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entitled 'Social Security Administration: Strategic Workforce Planning 
Needed to Address Human Capital Challenges Facing the Disability 
Determination Services' which was released on January 27, 2004.

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Report to the Chairman, Subcommittee on Social Security, Committee on 
Ways and Means, House of Representatives:

United States General Accounting Office:

GAO:

January 2004:

Social Security Administration:

Strategic Workforce Planning Needed to Address Human Capital Challenges 
Facing the Disability Determination Services:

GAO-04-121:

GAO Highlights:

Highlights of GAO-04-121, a report to the Chairman, Subcommittee on 
Social Security, Committee on Ways and Means, House of 
Representatives

Why GAO Did This Study:

SSA oversees and fully funds primarily state-operated DDSs that 
determine whether applicants are eligible for disability benefits. The 
disability examiners employed by the DDSs play a key role in 
determining benefit eligibility. This report examines (1) the 
challenges the DDSs face today in retaining and recruiting examiners 
and enhancing their expertise; (2) the extent to which the DDSs engage 
in workforce planning and encounter obstacles in doing so; and (3) the 
extent to which SSA is addressing present and future human capital 
challenges in the DDSs.

What GAO Found:

GAO found—through its survey of 52 of the 54 Disability Determination 
Service (DDS) directors and interviews with SSA officials and DDS 
staff—that the DDSs face three key challenges in retaining examiners 
and enhancing their expertise:

High turnover: Over half of all DDS directors surveyed said that 
examiner turnover was too high in their offices. We found that 
examiner turnover was about twice that of federal employees performing 
similar work. Nearly two-thirds of all directors reported that 
turnover has increased SSA’s hiring and training costs and claims-
processing times. And two-thirds of all directors cited stressful 
workloads and noncompetitive salaries as major factors that 
contributed to turnover.

Recruiting and hiring difficulties: More than three-quarters of all 
DDS directors said they had difficulties over a three-year period in 
recruiting and hiring examiners. Of these, more than three-quarters 
said these difficulties contributed to increases in claims-processing 
times, examiner caseload levels, backlogs, and turnover. More than 
half of all directors reported that state-imposed compensation limits 
contributed to hiring difficulties.

Gaps in key skills: Nearly one-half of all DDS directors said that at 
least a quarter of their examiners needed additional training in areas 
critical to disability decision-making. Over half of all directors 
cited factors related to high workload levels as obstacles to 
examiners’ receiving additional training.

Despite the workforce challenges facing them, a majority of DDSs do 
not conduct long-term, comprehensive workforce planning. In prior 
reports, GAO found that such planning should include key strategies 
for recruiting, retaining, training, and otherwise developing a 
workforce capable of meeting long-term agency goals. However, of the 
DDSs that engage in longer-term workforce planning, a majority have 
plans that lack such key workforce planning strategies. Directors 
cited numerous obstacles to long-term workforce planning, such as 
lengthy state processes to approve DDS human capital changes.

SSA’s workforce efforts have not sufficiently addressed current and 
future DDS human capital challenges. Federal law requires agencies to 
include in their annual performance plans a description of the human 
capital strategies needed to meet their strategic goals. However, 
GAO’s review of key SSA planning documents shows they do not include a 
strategic human capital plan that addresses current and future DDS 
human capital needs. Thus, SSA does not link its strategic objectives 
to a workforce plan that covers the very people who are essential to 
accomplishing those objectives. GAO also found that SSA has not 
provided human capital assistance in a consistent manner across the 
DDSs and that SSA’s effectiveness in helping the DDSs negotiate human 
capital changes with the states can be limited by such factors as 
state budget problems and personnel rules. Finally, SSA has not used 
its authority to establish uniform human capital standards, such as 
minimum qualifications for examiners, which would address, on a 
nationwide basis, some of the DDS challenges.

What GAO Recommends:

While acknowledging the difficulties SSA faces in addressing DDS human 
capital issues within the federal-state context, GAO recommends that 
SSA improve its workforce planning by:

* Developing a nationwide strategic workforce plan that addresses 
present and future DDS human capital challenges; 

* Establishing uniform minimum qualifications for examiners; and

* Working with DDSs to close gaps between current and required 
examiner skills.

In its comments, SSA generally agreed with our recommendations’ intent 
but said that we did not fairly or adequately address the many sides 
of DDS human capital management issues. We continue to believe that 
the report is fair and balanced and that our scope and methods allowed 
us to adequately address these issues.

www.gao.gov/cgi-bin/getrpt?GAO-04-121.

To view the full product, including the scope and methodology, click 
on the link above. For more information, contact Robert E. Robertson 
at (202) 512-7215 or Robertsonr@gao.gov.

[End of section]

Contents:

Letter:

Results in Brief:

Background:

DDSs Face High Turnover, Recruiting and Hiring Difficulties, and Gaps 
in Key Knowledge and Skill Areas:

The Majority of DDSs Do Not Conduct Long-Term, Comprehensive Workforce 
Planning, and DDSs Cite Numerous Obstacles to Doing So:

SSA's Workforce Efforts Have Not Sufficiently Addressed Present and 
Future Human Capital Challenges in the DDSs:

Conclusions:

Recommendations to the Commissioner of SSA:

Agency Comments and Our Evaluation:

Appendix I: Scope and Methods:

Survey of Disability Determination Service Offices:

Analysis of Data from Our Survey and Other Sources:

Appendix II: Survey of DDS Directors' Views on Human Capital 
Challenges:

Appendix III: Related GAO Reports:

Modernizing Federal Disability Programs:

General Human Capital Management:

Strategic Workforce Planning:

Organizational Transformation:

Training and Development:

Appendix IV: Comments from the Social Security Administration:

GAO Comments:

Appendix V: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Staff Acknowledgments:

Tables:

Table 1: Turnover Rates for DDS Examiners, VBA Examiners, SSA 
Employees, and All Federal Employees:

Figures:

Figure 1: Percentage of DDSs by Type of Minimum Education Requirement 
for New Disability Examiners:

Figure 2: Three-Year Average Examiner Turnover Rates for Individual 
DDSs (Fiscal Years 2000 to 2002):

Figure 3: Distribution of Average State DDS Examiner Salaries as a 
Percentage of Average VBA Examiner Salaries:

Figure 4: Percentage of DDSs by their Workforce Planning Time Horizons:

Figure 5: Means and Strategies Addressing the DDS Workforces Are 
Largely Absent from SSA's Strategic and Workforce Plans:

Abbreviations:

DDS: Disability Determination Service:

DE: disability examiners:

DI: Disability Insurance:

NGA: National Governors Association:

OPM: Office of Personnel Management:

SDM: single decision-maker:

SSA: Social Security Administration:

SSI: Supplemental Security Income:

VBA: Veterans Benefits Administration:

United States General Accounting Office:

Washington, DC 20548:

January 27, 2004:

The Honorable E. Clay Shaw, Jr.: 
Chairman, Subcommittee on Social Security: 
Committee on Ways and Means: 
House of Representatives:

Dear Mr. Chairman:

In 2002, the Social Security Administration's (SSA) Disability 
Insurance (DI) and Supplemental Security Income (SSI) programs paid 
about $74.1 billion to about 8.5 million individuals with disabilities. 
Under the Social Security Act, SSA oversees and fully funds 54 
primarily state-operated Disability Determination Service (DDS) 
offices that determine whether applicants are eligible for disability 
benefits. Key to the accuracy and timeliness of these disability 
determinations are the more than 6,500 disability examiners employed by 
the DDSs to review medical and vocational evidence and help decide 
eligibility for disability benefits. The critical role played by the 
examiners will likely increase in the future, with the projected 
dramatic growth over the next decade in the number of applications for 
disability benefits as baby boomers enter their disability-prone years.

In our prior work, we have noted that the DDSs are confronting an 
impending retirement wave of skilled staff and stiff competition in the 
labor market for qualified staff.[Footnote 1] At the same time, SSA is 
facing problems with the accuracy and timeliness of its disability 
determinations. Beyond these immediate challenges, the design of SSA's 
disability programs remains grounded in outmoded concepts of disability 
that persist despite scientific advances and economic and social 
changes that have redefined the relationship between impairments and 
the ability to work. Because other federal disability programs are also 
not in line with the current status of science and the labor market, we 
designated modernizing federal disability programs--including SSA's DI 
and SSI programs--as a high-risk area in 2003.[Footnote 2] In September 
2003, the Commissioner unveiled her vision of a long-term strategy for 
improving the disability claims process to enhance timeliness and 
accuracy of decisions and for testing work incentives and opportunities 
aimed at helping people with disabilities return to work.[Footnote 3] 
The success of such a fundamental reorientation of SSA's disability 
determination process will depend greatly on having the staff with the 
right skill mixes and areas of expertise available when and where 
needed. DDS workforces will be a critical component in any future 
restructuring undertaken by SSA to modernize its disability programs.

In view of the significance of human capital management in the DDSs, 
this report addresses (1) the challenges the DDSs face today in 
retaining and recruiting examiners and enhancing their expertise, (2) 
the extent to which the DDSs engage in workforce planning and encounter 
obstacles in doing so, and (3) the extent to which SSA is addressing 
present and future human capital challenges in the DDSs.

To address these issues, we surveyed directors of 52 of the 54 
primarily state-operated DDSs.[Footnote 4] Our survey included 
questions about long-term workforce planning, recruiting and hiring, 
compensation, training and development, and retention of disability 
examiners. We also collected human capital data from the federal DDS, 
which provides case-processing assistance to state DDSs during periods 
of high workload demands, among other responsibilities.

For the purposes of this report, strategic workforce planning is a 
framework for decision-making that aims to ensure that an organization 
has the people with the right skills, available when and where needed, 
to respond to change and accomplish the agency's strategic 
goals.[Footnote 5] To be effective, workforce planning must be fully 
integrated with the agency's mission and goals and must be based on 
accurate and comprehensive workforce data. While such planning can 
include a range of programs and strategies, our prior work[Footnote 6] 
has found that the following strategies are key to effective workforce 
planning, including:

* recruiting strategies,

* retention strategies,

* training and professional development strategies,

* compensation strategies,

* performance expectation and evaluation strategies,

* employee-friendly workplace strategies,

* succession planning and strategies for maintaining expertise in the 
long term, and:

* contingency plans, in the event that resource levels do not meet 
expectations.

In addition, we reviewed relevant documents, including SSA laws, 
regulations, and procedures, and other pertinent laws. We also obtained 
and analyzed human capital data from DDSs, SSA, and other federal 
agencies. We interviewed disability examiners and their managers at two 
DDSs to gain an in-depth understanding of the issues related to our 
objectives. We also visited three SSA regional offices, interviewing 
officials who are responsible for DDS management assistance and serve 
as liaisons between SSA regional offices, the DDSs, and their 
respective state governments. In addition, we interviewed SSA officials 
at headquarters and a variety of key stakeholders such as officials of 
the National Council of Disability Determination Directors, the 
National Association of Disability Examiners, and staff of the Social 
Security Advisory Board. We performed our work in accordance with 
generally accepted government auditing standards between September 2002 
and October 2003. For more details about our scope and methods, see 
appendix I. For a copy of our survey, see appendix II.

Results in Brief:

DDSs face three key challenges in retaining examiners and enhancing 
their expertise: (1) high turnover, (2) recruiting and hiring 
difficulties, and (3) gaps in key knowledge and skills:

* High turnover. Results from GAO's survey of 52 DDSs show that over 
half of all DDS directors surveyed said that examiner turnover was too 
high in their offices. We also found that examiner turnover was about 
twice that of federal employees performing similar work. Nearly two-
thirds of all directors reported that turnover has increased SSA's 
hiring and training costs, decreased overall staff skill levels, and 
increased claims-processing times. In addition, two-thirds of all DDS 
directors cited stressful workloads and noncompetitive salaries as 
major factors that contributed to turnover.

* Recruiting and hiring difficulties. More than three-quarters of all 
DDS directors (43) reported experiencing difficulties over a three-year 
period in recruiting and hiring enough people who could become 
successful examiners. Of these directors, more than three-quarters 
reported that such difficulties contributed to increases in claims-
processing times, examiner caseload levels, backlogs, and turnover. In 
addition, more than half of all directors reported that state-imposed 
compensation limits contributed to these hiring difficulties, and more 
than a third of all directors attributed hiring difficulties to other 
state restrictions, such as hiring freezes.

* Gaps in key knowledge and skills. Nearly one-half of all DDS 
directors said that at least a quarter of their examiners need 
additional training in areas critical to disability decision-making, 
such as assessing symptoms and credibility of medical information, 
weighing medical opinions, and analyzing a person's ability to 
function. Over half of all directors cited factors related to high 
workload levels that limit trainer and trainee time as obstacles to 
examiners' receiving additional training.

Despite the workforce challenges facing the DDSs, data from our survey 
show that the majority of DDSs do not undertake long-term, 
comprehensive workforce planning, citing numerous obstacles to doing 
so. More than half of all the DDSs have workforce planning time 
horizons of less than two years. Moreover, among the DDSs that engage 
in workforce planning that is longer-term than one year, the majority 
have plans that lack key workforce planning strategies, such as those 
for recruiting, retention, or succession planning. The directors who 
report that they do not engage in workforce planning that is longer-
term than one year instead mainly rely on SSA's annual budget process 
for their workforce planning, even though GAO's research shows that the 
budget process does not constitute comprehensive workforce planning. 
Moreover, over half of all the DDSs do not make projections of 
retirements and other separations. DDS directors cited a number of 
obstacles that made long-term workforce planning more difficult than it 
would be otherwise. For example, two-thirds of all DDS directors 
reported that long-term planning is made more difficult by 
inconsistencies between state and SSA human capital policies and 
uncertainties about future resource levels from SSA. Further, three-
quarters of all directors said that they had insufficient time to 
attend to future problems because of the need to focus on current human 
capital challenges.

SSA's workforce efforts have not sufficiently addressed present and 
future DDS human capital challenges. The Government Performance and 
Results Act now requires agencies to include in their annual 
performance plans a description of the human capital strategies needed 
to meet their strategic goals. However, GAO's review of SSA's planning 
documents shows that neither SSA's strategic plan, nor its annual 
performance plan, nor its workforce plan contains a strategic human 
capital plan that addresses current and future DDS human capital needs. 
Thus SSA does not link its strategic objectives (such as making the 
right decision in the disability process as early as possible) to a 
workforce plan that covers the very people who are essential to 
accomplishing those objectives. In addition, one-half or more of DDS 
directors reported being dissatisfied with the adequacy of training 
that SSA provides to the DDSs in a number of key knowledge and skill 
areas. Beyond training, an analysis of GAO's survey data shows that SSA 
has not provided other human capital assistance in a consistent manner 
across the DDSs. For example, of the DDS directors who reported wanting 
help from SSA with negotiating human capital changes with the states 
(for example, in negotiating salary increases for examiners), more than 
half (24 DDSs) said that they had not received it. Moreover, more than 
half of the DDS directors who received such assistance (11 DDSs) said 
it was of limited effectiveness. Regional office officials and DDS 
directors explained in interviews, however, that the effectiveness of 
SSA and its regional offices in providing such help can be limited by 
such factors as state budget problems, political concerns, and 
personnel rules. Finally, SSA has not used the statutory authority it 
has to establish uniform human capital standards, such as minimum 
qualifications for disability examiners, which would address, on a 
nationwide basis, some of the human capital challenges facing the DDSs. 
The agency has instead allowed the states to retain maximum flexibility 
in the human capital management arena, citing potential difficulties 
inherent in changing the federal-state relationship. For example, some 
SSA officials expressed concern that states might perceive the 
establishment of uniform human capital standards as an unwelcome 
federal intrusion into state operations. While acknowledging these and 
other significant difficulties, several DDS and SSA officials 
interviewed by GAO expressed the view that uniform standards could help 
address the human capital challenges confronting the DDSs.

