Electronic Disability Claims Processing
SSA Is Proceeding with Its Accelerated Systems Initiative but Needs to Address Operational Issues Gao ID: GAO-05-97 September 23, 2005Through an initiative known as AeDib, the Social Security Administration (SSA) is implementing a system in which medical images and other documents that have traditionally been kept in paper folders will be stored in electronic folders, enabling disability offices--including SSA's 144 Office of Hearings and Appeals sites and 54 state disability determination services--to process disability claims electronically. This initiative supports a program that, in 2004, made payments of approximately $113 billion to more than 14 million beneficiaries and their families. In March 2004, GAO recommended that SSA take steps to ensure the successful implementation of the electronic disability system. GAO was asked to assess SSA's status in implementing AeDib and the actions the agency has taken in response to GAO's prior recommendations on this initiative.
Since January 2004, SSA has been implementing its electronic disability system at 53 state disability determination services and 85 Office of Hearings and Appeals sites. It plans to complete implementation in all state sites by October 2005 and all hearings and appeals sites by November 2005. Nonetheless, considerable work is needed before these entities will be ready to process all initial claims electronically. SSA's effort to certify all state offices to electronically process claims and maintain the electronic folder as an official claims record is not expected to be completed until January 2007. In addition, state disability officials expressed concerns about the system's operations and reliability and about limitations in their electronic processing capabilities. Accordingly, a number of the offices reported varying levels of system usage, and their officials said that processing claims electronically generally took longer and consumed more resources than the previous method. Further, SSA and the state disability determination services lacked continuity of operations plans for ensuring that states could continue to process disability claims during emergencies. As SSA has implemented its system, it has taken actions that supported three of GAO's five prior recommendations. It has initiated studies that could help validate AeDib planning assumptions, costs, and benefits. It has also approved new software and certified its systems for production. In addition, according to state disability officials, the agency had improved its communications with them. However, SSA did not demonstrate action on two recommendations calling for thorough testing of its interrelated system components before implementation and completion of risk mitigation strategies for the projects supporting the initiative. Thorough testing and risk mitigation strategies could have helped limit problems with the system's operation and other circumstances that could impede the project's success.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-05-97, Electronic Disability Claims Processing: SSA Is Proceeding with Its Accelerated Systems Initiative but Needs to Address Operational Issues
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Report to the Chairman, Committee on Finance, U.S. Senate:
September 2005:
Electronic Disability Claims Processing:
SSA Is Proceeding with Its Accelerated Systems Initiative but Needs to
Address Operational Issues:
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-97]:
GAO Highlights:
Highlights of GAO-05-97, a report to the Chairman, Committee on
Finance, United States Senate:
Why GAO Did This Study:
Through an initiative known as AeDib, the Social Security
Administration (SSA) is implementing a system in which medical images
and other documents that have traditionally been kept in paper folders
will be stored in electronic folders, enabling disability
offices”including SSA‘s 144 Office of Hearings and Appeals sites and 54
state disability determination services”to process disability claims
electronically. This initiative supports a program that, in 2004, made
payments of approximately $113 billion to more than 14 million
beneficiaries and their families. In March 2004, GAO recommended that
SSA take steps to ensure the successful implementation of the
electronic disability system.
GAO was asked to assess SSA‘s status in implementing AeDib and the
actions the agency has taken in response to GAO‘s prior recommendations
on this initiative.
What GAO Found:
Since January 2004, SSA has been implementing its electronic disability
system at 53 state disability determination services and 85 Office of
Hearings and Appeals sites. It plans to complete implementation in all
state sites by October 2005 and all hearings and appeals sites by
November 2005. Nonetheless, considerable work is needed before these
entities will be ready to process all initial claims electronically.
SSA‘s effort to certify all state offices to electronically process
claims and maintain the electronic folder as an official claims record
is not expected to be completed until January 2007. In addition, state
disability officials expressed concerns about the system‘s operations
and reliability and about limitations in their electronic processing
capabilities. Accordingly, a number of the offices reported varying
levels of system usage (see table), and their officials said that
processing claims electronically generally took longer and consumed
more resources than the previous method. Further, SSA and the state
disability determination services lacked continuity of operations plans
for ensuring that states could continue to process disability claims
during emergencies.
As SSA has implemented its system, it has taken actions that supported
three of GAO‘s five prior recommendations. It has initiated studies
that could help validate AeDib planning assumptions, costs, and
benefits. It has also approved new software and certified its systems
for production. In addition, according to state disability officials,
the agency had improved its communications with them. However, SSA did
not demonstrate action on two recommendations calling for thorough
testing of its interrelated system components before implementation and
completion of risk mitigation strategies for the projects supporting
the initiative. Thorough testing and risk mitigation strategies could
have helped limit problems with the system‘s operation and other
circumstances that could impede the project‘s success.
Reported Use of the Electronic Disability System in Selected Disability
Determination Services as of Late June 2005:
[See Table 2]
What GAO Recommends:
GAO is making recommendations to the Commissioner of Social Security
that focus on resolving operational problems with the electronic
disability system and ensuring the continuity of electronic disability
claims processing. In commenting on this report, SSA disagreed with
GAO‘s recommendation for resolving problems with the electronic system,
but agreed to implement plans for ensuring the continuity of disability
claims processing.
www.gao.gov/cgi-bin/getrpt?GAO-05-97.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Linda Koontz at (202) 512-
6240 or koontzl@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
SSA Is Meeting Its Overall AeDib Implementation Schedule, but
Operational and Other Concerns Could Impact the Success of the
Initiative:
SSA's Actions toward Implementing AeDib Have Addressed Some, but Not
All, of our Prior Recommendations for Improvement:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Comments from the Social Security Administration:
Appendix III: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Scheduled Certification of State DDSs as of June 30, 2005:
Table 2: Reported Use of the Electronic Disability System in Selected
DDS Offices as of Late June 2005:
Figure:
Figure 1: SSA's Electronic Disability Claims Processing System:
Letter September 23, 2005:
The Honorable Charles E. Grassley:
Chairman:
Committee on Finance:
United States Senate:
Dear Mr. Chairman:
This report responds to your request concerning the Social Security
Administration's (SSA) ongoing accelerated initiative to establish an
electronic disability claims processing capability--known as AeDib.
With this initiative, the agency is implementing a paperless system, in
which the large volumes of medical images, files, and other documents
that traditionally have been maintained in paper folders will be stored
in electronic folders, enabling the disability claims processing
offices to electronically view, process, and share claims information.
The disability claims processing offices include SSA's field offices,
where individuals apply for claims; state disability determination
services (DDS) offices, which determine claimants' medical eligibility
for disability benefits; and SSA's Office of Hearings and Appeals
(OHA), which processes appeals of claims that have been denied. SSA
began its national rollout of the key system components needed to
electronically process an entire disability case in late January 2004.
In pursuing this electronic capability, SSA has taken a positive and
necessary step toward more efficiently delivering benefits payments to
an increasing beneficiary population. However, we previously pointed
out that the agency's accelerated strategy for developing and
implementing the electronic disability system involved risks that
threatened the agency's complete and successful transition to this
capability. In reporting on AeDib in March 2004, for example, we noted
that the agency had begun its national rollout without conducting
essential testing to assess how the multiple interrelated system
components for this initiative would function in an integrated
environment.[Footnote 1] To address such deficiencies, we recommended
that the Commissioner of Social Security take several actions to reduce
the risks associated with the agency's strategy for developing the
electronic disability system. At your request, this report discusses
(1) the current status of SSA's implementation of AeDib and (2) the
actions SSA has taken in response to our prior recommendations on this
initiative.
To address these objectives, we analyzed project management and
technical documentation describing SSA's plans and progress related to
implementing its electronic disability system. In addition, we reviewed
relevant documents that describe the state DDSs' implementation and use
of the system, including reports of the National Council of Disability
Determination Directors--an organization representing the state DDSs.
We also obtained and reviewed relevant documentation describing SSA's
actions toward implementing our prior recommendations on AeDib.
Further, we interviewed key officials in SSA's Offices of Operations,
Systems, Disability and Income Security Programs, and Hearings and
Appeals to determine the current status of the system's implementation
and to discuss issues that the agency has identified during the
implementation. We also interviewed DDS officials in nine states--
California, Delaware, Florida, Illinois, Mississippi, Nebraska, New
York, North Carolina, and South Carolina--and the President of the
National Council of Disability Determination Directors, to obtain their
views on implementing the electronic disability system. To supplement
the interviews, we visited DDS and OHA sites in Mississippi and South
Carolina, where we observed the operations of the electronic disability
system and discussed these offices' implementations of and experiences
in using it. We conducted our work from October 2004 to July 2005, in
accordance with generally accepted government auditing standards.
Appendix I contains a more detailed discussion of the objectives,
scope, and methodology.
Results in Brief:
SSA is proceeding with its implementation of its electronic disability
claims process, which involves installing a data repository and the
capability to scan and image claimants' information and medical
evidence,[Footnote 2] enhancing existing claims processing systems in
DDS offices, and installing software that will enable DDS and OHA
systems to interface with electronic folders.[Footnote 3] The agency
had planned to equip all DDS offices and OHA sites with these
electronic capabilities by June 2005 and October 2005, respectively,
and since beginning the national rollout in late January 2004 has
largely met its implementation schedule. As of June 30, 2005, it had,
as planned, fully or partially implemented the electronic capabilities
in 53 of the 54 state DDS offices and in 85 of the 144 OHA sites.
