Federal Disability Programs: More Strategic Coordination Could	 
Help Overcome Challenges to Needed Transformation (20-MAY-08,	 
GAO-08-635).							 
                                                                 
In 2003, GAO designated federal disability programs as a	 
high-risk area because federal disability programs remained	 
grounded in outmoded concepts that have not been updated to	 
reflect the current state of science, medicine, technology, and  
labor market conditions. In addition, the Social Security	 
Administration (SSA) and the Department of Veterans Affairs (VA) 
faced management challenges, especially with their disability	 
claims processing. Further, disability experts have expressed	 
concerns about the level of coordination among the many federal  
agencies that provide benefits and services to individuals with  
disabilities. GAO was asked to determine: (1) what steps SSA and 
VA have taken to modernize their disability programs and (2) to  
what extent SSA and VA coordinate with other federal agencies	 
that provide services to individuals with disabilities. To do	 
this, GAO reviewed literature, agency strategic plans and	 
performance and accountability reports, and interviewed agency	 
officials.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-08-635 					        
    ACCNO:   A82148						        
  TITLE:     Federal Disability Programs: More Strategic Coordination 
Could Help Overcome Challenges to Needed Transformation 	 
     DATE:   05/20/2008 
  SUBJECT:   Aid for the disabled				 
	     Claims processing					 
	     Cost analysis					 
	     Cost control					 
	     Disabilities					 
	     Disability benefits				 
	     Eligibility criteria				 
	     Eligibility determinations 			 
	     Employees with disabilities			 
	     Employment 					 
	     Employment assistance programs			 
	     Employment of the disabled 			 
	     Federal employee disability programs		 
	     Interagency relations				 
	     Persons with disabilities				 
	     Policy evaluation					 
	     Program evaluation 				 
	     Program management 				 
	     Rehabilitation programs				 
	     Risk management					 
	     Schedule slippages 				 
	     Veterans benefits					 
	     Veterans employment programs			 
	     Program coordination				 
	     program goals or objectives			 
	     GAO High Risk Series				 
	     SSA Ticket to Work and Self-Sufficiency		 
	     Program						 
                                                                 

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GAO-08-635

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Could Help Overcome Challenges to Needed Transformation' which was 
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Report to the Ranking Member, Subcommittee on Oversight of Government 
Management, the Federal Workforce, and the District of Columbia, 
Committee on Homeland Security and Governmental Affairs, U.S. Senate: 

United States Government Accountability Office: 
GAO: 

May 2008: 

Federal Disability Programs: 

More Strategic Coordination Could Help Overcome Challenges to Needed 
Transformation: 

GAO-08-635: 

GAO Highlights: 

Highlights of GAO-08-635, a report to the Ranking Member, Subcommittee 
on Oversight of Government Management, the Federal Workforce, and the 
District of Columbia, Committee on Homeland Security and Governmental 
Affairs, U.S. Senate. 

Why GAO Did This Study: 

In 2003, GAO designated federal disability programs as a high-risk area 
because federal disability programs remained grounded in outmoded 
concepts that have not been updated to reflect the current state of 
science, medicine, technology, and labor market conditions. In 
addition, the Social Security Administration (SSA) and the Department 
of Veterans Affairs (VA) faced management challenges, especially with 
their disability claims processing. Further, disability experts have 
expressed concerns about the level of coordination among the many 
federal agencies that provide benefits and services to individuals with 
disabilities. 

GAO was asked to determine: (1) what steps SSA and VA have taken to 
modernize their disability programs and (2) to what extent SSA and VA 
coordinate with other federal agencies that provide services to 
individuals with disabilities. To do this, GAO reviewed literature, 
agency strategic plans and performance and accountability reports, and 
interviewed agency officials. 

What GAO Found: 

SSA and VA have taken some initial steps to recognize a more modern 
concept of disability, but both agencies still encounter challenges in 
fully assessing an individualï¿½s capacity to work and in addressing 
claims processing problems. SSA and VA have revised some eligibility 
criteria to reflect medical advances and to support beneficiariesï¿½ 
efforts to return to work and achieve self-sufficiency. However, their 
revisions to eligibility criteria fall short of fully incorporating a 
modern understanding of how technology and labor market changes should 
impact eligibility for disability benefits and return-to-work rates 
remain low. The low return-to-work rates may be due, in part, to the 
timing in which certain supports are offered to beneficiaries. However, 
the timing of services are constrained by several factors, including 
program design, laws, and the agenciesï¿½ limited span of authority over 
benefits and services offered by other agencies. Finally, although SSA 
and VA are taking steps to address management challenges, both agencies 
continue to experience delays in processing disability claims and 
persistent backlogs. 

Figure: Agencies Working Together to Integrate Services for Individuals 
with Disabilities: 

[See PDF for image] 

This figure is an illustration of agencies working together to 
integrate services for individuals with disabilities. Agencies 
represented are: 
Education; 
Labor; 
Veterans Administration; 
Social Security Administration; 
Health and Human Services; 
Other Agencies. 

Agenda: 
Develop federal strategy to integrate services for individuals with 
disabilities. 

Source: GAO analysis, Art Explosion (images). 

[End of figure] 

SSA and VA disability programs partner with other federal agencies that 
provide services to individuals with disabilities on specific 
initiatives, but governmentwide coordination of cross-cutting programs 
is lacking. For example, SSA and VA have partnered with specific 
agencies to support employment-related services, conduct research, and 
improve the integrity and operation of their disability programs, among 
other things. While interagency partnerships may help to improve some 
programs, individuals with disabilities and the programs serving them 
continue to operate without a centralized federal strategy or a 
coordinating entity to ensure federal policies, services, and supports 
are aligned. 

What GAO Recommends: 

GAO suggests that Congress, in consultation with key agencies and other 
stakeholders, consider authorizing an entity consisting of leaders from 
appropriate federal agencies to develop a cost-effective federal 
strategy that would integrate services and support to individuals with 
disabilities. The agencies reviewed our report and provided technical 
comments. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-635]. For more 
information, contact Daniel Bertoni at (202) 512-7215 or 
[email protected]. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

SSA and VA Have Taken Steps to Modernize Their Disability Programs, but 
Fully Recognizing Capacity to Work, Providing Timely Return-to-Work 
Initiatives, and Addressing Claims Processing Issues Remain 
Challenging: 

SSA and VA Are Making Efforts to Partner with Other Federal Agencies, 
but Governmentwide Coordination of Cross-Cutting Programs Is Lacking: 

Conclusions: 

Matter for Congressional Consideration: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Entities Making Recommendations to SSA and VA: 

Appendix III: Employment Supports for SSA's Disability Insurance (DI) 
and Supplemental Security Income (SSI) Beneficiaries: 

Appendix IV: Comments from the Department of Education: 

Appendix V: Comments from the Department of Health and Human Services: 

Appendix VI: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: VA's Five Tracks to Employment: 

Table 2: VA Claims Processing Teams: 

Figures: 

Figure 1: SSA's Five-Step Process for Determining Disability: 

Figure 2: SSA's Medical Listings Feedback Loop: 

Figure 3: Stages in SSA's Claims Process: 

Figure 4: Individuals with Disabilities Experience a Fragmented Federal 
Disability System: 

Figure 5: Federal Strategy to Integrate Services for Individuals with 
Disabilities: 

Abbreviations: 

CMS: Centers for Medicare and Medicaid Services: 

DDS: Disability Determination Services: 

DI: Disability Insurance: 

Education: Department of Education: 

HHS: Department of Health and Human Services: 

IDCC: Interagency Disability Coordinating Council: 

Labor: Department of Labor: 

NCD: National Council on Disability: 

NIH: National Institutes of Health: 

SGA: substantial gainful activity: 

SSI: Supplemental Security Income: 

SSA: Social Security Administration: 

VA: Department of Veterans Affairs: 

VDBC: Veterans' Disability Benefits Commission: 

VETS: Veterans' Employment and Training Services: 

VR&E: Vocational Rehabilitation and Employment Program: 

[End of section] 

United States Government Accountability Office: Washington, DC 20548: 

May 20, 2008: 

The Honorable George V. Voinovich: 
Ranking Member: 
Subcommittee on Oversight of Government Management, the Federal 
Workforce, and the District of Columbia: Committee on Homeland Security 
and Governmental Affairs: United States Senate: 

Dear Senator Voinovich: 

In 2005, the Social Security Administration (SSA) and the Department of 
Veterans Affairs (VA) collectively provided over $150 billion in cash 
benefits to individuals with disabilities and their families. During 
this timeframe, these agencies provided cash assistance to 
approximately 12.8 million SSA beneficiaries and 2.6 million VA 
beneficiaries. SSA and VA disability programs are expected to grow as 
baby boomers enter their disability-prone years and service members 
injured in the line of duty, including those returning from conflicts 
such as Operation Iraqi Freedom and Operation Enduring Freedom, apply 
for benefits. Both SSA and VA have experienced difficulty processing 
their disability claims workload, resulting in large backlogs and long 
waits for claimants seeking benefits. 

GAO designated federal disability programs as a high-risk area in 2003. 
In particular, our prior work found that three of the largest 
disability programs in SSA and VA relied on outmoded criteria for 
determining program eligibility that did not fully reflect advances in 
medicine and technology or changes in the labor market. As a result, 
SSA's and VA's disability programs may not recognize an individual's 
full potential to work. While SSA and VA disability programs differ in 
the purpose and populations they serve, they face similar challenges in 
making complex determinations about individuals with impairments and 
their capacity to work in today's labor market. 

Although SSA and VA are the largest providers of disability benefits, 
over 20 agencies and almost 200 federal programs provide benefits and 
services to individuals with disabilities. The Department of Education 
(Education), the Department of Labor (Labor), the Department of Health 
and Human Services (HHS), and the Centers for Medicare and Medicaid 
Services (CMS), an agency within HHS, are among the agencies that 
provide assistance for those with disabilities. Historically, these 
agencies have overseen a multitude of stand-alone services, including 
vocational rehabilitation, employment assistance, and health care. 
However, disability experts and advocates have expressed concerns about 
the level of coordination among the many federal agencies that provide 
benefits and services to individuals with disabilities and the effect 
this may have. Additionally, disability experts have noted that there 
is no agreement on the desired outcomes that these agencies together 
should achieve. With increasing expenditures, a growing beneficiary 
population, and the number of programs involved with providing 
assistance to individuals with disabilities, the importance of 
modernizing and effectively coordinating federal disability programs is 
greater than ever. 

In light of these challenges, you asked us to determine (1) what steps 
SSA and VA have taken to modernize their disability programs and (2) 
the extent to which SSA and VA have coordinated with other federal 
agencies that provide services to individuals with disabilities. 

To identify the steps that SSA and VA have taken to modernize their 
disability programs, we conducted a literature review using prior GAO 
reports, studies conducted by SSA's and VA's Inspectors General, and 
position papers and testimonies from various agencies, groups, and 
commissions (including the National Council on Disability (NCD), the 
Social Security Advisory Board, the Institute of Medicine, and the 
Veterans' Disability Benefits Commission). In addition, we reviewed SSA 
and VA internal documents and interviewed knowledgeable SSA and VA 
officials to obtain information on the current process and status of 
incorporating present-day medical advances and labor market conditions 
into their disability eligibility criteria. We also interviewed agency 
officials and reviewed agency documents to learn about the range of 
SSA's and VA's planned and ongoing return-to-work initiatives. To 
determine the extent to which SSA and VA coordinate with Education, 
Labor, HHS, and CMS, within HHS, on programs that serve individuals 
with disabilities, we analyzed SSA's and VA's performance plans and 
memorandums of understanding and interviewed officials from each of 
these agencies to ascertain the nature and extent of their 
collaboration. The details of our scope and methodology are in appendix 
I. 

