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The OHA benefits adjudication process, as described by Chassman and Rolston, seems badly awry. Evidence marshalled by them and by others reveals that ALJ award rates vary widely, and that nearly one-half of all administrative denials appealed to federal district courts are reversed or remanded. Moreover, although ALJ's hear relatively few cases, grants by ALJ's represent a large and increasing percentage of the total awards made by the system. A neutral observer might interpret this as evidence of an adjudicatory system wildly out of control.
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