Recommendation: The Under Secretary for Benefits should work with State and SSA to identify and implement ways to help ensure that embassy staff and RFBOs are made aware of relevant changes in VA policy and standard operating procedures in a timely and consistent manner and can more readily identify available resources so they can efficiently help veterans living abroad with VA's disability claims process. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Under Secretary for Benefits should identify and implement an interim strategy to consistently document the complete contact information for veterans living abroad within VBMS, while OIT and VBA continue to explore a long-term solution. (Recommendation 2)

Agency: Department of Veterans Affairs
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Under Secretary for Benefits should systematically assess the quality of embassy-referred exams and use the results of this review to identify whether there are common problems related to the use of these exams, and, if necessary, take steps to address those problems, such as by developing tailored technical assistance for embassy-referred examiners. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Under Secretary for Benefits and Under Secretary for Health—in concert with the General Counsel—should assess and decide whether to reimburse beneficiaries for travel to disability medical exams in foreign countries. (Recommendation 4)

Agency: Department of Veterans Affairs
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Under Secretary for Health, working with the Under Secretary of Benefits, should identify ways to reimburse examiners who conduct disability medical exams via direct deposit in the local currency, assess the cost-effectiveness of these options, and implement the method it selects. (Recommendation 5)

Agency: Department of Veterans Affairs
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of the Office of Workers' Compensation Programs should direct the Division of Federal Employees' Compensation to send a reminder to all FECA recipients as they approach retirement that they may want to obtain FERS retirement benefits estimates for comparisons with FECA, including annuity estimates from their employing agencies and estimates of their Thrift Savings Plan and Social Security benefits. (Recommendation 1)

Agency: Department of Labor
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of the Office of Workers' Compensation Programs should direct the Division of Federal Employees' Compensation to coordinate with the Social Security Administration to take steps to modernize and improve the process of manually generating benefit amounts with and without federal earnings and exchanging information between the agencies to enable the provision of offset estimates to FECA recipients upon request and to reduce the potential for human error in applying offsets. (Recommendation 2)

Agency: Department of Labor
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commissioner of Social Security should direct the Office of Earnings and International Operations to coordinate with the Division of Federal Employees' Compensation to take steps to modernize and improve the process of manually generating benefit amounts with and without federal earnings and exchanging information between the agencies to enable the provision of offset estimates to FECA recipients upon request and to reduce the potential for human error in applying offsets. (Recommendation 3)

Agency: Social Security Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Assistant Attorney General for the Civil Rights Division should work with Education's Office for Civil Rights to provide state educational agencies and school districts with online information, technical assistance, or training materials related to federal accessibility requirements specific to public school facilities. (Recommendation 1)

Agency: Department of Justice
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Assistant Attorney General for the Civil Rights Division should work with Education's Office for Civil Rights to provide state educational agencies and school districts with online information, technical assistance, or training materials related to federal accessibility requirements in public school facilities in the context of safety and security. This may include leveraging recent, online federal initiatives on school safety and physical security. (Recommendation 2)

Agency: Department of Justice
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of OPM should routinely track and report retention data for employees with disabilities and make such data available to federal agencies, including EEOC, through a centralized web portal—such as MAX.gov. For example, OPM could track and report such data by General Schedule level pay groupings, which could help pinpoint root causes that contribute to retention rates, inform assessments of government-wide progress on employee retention, and identify needed improvements. (Recommendation 1)

Agency: Office of Personnel Management
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Attorney General of the United States should develop and implement policies and procedures for assessing the impact of training provided to agency hiring managers and human resources staff on Schedule A hiring authority. This includes assessing the impact of its training on agency performance goals related to increased hiring of individuals with disabilities and targeted disabilities. (Recommendation 2)

Agency: Department of Justice
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Attorney General of the United States should develop and implement policies and procedures for obtaining employee feedback about the agency's reasonable accommodations efforts and use such information to evaluate the ongoing effectiveness of the program. This may include identifying any effects on employee retention, identifying potential risks, and determining any improvements that may be warranted. (Recommendation 3)

Agency: Department of Justice
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator of SBA should develop and implement policies and procedures for assessing and tracking the impact of training provided to agency hiring managers and human resources staff on Schedule A hiring authority. This includes assessing the impact of its training on agency performance goals related to increased hiring of individuals with disabilities and targeted disabilities. (Recommendation 4)

Agency: Small Business Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator of SBA should develop and implement policies and procedures for obtaining employee feedback about the agency's reasonable accommodations efforts and use such information to evaluate the ongoing effectiveness of the program. This may include identifying any effects on employee retention, identifying potential risks, and determining any improvements that may be warranted. (Recommendation 5)

Agency: Small Business Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commissioner of SSA should develop and implement policies and procedures for assessing and tracking the impact of training provided to agency hiring managers and human resources staff on Schedule A hiring authority. This includes assessing the impact of its training on agency performance goals related to increased hiring of individuals with disabilities and targeted disabilities. (Recommendation 6)

Agency: Social Security Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of BIE should establish consistent requirements for schools on making up missed special education and related services and monitor schools to ensure that they follow these requirements. (Recommendation 1)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation. The agency acknowledges that it must refine the guidance provided by its special education subject matter experts to ensure that guidance on missed special education related services is consistent. They anticipate fully implementing reforms through formally published guidance to its special education professionals.

Recommendation: The Director of BIE should work with knowledgeable stakeholders in Indian education to establish a community of practice or other formal mechanism to identify and disseminate promising practices for schools—especially those in remote locations—on recruiting, hiring, and retaining special education teachers and contracting with providers. The Director of BIE could consider conferring with BIE's special education advisory committee, OSEP, and relevant tribal and state education officials in addressing this recommendation. (Recommendation 2)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation. The agency plans to work collaboratively with all of its special education stakeholders to build on its internal human capital capabilities, Strategic Workforce Plan and other human capital improvements.

Recommendation: The Director of BIE should rescind the policy of its division overseeing tribally controlled schools that does not meet Interior's requirement to annually review all schools' documentation to verify the provision of services for every special education student, and ensure that all divisions comply with this requirement. (Recommendation 3)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation. The agency is reviewing all of its special education policies and procedures and, as of May 2020, anticipates an updated, comprehensive special education policy and handbook in the coming months. This includes replacing the Tribally-Controlled School Division's 3-year review policy with an annual review. A first draft of the new special education handbook and policy is expected in the summer of 2020.

Recommendation: The Director of BIE should update the agency's workforce plan to include a strategy and timeframe for filling vacant staff positions responsible for overseeing and supporting schools' special education programs. (Recommendation 4)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation and plans to update and expand its Strategic Workforce plan to include new function areas. They expect to update it in the coming months to include special education and Johnson O'Malley functions.

Recommendation: The Director of BIE should fully implement the agency's high-risk monitoring policy for IDEA and other federal education programs, including requirements for agency-wide coordination, and ensure that schools selected for such monitoring receive reports and technical assistance plans within 30 days of agency on-site visits, as required by BIE policy. (Recommendation 5)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation. Based on lessons learned in its first two years of implementation, the agency plans to make targeted refinements to the policy and process of high-risk monitoring. Regarding the timeliness of report submission and technical assistance delivery, the agency began a targeted reform designed to address this structural weakness, namely, the need to centralize the administrative functions of its oversight activities. The newly established Performance Office will assume the administrative and management oversight of the high-risk fiscal monitoring policy and handbook, including the timely delivery of monitoring reports and technical assistance plans.