We conducted this performance audit from May 2007 to May 2008 in 
accordance with generally accepted government auditing standards. Those 
standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

Results in Brief: 

SSA and VA have taken some initial steps to revise eligibility criteria 
to reflect medical advances and to support beneficiaries' efforts to 
return to work and achieve self-sufficiency, but challenges remain with 
adequately identifying an individual's capacity to work. SSA and VA 
also continue to face challenges with providing timely interventions to 
support return to work and addressing claims processing challenges, 
such as large backlogs. In 2002, we reported that SSA's and VA's 
eligibility criteria were outdated. Since then, SSA has implemented a 
new process for updating its eligibility criteria and has made changes 
to one-half of its 14 body systems--criteria based on each of the major 
body systems, such as respiratory and neurological--to reflect medical 
advances. In that same time period, VA has made changes to 1 of its 16 
body systems. While both agencies are updating their eligibility 
criteria to stay current with medical advances, the updating of 
criteria fall short of fully incorporating a modern understanding of 
how technology and labor market changes should impact the agencies' 
determination of individuals' eligibility for disability benefits. 
Moreover, although SSA and VA have been modifying their programs to 
better support beneficiaries' efforts to return to work, both agencies 
continue to have low return-to-work rates, perhaps due, in part, to the 
timing in which certain supports are offered to beneficiaries. Some 
experts have suggested that earlier access to vocational rehabilitation 
and health care might improve return-to-work rates. However, 
constraints, including the program design, laws, and the agencies' 
limited span of authority over benefits and services offered by other 
agencies, may hinder SSA and VA from providing this earlier access. 
Finally, although SSA and VA are taking steps to address claims 
processing challenges, both agencies continue to experience delays in 
processing disability claims and have persistent backlogs. 

SSA and VA disability programs partner with other federal agencies that 
provide services to individuals with disabilities on specific 
initiatives, but governmentwide coordination of cross-cutting programs, 
which experts and agency officials believe could improve program 
efficiency and effectiveness, is lacking. SSA and VA have partnered 
with specific agencies to support employment-related services, conduct 
research, and improve the integrity and operation of their disability 
programs, among other things. For example, VA established an 
interagency agreement with Labor to facilitate employment supports for 
their beneficiaries. However, in establishing such partnerships, both 
SSA and VA have encountered challenges, such as restrictions on data 
sharing. Additionally, policies and programs serving individuals with 
disabilities were developed over many years, with differing missions 
and eligibility criteria, creating a patchwork of federal policy and 
program initiatives without a unified set of national goals. Previous 
congressional and executive initiatives to address these issues have 
had limited success. As a result, individuals with disabilities and the 
programs serving them are operating without a centralized federal 
strategy or a coordinating entity to ensure policies, services, and 
supports are aligned. 

We are submitting a matter for congressional consideration. In order to 
ensure that federal disability policy is clearly stated, programs and 
policies are better coordinated, and to reduce the possibility of 
inefficiencies and duplication of programs, we are offering options for 
Congress, in consultation with key stakeholders, to consider 
authorizing a coordinating entity consisting of leadership from 
appropriate federal agencies to develop a cost-effective federal 
strategy to integrate services and support for individuals with 
disabilities. A successful coordinated federal effort should include 
defining and articulating common outcomes and establishing mutually 
reinforcing joint strategies among federal agencies to achieve 
identified goals. Further, clear agreement on agency roles and 
responsibilities and agency accountability for collaborative efforts 
will be critical to success. SSA, VA, HHS, Education, and Labor 
reviewed draft copies of this report and provided us with technical 
comments that we have incorporated as appropriate. 

Background: 

SSA and VA administer the largest federal disability programs, which 
have grown in size, cost, and complexity. SSA and VA provide cash 
assistance to individuals with a reduced capacity to work due to 
impairment; however, the programs differ in their intent and 
eligibility criteria. 

* SSA administers two disability programs: the Disability Insurance 
(DI) program, enacted in 1956, and the Supplemental Security Income 
(SSI) program, enacted in 1972. The DI program provides income for 
persons who have a Social Security work record. The amount of benefits 
is related to prior earnings levels. The SSI program provides monthly 
benefits to people with limited income and resources, who are disabled, 
blind, or age 65 or older. Blind or disabled children, as well as 
adults, can receive SSI. Initial determinations for disability benefits 
are made at state agencies called Disability Determination Services 
(DDS). If an applicant is initially denied benefits, he or she 
generally has three levels of appeal available within SSA: 
reconsideration (also administered at DDS), hearing (overseen by an 
administrative law judge), and Appeals Council. In order to be eligible 
for DI or SSI disability benefits, an individual must have a medically 
determinable physical or mental impairment that (1) has lasted or is 
expected to last at least 1 year or to result in death and (2) prevents 
the individual from engaging in substantial gainful activity 
(SGA).[Footnote 1] SSA uses a five-step process to evaluate an adult 
applicant's eligibility for disability benefits (see fig. 1).[Footnote 
2] Once an applicant meets the first two criteria outlined above, SSA 
looks to the Listings of Impairments (also known as the medical 
listings), which describes medical conditions that are determined by 
the agency to be severe enough to qualify an applicant as disabled as 
defined by law and eligible for benefits. At the end of October 2007, 
nearly 8.9 million disabled workers and their dependents were receiving 
DI benefits, and nearly 6.2 million individuals with disabilities 
received federally administered SSI payments. 

Figure 1: SSA's Five-Step Process for Determining Disability: 

[See PDF for image] 

This figure is an illustration of SSA's five-step process for 
determining disability. The following information is illustrated: 

Step 1: Work test: 
Is the claimant working and earning more than substantial gainful 
activity? 
If yes: benefits denied; 
If no, go to step 2. 

Step 2: Severity test: 
Does the claimant have a severe impairment that significantly limits 
his or her ability to do basic work activities and that also meets the 
duration requirements? 
If yes: go to step 3; 
If no, benefits denied. 

Step 3: Medical listings test; 
Does the condition meet SSAï¿½s medical listings, or is the condition 
equal in severity to one found on the medical listings?
If yes: benefits awarded; 
If no, go to step 4. 

Step 4: Previous work test: 
Can a person with the claimantï¿½s residual functional capacity perform 
any of the claimantï¿½s past work? 
If yes: benefits denied; 
If no, go to step 5. 

Step 5: Any work test: 
Can the claimant perform other types of work that exist in the national 
economy? 
If yes: benefits denied; 
If no, benefits awarded. 

Source: GAO analysis of SSA data. 

[End of figure] 

* VA's disability program compensates veterans for the average loss in 
earning capacity in civilian occupations that result from injuries or 
conditions incurred or aggravated during military service.[Footnote 3] 
VA uses a Schedule for Rating Disabilities (ratings schedule) as its 
set of criteria for determining if a veteran is eligible for disability 
benefits. VA determines the disability benefit level using a 
"percentage evaluation," commonly called the disability rating, which 
represents the average loss of earning capacity associated with the 
severity of physical or mental conditions, regardless of current 
employment status or income. In addition to cash assistance, VA 
provides disabled veterans with health care, vocational rehabilitation, 
and other employment-related services. As of 2006, 2.7 million veterans 
were receiving VA disability compensation, totaling $26.6 billion. 

SSA and VA disability beneficiaries may obtain assistance from other 
federal agencies for services, such as vocational rehabilitation, 
health care, and employment-related assistance. These agencies include 
Education, Labor, HHS, and CMS, an agency within HHS. All of these 
programs can differ in the populations they intend to serve and in the 
specific approaches they use to assess program eligibility. SSA and VA 
beneficiaries may receive the following benefits and services, among 
others: 

* Vocational rehabilitation and employment-related assistance. 
Individuals with disabilities, including SSA and VA beneficiaries, can 
obtain vocational rehabilitation services from providers, such as state 
vocational rehabilitation agencies, funded by Education's 
Rehabilitation Services Administration. Labor also provides employment-
related services to individuals with disabilities through its workforce 
investment system, such as employment and training services to eligible 
veterans through its Veterans' Employment and Training Service (VETS). 
VA's Vocational Rehabilitation and Employment Program (VR&E) provides a 
variety of employment-related services exclusively for veterans. 

* Medical care. CMS, as part of HHS, provides medical benefits to 
individuals with disabilities primarily through two programs: Medicare 
and Medicaid. Medicare provides health coverage to almost all Americans 
aged 65 or older, as well as people with disabilities who qualify for 
assistance. Medicaid provides access to health care services for 
certain individuals and families with low incomes and resources, 
including SSI beneficiaries. VA provides health care to its veterans 
through the Veterans Health Administration, which is a part of the VA. 

Congress has taken actions to encourage federal efforts to promote 
employment and self-sufficiency for individuals with disabilities by 
creating new programs and expanding existing programs that often span 
multiple federal agencies. For example, in 1999, Congress passed the 
Ticket to Work and Work Incentives Improvement Act[Footnote 4] to 
support individuals with disabilities' efforts to work by increasing 
beneficiaries' choices for rehabilitation and vocational services, 
reducing disincentives to work, and providing options for continuing 
health care coverage. The Act established the Ticket to Work Program, a 
voluntary program that provides eligible SSA beneficiaries with a 
"ticket" voucher that can be used to access employment services and 
supports. The Act also established certain programs to provide work 
incentives for SSA beneficiaries. For example, in recognition of health 
care being an important factor for many SSA disability beneficiaries, 
the Act allowed DI beneficiaries who earn above SGA levels to maintain 
Medicare coverage for up to 93 months following the end of a trial work 
period. The Act also established a state option to offer a Medicaid buy-
in program for workers with disabilities. 

Our prior work has examined SSA and VA modernization efforts, including 
exploring the extent to which these agencies are using updated medical, 
workforce, and economic information to inform their program eligibility 
criteria and steps the agencies were taking to improve the timeliness 
and accuracy of their claims evaluation process. We determined that 
SSA's and VA's disability programs were grounded in outmoded concepts 
of disability and that both agencies had difficulty managing their 
programs, including addressing a growing backlog of pending claims. We 
found that SSA's and VA's disability criteria had not been updated to 
reflect the current state of science, medicine, technology, and labor 
market conditions. In addition, we found both SSA and VA have lengthy 
disability claims processing times and limited assurance of the 
accuracy and consistency of disability decisions. As such, in 2003 GAO 
designated federal disability programs as a high-risk area.[Footnote 5] 

Concerns about SSA's and VA's disability programs have generated 
reviews by multiple other entities. These entities have provided 
various recommendations on how SSA and VA can incorporate present-day 
concepts into their programs, increase coordination with other 
programs, and improve service. Such entities include NCD, an 
independent federal agency that provides recommendations to the 
President and Congress to promote policies, programs, practices, and 
procedures that guarantee equal opportunity for individuals with 
disabilities.[Footnote 6] Other recommendations have been formulated by 
the Institute of Medicine of the National Academies, the Social 
Security Advisory Board, the Ticket to Work and Work Incentives 
Advisory Panel, the Veterans' Disability Benefits Commission, and the 
Commission on Care for America's Returning Wounded Warriors. (See app. 
II for more information about these entities.) Each of these groups was 
formed by executive or congressional recommendation to review VA's and 
SSA's disability programs. Some of these groups, such as the Commission 
on Care for America's Returning Wounded Warriors, were formed to review 
a program for a limited period of time, while others, such as the 
Social Security Advisory Board, were formed without a sunset date, 
allowing them to provide ongoing guidance on specific disability 
programs. 

