The raters have no special legal or medical training. They are not trained in any sort of administrative law process. They are just clerks who decide if you get a grant or become homeless. Many are functionally illiterate. Count the number of errors in spelling and grammar in your decision. Most cannot even put a paragraph together using proper English. They usually contradict themselves several times. Nice, huh? Actually, they use dice and the Wheel of Fortune to decide claims.