oversight

Modernizing SSA Disability Programs: Preliminary Observations on Updates of Medical and Occupational Criteria

Published by the Government Accountability Office on 2012-03-20.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                             United States Government Accountability Office

GAO                          Testimony
                             Before the Subcommittee on Social
                             Security, Committee on Ways and Means,
                             House of Representatives

                             MODERNIZING SSA
For Release on Delivery
Expected at 10:30 a.m. EDT
Tuesday, March 20, 2012

                             DISABILITY PROGRAMS
                             Preliminary Observations
                             on Updates of Medical and
                             Occupational Criteria
                             Statement of Daniel Bertoni, Director
                             Education, Workforce, and Income Security




GAO-12-511T
                                                March 20, 2012

                                                MODERNIZING SSA DISABILITY PROGRAMS
                                                Preliminary Observations on Updates to Medical and
                                                Occupational Criteria
Highlights of GAO-12-511T, a testimony to the
Subcommittee on Social Security, Committee
on Ways and Means, House of
Representatives



Why GAO Prepared This                           What GAO Found
Testimony                                       The Social Security Administration (SSA) has made several changes to improve
SSA administers two of the largest              the process it uses for updating its medical criteria, but continues to face
disability programs, with annual                challenges ensuring timely updates. SSA’s medical criteria for adults are in the
benefit payments that have grown                form of listings of medical conditions and impairments organized under 14 body
fivefold over the last 20 years—from            systems, which SSA periodically updates. To help ensure timely, periodic
$35 billion in 1990 to over $164                updates of a body system’s listings, SSA is moving away from comprehensively
billion in 2010—and the agency                  revising a body system’s listings toward a more targeted approach, wherein SSA
receives millions of new applications           selects for revision those impairment listings most in need of change. To date,
annually. GAO has designated                    SSA has completed comprehensive revisions of listings for 8 of the 14 body
federal disability programs as a high-          systems and now is in the process of reviewing them to determine whether and
risk area, in part because eligibility          which targeted revisions are appropriate. In 2010, the SSA Commissioner set a
criteria have not been updated to               5-year cycle time for updating listings for each body system, replacing the
reflect medical and technological               agency’s prior practice of setting expiration dates for listings that ranged from 3
advances and labor market changes.              to 8 years and then frequently extending them. To further increase the timeliness
Given the size and cost of its                  and accuracy of decisions, SSA has sought recommendations from the Institute
disability programs, SSA needs                  of Medicine and has acted on some of them, such as creating a standing
updated criteria to appropriately               committee to provide advice on updating the listings. However, SSA continues to
determine who qualifies for benefits.           face challenges keeping its listings up to date. For example, SSA is still working
                                                on completing comprehensive revisions of listings for six body systems that have
In this statement, GAO discusses                been ongoing for 19 to 33 years. SSA staff told us that a lack of staff and
initial observations from its ongoing           expertise, along with the complexity and unpredictability of the regulatory
review and assessment of SSA’s                  process, have made it challenging to maintain its schedule of periodic updates
efforts to (1) update its medical               for all listings.
criteria and (2) develop a new
occupational information system. To             SSA has embarked on an ambitious plan to produce by 2016 an occupational
do this, GAO reviewed prior GAO                 inventory database to support its disability benefit decisions, but it is too soon to
and SSA Inspector General reports;              determine if SSA will meet key time frames. SSA currently relies on an
relevant federal laws and                       occupational information source developed by the Department of Labor that was
regulations; program documentation              updated for the last time in 1991 and is viewed by many as outdated. In 2008,
including policies, procedures,                 SSA initiated a project to develop its own occupational information system (OIS),
strategic goals, and supporting                 which SSA expects will provide up-to-date information on the physical and
project plans; and cost estimates.              mental demands of work, and in sufficient detail to support its disability benefit
GAO also interviewed SSA officials,             decisions. To guide the creation of its OIS, SSA established an advisory panel,
project stakeholders, experts, and              collaborated with outside experts and other agencies, and in July 2011 issued a
representatives from other agencies             research and development plan detailing all relevant activities and goals between
that administer disability programs.            2010 and 2016. As of February 2012, SSA had completed many initial research
This work is ongoing and GAO has                efforts, including investigating other types of occupational information systems
no recommendations at this time.                and identifying job analysis methods. Despite preliminary progress, it is too early
GAO plans to issue its final report             to determine if SSA will meet its target implementation date. SSA officials told us
later in 2012.                                  that due to staffing shortages it did not meet all initial goals on time and may
                                                need to adjust its time frames for future activities. While GAO is still evaluating
                                                SSA’s schedule and cost estimates against best practices, we have preliminarily
                                                identified some potential gaps in SSA’s approach, such as not reflecting the
                                                costs to both implement and maintain a new OIS.
View GAO-12-511T. For more information,
contact Daniel Bertoni at (202) 512-7215 or
bertonid@gao.gov.