Recommendation: The Director of BIE should establish special education training requirements for staff in the agency's Education Resource Centers who are responsible for supporting and overseeing schools' special education programs, and ensure that staff complete those training requirements. (Recommendation 6)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation. The agency will ensure that special education training and professional development requirements are identified as part of its planned Strategic Workforce Plan update and expansion.

Recommendation: The Director of BIE should take steps to ensure that all of the agency's Education Resource Centers conduct outreach with schools to inform them of their new roles in overseeing and supporting schools' special education programs under BIE's reorganization. (Recommendation 7)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation. As BIE makes targeted reforms to improve the delivery of special education services, it will ensure that the roles and responsibilities of Education Resource Centers (ERC) are clearly identified and communicated to responsible BIE personnel. Specifically, as it updates and expands the Strategic Workforce Plan, it will clearly and directly define the role of ERC personnel with respect to special education services. In addition, as the new Performance Office establishes timely and routine technical assistance plans, the agency will operationalize the day-to-day engagement and outreach between ERC and school level personnel regarding special education related technical assistance.

Recommendation: The Assistant Secretary for the Office for Civil Rights should revise its CRDC business rule to require that every school district reporting zeros, regardless of district size or numbers of students with disabilities, affirm the zeros are correct during the CRDC data submission process. (Recommendation 1)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should develop and implement a CRDC business rule that targets schools and school districts that report very low numbers of incidents and set data-driven thresholds to detect such incidents. (Recommendation 2)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should develop and implement a CRDC business rule that targets schools and schools districts that report very high number of incidents and set data-driven thresholds to detect such incidents. (Recommendation 3)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should apply the CRDC business rule targeting illogical data at the school level to all schools, regardless of the number of incidents reported. (Recommendation 4)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should identify the factors that cause underreporting and misreporting of restraint and seclusion and take steps to help school districts overcome these issues. (Recommendation 5)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should further refine and clarify federal restraint and seclusion definitions and take steps to ensure that this information is conveyed to school districts. This could include providing common classroom scenarios that highlight the differences between a restraint and an escort, and a time out and a seclusion. (Recommendation 6)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Director of the Office of Workers' Compensation Programs should develop and implement procedures for coal mine operator self-insurance renewal that clarifies how long an operator is authorized to self-insure; when an operator must submit its renewal application and supporting documentation; and the conditions under which an operator's self-insurance authority would not be renewed. (Recommendation 1)

Agency: Department of Labor: Office of Workers' Compensation Programs
Status: Open

Comments: DOL agreed with this recommendation and said it is acting to implement it to achieve further improvements in ensuring the effective oversight of coal mine operator insurance. DOL reported that it would ensure letters granting or renewing self-insurance authority will inform operators that their authorization expires in one year and that they must submit renewal information three months in advance of the expiration date.

Recommendation: The Director of the Office of Workers' Compensation Programs should develop and implement procedures for self-insured coal mine operator appeals that identify time lines for self-insured operators to submit documentation supporting their appeals and that identify a goal for how much time DOL should take to make appeals decisions. (Recommendation 2)

Agency: Department of Labor: Office of Workers' Compensation Programs
Status: Open

Comments: DOL agreed with this recommendation and said it is acting to implement it to achieve further improvements in ensuring the effective oversight of coal mine operator insurance. DOL reported that it will ensure letters denying self-insurance will inform operators that they have a 30-day appeal period (limited to one extension) and that DOL has set a goal of resolving all appeals within 90 days of the denial letter.

Recommendation: The Director of the Office of Workers' Compensation Programs should develop and implement a process to monitor operator compliance with commercial insurance requirements and periodically evaluate the effectiveness of this process. This process should be designed to detect errors and omissions in reporting insurance coverage using complete, accurate, and consistently recorded data. (Recommendation 3)

Agency: Department of Labor: Office of Workers' Compensation Programs
Status: Open

Comments: DOL agreed with this recommendation and said it is acting to implement it to achieve further improvements in ensuring the effective oversight of coal mine operator insurance. DOL reported that it will modify existing computer systems to identify lapses or cancellations of commercial insurance coverage, and require operators identified as having lapsed or cancelled coverage to obtain or provide proof of coverage within 30 days.

Recommendation: The Secretary of VA should direct GEC leadership to develop measurable goals for its efforts to address key long-term care challenges: workforce shortages, geographic alignment of care, and difficulty meeting veterans' needs for specialty care. (Recommendation 1)

Agency: Department of Veterans Affairs: Office of the Secretary
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of VA should direct GEC leadership to set time frames for and implement a consistent GEC structure at the VAMC level. (Recommendation 2)

Agency: Department of Veterans Affairs: Office of the Secretary
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of VA should direct GEC leadership to set time frames for and implement a VAMC-wide standardization of the tool for assessing the noninstitutional program needs of veterans. (Recommendation 3)

Agency: Department of Veterans Affairs: Office of the Secretary
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of State should take additional steps to identify diversity issues that could indicate potential barriers to equal opportunity in its workforce. For example, State could conduct additional analyses of workforce data and of employee groups' feedback. (Recommendation 1)

Agency: Department of State
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commissioner of the Social Security Administration should clarify policies and procedures to remind staff that a diagnosis of a substance use disorder is not necessary to conduct a Drug Addiction and Alcoholism evaluation. (Recommendation 1)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation. The agency stated that it had revised related policies in February 2020, and had planned to issue guidance and video-on-demand training to further clarify policies and procedures in this area. However, SSA said its efforts to maintain mission critical activities amid the COVID-19 pandemic have delayed further implementation of this recommendation and a specific implementation date could not be provided at this time.

Recommendation: The Commissioner of the Social Security Administration should ensure that staff document their rationale for decisions involving the Drug Addiction and Alcoholism evaluation process. (Recommendation 2)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation. The agency said it had planned to issue guidance reinforcing its policy on properly documenting decisions involving the Drug Addiction and Alcoholism evaluation process. However, SSA said its efforts to maintain mission critical activities amid the COVID-19 pandemic have delayed implementation of this recommendation and a specific implementation date could not be provided at this time.

Recommendation: The Secretary of Veterans Affairs should ensure that the Office of Enterprise Integration develops a plan—including milestones and roles and responsibilities for OEI, VBA, and VHA—to address identified challenges that have hindered research on the health care outcomes for service-connected conditions of veterans receiving disability compensation. To align VA's efforts with the goals of its 2018-2024 Strategic Plan, VA's development of this plan should be completed and ready for implementation by June 1, 2020. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA agreed with this recommendation. VA stated that the Office of Enterprise Integration (OEI) will coordinate with VBA and the Veterans Health Administration (VHA) to create an operational plan that addresses challenges that have hindered research on health care outcomes for service-connected conditions of veterans receiving disability compensation. As of March 2020, VA anticipates completing this plan by June 2020. We will consider closing the recommendation when that effort is complete.