GAO is making several recommendations in this report to the 
Commissioner of Social Security to improve SSA's strategic workforce 
planning to address present and future human capital challenges facing 
the DDSs. These recommendations include that SSA work in partnership 
with the DDSs to develop a nationwide strategic workforce plan to 
address present and future human capital challenges facing the DDSs, 
establish uniform minimum qualifications for new examiners, and work 
with the DDSs to close gaps between current and required examiner 
skills. In commenting on a draft of this report, SSA officials 
generally agreed with the intent of our recommendations but stated that 
the report does not fairly address or adequately discuss the many sides 
of DDS human capital management issues. In particular, SSA criticized 
some of our study's methods and expressed concern that we did not 
sufficiently acknowledge the difficulties involved in making changes to 
the federal-state relationship. For example, SSA said that we relied 
heavily on opinions of DDS directors and that we did not sufficiently 
acknowledge the attitudes of the states toward modifying federal 
regulations to establish uniform human capital standards and the 
complexities involved. We surveyed DDS directors because they are some 
of the most knowledgeable respondents about human capital challenges 
facing their organizations. But in addition to our survey, we gathered 
information from a variety of sources, including site visits to three 
SSA regional offices, interviews with SSA officials at headquarters, 
and analyses of human capital data. In addition, our report 
acknowledged the difficulties SSA has encountered in convincing the 
DDSs to comply with SSA guidelines on personnel issues and stressed 
that establishing uniform qualifications for examiners will be 
difficult. But we maintain that, despite such difficulties, as the 
agency with fiduciary responsibility for administering multibillion 
dollar disability programs that are nationwide in scope, SSA is 
obligated to address the human capital challenges facing the DDSs. We 
continue to believe that the report presents a fair and balanced 
portrayal of the multifaceted issue of human capital management in the 
DDSs. Our summary evaluation of the agency's comments begins on page 
44. SSA's comments and our responses are provided in full in appendix 
IV.

Background:

The DI and SSI programs are the two largest federal programs providing 
cash assistance to people with disabilities. The DI program, 
established in 1956 by the Social Security Act, provides monthly cash 
benefits to workers with disabilities (and their dependents and 
survivors) whose employment history qualifies them for disability 
benefits. In 2002, SSA paid about $55.5 billion in DI benefits to 5.5 
million workers with disabilities (age 18 to 64).[Footnote 7] SSI is a 
means-tested income assistance program created in 1972 that provides a 
financial safety net for individuals who are aged or blind or have 
other disabilities and who have low income and limited resources. 
Unlike the DI program, SSI has no prior work requirement. In 2002, SSA 
paid about $18.6 billion in SSI federal benefits to about 3.8 million 
people with disabilities (age 18 to 64).

SSA's Disability Determination Process:

To be considered eligible for benefits for either SSI or DI as an 
adult, a person must be unable to perform any substantial gainful 
activity by reason of a medically determinable physical or mental 
impairment that is expected to result in death or that has lasted or 
can be expected to last for a continuous period of at least 12 months. 
Work activity is generally considered to be substantial and gainful if 
the person's earnings exceed a particular level established by statute 
and regulations.[Footnote 8]

To obtain disability benefits, a claimant must file an application 
online, by phone or mail, or in person at any of SSA's field 
offices.[Footnote 9] If the claimant meets the non-medical eligibility 
criteria, the field office staff forwards the claim to the appropriate 
DDS office. DDS staff--generally a team composed of disability 
examiners and medical consultants--obtains and reviews medical and 
other evidence as needed to assess whether the claimant satisfies 
program requirements, and makes the initial disability determination. 
If the claimant is not satisfied with the decision, the claimant may 
ask the DDS to reconsider its finding.[Footnote 10] If the claimant is 
not satisfied with the reconsideration, the claimant may request a 
hearing before one of SSA's federal administrative law judges in an SSA 
hearing office. If the claimant is still dissatisfied with the 
decision, the claimant may request a review by SSA's Appeals 
Council.[Footnote 11]

The Federal-State Relationship:

The 1954 amendments to the Social Security Act specified that 
disability determinations would be made by state agencies under 
individual contractual agreements with SSA. Under these agreements, 
SSA's primary role was to fund the states' disability operations. 
However, following criticism from GAO and others about the quality and 
uniformity of the disability determination process, Congress amended 
the Social Security Act in 1980 to strengthen SSA management of the 
disability programs and allow greater SSA control and oversight of the 
DDSs. The 1980 amendments directed SSA to issue regulations specifying 
performance standards and administrative requirements to be followed to 
assure effective and uniform administration of disability 
determinations across the nation.[Footnote 12]

The regulations issued by SSA, which established the current federal-
state relationship, allow SSA to remove the disability determination 
function from a state if the DDS fails to make determinations that meet 
thresholds for performance accuracy and processing time.[Footnote 13] 
SSA's regulations give DDSs maximum managerial flexibility in meeting 
the performance standards, allowing them to retain substantial 
independence in how they manage their workforce.[Footnote 14] For 
example, under the regulations, the DDSs are to follow state personnel 
standards in selection, tenure, and compensation of DDS 
employees.[Footnote 15]

As employees of the state, DDS staff are subject to the rules and 
regulations of each state's individual personnel classification system. 
Classification systems generally categorize positions on the basis of 
job responsibilities and the knowledge, skills, and competencies 
required to perform them. Within a classification system, a group of 
positions that have sufficiently similar responsibilities are put in 
the same class. Arranging positions in classes with common levels of 
difficulty and responsibility makes it possible to set ranges of 
compensation for whole classes of jobs across multiple state agencies. 
Specifying the responsibilities of each position also allows the state 
to identify and develop effective hiring qualifications, promotion 
criteria, and training requirements. The development and operation of 
such a classification system depend upon the adequacy of information 
about individual positions.

Description of the DDSs and the Disability Examiner Position:

Within the federal-state relationship, each DDS reports to its own 
state government, usually to a parent agency such as the state 
vocational rehabilitation agency.[Footnote 16] DDS staff generally 
include a variety of positions, such as medical consultants, vocational 
specialists, quality assurance personnel, as well as disability 
examiners. The number of disability examiners varies substantially 
among the DDSs. Data from our survey show that the number of full-time 
permanent examiners in each DDS ranged from 9 to 529 at the end of 
fiscal year 2002. Our prior work has found that the examiner's job--
which involves working with medical consultants to determine impairment 
severity, ability to function, and disability benefit eligibility--
requires considerable expertise and knowledge of complex regulations 
and policies.[Footnote 17] And according to the Social Security 
Advisory Board, changes in agency rules and in the types of disability 
claims received by the DDSs have made disability decision-making more 
subjective and difficult.[Footnote 18] In addition, as part of its 
efforts to reduce claims-processing times, SSA has been testing a new 
disability examiner position called the single decision-maker (SDM), 
which would expand an examiner's authority to independently decide 
claimants' eligibility for benefits.[Footnote 19] 20 DDSs are testing 
this new position.

Qualification requirements for new examiner hires vary substantially 
among the states. While five DDSs require a master's or a registered 
nursing degree for certain new examiner hires, figure 1 shows that over 
one-third of all DDSs can hire new examiners with either a high school 
diploma or less.[Footnote 20] In addition, data show that examiners in 
nearly one-half of all DDSs are covered by union agreements, and issues 
related to compensation levels, hiring and promotion procedures, and 
weekly hours worked are open to union negotiation in the majority of 
these DDSs.

Figure 1: Percentage of DDSs by Type of Minimum Education Requirement 
for New Disability Examiners:

[See PDF for image]

Note: These figures represent the lowest possible educational level a 
DDS requires for a new examiner, regardless of the type of applicant 
for the job. Data provided in the figure do not add to 100 percent due 
to rounding. One DDS did not answer this question.

[End of figure]

To enhance the skills of both new and experienced examiners, SSA 
provides a number of optional training tools to the DDSs, including 
written materials covering new examiner basic training, interactive 
video programs supplementing basic training and providing refresher 
training and updates on policy changes, and materials and presentations 
provided by the regional offices and SSA headquarters. However, states 
have primary responsibility for training examiners, and many DDSs adapt 
or supplement SSA's training to meet their examiners' training needs. 
DDSs generally provide new examiners with SSA's basic examiner 
training, followed by extensive on-the-job training, including 
mentoring by experienced examiners who guide the less experienced 
examiners in becoming more proficient in the disability claims process. 
New hires generally are not considered fully proficient until after one 
to two years of experience.

The DDSs' ability to hire examiners is affected by both SSA and state 
government funding decisions and hiring policies. SSA determines the 
funding available for each DDS and advises the DDSs about the number of 
full-time equivalent staff supported by this funding, and SSA adjusts 
these levels throughout the fiscal year based on workload fluctuations 
and funding availability. Normally SSA allows DDSs to replace staff who 
leave the DDS as long as they remain within authorized staffing levels, 
but for over half of fiscal year 2003, SSA froze DDS hiring, preventing 
DDSs from hiring new examiners or replacing those who had left. SSA 
officials told us that the temporary freeze was necessary to ensure 
that SSA's expenditures did not exceed authorized levels and to avoid 
future layoffs of DDS staff.[Footnote 21]

DDSs also have experienced state government hiring restrictions in 
recent years. Despite full federal funding, under the current 
federal-state relationship, DDSs generally cannot spend funds for new 
personnel without the approval of their state governments. States 
currently are facing severe budget crises, causing them to cut their 
payrolls for most state government functions. When states use methods 
such as hiring freezes, reductions in force, and early retirement 
incentives to limit spending on state employee payrolls, these policies 
sometimes prevent DDSs from hiring and retaining examiners at levels 
authorized by SSA.

Modernizing Federal Disability Programs Designated as a High-Risk Area:

In earlier reports, we have noted that SSA's disability determination 
process is mired in concepts from the past and needs to be brought into 
line with the current state of science, medicine, technology, and labor 
market conditions.[Footnote 22] With other federal disability programs 
similarly structured around outmoded concepts, we designated 
modernizing federal disability programs--including SSA's DI and SSI 
disability programs--as a high-risk area in 2003.[Footnote 23] (See 
appendix III for a list of GAO reports on modernizing federal 
disability programs.) We made this designation owing in part to SSA's 
(1) outmoded concepts of disability, (2) lengthy processing times, and 
(3) decisional inconsistencies:

* SSA's outmoded concepts of disability. While technological and 
medical advances and societal changes have increased the potential for 
some people with disabilities to participate in the labor force, few DI 
and SSI beneficiaries leave the disability rolls to work. Our prior 
work shows that, unlike some private sector disability insurers and 
social insurance systems in other countries, SSA does not incorporate 
into its disability eligibility assessment process an evaluation of 
what is needed for an individual to return to work.[Footnote 24] These 
private insurers and other social insurance systems have access to 
staff with a wide range of expertise to apply, not only in making 
eligibility decisions, but also in providing return-to-work assistance. 
We have recommended that SSA develop a comprehensive return-to-work 
strategy that integrates earlier identification of work capacities and 
the expansion of such capacities by providing return-to-work assistance 
for applicants and beneficiaries. Adopting such a strategy is likely to 
require fundamental changes to the disability determination process, as 
well as changes to staff skill mixes and areas of expertise.

* Lengthy processing times for disability claims. The disability claims 
process can be lengthy, with many individuals who appeal SSA's initial 
decision waiting a year or longer for final decisions on their benefit 
claims. According to SSA, a claimant can wait as long as 1,153 days 
from initial claim through a decision from the Appeals Council. As one 
means of reducing its claims-processing time, SSA aims to eliminate 
backlogs for initial disability claims, hearings, and appeals by 2008. 
Nevertheless, growth in the disability claims workload is likely to 
exacerbate SSA's claims-processing challenges: SSA expects the DI rolls 
to grow by 35 percent between 2002 and 2012.[Footnote 25]

* Inconsistencies in disability decisions. SSA has had difficulty 
ensuring that decisions regarding a claimant's eligibility for 
disability benefits are accurate and consistent across adjudicative 
levels and locations, raising questions about the fairness, integrity, 
and cost of these programs.[Footnote 26] For example, the Social 
Security Advisory Board has shown wide variances among the DDSs in 
rates of allowances and denials of disability benefits.[Footnote 27] 
The Advisory Board has cited differences in state-established personnel 
policies such as salaries, training, and qualifications of disability 
examiners across the DDSs, along with state economic and demographic 
differences, as some of the key factors that may affect the consistency 
of disability decision-making.[Footnote 28]

SSA's New Long-Term Strategy for Improving Its Disability Programs:

The Commissioner's September 2003 testimony sets forth her long-term 
strategy for improving the timeliness and accuracy of the disability 
claims process and fostering return to work for people with 
disabilities. For example, to speed decisions for some claimants, the 
Commissioner intends to initiate an expedited decision for claimants 
with more easily identifiable disabilities, such as aggressive cancers. 
Under this new approach, special units located primarily in SSA's 
regional offices would handle the expedited claims, leaving DDS 
examiners responsible for evaluating the more complex claims. The 
Commissioner's strategy also aims to increase decisional accuracy by, 
among other approaches, requiring DDS examiners to develop more 
complete documentation of their disability determinations, including 
explaining the basis for their decisions. Beyond steps to improve the 
timeliness and accuracy of the process, the Commissioner also plans to 
conduct several demonstrations aimed at helping people with 
disabilities return to work by providing work incentives and 
opportunities earlier in the disability process.

In addition, to improve the disability decision process, the 
Commissioner has implemented some shorter-term remedies while 
developing her longer-range strategies. For example, SSA is 
accelerating its transition to an electronic disability claims folder, 
through which the DDSs, the field offices, and the Office of Hearings 
and Appeals are to be linked to one another. The folder is being 
designed to transmit case file data electronically from one claims-
processing location to another and to serve as a data repository--
storing documents that are keyed in, scanned, or faxed. According to 
the Commissioner, successful implementation of the electronic folder is 
essential for improving the disability process. In our prior work, we 
have cautioned SSA to ensure that it has the right mix of skills and 
capabilities to support this major technological transition.[Footnote 
29]

Strategic Human Capital Management Designated a High-Risk Area:

Recognizing the importance of people to the success of any organization 
in managing for results, GAO designated strategic human capital 
management a government-wide high-risk area in 2001.[Footnote 30] In 
prior reports on this high-risk area, we identified strategic workforce 
planning as essential to effective performance and stated that it 
should be a priority of agency leaders.[Footnote 31] We also noted that 
effective workforce planning must be fully integrated with an agency's 
mission and program goals and be based on accurate and comprehensive 
workforce data. We recently identified a few key principles for 
strategic workforce planning.[Footnote 32] These principles include:

* involving top management, employees, and other key stakeholders in 
developing, communicating, and implementing the workforce plan;

* determining the critical skills and competencies needed to achieve 
current and future program goals, and developing strategies to fill 
identified gaps;

* building the capability necessary to address administrative, 
educational, or other requirements to support the workforce strategies; 
and:

* monitoring and evaluating progress in meeting workforce goals and how 
well the workforce plan has contributed to reaching overall program 
goals.

Congress has additionally recognized the importance of workforce 
planning and, in 2002, added to the Government Performance and Results 
Act a provision requiring agencies to include human capital strategies 
needed to meet their strategic goals in their annual performance 
plans.[Footnote 33] We have found that high-performing organizations 
use workforce planning as a management tool to develop a compelling 
case for human capital investments and to anticipate and prepare for 
upcoming human capital issues that could jeopardize accomplishment of 
the organizations' goals.[Footnote 34] (See appendix III for a list of 
GAO reports on human capital management.):

DDSs Face High Turnover, Recruiting and Hiring Difficulties, and Gaps 
in Key Knowledge and Skill Areas:

The DDSs face several key challenges in retaining disability examiners 
and enhancing their expertise: high turnover, difficulties in 
recruiting and hiring, and gaps in key knowledge and skill areas. The 
DDSs are experiencing high and costly turnover of examiners, which data 
from our survey show is fostered in part by stressful workloads and 
noncompetitive salaries. DDSs need to recruit and hire sufficient 
numbers of qualified new examiners to fill the vacancies resulting from 
the high turnover. Yet more than three-quarters of DDS directors 
reported recruiting and hiring difficulties. Directors said such 
difficulties were due in part to state-imposed personnel restrictions, 
such as state limits on examiner salaries and hiring. Finally, 
directors reported that many examiners need additional training in key 
analytical areas that are critical to disability decision-making, 
including assessing credibility of medical information, evaluating 
applicants' symptoms, and analyzing applicants' ability to function.