SSA and VA Have Taken Steps to Modernize Their Disability Programs, but 
Fully Recognizing Capacity to Work, Providing Timely Return-to-Work 
Initiatives, and Addressing Claims Processing Issues Remain 
Challenging: 

SSA and VA have taken some initial steps to revise eligibility criteria 
in their disability programs, but three key challenges remain: 
incorporating a modern understanding of an individual's capacity to 
work, providing timely interventions to support return to work, and 
addressing growing claims processing challenges. SSA and VA have made 
some revisions to their eligibility criteria, but both agencies are, to 
some extent, still relying on outdated concepts. These outdated 
concepts continue to equate medical severity with an inability to work 
and may not adequately take into account technological advances that 
provide a wider range of employment options for individuals with 
disabilities in today's labor market. While SSA and VA have been 
modifying their programs to better support beneficiaries' efforts to 
return to work, both agencies continue to have low return-to-work 
rates, perhaps due, in part, to the timing in which supports and 
interventions are given to their beneficiaries. Both agencies also 
continue to face challenges with processing their disability claims in 
a timely manner and reducing growing backlogs. 

SSA and VA Face Challenges with Fully Incorporating Medical, 
Technological, and Labor Market Changes into Their Eligibility 
Criteria: 

SSA and VA have revised some of their eligibility criteria to reflect 
medical advances but continue to face challenges with fully 
incorporating all of the factors that should play a critical role in 
eligibility criteria--medical, technological, and labor market changes. 
In 2002, we reported that both SSA and VA were slow to incorporate 
medical advances into their criteria and did not have specific time 
frames for making their updates.[Footnote 7] Since then, SSA began 
using an outreach-based model to update its medical listings. As shown 
in figure 2, under this model, SSA incorporates feedback from multiple 
parties, including medical experts and disability examiners, to update 
their medical criteria. As of January 2008, SSA officials told us they 
had completed updating an additional seven body systems and expect to 
finish the remaining seven body system updates by mid- 2010.[Footnote 
8] However, SSA officials told us that their release dates on the 
updates could change based on the review process. With regard to VA's 
eligibility criteria, in 2002 we reported that VA had completed 11 of 
16 body systems updates. Since then, VA has completed updating 1 
additional body system.[Footnote 9] VA officials did not have specific 
timelines for updating the remaining body systems, in part, because VA 
is awaiting results from an ongoing external study being conducted by 
Economic Systems, Inc. The study, which is expected to be completed in 
August 2008, is assessing VA's entire disability system, which could 
impact how they revise their eligibility criteria. Additionally, VA 
officials cited other reasons for the uncertainty surrounding the 
estimated completion of the remaining updates, including the lack of 
staff available to make updates and a lengthy internal and external 
review process. 

Figure 2: SSA's Medical Listings Feedback Loop: 

[See PDF for image] 

This figure is an illustration of SSA's medical listings feedback loop, 
as follows: 

* Internal 1 year study; 
* External 1 year study; 
* Publish Advanced Notice of Proposed Rulemaking; 
* Host outreach; 
* Input from regions and medical specialists; 
* Draft the Notice of Proposed Rulemaking; 
* Case studies; 
* Internal comments; 
* Office of Management and Budget; 
* Publish Notice of Proposed Rulemaking; 
* Receive public comments; 
* Draft final rule; 
* Office of Management and Budget; 
* Publish regulation for new or revised body system; 
* Questions from field; 
* Back to first step. 

Source: GAO analysis of SSA data. 

[End of figure] 

Although SSA and VA continue to update their medical eligibility 
criteria, the updates do not always account for technological advances 
or labor market changes that affect an individual's potential to work. 
Historically, severe medical conditions were often considered to be 
reliable indicators of one's ability to function in the workplace. 
However, in the years since SSA's and VA's disability programs were 
created, jobs in our workforce and the availability of technological 
assistance have changed. These technological advances and labor market 
changes provide more opportunities for some individuals with 
disabilities to participate in the workforce. For example, the Social 
Security Advisory Board reported that jobs in the manufacturing sector 
accounted for over 40 percent of the jobs in the U.S. economy in the 
mid-1950s, as compared to 18 percent in 2002. In an economy that relied 
so heavily on physical labor, the severity of one's medical condition, 
in many instances, may have been an appropriate indicator of one's 
capacity to work. Because the U.S. economy has shifted from a 
manufacturing-based economy to a service-and knowledge-based economy, 
assessing the degree to which a medical condition limits an 
individual's ability to participate in the workforce becomes more 
complex. Additionally, as technology advances, people with medical 
impairments may be able to use technology to help them perform job 
functions. For example, voice recognition could make it easier to work 
in the current economy if an individual had an impairment that limited 
their ability to use a computer keyboard. Medical severity as measured 
by clinical findings alone may not reflect one's ability to function in 
the workplace, considering the availability of assistive devices and 
new workplace technology. 

SSA's medical listings do not consistently reflect one's ability to 
work in the current labor market, and as a result, individuals with 
disabilities may not receive an accurate assessment of their potential 
to participate in the workforce. If individuals meet the criteria set 
forth in the medical listings, they become automatically eligible for 
disability benefits. While the medical listings were originally 
established to serve as an objective proxy for determining disability, 
they do not consistently evaluate an individual's capacity to function 
in today's work setting with accommodation. Rather, the listings equate 
medical severity with the incapacity to function in the workplace. 
Generally, SSA applicants provide hospital records and other medical 
documentation to support a medical condition. However, at this stage in 
the decision-making process, applicants generally are not required to 
support how the medical condition translates into an inability to work. 
In its 2007 report, the Institute of Medicine noted that as medical 
treatments and assistive technologies advance, the medical listings 
will become less and less useful.[Footnote 10] The Institute of 
Medicine recommended that SSA consider one's capacity to function in 
the workplace at the step in which the medical condition is assessed 
using the medical listings (see fig. 1). 

SSA is also using outdated labor market data to assess what job 
opportunities exist for applicants with disabilities who do not 
automatically qualify for benefits based on the medical listings. SSA 
uses a database that has not been updated since 1991 to determine if 
there are any jobs in the national economy that would allow the 
individual applying for disability benefits to participate in the 
workforce.[Footnote 11] Given the changes in the types of jobs 
available in the current labor market, it is not likely that SSA's 
eligibility criteria accurately reflect the potential job opportunities 
for individuals with medical impairments. SSA officials told us that 
they recognize that they are using an outdated database and are 
beginning to research how to update labor market data. The officials 
also told us that collecting more current and accurate data on the 
national economy was expensive. However, they are beginning discussions 
with the National Institutes of Health (NIH), an agency within HHS, to 
learn how they may obtain more accurate information on the types of 
activities that are required for employment in various sectors of the 
U.S. economy. SSA has entered into an interagency agreement with NIH to 
assess, among other things, the functional limitations that prevent an 
individual from working. 

Similar to SSA, VA has not fully incorporated the changing economy or 
advances in technology into its ratings schedule. Disability decisions 
are based on the ratings schedule, which is intended to reflect how a 
service-connected medical impairment might translate into a loss in 
earnings for the average person. VA's system is intended to provide 
payment for veterans with service-connected disabilities, regardless of 
his or her ability to overcome the disability and participate in the 
workforce. As a result, the majority of veterans receiving disability 
compensation are partially or fully employed. Because the ratings 
schedule assigns percentage ratings to indicate the expected percentage 
decrease in earning capacity for the average person, an understanding 
of how a medical impairment affects one's earnings is essential to VA's 
system for determining disability. However, VA's understanding of the 
impact on earnings is based on the labor market as it existed in 1945. 
While VA has made some changes to its ratings schedule to account for 
medical advances, it has generally not re-examined the estimates of how 
impairments affect veterans' earnings in today's economy. As such, VA 
could be misinterpreting the impact of a medical impairment on a 
veteran's earning capacity. VA expects that the study being conducted 
by Economic Systems, Inc. will include proposals on the appropriate 
compensation for veterans with disabilities in the twenty-first century 
labor market. 

SSA and VA Are Taking Steps to Support Return to Work and to Provide 
More Timely Interventions but Have Encountered Challenges with 
Achieving Successful Employment Outcomes: 

SSA and VA have a number of initiatives to encourage and support 
beneficiaries' efforts to return to work, but these efforts have not 
resulted in high return-to-work rates. One SSA initiative, the Ticket 
to Work and Self-Sufficiency (Ticket) Program, has been operational 
since 2002. The voluntary Ticket Program provides SSA beneficiaries 
with a "ticket" that can be used as a voucher to obtain vocational 
rehabilitation, employment, or other support services from a variety of 
sources--traditional state vocational rehabilitation agencies, as well 
as SSA-approved public or private providers known as employment 
networks. According to SSA, as of August 2007, 1.4 percent of eligible 
beneficiaries had participated in the program. Over the years, SSA has 
experienced difficulty implementing the Ticket Program, especially in 
the areas of recruiting an adequate number of employment networks to 
provide rehabilitative services and in recruiting program participants. 
To help address some of these issues, SSA has proposed new regulations 
to encourage employment networks to participate in the program and to 
make it easier for beneficiaries to use the Ticket Program.[Footnote 
12] According to SSA officials, these new regulations will be finalized 
in May 2008. 

In addition to the Ticket Program, SSA has other initiatives to help 
beneficiaries return to work. Some initiatives, such as the Trial Work 
Period, help some beneficiaries maintain their disability income while 
they transition into employment. The Trial Work Period allows DI 
beneficiaries to work for 9 months in a 60-month rolling period without 
earnings affecting their disability benefits. Other initiatives were 
designed to help beneficiaries better understand the impact of 
employment on their benefits. For example, the Work Incentives Planning 
and Assistance Organizations projects are community-based organizations 
that receive grants from SSA to provide all SSA disability 
beneficiaries with free access to work incentives planning and 
assistance that can help beneficiaries make better and more informed 
choices about work and its potential effect on benefits from a variety 
of assistive programs, including those from SSI, DI, Medicaid, and Food 
Stamps. (See app. III for more information on work incentives provided 
by SSA.) 

Despite SSA's initiatives over the years to help beneficiaries return 
to work, few actually do. In a 2004 evaluation of the Ticket Program, 
Mathematica Policy Research, Inc. reported that less than 0.5 percent 
of beneficiaries on SSA's disability rolls returned to work. A number 
of factors beyond the severity of beneficiaries' impairments could 
contribute to the low return-to-work rate, including when disability 
beneficiaries are offered services. Vocational rehabilitation experts 
believe that rehabilitation has the best chance for success if offered 
early, while individuals still have a strong attachment to working and 
may also have a continuing relationship with an employer. However, 
under the current design of SSA's Ticket Program, vocational 
rehabilitation is offered to beneficiaries after they have gone through 
the lengthy disability application process and have had to provide 
adequate documentation supporting their case for why they cannot work. 
Additionally, SSA does not provide "tickets" to individuals who they 
have determined to be most likely to have an improvement in their 
medical status and who might return to work until these individuals 
have been re-evaluated for continued eligibility.[Footnote 13] 
Furthermore, some experts believe that SSA would have better success 
with its return-to-work efforts if beneficiaries received earlier 
access to health care and had access to health care after they returned 
to work. Under current eligibility requirements, Medicare is offered to 
DI beneficiaries only after they have been receiving DI benefits for 24 
months. Additionally, premium-free Medicare benefits are only available 
for a limited amount of time after beneficiaries return to work. 
Disability experts and advocates have cited beneficiaries' fears of 
losing health care coverage as a major disincentive to returning to 
work. While the timing in which vocational rehabilitation and health 
care are offered could have an effect on beneficiary return-to-work 
rates, SSA does not have the authority to address these issues alone. 
To make any changes in the design of these programs will, in some 
cases, require a change in law and, in other cases, a multiagency 
coordinated strategy that would consider the potential costs of 
expanding vocational rehabilitation and health care. 

