Modernizing SSA Disability Programs:

Progress Made, but Key Efforts Warrant More Management Focus

GAO-12-420: Published: Jun 19, 2012. Publicly Released: Jul 19, 2012.

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What GAO Found

The Social Security Administration (SSA) has taken steps that hold promise for improving the process for updating its medical criteria, but continues to face challenges ensuring timely updates. SSA now uses a two-tiered system for ongoing revisions to its medical listings. First, it completes a comprehensive review of all medical conditions listed within each of 14 body systems, making needed revisions. For subsequent updates for a body system, the agency uses a targeted approach, selecting for review and revision only those medical conditions most in need of change. To date, SSA has completed comprehensive revisions for 8 of the 14 body systems and now is reviewing conditions under them to determine where targeted revisions are appropriate. However, some of these targeted revisions have experienced delays. Moreover, SSA has yet to complete comprehensive revisions for six body systems that have been ongoing for 19 to 33 years. SSA officials attributed delays to a lack of staff and expertise, along with the complexity and unpredictability of the regulatory process.

SSA has embarked on an ambitious plan to design by 2016 an occupational information system for use in its disability decision-making process, but has fallen short of best practices for estimating costs, maintaining a schedule, and considering risks and alternatives. SSA currently relies on occupational information developed by the Department of Labor which has not had a major update since 1977. In 2008, SSA initiated a project to develop its own occupational information system (OIS), which SSA expects will provide up-to-date information on the physical and mental demands of work to support its decision-making process. To guide the creation of its OIS, SSA established an advisory panel, collaborated with outside experts and other agencies, and in July 2011 issued a research and development plan detailing relevant activities through 2016. SSA has made progress on some baseline activities in the plan. However, SSA’s cost estimate and schedule had key deficiencies, such as not including any estimate of the cost of producing, maintaining, and operating the system, which can inform design options. SSA also did not adequately consider inherent risks or potential alternatives, which could heighten the risk of additional costs or project failure.

Consistent with modern views of disability, SSA has taken some concrete steps toward greater consideration of an individual’s ability to function with a disability but faces constraints in fully modernizing. SSA has incorporated some criteria into its medical listings to determine whether a claimant’s impairments result in functional limitations that can prohibit the ability to work. SSA is also sponsoring research through the National Institutes of Health to evaluate how functional abilities can further be considered in determining disability. One project aims to develop a computerized tool to assist adjudicators in evaluating how various impairments affect an individual’s function and ability to work. However, SSA officials maintain that other modern concepts of disability cannot be fully incorporated into SSA’s disability decisions. Specifically, SSA faces constraints considering the extent to which assistive devices and workplace accommodations can mitigate work disability, because these are not universally available and SSA lacks the resources to conduct individualized assessments.

Why GAO Did This Study

SSA administers two of the largest federal disability programs. GAO designated federal disability programs as a high-risk area, in part because eligibility criteria had not been updated to reflect medical and technological advances and labor market changes. Given the size and cost of its disability programs, SSA needs updated criteria to appropriately determine who qualifies for benefits. GAO has been asked to assess SSA’s efforts to update its medical criteria and develop a new occupational information system, and to identify other steps taken to modernize disability determination criteria. To do this, GAO reviewed relevant publications and federal laws and regulations; assessed agency plans, cost estimates, schedules, and other documentation against established project management criteria; and interviewed SSA officials, experts, and stakeholders.

What GAO Recommends

GAO recommends that SSA (1) explicitly identify resources needed to achieve its 5-year time frame for updating its medical listings; (2) follow best practices in its cost estimate, schedule, and risk assessment for the occupational information system; and (3) conduct limited, focused studies on how to more fully consider assistive devices and workplace accommodations in its disability determinations. SSA agreed with the first two recommendations and disagreed with the third, stating that such studies would be inconsistent with Congress’ intentions. GAO continues to believe the recommendation has merit, as discussed more fully within the report.

For more information, contact Daniel Bertoni at (202) 512-7215 or

Status Legend:

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  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: To achieve the goal of updating listings for each body system within SSA's 5-year time frame, the Commissioner of Social Security should explicitly identify the resources needed to achieve this goal, such as staff, contractors, and technology aids, and its plans to overcome any resource limitations.

    Agency Affected: Social Security Administration

    Status: Open

    Comments: In July 2013, SSA reported that the agency routinely assesses its resource needs as part of the annual budgeting process and is working within its resource limitations. GAO will consider this recommendation closed when SSA has explicitly identified the resources needed to update body system listings within a 5-year timeframe, including staff, use of contractors, and use of technology. For example, this could be documented in a budget document or a different internal planning document.

    Recommendation: To ensure that its work to revise occupational information is feasible and cost effective, and to improve its chance for success, the Commissioner of Social Security should (1) formally assess risks to the success of the OIS -- addressing such challenges as related to controlling cost, acquiring expertise, managing project complexity, and coordinating with ongoing and related SSA research -- and develop appropriate mitigation strategies, and (2) develop a comprehensive and reliable cost estimate and schedule for the life cycle of the project, in accordance with best practices.

    Agency Affected: Social Security Administration

    Status: Open

    Comments: In May 2013, GAO reported on SSA's progress toward replacing its outdated occupational information system, including signing an interagency agreement with the Bureau of Labor Statistics to assess the feasibility of using an existing survey to collect its data. In July 2013, SSA reported that the agency will also explore the possibility of incorporating O*NET and resources from other agencies in order to advance the new occupational information system. The May 2013 report also noted officials told us that while the agency expects that its current approach will cost less and take less time than previously expected, the agency has not yet finalized a cost estimate. GAO will consider this recommendation closed when SSA has either assessed or addressed risks to the project identified by GAO, as well as developed a reliable cost estimate and schedule for the project that is appropriate and consistent with best practices.

    Recommendation: To help ensure that SSA's disability decisions are as equitable and consistent with modern views of disability as possible, the Commissioner of Social Security should conduct limited and focused studies on the availability and effects of considering more fully assistive devices and workplace accommodations in its disability determinations.

    Agency Affected: Social Security Administration

    Status: Open

    Comments: In July 2013, SSA reported the agency continues to disagree with this recommendation as inconsistent with Congress' intentions. Specifically, SSA referred to a Supreme Court decision that recognized determinations made under the Americans with Disabilities Act (ADA) as separate from disability determinations under the Social Security Act. However, in May 2013, GAO reported SSA said it would explore the possibility of conducting research in the area of assistive devices, noting that this research would require the involvement of highly specialized medical professionals. GAO continues to believe that SSA should conduct limited and focused studies on the availability and effects of considering more fully assistive devices and workplace accommodations in its disability determination process. The fact that workplace accommodations are addressed by the ADA would necessarily preclude SSA from potentially considering them in making disability determinations.

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