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United States Government Accountability Office: 
GAO: 

Testimony: 

Before the Subcommittee on Human Resources, Committee on Ways and 
Means, House of Representatives: 

For Release on Delivery: 
Expected at 9:00 a.m. EDT: 
Thursday, October 27, 2011: 

Supplemental Security Income: 

Preliminary Observations on Children with Mental Impairments: 

Statement of Daniel Bertoni, Director: Education, Workforce, and 
Income Security: 

GAO-12-196T: 

GAO Highlights: 

Highlights of GAO-12-196T, testimony before the Subcommittee on Human 
Resources, Committee on Ways and Means, House of Representatives. 

Why GAO Prepared This Testimony: 

The Social Security Administration’s (SSA) Supplemental Security 
Income (SSI) program provides cash benefits to eligible low-income 
disabled individuals, including children, as well as certain others. 
Children may generally qualify for SSI benefits if they meet certain 
financial requirements and are deemed to have a qualifying medically 
determinable physical or mental impairment of a specified duration or 
severity that results in a functional limitation. In 2010, SSA paid 
more than $9 billion to about 1.2 million disabled children. Over the 
past decade, the overall number of children receiving SSI benefits has 
continued to rise. 

In this statement, GAO discusses initial observations from its ongoing 
review and examines (1) the trends in the rate of children receiving 
SSI benefits due to mental impairments over the past decade; (2) the 
role that medical and nonmedical information, such as medication and 
school records, play in the initial determination of a child’s medical 
eligibility; and (3) the steps SSA has taken to monitor the continued 
medical eligibility of these children. To examine these issues, GAO 
analyzed program data, interviewed SSA officials, conducted site 
visits to SSA field offices and state disability determination 
services (DDS) offices, and interviewed external experts. This work is 
ongoing and GAO has no recommendations at this time. GAO plans to 
issue its final report in April 2012. 

What GAO Found: 

The numbers of children applying for and receiving SSI benefits due to 
a mental impairment has increased over the past decade and now 
comprise a growing majority of all child beneficiaries. While more 
than half of child applicants are denied each year, children with 
mental impairments, such as autism, have represented a growing share 
of those medically allowed for benefits—-increasing from 60 to 67 
percent between fiscal years 2000 and 2010. Factors including but not 
limited to the rising number of children living in poverty and 
increased diagnosis of certain mental impairments may have contributed 
to such growth. However, the relative effects of these and other 
factors on program growth are not fully known at this time. 

Figure: Number of Children under Age 18 Receiving Federally 
Administered SSI Payments, by Mental and Physical Impairment Group, 
December 2000–December 2010: 

[Refer to PDF for image: stacked line graph] 

Year: 2000; 
Physical: 0.27 million; 
Mental: 0.54 million; 
Total: 0.81 million. 

Year: 2001; 
Physical: 0.28 million; 
Mental: 0.57 million; 
Total: 0.85 million. 

Year: 2002; 
Physical: 0.30 million; 
Mental: 0.58 million; 
Total: 0.88 million. 

Year: 2003; 
Physical: 0.31 million; 
Mental: 0.61 million; 
Total: 0.92 million. 

Year: 2004; 
Physical: 0.31 million; 
Mental: 0.65 million; 
Total: 0.96 million. 

Year: 2005; 
Physical: 0.32 million; 
Mental: 0.69 million; 
Total: 1.01 million. 

Year: 2006; 
Physical: 0.34 million; 
Mental: 0.72 million; 
Total: 1.06 million. 

Year: 2007; 
Physical: 0.35 million; 
Mental: 0.74 million; 
Total: 1.09 million. 

Year: 2008; 
Physical: 0.37 million; 
Mental: 0.76 million; 
Total: 1.13 million. 

Year: 2009; 
Physical: 0.38 million; 
Mental: 0.79 million; 
Total: 1.17 million. 

Year: 2010; 
Physical: 0.39 million; 
Mental: 0.83 million; 
Total: 1.22 million. 

Source: GAO analysis of SSA data form the Supplemental Security Record. 

[End of figure] 

Generally, DDS officials reported that they rely on a combination of 
key medical and nonmedical information—such as medical records and 
teacher and parent assessments—in determining a child’s medical 
eligibility and that they consider the totality of information related 
to the child’s impairments, rather than one piece of information in 
isolation. For example, SSA and DDS officials said that they consider 
a child’s use of prescribed medications in the context of other 
information including school records and teacher assessments, which 
are critical in evaluating the child’s functioning over time. Yet, 
despite the importance of such nonmedical evidence, GAO’s work shows 
that examiners sometimes face challenges in obtaining this information 
partly due to teachers’ reluctance to complete the assessments. 

SSA is required to periodically review the medical eligibility of 
certain children receiving SSI benefits, but GAO’s work shows that SSA 
has conducted significantly fewer childhood continuing disability 
reviews (CDR) in recent years. Between fiscal years 2000 and 2010, the 
number of childhood CDRs and age 18 reviews overall fell from more 
than 200,000 to about 126,000 (a 38 percent decrease), while childhood 
CDRs for those with mental impairments dropped from more than 84,000 
to about 13,000 (an 84 percent decrease). SSA officials have 
acknowledged that the agency is not conducting childhood CDRs in a 
timely manner mostly due to resource constraints. However, SSA 
recognizes the importance of conducting CDRs and has recently 
estimated that the CDR process yields a savings-to-cost ratio of 
$12.50 to $1. 

View [hyperlink, http://www.gao.gov/products/GAO-12-196T]. For more 
information, contact Daniel Bertoni at (202) 512-7215 or 
bertonid@gao.gov. 

[End of section] 

Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to discuss our preliminary observations 
on children with mental impairments in the Supplemental Security 
Income (SSI) program. Administered by the Social Security 
Administration (SSA), SSI is a nationwide federal assistance program 
that provides cash benefits to eligible low-income disabled 
individuals, including children, as well as certain individuals who 
are aged or blind. In 2010, SSA paid almost 8 million recipients about 
$50 billion in SSI benefits, of which more than $9 billion was paid to 
about 1.2 million disabled children. During the early and mid 1990s, 
the SSI program experienced a period of unprecedented growth for 
children due, in part, to legal developments that expanded program 
eligibility for children with mental impairments. For example, from 
the end of 1989 through 1996, the number of children receiving SSI 
benefits more than tripled from 265,000 to about 955,000. Since that 
time, the number of children receiving SSI benefits has continued to 
rise, especially for those with mental impairments. Our prior work has 
shown that accurately diagnosing some types of mental impairments is a 
complex and often subjective process for SSA, which can sometimes be 
vulnerable to fraud and abuse. 