Nonetheless, the agency still has considerable work to accomplish
before it will be effectively positioned to fully process disability
claims in an electronic environment. As of early July 2005, it had
certified only three DDSs to process all initial disability claims
electronically and to maintain the electronic folder as an official
record; it does not expect to complete all certifications until January
2007. In addition, officials in a number of the DDSs expressed concerns
about the operations and reliability of the electronic disability
system, stating, for example, that inadequacies in the electronic forms
and the computer monitors used to view claims information had slowed
systems performance and impeded their productivity. Consequently, these
officials reported varying levels of system usage and stated that
processing claims electronically had thus far taken longer and consumed
more resources than prior to the system's implementation. Further,
although SSA is moving to fully implement its system, the agency and
state DDSs have not yet developed continuity of operations plans for
mutually ensuring the continuity of this vital disability benefits
service during short- or long-term disruptions to their electronic
claims processing capabilities. Until SSA adequately resolves the
concerns surrounding its electronic disability system, it jeopardizes
its progress toward successfully achieving a more efficient means of
delivering disability benefits payments to its increasing beneficiary
population.
In proceeding with the AeDib initiative, SSA has taken actions related
to three of five recommendations we made in our prior report. For
example, it has initiated studies to help validate its planning
assumptions supporting the initiative's costs and benefits, begun
ensuring users' approval of new software and the certification of its
systems for production, and improved its communications about the
initiative with DDS officials. However, the agency did not demonstrate
any action on two other recommendations--to conduct essential end-to-
end testing to determine how the interrelated system components would
work together prior to their implementation and to complete strategies
for mitigating risks to the projects supporting the initiative.
Thorough testing and risk mitigation strategies could have helped limit
problems with the system's operation and prevented circumstances that
could impede the project's success.
To further reduce risks to SSA's progress in achieving its electronic
disability claims processing capability, we are recommending that the
Commissioner of Social Security (1) develop and implement a strategy
that articulates milestones, resources, and priorities for resolving
operational problems with the electronic disability system and (2)
ensure that state DDSs develop and implement continuity of operations
plans that address the continuation of disability claims processing in
emergency situations.
In written comments on a draft of our report (reprinted in app. II),
SSA agreed to ensure that state DDSs develop and implement continuity
of operations plans for continuing essential disability claims
processing functions during emergencies. However, the agency disagreed
with our recommendation that it develop and implement a strategy that
articulates milestones, resources, and priorities for efficiently and
effectively resolving problems with the electronic disability system's
operations. The agency stated that it already had plans in place and
had taken various actions to improve the electronic disability system's
operations by, for example, establishing a work group to identify
software improvements for its electronic forms and hiring a contractor
to test new computer monitor configurations. However, during our
review, SSA could not provide a time table for the work group's
efforts, and it does not anticipate a final report on its tests of
monitor configurations until January 2007. As SSA moves forward with
actions to improve the electronic disability system, a strategy that
articulates clear milestones, resources, and priorities will be
essential to guide the agency's efforts and ensure that all operational
concerns are fully and effectively addressed.
Background:
SSA's Disability Insurance and Supplemental Security Income programs
are the nation's largest providers of federal income assistance to
disabled individuals, with the agency making payments of approximately
$113 billion to more than 14 million beneficiaries and their families
in 2004. Yet, over the years, it has become more challenging for the
agency to ensure an acceptable level of service--in terms of both the
quality and the timeliness of its support to these individuals. In
January 2003, we designated disability benefits programs across the
federal government as high risk--in need of urgent attention and
transformation.[Footnote 4]
The process through which SSA approves or denies disability benefits is
complex and involves multiple partners at both the federal and state
levels in determining a claimant's eligibility. SSA's 1,300 field
offices are the initial points of contact for individuals applying for
benefits.[Footnote 5] SSA also depends on 54 state DDS offices to
provide crucial support to the claims process through their role in
determining an individual's medical eligibility for disability
benefits. DDSs make initial determinations regarding disability claims
in accordance with federal regulations and policies; the federal
government reimburses 100 percent of all costs incurred by states to
make disability determinations. Physicians and other members of the
medical community provide the DDSs with medical evidence to help them
evaluate disability claims. When disability claims have been denied by
the DDSs, claimants can appeal to SSA's OHA.[Footnote 6]
The process begins when individuals apply for disability benefits at an
SSA field office, where determinations are made about whether they meet
nonmedical criteria for eligibility.[Footnote 7] If the claimant is
eligible, the field office forwards the application to the appropriate
state DDS, where a disability examiner collects the necessary medical
evidence to make the initial determination of whether the claimant's
condition meets the definition of disability. Once the claimant's
medical eligibility is determined, the DDS returns the claim folder to
SSA for final processing.
A claimant who is initially denied benefits can ask the DDS to
reconsider its determination. If the DDS denies the claim again, the
claimant can request a hearing before a federal administrative law
judge at an SSA hearings office and, if still dissatisfied, can request
a review of the claim by SSA's Appeals Council. Upon exhausting these
administrative remedies, the claimant may file a complaint in federal
district court. Each level of appeal involves multistep procedures for
collecting evidence, reviewing information, and making the decision.
Many individuals who appeal the initial determination on their claims
will wait a year or longer--perhaps up to 3 years--for a final
decision.
To address concerns regarding the program's efficiency, in 1992, SSA
initiated its Modernized Disability System project, intending to
redesign the disability claims process emphasizing the use of
automation to achieve an electronic (paperless) processing capability.
This project, which in 1994 was renamed the Reengineered Disability
System, was to automate the entire disability claims process--from the
initial claims intake in the field office to the gathering and
evaluation of medical evidence by the state DDSs, to payment by the
field office or processing center. The system also was intended to
automate the handling of appeals by SSA's hearings offices. However, as
our prior work noted, SSA encountered performance and other problems
during its initial pilot testing of the system and, after spending more
than $71 million, suspended this project in 1999.
In August 2000, SSA renewed its commitment to developing an electronic
disability system by the end of 2005. The agency worked on this
initiative through the spring of 2002, at which time the Commissioner
of Social Security announced an accelerated electronic disability
initiative--AeDib--to more quickly move to an automated process. Under
the accelerated strategy, the agency planned to begin implementing its
electronic disability system by January 2004. SSA anticipated that the
electronic disability system would enable the disability offices to
achieve processing efficiencies, improve data completeness, reduce
keying errors, and save time and money. With technologically enhanced
claims processing offices, the agency projected that it could realize
benefits of more than $1 billion--at an estimated cost of approximately
$900 million--over the 10-year life of the initiative.[Footnote 8] SSA
reported actual AeDib costs of approximately $215 million through
fiscal year 2004 for planning, hardware and software acquisition,
maintenance, and personnel.
The AeDib strategy focuses on developing the capability to
electronically process claimant information and large volumes of
medical images, files, and other documents that are currently
maintained in paper folders. Stored in electronic folders, this
information could then be accessed, viewed, and shared among the
disability claims processing offices. The initiative to achieve this
electronic capability involves five key projects:
* an Electronic Disability Collect System that would provide the
capability for SSA field offices to capture electronically, in fixed
data fields, information about a claimant's disability that previously
had been contained on paper disability forms (structured data) and to
store it in databases for later use by the SSA and DDS offices
responsible for processing disability claims;
* a Document Management Architecture to provide a data repository and
scanning and imaging capabilities that would allow unstructured
claimant and medical data, such as images or information not found in
fixed data fields (e.g., a hospital report, doctors' notes, or an x-ray
report), to be stored, indexed, and shared among the disability
processing offices;
* Internet applications to enable the public to submit disability
claims and medical information to SSA via the Internet (all data keyed
into the Internet applications would be transmitted directly into the
Electronic Disability Collect System);
* a systems migration and electronic folder software interface to
position DDS offices to operate on a common IBM-series hardware
platform and enhance their existing claims systems to process the
electronic claims information and to enable the DDS systems to access
information in the electronic folder; and:
* a Case Processing Management System that would interface with the
electronic folder and enable OHA's staff to track, manage, and complete
case-related tasks electronically.
According to SSA, the Electronic Disability Collect System and the
Document Management Architecture are the two fundamental components
needed to create the electronic disability folder. Via their claims
processing systems, SSA and DDS users would be able to access and pull
the structured and unstructured claimant data into appropriate computer
screens, organized as electronic folders of information.[Footnote 9]
The agency's electronic disability claims processing system is depicted
in figure 1.
Figure 1: SSA's Electronic Disability Claims Processing System:
[See PDF for image]
[End of figure]
By mid-January 2004, SSA had implemented all planned releases of the
Electronic Disability Collect System and had completed and placed into
production Internet applications to aid claimants in filing online for
disability benefits and services. It also had enhanced the DDSs' claims
processing systems by migrating and upgrading hardware to allow these
offices to operate on a common IBM-series platform and by upgrading the
claims processing software in all but 3 state DDS offices that used the
standard disability claims processing systems.[Footnote 10] In
addition, SSA had begun pilot testing OHA's Case Processing Management
System in a standalone environment at five sites. Further, the agency
was pilot testing the Document Management Architecture in three state
DDS locations--North Carolina, Illinois, and California. However, it
had not yet implemented the Document Management Architecture repository
and scanning and imaging capabilities and related DDS software
enhancements or the software to enable DDS and OHA systems to interface
with the electronic folders. SSA began its national rollout of these
remaining system components at the Mississippi DDS on January 26, 2004.
When we last reported on the initiative in late March 2004, SSA was
proceeding with its implementation of its electronic disability
system.[Footnote 11] However, our work had noted that the agency's
strategy for developing the system components involved risks that
threatened the success of the project. For example, we determined that
the agency (1) had begun the national rollout without conducting
testing that was adequate to evaluate the performance of all system
components collectively, (2) could not provide evidence that it was
consistently applying established procedures to guide the AeDib
software development or had developed risk mitigation strategies, (3)
had not validated its analysis to ensure the reasonableness of
estimated AeDib costs and benefits, and (4) had not articulated a
comprehensive plan for ensuring that state DDSs' concerns about the
initiative were addressed. In view of the risks and the technological
complexity, scope, and size of the initiative, we had recommended that
the Commissioner of Social Security, before continuing with the
national rollout of AeDib,
* ensure that all critical problems identified in pilot testing of the
electronic disability system were resolved and that end-to-end testing
of the interrelated systems was performed,
* ensure that the software that had been developed was approved and
that the systems had been certified for production,
* establish a revised time frame for and expedite actions toward
finalizing AeDib risk mitigation strategies,
* validate all AeDib cost and benefit estimates, and:
* implement a communications plan to clearly and comprehensively convey
SSA's approach for effectively addressing disability stakeholders' and
users' concerns and ensuring their full involvement in the AeDib
initiative.