                                                                                         United States Government Accountability Office
Chairman Johnson, Ranking Member Becerra, and Members of the
Subcommittee:

I am pleased to be here today to discuss our preliminary observations on
efforts by the Social Security Administration (SSA) to modernize its
disability criteria. In the last 20 years, SSA disability benefit payments to
beneficiaries and their dependents have increased almost fivefold, from
$35 billion in 1990 to over $164 billion in 2010. The number of working-
age beneficiaries also grew from about 9 million in 2000 to almost 12
million in 2010, and, as more baby boomers enter their disability-prone
years, SSA expects the number of claims to grow. 1 Given the extensive
size and cost of its disability programs, SSA must have current and
appropriate criteria by which to assess whether an applicant’s medical
conditions affect his or her ability to perform work in the national
economy. GAO has designated SSA’s federal disability program as a
high-risk area; in 2008, we reported that the agency’s medical criteria did
not fully reflect medical and technological advances, and the occupational
criteria it used from the Department of Labor (Labor) had not been
updated since 1991, despite the trend away from manual labor jobs and
towards service- and knowledge-based jobs.

My statement today focuses on initial observations from our ongoing
review for this subcommittee and examines the status and management
of SSA’s efforts to (1) update its medical listings to reflect current medical
knowledge and (2) develop its own occupational information system (OIS)
to reflect labor market changes. To examine these issues we reviewed
prior GAO and SSA Office of Inspector General reports; relevant federal
laws and regulations; program documentation including policies,
procedures, strategic goals, and supporting project plans and cost
estimates; and position papers and testimonies from disability groups and
commissions. We interviewed SSA officials, key project contractors and
stakeholders, disability experts, and representatives of other agencies
that administer disability programs. In our ongoing work, we will further
evaluate SSA’s plan to develop its own OIS against best practices for
cost estimating and scheduling. We will also review more broadly other
steps SSA is taking to incorporate modern concepts of disability into its
programs. We plan to issue our final report later in 2012 in accordance



1
 In fiscal year 2010, SSA received 6.3 million benefit claims from either workers with
disabilities or their dependents, up from 3.1 million in 2000.




Page 1                                                                         GAO-12-511T
             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
             provides a reasonable basis for our findings and conclusions based on
             our audit objectives.


             SSA administers two of the largest disability programs: the Disability
Background   Insurance (DI) program, enacted in 1956, and the Supplemental Security
             Income (SSI) program, enacted in 1972. 2 In order to be eligible for DI or
             SSI benefits based on a disability, an individual must meet the definition
             of disability for these programs—that is, they must have a medically
             determinable physical or mental impairment that (1) prevents the
             individual from engaging in any substantial gainful activity, and (2) has
             lasted or is expected to last at least one year or result in death. 3

             To determine eligibility, SSA uses a five-step sequential process that is
             intended, in part, to expedite disability decisions when possible and limit
             administrative costs by conducting less intensive assessments at earlier
             steps (see fig. 1). 4 At steps 1 and 2 of the process, SSA determines
             whether an applicant is working and meets income thresholds as well as
             the medical severity of impairments. If so, the applicant moves to step 3
             of the process. At this step, SSA examiners assess the applicant’s
             medical impairment(s) against the Listings of Impairments, also known as
             the medical listings, which are organized into 14 major body systems for
             adults and reflect medical conditions that have been determined by the
             agency to be severe enough to qualify an applicant for benefits. 5 If the
             individual’s impairment meets or is equal in severity to one or more of


             2
              The DI program provides monthly cash benefits to eligible applicants who have a
             sufficient work record. The SSI program provides monthly benefits to eligible applicants
             with limited income and resources who are disabled, blind, or age 65 or older.
             3
              42 U.S.C. §§ 423(d)(1)(A) and 1382c(a)(3)(A). Substantial gainful activity is generally
             work activity involving significant physical or mental activities that are done for pay or
             profit, whether or not a profit is realized. 20 C.F.R. §§ 404.1572 and 416.972. In 2012, the
             substantial gainful activity threshold is $1,690 per month for blind recipients and $1,010
             per month for individuals with other disabilities.

