Electronic Disability Claims Processing: SSA Is Proceeding with
Its Accelerated Systems Initiative but Needs to Address
Operational Issues (23-SEP-05, GAO-05-97).
Through an initiative known as AeDib, the Social Security
Administration (SSA) is implementing a system in which medical
images and other documents that have traditionally been kept in
paper folders will be stored in electronic folders, enabling
disability offices--including SSA's 144 Office of Hearings and
Appeals sites and 54 state disability determination services--to
process disability claims electronically. This initiative
supports a program that, in 2004, made payments of approximately
$113 billion to more than 14 million beneficiaries and their
families. In March 2004, GAO recommended that SSA take steps to
ensure the successful implementation of the electronic disability
system. GAO was asked to assess SSA's status in implementing
AeDib and the actions the agency has taken in response to GAO's
prior recommendations on this initiative.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-05-97
ACCNO: A38017
TITLE: Electronic Disability Claims Processing: SSA Is
Proceeding with Its Accelerated Systems Initiative but Needs to
Address Operational Issues
DATE: 09/23/2005
SUBJECT: Claims processing
Disability benefits
Electronic data processing
Federal social security programs
Federal/state relations
State-administered programs
Strategic planning
Systems analysis
Systems design
Systems evaluation
Program implementation
SSA AeDib
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GAO-05-97
United States Government Accountability Office
GAO Report to the Chairman, Committee on Finance, U.S. Senate
September 2005
ELECTRONIC DISABILITY CLAIMS PROCESSING
SSA Is Proceeding with Its Accelerated Systems Initiative but Needs to Address
Operational Issues
a
GAO-05-97
[IMG]
September 2005
ELECTRONIC DISABILITY CLAIMS PROCESSING
SSA Is Proceeding with Its Accelerated Systems Initiative but Needs to Address
Operational Issues
What GAO Found
Since January 2004, SSA has been implementing its electronic disability
system at 53 state disability determination services and 85 Office of
Hearings and Appeals sites. It plans to complete implementation in all
state sites by October 2005 and all hearings and appeals sites by November
2005. Nonetheless, considerable work is needed before these entities will
be ready to process all initial claims electronically. SSA's effort to
certify all state offices to electronically process claims and maintain
the electronic folder as an official claims record is not expected to be
completed until January 2007. In addition, state disability officials
expressed concerns about the system's operations and reliability and about
limitations in their electronic processing capabilities. Accordingly, a
number of the offices reported varying levels of system usage (see table),
and their officials said that processing claims electronically generally
took longer and consumed more resources than the previous method. Further,
SSA and the state disability determination services lacked continuity of
operations plans for ensuring that states could continue to process
disability claims during emergencies.
As SSA has implemented its system, it has taken actions that supported
three of GAO's five prior recommendations. It has initiated studies that
could help validate AeDib planning assumptions, costs, and benefits. It
has also approved new software and certified its systems for production.
In addition, according to state disability officials, the agency had
improved its communications with them. However, SSA did not demonstrate
action on two recommendations calling for thorough testing of its
interrelated system components before implementation and completion of
risk mitigation strategies for the projects supporting the initiative.
Thorough testing and risk mitigation strategies could have helped limit
problems with the system's operation and other circumstances that could
impede the project's success.
Reported Use of the Electronic Disability System in Selected Disability
Determination Services as of Late June 2005
Disability Percentage of Percentage of initial determination services
examiners using disability cases being office Implementation date new
system processed electronically
North Carolina July 2003 100 100
Illinois September 2003 100 100
California October 2003 100 8
Mississippi January 2004 100 100
South Carolina March 2004 100 100
Florida September 2004 31 4-5
Delaware May 2005 100 19
Nebraska June 2005 5 4
Source: GAO analysis of SSA and disability determination service data.
Note: The last column represents initial disability cases being processed
electronically. However, as of late June 2005, California, Florida,
Delaware, Nebraska, and North Carolina had not yet received all of the
software they needed to be certified to perform exclusively electronic
processing.
United States Government Accountability Office
Contents
Letter 1
Results in Brief 2
Background 4
SSA Is Meeting Its Overall AeDib
Implementation Schedule, but
Operational and Other Concerns Could Impact
the Success of the
Initiative 11
SSA's Actions toward Implementing AeDib Have
Addressed Some,
but Not All, of Our Prior Recommendations for 25
Improvement
Conclusions 27
Recommendations for Executive Action 28
Agency Comments and Our Evaluation 28
Appendixes
Appendix I: Objectives, Scope, and Methodology 34
Appendix II: Comments from the Social Security 36
Administration
Appendix III: GAO Contact and Staff Acknowledgments 42
Table 1: Scheduled Certification of State DDSs
Tables as of June 30,
2005 15
Table 2: Reported Use of the Electronic
Disability System in
Selected DDS Offices as of Late June 2005 20
Figure Figure 1: SSA's Electronic Disability Claims Processing System
Abbreviations
DDS Disability Determination Services
DMA Document Management Architecture
EDCS Electronic Disability Collect System
GAO Government Accountability Office
OHA Office of Hearings and Appeals
SSA Social Security Administration
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A
United States Government Accountability Office Washington, D.C. 20548
September 23, 2005
The Honorable Charles E. Grassley Chairman Committee on Finance United
States Senate
Dear Mr. Chairman:
This report responds to your request concerning the Social Security
Administration's (SSA) ongoing accelerated initiative to establish an
electronic disability claims processing capability-known as AeDib. With
this initiative, the agency is implementing a paperless system, in which
the large volumes of medical images, files, and other documents that
traditionally have been maintained in paper folders will be stored in
electronic folders, enabling the disability claims processing offices to
electronically view, process, and share claims information. The disability
claims processing offices include SSA's field offices, where individuals
apply for claims; state disability determination services (DDS) offices,
which determine claimants' medical eligibility for disability benefits;
and SSA's Office of Hearings and Appeals (OHA), which processes appeals of
claims that have been denied. SSA began its national rollout of the key
system components needed to electronically process an entire disability
case in late January 2004.
In pursuing this electronic capability, SSA has taken a positive and
necessary step toward more efficiently delivering benefits payments to an
increasing beneficiary population. However, we previously pointed out that
the agency's accelerated strategy for developing and implementing the
electronic disability system involved risks that threatened the agency's
complete and successful transition to this capability. In reporting on
AeDib in March 2004, for example, we noted that the agency had begun its
national rollout without conducting essential testing to assess how the
multiple interrelated system components for this initiative would function
in an integrated environment.1 To address such deficiencies, we
recommended that the Commissioner of Social Security take several actions
to reduce the risks associated with the agency's strategy for
1GAO, Electronic Disability Claims Processing: SSA Needs to Address Risks
Associated with Its Accelerated Systems Development Strategy, GAO-04-466
(Washington, D.C.: Mar. 26, 2004).
developing the electronic disability system. At your request, this report
discusses (1) the current status of SSA's implementation of AeDib and (2)
the actions SSA has taken in response to our prior recommendations on this
initiative.
To address these objectives, we analyzed project management and technical
documentation describing SSA's plans and progress related to implementing
its electronic disability system. In addition, we reviewed relevant
documents that describe the state DDSs' implementation and use of the
system, including reports of the National Council of Disability
Determination Directors-an organization representing the state DDSs. We
also obtained and reviewed relevant documentation describing SSA's actions
toward implementing our prior recommendations on AeDib. Further, we
interviewed key officials in SSA's Offices of Operations, Systems,
Disability and Income Security Programs, and Hearings and Appeals to
determine the current status of the system's implementation and to discuss
issues that the agency has identified during the implementation. We also
interviewed DDS officials in nine states-California, Delaware, Florida,
Illinois, Mississippi, Nebraska, New York, North Carolina, and South
Carolina-and the President of the National Council of Disability
Determination Directors, to obtain their views on implementing the
electronic disability system. To supplement the interviews, we visited DDS
and OHA sites in Mississippi and South Carolina, where we observed the
operations of the electronic disability system and discussed these
offices' implementations of and experiences in using it. We conducted our
work from October 2004 to July 2005, in accordance with generally accepted
government auditing standards. Appendix I contains a more detailed
discussion of the objectives, scope, and methodology.
