In 2003, we deemed SSA’s and other federal disability programs as  high-risk areas, in part, because their programs continue to emphasize  medical conditions in assessing work capacity, without adequate  consideration of work opportunities afforded by advances in medicine,  technology, and changes in the labor market. The DOT has not had a major update since 1977 the Department of Labor (Labor) replaced it with a new database in 1998  called the Occupational Information Network (O*NET). However, SSA  determined that O*NET is not sufficiently detailed for evaluating DI and  SSI disability claims, so SSA has begun developing its own occupational  information system to better reflect the physical and mental demands of  work in the national economy. First, the agency is  using a two-tiered system for ongoing revisions to the listings. Under this  system, SSA first completes a comprehensive listings update for a body  system, which entails reviewing all the diseases and disorders listed  within that system and making necessary revisions. As of early March 2012, SSA had begun the ongoing  review process to identify opportunities for targeted revisions for 8 of the  14 adult body systems that were recently comprehensively revised. 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 Experienced Delays with Its Revision Process

SSA has made progress, but continues to face delays in completing both  comprehensive and ongoing targeted updates. SSA Has Begun an Ambitious Project to Develop Updated Occupational Information, but Many Uncertainties Remain

		SSA is Designing a New Occupational Information System, but Has Fallen behind with Some Activities

In 2008, SSA began a multiyear project to research and design a new  source of occupational information that will replace the outdated  information currently being used to determine if claimants are able to do  their past work or any other work in the national economy.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 officials told us that they did not have enough staffing  to complete all of the 2012 planned activities within the estimated  schedule. We compared SSA’s cost estimate to three best practices for assuring a  reliable cost estimate and found SSA only minimally or partially met  each of these (see table 3). Other federal information systems provide some  basis for estimating the cost of producing or maintaining an OIS. SSA Has Taken Other Steps to Modernize Criteria but Faces Limitations

		SSA Has Taken Steps to Incorporate Modern Concepts of Disability into Eligibility Criteria

Although SSA’s adult disability programs were initially built upon the  assumption that certain severe medical conditions equate to work  incapacity, through its medical listings updates and ongoing research, SSA  has taken steps to modify its eligibility criteria. Updates to the medical listings have been one vehicle through which SSA  can include an assessment of an individual’s functional abilities to  determine whether an impairment prevents work. SSA Faces Constraints to Incorporating Modern Concepts

Consistent with modern views of disability, a key consideration in  assessing disability is that the environment can hinder or enhance an  individual’s ability to function. To achieve the goal of updating listings for each body system within  SSA’s 5-year time frame, we recommend that the Commissioner of  Social Security explicitly identify the resources needed to achieve this  goal, such as staff, contractors, and technology aids, and its plans to  overcome any resource limitations. 2. To ensure that its work to revise occupational information is feasible  and cost effective, and to improve its chance for success, we  recommend that the Commissioner of Social Security: formally assess risks to the success of the OIS—addressing such  challenges as related to controlling cost, acquiring expertise,  managing project complexity, and coordinating with ongoing and  related SSA research—and develop appropriate mitigation  strategies, and develop a comprehensive and reliable cost estimate and schedule  for the life cycle of the project, in accordance with best practices. SSA also  provided written comments, which are reproduced in appendix V.
SSA agreed with the first two recommendations and disagreed with the  third recommendation that the agency should conduct limited and focused  studies on the availability and effects of considering more fully assistive  devices and workplace accommodations in its disability determinations. SSA stated that conducting such studies is inconsistent with Congress’  intentions. SSA asserts that because Congress has made no  effort to change the balance between its disability programs and the ADA  in the past 22 years, it would be inappropriate for SSA to spend its limited  administrative resources on “an initiative that would undermine the  balance Congress chose to strike.”
Notwithstanding SSA’s response, we continue to believe that SSA should  conduct limited and focused studies on the availability and effects of  considering more fully assistive devices and workplace accommodations  in its disability determination process. Specifically, we examined  the status and management of efforts to update its medical listings to  reflect current medical knowledge and develop a new occupational  information system (OIS) to reflect labor market changes, and we  identified other steps taken by SSA to incorporate a modern view of  disability into its eligibility criteria.
Why GAO Did This Study

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

What GAO Found

The Social Security Administration (SSA) has taken steps that hold promise for improving the process for updating its medical criteria, but continues to face challenges ensuring timely updates. SSA now uses a two-tiered system for ongoing revisions to its medical listings. First, it completes a comprehensive review of all medical conditions listed within each of 14 body systems, making needed revisions. For subsequent updates for a body system, the agency uses a targeted approach, selecting for review and revision only those medical conditions most in need of change. To date, SSA has completed comprehensive revisions for 8 of the 14 body systems and now is reviewing conditions under them to determine where targeted revisions are appropriate. However, some of these targeted revisions have experienced delays. Moreover, SSA has yet to complete comprehensive revisions for six body systems that have been ongoing for 19 to 33 years. SSA officials attributed delays to a lack of staff and expertise, along with the complexity and unpredictability of the regulatory process.
SSA has embarked on an ambitious plan to design by 2016 an occupational information system for use in its disability decision-making process, but has fallen short of best practices for estimating costs, maintaining a schedule, and considering risks and alternatives. SSA currently relies on occupational information developed by the Department of Labor which has not had a major update since 1977. In 2008, SSA initiated a project to develop its own occupational information system (OIS), which SSA expects will provide up-to-date information on the physical and mental demands of work to support its decision-making process. To guide the creation of its OIS, SSA established an advisory panel, collaborated with outside experts and other agencies, and in July 2011 issued a research and development plan detailing relevant activities through 2016. SSA has made progress on some baseline activities in the plan. However, SSAs cost estimate and schedule had key deficiencies, such as not including any estimate of the cost of producing, maintaining, and operating the system, which can inform design options. SSA also did not adequately consider inherent risks or potential alternatives, which could heighten the risk of additional costs or project failure.
Consistent with modern views of disability, SSA has taken some concrete steps toward greater consideration of an individuals ability to function with a disability but faces constraints in fully modernizing. SSA has incorporated some criteria into its medical listings to determine whether a claimants impairments result in functional limitations that can prohibit the ability to work. SSA is also sponsoring research through the National Institutes of Health to evaluate how functional abilities can further be considered in determining disability. One project aims to develop a computerized tool to assist adjudicators in evaluating how various impairments affect an individuals function and ability to work. However, SSA officials maintain that other modern concepts of disability cannot be fully incorporated into SSAs disability decisions. Specifically, SSA faces constraints considering the extent to which assistive devices and workplace accommodations can mitigate work disability, because these are not universally available and SSA lacks the resources to conduct individualized assessments.

What GAO Recommends

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