             See 20 C.F.R. §§ 404.1520 and 416.920.
             4


             5
              According to agency officials, there are almost 300 medical impairments organized in 119
             listings under the 14 major body systems for adults.




             Page 2                                                                         GAO-12-511T
                                         those in the listings, the individual is determined to have a disability. If
                                         not, SSA performs an assessment of the individual’s physical and mental
                                         residual functional capacity. 6 Based on this assessment, SSA determines
                                         whether the individual is able to perform past relevant work (step 4) or
                                         any work that is performed in the national economy (step 5). To inform
                                         determinations at steps 4 and 5, SSA uses a Department of Labor
                                         database—known as the Dictionary of Occupational Titles (DOT)—for an
                                         inventory of occupations performed in the national economy.

Figure 1: SSA’s Five-Step Sequential Evaluation Process for Determining Disability




                                         6
                                          SSA’s physical and mental residual functional capacity assessments establish the extent
                                         to which an individual’s medically determinable impairment(s), including any related
                                         symptoms, such as pain, may cause physical or mental limitations or restrictions that may
                                         affect his or her capacity to do work-related physical and mental activities.




                                         Page 3                                                                       GAO-12-511T
Since 2003, SSA’s and other federal disability programs have remained
on our high-risk list, in part, because their programs emphasize medical
conditions in assessing work capacity without adequate consideration of
work opportunities afforded by advances in medicine, technology, and job
demands. Since the 1990s, we, along with SSA’s Office of Inspector
General and the Social Security Advisory Board, have expressed
concerns that the medical listings being used no longer provide sufficient
criteria to evaluate disability applicants’ inability to work and that SSA was
simply extending the listings instead of periodically updating them. In
2008, we reported that SSA had established a new process for revising
the listings—referred to by SSA as the “business process”—to better
incorporate feedback into its continuous updates. 7 This process, which
has been in effect since 2003, includes incorporating feedback from
multiple parties, including medical experts and claims examiners, to
update their medical criteria. SSA should also gather external feedback
through comments associated with regulatory actions, such as the
publication of advanced notices of proposed rulemaking (advanced
notices) and notices of proposed rulemaking (notices) in the Federal
Register. 8 In addition, one year after a revision is made, SSA should
conduct a study reviewing the changes. According to SSA
documentation, this internal case study, now referred to as the
postimplementation study, should involve surveying the field regarding
the results of the regulation and areas to improve, as well as reviewing
the data to determine whether expectations from the revision have been
proven.

With respect to information on jobs in the national economy that supports
SSA’s occupational criteria, we and others have reported that the DOT,
which SSA still relies on to assess eligibility at steps 4 and 5 of the
process, is outdated. The DOT has not been updated since 1991, and
Labor has since replaced the DOT with a new database called the




GAO, Federal Disability Programs: More Strategic Coordination Could Help Overcome
7

Challenges to Needed Transformation, GAO-08-635 (Washington, D.C.: May 20, 2008).
8
 Any changes to the medical listings have to proceed according to an established process
for rulemaking outlined in federal law. As such, when changes are made to the listings, a
notice of proposed rulemaking must generally be published in the Federal Register with a
public comment period before the final rule is issued. 5 U.S.C. § 553.




Page 4                                                                       GAO-12-511T
                             Occupational Information Network (O*NET). 9 However, SSA has
                             determined that O*NET is not sufficiently detailed for evaluating DI and
                             SSI disability claims and therefore has begun developing its own OIS in
                             order to better reflect the physical and mental demands of work in the
                             national economy.



