Electronic Disability Claims Processing: Social Security
Administration's Accelerated Strategy Faces Significant Risks
(24-JUL-03, GAO-03-984T).
Providing benefits to disabled individuals is one of the Social
Security Administration's (SSA) most important service delivery
obligations--touching the lives of about 10 million individuals.
In recent years, however, providing this benefit in a timely and
efficient manner has become an increasing challenge for the
agency. This past January, in fact, GAO designated SSA's
disability programs as highrisk. Following a prior unsuccessful
attempt, the agency is now in the midst of a major initiative to
automate its disability claims functions, taking advantage of
technology to improve this service. Seeking immediate program
improvements, SSA is using an accelerated approach--called
AeDib--to develop an electronic disability claims processing
system. At the request of the Subcommittee on Social Security,
House Committee on Ways and Means, GAO is currently assessing the
strategy that underlies SSA's latest initiative to develop the
electronic disability system. For this testimony, GAO was asked
to discuss its key observations to date regarding the AeDib
initiative, including strategy, risks, and stakeholder
involvement. GAO plans to discuss more fully the results of this
continuing review in a subsequent report
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-03-984T
ACCNO: A07694
TITLE: Electronic Disability Claims Processing: Social Security
Administration's Accelerated Strategy Faces Significant Risks
DATE: 07/24/2003
SUBJECT: Claims processing
Disability benefits
Federal social security programs
Information resources management
Operational testing
Persons with disabilities
Social security benefits
Strategic information systems planning
Systems analysis
Stakeholder consultations
SSA Accelerated Electronic Disability
Initiative
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GAO-03-984T
A
Test i mony Before the Subcommittee on Social Security, Committee on Ways
and Means, House of Representatives
For Release on Delivery Expected at 10: 00 a. m. EDT ELECTRONIC DISABILITY
Thursday, July 24, 2003 CLAIMS PROCESSING
Social Security Administration*s Accelerated Strategy Faces Significant
Risks
Statement of Linda D. Koontz, Director Information Management Issues
GAO- 03- 984T
Mr. Chairman and Members of the Subcommittee: I am pleased to be here
today to participate in your continuing dialogue on the Social Security
Administration*s (SSA) service- delivery capability. My testimony focuses
on a critical aspect of SSA*s overall goal* its ongoing initiative to
achieve an electronic disability claims process. As you know, one of SSA*s
most vital obligations is paying cash benefits to disabled individuals
under the Disability Insurance and Supplemental Security Income programs.
In 2002, the agency paid approximately $86 billion to about 10 million
disabled beneficiaries. Yet, over the years, it has become an increasing
challenge for SSA to ensure an acceptable level of service* both in terms
of quality and timeliness. This past January, in fact, we reported SSA*s
disability programs as high- risk. 1
During testimony before this Subcommittee in May 2002, the Commissioner of
Social Security voiced concerns about the length of time that the current
disability process can take, and promised immediate improvements. Among
these improvements, she announced plans to accelerate SSA*s initiative to
develop an electronic disability claims process
by late January 2004 rather than late 2005 as initially planned. SSA*s
refocused project is known as the accelerated electronic disability
initiative* AeDib. At your request, we are currently reviewing AeDib to
assess SSA*s strategy for developing the electronic disability claims
process. My testimony will discuss our key observations to date regarding
the initiative, including SSA*s (1) accelerated approach for and progress
toward completing the electronic disability system, (2) actions for
ensuring the system*s successful operations and protection against risks,
and (3) consultation
with and support from key stakeholders. We plan to discuss more fully the
results of our ongoing review in a subsequent report to you.
In conducting this work, we analyzed relevant documentation describing
SSA*s plans and strategies for developing and implementing the AeDib
system and its progress in doing so. We reviewed technical documents
pertaining to the system development and interviewed appropriate SSA
officials to determine the extent to which the agency has followed its
software development guidance. We supplemented our analysis with 1 U. S.