Recommendation: The Under Secretary for Benefits should develop and implement a periodic analysis of program management data for trends in the individual service-connected conditions being reevaluated as well as data on the outcomes of reevaluations. (Recommendation 2)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA stated in March 2020 that it plans to develop requirements to augment its capacity to analyze reevaluation trends. According to officials, VA has determined the necessary requirements for the data needed to analyze the outcomes of reevaluations. VBA will review 12 months of data to assess trends and make recommendations based on the review. VA plans to complete the trend analysis by the end of June 2020 and will establish a process for periodic analysis of data trends. We will consider closing this recommendation when VA has analyzed multiple data points to assess trends in reevaluations on a periodic basis.

Recommendation: The Under Secretary for Benefits should implement the two recommendations in VBA's May 2018 consistency study to provide training on how to determine when a reevaluation is needed and review reevaluation decisions for accuracy at the lowest-scoring offices and take corrective action as needed. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

Comments: In November 2019, VA stated that VBA provided a reminder to all regional offices about the availability of training resources on how to determine when a reevaluation is needed. VA also stated that VBA conducted another consistency study on this issue in August 2019 and plans to use that study's results to guide its review of the lowest-scoring regional offices. This study recommended inspecting claims processed at the two lowest-scoring offices, because they may have high numbers of errors related to reevaluation requirements. VA stated that VBA would devise a statistically valid sample of claims based on the August 2019 study. In April 2020, VA provided information from national accuracy reviews and individual claims processor quality reviews for these two offices. However, these reviews were not specifically designed to assess the quality of decisions on reevaluations, and as such, do not provide generalizable information on all reevaluations decided by these two offices. To help close this recommendation, VA should take steps to focus its review on claims with reevaluations, in order to identify and correct root causes of any deficiencies, such as through additional training or the improvement of training. Using the results of both the 2018 and 2019 studies would allow VBA to more fully assess this issue.

Recommendation: The Under Secretary for Benefits should clarify guidance in its procedures manual regarding the knowledge, skills, and abilities needed to make decisions on whether to reevaluate veterans for changes in their service-connected conditions. (Recommendation 4)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA agreed with this recommendation in principle, acknowledging the importance of having appropriately skilled and trained employees to process reevaluations and other claims. VA stated that it believes the procedures outlined in its manual accurately describe the steps necessary for claims adjudicators to make the decision whether to reevaluate veterans for changes in their service-connected conditions. It further stated that regional office management ensures compliance with the procedures through the quality assurance program, and makes the decisions about which claims processors are best suited to perform the work. Accordingly, as of March 2020, VBA plans to assess the quality of routine future examinations requested by non-raters. Based on the results of this new quality review, VBA will determine if any additional actions are needed. VBA plans to complete this effort by October 2020. We are encouraged by VA's interest in conducting this analysis, and we will consider closing the recommendation when that effort is complete.

Recommendation: The Under Secretary for Benefits should align training requirements with the knowledge, skills, and abilities needed for reviewing claims to decide whether to conduct a reevaluation. (Recommendation 5)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA agreed with this recommendation in principle. As noted in recommendation 4, as of March 2020, VBA plans to assess the quality of routine future examinations requested by non-raters, and determine if any additional actions are needed. VA also stated that if any refresher training is warranted for raters, local quality review team members can provide focused training locally. VBA plans to complete this effort by October 2020. We will consider closing the recommendation when that effort is complete.

Recommendation: The Secretary of VA should ensure that the Director of VR&E assesses the consistency of VR&E plans among counselors and takes mitigating steps if results warrant. For example, as part of its training efforts, VA could have counselors respond to identical hypothetical veteran cases and, if unfair inconsistencies in plans result, the agency could enhance training on plan development. (Recommendation 1)

Agency: Department of Veterans Affairs: Office of the Secretary
Status: Open

Comments: In February and March 2020, VA's Vocational Rehabilitation & Employment (VR&E) conducted a consistency study of VR&E plan development. The study identified areas that warrant refresher training for counselors. VR&E plans to roll out this training to all counselors by August 2020. We will consider closing this recommendation when VR&E completes this effort.

Recommendation: The Director of ICE should implement a process to collect and maintain data in a readily available format on detained parents or legal guardians of U.S. citizen and legal permanent resident minors to ensure that information on this population is entered into ICE's data system as required by policy. (Recommendation 1)

Agency: Department of Homeland Security: United States Immigration and Customs Enforcement
Status: Open

Comments: In November 2019, ICE DHS did not concur with this recommendation, stating that ICE did not have any requirement or need to aggregate data on detained parents or legal guardians of U.S. citizens and legal permanent resident minors and doing so would not better inform ICE's decision-making processes. In a May 2020 update, ICE noted that ICE Enforcement and Removal Operations (ERO) officers continue to collect and maintain information in EARM and EAGLE regarding whether an alien is a parent, or legal guardian, of a U.S.-born citizen or legal permanent resident minor for actions specific to individual cases; and that this case-specific information is readily available to approved EARM users, including Child Welfare Coordinators. However, as we noted in our report, these data are not readily available because ICE's data on family relationships, including parents or legal guardians of U.S. citizens and legal permanent resident minors, can only be accessed by manually reviewing each separate case file in EARM. Further, ICE's policy states that in pursing the enforcement of U.S. immigration laws against parents of minors, ICE personnel should remain cognizant of the impact enforcement actions may have on U.S. citizen or legal permanent resident minors. Without making these data readily available, ICE is not able to account for the overall impact of its enforcement actions on U.S. citizen or legal permanent resident minors whose parents or legal guardians have been detained. In its May 2020 update, ICE also noted that ERO provided Congress with the report, "Deportation of Parents of U.S.-Born Children," incorporating the first half of calendar year 2019, in April 2020. However, as we noted in our report, to generate this semi-annual required report to Congress on removals of parents of U.S.-born citizen children, ICE must review this information manually. Also, there is no similar requirement to report in an aggregate way on parents of U.S. citizen or legal permanent residents who are detained. We continue to believe that collecting and maintaining information in a readily available format on detained parents or legal guardians of U.S. citizen or legal permanent resident minors could help ensure that ICE personnel can identify, evaluate, and share information on this population, as required by ICE policy.

Recommendation: The Under Secretary for Benefits should systematically solicit and collect information on potential financial exploitation from VA's Pension Management Centers and other relevant VA components, including VA's Office of General Counsel, and assess this information to inform plans to address the potential exploitation of veterans receiving pension benefits. Such plans could also address the broader population of veterans with disabilities. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

Comments: As of July 2020, VA reported taking steps to share data on potential financial exploitation threats, but further opportunities to collect information exist. In February 2020, VA updated its policy manual, instructing Pension Management Centers to send copies of any OIG fraud referrals to VA's Fraud, Waste, and Abuse Incident Team. This team plans to use the information to identify trends in potential fraud, and recommend changes to VA laws, policies, or procedures, as needed. VA also plans to use this data to coordinate with other Government agencies and offices to help prevent financial exploitation. However, VA has not reported taking steps to collect information from its Office of General Counsel, Pension Management Centers, and other components on threats to veterans that do not result in fraud referrals to OIG. VA asserts that collecting additional information on suspicious activities that do not meet the level of fraud that can be referred to OIG would be inappropriate because VA lacks investigative authority. As GAO noted in its report, not all suspicious activity or complaints rise to the level of fraud. Collecting additional information could improve VA's ability to understand threats to veterans and develop responses, such as outreach, and could build on VA efforts already underway with its Fraud, Waste, and Abuse Incident Team.