SSA Has Improved Its
Process for Updating
Medical Listings, but
Faces Challenges
Completing Updates

SSA Has Improved Its         Since our last review in 2008, SSA has made several changes that hold
Strategy to Update Medical   promise for improving medical listings updates. First, the agency is using
Listings                     a two-tiered system for ongoing revisions to the listings. Under this
                             system, SSA first completes a comprehensive listings update for a body
                             system that reviews all the diseases and disorders listed within that
                             system and makes revisions it determines are needed. For subsequent
                             updates of listings for a body system that underwent a comprehensive
                             revision, SSA will pursue a more targeted approach—that is, SSA will
                             conduct ongoing reviews with the expectation of making targeted
                             revisions for a small number of medical diseases or disorders that need to
                             be updated. Agency officials told us that targeted updates should be
                             completed more quickly than comprehensive updates, allowing them to
                             focus on the most critical changes needed. However, officials also noted
                             that these ongoing reviews could result in major or even no changes, as
                             appropriate. As of early March 2012, SSA had begun the ongoing review
                             process to consider opportunities for targeted revisions for 8 out of 14
                             adult body systems that were recently comprehensively revised. Also as
                             of early March 2012, the agency had not yet completed comprehensive
                             revisions for the six remaining systems, which the agency expects to do
                             before they conduct subsequent reviews under the targeted approach.



                             9
                              Labor launched O*NET, a general purpose occupational information database used for
                             workforce development, economic development, career exploration, academic and policy
                             research, in 1998.




                             Page 5                                                                   GAO-12-511T
Another change, according to agency officials, is that in 2010 the SSA
Commissioner set a 5-year cycle time for updating listings for each body
system. 10 Previously, SSA set expiration dates for periodically updating
listings according to each body system, ranging from 3 to 8 years, but
frequently extended them. SSA officials believe that conducting targeted
reviews will generally allow the agency to conclude any necessary
revisions prior to the 5-year expiration period. Additionally, they expect
that using the “business process,” which requires early public notification
of changes and obtaining necessary data and feedback from internal and
external parties, should help keep continuous reviews on track. See figure
2 for the status and expiration dates of listings for the 14 adult body
systems, undergoing review for either comprehensive or possible
targeted revisions, as of early March 2012.




 The 5-year expiration period will be applied to listings under a body system upon
10

completion of their current revision. SSA began applying the 5-year expiration period in
2011 when it comprehensively updated the endocrine body system listings. For other body
systems listings updated prior to 2011, SSA generally assigned expiration periods
extending beyond 5 years.




Page 6                                                                     GAO-12-511T
Figure 2: Status of Revisions for SSA’s Adult Body System Listings




a
 For the two-tiered revision process, the beginning point is the date of the last comprehensive or
targeted revision.
b
 SSA officials told us they have grouped the disorders in the special senses and speech listings into
two broad sections—vision and hearing—and two standalone medical conditions. SSA has not yet
comprehensively revised the two standalone medical conditions that cover speech and disturbances
of labyrinthine-vestibular function. The two sections have undergone comprehensive revisions and
are undergoing reviews that began in 2007 for the vision section and in 2010 for the hearing section.
Special senses and speech listings are set to expire in 2015.
c
 SSA published limited revisions for the hematological disorders listings in 1988, the mental disorders
listings in 2000, and the musculoskeletal system listings in 2002.


SSA has made another change by more extensively engaging the
medical community to identify ways to improve the medical listings. For
example, SSA contracted with the Institute of Medicine to study its




Page 7                                                                                   GAO-12-511T
                           medical criteria for determining disability and to make recommendations
                           for improving the timeliness and accuracy of its disability decisions,
                           resulting in a 2007 report with recommendations 11 and a symposium of
                           experts in 2010. SSA has addressed some of the institute’s
                           recommendations, such as making better use of its administrative data to
                           update criteria and creating a standing committee through the institute to
                           provide recommendations for listings revisions.


