	Background

The Social Security Administration (SSA) administers two programs under  the Social Security Act that provide benefits to people with disabilities: (1)  Disability Insurance (DI) and (2) Supplemental Security Income (SSI). There was no statutory requirement for SSA to show that a beneficiary had  improved medically in order to remove him or her from the programs. More beneficiaries leave the disability programs because  they either die or convert to social security retirement benefits. In  addition, while full medical CDRs are the agency’s most comprehensive  tool for determining whether a beneficiary continues to have a disability,  about 2.8 percent of those who receive these CDRs are found to no longer  have a disability under the medical improvement standard. Of  the individuals removed from the programs as a result of receiving a CDR  between fiscal years 1999 and 2005, an average of about 13,800 individuals  (or 2.8 percent of all CDRs conducted between fiscal years 1999 and 2005)  were removed annually because SSA determined that they had improved  medically, while an average of about 10,300 individuals (or about 2.1  percent) were removed each year for failure to cooperate. Several Factors Challenge SSA’s Ability to Assess Whether Beneficiaries Continue to Be Eligible for Benefits

Our review suggests that several factors associated with the standard pose  challenges for SSA’s ability to assess whether beneficiaries continue to be  eligible for benefits. First, limitations in SSA guidance may result in  inconsistent application of the standard. For example, we found that SSA  does not clearly define the degree of improvement needed to meet the  standard, and the DDS directors we surveyed reported using different  thresholds to show medical improvement. Second, we found that most DDSs are incorrectly conducting  CDRs with the presumption that a beneficiary has a disability. Limitations in SSA Guidance for Applying the Medical Improvement Standard May Result in Inconsistent Disability Decisions

Our work shows that SSA does not clearly define the degree of  improvement needed for examiners to determine if a beneficiary has  improved medically. The DDS directors we surveyed reported that they  interpret this guidance differently. While these problems raise concerns about the consistency of  decisions when determining if medical improvement has occurred, the  ultimate impact of presuming that an individual has a disability on CDR  decisions is unknown because we were unable to empirically test how the  presumption of a disability impacts CDR decisions to continue or  discontinue benefits. Other factors, including inadequate  documentation of evidence, are more difficult to address in the short term. The purpose of this survey was to assess  the extent to which the standard impacts outcomes of CDRs and  determine if the standard poses any special challenges for SSA when  determining whether beneficiaries continue to be eligible for benefits.
Why GAO Did This Study

The Social Security Act requires that the Social Security Administration (SSA) find an improvement in a beneficiary's medical condition in order to remove him or her from either the Disability Insurance (DI) or Supplemental Security Income (SSI) programs. GAO was asked to (1) examine the proportion of beneficiaries who have improved medically and (2) determine if factors associated with the standard pose challenges for SSA when determining whether beneficiaries continue to be eligible for benefits. To answer these questions, GAO surveyed all 55 Disability Determination Services (DDS) directors, interviewed SSA officials, and reviewed pertinent SSA data.

What GAO Found

Each year, about 13,800 beneficiaries, or 1.4 percent of all the people who left the disability programs between fiscal years 1999 and 2005, did so because SSA found that they had improved medically. More beneficiaries leave because they convert to regular retirement benefits, die, or for other reasons--including having earnings above program limits. In addition, while continuing disability reviews (CDR) are SSA's most comprehensive tool for determining whether a recipient continues to have a disability, on average, 2.8 percent of beneficiaries were found to have improved medically and to be able to work following a CDR during this 7-year period. Several factors associated with the medical improvement standard (the standard) pose challenges for SSA when assessing whether beneficiaries continue to be eligible for benefits. First, limitations in SSA guidance may result in inconsistent application of the standard. For example, SSA does not clearly define the degree of improvement needed to meet the standard, and the DDS directors GAO surveyed reported that they use different thresholds to assess if medical improvement has occurred. Second, contrary to existing policy, disability examiners in a majority of the DDSs are incorrectly conducting CDRs with the presumption that a beneficiary has a disability rather than with a "neutral" perspective. Other challenges associated with the standard include inadequate documentation of evidence as well as the judgmental nature of medical improvement determinations. All these factors have implications for the consistency of CDR decisions. However, due to data limitations, GAO was unable to determine the extent to which these problems affect decisions to continue or discontinue benefits.