Recommendation: The Under Secretary for Benefits should place additional warnings on paper and electronic documents, including on benefit applications, regarding fees which veterans cannot be charged. (Recommendation 2)

Agency: Department of Veterans Affairs
Status: Open

Comments: As of July 2020, VA reports that it plans to include warnings on its pension applications to clarify which fees attorneys and others may charge veterans for representing them when applying for pension benefits. According to VA, information collection requests were published in the Federal Register in June 2020, and VA expects its application forms to be revised by the end of calendar year 2020. GAO will close this recommendation once VA's applications are revised.

Recommendation: The Under Secretary for Benefits should explore the costs and benefits of additional steps claims processors could take to verify that the direct deposit information provided by claimants on their applications is for the appropriate party. (Recommendation 4)

Agency: Department of Veterans Affairs
Status: Open

Comments: In August 2020 VA reported that it is in the process of updating its application forms to require claimants to submit documentation, such as a voided check or deposit slip, when applying for pension benefits. GAO will close this recommendation once changes to these applications are complete.

Recommendation: The Attorney General should direct the Bureau of Justice Assistance to enhance quality checks to ensure the accuracy of information in its 180-day reports about Public Safety Officers' Benefits claims related to public safety officers affected by 9/11. (Recommendation 1)

Agency: Department of Justice
Status: Open

Comments: The Bureau of Justice Assistance agreed with this recommendation. The agency said it will develop and implement quality checks to confirm the accuracy of information reported in the 180-day reports related to PSOB 9/11 claims. We will consider closing this recommendation when this effort is completed.

Recommendation: The Secretary of Homeland Security should develop performance metrics for the department's EEO program including a mechanism for tracking progress towards eliminating barriers. (Recommendation 1)

Agency: Department of Homeland Security
Status: Open

Comments: On August 18, 2020, DHS informed us that the work it is undertaking to respond to this recommendation is ongoing.

Recommendation: DHS component EEO Directors, in consultation with the Deputy Officer for EEO and Diversity, should develop policies and procedures to help ensure that their component EEO programs have action plans for addressing deficiencies in their Management Directive 715 (MD-715) reports. (Recommendation 2)

Agency: Department of Homeland Security
Status: Open

Comments: On May 11, 2020, DHS provided GAO with copies of standard operating procedures for addressing EEO program deficiencies for seven out of eight operational components as well as DHS headquarters. Each of the components' standard operating procedures require that action plans are in place to address any outstanding EEO program deficiencies.

Recommendation: The Deputy Officer for EEO and Diversity should develop a formal staffing model for its EEO program. (Recommendation 3)

Agency: Department of Homeland Security
Status: Open

Comments: On August 18, 2020, DHS informed us that the work it is undertaking to respond to this recommendation is ongoing.

Recommendation: DHS component EEO Directors, in collaboration with the Deputy Officer for EEO and Diversity, should develop component formal staffing models. (Recommendation 4)

Agency: Department of Homeland Security
Status: Open

Comments: On August 18, 2020, DHS informed us that the work it is undertaking to respond to this recommendation is ongoing.

Recommendation: The Secretary of Homeland Security—in consultation with the Office for Civil Rights and Civil Liberties (CRCL) and EEOC, and other agencies and components, as relevant—should analyze options for granting additional authorities to the Deputy Officer for EEO and Diversity to ensure DHS components comply with MD-715 guidance, including the authority of the Deputy Officer for EEO and Diversity to certify components' MD-715 reports. (Recommendation 6)

Agency: Department of Homeland Security
Status: Open

Comments: On August 18, 2020, DHS informed us that the work it is undertaking to respond to this recommendation is ongoing.

Recommendation: The FEMA Administrator should develop and publicize guidance for partners working to assist individuals who are older or have disabilities for requesting data and working with FEMA staff throughout the data sharing process to obtain Individual Assistance data, as appropriate. (Recommendation 1)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: DHS agreed with this recommendation and has plans to address it. Specifically, FEMA is developing new, enhanced templates, policies and guidance for field staff to facilitate data sharing with states and other partners. The agency also reported that it is expanding its Open FEMA datasets to provide more autonomous, self-service sharing of aggregated data to fulfill partner data needs when personally identifiable information data is not required. FEMA plans to publish data sharing guidelines on its web site by March 31, 2020 on how to obtain FEMA data to best service individuals who are older or have disabilities.

Recommendation: The FEMA Administrator should improve communication of registrants' disability-related information across FEMA programs, such as by developing an alert within survivor files that indicates an accommodation request. (Recommendation 3)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: FEMA disagreed with this recommendation, noting that it lacks specific funding to augment the legacy data systems that capture and communicate registration information. Also, FEMA began a long-term initiative in April 2017 to improve data management and exchange, and improve overall data quality and standardization. The agency expects the initiative to include the development of a modern, cloud-based data storage system with a data analytics platform that will allow analysts, decision makers, and stakeholders more ready access to FEMA data. After the completion of this initiative, FEMA expects that efforts to share and flag specific disability-related data will be much easier. Our recommendation, however, is not solely focused on system changes: other cost-effective ways may improve communication of registrants' disability-related information prior to implementing the system upgrades. For example, as noted in the report, FEMA officials handling different stages of the disaster assistance process may overlook disability-related needs recorded in the case file notes. FEMA could revise its guidance to remind program officials to review the notes to identify whether there is a record of any such needs. As FEMA moves ahead with its data improvement initiatives, we encourage it to consider and ultimately implement technology changes, such as developing an alert within files that indicates an accommodation request. Such improvements would be consistent with the recommendation and help improve communication across FEMA programs.

Recommendation: The FEMA Administrator should communicate to Regional Administrators and Regional Disability Integration Specialists a written plan for implementing its new disability integration staffing approach, consistent with the objectives established for disability integration. Such a plan should include an implementation timeline and details on staff responsibilities, which regions could use to evaluate staff performance. (Recommendation 5)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: DHS agreed with this recommendation, reporting that it is developing a project plan to implement the proposed staffing approach in the Regions. The plan will include implementation timelines, detailed roles and responsibilities for the proposed Disability Integration Advisor positions, a force structure for each Region, and recommendations to the Regional Administrator to establish performance metrics for the new positions that support the overall approach to disability integration. The plan will be presented to the Administrator for review and concurrence in 2019.

Recommendation: The FEMA Administrator should develop a plan for delivering training to FEMA staff that promotes competency in disability awareness. The plan should include milestones and performance measures, and outline how performance will be monitored. (Recommendation 6)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: FEMA agreed with this recommendation and has plans to improve disability competencies among FEMA staff, but it does not include training. Specifically, FEMA is developing a plan to include a disability integration competency in the position task books for all deployable staff, rather than through training. Position task books outline the required activities, tasks, and behaviors for each job, and serve as a record for task completion. The plan will also include a communications and outreach plan; milestones for measuring the effectiveness of the integration of this competency across the agency; and a monitoring plan and milestones to measure the overall integration of this competency across the deployable workforce. However, the plan doesn't cover how it will deliver training to promote competency in disability awareness among its staff, including milestones, performance measures, and how performance will be monitored.