Results in Brief SSA is proceeding with its implementation of its
electronic disability claims process, which involves installing a data
repository and the capability to scan and image claimants' information and
medical evidence,2 enhancing
2The data repository and the capability to scan images, documents, and
forms that previously have been contained in paper folders comprise the
Document Management Architecture infrastructure project. This system will
enable disability-related information to be viewed and shared
electronically by all disability processing components and is a
fundamental element needed to achieve the electronic folder processing
environment.
existing claims processing systems in DDS offices, and installing software
that will enable DDS and OHA systems to interface with electronic
folders.3 The agency had planned to equip all DDS offices and OHA sites
with these electronic capabilities by June 2005 and October 2005,
respectively, and since beginning the national rollout in late January
2004 has largely met its implementation schedule. As of June 30, 2005, it
had, as planned, fully or partially implemented the electronic
capabilities in 53 of the 54 state DDS offices and in 85 of the 144 OHA
sites. Nonetheless, the agency still has considerable work to accomplish
before it will be effectively positioned to fully process disability
claims in an electronic environment. As of early July 2005, it had
certified only three DDSs to process all initial disability claims
electronically and to maintain the electronic folder as an official
record; it does not expect to complete all certifications until January
2007. In addition, officials in a number of the DDSs expressed concerns
about the operations and reliability of the electronic disability system,
stating, for example, that inadequacies in the electronic forms and the
computer monitors used to view claims information had slowed systems
performance and impeded their productivity. Consequently, these officials
reported varying levels of system usage and stated that processing claims
electronically had thus far taken longer and consumed more resources than
prior to the system's implementation. Further, although SSA is moving to
fully implement its system, the agency and state DDSs have not yet
developed continuity of operations plans for mutually ensuring the
continuity of this vital disability benefits service during short-or
long-term disruptions to their electronic claims processing capabilities.
Until SSA adequately resolves the concerns surrounding its electronic
disability system, it jeopardizes its progress toward successfully
achieving a more efficient means of delivering disability benefits
payments to its increasing beneficiary population.
In proceeding with the AeDib initiative, SSA has taken actions related to
three of five recommendations we made in our prior report. For example, it
has initiated studies to help validate its planning assumptions supporting
the initiative's costs and benefits, begun ensuring users' approval of new
software and the certification of its systems for production, and improved
its communications about the initiative with DDS officials. However, the
3The electronic folder interface software is electronically linked to the
claims processing system and allows for the transfer of data between the
electronic folder and the Document Management Architecture data
repository. The electronic folder is an information storage system that
electronically houses claimant information and medical evidence previously
maintained in the paper folder (for example, data, images, and forms).
agency did not demonstrate any action on two other recommendations-to
conduct essential end-to-end testing to determine how the interrelated
system components would work together prior to their implementation and to
complete strategies for mitigating risks to the projects supporting the
initiative. Thorough testing and risk mitigation strategies could have
helped limit problems with the system's operation and prevented
circumstances that could impede the project's success.
To further reduce risks to SSA's progress in achieving its electronic
disability claims processing capability, we are recommending that the
Commissioner of Social Security (1) develop and implement a strategy that
articulates milestones, resources, and priorities for resolving
operational problems with the electronic disability system and (2) ensure
that state DDSs develop and implement continuity of operations plans that
address the continuation of disability claims processing in emergency
situations.
In written comments on a draft of our report (reprinted in app. II), SSA
agreed to ensure that state DDSs develop and implement continuity of
operations plans for continuing essential disability claims processing
functions during emergencies. However, the agency disagreed with our
recommendation that it develop and implement a strategy that articulates
milestones, resources, and priorities for efficiently and effectively
resolving problems with the electronic disability system's operations. The
agency stated that it already had plans in place and had taken various
actions to improve the electronic disability system's operations by, for
example, establishing a work group to identify software improvements for
its electronic forms and hiring a contractor to test new computer monitor
configurations. However, during our review, SSA could not provide a time
table for the work group's efforts, and it does not anticipate a final
report on its tests of monitor configurations until January 2007. As SSA
moves forward with actions to improve the electronic disability system, a
strategy that articulates clear milestones, resources, and priorities will
be essential to guide the agency's efforts and ensure that all operational
concerns are fully and effectively addressed.
Background SSA's Disability Insurance and Supplemental Security Income
programs are the nation's largest providers of federal income assistance
to disabled individuals, with the agency making payments of approximately
$113 billion to more than 14 million beneficiaries and their families in
2004. Yet, over the years, it has become more challenging for the agency
to ensure an acceptable level of service-in terms of both the quality and
the timeliness
of its support to these individuals. In January 2003, we designated
disability benefits programs across the federal government as high risk-in
need of urgent attention and transformation.4
The process through which SSA approves or denies disability benefits is
complex and involves multiple partners at both the federal and state
levels in determining a claimant's eligibility. SSA's 1,300 field offices
are the initial points of contact for individuals applying for benefits.5
SSA also depends on 54 state DDS offices to provide crucial support to the
claims process through their role in determining an individual's medical
eligibility for disability benefits. DDSs make initial determinations
regarding disability claims in accordance with federal regulations and
policies; the federal government reimburses 100 percent of all costs
incurred by states to make disability determinations. Physicians and other
members of the medical community provide the DDSs with medical evidence to
help them evaluate disability claims. When disability claims have been
denied by the DDSs, claimants can appeal to SSA's OHA.6
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.7 If the claimant is eligible, the
field office forwards the application to the appropriate state DDS, where
a disability examiner collects the necessary medical evidence to make the
initial determination of whether the claimant's condition meets the
definition of disability. Once the claimant's medical eligibility is
determined, the DDS returns the claim folder to SSA for final processing.
A claimant who is initially denied benefits can ask the DDS to reconsider
its determination. If the DDS denies the claim again, 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 of the
claim by SSA's Appeals Council. Upon exhausting these administrative
remedies, the claimant may file a complaint in federal district court.
Each level of appeal
4GAO, Major Management Challenges and Program Risks: Social Security
Administration, GAO-03-117 (Washington, D.C.: January 2003).
5Nationwide, about 2.6 million initial disability claims were filed in
fiscal year 2004.
6SSA maintains 144 Office of Hearings and Appeals (OHA) sites.
7Nonmedical eligibility criteria may include an individual's age,
employment, marital status, or Social Security coverage information.
involves multistep procedures for collecting evidence, reviewing
information, and making the decision. Many individuals who appeal the
initial determination on their claims 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 its Modernized Disability System project, intending to redesign
the disability claims process emphasizing the use of automation to achieve
an electronic (paperless) processing capability. This project, which in
1994 was renamed the Reengineered Disability System, 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 by the
state DDSs, to payment by the field office or processing center. The
system also was intended to automate the handling of appeals by SSA's
hearings offices. However, as our prior work noted, SSA encountered
performance and other problems during its initial pilot testing of the
system and, after spending more than $71 million, suspended this project
in 1999.
In August 2000, SSA renewed its commitment to developing an electronic
disability system by the end of 2005. The agency worked on this initiative
through the spring of 2002, at which time the Commissioner of Social
Security announced an accelerated electronic disability initiative-
AeDib-to more quickly move to an automated process. Under the accelerated
strategy, the agency planned to begin implementing its electronic
disability system by January 2004. SSA anticipated that the electronic
disability system would enable the disability offices to achieve
processing efficiencies, improve data completeness, reduce keying errors,
and save time and money. With technologically enhanced claims processing
offices, the agency projected that it could realize benefits of more than
$1 billion-at an estimated cost of approximately $900 million-over the
10year life of the initiative.8 SSA reported actual AeDib costs of
approximately $215 million through fiscal year 2004 for planning, hardware
and software acquisition, maintenance, and personnel.
