Modernizing SSA Disability Programs:
Progress Made, but Key Efforts Warrant More Management Focus
GAO-12-420: Published: Jun 19, 2012. Publicly Released: Jul 19, 2012.
What GAO Found
The Social Security Administration (SSA) has taken steps that hold promise for improving the process for updating its medical criteria, but continues to face challenges ensuring timely updates. SSA now uses a two-tiered system for ongoing revisions to its medical listings. First, it completes a comprehensive review of all medical conditions listed within each of 14 body systems, making needed revisions. For subsequent updates for a body system, the agency uses a targeted approach, selecting for review and revision only those medical conditions most in need of change. To date, SSA has completed comprehensive revisions for 8 of the 14 body systems and now is reviewing conditions under them to determine where targeted revisions are appropriate. However, some of these targeted revisions have experienced delays. Moreover, SSA has yet to complete comprehensive revisions for six body systems that have been ongoing for 19 to 33 years. SSA officials attributed delays to a lack of staff and expertise, along with the complexity and unpredictability of the regulatory process.
SSA has embarked on an ambitious plan to design by 2016 an occupational information system for use in its disability decision-making process, but has fallen short of best practices for estimating costs, maintaining a schedule, and considering risks and alternatives. SSA currently relies on occupational information developed by the Department of Labor which has not had a major update since 1977. In 2008, SSA initiated a project to develop its own occupational information system (OIS), which SSA expects will provide up-to-date information on the physical and mental demands of work to support its decision-making process. To guide the creation of its OIS, SSA established an advisory panel, collaborated with outside experts and other agencies, and in July 2011 issued a research and development plan detailing relevant activities through 2016. SSA has made progress on some baseline activities in the plan. However, SSAs cost estimate and schedule had key deficiencies, such as not including any estimate of the cost of producing, maintaining, and operating the system, which can inform design options. SSA also did not adequately consider inherent risks or potential alternatives, which could heighten the risk of additional costs or project failure.
Consistent with modern views of disability, SSA has taken some concrete steps toward greater consideration of an individuals ability to function with a disability but faces constraints in fully modernizing. SSA has incorporated some criteria into its medical listings to determine whether a claimants impairments result in functional limitations that can prohibit the ability to work. SSA is also sponsoring research through the National Institutes of Health to evaluate how functional abilities can further be considered in determining disability. One project aims to develop a computerized tool to assist adjudicators in evaluating how various impairments affect an individuals function and ability to work. However, SSA officials maintain that other modern concepts of disability cannot be fully incorporated into SSAs disability decisions. Specifically, SSA faces constraints considering the extent to which assistive devices and workplace accommodations can mitigate work disability, because these are not universally available and SSA lacks the resources to conduct individualized assessments.
Why GAO Did This Study
SSA administers two of the largest federal disability programs. GAO designated federal disability programs as a high-risk area, in part because eligibility criteria had not been updated to reflect medical and technological advances and labor market changes. Given the size and cost of its disability programs, SSA needs updated criteria to appropriately determine who qualifies for benefits. GAO has been asked to assess SSAs efforts to update its medical criteria and develop a new occupational information system, and to identify other steps taken to modernize disability determination criteria. To do this, GAO reviewed relevant publications and federal laws and regulations; assessed agency plans, cost estimates, schedules, and other documentation against established project management criteria; and interviewed SSA officials, experts, and stakeholders.
What GAO Recommends
GAO recommends that SSA (1) explicitly identify resources needed to achieve its 5-year time frame for updating its medical listings; (2) follow best practices in its cost estimate, schedule, and risk assessment for the occupational information system; and (3) conduct limited, focused studies on how to more fully consider assistive devices and workplace accommodations in its disability determinations. SSA agreed with the first two recommendations and disagreed with the third, stating that such studies would be inconsistent with Congress intentions. GAO continues to believe the recommendation has merit, as discussed more fully within the report.