My statement today focuses on initial observations from our ongoing 
review and examines (1) the trends in the rate of children receiving 
SSI benefits due to mental impairments over the past decade; (2) the 
role that medical and nonmedical information, such as medication and 
school records, play in the initial determination of a child's medical 
eligibility; and (3) the steps SSA has taken to monitor the continued 
medical eligibility of these children. To examine these issues, we 
collected agency data on the overall number of initial disability 
determinations and allowances, the number and types of mental 
impairments, and the number of continuing disability reviews of 
children conducted by SSA. We assessed the reliability of the data 
presented in this statement and found potential limitations with the 
extent to which primary and secondary impairment codes within SSA's 
831 disability files--the file that contains data on disability 
determinations--may be complete. However, because the 831 disability 
files are used by SSA to reflect the decisions made regarding medical 
determinations, we determined that these data were sufficiently 
reliable to describe certain trends among children in the SSI program. 
In our ongoing work, we will conduct a case file review of a random, 
generalizable sample of select SSI child mental impairments cases 
decided in fiscal year 2010, which will potentially assist us in 
better understanding the extent of this limitation. We also conducted 
in-depth interviews with SSA management and line staff at SSA 
headquarters and six SSA regions--Philadelphia, Pennsylvania; Boston, 
Massachusetts; Atlanta, Georgia; Dallas, Texas; Chicago, Illinois; and 
San Francisco, California. Our work included site visits to 9 field 
offices within these regions, as well as 11 state disability 
determination services (DDS) offices (state agencies under the 
direction of SSA that perform medical eligibility determinations and 
continuing disability reviews of SSI applicants). We selected these 
sites on the basis of their geographic location, as well as the volume 
of SSI applications and benefit allowances for children with mental 
impairments. In addition, we interviewed numerous external experts 
from the medical and disability advocacy communities and reviewed 
relevant federal laws and regulations. We plan to issue our final 
report in April 2012 in accordance with generally accepted government 
auditing standards. Those standards require that we plan and perform 
the audit to obtain sufficient, appropriate evidence to provide a 
reasonable basis for our findings and conclusions based on our audit 
objectives. We believe that the evidence obtained will provide a 
reasonable basis for our findings and conclusions based on our audit 
objectives. 

Background: 

Since 1974, the SSI program, under Title XVI of the Social Security 
Act, as amended,[Footnote 1] has provided benefits to low-income blind 
and disabled persons, including adults and children[Footnote 2] as 
well as certain aged individuals who meet financial eligibility 
requirements and SSA's definition of disability. For children, a 
disability is a medically determinable physical or mental impairment 
that results in certain functional limitations, and is expected to 
result in death or which has lasted or can be expected to last for a 
continuous period of at least 12 months.[Footnote 3] Families of 
children receiving SSI payments are generally required to use the 
benefit to meet a child's current and future needs, including food, 
clothing, and shelter.[Footnote 4] The maximum payment for a child 
receiving SSI benefits is $674 per month regardless of the severity of 
the child's impairment.[Footnote 5] As of December 2010, the average 
monthly child benefit was $597. 

To apply for benefits, the child's parent or guardian usually submits 
an application to SSA either in person at a local SSA field office, by 
telephone, or by mail. SSA's field offices are responsible for 
processing these applications and for verifying the child's and legal 
guardian's nonmedical eligibility requirements, including income, 
resources, and living arrangement information. After initial 
verification, the field office transmits the case file to their state 
disability determination services office for a medical evaluation. 
[Footnote 6] To aid in evaluating whether a child is medically 
eligible, DDS offices review various medical and nonmedical 
information about the child, such as physician notes, psychological 
tests, school records, and teacher assessments.[Footnote 7] In certain 
situations, such as when the evidence is not sufficient to support a 
decision as to whether a child is disabled, the DDS may purchase a 
consultative examination to assist in making the decision.[Footnote 8] 
If there is evidence that indicates the existence of a mental 
impairment, DDS makes every reasonable effort to ensure that a 
qualified psychiatrist or psychologist has completed the medical 
portion of the case review.[Footnote 9] 

After it makes its initial determination, the DDS returns the case 
file to the field office, where SSA completes any outstanding non-
disability case development, computes the benefit amount, and begins 
paying benefits if the claimant was determined disabled. If the claim 
is denied, a claimant has 60 days to request that SSA reconsider its 
decision. If the claimant is dissatisfied with the reconsideration, he 
or she may request a hearing before an administrative law judge, whose 
decision may then be reviewed by SSA's Appeals Council. When these 
administrative review options have been exhausted, the claimant may 
request judicial review by filing an action in a federal district 
court.[Footnote 10] 

After SSA determines that a child is disabled, the agency is required 
by law, in certain circumstances, to conduct periodic reviews, known 
as a continuing disability review (CDR), to verify a child's continued 
medical eligibility for receiving SSI benefits.[Footnote 11] SSA is 
generally required to perform CDRs (1) during the first year after 
birth for babies whose low birth weight is a contributing factor to 
the determination of disability[Footnote 12] and (2) at least once 
every 3 years for all other children under age 18 whose conditions are 
considered likely to improve.[Footnote 13] DDS offices determine when 
beneficiaries will be due for CDRs on the basis of their potential for 
medical improvement, and select and schedule a review date--otherwise 
known as a "diary date"--for each beneficiary's CDR. At the time of 
these reviews, the child's representative payee generally must present 
evidence that the child is and has been receiving medically necessary 
and available treatment for his or her impairment. SSA is also 
required to redetermine the eligibility of children against the adult 
criteria[Footnote 14] for disability after they reach age 18.[Footnote 
15] 

Number of Children Applying for and Receiving SSI Benefits Due to 
Mental Impairments Has Increased: 

The numbers of children applying for and receiving SSI benefits due to 
a mental impairment has increased over the past decade and now 
comprise a growing majority of all child beneficiaries. While not all 
such children who are deemed medically eligible ultimately meet SSI's 
financial eligibility requirements,[Footnote 16] our preliminary 
analysis of medical allowances suggests that the growth in the number 
of child beneficiaries is roughly proportionate to the growth in the 
number of applicants. Furthermore, SSA data showed that the agency has 
denied a majority of child applicants each year.[Footnote 17] Between 
fiscal years 2000 and 2010, the average medical allowance rates for 
children with physical and mental impairments were about 37 and 46 
percent, respectively (see figure 1). 

Figure 1: SSI Applications and Allowances for Children under Age 18, 
by Mental and Physical Impairment Group, Fiscal Years 2000-2010: 

[Refer to PDF for image: 2 stacked line graphs] 

Physical: 

Year: 2000; 
Applications: 145,350; 
Allowances: 55,270 (38%). 

Year: 2001; 
Applications: 146,010; 
Allowances: 56,720. 

Year: 2002; 
Applications: 151,540; 
Allowances: 55,680. 

Year: 2003; 
Applications: 158,440; 
Allowances: 57,960. 

Year: 2004; 
Applications: 160,540; 
Allowances: 58,650. 

Year: 2005; 
Applications: 160,040; 
Allowances: 58,430 (37%). 

Year: 2006; 
Applications: 158,730; 
Allowances: 57,710. 

Year: 2007; 
Applications: 161,960; 
Allowances: 58,600. 

Year: 2008; 
Applications: 162,690; 
Allowances: 61,240. 

Year: 2009; 
Applications: 169,040; 
Allowances: 64,200. 

Year: 2010; 
Applications: 179,350; 
Allowances: 64,820 (36%). 

Mental: 

Year: 2000; 
Applications: 187,050; 
Allowances: 81,330 (43%). 

Year: 2001; 
Applications: 194,610; 
Allowances: 92,540. 

Year: 2002; 
Applications: 217,390; 
Allowances: 104,470. 

Year: 2003; 
Applications: 244,790; 
Allowances: 117,700. 

Year: 2004; 
Applications: 255,350; 
Allowances: 120,600. 

Year: 2005; 
Applications: 254,920; 
Allowances: 117,540 (46%). 

Year: 2006; 
Applications: 242,410; 
Allowances: 109,810. 

Year: 2007; 
Applications: 241,200; 
Allowances: 106,350. 

Year: 2008; 
Applications: 250,080; 
Allowances: 113,400. 

Year: 2009; 
Applications: 267,600; 
Allowances: 123,670. 

Year: 2010; 
Applications: 298,260; 
Allowances: 132,030 (44%). 

