SSA Disability Redesign: More Testing Needed to Assess Feasibility of New
Claim Manager Position (Letter Report, 09/27/96, GAO/HEHS-96-170).
Pursuant to a congressional request, GAO assessed the Social Security
Administration's (SSA) establishment of the disability claims manager
(DCM) position, focusing on: (1) SSA efforts to test and implement the
position; (2) major concerns about the position; and (3) SSA efforts to
staff the position.
GAO found that: (1) as envisioned by SSA, DCM would be solely
responsible for processing and approving initial disability claims,
assume functions currently performed by at least three federal and state
workers, and serve as a single, personal point of contact for claimants;
(2) SSA has several initiatives under way to team claims representatives
and disability examiners so that they can coordinate claims processing
functions and prepare for transition to the DCM position; (3) although
it has not yet implemented other initiatives and support features that
are critical to the DCM position, SSA has decided to proceed with plans
to test the DCM position; (4) a three-phase testing plan proposed by an
SSA work group of management representatives, claims representatives,
disability examiners, and federal and state union members may leave some
important DCM features untested and does not have the support of all
work group members; (5) concerns raised about the DCM position include
the complexity of DCM responsibilities, compromises to safety and
controls, salary differential between federal and state workers, and
impact on field operations; and (6) SSA expects to recruit DCM from its
current staff of federal claims examiners and state disability
examiners, but some staff may be unwilling or lack the necessary skills,
and SSA has not developed a plan for providing technical and clerical
support for DCM.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: HEHS-96-170
TITLE: SSA Disability Redesign: More Testing Needed to Assess
Feasibility of New Claim Manager Position
DATE: 09/27/96
SUBJECT: Federal social security programs
Claims processing
Disability insurance
Human resources utilization
Claims adjudicators
Aid for the disabled
Eligibility determinations
Productivity
IDENTIFIER: SSA Disability Process Redesign
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Cover
================================================================ COVER
Report to the Chairman, Subcommittee on Social Security, Committee on
Ways and Means, House of Representatives
September 1996
SSA DISABILITY REDESIGN - MORE
TESTING NEEDED TO ASSESS
FEASIBILITY OF NEW CLAIM MANAGER
POSITION
GAO/HEHS-96-170
Claim Manager Position
(106901)
Abbreviations
=============================================================== ABBREV
DCM - disability claim manager
DDS - disability determination service
DI - Disability Insurance
DPRT - Disability Process Redesign Team
SSA - Social Security Administration
SSI - Supplemental Security Income
Letter
=============================================================== LETTER
B-265665
September 27, 1996
The Honorable Jim Bunning
Chairman, Subcommittee on Social Security
Committee on Ways and Means
House of Representatives
Dear Mr. Chairman:
To better manage increasing workloads with fewer resources, in
October 1993, the Social Security Administration (SSA) embarked on a
7-year effort to redesign its disability claims process. SSA is
responsible for administering federal disability programs that
provide cash and medical assistance to blind, aged, or disabled
people. Between 1985 and 1995 SSA's blind and disabled enrollment
increased about 50 percent. At the same time, SSA's staff decreased,
from 77,741 to an estimated 64,000. In 1995 SSA paid over $61.3
billion in cash benefits to program recipients.
SSA is redesigning its disability claims process to make it more
customer focused and efficient. Currently, disability claimants
frequently wait almost a year for a final disability decision.
Further, disability claimants are dissatisfied with the lack of
personal, specifically, face-to-face, contact with SSA staff who make
the disability decisions. SSA's redesign plan encompasses the
disability determination process: A potential claimant files for
disability benefits; he or she is then assigned benefits or is found
ineligible and files an administrative appeal of a denial of
benefits.
A key initiative in SSA's redesign plan is the establishment of the
disability claim manager (DCM) position. The person in this position
would have total responsibility for adjudicating disability claims
and authorizing the payment of benefits. This is a major change from
current practice: An SSA claims representative makes the initial
contact with the claimant and determines nonmedical eligibility for
the program. Then, a state disability examiner and a medical
consultant determine medical eligibility for the claim, usually
without ever seeing the claimant in person. The goal of the redesign
plan is to give the claimant access to the decisionmaker, the person
who makes the determination, and allow for dialogue between them.
SSA's initial efforts do not include full implementation of the DCM
position before 2001.
In its 1994 redesign plan, SSA intended to move toward the DCM
position in phases, first implementing several initiatives that would
(1) improve service to the public and (2) provide SSA information on
ways to facilitate interaction and teamwork between claims
representatives and disability examiners. Among these initiatives is
sequential interviewing, in which there is an immediate handoff of a
portion of the initial claim from a claims representative to a
disability examiner; the latter would obtain the necessary medical
information directly from the claimant. Another initiative, the
Early Decision List, would assess the effect of claims
representatives, rather than disability examiners, making medical
determinations on disabilities that are included in some categories
of severe impairments. However, SSA's redesign plan has evolved; as
of June 1996, SSA expects to concurrently test the DCM position, as
well as related initiatives.
Given your interest in SSA's redesign plan, you asked us to evaluate
(1) SSA's efforts to test and implement the DCM position, (2) the
major concerns about the position, and (3) SSA's efforts to staff the
position. We performed our work between June 1995 and June 1996 in
accordance with generally accepted government auditing standards.
Our scope and methodology are discussed in appendix I.
