Social Security Disability
Additional Outreach and Collaboration on Sharing Medical Records Would Improve Wounded Warrior's Access to Benefits Gao ID: GAO-09-762 September 16, 2009Disability benefits available through the Social Security Administration (SSA) can be an important source of financial support for some wounded warriors, and Congress has mandated that the Departments of Defense (DOD) and Veterans Affairs (VA) help them learn about and apply for such benefits. GAO was asked to determine: (1) how many wounded warriors have applied and been approved for SSA benefits and the extent to which they are receiving benefits from across the three agencies; (2) what steps DOD, VA, and SSA have taken to inform wounded warriors about SSA benefits, and the challenges that confront this process; and (3) steps taken by all three agencies to facilitate the processing of wounded warrior disability claims. Focusing on those wounded since 2001, GAO reviewed policy documents, contacted DOD and VA medical facilities, surveyed wounded warriors, and analyzed administrative data.
As of December 2008, about 7,600 of the16,000 wounded warriors who have applied for SSA disability benefits since 2001 have been approved. The majority filed their applications since 2007. Also, a sizable minority of approved claimants filed long enough after injury that they lost some retroactive benefits; SSA is considering a legislative proposal to change the retroactive period for wounded warriors. Among wounded warriors receiving DOD or VA disability benefits, 4 percent were receiving SSA benefits. In addition, more than 6 percent had applied but were not receiving SSA benefits; some still had claims pending. Those with higher disability ratings from DOD or VA were more likely to receive SSA benefits. To varying degrees, SSA, DOD, and VA have increased outreach to help wounded warriors learn about and apply for SSA disability benefits. Since 2007, SSA has increased its outreach to DOD and VA medical facilities and has tailored benefit information for wounded warriors. DOD--and to some extent VA--have incorporated SSA information into their case management practices as well. Locally, DOD and SSA staff have worked together to reach servicemembers, but collaboration has been less common at VA hospitals. Meanwhile, there are challenges to reaching and working with this population. Many of the wounded warriors may not be ready or able to hear about SSA benefits early in their recovery. Also, brain injuries and mental health disorders can impede many wounded warriors' ability to absorb outreach information and complete the benefit application. With help from DOD and VA, SSA has been able to expedite processing of wounded warrior claims. SSA has established a nationwide policy requiring its offices to give priority to wounded warrior claims. For their part, DOD helps SSA identify claimants who are wounded warriors, and VA has expedited the transfer of its medical records and histories to SSA. However, DOD's paper-based transfer of medical records to SSA is slow, which can prolong the process by weeks or months, according to claims processing staff.
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Director: Team: Phone:GAO-09-762, Social Security Disability: Additional Outreach and Collaboration on Sharing Medical Records Would Improve Wounded Warrior's Access to Benefits
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Report to the Subcommittee on Social Security, Committee on Ways and
Means, House of Representatives:
United States Government Accountability Office:
GAO:
September 2009:
Social Security Disability:
Additional Outreach and Collaboration on Sharing Medical Records Would
Improve Wounded Warriors' Access to Benefits:
GAO-09-762:
GAO Highlights:
Highlights of GAO-09-762, a report to the Subcommittee on Social
Security, Committee on Ways and Means, House of Representatives.
Why GAO Did This Study:
Disability benefits available through the Social Security
Administration (SSA) can be an important source of financial support
for some wounded warriors, and Congress has mandated that the
Departments of Defense (DOD) and Veterans Affairs (VA) help them learn
about and apply for such benefits. GAO was asked to determine: (1) how
many wounded warriors have applied and been approved for SSA benefits
and the extent to which they are receiving benefits from across the
three agencies; (2) what steps DOD, VA, and SSA have taken to inform
wounded warriors about SSA benefits, and the challenges that confront
this process; and (3) steps taken by all three agencies to facilitate
the processing of wounded warrior disability claims. Focusing on those
wounded since 2001, GAO reviewed policy documents, contacted DOD and VA
medical facilities, surveyed wounded warriors, and analyzed
administrative data.
What GAO Found:
As of December 2008, about 7,600 of the16,000 wounded warriors who have
applied for SSA disability benefits since 2001 have been approved. The
majority filed their applications since 2007. Also, a sizable minority
of approved claimants filed long enough after injury that they lost
some retroactive benefits; SSA is considering a legislative proposal to
change the retroactive period for wounded warriors. Among wounded
warriors receiving DOD or VA disability benefits, 4 percent were
receiving SSA benefits. In addition, more than 6 percent had applied
but were not receiving SSA benefits; some still had claims pending.
Those with higher disability ratings from DOD or VA were more likely to
receive SSA benefits.
Figure: Number of Wounded Warrior Applicants for SSA Disability
Benefits:
[Refer to PDF for image: vertical bar graph]
Calendar year: 2002;
Number of Wounded Warrior Applicants: 4.
Calendar year: 2003;
Number of Wounded Warrior Applicants: 93.
Calendar year: 2004;
Number of Wounded Warrior Applicants: 217.
Calendar year: 2005;
Number of Wounded Warrior Applicants: 481.
Calendar year: 2006;
Number of Wounded Warrior Applicants: 1,330.
Calendar year: 2007;
Number of Wounded Warrior Applicants: 5,200.
Calendar year: 2008;
Number of Wounded Warrior Applicants: 8,652.
Source: GAO analysis of SSA data.
[End of figure]
To varying degrees, SSA, DOD, and VA have increased outreach to help
wounded warriors learn about and apply for SSA disability benefits.
Since 2007, SSA has increased its outreach to DOD and VA medical
facilities and has tailored benefit information for wounded warriors.
DOD”and to some extent VA”have incorporated SSA information into their
case management practices as well. Locally, DOD and SSA staff have
worked together to reach servicemembers, but collaboration has been
less common at VA hospitals. Meanwhile, there are challenges to
reaching and working with this population. Many of the wounded warriors
may not be ready or able to hear about SSA benefits early in their
recovery. Also, brain injuries and mental health disorders can impede
many wounded warriors‘ ability to absorb outreach information and
complete the benefit application.
With help from DOD and VA, SSA has been able to expedite processing of
wounded warrior claims. SSA has established a nationwide policy
requiring its offices to give priority to wounded warrior claims. For
their part, DOD helps SSA identify claimants who are wounded warriors,
and VA has expedited the transfer of its medical records and histories
to SSA. However, DOD‘s paper-based transfer of medical records to SSA
is slow, which can prolong the process by weeks or months, according to
claims processing staff.
What GAO Recommends:
GAO recommends that SSA move ahead with its consideration of a
legislative proposal on retroactive benefits, VA work with SSA to
improve outreach to veterans on SSA benefits, and DOD work with SSA to
meet SSA‘s need for timely medical records. In their comments on our
draft report, SSA and VA agreed with our findings and recommendations
and noted actions they plan to take to address our recommendations. DOD
did not provide formal comments.
View [hyperlink, http://www.gao.gov/products/GAO-09-762] or key
components. For more information, contact Daniel Bertoni at (202) 512-
7215 or bertonid@gao.gov.
[End of section]
Contents:
Letter:
Background:
Thousands of Wounded Warriors Have Applied and Been Approved for SSA
Disability Benefits, and Relatively Few Receiving DOD or VA Benefits
Also Receive SSA Benefits:
Agencies Have Taken Steps to Conduct Outreach to Wounded Warriors on
SSA Benefits but a Number of Challenges Exist:
SSA Is Expediting Wounded Warrior Claims With Assistance From DOD and
VA, but The Transfer Of DOD Medical Records Can Prolong Decision-
Making:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Summary of Major Disability Benefit Programs Available to
Wounded Warriors:
Appendix III: Complete Results of Wounded Warrior Survey:
Appendix IV: VA Standard Summary:
Appendix V: Comments from the Social Security Administration:
Appendix VI: Comments from the Department of Veterans Affairs:
Appendix VII: GAO Contact and Staff Acknowledgments:
Related GAO Products:
Tables:
Table 1: Summary of Outreach Activities at DOD and VA Medical
Facilities:
Table 2: Local Offices Contacted:
Figures:
Figure 1: Number of Wounded Warrior Applicants for SSA's DI or SSI
Benefits, by Year in Which Applications Were Submitted:
Figure 2: Length of Time from Disability Onset to Application Filing
Date for Wounded Warrior Applicants Approved at the Initial Stage:
Figure 3: Claim Outcomes for Wounded Warrior Applicants at Initial,
Reconsideration, and Hearing Stages:
Figure 4: Body System Category of Primary Impairment, for Wounded
Warriors with Allowed Claims at Initial and Reconsideration Stages:
Figure 5: Wounded Warriors' Receipt of Disability Benefits by Agency,
as of July 2008:
Figure 6: Percentage of Wounded Warriors Receiving DOD or VA Disability
Benefits Who Had Applied for and were Receiving SSA Disability Benefits
by Disability Percentage Rating, as of July 2008:
Figure 7: Sample Page from SSA Publication:
Figure 8: Sample Page from Army Wounded Warrior Patient Intake Form
that Includes SSA:
Figure 9: Excerpts from the Customized Walk-Through Presentation:
Figure 10: Estimated Length of Time for Wounded Warriors to First Learn
about SSA Disability Benefits After Onset of Medical Condition:
Figure 11: How Wounded Warriors' First Learned of SSA Disability
Benefits (Estimated):
Figure 12: Difficulties Wounded Warriors Had with Completing the SSA
Disability Benefits Application:
Figure 13: Median Days from Application to Initial Decision for Wounded
Warriors' DI Claims Versus All DI Claims:
Figure 14: Locations Contacted During Study:
Figure 15: VA Standard Summary:
Abbreviations:
AAJ: administrative appeals judge:
ALJ: administrative law judge:
DDS: Disability Determination Services:
DI: Disability Insurance:
DMDC: Defense Manpower Data Center:
DOD: Department of Defense:
IU: Individual Unemployability:
MBR: Master Beneficiary Record:
MEB: medical evaluation board:
MTF: military treatment facility:
NHIN: Nationwide Health Information Network:
ODAR: Office of Disability Adjudication and Review:
OEF: Operation Enduring Freedom:
OIF: Operation Iraqi Freedom:
PDRL: Permanent Disability Retired List:
PEB: physical evaluation board:
PTSD: post traumatic stress disorder:
SDR: Structured Data Repository:
SSA: Social Security Administration:
SSI: Supplemental Security Income:
SSR: Supplemental Security Record:
TBI: traumatic brain injury:
TDRL: Temporary Disability Retired List:
VA: Department of Veterans Affairs:
VASRD: Department of Veterans Affairs Schedule for Rating Disabilities:
VBA: Veterans Benefits Administration:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
September 16, 2009:
The Honorable John S. Tanner:
Chairman:
The Honorable Sam Johnson:
Ranking Member:
Subcommittee on Social Security:
Committee on Ways and Means:
House of Representatives:
Since October 2001, more than 1.6 million military personnel have been
deployed in support of Operation Enduring Freedom (OEF) and Operation
Iraqi Freedom (OIF).[Footnote 1] Estimates of the number wounded in
these conflicts vary widely depending, for example, on the medical
conditions counted. Due to advances in battlefield medicine, a larger
proportion of military personnel are surviving their wounds than in
previous years, though often with serious medical conditions including
amputations, traumatic brain injury (TBI), and post traumatic stress
disorder (PTSD). For those servicemembers and veterans who were
wounded, injured, or became ill while on active duty since 2001--also
called wounded warriors--a range of financial benefits are available.
The Department of Defense (DOD) and the Department of Veterans Affairs
(VA) provide disability benefits that are linked to military service.
In addition, the Social Security Administration (SSA) administers
disability benefit programs that are not tied to military service, but
may still be an important part of a wounded warrior's total package of
financial assistance--if they are aware of and apply for these
benefits. Wounded warriors may receive certain benefits from SSA while
receiving DOD or VA disability benefits.
Some reports issued in 2007 raised questions concerning whether the
federal government had been sufficiently focused on helping wounded
warriors access SSA disability benefits. For example, the Veterans'
Disability Benefits Commission report suggested that many veterans who
may be eligible for SSA disability benefits are not receiving such
benefits, and that outreach to disabled veterans regarding SSA benefits
may be inadequate.[Footnote 2] Partly as a result of the controversy
surrounding conditions at the Walter Reed Army Medical Center, Congress
has focused increased attention on the care that recovering
servicemembers and veterans receive, including efforts to ensure they
receive their entitled benefits. The National Defense Authorization Act
for Fiscal Year 2008 requires DOD and VA to develop, in consultation
with other relevant federal agencies, a comprehensive policy for the
improvement of case management for recovering servicemembers and
veterans.[Footnote 3] This plan is to include connecting wounded
warriors with SSA benefits, although the statute does not formally
specify a role for SSA in the case management process. In accordance
with increased congressional attention and statutory requirements, DOD
and VA have developed several new programs designed to help wounded
warriors heal and transition back to their military duties or to
civilian life. These and other programs may potentially help wounded
warriors learn about and apply for SSA benefits. However, while a
number of studies have looked at DOD and VA efforts to help recovering
servicemembers and veterans, these studies have not focused on how SSA
benefits have been provided to wounded warriors and the challenges in
doing so.
Given this context, you asked us to determine (1) the number of wounded
warriors who have applied and been approved for SSA disability
benefits, and the extent to which wounded warriors who receive DOD or
VA disability benefits also receive SSA benefits; (2) the extent to
which SSA, DOD, and VA have worked to inform wounded warriors about and
help them apply for SSA disability benefits, and the challenges
confronting this outreach effort; and (3) whether the agencies have
taken any steps to facilitate the processing of wounded warriors' SSA
disability benefit claims.
In addressing these questions, we have focused our research on wounded
warriors who were wounded, injured, or ill while on active duty since
2001. More specifically, to answer the questions, we reviewed policy
and other documents from SSA, DOD, and VA, and interviewed officials
responsible for outreach and case management policies at each agency.
We selected seven DOD and five VA medical treatment facilities in order
to examine local-level activities and collaboration. We selected
several of these sites because they serve a majority of the severely
wounded servicemembers. The remaining sites were selected based on
factors including the number of pending SSA claims submitted by wounded
warriors in the region in which the facility is located and the number
of recovering servicemembers assigned to each facility. For each
selected location, we generally interviewed staff from the DOD or VA
facility, an SSA district office, and the state office responsible for
medical evaluation of SSA claims; at some sites we also interviewed
servicemembers. In addition, we obtained and analyzed administrative
data from SSA, DOD, and VA on wounded warriors' utilization of
financial benefits from all three agencies. We found the administrative
data to be sufficiently reliable for the purposes of our report.
Finally, to gain a broader understanding of the experiences and
opinions of wounded warriors, we conducted a mail survey of a sample of
wounded warriors who had applied for SSA disability benefits during
fiscal year 2008. The survey attained a 53 percent response rate. While
a nonresponse bias analysis revealed that older and more educated
individuals were more likely to respond to our survey than younger and
less educated individuals, it did not reveal large or systematic bias
in our overall survey results. Unless otherwise noted, percentage
estimates from the survey have 95 percent confidence intervals within
plus or minus 8 percentage points or less of the estimate, and are
generalizable to the entire population of fiscal year 2008 applicants.
We conducted this performance audit from March 2008 through September
2009 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. (See
appendix I for more details on our objectives, scope, and methodology.)
Background:
Military personnel wounded since 2001--the exact number is not known--
may qualify for financial benefits from several federal agencies. While
SSA, VA, and DOD each provide disability benefits that are available to
wounded warriors, these programs have different eligibility criteria
and serve different purposes. SSA has two programs, Disability
Insurance (DI) and Supplemental Security Income (SSI), to provide
benefits for those whose disabilities prevent them from working. VA's
disability compensation program and DOD's disability retirement program
provide benefits to those with service-connected disabilities. (See
appendix II for a table summarizing the three agencies' disability
programs.)
Varying Estimates of the Total Number of Wounded Warriors Since 2001:
Estimates of the number of military personnel wounded, ill, or injured
since 2001 vary widely depending on what conditions are counted and the
source of data used. DOD has reported that about 34,000 servicemembers
have been wounded in action in the OEF/OIF campaigns through the
beginning of June 2009. On the other hand, our analysis of VA data
shows that almost 250,000 OEF/OIF veterans were receiving VA disability
compensation benefits as of July 2008. This figure may be larger than
DOD's estimate because, for example, some wounded warriors' service-
related medical conditions may have only appeared or been recognized
after they separated from the military. Yet another estimate comes from
a 2008 study by the RAND Corporation.[Footnote 4] Based on a survey of
individuals deployed in support of OEF and OIF, this study estimated
that more than 500,000 OEF/OIF veterans and servicemembers likely
suffer from at least one of three mental health or cognitive
conditions--PTSD, major depression, and probable TBI--that are likely
linked to combat experience. The RAND estimate, unlike the VA estimate,
includes wounded warriors whose medical conditions may not even have
been medically diagnosed.
SSA Disability Benefits:
To be eligible for either DI or SSI, an adult must be unable to engage
in "substantial gainful activity"--typically work that results in
earnings above a monthly threshold established each year by SSA--
because of a medically determinable physical or mental impairment that
is expected to last at least 12 months or result in death.[Footnote 5]
Established in 1956, the DI program provides monthly benefits to
individuals (and sometimes their dependents) whose work history
qualifies them for disability benefits and whose impairment is
disabling. To qualify for DI, individuals must have worked a certain
minimum amount of time in employment covered by Social Security; the
monthly amount of DI benefits is based on the worker's past average
monthly earnings. In fiscal year 2008, the average monthly DI benefit
payment was $997. SSI is a means-tested income assistance program
created in 1972 that provides a financial safety net for people who are
aged, blind, or disabled, and have low incomes and limited assets.
