News & Information

CCH® UNEMPLOYMENT INSURANCE — 10/05/12

GAO: Problems and challenges exist related to modernizing the SSA disability programs

Recent testimony by Daniel Bertoni, Director of Education, Workforce, and Income Security Issues at the Government Accountability Office (GAO), focused on the future of the Social Security disability programs.

Background

The Social Security Administration (SSA) manages two of the largest federal disability benefit programs—Social Security Disability Insurance (DI) and Supplemental Security Income (SSI)—which provided more than $178 billion in payments to about 14.5 million people with disabilities and their families in fiscal year 2011. Given the extensive size and cost of its disability programs, the SSA must have current and appropriate criteria by which to assess whether a claimant's medical conditions affect his or her ability to perform work in the national economy. However, in previous reports, the GAO designated federal disability programs as high risk, in part because the programs do not reflect a modern concept of disability. Specifically, the GAO noted that the SSA's disability programs emphasize medical conditions in assessing work incapacity without adequate consideration of the work opportunities afforded by advances in medicine, technology, and job demands. In addition, the agency found that the medical criteria and occupational information the SSA uses to make disability benefit decisions were out of date. In contrast, modern concepts of disability take into account the interaction of health conditions and contextual factors—such as products, technology, attitudes, and services—on an individual's functional capacity, rather than viewing disability solely as a medical or biological issue. Such concepts also focus on an individual's functional abilities in, for example, the workplace environment, taking into consideration the presence or lack of assistance. Experts also have noted that the SSA's process should give more consideration to an individual's ability to function with an impairment, and whether the individual can work if given appropriate supports.

Concrete steps taken, constraints exist going forward

The GAO found that the SSA has taken concrete steps to incorporate modern concepts of disability into its determination criteria, but faces constraints to more fully considering assistive devices and workplace accommodations.

Giving greater consideration to a claimant's functional capacity. The SSA has begun taking a more modern view of disability that looks beyond the claimant's medical condition by giving greater consideration to his or her functional capacity, consistent with the International Classification of Functioning, Disability and Health (ICF) framework. In updates to some of its medical criteria, the agency has included an assessment of an individual's functional abilities to determine whether his or her impairment prevents work. For example, as part of the SSA's comprehensive revision to the medical listings for the immune system, the agency included several functional criteria, such as performing activities of daily living, maintaining social functioning, and completing tasks in a timely manner despite deficiencies in concentration or persistence.

Generally, SSA officials, adjudicators, and disability experts the GAO spoke with support incorporating appropriate functional criteria into the medical listings to facilitate a more reliable assessment of an individual's ability to work. However, some also have noted that including functional criteria may result in a more subjective assessment by adjudicators because functional evidence is inherently more subjective than medical evidence, which in turn could increase the difficulty of making consistent disability determinations.

Sponsoring research on functional capacity and disability determinations. Since 2008, the SSA has had an interagency agreement with the National Institutes of Health (NIH) to conduct short- and long-term research to assist the agency's efforts to incorporate functional information into its disability criteria. For example, the SSA is sponsoring longer-term NIH research to develop a computer-based tool to rapidly and reliably assess the functional abilities of individual claimants for disability determinations. SSA and NIH officials anticipate several benefits from the functional assessment tool, such as providing more consistent and comprehensive information on the impact of functional limitations earlier in the disability determination process. This information may help adjudicators more quickly, accurately, and uniformly assess whether a person can perform certain kinds of work given his or her functional and occupational capabilities. While this research is promising, SSA officials said they have not yet determined when or how the tool will be integrated into the disability determination process. The officials said they expect to pilot the functional assessment tool by 2016.

Modern concepts not fully incorporated into determinations

Although these steps are promising, the SSA has not fully incorporated other modern concepts of disability into its disability determinations. A modern view of disability takes into account factors that can hinder or enhance an individual's ability to function, such as assistive devices or accommodations that can mitigate barriers. Although giving broad consideration of assistive devices and workplace accommodations may be difficult to incorporate into the current disability criteria and process, the SSA may be missing opportunities to move further in that direction. By conducting studies on this issue, the SSA would be in a better position to thoughtfully weigh the costs and benefits of the various policy options before deciding on an appropriate course of action.

Conclusions

The SSA has taken important steps toward modernizing its disability criteria by sponsoring promising research that may lead the agency to increase its consideration of functional ability in its medical listings and other aspects of its disability decisionmaking process. However, consistent with a modern view of disability, the SSA can do more—through its various research and contract arrangements—to better determine whether and how commonly available assistive devices and workforce accommodations might be incorporated into its disability criteria. The SSA and others have raised valid concerns about the universal availability of assistive devices and accommodations. However, without such efforts to study how certain assistive devices and accommodations are playing a role in helping individuals with impairments stay at work or return to work, and their costs in comparison to potentially providing years of disability benefit payments, the SSA may be missing an opportunity to assist individuals with disabilities to reengage in the workforce. It also may be missing an opportunity to target finite resources efficiently and effectively.

For more information, contact Daniel Bertoni at 202-512-7215 or bertonid@gao.gov (GAO-12-891T, September 14, 2012).