, can provide reasonable information and discussion on a variety of topics - such as TSAs. In my opinion, your reliance on the one article (Dunn & Growick) is not representative (although well-written) of all the work that has been completed on TSAs. Besides, the Dunn and Growick article is but one view of how TSAs might be completed. There is a wealth of information on this topic and I would strongly suggest that you become familiar with this body of knowledge (covering nearly 30 years) before you proceed further with your mission. Regarding the CRCC and their Ethics Statements, I think you are incorrect regarding how they provide information about their program. The Commission has a history of being very open, democratic and informative about their proceedings. The names of people on the various committees are available as well. In that regard, I looked for who you folks were -- by names and background, and there is virtually no information. I am asking now: who are you? your backgrounds? who you represent? and/or who pays your salary? This would be a good addition to your website. I think with more information and an understanding of the TSA process and methods, there would be less need for your anger and misinformation. If you need help in finding TSA information, let me know - I have been publishing in this area for 25 years.

The TSA in the case study is very troubling if the facts are being presented fairly. Changing the SVP and Strength to produce a desired result is very strange. The site is painting too broad a brush, if this type of TSA is an exception not the norm.

The CRCC Ethics Committee is anonymous? and the process is "confidential". Do you know who the members of the committee are? They are not listed on the website nor are the members of the commission. Agree that most CRC's are ethical that is why the web site uses the word "some". However, a "few" or "some" poorly educated, ethically irresponsible CRC's can create some serious problems for "clients". Claim management is the Insurers reponsibility. A CRC's responsibility is to his/her "client". That means demanding all documents and disclosing all influence by the Insurance Company in the TSA. It also means rescinding a TSA if the CRC finds out the Insurer played "claim management" games.

I am an HR manager, and owner of a business that manages disability claims. Many of us cannot respond to your mission or be a part of it because we rely on the Insurance industry for vocational rehabilitation referrals. In other words your site is going to anger many in the field. Most CRC's who work in the Insurance field are ethical. The TSA is only one part of the claim process. poor claim management is the real issue. If you want your mission to succeed I suggest you tone down the anger and sign your work. Every TSA, even the unethical ones has an author with their signature. CRC's like constructive convesation and debate. until the tone, changes the TSA process will not.

We have received numerous requests (demands in one case) for information via email. We are a group of individuals primarily with backgrounds in Corporate Human Resources that witnessed very troubling issues surrounding ERISA claims from a distance without getting into the mechanics of how the Insurance Industry was adjudicating ERISA cases. We recently learned a great deal more and our suspicions were validated. Unfortunately, it became apparent the Insurance Industry was hanging their hat on the CRC designation using all sorts of means to manipulate TSA outcomes and CRC's were letting it happen. We believe the CRC profession is allowing the Insurance Industry in some cases to use the CRC designation in a fashion that it was never intended to be used despite a Code of Ethics. Additionally, the Federal ERISA appeal process was never intended to be adversarial. These are hard-earned benefits. Some CRC's have unfortunately allowed themselves to be injected into an adversarial process that favors Insurance companies with their wealth of legal, expert and financial resources that individual's (THE CLIENT) do not have at their disposal. The web site is very clear what we want. We want accountability, transparency, change and a refocus on the CLIENT. We want a Code of Ethics that puts all CRC's on a level playing field, regardless of who the referrer is, and does not leave any gray areas that the Insurance Industry can exploit in these cases.

I'm inclined to think the Insurance Industry is predisposed to find the least ethical CRC's they can. It is in their financial interests to do so if it leads to claim denials. That is perverted. Something has to change.

Lynne, Thank you for speaking your passion for your profession. This site does not want to excoriate CRC's it wants CRC's to evaluate what is happening and to strengthen the one bond that unites you...THE CODE OF ETHICS. A strong Code of Ethics and a serious threat of ethical adjudication will end the ROT. What are your thoughts about the case in the "case study" section?

We, as CRC's, have to stop the "ROT" within our profession. The insurance industry continues to give our profession a bad name, making it difficult for the public to recognize that we are highly educated professional counselors with a sincere desire to assist and advocate for people with disabilities. We are not the insurance industry's "hired guns"!!

Unaware of any study comparing Ethical Compliance b/w public and private CRC's. Very good question. Academia needs to step up the plate. Unfortunately, the comments regarding money and accountability ring true. Add methodology. Apparently, throwing three or four dart's at the Dictionary of Occupational titles passes as professionalism these days.

This is all about money not "clients". Rehabilitation Counselors know where their bread is buttered and are afraid to disappoint the payor. The insurance companies have spread their money net wide and large. They then track and choose the CRC's inclined to push the ethical and moral boundaries for their cases. The scary part is fellow CRC colleagues, bound by the same ethical code, are running the show at the insurance companies. The current situation in the Insurance related rehabilitation counselor profession is correctly described in the site as a "ROT". There is no ethical accountability, no ethical enforcement, no ethical transparency...... You are fighting an uphill battle---good luck

The Insurer CRC designation should be changed to LD for .........Lapdog. TSA should be changed to WIN.........What Insurer Needs. Good luck. This is all about money, not about disabled individuals and their needs. Nobody is enforcing the Code of Ethics. Very sad.

Has there ever been an academic study comparing the Ethical Compliance of Public CRC's and CRC's working for insurance companies?

Thanks for the info. The CRCC must advise it's membership that they are supposed to be objective. Many claim denials hinge on a CRC's conclusions and the Insurer's know that. Mike