Social Security Administration: Strategic Workforce Planning
Needed to Address Human Capital Challenges Facing the Disability
Determination Services (27-JAN-04, GAO-04-121).
SSA oversees and fully funds primarily state-operated DDSs that
determine whether applicants are eligible for disability
benefits. The disability examiners employed by the DDSs play a
key role in determining benefit eligibility. This report examines
(1) the challenges the DDSs face today in retaining and
recruiting examiners and enhancing their expertise; (2) the
extent to which the DDSs engage in workforce planning and
encounter obstacles in doing so; and (3) the extent to which SSA
is addressing present and future human capital challenges in the
DDSs.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-04-121
ACCNO: A09154
TITLE: Social Security Administration: Strategic Workforce
Planning Needed to Address Human Capital Challenges Facing the
Disability Determination Services
DATE: 01/27/2004
SUBJECT: Disability benefits
Eligibility determinations
Human resources utilization
Labor force
Personnel management
Persons with disabilities
Strategic planning
Employee retention
Human capital
SSA Disability Insurance Program
Supplemental Security Income Program
******************************************************************
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GAO-04-121
United States General Accounting Office
GAO
Report to the Chairman, Subcommittee
on Social Security, Committee on Ways and Means, House of Representatives
January 2004
SOCIAL SECURITY
ADMINISTRATION
Strategic Workforce Planning Needed to Address Human Capital Challenges Facing
the Disability Determination Services
GAO-04-121
Highlights of GAO-04-121, a report to the Chairman, Subcommittee on Social
Security, Committee on Ways and Means, House of Representatives
SSA oversees and fully funds primarily state-operated DDSs that determine
whether applicants are eligible for disability benefits. The disability
examiners employed by the DDSs play a key role in determining benefit
eligibility. This report examines (1) the challenges the DDSs face today
in retaining and recruiting examiners and enhancing their expertise; (2)
the extent to which the DDSs engage in workforce planning and encounter
obstacles in doing so; and (3) the extent to which SSA is addressing
present and future human capital challenges in the DDSs.
While acknowledging the difficulties SSA faces in addressing DDS human
capital issues within the federal-state context, GAO recommends that SSA
improve its workforce planning by:
o Developing a nationwide strategic workforce plan that addresses
present and future DDS human capital challenges;
o Establishing uniform minimum qualifications for examiners; and
o Working with DDSs to close gaps
between current and required examiner skills.
In its comments, SSA generally
agreed with our recommendations'
intent but said that we did not
fairly or adequately address the
many sides of DDS human capital
management issues. We continue
to believe that the report is fair and
balanced and that our scope and
methods allowed us to adequately
address these issues.
www.gao.gov/cgi-bin/getrpt?GAO-04-121.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Robert E. Robertson at (202)
512-7215 or [email protected]
January 2004
SOCIAL SECURITY ADMINISTRATION
Strategic Workforce Planning Needed to Address Human Capital Challenges Facing
the Disability Determination Services
GAO found-through its survey of 52 of the 54 Disability Determination
Service (DDS) directors and interviews with SSA officials and DDS staff-
that the DDSs face three key challenges in retaining examiners and
enhancing their expertise: High turnover: Over half of all DDS directors
surveyed said that examiner turnover was too high in their offices. We
found that examiner turnover was about twice that of federal employees
performing similar work. Nearly twothirds of all directors reported that
turnover has increased SSA's hiring and training costs and
claims-processing times. And two-thirds of all directors cited stressful
workloads and noncompetitive salaries as major factors that contributed to
turnover. Recruiting and hiring difficulties: More than three-quarters of
all DDS directors said they had difficulties over a three-year period in
recruiting and hiring examiners. Of these, more than three-quarters said
these difficulties contributed to increases in claims-processing times,
examiner caseload levels, backlogs, and turnover. More than half of all
directors reported that state-imposed compensation limits contributed to
hiring difficulties. Gaps in key skills: Nearly one-half of all DDS
directors said that at least a quarter of their examiners needed
additional training in areas critical to disability decision-making. Over
half of all directors cited factors related to high workload levels as
obstacles to examiners' receiving additional training.
Despite the workforce challenges facing them, a majority of DDSs do not
conduct long-term, comprehensive workforce planning. In prior reports, GAO
found that such planning should include key strategies for recruiting,
retaining, training, and otherwise developing a workforce capable of
meeting long-term agency goals. However, of the DDSs that engage in
longer-term workforce planning, a majority have plans that lack such key
workforce planning strategies. Directors cited numerous obstacles to
long-term workforce planning, such as lengthy state processes to approve
DDS human capital changes.
SSA's workforce efforts have not sufficiently addressed current and future
DDS human capital challenges. Federal law requires agencies to include in
their annual performance plans a description of the human capital
strategies needed to meet their strategic goals. However, GAO's review of
key SSA planning documents shows they do not include a strategic human
capital plan that addresses current and future DDS human capital needs.
Thus, SSA does not link its strategic objectives to a workforce plan that
covers the very people who are essential to accomplishing those
objectives. GAO also found that SSA has not provided human capital
assistance in a consistent manner across the DDSs and that SSA's
effectiveness in helping the DDSs negotiate human capital changes with the
states can be limited by such factors as state budget problems and
personnel rules. Finally, SSA has not used its authority to establish
uniform human capital standards, such as minimum qualifications for
examiners, which would address, on a nationwide basis, some of the DDS
challenges.
Contents
Letter
Results in Brief
Background
DDSs Face High Turnover, Recruiting and Hiring Difficulties, and
Gaps in Key Knowledge and Skill Areas
The Majority of DDSs Do Not Conduct Long-Term, Comprehensive
Workforce Planning, and DDSs Cite Numerous Obstacles to
Doing So
SSA's Workforce Efforts Have Not Sufficiently Addressed Present
and Future Human Capital Challenges in the DDSs
Conclusions
Recommendations to the Commissioner of SSA
Agency Comments and Our Evaluation
1
4 7
16
26
31 41 42 44
Appendix I: Scope and Methods 47
Survey of Disability Determination Service Offices 47
Analysis of Data from Our Survey and Other Sources 48
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges 51
Appendix III: Related GAO Reports 80
Modernizing Federal Disability Programs 80
General Human Capital Management 80
Strategic Workforce Planning 80
Organizational Transformation 81
Training and Development 82
Appendix IV: Comments from the Social Security Administration 83
GAO Comments 87
Appendix V: GAO Contacts and Staff Acknowledgments 93
GAO Contacts 93
Staff Acknowledgments 93
Tables
Table 1: Turnover Rates for DDS Examiners, VBA Examiners, SSA Employees,
and All Federal Employees
Figures
Figure 1: Percentage of DDSs by Type of Minimum Education Requirement for
New Disability Examiners 11 Figure 2: Three-Year Average Examiner Turnover
Rates for Individual DDSs (Fiscal Years 2000 to 2002) 18 Figure 3:
Distribution of Average State DDS Examiner Salaries as a Percentage of
Average VBA Examiner Salaries 22 Figure 4: Percentage of DDSs by their
Workforce Planning Time Horizons 27
Figure 5: Means and Strategies Addressing the DDS Workforces Are Largely
Absent from SSA's Strategic and Workforce Plans 32
Abbreviations
DDS Disability Determination Service
DE disability examiners
DI Disability Insurance
NGA National Governors Association
OPM Office of Personnel Management
SDM single decision-maker
SSA Social Security Administration
SSI Supplemental Security Income
VBA Veterans Benefits Administration
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
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copyright holder may be necessary if you wish to reproduce this material
separately.
United States General Accounting Office Washington, DC 20548
January 27, 2004
The Honorable E. Clay Shaw, Jr.
Chairman, Subcommittee on Social Security
Committee on Ways and Means
House of Representatives
Dear Mr. Chairman:
In 2002, the Social Security Administration's (SSA) Disability Insurance
(DI) and Supplemental Security Income (SSI) programs paid about $74.1
billion to about 8.5 million individuals with disabilities. Under the
Social
Security Act, SSA oversees and fully funds 54 primarily state-operated
Disability Determination Service (DDS) offices that determine whether
applicants are eligible for disability benefits. Key to the accuracy and
timeliness of these disability determinations are the more than 6,500
disability examiners employed by the DDSs to review medical and
vocational evidence and help decide eligibility for disability benefits.
The
critical role played by the examiners will likely increase in the future,
with
the projected dramatic growth over the next decade in the number of
applications for disability benefits as baby boomers enter their
disability
prone years.
In our prior work, we have noted that the DDSs are confronting an
impending retirement wave of skilled staff and stiff competition in the
labor market for qualified staff.1 At the same time, SSA is facing
problems
with the accuracy and timeliness of its disability determinations. Beyond
these immediate challenges, the design of SSA's disability programs
remains grounded in outmoded concepts of disability that persist despite
scientific advances and economic and social changes that have redefined
the relationship between impairments and the ability to work. Because
other federal disability programs are also not in line with the current
status of science and the labor market, we designated modernizing federal
disability programs-including SSA's DI and SSI programs-as a high-risk
1U.S. General Accounting Office, SSA Customer Service: Broad Service
Delivery Plan Needed to Address Future Challenges, GAO/T-HEHS/AIMD-00-75
(Washington, D.C.: February 10, 2000).
area in 2003.2 In September 2003, the Commissioner unveiled her vision of
a long-term strategy for improving the disability claims process to
enhance timeliness and accuracy of decisions and for testing work
incentives and opportunities aimed at helping people with disabilities
return to work.3 The success of such a fundamental reorientation of SSA's
disability determination process will depend greatly on having the staff
with the right skill mixes and areas of expertise available when and where
needed. DDS workforces will be a critical component in any future
restructuring undertaken by SSA to modernize its disability programs.
In view of the significance of human capital management in the DDSs, this
report addresses (1) the challenges the DDSs face today in retaining and
recruiting examiners and enhancing their expertise, (2) the extent to
which the DDSs engage in workforce planning and encounter obstacles in
doing so, and (3) the extent to which SSA is addressing present and future
human capital challenges in the DDSs.
To address these issues, we surveyed directors of 52 of the 54 primarily
state-operated DDSs.4 Our survey included questions about long-term
workforce planning, recruiting and hiring, compensation, training and
development, and retention of disability examiners. We also collected
human capital data from the federal DDS, which provides case-processing
assistance to state DDSs during periods of high workload demands, among
other responsibilities.
For the purposes of this report, strategic workforce planning is a
framework for decision-making that aims to ensure that an organization has
the people with the right skills, available when and where needed, to
2U.S. General Accounting Office, High-Risk Series: An Update, GAO-03-119
(Washington, D.C.: January 2003).
3Statement of the Honorable Jo Anne B. Barnhart, Commissioner, Social
Security Administration: Testimony before the Subcommittee on Social
Security of the House Committee on Ways and Means, September 25, 2003.
4The 54 DDSs include one in each state and in the District of Columbia,
Guam, and Puerto Rico, as well as a DDS for the Blind in South Carolina.
We excluded the Guam DDS and the South Carolina DDS for the Blind from the
survey, because they each employ only one person. Throughout this report,
we refer to the Puerto Rico and the District of Columbia DDSs as state
agencies.
respond to change and accomplish the agency's strategic goals.5 To be
effective, workforce planning must be fully integrated with the agency's
mission and goals and must be based on accurate and comprehensive
workforce data. While such planning can include a range of programs and
strategies, our prior work6 has found that the following strategies are
key to effective workforce planning, including
o recruiting strategies,
o retention strategies,
o training and professional development strategies,
o compensation strategies,
o performance expectation and evaluation strategies,
o employee-friendly workplace strategies,
o succession planning and strategies for maintaining expertise in the
long term, and
o contingency plans, in the event that resource levels do not meet
expectations.
In addition, we reviewed relevant documents, including SSA laws,
regulations, and procedures, and other pertinent laws. We also obtained
and analyzed human capital data from DDSs, SSA, and other federal
agencies. We interviewed disability examiners and their managers at two
DDSs to gain an in-depth understanding of the issues related to our
objectives. We also visited three SSA regional offices, interviewing
officials who are responsible for DDS management assistance and serve as
liaisons between SSA regional offices, the DDSs, and their respective
state governments. In addition, we interviewed SSA officials at
headquarters and a variety of key stakeholders such as officials of the
National Council of Disability Determination Directors, the National
Association of Disability Examiners, and staff of the Social Security
Advisory Board. We performed our work in accordance with generally
accepted government auditing standards between September 2002 and October
2003. For more details about our scope and methods, see appendix I. For a
copy of our survey, see appendix II.
5The Government Performance and Results Act established a planning time
horizon of at least five years for agency strategic plans. We have
reported that the act's strategic planning requirements provide a useful
framework for agencies to integrate their human capital strategies with
their strategic and programmatic planning. See U.S. General Accounting
Office, High-Risk Series: An Update, GAO-01-263 (Washington, D.C.: January
2001).
6GAO-01-263.
Results in Brief
DDSs face three key challenges in retaining examiners and enhancing their
expertise: (1) high turnover, (2) recruiting and hiring difficulties, and
(3) gaps in key knowledge and skills:
o High turnover. Results from GAO's survey of 52 DDSs show that over
half of all DDS directors surveyed said that examiner turnover was too
high in their offices. We also found that examiner turnover was about
twice that of federal employees performing similar work. Nearly twothirds
of all directors reported that turnover has increased SSA's hiring and
training costs, decreased overall staff skill levels, and increased
claims-processing times. In addition, two-thirds of all DDS directors
cited stressful workloads and noncompetitive salaries as major factors
that contributed to turnover.
o Recruiting and hiring difficulties. More than three-quarters of all
DDS directors (43) reported experiencing difficulties over a three-year
period in recruiting and hiring enough people who could become successful
examiners. Of these directors, more than three-quarters reported that such
difficulties contributed to increases in claims-processing times, examiner
caseload levels, backlogs, and turnover. In addition, more than half of
all directors reported that state-imposed compensation limits contributed
to these hiring difficulties, and more than a third of all directors
attributed hiring difficulties to other state restrictions, such as hiring
freezes.
o Gaps in key knowledge and skills. Nearly one-half of all DDS directors
said that at least a quarter of their examiners need additional training
in areas critical to disability decision-making, such as assessing
symptoms and credibility of medical information, weighing medical
opinions, and analyzing a person's ability to function. Over half of all
directors cited factors related to high workload levels that limit trainer
and trainee time as obstacles to examiners' receiving additional training.