Unlike the DI program, SSI has no prior work requirements. The basic
federal SSI benefit is the same for all individual
beneficiaries.[Footnote 6] This basic, monthly SSI benefit may be
reduced if an individual has other income or receives in-kind (noncash)
support or maintenance. In fiscal year 2008, the average monthly SSI
benefit payment was $476. Some individuals with disabilities can
receive both DI and SSI benefits if they meet both DI's work history
requirements and SSI's income and asset limits.
The process to determine a claimant's eligibility for SSA disability
benefits is complex, involving several state and federal offices. A
claimant first completes an application, or claim, for DI or SSI
benefits, which includes information regarding illnesses, injuries, or
conditions and a signature giving SSA permission to request medical
records from medical care providers. Once the SSA field office staff
verify that nonmedical eligibility requirements are met, the claim is
sent to the state's Disability Determination Services (DDS) office for
determination of medical disability.[Footnote 7] If the claim is
approved, a claimant will be notified and will receive benefits,
including limited retroactive benefits for some DI claimants.[Footnote
8] If the claim is rejected, a claimant has 60 days to request that the
DDS reconsider its decision. If the DDS reconsideration determination
concurs with the initial denial of benefits, the claimant has 60 days
to appeal and request a hearing before an SSA administrative law judge
(ALJ). A claimant may appeal an unfavorable ALJ decision to SSA's
Appeals Council--which includes administrative appeals judges (AAJ) and
appeals officers--and, finally, to the federal courts. SSA and DDS
officials (for example. disability examiners, ALJs, and AAJs) determine
disability based on evidence, such as medical findings and statements
of functional capacity, obtained during the initial determination
process and updated as necessary at each appeal level.
VA Disability Compensation Benefits:
VA's disability compensation program compensates veterans for the
average loss in civilian earning capacity that results from injuries or
diseases incurred or aggravated during military service, regardless of
current employment status or income. VA uses the Department of Veterans
Affairs Schedule for Rating Disabilities (VASRD) as criteria to
determine the disability percentage rating. Disability ratings range
from 0 (least severe) to 100 percent (most severe) in increments of 10
percent. For example, an amputation of a thumb could result in a 40
percent rating, while an amputation of a ring finger could result in a
20 percent rating. If the veteran is found to have one or more service-
connected disabilities with a combined rating of at least 10 percent,
VA will pay monthly compensation, with amounts higher for those with
higher ratings. As of December 2008, a veteran without dependents rated
at 20 percent disabled receives monthly compensation of $243, whereas a
veteran without dependents rated at 100 percent disabled receives
$2,673 monthly. The veteran can be re-evaluated if the extent of the
veteran's disability changes or if new or newly recognized medical
conditions or illnesses occur and are determined to have been caused or
aggravated by military service. The veteran may, upon re-evaluation,
receive a different percentage rating than they initially received.
DOD Disability Retirement Benefits:
DOD's disability system awards compensation to those servicemembers who
are found to be no longer medically fit for duty, and, if they do not
recover, separates them from the military. Like VA, DOD uses the VASRD
as criteria to determine the disability percentage rating. The amount
of DOD disability payment is based on whether the disability is service-
related, the years of service, and the disability rating percentage.
Servicemembers who receive a disability rating of 30 percent or higher--
regardless of their years of service--generally will be retired and may
be eligible for lifelong benefits, including retirement pay and health
insurance for the servicemember and their family. These servicemembers
are placed on the Permanent Disability Retired List (PDRL).
Servicemembers with fewer than 20 years of service who are separated
with a disability rating of 20 percent or less receive a single lump-
sum severance payment; those with at least 20 years of service who
receive a disability rating under 30 percent are placed on the PDRL and
receive on-going monthly benefits. Servicemembers may also be placed on
the Temporary Disability Retired List (TDRL) if they are found to be
medically unfit for duty by military examiners, but their service-
related illnesses or injuries are not stable enough to assign them a
permanent disability rating. Once a permanent disability rating can be
assigned, depending on the rating and the servicemember's years of
military service, DOD may place those on the TDRL on the PDRL, grant
them a one-time severance payment, or find them fit to return to
military service.
SSA Disability Coverage for Wounded Warriors:
Military servicemembers pay Social Security payroll taxes and may
qualify for DI benefits on the basis of their service if they have a
sufficient number of work quarters. Military service, for Social
Security purposes, includes service in the Army, Navy, Air Force,
Marines, and Coast Guard, including service in the Reserves and
National Guard. Those who served in the military during certain periods
of time are given credits that increase the earnings that SSA looks at
in determining DI eligibility and benefit levels. Individuals are
considered to have earned an additional $300 per quarter for military
service between 1957 and 1977, and an additional $100 for every $300
actually earned--up to a maximum of $1,200--per calendar year between
1978 and 2001. In addition to DI benefits, wounded warriors may qualify
for SSI benefits if they have low income and assets.
Furthermore, active duty servicemembers may receive DI benefits while
also receiving military pay. Social Security law gives SSA the
discretion to determine when an individual is actually performing work
at the substantial gainful activity level, regardless of the
individual's income. Accordingly, in determining eligibility for
benefits in cases when an applicant is receiving military pay, but is
also receiving medical treatment or is on limited duty status, SSA
assesses not the servicemember's actual earnings, but rather what the
servicemember would be paid in the civilian labor market for their
work. If the wage that the servicemember could theoretically receive in
the civilian workforce is less than SSA's substantial gainful activity
level, then SSA will not automatically disqualify the servicemember
from receiving disability benefits.[Footnote 9]
Impact of VA and DOD Disability Decisions on SSA Decisions:
Given that the SSA, VA, and DOD disability programs have different
purposes and eligibility criteria, not all wounded warriors found to be
disabled by VA or DOD--even those found 100 percent disabled--will
necessarily qualify for SSA disability benefits. SSA's DI program, for
example, is an insurance program designed to replace workers' income if
they become unable to work due to disability. If an individual can
perform any kind of work in the U.S. economy, then this person is not
eligible for DI benefits.[Footnote 10] By contrast, VA's disability
compensation program is designed to compensate veterans for the average
loss of earnings resulting from a particular disability--regardless of
the actual effect on an individual veteran's capacity to work. A
veteran could be rated 100 percent disabled under the VASRD by VA and
receive VA disability benefits, but also be working and earning more
than SSA's substantial gainful activity level, and therefore be
ineligible for SSA benefits.
While SSA programs have different eligibility criteria than VA or DOD
programs, and SSA makes its own disability decisions separate from
those of VA or DOD, SSA regulations state that SSA eligibility
determinations are to take disability decisions by other agencies into
account. SSA regulations specify that the agency must evaluate all the
evidence in a case record that may have a bearing on its disability
decision, including decisions by other governmental and nongovernmental
agencies. SSA has issued guidance to its adjudicative staff--including
DDS claims examiners and SSA ALJs and AAJs--that when making a
disability decision they must consider all the evidence in the case
file, including a finding of disability by another agency such as VA.
Adjudicators should explain the consideration given to a finding of
disability by another agency in the case record for initial and
reconsideration claims or in the notice of decision for hearing claims.
However, the SSA regulations also note that a finding of disability by
another government agency, related to a different benefit program, is
not binding on SSA's own disability determination.
Financial Interaction of SSA, DOD, and VA Benefits:
Depending on their circumstances, wounded warriors may receive cash
benefits simultaneously from SSA and from DOD or VA. However, receipt
of DOD or VA benefits sometimes affects the amount of SSA benefits that
a wounded warrior may receive. Specifically, SSI benefits are reduced
if the beneficiary also receives benefits from certain other government
programs such as DOD or VA benefits. On the other hand, DI benefits are
not offset by VA or DOD disability benefits, so wounded warriors may
receive their full DI benefits along with benefits from these other
agencies. By contrast, DOD disability retirement benefits and VA
disability compensation benefits are awarded on the basis of the
content of disabilities incurred during military service rather than on
the basis of income. Wounded warriors may receive their full DOD or VA
disability benefits along with any SSA benefits.[Footnote 11]
Thousands of Wounded Warriors Have Applied and Been Approved for SSA
Disability Benefits, and Relatively Few Receiving DOD or VA Benefits
Also Receive SSA Benefits:
More than 16,000 wounded warriors have applied for SSA disability
benefits and their approval rate has been about 60 percent; in
addition, about 4 percent of wounded warriors receiving DOD or VA
disability benefits are also receiving SSA disability benefits. At
least 16,000 wounded warriors have applied for SSA disability benefits
since 2001, with close to 90 percent of applications submitted in 2007
and 2008. A sizable minority of wounded warriors submitted their
applications more than a year after injury, often foregoing some
retroactive benefits because of this delay in applying. About 60
percent of the applicants with no pending claims have been approved for
benefits by SSA, with a majority of the approved claimants having a
mental health disorder as their primary impairment. Among wounded
warriors who were receiving disability benefits from DOD or VA, about
10 percent had applied for SSA disability benefits, and about 4 percent
of the total cohort of wounded warriors receiving DOD or VA benefits
were also receiving SSA benefits. Wounded warriors with higher
disability ratings were more likely to have applied and to be receiving
SSA disability benefits.
At Least 16,000 Wounded Warriors Have Applied for SSA Disability
Benefits--Often A Year Or More After Injury--and Their Approval Rate
Has Been 60 Percent:
Since 2001, at least 16,000 wounded warriors have applied for SSA
disability benefits.[Footnote 12] This figure represents the number of
applicants whom SSA has identified in its systems as wounded warriors,
but because of limitations with SSA's data sources the total number of
applicants is likely higher. In its databases, SSA identifies wounded
warriors as those applicants who were disabled while in active military
service on or after October 1, 2001, regardless of where the disability
occurred. SSA uses two sources of information to identify wounded
warrior applicants. First, DOD provides SSA with a list every week of
military personnel who have been wounded, injured, or become ill while
in support of the OEF/OIF campaigns. According to DOD, though, while
this list is the only data they have available, it is not necessarily a
comprehensive list of all military personnel wounded, ill, or injured
in OEF/OIF. In addition, applicants may self-identify as wounded
warriors when they submit their applications. However, SSA only started
collecting this information from applicants in 2005, so wounded
warriors who applied before 2005 and are not in DOD's data would have
been missed.[Footnote 13]
Meanwhile, we found that of the more than 16,000 wounded warriors
appearing in SSA's data as having applied for SSA benefits, virtually
all had submitted claims for DI benefits, with many also submitting a
claim for SSI. (Applicants may file claims for DI benefits on the basis
of their past work history or SSI benefits on the basis of low income
and assets.)[Footnote 14] Among these 16,000 applicants, about 53
percent had applied for both DI and SSI benefits concurrently, another
47 percent applied for DI benefits only, and less than 1 percent
applied for SSI benefits only.
We also found that the vast majority of the applicants submitted their
claims within the last two calendar years. Although wounded warriors
who have served since 2001 have applied for SSA disability benefits in
every year dating back to 2002, the number of claims submitted has
increased each year--almost 90 percent of the applicants submitted
their claims in 2007 or 2008 (see figure 1).
Figure 1: Number of Wounded Warrior Applicants for SSA's DI or SSI
Benefits, by Year in Which Applications Were Submitted:
[Refer to PDF for image: vertical bar graph]
Calendar year: 2002;
Number of Wounded Warrior Applicants: 4.
Calendar year: 2003;
Number of Wounded Warrior Applicants: 93.
Calendar year: 2004;
Number of Wounded Warrior Applicants: 217.
Calendar year: 2005;
Number of Wounded Warrior Applicants: 481.
Calendar year: 2006;
Number of Wounded Warrior Applicants: 1,330.
Calendar year: 2007;
Number of Wounded Warrior Applicants: 5,200.
Calendar year: 2008;
Number of Wounded Warrior Applicants: 8,652.
Source: GAO analysis of SSA data.
Note: This figure reflects data for more than 99 percent of the 16,005
wounded warrior applicants. Data on the remaining applicants were
missing or miscoded in SSA's database.
[End of figure]
While most of the wounded warriors for whom SSA has determined a
disability onset date submitted their applications to SSA within a year
of sustaining their wound, injury, or illness, a substantial number
submitted applications a year or more after injury. Among wounded
warriors whose claims were approved at the initial stage of
adjudication and for whom SSA has established a disability onset
date,[Footnote 15] more than half submitted their applications within a
year of this onset date. But about 40 percent submitted claims at least
12 months after disability onset, and almost a quarter submitted claims
at least 18 months after onset. (See figure 2.) DI claimants who file
an application more than 17 months after disability onset will forego
some retroactive benefits, because their 12-month retroactive benefit
period will not extend all the way back to the end of the 5-month
waiting period (between the disability onset date and the date a
claimant can start receiving DI benefits). SSA has for some time been
considering a legislative proposal to change or waive the statutory
retroactive benefit period specifically for wounded warriors to help
those who may not apply soon enough after disability onset. An SSA
official reported that the agency's consideration of such a proposal is
based in part on anecdotal evidence from local offices about wounded
warriors not applying for benefits in a timely manner. SSA has not
provided us with any further details about their potential proposal.
Figure 2: Length of Time from Disability Onset to Application Filing
Date for Wounded Warrior Applicants Approved at the Initial Stage:
[Refer to PDF for image: pie-chart]
Under 6 months: 34%;
6 to 11 months: 25%;
12 to 17 months: 17%;
18 to 23 months: 9%;
24 months or more: 15%.
Source: GAO analysis of SSA data.
Note: Established onset date was not available for 12 percent of
wounded warrior applicants who were approved at the initial stage.
[End of figure]
Turning to the claim outcomes for wounded warrior applicants identified
in SSA's data, we found that the approval rate for these wounded
warriors was 60 percent.[Footnote 16] By comparison, among all
individuals who filed a claim for DI benefits in 2007, 32 percent had a
claim approved by August 2008.[Footnote 17] Specifically, about 7,600
of the wounded warrior applicants had at least one claim allowed for
either DI or SSI. The vast majority of these claim allowances have come
at the initial stage of adjudication. Of the approximately 7,600
claimants with allowed claims, 96 percent had claims allowed at the
initial stage, and 4 percent at the hearings level.[Footnote 18] Of the
remaining wounded warriors with no allowed claim, the majority had
their claims denied, though many still had at least one claim pending a
final decision. (See figure 3.)
Figure 3: Claim Outcomes for Wounded Warrior Applicants at Initial,
Reconsideration, and Hearing Stages:
[Refer to PDF for image: vertical bar graph]
Claim outcome: Allowance;
Number of wounded warrior applicants: 7,569.
Claim outcome: Denial;
Number of wounded warrior applicants: 5,067.
Claim outcome: Pending;
Number of wounded warrior applicants: 2,963.
Claim outcome: No determination/dismissal;
Number of wounded warrior applicants: 286.
Source: GAO analysis of SSA data.
Note: Outcome data were missing for less than 1 percent of wounded
warrior claimants. Also, according to SSA officials, sufficient data
were not available on how many wounded warriors appealed their claims
to the Appeals Council and to the federal courts.
[End of figure]
Breaking out DI and SSI claims, we found that wounded warriors were
much more likely to have claims allowed for DI than for SSI, and a
major reason was that many wounded warriors exceeded SSI income and
asset requirements. Of the almost 16,000 wounded warriors who submitted
a claim for DI, about 7,500 had a DI claim allowed. Of the roughly
8,500 who submitted a claim for SSI--often concurrently with their DI
claim--fewer than 900 had an SSI claim allowed. Wounded warriors' SSI
claims were much more likely to be denied for technical--nonmedical--
reasons. Of those who applied for SSI, 64 percent were denied for
technical reasons, particularly for having income or resources above
the program's limits. In contrast, of those who applied for DI, less
than 1 percent were denied for technical reasons, such as insufficient
work history.
Finally, looking at the medical conditions of wounded warriors whose
claims were allowed, we found that the majority were found eligible on
the basis of mental health disorders. That is, the primary medical
impairment for about 60 percent of wounded warriors allowed at the
initial or reconsideration stages, fell into the overall category of
mental disorders (see figure 4).[Footnote 19] By contrast, among all
disabled workers who had DI claims allowed in 2008, 23 percent had a
mental disorder. Among wounded warriors with mental disorders, the
three most common specific conditions--accounting for more than half of
all the wounded warriors with allowed claims--were anxiety disorders,
mood or affective disorders, and chronic brain syndrome. According to
SSA officials, wounded warriors with PTSD are included in either the
anxiety disorder category or the mood or affective disorder category.
Also, those with TBI may be classified as having chronic brain
syndrome, or as having any of a number of neurological conditions
depending on their symptoms. Aside from mental disorders, most of the
remaining wounded warriors with allowed claims had a musculoskeletal
condition as their primary impairment. The most common musculoskeletal
conditions--accounting for about 13 percent of all wounded warriors
with allowed claims--were back disorders, amputations, and lower limb
fractures.
Figure 4: Body System Category of Primary Impairment, for Wounded
Warriors with Allowed Claims at Initial and Reconsideration Stages:
[Refer to PDF for image: vertical bar graph]
Body system: Mental;
Percentage: 59.
Body system: Musculoskeletal;
Percentage: 21.
Body system: Unknown;
Percentage: 7.