SSA is conducting some demonstration projects to research various 
interventions' impacts on return-to-work rates. One demonstration 
project--the Accelerated Benefits Demonstration--is designed to test 
whether providing immediate health benefits and employment supports to 
certain newly entitled DI beneficiaries might result in higher return- 
to-work rates. SSA officials are conducting this study over a 5-year 
period to determine what effect earlier access to health care may have 
on the participants' return-to-work rates. In another demonstration-- 
the Youth Transition Demonstration--SSA is conducting a 9-year study to 
understand if providing additional support to youth with disabilities 
as they transition from school to work prevents them from becoming long-
term adult disability beneficiaries. In this demonstration, states were 
awarded grants to provide a broad array of transition-related services 
and supports to SSI and DI applicants and children as they left school 
and either pursued post-secondary education or entered the workforce. 

Like SSA, VA also offers services and assistance to help veterans with 
disabilities gain self-sufficiency and return to work. Under VA's 
Vocational Rehabilitation and Employment (VR&E) Program, eligible 
veterans can obtain assistance with job-related services. In May 2006, 
VA revised VR&E and established a new five-track service delivery 
system to address the varying levels of support that veterans with 
service-connected disabilities may need. The goal of this system is to 
place veterans as quickly as possible into a track of service that is 
most appropriate to meet their employment or independent living goals. 
Also, similar to SSA, veterans generally first go through a lengthy 
application process for disability benefits before becoming eligible 
for services through VR&E. After becoming eligible for VA benefits, a 
VA counselor and the veteran applicant decide which of the five tracks 
are appropriate. (See table 1 for a description of the five tracks to 
employment.) 

Table 1: VA's Five Tracks to Employment: 

Track to employment: Re-employment; 
Description of track: This track is designed for those individuals 
separating from active duty or in the National Guard or Reserves and 
who are now returning to work for their previous employer. 

Track to employment: Rapid access to employment; 
Description of track: Rapid access to employment is targeted to those 
individuals who have expressed a desire to seek employment soon after 
separation or who already have the necessary skills to be competitive 
in the job market in an appropriate occupation. 

Track to employment: Employment through long-term services; 
Description of track: Long-term services are targeted to individuals 
who need specialized training or education to obtain and maintain 
suitable employment. 

Track to employment: Self-employment; 
Description of track: Self-employment is targeted to individuals who 
have limited access to traditional employment, need flexible work 
schedules, or who need a more accommodating work environment due to 
their disabling conditions or other life circumstances. 

Track to employment: Independent living; 
Description of track: Independent living services are targeted to 
individuals who may not be able to work right now and need 
rehabilitation services to live more independently. 

Source: VA program information. 

[End of table] 

To help veterans with job placement, VA has a number of initiatives and 
partnerships underway. For example, VA has both formal and informal 
agreements with various employers so that veterans with specific skills 
and interests may have easier access to employment opportunities with 
those employers. VA also has some early outreach efforts, such as the 
Coming Home to Work Initiative, to help veterans gain work experience 
while they are early in their recovery. Through this initiative, among 
other services, participants can work with a vocational rehabilitation 
counselor to obtain unpaid work experience with the federal government. 

While VR&E has several new initiatives to help veterans return to work, 
it is unclear how many of their program participants meet their 
employment and independent living goals established upon entering the 
program. In its 2007 Performance and Accountability Report, VA reported 
that 73 percent of its program participants were rehabilitated. 
[Footnote 14] However, in a December 2007 report, the VA Inspector 
General stated that in this percentage, VA excluded the majority of 
veterans participating in VR&E.[Footnote 15] Specifically, VA did not 
include veterans who discontinued participation in the program without 
a written rehabilitation plan. In a sample of cases, the VA Inspector 
General reported that if VA included all of the veterans who 
participated in the program--including those who did not have a written 
plan for rehabilitation--the rehabilitation rate would have been 18 
percent.[Footnote 16] In its 2007 report, the Veterans' Disability 
Benefits Commission (VDBC) makes a similar point. The VDBC reported 
that in 2006, VR&E rehabilitated about 12,000 of its nearly 91,000 
active cases.[Footnote 17] While many of the active cases may have been 
for veterans who were still in the process of reaching their 
rehabilitation goals, the VDBC report points out that VR&E has 
continued to rehabilitate the same number of people per year, even 
though the number of participants in their programs has grown. Many 
factors could contribute to these trends in rehabilitation, including 
VA staffing shortages and veterans dropping out of the program. VA is 
conducting some research to understand how to better serve its 
beneficiaries in reaching their rehabilitation goals, including those 
who dropped out of the program. In 2005, VA began its Veterans 
Employability Research Study. The purpose of the Veterans Employability 
Research Study is to obtain information on veterans who discontinued or 
interrupted their VR&E participation. VA plans to use the data from 
this study to determine factors impacting program completion rates, 
veteran employability, and the types of interventions that might enable 
veterans to stay in the program. Additionally, the study will compare 
these veterans with veterans who successfully completed the program, as 
well as with all other veterans. 

SSA and VA Continue to Face Challenges Managing Their Disability Claims 
Process: 

As SSA and VA continue to work on modernizing their eligibility 
criteria and programs, both agencies also continue to face challenges 
with processing disability claims in a timely manner and reducing their 
backlogs. In December 2007, we reported that the backlogs of SSA 
disability claims doubled from fiscal years 1997 through 2006, reaching 
about 576,000 cases.[Footnote 18], [Footnote 19] Backlogs have occurred 
at each stage of the claims process, and over the 10-year time frame, 
they have increased at all stages, except at the Appeals Council. 
[Footnote 20] (For a description of the various stages in the claims 
process, see fig. 3.) The greatest backlog--exceeding 415,000 and 
accounting for 72 percent of the total backlog--was at the hearings 
level, which is the third of the four stages in SSA's disability claims 
process. Backlogs at this level increased rapidly after almost being 
eliminated from fiscal year 1997 through 1999. This increase can be 
attributed, in part, to initiatives that were not successfully 
implemented, staffing challenges, and large numbers of requests for 
hearings from applicants who had been denied benefits at previous 
levels of the claims process. Additionally, from 1997 to 2006, the 
average time for processing a disability claim increased in three of 
the four stages, most significantly at the hearings level. The average 
amount of time required to render a hearing decision rose from 386 days 
in fiscal year 1997 to 483 days in fiscal year 2006. 

Figure 3: Stages in SSA's Claims Process: 

[See PDF for image] 

This figure is an illustration of the stages in SSA's claims process, 
as follows: 

Claimant contacts SSA field office: 
Application process begins. SSA field office personnel: 
* obtain information and store in electronic record; 
* determine if claimant meets basic requirements for eligibility. 
If requirements are met, application is forwarded to DDS. 

Initial determination: 
State DDS personnel: 
* Gather, develop, and review medical and vocational evidence; 
* Decide eligibility on basis of medical and work-related factors. 
If claimant is dissatisfied with the determination, claimant has 60 
days to request a reconsideration. 

Reconsideration[A]: 
State DDS personnel (different group): 
* re-examine prior and any new evidence; 
* render a new, independent eligibility decision. 

If claimant is dissatisfied with the determination, claimant has 60 
days to request a hearing before an administrative law judge (ALJ). 

Administrative law judge hearing: 
SSA hearings office personnel: 
* conduct a new review of the case, including any new evidence 
submitted; 
* conduct a hearing by videoconference or in person and render a new 
decision; 
* ALJ may also render a decision based solely on the review of 
evidence. 

If claimant is dissatisfied with the determination, claimant has 60 
days to request an Appeals Council review. 

Appeals Council: 
SSA Appeals Council: 
* decide whether to review the case and new evidence; 
* if case is reviewed, decides whether to issue a decision or return 
case to ALJ. 

Source: GAO analysis of SSA data; Art Explosion (images). 

[A] In 1999, SSA eliminated the reconsideration step in 10 states 
(Alabama, Alaska, Colorado, Louisiana, Michigan, Missouri, New 
Hampshire, New York, Pennsylvania, and in the Los Angeles area of 
California) as part of an initiative. In these states, claimants who 
wish to appeal their initial DDS determination must appeal for review 
before an administrative law judge. As of August 2006, New Hampshire 
discontinued participation in this initiative so that it could 
participate in another initiative specific to the Boston region. 

[End of figure] 

Over the years, SSA has introduced several initiatives to improve 
processing times and decrease backlogs, but poor execution of these 
initiatives may have contributed to an even greater increase in the 
backlogs. For example, in fiscal year 2000, SSA introduced the 
"Hearings Process Improvement" initiative to reduce the number of 
appeals by improving the review at the hearing level. This initiative 
resulted in the promotion of some staff that had formerly been 
responsible for assembling claims documents for hearings. However, SSA 
did not fill the vacancies that were created as a result of these 
promotions. Additionally, the automated systems that were necessary to 
support the full implementation of this initiative were never put in 
place. The hearing backlog increased from under 12,000 claims in fiscal 
year 1999 to almost 136,000 by the end of fiscal year 2001. 

Another contributing factor to the growing backlogs was SSA's loss of 
key personnel. For example, SSA experienced reductions in 
administrative law judges who conduct hearings and the staff who 
support them. The Commissioner of SSA has noted that the agency 
required at least 1,250 administrative law judges to properly handle 
the hearings workload, but in fiscal year 2006, SSA had 1,018 
administrative law judges available to conduct hearings. Additionally, 
in fiscal year 2006, the ratio of support staff to administrative law 
judges was the lowest it had been in 10 years. SSA officials stated 
that budget constraints were a key contributor to these staffing 
shortages and the backlog. Further, SSA experienced a 21 percent 
increase in initial disability applications from fiscal year 1997 to 
2006, receiving over 2 million applications in fiscal year 2006. In 
April 2008, the Commissioner of SSA testified that SSA was in the 
process of hiring an additional 175 ALJs. Additionally, SSA officials 
told us that the ratio of support staff to administrative law judges 
increased in fiscal year 2007. 

SSA has taken a number of steps to address the claims backlog across 
all levels of the process. These steps include enhancing its electronic 
processing system, reallocating workloads, and increasing hearing 
office capacity. In 2007, SSA published its most recent plan to 
eliminate the hearing backlog and prevent its recurrence, which 
outlined its strategies for improving hearing office procedures, 
increasing adjudicator capacity, and increasing efficiency. However, it 
is too early to report on the impact that these actions have had on the 
backlog. 

Similarly, the number of VA disability claims awaiting an initial 
disability decision grew by more than 50 percent from 2003 to 2007; 
reaching about 392,000 claims (see table 2 for information on VA's 
claims process). Additionally, claims pending for more than 6 months 
more than doubled from about 47,000 to about 101,000 during that same 
time period. Several factors have contributed to the growing inventory 
of pending claims for VA. One contributing factor is that the agency 
has faced increases in the number of applications filed, including 
those filed by veterans returning from Iraq and Afghanistan. VA 
officials have also attributed the growing number of claims to their 
successful outreach efforts. Additionally, many new VA disability 
applications are filed with multiple conditions, requiring VA claims 
examiners to conduct a separate evaluation for each condition claimed. 
Like SSA, VA is taking steps to address its growing inventory of 
pending claims. Most recently, VA hired more claims examiners, 
including retired VA employees, to help provide training and to process 
the growing number of disability claims. VA officials expected the 
retired employees to help process and complete 23,000 claims in 2008. 
VA has also used other initiatives, such as brokering claims between 
offices to help manage its claims inventory. In 2007, VA announced an 
initiative to provide priority processing of disability claims for all 
Operation Iraqi Freedom and Operation Enduring Freedom veterans. 
Additionally, VA and the Department of Defense have begun a pilot 
program in which VA completes disability ratings for service members 
who have been found unfit for duty by the military services due to 
disability. Because VA rates disabilities while the service member is 
still in the military service, disability benefits can be awarded soon 
after the service member is discharged. 

Table 2: VA Claims Processing Teams: 

Team: Public contact; 
Description: Answers telephone and in-person inquiries, refers claims 
to triage, and informs veterans of the status of their claims. 