Source: GAO analysis of SSA data from the 831 Disability Files. 

Note: The information highlighted in this figure is based on the 
primary impairment code recorded in the disability determination. Data 
represented as "applications" reflect SSI benefit claims were an 
initial disability determination was made each year. Some claims may 
have more than one determination if selected for a quality review or 
if the disability claim is updated during the same year. Such 
determinations are reflected in the data presented above. 

[End of figure] 

SSA data show the number of child applicants with mental impairments 
increased 60 percent between fiscal year 2000 and fiscal year 2010, 
from 187,052 to 298,264, while the total number of SSI child 
beneficiaries with mental impairments on the rolls grew 52 percent 
from 543,000 to 827,000 (see figure 2).[Footnote 18] Our preliminary 
research suggests that several factors may have contributed to the 
increased number of child applicants and beneficiaries, including but 
not limited to SSA's and child advocates' outreach efforts, improved 
access to health insurance for children, the rising number of children 
living in poverty, and increased diagnosis of certain mental 
impairments. However, the relative effects of these and other factors 
on program growth are not fully known at this time. 

Figure 2: Number of Children under age 18 Receiving Federally 
Administered SSI Payments, by Mental and Physical Impairment Group, 
Dec. 2000-Dec. 2010: 

[Refer to PDF for image: stacked line graph] 

Year: 2000; 
Physical: 0.27 million; 
Mental: 0.54 million; 
Total: 0.81 million. 

Year: 2001; 
Physical: 0.28 million; 
Mental: 0.57 million; 
Total: 0.85 million. 

Year: 2002; 
Physical: 0.30 million; 
Mental: 0.58 million; 
Total: 0.88 million. 

Year: 2003; 
Physical: 0.31 million; 
Mental: 0.61 million; 
Total: 0.92 million. 

Year: 2004; 
Physical: 0.31 million; 
Mental: 0.65 million; 
Total: 0.96 million. 

Year: 2005; 
Physical: 0.32 million; 
Mental: 0.69 million; 
Total: 1.01 million. 

Year: 2006; 
Physical: 0.34 million; 
Mental: 0.72 million; 
Total: 1.06 million. 

Year: 2007; 
Physical: 0.35 million; 
Mental: 0.74 million; 
Total: 1.09 million. 

Year: 2008; 
Physical: 0.37 million; 
Mental: 0.76 million; 
Total: 1.13 million. 

Year: 2009; 
Physical: 0.38 million; 
Mental: 0.79 million; 
Total: 1.17 million. 

Year: 2010; 
Physical: 0.39 million; 
Mental: 0.83 million; 
Total: 1.22 million. 

Source: GAO analysis of SSA data form the Supplemental Security Record. 

Note: The above figure does not include those diagnostic groups that 
SSA reported as "unknown." SSA data showed that as of December 2000, 
"unknowns' totaled 33,042 children (0.04 percent), and as of December 
2010, 26,417 children (0.02 percent). 

[End of figure] 

While it is unclear how various factors are contributing to growth at 
this time, SSA data show that since fiscal year 2000, children with 
mental impairments have represented the majority of all child 
applications and medical allowances for SSI benefits. For example, in 
fiscal year 2010, about 62 percent of all SSI child applicants had a 
mental impairment as a primary diagnosis, and about 67 percent of 
those applicants were medically approved for benefits. For those 
applicant children with mental impairments, SSA data also suggests 
that the number of children found medically eligible for benefits has 
increased for almost every mental impairment category--such as speech 
and language delay and mood disorders--between fiscal years 2000 and 
2010, with the exception of intellectual disability as most notable 
(see figure 3).[Footnote 19] 

Figure 3: Medical Allowances for SSI Children with Mental Impairments, 
by Primary Impairment, Fiscal Year 2000-2010: 

[Refer to PDF for image: multiple line graph] 

Year: 2000; 
Conduct/Oppositional Defiant/Personality disorders: 3,840; 
Mental disorders: 5,050; 
Autistic Disorder and other pervasive development disorders: 5,090; 
Speech and language delays: 11,570; 
ADD/ADHD Disorder: 13,860; 
Intellectual disability: 26,370; 
Other[A]: 15,550. 

Year: 2001; 
Conduct/Oppositional Defiant/Personality disorders: 4,900; 
Mental disorders: 6,220; 
Autistic Disorder and other pervasive development disorders: 6,590; 
Speech and language delays: 13,360; 
ADD/ADHD Disorder: 18,120; 
Intellectual disability: 26,670; 
Other[A]: 16,680. 

Year: 2002; 
Conduct/Oppositional Defiant/Personality disorders: 5,730; 
Mental disorders: 7,490; 
Autistic Disorder and other pervasive development disorders: 7,790; 
Speech and language delays: 16,410; 
ADD/ADHD Disorder: 21,560; 
Intellectual disability: 27,180; 
Other[A]: 18,330. 

Year: 2003; 
Conduct/Oppositional Defiant/Personality disorders: 6,210; 
Mental disorders: 8,630; 
Autistic Disorder and other pervasive development disorders: 9,010; 
Speech and language delays: 19,810; 
ADD/ADHD Disorder: 26,160; 
Intellectual disability: 27,560; 
Other[A]: 20,320. 

Year: 2004; 
Conduct/Oppositional Defiant/Personality disorders: 6,210; 
Mental disorders: 9,680; 
Autistic Disorder and other pervasive development disorders: 9,760; 
Speech and language delays: 21,340; 
ADD/ADHD Disorder: 28,740; 
Intellectual disability: 24,600; 
Other[A]: 20,270. 

Year: 2005; 
Conduct/Oppositional Defiant/Personality disorders: 5,800; 
Mental disorders: 10,630; 
Autistic Disorder and other pervasive development disorders: 9,840; 
Speech and language delays: 21,610; 
ADD/ADHD Disorder: 28,030; 
Intellectual disability: 22,240; 
Other[A]: 19,400. 

Year: 2006; 
Conduct/Oppositional Defiant/Personality disorders: 5,380; 
Mental disorders: 11,610; 
Autistic Disorder and other pervasive development disorders: 9,080; 
Speech and language delays: 20,910; 
ADD/ADHD Disorder: 25,960; 
Intellectual disability: 19,160; 
Other[A]: 17,720. 

Year: 2007; 
Conduct/Oppositional Defiant/Personality disorders: 5,17; 
Mental disorders: 12,93; 
Autistic Disorder and other pervasive development disorders: 8,91; 
Speech and language delays: 21,14; 
ADD/ADHD Disorder: 24,63; 
Intellectual disability: 17,15; 
Other[A]: 16,430. 

Year: 2008; 
Conduct/Oppositional Defiant/Personality disorders: 5,250; 
Mental disorders: 15,810; 
Autistic Disorder and other pervasive development disorders: 9,200; 
Speech and language delays: 22,950; 
ADD/ADHD Disorder: 26,310; 
Intellectual disability: 17,180; 
Other[A]: 16,700. 

Year: 2009; 
Conduct/Oppositional Defiant/Personality disorders: 5,550; 
Mental disorders: 18,230; 
Autistic Disorder and other pervasive development disorders: 9,870; 
Speech and language delays: 26,840; 
ADD/ADHD Disorder: 27,670; 
Intellectual disability: 17,830; 
Other[A]: 17,680. 

Year: 2010; 
Conduct/Oppositional Defiant/Personality disorders: 5,790; 
Mental disorders: 20,320; 
Autistic Disorder and other pervasive development disorders: 10,590; 
Speech and language delays: 29,150; 
ADD/ADHD Disorder: 30,110; 
Intellectual disability: 17,680; 
Other[A]: 18,390. 