SSA Is Meeting Its Overall AeDib Implementation Schedule, but
Operational and Other Concerns Could Impact the Success of the
Initiative:
SSA is proceeding with a national rollout of its electronic disability
system and has generally met its schedule for implementing the
remaining key components--the Document Management Architecture and the
electronic folder interface software--that are required to process an
entire disability case electronically. Nonetheless, the agency has
considerable work to accomplish before it will be effectively
positioned to fully process all disability claims in an electronic
environment. Among the critical tasks that remain are certifying all
state DDS offices and OHA sites to electronically process claims and
addressing operational and other concerns that threaten to undermine
the reliability and use of the system. Until SSA has effectively
addressed these matters, it remains uncertain when and to what degree
the agency will realize the full benefits of its electronic processing
capability.
AeDib Implementation Schedule Was Generally Met through June 2005:
The AeDib implementation schedule had called for all state DDSs and OHA
sites to be equipped with the electronic disability claims processing
capability by June 27, 2005, and October 3, 2005, respectively. Since
beginning the national rollout of the Document Management Architecture
and related DDS software enhancements and the electronic folder
interface software in late January 2004,[Footnote 12] the agency has
largely met its implementation schedule. As of late June 2005, SSA had
fully or partially implemented the electronic disability system in 53
of the 54 state DDS offices and in 85 of the 144 OHA sites, as planned.
The agency reported that it expected to finish implementing the
electronic disability system in the one remaining DDS--New York--in
October 2005.
SSA officials attributed the 4-month delay in the planned
implementation at the New York DDS to the need for additional time to
interface the electronic disability system with that state's existing
claims processing capabilities. New York and Nebraska are the only two
DDSs in which the states' claims processing capabilities are not
supported by the common hardware platform that the majority of DDSs use
and that have developed and rely on disability claims processing
software that is unique to their processing environments. As a result
of New York's efforts to develop and test an electronic disability
claims process, it had achieved a level of electronic processing,
including the capability to scan medical evidence into its system,
prior to SSA's completion of the electronic disability system. SSA and
New York DDS officials agreed to interface the new electronic
disability system with portions of that state's existing claims
processing capabilities.[Footnote 13]
In addition, SSA officials reported, as of early July 2005, that they
expected to meet the scheduled completion date of October 3, 2005, for
115 of the 144 OHA sites. They stated that the agency expected to
complete implementation of the electronic disability system at the
remaining 29 OHA sites approximately 1 month later, in November 2005.
According to agency officials, 10 of the 29 sites support claims that
are processed by the New York DDS. The agency delayed implementation at
these sites in order to be more in step with New York's revised
implementation schedule and with anticipated time frames for when the
DDS will be positioned to process disability cases using the electronic
folder. Regarding the remaining 19 sites, officials explained that the
agency did not wish to train staff and provide the electronic folder
capability to OHA sites too far in advance of when these offices
expected to receive electronic cases from the DDSs, believing that too
much lag time between training and actual use of the system could
result in the staffs' losing some of the knowledge and skills they need
to process cases electronically.
Operational and Other Concerns Could Impact the Electronic Disability
System's Reliability and Use:
Although the roll out of the electronic disability system is moving
toward completion, the agency still has considerable work to accomplish
before it will be effectively positioned to process all disability
claims in a fully electronic environment. After implementing the
electronic system, each DDS must undergo an assessment of the quality
and accuracy of its electronic processing capabilities and must be
certified by SSA to use the electronic folder as its official
disability claims record. This assessment, referred to as the
Independence Day Assessment, is intended to validate that an office is
ready to process 100 percent of the initial disability claims and any
reconsiderations that it receives in the electronic environment and
that the electronic folder can serve as the official disability claims
record.[Footnote 14] According to SSA Operation's staff, the assessment
involves examining the disability office's operations and claims
processing tasks to ensure that (1) the business process (e.g., the way
in which the disability claims office is organized to do its work) and
the electronic processing environment are compatible; (2) existing
claims processing systems have the necessary functionality to process
electronic folders; and (3) staff can, when using the electronic
disability system, produce complete information that equals what is
contained in the paper folders.
As of early July 2005, SSA reported that only three state DDSs--
Mississippi, Illinois, and Hawaii--had completed assessments and been
certified to process all initial disability claims in a paperless
electronic environment in which the electronic folder is recognized as
the official disability claims record. SSA reported that it had
certified Mississippi--the first state under the national rollout--to
process all of its initial disability claims electronically by February
2005; the agency further reported that it had completed certifications
in June 2005 for Illinois--one of the three states that had
participated in a pilot test of the Document Management Architecture in
2003--and for Hawaii, one of the smallest states (consisting of 15
disability claims examiners), which completed its system's
implementation in February 2005.
In discussing Mississippi's certification, the DDS director stated that
the approximately 1-year time frame between the implementation and the
certification of the office's system had been devoted to such tasks as
updating and testing software versions in order to give the office the
full complement of functionality that it would need to use the
electronic folder and to ensuring that the office's business processes
effectively supported electronic processing by, for example,
familiarizing staff with the electronic capabilities, training them in
using the capabilities, and testing the use of scanning equipment in
the office. The director added that, since Mississippi was the first
state to be assessed and certified, SSA had reviewed a substantially
larger number of disability cases (approximately 300) than it intends
to review in the assessments of other states using the same claims
processing software.
SSA officials said that, following Mississippi's certification, the
Commissioner of Social Security had placed a moratorium on any
additional certifications pending SSA's review of the assessment that
had been undertaken in that state. They said that the commissioner had
wanted to capture lessons learned from Mississippi's assessment to
identify any needed improvements in the assessment process and to
ensure that any business or user concerns about the assessments were
resolved before they applied the process broadly across all DDSs and
OHA sites. For example, according to the officials, they learned that a
smaller sample of disability cases could be examined in subsequent
offices using the same software as Mississippi's without diminishing
the integrity of the assessment and the related certification.
As of July 2005, SSA officials told us that they had resumed the
assessments and that the agency's plans called for a total of seven
state DDSs to be certified to process claims electronically by the end
of fiscal year 2005.[Footnote 15] However, as indicated in table 1, not
all of the 54 state DDSs are expected to be certified to process
initial disability claims and to use the electronic folder as the
official record until January 2007.
Table 1: Scheduled Certification of State DDSs as of June 30, 2005:
Implementation date: January 2004;
DDS office: Mississippi;
Certification date: February 2005.
Implementation date: September 2003;
DDS office: Illinois;
Certification date: June 2005.
Implementation date: February 2005;
DDS office: Hawaii;
Certification date: June 2005.
Implementation date: March 2005;
DDS office: Nevada;
Certification date: August 2005.
Implementation date: March 2004;
DDS office: South Carolina;
Certification date: September 2005.
Implementation date: October 2004;
DDS office: Wyoming;
Certification date: September 2005.
Implementation date: October 2003;
DDS office: California;
Certification date: October 2005.
Implementation date: September 2004;
DDS office: Maine;
Certification date: October 2005.
Implementation date: October 2004;
DDS office: Minnesota;
Certification date: October 2005.
Implementation date: November 2004;
DDS office: Oklahoma;
Certification date: October 2005.
Implementation date: January 2005;
DDS office: Oregon;
Certification date: October 2005.
Implementation date: June 2005;
DDS office: Guam;
Certification date: October 2005.
Implementation date: March 2005;
DDS office: Virgin Islands;
Certification date: November 2005.
Implementation date: May 2005;
DDS office: Delaware;
Certification date: November 2005.
Implementation date: October 2004;
DDS office: Texas;
Certification date: December 2005.
Implementation date: June 2005;
DDS office: Alaska;
Certification date: December 2005.
Implementation date: July 2003;
DDS office: North Carolina;
Certification date: January 2006.
Implementation date: May 2005;
DDS office: New Hampshire;
Certification date: January 2006.
Implementation date: June 2005;
DDS office: North Dakota;
Certification date: January 2006.
Implementation date: April 2004;
DDS office: Tennessee;
Certification date: February 2006.
Implementation date: August 2004;
DDS office: Idaho;
Certification date: February 2006.
Implementation date: October 2004;
DDS office: Connecticut;
Certification date: February 2006.
Implementation date: November 2004;
DDS office: Iowa;
Certification date: February 2006.
Implementation date: December 2004;
DDS office: Arizona;
Certification date: February 2006.
Implementation date: March 2005;
DDS office: Vermont;
Certification date: February 2006.
Implementation date: April 2005;
DDS office: Massachusetts;
Certification date: February 2006.
Implementation date: June 2004;
DDS office: Alabama;
Certification date: March 2006.
Implementation date: June 2004;
DDS office: Georgia;
Certification date: March 2006.
Implementation date: January 2005;
DDS office: Missouri;
Certification date: March 2006.
Implementation date: April 2005;
DDS office: New Jersey;
Certification date: March 2006.
Implementation date: April 2005;
DDS office: Rhode Island;
Certification date: March 2006.
Implementation date: July 2004;
DDS office: Utah;
Certification date: April 2006.
Implementation date: December 2004;
DDS office: Michigan;
Certification date: April 2006.
Implementation date: January 2005;
DDS office: Wisconsin;
Certification date: April 2006.
Implementation date: January 2005;
DDS office: Louisiana;
Certification date: April 2006.
Implementation date: September 2004;
DDS office: Florida;
Certification date: May 2006.
Implementation date: September 2004;
DDS office: Ohio;
Certification date: May 2006.
Implementation date: November 2004;
DDS office: South Dakota;
Certification date: May 2006.
Implementation date: January 2005;
DDS office: Arkansas;
Certification date: May 2006.
Implementation date: February 2005;
DDS office: Washington;
Certification date: May 2006.
Implementation date: April 2005;
DDS office: Indiana;
Certification date: May 2006.