The AeDib strategy focuses on developing the capability to electronically
process claimant information and large volumes of medical images, files,
and other documents that are currently maintained in paper folders. Stored
in electronic folders, this information could then be accessed, viewed,
and
8The 10-year life of the AeDib initiative covers the time frame from 2002
through 2011.
shared among the disability claims processing offices. The initiative to
achieve this electronic capability involves five key projects:
o an Electronic Disability Collect System that would provide the
capability for SSA field offices to capture electronically, in fixed data
fields, information about a claimant's disability that previously had been
contained on paper disability forms (structured data) and to store it in
databases for later use by the SSA and DDS offices responsible for
processing disability claims;
o a Document Management Architecture to provide a data repository and
scanning and imaging capabilities that would allow unstructured claimant
and medical data, such as images or information not found in fixed data
fields (e.g., a hospital report, doctors' notes, or an x-ray report), to
be stored, indexed, and shared among the disability processing offices;
o Internet applications to enable the public to submit disability claims
and medical information to SSA via the Internet (all data keyed into the
Internet applications would be transmitted directly into the Electronic
Disability Collect System);
o a systems migration and electronic folder software interface to
position DDS offices to operate on a common IBM-series hardware platform
and enhance their existing claims systems to process the electronic claims
information and to enable the DDS systems to access information in the
electronic folder; and
o a Case Processing Management System that would interface with the
electronic folder and enable OHA's 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 components needed
to create the electronic disability folder. Via their claims processing
systems, SSA and DDS users would be able to access and pull the structured
and unstructured claimant data into appropriate computer
screens, organized as electronic folders of information.9 The agency's
electronic disability claims processing system is depicted in figure 1.
9Conceptually, the Electronic Disability Collect System and Document
Management Architecture provide the capability to hold an aggregation of
both the structured and unstructured data so that all of a claimant's
information can be organized in a virtual folder and then viewed
collectively and shared electronically. A virtual folder is a type of
folder that is dynamically assembled at the time of the request. The
virtual folder may represent a subset of a static folder or a
cross-section of static folders.
claims processing software in all but 3 state DDS offices that used the
standard disability claims processing systems.10 In addition, SSA had
begun pilot testing OHA's Case Processing Management System in a
standalone environment at five sites. Further, the agency was pilot
testing the Document Management Architecture in three state DDS
locations-North Carolina, Illinois, and California. However, it had not
yet implemented the Document Management Architecture repository and
scanning and imaging capabilities and related DDS software enhancements or
the software to enable DDS and OHA systems to interface with the
electronic folders. SSA began its national rollout of these remaining
system components at the Mississippi DDS on January 26, 2004.
When we last reported on the initiative in late March 2004, SSA was
proceeding with its implementation of its electronic disability system.11
However, our work had noted that the agency's strategy for developing the
system components involved risks that threatened the success of the
project. For example, we determined that the agency (1) had begun the
national rollout without conducting testing that was adequate to evaluate
the performance of all system components collectively, (2) could not
provide evidence that it was consistently applying established procedures
to guide the AeDib software development or had developed risk mitigation
strategies, (3) had not validated its analysis to ensure the
reasonableness of estimated AeDib costs and benefits, and (4) had not
articulated a comprehensive plan for ensuring that state DDSs' concerns
about the initiative were addressed. In view of the risks and the
technological complexity, scope, and size of the initiative, we had
recommended that the Commissioner of Social Security, before continuing
with the national rollout of AeDib,
o ensure that all critical problems identified in pilot testing of the
electronic disability system were resolved and that end-to-end testing of
the interrelated systems was performed,
o ensure that the software that had been developed was approved and that
the systems had been certified for production,
10The majority of DDSs use standard claims processing systems that are
provided by three sources: iLevy, Versa, and MIDAS. Two DDSs-Nebraska and
New York-use systems developed by their own offices.
11GAO-04-466.
o establish a revised time frame for and expedite actions toward
finalizing AeDib risk mitigation strategies,
o validate all AeDib cost and benefit estimates, and
o implement a communications plan to clearly and comprehensively convey
SSA's approach for effectively addressing disability stakeholders' and
users' concerns and ensuring their full involvement in the AeDib
initiative.
SSA Is Meeting Its Overall AeDib Implementation Schedule, but Operational and
Other Concerns Could Impact the Success of the Initiative
SSA is proceeding with a national rollout of its electronic disability
system and has generally met its schedule for implementing the remaining
key components-the Document Management Architecture and the electronic
folder interface software-that are required to process an entire
disability case electronically. Nonetheless, the agency has considerable
work to accomplish before it will be effectively positioned to fully
process all disability claims in an electronic environment. Among the
critical tasks that remain are certifying all state DDS offices and OHA
sites to electronically process claims and addressing operational and
other concerns that threaten to undermine the reliability and use of the
system. Until SSA has effectively addressed these matters, it remains
uncertain when and to what degree the agency will realize the full
benefits of its electronic processing capability.
AeDib Implementation Schedule Was Generally Met through June 2005
The AeDib implementation schedule had called for all state DDSs and OHA
sites to be equipped with the electronic disability claims processing
capability by June 27, 2005, and October 3, 2005, respectively. Since
beginning the national rollout of the Document Management Architecture and
related DDS software enhancements and the electronic folder interface
software in late January 2004,12 the agency has largely met its
implementation schedule. As of late June 2005, SSA had fully or partially
implemented the electronic disability system in 53 of the 54 state DDS
offices and in 85 of the 144 OHA sites, as planned. The agency reported
that
12Three states included in the national roll-out-North Carolina, Illinois,
and California- actually began their implementation of the Document
Management Architecture as part of SSA's pilot tests of this technology in
2003.
it expected to finish implementing the electronic disability system in the
one remaining DDS-New York-in October 2005.
SSA officials attributed the 4-month delay in the planned implementation
at the New York DDS to the need for additional time to interface the
electronic disability system with that state's existing claims processing
capabilities. New York and Nebraska are the only two DDSs in which the
states' claims processing capabilities are not supported by the common
hardware platform that the majority of DDSs use and that have developed
and rely on disability claims processing software that is unique to their
processing environments. As a result of New York's efforts to develop and
test an electronic disability claims process, it had achieved a level of
electronic processing, including the capability to scan medical evidence
into its system, prior to SSA's completion of the electronic disability
system. SSA and New York DDS officials agreed to interface the new
electronic disability system with portions of that state's existing claims
processing capabilities.13
In addition, SSA officials reported, as of early July 2005, that they
expected to meet the scheduled completion date of October 3, 2005, for 115
of the 144 OHA sites. They stated that the agency expected to complete
implementation of the electronic disability system at the remaining 29 OHA
sites approximately 1 month later, in November 2005. According to agency
officials, 10 of the 29 sites support claims that are processed by the New
York DDS. The agency delayed implementation at these sites in order to be
more in step with New York's revised implementation schedule and with
anticipated time frames for when the DDS will be positioned to process
disability cases using the electronic folder. Regarding the remaining 19
sites, officials explained that the agency did not wish to train staff and
provide the electronic folder capability to OHA sites too far in advance
of when these offices expected to receive electronic cases from the DDSs,
believing that too much lag time between training and actual use of the
system could result in the staffs' losing some of the knowledge and skills
they need to process cases electronically.
13SSA also interfaced the electronic disability system with Nebraska's
independent disability claims processing system, although Nebraska's
system included fewer automated capabilities than did New York's system.
This action was completed as scheduled in late June 2005.
Operational and Other Concerns Could Impact the Electronic Disability
System's Reliability and Use
Although the roll out of the electronic disability system is moving toward
completion, the agency still has considerable work to accomplish before it
will be effectively positioned to process all disability claims in a fully
electronic environment. After implementing the electronic system, each DDS
must undergo an assessment of the quality and accuracy of its electronic
processing capabilities and must be certified by SSA to use the electronic
folder as its official disability claims record. This assessment, referred
to as the Independence Day Assessment, is intended to validate that an
office is ready to process 100 percent of the initial disability claims
and any reconsiderations that it receives in the electronic environment
and that the electronic folder can serve as the official disability claims
record.14 According to SSA Operation's staff, the assessment involves
examining the disability office's operations and claims processing tasks
to ensure that (1) the business process (e.g., the way in which the
disability claims office is organized to do its work) and the electronic
processing environment are compatible; (2) existing claims processing
systems have the necessary functionality to process electronic folders;
and (3) staff can, when using the electronic disability system, produce
complete information that equals what is contained in the paper folders.
