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Social Security Administration: Actions Needed by SSA to Ensure Disability Medical Consultants Are Properly Screened and Trained

GAO-22-103815 Published: Nov 09, 2021. Publicly Released: Nov 09, 2021.
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Fast Facts

The Social Security Administration pays benefits to eligible people who are unable to work due to disability. State agencies review claims for disability benefits, and use "consultants" (physicians) to determine if claimants are medically eligible.

SSA requires state agencies to ensure consultants meet its employment and training standards. While most states we surveyed reported meeting the requirements, several did not. As a result, SSA risks using consultants who are ineligible or not fully trained.

We recommended that SSA take further steps, such as periodic reminders for states, to ensure states properly screen and train consultants.

Social Security Administration seal on its building

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Why This Matters

Social Security disability benefits are generally intended to help people who cannot work due to a disability. All of the state agencies that review disability claims consult with physicians to evaluate claimants' medical eligibility.

Concerns have been raised about:

  1. SSA's oversight of states' consultants, and
  2. Whether paying contract consultants per claim affects the quality of their work.

Key Takeaways

SSA cannot be sure that the state agencies' consultants are qualified and trained to appropriately inform decisions on disability claims.

SSA policy requires state agencies to screen their consultants by checking them against a database of individuals barred from participating in federal programs. Also, SSA policy sets requirements for state agencies to provide initial and follow-up training. However, state agencies told us they do not always do so.

Of the 52 agencies:

  • 14 said they did not consistently perform required checks on consultants either when hiring or annually, and
  • Nine said they did not give consultants some element of required initial or refresher training.

We also looked into whether paying consultants per claim rather than an hourly or salary rate—which 19 agencies do—affects the quality of their work. Our analysis of SSA data did not find conclusive evidence of a link between how a state pays consultants and the quality of disability decisions in each state.

Employment of Disability Consultants by State

Employment of Disability Consultants by State

How GAO Did This Study

We surveyed disability agencies that review claims in the 50 states, District of Columbia, and Puerto Rico. We also analyzed SSA quality assurance data by state, reviewed SSA policies and relevant federal laws and regulations, and interviewed SSA officials and officials from agencies in several states.


SSA should take additional steps to ensure states conduct required screenings and training, such as by clarifying its policies and providing periodic reminders. SSA agreed with our recommendations.

Recommendations for Executive Action

Agency Affected Recommendation Status
Social Security Administration The Commissioner of the Social Security Administration should take additional steps to ensure DDSs conduct required SAM checks for consultants, such as policy reminders or periodic checks of compliance. (Recommendation 1)
Closed – Implemented
SSA issued a policy reminder in March 2022 to DDSs to conduct SAM and licensure checks for medical consultants and SSA plans to issue these reminders annually. Additionally, SSA completed development of an online database in December 2022 to allow DDSs to track their required actions, including SAM checks for medical consultants. The database also allows users to query information about medical consultants across states. Additionally, SSA's database contains information on the verification process and has the ability to send automated alerts to DDSs when an action is taken in the database. SSA's actions will help ensure that DDSs only employ eligible individuals as medical consultants.
Social Security Administration The Commissioner of the Social Security Administration should take additional steps to ensure DDSs' compliance with SSA's training policy for consultants, such as reviewing the adequacy of training DDSs provide or sending DDSs periodic reminders about initial and follow-up training policies. (Recommendation 2)
Closed – Implemented
SSA agreed with this recommendation. SSA developed training materials for new DDS administrators that incorporate reminders of consultant training requirements and the importance of timely checks of consultant credentials. The agency also completed a video-on-demand (VOD) for DDSs to incorporate into the refresher training they provide to consultants which covers how they should evaluate medical evidence. SSA made this video available to DDSs and provided them with links to the VOD on its training webpage. These actions will help SSA ensure that consultants are properly trained in how to review disability claims.

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ConsultantsDisability benefitsDisability claimsDisability determination processDisability determinationsFederal assistance programsHealth care standardsMedical evidencePhysical disabilitiesSupplemental security incomeSocial security benefitsSocial security disability