RESULTS IN BRIEF
------------------------------------------------------------ Letter :1
Although SSA's efforts may offer the potential to make its disability
claims process more customer focused and efficient, current plans to
test the DCM position are limited in two significant ways. First,
the DCM test will not evaluate all of the duties anticipated for the
position. Second, SSA may not have the appropriate data to compare
the results--such as claimant and employee satisfaction and
reductions in processing time--of assessing the relative merits of
the DCM position, sequential interviewing, and the Early Decision
List testing. This assessment would provide the agency with useful
information for deciding whether and how to proceed with implementing
the DCM position.
Both SSA and state disability determination service (DDS) managers
and staff have raised many concerns about the feasibility of the DCM
position. Because the DCM is charged with denying disability claims
in person, there is concern about safety. In addition, since state
and federal DCMs would be paid under different compensation systems,
many state DCMs would be doing the same work for less pay than their
federal counterparts. Although the work group that developed SSA's
test for the DCM position has developed proposals for addressing
safety concerns, the salary differential between state and federal
DCMs, as well as other concerns, has not yet been addressed.
SSA may encounter problems in its efforts to staff about 11,000 DCM
positions from its current state and federal workforce of about
22,000. These problems are related to concerns for personal safety
and reluctance to carry out some of the tasks required by the new
position. In addition, managers believe that many of their staff may
not have the appropriate skills or background for the position.
BACKGROUND
------------------------------------------------------------ Letter :2
SSA provides assistance to people who qualify as disabled under two
programs: (1) Disability Insurance (DI), which provides benefits to
people who have worked and paid Social Security payroll taxes, and
(2) Supplemental Security Income (SSI), which is an assistance
program for people with limited income and resources who are blind,
aged, or disabled.\1
Currently, the disability determination process starts when a person
first applies for DI or SSI disability benefits. To apply for
benefits, he or she calls the national toll-free telephone number and
is referred to a local SSA field office or visits or calls one of
1,300 local field offices. Claims representatives in field offices
assist with the completion of claims, obtain detailed medical and
vocational history, and screen nonmedical eligibility factors.
Field office staff forward the claim to a DDS. At the DDS, medical
evidence is developed by a disability examiner and a medical
consultant; a final determination is made as to the existence of a
medically determinable disability. The DDSs then send allowed claims
to SSA field offices or SSA processing centers for payment and
storage. Files for denied cases are retained in field offices,
pending possible appeal. According to SSA, in part because of the
numerous handoffs among staff involved in processing a disability
claim, a claimant can wait, on average, between 78 and 94 days from
the time of filing with SSA until receiving an initial claim decision
notice--when in fact only 13 hours is actually spent working on the
claim.\2
In 1994, SSA released its redesign plan for receiving and deciding
disability claims. The plan aims to improve the current process,
which is labor intensive and slow, so as to increase claimant and
staff satisfaction. To develop the plan, SSA created a Disability
Process Reengineering Team, charged with producing a new process that
is customer-focused, operationally feasible, and an improvement over
the current process. A Disability Process Redesign Team (DPRT) was
later formed to implement the Reengineering Team's plan.
In developing its redesign plan, Reengineering Team members solicited
views from customer focus groups, frontline staff, managers and
executives, and parties outside of SSA. The Reengineering Team found
that claimants were frustrated with the fragmented nature of the
current process and wanted more personalized service. In addition,
some SSA staff were frustrated because they were not trained to
answer claimants' questions about medical disability decisions or
about the status of cases while in DDS offices. To address these
concerns, SSA created the DCM position as the cornerstone of its
redesign plan.
Under SSA's redesign plan, the DCM--a single decisionmaker located at
either an SSA or a DDS office--would be solely responsible for
processing the initial disability claim and making the decision,
thereby assuming functions currently performed by at least three
federal and state workers. The DCM would conduct personal
interviews, which could be face-to-face, by telephone, or by video
conference; develop evidentiary records; and determine medical and
nonmedical eligibility. Specifically, the DCM would gather and store
claim information; develop both medical and nonmedical evidence;
share necessary facts in a claim with medical consultants and
specialists in nonmedical or technical issues; analyze evidence;
prepare well-reasoned decisions on both medical and nonmedical
issues; and produce clear, understandable notices to convey
information to claimants. In addition, the DCM would authorize
payment of the claim. Although DCMs would still have access to
medical and technical support personnel, they alone would make the
final decision on both medical and nonmedical aspects of a disability
claim. A medical consultant's signature would no longer be required
on decisions.
The DCM would also serve as a single, personal point of contact for
claimants. When filing claims, claimants could first speak in person
with a DCM to obtain information about the process. In addition, a
claimant would be entitled to contact the DCM throughout the process
and meet personally with the DCM to provide additional evidence if
the DCM expected to deny a claim. See appendix II for a comparison
of the tasks currently assigned to claims representatives and
disability examiners with those expected of the DCM.
Recognizing the complexity of the DCM position responsibilities, the
redesign plan calls for implementing several new support features
that SSA considers critical to the DCM position: (1) SSA plans to
develop a simplified decision methodology that would provide a less
complex, more structured approach for DCMs to use when deciding
claims. (2) New hardware and software would automate most aspects of
the process and allow SSA to move from a process that depends on
paper folders to one that depends on electronic records. These
records would be easy to transmit between headquarters, field
offices, and state DDSs. (3) In order to address the perception that
different policy standards are applied at different levels of
disability decision-making, SSA intends to develop a process that
generates similar decisions for similar cases at all stages of the
disability process through consistent application of laws,
regulations, and rulings. SSA refers to this feature as process
unification. Without these new features, SSA managers do not expect
that DCMs would be able to handle the broad range of activities that
the position requires. However, as of July 1996, none of these
support features were available.
