Social Security Disability:

Improved Processes for Planning and Conducting Demonstrations May Help SSA More Effectively Use Its Demonstration Authority

GAO-05-19: Published: Nov 4, 2004. Publicly Released: Nov 4, 2004.

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Since 1980, the Congress has required the Social Security Administration (SSA) to conduct demonstration projects to test the effectiveness of possible program changes that could encourage individuals to return to work and decrease their dependence on Disability Insurance (DI) benefits. To conduct these demonstrations, the Congress authorized SSA, on a temporary basis, to waive certain DI and Medicare program rules and to use Social Security Trust Funds. The Congress required GAO to review SSA's use of its DI demonstration authority and to make a recommendation as to whether this authority should be made permanent.

SSA has not used its demonstration authority to extensively evaluate a wide range of DI policy areas dealing with return to work. Despite being given the authority to assess a broad range of policy alternatives, SSA has, until very recently, focused its demonstration efforts mostly on a relatively narrow set of policy issues--those dealing with the provision of vocational rehabilitation and employment services. SSA's recently proposed or initiated demonstrations have begun to address a broader range of policy issues, such as provisions to reduce, rather than terminate, benefits based on earnings above a certain level. However, the agency has no systematic processes or mechanisms for ensuring that it is adequately identifying and prioritizing those issues that could best be addressed through use of its demonstration authority. For example, the agency has not developed a formal demonstration research agenda explicitly identifying its broad vision for using its DI demonstration authority and explaining how ongoing or proposed demonstration projects support achievement of the agency's goals and objectives. SSA's demonstration projects have had little impact on the agency's and the Congress' consideration of DI policy issues. This is due, in part, to methodological limitations that have prevented SSA from producing project results that are useful for reliably assessing DI policy alternatives. In addition, SSA has not established a formal process for ensuring that its demonstration results are fully considered for potential policy implications. For example, SSA does not maintain a comprehensive record of its demonstration results that could be used to build a body of knowledge for informing policy decisions and planning future research. Furthermore, SSA's reporting of demonstration project results has been insufficient in ensuring that the Congress is fully apprised of these results and their policy implications.

Matters for Congressional Consideration

  1. Status: Closed - Not Implemented

    Comments: In 2007, Congress took no action and had not yet revisited the issue of whether to renew SSA's demonstration authority on a temporary basis or make such authority permanent. As of July 31, 2008, the House introduced the Social Security Disability Insurance Demonstration Authority Act of 2008 to reestablish SSA's Demonstration Authority, however, the bill does not address our recommendation.

    Matter: To facilitate close congressional oversight and provide greater assurance that SSA will make effective use of its DI demonstration authority, the Congress may wish to establish reporting requirements that more clearly specify what SSA is expected to communicate to the Congress in its annual reports on DI demonstrations. Among such requirements could be a description of all SSA projects that the SSA Commissioner is considering conducting or is conducting some preliminary work on. For each demonstration project that the agency is planning or conducting, SSA should provide clear information on the projects' specific objectives, potential costs, key milestone dates (e.g., actual or expected dates for RFP, award of contracts or grants, start of project operations, completion of operations, completion of analysis, and final report), potential obstacles to project completion, and the types of policy alternatives that SSA might consider pursuing depending on the results of the demonstration. This would provide the Congress with a more complete understanding of the direction and progress of SSA in its efforts to fulfill its DI demonstration requirements.

  2. Status: Closed - Not Implemented

    Comments: In 2007, Congress took no action and had not yet revisited the issue of whether to renew SSA's demonstration authority on a temporary basis or make such authority permanent. As of July 31, 2008, the House introduced the Social Security Disability Insurance Demonstration Authority Act of 2008 to reestablish SSA's Demonstration Authority, however, the bill does not address our recommendation.

    Matter: To facilitate close congressional oversight and provide greater assurance that SSA will make effective use of its DI demonstration authority, the Congress may wish to require that SSA periodically provide a comprehensive report to the Congress summarizing the results and policy implications of all of its DI demonstration projects. The due date for this report could either coincide with the expiration of SSA's DI demonstration authority or, if this authority is made permanent or extended for a period greater than 5 years, be set for every 5 years. Such reports could serve as a basis for the Congress' assessment of SSA's use of its demonstration authority and its consideration of whether this authority should be renewed.

  3. Status: Closed - Not Implemented

    Comments: In 2007, Congress took no action and had not yet revisited the issue of whether to renew SSA's demonstration authority on a temporary basis or make such authority permanent. As of July 31, 2008, the House introduced the Social Security Disability Insurance Demonstration Authority Act of 2008 to reestablish SSA's Demonstration Authority, however, the bill does not address our recommendation.