General Accounting Office, Major Management Challenges and Program Risks:
Social Security Administration, GAO- 03- 117 (Washington, D. C.: January
2003).
interviews of SSA officials in the Offices of Disability Programs,
Operations, Systems, and Hearings and Appeals. In addition, we visited SSA
field offices in Delaware and Texas to observe disability claims intake
operations and obtain staff perspectives on the AeDib project. We also
conducted site visits at the Delaware, New York, Texas, and Wisconsin
Disability Determination Services (DDS) offices to observe disability
system pilot tests and discuss these offices* involvement in planning and
implementing AeDib. Further, we surveyed staff in six other DDS offices,
and interviewed representatives of state and SSA employees and the medical
community. These included the National Council of Disability Determination
Directors, the American Federation of Government Employees, and the
American Health Information Management Association. We performed our work
to date in accordance with generally accepted government auditing
standards, from December 2002 through July of this year.
Results in Brief SSA*s goal of achieving an electronic disability claims
process represents an important, positive direction toward more efficient
delivery of disability payments to an increasing beneficiary population.
In undertaking AeDib, SSA*s immediate focus is on developing the
capability to allow claimant information and large volumes of medical
images, files, and other documents that are currently maintained in paper
folders to be stored in electronic folders, and then accessed, viewed, and
shared by the disability processing offices. Since announcing the
accelerated initiative in May 2002, SSA has made progress toward attaining
this capability, including implementing initial automated claims- intake
functions in its field offices. Nonetheless, substantial work remains* the
most crucial of which is
developing document management and scanning and imaging capabilities that
are fundamental to achieving the electronic folder.
SSA*s current strategy, however, involves risks that could jeopardize its
successful transition to an electronic disability process. A pilot test
that would determine whether technology supporting the electronic folder
will work as intended, is not expected to be completed until at least
December* just 1 month before SSA plans to begin implementing the
electronic folder to the disability offices* leaving the agency little
time to incorporate test results. The agency also does not currently plan
to perform end- to- end testing to demonstrate, prior to the national
implementation, how successfully the multiple components will operate
together to electronically process disability claims. Adding to the
system*s vulnerability is that SSA has not yet performed a comprehensive
assessment to identify and establish strategies for mitigating project
risks that could result in cost, schedule, and performance shortfalls.
Finally, SSA has not yet successfully resolved certain concerns among key
disability stakeholders regarding the AeDib strategy. SSA officials
maintain that they have involved stakeholders in developing AeDib through
including them in working groups and steering committee meetings. However,
state DDSs in particular, have significant concerns about how the
system is being developed and implemented, and do not believe that their
offices have been effectively involved with SSA in making key decisions
about the initiative; they question whether this strategy will effectively
support their business processes. Further, although physicians and other
providers of medical evidence are critical to the disability process,
SSA*s consultations with the medical community have thus far been limited
and their representatives have concerns about electronically submitting
evidence for disability determinations. Until SSA can ensure itself and
all stakeholders that the concerns have been effectively considered and
addressed* and the stakeholders view themselves as fully engaged in the
initiative* the agency risks not having full acceptance and use of this
vital
service- delivery tool. Background The Disability Insurance and
Supplemental Security Income programs are
the nation*s largest providers of federal income assistance to disabled
individuals, with SSA making payments of approximately $86 billion to
about 10 million beneficiaries in 2002. The process through which SSA
approves or denies disability benefits is complex and involves multiple
partners at both the state and federal levels in determining a claimant*s
eligibility. Within SSA, these include its 1, 300 field offices, which
serve as the initial point of contact for individuals applying for
benefits, and the
Office of Hearings and Appeals, which, at the request of claimants,
reconsiders SSA*s decisions when benefits are denied.
SSA also depends on 54 state Disability Determination Services (DDS)
offices to help process claims under its disability insurance programs. 2
State DDSs provide crucial support to the initial disability claims
process*
one that accounts for most of SSA*s workload* through their role in
determining an individual*s medical eligibility for disability benefits.
DDSs
2 DDSs are located in all 50 states, the District of Columbia, Guam,
Puerto Rico, and the Virgin Islands.
make decisions regarding disability claims in accordance with federal
regulations and policies; the federal government reimburses 100 percent of
all DDS costs in making disability determination decisions. Physicians and
other members of the medical community support the DDSs by providing the
medical evidence to evaluate disability claims.
The process begins when individuals apply for disability benefits at an
SSA field office, where determinations are made about whether they meet
nonmedical criteria for eligibility. The field office then forwards the
applications to the appropriate state DDS, where a disability examiner
collects the necessary medical evidence to make the initial determination
of whether the applicant meets the definition of disability. Once the
applicant*s medical eligibility is determined, the DDS forwards this
decision to SSA for final processing.