Team: Triage; 
Description: Reviews, controls, processes, and routes all incoming 
mail. If claim can be resolved immediately without a claims folder, the 
triage team does so. 

Team: Predetermination; 
Description: Develops claims. Tasks include requesting and obtaining 
all evidence needed to support a claim. 

Team: Rating; 
Description: Makes decisions on rating-related claims. 

Team: Postdetermination; 
Description: Approves the establishment of benefits, authorizes 
payments to beneficiaries, and notifies claimants of the Veterans 
Benefits Administration's decisions. 

Team: Appeals; 
Description: Processes appeals and remands of regional office 
decisions. 

Source: Veterans Benefits Administration. 

[End of table] 

SSA and VA Are Making Efforts to Partner with Other Federal Agencies, 
but Governmentwide Coordination of Cross-Cutting Programs Is Lacking: 

SSA and VA disability programs partner with Education, Labor, HHS and 
CMS, an agency within HHS, on specific programmatic initiatives to 
support employment-related services and research and improve the 
integrity and operation of their disability programs.[Footnote 21] 
However, agency officials cite challenges to interagency partnerships 
and coordination of programs across the federal government. Experts 
have stated that while interagency partnerships and collaborations are 
helping to improve some programs providing benefits and services, an 
integrated system of services to support individuals with disabilities 
is needed. 

SSA and VA Disability Programs Partner with Other Agencies on Specific 
Initiatives, but Face Challenges to Coordination: 

SSA's and VA's interagency partnerships generally take place on a case- 
by-case basis between other agencies' programs for specific purposes, 
such as supporting beneficiaries' and veterans' efforts to return to 
work and attain self-sufficiency.[Footnote 22] For example, VA's VR&E 
signed a national memorandum of understanding with Labor's Veterans' 
Employment & Training Service (VETS) in 2005 to coordinate efforts to 
advance and expand employment opportunities for veterans with 
disabilities. These two programs have historically worked together to 
serve veterans, but in 2005, they developed an agreement to improve 
interagency collaboration and coordination. In our September 2007 
report, we found that Labor and VA had implemented some elements of 
their agreement to coordinate efforts on the national level, such as 
establishing joint workgroups to address issues related to shared 
performance measures, staff training, and joint data collection. 
However, Labor and VA were still in the process of creating a plan to 
fully implement and assess the progress of the agreement and faced 
challenges to fully executing the agreement, such as data sharing 
restrictions and staffing limitations.[Footnote 23] In another example 
of a partnership to support efforts to return to work, SSA and Labor 
jointly established the Disability Program Navigator initiative in 2002 
to better inform SSA beneficiaries and other individuals with 
disabilities about the work support programs available through Labor's 
workforce investment system.[Footnote 24] 

SSA and VA also partner with other federal agencies to support research 
on ways to help beneficiaries return to work. For example, SSA 
developed a memorandum of understanding with Education to share data to 
promote research activities about beneficiaries who receive state 
vocational rehabilitation services funded by Education. According to 
SSA officials, these research initiatives generate information that 
helps inform policy, including ways to support current and potential 
beneficiaries' efforts to attain self-sufficiency. SSA and VA also 
participate in the Interagency Committee on Disability Research, which 
Congress created to facilitate the exchange of information on 
disability and rehabilitation research and coordinate research 
activities among federal agencies.[Footnote 25] As part of this 
interagency committee, agencies have come together to discuss common 
challenges, such as barriers to accessing other agencies' data. 

In addition to partnerships meant to support return-to-work 
initiatives, some interagency partnerships between SSA, VA, and other 
federal agencies focus on improving the integrity and operation of 
disability programs through data sharing efforts. With regard to 
improving program integrity, both SSA and VA have electronic data 
matching agreements with other agencies to prevent improper payments. 
For example, SSA and VA have a data matching agreement to provide VA 
with income tax return information disclosed to SSA to verify 
eligibility for certain VA benefit programs. VA uses this data to 
determine continued eligibility for VA compensation and pension 
benefits.[Footnote 26] With regard to improving program operations, SSA 
and VA have data sharing agreements with other agencies to enhance the 
efficiency of their administration of disability programs. For example, 
CMS and SSA share electronic data in order to assure that SSA 
beneficiaries receive Medicare benefits when they are legally entitled. 

While SSA and VA recognize the value of partnering with other federal 
agencies, agency officials cited challenges to these interagency 
partnerships.[Footnote 27] In establishing such partnerships, SSA and 
VA enter into memorandums of understanding with other agencies that 
officials said can be time-consuming to develop and renew. These 
officials stated that each federal agency had its own requirements and 
protocols for entering into formal agreements, which presented a 
challenge when agency procedures were incompatible. Agency officials 
also told us that because the process was so time-consuming, they were 
hesitant to enter into formal agreements with other agencies because 
resources were not available to establish the agreement. Officials 
noted that staff sometimes encountered difficulty sharing information 
because they may not know the appropriate contact person in another 
federal agency. In addition, officials noted that they experienced 
challenges with sharing data, in part, due to privacy concerns and 
differing data systems. Further, in facilitating joint services or 
research endeavors, SSA and VA face challenges related to legal 
restrictions on program activities and sharing appropriated funds. 
Officials also identified a reluctance for agencies to coordinate with 
one another due to concerns about losing control over scarce program 
funds and a lack of clear incentives to form partnerships. 

Comprehensive Governmentwide Coordination of Cross-Cutting Disability 
Programs Is Lacking: 

Although agencies are partnering on a case-by-case basis, agency 
officials and experts have cited a lack of comprehensive coordination 
among the various federal programs that serve individuals with 
disabilities. In 2005, we identified more than 20 federal agencies and 
almost 200 programs that served individuals with disabilities in a 
multifaceted and complex manner. Although some of these programs had 
similar missions and provided similar types of assistance, they often 
differed in their eligibility criteria, and thus, served different 
populations. Our 2005 report also noted that these agencies and 
programs generally operated independently of one another and 
experienced difficulty communicating and coordinating with other 
programs serving individuals with disabilities.[Footnote 28] Further, 
experts in a 2007 GAO Comptroller General's forum identified 
fragmentation and duplication among disability programs and a need for 
strengthening partnerships and coordination of federal programs and 
policies serving individuals with disabilities.[Footnote 29] Other 
entities, such as the Social Security Advisory Board and the Veterans' 
Disability Benefits Commission have conducted studies of SSA and VA 
disability programs and consistently found that increased coordination 
between SSA, VA, and other federal agencies is needed to adequately 
serve individuals with disabilities. 

Individuals with disabilities may experience the greatest impact of the 
decentralization and fragmentation of federal disability programs and 
policies (see fig. 4). In its 2007 final report to the President and 
Congress, the Ticket to Work and Work Incentives Advisory Panel found 
that individuals with disabilities encountered a myriad of policies and 
procedures from other systems that did not work in concert with one 
another and may even have worked at cross purposes.[Footnote 30] For 
example, beneficiaries testifying before the panel shared frustration 
with their interactions with state vocational rehabilitation agencies, 
the Medicaid system, and Social Security field offices that did not 
understand one another's policies. The panel found that despite these 
programs' common mandated objective to improve employment outcomes and 
support self-sufficiency, the responsibility of navigating these 
different systems was placed on the beneficiary. Further, participants 
in National Council on Disability (NCD) focus groups and public forums 
affirmed the lack of coordination among multiple systems of support, as 
well as the complexity of the rules and regulations faced by 
beneficiaries. Beneficiaries navigating the system found that 
coordination and collaboration among vocational rehabilitation 
agencies, Labor's workforce development system, VA, and SSA were 
limited and typically did not provide a seamless system of 
support.[Footnote 31] Because individuals with disabilities may need a 
variety of services to seek or retain employment from various federal 
agencies, coordination of these activities is vital. 

Figure 4: Individuals with Disabilities Experience a Fragmented Federal 
Disability System: 

[See PDF for image] 

This figure is an illustration of an individual with disabilities 
experiencing a fragmented federal disability system. The individual 
encounters the following: 
 
Department of Education: 
* Vocational rehabilitation; 
* Research. 

Social Security Administration: 
* Cash assistance; 
* Work incentives. 

Department of Health and Human Services: 
* Health care. 

Department of Labor: 
* Employment-related assistance. 

Department of Veterans Affairs: 
* Cash assistance; 
* Vocational rehabilitation; 
* Medical care. 

Other Assistance: 

Source: GAO analysis; Art Explosion (images). 

[End of figure] 

Disability policy and programs in the United States have been developed 
on an individual basis over many years, creating a patchwork of federal 
policy and program initiatives without a unified set of national goals. 
As a result, federal programs serving individuals with disabilities 
often have different legal mandates, funding streams, missions, 
eligibility criteria, and priorities for their programs and services. 
As we reported in March 2000, if agencies' missions and goals are not 
mutually reinforcing, reaching consensus on strategies and priorities 
is difficult.[Footnote 32] Additionally, without clear national goals, 
agencies may lack appropriate incentives to coordinate because of 
concerns about protecting jurisdiction over missions and control over 
resources. For example, many officials we interviewed said that 
agencies face challenges fulfilling prescriptive agency mandates for 
their particular programs with limited funds and staff and may not have 
adequate incentives to coordinate with other agencies if it appears 
they will lose resources as a result. To overcome these disincentives, 
agencies may need to reach consensus on the desired outcomes for the 
beneficiaries they are serving and the roles that each agency plays in 
achieving those outcomes. We have identified practices that have helped 
to enhance and sustain collaboration among federal agencies.[Footnote 
33] For example, establishing a shared purpose or common outcome that 
is consistent with agencies' respective goals and missions helps 
agencies to work across agency boundaries. Some specific practices 
include: 

* defining and articulating a common outcome; 

* establishing mutually reinforcing or joint strategies; 

* identifying and addressing needs by leveraging resources; 

* agreeing on roles and responsibilities; 

* establishing compatible policies, procedures, and other means to 
operate across agency boundaries; 

* developing mechanisms to monitor, evaluate, and report on results; 

* reinforcing agency accountability for collaborative efforts through 
agency plans and reports; and: 

* reinforcing individual accountability for collaborative efforts 
through performance management systems. 

Various executive initiatives have been implemented to improve the 
federal government's provision of services and supports for individuals 
with disabilities, however as of yet, none have coordinated disability- 
related services governmentwide. In 2001, the President implemented the 
New Freedom Initiative, a set of guiding principles and initiatives 
aimed at improving the integration of individuals with disabilities in 
all aspects of society.[Footnote 34] As part of this initiative, 
federal agencies report to the President on ways they are supporting 
individuals with disabilities; however, the initiative does not require 
interagency coordination to achieve these goals. The Presidential Task 
Force on Employment of Adults with Disabilities is another executive 
initiative, which was issued in 1998.[Footnote 35] Created with the 
goal of developing a coordinated national policy to bring adults with 
disabilities into gainful employment, the task force membership 
included the Secretaries and heads of relevant federal agencies. 
Several agency officials we interviewed noted that this type of task 
force was successful at bringing agencies to the table to discuss ways 
to better serve individuals with disabilities, but the task force was 
dissolved in 2002. These executive initiatives may have served their 
intended purpose while in effect, but the focus, implementation, and 
level of commitment to such initiatives have been subject to change or 
abandonment as administrations change. 