Source: GAO analysis of SSA data from the 831 Disability Files. 

Note: The information highlighted in this figure is based on the 
primary impairment code recorded in the disability determination. 

[A] The "other" category includes borderline intellectual functioning; 
learning disorders; developmental and emotional disorders in newborns 
and younger infants; psychoactive substance dependence disorder; 
somatoform disorders/eating and tic disorders; anxiety disorders; 
schizophrenic, delusional, schizoaffective and other psychotic 
disorders; and organic mental disorders. 

[End of figure] 

As part of our preliminary work, we examined individual mental 
impairments to determine which impairments had the highest number of 
applications and medical allowances. SSA's data on disability 
determinations is based on the primary impairment as designated by the 
DDS.[Footnote 20] SSA's policy operations manual directs DDS examiners 
to code the primary impairment as the most severe condition that 
rendered the child disabled. In instances where multiple impairments 
are present, the secondary impairment is generally the next most 
severe following the primary. However, SSA officials have acknowledged 
that primary impairment codes are sometimes missing or inaccurately 
coded.[Footnote 21] In addition, the primary impairment code listed 
may be only one of several impairments that led DDS examiners to find 
the child medically eligible for benefits. In our ongoing review, we 
plan to conduct an in-depth case file review to determine the extent 
to which a secondary impairment was present for the most prevalent 
impairments and the extent to which the secondary impairment, or 
combination of impairments, influenced the eligibility decision. SSA 
data show that for fiscal year 2010, the three most prevalent primary 
mental impairments among medical allowances were for (1) attention 
deficit disorder/attention deficit hyperactivity disorder (ADD/ADHD), 
(2) speech and language delay, and (3) autistic disorder and other 
pervasive development disorders (autism). The following information 
provides a brief summary of each of these three impairments as they 
compare to the incidence of all mental impairments, as well as in 
terms of the proportion of applications and medical allowances: 

ADD/ADHD. Between fiscal years 2000 to 2010, applications for this 
condition as a primary impairment more than doubled, from about 55,000 
to 113,000. Also, the number of children found to be medically 
eligible increased by more than 100 percent, from 13,857 to 30,108 
(see figure 4). By December 2010, about 212,000 such children were 
receiving SSI benefits, and they comprised 26 percent of child 
recipients with mental impairments. 

Figure 4: Applications and Medical Allowances for Children with 
Attention Deficit Disorder/Attention Deficit Hyperactivity Disorder as 
a Primary Impairment, Fiscal Year 2000-2010: 

[Refer to PDF for image: stacked vertical bar graph] 

Year: 2000; 
Allowances: 13,857 (25%); 
Applications: 41,347. 

Year: 2001; 
Allowances: 18,124 (32%); 
Applications: 39,267. 

Year: 2002; 
Allowances: 21,558 (33%); 
Applications: 44,509. 

Year: 2003; 
Allowances: 26,162 (33%); 
Applications: 53,268. 

Year: 2004; 
Allowances: 28,739 (32%); 
Applications: 60,176. 

Year: 2005; 
Allowances: 28,026 (31%); 
Applications: 62,865. 

Year: 2006; 
Allowances: 25,959 (30%); 
Applications: 61,808. 

Year: 2007; 
Allowances: 24,632 (28%); 
Applications: 63,607. 

Year: 2008; 
Allowances: 26,305 (28%); 
Applications: 66,568. 

Year: 2009; 
Allowances: 27,669 (28%); 
Applications: 71,824. 

Year: 2010; 
Allowances: 30,108 (27%); 
Applications: 83,338. 

Source: GAO analysis of SSA data from the 831 Disability Files. 

Note: The information highlighted in this figure is based on the 
primary impairment code recorded in the disability determination. Data 
represented as "applications" reflect SSI benefit claims where an 
initial disability determination was made within each year. 

[End of figure] 

While children with ADD/ADHD represent the single largest primary 
diagnostic group, SSA data show that the majority of ADD/ADHD 
applications over the years have been medically denied. Some of the 
examiners we interviewed said that they rarely find a child medically 
eligible for benefits solely on the basis of an ADD/ADHD impairment 
alone, but more commonly in combination with another impairment, such 
as asthma or oppositional defiant disorder. Nevertheless, SSA 
officials suggested that the increase in both applications and medical 
allowances for children with ADD/ADHD might be attributable to an 
increase in diagnosis over the last decade, and cited a National 
Institute of Health survey finding that ADHD diagnoses had increased, 
on average, by 3 percent from 1996 to 2006 and by 5.5 percent, on 
average, from 2003 to 2007.[Footnote 22] SSA officials also noted a 
2008 medical study reporting that ADHD is one of the most commonly 
diagnosed childhood neurobehavioral disorders.[Footnote 23] 

Speech and language delay. During the last decade, both applications 
and medical allowances for children with speech and language delay 
have increased overall, but the proportion of applicants found 
medically eligible has remained relatively stable over time. Between 
fiscal years 2000 to 2010, applications for this impairment more than 
doubled, from 21,615 to 49,664 while the number of children found to 
be medically eligible nearly tripled, from 11,565 to 29,147 (see 
figure 5). As of December 2010, about 174,000 (21 percent) children 
with mental impairments were receiving benefits due to a speech and 
language delay. While some DDS officials expressed the view that 
increases could be attributed to increased school testing and 
screening programs, SSA officials said further study was needed to 
better understand these particular increases. 

Figure 5: Applications and Medical Allowances for Children with Speech 
and Language Delay as Primary Impairment, Fiscal Year 2000-2010: 

[Refer to PDF for image: stacked vertical bar graph] 

Year: 2000; 
Allowances: 11,565 (54); 
Applications: 10,050. 

Year: 2001; 
Allowances: 13,358 (56%); 
Applications: 10,386. 

Year: 2002; 
Allowances: 16,407 (58%); 
Applications: 11,753. 

Year: 2003; 
Allowances: 19,812 (60%); 
Applications: 13,279. 

Year: 2004; 
Allowances: 21,342 (60%); 
Applications: 14,251. 

Year: 2005; 
Allowances: 21,613 (59%); 
Applications: 14,900. 

Year: 2006; 
Allowances: 20,905 (59%); 
Applications: 14,709. 
  
Year: 2007; 
Allowances: 21,137 (58%); 
Applications: 15,018. 

Year: 2008; 
Allowances: 22,946 (59%); 
Applications: 15,914. 

Year: 2009; 
Allowances: 26,841 (61%); 
Applications: 17,050. 

Year: 2010; 
Allowances: 29,147 (59%); 
Applications: 20,517. 

Source: GAO analysis of SSA data from the 831 Disability Files. 

Note: The information highlighted in this figure is based on the 
primary impairment code recorded in the disability determination. Data 
represented as "applications" reflect SSI benefit claims where an 
initial disability determination was made within each year. 

[End of figure] 

Autism. Between fiscal years 2000 and 2010, autism applications more 
than quadrupled from 5,430 to 23,203, and medical allowances increased 
similarly from 5,050 to 20,319 (see figure 6). As of December 2010, 
about 95,000 (11 percent) children with mental impairments were 
receiving SSI benefits due to autism. DDS examiners have generally 
found the vast majority of those children applying for SSI on the 
basis of autism medically eligible for benefits. SSA officials 
attributed the increase in the number of autism applications and 
medical allowances over the years to greater incidence of autism among 
children and explained that some children who may have previously been 
diagnosed as intellectually disabled are instead being diagnosed as 
autistic. According to one study SSA cited, the prevalence of autism 
in children has increased from 0.6 per 1,000 live births in 1994 to 
3.1 per 1,000 live births in 2003, while the prevalence of 
intellectual disability decreased by 2.8 per 1,000 live births in 2003 
[Footnote 24]. 