--------------------
\1 In this report, we are focusing only on the blind and disabled.
\2 According to the Office of Disability, through June 1996, the
average time for processing an initial DI claim is 77.6 days and an
initial SSI claim, 94.1 days.
TEST RESULTS SHOULD BE USED TO
PROVIDE BASIS FOR DECISION ON
DCM CONTINUANCE
------------------------------------------------------------ Letter :3
During the next few years, SSA expects to test the DCM position and
several DCM-related initiatives. Some of the related initiatives,
which SSA believes will immediately improve customer service, are
being tested because SSA initially thought that the DCM position
could not be immediately implemented. Other tests, which had been
planned prior to redesign, are designed to provide information on
various functions now incorporated into the DCM position. These
tests are described below. Appendix III provides information on
their status.
SSA IMPLEMENTING EARLY
DECISION LIST, SEQUENTIAL
INTERVIEWING, AND MODEL
SITES
---------------------------------------------------------- Letter :3.1
SSA's initial 1994 redesign plan called for testing and implementing
alternative ways of serving claimants, based on teams of claims
representatives and disability examiners. Currently, a disability
claim is handled primarily by two staff members (the claims
representative and the disability examiner), each working
independently of the other, with minimal coordination. As part of
the redesign plan, SSA expects to team its claims representatives and
DDS disability examiners so they can process claims in a coordinated
manner. SSA also expects that this team environment would allow
claims representatives and disability examiners to share skills and
enhance communication, thus better preparing them for the transition
to the DCM position.
Following this initial teaming of claims representatives and
disability examiners, SSA plans to build on teaming by implementing
the Early Decision List and sequential interviewing initiatives. SSA
envisions that the Early Decision List and sequential interviewing
would provide claims representatives and disability examiners with
opportunities to (1) expedite the processing of disability claims by
streamlining the interview process and (2) expand the claims
representatives' skills and experience in the medical area and that
of the disability examiners in the nonmedical area.
The Early Decision List identifies severe disabilities that can be
adjudicated by claims representatives with minimal training and
documentation. The Early Decision List will allow a claims
representative to approve certain types of claims. After approving a
claim, the claims representative would forward the case to a medical
consultant for final approval. Currently, only the disability
examiner and the medical consultant approve these claims. SSA
expects that initially, about 100,000 claims per year might be
approved under the Early Decision List. Eventually, the number of
Early Decision List cases will expand as claims representatives'
skills and knowledge base increase. This expansion will result from
(1) phasing in additional categories of disabilities and (2) the
option for claims representatives to issue denials.
The sequential interviewing initiative is designed to provide
disability examiners with preliminary interviewing experience for
certain categories of disability claims. Additional categories will
be phased in over time as the examiners' experience increases. Under
sequential interviewing, after the claims representative completes
the nonmedical portion of the claim, he or she will turn the claimant
over to the disability examiner, who will complete the medical
portion of the application. The disability examiner will either talk
with the claimant by telephone before he or she leaves the field
office or talk by telephone at a later date.
According to SSA's plan, the Early Decision List and sequential
interviewing are modeled on existing teaming initiatives in field
offices and state DDSs. For example, some offices have already
experimented with sequential interviewing; in other offices, SSA
claims representatives already assist DDSs by making medical
determinations for some categories of severe disabilities.
Preliminary results from these local initiatives indicate that they
can improve customer service, work flow, and job satisfaction. For
example, one field office that used sequential interviewing processed
initial claims in 46 days, well below the current average of between
78 and 94 days. Customer surveys indicate that claimants served in
these efforts were pleased with the sequential interviewing. In
addition, claims representatives and disability examiners
participating in these initiatives were satisfied with the team
tests, they said.
Currently, SSA expects to conduct formal testing and evaluation of
the Early Decision List, but it will rely on states to test
sequential interviewing. SSA also expects to make available its
Office of Workforce Analysis and Office of Program and Integrity
Reviews to provide test assistance to states. According to the DPRT
director, SSA made this decision because (1) of resource constraints
and (2) sequential interviewing is viewed as only a temporary
measure, which will lead to the DCM position. However, the director
acknowledged that formal testing of sequential interviewing would be
necessary to allow for a comparison of this initiative with the
proposed DCM position.
In addition to sequential interviewing and Early Decision List
initiatives, SSA expects to test modifications to the disability
determination process at model sites in federal offices and state
DDSs. One model site test--the single medical
decisionmaker--exemplifies the concept of the disability examiner
making eligibility decisions alone, except in cases for which medical
consultant involvement is required by statute. SSA considers this
test useful because it analyzes the aspects of the redesign plan that
have DCMs making eligibility decisions without necessarily soliciting
medical consultants' input for all cases. In this test, a disability
examiner will be authorized to make medical eligibility decisions
without obtaining a medical consultant's signature, on the SSA form,
certifying the determination.
