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Improving and Modernizing Federal Disability Programs

This information appears as published in the 2015 High Risk Report.

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Federal disability programs across government remain fragmented and in need of modernization. Numerous federal programs provide a patchwork of services and supports to people with disabilities,[1] and work independently without a unified vision and strategy or set of goals to guide their outcomes. Further, three of the largest disability benefit programs—managed by the Social Security Administration (SSA) and the Department of Veterans Affairs (VA)[2]—rely on outdated criteria to determine whether individuals should qualify for benefits. Although SSA and VA have undertaken efforts to update their criteria, aspects of their programs continue to emphasize medical conditions when assessing an individual’s ability to work without sufficient consideration of improvements offered by advances in medicine, technology, or changes in the modern work environment. Moreover, these programs may continue to face growing disability claims workloads resulting in part from individuals with disabilities leaving the workforce during a difficult economic recovery and from service members returning from war. These workload challenges are likely to persist, not withstanding SSA and VA efforts to process more claims. We designated improving and modernizing federal disability programs as high risk in 2003.

[1] In our 2012 report, we identified 45 federal programs that supported employment for people with disabilities. GAO, Employment for People with Disabilities: Little is Known about the Effectiveness of Fragmented and Overlapping Programs, GAO‑12‑677 (Washington, D.C.: June 29, 2012).

[2] SSA’s Disability Insurance and Supplemental Security Income programs together paid $193.4 billion in benefits in fiscal year 2014, while VA paid $49.2 billion in disability compensation benefits in fiscal year 2013. Benefits paid under these programs have grown and are expected to continue growing for the foreseeable future. In particular, SSA’s Disability Insurance Trust Fund is predicted to be depleted in 2016, due in part to a growing population of beneficiaries.

Improving and Modernizing Federal Disability Programs

Since our 2013 update, the federal government’s progress in improving and modernizing disability programs has been mixed. Our summary assessment of partially met for each of the five high-risk criteria reflects that some agencies met the criteria while others did not. When the ratings are combined, the resulting summary rating shows the criteria were partially met. Specifically, SSA and VA have taken concrete steps towards modernizing their disability criteria and managing their claims workloads, but less has been done by Office of Management and Budget (OMB) to reduce fragmentation across all federal programs and to establish government-wide goals.


Programs with Unified Strategies and Goals (OMB)

Programs with Unified Strategies and Goals (OMB)

Since our 2013 update, OMB—the focal point for management in the executive branch—has made some progress towards enhancing coordination across programs that support employment for people with disabilities, but it has not established a larger vision for disability programs that include appropriate government-wide goals and strategies for achieving those goals.

OMB partially met our criterion for leadership commitment. Specifically, since our 2013 update, the administration has taken steps towards establishing government-wide goals to support employment of individuals with disabilities in the federal sector. The Department of Labor promulgated a final rule that set a goal for hiring by federal contractors.[1] In response to our recommendation, the administration also launched a training course in July 2014 to help federal agencies hire, retain, and advance employees with disabilities. Further, OMB reported that it is participating in interagency efforts to develop shared definitions for the common measures required by the recently enacted Workforce Innovation and Opportunity Act, and that these shared measures will allow for greater coordination of job-training efforts across core programs under the Departments of Education and Labor. This progress notwithstanding, OMB has not taken steps toward establishing government-wide goals across all relevant agencies and programs that support employment of individuals with disabilities beyond the federal sector, although our past work on duplication and cost savings suggested that doing so could spur greater coordination and more efficient service delivery. Without government-wide goals, the success of efforts—such as coordinating job-training efforts across various agencies and programs or working with private sector employers—cannot be known or measured effectively.