Body system: Neurological;
Percentage: 6.
Body system: Malignant neoplastic diseases;
Percentage: 2.
Body system: Special senses and speech;
Percentage: 1.
Body system: Skin;
Percentage: 1.
Body system: Digestive;
Percentage: 1.
Body system: Special/Other;
Percentage: 1.
Body system: Cardiovascular;
Percentage: 1.
Body system: Immune;
Percentage: 1.
Source: GAO analysis of SSA data.
Note: Percentages add to more than 100 because of rounding. Also,
several additional body system categories each included less than 1
percent of wounded warriors' primary impairments.
[End of figure]
A Small Percentage of Wounded Warriors Receiving DOD or VA Benefits
Also Receive SSA Benefits, and Those With Higher Disability Ratings Are
More Likely to Receive Benefits From SSA:
Among almost 251,000 wounded warriors receiving DOD or VA disability
benefits, we found that about 26,000 (10 percent) of this cohort had
applied for SSA disability benefits and about 9,000 (4 percent) were
receiving SSA benefits as of July 2008. It is likely that some
applicants still had claims pending as of July 2008--the cut-off date
for our analysis--and could have eventually been approved for benefits.
It is also possible that some of the applicants had been approved for
SSA benefits in the past, but were no longer receiving them in July
2008.[Footnote 20] Our analysis focused on wounded warriors receiving
DOD disability retirement VA disability compensation benefits, or both,
in July 2008 who had served in active duty at any point since September
2001.[Footnote 21] The vast majority (92 percent) of the cohort of
251,000 wounded warriors received benefits only from VA. Another 2
percent received benefits only from DOD. The remaining wounded warriors
received benefits from more than one agency.[Footnote 22] (See figure
5.)
Figure 5: Wounded Warriors' Receipt of Disability Benefits by Agency,
as of July 2008:
[Refer to PDF for image: pie-chart]
VA only: 91.6%;
VA and DOD: 3.3%;
VA and SSA: 3.0%;
DOD only: 1.5%;
VA, DOD, and SSA: 0.5%;
DOD and SSA: 0.1%.
Source: GAO analysis of data from SSA, DOD, and VA.
[End of figure]
We also found that among wounded warriors receiving DOD or VA
disability benefits those with higher disability ratings were more
likely to have applied for and been receiving SSA disability benefits.
Among the approximately 7,400 wounded warriors rated as 100 percent
disabled by DOD or VA, 63 percent had applied for SSA benefits and 41
percent--of the entire group of 7,400--were receiving them in July
2008. By comparison, among those rated as less than 50 percent
disabled, fewer than 10 percent had applied for and fewer than 2
percent were receiving SSA disability benefits. (See figure 6.)
Importantly, not all wounded warriors rated as 100 percent disabled by
DOD or VA will necessarily qualify for SSA disability benefits, given
differences in the purposes and eligibility criteria between the
agencies' programs. Similarly, some wounded warriors rated as less
severely disabled by DOD or VA could qualify for SSA benefits. DOD
disability retirement and VA disability compensation benefits --unlike
SSA benefits--are awarded on the basis of service-connected
disabilities. According to SSA officials, some veterans found by DOD or
VA to have only moderate service-connected disabilities could have
experienced an additional injury or illness after separating from the
military, which later qualified them for SSA benefits.
Figure 6: Percentage of Wounded Warriors Receiving DOD or VA Disability
Benefits Who Had Applied for and were Receiving SSA Disability Benefits
by Disability Percentage Rating, as of July 2008:
[Refer to PDF for image: vertical bar graph]
VA or DOD disability percentage rating: 100;
Applied for SSA disability benefits: 63%;
Receiving SSA disability benefits: 41%.
VA or DOD disability percentage rating: 90;
Applied for SSA disability benefits: 34%;
Receiving SSA disability benefits: 15%.
VA or DOD disability percentage rating: 80;
Applied for SSA disability benefits: 24%;
Receiving SSA disability benefits: 9%.
VA or DOD disability percentage rating: 70;
Applied for SSA disability benefits: 18%;
Receiving SSA disability benefits: 6%.
VA or DOD disability percentage rating: 60;
Applied for SSA disability benefits: 12%;
Receiving SSA disability benefits: 3%.
VA or DOD disability percentage rating: 50;
Applied for SSA disability benefits: 10%;
Receiving SSA disability benefits: 3%.
VA or DOD disability percentage rating: 40;
Applied for SSA disability benefits: 8%;
Receiving SSA disability benefits: 2%.
VA or DOD disability percentage rating: 30;
Applied for SSA disability benefits: 8%;
Receiving SSA disability benefits: 2%.
VA or DOD disability percentage rating: 20;
Applied for SSA disability benefits: 4%;
Receiving SSA disability benefits: 1%.
VA or DOD disability percentage rating: 10;
Applied for SSA disability benefits: 3%;
Receiving SSA disability benefits: 0%.
VA or DOD disability percentage rating: 0;
Applied for SSA disability benefits: 6%;
Receiving SSA disability benefits: 2%.
Source: GAO analysis of SSA, DOD, and VA data.
[End of figure]
Agencies Have Taken Steps to Conduct Outreach to Wounded Warriors on
SSA Benefits but a Number of Challenges Exist:
Outreach to help wounded warriors learn about and apply for disability
benefits under SSA has increased in recent years as a result of both
agency actions at the national level and local initiative taken at
major medical facilities for the wounded. The agencies involved--SSA,
DOD, and VA--have taken individual and joint steps to specifically
target this population, tailor information to military needs, and, in
effect, re-enforce the message that wounded warriors may qualify for
SSA benefits. At the local level we found many instances of DOD staff
and local SSA representatives working in concert at DOD treatment
facilities to convey this information to the wounded. However,
collaboration between VA and SSA was less prevalent at VA medical
centers. A number of challenges can affect agency efforts to reach out
and assist this population, particularly for those diagnosed with PTSD
and TBI.
SSA, DOD, and VA Have Developed Programs and Initiatives to Reach
Wounded Warriors, Particularly since 2007:
SSA, DOD, and VA have taken individual and collaborative steps at the
national level to establish and maintain outreach to wounded warriors
who may qualify for SSA disability benefits.
SSA:
Since 2007, SSA has increased its outreach efforts to wounded warriors
by initiating contact with DOD and VA medical facilities and tailoring
its information about disability benefits to meet their needs. SSA
officials reported that they had begun to specifically target the
wounded warrior population partly as a result of their participation in
a 1-year pilot project with the U.S. Navy. Conducted from 2006 to 2007,
the pilot was designed to help reduce the time it was taking for
information to be disseminated and decisions to be made on SSA benefits
for servicemembers.[Footnote 23] Following this project, SSA
headquarters directed its field offices to increase their efforts to
work with DOD and VA medical facilities to conduct outreach. SSA
officials reported that their field offices have subsequently been in
contact with wounded warriors or staff at almost 30 DOD facilities and
more than 50 VA facilities across the country. In addition, the agency
has developed publications and established a Web site with SSA
disability benefits information that has been customized for wounded
military personnel and veterans. These resources explain, for example,
how military pay affects eligibility for SSA's programs and how to
apply. (See figure 7.) SSA officials told us although SSA does not have
any formal practices in place to determine whether or not outreach has
been effective, there is an internal workgroup--consisting of staff
from headquarters, regional, district, and DDS offices--that meets
quarterly to discuss and share successful local efforts in serving
wounded warriors, as well as best practices for reaching wounded
warriors.
Figure 7: Sample Page from SSA Publication:
[Refer to PDF for image: illustration]
Disability Benefits for Wounded Warriors:
Military service members can receive expedited processing of disability
claims from processing. Benefits available through Social Security are
different than those from the Department of Veterans Affairs and
require a separate application.
The expedited process is used for military service members who become
disabled while on active military service on or after October 1, 2001,
regardless of where the disability occurs.
The following are answers to questions most people ask about applying
for disability benefits. Knowing the answers to these questions will
help you understand the process.
What types of benefits can I receive?
Social Security pays disability benefits through two programs: the
Social Security disability insurance program, which pays benefits to
you and certain members of your family if you are "insured," meaning
that you worked long enough and paid Social Security taxes; and the
Supplemental Security Income (SSI) program, which pays benefits based
on financial need.
This fact sheet is about the Social Security disability program. For
more information about the Social Security disability program, ask for
Disability Benefits (Publication call1.800-772-1213 information about
the SSI disability program for adults, ask for Supplemental Security
Income (Publication No. 05-11000). These publications also are
available online at [hyperlink,
http://www.socialsecurity.gov/woundedwarriors].
What is Social Security's definition of disability?
By law, Social Security has a very strict definition. To be found
disabled:
* You must be unable to do substantial work because of your medical
condition(s); and;
* Your medical condition(s) must have lasted, or be expected to last,
at least one year or be expected to result in death.
While some programs give money to people with partial disability or
short-term disability, Social Security does not.
How does military pay affect eligibility for disability benefits?
You cannot engage in substantial work activity for pay or profit, also
known as substantial gainful activity. Active duty status and receipt
of military pay does not, in itself, necessarily prevent payment of
disability benefits. Receipt of military payments should never stop you
from applying for disability benefits from Social Security. If you are
receiving treatment at a military medical facility and working in a
designated therapy program or on limited duty, we will evaluate your
work activity to determine your eligibility for benefits. The actual
work activity is the controlling factor and not the amount of pay you
receive or your military duty status.
How do I apply?
You may apply for disability benefits at any time while in military
status or after discharge, whether you are still hospitalized, in a
rehabilitation program or undergoing out-patient treatment in a
military or civilian medical facility. You may apply online at
[hyperlink, http://www.socialsecurity.gov/woundedwarriors], in person
at the nearest Social Security office, or by telephone. You may call 1-
800-772-1213 schedule an appointment. If you are deaf or hard of
hearing, you may call our TTY number, 1-800-325-0778. Online we have a
"disability starter kit" available to help you complete your
application.
What do I need to apply?
Claimants and their representatives must provide information and
documentation about age, employment, proof of citizenship, Social
Security coverage and information regarding all impairments and related
treatment. Social Security will make every reasonable effort to help
you get the necessary medical evidence.
Important: You should file the application for disability benefits as
soon as possible with any documents readily available. Do not delay
filing because you do not have all the documents mentioned below.
* Original or certified copy of your birth certificate or proof of U.S.
citizenship or legal residency if foreign born;
[hyperlink, http://www.socialsecurity.gov]
Source: SSA as of August 2007.
[End of figure]
DOD:
DOD has taken a number of steps to help wounded warriors learn about
and apply for SSA disability benefits, particularly since 2007. The
department has incorporated information about SSA benefits into the
many case management programs run by the service branches--programs
already providing a range of advice and assistance to wounded warriors
and their families. We found that these programs--the Army Wounded
Warrior Program, the Warrior Transition Brigade, the Marine Wounded
Warrior Regiment, and the Navy Safe Harbor Program--covered SSA
benefits in their case management review materials or list SSA as a
resource on their Web sites.[Footnote 24] (See figure 8 for an example
of one of the assessment tools used in the case management programs to
help ensure SSA disability benefits are discussed.) Additionally, DOD
case managers for these programs received briefings from SSA as part of
their training regimen, according to DOD officials. A DOD official told
us the agency has also included SSA disability programs in the
portfolio of information to be disseminated through its Recovery
Coordination Program, which was included in the comprehensive recovery
plan for wounded warriors developed in response to the National Defense
Authorization Act for Fiscal Year 2008.[Footnote 25] This recovery plan
does not formally spell out how DOD case managers should conduct
outreach on SSA benefits or work with SSA.
Figure 8: Sample Page from Army Wounded Warrior Patient Intake Form
that Includes SSA:
[Refer to PDF for image: illustration]
The following are highlighted on the sample page:
2. Finance Data:
Soldier/Family has applied for Social Security Disability:
2. Finance Interventions:
Referred Family to (SSA) [hyperlink, http://www.socialsecurity.gov].
Source: Army Wounded Warrior program.
[End of figure]
DOD has also added SSA benefit information to a variety of resources
available to wounded warriors--for example, DOD's Compensation and
Benefits Handbook dedicates a section to the subject. DOD also has Web
sites that contain some information about SSA and it has added links to
SSA's own wounded warrior Web site. Meanwhile, information about SSA
disability benefits has also been included in joint briefings that DOD,
VA, and other agencies conduct at all DOD bases and military treatment
facilities for servicemembers who are being discharged from the
military.[Footnote 26]
VA:
VA has also taken some steps to inform and help wounded warriors apply
for SSA disability benefits. In 2007, the agency, working with DOD,
established the Federal Recovery Coordination Program, which is a
counterpart to DOD's Recovery Coordination Program, to provide a case
management framework for ensuring that the most severely wounded
warriors are engaged by SSA's benefit programs, as well as by other
support services.[Footnote 27] Additionally, VA case managers for the
Federal Recovery Coordination Program have received information from
SSA specialists regarding SSA disability benefits. Meanwhile, staff
from other VA programs in existence prior to 2007, such as the Office
of Seamless Transition, told us they sometimes include the topic of SSA
benefits when case managers interview veterans about their clinical and
nonclinical needs.[Footnote 28] VA has also included SSA disability
information in other resources that are available to wounded warriors,
such as VA's Federal Benefits for Veterans and Dependents and VA's Web
site. This Web site also has links to SSA's Web site. In addition, the
agency's Veterans Benefits Administration (VBA), which administers VA
disability compensation benefits, includes on its application forms
some limited information about SSA benefits and SSA contact
information. VBA officials told us, however, that their disability
compensation claims representatives do not have any particular guidance
or training for how or whether to refer wounded warriors to SSA when
they apply for VA benefits. According to a VA official, while VA began
a phone outreach campaign in 2006 to OEF/OIF veterans to remind them
about VA's health and benefit services, this campaign has not included
information about SSA's programs and benefits.
Local Agency Outreach Efforts at Treatment Facilities:
Turning to the sites we contacted, we often found that DOD medical
treatment facilities were working with local SSA offices to better
inform wounded warriors about SSA disability benefits and help them
apply. This level of interaction was less common at VA sites. At all of
the DOD military treatment facilities we visited, including the four
major facilities that treat the most severely wounded warriors,
[Footnote 29] SSA representatives were coming onto the base to conduct
briefings and field questions about SSA disability benefits from
wounded warriors and staff. At many of these locations, SSA
representatives had also taken benefit applications. For example, at
Walter Reed Army Medical Center, SSA representatives were holding
office hours twice a week to take applications, and provide regular
briefings to wounded warriors and case managers. At Brooke Army Medical
Center, SSA claims representatives were conducting presentations at
weekly briefings for recovering servicemembers and also taking benefit
applications. Moreover, according to our survey of wounded warriors who
had applied for SSA disability benefits they faced few obstacles to
finding SSA representatives, if and when they did seek help.[Footnote
30] Based on the survey, we estimate that almost three quarters--73
percent--of wounded warrior applicants found it was easy to make
initial contact with an SSA representative. Most of the local SSA staff
we spoke with told us that in recent years they have reached out to
local DOD personnel to obtain access to DOD's facilities where
potentially eligible wounded warriors can be found. Some of the local
SSA offices we spoke with noted that it had taken some time to
establish working relationships at some of the DOD bases they
contacted. For example, they said certain DOD personnel at the Brooke
Army Medical Center had not been routinely cooperative until the base
commander issued an order. In addition, several local SSA officials
told us that staff turnover at DOD facilities creates a challenge. For
example, officials from the Colorado Springs SSA office told us that
because of frequent staff turnover at Evans U.S. Army Hospital (Fort
Carson), new DOD staff are often unaware of SSA benefits and as a
result do not refer servicemembers to SSA who might be eligible for SSA
disability benefits.
In the course of our site visits, we also learned that in serving DOD
facilities and the wounded warrior population, most of the SSA offices
we conducted interviews at had representatives who had developed some
expertise in working with military personnel. Some local SSA officials
told us these representatives know what questions to ask and what
documents to collect to support wounded warriors' claims. Wounded
warriors also reported that they found SSA officials helpful. Based on
our survey, we estimate that about 63 percent found the information
they received from SSA representatives to be helpful. In one location
where SSA did not employ specialized claims representatives, DOD case
managers had become more familiar with SSA disability benefits and had
developed a customized walk-through presentation to help wounded
warriors better navigate SSA's application process. See figure 9 for an
excerpt from this presentation.
Figure 9: Excerpts from the Customized Walk-Through Presentation:
[Refer to PDF for image: illustration]
Excerpts:
Click No, if you didn‘t or have not returned to full duty or have not
been employed as a civilian.
Click Yes! (you received military pay).
This doesn‘t refer to TSGLI. Estimate all military pay that you have
received from the date of your injury up to the date that you returned
to full duty or were employed. If you haven‘t returned to full duty
(Working in your MOS) estimate all military pay that you have received
from the date of injury up to the present day.
Click Other for regular military pay.
Military or Civilian pay (this doesn‘t refer to TSGLI; TSGLI is not
your employer).
Click Other for regular military pay.
Military Information for Luke Skywalker:
A period is referring to active duty enlistment dates or dates when you
were on orders.
Example: Input your 1st enlistment dates (when you joined the Marine
Corps and your EAS).
Source: Marine Wounded Warrior Battalion, Marine Corps Base Camp
Pendleton.