In other model site tests, scheduled for completion in late 1998, SSA
will expand the single medical decisionmaker test to evaluate other
aspects of the disability process. In the expanded test, SSA will
consider the effect of allowing claimants to have a personal
predecision interview with the decisionmaker, in order to provide
additional evidence if a denial is imminent. This is an opportunity
not available under the existing system. As of June 1996, SSA was
testing the single medical decisionmaker at DDSs in eight states and
was developing the expanded test for implementation in seven states
and two SSA offices.
SSA PLANS TO TEST AND
EVALUATE THE DCM POSITION
INCREMENTALLY
---------------------------------------------------------- Letter :3.2
In its original redesign plan, SSA intended to test the DCM position
only after testing was under way on the Early Decision List,
sequential interviewing, and initiatives being explored at the model
sites. SSA also intended that critical support features--including a
structured approach for deciding claims, new hardware and software,
and a process that ensures similar decisions for similar cases at all
stages of the disability process--would be in place before the DCM
could be implemented. However, in October 1995, SSA decided to
initiate DCM testing in 1996, even though SSA had not yet (1)
implemented these other initiatives or (2) developed any of the
support features that had been included in the redesign plan as
critical to the position.
According to the DPRT director, SSA management accelerated DCM
testing to address several factors that might impede the overall
redesign plan. For example, the DPRT director became concerned that
delaying DCM testing until critical support features were in place
would slow the momentum for the redesign plan, particularly because
delays were already occurring in SSA's original schedule to implement
these features. SSA also wanted to gain endorsement from its federal
employee union, which originally was concerned about the DCM
position.
The DPRT director further cited state DDS directors' concerns--about
providing disability examiners with little opportunity to gain
nonmedical case development experience--as a factor influencing his
decision to begin testing the DCM position. According to the DPRT
director, the tests will provide states with additional time to
become accustomed to the DCM concept and with the opportunity to
address concerns about the position. However, state DDS directors'
representatives said, DPRT misunderstood their concerns. DDS
directors oppose SSA's plan to accelerate implementation of the DCM
position without the necessary critical support features and are
concerned that SSA is beginning to give a workload to federal
employees that is currently states' responsibility.
According to the president of the American Federation of Government
Employees, Local 1923, the union would have opposed the DCM position
if SSA attempted to implement it as a grade 11. Under a memorandum
of understanding between the union and SSA, people who are assigned
to DCM positions will receive temporary promotions to grade 12, one
grade higher than the journeyman level for the claims representative
position. According to the Deputy Commissioner for Human Resources,
if SSA decides to make the DCM position permanent, an evaluation will
be required to determine the appropriate salary level for the job.
WORK GROUP ESTABLISHED TO
DEFINE PARAMETERS
OF DCM TEST
---------------------------------------------------------- Letter :3.3
To develop parameters for conducting and evaluating the DCM test, SSA
assembled a work group consisting of representatives from SSA and DDS
management, claims representatives and disability examiners, and
federal and state union members. Throughout redesign, SSA has relied
on such work groups to formulate plans for the individual redesign
components. In July 1996, the work group released its final proposal
for testing the DCM position. Agreement to the proposal, developed
by this work group, must be obtained from the states, unions, and SSA
management.
The work group's report recommends that SSA (1) conduct the DCM test
in three phases, over a 3-year period, and (2) decide, at the end of
each phase, how to proceed with the balance of the test. During the
first phase, scheduled to last for 18 months, SSA would test 150
federal and 150 state DCM positions. At the end of this phase, SSA
would evaluate the results to determine whether it should continue,
modify, or terminate the DCM test. For the second phase, if SSA
decides to continue the test, it would then introduce an additional
200 federal and 200 state DCMs. After this phase, SSA would again
evaluate the results to determine whether the agency should continue,
modify, or terminate the test. If SSA decides to proceed with the
third phase, it would then establish an additional 400 federal and
400 state DCMs. At the end of this third and final phase, SSA would
conduct a comprehensive review of the entire DCM test in order to
decide whether it should implement the DCM position permanently.
However, the testing proposed by the DCM work group may leave
untested an important feature of the position. During the initial
test of the position, the claimant may not be given an opportunity to
meet personally, face-to-face, with the DCM in a predecision
interview. At this time, the claimant could provide additional
evidence if the DCM expects to deny the claim. The predecision
interview is a key factor of the DCM position, one that (1) could
easily be tested without waiting for the critical support features
and (2) many claims representatives and disability examiners would
prefer not to do.
Further, even though DDS representatives were work group
participants, they did not support SSA's proposal to test 1,500 DCM
positions. At the conclusion of the DCM work group's activities, the
National Council of Disability Determination Directors presented a
position paper to the DPRT director, stating that they would only
agree to a test involving 60 state and 60 federal DCMs.
CONCERNS ABOUT THE DCM POSITION
------------------------------------------------------------ Letter :4
Concerns have been raised about the DCM position since the DPRT first
proposed it in 1994. These concerns include the complexity of the
responsibilities, compromises to safety and internal controls, salary
differential between federal and state employees, and structure of
field operations.
DCM RESPONSIBILITIES
CONSIDERED COMPLEX
---------------------------------------------------------- Letter :4.1
SSA and state DDS managers and staff, as well as employee groups and
union representatives, are concerned about one person's ability to
master the complex responsibilities expected of a DCM. The DCM will
combine major segments of two positions--claims representative and
disability examiner--and will also include responsibilities now
assigned to medical consultants.