Congress has also attempted to improve the federal government's 
provision of services and supports for individuals with disabilities; 
however, governmentwide coordination still remains a challenge. In 
1978, Congress established NCD, which serves as an independent federal 
agency making recommendations to the President and Congress to promote 
policies, programs, practices, and procedures that guarantee equal 
opportunity for individuals with disabilities.[Footnote 36] NCD has 
evaluated a range of federal programs serving individuals with 
disabilities and has made recommendations for improvement. In 1992, 
Congress authorized the Interagency Disability Coordinating Council 
(IDCC) to coordinate federal activities to promote independence and 
productivity of individuals with disabilities.[Footnote 37] However, 
IDCC has never met or reported to Congress, as required by law, and no 
other interagency body exists to perform this function. Although the 
council was given the authority to coordinate federal activities and 
policies, it did not have the appropriate leadership or membership to 
accomplish this goal. While SSA, VA, and other critical agencies could 
be invited to join IDCC, these agencies were not mandated members. 
Further, agency roles and responsibilities were not clearly defined. 
While the council was required to report annually, specific outcomes 
were not provided. In 2003, NCD, which is required to provide advice 
regarding the activities of IDCC, recommended to Congress that IDCC be 
revived in order to fulfill its intended purpose. However, NCD does not 
have the authority to require implementation of its recommendations 
and, as of 2008, IDCC remains inactive.[Footnote 38] As suggested in 
figure 5, agency officials indicated that a coordinating entity should 
be in place to ensure that the multiple agencies serving individuals 
with disabilities are communicating on a governmentwide scale to ensure 
integration of services. 

Figure 5: Federal Strategy to Integrate Services for Individuals with 
Disabilities: 

[See PDF for image] 

This figure is an illustration of agencies working together to 
integrate services for individuals with disabilities. Agencies 
represented are: 
Education; 
Labor; 
Veterans Administration; 
Social Security Administration; 
Health and Human Services; 
Other Agencies. 

Agenda: 
Develop federal strategy to integrate services for individuals with 
disabilities: 
* Cash assistance; 
* Health care; 
* Employment-related assistance; 
* Vocational rehabilitation; 
* Other assistance. 

Source: GAO analysis, Art Explosion (images). 

[End of figure] 

While individual agencies' attempts to collaborate with one another may 
improve some benefits and services, there is an absence of a 
centralized consensus-based federal strategy to serve individuals with 
disabilities. Without high-level governmentwide coordination of federal 
disability programs, it is difficult for individual agencies to 
determine if the most appropriate cooperation is occurring within the 
context of a governmentwide system. Further, the absence of an 
integrated federal strategy may impede SSA's and VA's ability to 
modernize their federal programs, as no single agency has the span of 
authority to coordinate the variety of services provided to 
beneficiaries by various federal programs. 

Conclusions: 

Over the years, with advances in medicine and technology and changes in 
the labor market, the effect a medical impairment or disability has on 
one's ability to function, especially in a work setting, has changed. 
SSA and VA have taken some steps to incorporate these advances, but 
their changes have largely been at the margins, resulting in temporary 
fixes to a system that requires ongoing re-examination and 
transformation. SSA's and VA's programs do not sufficiently assess the 
work capacity of individuals with disabilities in the twenty-first 
century or adequately ensure individuals are given timely and 
appropriate benefits and services. All of these factors are needed for 
both agencies to better serve their beneficiaries and see better 
results with their return-to-work and self-sufficiency initiatives. 
This transformation will likely require legislative and regulatory 
changes so that those who can work are identified early in the process 
and given timely supports, while the benefits for those who cannot work 
are protected. In addition, such transformation would require the 
participation and cooperation of other federal agencies that provide 
many of the supports for individuals with disabilities. These agencies 
must operate with a framework of agreed-upon, desired outcomes for 
disability policies and programs and the processes to achieve them. 
However, because of the many agencies and programs involved and the 
many challenges to coordination, it will be especially difficult for 
individual agencies, such as SSA and VA, to modernize their programs in 
a manner that would provide an integrated system of benefits and 
services to individuals with disabilities. Without a mechanism to 
facilitate governmentwide agreement on outcomes and coordination of 
cross-cutting programs, it is unlikely that leaders from individual 
agencies will be able to effectively work together across agency 
boundaries to find comprehensive and sustainable solutions to better 
serve disability beneficiaries. Prior attempts to coordinate federal 
disability programs, such as through the IDCC, have had limited success 
primarily because all of the necessary stakeholders were not included 
and outcomes were not clearly stated. Moving forward, options exist for 
creating a coordinated federal disability system, including reviving 
the IDCC and altering its mandated membership and stated mission for 
this purpose or creating a similar body. In either case, any future 
attempts to develop a cost-effective national strategy to integrate 
federal services and supports will need to be based on clear disability 
policy goals, have well defined program outcomes, and involve all of 
the stakeholders. 

Matter for Congressional Consideration: 

In order to help ensure that federal disability policy is more clearly 
stated, programs and policies are better coordinated, and to reduce the 
possibility of inefficiencies and duplication of programs, Congress, in 
consultation with key agencies and other stakeholders, should consider 
authorizing a coordinating entity consisting of leadership from 
appropriate federal agencies to develop a cost-effective federal 
strategy to integrate services and support for individuals with 
disabilities. Options to achieve this include reviving the IDCC or 
creating a similar entity with the key agency officials represented and 
clear expectations for outcomes of the entity. A successful coordinated 
federal effort should include defining and articulating common outcomes 
and establishing mutually reinforcing joint strategies among federal 
agencies to achieve identified goals. Further, clear agreement on 
agency roles and responsibilities and agency accountability for 
collaborative efforts and outcomes will be critical to success. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Commissioner of the Social 
Security Administration, the Secretary of Veterans Affairs, the 
Secretary of the Department of Education, the Secretary of the 
Department of Health and Human Services, and the Secretary of the 
Department of Labor. Each of these agencies provided technical comments 
which we have incorporated as appropriate into the final report. Also, 
HHS provided additional examples of their coordination efforts. The 
Department of Education and the Department of Health and Human Services 
provided written comments that appear in appendix IV and V, 
respectively. We also provided a draft of this report to the Executive 
Director of the National Council on Disability, who agreed with our 
findings and matter for congressional consideration. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 5 days 
from the report date. At that time, we will send copies to relevant 
congressional committees, the Commissioner of the Social Security 
Administration, the Secretary of Veterans Affairs, the Secretary of the 
Department of Education, the Secretary of the Department of Health and 
Human Services, and the Secretary of the Department of Labor, and other 
interested parties. We will also make copies available to others on 
request. In addition, the report will be available at no charge on the 
GAO Web site at [hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-7215 or [email protected]. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. GAO staff who made key contributions 
to this report are listed in appendix VI. 

Sincerely yours, 

Signed by: 

Daniel Bertoni: 
Director, Education, Workforce, and Income Security Issues: 

[End of section] 

Appendix I: Scope and Methodology: 

To identify the steps that the Department of Veterans Affairs (VA) and 
the Social Security Administration (SSA) have taken to modernize their 
disability programs, we conducted a literature review, including prior 
GAO reports, reports written by the National Council on Disability 
(NCD), studies conducted by SSA's and VA's Inspectors General, and 
position papers and testimonies from national groups (including the 
Social Security Advisory Board and the Veterans' Disability Benefits 
Commission). Specifically, to gain an understanding of the changes that 
would be required for SSA to modernize its programs, we reviewed 
multiple reports from the Social Security Advisory Board, including A 
Disability System for the 21st Century and The Social Security 
Definition of Disability; the final Ticket to Work and Work Incentives 
Advisory Panel report, Building on the Ticket: A New Paradigm for 
Investing in Economic Self-Sufficiency for People with Significant 
Disabilities; and Improving the Social Security Disability Decision 
Process from the Institute of Medicine of the National Academies. To 
review VA's modernization efforts, we reviewed the final report 
released by the Veterans' Disability Benefits Commission, Honoring the 
Call to Duty: Veterans' Disability Benefits in the 21st Century; a 
report published by the Institute of Medicine of the National 
Academies, A 21st Century System for Evaluating Veterans for Disability 
Benefits; and a VA Office of Inspector General report entitled Audit of 
Vocational Rehabilitation and Employment Program Operations. 

In addition, we reviewed relevant agency documents, including strategic 
plans and government performance and accountability reports. We 
interviewed knowledgeable SSA and VA officials to obtain information on 
the current process and status of incorporating present-day medical and 
labor market conditions into their disability eligibility criteria. We 
also interviewed agency officials and reviewed agency documents on the 
range of SSA's and VA's planned and ongoing return-to-work initiatives, 
including SSA's Ticket to Work Program and other ongoing demonstration 
projects, as well as VA's Vocational Rehabilitation and Employment 
Services (VR&E) program. To determine how SSA and VA coordinate efforts 
with Education, Labor, HHS, and CMS, an agency within HHS, we analyzed 
a list of SSA's and VA's memorandums of understanding relevant to our 
study that was provided to us by agency officials. We also interviewed 
agency officials from each of these agencies and NCD to learn about the 
types of barriers that may hinder interagency coordination and what 
other opportunities for collaboration may exist. 

Much of the numerical data in this report was obtained from outside 
reviews of SSA's and VA's disability programs. The data provides 
background and context for the findings but were not necessary to 
support our findings or matter for congressional consideration. 
Instead, our findings and the matter for congressional consideration 
are based on our analysis of information received from a variety of 
sources, including a literature review and interviews with agency 
officials and experts. 

We conducted this performance audit from May 2007 through May 2008 in 
accordance with generally accepted government auditing standards. Those 
standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

Appendix II: Entities Making Recommendations to SSA and VA: 

Entity: National Council on Disability (NCD); 
Purpose: The National Council on Disability was established in 1978 as 
an advisory board within the Department of Education (Pub.L. 95-602). 
The Rehabilitation Act Amendments of 1984 (Pub.L. 98-221) transformed 
NCD into an independent federal agency with 15 members appointed by the 
President of the United States and confirmed by the U.S. Senate. The 
purpose of NCD is to promote policies, programs, practices, and 
procedures that guarantee equal opportunity for all individuals with 
disabilities, regardless of the nature or significance of the 
disability, and to empower individuals with disabilities to achieve 
economic self- sufficiency, independent living, and inclusion and 
integration into all aspects of society; 
Examples of reports with recommendations: Empowerment for Americans 
with Disabilities: Breaking Barriers to Careers and Full Employment 
(October 2007). 

Entity: Institute of Medicine of the National Academies; 
Purpose: The National Academy of Sciences (National Academies) is a 
private, nonprofit society of distinguished scholars engaged in 
scientific and engineering research, which was chartered by Congress in 
1863 with a mandate to advise the federal government on scientific and 
technical matters. The Institute of Medicine was established in 1970 by 
the National Academy of Sciences to, among other things, advise the 
federal government on issues of medical care, research, and education; 
Examples of reports with recommendations: Improving the Social Security 
Disability Decision Process (2007); A 21st Century System for 
Evaluating Veterans for Disability Benefits (2007). 

Entity: Social Security Advisory Board; 
Purpose: The Social Security Independence and Program Improvements Act 
of 1994 (Pub.L. 103-296) established the Social Security Advisory Board 
to advise the President, Congress, and the Commissioner of SSA on 
matters relating to the Social Security and Supplemental Security 
Income programs; 
Examples of reports with recommendations: A Disability System for the 
21st Century (September 2006). 

Entity: Ticket to Work and Work Incentives Advisory Panel; 
Purpose: The Ticket to Work and Work Incentives Improvement Act 
established the Ticket to Work and Work Incentives Advisory Panel 
within SSA to advise the President, Congress, and the Commissioner of 
SSA on issues related to work incentive programs, planning and 
assistance for individuals with disabilities, and the Ticket to Work 
Program; 
Examples of reports with recommendations: Building on the Ticket: A New 
Paradigm for Investing in Economic Self-Sufficiency for People with 
Significant Disabilities, Final Report to the President and Congress, 
Year Eight of the Panel (December 2007). 

Entity: Veterans' Disability Benefits Commission; 
Purpose: The National Defense Authorization Act of 2004 (Pub. L. 108-
136) established the Veterans' Disability Benefits Commission to study 
the benefits and services available to U.S. veterans and their 
dependents and survivors to compensate for and assist with disabilities 
and deaths attributable to military service; 
Examples of reports with recommendations: Honoring the Call to Duty: 
Veterans' Disability Benefits in the 21st Century (October 2007). 