As of early July 2005, SSA reported that only three state
DDSs-Mississippi, Illinois, and Hawaii-had completed assessments and been
certified to process all initial disability claims in a paperless
electronic environment in which the electronic folder is recognized as the
official disability claims record. SSA reported that it had certified
Mississippi-the first state under the national rollout-to process all of
its initial disability claims electronically by February 2005; the agency
further reported that it had completed certifications in June 2005 for
Illinois-one of the three states that had participated in a pilot test of
the Document Management Architecture in 2003-and for Hawaii, one of the
smallest states (consisting of 15 disability claims examiners), which
completed its system's implementation in February 2005.
In discussing Mississippi's certification, the DDS director stated that
the approximately 1-year time frame between the implementation and the
certification of the office's system had been devoted to such tasks as
updating and testing software versions in order to give the office the
full
14An initial disability claim is one that is filed for the first time by a
disability claimant, versus, for example, reconsiderations and continuing
disability reviews of claims that have already been decided.
complement of functionality that it would need to use the electronic
folder and to ensuring that the office's business processes effectively
supported electronic processing by, for example, familiarizing staff with
the electronic capabilities, training them in using the capabilities, and
testing the use of scanning equipment in the office. The director added
that, since Mississippi was the first state to be assessed and certified,
SSA had reviewed a substantially larger number of disability cases
(approximately 300) than it intends to review in the assessments of other
states using the same claims processing software.
SSA officials said that, following Mississippi's certification, the
Commissioner of Social Security had placed a moratorium on any additional
certifications pending SSA's review of the assessment that had been
undertaken in that state. They said that the commissioner had wanted to
capture lessons learned from Mississippi's assessment to identify any
needed improvements in the assessment process and to ensure that any
business or user concerns about the assessments were resolved before they
applied the process broadly across all DDSs and OHA sites. For example,
according to the officials, they learned that a smaller sample of
disability cases could be examined in subsequent offices using the same
software as Mississippi's without diminishing the integrity of the
assessment and the related certification.
As of July 2005, SSA officials told us that they had resumed the
assessments and that the agency's plans called for a total of seven state
DDSs to be certified to process claims electronically by the end of fiscal
year 2005.15 However, as indicated in table 1, not all of the 54 state
DDSs are expected to be certified to process initial disability claims and
to use the electronic folder as the official record until January 2007.
15The seven states are Mississippi, Illinois, Hawaii, South Carolina,
Missouri, Wyoming, and Nevada.
Table 1: Scheduled Certification of State DDSs as of June 30, 2005
Page 15 GAO-05-97 Electronic Disability Claims Processing
Implementation DDS Certification January Mississippi February September Illinois June February Hawaii June March Nevada August March South September October Wyoming September October California October September Maine October October Minnesota October November Oklahoma October January Oregon October June Guam October March Virgin November May Delaware November October Texas December June Alaska December July North January May New January June North January April Tennessee February August Idaho February October Connecticut February November Iowa February December Arizona February March Vermont February April Massachusetts February June Alabama March June Georgia March January Missouri March April New March April Rhode March July Utah April December Michigan April January Wisconsin April January Louisiana April
date office date 2004 2005 2003 2005 2005 2005 2005 2005 2004 Carolina 2005 2004 2005 2003 2005 2004 2005 2004 2005 2004 2005 2005 2005 2005 2005 2005 Islands 2005 2005 2005 2004 2005 2005 2005 2003 Carolina 2006 2005 Hampshire 2006 2005 Dakota 2006 2004 2006 2004 2006 2004 2006 2004 2006 2004 2006 2005 2006 2005 2006 2004 2006 2004 2006 2005 2006 2005 Jersey 2006 2005 Island 2006 2004 2006 2004 2006 2005 2006 2005 2006
(Continued From Previous Page)
Implementation date DDS office Certification date
September 2004 Florida May 2006
September 2004 Ohio May 2006
November 2004 South Dakota May 2006
January 2005 Arkansas May 2006
February 2005 Washington May 2006
April 2005 Indiana May 2006
September 2004 West Virginia June 2006
December 2004 Puerto Rico June 2006
December 2004 Kentucky June 2006
June 2005 Nebraska June 2006
March 2005 Pennsylvania July 2006
March 2005 Maryland July 2006
April 2005 Kansas July 2006
April 2005 New Mexico July 2006
May 2005 Montana August 2006
March 2005 Colorado September 2006
January 2005 Virginia October 2006
June 2005 Washington, DC November 2006
October 2005 New York January 2007
Source: GAO analysis of SSA information.
According to OHA's deputy director, SSA expects to certify each OHA site
shortly after certifying the corresponding DDS office. The official noted
that because all OHA sites will rely on the same standard system (the Case
Processing Management System), their certification process is expected to
be less complicated than the process for the DDSs. Until they are
certified, offices that have already implemented the electronic disability
system are expected to maintain paper folders as well as electronic ones
for any initial disability cases that they process electronically. The
paper folders will continue to serve as the official records for these
cases.
Operational Concerns Exist Even as the agency proceeds in certifying
states' electronic capabilities, however, operational concerns associated
with the electronic disability system could undermine its reliability and
use. Officials in seven of the nine DDS offices that we contacted
(California, Delaware, Florida, Illinois, Mississippi, North Carolina, and
South Carolina) stated that operational problems they had encountered
while using the electronic disability system
had affected its performance and raised doubts about its reliability in
supporting their processing needs.
DDS officials stated, for example, that as SSA had brought the system
online at the different DDS offices and/or added new software to enhance
functionality, their staffs had encountered various operating problems
that affected the performance of the system. They stated that their
offices had experienced problems such as computer screen freezes, system
slowdowns, and system access issues-all of which had disrupted the
offices' processing of claims. They described these problems as
unpredictable and random because they did not always occur consistently
among all of the offices using the same claims processing software or even
among examiners in a particular office. The officials added that although
SSA has been able to resolve many of the problems that affected their
ability to process claims, additional instances of screen freezes, system
slowdowns, and access issues have continued to occur throughout the
system's implementation.
According to the manager of the South Carolina DDS, which implemented the
electronic disability system in March 2004, that office's productivity had
been adversely affected by system slowdowns that resulted from having
inadequate network bandwidth to support its disability claims processing
operations. In July 2005, the manager stated that SSA had recently made
modifications to the office's network architecture and had increased its
bandwidth by installing two additional communications lines; at that time,
the office was in the process of testing these enhancements. The manager
said that all of the office's disability claims examiners had begun
processing all initial disability claims electronically and that, as a
result of the enhancements, they expected the office's claims processing
efficiency and productivity to increase.
In addition, DDS officials in six offices (California, Delaware, Florida,
Mississippi, North Carolina, and South Carolina) reported problems with
the electronic forms that SSA had installed to facilitate the processing
of disability claims.16 The officials explained that, while using the
electronic forms, disability claims examiners had experienced slow system
response times or system freezes that had contributed to increased claims
16Some of the electronic forms used by the DDSs include the Disability and
Determination Transmittal Form (SSA Form 831) and the Authorization to
Disclose Information to the Social Security Administration (SSA Form 827).
processing times. Officials in California stated that they had stopped
using the electronic forms as a result of the problems that their staff
had encountered and instead were continuing to rely on paper forms. In a
February 2005 survey, the National Council of Disability Determination
Directors found that 22 DDSs had experienced problems with the electronic
forms and had reported that the slow pace involved in loading and using
these forms was barely tolerable. Further, based on its May 2005 quarterly
evaluation of the electronic disability system, SSA reported that one of
the systems-related problems that disability processing offices identified
most frequently was the slow response times and lack of userfriendliness
of the electronic forms.