Claimants who are initially denied benefits can ask to have the DDS
reconsider its denial. If the decision remains unfavorable, the claimant
can request a hearing before a federal administrative law judge at an SSA
hearings office, and, if still dissatisfied, can request a review by SSA*s
Appeals Council. Upon exhausting these administrative remedies, the
individual may file a complaint in federal district court. Each level of
appeal, if undertaken, involves multi- step procedures for the collection
of evidence, information review, and decision making. Many individuals who
appeal SSA*s initial decision will wait a year or longer* perhaps up to 3
years* for a final decision.
To address concerns regarding the program*s efficiency, in 1992 SSA
initiated a plan to redesign the disability claims process, emphasizing
the use of automation to achieve an electronic (paperless) processing
capability. The automation project started in 1992 as the Modernized
Disability System, and was redesignated the Reengineered Disability System
(RDS) in 1994. RDS was to automate the entire disability claims process*
from the initial claims intake in the field office to the gathering
and evaluation of medical evidence at the state DDSs, to payment execution
in the field office or processing center, and including the handling of
appeals at the hearings offices. However, our prior work noted that SSA
had encountered problems with RDS during its initial pilot
testing. 3 For example, systems officials had stated that, using RDS, the
reported productivity of claims representatives in the SSA field offices
dropped. They noted that before the installation of RDS, each field office
claims representative processed approximately five case interviews per
day. After RDS was installed, each claims representative could process
only about three cases per day. As a result, following an evaluation by a
contractor, SSA suspended RDS in 1999 after approximately 7 years and more
than $71 million reportedly spent on the initiative.
In August 2000 SSA issued a management plan with a renewed call for
developing an electronic disability system by the end of 2005. The
strategy was to incorporate three components: an electronic disability
intake process that would include (1) a subset of the existing RDS
software, (2) the existing DDS claims process, and (3) a new system for
the Office of Hearings and Appeals. The management plan also provided for
several pilot projects to test the viability and performance of each
project component. SSA*s work on this effort occurred through the spring
of 2002, at which time the Commissioner announced that she had begun an
accelerated initiative to more quickly automate the disability claims
process. The agency anticipated that, with technologically advanced
disability processing offices, it could potentially realize benefits of
more than $1 billion, at an estimated cost of approximately $900 million,
over the 10- year life of the accelerated initiative.
AeDib*s Strategy Calls In undertaking AeDib, SSA has embarked on a major
initiative consisting of
For Developing and multiple projects that are intended to move all
partners in its disability
claims adjudication and review to an electronic business process. SSA
Integrating Multiple
envisions that AeDib will allow its disability components to stop relying
on Disability System paper folders to process claims and to develop new
business processes
Projects using legacy systems and information contained in an electronic
folder to
move and process all of its work. In so doing, SSA anticipates that AeDib
will enable disability components to achieve processing efficiencies,
improve data completeness, reduce keying errors, and save time and money.
3 U. S. General Accounting Office, Social Security Administration:
Technical and
Performance Challenges Threaten Progress of Modernization, GAO/ AIMD- 98-
136 (Washington, D. C.: June 19, 1998).
The AeDib strategy focuses on developing the capability for claimant
information and large volumes of medical images, files, and other
documents that are currently maintained in paper folders to be stored in
electronic folders, and then accessed, viewed, and shared by the
disability processing offices. SSA is undertaking five key projects to
support the strategy: An Electronic Disability Collect System to provide
the capability for SSA
field offices to electronically capture information about the claimant*s
disability and collect this structured data in an electronic folder for
use by the disability processing offices; A Document Management
Architecture that will provide a data
repository and scanning and imaging capabilities to allow claimant
information and medical evidence to be captured, stored, indexed, and
shared electronically between the disability processing offices.
Internet applications that will provide the capability to obtain
disability claims and medical information from the public via the
Internet.
A DDS systems migration and electronic folder interface that will
migrate and enhance the existing case processing systems to allow the
state disability determination services offices to operate on a common
platform and prepare their legacy systems to share information in the
electronic folder; and
A Case Processing and Management System for the Office of Hearings and
Appeals that will interface with the electronic folder and enable its
staff to track, manage, and complete case- related tasks electronically.