Figure 6: Applications and Medical Allowances for Children with Autism 
as a Primary Impairment, Fiscal Year 2000-2010: 

[Refer to PDF for image: stacked vertical bar graph] 

Year: 2000; 
Allowances: 5,050 (93%); 
Applications: 0,380. 

Year: 2001; 
Allowances: 6,220 (94%); 
Applications: 0,370. 

Year: 2002; 
Allowances: 7,490 (94%); 
Applications: 0,490. 

Year: 2003; 
Allowances: 8,630 (93%); 
Applications: 0,640. 

Year: 2004; 
Allowances: 9,680 (92%); 
Applications: 0,810. 

Year: 2005; 
Allowances: 10,630 (92%); 
Applications: 0,890. 

Year: 2006; 
Allowances: 11,610 (92%); 
Applications: 1,070. 

Year: 2007; 
Allowances: 12,930 (90%); 
Applications: 1,420. 

Year: 2008; 
Allowances: 15,810 (90%); 
Applications: 1,670. 

Year: 2009; 
Allowances: 18,230 (90%); 
Applications: 2,130. 

Year: 2010; 
Allowances: 20,320 (88%); 
Applications: 2,880. 

Source: GAO analysis of SSA data from the 831 Disability Files. 

Note: The information highlighted in this figure is based on the 
primary impairment code recorded in the disability determination. Data 
represented as "applications" reflect SSI benefit claims where an 
initial disability determination was made within each year. 

[End of figure] 

Examiners Report Using a Combination of Key Information Sources in 
Determining Medical Eligibility: 

In our preliminary work, DDS officials reported that they rely on a 
combination of key medical and nonmedical information--such as medical 
records, prescribed medications, school records, and teacher and 
parent assessments--in determining a child's medical eligibility. 
[Footnote 25] Several DDS officials said that when making a 
determination, they consider the totality of information related to 
the child's impairments, rather than one piece of information in 
isolation.[Footnote 26] With regard to the medical information used by 
examiners, SSA generally requires DDS examiners to assist children and 
their parents or guardians in obtaining medical records in an effort 
to develop at least a 1-year-long medical history prior to applying 
for benefits.[Footnote 27] According to many of the DDS officials we 
interviewed, examiners attempt to obtain medical evidence, such as 
psychological tests, physician's notes, and mental health records, for 
children with alleged mental impairments. If such evidence is not 
available or existing evidence is inconclusive, some DDS officials we 
spoke with said that they will purchase a consultative examination for 
the child. This examination is intended to provide the additional 
medical evidence, such as results of a physical examination and 
laboratory findings, needed for a determination. However, many DDS 
officials told us that such examinations are only a "snap-shot" in 
time and do not provide a longitudinal view of the child's functioning 
over time. For this reason, some DDS officials said that information 
from a treating source with a long-standing relationship with the 
child, such as a physician, is more useful. 

In response to concerns among many about the role medication plays in 
the determination process, we asked SSA and DDS officials how 
information about a child's use of prescribed medications is used, and 
they told us it is generally given no more weight than any other 
medical or nonmedical information in determining a child's medical 
eligibility.[Footnote 28] Several DDS officials told us that when 
making determinations for children with mental impairments, medication 
is considered in the context of other sources of information as "just 
one piece of the puzzle." To the extent that medication improves 
functioning, some DDS officials told us they could potentially find 
that the child is not disabled under program rules. Despite this fact, 
certain field office and DDS officials acknowledged they believe some 
parents are under the impression that medicating their children will 
improve their likelihood of being found eligible for benefits. 
However, other DDS officials said they think a number of parents may 
avoid medicating their child prior to a consultative examination so 
that the child misbehaves and appears more disabled. 

To better understand the role of prescribed medications, in March 
2011, SSA conducted an analysis to determine the effect reported use 
of medications has on determinations for children with three different 
mental impairments and concluded that no effect existed. To conduct 
this review, SSA compiled reports of medication usage for all fiscal 
year 2010 initial determinations for children with ADD/ADHD, 
oppositional/defiant disorder, or conduct disorder impairments. 
[Footnote 29] For each impairment, SSA calculated the share of 
allowance and denial decisions for those claims with and without 
related medications. SSA subsequently noted that for the children 
examined, those with reports of related medication were more likely to 
be denied than to be allowed. Although SSA's analysis indicates that 
allowance and denial rates were similar for children with ADD/ADHD who 
were and were not taking related medications, children with related 
medications were somewhat more likely to be allowed for oppositional/ 
defiant disorder and conduct disorder than those without medications. 
Because only about one-third of those allowed for these three 
impairments had reports of related medication, SSA concluded that 
medication usage does not affect the allowance of child claims for 
these impairments. However, SSA's analysis did not control for other 
factors, such as DDS location or claimant age, which may also affect 
allowance rates. Without a more in-depth analysis, the effect of the 
underlying causes of such differences is unknown. Although we did not 
independently validate SSA's findings, as part of our ongoing review, 
we plan to conduct a case file review of a random, generalizable 
sample of initial determinations decided in fiscal year 2010 for the 
most prevalent mental impairments--ADD/ADHD, speech and language 
delay, and autism. As part of this effort, we will identify what 
sources DDSs reported using to determine the child's medical 
eligibility and how they reported weighing various sources if material 
inconsistencies could not be resolved. This case file review should 
allow us to verify testimonial evidence from interviews with field 
office and DDS officials. 

In addition to medical evidence, SSA policy directs DDS offices to use 
available evidence from nonmedical sources to evaluate the severity of 
the child's impairment and functioning as part of the eligibility 
determination. These sources include parents, day care providers, 
teachers, and others knowledgeable about the child's day-to-day 
behavior and activities. SSA field office staff may also provide 
observations about the child, if the child is present when the parent 
submits the application, in person, and the field office may notify 
the DDS if multiple siblings apply for benefits at the same time. 
Several DDS officials told us school records and teacher assessments 
(standardized questionnaires)[Footnote 30] are especially critical, 
because these assessments provide information on the child's 
functioning over time and are generally more objective than parent 
assessments. Because parents may be unable to accurately assess the 
extent of their child's impairment, nearly all the DDS officials we 
interviewed said that information from the school, including the 
teacher assessment, was critical for making accurate determinations. 
According to some DDS officials, parents may primarily observe their 
child in an unstructured home environment after the child's 
medications have worn off, and they may not know what behaviors are 
developmentally normal, whereas teachers are generally in a position 
to compare the child to other children and provide neutral 
observations on how the child relates to peers, responds to 
medication, and performs in school. Several DDS officials told us that 
they compare all the information they collect to identify 
inconsistencies and decide how much weight to assign the various 
sources. For example, some officials told us examiners assess the 
credibility of parents' assessments of children's functioning by 
comparing it to physicians' and teachers' statements. 