[End of figure]
On the other hand, at the medical centers operated by VA through its
Veterans Health Administration, we found less contact underway between
local SSA and VA staff. According to VA officials at the medical
centers we contacted, none of them had an SSA representative onsite to
answer questions or take applications, though some of the VA officials
we spoke with thought it would be a good idea. Case managers at three
of the five sites we contacted said they refer veterans to a specific
point of contact at a local SSA office who may specialize in wounded
warrior claims. Officials at the other two sites did not always have a
point of contact at all of the local SSA offices in the area. Case
managers at one of these sites said that when they refer veterans to
SSA without a specific point of contact, the veterans have challenges
navigating SSA's automated phone system or reaching a live
representative. In addition, case managers at two sites told us that
they had received some training from SSA on SSA's disability benefits.
However, case managers at the other sites told us they had not received
training from SSA on SSA disability benefits and believed having such
training would be beneficial. Table 1 summarizes the outreach
activities at DOD and VA medical facilities we contacted.
Table 1: Summary of Outreach Activities at DOD and VA Medical
Facilities:
Military treatment facilities:
Location: Carl R. Darnall Army Medical Center;
SSA holds regular office hours to take applications or answer
questions: [Empty];
SSA takes applications on site: [Check];
SSA gives briefings to wounded warriors on site: [Check];
Case managers refer wounded warriors to specific point of contact at
SSA local office: [Check];
Case managers only refer wounded warriors to SSA without a specific
point of contact: [Empty];
SSA conducts training for staff: [Check].
Location: Evans US Army Hospital;
SSA holds regular office hours to take applications or answer
questions: [Check];
SSA takes applications on site: [Check];
SSA gives briefings to wounded warriors on site: [Check];
Case managers refer wounded warriors to specific point of contact at
SSA local office: [Check];
Case managers only refer wounded warriors to SSA without a specific
point of contact: [Empty];
SSA conducts training for staff: [Check].
Location: Camp Pendleton Naval Hospital;
SSA holds regular office hours to take applications or answer
questions:[Empty];
SSA takes applications on site: [Empty];
SSA gives briefings to wounded warriors on site: [Check];
Case managers refer wounded warriors to specific point of contact at
SSA local office: [Empty];
Case managers only refer wounded warriors to SSA without a specific
point of contact: [Check];
SSA conducts training for staff: [Check].
Location: National Naval Medical Center (Bethesda);
SSA holds regular office hours to take applications or answer
questions: [Empty];
SSA takes applications on site: [Check];
SSA gives briefings to wounded warriors on site: [Empty];
Case managers refer wounded warriors to specific point of contact at
SSA local office: [Check];
Case managers only refer wounded warriors to SSA without a specific
point of contact: [Empty];
SSA conducts training for staff: [Check].
Location: National Naval Medical Center San Diego (Balboa);
SSA holds regular office hours to take applications or answer
questions: [Empty];
SSA takes applications on site: [Empty];
SSA gives briefings to wounded warriors on site: [Check];
Case managers refer wounded warriors to specific point of contact at
SSA local office: [Check];
Case managers only refer wounded warriors to SSA without a specific
point of contact: [Empty];
SSA conducts training for staff: [Check].
Location: Brooke Army Medical Center;
SSA holds regular office hours to take applications or answer
questions: [Check];
SSA takes applications on site: [Check];
SSA gives briefings to wounded warriors on site: [Check];
Case managers refer wounded warriors to specific point of contact at
SSA local office: [Check];
Case managers only refer wounded warriors to SSA without a specific
point of contact: [Empty];
SSA conducts training for staff: [Check].
Location: Walter Reed Army Medical Center;
SSA holds regular office hours to take applications or answer
questions: [Check];
SSA takes applications on site: [Check];
SSA gives briefings to wounded warriors on site: [Check];
Case managers refer wounded warriors to specific point of contact at
SSA local office: [Check];
Case managers only refer wounded warriors to SSA without a specific
point of contact: [Empty];
SSA conducts training for staff: [Check].
VA medical centers:
Location: Audie L. Murphy VA Hospital;
SSA holds regular office hours to take applications or answer
questions: [Empty];
SSA takes applications on site: [Empty];
SSA gives briefings to wounded warriors on site: [Empty];
Case managers refer wounded warriors to specific point of contact at
SSA local office: [Check];
Case managers only refer wounded warriors to SSA without a specific
point of contact: [Empty];
SSA conducts training for staff: [Empty].
Location: Fayetteville VA Medical Center;
SSA holds regular office hours to take applications or answer
questions: [Empty];
SSA takes applications on site: [Empty];
SSA gives briefings to wounded warriors on site: [Empty];
Case managers refer wounded warriors to specific point of contact at
SSA local office: [Empty];
Case managers only refer wounded warriors to SSA without a specific
point of contact: [Check];
SSA conducts training for staff: [Empty].
Location: Hunter Holmes McGuire VA Medical Center;
SSA holds regular office hours to take applications or answer
questions: [Empty];
SSA takes applications on site: [Empty];
SSA gives briefings to wounded warriors on site: [Empty];
Case managers refer wounded warriors to specific point of contact at
SSA local office: [Check];
Case managers only refer wounded warriors to SSA without a specific
point of contact: [Empty];
SSA conducts training for staff: [Empty].
Location: Olin E. Teague Veterans' Center;
SSA holds regular office hours to take applications or answer
questions: [Empty];
SSA takes applications on site: [Empty];
SSA gives briefings to wounded warriors on site: [Empty];
Case managers refer wounded warriors to specific point of contact at
SSA local office: [Empty];
Case managers only refer wounded warriors to SSA without a specific
point of contact: [Check];
SSA conducts training for staff: [Empty].
Location: VA Palo Alto Health Care System;
SSA holds regular office hours to take applications or answer
questions: [Empty];
SSA takes applications on site: [Empty];
SSA gives briefings to wounded warriors on site: [Empty];
Case managers refer wounded warriors to specific point of contact at
SSA local office: [Check];
Case managers only refer wounded warriors to SSA without a specific
point of contact: [Empty];
SSA conducts training for staff: [Check].
Source: GAO analysis.
[End of table]
As for the regional VBA offices, officials at the offices we contacted
said their claims staff sometimes refer wounded warriors to SSA when
they apply for VA benefits. For example, officials at one regional
office we contacted said veterans applying for certain types of
benefits are also referred to SSA.[Footnote 31] However, according to
officials at two of the sites we contacted, they generally do not
provide any SSA literature or work with SSA personnel in local outreach
efforts such as VA's Stand Down event and its Welcome Home event.
[Footnote 32] When wounded warriors ask about SSA at these outreach
events, regional office officials said they will generally respond by
providing SSA's phone number.
A Number of Challenges Affect Agencies' Outreach Efforts to Wounded
Warriors, Especially for Those with TBI and PTSD:
Agency efforts to help wounded warriors learn about and apply for SSA
disability benefits early in the recovery process can be affected by
challenges, including some servicemembers not being ready to apply and
misinformation that may be passed among wounded warriors. According to
local officials from all three agencies we spoke with, wounded warriors
may not be ready or able to learn about SSA disability benefits early
in their recovery. Some may not have yet accepted the severity of their
injuries, while others have physical or psychological conditions that
have not stabilized. Case managers told us the timing of when they
inform wounded warriors about SSA disability benefits is therefore
determined on a case-by-case basis. Based on our survey, we estimate
that the timing of when wounded warriors first learned about SSA
disability benefits varied widely, with 44 percent reporting they first
heard about the benefit 12 months or longer after injury (see figure
10).
Figure 10: Estimated Length of Time for Wounded Warriors to First Learn
about SSA Disability Benefits After Onset of Medical Condition:
[Refer to PDF for image: vertical bar graph]
Less than 3 months: 15%;
95 percent confidence interval: 10-21%.
From 3 to less than 6 months: 9%;
95 percent confidence interval: 6-15%.
From 6 to less than 9 months: 15%;
95 percent confidence interval: 11-21%.
From 9 to less than 12 months: 7%;
95 percent confidence interval: 4-11%.
12 months or more: 44%;
95 percent confidence interval: 36-51%.
Do not remember: 9%;
95 percent confidence interval: 6-14%.
Source: GAO survey of wounded warriors who applied for SSA benefits
during fiscal year 2008.
[End of figure]
It was also suggested by case managers and some recovering
servicemembers that wounded warriors may be hesitant to apply for SSA
benefits because of misinformation about SSA disability benefits given
by their colleagues. Wounded warriors were just as likely to first hear
about SSA disability benefits from their peers as from their DOD or VA
case managers, according to our survey estimates (see figure 11).
Moreover, both wounded warriors and agency officials told us that the
information about SSA benefits that gets passed among military
personnel is not always accurate. For example, some recovering
servicemembers said their peers had told them they would not qualify
for SSA disability benefits and others said they had heard that in
order to avoid paying retroactive benefits, SSA initially denies
benefits to servicemembers who have been hospitalized for long periods
of time.
Figure 11: How Wounded Warriors' First Learned of SSA Disability
Benefits (Estimated):
[Refer to PDF for image: vertical bar graph]
Another servicemember: 2%;
95 percent confidence interval: 21-34%.
DOD personnel: 25%;
95 percent confidence interval: 19-32%.
VA personnel: 20%;
95 percent confidence interval: 14-26%.
Family: 11%;
95 percent confidence interval: 7-17%.
SSA representative: 8%;
95 percent confidence interval: 4-12%.
Other: 8%;
95 percent confidence interval: 4-12%.
Internet: 2%;
95 percent confidence interval: 0.5-5%.
Source: GAO survey of wounded warriors who applied for SSA benefits
during fiscal year 2008.
[End of figure]
Another challenge with regard to wounded warriors applying for SSA
disability benefits is reported to be the benefit application itself,
which reflects civilian more than military careers. At some of the
sites we contacted, case managers and wounded warriors themselves said
it was difficult for wounded warriors to complete the employment
section of the application because it does not take into account, for
example, the difference between a civilian 8-hour day and military
duty, which requires a 24-hour obligation. Of all the aspects of the
application process we asked about in our survey, wounded warriors most
often reported understanding the SSA application to be difficult (see
figure 12).
Figure 12: Difficulties Wounded Warriors Had with Completing the SSA
Disability Benefits Application:
[Refer to PDF for image: vertical bar graph]
Difficulty in understanding SSA application: 49%;
95 percent confidence interval: 42-56%.
Difficulty in understanding SSA letters: 40%;
95 percent confidence interval: 33-47%.
Difficulty in understanding how SSA could impact other benefits: 32%;
95 percent confidence interval: 25-39%.
Difficulty in maintaining contact with SSA: 30%;
95 percent confidence interval: 24-37%.
Difficulty in obtaining medical records: 28%;
95 percent confidence interval: 22-35%.
Difficulty in making initial contact with SSA: 22%;
95 percent confidence interval: 17-29%.
Difficulty in receiving mail at DOD or VA hospital: 15%;
95 percent confidence interval: 11-21%.
Source: GAO survey of wounded warriors who applied for SSA benefits
during fiscal year 2008.
[End of figure]
Agency officials told us that in addition to the above challenges, TBI
and PTSD--signature disabilities of the recent conflicts--can further
challenge their outreach efforts and may contribute to some wounded
warriors applying a number of months after disability onset. According
to one DOD official, these conditions tend to impede wounded warriors'
ability to absorb and retain information. Some agency officials and
wounded warriors also told us that individuals with TBI or PTSD can
have trouble going to SSA offices as they have become anxious around
crowds. Also, some wounded warriors we interviewed found SSA's benefits
application to be lengthy and complex and became frustrated trying to
complete it. In addition, agency officials and wounded warriors said
this population may also forget to complete the application, due to a
short attention span.
Finally, outreach efforts face an elusive target at times, given that
TBI and PTSD are conditions that are not necessarily diagnosed early
and that can develop months or years later. According to some agency
officials, servicemembers who have yet to be diagnosed with TBI and
PTSD are not likely to receive information on all of the services,
programs, or benefits to which they could be entitled. Several agency
officials reported they have challenges in diagnosing TBI and PTSD,
because these conditions are often not as clearly apparent as some
other physical disabilities. Wounded warriors also may not realize they
have these conditions and as such, may not have sought out medical
attention. A RAND study reported that 57 percent of wounded warriors
who probably have undiagnosed TBI had not been evaluated by a physician
for brain injury.[Footnote 33]
SSA Is Expediting Wounded Warrior Claims With Assistance From DOD and
VA, but The Transfer Of DOD Medical Records Can Prolong Decision-
Making:
SSA has expedited the processing of wounded warrior benefit claims,
with assistance from VA and DOD; however, weaknesses in the transfer of
DOD medical records to SSA can prolong decision-making for some cases.
SSA has established a nationwide policy requiring its district offices,
the state DDS offices, hearing offices, and the Appeals Council to give
priority to wounded warrior claims. For its part, DOD has worked with
SSA by sharing wounded warriors' key identification information that
SSA can use to target their claims for expedited processing. VA has
also worked with SSA to accelerate information sharing to DDS offices.
However, wounded warrior claim decisions can still be prolonged in some
instances because of challenges in receiving DOD medical records. DOD
medical records are transferred to SSA as paper documents, a process
which can take weeks or months, according to DDS officials. Although
DOD stores some medical records electronically, DOD and SSA have not
developed the capacity for DOD to transfer its records electronically
to SSA.
With Assistance from DOD and VA, SSA Has Taken Steps to Expedite
Wounded Warrior Claims:
Since 2005, SSA has identified wounded warrior applicants for the
purpose of expediting their claims. SSA attempts to identify any
servicemember wounded, injured, or taken ill during military service
since October 1, 2001, regardless of whether the disabling event
occurred domestically or overseas. In order to give priority to these
cases, SSA identifies wounded warriors in two ways. First, starting in
2005, applicants can self identify as a wounded warrior when submitting
the disability application. SSA added questions on its disability
claims application to enable servicemembers or veterans to identify
themselves as having served in the military and to indicate their dates
of service. Secondly, in a 2008 memorandum of understanding, DOD agreed
to send weekly electronic updates to SSA with the key identification
information of servicemembers who were wounded, injured or became ill
in the OEF/OIF theaters, to further assure that military applicants are
identified. Any applicant is automatically identified as a wounded
warrior if their name appears on the DOD list.
The agency requires that its district offices, DDS offices, and hearing
offices give priority to wounded warrior claims. SSA uses a process
originally developed to expedite terminally ill (critical) case
adjudication for all wounded warrior disability claims. For such cases,
SSA staff who receive a disability claim request via SSA's toll free
phone number are required to schedule an applicant interview at an SSA
field office within 3 working days, if possible, to take the full
application.[Footnote 34] Then the SSA field office refers the
application to a state DDS office for review, and follows up within 7
days to ensure receipt by the DDS system. DDS staff, in turn, are
required to prioritize wounded warrior cases, by considering them as
early as possible. Moreover, DDS staff are instructed to
comprehensively consider these cases by exploring all potential
physical and mental impairments, including those that may be suggested
by any of the medical evidence, such as signs of PTSD. Lastly, as with
critical cases, SSA staff at the hearing stage are required to schedule
wounded warrior cases in the first available open hearing slots.
Additionally, SSA and DDS offices track and monitor wounded warrior
cases to ensure that they receive expedited handling. SSA's regional
offices track these claims through the different stages of the
disability determination process, including appeals. One SSA regional
office, for example, generates reports listing all wounded warrior
cases, including the level of adjudication for each claim and its
status. Also, officials in some DDS offices told us that they generate
reports on processing times specifically for wounded warrior cases,
such as reports that list the pending wounded warrior cases, which may
include other details of the claim. Officials in one DDS office stated
that they monitor all wounded warrior cases at specific intervals after
they have been received from SSA--30 days, 45 days, and 90 days--to
ensure cases are not unnecessarily delayed.
To support agency processing of wounded warrior cases, SSA officials
reported that they have created specific training and briefing
materials for SSA and DDS staff, including information about TBI and
PTSD. According to an SSA official, the agency provided on-site
training at local offices and through videoconferences, and instructed
staff to be alert to reported symptoms that may be related to TBI and
PTSD. The SSA official told us that within DDS offices, all disability
examiners received some training on TBI and PTSD. In addition to
training, SSA reported that it provides training materials and guidance
for staff to use when handling wounded warrior cases. For example, SSA
issued guidance in August 2007 that cites indicators of possible TBI
conditions, such as exposure to an improvised explosive device blast, a
motor vehicle accident, or a fall. This policy also specifies clinical
markers, such as the loss of consciousness for more than 6 hours
following traumatic brain injury. At several DDS offices, DDS staff
reported that they received training material from SSA on TBI and PTSD.
Finally, SSA issued guidance and reminders to staff on the proper
treatment of wages for active duty soldiers.
In spite of their wounded warrior training, all of the nine DDS offices
we contacted reported difficulties, for several reasons, in making
determinations on TBI and PTSD cases. First, though officials at almost
all the DDS offices we spoke with reported that DOD and VA records
generally provide enough information regarding physical disabilities,
this is not necessarily the case regarding psychological problems. The
DDS officials told us that, consequently, they generally need to order
more consultative exams[Footnote 35] to assess potential cases of TBI
or PTSD. Secondly, some DDS officials also reported that servicemembers
sometimes ask them not to include a diagnosis of TBI or PTSD in their
records. According to officials in two of these DDS offices,
servicemembers have either been reluctant to discuss symptoms of PTSD
with DDS staff, or asked DDS staff not to pursue a mental health
disability claim. Finally, because PTSD and in some cases, TBI, may
take several months to manifest, and because these conditions may
improve over time, officials in some DDS offices said it can be
difficult to determine whether they meet the 12-month duration
requirement.[Footnote 36] To address this challenge, SSA has a specific
TBI policy: If a TBI disability determination is not possible within 3
months of injury, SSA and DDS staff are required to defer adjudication
until at least 3 months after injury, and may defer again until at
least 6 months after injury, in order to observe and evaluate the
claimant's condition.