According to SSA, the Electronic Disability Collect System and the
Document Management Architecture are the two fundamental elements needed
to achieve the electronic disability folder. By late January 2004,
SSA plans to have developed these two components. It also expects to have
completed five Internet disability applications, enhanced the DDS legacy
systems, and developed the software that will allow existing SSA and DDS
systems to interface with the electronic folder. However, SSA will not yet
have implemented the scanning and imaging capabilities and the interface
software to enable each disability processing office to access and use the
data contained in the electronic folder. SSA officials explained that, at
the end of next January, the agency plans to begin an 18- month rollout
period, in which it will implement the scanning and imaging capabilities
and
establish the necessary interfaces. SSA has drafted but not yet finalized
the implementation strategy for the rollout.
SSA Has Completed SSA has performed several important project tasks since
beginning the
Important AeDib accelerated initiative in 2002. For example, it has
implemented limited
claims- intake functionality as part of the Electronic Disability Collect
Tasks, But Much Work
System, and begun additional upgrades of this software. In addition, it
has Remains
developed two Internet applications for on- line forms to aid claimants in
filing for disability benefits and services. Further, to support
electronic disability processing, SSA is in the process of migrating and
upgrading hardware and case processing software to allow all of the 54
state DDSs to operate on a common platform, 4 and has begun developing
software to enable the DDS systems to interface with the electronic
folder. SSA has also performed some initial tasks for the Document
Management Architecture, including developing a system prototype,
establishing requirements for the scanning capability, and drafting a
management plan and training strategy. Nonetheless, the agency still has a
significant amount of work to
accomplish to achieve the electronic disability folder by the end of next
January. While substantial work remains for each of the AeDib components,
primary among SSA*s outstanding tasks is completing the Document
Management Architecture*s development, testing, and installation at the
agency*s National Computer Center. Table 1 illustrates
SSA*s progress through last June in accomplishing tasks included in the
AeDib initiative, along with the many critical actions still required to
develop and implement the electronic disability processing capability. 4
Thirty of the 54 state DDSs previously operated on a platform consisting
of Wang hardware
and iLevy disability processing software. SSA is now moving all DDSs to an
IBM series platform in an attempt to achieve consistency among all DDS
systems in processing disability claims.
Tabl e 1: Status of Tasks Involved in Developing the AeDib Key tasks to be
completed during 18- month national AeDib
Tasks completed as of Tasks to be completed by Planned January 2004
project
rollout (2/ 2004* component June 30, 2003 January 30, 2004 status
7/ 2005)
Electronic Developed EDCS release Develop electronic folder interface
EDCS software v. 6 operational None reported. Disability
4.2. 3 requirements for AeDib legacy
in all SSA field offices. It will Collection
Developed EDCS release systems automate the disability interview System
(EDCS)
5.0 process. Data will be Developed EDCS release Develop software for
version 6. X
propagated to EDCS and /or the 5.1
electronic folder from SSA Drafted training strategy
* Complete design and legacy mainframe systems and system support for v6.0
disability Internet applications.
Complete validation for V. 6.01 Compete validation for V6. 02
Complete design, legacy system support, and integration and environmental
testing for V6. 1 Validate software Conduct integration and
environmental testing Release software to production Train users
(Continued From Previous Page)
Key tasks to be completed during 18- month national AeDib
Tasks completed as of Tasks to be completed by Planned January 2004
project
rollout (2/ 2004* component June 30, 2003 January 30, 2004 status
7/ 2005)
Document Developed document
Develop procurement strategies DMA infrastructure established
Ensure site Management
imaging and Conduct performance engineering in the SSA National Computer
preparation for DMA Architecture
management system and tuning Center (DMA)
prototype Roll out DMA
Conduct validation infrastructure (e. g., Provided technical
casual scanning training to DMA staff
Conduct integration and equipment, object
environmental testing repository servers, Developed management
scanning and approach and plan Install pilots
imaging servers, and fax servers) Developed DMA
Conduct pilot testing Conduct process requirements
evaluation Evaluate pilot results Acquired AeDib pilot infrastructure
Address any pilot issues Drafted training strategy
Setup production environment Procure AeDib infrastructure Establish object
management system
Contract with outsourced scanning vendors for national scanning support
Finalize training strategy
(Continued From Previous Page)
Key tasks to be completed during 18- month national AeDib
Tasks completed as of Tasks to be completed by Planned January 2004
project
rollout (2/ 2004* component June 30, 2003 January 30, 2004 status
7/ 2005)
Internet Developed and released Complete Internet form 3820
Public will have Internet access None reported. disability
into production Internet (child)
to disability applications a applications form 3368 (disability report)
Validation i3368 (disability report) Developed and released
Integration testing i827 (authorization to release
into production Internet information) form 827 (authorization to Pre-
release tasks release information) i3820 (child) Complete Internet form
3369 Drafted training strategy
(work history) i3369 (work history) Construction including
i3441 (appeals) hardware, capacity management, security support
Data will be automatically activities generated to EDCS from the i3368
(disability report), i3820
Software development (child), i3369 (work history), and i3441 (appeals).