As SSA's key staff providing public service, claims representatives
carry out a wide range of complex tasks in the disability program.
When processing an initial disability claim, a claims representative,
through interviews, obtains and clarifies information from a
disability claimant. The claims representative assists claimants
with securing necessary additional evidence. Ultimately, the
representative (1) determines whether claimants meet nonmedical
requirements for benefits, using a series of administrative
publications, including SSA's Program Operations Manual System that
interprets federal laws and regulations, (2) calculates benefit
amounts, and (3) authorizes payments for allowed claims. Because of
voluminous, detailed, and complicated program guidelines, some claims
representatives specialize in processing claims for a specific SSA
program, such as SSI.
State DDS disability examiners also perform a wide range of complex
tasks to determine whether a claimant's disability meets SSA's
medical criteria for benefits eligibility. The disability examiner
reviews claims forwarded by SSA field offices, obtaining additional
medical records and vocational documentation on claimants as
necessary. In making a medical determination, a disability examiner
must establish the date of onset, duration, and level of severity of
the disability; the prognosis for improvement; and the effect of the
disability on a claimant's ability to engage in gainful employment.
As with guidelines for claims representatives, the complicated
disability program guidelines lead some disability examiners to
specialize in processing either child or adult claims.
The complexity of disability examiners' and claims representatives'
responsibilities is evidenced by the training required for the
positions. Newly hired SSA claims representatives typically take 13
weeks of classroom training, followed by on-the-job training and
mentoring. They reach journeyman level after a minimum of 2 years on
the job. Similarly, the state DDS examiners go through a formal
2-year training program that includes classroom training and close
individual supervision and guidance from unit supervisors; only then
are examiners able to make medical eligibility determinations
independently.
According to some SSA and DDS managers and employees, the DCM
position may stretch staff to the point that they cannot competently
manage all the required tasks. For example, in one state that we
visited, a local demonstration project has claims representatives
approving disability decisions for some categories of claims--those
for which the disability is easily determined. According to quality
assurance staff reviewing these decisions, claims representatives are
beginning to make errors on nonmedical portions of claims, possibly
because these representatives are branching out into areas beyond
their knowledge and experience.
Although the DPRT director agreed that the responsibilities of the
DCM position are complex, he stated that SSA designed it in response
to claimants' concerns that the existing process did not meet their
needs. The new position is intended to (1) simplify the application
process for claimants by allowing them personal contact with
decisionmakers and (2) provide for more rapid decisions on claims.
In addition, he stated that the DCM test will permit SSA to assess
the feasibility of the DCM position.
DCM POSITION COULD
COMPROMISE SAFETY AND
INTERNAL CONTROLS
---------------------------------------------------------- Letter :4.2
According to some federal and state staff and managers, the DCM
position has the potential to compromise internal controls and safety
of staff, issues that are currently not a problem because
responsibilities are split between state and federal staff. These
staff and managers are concerned about the safety of DCMs when they
conduct face-to-face interviews with claimants. They are also
concerned that the DCM position could compromise existing internal
controls on the disability program.
SSA's redesign plan provides an opportunity for claimants to speak
face-to-face with the DCMs who make decisions on their cases.
Currently, claimants rarely meet face-to-face with disability
examiners, who are primarily responsible for making the disability
decision. As a matter of practice, claimants have personal
interviews--by telephone or face-to-face--with field office claims
representatives, who are frequently not trained to answer claimants'
questions about medical disability decisions.
According to claims representatives and disability examiners, because
of past incidents of claimant violence and the fact that some
claimants have a history of mental illness, they are worried that
claimants could become violent with DCMs who notify them,
face-to-face, that their claims will be denied unless they can
provide additional information as support. In addition, state staff
said, some disability examiners chose their profession partly because
it did not involve face-to-face interviews with claimants.
Consequently, claims representatives and disability examiners may be
reluctant to become DCMs because of such safety and job preference
concerns.
SSA's plan to provide claimants an opportunity to meet face-to-face
with decisionmakers differs from the approach used by many private
companies that provide disability and workers compensation insurance.
In these organizations, face-to-face interviews are generally used
only under specific conditions, such as to investigate potential
fraud or to help facilitate rehabilitation. According to officials
from various private companies, direct personal contact with
claimants generally is not economically viable because such meetings
take a considerable amount of time. Further, these officials said,
face-to-face meetings provide little additional information besides
that which can be obtained by phone and mail and that they often
create stress for staff who deny claimants' benefits.
Further, under the existing system, different groups of federal and
state staff--including claims representatives, disability examiners,
and claims authorizers--are responsible for making eligibility
decisions, medical determinations, and claim payment authorizations.
This division of responsibilities helps meet standards for internal
controls in the federal government. These standards require that key
duties and responsibilities in authorizing, processing, recording,
and reviewing transactions be separated among staff. Such standards
help to reduce the risk of error, waste, or wrongful acts because
each staff member carries out his or her tasks for specific
transactions; he or she is independent from the other staff members
involved in processing the same transaction.
Under the SSA redesign plan, however, the DCM--a single
decisionmaker--would be responsible for making medical and nonmedical
eligibility decisions and for authorizing benefit payments for each
disability claim. By assigning all these responsibilities to one
decisionmaker, SSA is increasing the potential for staff fraud, as
other staff will not be processing the different parts of the claim.