SSA Has Experienced        SSA continues to face delays in completing both comprehensive and
Delays with Its Revision   other ongoing updates. For example, as of early March 2012, SSA
Process                    officials told us they still needed to complete comprehensive revisions for
                           listings of six body systems that have been ongoing for the last 19 to 33
                           years, after numerous extensions beyond the original expiration periods
                           (see table 1). Two of the remaining six body system listings—mental and
                           neurological disorders, which are among those SSA uses most frequently
                           in its eligibility determination process—have not been comprehensively
                           revised for 27 years. 12 Four of the remaining body system listings are set
                           to expire in 2012. Of these four, SSA is developing a notice of proposed
                           rulemaking for three of them and has issued a notice on the fourth.
                           However, it is unclear whether SSA will complete the revisions before
                           they are set to expire.




                            Institute of Medicine, Improving the Social Security Disability Decision Process
                           11

                           (Washington, D.C.: 2007).
                           12
                             According to SSA officials, the agency made limited, but not comprehensive, revisions to
                           the mental disorders listings in 2000.




                           Page 8                                                                        GAO-12-511T
Table 1: Key Dates for Comprehensive Revisions to Body System Listings

                                                                             Year   Years since
                                                                   comprehensive comprehensive     Current
                                                                     revision last revision last expiration
    Body system and section                                            published     publisheda       dateb
    Special senses and speechc                                              1979              33      2015
    •   Speech
    •   Disturbances of labyrinthine-vestibular
        function
    Neurological disorders                                                  1985              27      2012
    Mental disorders                                                        1985              27      2012
    Hematological disorders                                                 1985              27      2012
    Musculoskeletal system                                                  1985              27      2013
    Respiratory system                                                      1993              19      2012
Source: GAO analysis based on information provided by SSA officials.

a
  SSA published limited revisions to listings for the hematological disorders in 1988, the mental
disorders in 2000, and the musculoskeletal system in 2002.
b
  SSA has continually extended the expiration dates of the listings.
c
  The special senses and speech listings have two sections—vision and hearing—which have been
comprehensively revised.


While ongoing reviews involving SSA’s targeted approach seem to be
moving at a faster pace than the comprehensive revisions, SSA has
already extended the expiration date for its review of the cardiovascular
system. SSA may also need to extend expiration dates for listings under
two other body systems set to expire in 2012, according to agency
officials. Extensions may be needed because SSA has not yet published
the notice of proposed rulemaking for those two body system listings and
may not have time to publish these notifications, respond to comments,
and complete the final updates of the listings by their current expiration
date.

At the same time that SSA has been experiencing delays completing
timely revisions, agency officials reported challenges with other steps in
the business process. Whereas they always intended to review data at
the one year mark to determine whether expectations from a revision
were met, SSA officials told us they only began conducting these reviews
in 2010. Specifically, they completed one postimplementation study in
2011 that involved a targeted sample of 175 cases, and they are
conducting and planning to conduct two more studies at the one year
mark. While disability experts we interviewed spoke highly of SSA’s
business and targeted review processes to obtain feedback early on and
update the listings more promptly, recent delays raise questions


Page 9                                                                                       GAO-12-511T
regarding the agency’s ability to follow its current business process while
completing continuous and timely revisions for all 14 body systems.

SSA officials offered two key reasons for the delays in updating the
listings: limitations in the number and expertise of staff and the complexity
and unpredictability of the regulatory process. According to SSA officials,
revising the medical listings requires research, deliberation, testing,
regulatory review, and consensus with many stakeholders, and
consequently is difficult and time-consuming to achieve. In addition,
according to an SSA official in the Office of Medical Listings
Improvement, the office is short-staffed and some staff lack the expertise
necessary to perform this work. To address these constraints, SSA has
contracted with the Institute of Medicine to review and develop
recommendations for revising two of the body system listings. 13 However,
SSA officials told us that the agency does not currently have a plan to
renew this contract after it expires in 2012, nor use any other contractor to
address staffing shortfalls due to budget constraints. Also contributing to
delays is the time required for internal review and public comment under
the regulatory process that depends largely on the number and the
substance of comments received, according to an SSA official. For
example, SSA officials told us that the advanced notice of proposed
rulemaking to the listings of mental disorders in 2003 resulted in 500
comments, which took SSA 5 years to incorporate into a draft notice of
proposed changes for regulatory review.




13
  The institute provided recommendations for changes to the cardiovascular and the
Human Immunodeficiency Virus listings in two reports. For the reports see, Institute of
Medicine, Cardiovascular Disability: Updating the Social Security Listings (Washington,
D.C.: 2010) and HIV and Disability: Updating the Social Security Listings (Washington,
D.C.: 2010).