Further, officials in five of the DDSs that we contacted among those that
had implemented the electronic disability system (California, Illinois,
Mississippi, North Carolina, and South Carolina) stated that their
disability examiners faced difficulties in reading medical evidence on
screen and performing certain case development or adjudication tasks
because the size of the computer monitors that they had been provided to
process medical evidence had proven inadequate. Users of the
system-including managers, claims examiners, and medical
consultants-reported difficulty with simultaneously viewing two documents
on their monitors; some staff reported that they had resorted to printing
out or toggling between documents to avoid using the split screen to
review them. As a result of the inadequacies associated with using the
existing monitors, the users reported that they needed longer periods of
time to perform certain claims adjudication tasks and that they had been
unable to complete as many cases per day as they could before they had the
electronic disability system.
Beyond these concerns, officials in four of the DDSs that we contacted
told us that, although their electronic capability had been implemented,
they had not been provided certain software enhancements that they needed
to fully process a claim electronically and that were critical to
improving the efficiency of their offices' claims processing capabilities.
Specifically, Florida officials stated that their claims processing
software did not provide the capability to electronically notify staff of
the actions that were required to process a claim. As a result, the staff
had to expend additional time notifying each other of actions needed to
process the claim by, for example, sending e-mail notices. In addition,
the director of the North Carolina DDS stated that that office lacked the
necessary software to enable staff to electronically send claims files to
SSA's Disability Quality Branch, which is responsible for conducting
quality reviews of the
accuracy of DDSs' disability determinations. The director added that staff
could not yet respond electronically to SSA components that requested
information on a particular claim that had been processed in their office.
Further, in Nebraska, the DDS manager stated that that office was in need
of additional software modifications to provide the functionality required
to electronically import all required documents into the electronic
folder. Finally, the manager of the California DDS stated that his office
had lacked the capability to electronically process nonmedical claims data
that were required to be included in the disability claims folders, such
as a claimant's work history. The manager stated that they also had lacked
the functionality to electronically refer claims to medical consultants
for consultative examinations.
In light of the operational and other concerns that have been encountered
in using the electronic disability system, coupled with factors such as
having to concurrently maintain paper and electronic claims folders while
awaiting certification, both SSA and DDS managers acknowledged that the
DDS offices had exercised wide discretion in their use of the new system.
The President of the National Council of Disability Determination
Directors stated that two key factors had affected some DDSs' decisions
about ramping up to full use of the system: (1) concerns about a drop in
productivity in a fully electronic environment and (2) the instability of
the electronic disability processing environment, particularly in terms of
system performance and software reliability. In this regard, officials in
eight DDS offices that we contacted-all of which had implemented the
electronic disability system by the end of June17-reported varying levels
of usage, as shown in table 2.
17The New York DDS had not yet implemented the electronic disability
system.
Table 2: Reported Use of the Electronic Disability System in Selected DDS
Offices as of Late June 2005
Percentage of
Percentage initial disability Disability of examiners cases being
determination Implementation Actual/planned using new processed services
office date certification system electronically
North Carolina July 2003 January 2006 100 100
Illinois September 2003 June 2005 100 100
California October 2003 October 2005 100
Mississippi January 2004 February 2005 100 100
South Carolina March 2004 September 2005 100 100
Florida September 2004 May 2006 31 4-5
Delaware May 2005 November 2005 100
Nebraska June 2005 June 2006 5
Source: GAO analysis of SSA and DDS data.
Note: The last column represents initial disability cases being processed
electronically. However, as of late June 2005, California, Florida,
Delaware, Nebraska, and North Carolina had not yet received all of the
software they needed to be certified to perform exclusively electronic
processing.
Regarding the extent of their usage, managers in the Mississippi and
Illinois DDSs acknowledged that problems had been encountered following
their implementation of the electronic disability system but stated that
they had nonetheless chosen to expedite efforts to achieve full electronic
processing of disability claims in an attempt to minimize the
inefficiencies associated with having to maintain both paper and
electronic disability folders. Further, to help bring their states to full
electronic processing, the managers of the Mississippi and Illinois DDSs
stated that they had expended additional resources on overtime pay to
disability examiners and on additional support from the software vendor to
alleviate and/or establish workarounds for the operational problems that
their examiners had encountered. While Mississippi officials said that
they were unable to provide a dollar amount for their overtime usage, an
Illinois DDS official provided documentation indicating that between
September 2003 and May 2005, that office had spent over $2 million on
overtime, which assisted them in processing disability claims in the
electronic environment.
However, DDS managers in several other offices that we contacted stated
that, as a result of the problems with and the resulting unpredictability
of the electronic disability system, they had been reluctant to bring the
system to full use. They expressed reluctance to increase their use of the
system
until a more reliable level of performance has been sustained, stating
generally that the current problems with the system could hamper their
ability to maintain their productivity levels.
For example, officials in the California DDS told us that the electronic
disability system had not been used to fully process any of the
approximately 450,000 initial claims that the office had received since it
had implemented the system in October 2003.18 The officials stated that
they had chosen not to ramp up the system until it proved to be more
stable and all critical processing capabilities had been delivered. The
manager believed that trying to use the system to process all of the
office's initial disability claims before the problems affecting their
system's operations were resolved and before all critical processing
capabilities were delivered would prevent the office from maintaining its
productivity levels. In mid-July 2005, California DDS officials stated
that the vendor supporting their disability claims processing system19 had
recently provided a software enhancement that gave them the capability to
fully process claims and that the agency would begin a phased increase in
the number of initial disability claims it would process in the electronic
environment. According to the manager, each examiner would initially be
assigned one disability case per week to process electronically.
In addition, in Florida, DDS officials stated that they had limited the
number of claims being processed by their disability examiners until SSA
was able to enhance their software to achieve better user efficiency. As a
result, at the time of our review, only 109 of the office's 487 disability
examiners were using the electronic system to process cases, and only
about 4 to 5 percent of initial disability claims were being processed
electronically. Further, while the Nebraska DDS's electronic capabilities
were implemented in late June 2005, officials in that office stated that
they did not plan to ramp up their use of the system until about September
2005. They explained that, lacking the software modifications required to
electronically import all documents into the electronic folder, the office
was reluctant to increase its use of the electronic disability system.
They stated that doing so would require them to commit additional
resources to scan documents that could not automatically be entered into
the electronic
18The California DDS was one of the three offices where SSA had initially
piloted the Document Management Architecture hardware and software in
2003. Its implementation of the Document Management Architecture was
completed in September 2004.
19California uses MIDAS software, which is supported by SSA.
system. The officials added that they expect to receive additional
software modifications that they need to improve the efficiency of the
office's electronic processing capability in the September 2005 time
frame.
Given the current status of the electronic disability system, neither SSA
nor the state offices had yet been able to effectively assess or quantify
benefits resulting from its use. All of the managers of the DDS offices
that we contacted stated that they saw the potential for realizing
substantial claims processing improvements from using the system;
nonetheless, these managers-including the managers of the Mississippi and
Illinois DDSs- stated that it was too early to determine whether and to
what extent the electronic disability system would contribute to
processing improvements in their offices. In their view, the system had
not yet reached a level of maturity where it was feasible to quantify the
benefits of its use, due in large measure to factors such as (1) the
learning curve associated with using the system; (2) current
inefficiencies involved in having to maintain paper folders until an
office is certified to electronically process claims; (3) certain DDSs'
decisions to not fully utilize the system until further problem
resolution; and (4) certain offices' use of additional resources, such as
overtime and temporary hires, to support their processing of claims
following the system's implementation. The managers added that processing
claims electronically had thus far taken longer and consumed more
resources than before the electronic system was implemented. In addition,
because of ongoing system implementation in the OHA sites, along with the
normal processing delays associated with bringing disability claims to the
appeals stage, these sites had not yet accrued enough experience in using
the electronic folder to make a reasonable assessment of processing
improvements.
In speaking to the concerns that were raised about the reliability and use
of the electronic disability system, SSA officials acknowledged the
problems that had been identified by the DDSs, and that as a result,
current use of the system among those offices varied considerably.