According to SSA, the DPRT has not yet developed a way to address
this concern. However, according to the deputy associate
commissioner for Office Financial Policy and Operations, SSA will
address these issues as the redesign plan is implemented.
UPGRADED POSITION WILL WIDEN
STATE AND FEDERAL SALARY
DIFFERENTIAL
---------------------------------------------------------- Letter :4.3
State DDS representatives are concerned about SSA's agreement with
labor union officials to compensate federal DCMs, during the test, at
a higher salary level than claims representatives. Their concern is
that the agreement will exacerbate the salary differential between
state and federal staff. According to Wisconsin DDS calculations,
federal claims representatives now earn about $7,863 more on average
in annual salary and benefits ($49,607) than state disability
examiners ($41,744). However, disability examiners and claims
representatives currently have different job responsibilities, which
partially explains the salary differential.
If SSA promotes grade 11 claims representatives to grade 12 DCMs, the
differential between federal and state DCMs will ultimately widen to
over $17,714. Federal DCMs will earn about $59,458 in salary and
benefits, but state DCMs are not expected to receive a similar
position upgrade. This differential would be more problematic than
the current one because federal and state DCMs would be doing
identical jobs. According to DDS directors, the salary differential
between federal and state DCMs could cause serious morale problems
among staff.
According to the DPRT director, the salary differential between
federal and state DCMs will continue to exist. However, the director
said, states should use the DCM test as an opportunity to take
position descriptions to their civil service boards to see if the
positions can be upgraded. The director plans to work with state
DDSs to facilitate this upgrade. However, according to the president
of the National Council of Disability Determination Directors, many
states will be unable to upgrade DDS employees because disability
examiner positions are frequently classified with other unrelated
positions and can not be upgraded without affecting states' overall
pay structures.
DCM'S IMPACT ON FIELD
OPERATIONS UNCERTAIN
---------------------------------------------------------- Letter :4.4
The DCM position may require SSA and the state DDSs to restructure
their field operations. Currently, SSA has about 1,300 field offices
at which claimants can file their initial claims. The 54 DDSs have
different types of field structures: 38 are centralized, with staff
located in one office; the remaining 16 are decentralized, with staff
in more than one office. However, in a given state, even
decentralized DDSs have fewer field offices than SSA has.
Since both state and federal offices will be handling claimants'
initial claims after redesign, SSA and DDSs may need to consider
changing their current field operations to avoid overlapping areas of
service within the same metropolitan area. States with DDS staff in
one area, however, would need to relocate some of them or open new
offices that are convenient to claimants throughout their states.
Finally, because medical consultants are generally only located in
DDSs, SSA will need to consider how to provide federal and state DCMs
with access to medical consultants.
Although the DCM work group recognized these concerns, it did not
propose ways to deal with them in the upcoming accelerated DCM tests.
According to the DPRT director, SSA has not yet addressed and
resolved these concerns.
UNCERTAINTIES EXIST ABOUT
AVAILABILITY OF DCM STAFF
------------------------------------------------------------ Letter :5
SSA expects to recruit the approximately 11,000 DCMs, which it
estimates will be needed, from its current staff of federal claims
representatives and state disability examiners. However, some of
these staff may be unwilling or lack the necessary skills to assume
DCM responsibilities. In addition, SSA has not yet developed plans
for providing technical and clerical support staff for the DCM
position.
ISSUES AFFECTING DCM STAFF
---------------------------------------------------------- Letter :5.1
SSA management estimates that it will need about 11,000 DCMs to
process disability claims. SSA expects to recruit DCMs from its
current staff of about 16,000 claims representatives and about 6,000
disability examiners. Although some claims representatives may
process either retirement and survivor or disability claims,
disability examiners only work on disability claims. According to
DPRT team members, federal claims representatives who lack the
interest or skills necessary to become DCMs will be able to continue
processing retirement and survivor claims. In contrast, it is
unclear what employment options will be available for state
disability examiners who do not want to become DCMs since DCMs will
make all disability decisions.
Although SSA plans to recruit DCMs from the current ranks of claims
representatives and disability examiners, SSA management will face
various challenges doing so. Many SSA and DDS field office managers
and staff, whom we interviewed, were skeptical about whether enough
claims representatives and disability examiners would have the
necessary skills to assume the additional responsibilities expected
of DCMs. Claims representatives and disability examiners will need
extensive training to learn each others' job requirements.
Further, disability examiners in California, Florida, North Carolina,
and Wisconsin would prefer not to have direct contact with claimants
because of the pressure of face-to-face interviews, they said.
Currently, disability examiners generally make disability decisions
based on a review of documents without face-to-face contact with the
claimant. Some disability examiners also indicated that they were
unwilling to become DCMs because they were not interested in
performing the nonmedical tasks involved in processing a claim.
According to the DPRT director, concerns about staff availability and
the stress associated with the DCM position are valid. However, he
stated, the potential for stress is not a reason for SSA to abandon
the DCM position. In his opinion, SSA cannot focus solely on its
staff and ignore its customers' demands for improved service;
further, the DCM test would consider the effect of stress and ways to
alleviate it. However, during the first phase of the upcoming test,
as proposed by the DCM work group, SSA would not test the
face-to-face predecision interview, one of the major points of
potential stress for staff filling the new position.