Despite the importance of nonmedical information in determining a 
child's medical eligibility, our preliminary work shows that examiners 
sometimes face challenges obtaining complete information. For example, 
some DDS offices reported difficulty obtaining school records or 
teacher assessments, which they partly attributed to school and 
teacher concerns about the time involved to compile this information, 
potential liability issues, or confusion about how such information is 
used in the disability decision-making process. In addition, DDS 
examiners told us that they do not routinely receive information on 
multiple siblings receiving SSI benefits within the same household 
even though they are directed to be alert for such cases. SSA's policy 
operations manual states that disabilities may occur in more than one 
member of a family or household, but notes prior case experience has 
shown this type of situation is an indicator of potential fraud or 
abuse, particularly where certain mental impairments are involved. For 
example, SSA recently investigated a case in which parents applied for 
SSI benefits on behalf of their four children, alleging that they all 
suffered from ADHD and conduct issues.[Footnote 31] However, 
investigators found that the school guidance counselor had never 
observed the children exhibiting symptoms of ADHD despite seeing them 
daily and that a doctor had rescinded an order authorizing the school 
to administer ADHD medication to the children. In this instance, SSA 
subsequently denied the siblings' applications for SSI benefits. Based 
on our interviews, it appears that SSA field offices do not 
consistently notify DDS examiners when an applicant's siblings are 
already receiving SSI benefits, nor are they always made aware of 
concurrent sibling applications. Without such information, DDS 
examiners may be limited in their abilities to identify potential 
fraud or abuse in the program. 

SSA Has Conducted Significantly Fewer CDRs for SSI Children with 
Mental Impairments: 

SSA is required to periodically review the medical eligibility of 
certain individuals,[Footnote 32] though our preliminary work shows 
that SSA has conducted significantly fewer CDRs for children receiving 
SSI benefits in recent years, including those with mental impairments. 
Between fiscal years 2000 and 2010, childhood CDRs for those 
recipients under age 18 and age 18 redeterminations overall fell from 
more than 200,000 to about 126,000 (a 38 percent decrease), and more 
specifically, childhood CDRs for those with mental impairments 
declined from more than 84,000 to about 13,000 (an 84 percent 
decrease) (see figure 7). SSA officials attribute the decrease in CDRs 
overall primarily to resource limitations and a greater emphasis on 
processing initial claims and reducing the backlog of requests for 
appeals hearings in recent years. While SSA did increase the number of 
CDRs it performed after receiving additional funding specifically 
targeted for CDRs between fiscal years 1996 and 2002, CDRs decreased 
once the funding expired. 

Figure 7: Number of Childhood CDRs Conducted for SSI Recipients under 
Age 18, by Primary Impairment, Fiscal Years 2000-2010: 

[Refer to PDF for image: stacked vertical bar graph] 

Year: 2000; 
Mental impairment CDRs: 84,010; 
Physical impairment CDRs: 66,860. 

Year: 2001; 
Mental impairment CDRs: 67,010; 
Physical impairment CDRs: 37,910. 

Year: 2002; 
Mental impairment CDRs: 112,530; 
Physical impairment CDRs: 63,970. 

Year: 2003; 
Mental impairment CDRs: 90,430; 
Physical impairment CDRs: 44,300. 

Year: 2004; 
Mental impairment CDRs: 68,440; 
Physical impairment CDRs: 47,050. 

Year: 2005; 
Mental impairment CDRs: 41,280; 
Physical impairment CDRs: 33,820. 

Year: 2006; 
Mental impairment CDRs: 13,610; 
Physical impairment CDRs: 14,080. 

Year: 2007; 
Mental impairment CDRs: 2,980; 
Physical impairment CDRs: 4,630. 

Year: 2008; 
Mental impairment CDRs: 3,310; 
Physical impairment CDRs: 6,670. 

Year: 2009; 
Mental impairment CDRs: 7,980; 
Physical impairment CDRs: 15,170. 

Year: 2010; 
Mental impairment CDRs: 13,090; 
Physical impairment CDRs: 25,990. 

Source: GAO analysis of SSA data from the CDR Waterfall Files. 

[End of figure] 

SSA has conducted fewer childhood CDRs in recent years. As of August 
1, 2011, SSA had not yet conducted CDRs for about 434,000 SSI 
recipients under age 18 with mental impairments who had reached their 
scheduled CDR date (see figure 8).[Footnote 33] Of these recipients, 
about 343,000 (79 percent) had exceeded the scheduled date by at least 
a year, with about 205,000 (47percent) exceeding their date by 3 years 
and 24,400 (6 percent) exceeding by 6 years. SSA data also indicate 
that while age 18 redeterminations are conducted in a more timely 
manner, about 8 percent of these reviews are also overdue by 3 years 
or more.[Footnote 34] In September 2011, SSA's Office of the Inspector 
General also reported that SSA had not completed all childhood CDRs 
and age 18 redeterminations in a timely manner. When reviews of 
benefits are delayed or not conducted, some beneficiaries may receive 
benefits for which they are no longer eligible. The Inspector General 
estimated that SSA had paid about $1.4 billion in SSI benefits to 
approximately 513,000 recipients under age 18 who should not have 
received them.[Footnote 35] SSA has recently estimated that the CDR 
process yielded a savings-to-cost ratio of roughly $12.50 to $1 in 
fiscal year 2009, and that those CDRs conducted for adults and 
children combined in fiscal year 2009 will save federal programs an 
estimated $4.6 billion.[Footnote 36] 

Figure 8: Pending Childhood CDRs and Age 18 SSI Redeterminations for 
Recipients with Mental Impairments, by Time Lapsed, as of August 1, 
2011: 

[Refer to PDF for image: vertical bar graph] 

Years from scheduled date: Less than 1; 
CDRs: 90,090; 
Age 18 recommendations: 27,680. 

Years from scheduled date: Less than 2; 
CDRs: 72,280; 
Age 18 recommendations: 5,130. 

Years from scheduled date: Less than 3; 
CDRs: 67,130; 
Age 18 recommendations: 1,780. 

Years from scheduled date: Less than 4; 
CDRs: 70,730; 
Age 18 recommendations: 1,110. 

Years from scheduled date: Less than 5; 
CDRs: 62,760; 
Age 18 recommendations: 650. 

Years from scheduled date: Less than 6; 
CDRs: 46,800; 
Age 18 recommendations: 510. 

Years from scheduled date: 6 or more; 
CDRs: 24,400; 
Age 18 recommendations: 830. 

Source: GAO analysis of SSA data from the CDR Waterfall Files. 

[End of figure] 

Of those reviews conducted for child recipients in recent years, the 
vast majority were for age 18 redeterminations and low-birth weight 
babies. SSA is generally required by law to conduct age 18 
redeterminations, within 1 year after a child turns 18, and within 12 
months after the birth of a child who was allowed benefits because of 
low birth weight. In fiscal year 2010, 87 percent of CDRs conducted 
for child recipients were done in these two areas, and SSA 
subsequently terminated benefits for about 52 percent of age 18 
recipients and 60 percent of low birth weight recipients. The 
remaining 13 percent of CDRs conducted were mostly reviews of children 
with mental impairments. Of those CDRs conducted for children under 
age 18 with mental impairments, SSA terminated benefits for about 24 
percent of recipients in fiscal year 2010, and personality disorders 
[Footnote 37] and speech and language delay had the highest cessation 
rates (34 and 33 percent, respectively). 

SSA and DDS officials have acknowledged that the agency is not 
conducting reviews for child recipients in a timely manner, and in 
some cases, they have not conducted required childhood CDRs prior to a 
child's age 18 redeterminations. SSA officials said that they would 
like to conduct additional childhood CDRs, but added that due mostly 
to funding constraints they are not able to do so. From 1996 to 2002, 
Congress provided funding to SSA to conduct additional CDRs for both 
Social Security disability and SSI beneficiaries. Since this funding 
expired, the number of CDRs SSA has conducted overall has dramatically 
declined.[Footnote 38] The recently enacted Budget Control Act of 
2011[Footnote 39] authorized an increase in funding for CDRs and 
redeterminations under both the SSI and the Social Security Disability 
Insurance programs, starting with an additional $623 million in fiscal 
year 2012 and reaching an additional $1.3 billion in each of fiscal 
years 2017 to 2021. At the time of this statement, SSA was evaluating 
how to use this funding for CDRs, should it be appropriated, and it is 
not yet known to what extent the agency would (a) increase the number 
of childhood CDRs in the future or (b) target such CDRs toward those 
mental impairments with the highest cessation rates. 