    Matter: To facilitate close congressional oversight and provide greater assurance that SSA will make effective use of its DI demonstration authority, the Congress may wish to continue to provide DI demonstration authority to SSA on a temporary basis but allow SSA to complete all projects that have been initiated prior to expiration of this authority. This would provide SSA with greater certainty and stability in its efforts to plan and conduct demonstration projects while preserving the Congress' ability to periodically reassess and reconsider SSA's overall use of DI demonstration authority.

  4. Status: Closed - Not Implemented

    Comments: In 2007, Congress took no action and had not yet revisited the issue of whether to renew SSA's demonstration authority on a temporary basis or make such authority permanent. As of July 31, 2008, the House introduced the Social Security Disability Insurance Demonstration Authority Act of 2008 to reestablish SSA's Demonstration Authority, however, the bill does not address our recommendation.

    Matter: To facilitate close congressional oversight and provide greater assurance that SSA will make effective use of its DI demonstration authority, the Congress may wish to more clearly specify the methodological and evaluation requirements for DI demonstrations to better ensure that such projects are designed in the most rigorous manner possible and that their results are useful for answering specific policy questions and for making, where appropriate, well-supported policy recommendations. Such requirements should not be entirely prescriptive given the need for SSA to have sufficient flexibility for choosing the right methodological approach based on the specific circumstances and objectives of a particular demonstration project. However, the requirements could call for SSA to choose, to the extent practical and feasible, the most rigorous methods possible in conducting these demonstrations. Whatever methods are ultimately selected, SSA should be sure that the methods used will allow for a reliable assessment of the potential effect on the DI program of the individual policy alternatives being studied. Finally, SSA's legislative requirements could be revised to include a more explicit list of project objectives--such as assessments of specific employment outcomes, costs and benefits, and Trust Fund savings--similar to the language that was included under Sections 302(b)(1) and (b)(2) of the Ticket to Work and Work Incentives Improvement Act.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: The Social Security Administration (SSA) reported receiving interim reports for a number of demonstration projects and the results from these reports have been presented to the Congress in our annual section 234 report. In addition, the reports are available on SSA's website and in journal articles. SSA also reported that they briefed congressional staff on the demonstration projects.

    Recommendation: To help ensure the effectiveness of SSA's DI demonstration projects, the Commissioner of Social Security should establish formal processes to ensure that, at the conclusion of each demonstration project, SSA fully considers and assesses the policy implications of its demonstration results and clearly communicates SSA's assessment to the Congress. Such processes should ensure that SSA consults sufficiently with internal and external experts in its review of demonstration project results and that SSA issues a report to the Congress clearly identifying (1) major project outcomes, (2) major project limitations, (3) total project costs, (4) any policy options or recommendations, (5) expected costs and benefits of proposed options or recommendations, and (6) any further research or other actions needed to clarify or support the project's results. Another key aspect of such formal processes should be a requirement that SSA maintain a comprehensive record of DI demonstration projects. This record would help SSA in establishing an empirically based body of knowledge regarding possible return-to-work strategies and in deriving the full value of its substantial investments in demonstration projects.

    Agency Affected: Social Security Administration

  2. Status: Closed - Implemented

    Comments: The Social Security Administration (SSA) reported that it is using a Technical Advisory Group (TAG) for each demonstration project that consists of nationally renowned subject matter experts and other experts from the research community. SSA also reported developing a guidebook and is in the process of updating it based on the recommendation of a more recent GAO report (GAO 08-1053). The Guidebook includes procedures for the use of expert panels that include internal and external experts for the development of demonstration projects. The Guidebook also references the need for input and review of the draft statement of work from external experts.

    Recommendation: To help ensure the effectiveness of SSA's DI demonstration projects, the Commissioner of Social Security should establish an expert panel to review and provide regular input on the design and implementation of demonstration projects from the early stages of a project through its final evaluation. Such a panel should include SSA's key research personnel as well as outside disability experts and researchers. SSA should establish guidelines to ensure that its project plans and activities adequately address the issues or concerns raised by the panel or provide a clear rationale for not addressing such issues.

    Agency Affected: Social Security Administration

  3. Status: Closed - Implemented

    Comments: The Social Security Administration (SSA) reported that they are receiving interim results from the demonstration project research, and are in the process of determining how it may inform disability insurance policy decisions and/or the direction of future studies on particular issues or populations. SSA also reported it is consulting with interested groups and individuals on or agenda, and using their input to help shape future projects.

    Recommendation: To help ensure the effectiveness of SSA's DI demonstration projects, the Commissioner of Social Security should develop a formal agenda reflecting the agency's long-term plans and priorities for conducting DI demonstration projects. In establishing this agenda, SSA should consult broadly with key internal and external stakeholders, including SSA advisory groups, disability researchers, and the Congress.

    Agency Affected: Social Security Administration

 

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