DDSs Face High and Costly Turnover Fostered by Stressful Workloads and 
Noncompetitive Salaries:

Over half of all DDS directors responding to our survey said that 
examiner turnover in their offices was too high. Our analysis of data 
from our survey and from federal agencies shows that, over fiscal years 
2000 through 2002, DDS examiner turnover was about twice that of 
Veterans Benefits Administration (VBA) disability examiners with 
responsibilities similar to those of DDS examiners.[Footnote 35] For 
example, DDS examiner turnover averaged 13 percent over fiscal years 
2000 to 2002, compared with 6 percent for VBA disability examiners. 
(See table 1.) In addition, during the same period, the turnover rate 
of DDS examiners was substantially greater than that of all SSA 
employees as well as that of all federal government employees.[Footnote 
36] DDS examiner turnover has been even higher among new hires: 
turnover of examiners hired in fiscal year 2001 was 25 percent, 
compared with 14 percent among all DDS examiners.[Footnote 37] 
Moreover, while it is typical for new hires to leave at higher rates 
than other employees, turnover of new DDS examiners was considerably 
higher than that of new VBA examiners, new SSA employees, and all new 
federal government employees in fiscal years 2000 and 2001.

Table 1: Turnover Rates for DDS Examiners, VBA Examiners, SSA 
Employees, and All Federal Employees:

National turnover rates[A]:

Fiscal year: 2000; 

Experienced staff and new hires[B]: 

DDS examiners: 15%; 
VBA examiners: 5%; 
SSA employees: 6%; 
All federal employees: 8%; 

New hires only[C]: 

DDS examiners: 31%; 
VBA examiners: 19%; 
SSA employees: 16%; 
All federal employees: 24%.

Fiscal year: 2001; 

Experienced staff and new hires[B]: 

DDS examiners: 14; 
VBA examiners: 6; 
SSA employees: 5; 
All federal employees: 7; 

New hires only[C]: 

DDS examiners: 25; 
VBA examiners: 18; 
SSA employees: 14; 
All federal employees: 21.

Fiscal year: 2002; 

Experienced staff and new hires[B]: 

DDS examiners: 12; 
VBA examiners: 7; 
SSA employees: 5; 
All federal employees: 7; 

New hires only[C]: 

DDS examiners: [D]; 
VBA examiners: [D]; 
SSA employees: [D]; 
All federal employees: [D].

Average[E]; 

Experienced staff and new hires[B]: 

DDS examiners: 13; 
VBA examiners: 6; 
SSA employees: 5; 
All federal employees: 7; 

New hires only[C]: 

DDS examiners: 28; 
VBA examiners: 18; 
SSA employees: 15; 
All federal employees: 22. 

Source: GAO analysis of data from our survey of DDS directors, April 
2003, and from the U.S. Office of Personnel Management's Central 
Personnel Data File.

[A] The calculation of the annual turnover rate and the new hire 
turnover rate for SSA and VBA examiners included transfers to other 
agencies within the federal government, but such transfers were not 
included in the turnover rate calculation for federal employees 
government-wide. In addition, some DDSs did not provide complete 
turnover data for all three years. The fiscal year 2000 turnover rate 
for experienced DDS staff is based on data from 47 DDSs; the fiscal 
year 2001 rate is based on data from 49 DDSs; and the fiscal year 2002 
rate is based on data from 52 DDSs. The average turnover rate accounts 
for these differences in number of DDSs and total employees across 
years.

[B] We based our calculation of the annual turnover rate for DDS 
examiners, VBA examiners, and SSA employees on the total number of 
retirements and other separations during a fiscal year, divided by the 
average number of permanent employees. We calculated the number of 
permanent employees by averaging the total number employed at the 
beginning and the end of the fiscal year.

[C] We based our calculation of the yearly new hire turnover rate on 
the total number of new hires separating in the fiscal year following 
their year of hire, divided by the total number hired in that year.

[D] No data available.

[E] Average turnover rates for experienced staff and new hires are 
based on fiscal years 2000, 2001, and 2002. Average turnover rates for 
new hires only are based on fiscal years 2000 and 2001.

[End of table]

Our survey results also show that examiner turnover is particularly 
high in some DDSs. An examination of three-year averages (fiscal years 
2000 to 2002) of DDS turnover rates showed that one DDS had a turnover 
rate of 43 percent, and a quarter of the DDSs had turnover rates of 20 
percent or greater. (See fig. 2.):

Figure 2: Three-Year Average Examiner Turnover Rates for Individual 
DDSs (Fiscal Years 2000 to 2002):

[See PDF for image]

Note: Three-year average turnover rates are based on data from 47 DDSs. 
Five DDSs did not provide turnover data for all three fiscal years 
(2000, 2001, and 2002). The highest three-year turnover rate was 43 
percent.

[End of figure]

When we asked DDS directors in our survey about the consequences of 
turnover, they told us that examiner turnover increased hiring and 
training costs and hindered claims processing by decreasing overall 
examiner skill levels, and increasing examiner caseloads, claims-
processing times, and backlogs, as follows:[Footnote 38]

* Increased hiring and training costs. Nearly two-thirds of all DDS 
directors reported in our survey that turnover had increased SSA's 
recruiting, hiring, or training costs. Directors and other DDS 
officials explained in interviews why these costs had increased as a 
result of turnover. Some DDS directors said that they must invest time 
in reviewing applications, interviewing candidates, and making hiring 
decisions. They also said they have to provide inexperienced new hires 
with 12 to 18 months of extensive training and mentoring. SSA estimates 
the cost of turnover of its own employees at 1.5 times average annual 
salary. Using this rate, we estimate that the cost of DDS examiner 
turnover in fiscal year 2002 was in the tens of millions of dollars.

* Decreased overall examiner skill levels. Two-thirds of all DDS 
directors reported that losses of experienced staff due to turnover 
have decreased overall examiner skill levels. While SSA officials told 
us that one to two years of experience is generally required to become 
proficient in the examiner role, our survey data show that, in two-
thirds of the DDSs, at least a quarter of examiners had two years or 
less experience at the end of fiscal year 2002.

* Increased examiner caseloads. Nearly two-thirds of all DDS directors 
we surveyed said turnover had increased examiner caseload levels. DDS 
directors and SSA officials explained in interviews and survey comments 
that the caseloads of examiners who leave the DDS have to be 
redistributed among those who remain. Some directors told us that these 
higher caseloads created a more stressful work environment for the 
remaining employees.

* Increased claims-processing times and backlogs. Our survey results 
showed that over one-half of all directors said that turnover had 
increased DDS claims-processing times and backlogs. DDS directors and 
SSA officials we spoke with explained that turnover increased claims-
processing times because new examiners hired to fill vacancies are less 
productive due to their inexperience and time spent in training. These 
officials also told us that the productivity of experienced staff is 
lowered while they are training and mentoring the new examiners. SSA 
itself acknowledged the potential impact on service in a 2001 internal 
document. This document noted that the need to replace retiring 
managers, by drawing from an examiner pool already diminished by 
turnover, would further reduce the examiner ranks and exacerbate the 
challenge of processing the growing claims workload. In addition, we 
noted in a prior report that a majority of DDS directors expressed the 
view that examiner turnover is likely to jeopardize their ability to 
complete periodic reviews of beneficiaries' disability status, known as 
continuing disability reviews, potentially contributing to backlogs of 
these reviews.[Footnote 39]

When we asked DDS directors about causes of examiner turnover, more 
than two-thirds identified each of the following as contributing 
factors: (1) large examiner caseloads along with workplace stress, high 
production expectations, and highly complex work and (2) noncompetitive 
pay.[Footnote 40]

* High caseloads, stress, production expectations, and highly complex 
work. Over two-thirds of all DDS directors identified large examiner 
caseloads, a stressful workplace, high production expectations for the 
number of cases completed, and the highly complex nature of the work as 
factors contributing to examiner turnover. DDS directors explained in 
interviews that the combination of growth in the claims workloads and 
increasingly complex examiner responsibilities is making the examiner 
position more challenging and stressful. DDS directors also noted in 
our survey and in interviews that insufficient staffing had increased 
the caseloads and stress levels of their examiners. Nearly 9 out of 10 
DDS directors surveyed reported that the number of examiners in their 
DDSs had not been sufficient for their workload in at least one of the 
past three fiscal years, and nearly all of these directors said that 
this understaffing had resulted in a more stressful work environment.

* Noncompetitive pay. Two-thirds of all directors stated that 
noncompetitive pay had contributed to examiner turnover. Our survey 
data showed that many state DDS examiners were paid substantially less 
than examiners employed by the federal DDS in 2002 despite comparable 
skills and experience.[Footnote 41] Specifically, all of the state DDSs 
for which we have data have average examiner salaries that are less 
than the federal DDS average salary, and over half of the DDSs (31) 
have an average examiner salary that is less than two-thirds of the 
federal DDS average salary. In addition, we found that DDS examiner 
salaries are substantially lower than those of VBA examiners 
nationwide. For example, the average salary for DDS examiners was 
$40,464 in 2002, compared with $49,684 for VBA examiners.[Footnote 42] 
Specifically, we found that average DDS examiner salaries are less than 
those of VBA examiners in 47 states. (See fig. 3.) Several DDS 
directors told us in interviews that examiners have left some DDSs to 
accept higher salaries in federal agencies, particularly in SSA 
offices. For example, our analysis of selected case data provided by 
two DDS directors showed that, between 2000 and 2003, 13 former 
examiners received pay increases ranging from 9 to 48 percent when they 
moved from their DDSs to positions in SSA offices.[Footnote 43]

Figure 3: Distribution of Average State DDS Examiner Salaries as a 
Percentage of Average VBA Examiner Salaries:

[See PDF for image]

Note: One DDS did not provide examiner salary data.

[End of figure]

DDSs Face Difficulties in Recruiting and Hiring Partly Due to State-
Imposed Personnel Restrictions:

In addition to facing high turnover and growing caseloads, more than 
three-quarters of all DDS directors (43) reported experiencing 
difficulties over a three-year period in recruiting and hiring enough 
people who could become successful examiners.[Footnote 44] Of these 
directors, more than three-quarters said that such difficulties 
contributed to decreased accuracy in disability decisions or to 
increases in job stress, claims-processing times, examiner caseloads, 
backlogs, or turnover.[Footnote 45] For example, one SSA official 
explained that, because of state-imposed hiring restrictions, one DDS 
developed a large backlog of cases that negatively affected its 
productivity.

When we asked DDS directors what made it difficult for their DDSs to 
recruit and hire, they said that the following factors, many of which 
were related to state personnel restrictions, made it moderately to 
much more difficult than it would be otherwise to recruit and hire:

* state limits on examiner salaries and other forms of compensation,

* restrictive job classification system for state employees,

* state-imposed hiring limitations or hiring freezes and lengthy time 
periods for the state to hire DDS examiners, and:

* SSA-imposed hiring restrictions and budget allocations limiting DDS 
staffing levels.

State limits on examiner salaries and other forms of compensation. More 
than two-thirds of all directors reported that state limits on examiner 
salaries hindered recruiting and hiring, and the same proportion 
reported that noncompetitive salaries were insufficient to recruit or 
retain staff with the skills necessary to assume enhanced examiner 
responsibilities.[Footnote 46] One DDS director noted in survey 
comments that the low entry-level salary for examiners in that 
particular state no longer attracted "…the caliber of employees needed 
to perform the increasingly complex [examiner] job." Another commented 
that, owing to noncompetitive salaries, job candidates "…who have the 
requisite combination of skills needed as a [disability examiner] will 
find better offers of employment, [with] either better pay or less 
workload stress." And officials we spoke with in an SSA regional office 
said that low examiner salaries in still another DDS have meant that 
this DDS has been unable to recruit candidates with strong analytical 
skills. They noted that the DDS has, therefore, had difficulty training 
its new examiners in such challenging tasks as weighing the credibility 
of medical and other evidence. In addition to citing limits on 
salaries, more than half of all directors reported that state limits on 
other forms of compensation, such as performance-based pay and hiring 
bonuses, also contributed to recruiting and hiring difficulties.

Restrictive job classification system. Nearly one-half of all DDS 
directors attributed difficulties in recruiting and hiring examiners to 
their restrictive state job classification systems. Close to a third of 
all states place disability examiners in the same classification as 
other positions--such as a vocational rehabilitation specialist--and 
some DDS officials we interviewed said this made it difficult to 
attract people with skills appropriate to the disability examiner 
position.

State-imposed hiring limitations and lengthy time for hiring. Nearly 
one-half of all DDS directors cited state hiring limitations or hiring 
freezes--and more than one-third reported lengthy hiring processes--as 
impediments to acquiring qualified examiners. For instance, officials 
we interviewed in one DDS explained that their state government had 
capped the number of staff the DDS could hire. These officials noted 
that, while SSA was willing to fund hiring above that level, it could 
take three years to obtain the state legislature's approval to increase 
the DDS staffing level. SSA officials told us that another DDS could 
only hire individuals who have taken a required state test. They 
explained that, because the state administers the test only two times a 
year, the requirement hampers DDS hiring efforts.

SSA-imposed hiring restrictions and budget allocations. Close to two-
thirds of all DDS directors said that, over the past three fiscal 
years, SSA-imposed hiring restrictions and budget allocations that 
limit DDS staffing levels have presented recruiting and hiring 
challenges for the DDSs. DDS managers explained in interviews and in 
survey comments that, given the one to two years it takes for an 
examiner to become fully trained, DDSs that are restricted from quickly 
replacing staff lost to attrition will not have sufficient numbers of 
experienced examiners to process future claims.

Many Examiners Need Additional Training in Key Analytical Areas:

In addition to high turnover and difficulties in recruiting and hiring, 
the DDSs are also experiencing gaps in key knowledge and skills areas. 
When we surveyed all DDS directors about specific knowledge and skill 
needs, nearly one-half said that at least a quarter of their examiners 
needed additional training or mentoring in each of the following areas 
to successfully assume expanded responsibilities under an enhanced 
examiner position in either the present or the future:[Footnote 47]

* assessment of an applicant's symptoms and evaluation of the 
credibility of medical and other evidence,

* evaluation of the weight to be given to medical evidence from a 
treating physician,

* assessment and documentation of an applicant's ability to function,

* assessment of vocational factors,

* updates on policies and procedures, and:

* assessment of childhood disabilities.

Even for those 19 DDSs in our survey that were testing the enhanced 
examiner position at the time of our study, over half (11 DDSs) 
reported that at least a quarter of the examiners with expanded 
responsibilities needed additional training or mentoring in two or more 
of these same knowledge and skill areas, and eight of these directors 
reported needs in four or more of these areas.[Footnote 48]

But regardless of whether a DDS was testing this enhanced position, 
these areas are critical to the examiner's task of disability decision-
making in general. Indeed, one DDS director explained in an interview 
that, while that DDS was not officially testing this position, over the 
last several years it had hired examiners who were able to function in 
a manner that was increasingly independent of the medical consultant. 
This director noted that, as a result, it was becoming more difficult 
to distinguish the responsibilities of the disability examiner from 
those of an examiner with enhanced authority. Moreover, under SSA's new 
approach for improving the disability determination process, these same 
knowledge and skill areas will be even more critical as DDS examiners 
take responsibility for evaluating only the more complex claims and as 
they are required to fully document and explain the basis for their 
decision.[Footnote 49]

DDS directors cited several obstacles to examiners receiving needed 
training or mentoring.[Footnote 50] These obstacles primarily involved 
high workload levels that limited the time available to either provide 
or receive training or mentoring. Specifically, more than 70 percent of 
all DDS directors reported that work demands impeded mentors from 
providing examiners with needed on-the-job training.[Footnote 51] In 
addition, about two-thirds of all DDS directors reported that either 
the large size of examiners' caseloads or high expectations for 
completing those cases did not allow examiners enough time to attend 
training. And more than half of all directors cited high work levels as 
a barrier to examiners seeking mentoring assistance.

The Majority of DDSs Do Not Conduct Long-Term, Comprehensive Workforce 
Planning, and DDSs Cite Numerous Obstacles to Doing So:

Despite the workforce challenges facing them, a majority of DDSs do not 
conduct long-term, comprehensive workforce planning. Of the DDSs that 
engage in workforce planning that is longer-term, a majority have plans 
that lack key workforce planning strategies, such as those for 
recruiting, retention, or succession planning. Directors identified 
numerous obstacles to long-term workforce planning, such as a lengthy 
state process to approve DDS human capital changes.