Given these challenges, eight of the nine DDS offices we visited had
assigned specific, experienced examiners to process wounded warrior
claims. An SSA official stated that those DDS examiners who focus on
wounded warrior cases--ranging between three and five specialists at
each of several DDS offices we visited--received more extensive
training. These officials reported employing special techniques for
working with wounded warriors. For example, some officials told us they
can draw conclusions from pieces of evidence in DOD and VA medical
records that indicate possible PTSD or TBI, and then collect additional
information to make a determination regarding the presence of those
conditions, even if such conditions have not been officially diagnosed.
Also, an official in one DDS office reported that she looks at the VA
disability evaluation decision, when available, for useful information
about an applicant's medical condition; though officials in that office
and several others said VA's actual disability decisions do not affect
their own determinations. Further, other officials told us they work
aggressively to obtain medical records from the VA, DOD, or private
medical facilities. Officials in one DDS office said they conduct a
special review of any wounded warrior claim that is going to be denied
to ensure that all the evidence was considered appropriately. Lastly,
because wounded warrior claimants may take more time to respond to
information requests, one DDS official typically gives them more time,
and will do more to track down their needed information and records.
To further expedite claims processing for wounded warriors, SSA has
worked with VA to improve the quality of and speed with which VA
forwards veterans' medical records to the DDS offices. According to an
SSA official, due to DDS concerns about the timeliness and condition of
VA medical records, SSA and VA began to work together in 1999 to
improve data sharing. A period of pilot testing resulted in the
creation of the Standard Summary, which is an electronic extraction of
a standardized set of pertinent medical records from a patient's
overall records that is transmitted electronically to DDS offices upon
request. In 2006, VA issued a directive to formalize use of the
Standard Summary by VA medical facilities. Generally, the Standard
Summary includes 2 years of patient health information and 4 years of
major exams and patient discharge summaries. Specifically, the Standard
Summary includes information such as the onset dates of all known
health problems for a patient, the future clinic appointments scheduled
for a patient with VA providers, and all outpatient medical visits.
(See appendix IV for a list of elements included in the Standard
Summary.) In order to establish usage of the Standard Summary, the
appropriate local VA staff are encouraged to work with local DDS staff
to enter an agreement and ensure that their computer systems are
compatible. Individual DDS offices may also work with VA hospitals to
tailor the data extracted by the Standard Summary for their needs. An
SSA official told us that, as of June 2009, roughly 75 percent of VA
hospitals nationwide were using the Standard Summary to send
information to DDS offices.
According to many DDS officials we interviewed, use of the Standard
Summary has accelerated VA's responses to DDS requests and made it
somewhat easier to review VA records. Although not all sites nationally
are using the Standard Summary, most of the DDS offices we visited
reportedly were using it. DDS officials in several offices reported
that generally, the Standard Summary contains relevant or useful
information. Also, officials in several DDS offices told us that their
receipt of VA's electronic transfer of medical records via the Standard
Summary averages 1 to 2 weeks after the request is made, a
significantly shorter period than before it was used.
Over time, even with an increasing number of wounded warrior
applications, SSA has handled these applications more quickly than
those from the general public. Since fiscal year 2004, the median time
from application to initial decision for wounded warriors' DI claims
has been consistently faster than for other DI claims.[Footnote 37]
(See figure 13.) For example, in fiscal year 2008, the processing time
was 84 days for wounded warriors, compared to 101 days for all DI
applicants. Since it was implemented in 2005, SSA's expedited
procedures may have helped to make the processing faster over time for
wounded warriors.
Figure 13: Median Days from Application to Initial Decision for Wounded
Warriors' DI Claims Versus All DI Claims:
[Refer to PDF for image: vertical bar graph]
Fiscal year: 2003;
Median days, Wounded warrior DI claims: 88;
Median days, all DI claims: 88.
Fiscal year: 2004;
Median days, Wounded warrior DI claims: 75;
Median days, all DI claims: 92.
Fiscal year: 2005;
Median days, Wounded warrior DI claims: 92;
Median days, all DI claims: 102.
Fiscal year: 2006;
Median days, Wounded warrior DI claims: 94;
Median days, all DI claims: 107.
Fiscal year: 2007;
Median days, Wounded warrior DI claims: 80;
Median days, all DI claims: 104.
Fiscal year: 2008;
Median days, Wounded warrior DI claims: 84;
Median days, all DI claims: 101.
Source: GAO analysis of SSA data.
Note: These cases represent claims decided by SSA during each fiscal
year. The number of wounded warrior cases decided per year has risen
steadily from fiscal year 2003 (72 cases) to fiscal year 2008 (8,593
cases).
[End of figure]
Delays in Obtaining DOD Records Can Slow SSA's Eligibility
Determinations:
Wounded warrior claim decisions are prolonged in some instances because
of difficulties in obtaining DOD medical records, most DDS officials
reported. Generally, DOD military treatment facilities (MTF) provide
paper-based records to DDS offices. Many of the DDS offices we visited
reported lengthy wait times--ranging from a few weeks to a few months--
to receive paper records from MTFs. Corroborating this point, DOD case
managers at several MTFs also reported delays in obtaining wounded
warrior medical records. Several DDS officials we spoke with said such
delays can slow down the disability determination process. DDS staff in
some locations reported that local MTFs had made efforts to reduce
these delays. For example, an official in the Texas DDS office noted
that the Carl R. Darnall Army Medical Center and Brooke Army Medical
Center (the local MTFs) agreed to allow a DDS staffer onsite full time
in the records office to respond to DDS medical record requests. At
several other DDS offices, staff reported that local MTFs responded to
their requests for faster records response by designating a point of
contact to handle all DDS requests, which has improved response time.
Decision making can also be affected by the cumbersome nature of DOD
records. Many DDS staff said DOD records are lengthy, and can number
hundreds, if not thousands, of pages. They also noted that some medical
documents that are referenced in the records are missing when received
by DDS offices, or can sometimes be redundant.
DOD has, in recent years, begun to computerize military medical records
and make them transferable to VA, in part due to a recent statutory
requirement. According to DOD officials, DOD currently stores certain
types of information--such as patient consultations and evaluation
notes--in electronic medical records at 21 MTFs, representing more than
half of DOD's inpatients. The agency is working toward storing more
records electronically. Furthermore, after a 10 year joint effort, DOD
is transferring some medical records electronically to VA. For example,
since January 2009, DOD and VA have been electronically exchanging drug
allergy information on more than 27,000 shared patients. Ultimately,
better exchange of electronic medical records could allow
servicemembers to transition seamlessly between the two departments
with a single, comprehensive medical record. In part, DOD and VA's
electronic records exchange is spurred by recent legislation. Congress
has mandated that DOD and VA jointly develop and implement, by
September 30, 2009, electronic health record systems or capabilities
that are fully interoperable[Footnote 38] and comply with applicable
federal interoperability standards.[Footnote 39]
By comparison, DOD and SSA's electronic exchange efforts are far less
developed. An SSA official told us the agency would like to work with
DOD to develop some mechanism for obtaining medical records
electronically. For their part, DOD officials also expressed interest
in working with SSA to resolve the issue of electronic records
transfer. Nevertheless, the agencies have no formal plans to do so. SSA
and DOD have told us that one approach for sharing records
electronically could be through the Nationwide Health Information
Network (NHIN), an emerging new federal technology. [Footnote 40]
Although SSA, DOD, and VA are all participating in this technology
initiative, the NHIN is still under development in a pilot testing
phase.
Conclusions:
Wounded warriors with severe disabilities, who have made significant
sacrifices in the line of duty, may face challenges in supporting
themselves financially. Disability benefits available through SSA can
be a critical part of the financial assistance they receive. Congress
has required that DOD and VA help wounded warriors gain access to the
benefits and services they need, including SSA disability benefits, and
to consult with other relevant federal agencies in doing so. Outreach
to wounded warriors about SSA benefits has, in fact, been stepped up
since 2007, particularly by SSA and DOD in several key sites where
there has been a well-coordinated message reinforced by each agency.
These efforts may well have contributed to the substantial increase in
wounded warrior applications for SSA disability benefits since 2007.
Certainly, significant challenges remain to reaching those warriors who
are currently being discharged, as evidenced by the numbers who have
reported to us difficulties with the SSA benefit application, or the
fact that nearly one in four of those with approved claims has foregone
retroactive benefits because they did not apply soon enough after their
injury. The sooner that SSA completes its analysis of whether a
legislative fix to the retroactive benefits formula is warranted, the
sooner this information can be brought to the Congress for
consideration.
While VA has also taken steps to help wounded warriors who have become
veterans, collaboration between VA and SSA at VA medical centers has
not been consistent. Furthermore, VA does not provide its claims
processing staff with any guidance on referring veterans to SSA when
they apply for veterans' benefits. Yet the risk of not reaching wounded
warriors is greater once they are discharged and re-enter civilian
life. Absent a commensurate level of outreach on the part of VA and
SSA, it seems likely that some veterans who are, in fact, severely
disabled, will not receive all the financial support to which they are
entitled. Of particular concern are veterans discharged prior to 2007-
-when the focus on outreach increased--and those with impairments such
as PTSD and TBI, which may emerge after discharge from the military.
While not all veterans rated as 100 percent disabled by DOD or VA will
necessarily be eligible for SSA benefits, the fact that more than one-
third of these severely disabled veterans have not even applied for SSA
disability benefits suggests there is more to be done in this area.
Finally, SSA policies for accelerating the processing of wounded
warrior applications appear to have had a positive effect. Yet some
wounded warriors will still experience a long wait for an eligibility
determination if their DOD medical records are slow to be transferred.
The inability of DOD and SSA to share records electronically undermines
SSA's ability to fully expedite the process. Yet SSA and DOD lack a
strategy for integrating their systems to enable such transfers.
Fortunately, electronic records exchange is an issue that has attention
across a number of federal agencies, and current technology initiatives
may present models for DOD and SSA to consider using.
Recommendations for Executive Action:
To improve wounded warriors' access to SSA disability benefits, we are
making the following recommendations:
1. The Commissioner of Social Security should move ahead with his
consideration of the need for a legislative proposal to amend the DI
program's retroactive benefit period for wounded warriors, given the
unique challenges faced by this population in applying for benefits in
a timely manner.
2. The Secretary of Veterans Affairs and the Commissioner of Social
Security should work together to improve outreach to veterans on SSA
disability benefits. In doing so, the VA and SSA should, in particular,
seek to reach veterans who either were discharged between 2001 and
2007; have disabilities that manifest after service such as PTSD; or
were assigned a 100 percent disability rating. Specific actions that VA
could take include issuing guidance to VA medical centers and regional
offices for referring veterans to SSA and including information about
SSA disability benefits in VA's phone outreach campaign to OEF/OIF
veterans. In addition, SSA could work with VA to ensure stronger
coordination between local SSA offices and VA medical facilities, for
example by making sure that VA medical centers have a point of contact
at a local SSA office or receive training from SSA staff on SSA
benefits.
3. The Secretary of Defense and the Commissioner of Social Security
should work together to better meet SSA's need for obtaining military
medical records in a timely manner for processing DI and SSI
applications from wounded warriors. This effort should consider how to
ensure records that are stored electronically are also electronically
transferable.
Agency Comments:
We provided a draft of this report to the Secretary of Defense, the
Secretary of Veterans Affairs, and the Commissioner of Social Security
for review and comment. In their comments, SSA and VA agreed with our
findings and recommendations and noted actions they plan to take to
address our recommendations. For example, SSA indicated that it plans
to move ahead with a legislative proposal to amend the disability
benefit retroactive period for wounded warriors, and VA indicated that
VBA officials plan to meet with SSA officials to discuss how the two
agencies can ensure that veterans receive information about SSA
disability benefits. DOD provided no formal comments. All three
agencies also provided technical comments, which were incorporated as
appropriate. SSA's and VA's comments are reproduced in appendices V and
VI.
As agreed with your office, unless you publicly announce the content of
this report early, we plan not to further distribute until 30 days from
the report date. We are sending copies of this report to the Secretary
of Defense, the Secretary of Veterans Affairs, the Commissioner of
Social Security, relevant congressional committees, and others who are
interested. We will also provide copies to others on request. The
report is also available at no charge on GAO's Web site at [hyperlink,
http://www.gao.gov/].
Please contact me at (202) 512-7215 or bertonid@gao.gov if you or your
staff have any questions about this report. Contact points for the
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. Key contributors are listed in appendix
VII.
Sincerely,
Signed by:
Daniel Bertoni:
Director, Education, Workforce, and Income Security Issues:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
We were asked to examine (1) the number of wounded warriors who have
applied and been approved for Social Security Administration (SSA)
disability benefits, and the extent to which wounded warriors who
receive Department of Defense (DOD) or Department of Veterans Affairs
(VA) disability benefits also receive SSA benefits; (2) the extent to
which SSA, DOD, and VA have worked to inform wounded warriors about and
help them apply for SSA disability benefits, and the challenges that
confront this outreach effort; and (3) whether the agencies have taken
any steps to facilitate the processing of wounded warriors' SSA
disability benefit claims. In addressing these questions, we have
focused our research on wounded warriors who have become wounded,
injured, or ill while in active duty since 2001. More specifically, to
answer the questions, we reviewed policy and other documents from SSA,
DOD, and VA and interviewed officials responsible for outreach or case
management policies at each agency. We also interviewed officials from
several organizations that represent veterans, including Disabled
American Veterans, Paralyzed Veterans of America, Vietnam Veterans of
America, and the United Spinal Association. To learn about agencies'
efforts at the local level, we interviewed staff--and sometimes
recovering servicemembers--at a number of DOD and VA medical
facilities, SSA field offices, Disability Determination Services (DDS)
offices, and VA regional offices. We obtained and analyzed
administrative data from SSA, DOD, and VA on wounded warriors'
utilization of financial benefits from all three agencies. Finally, we
conducted a mail survey of wounded warriors who had applied for SSA
disability benefits during fiscal year 2008. We conducted this
performance audit from March 2008 through September 2009 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.
Interviews with Local Staff and Recovering Servicemembers:
To learn about local efforts by SSA, DOD, and VA to conduct outreach to
wounded warriors and facilitate claims processing, we selected 12 sites
where wounded warriors receive medical care--7 DOD medical treatment
facilities (MTF) and 5 VA medical centers (see figure 14). We selected
these locations based on several factors. First, we selected the four
military treatment facilities that serve most of the severely wounded
servicemembers: Walter Reed Army Medical Center, National Naval Medical
Center (Bethesda), Naval Medical Center San Diego, and Brooke Army
Medical Center. We also selected two of the four VA polytrauma centers
that serve severely wounded servicemembers and veterans: VA Palo Alto
Health Care System and Hunter Holmes McGuire VA Medical Center. We then
selected additional sites (1) that are in regions of the country where
varying numbers of wounded warriors had SSA disability benefit claims
pending between July 2007 and March 2008, (2) that have varying numbers
of recovering servicemembers in affiliated Army warrior transition
brigades, and (3) that according to SSA have varying levels of
collaboration with local SSA offices.
Figure 2: Locations Contacted During Study:
[Refer to PDF for image: U.S. map]
1) Carl R. Darnall Army Medical Center:
2) Evans US Army Hospital, Fort Carson:
3) Camp Pendleton Naval Hospital:
4) National Naval Medical Center:
5) Naval Medical Center San Diego:
6) Brooke Army Medical Center:
7) Walter Reed Army Medical Center:
8) Audie L. Murphy VA Hospital:
9) Fayetteville VA Medical Center:
10) Hunter Holmes McGuire VA Medical Center:
11) Olin E. Teague Veterans‘ Center:
12) VA Palo Alto Health Care System.
Sources: GAO analysis; Map Resources (map).
[End of figure]
At the selected locations, we conducted on-site or telephone interviews
with a range of local staff from different agencies. We spoke with DOD
and VA case managers, hospital management staff, VA liaisons, and
medical records personnel about their practices for informing wounded
warriors about SSA benefits, helping them apply, or both. At almost
every site we also contacted the SSA district offices and DDS offices
that serve the medical facility. At the SSA and DDS offices, we spoke
with office managers and other staff, including public affairs staff,
claims examiners, and claims representatives about their practices for
informing wounded warriors about SSA benefits, helping them apply, and
processing wounded warrior claims.
At five of the MTFs we also held discussion groups with recovering
servicemembers to learn about their experiences in hearing about and
applying for SSA disability benefits. We interviewed a total of 45
servicemembers and 1 veteran at these five sites. At each of these
sites, we asked MTF personnel to identify servicemembers who were
wounded, ill, or injured since October 2001 and had applied, or were in
the process of applying, for SSA benefits. See table 2 for the list of
offices we contacted.
Table 2: Local Offices Contacted:
DOD or VA medical facilities selected: Carl R. Darnall Army Medical
Center (Fort Hood, Texas;
SSA district offices serving DOD or VA medical facilities: Temple,
Texas;
DDS offices serving DOD or VA medical facilities: Austin, Texas.
DOD or VA medical facilities selected: Evans US Army Hospital (Colorado
Springs, Colorado);
SSA district offices serving DOD or VA medical facilities: Colorado
Springs, Colorado;
DDS offices serving DOD or VA medical facilities: Denver, Colorado.