Despite the workforce challenges facing the DDSs, data from our survey
show that the majority of DDSs do not undertake long-term, comprehensive
workforce planning, citing numerous obstacles to doing so. More than half
of all the DDSs have workforce planning time horizons of less than two
years. Moreover, among the DDSs that engage in workforce planning that is
longer-term than one year, the majority have plans that lack key workforce
planning strategies, such as those for recruiting, retention, or
succession planning. The directors who report that they do not engage in
workforce planning that is longer-term than one year instead mainly rely
on SSA's annual budget process for their workforce planning, even though
GAO's research shows that the budget process does not constitute
comprehensive workforce planning.
Moreover, over half of all the DDSs do not make projections of retirements
and other separations. DDS directors cited a number of obstacles that made
long-term workforce planning more difficult than it would be otherwise.
For example, two-thirds of all DDS directors reported that longterm
planning is made more difficult by inconsistencies between state and SSA
human capital policies and uncertainties about future resource levels from
SSA. Further, three-quarters of all directors said that they had
insufficient time to attend to future problems because of the need to
focus on current human capital challenges.
SSA's workforce efforts have not sufficiently addressed present and future
DDS human capital challenges. The Government Performance and Results Act
now requires agencies to include in their annual performance plans a
description of the human capital strategies needed to meet their strategic
goals. However, GAO's review of SSA's planning documents shows that
neither SSA's strategic plan, nor its annual performance plan, nor its
workforce plan contains a strategic human capital plan that addresses
current and future DDS human capital needs. Thus SSA does not link its
strategic objectives (such as making the right decision in the disability
process as early as possible) to a workforce plan that covers the very
people who are essential to accomplishing those objectives. In addition,
one-half or more of DDS directors reported being dissatisfied with the
adequacy of training that SSA provides to the DDSs in a number of key
knowledge and skill areas. Beyond training, an analysis of GAO's survey
data shows that SSA has not provided other human capital assistance in a
consistent manner across the DDSs. For example, of the DDS directors who
reported wanting help from SSA with negotiating human capital changes with
the states (for example, in negotiating salary increases for examiners),
more than half (24 DDSs) said that they had not received it. Moreover,
more than half of the DDS directors who received such assistance (11 DDSs)
said it was of limited effectiveness. Regional office officials and DDS
directors explained in interviews, however, that the effectiveness of SSA
and its regional offices in providing such help can be limited by such
factors as state budget problems, political concerns, and personnel rules.
Finally, SSA has not used the statutory authority it has to establish
uniform human capital standards, such as minimum qualifications for
disability examiners, which would address, on a nationwide basis, some of
the human capital challenges facing the DDSs. The agency has instead
allowed the states to retain maximum flexibility in the human capital
management arena, citing potential difficulties inherent in changing the
federal-state relationship. For example, some SSA officials expressed
concern that states might perceive the establishment of uniform human
capital standards as an unwelcome federal intrusion into state
operations. While acknowledging these and other significant difficulties,
several DDS and SSA officials interviewed by GAO expressed the view that
uniform standards could help address the human capital challenges
confronting the DDSs.
GAO is making several recommendations in this report to the Commissioner
of Social Security to improve SSA's strategic workforce planning to
address present and future human capital challenges facing the DDSs. These
recommendations include that SSA work in partnership with the DDSs to
develop a nationwide strategic workforce plan to address present and
future human capital challenges facing the DDSs, establish uniform minimum
qualifications for new examiners, and work with the DDSs to close gaps
between current and required examiner skills. In commenting on a draft of
this report, SSA officials generally agreed with the intent of our
recommendations but stated that the report does not fairly address or
adequately discuss the many sides of DDS human capital management issues.
In particular, SSA criticized some of our study's methods and expressed
concern that we did not sufficiently acknowledge the difficulties involved
in making changes to the federal-state relationship. For example, SSA said
that we relied heavily on opinions of DDS directors and that we did not
sufficiently acknowledge the attitudes of the states toward modifying
federal regulations to establish uniform human capital standards and the
complexities involved. We surveyed DDS directors because they are some of
the most knowledgeable respondents about human capital challenges facing
their organizations. But in addition to our survey, we gathered
information from a variety of sources, including site visits to three SSA
regional offices, interviews with SSA officials at headquarters, and
analyses of human capital data. In addition, our report acknowledged the
difficulties SSA has encountered in convincing the DDSs to comply with SSA
guidelines on personnel issues and stressed that establishing uniform
qualifications for examiners will be difficult. But we maintain that,
despite such difficulties, as the agency with fiduciary responsibility for
administering multibillion dollar disability programs that are nationwide
in scope, SSA is obligated to address the human capital challenges facing
the DDSs. We continue to believe that the report presents a fair and
balanced portrayal of the multifaceted issue of human capital management
in the DDSs. Our summary evaluation of the agency's comments begins on
page 44. SSA's comments and our responses are provided in full in appendix
IV.
Background The DI and SSI programs are the two largest federal programs
providing cash assistance to people with disabilities. The DI program,
established in 1956 by the Social Security Act, provides monthly cash
benefits to workers with disabilities (and their dependents and survivors)
whose employment history qualifies them for disability benefits. In 2002,
SSA paid about $55.5 billion in DI benefits to 5.5 million workers with
disabilities (age 18 to 64).7 SSI is a means-tested income assistance
program created in 1972 that provides a financial safety net for
individuals who are aged or blind or have other disabilities and who have
low income and limited resources. Unlike the DI program, SSI has no prior
work requirement. In 2002, SSA paid about $18.6 billion in SSI federal
benefits to about 3.8 million people with disabilities (age 18 to 64).
SSA's Disability Determination Process
To be considered eligible for benefits for either SSI or DI as an adult, a
person must be unable to perform any substantial gainful activity by
reason of a medically determinable physical or mental impairment that is
expected to result in death or that has lasted or can be expected to last
for a continuous period of at least 12 months. Work activity is generally
considered to be substantial and gainful if the person's earnings exceed a
particular level established by statute and regulations.8
To obtain disability benefits, a claimant must file an application online,
by phone or mail, or in person at any of SSA's field offices.9 If the
claimant meets the non-medical eligibility criteria, the field office
staff forwards the claim to the appropriate DDS office. DDS
staff-generally a team composed of disability examiners and medical
consultants-obtains and reviews medical and other evidence as needed to
assess whether the claimant satisfies program requirements, and makes the
initial disability determination. If the claimant is not satisfied with
the decision, the
7DI beneficiaries with low income and assets can also receive SSI
benefits. Of the 5.5 million DI beneficiaries, about 800,000 also received
SSI in 2002.
8The Commissioner of Social Security has the authority to set the
substantial and gainful activities level for individuals who have
disabilities other than blindness. In December 2000, SSA finalized a rule
calling for the annual indexing of the nonblind level to the average wage
index of all employees in the United States. The 2004 nonblind level is
set at $810 a month. The level for individuals who are blind is set by
statute and is also indexed to the average wage index. In 2004, the level
for blind individuals is $1,350 of countable earnings.
9SSA permits DI, but not SSI, applicants to file for benefits online.
claimant may ask the DDS to reconsider its finding.10 If the claimant is
not satisfied with the reconsideration, the claimant may request a hearing
before one of SSA's federal administrative law judges in an SSA hearing
office. If the claimant is still dissatisfied with the decision, the
claimant may request a review by SSA's Appeals Council.11
The Federal-State Relationship
The 1954 amendments to the Social Security Act specified that disability
determinations would be made by state agencies under individual
contractual agreements with SSA. Under these agreements, SSA's primary
role was to fund the states' disability operations. However, following
criticism from GAO and others about the quality and uniformity of the
disability determination process, Congress amended the Social Security Act
in 1980 to strengthen SSA management of the disability programs and allow
greater SSA control and oversight of the DDSs. The 1980 amendments
directed SSA to issue regulations specifying performance standards and
administrative requirements to be followed to assure effective and uniform
administration of disability determinations across the nation.12
The regulations issued by SSA, which established the current federal-state
relationship, allow SSA to remove the disability determination function
from a state if the DDS fails to make determinations that meet thresholds
for performance accuracy and processing time.13 SSA's regulations give
DDSs maximum managerial flexibility in meeting the performance standards,
allowing them to retain substantial independence in how they
10In 2002, the DDSs made 2.3 million initial disability determinations and
over 484,000 reconsiderations. In September 2003, the Commissioner
testified before the House Committee on Ways and Means, saying that she
intended to revise the disability determination process. For example, she
proposed eliminating the reconsideration and the Appeals Council stages of
the current process.
11If the claimant is not satisfied with the Appeals Council decision, the
claimant may appeal to a federal district court. The claimant can continue
legal appeals, as needed, to the U.S. Circuit Court of Appeals and
ultimately to the Supreme Court of the United States.
12See Pub. L. No. 96-265, Sec. 304(a) (1980).
13See 20 C.F.R. Sec. 404.1503(a) and 416.903(a) (2003).
manage their workforce.14 For example, under the regulations, the DDSs are
to follow state personnel standards in selection, tenure, and compensation
of DDS employees.15
As employees of the state, DDS staff are subject to the rules and
regulations of each state's individual personnel classification system.
Classification systems generally categorize positions on the basis of job
responsibilities and the knowledge, skills, and competencies required to
perform them. Within a classification system, a group of positions that
have sufficiently similar responsibilities are put in the same class.
Arranging positions in classes with common levels of difficulty and
responsibility makes it possible to set ranges of compensation for whole
classes of jobs across multiple state agencies. Specifying the
responsibilities of each position also allows the state to identify and
develop effective hiring qualifications, promotion criteria, and training
requirements. The development and operation of such a classification
system depend upon the adequacy of information about individual positions.
Description of the DDSs and the Disability Examiner Position
Within the federal-state relationship, each DDS reports to its own state
government, usually to a parent agency such as the state vocational
rehabilitation agency.16 DDS staff generally include a variety of
positions, such as medical consultants, vocational specialists, quality
assurance personnel, as well as disability examiners. The number of
disability examiners varies substantially among the DDSs. Data from our
survey show that the number of full-time permanent examiners in each DDS
ranged from 9 to 529 at the end of fiscal year 2002. Our prior work has
found that the examiner's job-which involves working with medical
consultants to determine impairment severity, ability to function, and
disability benefit eligibility-requires considerable expertise and
14In the preamble to these regulations, SSA stated that it did not define
DDS administrative requirements in detail and instead elected to regulate
only to the extent necessary to ensure effective and uniform
administration of the disability program. (46 Fed. Reg. 29,190, 29,198
(1981). SSA also stated that, overall, the states supported the agency's
proposed regulatory approach. (Id. at 29,196.)
15The regulations also encourage the states to refrain from imposing state
personnel freezes and restrictions against overtime work on the DDSs to
the extent possible. See 20 C.F.R. Sec. 404.1621(b) and 416.1021(b).
16Our survey data show that 50 out of 52 DDSs report to a state parent
agency, and among these, 28 DDSs report to the state's vocational
rehabilitation agency.
knowledge of complex regulations and policies.17 And according to the
Social Security Advisory Board, changes in agency rules and in the types
of disability claims received by the DDSs have made disability
decision-making more subjective and difficult.18 In addition, as part of
its efforts to reduce claims-processing times, SSA has been testing a new
disability examiner position called the single decision-maker (SDM), which
would expand an examiner's authority to independently decide claimants'
eligibility for benefits.19 20 DDSs are testing this new position.
Qualification requirements for new examiner hires vary substantially among
the states. While five DDSs require a master's or a registered nursing
degree for certain new examiner hires, figure 1 shows that over one-third
of all DDSs can hire new examiners with either a high school diploma or
less.20 In addition, data show that examiners in nearly one-half of all
DDSs are covered by union agreements, and issues related to compensation
levels, hiring and promotion procedures, and weekly hours worked are open
to union negotiation in the majority of these DDSs.
17See GAO/T-HEHS/AIMD-00-75.
18For example, due to changes in agency rules, examiners must now adhere
to more complex requirements regarding such matters as determining the
weight that should be given to the opinion of a treating source and making
a finding as to the credibility of claimants' statements about the effect
of pain on functioning. See Social Security Advisory Board, Agenda for
Social Security: Challenges for the New Congress and the New
Administration (February 2001).
19Expansion of an examiner's authority would bypass the current need for a
medical consultant to certify the decision unless the law mandates
otherwise. Medical consultants are required to certify all SSI childhood
disability claims and all less than fully favorable decisions on DI and
SSI claims involving an indication of a mental impairment.
20Some DDSs may have higher educational requirements for some applicants
or may use standards other than, or in addition to, education-such as
relevant skills, previous equivalent experience, or some type of selection
examination for which a qualifying score or ranking is needed for hiring
eligibility. The minimum education requirements shown in this figure do
not necessarily reflect the actual credentials of DDS examiners hired by
the DDSs. For example, one DDS director explained in an interview that,
despite the lack of any educational requirements for new examiner hires in
the state, most examiners employed by the DDS had four-year college
degrees, and several had masters' degrees.
Figure 1: Percentage of DDSs by Type of Minimum Education Requirement for
New Disability Examiners
Combined amounts to over one-third of the DDSs
(bachelor)
Source: GAO analysis of responses to its survey of DDS directors, April
2003.
Note: These figures represent the lowest possible educational level a DDS
requires for a new examiner, regardless of the type of applicant for the
job. Data provided in the figure do not add to 100 percent due to
rounding. One DDS did not answer this question.
To enhance the skills of both new and experienced examiners, SSA provides
a number of optional training tools to the DDSs, including written
materials covering new examiner basic training, interactive video programs
supplementing basic training and providing refresher training and updates
on policy changes, and materials and presentations provided by the
regional offices and SSA headquarters. However, states have primary
responsibility for training examiners, and many DDSs adapt or supplement
SSA's training to meet their examiners' training needs. DDSs generally
provide new examiners with SSA's basic examiner training, followed by
extensive on-the-job training, including mentoring by experienced
examiners who guide the less experienced examiners in becoming more
proficient in the disability claims process. New hires generally are not
considered fully proficient until after one to two years of experience.
The DDSs' ability to hire examiners is affected by both SSA and state
government funding decisions and hiring policies. SSA determines the
funding available for each DDS and advises the DDSs about the number of
full-time equivalent staff supported by this funding, and SSA adjusts
these levels throughout the fiscal year based on workload fluctuations and
funding availability. Normally SSA allows DDSs to replace staff who leave
the DDS as long as they remain within authorized staffing levels, but for
over half of fiscal year 2003, SSA froze DDS hiring, preventing DDSs from
hiring new examiners or replacing those who had left. SSA officials told
us that the temporary freeze was necessary to ensure that SSA's
expenditures did not exceed authorized levels and to avoid future layoffs
of DDS staff.21
DDSs also have experienced state government hiring restrictions in recent
years. Despite full federal funding, under the current federal-state
relationship, DDSs generally cannot spend funds for new personnel without
the approval of their state governments. States currently are facing
severe budget crises, causing them to cut their payrolls for most state
government functions. When states use methods such as hiring freezes,
reductions in force, and early retirement incentives to limit spending on
state employee payrolls, these policies sometimes prevent DDSs from hiring
and retaining examiners at levels authorized by SSA.
