Hierarchy: Levels are cumulative β each presupposes the prior. Foundational is necessary but insufficient for semantic; semantic is necessary but insufficient for organizational.
Electronic data exchange between SSA, state Disability Determination Services (DDS), some EHRs, and some federal courts is technically possible. SSA's Electronic Records Express (ERE), Health Information Exchange (HIE) infrastructure, and TEFCA's QHINs provide underlying connectivity.
Gap: The "last mile" to the pro se litigant is weak. Claimants submit paper records, paper SSA-827 forms, unstructured PDFs. From the litigant's vantage, the foundational layer feels like a wall of fax machines.
Failure mode: "Pipes open to the agency's side, closed on the claimant's side."
SSA internal data models (DDS disability folder, eView, AC database) are internally structured but not exposed in standard interoperable formats to claimants, representatives, or AI tools. There is no FHIR-equivalent API for "give me a claimant's complete disability record in structured form."
Gap: A pro se litigant's medical record exported from SSA may be a flat PDF; CE reports are free-text with no field-level structure.
Failure mode: "Receiving system has the file but cannot parse the fields."
The central problem. Disability evidence is meaning β the meaning of a diagnosis for this claimant's specific functional limitations for this type of work. Three semantic failures:
Failure mode: "Both systems store 'impairment' but disagree on what counts, how severe, and what work it precludes."
Requires governance, policy, trust, and consent frameworks across organizational boundaries. In disability adjudication, this is the procedural and constitutional regime: APA, Social Security Act, Due Process, Rehabilitation Act Β§504, Mathews v. Eldridge, mandamus remedies.
The data: 30,000 deaths-while-pending in FY2023; 60β65% federal-court remand rates; two-thirds of remanded cases ultimately awarded benefits.
Failure mode: "Technically meaningful records, semantically interpretable, blocked from producing timely legal effect."
Assessed against the HIMSS four-level model. Data drawn from the Research Portfolio Exhibit, PSDLEF paper, GAO reports, and SSA workload data.
| Level | HIMSS Health-IT Analogue | SSA / Pro Se Status | Principal Failure Mode |
|---|---|---|---|
| 1 | Two systems connected | Partial Agency-side yes, claimant-side no | Paper submissions, fax, PDF |
| 2 | HL7 FHIR / C-CDA | Absent No public API, no SSA-specific profile | Medical records as opaque PDFs |
| 3 | SNOMED CT / LOINC / ICD-10 | Largely Absent No shared adjudicator-legible vocabulary for functional impairment | Diagnosis β work-disability |
| 4 | TEFCA, QHINs, governance | Failing 30,000 deaths/yr, 60β65% remand | Rights exist but no timely correction |
Diagnostic conclusion: The SSA adjudication system is Level 1/2 with catastrophic Level 3/4 failure. PSDLEF is in principle positioned to provide Level 1β4 architecture for pro se litigants β but only if its modules are explicitly re-specified in interoperability terms.
SIL is a normative, evidence-mapping function that takes heterogeneous disability evidence and produces a claimant-specific, adjudicator-legible representation of functional impairment and its work-limiting effects. It is not a database, a vocabulary, or a checklist. It is an interpretive function β closer in form to a latent-variable model than to a data schema.
Notation:
Parameters are estimated by minimizing the discrepancy between model-implied and observed cross-evidence consistency matrices. The observed consistency matrix is constructed by pairing each evidence piece with each other piece, coding consistency (concordant / complementary / conflicting / unrelated), and aggregating. Estimation uses diagonally weighted least squares (DWLS) β the same estimator as Genomic-SEM β adapted to ordinal consistency coding.
| Output | Description |
|---|---|
| Ε΄ score | Estimated work-disability score with confidence interval |
| XΜ vector | Domain-by-domain capacity scores with CIs |
| Evidence map | Machine-readable trace from each claim to underlying source and factor loading |
| Consistency report | Flags concordant, complementary, and conflicting evidence |
β A decision-making system β SIL does not allow or deny benefits. The adjudicator decides.