Software validation Integration testing Pre- release tasks
Complete Internet form 3441
(appeals) Construction including hardware, capacity management, security
support activities Software development Validation Integration
testing Pre- release tasks
(Continued From Previous Page)
Key tasks to be completed during 18- month national AeDib
Tasks completed as of Tasks to be completed by Planned January 2004
project
rollout (2/ 2004* component June 30, 2003 January 30, 2004 status
7/ 2005)
DDS AS/ 400 Contracted for AS/ 400 Complete migration of iLevy Enhanced
legacy systems
Install DMA migration and
migration and electronic software prepared to interface with
infrastructure based electronic folder folder interface electronic folder
on rollout schedule interface
Complete procurement of IBM and strategy Installed AS/ 400
AS/ 400 upgrades hardware Complete changes to Complete IBM install
upgrades New York and Provided core AS/ 400
Nebraska legacy training Complete AS/ 400 training systems to interface
with electronic folder Drafted training strategy
Install print servers Complete software changes to support electronic
folder interface
Conduct process evaluation Hearings and
Documented business Complete post- demo
CPMS stand- alone software Complete appeals Case process description
requirements without management
development of Processing information functionality and CPMS management
Management
Developed software Conduct system validation prepared to interface with
information System
development plan electronic folder functionality (CPMS)
Conduct integration and Developed pre- demo environmental testing Roll out
CPMS requirements software to hearings
Establish CPMS software for pilot and appeals sites Drafted training
strategy
starting in March Conduct pilot training 2004 Conduct pilot Conduct
training
Begin pilot evaluation Install DMA infrastructure Begin to address any
pilot issues Finalize training strategy
Source: GAO analysis of SSA AeDib project documentation. a SSA reported
that Disability Internet form i454 (Continuing Disability Review) is being
revised and will not be available by January 2004.
As the table reflects, SSA*s electronic disability claims process hinges
on accomplishing numerous critical tasks by the end of January 2004. In
discussing the overall progress of the initiative, SSA officials in the
Offices of Systems and Disability Programs acknowledge that the agency
will be severely challenged to accomplish all of the tasks planned for
completion by the end of January. Nonetheless, they believe that SSA will
meet the targeted project completion dates, stating that the agency has
conducted
the necessary analyses to ensure that the accelerated schedule can
accommodate the project*s scope. Risks in Developing the
Beyond meeting an ambitious project implementation schedule, SSA must
Electronic Disability
ensure that the system it delivers successfully meets key business and
technical requirements for reliably exchanging data among disability
System Increase
processing components and is protected from errors and vulnerabilities
AeDib*s Overall
that can disrupt service. Accomplishing this necessitates that SSA conduct
Vulnerability
complete and thorough testing to provide reasonable assurance that systems
perform as intended. These include tests and evaluations of pilot projects
to obtain data on a system*s functional performance and end- toend tests
to ensure that the interrelated systems will operate together effectively.
In addition, the success of the system will depend on the agency
identifying and mitigating critical project risks.
SSA plans to rely on pilot tests and evaluations to help guide business
and technical decisions about the electronic disability folder, including
critical decisions regarding the document management technology. For
example, SSA stated that the Document Management Architecture pilots will
be used to test electronic folder interface requirements and DDS site
configurations for AeDib national implementation. In addition, the pilots
are expected to
test the business process and work flow associated with incorporating the
Document Management Architecture. SSA has stated that this information is
crucial for determining whether the technology selected for the Document
Management Architecture will adequately support the electronic folder.