Implementation date: September 2004;
DDS office: West Virginia;
Certification date: June 2006.
Implementation date: December 2004;
DDS office: Puerto Rico;
Certification date: June 2006.
Implementation date: December 2004;
DDS office: Kentucky;
Certification date: June 2006.
Implementation date: June 2005;
DDS office: Nebraska;
Certification date: June 2006.
Implementation date: March 2005;
DDS office: Pennsylvania;
Certification date: July 2006.
Implementation date: March 2005;
DDS office: Maryland;
Certification date: July 2006.
Implementation date: April 2005;
DDS office: Kansas;
Certification date: July 2006.
Implementation date: April 2005;
DDS office: New Mexico;
Certification date: July 2006.
Implementation date: May 2005;
DDS office: Montana;
Certification date: August 2006.
Implementation date: March 2005;
DDS office: Colorado;
Certification date: September 2006.
Implementation date: January 2005;
DDS office: Virginia;
Certification date: October 2006.
Implementation date: June 2005;
DDS office: Washington, DC;
Certification date: November 2006.
Implementation date: October 2005;
DDS office: New York;
Certification date: January 2007.
Source: GAO analysis of SSA information.
[End of table]
According to OHA's deputy director, SSA expects to certify each OHA
site shortly after certifying the corresponding DDS office. The
official noted that because all OHA sites will rely on the same
standard system (the Case Processing Management System), their
certification process is expected to be less complicated than the
process for the DDSs. Until they are certified, offices that have
already implemented the electronic disability system are expected to
maintain paper folders as well as electronic ones for any initial
disability cases that they process electronically. The paper folders
will continue to serve as the official records for these cases.
Operational Concerns Exist:
Even as the agency proceeds in certifying states' electronic
capabilities, however, operational concerns associated with the
electronic disability system could undermine its reliability and use.
Officials in seven of the nine DDS offices that we contacted
(California, Delaware, Florida, Illinois, Mississippi, North Carolina,
and South Carolina) stated that operational problems they had
encountered while using the electronic disability system had affected
its performance and raised doubts about its reliability in supporting
their processing needs.
DDS officials stated, for example, that as SSA had brought the system
online at the different DDS offices and/or added new software to
enhance functionality, their staffs had encountered various operating
problems that affected the performance of the system. They stated that
their offices had experienced problems such as computer screen freezes,
system slowdowns, and system access issues--all of which had disrupted
the offices' processing of claims. They described these problems as
unpredictable and random because they did not always occur consistently
among all of the offices using the same claims processing software or
even among examiners in a particular office. The officials added that
although SSA has been able to resolve many of the problems that
affected their ability to process claims, additional instances of
screen freezes, system slowdowns, and access issues have continued to
occur throughout the system's implementation.
According to the manager of the South Carolina DDS, which implemented
the electronic disability system in March 2004, that office's
productivity had been adversely affected by system slowdowns that
resulted from having inadequate network bandwidth to support its
disability claims processing operations. In July 2005, the manager
stated that SSA had recently made modifications to the office's network
architecture and had increased its bandwidth by installing two
additional communications lines; at that time, the office was in the
process of testing these enhancements. The manager said that all of the
office's disability claims examiners had begun processing all initial
disability claims electronically and that, as a result of the
enhancements, they expected the office's claims processing efficiency
and productivity to increase.
In addition, DDS officials in six offices (California, Delaware,
Florida, Mississippi, North Carolina, and South Carolina) reported
problems with the electronic forms that SSA had installed to facilitate
the processing of disability claims.[Footnote 16] The officials
explained that, while using the electronic forms, disability claims
examiners had experienced slow system response times or system freezes
that had contributed to increased claims processing times. Officials in
California stated that they had stopped using the electronic forms as a
result of the problems that their staff had encountered and instead
were continuing to rely on paper forms. In a February 2005 survey, the
National Council of Disability Determination Directors found that 22
DDSs had experienced problems with the electronic forms and had
reported that the slow pace involved in loading and using these forms
was barely tolerable. Further, based on its May 2005 quarterly
evaluation of the electronic disability system, SSA reported that one
of the systems-related problems that disability processing offices
identified most frequently was the slow response times and lack of user-
friendliness of the electronic forms.
Further, officials in five of the DDSs that we contacted among those
that had implemented the electronic disability system (California,
Illinois, Mississippi, North Carolina, and South Carolina) stated that
their disability examiners faced difficulties in reading medical
evidence on screen and performing certain case development or
adjudication tasks because the size of the computer monitors that they
had been provided to process medical evidence had proven inadequate.
Users of the system--including managers, claims examiners, and medical
consultants--reported difficulty with simultaneously viewing two
documents on their monitors; some staff reported that they had resorted
to printing out or toggling between documents to avoid using the split
screen to review them. As a result of the inadequacies associated with
using the existing monitors, the users reported that they needed longer
periods of time to perform certain claims adjudication tasks and that
they had been unable to complete as many cases per day as they could
before they had the electronic disability system.
Beyond these concerns, officials in four of the DDSs that we contacted
told us that, although their electronic capability had been
implemented, they had not been provided certain software enhancements
that they needed to fully process a claim electronically and that were
critical to improving the efficiency of their offices' claims
processing capabilities. Specifically, Florida officials stated that
their claims processing software did not provide the capability to
electronically notify staff of the actions that were required to
process a claim. As a result, the staff had to expend additional time
notifying each other of actions needed to process the claim by, for
example, sending e-mail notices. In addition, the director of the North
Carolina DDS stated that that office lacked the necessary software to
enable staff to electronically send claims files to SSA's Disability
Quality Branch, which is responsible for conducting quality reviews of
the accuracy of DDSs' disability determinations. The director added
that staff could not yet respond electronically to SSA components that
requested information on a particular claim that had been processed in
their office. Further, in Nebraska, the DDS manager stated that that
office was in need of additional software modifications to provide the
functionality required to electronically import all required documents
into the electronic folder. Finally, the manager of the California DDS
stated that his office had lacked the capability to electronically
process nonmedical claims data that were required to be included in the
disability claims folders, such as a claimant's work history. The
manager stated that they also had lacked the functionality to
electronically refer claims to medical consultants for consultative
examinations.
In light of the operational and other concerns that have been
encountered in using the electronic disability system, coupled with
factors such as having to concurrently maintain paper and electronic
claims folders while awaiting certification, both SSA and DDS managers
acknowledged that the DDS offices had exercised wide discretion in
their use of the new system. The President of the National Council of
Disability Determination Directors stated that two key factors had
affected some DDSs' decisions about ramping up to full use of the
system: (1) concerns about a drop in productivity in a fully electronic
environment and (2) the instability of the electronic disability
processing environment, particularly in terms of system performance and
software reliability. In this regard, officials in eight DDS offices
that we contacted--all of which had implemented the electronic
disability system by the end of June[Footnote 17]--reported varying
levels of usage, as shown in table 2.
Table 2: Reported Use of the Electronic Disability System in Selected
DDS Offices as of Late June 2005:
Disability determination services office: North Carolina;
Implementation date: July 2003;
Actual/planned certification: January 2006;
Percentage of examiners using new system: 100%;
Percentage of initial disability cases being processed electronically:
100%.
Disability determination services office: Illinois;
Implementation date: September 2003;
Actual/planned certification: June 2005;
Percentage of examiners using new system: 100%;
Percentage of initial disability cases being processed electronically:
100%.
Disability determination services office: California;
Implementation date: October 2003;
Actual/planned certification: October 2005;
Percentage of examiners using new system: 100%;
Percentage of initial disability cases being processed electronically:
8%.
Disability determination services office: Mississippi;
Implementation date: January 2004;
Actual/planned certification: February 2005;
Percentage of examiners using new system: 100%;
Percentage of initial disability cases being processed electronically:
100%.
Disability determination services office: South Carolina;
Implementation date: March 2004;
Actual/planned certification: September 2005;
Percentage of examiners using new system: 100%;
Percentage of initial disability cases being processed electronically:
100%.
Disability determination services office: Florida;
Implementation date: September 2004;
Actual/planned certification: May 2006;
Percentage of examiners using new system: 31%;
Percentage of initial disability cases being processed electronically:
4-5%.
Disability determination services office: Delaware;
Implementation date: May 2005;
Actual/planned certification: November 2005;
Percentage of examiners using new system: 100%;
Percentage of initial disability cases being processed electronically:
19%.
Disability determination services office: Nebraska;
Implementation date: June 2005;
Actual/planned certification: June 2006;
Percentage of examiners using new system: 5%;
Percentage of initial disability cases being processed electronically:
4%.
Source: GAO analysis of SSA and DDS data.
Note: The last column represents initial disability cases being
processed electronically. However, as of late June 2005, California,
Florida, Delaware, Nebraska, and North Carolina had not yet received
all of the software they needed to be certified to perform exclusively
electronic processing.
[End of table]
Regarding the extent of their usage, managers in the Mississippi and
Illinois DDSs acknowledged that problems had been encountered following
their implementation of the electronic disability system but stated
that they had nonetheless chosen to expedite efforts to achieve full
electronic processing of disability claims in an attempt to minimize
the inefficiencies associated with having to maintain both paper and
electronic disability folders. Further, to help bring their states to
full electronic processing, the managers of the Mississippi and
Illinois DDSs stated that they had expended additional resources on
overtime pay to disability examiners and on additional support from the
software vendor to alleviate and/or establish workarounds for the
operational problems that their examiners had encountered. While
Mississippi officials said that they were unable to provide a dollar
amount for their overtime usage, an Illinois DDS official provided
documentation indicating that between September 2003 and May 2005, that
office had spent over $2 million on overtime, which assisted them in
processing disability claims in the electronic environment.
However, DDS managers in several other offices that we contacted stated
that, as a result of the problems with and the resulting
unpredictability of the electronic disability system, they had been
reluctant to bring the system to full use. They expressed reluctance to
increase their use of the system until a more reliable level of
performance has been sustained, stating generally that the current
problems with the system could hamper their ability to maintain their
productivity levels.