The Majority of DDSs Do Not Conduct Long-Term, Comprehensive Workforce 
Planning:

The majority of DDSs do not conduct long-term, comprehensive workforce 
planning. As figure 4 shows, more than half of all the DDSs have 
workforce planning time horizons of less than two years, and almost 
one-half have a time horizon of no longer than a year (the time horizon 
of SSA's annual budget process for the DDSs).

Figure 4: Percentage of DDSs by their Workforce Planning Time Horizons:

[See PDF for image]

Note: Data provided in the figure do not add to 100 percent due to 
rounding.

[End of figure]

DDS directors who reported that their workforce planning time horizons 
are no longer than a year mainly rely on SSA's annual budget process 
for the DDSs for their workforce planning. However, SSA officials told 
us in interviews that their budget process is not designed to serve as 
a long-term strategic workforce planning process. These officials said 
that the following strategies of comprehensive, long-term workforce 
planning are generally not part of the budget process but rather are 
left to the states:

* recruiting strategies,

* retention strategies,

* training and professional development strategies,

* compensation strategies,

* performance expectation and evaluation strategies,

* employee-friendly workplace strategies,

* succession planning and strategies for maintaining expertise in the 
long term, and:

* contingency plans, in the event that resource levels do not meet 
expectations.[Footnote 52]

In addition, even among the 28 DDSs that engage in workforce planning 
that is longer-term than one year, the majority (18) lack one or more 
of these key workforce planning strategies.[Footnote 53]

Furthermore, many DDSs do not collect the data needed to develop 
effective workforce plans.[Footnote 54] Although DDSs face high 
turnover and are expected by SSA to experience a retirement wave in the 
next decade, over half of all DDS directors said they had not made 
projections of expected retirements and other separations for examiners 
and related staff within the last two fiscal years.

Although the majority of DDSs do not conduct comprehensive, long-term 
workforce planning, some state governments do engage in strategic 
workforce planning efforts that encompass DDS employees. For example, 
the state parent agency of one DDS has produced reports identifying the 
workforce risks faced by the DDS (such as a coming retirement wave) and 
has assisted the director with succession planning. However, ongoing 
studies of state government workforce planning efforts have found that 
formal strategic workforce planning is not taking place in all 
states.[Footnote 55] During an interview with several DDS directors, we 
were told that even states with sophisticated long-term workforce 
planning efforts are not necessarily focusing on ensuring that their 
DDSs have the workforces needed to accomplish SSA goals, such as 
reducing claims-processing times.

DDS Directors Cited Numerous Obstacles to Long-term Workforce Planning:

DDS directors noted in interviews that they face unique challenges 
related to the federal-state relationship that compound the 
difficulties of planning for future workforce needs. We asked DDS 
directors in our survey to what extent they had experienced various 
factors that might make workforce planning more difficult than it would 
be otherwise. Directors identified the following as major obstacles to 
long-term workforce planning:[Footnote 56]

* Lengthy state processes to approve DDS human capital changes. Over 
half of all DDS directors said that lengthy state processes to approve 
DDS human capital changes made statewide DDS long-term workforce 
planning more difficult. For example, an SSA official said it took over 
a year to obtain approval to hire seven DDS staff due to a state hiring 
freeze. In addition, a 2001 audit by SSA's Office of the Inspector 
General found that the parent agency of one DDS had failed to provide 
sufficient staffing resources, such as timely permission to fill 
vacancies, for the DDS to efficiently process its disability 
workload.[Footnote 57]

* Inconsistencies between state and SSA human capital policies. Two-
thirds of all DDS directors reported that long-term planning is made 
more difficult than it would be otherwise due to inconsistencies 
between state and SSA human capital policies, such as those related to 
staffing levels. For example, a former DDS director we spoke with 
explained that directors have had difficulties planning for future 
needs because of discrepancies between hiring levels authorized by SSA 
and those approved by their states. One DDS director told us that after 
working for two years to obtain state approval to hire additional 
examiners initially authorized by SSA, the DDS lost permission from SSA 
to fill the positions.

* Directors' concern that SSA does not incorporate DDS workforce plans 
when making resource decisions. When asked in our survey what makes 
long-term planning more difficult, over two-thirds of DDS directors 
reported their concern that SSA does not incorporate the DDSs' 
workforce plans when making resource decisions. Moreover, 45 DDS 
directors responded that they had only some or no opportunity to factor 
future DDS human capital needs into SSA's spending projections beyond 
the upcoming fiscal year. Several DDS officials explained in interviews 
that long-term planning seemed futile if SSA was not going to use the 
results of the DDS planning efforts when making resource decisions. SSA 
officials, however, told us that they consider input from the DDSs 
related to funding decisions on a regular basis. SSA officials 
explained that the agency must disperse funds within its own overall 
budget allocation, and this often does not allow for meeting all DDS 
funding requests.

* Uncertainty about future resource levels from SSA and state-imposed 
hiring restrictions or separation incentives. Over three-quarters of 
all DDS directors we surveyed reported that long-term planning is made 
more difficult by uncertainty about future resource levels from SSA, as 
well as uncertainty about resources needed to implement major changes 
in SSA policies, procedures, and systems. In addition, one-half of DDS 
directors surveyed said that DDS long-term workforce planning was made 
more difficult by uncertainty about state-imposed hiring restrictions 
or separation incentives.

* Insufficient time to attend to future problems and insufficient data 
for workforce planning. Three-quarters of all directors surveyed said 
that they had insufficient time to attend to future problems because of 
the need to focus on current human capital challenges. One DDS director 
said in an interview that the day-to-day demands of directors' jobs, 
such as managing high caseloads and hiring and training new examiners, 
often prevent them from planning for future workforce needs. Other DDS 
directors and officials told us that, when planning does take place, it 
is generally crisis-driven and reactive rather than long-term and 
strategic. In addition, over half of the directors reported in our 
survey that insufficient data for workforce planning makes DDS long-
term workforce planning more difficult. Moreover, DDSs that do not 
engage in workforce planning longer-term than one year were more likely 
than other DDSs surveyed to cite insufficient data and planning tools, 
such as statistical software and information technology systems, as 
challenges that make long-term workforce planning more difficult.

SSA's Workforce Efforts Have Not Sufficiently Addressed Present and 
Future Human Capital Challenges in the DDSs:

SSA's workforce efforts have not sufficiently addressed both present 
and future DDS workforce challenges. Neither SSA's strategic plan, nor 
its annual performance plan, nor its workforce plan adequately 
addresses the human capital challenges facing the DDSs. In addition, in 
our survey, DDS directors reported being dissatisfied with the adequacy 
of the training that SSA provides to the DDSs. Beyond training, SSA has 
not consistently provided other human capital assistance across the 
DDSs and faces difficulties negotiating human capital changes, such as 
increases in examiner salaries, with state governments. Finally, SSA 
has not used the statutory authority it has to set standards for the 
DDS workforce.

SSA's Strategic and Workforce Plans Do Not Adequately Address DDS Human 
Capital Challenges:

SSA has not developed a nationwide strategic workforce plan that 
addresses present and future human capital challenges in the DDSs. As 
shown in figure 5, SSA does recognize a need to have higher-skilled and 
better-compensated DDS employees. In addition, SSA's strategic plan for 
2003-2008 places a high priority on improving the accuracy and the 
timeliness of the disability decision-making process. While 
accomplishment of this objective depends to a great extent on the DDS 
workforce, the plan cautions that the DDSs, like SSA, will face a 
continuing challenge of hiring and retaining a highly skilled workforce 
in a competitive job market. Nevertheless, SSA's strategic plan, as 
well as the agency's annual performance plan and workforce plan, are 
all largely silent on the means and strategies the agency will use to 
recruit, develop, and retain a high-performing DDS workforce, even 
though the Government Performance and Results Act now requires agencies 
to include in their annual performance plans a description of the human 
capital strategies needed to meet their strategic goals.

Figure 5: Means and Strategies Addressing the DDS Workforces Are 
Largely Absent from SSA's Strategic and Workforce Plans:

[See PDF for image]

[A] SSA officials said in interviews that SSA is no longer pursuing two 
proposed strategies for improving training for disability examiners.

[End of figure]

Absent any strategic workforce plan addressing DDS employees, SSA does 
not use data that it collects on the DDS workforces in a strategic 
manner. While SSA routinely gathers certain DDS employee data--such as 
salaries, turnover rates, and the number of new hires and experienced 
disability examiners--the agency primarily uses these data in 
connection with its annual budget process. Moreover, SSA does not 
regularly collect many other key indicators of DDS human capital 
performance, such as gaps in basic skills relative to specific 
competencies, despite SSA's acknowledging the importance of investing 
in and retaining a skilled DDS workforce in the face of an anticipated 
retirement wave.

When we asked SSA officials how workforce planning for the DDSs was 
conducted, they said that they consider DDS workforce matters to be, in 
general, a state government and DDS responsibility, particularly in 
light of the variations in state personnel systems and political 
concerns. One of these officials explained that SSA takes DDS workforce 
needs into account within SSA's annual budget process and through the 
consultation that occurs between the DDSs and SSA's regional offices. 
The regional office staff--and in particular, the disability program 
administrators assigned as SSA's liaisons with each DDS--are 
responsible for providing human capital assistance to the DDSs as 
needed. However, as noted earlier, SSA's annual budget process lacks 
key components of comprehensive, long-term workforce planning. In 
addition, officials we interviewed in one regional office said that 
they lacked the tools and the time to assist the DDSs with long-term 
strategic workforce planning, and SSA officials we spoke with 
questioned whether disability program administrators were sufficiently 
trained in strategic workforce planning techniques.

Several regional office and former and current DDS officials we spoke 
with expressed a desire for greater SSA leadership in terms of long-
term strategic workforce planning focusing on DDS human capital 
challenges. One of these officials observed that SSA is already active 
in a variety of DDS human capital areas--such as determining 
appropriate DDS staffing levels, imposing a nationwide DDS hiring 
freeze, and providing national human capital guidance for implementing 
the electronic disability initiative--and could appropriately assist 
with strategic workforce planning.

Directors Expressed Dissatisfaction with the Adequacy of SSA's Training 
for the DDSs:

DDS directors are dissatisfied with the adequacy of SSA-provided 
training. Specifically, when we asked DDS directors whether they found 
SSA's training to be adequate to prepare examiners to be proficient in 
the claims process, half or more of the directors responded that they 
were dissatisfied with the adequacy of SSA's training in each of the 
following knowledge and skill areas:[Footnote 58]

* medical knowledge about body systems (32 DDSs),

* specific knowledge about the disability program (30 DDSs),

* assessment of vocational factors (29 DDSs),

* basic claim development techniques (29 DDSs),

* evaluation of the weight to be given to medical evidence from a 
treating physician (28 DDSs),

* updates on policies and procedures (28 DDSs),

* assessment of childhood disabilities (28 DDSs),

* assessment of an applicant's symptoms and evaluation of the 
credibility of medical and other evidence (27 DDSs), and:

* use of computers and technologies (26 DDSs).

Moreover, nearly half of the directors (25 DDSs) reported that they 
were dissatisfied with SSA's basic training materials for new 
disability examiners, and over one-third (19 DDSs) reported 
dissatisfaction with training on the assessment and documentation of an 
applicant's ability to function.

In addition, nearly all DDS directors (49) reported that they had 
adapted (or wanted to adapt) SSA's training in one or more of these 
knowledge and skill areas to make it adequate.[Footnote 59] When we 
asked these DDS directors why they had adapted or wanted to adapt SSA's 
training, more than half cited each of the following reasons pertaining 
to the quality, completeness, and timeliness of SSA's training approach 
as contributing factors:[Footnote 60]

* Training is too conceptual and not sufficiently linked to day-to-day 
case processing (44 DDSs).

* Training provides insufficient opportunity to interact with the 
trainer (40 DDSs).

* Training provides insufficient opportunity to practice skills taught 
(38 DDSs).

* Certain types of training over-rely on the interactive video training 
technology (37 DDSs).

* Training content is incomplete (32 DDSs).

* Training presenters lack effective presentation skills (31 DDSs).

* Training lacks sufficient written materials, such as handouts and 
desk aids (30 DDSs).

* Training is delivered too early or too late (28 DDSs).

In interviews, DDS officials expressed some particular concerns about 
video training. Some DDS officials told us that, because presenters 
lack sufficient hands-on case-processing experience, the training that 
SSA provided through its video training technology was too theoretical. 
In addition, other DDS officials described SSA's video training 
technology as not allowing sufficient opportunity for clarification and 
follow-up with the presenter. Some officials explained that technical 
problems with the technology impeded interaction with the trainers. For 
example, they told us that, while staff are supposed to be able to use 
a keypad to call in and question the presenters during a class 
broadcast, it is often difficult to obtain access to the presenters. 
Further, some former DDS officials said that SSA applies its video 
training technology to many types of instructional needs for which it 
may not be appropriate. Yet, in our prior work, we have noted that, to 
be effective, the training method used needs to be tailored to the 
nature of the training content.[Footnote 61]

We asked SSA officials we spoke with to comment on the DDS directors' 
views on the quality of SSA-provided training. While an SSA official 
explained that the video training technology helps SSA to provide 
consistent training across the entire country quickly, she acknowledged 
that the training is sometimes too general and explained that SSA is 
attempting to improve the presentations. SSA officials also told us 
that they tap the expertise of the DDS community, among other agency 
components, to help develop and improve training materials and identify 
training needs.

However, despite such efforts, nearly 85 percent of all DDS directors 
reported in our survey that they would be able to spend fewer resources 
adapting SSA's training for use in their individual DDSs if SSA were to 
improve the quality, completeness, and timeliness of its 
training.[Footnote 62] Our survey data show that, in fiscal year 2002, 
the 52 DDSs used, in total, the equivalent of nearly 150 full-time DDS 
employees in preparing and delivering examiner training related to 
disability claims processing. Moreover, staff resources devoted to 
training may constitute a significant portion of total examiner staff 
in some DDSs. To illustrate, the director of one DDS with 83 disability 
examiners reported in our survey using the equivalent of about 12 full-
time employees in fiscal year 2002 to prepare and deliver examiner 
training. SSA and DDS officials explained in interviews that, while 
some larger DDSs have staff who are dedicated solely to training, 
smaller DDSs generally use their most experienced, and hence most 
productive, examiners to prepare training and deliver it to their 
staff.

SSA Has Not Consistently Provided Other Human Capital Assistance across 
the DDSs and Faces Difficulties Negotiating Key Human Capital Issues 
with State Governments:

Beyond training, information from our survey and interviews shows that 
SSA has not consistently provided other human capital assistance across 
the DDSs and faces difficulties negotiating human capital changes, such 
as increases in examiner salaries, with state governments. SSA provides 
many types of human capital assistance to the DDSs through its regional 
offices and its headquarters. For example, SSA regional office 
officials we interviewed explained that they have attempted to persuade 
state governments to exempt examiners from state hiring restrictions 
and to reclassify DDS examiner positions and increase examiner salaries 
in light of new responsibilities. In addition to the assistance 
provided by regional offices, SSA officials said that SSA headquarters 
has provided human capital assistance to the DDSs, such as sponsoring a 
study that identified the knowledge, skills, and abilities required for 
the disability examiner position, among other positions.

But in our survey of the DDS directors who said they wanted particular 
types of human capital assistance from SSA headquarters and its 
regions, more than half said that they had not received assistance in 
each of the following areas:[Footnote 63]

* help with regular nationwide surveys of examiners' issues and 
concerns (32 out of 36 DDSs),

* help in negotiating increases in examiner salaries with state 
government officials (24 out of 36 DDSs),

* guidance on roles and responsibilities for examiners with enhanced 
responsibilities (22 out of 42 DDSs),

* help in designing training and developing training materials for 
examiners with enhanced responsibilities and the staff who will be 
supporting them (22 out of 42 DDSs),

* help with workforce planning, including projecting turnover and 
developing succession plans (21 out of 31 DDSs),

* guidance on how to determine which examiners have sufficient skills 
to take on enhanced examiner responsibilities (15 out of 20 DDSs), and:

* help in identifying gaps in examiner skills (15 out of 21 DDSs).