However, SSA may not be able to make timely and fully informed decisions
about the system based on the pilot test results. The pilot tests were to
begin this month, and some of the test results upon which decisions are to
be based are not expected to be available until the end of December at the
earliest, 5 leaving little time to incorporate the results into the system
that is to be implemented by late January. Further, even when completed,
the pilot tests will provide only limited information about the electronic
folder*s functionality. SSA stated that they will not test certain
essential aspects of
the folder usage, such as the DDS*s disability determination function.
Thus, whether SSA will have timely and complete information needed to make
5 SSA plans to conduct the pilot tests at three state DDS sites* North
Carolina, Illinois, and California* beginning this month. It plans to
complete the tests in December.
decisions that are essential to developing and implementing the electronic
disability folder is questionable.
In addition, given the technological complexity of the AeDib project, the
need for end- to- end testing is substantial. Our prior work has noted the
need for such testing to ensure that interrelated systems that
collectively support a core business area or function will work as
intended in a true operational environment. 6 End- to- end testing
evaluates both the functionality and performance of all systems
components, enhancing an organization*s ability to trust the system*s
reliability. SSA*s development and use of new electronic tools to
integrate an electronic folder with its own and DDS legacy systems, along
with Web- based applications and the new Document Management Architecture,
elevates the importance of ensuring that all parts will work together as
intended. However, the agency currently has not completed a test and
evaluation
strategy to conduct end- to- end testing to demonstrate, before
deployment, that these systems will operate together successfully. They
added that conducting end- to- end testing would require delaying system
implementation to allow the time needed for a claim to be tested as it
moved through all of the disability components* a process that could take
up to 6 months to complete. However, determining that all AeDib components
can correctly process disability claims when integrated is vital to SSA*s
knowing whether the electronic disability system can perform as intended.
Compounding AeDib*s vulnerability is that SSA has not yet undertaken a
comprehensive assessment of project risks to identify facts and
circumstances that increase the probability of failing to meet project
commitments, and taking steps to prevent this from occurring. Best
practices and federal guidance 7 advocate risk management. To be
effective, risk management activities should be (1) based on documented
policies and procedures and (2) executed according to a written plan that
provides for identifying and prioritizing risks, developing and
implementing appropriate risk mitigation strategies, and tracking and
reporting on
6 U. S. General Accounting Office, Year 2000 Computing Crisis: FAA Is
Making Progress But Important Challenges Remain, GAO/ T- AIMD/ RCED- 99-
118 (Washington, D. C.: March 15, 1999).
7 See, for example, Software Acquisition Capability Maturity Model SM
(CMU/ SEI- 99- TR002, April 1999); OMB Circular A- 130 (November 30,
2000).
progress in implementing the strategies. By doing so, potential problems
can be avoided before they manifest themselves into cost, schedule and
performance shortfalls.
SSA has developed a risk management plan to guide the identification and
mitigation of risks, and based on that plan, has developed a high- level
risk assessment of program and project risks. The high- level assessment,
which SSA issued last February, identified 35 risks that the agency
described as general in nature and addressing only overall program
management issues related to the project*s costs, schedule, and hardware
and software. For example, one of the high- level risks stated that the
overall availability of the Document Management Architecture might not
meet service- level commitments. The related mitigation strategy stated
that the agency should continue to investigate various approaches to
ensure the system*s availability.
SSA has acknowledged the potential for greater risks given the electronic
case processing and technological capability required for AeDib. Further,
in response to our inquiries, its officials stated that the agency would
conduct and document a comprehensive assessment of project risks by June
30 of this year. The officials added that AeDib project managers would be
given ultimate responsibility for ensuring that appropriate risk-
mitigation strategies existed and that SSA had tasked a contractor to work
with the managers to identify specific risks associated with each system
component. However, at this time, SSA is still without a comprehensive
assessment of risks that could affect the project. Until it has a sound
analysis and mitigation strategy for AeDib, SSA will not be in a position
to cost- effectively plan for and prevent circumstances that could impede
a
successful project outcome. Unresolved
Integral to AeDib*s success are disability process stakeholders that SSA
Stakeholder Concerns
relies on to fulfill the program*s mission, including state disability
determination officials and medical providers. As primary partners in the
Could Undermine
disability determination process, stakeholders can offer valuable and
AeDib*s Success
much- needed insight regarding existing work processes and information
technology needs, and their stake and participation in the systems
development initiative is essential for ensuring its acceptance and use.