Recommendation: The Under Secretary for Benefits should develop and implement a plan for how VBA will use data from the new exam management system to oversee contractors, including how it will capture accurate data on the status of exams and use it to (1) assess contractor timeliness, (2) monitor time spent correcting inadequate and insufficient exams, and (3) verify proper exam invoicing. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with this recommendation and outlined improvements in the information collected through VBA's new exam management system. VBA is testing a mechanism to validate exam invoices submitted by contractors. It will be important for VBA to take the next step of developing and implementing a plan for how it will use information from the new system to ensure both accurate timeliness data and proper exam invoicing.

Recommendation: The Under Secretary for Benefits should regularly monitor and assess aggregate performance data and trends over time to identify higher-level trends and program-wide challenges. (Recommendation 2)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA agreed with this recommendation. The agency stated that VBA will use improved data in the new exam management system to regularly monitor and assess aggregate performance data, identify error trends, and monitor contractor performance and program-wide challenges.

Recommendation: The Under Secretary for Benefits should document and implement a plan and processes to verify that contracted examiners have completed required training. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA agreed with this recommendation. The agency stated that VBA has started developing a training plan for contractors, as well as a new training delivery system, to validate that required training has been completed and to assess the effectiveness of this training through feedback from trainees, contractors, and quality review staff in VBA's contract exam program office. VBA intends to use this information to improve the implementation and content of training. VBA expects to fully implement its new training system before the end of fiscal year 2020. Once implemented, GAO will be able to close both of its recommendations related to training verification and assessment.

Recommendation: The Under Secretary for Benefits should collect information from contractors or examiners on training and use this information to assess training and make improvements as needed. (Recommendation 4)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA agreed with this recommendation. The agency stated that VBA has started developing a training plan for contractors, as well as a new training delivery system, to validate that required training has been completed and to assess the effectiveness of this training through feedback from trainees, contractors, and quality review staff in VBA's contract exam program office. VBA intends to use this information to improve the implementation and content of training. VBA expects to fully implement its new training system before the end of fiscal year 2020. Once implemented, GAO will be able to close both of its recommendations related to training verification and assessment.

Recommendation: The Secretary of Education should establish timeframes for providing states with additional information on allowable expenditures of funds reserved for pre-employment transition services. (Recommendation 1)

Agency: Department of Education
Status: Open

Comments: Education agreed with this recommendation and stated that it would establish projected timeframes for providing states with additional information on allowable expenditures for the provision of preemployment transition services. Education also stated that it intends to provide states with additional information in at least two forums before the end of calendar year 2018 and to review and analyze previous guidance provided to states on allowable expenditures.

Recommendation: The Secretary of Education should take additional steps to provide states assistance on updating and finalizing their interagency agreements with state educational agencies to include pre-employment transition services. These steps could include, for example, accelerating their efforts to discuss the benefits of finalizing interagency agreements, and reminding states of existing technical assistance resources pertaining to updating and finalizing interagency agreements. (Recommendation 2)

Agency: Department of Education
Status: Open

Comments: Education disagreed with this recommendation, in large part, because there is no statutory provision authorizing the agency to identify such states. Nevertheless, Education stated that it is taking some steps as part of its ongoing monitoring of the VR program to provide assistance to states that have not updated their interagency agreements. This is consistent with the intention of our recommendation but we believe more could be done. The agency also noted that it would continue to offer and provide technical assistance if it becomes known through the onsite monitoring of the VR program or through other means that states have not updated their interagency agreements between VR agencies and state educational agencies. In addition, its Rehabilitation Services Administration (RSA) and Office of Special Education Programs will provide information related to sources of technical assistance, as appropriate, to VR agencies and state educational agencies. While these steps may be helpful, given the number of states that have not updated and finalized their agreements and the length of time Education officials say they will take to complete this round of monitoring where Education asks state VR agencies about these agreements, additional action by Education may be needed to help states more efficiently and effectively coordinate services to students with disabilities.

Recommendation: The Secretary of Education should develop a written plan with specific timeframes and activities for identifying and disseminating best practices that address, as appropriate, implementation challenges for pre-employment transition services, such as those identified in this report. (Recommendation 3)

Agency: Department of Education
Status: Open

Comments: Education disagreed with this recommendation believing it is premature to develop a timeline for the dissemination of best practices. The agency stated that the identification of "best" practices, meaning those that are clearly supported by a body of evidence derived from valid and reliable research findings, is still emerging as states implement the requirements. Education stated that as RSA identifies best practices through its monitoring and technical assistance activities, it will, in collaboration with its Office of Special Education Programs, consider when and how best to disseminate this information to state VR and educational agencies. With regard to including specific timeframes and activities in a written plan, by detailing the specific steps Education is taking and plans to take along with the amount of time it expects them to take, Education would be better positioned to complete those steps in a timely manner and meet the statutory requirement that Education highlight best state practices and support state agencies.

Recommendation: The Deputy Commissioner for Hearings Operations should evaluate the costs versus the benefits of changing system limitations that hinder users' ability to correctly and efficiently identify and transfer batches of cases. (Recommendation 2)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed and in May 2019 stated that it is in the early stages of developing and rolling out a new case processing system to replace its Case Processing and Management System called the Hearings and Appeals Case Processing System (HACPS). HACPS will provide end-to-end disability claims processing infrastructure to support the full life-cycle of a disability claim and give users greater flexibility in correctly and accurately transferring cases to and from hearing sites process. It will include hearings and appeals case processing functionality. In early 2020, SSA reported that there were six releases of HACPS from November 2018 through September 2019 and they expect full implementation by early FY 2021.

Recommendation: The Secretary of Defense should direct the Office of Special Needs (OSN) to assess the extent to which each Service is (1) providing sufficient resources for an appropriate number of family support providers, and (2) developing services plans for each family with special needs, and to include these results as part of OSN's analysis of any gaps in services for military families with special needs in each annual report issued by the Department to the congressional defense committees. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: DOD agreed with this recommendation. In April 2019, DOD officials noted they plan to pilot a staffing tool that will help the Services determine the number of family support providers needed at each installation. The pilot currently includes multiple Services and is expected to last two years. DOD officials also noted that DOD is in the process of standardizing its case management processes for military families with special needs through its family needs assessment form. Among other things, this form is meant to help family support providers address requirements for individualized services plans and gain a better understanding of each family's current needs and goals. In its 2018 annual report to the congressional defense committees, DOD noted the National Defense Authorization Act for Fiscal Year 2010 requirement to develop and continuously update an individualized services plan for each military family with special needs. However, DOD said OSN may propose legislative changes to this requirement that would require an individualized services plan to be developed and updated only for those families that request services from family support providers. As of June 2020, we will consider closing this recommendation when the staffing tool is finalized and OSN has assessed each Service's number of family support providers and efforts to develop services plans.

Recommendation: The Secretary of Defense should direct the Office of Special Needs (OSN) to develop common performance metrics for assignment coordination and family support, in accordance with leading practices for performance measurement. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD agreed with this recommendation. In April 2019, DOD officials noted that each Service submits data for assignment coordination and family support to the EFMP data repository on a quarterly basis. According to DOD officials, in 2018, the data repository was expanded to include a full year of quarterly data for each Service, and OSN is currently developing additional performance metrics for assignment coordination and family support. DOD also noted that it will continue to use the data repository to identify gaps and trends related to assignment coordination and family support, including collecting data from each installation. As of June 2020, we await documentation that OSN has developed performance metrics for assignment coordination and family support and uses them to identify gaps and trends across the Services.