Modernizing Federal Disability Programs Designated as a High-Risk Area
In earlier reports, we have noted that SSA's disability determination
process is mired in concepts from the past and needs to be brought into
line with the current state of science, medicine, technology, and labor
market conditions.22 With other federal disability programs similarly
structured around outmoded concepts, we designated modernizing federal
disability programs-including SSA's DI and SSI disability programs-as a
high-risk area in 2003.23 (See appendix III for a list of GAO reports on
modernizing federal disability programs.) We made this designation owing
in part to SSA's (1) outmoded concepts of disability, (2) lengthy
processing times, and (3) decisional inconsistencies:
o SSA's outmoded concepts of disability. While technological and medical
advances and societal changes have increased the potential for some people
with disabilities to participate in the labor force, few DI and SSI
beneficiaries leave the disability rolls to work. Our prior work shows
that, unlike some private sector disability insurers and social insurance
systems in other countries, SSA does not incorporate into its disability
21SSA officials said the agency's policy was to avoid layoffs of DDS
employees.
22See, for example, U.S. General Accounting Office, SSA and VA Disability
Programs: Re-Examination of Disability Criteria Needed to Help Ensure
Program Integrity,
GAO-02-597 (Washington, D.C.: August 9, 2002). 23GAO-03-119.
eligibility assessment process an evaluation of what is needed for an
individual to return to work.24 These private insurers and other social
insurance systems have access to staff with a wide range of expertise to
apply, not only in making eligibility decisions, but also in providing
returnto-work assistance. We have recommended that SSA develop a
comprehensive return-to-work strategy that integrates earlier
identification of work capacities and the expansion of such capacities by
providing return-to-work assistance for applicants and beneficiaries.
Adopting such a strategy is likely to require fundamental changes to the
disability determination process, as well as changes to staff skill mixes
and areas of expertise.
o Lengthy processing times for disability claims. The disability claims
process can be lengthy, with many individuals who appeal SSA's initial
decision waiting a year or longer for final decisions on their benefit
claims. According to SSA, a claimant can wait as long as 1,153 days from
initial claim through a decision from the Appeals Council. As one means of
reducing its claims-processing time, SSA aims to eliminate backlogs for
initial disability claims, hearings, and appeals by 2008. Nevertheless,
growth in the disability claims workload is likely to exacerbate SSA's
claims-processing challenges: SSA expects the DI rolls to grow by 35
percent between 2002 and 2012.25
o Inconsistencies in disability decisions. SSA has had difficulty
ensuring that decisions regarding a claimant's eligibility for disability
benefits are accurate and consistent across adjudicative levels and
locations, raising questions about the fairness, integrity, and cost of
these programs.26 For example, the Social Security Advisory Board has
shown wide variances among the DDSs in rates of allowances and denials of
disability benefits.27 The Advisory Board has cited differences in
state-established personnel policies such as salaries, training, and
qualifications of disability examiners across the DDSs, along with state
economic and demographic
24GAO-01-153.
25Social Security Administration, Strategic Plan 2003-2008.
26The cost of administering the DI and SSI programs reflects the demanding
nature of the process. Although SSI and DI program benefits account for
less than 20 percent of the total benefit payments made by SSA, they
consume nearly 55 percent of SSA's annual administrative resources.
27Social Security Advisory Board, Charting the Future of Social Security's
Disability Programs: The Need for Fundamental Change (Washington, D.C.:
January 2001).
differences, as some of the key factors that may affect the consistency of
disability decision-making.28
SSA's New Long-Term Strategy for Improving Its Disability Programs
The Commissioner's September 2003 testimony sets forth her long-term
strategy for improving the timeliness and accuracy of the disability
claims process and fostering return to work for people with disabilities.
For example, to speed decisions for some claimants, the Commissioner
intends to initiate an expedited decision for claimants with more easily
identifiable disabilities, such as aggressive cancers. Under this new
approach, special units located primarily in SSA's regional offices would
handle the expedited claims, leaving DDS examiners responsible for
evaluating the more complex claims. The Commissioner's strategy also aims
to increase decisional accuracy by, among other approaches, requiring DDS
examiners to develop more complete documentation of their disability
determinations, including explaining the basis for their decisions. Beyond
steps to improve the timeliness and accuracy of the process, the
Commissioner also plans to conduct several demonstrations aimed at helping
people with disabilities return to work by providing work incentives and
opportunities earlier in the disability process.
In addition, to improve the disability decision process, the Commissioner
has implemented some shorter-term remedies while developing her
longer-range strategies. For example, SSA is accelerating its transition
to an electronic disability claims folder, through which the DDSs, the
field offices, and the Office of Hearings and Appeals are to be linked to
one another. The folder is being designed to transmit case file data
electronically from one claims-processing location to another and to serve
as a data repository-storing documents that are keyed in, scanned, or
faxed. According to the Commissioner, successful implementation of the
electronic folder is essential for improving the disability process. In
our prior work, we have cautioned SSA to ensure that it has the right mix
of skills and capabilities to support this major technological
transition.29
28Social Security Advisory Board, Disability Decision-Making: Data and
Materials (Washington, D.C.: January 2001).
29U.S. General Accounting Office, Major Management Challenges and Program
Risks: Social Security Administration, GAO-03-117 (Washington, D.C.:
January 2003).
Strategic Human Capital Management Designated a High-Risk Area
Recognizing the importance of people to the success of any organization in
managing for results, GAO designated strategic human capital management a
government-wide high-risk area in 2001.30 In prior reports on this
high-risk area, we identified strategic workforce planning as essential to
effective performance and stated that it should be a priority of agency
leaders.31 We also noted that effective workforce planning must be fully
integrated with an agency's mission and program goals and be based on
accurate and comprehensive workforce data. We recently identified a few
key principles for strategic workforce planning.32 These principles
include
o involving top management, employees, and other key stakeholders in
developing, communicating, and implementing the workforce plan;
o determining the critical skills and competencies needed to achieve
current and future program goals, and developing strategies to fill
identified gaps;
o building the capability necessary to address administrative,
educational, or other requirements to support the workforce strategies;
and
o monitoring and evaluating progress in meeting workforce goals and how
well the workforce plan has contributed to reaching overall program goals.
Congress has additionally recognized the importance of workforce planning
and, in 2002, added to the Government Performance and Results Act a
provision requiring agencies to include human capital strategies needed to
meet their strategic goals in their annual performance plans.33 We have
found that high-performing organizations use workforce planning as a
management tool to develop a compelling case for human capital investments
and to anticipate and prepare for upcoming human capital
30GAO-01-263.
31GAO-01-263 and U.S. General Accounting Office, Human Capital: Key
Principles for Effective Strategic Workforce Planning, GAO-04-39
(Washington, D.C.: December 11, 2003).
32GAO-04-39.
33See 31 U.S.C. Sec. 1115(a)(3) and (f) (2003).
DDSs Face High Turnover, Recruiting and Hiring Difficulties, and Gaps in Key
Knowledge and Skill Areas
issues that could jeopardize accomplishment of the organizations' goals.34
(See appendix III for a list of GAO reports on human capital management.)
The DDSs face several key challenges in retaining disability examiners and
enhancing their expertise: high turnover, difficulties in recruiting and
hiring, and gaps in key knowledge and skill areas. The DDSs are
experiencing high and costly turnover of examiners, which data from our
survey show is fostered in part by stressful workloads and noncompetitive
salaries. DDSs need to recruit and hire sufficient numbers of qualified
new examiners to fill the vacancies resulting from the high turnover. Yet
more than three-quarters of DDS directors reported recruiting and hiring
difficulties. Directors said such difficulties were due in part to
stateimposed personnel restrictions, such as state limits on examiner
salaries and hiring. Finally, directors reported that many examiners need
additional training in key analytical areas that are critical to
disability decision-making, including assessing credibility of medical
information, evaluating applicants' symptoms, and analyzing applicants'
ability to function.
DDSs Face High and Over half of all DDS directors responding to our survey
said that examiner Costly Turnover Fostered turnover in their offices was
too high. Our analysis of data from our survey by Stressful Workloads and
and from federal agencies shows that, over fiscal years 2000 through 2002,
DDS examiner turnover was about twice that of Veterans Benefits
Noncompetitive Salaries Administration (VBA) disability examiners with
responsibilities similar to those of DDS examiners.35 For example, DDS
examiner turnover averaged 13 percent over fiscal years 2000 to 2002,
compared with 6 percent for VBA
34U.S. General Accounting Office, A Model of Strategic Human Capital
Management, GAO-02-373SP (Washington, D.C.: March 15, 2002).
35VBA employs 5,000 disability claims examiners, called veterans service
representatives (VSRs) and ratings veterans service representatives
(RVSRs), in 57 offices covering each state. Because the Office of
Personnel Management's Central Personnel Data File groups both positions
together, our comparisons include both groups. Both positions have certain
responsibilities similar to those of DDS examiners. For example, RVSRs and
DDS examiners are responsible for analyzing disability claims to determine
disability benefit eligibility. Moreover, VSRs and DDS examiners are
responsible for investigating disability claims and serving as the primary
contact for claimants and health providers. However, when compared with
the DDS examiner, RVSRs have the additional responsibility of determining
whether claimants' impairments are related to their military service, and
VSRs have the added task of conducting initial interviews with applicants.
In this report, we are referring to both RVSRs and VSRs as VBA examiners.
disability examiners. (See table 1.) In addition, during the same period,
the turnover rate of DDS examiners was substantially greater than that of
all SSA employees as well as that of all federal government employees.36
DDS examiner turnover has been even higher among new hires: turnover of
examiners hired in fiscal year 2001 was 25 percent, compared with 14
percent among all DDS examiners.37 Moreover, while it is typical for new
hires to leave at higher rates than other employees, turnover of new DDS
examiners was considerably higher than that of new VBA examiners, new SSA
employees, and all new federal government employees in fiscal years 2000
and 2001.
Table 1: Turnover Rates for DDS Examiners, VBA Examiners, SSA Employees, and All
Federal Employees
National turnover ratesa
Experienced staff and new hiresb New hires onlyc Fiscal DDS VBA SSA All
federal DDS VBA
SSA
All federal employeesyear
examiners examiners employees employees examiners examiners employees
2000 15% 5% 6% 8% 31% 19% 16% 24%
2001 14 6 5 7 25 18 14
2002 12 7 5 7 d d d d
Average e 13 6 5 7 28 18 15
Source: GAO analysis of data from our survey of DDS directors, April 2003,
and from the U.S. Office of Personnel Management's Central Personnel Data
File.
aThe calculation of the annual turnover rate and the new hire turnover
rate for SSA and VBA examiners included transfers to other agencies within
the federal government, but such transfers were not included in the
turnover rate calculation for federal employees government-wide. In
addition, some DDSs did not provide complete turnover data for all three
years. The fiscal year 2000 turnover rate for experienced DDS staff is
based on data from 47 DDSs; the fiscal year 2001 rate is based on data
from 49 DDSs; and the fiscal year 2002 rate is based on data from 52 DDSs.
The average turnover rate accounts for these differences in number of DDSs
and total employees across years.
bWe based our calculation of the annual turnover rate for DDS examiners,
VBA examiners, and SSA employees on the total number of retirements and
other separations during a fiscal year, divided by the average number of
permanent employees. We calculated the number of permanent employees by
averaging the total number employed at the beginning and the end of the
fiscal year.
cWe based our calculation of the yearly new hire turnover rate on the
total number of new hires separating in the fiscal year following their
year of hire, divided by the total number hired in that year.
36We were unable to obtain data on turnover rates of private sector
employees who perform work similar to that of DDS examiners that was
comprehensive enough to allow valid comparisons. We were also unable to
obtain recent data on the turnover rates of state employees other than DDS
employees.
37According to human resource experts, it is typical for new employees to
leave at higher rates than all other employees. See U.S. General
Accounting Office, Veterans Benefits Administration: Better Collection and
Analysis of Attrition Data Needed to Enhance Workforce Planning,
GAO-03-491 (Washington, D.C.: April 28, 2003).
dNo data available.
eAverage turnover rates for experienced staff and new hires are based on
fiscal years 2000, 2001, and 2002. Average turnover rates for new hires
only are based on fiscal years 2000 and 2001.
Our survey results also show that examiner turnover is particularly high
in some DDSs. An examination of three-year averages (fiscal years 2000 to
2002) of DDS turnover rates showed that one DDS had a turnover rate of 43
percent, and a quarter of the DDSs had turnover rates of 20 percent or
greater. (See fig. 2.)
Figure 2: Three-Year Average Examiner Turnover Rates for Individual DDSs
(Fiscal Years 2000 to 2002)
DDSs
25
20
20
15
10
5
0
0-9% 10-19% 20-29% 30-39% 40% or greater
DDS 3-year average turnover rate
Sources: GAO analysis of survey of DDS directors, April 2003, and GAO
analysis of OPM's Central Personnel Data File.
Note: Three-year average turnover rates are based on data from 47 DDSs.
Five DDSs did not provide turnover data for all three fiscal years (2000,
2001, and 2002). The highest three-year turnover rate was 43 percent.
When we asked DDS directors in our survey about the consequences of
turnover, they told us that examiner turnover increased hiring and
training
costs and hindered claims processing by decreasing overall examiner skill
levels, and increasing examiner caseloads, claims-processing times, and
backlogs, as follows:38
o Increased hiring and training costs. Nearly two-thirds of all DDS
directors reported in our survey that turnover had increased SSA's
recruiting, hiring, or training costs. Directors and other DDS officials
explained in interviews why these costs had increased as a result of
turnover. Some DDS directors said that they must invest time in reviewing
applications, interviewing candidates, and making hiring decisions. They
also said they have to provide inexperienced new hires with 12 to 18
months of extensive training and mentoring. SSA estimates the cost of
turnover of its own employees at 1.5 times average annual salary. Using
this rate, we estimate that the cost of DDS examiner turnover in fiscal
year 2002 was in the tens of millions of dollars.
o Decreased overall examiner skill levels. Two-thirds of all DDS
directors reported that losses of experienced staff due to turnover have
decreased overall examiner skill levels. While SSA officials told us that
one to two years of experience is generally required to become proficient
in the examiner role, our survey data show that, in two-thirds of the
DDSs, at least a quarter of examiners had two years or less experience at
the end of fiscal year 2002.
o Increased examiner caseloads. Nearly two-thirds of all DDS directors
we surveyed said turnover had increased examiner caseload levels. DDS
directors and SSA officials explained in interviews and survey comments
that the caseloads of examiners who leave the DDS have to be redistributed
among those who remain. Some directors told us that these higher caseloads
created a more stressful work environment for the remaining employees.
o Increased claims-processing times and backlogs. Our survey results
showed that over one-half of all directors said that turnover had
increased DDS claims-processing times and backlogs. DDS directors and SSA
officials we spoke with explained that turnover increased claimsprocessing
times because new examiners hired to fill vacancies are less productive
due to their inexperience and time spent in training. These officials also
told us that the productivity of experienced staff is lowered while they
are training and mentoring the new examiners. SSA itself
38We categorized these conditions as consequences of turnover if directors
reported that they had occurred to a moderate to very great extent as a
result of turnover.
acknowledged the potential impact on service in a 2001 internal document.