In assessing lessons learned from SSA*s earlier attempt to implement the
failed Reengineered Disability System, Booz- Allen and Hamilton
recommended that SSA at all times keep key stakeholders involved in its
process to develop an electronic disability processing capability.
SSA disability program and systems officials told us that the agency has
involved its various stakeholders in developing AeDib. They stated that
the agency has entered into memorandums of understanding for data sharing
with state DDSs, established work groups comprising DDS representatives to
obtain advice on development activities, and included these stakeholders
in steering committee meetings to keep them informed of the project*s
status. In addition, SSA stated, it has met with representatives of major
medical professional associations to seek their support for SSA*s requests
for releases of medical evidence.
However, officials that we contacted in nine of the ten DDS offices stated
that their concerns were not adequately heard and considered in the
decision- making process for the development of AeDib, despite the
critical and extensive role that states play in making disability
determinations. Because of this limited involvement, the National Council
of Disability Determination Directors, which represents the DDSs, stated
that they were concerned that SSA may be pursuing an automated disability
strategy that could negatively affect business operations by creating
delays in the ability to make decisions on disability cases. The DDS
representatives stated that SSA has not articulated a clear and cohesive
vision of how the disability components will work to achieve the AeDib
goal and that decisions about AeDib were being made without considering
their perspectives. They explained, for example, that SSA*s decision to
use a scanning and imaging
vendor to whom medical providers would have to submit evidence would
introduce an additional step into the disability process, and might result
in DDSs* not being able to effectively manage the critical information
that they need to make disability determinations. Further, they have
questions about how in the disability process evidence will be
electronically stored, noting that SSA has proposed, but not yet decided
among, three possible scenarios for establishing repositories to house
medical evidence.
Last March, the National Council of Disability Determination Directors
made three suggestions to SSA aimed at allowing the DDSs to have greater
responsibility for this aspect of the disability business process. Among
their proposals was that DDSs (1) be allowed to manage the contractors who
will be responsible for scanning and imaging all records received from
medical providers; (2) have the choice of receiving electronic medical
evidence at a repository maintained at their sites rather than at remote,
centralized locations; and (3) be allowed to test the possibility of
scanning records after, rather than before, the DDS adjudicates a claim.
According to the council, this latter approach would ensure that the DDSs
could make timely and accurate disability determinations, while also
allowing SSA the
time to perfect the electronic business process and transition to the
initial case process. As of last week, however, SSA had not responded. For
its part, SSA stated that it is reviewing, but has not yet taken a
position on, the council*s proposals.
SSA*s consultation with the medical community (physicians and other
sources of medical evidence used to evaluate disability claims) also has
been limited. These stakeholders are critical, as they represent the basic
source of most of the information that states use to evaluate an
individual*s disability. One of the key savings that SSA anticipates from
AeDib is based on physicians and other medical sources electronically
transmitting or faxing medical evidence that is now mailed to the DDSs.
SSA has estimated
that as much as 30 percent of all medical evidence could be faxed or
electronically received from these providers, with the majority of it
being faxed. In speaking with American Health Information Management
Association officials in Georgia and Wisconsin, however, they expressed
concern about the possibility that SSA will want medical providers to fax
evidence. They cited the voluminous nature of much of the medical evidence
that they send to the DDSs, and believe that faxing it would be too costly
and not secure.
Our review to date has not assessed the validity of the concerns expressed
by the stakeholders, or SSA*s responses to them. Nonetheless, as long as
such concerns exist, SSA must be diligent in pursuing a mutually
agreedupon understanding with its stakeholders about its vision and plan
of action being pursued. SSA*s success in implementing AeDib depends
heavily on resolving all outstanding issues and concerns that could affect
the use and, ultimately, the outcome of the intended electronic
capability. Without stakeholders* full and effective involvement in
AeDib*s planning and development, SSA cannot be assured that the system
will satisfy
critical disability process requirements and be used as intended to
achieve desired processing efficiencies and improved delivery of services
to beneficiaries. To summarize, Mr. Chairman, in moving toward an
electronic disability
process, SSA has undertaken a positive and very necessary endeavor. Having
the means to more effectively and efficiently provide disability benefits
and services is essential to meeting the needs of a rapidly aging and
disabled population, and we applaud the Commissioner*s
determination and proactive pursuit of this service- delivery enhancement.