However, these officials said they believed that the majority of the DDS
offices would be able to bring their systems to full use with only a
minimum of complications; they viewed California's concerns, in
particular, as not having been representative of other states'
experiences. Nonetheless, the officials said that the agency had initiated
a number of measures to address the problems that had been encountered in
using the system. For example, they stated that the agency had established
a new help desk to more readily support those offices experiencing
specific hardware and software problems while using the electronic
disability system. In addition, they
stated that SSA had assembled a work group to examine the DDSs' use of the
electronic forms, with the intent of determining whether a more suitable
commercial-off-the-shelf product was available that could address the
problems currently being encountered with these forms. Regarding the size
of the computer monitors that disability examiners use, the officials
stated that the agency planned to conduct a pilot test to address concerns
with and identify a solution for ensuring that users have the monitors
they need.
SSA's actions to address the outstanding concerns with its electronic
disability system represent a positive step toward achieving success in
the use of the new system. However, as of July 2005, the agency did not
have an overall strategy-articulating milestones, resources, and
priorities-to guide its efforts in efficiently and effectively resolving
the operational problems and system limitations being experienced with the
electronic disability system. For example, although the agency had
established a work group to explore options for resolving problems being
encountered with the electronic forms, it had not yet established plans
and a time frame for completing actions to address this concern. In
addition, although the agency planned to conduct a pilot test of computer
monitors, it did not yet have essential information to determine what type
of equipment would best meet the needs of the electronic disability system
users or the resources and time that it would need to devote to resolving
this matter. Adequately resolving the concerns with and gaining full
acceptance and use of its electronic capabilities will be essential to
SSA's achieving a more efficient means of delivering disability benefits
payments to its increasing beneficiary population.
The Lack of Continuity of Operations Plans for the Electronic Disability
System Places Claims Processing at Increased Risk
In addition to ensuring the immediate availability of the electronic
disability claims processing system by preventing operational problems
that could impact its performance and use, it is essential that SSA and
the DDSs have plans for mutually ensuring the continuity of this vital
disability benefits service in emergency situations. Federal law and
guidance require that agencies develop plans for dealing with emergency
situations involving maintaining services and protecting vital assets that
could result from disruptions, such as localized shutdowns due to severe
weather
conditions, building-level emergencies, or terrorist attacks.20 Moreover,
this guidance notes, a key element in developing a viable continuity
capability is identifying interdependencies among agencies that support
the performance of essential functions and ensuring the development of
complementary continuity of operations plans by those agencies that
provide information or data integral to the delivery of essential
functions. Such planning would include developing and documenting
procedures for continued performance of essential functions, identifying
alternates to fill key positions in an emergency and delegating
decision-making authority, and identifying vital electronic and paper
records-along with measures for ensuring their protection and
availability.
However, SSA and the DDSs currently lack continuity of operations plans to
ensure that the DDS offices could continue to process disability claims in
the event of a short-or long-term disruption to the electronic disability
system. A September 2004 report, issued by SSA's Acting Inspector General,
noted that the agency's existing continuity of operations plan did not
address the information or the electronic disability claims processing
systems managed by the DDSs.21 The report further noted that, in relying
heavily on the DDSs, SSA would lack certainty about the availability of
information from these offices in the event of a disaster. Based on its
findings, the Acting Inspector General recommended that SSA implement a
complete and coordinated continuity of operations plan for the agency.
Officials in the nine DDSs that we contacted further stated that their
offices had not developed continuity of operations plans covering the
electronic disability claims processing capabilities; yet, in discussing
this matter, officials considered such plans to be vital to successfully
ensuring the continued processing of disability claims. Officials in the
Mississippi DDS stressed, for example, that in the event of a disruption
to their system's communications with SSA's headquarters computer
facilities, disability examiners would be unable to access the Document
Management Architecture repository, send or receive faxes via the
electronic system, or access the electronic forms they needed to support
their work. In addition,
20Federal Information Security Management Act of 2002, P. L. 107-347,
Title III, Sec. 301, 44 U.S.C. S:3544(b) (8), Presidential Decision
Directive 67, Enduring Constitutional Government and Continuity of
Government Operations, October 21, 1998.
21Fiscal Year 2004 Evaluation of the Social Security Administration's
Compliance with the Federal Information Security Management Act, September
30, 2004 (A-14-04-14040).
they stated that medical examiners would be unable to perform tasks in
support of disability determinations.
In discussing this matter, SSA officials acknowledged that their existing
plan had not addressed the electronic claims processing functions of the
DDSs. They stated that the agency had recently initiated actions to help
resolve this limitation by having a contractor develop a business
continuity planning strategy. According to the officials, the contractor
began work on this strategy in May 2005 and is expected to deliver an
initial report in September 2005. However, the officials did not
articulate the agency's specific plans or a time frame for ensuring that
its continuity of operations plan addresses the electronic claims
processing functions of the DDS offices or for ensuring that these offices
develop and implement complementary plans for continuing essential
functions to support the disability claims process in an emergency
situation.
As SSA moves toward full implementation and use of the electronic
disability system, the capability to continue essential electronic
disability claims processing functions in any emergency or situation that
may disrupt normal operations becomes increasingly important. In view of
the fact that three states have already begun using electronic folders as
official disability claims records, it is imperative that both SSA and the
DDSs have plans that address the state systems' interdependencies with the
electronic disability claims processing components and that include
preparations for continuing to provide critical claims processing services
in the event of a disaster. Without continuity of operations plans, SSA
will lack assurance that it is positioned to successfully sustain the
essential delivery of disability benefits during unforeseen circumstances.
SSA's Actions toward Implementing AeDib Have Addressed Some, but Not All, of
Our Prior Recommendations for Improvement
As discussed earlier, in reporting on this initiative in March 2004, we
recommended that the agency take measures to reduce the risks associated
with its electronic disability strategy before continuing with its
national rollout of this capability. These recommendations called for the
agency to (1) resolve critical problems that it had identified in pilot
testing of the electronic disability system and conduct end-to-end testing
of the interrelated system components, (2) ensure that users approved the
software being developed and that systems were certified for production,
(3) finalize AeDib risk mitigation strategies, (4) validate AeDib cost and
benefit estimates, and (5) improve communications with and effectively
address the concerns of disability stakeholders and users involved in the
initiative.
In proceeding with the implementation of its electronic disability system,
SSA has taken actions related to three of the five recommendations.
Specifically, SSA officials provided evidence indicating that the agency
has taken measures to ensure that users approve new software and that it
certifies its systems for production. For instance, we reviewed agency
documentation reflecting disability system users' approval of new software
and SSA's certification of over 50 cases where software was put into
production from February 2004 (shortly after the national rollout of the
electronic disability system began) through October 2004. By continuing to
validate its software and certify its systems, SSA should be able to
better ensure that its systems are ready for production and will be
acceptable to their end users.
In addition, regarding our recommendation that it validate AeDib cost and
benefit estimates, SSA has initiated studies, including quarterly
evaluations of the initiative, that could help it assess the electronic
disability system's performance, costs, and processing times. The agency
also has plans for conducting post-implementation reviews of the system,
which include comparing baseline and current information to evaluate the
system's impact on performance, productivity, and cost-measures that if
implemented fully and effectively could help validate AeDib's costs and
benefits.
Further, although the agency has not implemented a communications plan,
DDS officials, including the President of the National Council of
Disability Determination Directors, told us that SSA had improved its
communications with these offices and had made progress in including DDS
officials in AeDib decision making. Such action reflects a positive move
toward involving stakeholders in the agency's efforts. Nonetheless, we
continue to advocate the importance of having a clear and comprehensive
plan for communicating with stakeholders to sustain vital user acceptance
and achieve full use of the electronic disability system.