DOD or VA medical facilities selected: Camp Pendleton Naval Hospital
(Camp Pendleton, California);
SSA district offices serving DOD or VA medical facilities: Oceanside,
California;
DDS offices serving DOD or VA medical facilities: San Diego, California
La Jolla, California.
DOD or VA medical facilities selected: National Naval Medical Center
(Bethesda, Maryland);
SSA district offices serving DOD or VA medical facilities: Silver
Spring, Maryland;
DDS offices serving DOD or VA medical facilities: District of Columbia;
Fairfax, Virginia.
DOD or VA medical facilities selected: Naval Medical Center San Diego
(San Diego, California);
SSA district offices serving DOD or VA medical facilities: San Diego
(Front Street), California Kearney Mesa, California;
DDS offices serving DOD or VA medical facilities: La Jolla, California.
DOD or VA medical facilities selected: Brooke Army Medical; Center (San
Antonio, Texas;
SSA district offices serving DOD or VA medical facilities: San Antonio
(East Durango), Texas;
DDS offices serving DOD or VA medical facilities: Austin, Texas.
DOD or VA medical facilities selected: Walter Reed Army Medical Center
(District of Columbia);
SSA district offices serving DOD or VA medical facilities: Shepherd
Park, Maryland;
DDS offices serving DOD or VA medical facilities: District of Columbia
Fairfax, Virginia.
DOD or VA medical facilities selected: Audie L. Murphy VA Hospital (San
Antonio, Texas);
SSA district offices serving DOD or VA medical facilities: n/a[A];
DDS offices serving DOD or VA medical facilities: Austin, Texas.
DOD or VA medical facilities selected: Fayetteville VA Medical Center
(Fayetteville, North Carolina);
SSA district offices serving DOD or VA medical facilities:
Fayetteville, North Carolina;
DDS offices serving DOD or VA medical facilities: Raleigh, North
Carolina.
DOD or VA medical facilities selected: Hunter Holmes McGuire VA Medical
Center (Richmond, Virginia);
SSA district offices serving DOD or VA medical facilities: Richmond,
Virginia;
DDS offices serving DOD or VA medical facilities: Richmond, Virginia.
DOD or VA medical facilities selected: Olin E. Teague Veterans' Center
(Temple, Texas);
SSA district offices serving DOD or VA medical facilities: Temple,
Texas;
DDS offices serving DOD or VA medical facilities: Austin, Texas.
DOD or VA medical facilities selected: VA Palo Alto Health Care System
(Palo Alto, California);
SSA district offices serving DOD or VA medical facilities: Mountain
View, California;
DDS offices serving DOD or VA medical facilities: Roseville,
California.
Source: GAO.
[A] We did not interview an SSA office that served the Audie L. Murphy
VA Hospital.
[End of table]
We also contacted three Veterans Benefits Administration (VBA) regional
offices that administer VA disability compensation benefits--Atlanta,
Georgia; Waco, Texas; and San Diego, California. We selected these
locations based primarily on their proximity to DOD and VA sites we
contacted. At these locations we spoke with VBA public liaisons or
regional office management staff about their practices for informing
discharged veterans about SSA benefits and helping them apply.
Analysis of Administrative Data:
To examine wounded warriors' utilization of SSA disability benefits, we
obtained and analyzed administrative data from several SSA databases.
We analyzed data from the electronic folder's Structured Data
Repository (SDR) on wounded warriors' claims at the initial,
reconsideration, and hearing stages of adjudication, including claimant
demographic information, date of disability onset, date of application,
primary diagnosis, and the decision on the claim. We analyzed data from
the Master Beneficiary Record (MBR) on Disability Insurance (DI) claims
that were denied for technical--nonmedical--reasons, including the
application date and the reason for denial. We analyzed data from the
Supplemental Security Record (SSR) on Supplemental Security Income
(SSI) claims that were denied for technical reasons, again including
application date and reason for denial. Finally, we used data from
SSA's 831 file to analyze the elapsed time from application date to DDS
decision date, both for wounded warriors and for SSA's overall DI and
SSI caseloads. SSA provided us with data on all applicants who have
been flagged in its systems as wounded warriors. Applicants have been
flagged as wounded warriors when they self-identify (since 2005) or
when they appear on a list of wounded warriors provided weekly by DOD
(since 2008). In addition, SSA identified wounded warriors who appear
on the DOD list--which is cumulative and includes those wounded in
Operation Enduring Freedom (OEF) and Operation Iraqi Freedom (OIF)
[Footnote 41]--but who applied prior to 2008, when SSA started using
this list to flag applicants. To assess the reliability of these SSA
data, we reviewed agency documents, interviewed agency officials, and
performed electronic testing of certain data. We found several
limitations with the data, including the lack of complete data on
claims at the Appeals Council and federal court stages of adjudication,
and unreliable application date data for claims beyond the initial
stage. However, we found the data we used to be sufficiently reliable
for our reporting objectives.
In addition, to determine the extent to which wounded warriors
receiving DOD or VA disability benefits also receive SSA disability
benefits, we obtained data from DOD and VA and asked SSA to match these
data against its databases. DOD provided us with monthly data from the
Retired Pay File for the period January 2000 to September 2008, on
individuals who were first on the Temporary Disability Retired List
(TDRL) or Permanent Disability Retired List (PDRL) in January 2000 or
later. These data included the individuals' social security numbers,
DOD disability rating, and monthly benefit amount received. We created
a customized file of DOD data by extracting the data only for those
individuals who were on the TDRL or PDRL in July 2008 and first
appeared on the TDRL or PDRL in November 2001 or later, i.e. who were
in active duty in October 2001 or later. (The Retired Pay File does not
include an indicator of whether an individual is disabled as a result
of service in the OEF/OIF campaigns.) VA provided us with data from its
VETSNET system on veterans receiving VA disability compensation
benefits as of July 2008, who were identified in VETSNET as being OEF/
OIF veterans. OEF/OIF veterans are identified by VA in two ways: (1)
through a regular match of VA data with a Defense Manpower Data Center
(DMDC) file containing the social security numbers of OEF/OIF veterans,
and (2) by VA staff when they take disability benefit applications from
veterans. The data file provided by VA included veterans' social
security number, disability ratings,[Footnote 42] and benefit amounts
received in July 2008. We then asked SSA to match the social security
numbers contained in the DOD and VA files against its MBR and SSR
databases, to determine whether these individuals had ever applied for
SSA disability benefits and if they were receiving SSA benefits in July
2008. To assess the reliability of the VA and DOD data, we interviewed
agency officials, reviewed agency documents, and performed electronic
testing of certain data. We found several limitations with the data,
including the fact that those identified as OEF/OIF veterans in VA's
data may not include all veterans who served since 2001 and are
receiving VA disability compensation benefits. However, we found the
data we used to be sufficiently reliable for our reporting objectives.
Survey of Wounded Warriors:
To learn about the experiences and opinions of wounded warriors who
have applied for SSA disability benefits, we conducted a survey of a
random sample of wounded warriors who had applied for SSA disability
benefits during fiscal year 2008. We conducted this mail survey from
December 2008 to March 2009. The survey included questions on topics
such as how wounded warriors learned about SSA disability benefits,
when they learned about SSA benefits, and what challenges, if any, they
faced in completing the SSA application.
Developing the Survey Sample:
To identify our sample of wounded warriors, we used SSA's SDR, MBR, and
SSR databases, which contain data on SSA applicants who have been
identified as wounded warriors. We drew a random sample of 350 wounded
warriors out of a total universe of 10,438 wounded warriors who SSA's
databases indicated had applied for disability benefits in fiscal year
2008. We considered respondents to be in scope for our survey if they
had applied for disability benefits in fiscal year 2008 and had not
separated from the military prior to 2001.
Confidence Intervals in Survey Response and Nonresponse Bias Analysis:
Survey results based on probability samples are subject to sampling
error. The sample is only one of a large number of samples we might
have drawn from the respective population. Because each sample could
have provided different estimates, we express our confidence in the
precision of our two particular samples' results as 95 percent
confidence intervals. These are intervals that would contain the actual
population values for 95 percent of the samples we could have drawn. As
a result, we are 95 percent confident that each of the confidence
intervals in this report will include the true values in the respective
study populations. Unless otherwise noted, the margin of error for
percentage estimates from this survey is plus or minus 8 percentage
points or less at the 95 percent level of confidence.
The overall response rate for our survey was 53 percent.[Footnote 43]
To assess the potential for bias in our estimates, we used SSA
administrative data to examine differences between the respondents and
nonrespondents to our survey. Our analysis showed that respondents to
our survey were typically older and more educated than individuals in
our sample who did not respond to the survey; these differences were
significant at the 95 percent confidence level. In light of these
results, we conducted three separate sets of tests to compare
individuals in different age and education categories. The first set of
tests examined demographic and usage variables from the survey--that
is, whether or not wounded warrior had received information or
application assistance, or had taken certain steps in the course of
completing the SSA disability application. The second set of tests
examined wounded warriors' opinions about sources of information or
assistance and steps taken in the course of applying for benefits. The
third set of tests examined item nonresponse for each item in the
survey. Only two of the initial differences we observed persisted after
adjusting for multiple comparisons.[Footnote 44] First, we found that
older respondents were more likely to have served in the Reserves or
National Guard than their younger counterparts. However, we did not
find any significant differences in demographics, usage of specific
resources, opinions, or item nonresponse between respondents that
served in the Reserves or National Guard and those that did not.
Second, we found that college-educated individuals were more likely
than those without a college degree to have found information from VA
personnel helpful--of individuals with an opinion, 100 percent of
college educated individuals found VA personnel to be very or somewhat
helpful, compared to 76 percent of those without a college degree.
Our failure to detect systematic differences does not guarantee that
our results are free from potential nonresponse bias; as with any
survey, to the extent respondents differ from nonrespondents in
undetected ways, our results should be interpreted with caution.
However, with the exception of the two items noted above, we were
unable to detect large or systematic differences in the reported
experiences and opinions of individuals in different age or education
categories, and believe it is not misleading to generalize the results
to the population of wounded warrior SSA disability applicants in
fiscal year 2008.
Efforts to Minimize Nonsampling Errors:
The practical difficulties of conducting any survey may also introduce
other types of errors, commonly referred to as nonsampling errors. For
example, difficulties in how a particular question is interpreted, in
the sources of information that are available to respondents, or in how
the data were entered into a database or were analyzed can introduce
unwanted variability into the survey results. With this survey, we took
steps to minimize these nonsampling errors. For example, GAO staff with
subject matter expertise designed the questionnaires in collaboration
with GAO survey specialists. Then the draft questionnaires were
pretested with wounded warriors to ensure that the questions were
relevant and clearly stated--with the purpose of reducing nonsampling
error. When the data were analyzed, a second, independent GAO analyst
independently verified all analysis.
Efforts to Increase Response Rate for Survey of Wounded Warriors:
We took several steps to enhance our response rate. We resent the
survey to nonrespondents after about 5 weeks, and conducted follow-up
phone calls to nonrespondents encouraging them to complete the survey,
with the option to complete the survey over the phone with GAO staff,
after about 7 weeks. If in the course of our phone calling we learned a
correct address, we sent another copy of the survey to the current
address. These comprehensive nonrespondent follow-up efforts, as well
as our nonresponse bias analysis, give us confidence that our overall
survey results can be generalized to the population of wounded warriors
applying for SSA disability benefits in fiscal year 2008.
Important Outreach Practices:
We used a set of six important outreach practices as criteria for
assessing the three agencies' outreach to wounded warriors regarding
SSA disability benefits:
* outlining of strategic goals for the campaign and determination of a
desired response;
* identification and researching of the target audience to understand
some of its key characteristics, such as size of the population, ethnic
and racial composition, linguistic groups, geographic location, and
awareness or knowledge of the outreach subject;
* establishment of strategic partnerships with other entities that are
stakeholders in the issue to get help with planning and implementing
the outreach campaign;
* targeting of the outreach message with audience specific, culturally
sensitive content and use of mediums and languages that are the most
appropriate for the audience;
* reinforcement of the message with repetition and different mediums,
especially when targeting people who may be challenging to serve; and:
* development and implementation of measures for evaluating the
effectiveness of the outreach campaign.
We identified these practices through a review of prior GAO and
external reports that addressed outreach campaigns primarily for social
and employment programs. We also contacted several external
organizations that have some expertise in outreach for social programs
to obtain their feedback on the identified practices. Comments were
received from the National Association of Social Workers and the
National League of Cities, and these comments were incorporated into
our final set of practices.
[End of section]
Appendix II: Summary of Major Disability Benefit Programs Available to
Wounded Warriors:
Purpose and target population:
SSA: DI: Replace lost income for workers under age 65 who have paid
into Social Security but can no longer work because of a disability.
SSI: Provide cash payments assuring a minimum income for aged, blind,
or disabled individuals who have very limited income and assets;
VA: Disability compensation. Compensate veterans for average reduction
in earnings capacity due to their disabilities;
DOD: Disability retirement. Provide financial support to servicemembers
whose disabling conditions render them unable to perform their military
duties.
Eligibility criteria:
SSA: DI and SSI (adult disability). Applicant is unable to perform
substantial gainful activity due to condition, which is expected to
last at least a year or to result in death. DI. Must have worked a
minimum amount of time in employment covered by Social Security. SSI.
Total earned and unearned countable income must be below the federal
benefit rate. First $20 of unearned income and various types of public
assistance are not counted. Also, must have less than $2,000 in
countable resources for an individual;
VA: Applicant must be a veteran with a diagnosis of an injury or
disease that is found to be disabling. Also, there must be evidence of
an in-service occurrence or aggravation of the injury or disease;
DOD: Servicemembers must have a permanent disability that renders them
unfit to perform their military duties. Also, the injury must be
connected to service in the military.
Possible outcomes of eligibility determination:
SSA: Individuals are deemed disabled or not disabled. No percentage
ratings or partial disability determinations;
VA: Claimant is assigned a rating for each service-connected disability
based on the VA's Schedule for Rating Disabilities (VASRD). Ratings
range from 0 to 100 percent. Individual unemployability (IU) benefits
provide certain veterans with compensation at the 100-percent level if
their disabilities prevent them from working, even though their
disability was rated below 100 percent under the VASRD;
DOD: Servicemembers are assigned a rating for each unfitting condition
based on the VASRD, with ratings ranging from 0 to 100 percent.; If the
disabilities are deemed noncompensable, because they were not in the
line of duty, servicemembers are separated without benefits. If
servicemembers receive a disability rating of less than 30 percent,
they receive a lump sum payment upon separation. (If servicemembers
have 20 or more years of service and a disability rating below 30
percent, they could still be eligible for disability retirement.) If
servicemembers have a disability rating of 30 percent or greater, they
will be separated from the military and receive monthly cash benefit
payments (PDRL) unless conditions are not stable, whereas the
servicemembers are placed on TDRL.
How benefits are calculated;
SSA: DI. Based on past average monthly earnings. SSI. Basic monthly
payment is the same for all beneficiaries. This basic amount is reduced
when beneficiary receives certain types of earned and unearned income;
VA: If the veteran is found to have one or more service-connected
disabilities with a combined rating of at least 10 percent, VA will pay
monthly compensation. The benefits range by rating, with a higher
rating resulting in greater compensation. Veterans with severe
disabilities may be entitled to special monthly compensation, which
provides payments greater than the compensation payable under the VASRD
for the disability;
DOD: If the unfitting disabilities are determined to be service-
connected, DOD takes into account the years of service and the
disability rating percentage.
Disability determination process;
SSA: One of about 1,300 SSA field offices assesses a claimant's
nonmedical eligibility. If the claimant meets these criteria, a state
DDS office evaluates the claimant's medical eligibility. Claimants may
appeal an initial DDS decision back to the DDS, then to an
administrative law judge (ALJ), the SSA appeals council, and ultimately
the federal court;
VA: One of VA's 57 regional offices assesses eligibility and assists in
obtaining relevant evidence to substantiate the claim. Such evidence
includes veterans' military service records (including medical
records), medical examinations, and treatment records from VA medical
facilities and private medical service providers. Claimants may appeal
an initial VA decision to the Board of Veterans' Appeals, then,
ultimately, to different levels of federal courts;
DOD: The servicemember goes through a medical evaluation board (MEB)
proceeding, where medical evidence is evaluated, and potentially unfit
conditions are identified. The member then goes through an informal
physical evaluation board (PEB) process, where a determination of
fitness or unfitness for duty is made and, if found unfit for duty, a
combined percentage rating is assigned for all unfit conditions and the
servicemember is discharged from duty. If servicemembers disagree with
the informal PEB's findings and recommendations, they can, under
certain conditions, appeal to the formal PEB's reviewing authority The
services differ in how many opportunities they offer servicemembers to
appeal.[A]
Source: GAO analysis.
[A] DOD and VA are piloting a joint disability evaluation system to
improve the timeliness and resource use of DOD's and VA's separate
disability evaluation systems. Key features of the pilot include a
single physical examination conducted to VA standards as part of the
MEB, and disability ratings prepared by VA, for use by both DOD and VA
in determining disability benefits.