In interviews, some DDS directors specifically cited surveys of 
examiners' issues and concerns as an area with which they wanted 
assistance. They explained that such surveys could be used to identify 
and share DDS best practices in managing staff, including how different 
DDSs manage examiner caseloads and train examiners. One director noted 
that information on DDS best practices in human capital management is 
not currently available and that only SSA can "survey the landscape 
nationally." Moreover, a former DDS director explained that directors 
view nationwide surveys as a means for communicating to SSA their human 
capital challenges.

We also asked DDS directors about the effectiveness of various types of 
human capital assistance that they did receive from SSA and its 
regional offices, including assistance in negotiating human capital 
changes with state governments. We found that more than half of the DDS 
directors who received assistance said that such assistance was of 
limited effectiveness in each of the following areas:[Footnote 64]

* helping project trends in the nature of the disability workload (24 
out of 34 DDSs);

* assisting in negotiating easing of state restrictions (e.g., on 
hiring and travel) with the state government (19 out of 24 DDSs);

* providing guidance on roles and responsibilities for examiners with 
enhanced responsibilities (18 out of 26 DDSs);

* helping to design training and developing training materials for 
examiners with enhanced responsibilities and the staff who will be 
supporting them (16 out of 22 DDSs);

* assisting in allowing DDSs to reduce the total caseload level for 
examiners taking on enhanced responsibilities (13 out of 24 DDSs);

* helping in assessing readiness for transition to an examiner role 
with enhanced responsibilities (12 out of 14 DDSs);

* helping with workforce planning, including projecting separations and 
developing succession plans (11 out of 13 DDSs); and:

* providing help in negotiating increases in examiner salaries with the 
state government (11 out of 16 DDSs).

Regional office officials and DDS directors explained in interviews 
that the effectiveness of SSA and its regional offices in helping the 
DDSs negotiate human capital changes with the states can be limited by 
such factors as state budget problems, political concerns, and 
personnel rules. For example, some officials said in interviews that 
state budget crises had created political pressure to limit or prevent 
increases in state employee salaries. Other DDS directors told us that 
state officials were concerned that raising examiner salaries would 
prompt increases in the salaries of other state employees, such as 
employees within the same job classification. In addition, although 19 
DDS directors reported in our survey that DDS salary levels are open to 
negotiation with unions, some regional office officials said in 
interviews that obtaining salary increases for disability examiners 
apart from other state employees covered by union contracts could be 
difficult.

In light of such difficulties in negotiating human capital changes with 
the states, one key regional office official we spoke to said that "all 
the regional office can do is cajole" the state governments about DDS 
human capital issues, since under the regulations the authority in this 
arena generally remains with the states. Similarly, another top 
regional official cautioned that, while the regional office tries to 
help the DDSs address the human capital challenges they face, it is 
difficult to do so. This official stated that the federal-state 
relationship is "unwieldy," explaining that it is easier for state 
governments to apply state human capital policies--such as hiring 
freezes--to all state personnel than to make exceptions for DDS 
employees, despite SSA's full reimbursement of DDS expenses. The 
official said that, because the regional office must continually 
educate and explain to each newly elected state governor's 
administration that the DDS is federally funded, the regional office is 
seeking ways to make such education more effective and less labor-
intensive. Indeed, current and former DDS directors we spoke with said 
that outreach from SSA to state governors through such national groups 
as the National Governors Association (NGA) is needed to foster an 
appreciation of the importance of a highly qualified DDS workforce to 
improving service to disability claimants.[Footnote 65]

SSA Has Not Used Its Statutory Authority to Address DDS Workforce 
Needs:

SSA has not used the statutory authority it has to set standards for 
the DDS workforce. Although amendments to the Social Security Act in 
1980 granted SSA the authority to issue regulations to ensure effective 
and uniform administration of the national disability programs, SSA has 
not used this authority to address wide variations in staff salaries, 
entry-level qualification requirements, and training for different 
DDSs. The Social Security Advisory Board, in 2001, called these 
variations potential contributors to inconsistencies in SSA's 
disability decisions.[Footnote 66] Emphasizing that the disability 
programs are national in scope and that equal treatment for all 
claimants wherever they reside is essential, the Advisory Board 
recommended that SSA revise its regulations to establish guidelines for 
salaries, entry-level qualification requirements, training, and other 
factors affecting the ability of DDS staff to make quality and timely 
decisions.[Footnote 67] SSA has not acted on the Advisory Board's 
recommendations, however.

While SSA officials acknowledged in interviews that the agency has the 
authority to establish uniform minimum human capital standards, they 
told us that the agency has chosen not to exercise this authority 
because of concerns about the difficulties such actions could raise in 
terms of the federal-state relationship. For example, they explained 
that requiring uniform human capital standards might be perceived by 
some states as unwelcome federal interference in state operations and 
could raise the prospect of states withdrawing their participation in 
making disability determinations for the disability programs. Indeed, 
in a prior report, we noted that, in the late 1970s, SSA could get only 
21 of the 54 DDSs to revise their operating agreements with SSA, partly 
because the states regarded the revisions as infringements on their 
traditional prerogatives. The revised agreements required DDSs to 
comply with guidelines issued by SSA with regard to personnel matters, 
among other administrative requirements.[Footnote 68]

Many DDS and SSA officials we spoke with acknowledged the difficulties 
that would be involved with implementing uniform standards for DDS 
personnel. Nevertheless, the National Council of Disability 
Determination Directors and several DDS and SSA officials we 
interviewed (including some top regional office officials) expressed 
the view that uniform standards for DDS employees could help address 
the human capital challenges confronting the DDSs.[Footnote 69] Some 
referred to the vocational rehabilitation program administered by the 
Department of Education's Rehabilitation Services Administration in 
partnership with the states as an example of a federal-state program 
that has set qualification standards for state employees.[Footnote 70]

Conclusions:

DDS disability examiners are essential to SSA's meeting its strategic 
goal for better serving disability claimants by making the right 
decision in the disability process as early as possible. Yet SSA has 
not developed a nationwide strategic workforce plan to address the very 
personnel who will be crucial to meeting that goal. The immediate 
challenges that DDS directors face today in maintaining and improving 
the examiner workforce are unlikely to lessen with time and will likely 
have even more severe consequences as the DDSs confront increasing 
numbers of applicants for disability benefits. The critical task of 
making disability decisions is complex, requiring strong analytical 
skills and considerable expertise, and it will become even more 
demanding with the implementation of the Commissioner's new long-term 
improvement strategy and the projected growth in workload. Moreover, 
because SSA has not set uniform minimum qualifications for examiners, 
some DDSs may find it difficult to justify an appropriate job 
classification and level of compensation needed to recruit and retain 
these critical employees.

Without a plan to develop and maintain a skilled workforce--as well as 
measures to establish uniform minimum qualifications for examiners, 
close critical skill gaps, and improve training--SSA's ability to 
provide high-quality service to disability claimants could be further 
weakened by gaps in critical competency areas and the loss of 
experienced DDS examiners due to high turnover. As vacancies are filled 
by new hires and trainees who need one to two years to become fully 
productive, the DDSs will likely have difficulty maintaining skill 
levels and successfully coping with expected high growth in workloads. 
The combination of decreased overall skill levels and increased 
workload could make the work environment even more stressful, further 
increasing turnover. This spiraling effect, if not addressed, could 
undermine the agency's efforts to ensure that disability decisions are 
made accurately, consistently, and in a timely manner.

A strategic workforce plan is even more critical to the Commissioner's 
long-term strategy for improving the disability claims process and her 
ability to bring SSA's approach to disability decision-making in line 
with the current state of science, medicine, technology, and labor 
market conditions. Failure to look ahead and plan to ensure that the 
appropriate mix of skills and capabilities are available when and where 
needed could obstruct SSA's progress as it seeks to fundamentally 
restructure its disability programs to improve the accuracy and 
timeliness of decisions and focus on identifying and enhancing 
claimants' productive capacities. Given such a profound transition in 
an environment of constrained resources, SSA must be able to plan 
effectively if it is to anticipate how its requirements for DDS staff 
will change and be convincing about the need for increased human 
capital investments.

It will not be simple to implement a nationwide strategic workforce 
plan for a program that is administered in partnership with the states. 
Negotiating changes in state human capital policies, such as 
restrictive job classifications or hiring limitations, will be 
difficult. Improving the content and delivery of SSA-provided training 
and closing gaps in examiner skills across the DDSs will be challenging 
and potentially costly. Establishing uniform minimum qualifications for 
examiners throughout the DDSs will also be a difficult task, requiring 
delicate and time-consuming discussions with some state governments. 
However, despite the acknowledged difficulties, SSA cannot afford to 
forgo developing an overarching, guiding framework to use as a basis 
for making short-and long-term human capital decisions for the DDSs. As 
an agency with fiduciary responsibility for administering multibillion 
dollar disability programs that are nationwide in scope, SSA has an 
obligation to take a leadership role in planning--together with its 
state partners--to address both the immediate and future workforce 
needs in the DDSs.

Recommendations to the Commissioner of SSA:

We recommend that SSA take the following actions:

1. Develop a nationwide strategic workforce plan that addresses present 
and future human capital challenges in the DDSs. This plan should 
enable SSA to identify the key actions needed to deal with immediate 
DDS problems with recruiting and hiring, training, retention, and 
succession planning in support of SSA's strategic plan. It should 
additionally enable SSA to anticipate and plan for the future workforce 
that will be needed as SSA modernizes and fundamentally transforms its 
approach to disability decision-making. To develop and implement this 
comprehensive workforce plan, SSA should work in partnership with the 
DDSs and their parent agencies. As part of the planning process, SSA 
should:

a. Identify a small number of key DDS indicators of human capital 
performance, including recruiting and hiring measures, level of stress 
in the workplace, training needs, and turnover. SSA should establish 
standards for acceptable performance on these indicators, routinely 
collect and analyze the data to identify trends, and use this 
information to guide decisions regarding future DDS workforce needs and 
the strategies to meet them.

b. Provide necessary tools and technical assistance to the DDSs to 
enable them to conduct long-term workforce planning. SSA should ensure 
that SSA staff responsible for providing this assistance are well 
trained in the tenets of workforce planning.

c. Require each DDS to develop its own long-term workforce plan that is 
linked to the nationwide long-term DDS workforce plan. SSA should work 
in partnership with the DDSs and their parent agencies to develop these 
plans.

d. Establish an ongoing program of outreach from SSA's leadership to 
state governors and national associations of state government officials 
to discuss the benefits and challenges of the federal-state 
relationship and encourage them to address human capital challenges 
identified by DDS directors, such as salary limits and hiring freezes.

e. Link performance expectations of appropriate SSA executives to their 
efforts in accomplishing goals and objectives of the workforce plan.

2. Issue regulations that establish uniform minimum qualifications for 
new disability examiners. The minimum qualifications should be based on 
an analysis of the position that identifies the examiner's 
responsibilities and the minimum knowledge, skills, and competencies 
necessary to adequately perform them. The minimum qualifications for 
the examiner's position should take into account any changes in the 
complexity of the tasks required for this position stemming from the 
Commissioner's new long-term strategy.

3. Work with DDSs to close the gaps between current examiner skills and 
required job skills. To do so, SSA should work with the DDSs to:

a. analyze examiner training needs, using as a foundation the analysis 
of job responsibilities and related minimum knowledge, skills, and 
competencies recommended above;

b. improve training content and delivery to meet these needs, basing 
such efforts on analyses of training content and appropriateness of 
training delivery methods; and:

c. develop performance measures to track effectiveness of these 
improvements to training.

Agency Comments and Our Evaluation:

We provided a draft of this report to SSA for comment. SSA generally 
agreed with the intent of the recommendations in the report but stated 
that the report does not fairly address or adequately discuss the many 
sides of the DDS human capital management issues. In particular, SSA 
criticized some of our study's methods and expressed concern that we 
did not sufficiently acknowledge the difficulties involved in making 
changes to the federal-state relationship. We continue to believe, 
however, that the report presents a fair and balanced portrayal of the 
multifaceted issue of human capital management in the DDSs.

Generally agreeing with the intent of our recommendations, SSA said it 
would consider incorporating a nationwide strategic workforce plan for 
the DDSs into its current strategy to improve the disability 
determination process. To do so will be essential, since the Government 
Performance and Results Act now requires agencies to report annually, 
as we noted in our report, on human capital strategies needed to meet 
their strategic goals. Regarding our recommendation on improving 
training, SSA said that it would continue ongoing efforts to improve 
examiner job skills. Results from our survey of DDS directors, however, 
revealed gaps in critical examiner knowledge and skills and a large 
proportion of DDS directors who would be able to spend fewer resources 
on adapting SSA's training if SSA were to improve the quality, 
completeness, and timeliness of its training. Given such results, our 
report recommended that SSA go beyond its current efforts and base its 
training improvement initiatives on a systematic assessment of the 
examiner's job responsibilities and related knowledge, skills, and 
competencies. In terms of our recommendation on outreach, SSA said that 
it is already conducting an outreach program to state officials and 
that it intends to engage in discussions with the NGA on DDS issues. 
While we noted efforts on the part of SSA's regional offices to 
negotiate human capital changes with state governments, we maintain 
that SSA's outreach program requires the sustained attention of SSA's 
leadership at the national level. SSA's expressed intent to pursue such 
discussions with the NGA is therefore a step in the right direction.

SSA criticized some of our study methods, saying that we relied heavily 
on opinions of DDS directors and used rather leading and ambiguous 
survey questions. In terms of survey design, we surveyed DDS directors 
because their first-hand experiences make them some of the most 
knowledgeable respondents about human capital challenges experienced in 
their organizations. In addition, our survey was developed in 
accordance with GAO's guidance on survey design and 
development,[Footnote 71] including extensive pretesting with current 
and former DDS directors to identify potential question bias and to 
clarify wording. We also gave SSA disability program officials, on two 
occasions, the opportunity to review and comment on the survey. 
Following the second review, the SSA official coordinating the review 
said that, while some of the questions might be difficult for the DDS 
directors to answer, we should go ahead with the survey as it stood. 
The official did not refer to any bias in the survey questions. SSA 
also was concerned that we administered the survey at a time of budget 
constraint that SSA said influenced some of the directors' responses. 
Our survey, however, reflects ongoing challenges facing the DDSs and 
was not limited to the particular circumstances of 2003. Further, our 
study findings did not rest solely on the opinions expressed in our 
survey of DDS directors. In addition to the survey, we gathered 
information through interviews with several other sources as well, 
including officials at two DDSs, three SSA regional offices, and SSA 
headquarters; officials of the National Council of Disability 
Determination Directors and the National Association of Disability 
Examiners; and staff of the Social Security Advisory Board. We also 
reviewed pertinent laws, regulations, and procedures, and obtained and 
analyzed human capital data from several sources.

SSA was also concerned that we did not sufficiently acknowledge the 
attitudes of the states toward modifying federal regulations to 
establish uniform human capital standards and the complexities involved 
in such regulatory changes, such as the problems that SSA says it would 
face if a large state declined to make disability determinations and 
transferred these responsibilities to the federal government. We 
acknowledged in our report the difficulties SSA has encountered in 
convincing the DDSs to comply with SSA guidelines on personnel issues, 
due in part to the states' perceptions of infringements on traditional 
state responsibilities. We also stressed that establishing uniform 
minimum qualifications for examiners will be difficult, requiring 
delicate and time-consuming discussions with some state governments. 
But we maintain that, despite the difficulties, SSA is obligated to 
address the human capital challenges facing the DDSs. An outreach 
program involving SSA's leadership and a close working partnership 
among SSA, the DDSs, and their state parent agencies will be vital to 
help ensure the success of SSA's efforts.

In addition, SSA expressed a number of other concerns about the draft 
report. These concerns, as well as our comments on them, are provided 
in full in appendix IV.

Copies of this report are being sent to the Commissioner of SSA, 
appropriate congressional committees, and other interested parties. The 
report is also available at no charge on GAO's Web site at http://
www.gao.gov. If you have any questions about this report, please 
contact me at (202) 512-7215. Other contacts and staff acknowledgments 
are listed in appendix V.