For example, officials in the California DDS told us that the
electronic disability system had not been used to fully process any of
the approximately 450,000 initial claims that the office had received
since it had implemented the system in October 2003.[Footnote 18] The
officials stated that they had chosen not to ramp up the system until
it proved to be more stable and all critical processing capabilities
had been delivered. The manager believed that trying to use the system
to process all of the office's initial disability claims before the
problems affecting their system's operations were resolved and before
all critical processing capabilities were delivered would prevent the
office from maintaining its productivity levels. In mid-July 2005,
California DDS officials stated that the vendor supporting their
disability claims processing system[Footnote 19] had recently provided
a software enhancement that gave them the capability to fully process
claims and that the agency would begin a phased increase in the number
of initial disability claims it would process in the electronic
environment. According to the manager, each examiner would initially be
assigned one disability case per week to process electronically.
In addition, in Florida, DDS officials stated that they had limited the
number of claims being processed by their disability examiners until
SSA was able to enhance their software to achieve better user
efficiency. As a result, at the time of our review, only 109 of the
office's 487 disability examiners were using the electronic system to
process cases, and only about 4 to 5 percent of initial disability
claims were being processed electronically. Further, while the Nebraska
DDS's electronic capabilities were implemented in late June 2005,
officials in that office stated that they did not plan to ramp up their
use of the system until about September 2005. They explained that,
lacking the software modifications required to electronically import
all documents into the electronic folder, the office was reluctant to
increase its use of the electronic disability system. They stated that
doing so would require them to commit additional resources to scan
documents that could not automatically be entered into the electronic
system. The officials added that they expect to receive additional
software modifications that they need to improve the efficiency of the
office's electronic processing capability in the September 2005 time
frame.
Given the current status of the electronic disability system, neither
SSA nor the state offices had yet been able to effectively assess or
quantify benefits resulting from its use. All of the managers of the
DDS offices that we contacted stated that they saw the potential for
realizing substantial claims processing improvements from using the
system; nonetheless, these managers--including the managers of the
Mississippi and Illinois DDSs--stated that it was too early to
determine whether and to what extent the electronic disability system
would contribute to processing improvements in their offices. In their
view, the system had not yet reached a level of maturity where it was
feasible to quantify the benefits of its use, due in large measure to
factors such as (1) the learning curve associated with using the
system; (2) current inefficiencies involved in having to maintain paper
folders until an office is certified to electronically process claims;
(3) certain DDSs' decisions to not fully utilize the system until
further problem resolution; and (4) certain offices' use of additional
resources, such as overtime and temporary hires, to support their
processing of claims following the system's implementation. The
managers added that processing claims electronically had thus far taken
longer and consumed more resources than before the electronic system
was implemented. In addition, because of ongoing system implementation
in the OHA sites, along with the normal processing delays associated
with bringing disability claims to the appeals stage, these sites had
not yet accrued enough experience in using the electronic folder to
make a reasonable assessment of processing improvements.
In speaking to the concerns that were raised about the reliability and
use of the electronic disability system, SSA officials acknowledged the
problems that had been identified by the DDSs, and that as a result,
current use of the system among those offices varied considerably.
However, these officials said they believed that the majority of the
DDS offices would be able to bring their systems to full use with only
a minimum of complications; they viewed California's concerns, in
particular, as not having been representative of other states'
experiences. Nonetheless, the officials said that the agency had
initiated a number of measures to address the problems that had been
encountered in using the system. For example, they stated that the
agency had established a new help desk to more readily support those
offices experiencing specific hardware and software problems while
using the electronic disability system. In addition, they stated that
SSA had assembled a work group to examine the DDSs' use of the
electronic forms, with the intent of determining whether a more
suitable commercial-off-the-shelf product was available that could
address the problems currently being encountered with these forms.
Regarding the size of the computer monitors that disability examiners
use, the officials stated that the agency planned to conduct a pilot
test to address concerns with and identify a solution for ensuring that
users have the monitors they need.
SSA's actions to address the outstanding concerns with its electronic
disability system represent a positive step toward achieving success in
the use of the new system. However, as of July 2005, the agency did not
have an overall strategy--articulating milestones, resources, and
priorities--to guide its efforts in efficiently and effectively
resolving the operational problems and system limitations being
experienced with the electronic disability system. For example,
although the agency had established a work group to explore options for
resolving problems being encountered with the electronic forms, it had
not yet established plans and a time frame for completing actions to
address this concern. In addition, although the agency planned to
conduct a pilot test of computer monitors, it did not yet have
essential information to determine what type of equipment would best
meet the needs of the electronic disability system users or the
resources and time that it would need to devote to resolving this
matter. Adequately resolving the concerns with and gaining full
acceptance and use of its electronic capabilities will be essential to
SSA's achieving a more efficient means of delivering disability
benefits payments to its increasing beneficiary population.
The Lack of Continuity of Operations Plans for the Electronic
Disability System Places Claims Processing at Increased Risk:
In addition to ensuring the immediate availability of the electronic
disability claims processing system by preventing operational problems
that could impact its performance and use, it is essential that SSA and
the DDSs have plans for mutually ensuring the continuity of this vital
disability benefits service in emergency situations. Federal law and
guidance require that agencies develop plans for dealing with emergency
situations involving maintaining services and protecting vital assets
that could result from disruptions, such as localized shutdowns due to
severe weather conditions, building-level emergencies, or terrorist
attacks.[Footnote 20] Moreover, this guidance notes, a key element in
developing a viable continuity capability is identifying
interdependencies among agencies that support the performance of
essential functions and ensuring the development of complementary
continuity of operations plans by those agencies that provide
information or data integral to the delivery of essential functions.
Such planning would include developing and documenting procedures for
continued performance of essential functions, identifying alternates to
fill key positions in an emergency and delegating decision-making
authority, and identifying vital electronic and paper records--along
with measures for ensuring their protection and availability.
However, SSA and the DDSs currently lack continuity of operations plans
to ensure that the DDS offices could continue to process disability
claims in the event of a short-or long-term disruption to the
electronic disability system. A September 2004 report, issued by SSA's
Acting Inspector General, noted that the agency's existing continuity
of operations plan did not address the information or the electronic
disability claims processing systems managed by the DDSs.[Footnote 21]
The report further noted that, in relying heavily on the DDSs, SSA
would lack certainty about the availability of information from these
offices in the event of a disaster. Based on its findings, the Acting
Inspector General recommended that SSA implement a complete and
coordinated continuity of operations plan for the agency.
Officials in the nine DDSs that we contacted further stated that their
offices had not developed continuity of operations plans covering the
electronic disability claims processing capabilities; yet, in
discussing this matter, officials considered such plans to be vital to
successfully ensuring the continued processing of disability claims.
Officials in the Mississippi DDS stressed, for example, that in the
event of a disruption to their system's communications with SSA's
headquarters computer facilities, disability examiners would be unable
to access the Document Management Architecture repository, send or
receive faxes via the electronic system, or access the electronic forms
they needed to support their work. In addition, they stated that
medical examiners would be unable to perform tasks in support of
disability determinations.
In discussing this matter, SSA officials acknowledged that their
existing plan had not addressed the electronic claims processing
functions of the DDSs. They stated that the agency had recently
initiated actions to help resolve this limitation by having a
contractor develop a business continuity planning strategy. According
to the officials, the contractor began work on this strategy in May
2005 and is expected to deliver an initial report in September 2005.
However, the officials did not articulate the agency's specific plans
or a time frame for ensuring that its continuity of operations plan
addresses the electronic claims processing functions of the DDS offices
or for ensuring that these offices develop and implement complementary
plans for continuing essential functions to support the disability
claims process in an emergency situation.
As SSA moves toward full implementation and use of the electronic
disability system, the capability to continue essential electronic
disability claims processing functions in any emergency or situation
that may disrupt normal operations becomes increasingly important. In
view of the fact that three states have already begun using electronic
folders as official disability claims records, it is imperative that
both SSA and the DDSs have plans that address the state systems'
interdependencies with the electronic disability claims processing
components and that include preparations for continuing to provide
critical claims processing services in the event of a disaster. Without
continuity of operations plans, SSA will lack assurance that it is
positioned to successfully sustain the essential delivery of disability
benefits during unforeseen circumstances.
SSA's Actions toward Implementing AeDib Have Addressed Some, but Not
All, of Our Prior Recommendations for Improvement:
As discussed earlier, in reporting on this initiative in March 2004, we
recommended that the agency take measures to reduce the risks
associated with its electronic disability strategy before continuing
with its national rollout of this capability. These recommendations
called for the agency to (1) resolve critical problems that it had
identified in pilot testing of the electronic disability system and
conduct end-to-end testing of the interrelated system components, (2)
ensure that users approved the software being developed and that
systems were certified for production, (3) finalize AeDib risk
mitigation strategies, (4) validate AeDib cost and benefit estimates,
and (5) improve communications with and effectively address the
concerns of disability stakeholders and users involved in the
initiative.
In proceeding with the implementation of its electronic disability
system, SSA has taken actions related to three of the five
recommendations. Specifically, SSA officials provided evidence
indicating that the agency has taken measures to ensure that users
approve new software and that it certifies its systems for production.
For instance, we reviewed agency documentation reflecting disability
system users' approval of new software and SSA's certification of over
50 cases where software was put into production from February 2004
(shortly after the national rollout of the electronic disability system
began) through October 2004. By continuing to validate its software and
certify its systems, SSA should be able to better ensure that its
systems are ready for production and will be acceptable to their end
users.
In addition, regarding our recommendation that it validate AeDib cost
and benefit estimates, SSA has initiated studies, including quarterly
evaluations of the initiative, that could help it assess the electronic
disability system's performance, costs, and processing times. The
agency also has plans for conducting post-implementation reviews of the
system, which include comparing baseline and current information to
evaluate the system's impact on performance, productivity, and cost--
measures that if implemented fully and effectively could help validate
AeDib's costs and benefits.