[End of table]
[End of section]
Appendix III: Complete Results of Wounded Warrior Survey:
Below are the questions on our survey of wounded warriors, followed by
the breakdown of answers we received. We received a total of 182
responses from wounded warriors. All answers are generalizable to the
overall population of wounded warriors who applied for SSA disability
benefits during fiscal year 2008, with a margin of error of plus or
minus 8 percent or less, except questions 6g and 7f. A nonresponse bias
analysis revealed that older and college educated individuals were more
likely to respond to our survey than their younger and less-educated
colleagues, but did not reveal systematic differences in wounded
warriors' overall experiences and opinions in applying for SSA
benefits. For a complete description of our survey methods and
nonresponse bias analysis, see appendix I.
Section 1: Information about your military service:
1. In what branch of the military do/did you serve?
Air Force: 7%;
Army: 73%;
Marine Corps: 11%;
Navy: 11%;
Combination of two Services: 5%.
Note: 182 wounded warriors responded to this question.
2. Are you now or were you at any point a National Guard or Reserve
member?
Yes, I am or was in the National Guard; 37%.
Yes, I am or was in the Reserves; 11%.
No; 48%.
Both National Guard and Reserves; 4%.
Note: 180 wounded warriors responded to this question.
3. As of today, have you separated from military service?
Yes, I am separated; 70%.
No, I am not separated; 30%.
Note: 181 wounded warriors responded to this question.
If so, in what year did you separate from military service?
2003; 2%.
2004; 7%.
2005; 11%.
2006; 15%.
2007; 20%.
2008; 44%.
2009; 3%.
Note: 123 wounded warriors responded to this question. Totals may not
equal 100 percent due to rounding.
Section 2: How you learned about SSA benefits:
4. After you were wounded, injured, or became ill, how did you first
learn about Social Security disability benefits? (Check only one
answer):
The Internet; 2%.
Another servicemember or separated servicemember; 27%.
Family member; 11%.
Social Security Administration representative; 8%.
DOD medical center or DOD personnel (for example, nurse case manager,
social worker, AW2 Advocate, WTU or WWR squad leader); 25%.
VA medical center or other VA personnel (for example, nurse case
manager, social worker, benefits counselor); 20%.
Other: please specify; 8%.
Note: 173 wounded warriors responded to this question. Totals may not
equal 100 percent due to rounding.
5. How long after you were wounded, injured, or became ill did you
first learn about Social Security disability benefits? (Check one
answer)
Less than 3 months; 15%.
From 3 to less than 6 months; 9%.
From 6 to less than 9 months; 15%.
From 9 to less than 12 months; 7%.
12 months or more; 44%.
Do not remember; 9%.
Note: 181 wounded warriors responded to this question. Totals may not
equal 100 percent due to rounding.
6. After you first learned about Social Security disability benefits,
how helpful, if at all, was any of the additional information you may
have received about Social Security disability benefits from any of the
following sources? (Check one answer in each row. If you did not
receive any information from a source, check the first column.)
6a. The Internet;
Very helpful: 16%;
Somewhat helpful: 24%;
Not helpful: 5%;
Did not receive information from this source: 54%;
Not sure: 1%;
Number of wounded warrior respondents: 172.
6b. Another servicemember(s) or separated servicemember(s);
Very helpful: 31%;
Somewhat helpful: 25%;
Not helpful: 8%;
Did not receive information from this source: 34%;
Not sure: 1%;
Number of wounded warrior respondents: 172.
6c. Family member(s);
Very helpful: 15%;
Somewhat helpful: 10%;
Not helpful: 7%;
Did not receive information from this source: 64%;
Not sure: 4%;
Number of wounded warrior respondents: 168.
6d. Social Security Administration representative (s);
Very helpful: 43%;
Somewhat helpful: 21%;
Not helpful: 13%;
Did not receive information from this source: 22%;
Not sure: 2%;
Number of wounded warrior respondents: 174.
6e. DOD medical center or other DOD personnel (for example, nurse case
manager, social worker, AW2 Advocate, WTU or WWR squad leader);
Very helpful: 22%;
Somewhat helpful: 17%;
Not helpful: 10%;
Did not receive information from this source: 49%;
Not sure: 1%;
Number of wounded warrior respondents: 174.
6f. VA medical center or other VA personnel (for example, nurse case
manager, social worker, benefits counselor);
Very helpful: 23%;
Somewhat helpful: 14%;
Not helpful: 9%;
Did not receive information from this source: 51%;
Not sure: 2%;
Number of wounded warrior respondents: 169.
6g. Someone else (please specify)[A];
Very helpful: n/a;
Somewhat helpful: n/a;
Not helpful: n/a;
Did not receive information from this source: n/a;
Not sure: n/a;
Number of wounded warrior respondents: 22.
[A] Too few respondents answered 6g to calculate a percentage estimate.
Note: Totals may not equal 100 percent due to rounding.
Section 3: Your experience completing the application for SSA benefits:
7. How helpful, if at all, was any of the assistance you may have
received from any of the following people in helping you complete your
Social Security disability benefits application? (Check one answer in
each row. If you did not receive any assistance from a person, check
the first column.)
7a. Another servicemember(s) or separated servicemember(s);
Very helpful: 9%;
Somewhat helpful: 7%;
Not helpful: 8%;
Did not receive assistance from this person: 76%;
Not sure: 1%;
Number of wounded warrior respondents: 171.
7b. Family member(s);
Very helpful: 22%;
Somewhat helpful: 9%;
Not helpful: 4%;
Did not receive assistance from this person: 64%;
Not sure: 1%;
Number of wounded warrior respondents: 170.
7c. Social Security Administration representative;
Very helpful: 53%;
Somewhat helpful: 17%;
Not helpful: 13%;
Did not receive assistance from this person: 17%;
Not sure: 1%;
Number of wounded warrior respondents: 172.
7d. DOD medical center or other DOD personnel (for example, nurse case
manager, social worker, AW2 Advocate, WTU or WWR squad leader);
Very helpful: 15%;
Somewhat helpful: 8%;
Not helpful: 11%;
Did not receive assistance from this person: 65%;
Not sure: 2%;
Number of wounded warrior respondents: 172.
7e. VA medical center or other VA personnel (for example, nurse case
manager, social worker, benefits counselor);
Very helpful: 14%;
Somewhat helpful: 6%;
Not helpful: 9%;
Did not receive assistance from this person: 69%;
Not sure: 2%;
Number of wounded warrior respondents: 169.
7f. Someone else (please specify)[A];
Very helpful: n/a;
Somewhat helpful: n/a;
Not helpful: n/a;
Did not receive assistance from this person: n/a;
Not sure: n/a;
Number of wounded warrior respondents: 17.
[A] Too few respondents answered 7f to calculate a percentage estimate.
Note: Totals may not equal 100 percent due to rounding.
8. How long after you were wounded, injured, or became ill did you
first apply for Social Security benefits?
Less than 3 months; 9%.
From 3 to less than 6 months; 9%.
From 6 to less than 9 months; 11%.
From 9 to less than12 months; 7%.
12 months or more; 59%.
Do not remember; 6%.
Note: 181 wounded warriors responded to this question. Totals may not
equal 100 percent due to rounding.
9. When completing the Social Security disability benefits application,
how easy or difficult were the following? (Check one answer in each
row. If you did not do this, check the first column.)
9a. Making initial contact with Social Security Administration
representative;
Very easy: 48%;
Somewhat easy: 25%;
Very difficult: 7%;
Somewhat difficult: 15%;
Did not do this: 3%;
Do not remember: 2%;
Number of wounded warrior respondents: 181.
9b. Maintaining contact with Social Security Administration
representative;
Very easy: 38%;
Somewhat easy: 24%;
Very difficult: 17%;
Somewhat difficult: 14%;
Did not do this: 6%;
Do not remember: 2%;
Number of wounded warrior respondents: 181.
9c. Understanding the Social Security disability benefits application;
Very easy: 22%;
Somewhat easy: 27%;
Very difficult: 18%;
Somewhat difficult: 31%;
Did not do this: 1%;
Do not remember: 2%;
Number of wounded warrior respondents: 181.
9d. Obtaining copies of your medical records from military or VA health
care providers;
Very easy: 41%;
Somewhat easy: 23%;
Very difficult: 11%;
Somewhat difficult: 18%;
Did not do this: 7%;
Do not remember: 2%;
Number of wounded warrior respondents: 180.
9e. Receiving your mail at a DOD or VA hospital in a timely manner;
Very easy: 19%;
Somewhat easy: 18%;
Very difficult: 8%;
Somewhat difficult: 7%;
Did not do this: 44%;
Do not remember: 4%;
Number of wounded warrior respondents: 179.
9f. Understanding information contained in letters sent from Social
Security Administration;
Very easy: 24%;
Somewhat easy: 34%;
Very difficult: 13%;
Somewhat difficult: 27%;
Did not do this: 1%;
Do not remember: 2%;
Number of wounded warrior respondents: 181.
9g. Getting information about how receiving Social Security disability
benefits could impact VA or DOD benefits;
Very easy: 13%;
Somewhat easy: 13%;
Very difficult: 13%;
Somewhat difficult: 18%;
Did not do this: 32%;
Do not remember: 9%;
Number of wounded warrior respondents: 180.
Note: Totals may not equal 100 percent due to rounding.
10. Were you aware that if an application for Social Security
disability benefits is denied, the decision can be appealed?
Yes; 84%.
No; 15%.
Not sure/do not remember; 1%.
Note: 181 wounded warriors responded to this question.
[End of section]
Appendix IV: VA Standard Summary:
We have reproduced the Standard Summary template as it appears in VA's
2006 directive, Veterans Health Administration Directive 2006-024, to
formalize use of the Standard Summary. The VA SSA-DDS Standard Summary
is an electronic extraction of a standardized set of pertinent medical
records from a patient's overall VA records.
Figure 15: VA Standard Summary:
[Refer to PDF for image: table]
Order: 1;
Component Acronym, Name and Limits: BDEM (Brief demographics);
Description: Brief patient demographic information. Includes address,
phone number, age, sex, race, ethnicity,mean test, and eligibility code
and known VA facilities that have provided care. Limits: not applicable
(NA)
Order: 2;
Component Acronym, Name and Limits: PLL (All Problems List) or PLA
(Active Problems) and PLI (Inactive Problems); Display ICD text = Yes,
Display provider narrative =Yes Limits: NA;
Description: All known problems, active (PLA) and inactive (PLI)for a
patient. Includes provider narrative, date of onset on active problems,
date problem resolved on inactive, date last modified, responsible
provider and all active comments for the problems (caution: list may be
incomplete).
Order: 3;
Component Acronym, Name and Limits: CVF (Future Clinic Visits); Limits:
NA;
Description: Displays future appointment dates and what VA component
the patient will see. Potential value in lieu of consultative
examination.
Order: 4;
Component Acronym, Name and Limits: OE (Outpatient Encounters); Display
long text narrative Limits: Time = 2 years; Occurrences = 150
(whichever comes first (WCF));
Description: Concise listing of all outpatient events including date,
outpatient diagnosis (international Classification of Diseases-9th
edition (ICD-9), and procedure (Current Procedural Terminology
(CPT))for each event. The complete VA record should have a detailed
Compensation and Pension or Progress Note (PN) for each OE. If number
of PNs exceeds occurrence limit, OE will help target possible follow-up
for older encounters.
Order: 5;
Component Acronym, Name and Limits: GAF (Global Assessment
Functioning); Limits: Time = 2 years Occurrences = no limit;
Description: Displays score taken from the GAF Scale to evaluate the
psychological, social, and occupational functioning on a hypothetical
continuum of mental health and/or illness. Also displayed is date of
assessment and name of health care professional giving the score.
Potential indicator of longitudinality and decompensation.
Order: 6;
Component Acronym, Name and Limits: DCS (Discharge Summaries); Limits:
Time = 4 years; Occurrences = five WCF;
Description: Inpatient discharge summaries, including report text for
the time period.
Order: 7;
Component Acronym, Name and Limits: CP (Compensation and Pension
Exams); Limits: Time = four years Occurrences = five WCF
Description: Compensation and pension exams for Veterans‘ benefits.
Order: 8;
Component Acronym, Name and Limits: PN (Progress Note); Limits: Time =
2 years; Occurrences = 40 WCF; Note: Occurrences can be reduced to 30,
if the PNs can be pulled selectively (see description);
Description: Includes: date and time, title, and text of note.
Notes:
--Need to assess local VA capabilities to distinguish types of PN and
exclude unneeded PN (e.g., inpatient notes (captured in DCS), nurses
notes, telephone triage, physical therapy) as possible.
--Outpatient PNs that exceed the occurrence limit are highlighted in OE
for follow-up request as needed.
Order: 9;
Component Acronym, Name and Limits: SR (Surgery Report), OR (operating
room)/NON (non operating room); Limits: Time = 2 years; Occurrences =
10 WCF;
Description: Contains reports of operative procedures and non-operative
procedures. Includes: date, specialty, pre and post operative
diagnosis, procedures performed,surgeon‘s dictation, indications for
procedure.
Order: 10;
Component Acronym, Name and Limits: SCD (Spinal Cord Dysfunction)
Limits: N/A;
Description: Includes patient registration status, highest level of
injury, information source for SCD, completeness of injury and extent
of paralysis.
Order: 11;
Component Acronym, Name and Limits: *MEDF (Medical Full Report )
Limits: Time = two years, Occurrences = 15 WCF;
*If unavailable locally, determine best alternative (e.g., Clinical
Procedures-Brief (CPB);
Description: This component provides a full report of procedures (e.g.,
Electrocardiogram (ECG), Pulmonary Function Tests (PFT), sleep studies)
as defined by the Medicine View file.
Order: 12;
Component Acronym, Name and Limits: IP (Imaging Profile); CPT modifiers
= No Limits: Time = 2 years, Occurrences = 10 WCF;
Description: Contains information from Radiology and/or Nuclear
Medicine. Includes: study date, procedure, status,report status, staff
and resident interpreting physicians and history, report, diagnostic
text and impression.
Order: 13;
Component Acronym, Name and Limits: CY (Cytopathology); Limits: Time =
2 years, Occurrences = 10 WCF;
Description: Includes: collection date and time, specimen, gross
description, microscopic exam, brief clinical history, and
cytopathology diagnosis.
Order: 14;
Component Acronym, Name and Limits: EM (Electron Microscopy); Limits:
Time = 2 years, Occurrences = 10 WCF;
Description: Includes: collection date and time, specimen, gross
description, microscopic exam, brief clinical history, supplemental
report, and EM diagnosis.
Order: 15:
Component Acronym, Name and Limits: MIC (Microbiology); Limits: Time =
2 years, Occurrences = 10 WCF;
Description: Includes: collection date and time, collection sample,
site and specimen, specimen comment, tests, urine screen, sputum
screen, sterility control, sterility results, comments for reports,
smear and/or prep, acidfast stain Parasite Report, organism(s),
Mycology Report, Bacteriology Report, Mycobacteriology Report, Gram
Stain Result, Culture and Susceptibility, Antibiotic Serum Level, and
remarks.
Order: 16;
Component Acronym, Name and Limits: SP (Surgical Pathology); Limits:
Time =2 years, Occurrences = 10 WCF;
Description: Includes: collection date and time, specimen, gross
description, microscopic description, brief clinical history,
supplemental report, frozen section, and surgical path diagnosis.
Order: 17;
Component Acronym, Name and Limits: ON (Oncology); Limits: Time = 2
years, Occurrences = NA;
Description: Selected data elements from the Oncology Primary file.
Order: 18;
Component Acronym, Name and Limits: CH (Chemistries and Hematology);
Display comments = Yes Limits: Time = 2 years; Occurrences = 20 WCF;
Description: Includes: collection date and time, specimen, test name,
results (with flag, either High, Low, or Critical), units, and
reference range.
[End of section]
Appendix V: Comments from the Social Security Administration:
Social Security:
The Commissioner:
Social Security Administration:
Baltimore, MD 21235-0001:
August 13, 2009:
Daniel Bertoni, Director:
Education, Workforce, and Income Security Issues:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, D.C. 20548:
Dear Mr. Bertoni:
Thank you for the opportunity to review and comment on the Government
Accountability Office (GAO) draft report, "Social Security Disability:
Additional Outreach and Collaboration on Sharing Medical Records Would
Improve Wounded Warriors' Access to Benefits" (GAO-09-762).
Enclosed are our comments to the draft report recommendations, along
with suggested technical revisions.
If you have any questions, please contact me or have your staff contact
Ms. Candace Skumik, Director, Audit Management and Liaison Staff at
(410) 965-4636.
Sincerely,
Signed by:
Michael J. Astrue:
Enclosure:
[End of letter]
Comments On The Government Accountability Office (GAO) Draft Report,
"Social Security Disability: Additional Outreach And Collaboration On
Sharing Medical Records Would Improve Wounded Warriors' Access To
Benefits" (GAO-09-762):
Our responses to the specific recommendations are as follows:
Recommendation 1:
The Commissioner Social Security should move ahead with his
consideration of the need for a legislative proposal to amend for
wounded warriors the Disability Insurance (DI) program's retroactive
benefit period, given the unique challenges faced by this population in
applying for benefits in a timely manner.
Comment:
We agree. We plan to move ahead with a legislative proposal to amend
the disability retroactive benefit period for wounded warriors. We
recognize disabled service members face special circumstances that may
lead to a loss of benefits due to delays in filing.