This document noted that the need to replace retiring managers, by
drawing from an examiner pool already diminished by turnover, would
further reduce the examiner ranks and exacerbate the challenge of
processing the growing claims workload. In addition, we noted in a prior
report that a majority of DDS directors expressed the view that examiner
turnover is likely to jeopardize their ability to complete periodic
reviews of
beneficiaries' disability status, known as continuing disability reviews,
potentially contributing to backlogs of these reviews.39
When we asked DDS directors about causes of examiner turnover, more
than two-thirds identified each of the following as contributing factors:
(1) large examiner caseloads along with workplace stress, high production
expectations, and highly complex work and (2) noncompetitive pay.40
o High caseloads, stress, production expectations, and highly complex
work. Over two-thirds of all DDS directors identified large examiner
caseloads, a stressful workplace, high production expectations for the
number of cases completed, and the highly complex nature of the work as
factors contributing to examiner turnover. DDS directors explained in
interviews that the combination of growth in the claims workloads and
increasingly complex examiner responsibilities is making the examiner
position more challenging and stressful. DDS directors also noted in our
survey and in interviews that insufficient staffing had increased the
caseloads and stress levels of their examiners. Nearly 9 out of 10 DDS
directors surveyed reported that the number of examiners in their DDSs had
not been sufficient for their workload in at least one of the past three
fiscal years, and nearly all of these directors said that this
understaffing had resulted in a more stressful work environment.
o Noncompetitive pay. Two-thirds of all directors stated that
noncompetitive pay had contributed to examiner turnover. Our survey data
showed that many state DDS examiners were paid substantially less than
examiners employed by the federal DDS in 2002 despite comparable
39U.S. General Accounting Office, Social Security Disability: Reviews of
Beneficiaries' Disability Status Require Continued Attention to Achieve
Timeliness and Cost-Effectiveness, GAO-03-662 (Washington, D.C.: July 24,
2003).
40We categorized factors as contributing to examiner turnover if DDS
directors reported that these factors contributed to turnover to a
moderate to very great extent.
skills and experience.41 Specifically, all of the state DDSs for which we
have data have average examiner salaries that are less than the federal
DDS average salary, and over half of the DDSs (31) have an average
examiner salary that is less than two-thirds of the federal DDS average
salary. In addition, we found that DDS examiner salaries are substantially
lower than those of VBA examiners nationwide. For example, the average
salary for DDS examiners was $40,464 in 2002, compared with $49,684 for
VBA examiners.42 Specifically, we found that average DDS examiner
salaries are less than those of VBA examiners in 47 states. (See fig. 3.)
Several DDS directors told us in interviews that examiners have left some
DDSs to accept higher salaries in federal agencies, particularly in SSA
offices. For example, our analysis of selected case data provided by two
DDS directors showed that, between 2000 and 2003, 13 former examiners
received pay increases ranging from 9 to 48 percent when they moved from
their DDSs to positions in SSA offices.43
41We collected average examiner salary data from the federal DDS
administered by SSA, adjusted it to reflect locality pay in each state,
and compared it with average DDS examiner salary data from our survey. One
DDS was excluded because it did not provide examiner salary data. While
the federal DDS examiner position carries responsibilities beyond those of
the state DDS examiners, state DDS examiners do not receive additional
training in order to perform the federal examiner job.
42We analyzed salary data from our survey and from VBA in order to compare
DDS examiner and VBA examiner salaries. We were unable to obtain
information on experience levels of VBA examiners and the distribution of
their experience levels across the states. It is possible that these
factors could help explain some of the differences between the average
salaries of VBA examiners and DDS examiners.
43See appendix I for an explanation of our methods for this analysis.
Figure 3: Distribution of Average State DDS Examiner Salaries as a
Percentage of Average VBA Examiner Salaries
DDSs
15
11 11 11
In addition to facing high turnover and growing caseloads, more than
three-quarters of all DDS directors (43) reported experiencing
difficulties over a three-year period in recruiting and hiring enough
people who could become successful examiners.44 Of these directors, more
than threequarters said that such difficulties contributed to decreased
accuracy in disability decisions or to increases in job stress,
claims-processing times, examiner caseloads, backlogs, or turnover.45 For
example, one SSA official explained that, because of state-imposed hiring
restrictions, one DDS
44DDS directors responding to this survey question had experienced
recruiting and hiring difficulties for any of fiscal years 2000, 2001, or
2002. We characterized DDSs as having difficulty if the director reported
having some to very great difficulty in recruiting and hiring.
45We categorized a condition as a consequence of recruiting and hiring
difficulties if DDS directors reported that the difficulties had
contributed to the condition from some to a very great extent.
10 5
0 40-49% 50-59% 60-69% 70-79% 80-89% 90-99%
100% or greater DDS examiner salaries as a percentage of VBA salaries
Sources: GAO analysis of survey of DDS directors, April 2003, and GAO
analysis of OPM's Central Personnel Data File.
Note: One DDS did not provide examiner salary data.
DDSs Face Difficulties in Recruiting and Hiring Partly Due to State-Imposed
Personnel Restrictions
developed a large backlog of cases that negatively affected its
productivity.
When we asked DDS directors what made it difficult for their DDSs to
recruit and hire, they said that the following factors, many of which were
related to state personnel restrictions, made it moderately to much more
difficult than it would be otherwise to recruit and hire:
o state limits on examiner salaries and other forms of compensation,
o restrictive job classification system for state employees,
o state-imposed hiring limitations or hiring freezes and lengthy time
periods for the state to hire DDS examiners, and
o SSA-imposed hiring restrictions and budget allocations limiting DDS
staffing levels.
State limits on examiner salaries and other forms of compensation. More
than two-thirds of all directors reported that state limits on examiner
salaries hindered recruiting and hiring, and the same proportion reported
that noncompetitive salaries were insufficient to recruit or retain staff
with the skills necessary to assume enhanced examiner responsibilities.46
One DDS director noted in survey comments that the low entry-level salary
for examiners in that particular state no longer attracted "...the caliber
of employees needed to perform the increasingly complex [examiner] job."
Another commented that, owing to noncompetitive salaries, job candidates
"...who have the requisite combination of skills needed as a [disability
examiner] will find better offers of employment, [with] either better pay
or less workload stress." And officials we spoke with in an SSA regional
office said that low examiner salaries in still another DDS have meant
that this DDS has been unable to recruit candidates with strong analytical
skills. They noted that the DDS has, therefore, had difficulty training
its new examiners in such challenging tasks as weighing the credibility of
medical and other evidence. In addition to citing limits on salaries, more
than half of all directors reported that state limits on other forms of
compensation, such as performance-based pay and hiring bonuses, also
contributed to recruiting and hiring difficulties.
46Specifically, the DDS directors said that noncompetitive salaries that
were insufficient to attract or retain staff with skills to become SDMs
were or were likely to be a moderate to very serious challenge for their
DDSs in making the transition to the SDM position. Under the SDM position,
examiners would be given expanded authority for making disability
decisions, allowing them in many cases to independently decide claimants'
eligibility for benefits without the need for medical consultant approval.
The agency is currently testing this position.
Restrictive job classification system. Nearly one-half of all DDS
directors attributed difficulties in recruiting and hiring examiners to
their restrictive state job classification systems. Close to a third of
all states place disability examiners in the same classification as other
positions- such as a vocational rehabilitation specialist-and some DDS
officials we interviewed said this made it difficult to attract people
with skills appropriate to the disability examiner position.
State-imposed hiring limitations and lengthy time for hiring. Nearly
one-half of all DDS directors cited state hiring limitations or hiring
freezes-and more than one-third reported lengthy hiring processes-as
impediments to acquiring qualified examiners. For instance, officials we
interviewed in one DDS explained that their state government had capped
the number of staff the DDS could hire. These officials noted that, while
SSA was willing to fund hiring above that level, it could take three years
to obtain the state legislature's approval to increase the DDS staffing
level. SSA officials told us that another DDS could only hire individuals
who have taken a required state test. They explained that, because the
state administers the test only two times a year, the requirement hampers
DDS hiring efforts.
SSA-imposed hiring restrictions and budget allocations. Close to
two-thirds of all DDS directors said that, over the past three fiscal
years, SSA-imposed hiring restrictions and budget allocations that limit
DDS staffing levels have presented recruiting and hiring challenges for
the DDSs. DDS managers explained in interviews and in survey comments
that, given the one to two years it takes for an examiner to become fully
trained, DDSs that are restricted from quickly replacing staff lost to
attrition will not have sufficient numbers of experienced examiners to
process future claims.
Many Examiners Need In addition to high turnover and difficulties in
recruiting and hiring, the Additional Training in Key DDSs are also
experiencing gaps in key knowledge and skills areas. When Analytical Areas
we surveyed all DDS directors about specific knowledge and skill needs,
nearly one-half said that at least a quarter of their examiners needed
additional training or mentoring in each of the following areas to
successfully assume expanded responsibilities under an enhanced examiner
position in either the present or the future:47
47The question excluded trainee examiners.
o assessment of an applicant's symptoms and evaluation of the
credibility of medical and other evidence,
o evaluation of the weight to be given to medical evidence from a
treating physician,
o assessment and documentation of an applicant's ability to function,
o assessment of vocational factors,
o updates on policies and procedures, and
o assessment of childhood disabilities.
Even for those 19 DDSs in our survey that were testing the enhanced
examiner position at the time of our study, over half (11 DDSs) reported
that at least a quarter of the examiners with expanded responsibilities
needed additional training or mentoring in two or more of these same
knowledge and skill areas, and eight of these directors reported needs in
four or more of these areas.48
But regardless of whether a DDS was testing this enhanced position, these
areas are critical to the examiner's task of disability decision-making in
general. Indeed, one DDS director explained in an interview that, while
that DDS was not officially testing this position, over the last several
years it had hired examiners who were able to function in a manner that
was increasingly independent of the medical consultant. This director
noted that, as a result, it was becoming more difficult to distinguish the
responsibilities of the disability examiner from those of an examiner with
enhanced authority. Moreover, under SSA's new approach for improving the
disability determination process, these same knowledge and skill areas
will be even more critical as DDS examiners take responsibility for
evaluating only the more complex claims and as they are required to fully
document and explain the basis for their decision.49
48Twenty DDSs were testing the SDM position at the time of our study. We
administered our survey to 19 of these DDSs. We excluded one of the DDSs
that was testing the SDM position-the Guam DDS-from this survey.
49These new examiner responsibilities were outlined by the Commissioner in
her testimony before the Subcommittee on Social Security of the House
Committee on Ways and Means, September 25, 2003.
DDS directors cited several obstacles to examiners receiving needed
training or mentoring.50 These obstacles primarily involved high workload
levels that limited the time available to either provide or receive
training or mentoring. Specifically, more than 70 percent of all DDS
directors reported that work demands impeded mentors from providing
examiners with needed on-the-job training.51 In addition, about two-thirds
of all DDS directors reported that either the large size of examiners'
caseloads or high expectations for completing those cases did not allow
examiners enough time to attend training. And more than half of all
directors cited high work levels as a barrier to examiners seeking
mentoring assistance.
Despite the workforce challenges facing them, a majority of DDSs do not
conduct long-term, comprehensive workforce planning. Of the DDSs that
engage in workforce planning that is longer-term, a majority have plans
that lack key workforce planning strategies, such as those for recruiting,
retention, or succession planning. Directors identified numerous obstacles
to long-term workforce planning, such as a lengthy state process to
approve DDS human capital changes.
The Majority of DDSs Do Not Conduct Long-Term, Comprehensive Workforce
Planning, and DDSs Cite Numerous Obstacles to Doing So
The Majority of DDSs Do The majority of DDSs do not conduct long-term,
comprehensive
Not Conduct Long-Term, workforce planning. As figure 4 shows, more than
half of all the DDSs
Comprehensive Workforce have workforce planning time horizons of less than
two years, and almost
one-half have a time horizon of no longer than a year (the time horizon
ofPlanning SSA's annual budget process for the DDSs).
50We asked whether various factors were obstacles to nontrainee examiners
receiving additional mentoring or refresher training over the next two
years to successfully perform the SDM role or to become successful SDMs.
However, as discussed above, the skills needed to perform the SDM role
apply more broadly. We categorized a factor as an obstacle if DDS
directors deemed it to be a moderate to very serious obstacle to receiving
needed training or mentoring.
51Current and former DDS officials told us that on-the-job training
provided by mentors was essential to learning to successfully perform the
examiner job.
Figure 4: Percentage of DDSs by their Workforce Planning Time Horizons
Over half of the DDSs have workforce planning time horizons of less than 2
years
Source: GAO survey of DDS directors, April 2003.
Note: Data provided in the figure do not add to 100 percent due to
rounding.
DDS directors who reported that their workforce planning time horizons are
no longer than a year mainly rely on SSA's annual budget process for the
DDSs for their workforce planning. However, SSA officials told us in
interviews that their budget process is not designed to serve as a
long-term strategic workforce planning process. These officials said that
the following strategies of comprehensive, long-term workforce planning
are generally not part of the budget process but rather are left to the
states:
o recruiting strategies,
o retention strategies,
o training and professional development strategies,
o compensation strategies,
o performance expectation and evaluation strategies,
o employee-friendly workplace strategies,
o succession planning and strategies for maintaining expertise in the
long term, and
o contingency plans, in the event that resource levels do not meet
expectations.52
In addition, even among the 28 DDSs that engage in workforce planning that
is longer-term than one year, the majority (18) lack one or more of these
key workforce planning strategies.53
Furthermore, many DDSs do not collect the data needed to develop effective
workforce plans.54 Although DDSs face high turnover and are expected by
SSA to experience a retirement wave in the next decade, over half of all
DDS directors said they had not made projections of expected retirements
and other separations for examiners and related staff within the last two
fiscal years.