β A black box β Every SIL output traces back to underlying evidence and loadings.
β A replacement for expertise β SIL is a common representation of clinical and vocational inputs.
β A one-time model β SIL is per-claimant instantiation of a model class; parameters update.
The analogy is deliberately drawn β and we argue it is genuinely illuminating rather than ornamental.
| Component | Genomic-SEM (Grotzinger 2019) | SIL (This Paper) |
|---|---|---|
| Federated evidence | Multiple GWAS cohorts with different phenotypes, instruments, sample sizes | Medical encounters, CE reports, work history, genomic findings, imaging, lay testimony |
| Covariance object | Genetic covariance matrix (via LD score regression) | Cross-evidence consistency matrix (via paired consistency coding) |
| Latent construct | Common genetic factor explaining shared signal across traits | Functional-impairment factor explaining shared signal across evidence |
| Downstream output | Multivariate GWAS on latent factor | Adjudicator-readable evidence map |
| Estimator | DWLS on genetic covariance | DWLS on consistency matrix (adapted to ordinal coding) |
Both operate on federated evidence β data never collected in a common model. Both construct a covariance-like object from pairwise relationships. Both estimate a latent construct that no individual data point directly measures. Both produce a downstream representation usable by the relevant community (statistical geneticists β adjudicators).
The analogies are not perfect β disability evidence is much messier than GWAS summary statistics β but the structural parallel is real, and importing the latent-variable formalism is more than cosmetic.
Each level scored 0β3 against five criteria β per-level 0β15 β total 0β60.
| Criterion | Description | Score (0β3) |
|---|
| Score Range | Interpretation |
|---|---|
| 0β15 | System essentially non-interoperable; cannot support meaningful adjudication |
| 16β30 | Foundational and partial structural only; semantic and organizational absent |
| 31β45 | Functional for straightforward cases; fails on complex, multimodal evidence |
| 46β60 | Capable of supporting full SIL-based pro se litigation model |
PSDLEF litigant-services modules scored against the four-level rubric.
| Module | L1 Foundational | L2 Structural | L3 Semantic | L4 Organizational | Total /60 | Interpretation |
|---|---|---|---|---|---|---|
| AI Doc Gen | 10 | 2 | 2 | 6 | 20 | Below functional band |
| Neurodiversity + Genomic | 8 | 6 | 6 | 8 | 28 | Below functional band β strongest overall |
| Court Navigation | 8 | 3 | 1 | 5 | 17 | Below functional band β weakest |
Build SIL before scaling the AI doc gen module. Doc gen without SIL produces documents that are pro se-formatted but not semantically interoperable β they reproduce the lay vocabulary of the claimant rather than translating into the adjudicator's functional-impairment frame.
Use the rubric as a portfolio instrument. The PSDLEF Board can evaluate proposed modules, partner integrations, and grant applications. A partner that does not raise at least Level 1 and Level 4 scores should not be assumed to add semantic value.
Engage SSA on Levels 2 and 4 before Level 3. SIL is technically feasible today; deployment is gated by organizational interoperability, not technical capability. The political-organisational engagement is the binding constraint.
The four-level model provides a diagnostic vocabulary for case-level failures: delay = Level 1 (foundational); records misinterpreted = Level 3 (semantic); valid claim denied three times = Level 4 (organizational). A pro se litigant can identify which level is failing and target the remedy accordingly β a forensic use of the framework.
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Level 1 β Foundational. Establishes inter-connectivity requirements for systems to securely communicate data to and receive data from another.
Level 2 β Structural. Defines format, syntax, and organization of data exchange (including at data-field level) for interpretation by the receiving system.
Level 3 β Semantic. Provides for common underlying models and codification of data, including data elements with standardized definitions from publicly available value sets, providing shared understanding and meaning.
Level 4 β Organizational. Includes governance, policy, social, legal, and organizational considerations to facilitate secure, seamless, timely communication and use of data. Enables shared consent, trust, and integrated workflows.