PLANS FOR TECHNICAL AND
CLERICAL SUPPORT
ARE UNCLEAR
---------------------------------------------------------- Letter :5.2
SSA recognizes that DCMs will need the assistance of technical and
clerical support staff to allow DCMs to perform their duties.
Although DCMs will be responsible for handling most aspects of
disability claims, SSA's redesign plan calls for DCMs to "work in a
team environment with internal medical and nonmedical experts...as
well as technical and other clerical personnel...." For example, DCMs
may need clerical help to assist in performing labor-intensive tasks
associated with the processing of disability claims, such as
processing mail and screening telephone calls. DCMs may also need
access to medical and technical support personnel. Although no
longer required on all cases, DCMs may need to obtain the opinion of
medical consultants for certain cases. Similarly, DCMs may also need
to call on technical support staff for assistance with claimant
contacts, status reports, development of nondisability issues, and
payment authorization.
In November 1995, an initial report, from the DPRT work group on the
DCM position, recommended that SSA create a new DCM assistant
position to provide various types of support to DCMs. The work group
recommended that SSA create one DCM assistant position for every two
DCMs. Although SSA management did not agree to create this new
position, management did agree to use existing personnel to staff DCM
model test sites with appropriate technical and clerical support.
However, this may be difficult for SSA because many of its field
offices presently have few or no clerical staff.
CONCLUSIONS
------------------------------------------------------------ Letter :6
Even though the critical support features required for the DCM are
unavailable, SSA's decision to test the DCM position provides an
opportunity to gather information about the position's feasibility,
efficiency, and effectiveness. Thorough data gathering and analysis
will provide SSA with some of the key information it needs to
determine whether the DCM position is the best way to serve the
claimant population and protect the public trust. The DCM work
group's proposal--calling for evaluating the activity of the first
group of DCMs 18 months into the test and using the evaluation
results to make a decision on whether to proceed with additional
testing, modify the DCM position, or cancel the position entirely--is
sound.
However, there are some limitations on what SSA can actually test
relative to the DCM position at this time. Because the critical
support features are not ready for testing, the test will not provide
a complete picture of the DCM position's feasibility, nor will it
allow SSA to assess the relative costs and benefits of implementing
the position. SSA will also not be able to assess the effects that
improvements, such as technological enhancements and a simplified
decision methodology, will bring to the overall disability claims
process. The DCM work group's consideration of delaying the
predecision interview may also limit the value of the test.
As SSA attempts to make a sound decision about further DCM testing or
implementation of the DCM position, SSA would benefit from
systematically assessing the results from all its DCM-related
initiatives--the DCM tests, the model site tests, the Early Decision
List, and sequential interviewing--and comparing their relative
effects on SSA's workforce, work flow, operating costs, and service
to claimants. SSA may find that the results of some of these
initiatives (1) increase decision-making efficiency and satisfy
claimants more effectively than the DCM position or (2) may suggest
better ways to satisfy claimant needs and reduce processing time. To
facilitate the evaluation of all these initiatives, SSA needs to
ensure that it has comparable test results for each of them.
RECOMMENDATIONS TO THE
COMMISSIONER OF THE SOCIAL
SECURITY ADMINISTRATION
------------------------------------------------------------ Letter :7
We recommend that the Commissioner of the Social Security
Administration assess current efforts to test the DCM position, so as
to ensure that SSA is provided with the best possible information for
making future decisions about the position. Specifically, the
Commissioner should
-- include, in the test of the DCM position, a personal predecision
interview that provides an opportunity for claimants to meet
with the DCM in person, by video conference, or by telephone,
and
-- continue testing of sequential interviewing, Early Decision
List, and model site initiatives throughout the DCM test.
Testing and subsequent evaluations should document the extent to
which the DCM position and the other initiatives increase service to
the public and decrease processing time. At the end of the initial
18-month testing period and, if appropriate, at subsequent decision
points, SSA should compare the evaluation results of the DCM and
other initiatives with respect to their relative benefits and costs.
SSA should consider these results before deciding to increase the
number of DCM test positions and before approving the DCM position
permanently.
AGENCY COMMENTS AND OUR
EVALUATION
------------------------------------------------------------ Letter :8
In its comments on this report, SSA generally agreed that we have
identified the issues and concerns raised by the establishment of the
new disability claims manager position. SSA also stated that it will
make or has already made the changes we recommended to ensure the
availability of the information necessary to assess the DCM position.
Finally, SSA also stated that it plans to use results from other
DCM-related initiatives to document the extent to which service to
the public is improved and processing time is reduced.
We believe SSA's planned actions would be more effective if SSA
included a predecision interview in its DCM test. We also believe
that SSA should ensure that states' evaluation of sequential
interviewing initiatives can be compared with the results of the DCM
and other related initiatives.
SSA made a number of technical comments, which we incorporated as
appropriate. The full text of SSA's comments and our responses are
included in appendix IV.
---------------------------------------------------------- Letter :8.1
We are providing copies of this report to the Director of the Office
of Management and Budget and the SSA Commissioner. We will also make
copies available to others upon request.
Major contributors to this report are listed in appendix V. If you
have any questions concerning this report or need additional
information, please call me on (202) 512-7215.
