Social Security:

New Functional Assessments for Children Raise Eligibility Questions

HEHS-95-66: Published: Mar 10, 1995. Publicly Released: Mar 10, 1995.

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Pursuant to a congressional request, GAO reviewed the effects of the judicially mandated individualized functional assessment (IFA) process on Supplemental Security Income (SSI) benefits, focusing on: (1) allegations that parents may be coaching their children to fake mental impairments to qualify under the lower eligibility standards created by IFA; and (2) how IFA affects the children's eligibility for benefits.

GAO found that: (1) the judicial decision that required changes in IFA essentially made the process for determining disability in children analogous to the adult process; (2) the new process assesses how children's impairments limit their ability to act and behave like unimpaired children of similar age; (3) it has become important to obtain evidence of disability from nonmedical sources as part of the children's assessment; (4) although the court required a new type of assessment for disabled children, it did not define the degree of limitation necessary to qualify for SSI benefits; (5) before the IFA process was introduced in 1991, the national award rate for all types of childhood cases was 38 percent, but the award rate jumped to 56 percent in the first 2 years after IFA regulations were issued; (6) the non-medical aspects of the IFA evaluation rely heavily on adjudicator judgment; (7) while the Social Security Administration (SSA) has attempted to improve the process, and thereby reduce fraud and improve accuracy in awards, IFA has an underlying conceptual problem; (8) although the IFA process attempts to improve accuracy, the presence of coaching by parents is almost impossible to detect; and (9) more consistent eligibility decisions could be made if adjudicators based functional assessments of children on the functional criteria in SSA medical listings.

Matter for Congressional Consideration

  1. Status: Closed - Implemented

    Comments: Congress enacted the Personal Responsibility and Work Opportunity Act, which the President signed on August 22, 1996. The act includes a provision eliminating IFAs as criteria for determining children's eligibility for benefits.

    Matter: Given widespread concern about growth in the SSI program for children and in light of GAO findings about the subjective nature of the IFA process, Congress should consider taking action to improve eligibility determinations for children with disabilities. One option Congress could consider is to eliminate IFA, which would require amending the statute. Congress could then direct SSA to revise its medical listings, including the functional criteria, so that all children receive functional assessments based on these revised criteria.

 

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