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Recommendations for Executive Action
Status: Closed - Implemented
Comments: In August 2014, SSA reported that the agency did an analysis of additional staff needed for updating the medical listings and allocated three hires out of the new hiring authority towards this effort. SSA posted an internal and external vacancy announcement to hire three employees to work on medical listings. As of August 8, 2014, SSA reported making two selections (those employees are scheduled to report on 8/11/14) and is continuing to evaluate applications and interview applicants to fill the remaining medical listings hire. Beyond hiring, SSA reported that it is in the process of completing final rules for 7 medical listings--all of which are targeted for completion by July 2015--after which SSA will have updated all 15 medical listings since 2007. SSA plans to continue updating and revising listings on a 3-5 year cycle, and conducting targeted updates as warrented by research and medical advancements.
Recommendation: To achieve the goal of updating listings for each body system within SSA's 5-year time frame, the Commissioner of Social Security should explicitly identify the resources needed to achieve this goal, such as staff, contractors, and technology aids, and its plans to overcome any resource limitations.
Agency Affected: Social Security Administration
Comments: In May 2013, SSA reported signing an interagency agreement with the Bureau of Labor Statistics to assess the feasibility of using an existing survey to collect its data. Officials told us that while the agency expects that its current approach will cost less and take less time than previously expected, the agency has not yet finalized a cost estimate. In July 2014, SSA reported it is in process of developing: a comprehensive project plan that includes the objectives, requirements, business processes, and risks of the project; a work breakdown structure that identifies and organizes the tasks necessary to complete the OIS project; and an integrated master schedule that links tasks together in a chronological format, lays out the full scope of project activities in a comprehensive timeline, and identifies how tasks are connected. SSA anticipates completing these plan at the end of FY 2014. SSA also reported that the Department of Labor's Bureau of Labor Statistics (BLS) is preparing for a large scale pre-production test of the OIS survey to begin in late FY 2014 and conclude in FY 2015. To date, SSA estimated a budget of $17.7 million for FY 2015 and $20 million for FY 2016, when BLS will begin collection production data. SSA noted that overall production costs will depend on the results of ongoing testing, the final survey design, and the final implementation schedule, and that such costs are likely change over time due to factors including, but not limited to, inflation, congressionally mandated salary increases, and the changing needs of SSA. GAO will continue monitoring completion of its plans, BLS' pre-production test, and onset of collection of production data.
Recommendation: To ensure that its work to revise occupational information is feasible and cost effective, and to improve its chance for success, the Commissioner of Social Security should (1) formally assess risks to the success of the OIS -- addressing such challenges as related to controlling cost, acquiring expertise, managing project complexity, and coordinating with ongoing and related SSA research -- and develop appropriate mitigation strategies, and (2) develop a comprehensive and reliable cost estimate and schedule for the life cycle of the project, in accordance with best practices.
Agency Affected: Social Security Administration
Comments: In July 2014, SSA reported that this recommendation includes 2 distinct issues: workplace accommodations and assistive devices. With respect to the use of assistive devices in disability determinations, SSA reported that it's current disability determination process already considers the use of usch devices to perform basic work activities, and routinely solicits input from the public and medical community regarding changes to assistive technology. Further, SSA agrees that the time is right to further study how assistive technology is considered in evaluating disability, and plans to task the Insitute of Medicine under an existing contract in late FY 2015 or early FY 2016 to conduct this study. In August 2014, SSA reported having held a meeting with the IOM Standing Committee on April 1, 2014, to discuss assistive devices and technology, and expects to complete and award a related task order within the next few months. However, given other IOM work activities already underway and planned, SSA does not expect IOM to begin this until late October 2015. GAO will continue to monitor SSA's and IOM's progress in conducting this study. With respect to workplace accomodation, SSA has no plans to study workplace accommodation, consistent with its original disagreement with this aspect of our recommendation. At the same time, SSA does plan to update its occupational information in concert with the Bureau of Labor Statistics. GAO believes this effort may provide an opportunity to gather limited information on workplace accommodations, which in turn could inform a limited and focused study of how workplace accommodations might be further considered in disability determinations. Therefore, we will continue to monitor SSA's effort to update its occupational information.
Recommendation: To help ensure that SSA's disability decisions are as equitable and consistent with modern views of disability as possible, the Commissioner of Social Security should conduct limited and focused studies on the availability and effects of considering more fully assistive devices and workplace accommodations in its disability determinations.
Agency Affected: Social Security Administration