Recommendation: The Secretary of Defense should implement a systematic process for evaluating the results of monitoring activities conducted by each Service's EFMP. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: DOD agreed with this recommendation. In April 2019, DOD said the family support component is monitored and evaluated through the each Service's certification process which includes specific standards for the EFMP. In addition, OSN participated in a monitoring site visit to Marine Corps Base Quantico in December 2018 and plans to participate in additional site visits that are coordinated by each Service's certification team. As of June 2020, we will consider closing this recommendation when DOD implements a process to evaluate the results of each Service's certification process.

Recommendation: The Secretary of Veterans Affairs should clearly articulate in VA's appeals plan how VA will monitor and assess the new appeals process compared to the legacy process, including specifying a balanced set of goals and measures--such as timeliness goals for all VBA appeals options and Board dockets, and measures of accuracy, veteran satisfaction, and cost--and related baseline data. (Recommendation 2)

Agency: Department of Veterans Affairs
Status: Open
Priority recommendation

Comments: VA concurred with this recommendation and, as of March 2020, addressed some but not all aspects of it. Regarding monitoring, VA has made progress in monitoring and addressing workload changes in its new and legacy appeals processes. For example, VA has developed sensitivity models and other analyses to monitor and forecast future VBA and Board workloads, production, and staffing requirements to help VA manage the new and legacy appeals processes. Further, the Board is aiming to complete non-remanded legacy appeals by December 2022 by first addressing hearing-requested appeals. However, VBA and the Board have yet to specify a complete set of balanced goals for monitoring the new and legacy appeals processes (e.g., timely and accurate processing of appeals while ensuring veteran satisfaction). For example, the Board will not establish timeliness goals for all new Board options until after collecting additional data during implementation of the new appeals process, thus delaying VA's vision for what successful implementation should look like and hindering awareness of resources required to achieve that vision. Regarding comparing the performance of the new and legacy appeals processes, VA officials have previously reported that they intend to use timeliness and productivity metrics from section 5 of the Appeals Modernization Act. Further, VBA and Board officials have articulated steps they are taking to collect, through surveys, comparable information on veterans' satisfaction with the new and legacy appeals processes. However, VA has not fully articulated detailed steps and timeframes for assessing the relative performance of the new and legacy appeals processes. For example, VA has not indicated how it will assess whether or the extent to which the new process, which also allows for multiple appeal opportunities, will achieve final resolution of veterans' appeals sooner, on average, than the legacy process, as we recommended in GAO-17-234. We will consider closing this recommendation when VA provides documentation indicating how it will assess the new appeals process against the legacy process vis a vis balanced measures.

Recommendation: The Secretary of Veterans Affairs should augment the master schedule for VA's appeals plan to reflect all activities--such as modifications to information technology (IT) systems--as well as assigned responsibilities, interdependencies, start and end dates for key activities for each workgroup, and resources, to establish accountability and reduce overall risk of implementation failures. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with this recommendation. Since our report was issued, VA took significant action on its project plan and in February 2019, implemented the Veterans Appeals Improvement and Modernization Act of 2017. VA provided increasingly more details in updates to its plan about sub-activities related to processing legacy appeals, monitoring implementation, drafting Board policies, training, and testing of the new process. For example, VA added activities related to the Rapid Appeals Modernization Program (RAMP) test of the VBA-only options as well as the test of the new Board options. In spring and summer 2018, according to VA officials, VA set a baseline schedule for implementing appeals reform in response to the potential February 2019 implementation date established in the Act. In October 2018, VA provided us with lower-level schedules and other related information that allowed us to conduct a more detailed assessment of VA's IMS against applicable best practices criteria. However, as of December 2018, VA's schedule did not fully align with best practices. For example, VA's schedule did not contain a work breakdown structure that defines the work, activities, and resources necessary to accomplish implementation-details that would inform resources and time needed for the project. (For details on this assessment, see GAO-19-272T.) While VA fully implemented appeals reform in February 2019, incorporating such lessons learned into future project planning could help VA improve its project scheduling capabilities. Specifically, in February 2020 VA reported that Caseflow-VA's replacement system intended to support appeals reform-had "minimal functionality," with many functionalities yet to be implemented. We will consider closing this recommendation when VA has produced a more complete plan for-and that establishes accountability and reduces risk of failure related to-developing, implementing, and integrating remaining key functionality envisioned under Caseflow. We will also continue tracking whether the Board addresses long-term Caseflow planning under recommendation 2 in GAO-17-234.

Recommendation: The Secretary of Veterans Affairs should ensure that the appeals plan more fully addresses risk associated with appeals reform--for example, by assessing risks against a balanced set of goals and measures, articulating success criteria and an assessment plan for RAMP, and testing or conducting sensitivity analyses of all appeals options--prior to fully implementing the new appeals process. (Recommendation 4)

Agency: Department of Veterans Affairs
Status: Open
Priority recommendation

Comments: The Department of Veterans Affairs (VA) concurred with our recommendation to more fully address risks associated with implementing a new appeals process. As of March 2020, VA has taken many steps to address our recommendation, although key steps are remaining for VA to better assess risks associated with implementing appeals reform and managing appeals workloads in the legacy process. Specifically, since May 2018, VBA and Board officials reported developing and using new sensitivity analyses that would allow the agency to project potential budget needs and staffing requirements. Further, VBA is using these analyses to more accurately predict resolution of legacy appeals given certain assumptions. Furthermore, in addition to testing two appeal options available within VBA through its Rapid Appeals Modernization Program (RAMP), VA conducted small-scale testing of the three new Board appeals options through the Board's Early Applicability of Appeals Modernization (BEAAM) pilot, testing that was missing from VA's original November 2017 plan. VA also reported using lessons learned from testing all appeals options to update the implementation process. However, as designed, RAMP and BEAAM lacked well-defined, measurable criteria for assessing lessons learned from its testing, and the agency did not fully test all aspects of the appeals options before moving to full implementation in February 2019. Even though VA has fully implemented the new disability appeals process without addressing these aspects of our recommendation, many of the other principles of sound planning practices that informed our recommendation remain relevant, even after implementation, to ensure the new process meets veterans' needs. Specifically, VA has not developed mitigation strategies for all identified risks, such as veterans appealing to the Board at higher rates than expected or choosing more resource-intensive Board options, such as those involving new evidence or a hearing. As of January 2020, the more resource-intensive hearing option accounted for over 50 percent of new appeals inventory. At the same time, the Board reported it plans to prioritize resources on reducing the legacy appeals inventory and on the least resource intensive appeal option for which it established a timeliness goal. Although the Board has increased productivity, addressing legacy hearings will take several years as veterans may continue choosing the new hearing option at high rates and the Board prioritizes other workloads. This circumstance could subject veterans to longer wait times and increasing backlogs under the hearing option. As of March 2020, VA also has not established a complete and balanced set of goals and measures for the new appeals options, which are a necessary pre-condition to effectively assessing risk. Lacking a complete set of goals and measures, VA may not have comprehensively identified key risks.