Further, although the agency has not implemented a communications plan,
DDS officials, including the President of the National Council of
Disability Determination Directors, told us that SSA had improved its
communications with these offices and had made progress in including
DDS officials in AeDib decision making. Such action reflects a positive
move toward involving stakeholders in the agency's efforts.
Nonetheless, we continue to advocate the importance of having a clear
and comprehensive plan for communicating with stakeholders to sustain
vital user acceptance and achieve full use of the electronic disability
system.
However, SSA did not demonstrate any actions on two of the
recommendations. As we previously noted, SSA did not take steps to
resolve all of the critical problems that had been identified during
pilot testing of the Document Management Architecture or to conduct end-
to-end testing of the interrelated electronic disability system
components before continuing with the national rollout of this system.
Resolving all critical problems and conducting end-to-end testing of
the interrelated system components prior to their implementation could
have limited the problems that SSA and the DDSs have encountered with
the electronic disability system's operation. In the absence of such
testing, as SSA moves to achieve certification and full use of the
system, it will be essential that the agency work diligently to
identify and alleviate the problems that could impact the successful
outcome of this technically complex initiative.
Further, while our earlier work noted that the agency had identified
the risks associated with the AeDib initiative and the related
automation projects, SSA has not provided any evidence that it has yet
completed risk mitigation strategies for these projects. Best practices
and federal guidance advocate risk management--including mitigation
strategies--to reduce risks and achieve schedule and performance
goals.[Footnote 22] Among the high-level risks identified, SSA noted
that the overall availability of the Document Management Architecture
might not meet service-level commitments to its users. Because the DDSs
could not effectively perform their work if the data repository or
document scanning and imaging capabilities provided by the architecture
were not available, it is critical that SSA have mitigation strategies
in place to reduce this risk and to help ensure that the DDSs can meet
their performance goals. In the continued absence of risk mitigation
strategies, the agency lacks a critical means of ensuring that it can
prevent circumstances that could impede a successful project outcome.
Conclusions:
SSA is relying on its electronic disability system to play a vital role
in improving service delivery to disabled individuals under its
disability programs, and the agency has made considerable progress in
implementing this system. However, even as the agency moves closer to
achieving full systems implementation, important work still needs to be
accomplished to ensure the system's success. Among the agency's
critical tasks will be certifying that all of the SSA and state DDS
offices are prepared to process all disability claims electronically.
Yet, a number of DDSs have concerns about the operations and
reliability of the electronic disability system, noting, for example,
inadequacies in electronic forms and the computer monitors used to view
claims information, as well as limitations in electronic processing
capabilities--factors that they say have slowed system performance and
impeded their productivity, and that have resulted in the levels of
system usage varying among the DDSs. Further, as the agency moves to
complete the system's implementation, it will be essential that SSA and
the DDSs have plans for mutually ensuring the continuity of this vital
disability benefits service in emergency situations. The absence of a
defined strategy or plans for ensuring that the electronic disability
system will operate and will meet users' needs as intended could
threaten the continued progress and success of this initiative and make
it uncertain when the agency will realize the full benefits of the
AeDib initiative.
Recommendations for Executive Action:
To further reduce the risks to SSA's progress in successfully achieving
its electronic disability claims processing capability, we recommend
that the Commissioner of Social Security take the following two
actions:
* develop and implement a strategy that articulates milestones,
resources, and priorities for efficiently and effectively resolving
problems with the electronic disability system's operations, including
(1) identifying and implementing a solution to improve the use of
electronic forms, (2) identifying and implementing a solution to
address concerns with existing computer monitors, and (3) ensuring that
the DDSs have the necessary software capabilities to fully and
efficiently process initial claims in the electronic processing
environment; and:
* ensure that the state DDSs develop and implement continuity of
operations plans that complement SSA's plans for continuing essential
disability claims processing functions in any emergency or other
situation that may disrupt normal operations.
Agency Comments and Our Evaluation:
In written comments on a draft of this report, the Commissioner of
Social Security expressed concern about our references to the agency's
testing of its electronic disability system and offered additional
views regarding our discussion of the state disability determination
services' use of overtime to assist in electronically processing
disability claims. In addition, the agency disagreed with one of our
recommendations and agreed with the other.
Regarding the testing of its electronic disability system, SSA
questioned why our report had concluded--months after the agency's
rollout of the system--that performing end-to-end testing of the
interrelated system components was still critical to the initiative's
success. The agency believed that we should delete references to the
criticality of such testing for this initiative so as not to lend
confusion to and cast doubt on its rollout experience.
In discussing SSA's decision not to conduct end-to-end testing before
rolling out the electronic disability system, our report responds to
one of the two stated objectives of our study--to determine the actions
that SSA has taken in response to our prior recommendations on the
AeDib initiative. In doing so, we did not conclude that it remains
critical for SSA to perform end-to-end testing at this stage in the
system's implementation. Rather, in speaking to this issue, we
described the agency's response to our prior recommendation that it
conduct end-to-end testing before proceeding with the national roll
out, and we emphasized the importance of such testing as a means of
limiting the types of problems that DDS officials told us they have
encountered with the system's operation. As our report stresses, in the
absence of end-to-end testing, it is essential that SSA remain diligent
in identifying and alleviating the problems that could impact the
successful outcome of the AeDib initiative as the agency moves to
achieve full certification and use of the electronic disability system.
Concerning the DDSs' reported cost and use of overtime, SSA emphasized
its belief that a number of factors other than the electronic
disability system had contributed to the Illinois DDS's increased use
of overtime. For example, the agency said that overtime had been used
to compensate for the loss of DDS employees that had accepted the
state's offer of early retirement. Based on our discussions with
Illinois DDS officials, we understand that the office may not have used
overtime solely to support its electronic processing of disability
claims. However, as noted in our report, the Illinois officials told us
that they had relied on overtime to assist in bringing their office to
full electronic processing of disability claims using the new system.
We have included language in the report to more clearly reflect this
point.
Beyond these points of discussion, SSA disagreed with our
recommendation that they develop and implement a strategy that
articulates milestones, resources, and priorities for efficiently and
effectively resolving problems with the electronic disability system's
operations, including (1) identifying and implementing a solution to
improve the use of electronic forms, (2) identifying and implementing a
solution to address concerns with existing computer monitors, and (3)
ensuring that the DDSs have the necessary software capabilities to
fully and efficiently process initial claims in the electronic
processing environment. Specifically, the agency stated that it had
substantially improved its electronic forms and already has a strategic
project plan to address residual issues concerning them. It noted that
a work group established in January 2005 had examined this issue and
that many key recommendations had been adopted to improve the
performance of and customer satisfaction with the electronic forms. SSA
added that it is using a contractor to examine alternatives and
determine if more robust software is available to better meet users'
needs, and that it may incorporate new software into the electronic
disability claims process.
Our report recognized that SSA had established a work group to explore
options for resolving problems with the electronic forms. However,
during our study, SSA officials could not provide a time table for the
work group's efforts and, despite our inquiries, gave no indication
that the agency had a defined strategy for addressing this area of
concern. Further, SSA did not inform us of a specific contract to
examine software alternatives or of the specific recommendations that
have been made to correct problems with the forms and the improvements
in performance and customer satisfaction that have been achieved. Thus,
we did not have an opportunity to evaluate and comment on the agency's
actions in this regard. Given the DDSs' expressed concerns about the
electronic forms throughout the course of our study and as reflected in
SSA's own quarterly evaluation of the electronic disability system, we
continue to stress the importance of SSA developing and implementing a
strategy to guide its efforts toward efficiently and effectively
resolving problems with this important electronic capability.
Regarding its existing computer monitors, SSA stated that it already
has a plan in place to evaluate this issue and potential ergonomic
solutions. The agency stated that it had awarded a contract to conduct
a controlled test of the impact of various monitor configurations on
ergonomics and productivity for all primary users of the electronic
disability system, and that a final report is due in January 2007. It
added that when final decisions are made regarding the appropriate
monitor requirements, a business plan will be deployed if warranted. As
noted in our report, SSA officials did inform us of their intent to
conduct a pilot test to identify potential solutions for ensuring that
users have appropriate monitors. However, the officials could not
provide contractual and other pertinent documents explaining the pilot
study and did not inform us of any plan that the agency had developed
to guide this effort. Given that SSA does not anticipate its final
report on its test of the monitor configurations until January 2007,
and does not intend to consider the deployment of a business plan until
final decisions are made regarding the monitor requirements, we believe
that the agency could benefit from a strategy articulating clear
milestones, resources, and priorities to guide its efforts toward
finalizing decisions on its computer monitors and ensure that all
users' concerns are fully and effectively addressed.
Further, regarding the DDSs' software capabilities, SSA stated that it
had established a help desk to provide support for specific hardware
and software issues associated with the electronic disability system,
and that it had no information that there are outstanding issues
concerning DDS software support. Moreover, the agency stated that our
report had inaccurately described supposed issues related to
implementing the electronic disability system in light of some states
having not yet been certified to fully process cases electronically.
For example, SSA commented that because Florida had not yet been
certified to fully process cases electronically, it was premature to
expect that the electronic disability system would notify staff of
actions to process claims. Similarly, SSA stated that because Nebraska
had not been certified to process cases electronically, it was
premature to indicate that the state needed additional software
modifications to electronically import all required documents into the
electronic folder. Further, the agency said that it was inaccurate for
us to report that the North Carolina DDS lacked the necessary software
to enable staff to electronically send claim files to SSA's Disability
Quality Branch, since all but two states--New York and Nebraska--had
this software. It added that the agency's planning and electronic
disability system roll out had addressed software capabilities and
other issues impacting individual DDSs, negating the need for a formal
strategy, as we have recommended.