However, SSA did not demonstrate any actions on two of the
recommendations. As we previously noted, SSA did not take steps to resolve
all of the critical problems that had been identified during pilot testing
of the Document Management Architecture or to conduct end-toend testing of
the interrelated electronic disability system components before continuing
with the national rollout of this system. Resolving all critical problems
and conducting end-to-end testing of the interrelated system components
prior to their implementation could have limited the problems that SSA and
the DDSs have encountered with the electronic
disability system's operation. In the absence of such testing, as SSA
moves to achieve certification and full use of the system, it will be
essential that the agency work diligently to identify and alleviate the
problems that could impact the successful outcome of this technically
complex initiative.
Further, while our earlier work noted that the agency had identified the
risks associated with the AeDib initiative and the related automation
projects, SSA has not provided any evidence that it has yet completed risk
mitigation strategies for these projects. Best practices and federal
guidance advocate risk management-including mitigation strategies-to
reduce risks and achieve schedule and performance goals.22 Among the
high-level risks identified, SSA noted that the overall availability of
the Document Management Architecture might not meet service-level
commitments to its users. Because the DDSs could not effectively perform
their work if the data repository or document scanning and imaging
capabilities provided by the architecture were not available, it is
critical that SSA have mitigation strategies in place to reduce this risk
and to help ensure that the DDSs can meet their performance goals. In the
continued absence of risk mitigation strategies, the agency lacks a
critical means of ensuring that it can prevent circumstances that could
impede a successful project outcome.
Conclusions SSA is relying on its electronic disability system to play a
vital role in improving service delivery to disabled individuals under its
disability programs, and the agency has made considerable progress in
implementing this system. However, even as the agency moves closer to
achieving full systems implementation, important work still needs to be
accomplished to ensure the system's success. Among the agency's critical
tasks will be certifying that all of the SSA and state DDS offices are
prepared to process all disability claims electronically. Yet, a number of
DDSs have concerns about the operations and reliability of the electronic
disability system, noting, for example, inadequacies in electronic forms
and the computer monitors used to view claims information, as well as
limitations in electronic processing capabilities-factors that they say
have slowed system performance and impeded their productivity, and that
have resulted in the levels of system usage varying among the DDSs.
Further, as the agency moves to complete the system's implementation, it
will be essential that SSA and the DDSs have plans for mutually ensuring
the continuity of
22Software Acquisition Capability Maturity Modelsm (CMU/SEI-99-TR-002,
April 1999); OMB Circular A-130 (November 30, 2000).
this vital disability benefits service in emergency situations. The
absence of a defined strategy or plans for ensuring that the electronic
disability system will operate and will meet users' needs as intended
could threaten the continued progress and success of this initiative and
make it uncertain when the agency will realize the full benefits of the
AeDib initiative.
Recommendations for Executive Action
To further reduce the risks to SSA's progress in successfully achieving
its electronic disability claims processing capability, we recommend that
the Commissioner of Social Security take the following two actions:
o develop and implement a strategy that articulates milestones,
resources, and priorities for efficiently and effectively resolving
problems with the electronic disability system's operations, including (1)
identifying and implementing a solution to improve the use of electronic
forms, (2) identifying and implementing a solution to address concerns
with existing computer monitors, and (3) ensuring that the DDSs have the
necessary software capabilities to fully and efficiently process initial
claims in the electronic processing environment; and
o ensure that the state DDSs develop and implement continuity of
operations plans that complement SSA's plans for continuing essential
disability claims processing functions in any emergency or other situation
that may disrupt normal operations.
Agency Comments and Our Evaluation
In written comments on a draft of this report, the Commissioner of Social
Security expressed concern about our references to the agency's testing of
its electronic disability system and offered additional views regarding
our discussion of the state disability determination services' use of
overtime to assist in electronically processing disability claims. In
addition, the agency disagreed with one of our recommendations and agreed
with the other.
Regarding the testing of its electronic disability system, SSA questioned
why our report had concluded-months after the agency's rollout of the
system-that performing end-to-end testing of the interrelated system
components was still critical to the initiative's success. The agency
believed that we should delete references to the criticality of such
testing for this initiative so as not to lend confusion to and cast doubt
on its rollout experience.
In discussing SSA's decision not to conduct end-to-end testing before
rolling out the electronic disability system, our report responds to one
of the two stated objectives of our study-to determine the actions that
SSA has taken in response to our prior recommendations on the AeDib
initiative. In doing so, we did not conclude that it remains critical for
SSA to perform end-to-end testing at this stage in the system's
implementation. Rather, in speaking to this issue, we described the
agency's response to our prior recommendation that it conduct end-to-end
testing before proceeding with the national roll out, and we emphasized
the importance of such testing as a means of limiting the types of
problems that DDS officials told us they have encountered with the
system's operation. As our report stresses, in the absence of end-to-end
testing, it is essential that SSA remain diligent in identifying and
alleviating the problems that could impact the successful outcome of the
AeDib initiative as the agency moves to achieve full certification and use
of the electronic disability system.
Concerning the DDSs' reported cost and use of overtime, SSA emphasized its
belief that a number of factors other than the electronic disability
system had contributed to the Illinois DDS's increased use of overtime.
For example, the agency said that overtime had been used to compensate for
the loss of DDS employees that had accepted the state's offer of early
retirement. Based on our discussions with Illinois DDS officials, we
understand that the office may not have used overtime solely to support
its electronic processing of disability claims. However, as noted in our
report, the Illinois officials told us that they had relied on overtime to
assist in bringing their office to full electronic processing of
disability claims using the new system. We have included language in the
report to more clearly reflect this point.
Beyond these points of discussion, SSA disagreed with our recommendation
that they develop and implement a strategy that articulates milestones,
resources, and priorities for efficiently and effectively resolving
problems with the electronic disability system's operations, including (1)
identifying and implementing a solution to improve the use of electronic
forms, (2) identifying and implementing a solution to address concerns
with existing computer monitors, and (3) ensuring that the DDSs have the
necessary software capabilities to fully and efficiently process initial
claims in the electronic processing environment. Specifically, the agency
stated that it had substantially improved its electronic forms and already
has a strategic project plan to address residual issues concerning them.
It noted that a work group established in January 2005 had examined this
issue and that many key
recommendations had been adopted to improve the performance of and
customer satisfaction with the electronic forms. SSA added that it is
using a contractor to examine alternatives and determine if more robust
software is available to better meet users' needs, and that it may
incorporate new software into the electronic disability claims process.
Our report recognized that SSA had established a work group to explore
options for resolving problems with the electronic forms. However, during
our study, SSA officials could not provide a time table for the work
group's efforts and, despite our inquiries, gave no indication that the
agency had a defined strategy for addressing this area of concern.
Further, SSA did not inform us of a specific contract to examine software
alternatives or of the specific recommendations that have been made to
correct problems with the forms and the improvements in performance and
customer satisfaction that have been achieved. Thus, we did not have an
opportunity to evaluate and comment on the agency's actions in this
regard. Given the DDSs' expressed concerns about the electronic forms
throughout the course of our study and as reflected in SSA's own quarterly
evaluation of the electronic disability system, we continue to stress the
importance of SSA developing and implementing a strategy to guide its
efforts toward efficiently and effectively resolving problems with this
important electronic capability.
Regarding its existing computer monitors, SSA stated that it already has a
plan in place to evaluate this issue and potential ergonomic solutions.
The agency stated that it had awarded a contract to conduct a controlled
test of the impact of various monitor configurations on ergonomics and
productivity for all primary users of the electronic disability system,
and that a final report is due in January 2007. It added that when final
decisions are made regarding the appropriate monitor requirements, a
business plan will be deployed if warranted. As noted in our report, SSA
officials did inform us of their intent to conduct a pilot test to
identify potential solutions for ensuring that users have appropriate
monitors. However, the officials could not provide contractual and other
pertinent documents explaining the pilot study and did not inform us of
any plan that the agency had developed to guide this effort. Given that
SSA does not anticipate its final report on its test of the monitor
configurations until January 2007, and does not intend to consider the
deployment of a business plan until final decisions are made regarding the
monitor requirements, we believe that the agency could benefit from a
strategy articulating clear milestones, resources, and priorities to guide
its efforts toward finalizing decisions on
its computer monitors and ensure that all users' concerns are fully and
effectively addressed.