Recommendation: To improve RRB's ability to make accurate disability benefit eligibility determinations, including CDRs, and to decrease the potential for making improper payments, Congress should consider granting RRB access to the Department of Health and Human Services' quarterly earnings information from the National Directory of New Hires database. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: As of March 2020, no legislation has been enacted resulting from this matter to Congress. RRB's (the Board) fiscal year 2020 budget proposal included a legislative proposal to provide the Board access to the NDNH. Although the Board reported that the resulting proposed legislation drafted by HHS - the entity that maintains the NDNH - would, if enacted, provide access to the NDNH, the Board opposed the proposal in part because it would not waive associated fees to access the NDNH, and concluded access to the NDNH would not be cost-effective. In January 2020, the Board informed GAO it is not currently seeking legislation to gain access to the NDNH, resulting in the Board continuing to use earnings data that may be outdated in its continuing disability reviews, but that it may seek access in the future.

Recommendation: To enhance RRB's ability to manage and oversee its CDR program, RRB should routinely compile and analyze CDR program data, such as the number of cases selected for review, the number of beneficiaries in each medical improvement category, outcomes, and the costs and benefits of conducting CDRs, to improve program oversight. (Recommendation 3)

Agency: Railroad Retirement Board
Status: Open

Comments: RRB agreed with this recommendation. In June 2020, RRB reported that its Program Evaluation and Management Services (PEMS) section will compile and analyze all relevant CDR program case and cost data to better oversee CDRs. RRB said that its first analysis would cover CDR's adjudicated from April 2019 through September 2020; as of June 2020 they had adjudicated 107 CDR cases. In addition, RRB reported that its monthly reporting on CDRs to the Director of Disability includes information on the type of CDR completed, the medical improvement category for medical CDR, and the disposition of the CDR. In August 2018, the agency had reported that it began reporting in October 2017 weekly pending CDR type action cases to the Director of Programs, and that it had begun tracking CDR reason codes for each medical improvement category. To close this recommendation, RRB will need to include an analysis of the costs and benefits of conducting CDRs, including any overpayments or underpayments processed, and share its complete analysis of CDRs through September 2020 after it is completed. At that point GAO will review the analysis and decide if it provides a sufficient bases for program oversight.

Recommendation: The Commissioner of SSA should develop a set of public performance measures, to include accuracy and consistency, as well as timeliness, of administrative law judges' (ALJ) disability decisions. SSA could consider whether existing quality review or monitoring efforts could provide suitable data for such measures. (Recommendation 1)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation and stated that it would address it as part of a comprehensive assessment and refinement of its oversight roles and processes. As of February 2020, SSA officials reported that the agency developed a new review of hearing decisions to assess decisional quality on a national level. Officials said they implemented the review throughout fiscal year 2019 and will draft a report on the findings in fiscal year 2020. As they review results from this review, SSA officials said that they will assess whether existing quality review measures will provide suitable data for performance measures related to timeliness, consistency, and accuracy. Officials said they do not have a timeline for implementing this recommendation.

Recommendation: The Commissioner of SSA should systematically evaluate the efficiency and effectiveness of its quality assurance reviews and take steps to reduce or better manage any unnecessary overlap among them to ensure strategic use of resources. Such steps could include enhancing collaboration where reviews overlap or only conducting the reviews that are most efficient and effective in achieving agency goals for improving accuracy and consistency of ALJ disability decisions. (Recommendation 2)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation and stated that it would address this recommendation as part of a comprehensive assessment and refinement of its oversight roles and processes. In March 2018, SSA noted that the Offices of Quality Review and Appellate Operations are now consolidated under the Office of Analytics, Review, and Oversight (OARO). According to SSA, OARO was created with the purposes of enhancing collaboration, eliminating unnecessary overlap, and enhancing the efficiency of reviews. As of February 2020, SSA officials said that they developed a new review of favorable and unfavorable hearing decisions to provide statistically valid results on the quality of decisions on appealed disability claims at the national level. Officials said they will use the results of this one-time review to help assess the utility of their other quality reviews. Successful completion of these efforts should help to ensure effective use of resources in overseeing the quality of decisions on appealed disability claims.

Recommendation: The Acting Commissioner of the Social Security Administration should analyze the SEIE data to determine why a large proportion of transition-age youth on SSI with reported earnings did not benefit from the SEIE and, if warranted, take actions to ensure that those eligible for the incentive benefit from it.

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation. In August 2018, the agency reported that it was evaluating the accuracy of its SEIE data and once completed, the agency would analyze these data to determine whether there are significant numbers of students with earnings who are not benefiting from the SEIE. In February 2020, SSA reported that it was still working to resolve the issues with SEIE data identified during GAO's audit. SSA does not currently have a timeline for completing its analysis of its SEIE data. SSA also reported that it has submitted legislative proposals in several Presidential Budgets, most recently in fiscal year 2021, that would eliminate earnings reporting for youth, which would prevent similar concerns in the future. GAO will close this recommendation when SSA analyzes SEIE data and, if warranted, takes actions needed to ensure those eligible for SEIE benefit from it, or when all students with earnings receive SEIE because SSA's legislative proposal was enacted.

Recommendation: The Acting Commissioner of the Social Security Administration should analyze options to improve communication about SSA-administered work incentives and the implications of work on SSI benefits, with a goal of increasing understanding of SSI program rules and work incentives among transition-age youth and their families. This should include, but not necessarily be limited to, updating SSAs procedures for staff meeting with SSI applicants, recipients, and their families to regularly and consistently discuss - when applicable--how work incentives can prevent reductions in benefit levels and how work history is considered during eligibility redeterminations.

Agency: Social Security Administration
Status: Open

Comments: SSA disagreed with this recommendation. In August 2018, SSA noted it already requires staff to meet with SSI recipients regularly and instructs staff to discuss relevant work incentives, and that there is no indication that staff are not providing youth with appropriate work incentive information. However, SSA did not explain how it knows or ensures that staff are providing this information and SSA policies do not instruct staff to consistently convey information to youth and families on how work may or may not affect age 18 redetermination. SSA also reported that Work Incentives Planning and Assistance (WIPA) projects must prioritize working with youth who are referred to them. While we recognize the important role that WIPA projects play in providing work incentives counseling to SSI youth, as we previously reported, WIPA projects have limited capacity for serving youth along with other SSI recipients and disability insurance beneficiaries. In June 2019, SSA reported it had updated a brochure-containing information in English or Spanish on age-18 redeterminations, impact of earnings on benefits, work incentives and contact information to include information on SSA work incentives that may allow recipients who work to keep their Medicaid benefits. As of February 2020, the agency reported that it began sending this brochure to approximately 358,000 youth between the ages of 14 and 17 who receive SSI, and made this brochure available on its website. SSA also reported that it has begun exploring ways to better utilize social media to reach youth. While these are positive steps, we previously reported that written information may not be sufficient for conveying complex information. GAO continues to believe that SSA field office staff are both obliged and best-positioned to explain these rules. Moreover, in response to an SSA request for information in January 2018, SSA received public feedback on how it might improve transition outcomes for youth on SSI through better communication, suggesting that SSA's current communication strategies may not be sufficiently effective. We will consider closing this recommendation when SSA has taken further steps to ensure field staff are providing consistent and accurate information.