Mr. Chairman and Members of the Subcommittee, this concludes my 
prepared statement. I will be happy to respond to any questions. 

GAO Contact and Staff Acknowledgments: 

For further information related to this statement, please contact me 
at (202) 512-7215. Individuals who may key contributions to this 
statement include Jeremy Cox, Assistant Director, James Bennett, 
Edward Bodine, Sue Bernstein, David Chrisinger, Alex Galuten, Monika 
Gomez, Jason Holsclaw, Kristen Jones, Sheila McCoy, Luann Moy, and 
Paul Wright. 

[End of section] 

Appendix I: Listings for Mental Disorders for Children under Age 18: 

The structure of the mental disorders listings for children under age 
18 parallels the structure for the mental disorders listings for 
adults but is modified to reflect the presentation of mental disorders 
in children. Under federal regulations, when a child is not performing 
substantial gainful activity and the impairment is severe, SSA is 
required to examine whether the child's impairment meets, medically 
equals, or functionally equals any of the impairments contained in the 
listings. The actual listings go into further detail about the level 
of severity necessary for this step of the determination, but the 
general listings for mental disorders in children are arranged in 11 
diagnostic categories.[Footnote 40] These categories include: 

Organic mental disorders: Abnormalities in perception, cognition, 
affect, or behavior associated with dysfunction of the brain. The 
history and physical examination or laboratory tests, including 
psychological or neuropsychological tests, demonstrate or support the 
presence of an organic factor judged to be etiologically related to 
the abnormal mental state and associated deficit or loss of specific 
cognitive abilities, or affective changes, or loss of previously 
acquired functional abilities. 

Schizophrenic, delusional (paranoid), schizoaffective, and other 
psychotic disorders: Onset of psychotic features, characterized by a 
marked disturbance of thinking, feeling, and behavior, with 
deterioration from a previous level of functioning or failure to 
achieve the expected level of social functioning. 

Mood disorders: Characterized by a disturbance of mood (referring to a 
prolonged emotion that colors the whole psychic life, generally 
involving either depression or elation), accompanied by a full or 
partial manic or depressive syndrome. 

Mental retardation: Characterized by significantly sub-average general 
intellectual functioning with deficits in adaptive functioning 
[Footnote 41]. 

Anxiety disorders: In these disorders, anxiety is either the 
predominant disturbance or is experienced if the individual attempts 
to master symptoms; e.g., confronting the dreaded object or situation 
in a phobic disorder, attempting to go to school in a separation 
anxiety disorder, resisting the obsessions or compulsions in an 
obsessive compulsive disorder, or confronting strangers or peers in 
avoidant disorders. 

Somatoform, eating, and tic disorders: Manifested by physical symptoms 
for which there are no demonstrable organic findings or known 
physiologic mechanisms; or eating or tic disorders with physical 
manifestations. 

Personality disorders: Manifested by pervasive, inflexible, and 
maladaptive personality traits, which are typical of the child's long- 
term functioning and not limited to discrete episodes of illness. 

Psychoactive substance dependence disorders: Manifested by a cluster 
of cognitive, behavioral, and physiologic symptoms that indicate 
impaired control of psychoactive substance use with continued use of 
the substance despite adverse consequences. 

Autistic disorder and other pervasive developmental disorders: 
Characterized by qualitative deficits in the development of reciprocal 
social interaction, in the development of verbal and nonverbal 
communication skills, and in imaginative activity. Often, there is a 
markedly restricted repertoire of activities and interests, which 
frequently are stereotyped and repetitive. 

Attention deficit hyperactivity disorder: Manifested by 
developmentally inappropriate degrees of inattention, impulsiveness, 
and hyperactivity. 

Developmental and emotional disorders of newborn and younger infants 
(birth to attainment of age 1): Developmental or emotional disorders 
of infancy are evidenced by a deficit or lag in the areas of motor, 
cognitive/communicative, or social functioning. These disorders may be 
related either to organic or to functional factors or to a combination 
of these factors. 

According to SSA, these listings are examples of common mental 
disorders that are severe enough to find a child disabled. When a 
child has a medically determinable impairment that is not listed, an 
impairment that does not meet the requirements of a listing, or a 
combination of impairments none of which meets the requirements of a 
listing, SSA will make a determination whether the child's 
impairment(s) medically or functionally equals the listings.[Footnote 
42] This determination can be especially important in older infants 
and toddlers (age 1 to attainment of age 3), who may be too young for 
identification of a specific diagnosis, yet demonstrate serious 
functional limitations. Therefore, the determination of equivalency is 
necessary to the evaluation of any child's case when the child does 
not have an impairment that meets or medically equals a listing. 

[End of section] 

Footnotes: 

[1] Pub. L. No. 92-603, § 301, 86 Stat. 1329, 1465. 

[2] For purposes of the SSI program, the term "child" means an 
individual who is neither married nor (as determined by the 
Commissioner of Social Security) the head of a household, and who is 
(1) under the age of 18, or (2) under the age of 22 and (as determined 
by the Commissioner of Social Security) a student regularly attending 
a school, college, or university, or a course of vocational or 
technical training designed to prepare him for gainful employment. 42 
U.S.C. § 1382c(c). 

[3] 42 U.S.C. § 1382c(a)(3)(C)(i) and 20 C.F.R. § 416.906. 

[4] Typically, a disabled child's SSI benefit is paid on behalf of the 
child to a "representative payee," such as a parent or guardian. The 
"representative payee" is responsible for using benefits received only 
for the child's use and benefit in a manner and for the purposes he or 
she determines, consistent with SSA guidelines, to be in the child's 
best interests. 20 C.F.R. § 416.635(a). 

[5] All but five states and the Commonwealth of the Northern Mariana 
Islands supplement federal SSI benefits with additional payments. 
Fourteen states and the District of Columbia have state supplements 
that are either partially or wholly administered by SSA, and 31 states 
self administer their supplements. 

[6] The medical evaluation is conducted under applicable legal 
requirements and SSA policy and assesses whether the child has a 
physical or mental impairment that is severe and that meets or 
medically or functionally equals impairments that are included in 
SSA's listing of impairments, and that meets the duration requirement. 
If these requirements are met, the child is found to be disabled for 
purposes of SSI. 20 C.F.R. § 416.924(a). The listing of impairments 
for children describes the impairments that cause marked and severe 
functional limitations. (See appendix I for additional information 
about the listing of mental disorders for children.) If a child has a 
severe impairment that does not meet or medically equal any listing, 
DDS will decide whether the impairment results in limitations that 
"functionally equal" the listings. Under functional equivalence, a 
child can be found medically eligible for benefits if the child's 
impairment limits his or her functional ability to the same degree as 
described in the listed impairment. Functional equivalence is based on 
the principle that it is the functional limitations resulting from an 
impairment that make the child disabled, regardless of the particular 
medical cause. It was added as a basis for eligibility for children in 
response to the U.S. Supreme Court's decision in Sullivan v. Zebley, 
493 U.S. 521, that SSA's use of medical listings of impairments for 
children--without conducting a functional analysis--was incomplete. 