Further, regarding the DDSs' software capabilities, SSA stated that it had
established a help desk to provide support for specific hardware and
software issues associated with the electronic disability system, and that
it had no information that there are outstanding issues concerning DDS
software support. Moreover, the agency stated that our report had
inaccurately described supposed issues related to implementing the
electronic disability system in light of some states having not yet been
certified to fully process cases electronically. For example, SSA
commented that because Florida had not yet been certified to fully process
cases electronically, it was premature to expect that the electronic
disability system would notify staff of actions to process claims.
Similarly, SSA stated that because Nebraska had not been certified to
process cases electronically, it was premature to indicate that the state
needed additional software modifications to electronically import all
required documents into the electronic folder. Further, the agency said
that it was inaccurate for us to report that the North Carolina DDS lacked
the necessary software to enable staff to electronically send claim files
to SSA's Disability Quality Branch, since all but two states-New York and
Nebraska-had this software. It added that the agency's planning and
electronic disability system roll out had addressed software capabilities
and other issues impacting individual DDSs, negating the need for a formal
strategy, as we have recommended.
We disagree that our report inaccurately described issues related to
implementing the electronic disability system or that it prematurely
highlighted limitations in certain states' use of the system. A primary
aspect of our review involved examining SSA's progress in rolling out the
electronic disability system, including the state DDSs' experiences in
implementing and using the system. In this regard, DDS officials apprised
us of their electronic disability claims processing capabilities, and in
certain instances, of their need for additional software capabilities that
they deemed essential to improving their offices' processing efficiency
and sustaining productivity in the electronic environment. As of mid-July
2005, North Carolina DDS officials told us that they lacked the necessary
software to enable staff to electronically send claim files to SSA's
Disability Quality Branch. We recognize that SSA does not expect to
complete all states' certifications until early 2007. However, in our
view, until the agency ensures that all DDSs have full electronic
processing capabilities, it will not be positioned to effectively assess
the extent to which the electronic
disability system can contribute to a more efficient and effective
disability claims process.
SSA further stated that system availability issues had been addressed, as
evidenced by its current fiscal year data on key electronic disability
system components (e.g., the Electronic Disability Collect System, the
Case Processing Management System, and the Document Management
Architecture). However, our report does not convey that these key
electronic disability system components were not available for use.
Rather, the concerns discussed in our report pertain to the inefficiencies
that DDS officials said they had encountered in using the electronic
disability system. For example, DDS officials pointed to the continuing
instances in which they had experienced processing slowdowns when using
electronic forms, which ultimately had impeded their disability claims
processing capability. Thus, we stand by our recommendation that SSA
develop and implement a strategy to ensure that the DDSs have the
necessary software capabilities to fully and efficiently process claims in
the electronic environment.
Regarding our second recommendation, the agency agreed to ensure that the
state DDSs develop and implement continuity of operations plans that
complement SSA's plans for continuing essential disability claims
processing functions during emergencies or other disruptions to normal
operations. In this regard, the commissioner stated that SSA is highly
committed to providing uninterrupted services to the public and had hired
a contractor to develop business continuity plans for the DDSs that
document how these offices would respond to long-and short-range
disruptive events. The actions that SSA stated that it is taking should
help improve the agency's and the DDSs' ability to ensure the continuity
of vital disability benefits services in emergency situations.
In addition to the aforementioned comments, SSA provided technical
comments, which we have incorporated, as appropriate. Appendix II
reproduces the agency's comments on our draft report.
As agreed with your office, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 30 days from
the report date. At that time, we will send copies of this report to the
Commissioner of Social Security and the Director, Office of Management and
Budget. Copies will also be available at no charge on our Web site at
www.gao.gov.
Should you have any questions on matters contained in this report, please
contact me at (202) 512-6240. I can also be reached by email at
[email protected]. Contact points for our Offices of Congressional Relations
and Public Affairs may be found on the last page of this report. Key
contributors to this report are listed in appendix III.
Sincerely yours,
Linda D. Koontz Director, Information Management Issues
Appendix I
Objectives, Scope, and Methodology
Our objectives were to (1) assess the current status of SSA's accelerated
implementation of its electronic disability system-the initiative known as
AeDib and (2) identify actions the agency has taken in response to our
prior recommendations on this initiative. To assess the agency's status in
implementing its electronic disability system, we analyzed relevant
project management documentation including schedules, project plans, and
reports documenting the status of the system's rollout to the 54 state
disability determination service (DDS) offices and SSA's 144 Office of
Hearings and Appeals (OHA) sites. In addition, we reviewed technical
documentation, such as software project scope agreements and software
development plans, to assess the development, implementation, and
operation of the electronic disability system. We also reviewed system
release certifications to ensure that systems had been validated and
certified.
To identify issues that arose during the AeDib implementation process, we
reviewed problems reported by the DDSs via SSA's Change Asset Problem
Reporting System. We also reviewed the results of the National Council of
Disability Determination Directors' February 2005 survey of its member DDS
offices on their experiences in implementing the electronic disability
system, as a means of identifying any problems and issues that the states
had encountered. In addition, we reviewed reports on the system's
implementation, performance, and capacity that had been prepared by the
Council and the DDSs.
We supplemented our analysis with interviews of SSA officials in the
Offices of Operations, Systems, Disability and Income Security Programs,
and Hearings and Appeals. We also interviewed DDS officials in nine
states: California, Delaware, Florida, Illinois, Mississippi, Nebraska,
New York, North Carolina, and South Carolina. In addition, we interviewed
the President of the National Council of Disability Determination
Directors, an organization that represents the DDSs.
Our selection of the nine states was based on the following criteria:
o The Mississippi DDS was the first state to which the electronic
disability system was rolled out, as well as the first state to achieve
total electronic processing of initial disability cases.
o The California, Illinois, and North Carolina DDSs had participated in
initial pilot tests of the electronic processing system, which had
included assessing use of the Document Management Architecture.
Appendix I
Objectives, Scope, and Methodology
o The Florida and South Carolina DDSs were states that received the
electronic disability system early in the implementation schedule.
o The New York and Nebraska DDSs posed potential unique challenges as the
only two "independent" states, in which their existing claims processing
capabilities were not supported by the common hardware platform that the
majority of DDSs used and that had developed and were relying on
disability claims processing software that was unique to their processing
environments.
o The Delaware DDS was managed by the President of the National Council
of Disability Determination Directors.
We conducted site visits at two DDSs-Mississippi and South Carolina-to
observe the electronic processing system in operation, and at OHA sites in
these same states to discuss their experiences in implementing and using
the electronic folder and their preparation for receiving appeals of
initial claims that had been processed electronically in the respective
state DDS offices.
To determine what actions SSA had taken toward implementing our prior
recommendations on the electronic disability system, we obtained and
reviewed software project scope agreements, software development plans,
user validation and system certification plans, and AeDib component
security risk assessment documentation. We also interviewed agency
officials regarding the status of their actions on each of the
recommendations made in our March 2004 report on AeDib. In addition, we
discussed SSA's efforts to improve communications on the initiative's
implementation with DDS officials in each of the offices that we contacted
and with the President of the National Council of Disability Determination
Directors.
We conducted our work at SSA's headquarters in Baltimore, Maryland, and at
selected DDS and OHA offices in Jackson, Mississippi, and Columbia, South
Carolina, from October 2004 to July 2005, in accordance with generally
accepted government auditing standards.
Appendix II
Comments from the Social Security Administration
Appendix II
Comments from the Social Security
Administration
Appendix II
Comments from the Social Security
Administration
Appendix II
Comments from the Social Security
Administration
Appendix II
Comments from the Social Security
Administration
Appendix II
Comments from the Social Security
Administration
Appendix III
GAO Contact and Staff Acknowledgments
GAO Contact Linda D. Koontz (202) 512-6240
Staff In addition to the individual named above, Valerie C. Melvin,
Assistant Director; Michael A. Alexander; J. Michael Resser; and Eric L.
Trout made
Acknowledgments significant contributions to this report. Neil J. Doherty
and Joanne Fiorino also contributed to the report.
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