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Social Security Disability Programs: Clearer Guidance Could Help SSA Apply the Medical Improvement Standard More Consistently

GAO-07-8 Published: Oct 03, 2006. Publicly Released: Nov 02, 2006.
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Highlights

The Social Security Act requires that the Social Security Administration (SSA) find an improvement in a beneficiary's medical condition in order to remove him or her from either the Disability Insurance (DI) or Supplemental Security Income (SSI) programs. GAO was asked to (1) examine the proportion of beneficiaries who have improved medically and (2) determine if factors associated with the standard pose challenges for SSA when determining whether beneficiaries continue to be eligible for benefits. To answer these questions, GAO surveyed all 55 Disability Determination Services (DDS) directors, interviewed SSA officials, and reviewed pertinent SSA data.

Recommendations

Recommendations for Executive Action

Agency Affected Recommendation Status
Social Security Administration To ensure that SSA is able to consistently assess whether DI and SSI beneficiaries have improved medically, the Commissioner of Social Security should clarify guidance for assessing medical improvement when conducting CDRs. More specifically, SSA should clarify guidance concerning (1) what degree of improvement is required to meet the standard and (2) when the use of exceptions to medical improvement is appropriate. SSA should also work with DDSs to ensure that CDRs are conducted on a neutral basis, without a presumption that beneficiaries continue to have a disability.
Closed – Not Implemented
The Deputy Commissioner of Operations, Office of Disability Determination and the Office of Disability Programs (ODP) collaborated to provide guidance to the DDSs for adjudicating CDRs. Staff members prepared "Development of Medical Evidence for Continuing Disability Review Cases" to assist with adjudication guidance, which provides reminder items for continuing disability review development. SSA reported in 2009 that CDRs are currently being adjudicated in the DDSs and that a pilot in Missouri to test 200 CDRs in the electronic environment (eCDR) is near completion. The next step is to rollout eCDR to the rest of the state. It is not clear to GAO, however, whether the adjudication guidance clarifies what degree of improvement is required to meet the standard or when the use of exceptions to medical improvement is appropriate. As of FY11, SSA had not demonstrated that it sufficiently implemented this recommendation.

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Topics

Disability benefitsEligibility criteriaFederal social security programsHealth policyPeople with disabilitiesPolicy evaluationProgram evaluationSocial security beneficiariesSocial security benefitsStandards evaluation