[7] 20 C.F.R. § 416.913. 

[8] 20 C.F.R. § 416.919a(b). A consultative examination is a physical 
or mental examination or test purchased from a treating source or 
another medical source, including a pediatrician, for an individual at 
SSA's request and expense. 20 C.F.R. § 416.919. 

[9] 20 C.F.R. § 416.903(e). 

[10] For more information about the administrative review process for 
disability determinations, see 20 C.F.R. § 416.1400 et seq. 

[11] SSA conducts two types of reviews to ensure that participants are 
eligible for benefits--CDRs and redeterminations. CDRs verify 
claimant's medical eligibility, while SSI redeterminations verify 
their financial eligibility and ensure that the beneficiary is 
receiving the right amount of SSI benefits. 20 C.F.R. §§ 416.989 and 
416.204. 

[12] 42 U.S.C. § 1382c(a)(3)(H)(iv). 

[13] 42 U.S.C. § 1382c(a)(3)(H)(ii)(I). 

[14] Adults are considered disabled if they are unable to engage in 
substantial gainful activity by reason of a medically determinable 
physical or mental impairment expected to result in death or last at 
least 12 months. 42 U.S.C. § 1382c(a)(3)(A). 

[15] 42 U.S.C. § 1382c(a)(3)(H)(iii). 

[16] Although a child may be found medically eligible for benefits due 
to a physical or mental impairment, SSA must verify the child's 
financial and other non-medical eligibility. If these other criteria 
are not met, the child will not receive SSI benefits. 

[17] Data and references to "applications" or "applicants" throughout 
this statement reflect SSI benefit claims where an initial disability 
determination was made each year. Some claims may have more than one 
determination if selected for a quality review or if the disability 
claim is updated during the same year. 

[18] The number of adults receiving SSI benefits has also steadily 
increased over the past decade. As of December 2010, 6.7 million 
adults were receiving SSI disability benefits up from 5.8 million as 
of December 2000. 

[19] In accordance with Rosa's Law, "intellectual disability" has 
generally replaced the term "mental retardation." Pub. L. No. 111-256, 
124 Stat. 2643. 

[20] The recorded primary impairment code identifies the primary 
impairment used in the medical determination for an individual's 
eligibility for Title XVI disability benefits. It appears in the 
Social Security Administration's 831 and 832/833 Disability files. 

[21] According to SSA officials, the error rate for impairment coding 
is estimated between 5 to 6 percent. 

[22] Centers for Disease Control and Prevention/National Survey of 
Children's Health, "National Health Interview Survey, 2004-2006." 

[23] Pastor, P.N., Reuben, C.A., "Diagnosed attention deficit 
hyperactivity disorder and learning disability: United States, 2004- 
2006" Vital Health Stat 2008; 10 (237). 

[24] Shattuck, P.T., "The contribution of diagnostic substitution to 
the growing administration prevalence of autism in the U.S. Special 
Education data." Pediatrics. 2006 117: 1028-1037. 

[25] See 20 C.F.R. § 416.913. 

[26] See 20 C.F.R. § 416.924(a). 

[27] 20 C.F.R. § 416.912(d). 

[28] SSA regulations require that, when evaluating the effect of a 
child's impairment on his or her functioning, examiners consider the 
effects of treatment, including medication, the child is receiving. 
Specifically, they are required to consider the effects of medication 
on the child's symptoms, signs, laboratory findings, and functioning. 
If it appears that the child's symptoms are reduced by medications, 
they are required to consider (1) any functional limitations that 
persist, despite the medication; (2) whether the medications create 
any side effects that cause or contribute to the child's limitations; 
(3) the frequency of the child's need for medication; (4) changes in 
the child's medication or the way it is prescribed; and (5) any 
evidence over time of how the medication helps or does not help the 
child to function compared to other children the same age who do not 
have impairments. 20 C.F.R. § 416.924a(b)(9)(i). 

[29] SSA excluded from its analysis any medications that were not 
related to the three impairments. For example, a claim for a child 
with ADD/ADHD who was only taking asthma medication would not be 
classified as having a related medication. 

[30] The standardized SSA teacher questionnaire includes checkboxes 
and multiple choice questions and is organized into sections that 
cover broad domains of functioning, such as acquiring and using 
information and attending and completing tasks. 

[31] SSA's Office of Operations and the Office of the Inspector's 
General Cooperative Disability Investigations Unit, which is 
responsible for investigating questions of fraud in SSA's disability 
programs, conducted this investigation. 

[32] Under Title XVI of the Social Security Act, SSA is required to 
(1) perform CDRs at least every 3 years on all children recipients 
under age 18 whose impairments are likely to improve (or, at the 
Commissioner's option, recipients whose impairments are unlikely to 
improve) (42 U.S.C. § 1382c(a)(3)(H)(ii)(I)) and (2) redetermine, 
within 1 year of the individual's 18TH birthday, the eligibility of 
any individual who was eligible for SSI childhood payments in the 
month before attaining age 18, by applying the criteria used in 
determining initial eligibility for individuals who are age 18 (42 
U.S.C. § 1382c(a)(3)(H)(iii)). 

[33] About 845,000 child recipients with mental impairments were 
receiving SSI benefits as of Aug. 1, 2011. 

[34] SSA informed us that 95.6 percent of the age 18 redeterminations 
are released to the field offices for processing by SSA headquarters 
within 2 months of the recipients' 18TH birthday, and most all of them 
were released by no later than their 19TH birthday. 

[35] The Inspector General estimated that SSA did not complete 79 
percent of childhood CDRs and 10 percent of age 18 redeterminations on 
the basis of the results of 275 cases of physical and mental 
impairments they reviewed. (Social Security Administration Office of 
the Inspector General, "Follow-Up: Childhood Continuing Disability 
Reviews and Age 18 Redeterminations" (A-01-11-11118), Sept. 23, 2011.) 

[36] This estimate represents the combined savings to the SSI, 
Disability Insurance, Medicare, and Medicaid programs from CDRs 
conducted for the SSI and Disability Insurance programs, as in some 
cases eligibility for those programs confers eligibility for certain 
Medicare or Medicaid benefits, as well. 

[37] Personality disorders are manifested by pervasive, inflexible, 
and maladaptive personality traits, which are typical of the child's 
long-term functioning and not limited to discrete episodes of illness. 
20 C.F.R. pt. 404, subpt. P, appendix 1 

[38] In part to reduce the CDR backlog, the Obama Administration 
proposed to increase the overall number of CDRs for adults and 
children in the SSI program in fiscal year 2012. The proposed fiscal 
year 2012 budget requests $562 million for conducting, in part, SSI 
CDRs and SSI redeterminations (for child and adult recipients 
combined), an increase of $298 million over FY 2011. SSA estimates 
that if granted, this level of funding would result in almost $4.2 
billion in savings to the SSI program alone over the next 10 years. 

[39] Pub. L. No. 112-25, sec. 101, § 251(b)(2)(B), 125 Stat. 240, 243- 
44. 

[40] For purposes of this appendix, we have provided basic information 
about the 11 mental disorders for children included in SSA's listings. 
For additional information about these listings, refer to 20 C.F.R. 
pt. 404, subpt. P, appendix 1. 

[41] Although for most purposes SSA refers to intellectual 
disabilities rather than mental retardation, its medical listings have 
not been updated to reflect this change. 

[42] See 20 C.F.R. §§ 416.926 and 416.926a. 

[End of section] 

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