Entity: Commission on Care for America's Returning Wounded Warriors; 
Purpose: The President's Commission on Care for America's Returning 
Wounded Warriors was established by Executive Order in March 2007 to 
conduct a comprehensive review of services provided to wounded warriors 
and deliver recommendations to the President, Secretary of the 
Department of Defense, and Secretary of the Department of Veterans 
Affairs. As of July 2007, the commission was officially closed; 
Examples of reports with recommendations: Serve, Support, Simplify: 
Report of the President's Commission on Care for America's Returning 
Wounded Warriors (July 2007). 

Entity: VA Vocational Rehabilitation and Employment (VR&E) Task Force; 
Purpose: The Secretary of the Department of Veterans Affairs chartered 
the VR&E Task Force in 2003 to assess the VR&E service and make 
recommendations for improvement; 
Examples of reports with recommendations: Report to the Secretary of 
Veterans Affairs: The Vocational Rehabilitation and Employment Program 
for the 21st Century Veteran (2004). 

Source: GAO review of disability reports written by national groups. 

[End of table] 

[End of section] 

Appendix III: Employment Supports for SSA's Disability Insurance (DI) 
and Supplemental Security Income (SSI) Beneficiaries: 

Work Incentive: Ticket to Work Program; 
Description: Under this program, many DI and SSI disability 
beneficiaries receive a "ticket" that they can use to obtain services 
from a state vocational rehabilitation agency or another approved 
provider of their choice. The program was created to increase the 
choices available for beneficiaries when obtaining employment services, 
vocational rehabilitation services, and other support services needed 
to get or keep a job. It is a free and voluntary service. Eligible 
beneficiaries can elect to use the ticket, but there is no penalty for 
not using it; 
Eligible beneficiaries: DI and SSI beneficiaries meeting SSA's criteria 
are mailed a "ticket." 

Work Incentive: Trial Work Period (TWP); 
Description: The TWP allows beneficiaries to test their ability to work 
for at least 9 months. During the TWP, beneficiaries will receive their 
full DI benefits, regardless of how high their earnings might be, as 
long as work activity is reported and the beneficiary continues to have 
a disabling impairment; 
Eligible beneficiaries: DI beneficiaries. 

Work Incentive: Extended Period of Eligibility (EPE); 
Description: The EPE allows beneficiaries, who stopped receiving DI 
benefits because their earnings exceeded income limits, to qualify for 
their benefits to be reinstated--without a new application--at any time 
during the 36 consecutive months following the TWP. Beneficiaries can 
receive benefits for any month in which their earnings fall below 
substantial gainful activity (SGA) levels and they continue to have a 
disabling impairment; 
Eligible beneficiaries: DI beneficiaries. 

Work Incentive: Impairment-Related Work Expenses (IRWE); 
Description: SSA will deduct from beneficiaries' gross incomes the cost 
of certain impairment-related items and services that are needed for 
them to work; 
Eligible beneficiaries: DI and SSI beneficiaries. 

Work Incentive: Unincurred Business Expenses; 
Description: SSA allows contributions made by others to support 
beneficiaries' self-employment efforts to be deducted from their 
earnings calculation. For example, if a state vocational rehabilitation 
agency provides a beneficiary with a computer for his/her business, SSA 
will deduct the cost of the computer from the net income to get an 
accurate measure of the value of the beneficiary's work; 
Eligible beneficiaries: DI beneficiaries. 

Work Incentive: Unsuccessful Work Attempt; 
Description: SSA will consider any work attempt of 6 months or less as 
an unsuccessful work attempt. Earnings during an unsuccessful work 
attempt are not counted if they occurred before the beneficiary would 
be awarded benefits; 
Eligible beneficiaries: DI beneficiaries. 

Work Incentive: Continued Payment under a Vocational Rehabilitation 
Program; 
Description: If a beneficiary's medical condition improves so that it 
is no longer considered a disabling impairment, SSA may continue 
providing benefits if the beneficiary is enrolled in an appropriate 
vocational rehabilitation program and the agency believes continued 
participation in the program would increase the likelihood of permanent 
removal from the disability benefit rolls; 
Eligible beneficiaries: DI and SSI beneficiaries. 

Work Incentive: Plan to Achieve Self-Support (PASS); 
Description: SSA allows beneficiaries to set aside income and/or 
resources for a specified time so that the beneficiary can reach a work 
goal, such as education, vocational training, or starting a business. 
Income used in the PASS will not be counted when calculating SSI 
payment amounts; 
Eligible beneficiaries: SSI beneficiaries. 

Work Incentive: Continuation of Medicare Coverage; 
Description: Most individuals with disabilities who work will continue 
to receive at least 93 consecutive months (after the 9-month TWP) of 
hospital and supplementary medical insurance under Medicare. The 
hospital insurance is premium-free; 
Eligible beneficiaries: DI beneficiaries. 

Work Incentive: Medicare for Individuals with Disabilities Who Work; 
Description: If an individual remains medically disabled but is 
working, continued Medicare coverage may be available for purchase 
after the premium-free Medicare coverage ends; 
Eligible beneficiaries: DI beneficiaries. 

Work Incentive: Earned Income Exclusion; 
Description: For SSI beneficiaries, SSA counts less than half of a 
beneficiaries earned income in any month when figuring the SSI payment 
amount; 
Eligible beneficiaries: SSI beneficiaries. 

Work Incentive: Student Earned Income Exclusion; 
Description: For SSI beneficiaries regularly attending school and under 
age 22, SSA will not count a certain amount of earned income per month 
when figuring the SSI payment amount; 
Eligible beneficiaries: SSI beneficiaries. 

Work Incentive: Property Essential to Self-Support; 
Description: SSA does not count certain resources that are essential to 
an individual's means of self-support when deciding initial and 
continuing eligibility; 
Eligible beneficiaries: SSI beneficiaries. 

Work Incentive: Special SSI Payments for Individuals Who Work; 
Description: Certain individuals can qualify to receive SSI cash 
benefits even when earned income is at the SGA level; 
Eligible beneficiaries: SSI beneficiaries. 

Work Incentive: Medicaid While Working; 
Description: Some individuals can continue to receive Medicaid coverage 
even if income is too high to receive SSI cash payment; 
Eligible beneficiaries: SSI beneficiaries. 

Source: GAO analysis of SSA data. 

[End of table] 

[End of section] 

Appendix IV: Comments from the Department of Education: 

United States Department Of Education: 
Office Of Special Education And Rehabilitative Services: 
The Assistant Secretary: 
600 Independence Ave., S.W. 
Washington, D.C. 20202-2500: 

Our mission is to ensure equal access to education and to promote 
educational excellence throughout the Nation. 

May 2, 2008: 

Mr. Daniel Bertoni, Director: 
Education, Workforce, and Income Security Issues: 
United States Government Accountability Office: 
Washington, D.C. 20548: 

Dear Mr. Bertoni: 

Thank you for the opportunity for the Department of Education to review 
the draft of your report, Federal Disability Programs: More Strategic 
Coordination Could Help Overcome Challenges to Needed Transformation 
(GAO-08-635). The draft report contains no recommendations for 
executive action. We have provided technical comments and suggestions 
to your staff in a few areas specific to programs we administer where 
we believe minor changes might contribute to clarity or understanding. 

Sincerely, 

Signed by: 

Tracy R. Justesen: 

[End of section] 

Appendix V: Comments from the Department of Health and Human Services: 

Department of Health and Human Services: 
Office of the Assistant Secretary for Legislation: 
Washington, DC 20201: 

Mr. Daniel Bertoni: 
Director, Education, Workforce, and Income Security Issues: 
441 G Street NW: 
Washington, DC 20548: 

Dear Mr. Bertoni: 

Enclosed are the U.S. Department of Health and Human Services' comments 
on the U.S. Government Accountability Office's (GAO) draft report 
entitled: "Federal Disability Programs: More Strategic Coordination 
Could Help Overcome Challenges to Needed Transformation" (GAO 08-635). 

The Department appreciates the opportunity to review and comment on 
this report before its publication. 

Sincerely, 

Signed by: 

Jennifer R. Luong, for: 

Vincent J. Ventimiglia, Jr. 
Assistant Secretary for Legislation: 

Attachment: 

General Comments Of The Department Of Health And Human Services (HHS) 
On The U.S. Government Accountability Office's (GAO) Draft Report 
Entitled: Federal Disability Programs: More Strategic Coordination 
Could Help Overcome Challenges To Needed Transformation (GAO 08-635): 

HHS remains committed to promoting federal disabilities programs. GAO 
should note that HHS currently coordinates on several programs that 
serve individuals with disabilities in partnership with the Department 
of Veterans Affairs (VA) and the Social Security Administration (SSA). 
The following are some examples of coordinating efforts: 

* Beginning November 2005, HHS and the VA continues to work together on 
accessibility issues for persons with disabilities through the Consumer 
Empowerment Workgroup of the American Health Information Community 
(AHIC), a federal advisory body chartered to make recommendations to 
the Secretary on how to accelerate the development and adoption of 
health information technology. 

* Beginning 2007, HHS and the VA have been Federal Partners in 
AIDS.gov, the internet gateway to guide users to Federal domestic 
HIV/AIDS information and resources on prevention, testing, treatment 
and research. 

* In March 2006, representatives from HHS and the VA participated in a 
panel discussion at the National Behavioral Health Conference on 
Returning Veterans and Their Families, "Restoring Hope and Building 
Resiliency," which was sponsored by the Substance Abuse and Mental 
Health Services Administration (SAMHSA) and the Therapeutic Communities 
of America (TCA). 

* HHS, SSA, and the VA work together in the Senior Workgroup for Mental 
Health, which is sponsored by SAMHSA as part of its "Mental Health 
System Transformation" program. 

* HHS' Office of Civil Rights (OCR), the VA Center for Health Equity 
Research and Promotion, and the Center for Minority Health at the 
University of Pittsburgh Graduate School of Public Health cosponsored 
and organized the Annual National Minority Health Leadership Summits 
for three (3) consecutive years beginning in 2003 through 2005. 

* HHS's Office of the National Coordinator (ONC) coordinates with SSA 
in development of a disability-based electronic personal health record 
(PHR). 

[End of section] 

Appendix VI: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Daniel Bertoni, (202) 512-7215 or [email protected]: 

Staff Acknowledgments: 

In addition, the following staff made key contributions to this report: 
Shelia Drake served as Assistant Director; Anjali Tekchandani 
coordinated team efforts as Analyst-In-Charge; Jean Cook served as a 
team member; Patricia M. Owens provided expertise on disability issues; 
Susannah Compton advised on report preparation; Walter Vance advised on 
design and methodology issues; Daniel Schwimer advised on legal issues; 
Lise Levie verified our findings. 

[End of section] 

Related GAO Products: 

Veterans' Disability Benefits: Claims Processing Challenges Persist, 
while VA Continues to Take Steps to Address Them. [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-08-473T]. Washington, D.C.: 
February 14, 2008. 

Social Security Disability: Better Planning, Management, and Evaluation 
Could Help Address Backlogs. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-08-40]. Washington, D.C.: December 7, 2007. 

Disabled Veterans' Employment: Additional Planning, Monitoring, and 
Data Collection Efforts Would Improve Assistance. [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-07-1020]. Washington, D.C.: 
September 12, 2007. 

Highlights of a Forum: Modernizing Federal Disability Policy. 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-934SP]. 
Washington, D.C.: August 3, 2007. 

Military and VA Disability Systems: GAO Findings and Recommendations 
Regarding DOD and VA Disability Systems. [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-07-906R]. Washington, D.C.: May 
25, 2007. 

