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.
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, SSAs 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 individuals 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 claimants 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 individuals function and ability to work. However, SSA officials maintain that other modern concepts of disability cannot be fully incorporated into SSAs 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 SSAs 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.
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Recommendations for Executive Action
Status: Closed - Implemented
Comments: In August 2014, SSA reported that the agency did an analysis of additional staff needed for updating the medical listings and allocated three hires out of the new hiring authority towards this effort. SSA posted an internal and external vacancy announcement to hire three employees to work on medical listings. As of August 8, 2014, SSA reported making two selections (those employees are scheduled to report on 8/11/14) and is continuing to evaluate applications and interview applicants to fill the remaining medical listings hire. Beyond hiring, SSA reported that it is in the process of completing final rules for 7 medical listings--all of which are targeted for completion by July 2015--after which SSA will have updated all 15 medical listings since 2007. SSA plans to continue updating and revising listings on a 3-5 year cycle, and conducting targeted updates as warrented by research and medical advancements.
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
Comments: In May 2013, SSA reported signing an interagency agreement with the Bureau of Labor Statistics (BLS) to assess the feasibility of using an existing survey to collect its data. In January 2015, SSA reported it had developed: a comprehensive project plan that includes the objectives, assumptions, business processes, and risks of the project; a work breakdown structure that identifies and organizes the tasks necessary to complete the OIS project; and an integrated master schedule that links tasks together in a chronological format and identifies how tasks are connected. In May, 2016 SSA reported that BLS collected occupational data in early fiscal year 2015 from about 2,500 employees nationwide in a large-scale pre-production test, and began the first cycle of production data collection in September 2015, which will take three years at an annual cost of approximately $30 million. This funding includes additional testing to establish the reliability and validity of the occupational data by comparing data obtained through direct observation of occupations with data collected through their interview method. BLS developed the testing with input from a contracted industrial and organizational psychologist that they contracted with earlier in the year. Also during the summer of 2015, BLS conducted further testing of the collection of the new data elements that describe the mental and cognitive requirements of occupations. Final costs for FY 2015 were $17.5 million, which is inclusive of $1 million for IT platform development. SSA has not yet developed lifecycle costs but is collecting information that will be useful in doing so. SSA reported that future costs will depend upon analysis of the first complete set of production data, how often they refresh occupational data (i.e., "shelf-life"), and the number of employers in each annual sample. To inform SSA's decision about the shelf-life of occupational data, BLS staff are currently conducting research about the rate at which occupations change in order. SSA expects to receive results from this research during fiscal year 2016. GAO will monitor SSA's progress towards the completion of these plans, and its efforts to develop life-cycle cost estimates.
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
Comments: On September 30, 2015 a committee convened by the Health and Medicine Division (HMD) of the National Academies of Science (previously the Institute of Medicine (IOM)) started an analysis of the use in adults of selected assistive products and technologies, including wheeled/seated mobility devices, upper extremity prostheses, and committee-selected products and technologies that pertain to hearing and to communication and speech, and will provide some information on the availability of these products and technologies as workplace reasonable accommodations. The review is expected to take until July 31, 2017 when the final report will be available. SSA indicated in August, 2015 that it will get other feedback on assistive technology as well - through the Idea Scale system and potentially through the Bureau of Labor Statistics' effort to collect information (as part of its OIS project) on workplace accommodations. We will continue to monitor the status and results of the HMD analysis and SSA's actions based on the committee's results and recommendations.
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