OMB partially met our criterion for building capacity for agency coordination by continuing to leverage the Domestic Policy and National Economic Councils. For instance, these entities, with the Office of the Vice President, led a review of effective components of job training efforts, culminating in a final report issued in July 2014 that identified actions needed to ensure that federally funded job training programs—including those that serve individuals with disabilities—are linked to employer needs and track outcomes. Additionally, the administration announced a new, multiple-agency initiative, “Curb Cuts to the Middle Class,” that is focused in the near term on supporting efforts to increase employment of individuals with disabilities by federal contractors and in the federal sector. Finally, the administration coordinated a multi-agency initiative to provide services to improve education and employment outcomes for youth in order to reduce their reliance on Social Security disability benefits. As of December 2014, however, the administration’s efforts omit meaningful coordination with programs at other agencies—notably VA and the Department of Defense—that provide key benefits and supports to individuals with disabilities.

With respect to monitoring and demonstrating progress, OMB partially met our criteria. The administration continued to track—and has made some progress increasing—employment for people with disabilities at federal agencies. Specifically, the administration made consistent progress hiring individuals with disabilities between fiscal years 2010 and 2013, and has hired a total of approximately 70,000 individuals with disabilities as of fiscal year 2013—the most current year of publicly available data. However, the administration has yet to meet its goal of hiring 100,000 individuals with disabilities in the federal workforce over 5 years—a goal originally set forth by Executive Order 13163[2] and reiterated by Executive Order 13548.[3]

Finally, OMB has not met our criterion for developing an action plan. The administration has yet to articulate specific plans for establishing measurable, government-wide goals that support employment for people with disabilities outside of the federal government.

Updating Disability Benefit Eligibility Criteria (SSA)

Updating Disability Benefit Eligibility Criteria (SSA)

SSA has taken steps on a number of fronts to update the disability criteria on which its benefit decisions are based. While the agency has developed plans to help ensure timely and ongoing updates to its criteria in the future, testing and development of some efforts are still underway and some related costs have yet to be determined.

SSA met our criterion for leadership commitment. Specifically, SSA leadership has dedicated significant attention and resources on several fronts—updating medical criteria and occupational information, and studying how it might further consider assistive technology in making eligibility decisions—as described below.

SSA partially met our criterion for capacity. With respect to updating medical criteria, since our 2013 update, SSA implemented our recommendation to identify and obtain additional resources needed to better ensure timely updates in accordance with its planned timetables. With respect to updating its occupational information, SSA replaced its earlier, highly ambitious plans with a potentially more cost-effective approach that makes use of existing expertise and resources in the federal government. Consistent with our recommendations, SSA (1) is partnering with the Bureau of Labor Statistics to collect and update occupational information through surveys, and (2) plans to work with the Institute of Medicine—under a contract with the National Academy of Sciences—to study how it might further incorporate the effect of assistive technologies and workplace accommodations into its determinations of individuals’ ability to work. However, officials noted this research will not begin until late fiscal year 2015 or early fiscal year 2016. These efforts notwithstanding, it remains to be determined whether this additional capacity will be sufficient to achieve its goals.

SSA partially met our criterion for action plans. As we reported in 2012, SSA has plans in place for updating its medical criteria—through comprehensive and targeted reviews—on an ongoing basis. SSA is also moving forward with efforts to update its occupational information and, as of January 2015, has developed a project plan that identifies specific steps to be taken and related risks. However, SSA’s plans do not include costs beyond 2015, even though we reported that estimating life-cycle costs—cost for the entire project—would help with management planning and decisions. Finally, SSA intends to further study the use of assistive technologies and workplace accommodations in its decision-making process, but does not plan to award a task order for this study until the summer of 2015.

SSA met our criterion for monitoring. The agency has continually tracked its progress towards completing comprehensive and targeted reviews of its medical criteria over time. Moreover, SSA has in place, as of January 2015, a project plan, schedule, and work breakdown for monitoring progress against planned timeframes.