Recommendation 2:
The Secretary of Veterans Affairs (VA) and the Commissioner of Social
Security should work together to improve outreach to veterans on Social
Security Administration (SSA) disability benefits. In doing so, the VA
and SSA should, in particular, seek to reach veterans who were either
discharged between 2001 and 2007, have emerging or undiagnosed
conditions such as post-traumatic stress disorder, or were assigned a
100 percent disability rating. Specific actions that VA could take
include issuing guidance to VA medical centers and Veterans Benefits
Administration regional offices for referring veterans to SSA and
including information about SSA disability benefits in VA's phone
outreach campaign to Operation Enduring Freedom/Operation Iraqi Freedom
(OEF/OIF) veterans. In addition, SSA could work with VA to ensure
stronger coordination between local SSA offices and VA medical
facilities, for example by making sure that VA medical centers have a
point of contact at a local SSA office and/or receive training from SSA
staff on SSA benefits.
Comment:
We agree. We will continue to work closely with the VA to improve our
outreach efforts for OEF/OIF veterans.
Recommendation 3:
The Secretary of Defense (DOD) and the Commissioner of Social Security
should work together to better meet SSA's need for obtaining military
medical records in a timely manner for processing DI and Supplemental
Security Income applications from wounded warriors. This effort should
consider how to ensure that those records that are stored
electronically are also electronically transferable.
Comment:
We agree. We will work with DOD to obtain military medical records in a
timely manner.
[End of section]
[End of section]
Appendix VI: Comments from the Department of Veterans Affairs:
Department of Veterans Affairs:
Office of the Secretary:
August 17, 2009:
Mr. Daniel Bertoni Director:
Education, Workforce, and Income Security Issues:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Mr. Bertoni:
The Department of Veterans Affairs (VA) has reviewed the Government
Accountability Office's (GAO) draft report, Social Security Disability:
Additional Outreach and Collaboration on Sharing Medical Records Would
Improve Wounded Warriors' Access to Benefits (GAO-09-762) and generally
agrees with GAO's conclusions and concurs with GAO's recommendation to
the Department.
The enclosure specifically addresses GAO's recommendation and provides
additional comments to the draft report. VA appreciates the opportunity
to comment on your draft report.
Sincerely,
Signed by:
John R. Gingrich:
Chief of Staff:
Enclosures:
[End of letter]
Department Of Veterans Affairs (VA) Comments To GAO Draft Report,
Social Security Disability: Additional Outreach and Collaboration on
Sharing Medical Records Would Improve Wounded Warriors' Access to
Benefits (GAO-09-762):
GAO Recommendation: The Secretary of Veterans Affairs and the
Commissioner SSA should work together to improve outreach to veterans
on SSA disability benefits. In doing so, the VA and SSA should, in
particular, seek to reach veterans who were either discharged between
2001 and 2007, have emerging or undiagnosed conditions such as post-
traumatic stress disorder, or were assigned a 100 percent disability
rating. Specific actions that VA could take include issuing guidance to
VA medical centers and VBA regional offices for referring veterans to
SSA and including information about SSA disability benefits in VA's
phone outreach campaign to OEF/OIF veterans. In addition, SSA could
work with VA to ensure stronger coordination between local SSA offices
and VA medical facilities, for example by making sure that VA medical
centers have a point of contact at a local SSA office and/or receive
training from SSA staff on SSA benefits.
VA Comments to the draft report: Concur. We agree that VA should work
with the Social Security Administration (SSA) to improve outreach to
Veterans regarding SSA disability benefits.
To initiate this effort, VA's Veterans Benefits Administration (VBA)
Compensation and Pension Service recently contacted SSA and scheduled a
meeting for August 18, 2009. At this meeting, VBA and SSA
representatives will discuss methods their administrations can use to
ensure that Veterans receive information about SSA disability benefits.
[End of section]
Appendix VII GAO Contact and Staff Acknowledgments:
GAO Contact:
Daniel Bertoni, (202) 512-7215 or bertonid@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, Brett Fallavollita, Lorin
Obler, David Forgosh, Rebecca Makar, and Joy Myers made major
contributions to this report; Bonnie Anderson, Rebecca Beale, Elizabeth
Curda, Patricia Owens, and Kelly Shaw provided guidance; Stuart
Kaufman, Anna Maria Ortiz, Minette Richardson, Beverly Ross, Vanessa
Taylor, and Walter Vance provided methodological support; Susan
Bernstein helped draft the report; Jessica Botsford and Daniel Schwimer
provided legal advice; and Matthew Goldstein provided research
assistance.
[End of section]
Related GAO Products:
Recovering Servicemembers: DOD and VA Have Made Progress to Jointly
Develop Required Policies but Additional Challenges Remain. [hyperlink,
http://www.gao.gov/products/GAO-09-540T]. Washington, D.C.: April 29,
2009.
Army Health Care: Progress Made in Staffing and Monitoring Units that
Provide Outpatient Case Management, but Additional Steps Needed.
[hyperlink, http://www.gao.gov/products/GAO-09-357]. Washington, D.C.:
April 20, 2009.
Military Disability Retirement: Closer Monitoring Would Improve the
Temporary Retirement Process. [hyperlink,
http://www.gao.gov/products/GAO-09-289]. Washington, D.C.: April 13,
2009.
Social Security Administration: Further Actions Needed to Address
Disability Claims and Service Delivery Challenges. [hyperlink,
http://www.gao.gov/products/GAO-09-511T]. Washington, D.C.: March 24,
2009.
Information Technology: Challenges Remain for VA's Sharing of
Electronic Health Records with DOD. [hyperlink,
http://www.gao.gov/products/GAO-09-427T]. Washington, D.C.: March 12,
2009.
Electronic Health Records: DOD's and VA's Sharing of Information Could
Benefit from Improved Management. [hyperlink,
http://www.gao.gov/products/GAO-09-268]. Washington, D.C.: January 28,
2009.
Social Security Disability: Collection of Medical Evidence Could Be
Improved with Evaluations to Identify Promising Collection Practices.
[hyperlink, http://www.gao.gov/products/GAO-09-149]. Washington, D.C.:
December 17, 2008.
Military Disability System: Increased Supports for Servicemembers and
Better Pilot Planning Could Improve the Disability Evaluation Process.
[hyperlink, http://www.gao.gov/products/GAO-08-1137]. Washington, D.C.:
September 24, 2008.
Electronic Health Records: DOD and VA Have Increased Their Sharing of
Health Information, but More Work Remains. [hyperlink,
http://www.gao.gov/products/GAO-08-954]. Washington, D.C.: July 28,
2008.
Federal Disability Programs: More Strategic Coordination Could Help
Overcome Challenges to Needed Transformation. [hyperlink,
http://www.gao.gov/products/GAO-08-635]. Washington, D.C.: May 20,
2008.
DOD and VA: Preliminary Observations on Efforts to Improve Care
Management and Disability Evaluations for Servicemembers. [hyperlink,
http://www.gao.gov/products/GAO-08-514T]. Washington, D.C.: February
27, 2008.
VA Health Care: Mild Traumatic Brain Injury Screening and Evaluation
Implemented for OEF/OIF Veterans, but Challenges Remain. [hyperlink,
http://www.gao.gov/products/GAO-08-276]. Washington, D.C.: February 8,
2008.
Results-Oriented Government: Practices That Can Help Enhance and
Sustain Collaboration among Federal Agencies. [hyperlink,
http://www.gao.gov/products/GAO-06-15]. Washington, D.C.: October 21,
2005.
Health Information Technology: HHS Is Taking Steps to Develop a
National Strategy. [hyperlink, http://www.gao.gov/products/GAO-05-628].
Washington, D.C.: May 27, 2005.
Military and Veterans' Benefits: Enhanced Services Could Improve
Transition Assistance for Reserves and National Guard. [hyperlink,
http://www.gao.gov/products/GAO-05-544]. Washington, D.C.: May 20,
2005.
[End of section]
Footnotes:
[1] OEF, which began in October 2001, supports combat operations in
Afghanistan and other locations, and OIF, which began in March 2003,
supports combat operations in Iraq and other locations.
[2] Veterans' Disability Benefits Commission, Honoring the Call to
Duty: Veterans' Disability Benefits in the 21st Century (Washington,
D.C., October 2007), 279.
[3] Pub. L. No. 110-181, § 1611
[4] Rand Corporation, Invisible Wounds of War: Psychological and
Cognitive Injuries, Their Consequences, and Services to Assist Recovery
(2008), xxi.
[5] In 2009, the substantial gainful activity income level is $980 per
month.
[6] In 2009, the basic maximum SSI payment is $674 per month for an
individual.
[7] SSA verifies different nonmedical requirements for the DI and SSI
programs; for example SSA field offices verify, among other things,
age, work credits, and current earnings for DI claimants and income and
assets for SSI claimants. DDSs are state agencies with guidance and
oversight provided by SSA.
[8] Approved DI claimants must wait 5 months after disability onset
before they can start receiving benefits, regardless of when they apply
and are approved for benefits. When they do start receiving benefits,
they may be eligible for retroactive benefits for months between the
end of this 5-month waiting period and their application date, up to a
maximum of 12 months of retroactive benefits.
[9] In deciding whether earnings show that an applicant has done
substantial gainful activity, SSA considers only the income directly
related to the applicant's productivity. 20 C.F.R. § 404.1574.
[10] In assessing whether an applicant can perform any work in the
national economy, SSA takes into account the applicant's age,
education, and work experience. 20 C.F.R. § 404.1520.
[11] In general, veterans cannot receive both DOD disability retirement
and VA disability compensation benefits concurrently, as their DOD
disability benefits are offset on a dollar for dollar basis by any VA
disability benefits they receive. However, veterans with 20 years or
more of service who have a service-connected disability that is rated
at 50 percent or higher may qualify to receive concurrent benefits,
subject to certain phase-in requirements through the year 2013.
[12] The data presented on the number of wounded warrior applicants
identified by SSA, their characteristics, and their outcomes reflect
wounded warrior claims filed through December 8, 2008, when the data
were extracted from SSA's databases.
[13] It is difficult to determine the proportion of all wounded
warriors who have applied for SSA disability benefits, not only because
of uncertainty about the number of applicants for SSA benefits, but
also because of the varying estimates of the total number of wounded
warriors since 2001.
[14] When an applicant files a claim for disability benefits, SSA
evaluates the applicant's potential entitlement for DI benefits based
on a wage earner's earnings history and their potential eligibility for
SSI benefits based on SSI income and resource limits.
[15] Applicants provide an alleged disability onset date when they file
a claim for DI or SSI. The established disability onset date is the
date on which SSA has determined that a disability actually began,
based on the medical and other evidence.
[16] We are defining the approval rate as the percentage of wounded
warrior applicants with final decisions on their claims, and with no
claims pending, who had an allowed claim.
[17] SSA calculates this 32 percent rate by dividing the number of
claim allowances at all levels of adjudication by the number of claims
(minus claims pending a final decision). One factor contributing to the
different rates for all claimants and wounded warrior claimants is that
a much higher percentage of all DI claimants, compared to wounded
warrior DI claimants, were denied for technical--nonmedical--reasons),
such as insufficient recent credits. Setting aside these technical
denials, SSA calculates that 51 percent of 2007 DI claimants had claims
allowed.
[18] Of wounded warriors denied at the initial stage, 1,960 requested a
reconsideration of this denial by the DDS, and 1,077 appealed their
claims to SSA's Office of Disability Adjudication and Review (ODAR) for
a hearing before an ALJ. Some applicants appeal a denial at the initial
level of adjudication directly to ODAR, without requesting a
reconsideration by the DDS.
[19] Data are not available on the body system category for claimants
allowed at the hearing level.
[20] Our data do not tell us conclusively whether these applicants have
ever had SSA claims approved, only whether they have ever applied and
whether they were receiving benefits in July 2008.
[21] These wounded warriors were included in data provided by DOD and
VA. The DOD provided data on wounded warriors assigned to the TDRL or
PDRL as of July 2008. We analyzed these data to identify individuals
placed on the TDRL or PDRL after October 2001, who had served in active
duty in October 2001 or later. The VA provided data on all veterans
receiving VA disability compensation benefits in July 2008 who were
identified in VA's database as OEF/OIF veterans. OEF/OIF veterans
include those who were physically based within the OEF/OIF combat
zones, as well as those who directly supported the OEF/OIF campaign
outside the combat zones. Many of the 26,000 DOD or VA benefit
recipients who have applied for SSA benefits are not identified as
wounded warriors in SSA's database and therefore are not included in
our estimate of 16,000 wounded warrior applicants reported above, which
is based on applicants identified as wounded warriors by SSA.
[22] Of those receiving SSA disability benefits, virtually all received
DI benefits, with only a small percentage receiving SSI benefits.
[23] The Severely Injured Marines and Sailors pilot program worked with
a small number of servicemembers to bring all relevant federal agencies
together in a coordinated way to help injured servicemembers understand
and apply for appropriate benefits. According to the program's final
report, the pilot examined the pros and cons of accelerating disability
retirement for severely injured servicemembers who are not expected to
return to duty within 12 months and would need financial support.
[24] According to DOD officials, the Army Wounded Warrior Program was
established in 2004 and has 51 locations across the country. The
program serves wounded warriors who are likely to be medically
discharged due to the severity of their medical condition. The Warrior
Transition Brigade was established in 2007 and is located at 35 Army
military treatment facilities in the United States and abroad. The
Brigade serves any wounded, ill, or injured servicemember from any
branch of service, including the Reserves and National Guard, who
requires at least 6 months of treatment.
[25] The Recovery Coordination Program began its operations in 2008
with 32 Recovery Care Coordinators. In the policy that established the
Recovery Coordination Program, it states Recovery Care Coordinators
should ensure that recovering servicemembers are afforded the
opportunity to be engaged by SSA's disability programs.
[26] The Transition Assistance Program and Disabled Transition
Assistance Program are regularly scheduled briefings conducted by DOD
and VA to servicemembers at DOD's military installations which include
SSA information.
[27] The Federal Recovery Care Coordination Program was established in
2007 and by 2008 nine Federal Recovery Coordinators had begun serving
DOD military treatment facilities and VA medical centers located across
the country. It became part of the DOD and VA comprehensive recovery
plan in 2008.
[28] According to a VA official, the OEF/OIF Program was established to
specifically serve veterans from the OEF/OIF campaigns. Staff are
located at each of the Veterans Health Administration's more than 150
medical centers across the country. Within this program, VA also
operates the Transition Patient Advocate Program that serves wounded
warriors with severe medical conditions.
[29] The four sites were: Walter Reed Army Medical Center, Washington
D.C.; National Naval Medical Center, Bethesda, Maryland; Brooke Army
Medical Center, San Antonio, Texas; and Naval Medical Center San Diego,
San Diego, California.
[30] We surveyed a random sample of wounded warriors who applied for
SSA benefits during fiscal year 2008 and received a response rate of 53
percent. A nonresponse bias analysis revealed that older and more
educated individuals were more likely to respond to our survey than
younger and less educated individuals, but did not reveal systemic bias
in our survey results. Unless otherwise noted, the margin of error for
percentage estimates from this survey is plus or minus 8 percentage
points or less at the 95 percent level of confidence. See appendix I
for more details on our survey methodology and our nonresponse bias
analysis, and appendix III for the questions and complete results.
[31] When veterans apply for pension benefits at this office, VA staff
ask them if they are receiving SSA benefits, because eligibility for
VA's pension program is affected by receipt of income from other
sources. If a veteran is not receiving SSA benefits, VA staff may refer
the veteran to SSA. VA's pension benefits are available to veterans who
have low incomes and are either aged or have a disability that is not
related to military service.
[32] VA's Welcome Home program are events that provide information on
VA's health and benefit services, services from the OEF/OIF program,
and other supportive services. Stand Down events provide services to
homeless veterans such as food, shelter, clothing, health screenings,
VA and SSA benefits counseling, and referrals to other services.
[33] RAND Corporation, Invisible Wounds of War, 23.
[34] For nonpriority claims, SSA staff are instructed to offer an
applicant the first available appointment.
[35] A consultative exam is a medical examination, performed by a
physician at SSA or DDS' request, to gather additional information to
enable DDS examiners to make a determination on a claimant's medical
condition.
[36] To qualify for SSA benefits, a claimant's condition must have
lasted or be expected to last for 12 consecutive months.
[37] Because there were so few wounded warrior SSI applications that
progressed to the DDS level for medical evaluation during 2001 to 2008,
we decided to focus our analysis on wounded warriors' DI processing
times only.
[38] Interoperability is the ability of two or more systems or
components to exchange information and to use the information that has
been exchanged.
[39] Pub. L. No. 110-181, § 1635 (2008).
[40] The Department of Health and Human Services is coordinating the
NHIN. The agency is advancing the NHIN as a "network of networks",
which will connect diverse entities--such as federal agencies and
health care providers--to exchange patients' health information.
[41] According to DOD, this list is not definitive, but is the only
available data it can provide to SSA.
[42] Veterans granted Individual Unemployability (IU) by VA were
included in the data we analyzed, but there was no indicator in these
data of which veterans were classified as IU. The data we used only
indicated these veterans' combined disability rating.
[43] Our response rate was calculated using the American Association
for Public Opinion Research's response rate number three. Of 187
respondents to our survey, 4 respondents separated from the military
prior to 2001 and 1 individual had applied for SSA retirement but not
disability benefits; these five individuals were considered out of
scope. Additionally, in the course of fielding our survey we discovered
that 2 individuals in our sample were deceased; we treated these
individuals as nonrespondents for the purposes of response rate
calculations.
[44] These differences were significant at the 95 percent confidence
level after an adjustment to account for the three different sets of
tests we used.
[End of section]
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