	Background

SSA administers two of the largest disability programs: the Disability  Insurance (DI) program, enacted in 1956, and the Supplemental Security  Income (SSI) program, enacted in 1972. 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. 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. 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have reported that the DOT,  which SSA still relies on to assess eligibility at steps 4 and 5 of the  process, is outdated.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  Occupational Information Network (O*NET).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. 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. 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. Previously, SSA set expiration dates for periodically updating  listings according to each body system, ranging from 3 to 8 years, but  frequently extended them. For  example, SSA contracted with the Institute of Medicine to study its  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 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 Delays with Its Revision Process

SSA continues to face delays in completing both comprehensive and  other ongoing updates. For example, as of early March 2012, SSA  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). SSA Has Begun an Ambitious Project to Develop Its Own Source of Occupational Information

		SSA is in the Preliminary Stage of Developing a New Up-to-Date Source of Occupational Information

In 2008, SSA began a multiyear project to develop a new source of  occupational information that will replace the outdated information  currently being used to determine if claimants are able to do their past  work or any other work in the national economy. SSA also plans to develop a strategy for piloting data  collection nationwide within this time frame. SSA Has Made Progress on Its OIS, but It Is Too Soon to Know if Project Timelines Will be Met

As of February 2012, SSA had made progress on many of the baseline  activities outlined in its research and development plan for the OIS. 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. 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. 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.
Why GAO Did This Study

SSA administers two of the largest disability programs, with annual benefit payments that have grown fivefold over the last 20 yearsfrom $35 billion in 1990 to over $164 billion in 2010and the agency receives millions of new applications annually. GAO has designated federal disability programs as a high-risk area, in part because eligibility criteria have not been updated to reflect medical and technological advances and labor market changes. Given the size and cost of its disability programs, SSA needs updated criteria to appropriately determine who qualifies for benefits.
In this statement, GAO discusses initial observations from its ongoing review and assessment of SSAs efforts to (1) update its medical criteria and (2) develop a new occupational information system. To do this, GAO reviewed prior GAO and SSA Inspector General reports; relevant federal laws and regulations; program documentation including policies, procedures, strategic goals, and supporting project plans; and cost estimates. GAO also interviewed SSA officials, project stakeholders, experts, and representatives from other agencies that administer disability programs. This work is ongoing and GAO has no recommendations at this time. GAO plans to issue its final report later in 2012.

What GAO Found

The Social Security Administration (SSA) has made several changes to improve the process it uses for updating its medical criteria, but continues to face challenges ensuring timely updates. SSAs medical criteria for adults are in the form of listings of medical conditions and impairments organized under 14 body systems, which SSA periodically updates. To help ensure timely, periodic updates of a body systems listings, SSA is moving away from comprehensively revising a body systems listings toward a more targeted approach, wherein SSA selects for revision those impairment listings most in need of change. To date, SSA has completed comprehensive revisions of listings for 8 of the 14 body systems and now is in the process of reviewing them to determine whether and which targeted revisions are appropriate. In 2010, the SSA Commissioner set a 5-year cycle time for updating listings for each body system, replacing the agencys prior practice of setting expiration dates for listings that ranged from 3 to 8 years and then frequently extending them. To further increase the timeliness and accuracy of decisions, SSA has sought recommendations from the Institute of Medicine and has acted on some of them, such as creating a standing committee to provide advice on updating the listings. However, SSA continues to 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 been ongoing for 19 to 33 years. SSA staff told us that a lack of staff and expertise, along with the complexity and unpredictability of the regulatory process, have made it challenging to maintain its schedule of periodic updates for all listings.
SSA has embarked on an ambitious plan to produce by 2016 an occupational inventory database to support its disability benefit decisions, but it is too soon to determine if SSA will meet key time frames. SSA currently relies on an occupational information source developed by the Department of Labor that was updated for the last time in 1991 and is viewed by many as outdated. In 2008, SSA initiated a project to develop its own occupational information system (OIS), which SSA expects will provide up-to-date information on the physical and mental demands of work, and in sufficient detail to support its disability benefit decisions. To guide the creation of its OIS, SSA established an advisory panel, collaborated with outside experts and other agencies, and in July 2011 issued a research and development plan detailing all relevant activities and goals between 2010 and 2016. As of February 2012, SSA had completed many initial research efforts, including investigating other types of occupational information systems and identifying job analysis methods. Despite preliminary progress, it is too early to determine if SSA will meet its target implementation date. SSA officials told us 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 SSAs schedule and cost estimates against best practices, we have preliminarily identified some potential gaps in SSAs approach, such as not reflecting the costs to both implement and maintain a new OIS.