Although the majority of DDSs do not conduct comprehensive, long-term
workforce planning, some state governments do engage in strategic
workforce planning efforts that encompass DDS employees. For example,
52While other strategies also may be included in workforce planning
efforts, our prior work has found that the strategies listed are key to
effective workforce planning. See GAO-01-263.
53We found that only 10 of the 28 DDSs that conduct workforce planning
efforts longerterm than SSA's annual budget process include all 8 key
planning strategies.
54Our prior work has shown that accurate, comprehensive human capital data
are essential to good workforce planning. See GAO-02-373SP.
the state parent agency of one DDS has produced reports identifying the
workforce risks faced by the DDS (such as a coming retirement wave) and
has assisted the director with succession planning. However, ongoing
studies of state government workforce planning efforts have found that
formal strategic workforce planning is not taking place in all states.55
During an interview with several DDS directors, we were told that even
states with sophisticated long-term workforce planning efforts are not
necessarily focusing on ensuring that their DDSs have the workforces
needed to accomplish SSA goals, such as reducing claims-processing times.
DDS Directors Cited Numerous Obstacles to Long-term Workforce Planning
DDS directors noted in interviews that they face unique challenges related
to the federal-state relationship that compound the difficulties of
planning for future workforce needs. We asked DDS directors in our survey
to what extent they had experienced various factors that might make
workforce planning more difficult than it would be otherwise. Directors
identified the following as major obstacles to long-term workforce
planning:56
o Lengthy state processes to approve DDS human capital changes. Over
half of all DDS directors said that lengthy state processes to approve DDS
human capital changes made statewide DDS long-term workforce planning more
difficult. For example, an SSA official said it took over a year to obtain
approval to hire seven DDS staff due to a state hiring freeze. In
addition, a 2001 audit by SSA's Office of the Inspector General found that
the parent agency of one DDS had failed to provide sufficient staffing
resources, such as timely permission to fill vacancies, for the DDS to
efficiently process its disability workload.57
o Inconsistencies between state and SSA human capital policies.
Two-thirds of all DDS directors reported that long-term planning is made
more difficult than it would be otherwise due to inconsistencies between
state and SSA human capital policies, such as those related to staffing
55Syracuse University, Maxwell School of Citizenship and Public Affairs,
Government Performance Project, Paths to Performance in State & Local
Government (Syracuse, NY: 2002).
56We categorized these factors as obstacles to long-term workforce
planning if directors reported that they had experienced them to a
moderate to very great extent.
57Management Advisory Report, Single Audit of the State of Louisiana for
the Fiscal Year Ended June 30, 2001, Office of the Inspector General,
Social Security Administration (December 2002).
levels. For example, a former DDS director we spoke with explained that
directors have had difficulties planning for future needs because of
discrepancies between hiring levels authorized by SSA and those approved
by their states. One DDS director told us that after working for two years
to obtain state approval to hire additional examiners initially authorized
by SSA, the DDS lost permission from SSA to fill the positions.
o Directors' concern that SSA does not incorporate DDS workforce plans
when making resource decisions. When asked in our survey what makes
long-term planning more difficult, over two-thirds of DDS directors
reported their concern that SSA does not incorporate the DDSs' workforce
plans when making resource decisions. Moreover, 45 DDS directors responded
that they had only some or no opportunity to factor future DDS human
capital needs into SSA's spending projections beyond the upcoming fiscal
year. Several DDS officials explained in interviews that long-term
planning seemed futile if SSA was not going to use the results of the DDS
planning efforts when making resource decisions. SSA officials, however,
told us that they consider input from the DDSs related to funding
decisions on a regular basis. SSA officials explained that the agency must
disperse funds within its own overall budget allocation, and this often
does not allow for meeting all DDS funding requests.
o Uncertainty about future resource levels from SSA and stateimposed
hiring restrictions or separation incentives. Over threequarters of all
DDS directors we surveyed reported that long-term planning is made more
difficult by uncertainty about future resource levels from SSA, as well as
uncertainty about resources needed to implement major changes in SSA
policies, procedures, and systems. In addition, onehalf of DDS directors
surveyed said that DDS long-term workforce planning was made more
difficult by uncertainty about state-imposed hiring restrictions or
separation incentives.
o Insufficient time to attend to future problems and insufficient data
for workforce planning. Three-quarters of all directors surveyed said that
they had insufficient time to attend to future problems because of the
need to focus on current human capital challenges. One DDS director said
in an interview that the day-to-day demands of directors' jobs, such as
managing high caseloads and hiring and training new examiners, often
prevent them from planning for future workforce needs. Other DDS directors
and officials told us that, when planning does take place, it is generally
crisis-driven and reactive rather than long-term and strategic. In
addition, over half of the directors reported in our survey that
insufficient data for workforce planning makes DDS long-term workforce
planning more difficult. Moreover, DDSs that do not engage in workforce
planning
SSA's Workforce Efforts Have Not Sufficiently Addressed Present and Future
Human Capital Challenges in the DDSs
longer-term than one year were more likely than other DDSs surveyed to
cite insufficient data and planning tools, such as statistical software
and information technology systems, as challenges that make long-term
workforce planning more difficult.
SSA's workforce efforts have not sufficiently addressed both present and
future DDS workforce challenges. Neither SSA's strategic plan, nor its
annual performance plan, nor its workforce plan adequately addresses the
human capital challenges facing the DDSs. In addition, in our survey, DDS
directors reported being dissatisfied with the adequacy of the training
that SSA provides to the DDSs. Beyond training, SSA has not consistently
provided other human capital assistance across the DDSs and faces
difficulties negotiating human capital changes, such as increases in
examiner salaries, with state governments. Finally, SSA has not used the
statutory authority it has to set standards for the DDS workforce.
SSA's Strategic and Workforce Plans Do Not Adequately Address DDS Human
Capital Challenges
SSA has not developed a nationwide strategic workforce plan that addresses
present and future human capital challenges in the DDSs. As shown in
figure 5, SSA does recognize a need to have higher-skilled and
better-compensated DDS employees. In addition, SSA's strategic plan for
2003-2008 places a high priority on improving the accuracy and the
timeliness of the disability decision-making process. While accomplishment
of this objective depends to a great extent on the DDS workforce, the plan
cautions that the DDSs, like SSA, will face a continuing challenge of
hiring and retaining a highly skilled workforce in a competitive job
market. Nevertheless, SSA's strategic plan, as well as the agency's annual
performance plan and workforce plan, are all largely silent on the means
and strategies the agency will use to recruit, develop, and retain a
high-performing DDS workforce, even though the Government Performance and
Results Act now requires agencies to include in their annual performance
plans a description of the human capital strategies needed to meet their
strategic goals.
Figure 5: Means and Strategies Addressing the DDS Workforces Are Largely
Absent from SSA's Strategic and Workforce Plans
Source: GAO analysis of SSA documentation.
aSSA officials said in interviews that SSA is no longer pursuing two
proposed strategies for improving training for disability examiners.
Absent any strategic workforce plan addressing DDS employees, SSA does not
use data that it collects on the DDS workforces in a strategic manner.
While SSA routinely gathers certain DDS employee data-such as salaries,
turnover rates, and the number of new hires and experienced disability
examiners-the agency primarily uses these data in connection with its
annual budget process. Moreover, SSA does not regularly collect many other
key indicators of DDS human capital performance, such as gaps in basic
skills relative to specific competencies, despite SSA's acknowledging the
importance of investing in and retaining a skilled DDS workforce in the
face of an anticipated retirement wave.
When we asked SSA officials how workforce planning for the DDSs was
conducted, they said that they consider DDS workforce matters to be, in
general, a state government and DDS responsibility, particularly in light
of the variations in state personnel systems and political concerns. One
of these officials explained that SSA takes DDS workforce needs into
account within SSA's annual budget process and through the consultation
that occurs between the DDSs and SSA's regional offices. The regional
office staff-and in particular, the disability program administrators
assigned as SSA's liaisons with each DDS-are responsible for providing
human capital assistance to the DDSs as needed. However, as noted earlier,
SSA's annual budget process lacks key components of comprehensive,
long-term workforce planning. In addition, officials we interviewed in one
regional office said that they lacked the tools and the time to assist the
DDSs with long-term strategic workforce planning, and SSA officials we
spoke with questioned whether disability program administrators were
sufficiently trained in strategic workforce planning techniques.
Several regional office and former and current DDS officials we spoke with
expressed a desire for greater SSA leadership in terms of long-term
strategic workforce planning focusing on DDS human capital challenges. One
of these officials observed that SSA is already active in a variety of DDS
human capital areas-such as determining appropriate DDS staffing levels,
imposing a nationwide DDS hiring freeze, and providing national human
capital guidance for implementing the electronic disability initiative-and
could appropriately assist with strategic workforce planning.
Directors Expressed DDS directors are dissatisfied with the adequacy of
SSA-provided training. Dissatisfaction with the Specifically, when we
asked DDS directors whether they found SSA's Adequacy of SSA's Training
training to be adequate to prepare examiners to be proficient in the
claims for the DDSs process, half or more of the directors responded that
they were
dissatisfied with the adequacy of SSA's training in each of the following
knowledge and skill areas:58
o medical knowledge about body systems (32 DDSs),
o specific knowledge about the disability program (30 DDSs),
o assessment of vocational factors (29 DDSs),
o basic claim development techniques (29 DDSs),
o evaluation of the weight to be given to medical evidence from a
treating physician (28 DDSs),
o updates on policies and procedures (28 DDSs),
o assessment of childhood disabilities (28 DDSs),
o assessment of an applicant's symptoms and evaluation of the
credibility of medical and other evidence (27 DDSs), and
o use of computers and technologies (26 DDSs).
Moreover, nearly half of the directors (25 DDSs) reported that they were
dissatisfied with SSA's basic training materials for new disability
examiners, and over one-third (19 DDSs) reported dissatisfaction with
training on the assessment and documentation of an applicant's ability to
function.
In addition, nearly all DDS directors (49) reported that they had adapted
(or wanted to adapt) SSA's training in one or more of these knowledge and
skill areas to make it adequate.59 When we asked these DDS directors why
they had adapted or wanted to adapt SSA's training, more than half cited
each of the following reasons pertaining to the quality, completeness, and
timeliness of SSA's training approach as contributing factors:60
58In the survey, we explained that SSA's training included written
materials, interactive video training technology, and videos. The survey
question covered new examiner basic training and other training that SSA
provides beyond basic training.
59The survey asked whether the DDS: (1) had adapted SSA training to make
it adequate, and had offered this training in the past 24 months; or (2)
planned to-or wanted to but was unable to-adapt SSA training to make it
adequate and offer it in the next 12 months. Adapting training could
involve editing or revising SSA's training materials, not using some of
the materials, or offering a substitute course.
60We categorized factors as reasons for adapting SSA's training if DDS
directors deemed them to be a moderately to very important reason. Beyond
issues pertaining to quality, completeness, and timeliness of SSA's
training, DDS directors who adapted SSA's training cited operating
procedures and training preferences that are unique to the DDS as reasons
for adapting SSA's training. The question asked about procedures other
than those that respond to court decisions and laws.
o Training is too conceptual and not sufficiently linked to day-to-day
case processing (44 DDSs).
o Training provides insufficient opportunity to interact with the
trainer (40 DDSs).
o Training provides insufficient opportunity to practice skills taught
(38 DDSs).
o Certain types of training over-rely on the interactive video training
technology (37 DDSs).
o Training content is incomplete (32 DDSs).
o Training presenters lack effective presentation skills (31 DDSs).
o Training lacks sufficient written materials, such as handouts and desk
aids (30 DDSs).
o Training is delivered too early or too late (28 DDSs).
In interviews, DDS officials expressed some particular concerns about
video training. Some DDS officials told us that, because presenters lack
sufficient hands-on case-processing experience, the training that SSA
provided through its video training technology was too theoretical. In
addition, other DDS officials described SSA's video training technology as
not allowing sufficient opportunity for clarification and follow-up with
the presenter. Some officials explained that technical problems with the
technology impeded interaction with the trainers. For example, they told
us that, while staff are supposed to be able to use a keypad to call in
and question the presenters during a class broadcast, it is often
difficult to obtain access to the presenters. Further, some former DDS
officials said that SSA applies its video training technology to many
types of instructional needs for which it may not be appropriate. Yet, in
our prior work, we have noted that, to be effective, the training method
used needs to be tailored to the nature of the training content.61
We asked SSA officials we spoke with to comment on the DDS directors'
views on the quality of SSA-provided training. While an SSA official
explained that the video training technology helps SSA to provide
consistent training across the entire country quickly, she acknowledged
that the training is sometimes too general and explained that SSA is
attempting to improve the presentations. SSA officials also told us that
they tap the expertise of the DDS community, among other agency
61U.S. General Accounting Office, Human Capital: A Guide for Assessing
Strategic Training and Development Efforts in the Federal Government,
GAO-03-893G (Washington, D.C.: July 2003).
components, to help develop and improve training materials and identify
training needs.
However, despite such efforts, nearly 85 percent of all DDS directors
reported in our survey that they would be able to spend fewer resources
adapting SSA's training for use in their individual DDSs if SSA were to
improve the quality, completeness, and timeliness of its training.62 Our
survey data show that, in fiscal year 2002, the 52 DDSs used, in total,
the equivalent of nearly 150 full-time DDS employees in preparing and
delivering examiner training related to disability claims processing.
Moreover, staff resources devoted to training may constitute a significant
portion of total examiner staff in some DDSs. To illustrate, the director
of one DDS with 83 disability examiners reported in our survey using the
equivalent of about 12 full-time employees in fiscal year 2002 to prepare
and deliver examiner training. SSA and DDS officials explained in
interviews that, while some larger DDSs have staff who are dedicated
solely to training, smaller DDSs generally use their most experienced, and
hence most productive, examiners to prepare training and deliver it to
their staff.
SSA Has Not Consistently Provided Other Human Capital Assistance across the
DDSs and Faces Difficulties Negotiating Key Human Capital Issues with State
Governments
Beyond training, information from our survey and interviews shows that SSA
has not consistently provided other human capital assistance across the
DDSs and faces difficulties negotiating human capital changes, such as
increases in examiner salaries, with state governments. SSA provides many
types of human capital assistance to the DDSs through its regional offices
and its headquarters. For example, SSA regional office officials we
interviewed explained that they have attempted to persuade state
governments to exempt examiners from state hiring restrictions and to
reclassify DDS examiner positions and increase examiner salaries in light
of new responsibilities. In addition to the assistance provided by
regional offices, SSA officials said that SSA headquarters has provided
human capital assistance to the DDSs, such as sponsoring a study that
identified the knowledge, skills, and abilities required for the
disability examiner position, among other positions.