Sincerely yours,

Robert E. Robertson: 
Director, Education, Workforce, and Income Security Issues:

Signed by Robert E. Robertson: 

[End of section]

Appendix I: Scope and Methods:

The following describes the methods we used to survey Disability 
Determination Service (DDS) offices as well as the methods we used to 
compare some of our survey data with data from other sources.

Survey of Disability Determination Service Offices:

We surveyed all state DDS directors as well as the DDS directors in the 
District of Columbia, Puerto Rico, and the federal DDS office. We did 
not survey directors in Guam and the South Carolina Office for the 
Blind because these offices each had only one disability examiner. We 
mailed surveys to 53 DDS directors and received responses from all of 
them. However, because most of the questions in our survey do not apply 
to the federal DDS, we reported results for 52 DDSs. Our survey 
included questions about long-term workforce planning, recruiting and 
hiring, compensation, training and development, and retention of 
disability examiners.[Footnote 72] The survey results in this report 
represent the views of the DDS directors and do not necessarily 
represent the views of examiners or other DDS staff or the views of 
Social Security Administration (SSA) officials.

The practical difficulties of conducting any survey introduce various 
types of errors related to survey responses. For example, differences 
in how a particular question is interpreted and differences in the 
sources of information available to respondents can be sources of 
error. In addition, respondents might not be uniformly conscientious in 
expressing their views or they may be influenced by concerns about how 
their answers might be viewed by GAO, SSA, or the public. We included 
steps in both the data collection and analysis stages for the purpose 
of minimizing such errors. For example, to address differences in how 
questions were interpreted, we asked two members of the Social Security 
Advisory Board, as well as current and past officers of the National 
Council of Disability Determination Directors and the National 
Association of Disability Examiners, to review and critique the survey 
questions before pretesting. SSA disability program officials also 
reviewed our survey on two occasions. In addition, we pretested the 
survey with four former DDS directors and four current DDS directors. 
We modified the survey questions based on the results of these 
pretests.

Because we conducted our survey while 20 DDSs were testing the 
feasibility of implementing an examiner position with enhanced 
responsibilities, we tailored a few of the survey questions to be 
relevant for those DDSs testing these enhanced positions as well as for 
those not testing such positions. We also tailored questions for 
California's survey, which had separate offices testing and not testing 
the enhanced examiner position. In addition, we tailored questions for 
the survey that went to the federal DDS.

To address possible director concerns about how their answers might be 
viewed, we stated in the introduction to the survey that their 
responses would be reported in summary form only, without being 
individually identified, and that their responses would not be released 
unless requested by a member of Congress (see appendix II for a copy of 
our survey).

Analysis of Data from Our Survey and Other Sources:

When we analyzed the data from our survey, where possible, we checked 
survey answers involving numbers and percentages to ensure they summed 
correctly. When we identified a discrepancy, we contacted the relevant 
DDS director to resolve the discrepancy.[Footnote 73]

We wanted to determine how turnover rates (overall and for new hires) 
for DDS examiners compared with those for selected groups of federal 
employees. To do this, we compared the turnover rate of DDS examiners 
with that of Veterans Benefits Administration (VBA) examiners, SSA 
employees, and all federal employees. VBA examiners were selected 
because they perform duties similar to DDS examiners, such as 
developing claims using medical and disability program knowledge. We 
compared DDS examiner turnover rates with SSA turnover rates because 
SSA fully funds the DDSs to achieve its disability program mission. The 
federal employee turnover rate was selected as a general 
baseline.[Footnote 74]

We used data from the Office of Personnel Management's (OPM) Central 
Personnel Data File (CPDF) to calculate turnover rates for VBA 
examiners, SSA employees, and all federal employees.[Footnote 75] We 
counted how many permanent employees in each group left their position 
in each of fiscal years 2000, 2001, and 2002. For VBA examiners and SSA 
employees, transfers to other agencies were counted as separations. For 
all federal employees, only separations from federal service were 
counted as separations. To calculate overall turnover, we divided the 
number separated each year by the average of the number of staff (which 
we obtained by averaging the number of staff at the beginning of the 
fiscal year and the number of staff at the end of the fiscal 
year).[Footnote 76]

We also calculated a new hire turnover rate. We defined a new hire 
separation as a separation of an employee hired in one fiscal year who 
left before the end of the following fiscal year (for example, hired in 
fiscal year 2000 and left before the end of fiscal year 2001). To 
determine the turnover rate for new hires, we counted all career and 
career conditional appointments for each fiscal year 2000 and 2001. We 
then determined how many of these separated before the end of the 
following fiscal year and divided this by the number of new hires in 
the prior fiscal year. We also calculated turnover rates for DDS 
examiners using the same formulas.

We also compared DDS examiner salaries with VBA examiner salaries. We 
analyzed data from OPM's CPDF to calculate the average base salary, 
including locality adjustments, for VBA examiners state by state. We 
divided each DDS's average examiner salary by the average VBA examiner 
salary for each state, the District of Columbia, and Puerto Rico. This 
resulted in a measure of DDS average salary relative to average VBA 
examiner salaries for each location.

When we analyzed salaries of examiners who left DDSs to accept higher 
salaries in federal agencies, directors of two DDSs provided 
information on both the salaries of these examiners while they were 
employed by the DDSs, and on the federal General Schedule (GS) grade 
levels for their new SSA positions. To determine SSA salaries, we used 
the 2002 federal government GS pay scale, including locality 
adjustments. For cases in which the directors provided us with two 
possible SSA grade levels, we used the first step of the lower grade in 
our analysis. Three of these disability examiners also served as 
quality assurance reviewers, hearing officers, or trainers while 
employed in their DDS. Positions accepted at SSA by the departing 
examiners included regional office disability quality branch analyst, 
regional office program specialist, and field office claims 
representative, as well as posts in the federal DDS.

[End of section]

Appendix II: Survey of DDS Directors' Views on Human Capital 
Challenges:

We sent this version of the survey to the DDSs that were not testing 
the single decision-maker (SDM) position. We have annotated this 
version to indicate how the survey that we sent to the DDSs that were 
testing the SDM position differed from this version.

In addition, the survey we sent to the California DDS contained 
questions both for DDSs that were testing the SDM position, and for 
those not testing the SDM position, because some of the California DDS 
branches were testing the SDM, and some were not.

In the survey sent to DDSs that were testing the SDM position, the 
definitions and questions referred, where appropriate, to both SDMs as 
well as disability examiners (DEs), so that the survey questions would 
cover all examiners.

In the survey sent to DDSs that were testing the SDM position, Question 
17 referred to "current SDMs (excluding trainees) who need additional 
mentoring and/or refresher training to successfully perform the SDM 
role.":

In the survey sent to DDSs that were testing the SDM position, Question 
18 referred to "obstacles to your SDMs receiving needed additional 
mentoring and/or refresher training." The question asked: "To what 
extent, if any, is each of the following an obstacle to your current 
SDMs (excluding trainees) receiving, over the next two years, 
additional mentoring and/or refresher training needed to successfully 
perform the SDM role?":

In the survey sent to DDSs that were testing the SDM position, Question 
22 was phrased: "To what extent, if any, were the following factors a 
challenge for your DDS in making the transition to the SDM position?":

Question 23 was not included in the survey that was sent to the DDSs 
that were testing the SDM position, since those DDSs had already made 
the transition to the SDM position.

In the survey sent to the DDSs that were testing the SDM position, the 
"Yes/No" part of Question 24 was not included. Thus, the second part of 
Question 24 was asked generally of all DDSs testing the SDM position.

In the survey sent to the DDSs that were testing the SDM, Part II, 
Question 1, did not indicate "N/A" in row b.

In the survey sent to the DDSs that were testing the SDM, Part II, 
Question 3, did not indicate "N/A" in row b.

In the survey sent to the DDSs that were testing the SDM, Part II, 
Question 11, row a indicated "DEs and/or SDMs.":

In the survey sent to the DDSs that were testing the SDM, Part II, 
Question 9, row a indicated "DEs and/or SDMs.":

This question was only included in the survey sent to the DDSs that 
were testing the SDM position. It was not included in the survey sent 
to the DDSs that were not testing the SDM position.

[See PDF for image]

[End of figure]

[End of section]

Appendix III: Related GAO Reports:

Modernizing Federal Disability Programs:

Social Security Disability: Reviews of Beneficiaries' Disability Status 
Require Continued Attention to Achieve Timeliness and Cost-
Effectiveness. GAO-03-662. Washington, D.C.: July 24, 2003.

High-Risk Series: An Update. GAO-03-119. Washington, D.C.: January 1, 
2003.

SSA Disability: Other Programs May Provide Lessons for Improving 
Return-to-Work Efforts. GAO-01-153. Washington, D.C.: January 12, 2001.

Social Security Disability Insurance: Multiple Factors Affect 
Beneficiaries' Ability to Return to Work. GAO/HEHS-98-39. Washington, 
D.C.: January 12, 1998.

SSA Disability: Return-to-Work Strategies from Other Systems May 
Improve Federal Programs. GAO/HEHS-96-133. Washington, D.C.: July 11, 
1996.

SSA Disability: Program Redesign Necessary to Encourage Return to Work. 
GAO/HEHS-96-62. Washington, D.C.: April 24, 1996.

General Human Capital Management:

Human Capital: Opportunities to Improve Executive Agencies' Hiring 
Processes. GAO-03-450. Washington, D.C.: May 30, 2003.

Results-Oriented Cultures: Creating a Clear Linkage between Individual 
Performance and Organizational Success. GAO-03-488. Washington, D.C.: 
March 14, 2003.

High-Risk Series: Strategic Human Capital Management. GAO-03-120. 
Washington, D.C.: January 2003.

A Model of Strategic Human Capital Management. GAO-02-373SP. 
Washington, D.C.: March 15, 2002.

Human Capital: A Self-Assessment Checklist for Agency Leaders. GAO/OCG-
00-14G. Washington, D.C.: September 2000.

Strategic Workforce Planning:

Human Capital: Key Principles for Effective Strategic Workforce 
Planning. GAO-04-39. Washington, D.C.: December 11, 2003.

Foreign Assistance: Strategic Workforce Planning Can Help USAID Address 
Current and Future Challenges. GAO-03-946. Washington, D.C.: August 22, 
2003.

Tax Administration: Workforce Planning Needs Further Development for 
IRS's Taxpayer Education and Communication Unit. GAO-03-711. 
Washington, D.C.: May 30, 2003.

Human Capital Management: FAA's Reform Effort Requires a More Strategic 
Approach. GAO-03-156. Washington, D.C.: February 3, 2003.

HUD Human Capital Management: Comprehensive Strategic Workforce 
Planning Needed. GAO-02-839. Washington, D.C.: July 24, 2002.

NASA Management Challenges: Human Capital and Other Critical Areas Need 
to be Addressed. GAO-02-945T. Washington, D.C.: July 18, 2002.

Air Traffic Control: FAA Needs to Better Prepare for Impending Wave of 
Controller Attrition. GAO-02-591. Washington, D.C.: June 14, 2002.

Securities and Exchange Commission: Human Capital Challenges Require 
Management Attention. GAO-01-947. Washington, D.C.: September 17, 2001.

Human Capital: Implementing an Effective Workforce Strategy Would Help 
EPA to Achieve its Strategic Goals. GAO-01-812. Washington, D.C.: July 
31, 2001.

Single Family Housing: Better Strategic Human Capital Management Needed 
at HUD's Homeownership Centers. GAO-01-590. Washington, D.C.: July 26, 
2001.

Organizational Transformation:

Results-Oriented Cultures: Implementation Steps to Assist Mergers and 
Organizational Transformations. GAO-03-669. Washington, D.C.: July 2, 
2003.

Homeland Security: Management Challenges Facing Federal Leadership. 
GAO-03-260. Washington, D.C.: December 20, 2002.

Highlights of a GAO Forum: Mergers and Transformation: Lessons Learned 
for a Department of Homeland Security and Other Federal Agencies. GAO-
03-293SP. Washington, D.C.: November 14, 2002.

Managing for Results: Using Strategic Human Capital Management to Drive 
Transformational Change. GAO-02-940T. Washington, D.C.: July 15, 2002.

FBI Reorganization: Initial Steps Encouraging but Broad Transformation 
Needed. GAO-02-865T. Washington, D.C.: June 21, 2002.

Training and Development:

Human Capital: A Guide for Assessing Strategic Training and Development 
Efforts in the Federal Government. GAO-03-893G. Washington, D.C.: July 
1, 2003.

Foreign Languages: Human Capital Approach Needed to Correct Staffing 
and Proficiency Shortfalls. GAO-02-375. Washington, D.C.: January 31, 
2002.

Human Capital: Design, Implementation, and Evaluation of Training at 
Selected Agencies. GAO/T-GGD-00-131. Washington, D.C.: May 18, 2000.

[End of section]

Appendix IV: Comments from the Social Security Administration:

Note: GAO comments supplementing those in the report text appear at the 
end of this appendix.

SOCIAL SECURITY:

The Commissioner:

December 17, 2003:

Mr. Robert E. Robertson: 
Director, Education, Workforce, and Income Security Issues: 
U.S. General Accounting Office Room 5T57:

441 G Street, NW Washington, D.C. 20548:

Dear Mr. Robertson:

Thank you for the opportunity to review the draft report, "Social 
Security Administration - Strategic Workforce Planning Needed to 
Address Human Capital Challenges Facing the Disability Determination 
Services." I welcomed this study when first proposed since this is an 
area that SSA has worked on for some time. Further, I agree that human 
capital management in the disability area is critical to the success of 
our mission. SSA executives and their staff spent a great deal of time 
working with GAO auditors over the past year in order for them to fully 
understand the complexities of this issue and the overall Federal/State 
relationship. However, the report does not fairly address or adequately 
discuss the many sides of this issue.

The report relies heavily on the opinions expressed in a survey of the 
Disability Determination Services (DDS) Administrators. As SSA staff 
indicated to the auditors before they issued the survey, we found the 
questions rather leading in nature and the conclusions of the report 
already embedded in the nature of the questions. Further, the 
questionnaire was sent to the administrators during a continuing 
resolution (CR), which required tight budgetary constraints and a 
hiring freeze for the DDSs. We believe these circumstances colored some 
of the responses of the administrators.

SSA has long supported increased salaries for DDS examiners and has 
never declined a request from a DDS to support them on this issue. 
Consequently, the report's assertion on page 5 that 24 DDSs had been 
refused a request for assistance in this area is not true and should be 
removed. The survey questions' ambiguity may have caused the responders 
to answer in such a fashion. Based on the Agency's knowledge and daily 
contacts with the regional offices, we know of no State that was 
refused assistance or support in obtaining salary improvements for DDS 
examiners. On the contrary, SSA has worked very hard to obtain such 
salary improvements.

The report fails to acknowledge the high level of sophistication in 
many States in dealing with human resource management. Many States, 
especially the large ones, have organizational units that deal with 
human capital management issues for all State employees. But, the 
report 
dismisses the effectiveness of these units without having contacted 
them. DDS Administrators are responsible for the DDSs, not for human 
capital management in the States and, therefore, they cannot be viewed 
as the final word in these matters. To present a complete and informed 
picture, the auditors should also have contacted the State human 
resource organizations to provide a more accurate assessment of this 
activity in the States.

The report recommends conducting an outreach program to State governors 
and officials and such activity is already underway. SSA's regional 
commissioners and their delegates engage in such discussions with State 
officials, but must do so within the context of each State's 
organizational and political environment. These are highly sensitive 
discussions, and SSA's regional officials must exercise considerable 
judgment in assessing the most appropriate approach to take in each 
State. These judgments are made in concert with DDS management and must 
consider each State's circumstances. On the national level, we intend 
to engage in discussions with the National Governors Association 
regarding DDS issues.

The report also does not give the proper weight to the variety of 
attitudes in States on the matter of Federal mandates. While some 
States may accept a Federal mandate on qualifications, others may not, 
and may elect to opt out of the program. If they opt out, SSA needs to 
find a venue to process the claims for that State, and this would not 
be easy to do. The decision by even one large State to opt out of the 
program would present serious issues to SSA. Additionally, suddenly 
enlarging SSA's own workforce to deal with such a workload is not 
feasible.