SSA partially met our criterion for demonstrating progress. Since 2013, SSA reported progress updating its medical listing criteria, although it has had to extend target deadlines for publishing updates to several body systems. SSA also reported positive results from initial testing of its occupational information system. Nevertheless, key components of this update have not yet started or been fleshed out. For example, SSA expects in fiscal year 2015 to complete field testing of this effort and policy and process development by 2017. SSA also expects to begin developing an IT platform in 2015, but noted that progress in this area will depend upon funding. Finally, as noted above, SSA reported that research on the use of assistive technologies and workplace accommodations will not begin until late fiscal year 2015 or early fiscal year 2016. As such, it is too early to know the extent to which SSA’s efforts on each front will ultimately be successful. We will continue to monitor the agency’s progress.

Updating Disability Benefit Eligibility Criteria (VA)

Updating Disability Benefit Eligibility Criteria (VA)

Beginning in 2009 and continuing after our 2013 update, VA has made progress in updating the criteria it uses for rating disability, and has developed project plans and identified resources to help ensure its efforts are successful. However, some of its plans have yet to be tested.

VA leadership has dedicated significant attention and resources to completing an initial revision of its medical criteria and plans to keep them updated, as described below. As such, it met our criterion for leadership commitment for updating its disability eligibility criteria.

VA partially met our criterion for building capacity. To conduct initial revisions of all body systems, the agency leveraged prior studies on earning loss, in-house medical officers and medical information, and input from targeted experts. VA also reported that it is evaluating plans to use contractors to conduct additional earnings loss studies in the future. Nevertheless, VA could further bolster its internal resources and plans for conducting future studies on the impact of impairments on earnings, for example by developing more in-house resources for conducting earnings loss analyses or establishing long-term partnerships with research organizations. We will continue to monitor VA’s efforts toward making fact-based and timely revisions to the VA rating schedule.

Regarding action plans, VA partially met our criterion. In August 2013, VA issued a project plan to ensure its medical criteria are updated on a regular basis. The plan calls for an initial revision of all body systems to be completed by December 2016. Thereafter, VA will stagger its review of the body systems to ensure that each body system is subject to review and possible revision at least every 10 years. VA updated this plan in June 2014 with additional steps designed to help ensure a smooth and timely implementation of these planned revisions. Specifically, this plan specifies the resources and processes to be used to make updates to guidance, training, and systems, and to assess the effect of proposed changes. In doing so, VA implemented our recommendations for establishing formal policies for updating its criteria at regular intervals and for developing a written implementation strategy. This progress notwithstanding, VA is still drafting proposed regulations that will update portions of its disability criteria and it is too early to tell if it will successfully implement recent revisions or sustain regular future revisions to its rating schedule.

VA partially met our criterion for monitoring. Since 2009, the agency has tracked its progress completing updates of medical criteria and earnings information for different body systems. However, VA has only recently begun tracking progress against its August 2013 plan to ensure comprehensive updates by December 2016, and continuous updates every 10 years thereafter.

VA partially met our criterion for demonstrated progress. VA has been conducting a systematic review of its ratings since 2009, which (as noted above) includes updating medical criteria for rating disabilities and consideration of earnings loss information. As of December 2014, VA reported it has drafted regulations covering 14 body systems, which have moved into VA’s internal concurrence and review process, and is close to finishing work drafting regulations covering another body system. VA expects to issue these proposed regulations in fiscal year 2015 and final regulations in 2016, but the agency stated that further revisions may be needed depending on feedback received during the agency’s concurrence process. We will continue to track VA’s progress as it works to complete updates to its ratings.

Managing Disability Claims Workload (SSA)

Managing Disability Claims Workload (SSA)

SSA has made a number of important steps towards managing its claims workload, improving the efficiency and capacity of its operations, and to be positioned to sustain them over the long term. However, its results have so far been mixed and the agency faces capacity challenges that may endanger its progress.

Since our previous update, SSA appointed a chief strategic officer—in response to our past recommendation—responsible for coordinating agency-wide planning efforts, including those related to managing SSA’s claims workload. Additionally, SSA leadership has dedicated significant effort and thought into planning and implementing efforts to reduce its claims backlogs. As such, SSA met our criterion for leadership commitment regarding its disability claims workload.