Recommendation: The Acting Commissioner of the Social Security Administration should work with the Secretary of Education to determine the extent to which youth on SSI are not receiving transition services through schools that can connect them to VR agencies and services.

Agency: Social Security Administration
Status: Open

Comments: SSA partially agreed with this recommendation, but after discussing it with the Department of Education, reported that significant challenges exist to pursuing certain implementation approaches. In December 2019, SSA reported that it continues to support research to identify the connection between youth on SSI and the receipt of VR services through its Retirement and Disability Research Consortia and its Analyzing Relationships Between Disability, Rehabilitation, and Work programs. SSA also reported that until very recently, data on open VR cases were unavailable at the national level; thus, it has not been possible to actively monitor SSI and VR participation in a timely manner. However, SSA reported that the agency will explore the possibility of using newly available data on open VR cases as resources allow. Determining the extent to which SSI youth are receiving or have access to services may help youth on SSI achieve employment and, potentially, self-sufficiency.

Recommendation: The Acting Commissioner of the Social Security Administration should explore various options for increasing connections to VR agencies and services, including their potential costs and benefits. One option, among others, could be to expand the Ticket to Work program to include youth.

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation and, in August 2018, SSA officials reported that they had taken several steps to explore and pursue options for increasing youths' connections to vocational rehabilitation agencies and services. Specifically, officials previously reported that they published a request for information (RFI) in the Federal Register in January 2018 that asks, among other things, for strategies to connect youth receiving Supplemental Security Income (SSI) with vocational rehabilitation agencies and about options for programs like a Ticket to Work for youth. In July 2019, SSA reported receiving and analyzing almost 200 responses to its RFI and indicated that it plans to discuss its findings with federal partners and other stakeholders. SSA officials also previously reported that the agency reviewed the Social Security Act and that the law precludes SSA from directly or indirectly referring youth on SSI to vocational rehabilitation agencies. Therefore, as of December 2019, the agency reported that it has submitted legislative proposals in several presidential budgets, including its fiscal year 2021 budget justification, that would allow SSA to refer youth to vocational rehabilitation agencies. SSA officials also reported that the agency has initiated demonstration projects to determine whether youth on SSI benefit from referrals to vocational rehabilitation agencies and commissioned reports related to services for youth.. According to information provided in July 2019, one of SSA's demonstration projects analyzes an experimental intervention to improve the outcomes of children receiving SSI by providing personalized information to families about the likelihood that a child will not continue on SSI as an adult, as well as resources to help these youth with the transition to employment. The resources offered will include: math tutoring, SAT/ACT test preparation, and help with applying for vocational rehabilitation services. In addition, according to information SSA provided in July and December 2019, the agency's second demonstration project will involve testing direct referrals to VR in one state for 19 year olds who are or may become SSI or Social Security Disability Insurance beneficiaries, and involves data sharing between SSA and the state on individuals eligible to participate in the project. This project is scheduled to begin recruiting participants in January 2020. SSA also reported that it has commissioned two reports on youth services that will help it identify implementable polices related to youth. Exploring the potential costs and benefits of employment support services for youth who receive or are at risk of being disability program beneficiaries as adults may help SSA develop programs to support the self-sufficiency of these youth. However, to date, SSA has not indicated that it has explored, or it may be too soon to explore, the costs and benefits of any of the options SSA has considered for increasing access to vocational rehabilitation agencies for youth on SSI.

Recommendation: To better ensure FEMA's regional activities effectively support individuals with disabilities, the Secretary of Homeland Security should direct the FEMA Administrator to take steps to establish written procedures for how regions should involve the Office of Disability Integration and Coordination in clarifying disability integration staff's roles, evaluating staff performance, and setting expectations for how staff communicate with headquarters and the regions.

Agency: Department of Homeland Security
Status: Open

Comments: FEMA agreed with this recommendation and FEMA's Office of Disability Integration and Coordination (ODIC) is in the process of establishing a working group that will clarify and codify the roles, responsibilities, and expectations among the various agency offices and personnel involved in carrying out the agency's disability integration mission. In January 2018, FEMA reported that it had created Regional Integration Teams in the regions to improve the efficiency and efficacy of mission delivery. In August 2018, ODIC reported its goal to meet with Regional Administrators and other senior leaders across the agency by the end of CY 2018 to refine the role for disability integration staff. The reported intent of refining the role is to better align it with the FEMA Administrator's goal of empowering emergency managers in states, localities, tribes, and territories. In June 2019, ODIC officials reported plans to convene a workgroup to examine the role of the Regional Disability Integration Specialist, including their reporting chain and their roles and responsibilities in each of FEMA's ten regions. The workgroup will meet over two months and develop recommendations to be considered by FEMA's Chief of Staff by August 23, 2019. GAO is encouraged by FEMA's efforts to engage Regional Administrators and other senior leaders in its refinement of the role of disability integration staff, and awaits evidence of FEMA establishing documentation of the agency's procedures for carrying out its disability integration mission.

Recommendation: To help ensure its key training on incorporating access and functional needs into emergency planning reaches a sufficiently wide audience, the Secretary should direct the FEMA Administrator to collect information about the potential pool of participants, set general goals for the number of state and local emergency managers that will take this course, and implement the delivery methods needed to meet these goals.

Agency: Department of Homeland Security
Status: Open

Comments: FEMA agreed with this recommendation and reported that it will work with its regional staff to map potential training participants in each state and set goals for delivery of the course to state and local emergency managers. The agency also reported that it may be able to use data in the State Preparedness Report and states' self-reporting on the need for training on integrating the needs of people with access and functional needs into emergency management. As of January 2018, the Office of Disability Integration and Coordination reported plans to hire a permanent staff person to review, assess, and recommend how FEMA should incorporate disability into all internal and external training. In August 2018, FEMA reported hiring a new Program and Policy Branch Chief in July 2018, and noted that this individual will formulate a plan to incorporate the needs of people with disabilities into internal and external training over several weeks. However, FEMA did not address whether this individual will seek information about the potential pool of external participants, or set goals for the number of state and local emergency managers who could participate in external training. FEMA also reported providing just-in-time training in the field to support field staff in providing services to people with disabilities. The agency anticipates completing these efforts by December 31, 2019 and we will consider closing this recommendation when the agency can document it has addressed the recommendation.

Recommendation: To ensure the agency has sufficient information about risks to SSI program integrity when making decisions about efforts to address them, the Commissioner of the Social Security Administration should conduct a risk assessment of the current manual process for connecting and adjusting claim records of SSI recipients who live in households with other SSI recipients, and, as appropriate, take steps to make cost-effective improvements to SSA's claims management system to address identified risks.

Agency: Social Security Administration
Status: Open

Comments: In September 2020, SSA stated that it will include its current manual process for connecting and adjusting claims records for SSI recipients who live in households with other SSI recipients as a potential risk in the agency's upcoming Fraud Risk Assessment of the SSI program. According to SSA officials, the Fraud Risk Assessment will assess the current manual process based on its inherent risks, existing controls to reduce the risks, and the residual effects if the agency implements a process to connect SSI recipients' records. In addition, officials said they will determine a risk response as part of this assessment. SSA anticipates conducting the Fraud Risk Assessment of the SSI program by the end of calendar year 2020.