The report suggests that DDSs are failing to meet service delivery 
goals when, actually, DDSs are delivering the levels of service in 
processing time, quality and productivity set through the budget 
process. While the report states that processing times are increasing, 
attributing this to the inexperience of new recruits or the complexity 
of the decisionmaking, in fact processing times have been going down. 
DDS Title II processing time improved from 90.3 days in fiscal year 
(FY) 2001 to 84.8 days in FY 2003. DDS Title XVI processing time 
improved from 93.1 days in FY 2001 to 86.1 days in FY 2003. The report 
also suggests that DDS quality is deteriorating. However, the data in 
SSA's quality reviews have consistently scored annual DDS Net 
Decisionmaking Accuracy at least at 96.2 percent accurate in every year 
since 1992. In addition to improvement in processing times and 
consistency in accuracy, productivity-per-workyear showed a 3.2 percent 
increase from FY 2001 (261.9) through FY 2003 (270.4).

The report speaks in generalities at the national level that may not be 
helpful in assessing an individual State's experience. Further 
examination would reveal that higher DDS salaries, in and of 
themselves, do not guarantee improved DDS performance. As we conveyed 
to the auditors, at the individual State level, there has been no 
correlation between high salaries and good processing time, good 
accuracy or good productivity. There are many States with higher 
salaries that are below average performers and vice versa. The report's 
notion, therefore, that high salaries alone are a panacea is mistaken.

But more importantly, the report fails to acknowledge that, if all DDS 
examiner salaries were raised to the level of Federal examiners, it 
would introduce an additional annual cost of nearly $100 million to the 
DDS budget (salary increases plus indirect costs). Such information 
needs to be included in the report to keep the discussion in 
perspective.

Additionally, the report, in its calculation of costs on page 19, 
assumes that all attrition is bad and fails to acknowledge the value of 
bringing new employees into an organization to keep it vibrant and 
growing.

The report fails to provide an example of any other successful Federal 
agency that SSA might elect to model in this matter. While the report 
mentions the qualifications requirements of the Department of Education 
with regard to Vocational Rehabilitation Counselors, it fails to 
provide any evidence that this has helped that agency achieve its 
mission or improved its performance.

On September 25, 2003, I testified before the House Ways and Means 
Subcommittee on Social Security and presented my approach to improve 
the disability determination process. The proposed process would 
shorten decision times, pay benefits much earlier to people who are 
obviously disabled and test new incentives for people with disabilities 
who wish to remain in, or return to, the workforce.

In this context, I generally agree with the intent of the 
recommendations in the report and, as part of our overall plan to 
improve the disability determination process, we will consider 
developing a nationwide strategic workforce plan that addresses the 
human capital challenges in the DDSs. Such a plan would need to deal 
appropriately with Federal and State roles and the other considerations 
laid out in the comments above.

However, the report does not sufficiently acknowledge the historical 
record of the development of regulations governing the Federal/State 
relationship. The report mentions the:

1980 Amendments that provided SSA with additional authority to issue 
regulations governing program administration, but it does not 
acknowledge the subsequent regulatory development process and the 
States' reactions to proposals regarding increased Federal control of 
States' agencies. That is not to say that such regulatory changes 
should not be pursued, but the report should take more notice of the 
complexities involved.

In closing, I want to assure you that we will work with the DDSs to 
continue ongoing efforts to improve examiner job skills. In our efforts 
to continually improve training and meet the needs of the DDSs, we 
already have in place: (1) a Disability Training Steering Committee (4 
DDS representatives) that provides input on training needs and reviews 
subject matter materials; (2) a Disability Training Cadre that prepares 
and presents disability related training (also with 4 DDS 
representatives); (3) Bi-monthly Disability Topics (based on requests 
received from various sources, including the DDSs) that are presented 
via Interactive Video Training. We continually seek input from the DDSs 
on training needs for all types of employees. The input is used to 
develop and update training materials. Most recently, input was 
solicited from the DDSs by:

(1) conducting a DDS supervisory skills assessment in July 2003; and 
(2) seeking DDS input on a medical consultant curriculum outline in 
September 2003. Finally, SSA components are currently working to revise 
and update the Disability Examiner Basic Training Program, which is the 
entry-level course for new examiners.

If you have any questions, please have your staff contact Candace 
Skurnik, Director, Audit Management and Liaison Staff at (410) 965-
4636.

Sincerely,

Signed by: 

Jo Anne	B. Barnhart:

GAO Comments:

1. We believe that the report presents a fair and balanced portrayal of 
the multifaceted issue of human capital management in the DDSs. We 
designed the survey to obtain DDS directors' opinions about the extent 
to which, if any, a DDS had experienced certain human capital 
challenges and the likely factors and consequences involved. Moreover, 
the opinions were obtained from directors whose first-hand experiences 
make them some of the most knowledgeable sources of information about 
such issues in their organizations. But in addition to our survey, our 
overall study methods relied on information and data from several other 
sources as well. For example, we interviewed disability examiners and 
their managers at two DDSs, officials responsible for DDS management 
assistance at three of SSA's regional offices, SSA officials at 
headquarters, officials of the National Council of Disability 
Determination Directors and the National Association of Disability 
Examiners, and staff of the Social Security Advisory Board. We also 
reviewed pertinent laws, regulations, and procedures, and obtained and 
analyzed human capital data from the DDSs, SSA, and other federal 
agencies.

Our survey was developed in accordance with GAO's guidance on survey 
design and development.[Footnote 77] To avoid the potential for 
questions to be leading, on every question in which we asked for 
directors' opinions, we gave them the opportunity to say that they did 
not experience that particular challenge, contributing factor, or 
consequence. To this end, we constructed the questions so that the 
first response choice was "no extent" or equivalent wording. In 
addition, each question was specifically assessed for possible bias or 
problematic wording during extensive survey pretesting. We pretested 
the survey eight times--with four former DDS directors and four current 
directors. On the basis of these pretests, we modified the questions 
until pretesters raised no further issues.

We also gave SSA disability program officials the opportunity, on two 
occasions, to review and comment on the survey. SSA officials first 
reviewed the survey prior to its pretesting. Among other suggestions, 
they noted that some survey questions were leading in nature and that, 
in addition, we should develop scaled responses to provide respondents 
with the opportunity to modulate their answers (e.g., from "no extent" 
to "very great extent"). We modified the survey on the basis of their 
comments, including revising or eliminating questions that they thought 
were leading and constructing scaled responses as suggested. After 
additionally incorporating comments of several pretesters, we provided 
SSA with the chance to review a revised version of the survey. The 
official coordinating SSA's second review e-mailed us in reply, saying 
that, while some of the survey questions might be difficult for the DDS 
directors to answer, we should go ahead with the survey as revised. The 
official did not refer to any bias in the revised questions.

Our survey questions and our findings reflect ongoing human capital 
challenges facing the DDSs and were not limited to the particular 
circumstances of fiscal year 2003. The survey questions themselves were 
generally not limited to the most recent year, and several explicitly 
asked for data for the past two or three fiscal years or for the 
future. While the impact of the continuing resolution and the related 
SSA hiring freeze that was in place throughout much of fiscal year 2003 
may have affected DDS directors' responses, DDS and SSA officials have 
told us that resource constraints and budget uncertainties have been 
ongoing challenges for a number of years. Furthermore, certain aspects 
of the time period in which the survey was conducted likely downplayed 
some of the human capital challenges facing the DDSs. For example, DDS 
officials said in interviews that they expected examiner turnover to 
increase as economic conditions improved in the future.

2. Our report acknowledges the efforts made by SSA regional offices to 
persuade state governments to increase examiner salaries in light of 
their new responsibilities. Our report, however, does not assert that 
24 DDSs were refused assistance with negotiating salary increases for 
examiners after they had requested it. Rather, we said that, of the DDS 
directors who reported wanting help from SSA with negotiating salary 
increases, more than half (24 DDSs) said they had not received this 
kind of help. (SSA interpreted wanting help and not receiving it as 
having requested help and been refused such assistance.) But regardless 
of whether directors have specifically requested this or another type 
of human capital assistance, they reported in their survey responses 
that they want active support from SSA on this and a number of other 
issues involving human capital management.

3. Our report acknowledges that some states have strategic workforce 
planning initiatives that consider their DDS employees. However, the 
issue relevant to our study was not whether statewide human capital 
management offices were generally effective, as SSA suggests, but 
whether there were any workforce planning efforts by SSA or the DDSs 
that were integral to and supportive of SSA's mission and goals. As we 
noted in the report, even sophisticated statewide workforce planning 
efforts are not necessarily focused on ensuring that the DDSs have the 
workforces needed to accomplish such SSA goals as reducing claims-
processing times.

4. Our report acknowledges SSA's current efforts at outreach to state 
officials. For example, our report describes efforts on the part of 
regional office officials to persuade state governments to exempt 
examiners from state hiring restrictions, reclassify DDS examiner 
positions, and increase examiner salaries. We also emphasize that SSA 
and its regional offices can be limited in their ability to help the 
DDSs negotiate changes by such factors as state political and budget 
concerns, as well as state personnel rules. However, as noted in our 
report, we found no record to date of any discussions with the National 
Governors Association (NGA) or of NGA focusing on this topic. Our 
recommendation that SSA reach out to national associations such as the 
NGA is an acknowledgment that the DDSs and SSA's regional offices 
cannot successfully confront these difficult human capital challenges 
without the sustained attention of SSA's leadership at the national 
level. For clarity, we have emphasized this point in the text of our 
recommendation. SSA's expressed intent to pursue discussions on a 
national level with NGA is a step in the right direction.

5. We recounted in our report the view of SSA officials that requiring 
uniform human capital standards might be perceived by some states as 
unwelcome federal interference and could raise the prospect of states 
withdrawing their participation in making disability determinations. We 
also noted the difficulties SSA has encountered in the past in 
convincing the DDSs to comply with SSA guidelines on personnel issues, 
due in part to the states' perceptions of infringements on traditional 
prerogatives. Accordingly, we stressed in our report that establishing 
uniform minimum qualifications for examiners throughout the DDSs will 
be difficult, requiring delicate and time-consuming discussions with 
some state governments. However, establishing such qualifications will 
also be worthwhile, helping some DDSs justify an appropriate job 
classification and level of compensation needed to recruit and retain 
qualified disability examiners. As an agency with fiduciary 
responsibility for administering disability programs that are 
nationwide in scope, SSA has an obligation to do no less than take firm 
steps to address the human capital challenges facing the DDSs. We 
understand SSA's concern about the difficulties it would face if states 
opted out of the disability program and transferred these 
responsibilities to the federal government.[Footnote 78] To help ensure 
the success of SSA's efforts, outreach from SSA's leadership to the 
state governors will be vital. Also essential will be a close working 
partnership among the immediate stakeholders--SSA, the DDSs, and their 
state parent agencies--in developing a nationwide strategic workforce 
plan.

6. We did not examine the accuracy and timeliness of claims processing. 
Nevertheless, even had these measures of performance improved, the 
Commissioner noted in her September 25, 2003, testimony that SSA still 
has "a long way to go" in its efforts to be more timely and accurate, 
despite positive strides in the short term. Moreover, SSA's own 
published strategic plan for 2003 to 2008 warns that "the length of 
time it [currently] takes to process these claims is unacceptable." 
Results from our survey of DDS directors demonstrate the need to 
address such DDS human capital issues as high turnover and recruiting 
and hiring difficulties in order to improve the timeliness and accuracy 
of claims processing. Of the directors (43) who reported experiencing 
difficulties in recruiting and hiring enough people who could become 
successful examiners, more than three-quarters said that such 
difficulties contributed to decreased accuracy in disability decisions 
or to increases in claims-processing times. Moreover, over one-half of 
all directors reported that turnover had increased claims-processing 
times.

7. Our report neither states nor assumes that higher salaries alone 
guarantee improved DDS performance. Rather, it states that, according 
to more than two-thirds of all DDS directors, noncompetitive pay was 
one of several factors contributing to examiner turnover. Moreover, our 
report emphasized the costly consequences of such turnover, noting that 
the estimated cost of examiner turnover in fiscal year 2002 was in the 
tens of millions of dollars. (Our estimates show that this would be the 
case, regardless of whether the calculation is based on total turnover 
or turnover that is above that of the federal government as a whole.) 
SSA itself has been attempting to persuade state governments to 
increase examiner salaries to reflect new job responsibilities. 
Although increased compensation may increase costs, the turnover that 
can result from not addressing human capital management concerns, such 
as not compensating employees appropriately, can be costly as well, as 
we note in the report.

We agree with SSA that some attrition is desirable. But over half of 
all DDS directors told us in our survey that examiner turnover in their 
offices was too high, and we found that examiner turnover was about 
twice that of federal employees performing similar work. Because 
turnover is costly, we emphasize the importance of using data to 
identify current and future human capital needs. We have found in prior 
work that high-performing organizations analyze who is leaving, what 
skill gaps result, and how much turnover is desirable or acceptable. 
Organizations that fail to effectively manage their turnover risk not 
having the capacity to achieve their goals. A balance needs to be 
achieved between bringing in new employees with fresh and vibrant 
perspectives and retaining experienced employees whose institutional 
knowledge can maintain goals and help train others.

8. We cited the Department of Education's experience to show that 
establishing federal qualifications requirements for state employees, 
as we recommended that SSA do, can and has been done. While we have not 
studied federal experiences with workforce planning in an 
intergovernmental arena, the GAO reports we provide in appendix III 
highlight an array of initiatives on the part of federal agencies to 
embrace workforce planning, including SSA's planning models for its own 
employees. SSA has been willing to take the lead and develop models in 
workforce planning for its own employees. It should therefore build on 
its own internal expertise and lessons learned in this field to develop 
models of workforce planning in the demanding intergovernmental context 
as well. Lack of an existing model for the range of changes we 
recommend may make implementation more challenging, but it is not a 
convincing argument for inaction.

9. We support SSA's leadership in its efforts to improve the disability 
determination process and to help people with disabilities remain in or 
return to the workforce. SSA said that it generally agreed with the 
intent of our recommendations and would consider incorporating a 
nationwide strategic workforce plan for the DDSs into its current 
strategy to improve disability determinations. To do so will be 
essential, since the Government Performance and Results Act now 
requires agencies to report annually, as we noted in our report, on 
human capital strategies needed to meet their strategic goals. While we 
did not provide an exhaustive treatment of states' reactions to 
proposals for increased federal control, our report did note past 
opposition of some states to federal guidelines on personnel matters. 
In addition, we have added further detail in the report about the 
regulatory development process. We acknowledge the complexities 
involved in pursuing regulatory change. But despite these difficulties, 
we maintain that SSA has an obligation to address DDS workforce needs.

10. SSA said that it would continue ongoing efforts to improve examiner 
job skills. Results from our survey of DDS directors, however, revealed 
gaps in critical examiner knowledge and skills. Moreover, a large 
proportion of directors said they would be able to spend fewer 
resources on adapting SSA's training if SSA were to improve the 
quality, completeness, and timeliness of this training. Given such 
results, our report recommended that SSA go beyond its current efforts 
and base its training improvement initiatives on a systematic 
assessment of the examiner's job responsibilities and related 
knowledge, skills, and competencies.

[End of section]

Appendix V: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Robert E. Robertson (202) 512-7215 Carol Dawn Petersen (202) 512-7215:

Staff Acknowledgments:

In addition to those named above, the following individuals made 
significant contributions to this report: Barbara Bordelon, Marissa 
Jones, Suit Chan, and Beverly Crawford, Education, Workforce, and 
Income Security Issues; Ellen Rubin, Strategic Issues; Gregory Wilmoth, 
Applied Research and Methods; and B. Behn Miller, General Counsel.

FOOTNOTES

[1] U.S. General Accounting Office, SSA Customer Service: Broad Service 
Delivery Plan Needed to Address Future Challenges, GAO/T-HEHS/
AIMD-00-75 (Washington, D.C.: February 10, 2000).

[2] U.S. General Accounting Office, High-Risk Series: An Update, 
GAO-03-119 (Washington, D.C.: January 2003).