Page 10                                                                      GAO-12-511T
SSA Has Begun an
Ambitious Project to
Develop Its Own
Source of
Occupational
Information
SSA is in the Preliminary   In 2008, SSA began a multiyear project to develop a new source of
Stage of Developing a New   occupational information that will replace the outdated information
Up-to-Date Source of        currently being used to determine if claimants are able to do their past
                            work or any other work in the national economy. Since the 1960s, SSA
Occupational Information    has been using the DOT, which contains a list of job titles found in the
                            national economy and was last updated in 1991. 14 The DOT provides
                            SSA with descriptions of the physical demands of work—such as
                            climbing, balancing, and environmental requirements—for each of the
                            more than 12,000 occupations listed. According to SSA, these
                            descriptions have been essential to its evaluations of how much a
                            claimant can do despite his or her impairment and whether this level of
                            functioning enables the claimant to do his or her past work or any other
                            work. After its last limited update, Labor decided to replace the DOT with
                            O*NET, which has far fewer job titles compared with the DOT, but has
                            served Labor’s purposes more efficiently. According to an SSA report,
                            after investigating potential alternatives, SSA decided that O*NET and
                            other existing databases with occupational information were not
                            sufficiently detailed and able to withstand legal challenges for use in its
                            decision-making process. SSA further decided to develop its own
                            occupational information system, which would contain detailed
                            information as in the DOT, but would also include additional information,
                            such as the mental demands of work. In addition, the OIS should (1) meet
                            SSA’s legal, program, and data requirements; (2) be flexible enough to
                            incorporate changes in SSA’s policies and processes; and (3) be able to
                            be updated to reflect the evolving workplace environment.




                             The DOT provides a wide range of occupational information that could be used for job
                            14

                            placement, occupational research, career guidance, labor-market information, curriculum
                            development, and long-range job planning.




                            Page 11                                                                     GAO-12-511T
In 2008, SSA began taking several steps to guide the development of its
OIS. SSA created an internal office and working group, as well as an
Occupational Information Development Advisory Panel, comprised of
external experts in areas related to the development of occupational
information systems. 15 The advisory panel holds quarterly public meetings
and has several subcommittees that review material and make
recommendations to SSA on developing various components of the OIS.
For example, in a 2009 report, the advisory panel supported the need for
SSA to develop a new source of occupational information, rather than
adapt O*NET, and recommended the type of data SSA should collect, as
well as suggested ways to classify occupations.

To further inform its efforts, SSA has sought input from agencies or
organizations that either collect occupational information or also use the
DOT. For example, SSA officials held initial meetings with Labor and U.S.
Census Bureau officials to gain information on sampling methods used for
the O*NET, the Occupational Employment Statistics program, and
Census Bureau’s household surveys. 16 Additionally, SSA and Labor are
in the process of completing a Memorandum of Understanding that will
formalize their collaboration efforts on the new OIS. According to an SSA
official, as the OIS project progresses, SSA plans to convene ad hoc
roundtables with experts and other agency officials to explore specific
subject areas, such as sampling issues. Besides working with Labor and
Census Bureau officials, SSA officials and panel members have sought
input from other experts and current users of the DOT, such as SSA
disability adjudicators and external rehabilitation professionals, by
conducting a user needs analysis in 2009 and presenting the OIS project
at events and conferences.

In July 2011, SSA published a detailed research and development plan
outlining all activities related to researching, developing, and testing the



 The Occupational Information Development Advisory Panel was formed in December
15

2008 under the Federal Advisory Committee Act.
16
  The Occupational Employment Statistics program produces employment and wage
estimates for approximately 800 occupations. The Census Bureau’s household surveys
include (1) the American Community Survey, which is an ongoing survey that provides
annual data on demographics such as age, education, and disabilities, and (2) the Current
Population Survey , which is primarily a labor force survey, conducted every month by the
Census Bureau for the Bureau of Labor Statistics and provides data such as the national
unemployment rate.