We disagree that our report inaccurately described issues related to
implementing the electronic disability system or that it prematurely
highlighted limitations in certain states' use of the system. A primary
aspect of our review involved examining SSA's progress in rolling out
the electronic disability system, including the state DDSs' experiences
in implementing and using the system. In this regard, DDS officials
apprised us of their electronic disability claims processing
capabilities, and in certain instances, of their need for additional
software capabilities that they deemed essential to improving their
offices' processing efficiency and sustaining productivity in the
electronic environment. As of mid-July 2005, North Carolina DDS
officials told us that they lacked the necessary software to enable
staff to electronically send claim files to SSA's Disability Quality
Branch. We recognize that SSA does not expect to complete all states'
certifications until early 2007. However, in our view, until the agency
ensures that all DDSs have full electronic processing capabilities, it
will not be positioned to effectively assess the extent to which the
electronic disability system can contribute to a more efficient and
effective disability claims process.
SSA further stated that system availability issues had been addressed,
as evidenced by its current fiscal year data on key electronic
disability system components (e.g., the Electronic Disability Collect
System, the Case Processing Management System, and the Document
Management Architecture). However, our report does not convey that
these key electronic disability system components were not available
for use. Rather, the concerns discussed in our report pertain to the
inefficiencies that DDS officials said they had encountered in using
the electronic disability system. For example, DDS officials pointed to
the continuing instances in which they had experienced processing
slowdowns when using electronic forms, which ultimately had impeded
their disability claims processing capability. Thus, we stand by our
recommendation that SSA develop and implement a strategy to ensure that
the DDSs have the necessary software capabilities to fully and
efficiently process claims in the electronic environment.
Regarding our second recommendation, the agency agreed to ensure that
the state DDSs develop and implement continuity of operations plans
that complement SSA's plans for continuing essential disability claims
processing functions during emergencies or other disruptions to normal
operations. In this regard, the commissioner stated that SSA is highly
committed to providing uninterrupted services to the public and had
hired a contractor to develop business continuity plans for the DDSs
that document how these offices would respond to long-and short-range
disruptive events. The actions that SSA stated that it is taking should
help improve the agency's and the DDSs' ability to ensure the
continuity of vital disability benefits services in emergency
situations.
In addition to the aforementioned comments, SSA provided technical
comments, which we have incorporated, as appropriate. Appendix II
reproduces the agency's comments on our draft report.
As agreed with your office, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies of this report
to the Commissioner of Social Security and the Director, Office of
Management and Budget. Copies will also be available at no charge on
our Web site at [Hyperlink, http://www.gao.gov].
Should you have any questions on matters contained in this report,
please contact me at (202) 512-6240. I can also be reached by email at
[Hyperlink, koontzl@gao.gov]. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last
page of this report. Key contributors to this report are listed in
appendix III.
Sincerely yours,
Signed by:
Linda D. Koontz:
Director, Information Management Issues:
[End of section]
Appendixes:
Appendix I: Objectives, Scope, and Methodology:
Our objectives were to (1) assess the current status of SSA's
accelerated implementation of its electronic disability system--the
initiative known as AeDib and (2) identify actions the agency has taken
in response to our prior recommendations on this initiative. To assess
the agency's status in implementing its electronic disability system,
we analyzed relevant project management documentation including
schedules, project plans, and reports documenting the status of the
system's rollout to the 54 state disability determination service (DDS)
offices and SSA's 144 Office of Hearings and Appeals (OHA) sites. In
addition, we reviewed technical documentation, such as software project
scope agreements and software development plans, to assess the
development, implementation, and operation of the electronic disability
system. We also reviewed system release certifications to ensure that
systems had been validated and certified.
To identify issues that arose during the AeDib implementation process,
we reviewed problems reported by the DDSs via SSA's Change Asset
Problem Reporting System. We also reviewed the results of the National
Council of Disability Determination Directors' February 2005 survey of
its member DDS offices on their experiences in implementing the
electronic disability system, as a means of identifying any problems
and issues that the states had encountered. In addition, we reviewed
reports on the system's implementation, performance, and capacity that
had been prepared by the Council and the DDSs.
We supplemented our analysis with interviews of SSA officials in the
Offices of Operations, Systems, Disability and Income Security
Programs, and Hearings and Appeals. We also interviewed DDS officials
in nine states: California, Delaware, Florida, Illinois, Mississippi,
Nebraska, New York, North Carolina, and South Carolina. In addition, we
interviewed the President of the National Council of Disability
Determination Directors, an organization that represents the DDSs.
Our selection of the nine states was based on the following criteria:
* The Mississippi DDS was the first state to which the electronic
disability system was rolled out, as well as the first state to achieve
total electronic processing of initial disability cases.
* The California, Illinois, and North Carolina DDSs had participated in
initial pilot tests of the electronic processing system, which had
included assessing use of the Document Management Architecture.
* The Florida and South Carolina DDSs were states that received the
electronic disability system early in the implementation schedule.
* The New York and Nebraska DDSs posed potential unique challenges as
the only two "independent" states, in which their existing claims
processing capabilities were not supported by the common hardware
platform that the majority of DDSs used and that had developed and were
relying on disability claims processing software that was unique to
their processing environments.
* The Delaware DDS was managed by the President of the National Council
of Disability Determination Directors.
We conducted site visits at two DDSs--Mississippi and South Carolina--
to observe the electronic processing system in operation, and at OHA
sites in these same states to discuss their experiences in implementing
and using the electronic folder and their preparation for receiving
appeals of initial claims that had been processed electronically in the
respective state DDS offices.
To determine what actions SSA had taken toward implementing our prior
recommendations on the electronic disability system, we obtained and
reviewed software project scope agreements, software development plans,
user validation and system certification plans, and AeDib component
security risk assessment documentation. We also interviewed agency
officials regarding the status of their actions on each of the
recommendations made in our March 2004 report on AeDib. In addition, we
discussed SSA's efforts to improve communications on the initiative's
implementation with DDS officials in each of the offices that we
contacted and with the President of the National Council of Disability
Determination Directors.
We conducted our work at SSA's headquarters in Baltimore, Maryland, and
at selected DDS and OHA offices in Jackson, Mississippi, and Columbia,
South Carolina, from October 2004 to July 2005, in accordance with
generally accepted government auditing standards.
[End of section]
Appendix II: Comments from the Social Security Administration:
SOCIAL SECURITY:
The Commissioner:
September 6, 2005:
Ms. Linda Koontz:
Director, Information Management Issues:
U.S. Government Accountability Office:
Room 4-T-21:
441 G Street, NW:
Washington, D.C. 20548:
Dear Ms. Koontz:
Thank you for the opportunity to review and comment on the draft report
"ELECTRONIC DISABILITY CLAIMS PROCESSING: SSA Is Proceeding with Its
Accelerated Systems Initiative but Needs to Address Operational Issues"
(GAO-05-97). Our comments on the report are enclosed.
If you have any questions, please have your staff contact Candace
Skurnik, Director, Audit Management and Liaison Staff at (410) 965-
4636.
Sincerely,
Signed by:
Jo Anne B. Barnhart:
Enclosure:
COMMENTS ON THE GOVERNMENT ACCOUNTABILITY OFFICE (GAO) DRAFT REPORT
"ELECTRONIC DISABILITY CLAIMS PROCESSING: SSA IS PROCEEDING WITH ITS
ACCELERATED SYSTEMS INITIATIVE BUT NEEDS TO ADDRESS OPERATIONAL ISSUES"
(GAO-05-97):
We appreciate the opportunity to comment on the GAO draft report. We
also appreciate that the report acknowledges SSA's positive steps to
more efficiently process applications for benefits and supporting
evidence. However, we are somewhat puzzled as to why the GAO report
concludes--months after SSA's successful rollout--that performing end-
to-end testing prior to e-Dib rollout is still critical to the
initiative's success.
Clearly, this GAO conclusion is not supported by our experience. SSA's
rollout experience reflects a reasoned, deliberate process. SSA managed
the accelerated eDib initiative in a careful, prudent manner with high-
level management attention to all facets of the claims process. The
planning process developed detailed plans for achieving objectives,
identification and mitigation of risks, and consultation with the State
DDSs concerning their systems. Frequent meetings and planning sessions
provided ongoing evaluation of the initiative's progress and any newly-
identified issues. To ensure an independent assessment of potential
risks, SSA employed a contractor to identify potential risks as the
project moved forward. SSA's implementation included the establishment
of an Acceptance Testing Environment that allowed us to evaluate the
eDib procedures and systems. SSA's considerable experience in
developing and integrating software into existing software processes
allowed the agency to minimize potential risks, while avoiding up to a
two-year delay if end-to-end testing were exercised before
implementation.
Therefore, we believe that GAO should delete references to the belief
that end-to-end testing is critical to the initiative's success.
Including this conclusion will only confuse stakeholders who may read
the report by casting doubt on the reasoned, deliberate planning
process that SSA employed.
Concerning the Illinois DDS's overtime cost and use for the period
between September 2003 and May 2005, we believe a number of factors
other than eDib contributed to the increase in overtime use beginning
in the middle of fiscal year (FY) 2003. Over 50 DDS employees accepted
the State offer of early retirement in FY 2003, with most leaving in
January 2003. A State hiring freeze delayed the replacement of many of
these employees and overtime compensated for some of these losses.
The national DDS budget made overtime more readily available in FYs
2004 and 2005 than in some previous years, and Illinois was able to
take advantage of additional overtime. Overtime was used to supplement
their clerical resources as well as their examiner resources. In FY
2005, we encouraged all of the DDSs to maximize effective overtime use
to work toward the initial claims pending reduction goal, and Illinois
made excellent use of their overtime, both reducing their pending and
achieving high productivity.
SSA recognizes the importance of addressing systems issues. A help desk
has been established to provide support for specific hardware and
software issues associated with the electronic disability system and we
have contracted for services to monitor capacity of the computers'
processors. We think many of the electronic forms processes will be
enhanced as DDSs are retrofitted with Versa 7.0 or Levy 8.0 software.
The retrofitted software will ensure the DDSs have the necessary case
processing software to process initial claims electronically.
In addition, to identify and implement solutions to address concerns
with computer monitors, SSA has initiated several contracts to study
ergonomic issues in the eDib environment. We believe these studies will
provide the necessary data to determine the appropriate monitors that
should be used in the electronic process. In addition to these studies,
we are piloting the use of two monitors to address the issue with
monitor size.