[3] Statement of the Honorable Jo Anne B. Barnhart, Commissioner, 
Social Security Administration: Testimony before the Subcommittee on 
Social Security of the House Committee on Ways and Means, September 25, 
2003.

[4] The 54 DDSs include one in each state and in the District of 
Columbia, Guam, and Puerto Rico, as well as a DDS for the Blind in 
South Carolina. We excluded the Guam DDS and the South Carolina DDS for 
the Blind from the survey, because they each employ only one person. 
Throughout this report, we refer to the Puerto Rico and the District of 
Columbia DDSs as state agencies. 

[5] The Government Performance and Results Act established a planning 
time horizon of at least five years for agency strategic plans. We have 
reported that the act's strategic planning requirements provide a 
useful framework for agencies to integrate their human capital 
strategies with their strategic and programmatic planning. See U.S. 
General Accounting Office, High-Risk Series: An Update, GAO-01-263 
(Washington, D.C.: January 2001). 

[6] GAO-01-263.

[7] DI beneficiaries with low income and assets can also receive SSI 
benefits. Of the 5.5 million DI beneficiaries, about 800,000 also 
received SSI in 2002. 

[8] The Commissioner of Social Security has the authority to set the 
substantial and gainful activities level for individuals who have 
disabilities other than blindness. In December 2000, SSA finalized a 
rule calling for the annual indexing of the nonblind level to the 
average wage index of all employees in the United States. The 2004 
nonblind level is set at $810 a month. The level for individuals who 
are blind is set by statute and is also indexed to the average wage 
index. In 2004, the level for blind individuals is $1,350 of countable 
earnings.

[9] SSA permits DI, but not SSI, applicants to file for benefits 
online.

[10] In 2002, the DDSs made 2.3 million initial disability 
determinations and over 484,000 reconsiderations. In September 2003, 
the Commissioner testified before the House Committee on Ways and 
Means, saying that she intended to revise the disability determination 
process. For example, she proposed eliminating the reconsideration and 
the Appeals Council stages of the current process.

[11] If the claimant is not satisfied with the Appeals Council 
decision, the claimant may appeal to a federal district court. The 
claimant can continue legal appeals, as needed, to the U.S. Circuit 
Court of Appeals and ultimately to the Supreme Court of the United 
States.

[12] See Pub. L. No. 96-265, Sec. 304(a) (1980).

[13] See 20 C.F.R. Sec. 404.1503(a) and 416.903(a) (2003).

[14] In the preamble to these regulations, SSA stated that it did not 
define DDS administrative requirements in detail and instead elected to 
regulate only to the extent necessary to ensure effective and uniform 
administration of the disability program. (46 Fed. Reg. 29,190, 29,198 
(1981). SSA also stated that, overall, the states supported the 
agency's proposed regulatory approach. (Id. at 29,196.)

[15] The regulations also encourage the states to refrain from imposing 
state personnel freezes and restrictions against overtime work on the 
DDSs to the extent possible. See 20 C.F.R. Sec. 404.1621(b) and 
416.1021(b).

[16] Our survey data show that 50 out of 52 DDSs report to a state 
parent agency, and among these, 28 DDSs report to the state's 
vocational rehabilitation agency. 

[17] See GAO/T-HEHS/AIMD-00-75. 

[18] For example, due to changes in agency rules, examiners must now 
adhere to more complex requirements regarding such matters as 
determining the weight that should be given to the opinion of a 
treating source and making a finding as to the credibility of 
claimants' statements about the effect of pain on functioning. See 
Social Security Advisory Board, Agenda for Social Security: Challenges 
for the New Congress and the New Administration (February 2001).

[19] Expansion of an examiner's authority would bypass the current need 
for a medical consultant to certify the decision unless the law 
mandates otherwise. Medical consultants are required to certify all SSI 
childhood disability claims and all less than fully favorable decisions 
on DI and SSI claims involving an indication of a mental impairment. 

[20] Some DDSs may have higher educational requirements for some 
applicants or may use standards other than, or in addition to, 
education--such as relevant skills, previous equivalent experience, or 
some type of selection examination for which a qualifying score or 
ranking is needed for hiring eligibility. The minimum education 
requirements shown in this figure do not necessarily reflect the actual 
credentials of DDS examiners hired by the DDSs. For example, one DDS 
director explained in an interview that, despite the lack of any 
educational requirements for new examiner hires in the state, most 
examiners employed by the DDS had four-year college degrees, and 
several had masters' degrees. 

[21] SSA officials said the agency's policy was to avoid layoffs of DDS 
employees.

[22] See, for example, U.S. General Accounting Office, SSA and VA 
Disability Programs: Re-Examination of Disability Criteria Needed to 
Help Ensure Program Integrity, GAO-02-597 (Washington, D.C.: August 9, 
2002).

[23] GAO-03-119.

[24] GAO-01-153.

[25] Social Security Administration, Strategic Plan 2003-2008. 

[26] The cost of administering the DI and SSI programs reflects the 
demanding nature of the process. Although SSI and DI program benefits 
account for less than 20 percent of the total benefit payments made by 
SSA, they consume nearly 55 percent of SSA's annual administrative 
resources.

[27] Social Security Advisory Board, Charting the Future of Social 
Security's Disability Programs: The Need for Fundamental Change 
(Washington, D.C.: January 2001).

[28] Social Security Advisory Board, Disability Decision-Making: Data 
and Materials (Washington, D.C.: January 2001).

[29] U.S. General Accounting Office, Major Management Challenges and 
Program Risks: Social Security Administration, GAO-03-117 (Washington, 
D.C.: January 2003).

[30] GAO-01-263.

[31] GAO-01-263 and U.S. General Accounting Office, Human Capital: Key 
Principles for Effective Strategic Workforce Planning, GAO-04-39 
(Washington, D.C.: December 11, 2003).

[32] GAO-04-39.

[33] See 31 U.S.C. Sec. 1115(a)(3) and (f) (2003).

[34] U.S. General Accounting Office, A Model of Strategic Human Capital 
Management, GAO-02-373SP (Washington, D.C.: March 15, 2002).

[35] VBA employs 5,000 disability claims examiners, called veterans 
service representatives (VSRs) and ratings veterans service 
representatives (RVSRs), in 57 offices covering each state. Because the 
Office of Personnel Management's Central Personnel Data File groups 
both positions together, our comparisons include both groups. Both 
positions have certain responsibilities similar to those of DDS 
examiners. For example, RVSRs and DDS examiners are responsible for 
analyzing disability claims to determine disability benefit 
eligibility. Moreover, VSRs and DDS examiners are responsible for 
investigating disability claims and serving as the primary contact for 
claimants and health providers. However, when compared with the DDS 
examiner, RVSRs have the additional responsibility of determining 
whether claimants' impairments are related to their military service, 
and VSRs have the added task of conducting initial interviews with 
applicants. In this report, we are referring to both RVSRs and VSRs as 
VBA examiners.

[36] We were unable to obtain data on turnover rates of private sector 
employees who perform work similar to that of DDS examiners that was 
comprehensive enough to allow valid comparisons. We were also unable to 
obtain recent data on the turnover rates of state employees other than 
DDS employees. 

[37] According to human resource experts, it is typical for new 
employees to leave at higher rates than all other employees. See U.S. 
General Accounting Office, Veterans Benefits Administration: Better 
Collection and Analysis of Attrition Data Needed to Enhance Workforce 
Planning, GAO-03-491 (Washington, D.C.: April 28, 2003).

[38] We categorized these conditions as consequences of turnover if 
directors reported that they had occurred to a moderate to very great 
extent as a result of turnover. 

[39] U.S. General Accounting Office, Social Security Disability: 
Reviews of Beneficiaries' Disability Status Require Continued Attention 
to Achieve Timeliness and Cost-Effectiveness, GAO-03-662 (Washington, 
D.C.: July 24, 2003).

[40] We categorized factors as contributing to examiner turnover if DDS 
directors reported that these factors contributed to turnover to a 
moderate to very great extent.

[41] We collected average examiner salary data from the federal DDS 
administered by SSA, adjusted it to reflect locality pay in each state, 
and compared it with average DDS examiner salary data from our survey. 
One DDS was excluded because it did not provide examiner salary data. 
While the federal DDS examiner position carries responsibilities beyond 
those of the state DDS examiners, state DDS examiners do not receive 
additional training in order to perform the federal examiner job. 

[42] We analyzed salary data from our survey and from VBA in order to 
compare DDS examiner and VBA examiner salaries. We were unable to 
obtain information on experience levels of VBA examiners and the 
distribution of their experience levels across the states. It is 
possible that these factors could help explain some of the differences 
between the average salaries of VBA examiners and DDS examiners. 

[43] See appendix I for an explanation of our methods for this 
analysis. 

[44] DDS directors responding to this survey question had experienced 
recruiting and hiring difficulties for any of fiscal years 2000, 2001, 
or 2002. We characterized DDSs as having difficulty if the director 
reported having some to very great difficulty in recruiting and hiring.

[45] We categorized a condition as a consequence of recruiting and 
hiring difficulties if DDS directors reported that the difficulties had 
contributed to the condition from some to a very great extent.

[46] Specifically, the DDS directors said that noncompetitive salaries 
that were insufficient to attract or retain staff with skills to become 
SDMs were or were likely to be a moderate to very serious challenge for 
their DDSs in making the transition to the SDM position. Under the SDM 
position, examiners would be given expanded authority for making 
disability decisions, allowing them in many cases to independently 
decide claimants' eligibility for benefits without the need for medical 
consultant approval. The agency is currently testing this position.

[47] The question excluded trainee examiners.

[48] Twenty DDSs were testing the SDM position at the time of our 
study. We administered our survey to 19 of these DDSs. We excluded one 
of the DDSs that was testing the SDM position--the Guam DDS--from this 
survey. 

[49] These new examiner responsibilities were outlined by the 
Commissioner in her testimony before the Subcommittee on Social 
Security of the House Committee on Ways and Means, September 25, 2003.

[50] We asked whether various factors were obstacles to nontrainee 
examiners receiving additional mentoring or refresher training over the 
next two years to successfully perform the SDM role or to become 
successful SDMs. However, as discussed above, the skills needed to 
perform the SDM role apply more broadly. We categorized a factor as an 
obstacle if DDS directors deemed it to be a moderate to very serious 
obstacle to receiving needed training or mentoring.

[51] Current and former DDS officials told us that on-the-job training 
provided by mentors was essential to learning to successfully perform 
the examiner job.

[52] While other strategies also may be included in workforce planning 
efforts, our prior work has found that the strategies listed are key to 
effective workforce planning. See GAO-01-263. 

[53] We found that only 10 of the 28 DDSs that conduct workforce 
planning efforts longer-term than SSA's annual budget process include 
all 8 key planning strategies. 

[54] Our prior work has shown that accurate, comprehensive human 
capital data are essential to good workforce planning. See 
GAO-02-373SP.

[55] Syracuse University, Maxwell School of Citizenship and Public 
Affairs, Government Performance Project, Paths to Performance in State 
& Local Government (Syracuse, NY: 2002).

[56] We categorized these factors as obstacles to long-term workforce 
planning if directors reported that they had experienced them to a 
moderate to very great extent. 

[57] Management Advisory Report, Single Audit of the State of Louisiana 
for the Fiscal Year Ended June 30, 2001, Office of the Inspector 
General, Social Security Administration (December 2002).

[58] In the survey, we explained that SSA's training included written 
materials, interactive video training technology, and videos. The 
survey question covered new examiner basic training and other training 
that SSA provides beyond basic training.

[59] The survey asked whether the DDS: (1) had adapted SSA training to 
make it adequate, and had offered this training in the past 24 months; 
or (2) planned to--or wanted to but was unable to--adapt SSA training 
to make it adequate and offer it in the next 12 months. Adapting 
training could involve editing or revising SSA's training materials, 
not using some of the materials, or offering a substitute course.

[60] We categorized factors as reasons for adapting SSA's training if 
DDS directors deemed them to be a moderately to very important reason. 
Beyond issues pertaining to quality, completeness, and timeliness of 
SSA's training, DDS directors who adapted SSA's training cited 
operating procedures and training preferences that are unique to the 
DDS as reasons for adapting SSA's training. The question asked about 
procedures other than those that respond to court decisions and laws.

[61] U.S. General Accounting Office, Human Capital: A Guide for 
Assessing Strategic Training and Development Efforts in the Federal 
Government, GAO-03-893G (Washington, D.C.: July 2003).

[62] We included in this calculation those DDS directors who responded 
that they would be able to spend fewer resources in adapting SSA's 
training from some to a very great extent. 

[63] We categorized these types of assistance as ones that DDS 
directors wanted if the directors said that they wanted them from some 
to a very great extent.

[64] We categorized an area of assistance as being of limited 
effectiveness if DDS directors deemed it to be moderately to not 
effective.

[65] While some regional office officials said that they interact at 
the governors' level in the individual states and, in at least one 
instance according to SSA, with a regional governors' association, we 
could find, to date, no record from the NGA of discussions or forums in 
recent years focusing on the topic of the DDS workforce issues under 
the federal-state relationship regarding SSA's disability programs. We 
asked staff of the NGA whether, during the last five years, NGA staff 
had met with representatives of SSA's Office of the Commissioner or 
received communications from SSA on issues related to the DDSs and 
their employees. We also asked whether issues related to SSA's 
disability decision-making had appeared on the agenda of NGA official 
meetings over the last five years. 

[66] Social Security Advisory Board, Disability Decision Making: Data 
and Materials (Washington, D.C.: January 2001).

[67] Social Security Advisory Board, Charting the Future of Social 
Security's Disability Programs: The Need for Fundamental Change 
(Washington, D.C.: January 2001). The Advisory Board also recommended 
that regulations be revised to ensure that state hiring freezes would 
not apply to the DDS workforce. In making its recommendations, the 
Advisory Board stated that if any state withdrew from the DDS program, 
the agency should be prepared to take over that responsibility from the 
state.

[68] U.S. General Accounting Office, Current Status of the Federal/
State Arrangement for Administering the Social Security Disability 
Programs, GAO/HRD-85-71 (Washington, D.C.: September 30, 1985).

[69] In questions and answers submitted for the record to the 
Subcommittee on Social Security, Committee on Ways and Means, House of 
Representatives, the National Council of Disability Determination 
Directors stated that they agreed with the Social Security Advisory 
Board's recommendation that SSA's regulations be revised to require 
states to follow specific federal guidelines pertaining to human 
capital management in the DDSs. The council submitted these questions 
and answers on August 29, 2002, as follow-up to their June 11, 2002, 
testimony.

[70] The Rehabilitation Act requires state vocational rehabilitation 
agencies to establish personnel standards for rehabilitation counselors 
that are consistent with the degree standards of the highest licensing, 
certification, or registration requirement in the state, or the degree 
standards of the national certification program. As a result, 
vocational rehabilitation counselors in most states must hold a 
master's degree in rehabilitation counseling or certain comparable 
qualifications. A few states require a bachelor's degree. States must 
report annually on the number of rehabilitation counselors who meet 
their established standards and on their plans to train counselors who 
do not meet the standards. 

[71] U.S. General Accounting Office, Developing and Using 
Questionnaires, GAO/PEMD-10.1.7 (Washington, D.C.: October 1993).

[72] While we have focused this report specifically on disability 
examiners, other positions employed by the DDSs, such as medical 
consultants and vocational experts, are also critical to the disability 
determination process. 

[73] We also recorded all notes and comments from respondents that 
qualified their responses. 

[74] We were unable to obtain comprehensive turnover data for private 
insurers who employ disability examiners.

[75] VBA disability examiners were identified by using their unique 
occupational code. 

[76] The results of these calculations were multiplied by 100 to 
express turnover rates as percentages.

[77] U.S. General Accounting Office, Developing and Using 
Questionnaires, GAO/PEMD-10.1.7 (Washington, D.C.: October 1993).

[78] The Congress was also aware of these difficulties in 1980 when it 
required SSA to submit a detailed plan for how it would assume the 
functions and operations of a state disability determination function, 
were it necessary to do so. See discussion of Pub. L. No. 96-265, § 
304(b)(3) in S. Rep. No. 96-408, at 55 (1980) and in the Preamble to 
the 1981 Final Rule, 46 Fed. Reg. 29,190, 29,191 (1981).

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