But in our survey of the DDS directors who said they wanted particular
types of human capital assistance from SSA headquarters and its regions,
62We included in this calculation those DDS directors who responded that
they would be able to spend fewer resources in adapting SSA's training
from some to a very great extent.
more than half said that they had not received assistance in each of the
following areas:63
o help with regular nationwide surveys of examiners' issues and concerns
(32 out of 36 DDSs),
o help in negotiating increases in examiner salaries with state
government officials (24 out of 36 DDSs),
o guidance on roles and responsibilities for examiners with enhanced
responsibilities (22 out of 42 DDSs),
o help in designing training and developing training materials for
examiners with enhanced responsibilities and the staff who will be
supporting them (22 out of 42 DDSs),
o help with workforce planning, including projecting turnover and
developing succession plans (21 out of 31 DDSs),
o guidance on how to determine which examiners have sufficient skills to
take on enhanced examiner responsibilities (15 out of 20 DDSs), and
o help in identifying gaps in examiner skills (15 out of 21 DDSs).
In interviews, some DDS directors specifically cited surveys of examiners'
issues and concerns as an area with which they wanted assistance. They
explained that such surveys could be used to identify and share DDS best
practices in managing staff, including how different DDSs manage examiner
caseloads and train examiners. One director noted that information on DDS
best practices in human capital management is not currently available and
that only SSA can "survey the landscape nationally." Moreover, a former
DDS director explained that directors view nationwide surveys as a means
for communicating to SSA their human capital challenges.
We also asked DDS directors about the effectiveness of various types of
human capital assistance that they did receive from SSA and its regional
offices, including assistance in negotiating human capital changes with
state governments. We found that more than half of the DDS directors who
received assistance said that such assistance was of limited effectiveness
in each of the following areas:64
63We categorized these types of assistance as ones that DDS directors
wanted if the directors said that they wanted them from some to a very
great extent.
64We categorized an area of assistance as being of limited effectiveness
if DDS directors deemed it to be moderately to not effective.
o helping project trends in the nature of the disability workload (24
out of 34 DDSs);
o assisting in negotiating easing of state restrictions (e.g., on hiring
and travel) with the state government (19 out of 24 DDSs);
o providing guidance on roles and responsibilities for examiners with
enhanced responsibilities (18 out of 26 DDSs);
o helping to design training and developing training materials for
examiners with enhanced responsibilities and the staff who will be
supporting them (16 out of 22 DDSs);
o assisting in allowing DDSs to reduce the total caseload level for
examiners taking on enhanced responsibilities (13 out of 24 DDSs);
o helping in assessing readiness for transition to an examiner role with
enhanced responsibilities (12 out of 14 DDSs);
o helping with workforce planning, including projecting separations and
developing succession plans (11 out of 13 DDSs); and
o providing help in negotiating increases in examiner salaries with the
state government (11 out of 16 DDSs).
Regional office officials and DDS directors explained in interviews that
the effectiveness of SSA and its regional offices in helping the DDSs
negotiate human capital changes with the states can be limited by such
factors as state budget problems, political concerns, and personnel rules.
For example, some officials said in interviews that state budget crises
had created political pressure to limit or prevent increases in state
employee salaries. Other DDS directors told us that state officials were
concerned that raising examiner salaries would prompt increases in the
salaries of other state employees, such as employees within the same job
classification. In addition, although 19 DDS directors reported in our
survey that DDS salary levels are open to negotiation with unions, some
regional office officials said in interviews that obtaining salary
increases for disability examiners apart from other state employees
covered by union contracts could be difficult.
In light of such difficulties in negotiating human capital changes with
the states, one key regional office official we spoke to said that "all
the regional office can do is cajole" the state governments about DDS
human capital issues, since under the regulations the authority in this
arena generally remains with the states. Similarly, another top regional
official cautioned that, while the regional office tries to help the DDSs
address the human capital challenges they face, it is difficult to do so.
This official stated that the federal-state relationship is "unwieldy,"
explaining that it is easier for state governments to apply state human
capital policies-such as hiring freezes-to all state personnel than to
make exceptions for DDS
employees, despite SSA's full reimbursement of DDS expenses. The official
said that, because the regional office must continually educate and
explain to each newly elected state governor's administration that the DDS
is federally funded, the regional office is seeking ways to make such
education more effective and less labor-intensive. Indeed, current and
former DDS directors we spoke with said that outreach from SSA to state
governors through such national groups as the National Governors
Association (NGA) is needed to foster an appreciation of the importance of
a highly qualified DDS workforce to improving service to disability
claimants.65
SSA Has Not Used Its Statutory Authority to Address DDS Workforce Needs
SSA has not used the statutory authority it has to set standards for the
DDS workforce. Although amendments to the Social Security Act in 1980
granted SSA the authority to issue regulations to ensure effective and
uniform administration of the national disability programs, SSA has not
used this authority to address wide variations in staff salaries,
entry-level qualification requirements, and training for different DDSs.
The Social Security Advisory Board, in 2001, called these variations
potential contributors to inconsistencies in SSA's disability decisions.66
Emphasizing that the disability programs are national in scope and that
equal treatment for all claimants wherever they reside is essential, the
Advisory Board recommended that SSA revise its regulations to establish
guidelines for salaries, entry-level qualification requirements, training,
and other factors
65While some regional office officials said that they interact at the
governors' level in the individual states and, in at least one instance
according to SSA, with a regional governors' association, we could find,
to date, no record from the NGA of discussions or forums in recent years
focusing on the topic of the DDS workforce issues under the federal-state
relationship regarding SSA's disability programs. We asked staff of the
NGA whether, during the last five years, NGA staff had met with
representatives of SSA's Office of the Commissioner or received
communications from SSA on issues related to the DDSs and their employees.
We also asked whether issues related to SSA's disability decision-making
had appeared on the agenda of NGA official meetings over the last five
years.
66Social Security Advisory Board, Disability Decision Making: Data and
Materials (Washington, D.C.: January 2001).
affecting the ability of DDS staff to make quality and timely decisions.67
SSA has not acted on the Advisory Board's recommendations, however.
While SSA officials acknowledged in interviews that the agency has the
authority to establish uniform minimum human capital standards, they told
us that the agency has chosen not to exercise this authority because of
concerns about the difficulties such actions could raise in terms of the
federal-state relationship. For example, they explained that requiring
uniform human capital standards might be perceived by some states as
unwelcome federal interference in state operations and could raise the
prospect of states withdrawing their participation in making disability
determinations for the disability programs. Indeed, in a prior report, we
noted that, in the late 1970s, SSA could get only 21 of the 54 DDSs to
revise their operating agreements with SSA, partly because the states
regarded the revisions as infringements on their traditional prerogatives.
The revised agreements required DDSs to comply with guidelines issued by
SSA with regard to personnel matters, among other administrative
requirements.68
Many DDS and SSA officials we spoke with acknowledged the difficulties
that would be involved with implementing uniform standards for DDS
personnel. Nevertheless, the National Council of Disability Determination
Directors and several DDS and SSA officials we interviewed (including some
top regional office officials) expressed the view that uniform standards
for DDS employees could help address the human capital challenges
confronting the DDSs.69 Some referred to the vocational
67Social Security Advisory Board, Charting the Future of Social Security's
Disability Programs: The Need for Fundamental Change (Washington, D.C.:
January 2001). The Advisory Board also recommended that regulations be
revised to ensure that state hiring freezes would not apply to the DDS
workforce. In making its recommendations, the Advisory Board stated that
if any state withdrew from the DDS program, the agency should be prepared
to take over that responsibility from the state.
68U.S. General Accounting Office, Current Status of the Federal/State
Arrangement for Administering the Social Security Disability Programs,
GAO/HRD-85-71 (Washington, D.C.: September 30, 1985).
69In questions and answers submitted for the record to the Subcommittee on
Social Security, Committee on Ways and Means, House of Representatives,
the National Council of Disability Determination Directors stated that
they agreed with the Social Security Advisory Board's recommendation that
SSA's regulations be revised to require states to follow specific federal
guidelines pertaining to human capital management in the DDSs. The council
submitted these questions and answers on August 29, 2002, as follow-up to
their June 11, 2002, testimony.
Conclusions
rehabilitation program administered by the Department of Education's
Rehabilitation Services Administration in partnership with the states as
an example of a federal-state program that has set qualification standards
for state employees.70
DDS disability examiners are essential to SSA's meeting its strategic goal
for better serving disability claimants by making the right decision in
the disability process as early as possible. Yet SSA has not developed a
nationwide strategic workforce plan to address the very personnel who will
be crucial to meeting that goal. The immediate challenges that DDS
directors face today in maintaining and improving the examiner workforce
are unlikely to lessen with time and will likely have even more severe
consequences as the DDSs confront increasing numbers of applicants for
disability benefits. The critical task of making disability decisions is
complex, requiring strong analytical skills and considerable expertise,
and it will become even more demanding with the implementation of the
Commissioner's new long-term improvement strategy and the projected growth
in workload. Moreover, because SSA has not set uniform minimum
qualifications for examiners, some DDSs may find it difficult to justify
an appropriate job classification and level of compensation needed to
recruit and retain these critical employees.
Without a plan to develop and maintain a skilled workforce-as well as
measures to establish uniform minimum qualifications for examiners, close
critical skill gaps, and improve training-SSA's ability to provide
high-quality service to disability claimants could be further weakened by
gaps in critical competency areas and the loss of experienced DDS
examiners due to high turnover. As vacancies are filled by new hires and
trainees who need one to two years to become fully productive, the DDSs
will likely have difficulty maintaining skill levels and successfully
coping with expected high growth in workloads. The combination of
decreased overall skill levels and increased workload could make the work
70The Rehabilitation Act requires state vocational rehabilitation agencies
to establish personnel standards for rehabilitation counselors that are
consistent with the degree standards of the highest licensing,
certification, or registration requirement in the state, or the degree
standards of the national certification program. As a result, vocational
rehabilitation counselors in most states must hold a master's degree in
rehabilitation counseling or certain comparable qualifications. A few
states require a bachelor's degree. States must report annually on the
number of rehabilitation counselors who meet their established standards
and on their plans to train counselors who do not meet the standards.
environment even more stressful, further increasing turnover. This
spiraling effect, if not addressed, could undermine the agency's efforts
to ensure that disability decisions are made accurately, consistently, and
in a timely manner.
A strategic workforce plan is even more critical to the Commissioner's
long-term strategy for improving the disability claims process and her
ability to bring SSA's approach to disability decision-making in line with
the current state of science, medicine, technology, and labor market
conditions. Failure to look ahead and plan to ensure that the appropriate
mix of skills and capabilities are available when and where needed could
obstruct SSA's progress as it seeks to fundamentally restructure its
disability programs to improve the accuracy and timeliness of decisions
and focus on identifying and enhancing claimants' productive capacities.
Given such a profound transition in an environment of constrained
resources, SSA must be able to plan effectively if it is to anticipate how
its requirements for DDS staff will change and be convincing about the
need for increased human capital investments.
It will not be simple to implement a nationwide strategic workforce plan
for a program that is administered in partnership with the states.
Negotiating changes in state human capital policies, such as restrictive
job classifications or hiring limitations, will be difficult. Improving
the content and delivery of SSA-provided training and closing gaps in
examiner skills across the DDSs will be challenging and potentially
costly. Establishing uniform minimum qualifications for examiners
throughout the DDSs will also be a difficult task, requiring delicate and
time-consuming discussions with some state governments. However, despite
the acknowledged difficulties, SSA cannot afford to forgo developing an
overarching, guiding framework to use as a basis for making short- and
long-term human capital decisions for the DDSs. As an agency with
fiduciary responsibility for administering multibillion dollar disability
programs that are nationwide in scope, SSA has an obligation to take a
leadership role in planning- together with its state partners-to address
both the immediate and future workforce needs in the DDSs.
Recommendations to We recommend that SSA take the following actions:
the Commissioner of 1. Develop a nationwide strategic workforce plan that
addresses present
SSA and future human capital challenges in the DDSs. This plan should
enable SSA to identify the key actions needed to deal with immediate DDS
problems with recruiting and hiring, training, retention, and
succession planning in support of SSA's strategic plan. It should
additionally enable SSA to anticipate and plan for the future workforce
that will be needed as SSA modernizes and fundamentally transforms its
approach to disability decision-making. To develop and implement this
comprehensive workforce plan, SSA should work in partnership with the DDSs
and their parent agencies. As part of the planning process, SSA should:
a. Identify a small number of key DDS indicators of human capital
performance, including recruiting and hiring measures, level of stress in
the workplace, training needs, and turnover. SSA should establish
standards for acceptable performance on these indicators, routinely
collect and analyze the data to identify trends, and use this information
to guide decisions regarding future DDS workforce needs and the strategies
to meet them.
b. Provide necessary tools and technical assistance to the DDSs to enable
them to conduct long-term workforce planning. SSA should ensure that SSA
staff responsible for providing this assistance are well trained in the
tenets of workforce planning.
c. Require each DDS to develop its own long-term workforce plan that is
linked to the nationwide long-term DDS workforce plan. SSA should work in
partnership with the DDSs and their parent agencies to develop these
plans.
d. Establish an ongoing program of outreach from SSA's leadership to state
governors and national associations of state government officials to
discuss the benefits and challenges of the federal-state relationship and
encourage them to address human capital challenges identified by DDS
directors, such as salary limits and hiring freezes.
e. Link performance expectations of appropriate SSA executives to their
efforts in accomplishing goals and objectives of the workforce plan.
2. Issue regulations that establish uniform minimum qualifications for
new disability examiners. The minimum qualifications should be based on an
analysis of the position that identifies the examiner's responsibilities
and the minimum knowledge, skills, and competencies necessary to
adequately perform them. The minimum qualifications for the examiner's
position should take into account any changes in the complexity of the
tasks required for this position stemming from the Commissioner's new
long-term strategy.
3. Work with DDSs to close the gaps between current examiner skills and
required job skills. To do so, SSA should work with the DDSs to:
a. analyze examiner training needs, using as a foundation the analysis of
job responsibilities and related minimum knowledge, skills, and
competencies recommended above;
b. improve training content and delivery to meet these needs, basing such
efforts on analyses of training content and appropriateness of training
delivery methods; and
c. develop performance measures to track effectiveness of these
improvements to training.