With respect to the recommendations, we have addressed issues related
to eForms resulting in greatly improved performance. We are in the
process of studying various monitor configurations to determine what
would work best for users of eDib at all of the various stages. We have
worked closely with the DDSs to address their needs and to assist them
in adapting to the changes involved in the new process. We are
currently developing--with contractor assistance--a plan to build upon
existing Business Continuity plans for the DDS community. We have
achieved all of our very challenging goals within short timeframes and
continue to realize further enhancements as we rollout the process to
all levels of the eDib process. We are very proud of our continuing
success.
Our responses to the specific recommendations are as follows:
Recommendation 1:
"Develop and implement a strategy that articulates milestones,
resources, and priorities for efficiently and effectively resolving
problems with the electronic disability system's operations, including
(1) identifying and implementing a solution to improve the use of
electronic forms, (2) identifying and implementing a solution to
address concerns with existing computer monitors, and (3) ensuring that
the DDSs have the necessary software capabilities to fully and
efficiently process initial claims in the electronic processing
environment."
Response:
We disagree.
eForms:
SSA already has a strategic project plan that addressed or addresses
residual issues concerning electronic forms. Since the onset of the
eDIB rollout, SSA has substantially improved eForms. A workgroup formed
in January 2005 examined the issues and conducted site visits to
several DDSs. Subsequently, many key recommendations were adopted and
have improved performance and customer satisfaction with eForms
significantly.
In addition, SSA is looking at alternatives to the commercial off-the-
shelf software that was originally used for eForms rollout. A
contractor is examining the existing market to determine if new, more
robust software is available to better meet user needs and to improve
overall performance. As a result, SSA may incorporate new software into
the eDib process.
Computer Monitors:
SSA already has a plan in place to evaluate the monitor issue and
potential ergonomic solutions. SSA awarded a contract to conduct a
controlled test of the impact of various monitor configurations on
ergonomics and productivity for all of the primary users of eDib. This
study responds to the concerns raised about working with a single
monitor. The study will involve 135 - 230 individuals employed in 15 to
20 different positions in the Office of Central Operations, Office of
Quality Assurance and Performance Assessment, Office of Hearings and
Appeals, Field Offices and the State DDSs. A final report is due in
January 2007. When final decisions are made regarding the appropriate
monitor requirements, a business plan, if warranted, will be deployed.
Software Capabilities:
We have no information that there are outstanding issues concerning DDS
software support. SSA's planning and eDib rollout addressed software
capabilities and other issues impacting individual DDSs, negating the
need for developing a formal strategy plan. As the report notes, SSA
established a help desk that catalogs and monitors fixes through
amelioration.
For example, system availability issues have been addressed as
evidenced by current figures. Systems availability for the current
fiscal year is 99.66 percent for the Electronic Disability Collect
System, 99.74 percent for the Case Processing Management System and
98.54 percent for the Document Management Architecture. These figures
take into account local outages on individual components such as a fax
server, as well as enterprise-wide outages.
The report inaccurately describes supposed issues implementing eDib.
For example, Florida has not yet been certified to work cases fully
electronically. Therefore, it is premature to expect that the system
would notify staff of the actions to process claims. It is inaccurate
to state that the North Carolina DDS lacked the necessary software to
enable staff to electronically send claims files to SSA's Disability
Quality Branch. All DDSs, except New York and Nebraska, have the
functionality that allows for electronic selection and transmission of
claims for quality review by the SSA Disability Quality Branch.
Nebraska also has not been certified to work cases electronically.
Thus, it is premature to indicate that it needs additional software
modifications to electronically import all required documents into the
electronic folder. Nonetheless, Nebraska is currently scanning the
required documents into the Electronic Folder and, in November, they
will be provided the functionality to input documents into the
Electronic Folder. In California, scanning with a generated barcode has
always been available. Moreover, the California legacy system has the
ability to electronically refer claims to medical consultants.
Recommendation 2:
"Ensure that the state DDSs develop and implement continuity of
operations plans [COOP] that complement SSA's plans for continuing
essential disability claims processing functions in any emergency or
other situation that may disrupt normal operations."
Response:
We agree.
The agency is highly committed to provide uninterrupted services to the
public. We work with the State DDSs to provide guidance in developing
COOP. The most recent updates to the DDS Security Handbook (which
contains security guidelines for the State DDSs) were issued to the
DDSs September 12, 2003. According to these guidelines, each DDS is
responsible for documenting all local DDS emergency plans and
procedures involved in the event of a disruption of DDS functions,
including the disaster recovery plans. The handbook includes
instructions for DDS contact with the regional office, a list of
instructions for employees and contractors to follow in the event of an
emergency (e.g., emergency evacuation plans), line of
succession/delegation of authority (e.g., names, phone numbers,
responsibilities), and a flowchart of workloads/workflows, etc.
Disaster recovery is part of the overall COOP plan.
In addition, SSA has contracted with Booz Allen Hamilton to further
develop Business Continuity plans for the DDSs that will document how
to respond to both short and long-term disruptive events. The plan will
include arrangements and procedures for responding to a disruption,
recovering interrupted procedures and continuing business operations.
While a formal disaster recovery document for DDS electronic systems
does not exist, disaster recovery has been part of SSA's planning
process since the advent of eDib. In July 2005, SSA and the Florida DDS
successfully performed a comprehensive disaster recovery drill. The
drill involved having the Florida DDS deactivate their IBM iSeries
processor in their administrative site in Tallahassee and log on
remotely from each of the Florida branch offices to SSA's backup and
recovery iSeries in the National Computer Center. Three disability
cases were fully processed from receipt to closure in each of the
branch offices. SSA plans to test this concept in more DDSs in fiscal
year 2006 with different scenarios to include a centralized DDS and
other DDS software vendors. With regard to disaster recovery for DDS
electronic systems, SSA is currently reviewing the results of the
Florida drill and will use these results as a basis for developing a
general Disaster Recovery document for DDS systems.
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
Linda D. Koontz (202) 512-6240:
Staff Acknowledgments:
In addition to the individual named above, Valerie C. Melvin, Assistant
Director; Michael A. Alexander; J. Michael Resser; and Eric L. Trout
made significant contributions to this report. Neil J. Doherty and
Joanne Fiorino also contributed to the report.
(310726):
FOOTNOTES
[1] GAO, Electronic Disability Claims Processing: SSA Needs to Address
Risks Associated with Its Accelerated Systems Development Strategy, GAO-
04-466 (Washington, D.C.: Mar. 26, 2004).
[2] The data repository and the capability to scan images, documents,
and forms that previously have been contained in paper folders comprise
the Document Management Architecture infrastructure project. This
system will enable disability-related information to be viewed and
shared electronically by all disability processing components and is a
fundamental element needed to achieve the electronic folder processing
environment.
[3] The electronic folder interface software is electronically linked
to the claims processing system and allows for the transfer of data
between the electronic folder and the Document Management Architecture
data repository. The electronic folder is an information storage system
that electronically houses claimant information and medical evidence
previously maintained in the paper folder (for example, data, images,
and forms).
[4] GAO, Major Management Challenges and Program Risks: Social Security
Administration, GAO-03-117 (Washington, D.C.: January 2003).
[5] Nationwide, about 2.6 million initial disability claims were filed
in fiscal year 2004.
[6] SSA maintains 144 Office of Hearings and Appeals (OHA) sites.
[7] Nonmedical eligibility criteria may include an individual's age,
employment, marital status, or Social Security coverage information.
[8] The 10-year life of the AeDib initiative covers the time frame from
2002 through 2011.
[9] Conceptually, the Electronic Disability Collect System and Document
Management Architecture provide the capability to hold an aggregation
of both the structured and unstructured data so that all of a
claimant's information can be organized in a virtual folder and then
viewed collectively and shared electronically. A virtual folder is a
type of folder that is dynamically assembled at the time of the
request. The virtual folder may represent a subset of a static folder
or a cross-section of static folders.
[10] The majority of DDSs use standard claims processing systems that
are provided by three sources: iLevy, Versa, and MIDAS. Two DDSs--
Nebraska and New York--use systems developed by their own offices.
[11] GAO-04-466.
[12] Three states included in the national roll-out--North Carolina,
Illinois, and California--actually began their implementation of the
Document Management Architecture as part of SSA's pilot tests of this
technology in 2003.
[13] SSA also interfaced the electronic disability system with
Nebraska's independent disability claims processing system, although
Nebraska's system included fewer automated capabilities than did New
York's system. This action was completed as scheduled in late June
2005.
[14] An initial disability claim is one that is filed for the first
time by a disability claimant, versus, for example, reconsiderations
and continuing disability reviews of claims that have already been
decided.
[15] The seven states are Mississippi, Illinois, Hawaii, South
Carolina, Missouri, Wyoming, and Nevada.
[16] Some of the electronic forms used by the DDSs include the
Disability and Determination Transmittal Form (SSA Form 831) and the
Authorization to Disclose Information to the Social Security
Administration (SSA Form 827).
[17] The New York DDS had not yet implemented the electronic disability
system.
[18] The California DDS was one of the three offices where SSA had
initially piloted the Document Management Architecture hardware and
software in 2003. Its implementation of the Document Management
Architecture was completed in September 2004.
[19] California uses MIDAS software, which is supported by SSA.
[20] Federal Information Security Management Act of 2002, P. L. 107-
347, Title III, Sec. 301, 44 U.S.C. §3544(b) (8), Presidential Decision
Directive 67, Enduring Constitutional Government and Continuity of
Government Operations, October 21, 1998.
[21] Fiscal Year 2004 Evaluation of the Social Security
Administration's Compliance with the Federal Information Security
Management Act, September 30, 2004 (A-14-04-14040).
[22] Software Acquisition Capability Maturity ModelSM (CMU/SEI-99-TR-
002, April 1999); OMB Circular A-130 (November 30, 2000).
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