Sincerely yours,
Jane L. Ross
Director, Income Security Issues
SCOPE AND METHODOLOGY
=========================================================== Appendix I
To determine how SSA planned to test and implement the DCM position,
we interviewed and reviewed documents from key members of the
Redesign Team at SSA's headquarters in Baltimore, Maryland. We also
conducted site visits in California, Florida, Georgia, North
Carolina, and Wisconsin, where we (1) interviewed staff and managers
of SSA field offices and state DDSs and (2) analyzed documents they
provided. We judgmentally selected these locations because local SSA
field offices and DDSs in these states have already experimented with
a teaming initiative, so as to facilitate closer interaction between
SSA claims representatives and DDS disability examiners. Although
these initiatives were not part of SSA's redesign plan, we believe
the results provide some insight on how SSA could implement the DCM
position.
To identify the concerns associated with the DCM position, we spoke
with the following during our site visits: DPRT members, SSA
regional and field office managers and staff, employee union
representatives, and DDS managers and staff. We also reviewed
documents they provided us, which summarized their views on the DCM
position.
To determine whether SSA had ensured that it had an adequate staff to
implement the DCM position, we interviewed and analyzed information
from DPRT members, SSA field office managers and staff, and state DDS
officials and staff. To identify how organizations with employee
classifications similar to the DCM process claims, we also
interviewed representatives from four private insurers, two
affiliated trade associations, and a public utility.
COMPARISON OF TASKS ASSIGNED TO
CLAIMS REPRESENTATIVES, DISABILITY
EXAMINERS, AND DISABILITY CLAIM
MANAGERS
========================================================== Appendix II
Claims Disability
representati Disability claim
Task ves examiners managers
---------------- ------------ ------------ ------------
Intake
----------------------------------------------------------
Nonmedical X X
development
Disability X X
interview
Eligibility X X
status
Explain program X X X
to claimants,
representatives,
and third
parties
Evidence development
----------------------------------------------------------
Initial X X X
development
Purchase X X
consultative
examination
Vocational X X
development
Decision X
interview
Methodology
----------------------------------------------------------
Disability X X
decision
Consult with X X
medical
consultant
Prepare denial X X
notices
Final decision
----------------------------------------------------------
Nonmedical X X
development
Final X X
authorization
----------------------------------------------------------
Source: SSA's Disability Process Redesign Team.
STATUS OF SSA'S DCM-RELATED
INITIATIVES AS OF JUNE 28, 1996
========================================================= Appendix III
Original
implementation Status as of June
Initiative plan 28, 1996
------------------ ------------------ ------------------
Teaming To begin 11/95\a Not yet started;
negotiations with
state DDSs
continuing
Early Decision To be phased in Not yet started;
List starting 2/96\a negotiations with
state DDSs
continuing
Sequential To be phased in Not yet started;
interviewing starting 2/96\a negotiations with
state DDSs
continuing
Model site test: To begin 12/95\a Testing began in
single 4/96
decisionmaker
Model site test: To begin 1/96\a Not yet started;
expanded test expected to begin
9/96
Disability claim DCM positions to Testing
manager (DCM) test be tested during accelerated to be
FY 97-98\b simultaneous with
other initiatives;
DCM positions not
yet established;
and negotiations
with state DDSs
and unions
continuing
----------------------------------------------------------
\a Based on DPRT implementation schedule of 10/20/95.
\b Based on November 1994 Disability Redesign Planning Timetable.
(See figure in printed edition.)Appendix IV
COMMENTS FROM THE SOCIAL SECURITY
ADMINISTRATION AND OUR EVALUATION
========================================================= Appendix III
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
The following are GAO's comments on the Social Security
Administration's letter dated August 16, 1996.
GAO COMMENTS
1. We modified our recommendation to reflect the different ways that
a DCM could conduct a predecision interview with a claimant:
face-to-face, by video conferencing, or by telephone contact.
2. We continue to believe that SSA should incorporate the
predecision interview into the DCM test, beginning with the initial
18-month phase, to make the test as comprehensive as possible.
Incorporating the predecision interview into the DCM test would
provide SSA with valuable information for making future decisions
about the feasibility of the DCM position and whether testing should
continue beyond the first phase. In particular, testing the
predecision interview could provide information about the effect of
face-to-face interviews on office security, a main area of concern
raised about the DCM position. SSA should not wait for the
predecision interview to be tested as part of the expanded model site
test. Results from this test are not expected until late in 1998 and
may not be available in time for SSA to consider when it makes its
decision about further testing or implementation of the DCM position.
3. We support SSA's decision to provide an opportunity for the
claimant to readily and easily contact DCMs participating in the
test. Since SSA had already decided that claimants would have this
access to the DCM, we modified one of the recommendations in the
report.
4. We continue to be concerned that SSA may not have all the test
results it needs to decide whether the DCM position should be fully
adopted. SSA needs to ensure that states' evaluation of sequential
interviewing initiatives can be compared with the results from the
initiatives that SSA is conducting and analyzing itself. We believe
SSA's test of the DCM position, combined with results of other
related tests, should provide the basis for its decision on whether
or not to implement the position.
GAO CONTACTS AND STAFF
ACKNOWLEDGMENTS
=========================================================== Appendix V
GAO CONTACTS
Michael T. Blair, Jr., Assistant Director, (404) 679-1944
Lois L. Shoemaker, Evaluator-in-Charge, (404) 679-1806
STAFF ACKNOWLEDGMENTS
In addition to those named above, David G. Artadi coauthored the
report and contributed significantly to all data-gathering and
analysis efforts.
*** End of document. ***