Nonetheless, SSA*s accelerated strategy may involve risks of delivering a
system that will not sufficiently address its needs. The execution of
critical pilot tests that are not scheduled for completion until December
or later, coupled with the lack of planned end- to- end testing and a
comprehensive
assessment of risks, may prevent SSA from delivering an information
technology capability based on sound and informed decision making.
Moreover, uncertainties about the successful outcome of this project are
exacerbated by concerns that key stakeholders in the disability process
continue to have. Given the importance of this project to SSA*s future
service- delivery capability, it is essential that the agency satisfy
itself that AeDib will perform as intended with minimal risk before it is
deployed nationwide. We will continue to monitor SSA*s progress on this
initiative as part of our ongoing review.
This concludes my statement. I would be happy to respond to any questions
that you or other members of the Subcommittee may have at this time.
GAO Contacts and For information regarding this testimony, please contact
Linda D. Koontz, Staff
Director, or Valerie Melvin, Assistant Director, Information Management
Issues at (202) 512- 6240. Other individuals making key contributions to
this Acknowledgments
testimony include Michael Alexander, Tonia D. Brown, Derrick Dicoi, and
Mary J. Dorsey.
(310361)
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SSA*s goal to establish a more efficient, paperless disability claims
processing system is important, and one that could benefit millions. To
achieve this goal, SSA*s immediate focus is on developing an electronic
folder to store claimant information and large volumes of medical images,
files, and other documents that are currently maintained in paper folders,
and then make this information accessible to all entities involved in
disability determinations. SSA*s accelerated strategy calls for
development of this capability by January 2004 rather than in 2005, as
originally planned. (See figure.) Since accelerating this effort, SSA has
performed important tasks toward
establishing this initial electronic capability. Nonetheless, it has
substantial work to accomplish in order to develop the technologically
complex electronic folder and begin implementation by late next January.
While responsive to the agency*s need for an operational system as soon as
possible, SSA*s accelerated strategy involves risks. For example, pilot
tests that are to provide important information about the electronic
folder*s performance are not expected until late December* just 1 month
before its planned implementation. In addition, a strategy for end- to-
end testing to demonstrate that the individual components will work
together reliably has not been completed. Further increasing the system*s
vulnerability is that SSA has not yet comprehensively assessed project
risks. Unless addressed, these factors could ultimately derail the
initiative.
While SSA has taken steps to involve key stakeholders in the systems
development process, officials in state Disability Determination Services
offices that we contacted expressed concerns that they had only limited
involvement in the development effort. They stated that their concerns
were not adequately heard and considered in the decision- making process.
Unless
SSA addresses these issues, it cannot be assured of stakeholder agreement
with and full use of the system.
History of SSA*s Efforts to Achieve an Electronic Disability Claims
Processing System Providing benefits to disabled individuals is one of the
Social
Security Administration*s most important service delivery obligations*
touching the lives of about 10 million individuals. In recent years,
however, providing this benefit in a timely and efficient manner has
become an increasing challenge for the agency. This past January, in fact,
GAO designated SSA*s disability programs as highrisk.
Following a prior unsuccessful attempt, the agency is now in the midst of
a major initiative to
automate its disability claims functions, taking advantage of technology
to improve this service. Seeking immediate program improvements, SSA is
using an
accelerated approach* called AeDib* to develop an electronic disability
claims processing system.
At the request of the Subcommittee, GAO is currently assessing the
strategy that underlies SSA*s latest initiative to develop the electronic
disability system. For this testimony, GAO
was asked to discuss its key observations to date regarding the AeDib
initiative, including strategy, risks, and stakeholder involvement.
GAO plans to discuss more fully the results of this continuing review in a
subsequent report.
www. gao. gov/ cgi- bin/ getrpt? GAO- 03- 984T. To view the full product,
including the scope and methodology, click on the link above. For more
information, contact Linda Koontz at (202) 512- 6240 or koontzl@ gao. gov.
Highlights of GAO- 03- 984T, testimony
before the Subcommittee on Social Security, Committee on Ways and Means,
House of Representatives July 24, 2003
ELECTRONIC DISABILITY CLAIMS PROCESSING
Social Security Administration*s Accelerated Strategy Faces Significant
Risks
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