Although SSA has implemented a number of measures to increase the efficiency of its claims workload, it has struggled with managing competing workloads using current staffing levels. Therefore SSA partially met our criterion for building capacity. Specifically, SSA improved capacity by

  • expanding the use of IT tools to hearings and other offices, which the agency plans to use to efficiently promote consistency in claims processing and compliance with policies;
  • improving heath IT systems to more quickly obtain records and provide additional support to adjudicators;
  •  fast-tracking certain claims that do not require extensive development; and
  • providing additional assistance to offices that are having difficulty managing workloads for initial claims and appeals.

SSA also reported gaining efficiencies at the appellate level by conducting more hearings through video-conferencing. However, resource constraints and delays in some key initiatives have the potential to counteract efficiency gains. For example, development of the Disability Case Processing System—which SSA expects will improve workflows and reduce administrative costs—is delayed and unlikely to be implemented on schedule.

With respect to developing action plans, SSA partially met our criterion. To address its capacity and workload challenges, SSA is developing a human capital operating plan. In response to our recommendation, SSA is also developing a long-range strategic plan—informed by key stakeholders—with the goal of integrating information technology, service delivery, and human capital plans. SSA anticipates releasing this plan along with the President’s Budget for fiscal year 2016. While this effort is important and promising, its purpose is to establish a broad framework for improving SSA programs and it will fall to future plans to provide implementation details for any new service delivery models or operational efficiencies related to its disability programs.

SSA met our criterion for monitoring, but only partially met our criterion for demonstrated progress. The agency has clear goals for claims processing and timeliness, and regularly tracks its performance. To its credit, SSA has consistently reduced the number of initial claims awaiting decision from 842,000 in fiscal year 2010 to 633,000 in fiscal year 2014. Additionally, SSA maintained its timeliness despite increased workloads for processing initial claims through fiscal year 2013—the most current year of publicly available data—exceeding its target of 109 days by two days. However, SSA’s hearing wait times have increased over the past several years. This is due to SSA allocating relatively fewer resources to an increasing appeals workload. We will continue to monitor SSA’s progress and whether the human capital and service delivery plans described above address these issues.

Managing Disability Claims Workload (VA)

Managing Disability Claims Workload (VA)

VA has made notable progress managing its disability claims workload by taking concrete steps to build capacity, and developed action plans for addressing its backlog of claims. Nevertheless, the agency’s workload has continued to increase—including at the appellate level—and VA is still struggling to manage its appeals backlog.

VA met our criterion for leadership commitment. VA leadership has made eliminating its disability claims backlog a priority goal for the agency. To this end, VA has developed plans and implemented a number of program improvements—as described below—to help address its claims and appeals backlogs.

VA has taken a number of steps to build capacity; however, one key effort was short-term in nature and it is not clear whether the momentum generated by this will be sustainable over a longer period. As such, VA partially met our criterion for capacity. With respect to compensation claims, VA attributed its success in reducing its backlog in 2013 to a one-time effort to expedite claims for veterans who had waited over a year for a decision. Beyond this effort, VA has taken steps to build capacity through its people, processes and technology, including

  • (people) implementing segmented claims lanes to match claims with dedicated claims processors based on their complexity or urgency;
  • (process) redistributing cases among offices to even out workloads; establishing the Fully Developed Claims Program to encourage submission of all evidence by veterans and their representatives; and
  • (technology) implementing paperless claims processing across all regional offices to improve the efficiency and accuracy of its decisions; developing a national work queue to automatically route claims according to VA’s priorities; and increasing online service options.

At the appellate level, the agency reported hiring additional staff in 2013, holding more remote hearings by video, implementing checklists to ensure claims are ready to review, and triaging cases that need additional development. While such strategies can help address workload issues, claims are expected to continue to grow and ultimately increase workloads at the appellate level. As such, it remains to be seen whether capacity at both levels will be sufficient to keep pace with workloads.