Vocational Rehabilitation: Improved Information and Practices May 
Enhance State Agency Earnings Outcomes for SSA Beneficiaries. 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-521]. Washington, 
D.C.: May 23, 2007. 

Vocational Rehabilitation: Earnings Increased for Many SSA 
Beneficiaries after Completing VR Services, but Few Earned Enough to 
Leave SSA's Disability Rolls. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-07-332]. Washington, D.C.: March 30, 2007. 

High-Risk Series: An Update. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-07-310]. Washington, D.C.: January 2007. 

Results-Oriented Government: Practices That Can Help Enhance and 
Sustain Collaboration among Federal Agencies. [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-06-15]. Washington, D.C.: October 
21, 2005. 

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Examined in Light of 21st Century Challenges. [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-05-626]. Washington, D.C.: June 
2, 2005. 

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Program More Effective. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-05-248]. Washington, D.C.: March 2, 2005. 

VA Vocational Rehabilitation and Employment Program: GAO Comments on 
Key Task Force Findings and Recommendations. [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-04-853]. Washington, D.C.: June 
15, 2004. 

Social Security Administration: More Effort Needed to Assess 
Consistency of Disability Decisions. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-04-656]. Washington, D.C.: July 2, 2004. 

High-Risk Series: An Update. [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-03-119]. Washington, D.C.: January 2003. 

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Needed to Help Ensure Program Integrity. [hyperlink, 
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bin/getrpt?GAO-02-919T]. Washington, D.C.: July 11, 2002. 

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March 29, 2000. 

[End of section] 

Footnotes: 

[1] A person who is earning more than a certain monthly amount is 
ordinarily considered to be engaging in substantial gainful activity. 
In 2008, SGA is $940 per month for individuals with disabilities, not 
including blindness. For blind individuals, the SGA in 2008 is $1,570. 

[2] SSA uses a different three-step process for children who apply for 
payments based on disability under SSI. For individuals who are already 
receiving benefits, SSA also uses a different process when it decides 
whether the individual's disability continues to meet the eligibility 
requirements for disability benefits. However, all of these processes 
include steps at which SSA considers whether an impairment meets or 
equals the medical listings. 

[3] VA also has a pension program that compensates certain veterans 
with low incomes who are permanently and totally disabled, or are age 
65 and older. 

[4] Pub. L. No. 106-170 (1999). 

[5] GAO, High-Risk Series: An Update, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-03-119] (Washington, D.C.: 
January 2003). 

[6] NCD is composed of 15 members appointed by the President and 
confirmed by the U.S. Senate. In compliance with NCD's authorizing 
statute, the President selects members of NCD after soliciting 
recommendations from representatives of organizations representing a 
broad range of individuals with disabilities and organizations 
interested in individuals with disabilities. 

[7] GAO, SSA and VA Disability Programs: Re-Examination of Disability 
Criteria Needed to Help Ensure Program Integrity, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-02-597] (Washington, D.C.: Aug. 
9, 2002). 

[8] SSA and VA categorize their medical criteria based on each of the 
major body functions. SSA's has 14 adult and 15 child body systems, and 
VA's has 16. 

[9] Since 2002, VA completed partial updates of the musculoskeletal, 
respiratory, and neurological body systems. 

[10] Institute of Medicine of the National Academies, Improving the 
Social Security Disability Decision Process (Washington, D.C., 2006). 

[11] Labor and SSA worked collaboratively to define work that was 
meaningful for the disability program. The information was used to 
create the Dictionary of Occupational Titles (DOT) and its companion 
publication, the Selected Characteristics of Occupations (SCO)--two 
sources of information that SSA currently uses to understand work in 
the national economy. However, after the last publication of DOT and 
SCO in 1991, DOL created a new database, O*Net. SSA concluded that 
O*Net descriptions of work are not meaningful for disability 
evaluations. 

[12] The proposed regulations would revise the payment scheme for 
employment networks, which is expected to increase their participation. 
The proposed regulations are also expected to encourage greater 
beneficiary participation by increasing the number of rehabilitation 
providers available to them. 

[13] SSA is proposing to remove this delay in issuing tickets to 
beneficiaries whose medical condition is expected to improve. 

[14] VA defined the rehabilitation rate based on a formula. 
Specifically, the rate is the number of disabled veterans who 
successfully complete VA's vocational rehabilitation program and 
acquire and maintain suitable employment and the number of veterans 
with disabilities for whom employment is infeasible but who obtain 
independence in their daily living with assistance from the program, 
divided by the total number leaving the program--both those 
rehabilitated plus discontinued cases with a plan developed in one of 
three case statuses (independent living, rehabilitation to 
employability, or employment services). To determine the actual rate, 
this number is then subtracted from the number of individuals who 
benefited from, but left, the program and have been classified under 
one of three "maximum rehabilitation gain" categories: (1) the veteran 
accepted an employment position incompatible with disability 
limitations, (2) the veteran is employable but has informed VA that 
they are not interested in seeking employment, or (3) the veteran is 
not employed and not employable for medical or psychological reasons. 

[15] VA Office of Inspector General, Audit of Vocational Rehabilitation 
and Employment Program Operations (Washington, D.C., December 2007). 

[16] The VA Inspector General used statistical sampling techniques to 
determine the sites to be visited and the cases to be reviewed. The 
purpose of the statistical sample was to allow projection of results 
over the entire VA Regional Office site that was visited and for all 
Regional Offices, if necessary. The study also used statistical 
sampling techniques to randomly select a sample of 1,377 cases. 

[17] VDBC analysis of Veterans Benefits Administration, Annual Benefits 
Report Fiscal Year 2006. 

[18] GAO, Social Security Disability: Better Planning, Management, and 
Evaluation Could Help Address Backlogs, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-08-40] (Washington, D.C.: Dec. 7, 
2007). 

[19] SSA uses a relative measure to determine the backlog by 
considering how many cases should be pending at year-end. The number of 
pending claims at year-end that exceed these numbers represents the 
backlog. 

[20] We could not compute the number of claims backlogged at the 
reconsideration stage because SSA has not established an optimal level 
of pending claims that would allow computation of the backlog. 

[21] We studied partnerships that SSA and VA have with these agencies 
because of the number of programs targeting individuals with 
disabilities within these agencies. VA primarily coordinates with the 
Department of Defense; however, we did not include the Department of 
Defense in this study because we have ongoing research on partnerships 
between VA and the Department of Defense. 

[22] Our analysis focused on partnerships between agencies at the 
federal level. While outside the scope of this report, SSA and VA may 
work with agencies at the state or local levels to support disability 
beneficiaries, such as state vocational rehabilitation agencies. 

[23] GAO, Disabled Veterans' Employment: Additional Planning, 
Monitoring, and Data Collection Efforts Would Improve Assistance, 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-1020] (Washington, 
D.C.: Sept. 12, 2007). 

[24] The Disability Program Navigator initiative established a new 
position located within Labor's One-Stop Career Centers. As of May 
2008, Labor stated that there were approximately 525 Disability Program 
Navigators located in state local workforce investment systems in 45 
states, the District of Columbia, and Puerto Rico. The initiative's 
goals include developing new and ongoing partnerships to achieve 
seamless, accessible, comprehensive, and integrated access to services; 
creating systemic change; and expanding the workforce investment 
systems' capacity to serve customers with disabilities and employers. 

[25] The Interagency Committee on Disability Research facilitates the 
exchange of information on disability and rehabilitation research 
activities among its 20-plus member agencies and programs and 
coordinates activities that span the areas of assistive technology and 
universal design, medical rehabilitation, data and statistics, 
employment, and community participation. Participating agencies include 
Education, Labor, HHS, SSA, and VA. The director of Education's 
National Institute on Disability and Rehabilitation Research serves as 
chair of the committee. 

[26] As a result of this agreement, VA expects net savings of nearly 
$13.5 million per year over the life of the agreement. 

[27] SSA's strategic plan for fiscal years 2006 to 2011 discusses ways 
they can increase employment for people with disabilities. Strategies 
include focusing on the improvement and expansion of the agency's 
partnerships with other federal and state agencies, community-based 
organizations, and other public agencies, as well as private 
individuals and groups who serve Social Security beneficiaries with 
disabilities. As part of VA's strategic plan for fiscal years 2003 to 
2008, the agency aspires to meet the need of the nation's veterans and 
their families by, among other things, fostering partnerships with the 
Department of Defense and other federal agencies to leverage resources 
and enhance the quality of services provided to veterans. 

[28] GAO, Federal Disability Assistance: Wide Array of Programs Needs 
to be Examined in Light of 21st Century Challenges, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-05-626] (Washington, D.C.: June 
2, 2005). 

[29] GAO, Highlights of a GAO Forum: Modernizing Federal Disability 
Policy, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-934SP] 
(Washington, DC: Aug. 3, 2007). 

[30] See Ticket to Work and Work Incentives Advisory Panel, Building on 
the Ticket: A New Paradigm for Investing in Economic Self-Sufficiency 
for People with Significant Disabilities, Final Report to the President 
and Congress, Year Eight of the Panel, (Washington, D.C., December 
2007). 

[31] See National Council on Disability, Empowerment for Americans with 
Disabilities: Breaking Barriers to Careers and Full Employment 
(Washington, D.C., Oct. 1, 2007). 

[32] GAO, Managing For Results: Barriers to Interagency Coordination, 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/GGD-00-106] 
(Washington, D.C.: Mar. 29, 2000). 

[33] GAO, Results-Oriented Government: Practices That Can Help Enhance 
and Sustain Collaboration Among Federal Agencies, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-06-15] (Washington, D.C.: Oct. 1, 
2005). 

[34] President George W. Bush announced the New Freedom Initiative 
(NFI) on February 1, 2001, as part of a nationwide effort to remove 
barriers to community living for people with disabilities. The NFI 
directed six federal agencies, including the departments of Education, 
HHS, Housing and Urban Development, Justice, Labor, and the Social 
Security Administration to "evaluate the policies, programs, statutes 
and regulations of their respective agencies to determine whether any 
should be revised or modified to improve the availability of community- 
based services for qualified individuals with disabilities" and to 
report back to the President with their findings. The Office of 
Personnel Management, the Small Business Administration, and the 
departments of Transportation and Veterans Affairs, though not named in 
the Executive Order, also joined in the implementation effort. The NFI 
also has the following goals: increase access to assistive and 
universally designed technologies, expand educational opportunities, 
promote homeownership, integrate Americans with disabilities into the 
workforce, expand transportation options, and promote full access to 
community life. 

[35] On March 13, 1998, President William J. Clinton signed an 
Executive Order which created a Presidential Task Force on Employment 
of Adults with Disabilities. Task force members included the Secretary 
of Education, the Chair of the Equal Employment Opportunity Commission, 
the Secretary of Health and Human Services, the Chair of the National 
Council on Disability, the Administrator of the Small Business 
Administration, the Commissioner of the Social Security Administration, 
and the Secretary of Veterans Affairs. 

[36] Pub. L. No. 95-602 (1978). 

[37] Pub. L. No. 102-569 (1992). The law expanded duties of a prior 
council, the Interagency Coordinating Council, which had been given 
limited duties when established in 1978. The mandated members of the 
IDCC are the Chairperson of the Architectural and Transportation 
Barriers Compliance Board, the Attorney General, the Secretary of 
Education, the Chairperson of the Equal Employment Opportunity 
Commission, the Secretary of Health and Human Services, the Secretary 
of Housing and Urban Development, the Assistant Secretary of the 
Interior for Indian Affairs, the Secretary of Labor, the Director of 
the Office of Personnel Management, and the Secretary of 
Transportation. Additionally, other officials may be designated by the 
President. 

[38] See National Council on Disability, Rehabilitating Section 504 
(Washington, D.C., Feb. 12, 2003). 

[End of section] 

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