Page 12                                                                     GAO-12-511T
                              key components of the OIS in order to implement the OIS by 2016 at an
                              estimated cost of $108 million. For example, the plan includes several
                              baseline activities to identify and study other occupational information
                              systems and various approaches for analyzing occupations that may
                              inform or could be leveraged in SSA’s OIS data collection. The plan also
                              includes activities to identify the primary occupational, functional, and
                              vocational characteristics of current beneficiaries. Other key components
                              of the plan include developing descriptions of work requirements, such as
                              the physical and mental demands for jobs, and data collection and
                              analysis strategies. SSA also plans to develop a strategy for piloting data
                              collection nationwide within this time frame.


SSA Has Made Progress on      As of February 2012, SSA had made progress on many of the baseline
Its OIS, but It Is Too Soon   activities outlined in its research and development plan for the OIS. 17 For
to Know if Project            example, according to an SSA official, its investigation of existing
                              occupational information systems, now complete, has resulted in useful
Timelines Will be Met
                              information about design issues other organizations have confronted and
                              mitigated when creating their own system. Additionally, SSA’s preliminary
                              analysis of its own administrative data identified the most frequently cited
                              occupations and functional and vocational characteristics of disability
                              applicants. SSA officials told us the agency will target the occupations
                              identified in this analysis for its pilot studies of the OIS. Also in 2011, SSA
                              completed a comprehensive framework for assessing an individual’s
                              capacity to work—key to informing the OIS content, according to SSA
                              officials—which was based on recommendations of outside experts as
                              well as SSA’s policy and program requirements.

                              While SSA has made progress on several key activities, agency officials
                              delayed 2011 completion dates for certain activities and anticipate making
                              additional changes to its timeline as a result of not meeting its staffing
                              goals for fiscal year 2011. For example, the activities that were delayed
                              by several months included finalizing reports for the baseline studies and
                              conducting a literature review that would inform how occupations might
                              be analyzed for the OIS. SSA officials told us that they would have
                              needed to have the full complement of projected 2012 staff by September
                              2011 to complete all of the 2012 planned activities within the estimated



                               Some of the activities that were part of the research and development plan were
                              17

                              completed in years prior to the plan’s issuance.




                              Page 13                                                                     GAO-12-511T
                  schedule. However, SSA officials said they did not have the budget to
                  hire new staff in September 2011. To address this challenge, SSA
                  officials hired consultants to meet some of their needs. SSA officials also
                  met with the Office of Personnel Management to explore the possibility of
                  an interagency agreement that would allow SSA to use one or two of the
                  Office of Personnel Management’s industrial organizational psychologists
                  to help on a part-time basis.

                  As part of our ongoing work, we are assessing SSA’s current OIS project
                  schedule and cost estimates against best practices, and have
                  preliminarily identified some gaps in SSA’s approach. For example, best
                  practices require cost estimates to be comprehensive and include
                  information about life cycle costs—that is, how much the project is
                  expected to cost over time. However, while SSA has estimated the cost to
                  research and develop the OIS, the estimate does not project the future
                  costs to implement or maintain the system. The cost of sustaining an OIS
                  could be significant, based on other agencies’ experiences maintaining
                  their systems for collecting national occupational information. We
                  preliminarily identified other gaps, such as lack of documentation
                  describing step by step how the cost estimate was developed so that
                  those unfamiliar with the program could understand how it was created.
                  For our final report due later in 2012, we plan to deliver more
                  comprehensive findings on how well SSA is managing the development
                  of its OIS against best practices, such as estimating costs of the OIS and
                  ensuring that the project schedule reliably estimates related activities, the
                  length of time they will take, and how they are interrelated. We will also
                  identify any mitigation strategies the agency may have to address project
                  risks, such as the risk of the agency not receiving full funding.


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


                  For further information regarding this testimony, please contact me at
Contact and       202-512-7215 or bertonid@gao.gov. In addition, contact points for our
Acknowledgments   Offices of Congressional Relations and Public Affairs may be found on
                  the last page of this statement. Individuals who made key contributions to
                  this testimony are Michele Grgich, Assistant Director, James Bennett,
                  Kate Blumenreich, Julie DeVault, Alex Galuten, Sheila McCoy, Patricia M.
                  Owens, Anjali Tekchandani, Kathleen Van Gelder, and Walter Vance.



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