VA has developed plans to address its claims and appeal backlogs, but it only partially met our criterion for action plans because key aspects of the plans are tentative. VA published a plan to eliminate its backlog of claims in January 2013, addressing our prior recommendation. To date, VA has implemented several of the capacity improvements discussed in the plan, but continues to implement other efforts, such as further enhancements to its paperless claims system. VA also issued a preliminary plan in 2014 to address its appeals backlog. While this is a positive development, VA states some of the key recommendations identified in the plan will require Congressional action, while others lack timeframes for implementation. We will continue to monitor VA’s planning efforts and to determine whether the agency has actionable plans.

VA partially met our criterion for monitoring. VA has clear goals for processing claims and monitors them on an ongoing basis. However, VA’s Inspector General recently raised concerns that VA may be overstating its progress in reducing its backlog by removing some older claims from its inventory that are still awaiting a final decision. Additionally, in its most recent (2014) Performance and Accountability Report, VA either stopped or noted intentions to stop reporting key performance measures from prior years, such as average times for processing claims and resolving appeals, thereby reducing the transparency of VA’s progress.

Since our 2013 update, VA has increased the timeliness of its claims decisions, but continues to struggle with its appeals backlog—partially meeting our criterion for demonstrating progress. Notably, VA reported reducing its claims backlog by 61 percent from its peak of 611,000 in March 2013 to 239,000 in November 2014. Further, the percentage of claims that took longer than 125 days to process has declined in fiscal years 2013 and 2014. Nevertheless, according to VA officials, the average time to complete claims in 2014 was 229—well above the agency’s goal of 125 days. Regarding appeals, VA officials reported that the agency is processing about 50 percent more appeals annually compared to four years ago. Nonetheless, the increase in appeals workload—commensurate with its claims decisions—has resulted in longer processing times for appealed cases.

[1] Affirmative Action and Nondiscrimination Obligations of Contractors and Subcontractors Regarding Individuals with Disabilities, 78 Fed. Reg. 58,682 (Sept. 24, 2013).

[2] Exec. Order No. 13,163, 65 Fed. Reg. 46,563 (July 28, 2000).

[3] Exec. Order No. 13,548, 75 Fed. Reg. 45,039 (July 30, 2010).

Continued planning, management focus, and coordination are needed to complete the work of modernizing federal disability programs:

  • Efforts undertaken by the administration and OMB to coordinate across federal employment programs are laudable, but limited with respect to the scope of the agencies and programs involved and their focus on people with disabilities. OMB needs a government-wide action plan that describes how federal agencies will improve coordination and set measurable goals that support employment for people with disabilities beyond the public sector. Such a plan should identify additional opportunities to build capacity and leverage existing government resources. Moreover, the administration should set and monitor employment goals for agencies and programs that support employment of individuals with disabilities beyond the federal sector.
  • With respect to modernizing disability criteria, SSA has demonstrated considerable progress, but will need to ensure that it has appropriate plans and maintains sufficient capacity to complete and regularly update occupational information in the future. To help ensure its success with these updates, SSA should fully implement our 2012 recommendation to develop a comprehensive and reliable cost estimate for the life cycle of the project.
  • VA also made progress updating its disability ratings, but has yet to finalize and implement initial revisions. VA’s plans to conduct regular updates of its ratings every 10 years are relatively new and its plans to ensure sufficient capacity going forward are still in process. As such, it will take time to determine whether VA’s efforts to date are sufficient. VA will need to continue to closely monitor its progress and to seek additional capacity as needed.
  • Regarding SSA’s claims workload, increasing numbers of disability claims in light of budget constraints threaten to counteract the agency’s progress. SSA must press forward with completing its long-term strategic plan, and implement the steps outlined in it—as well as those in its human capital plan—to ensure it has the capacity and resources needed to manage future workloads while making quality decisions.
  • Lastly, continued leadership focus is needed on VA’s appeals backlog. Specifically, VA should continue to develop plans to reform and streamline its appeals process, and to accurately monitor its workload across components, including monitoring the effect that increased claims decisions have on appeals workloads.
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    • Daniel Bertoni
    • Director, Education, Workforce, and Income Security
    • (202) 512-7215