Agency Comments
and Our Evaluation
We provided a draft of this report to SSA for comment. SSA generally
agreed with the intent of the recommendations in the report but stated
that the report does not fairly address or adequately discuss the many
sides of the DDS human capital management issues. In particular, SSA
criticized some of our study's methods and expressed concern that we did
not sufficiently acknowledge the difficulties involved in making changes
to the federal-state relationship. We continue to believe, however, that
the report presents a fair and balanced portrayal of the multifaceted
issue of human capital management in the DDSs.
Generally agreeing with the intent of our recommendations, SSA said it
would consider incorporating a nationwide strategic workforce plan for the
DDSs into its current strategy to improve the disability determination
process. To do so will be essential, since the Government Performance and
Results Act now requires agencies to report annually, as we noted in our
report, on human capital strategies needed to meet their strategic goals.
Regarding our recommendation on improving training, SSA said that it would
continue ongoing efforts to improve examiner job skills. Results from our
survey of DDS directors, however, revealed gaps in critical examiner
knowledge and skills and a large proportion of DDS directors who would be
able to spend fewer resources on adapting SSA's training if SSA were to
improve the quality, completeness, and timeliness of its training. Given
such results, our report recommended that SSA go beyond its current
efforts and base its training improvement initiatives on a systematic
assessment of the examiner's job responsibilities and related knowledge,
skills, and competencies. In terms of our recommendation on outreach, SSA
said that it is already conducting an outreach program to state officials
and that it intends to engage in discussions with the NGA on
DDS issues. While we noted efforts on the part of SSA's regional offices
to negotiate human capital changes with state governments, we maintain
that SSA's outreach program requires the sustained attention of SSA's
leadership at the national level. SSA's expressed intent to pursue such
discussions with the NGA is therefore a step in the right direction.
SSA criticized some of our study methods, saying that we relied heavily on
opinions of DDS directors and used rather leading and ambiguous survey
questions. In terms of survey design, we surveyed DDS directors because
their first-hand experiences make them some of the most knowledgeable
respondents about human capital challenges experienced in their
organizations. In addition, our survey was developed in accordance with
GAO's guidance on survey design and development,71 including extensive
pretesting with current and former DDS directors to identify potential
question bias and to clarify wording. We also gave SSA disability program
officials, on two occasions, the opportunity to review and comment on the
survey. Following the second review, the SSA official coordinating the
review said that, while some of the questions might be difficult for the
DDS directors to answer, we should go ahead with the survey as it stood.
The official did not refer to any bias in the survey questions. SSA also
was concerned that we administered the survey at a time of budget
constraint that SSA said influenced some of the directors' responses. Our
survey, however, reflects ongoing challenges facing the DDSs and was not
limited to the particular circumstances of 2003. Further, our study
findings did not rest solely on the opinions expressed in our survey of
DDS directors. In addition to the survey, we gathered information through
interviews with several other sources as well, including officials at two
DDSs, three SSA regional offices, and SSA headquarters; officials of the
National Council of Disability Determination Directors and the National
Association of Disability Examiners; and staff of the Social Security
Advisory Board. We also reviewed pertinent laws, regulations, and
procedures, and obtained and analyzed human capital data from several
sources.
SSA was also concerned that we did not sufficiently acknowledge the
attitudes of the states toward modifying federal regulations to establish
uniform human capital standards and the complexities involved in such
regulatory changes, such as the problems that SSA says it would face if a
large state declined to make disability determinations and transferred
71U.S. General Accounting Office, Developing and Using Questionnaires,
GAO/PEMD-10.1.7 (Washington, D.C.: October 1993).
these responsibilities to the federal government. We acknowledged in our
report the difficulties SSA has encountered in convincing the DDSs to
comply with SSA guidelines on personnel issues, due in part to the states'
perceptions of infringements on traditional state responsibilities. We
also
stressed that establishing uniform minimum qualifications for examiners
will be difficult, requiring delicate and time-consuming discussions with
some state governments. But we maintain that, despite the difficulties,
SSA is obligated to address the human capital challenges facing the DDSs.
An outreach program involving SSA's leadership and a close working
partnership among SSA, the DDSs, and their state parent agencies will be
vital to help ensure the success of SSA's efforts.
In addition, SSA expressed a number of other concerns about the draft
report. These concerns, as well as our comments on them, are provided in
full in appendix IV.
Copies of this report are being sent to the Commissioner of SSA,
appropriate congressional committees, and other interested parties. The
report is also available at no charge on GAO's Web site at
http://www.gao.gov. If you have any questions about this report, please
contact me at (202) 512-7215. Other contacts and staff acknowledgments
are listed in appendix V.
Sincerely yours,
Robert E. Robertson
Director, Education, Workforce,
and Income Security Issues
Appendix I: Scope and Methods
Survey of Disability Determination Service Offices
The following describes the methods we used to survey Disability
Determination Service (DDS) offices as well as the methods we used to
compare some of our survey data with data from other sources.
We surveyed all state DDS directors as well as the DDS directors in the
District of Columbia, Puerto Rico, and the federal DDS office. We did not
survey directors in Guam and the South Carolina Office for the Blind
because these offices each had only one disability examiner. We mailed
surveys to 53 DDS directors and received responses from all of them.
However, because most of the questions in our survey do not apply to the
federal DDS, we reported results for 52 DDSs. Our survey included
questions about long-term workforce planning, recruiting and hiring,
compensation, training and development, and retention of disability
examiners.1 The survey results in this report represent the views of the
DDS directors and do not necessarily represent the views of examiners or
other DDS staff or the views of Social Security Administration (SSA)
officials.
The practical difficulties of conducting any survey introduce various
types of errors related to survey responses. For example, differences in
how a particular question is interpreted and differences in the sources of
information available to respondents can be sources of error. In addition,
respondents might not be uniformly conscientious in expressing their views
or they may be influenced by concerns about how their answers might be
viewed by GAO, SSA, or the public. We included steps in both the data
collection and analysis stages for the purpose of minimizing such errors.
For example, to address differences in how questions were interpreted, we
asked two members of the Social Security Advisory Board, as well as
current and past officers of the National Council of Disability
Determination Directors and the National Association of Disability
Examiners, to review and critique the survey questions before pretesting.
SSA disability program officials also reviewed our survey on two
occasions. In addition, we pretested the survey with four former DDS
directors and four current DDS directors. We modified the survey questions
based on the results of these pretests.
1While we have focused this report specifically on disability examiners,
other positions employed by the DDSs, such as medical consultants and
vocational experts, are also critical to the disability determination
process.
Appendix I: Scope and Methods
Analysis of Data from Our Survey and Other Sources
Because we conducted our survey while 20 DDSs were testing the feasibility
of implementing an examiner position with enhanced responsibilities, we
tailored a few of the survey questions to be relevant for those DDSs
testing these enhanced positions as well as for those not testing such
positions. We also tailored questions for California's survey, which had
separate offices testing and not testing the enhanced examiner position.
In addition, we tailored questions for the survey that went to the federal
DDS.
To address possible director concerns about how their answers might be
viewed, we stated in the introduction to the survey that their responses
would be reported in summary form only, without being individually
identified, and that their responses would not be released unless
requested by a member of Congress (see appendix II for a copy of our
survey).
When we analyzed the data from our survey, where possible, we checked
survey answers involving numbers and percentages to ensure they summed
correctly. When we identified a discrepancy, we contacted the relevant DDS
director to resolve the discrepancy.2
We wanted to determine how turnover rates (overall and for new hires) for
DDS examiners compared with those for selected groups of federal
employees. To do this, we compared the turnover rate of DDS examiners with
that of Veterans Benefits Administration (VBA) examiners, SSA employees,
and all federal employees. VBA examiners were selected because they
perform duties similar to DDS examiners, such as developing claims using
medical and disability program knowledge. We compared DDS examiner
turnover rates with SSA turnover rates because SSA fully funds the DDSs to
achieve its disability program mission. The federal employee turnover rate
was selected as a general baseline.3
We used data from the Office of Personnel Management's (OPM) Central
Personnel Data File (CPDF) to calculate turnover rates for VBA examiners,
SSA employees, and all federal employees.4 We counted how
2We also recorded all notes and comments from respondents that qualified
their responses.
3We were unable to obtain comprehensive turnover data for private insurers
who employ disability examiners.
4VBA disability examiners were identified by using their unique
occupational code.
Appendix I: Scope and Methods
many permanent employees in each group left their position in each of
fiscal years 2000, 2001, and 2002. For VBA examiners and SSA employees,
transfers to other agencies were counted as separations. For all federal
employees, only separations from federal service were counted as
separations. To calculate overall turnover, we divided the number
separated each year by the average of the number of staff (which we
obtained by averaging the number of staff at the beginning of the fiscal
year and the number of staff at the end of the fiscal year).5
We also calculated a new hire turnover rate. We defined a new hire
separation as a separation of an employee hired in one fiscal year who
left before the end of the following fiscal year (for example, hired in
fiscal year 2000 and left before the end of fiscal year 2001). To
determine the turnover rate for new hires, we counted all career and
career conditional appointments for each fiscal year 2000 and 2001. We
then determined how many of these separated before the end of the
following fiscal year and divided this by the number of new hires in the
prior fiscal year. We also calculated turnover rates for DDS examiners
using the same formulas.
We also compared DDS examiner salaries with VBA examiner salaries. We
analyzed data from OPM's CPDF to calculate the average base salary,
including locality adjustments, for VBA examiners state by state. We
divided each DDS's average examiner salary by the average VBA examiner
salary for each state, the District of Columbia, and Puerto Rico. This
resulted in a measure of DDS average salary relative to average VBA
examiner salaries for each location.
When we analyzed salaries of examiners who left DDSs to accept higher
salaries in federal agencies, directors of two DDSs provided information
on both the salaries of these examiners while they were employed by the
DDSs, and on the federal General Schedule (GS) grade levels for their new
SSA positions. To determine SSA salaries, we used the 2002 federal
government GS pay scale, including locality adjustments. For cases in
which the directors provided us with two possible SSA grade levels, we
used the first step of the lower grade in our analysis. Three of these
disability examiners also served as quality assurance reviewers, hearing
officers, or trainers while employed in their DDS. Positions accepted at
SSA by the departing examiners included regional office disability quality
5The results of these calculations were multiplied by 100 to express
turnover rates as percentages.
Appendix I: Scope and Methods
branch analyst, regional office program specialist, and field office
claims representative, as well as posts in the federal DDS.
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
We sent this version of the survey to the DDSs that were not testing the
single decision-maker (SDM) position. We have annotated this version to
indicate how the survey that we sent to the DDSs that were testing the SDM
position differed from this version.
In addition, the survey we sent to the California DDS contained questions
both for DDSs that were testing the SDM position, and for those not
testing the SDM position, because some of the California DDS branches were
testing the SDM, and some were not.
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
In the survey sent to DDSs that were testing the SDM position, the
definitions and questions referred, where appropriate, to both SDMs as
well as disability examiners (DEs), so that the survey questions would
cover all examiners.
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
In the survey sent to DDSs that were testing the SDM position, Question 17
referred to "current SDMs (excluding trainees) who need additional
mentoring and/or refresher training to successfully perform the SDM role."
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
In the survey sent to DDSs that were testing the SDM position, Question 18
referred to "obstacles to your SDMs receiving needed additional mentoring
and/or refresher training." The question asked: "To what extent, if any,
is each of the following an obstacle to your current SDMs (excluding
trainees) receiving, over the next two years, additional mentoring and/or
refresher training needed to successfully perform the SDM role?"
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
In the survey sent to DDSs that were testing the SDM position, Question 22
was phrased: "To what extent, if any, were the following factors a
challenge for your DDS in making the transition to the SDM position?"
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Question 23 was not included in the survey that was sent to the DDSs that
were testing the SDM position, since those DDSs had already made the
transition to the SDM position.
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
In the survey sent to the DDSs that were testing the SDM position, the
"Yes/No" part of Question 24 was not included. Thus, the second part of
Question 24 was asked generally of all DDSs testing the SDM position.
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
In the survey sent to the DDSs that were testing the SDM, Part II,
Question 1, did not indicate "N/A" in row b.
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
In the survey sent to the DDSs that were testing the SDM, Part II,
Question 3, did not indicate "N/A" in row b.
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
In the survey sent to the DDSs that were testing the SDM, Part II,
Question 9, row a indicated "DEs and/or SDMs."
In the survey sent to the DDSs that were testing the SDM, Part II,
Question 11, row a indicated "DEs and/or SDMs."
Appendix II: Survey of DDS Directors' Views on Human Capital Challenges
This question was only included in the survey sent to the DDSs that were
testing the SDM position. It was not included in the survey sent to the
DDSs that were not testing the SDM position.
Appendix III: Related GAO Reports
Modernizing Federal Social Security Disability: Reviews of Beneficiaries'
Disability Status Require Continued Attention to Achieve Timeliness and
Cost-Disability Programs Effectiveness. GAO-03-662. Washington, D.C.: July
24, 2003.
High-Risk Series: An Update. GAO-03-119. Washington, D.C.: January 1,
2003.
SSA Disability: Other Programs May Provide Lessons for Improving
Return-to-Work Efforts. GAO-01-153. Washington, D.C.: January 12, 2001.
Social Security Disability Insurance: Multiple Factors Affect
Beneficiaries' Ability to Return to Work. GAO/HEHS-98-39. Washington,
D.C.: January 12, 1998.
SSA Disability: Return-to-Work Strategies from Other Systems May Improve
Federal Programs. GAO/HEHS-96-133. Washington, D.C.: July 11, 1996.
SSA Disability: Program Redesign Necessary to Encourage Return to Work.
GAO/HEHS-96-62. Washington, D.C.: April 24, 1996.
General Human Human Capital: Opportunities to Improve Executive Agencies'
Hiring Processes. GAO-03-450. Washington, D.C.: May 30, 2003.Capital
Management
Results-Oriented Cultures: Creating a Clear Linkage between Individual
Performance and Organizational Success. GAO-03-488. Washington, D.C.:
March 14, 2003.
High-Risk Series: Strategic Human Capital Management. GAO-03-120.
Washington, D.C.: January 2003.
A Model of Strategic Human Capital Management. GAO-02-373SP. Washington,
D.C.: March 15, 2002.
Human Capital: A Self-Assessment Checklist for Agency Leaders.
GAO/OCG-00-14G. Washington, D.C.: September 2000.
Strategic Workforce Human Capital: Key Principles for Effective Strategic
Workforce Planning. GAO-04-39. Washington, D.C.: December 11, 2003.
Planning
Appendix III: Related GAO Reports
Foreign Assistance: Strategic Workforce Planning Can Help USAID Address
Current and Future Challenges. GAO-03-946. Washington, D.C.: August 22,
2003.
Tax Administration: Workforce Planning Needs Further Development for IRS's
Taxpayer Education and Communication Unit. GAO-03-711. Washington, D.C.:
May 30, 2003.
Human Capital Management: FAA's Reform Effort Requires a More Strategic
Approach. GAO-03-156. Washington, D.C.: February 3, 2003.
HUD Human Capital Management: Comprehensive Strategic Workforce Planning
Needed. GAO-02-839. Washington, D.C.: July 24, 2002.
NASA Management Challenges: Human Capital and Other Critical Areas Need to
be Addressed. GAO-02-945T. Washington, D.C.: July 18, 2002.
Air Traffic Control: FAA Needs to Better Prepare for Impending Wave of
Controller Attrition. GAO-02-591. Washington, D.C.: June 14, 2002.
Securities and Exchange Commission: Human Capital Challenges Require
Management Attention. GAO-01-947. Washington, D.C.: September 17, 2001.
Human Capital: Implementing an Effective Workforce Strategy Would Help EPA
to Achieve its Strategic Goals. GAO-01-812. Washington, D.C.: July 31,
2001.
Single Family Housing: Better Strategic Human Capital Management Needed at
HUD's Homeownership Centers. GAO-01-590. Washington, D.C.: July 26, 2001.
Results-Oriented Cultures: Implementation Steps to Assist Mergers and
Organizational Transformations. GAO-03-669. Washington, D.C.: July 2,
2003.
Homeland Security: Management Challenges Facing Federal Leadership.
GAO-03-260. Washington, D.C.: December 20, 2002.
Highlights of a GAO Forum: Mergers and Transformation: Lessons Learned for
a Department of Homeland Security and Other Federal Agencies.
GAO-03-293SP. Washington, D.C.: November 14, 2002.
Organizational
Transformation
Appendix III: Related GAO Reports
Managing for Results: Using Strategic Human Capital Management to Drive
Transformational Change. GAO-02-940T. Washington, D.C.: July 15, 2002.
FBI Reorganization: Initial Steps Encouraging but Broad Transformation
Needed. GAO-02-865T. Washington, D.C.: June 21, 2002.
Training and
Development
Human Capital: A Guide for Assessing Strategic Training and Development
Efforts in the Federal Government. GAO-03-893G. Washington, D.C.: July 1,
2003.
Foreign Languages: Human Capital Approach Needed to Correct Staffing and
Proficiency Shortfalls. GAO-02-375. Washington, D.C.: January 31, 2002.
Human Capital: Design, Implementation, and Evaluation of Training at
Selected Agencies. GAO/T-GGD-00-131. Washington, D.C.: May 18, 2000.
Appendix IV: Comments from the Social Security Administration
Note: GAO comments supplementing those in the report text appear at the
end of this appendix.
See comment 1.
See comment 2.
See comment 3.
Appendix IV: Comments from the Social Security Administration
See comment 4.
See comment 5.
See comment 6.
See comment 7.
Appendix IV: Comments from the Social Security Administration
See comment 8.
See comment 9.
See comment 10.
Appendix IV: Comments from the Social Security Administration
Appendix IV: Comments from the Social Security Administration
GAO Comments
1. We believe that the report presents a fair and balanced portrayal of
the multifaceted issue of human capital management in the DDSs. We
designed the survey to obtain DDS directors' opinions about the extent to
which, if any, a DDS had experienced certain human capital challenges and
the likely factors and consequences involved. Moreover, the opinions were
obtained from directors whose first-hand experiences make them some of the
most knowledgeable sources of information about such issues in their
organizations. But in addition to our survey, our overall study methods
relied on information and data from several other sources as well. For
example, we interviewed disability examiners and their managers at two
DDSs, officials responsible for DDS management assistance at three of
SSA's regional offices, SSA officials at headquarters, officials of the
National Council of Disability Determination Directors and the National
Association of Disability Examiners, and staff of the Social Security
Advisory Board. We also reviewed pertinent laws, regulations, and
procedures, and obtained and analyzed human capital data from the DDSs,
SSA, and other federal agencies.
Our survey was developed in accordance with GAO's guidance on survey
design and development.1 To avoid the potential for questions to be
leading, on every question in which we asked for directors' opinions, we
gave them the opportunity to say that they did not experience that
particular challenge, contributing factor, or consequence. To this end, we
constructed the questions so that the first response choice was "no
extent" or equivalent wording. In addition, each question was specifically
assessed for possible bias or problematic wording during extensive survey
pretesting. We pretested the survey eight times-with four former DDS
directors and four current directors. On the basis of these pretests, we
modified the questions until pretesters raised no further issues.
We also gave SSA disability program officials the opportunity, on two
occasions, to review and comment on the survey. SSA officials first
reviewed the survey prior to its pretesting. Among other suggestions, they
noted that some survey questions were leading in nature and that, in
addition, we should develop scaled responses to provide respondents with
the opportunity to modulate their answers (e.g., from "no extent" to "very
great extent"). We modified the survey on the basis of their comments,
including revising or eliminating questions
1U.S. General Accounting Office, Developing and Using Questionnaires,
GAO/PEMD10.1.7 (Washington, D.C.: October 1993).
Appendix IV: Comments from the Social Security Administration
that they thought were leading and constructing scaled responses as
suggested. After additionally incorporating comments of several
pretesters, we provided SSA with the chance to review a revised version of
the survey. The official coordinating SSA's second review emailed us in
reply, saying that, while some of the survey questions might be difficult
for the DDS directors to answer, we should go ahead with the survey as
revised. The official did not refer to any bias in the revised questions.
Our survey questions and our findings reflect ongoing human capital
challenges facing the DDSs and were not limited to the particular
circumstances of fiscal year 2003. The survey questions themselves were
generally not limited to the most recent year, and several explicitly
asked for data for the past two or three fiscal years or for the future.
While the impact of the continuing resolution and the related SSA hiring
freeze that was in place throughout much of fiscal year 2003 may have
affected DDS directors' responses, DDS and SSA officials have told us that
resource constraints and budget uncertainties have been ongoing challenges
for a number of years. Furthermore, certain aspects of the time period in
which the survey was conducted likely downplayed some of the human capital
challenges facing the DDSs. For example, DDS officials said in interviews
that they expected examiner turnover to increase as economic conditions
improved in the future.
2. Our report acknowledges the efforts made by SSA regional offices to
persuade state governments to increase examiner salaries in light of their
new responsibilities. Our report, however, does not assert that 24 DDSs
were refused assistance with negotiating salary increases for examiners
after they had requested it. Rather, we said that, of the DDS directors
who reported wanting help from SSA with negotiating salary increases, more
than half (24 DDSs) said they had not received this kind of help. (SSA
interpreted wanting help and not receiving it as having requested help and
been refused such assistance.) But regardless of whether directors have
specifically requested this or another type of human capital assistance,
they reported in their survey responses that they want active support from
SSA on this and a number of other issues involving human capital
management.
3. Our report acknowledges that some states have strategic workforce
planning initiatives that consider their DDS employees. However, the issue
relevant to our study was not whether statewide human capital management
offices were generally effective, as SSA suggests, but whether there were
any workforce planning efforts by SSA or the
Appendix IV: Comments from the Social Security Administration
DDSs that were integral to and supportive of SSA's mission and goals. As
we noted in the report, even sophisticated statewide workforce planning
efforts are not necessarily focused on ensuring that the DDSs have the
workforces needed to accomplish such SSA goals as reducing
claims-processing times.
4. Our report acknowledges SSA's current efforts at outreach to state
officials. For example, our report describes efforts on the part of
regional office officials to persuade state governments to exempt
examiners from state hiring restrictions, reclassify DDS examiner
positions, and increase examiner salaries. We also emphasize that SSA and
its regional offices can be limited in their ability to help the DDSs
negotiate changes by such factors as state political and budget concerns,
as well as state personnel rules. However, as noted in our report, we
found no record to date of any discussions with the National Governors
Association (NGA) or of NGA focusing on this topic. Our recommendation
that SSA reach out to national associations such as the NGA is an
acknowledgment that the DDSs and SSA's regional offices cannot
successfully confront these difficult human capital challenges without the
sustained attention of SSA's leadership at the national level. For
clarity, we have emphasized this point in the text of our recommendation.
SSA's expressed intent to pursue discussions on a national level with NGA
is a step in the right direction.
5. We recounted in our report the view of SSA officials that requiring
uniform human capital standards might be perceived by some states as
unwelcome federal interference and could raise the prospect of states
withdrawing their participation in making disability determinations. We
also noted the difficulties SSA has encountered in the past in convincing
the DDSs to comply with SSA guidelines on personnel issues, due in part to
the states' perceptions of infringements on traditional prerogatives.
Accordingly, we stressed in our report that establishing uniform minimum
qualifications for examiners throughout the DDSs will be difficult,
requiring delicate and time-consuming discussions with some state
governments. However, establishing such qualifications will also be
worthwhile, helping some DDSs justify an appropriate job classification
and level of compensation needed to recruit and retain qualified
disability examiners. As an agency with fiduciary responsibility for
administering disability programs that are nationwide in scope, SSA has an
obligation to do no less than take firm steps to address the human capital
challenges facing the DDSs. We understand SSA's concern about the
difficulties it would face if states opted out of the disability program
and transferred these
Appendix IV: Comments from the Social Security Administration
responsibilities to the federal government.2 To help ensure the success of
SSA's efforts, outreach from SSA's leadership to the state governors will
be vital. Also essential will be a close working partnership among
the immediate stakeholders-SSA, the DDSs, and their state parent
agencies-in developing a nationwide strategic workforce plan.
6. We did not examine the accuracy and timeliness of claims processing.
Nevertheless, even had these measures of performance improved, the
Commissioner noted in her September 25, 2003, testimony that SSA still has
"a long way to go" in its efforts to be more timely and accurate, despite
positive strides in the short term. Moreover, SSA's own published
strategic plan for 2003 to 2008 warns that "the length of time it
[currently] takes to process these claims is unacceptable." Results from
our survey of DDS directors demonstrate the need to address such DDS human
capital issues as high turnover and recruiting and hiring difficulties in
order to improve the timeliness and accuracy of claims processing. Of the
directors (43) who reported experiencing difficulties in recruiting and
hiring enough people who could become successful examiners, more than
three-quarters said that such difficulties contributed to decreased
accuracy in disability decisions or to increases in claims-processing
times. Moreover, over one-half of all directors reported that turnover had
increased claims-processing times.
7. Our report neither states nor assumes that higher salaries alone
guarantee improved DDS performance. Rather, it states that, according to
more than two-thirds of all DDS directors, noncompetitive pay was one of
several factors contributing to examiner turnover. Moreover, our report
emphasized the costly consequences of such turnover, noting that the
estimated cost of examiner turnover in fiscal year 2002 was in the tens of
millions of dollars. (Our estimates show that this would be the case,
regardless of whether the calculation is based on total turnover or
turnover that is above that of the federal government as a whole.) SSA
itself has been attempting to persuade state governments to increase
examiner salaries to reflect new job responsibilities. Although increased
compensation may increase costs, the turnover that can result from not
addressing human capital
2The Congress was also aware of these difficulties in 1980 when it
required SSA to submit a detailed plan for how it would assume the
functions and operations of a state disability determination function,
were it necessary to do so. See discussion of Pub. L. No. 96-265, S:
304(b)(3) in S. Rep. No. 96-408, at 55 (1980) and in the Preamble to the
1981 Final Rule, 46 Fed. Reg. 29,190, 29,191 (1981).
Appendix IV: Comments from the Social Security Administration
management concerns, such as not compensating employees appropriately, can
be costly as well, as we note in the report.
We agree with SSA that some attrition is desirable. But over half of all
DDS directors told us in our survey that examiner turnover in their
offices was too high, and we found that examiner turnover was about twice
that of federal employees performing similar work. Because turnover is
costly, we emphasize the importance of using data to identify current and
future human capital needs. We have found in prior work that
high-performing organizations analyze who is leaving, what skill gaps
result, and how much turnover is desirable or acceptable. Organizations
that fail to effectively manage their turnover risk not having the
capacity to achieve their goals. A balance needs to be achieved between
bringing in new employees with fresh and vibrant perspectives and
retaining experienced employees whose institutional knowledge can maintain
goals and help train others.
8. We cited the Department of Education's experience to show that
establishing federal qualifications requirements for state employees, as
we recommended that SSA do, can and has been done. While we have not
studied federal experiences with workforce planning in an
intergovernmental arena, the GAO reports we provide in appendix III
highlight an array of initiatives on the part of federal agencies to
embrace workforce planning, including SSA's planning models for its own
employees. SSA has been willing to take the lead and develop models in
workforce planning for its own employees. It should therefore build on its
own internal expertise and lessons learned in this field to develop models
of workforce planning in the demanding intergovernmental context as well.
Lack of an existing model for the range of changes we recommend may make
implementation more challenging, but it is not a convincing argument for
inaction.
9. We support SSA's leadership in its efforts to improve the disability
determination process and to help people with disabilities remain in or
return to the workforce. SSA said that it generally agreed with the intent
of our recommendations and would consider incorporating a nationwide
strategic workforce plan for the DDSs into its current strategy to improve
disability determinations. To do so will be essential, since the
Government Performance and Results Act now requires agencies to report
annually, as we noted in our report, on human capital strategies needed to
meet their strategic goals. While we did not provide an exhaustive
treatment of states' reactions to proposals for increased federal control,
our report did note past opposition of some states to federal guidelines
on personnel matters.
Appendix IV: Comments from the Social Security Administration
In addition, we have added further detail in the report about the
regulatory development process. We acknowledge the complexities involved
in pursuing regulatory change. But despite these difficulties, we maintain
that SSA has an obligation to address DDS workforce needs.
10. SSA said that it would continue ongoing efforts to improve examiner
job skills. Results from our survey of DDS directors, however, revealed
gaps in critical examiner knowledge and skills. Moreover, a large
proportion of directors said they would be able to spend fewer resources
on adapting SSA's training if SSA were to improve the quality,
completeness, and timeliness of this training. Given such results, our
report recommended that SSA go beyond its current efforts and base its
training improvement initiatives on a systematic assessment of the
examiner's job responsibilities and related knowledge, skills, and
competencies.
Appendix V: GAO Contacts and Staff Acknowledgments
GAO Contacts
Staff Acknowledgments
(130196)
Robert E. Robertson (202) 512-7215 Carol Dawn Petersen (202) 512-7215
In addition to those named above, the following individuals made
significant contributions to this report: Barbara Bordelon, Marissa Jones,
Suit Chan, and Beverly Crawford, Education, Workforce, and Income Security
Issues; Ellen Rubin, Strategic Issues; Gregory Wilmoth, Applied Research
and Methods; and B. Behn Miller, General Counsel.
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