Report to the Chairman, Subcommittee 

on Social Security, Committee on Ways 

and Means, House of Representatives 

United States General Accounting Office 

GAO 

January 2004 SOCIAL SECURITY 

ADMINISTRATION 

Strategic Workforce 

Planning Needed to 

Address Human 

Capital Challenges 

Facing the Disability 

Determination 

Services 

GAO-04-121 
GAO found—through its survey of 52 of the 54 Disability Determination 

Service (DDS) directors and interviews with SSA officials and DDS staff—

that the DDSs face three key challenges in retaining examiners and 

enhancing their expertise: 

High turnover: Over half of all DDS directors surveyed said that examiner 

turnover was too high in their offices. We found that examiner turnover was 

about twice that of federal employees performing similar work. Nearly twothirds of all directors reported that turnover has increased SSA’s hiring and 

training costs and claims-processing times. And two-thirds of all directors 

cited stressful workloads and noncompetitive salaries as major factors that 

contributed to turnover. 

Recruiting and hiring difficulties: More than three-quarters of all DDS 

directors said they had difficulties over a three-year period in recruiting and 

hiring examiners. Of these, more than three-quarters said these difficulties 

contributed to increases in claims-processing times, examiner caseload 

levels, backlogs, and turnover. More than half of all directors reported that 

state-imposed compensation limits contributed to hiring difficulties. 

Gaps in key skills: Nearly one-half of all DDS directors said that at least a 

quarter of their examiners needed additional training in areas critical to 

disability decision-making. Over half of all directors cited factors related to 

high workload levels as obstacles to examiners’ receiving additional training.

Despite the workforce challenges facing them, a majority of DDSs do not 

conduct long-term, comprehensive workforce planning. In prior reports, 

GAO found that such planning should include key strategies for recruiting, 

retaining, training, and otherwise developing a workforce capable of meeting 

long-term agency goals. However, of the DDSs that engage in longer-term 

workforce planning, a majority have plans that lack such key workforce 

planning strategies. Directors cited numerous obstacles to long-term 

workforce planning, such as lengthy state processes to approve DDS human 

capital changes. 

SSA’s workforce efforts have not sufficiently addressed current and future 

DDS human capital challenges. Federal law requires agencies to include in 

their annual performance plans a description of the human capital strategies 

needed to meet their strategic goals. However, GAO’s review of key SSA 

planning documents shows they do not include a strategic human capital 

plan that addresses current and future DDS human capital needs. Thus, SSA 

does not link its strategic objectives to a workforce plan that covers the very 

people who are essential to accomplishing those objectives. GAO also found 

that SSA has not provided human capital assistance in a consistent manner 

across the DDSs and that SSA’s effectiveness in helping the DDSs negotiate 

human capital changes with the states can be limited by such factors as state

budget problems and personnel rules. Finally, SSA has not used its authority 

to establish uniform human capital standards, such as minimum 

qualifications for examiners, which would address, on a nationwide basis, 

some of the DDS challenges.

SSA oversees and fully funds 

primarily state-operated DDSs that 

determine whether applicants are 

eligible for disability benefits. The 

disability examiners employed by 

the DDSs play a key role in 

determining benefit eligibility. This 

report examines (1) the challenges 

the DDSs face today in retaining 

and recruiting examiners and 

enhancing their expertise; (2) the 

extent to which the DDSs engage in 

workforce planning and encounter 

obstacles in doing so; and (3) the 

extent to which SSA is addressing 

present and future human capital 

challenges in the DDSs. 

While acknowledging the 

difficulties SSA faces in addressing 

DDS human capital issues within 

the federal-state context, GAO 

recommends that SSA improve its 

workforce planning by: 

• Developing a nationwide 

strategic workforce plan that 

addresses present and future 

DDS human capital challenges; 

• Establishing uniform minimum 

qualifications for examiners; and 

• Working with DDSs to close gaps 

between current and required 

examiner skills.

In its comments, SSA generally 

agreed with our recommendations’ 

intent but said that we did not 

fairly or adequately address the 

many sides of DDS human capital 

management issues. We continue 

to believe that the report is fair and 

balanced and that our scope and 

methods allowed us to adequately 

address these issues. 

www.gao.gov/cgi-bin/getrpt?GAO-04-121.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Robert E. 

Robertson at (202) 512-7215 or 

Robertsonr@gao.gov. 

Highlights of GAO-04-121, a report to the 

Chairman, Subcommittee on Social 

Security, Committee on Ways and Means, 

House of Representatives 

January 2004

SOCIAL SECURITY ADMINISTRATION

Strategic Workforce Planning Needed to 

Address Human Capital Challenges 

Facing the Disability Determination 

Services 
Page i GAO-04-121 Social Security Administration 

Letter 1

Results in Brief 4

Background 7

DDSs Face High Turnover, Recruiting and Hiring Difficulties, and 

Gaps in Key Knowledge and Skill Areas 16

The Majority of DDSs Do Not Conduct Long-Term, Comprehensive 

Workforce Planning, and DDSs Cite Numerous Obstacles to 

Doing So 26

SSA’s Workforce Efforts Have Not Sufficiently Addressed Present 

and Future Human Capital Challenges in the DDSs 31

Conclusions 41

Recommendations to the Commissioner of SSA 42

Agency Comments and Our Evaluation 44

Appendix I: Scope and Methods 47

Survey of Disability Determination Service Offices 47

Analysis of Data from Our Survey and Other Sources 48

Appendix II: Survey of DDS Directors’ Views on Human Capital Challenges 51 

Appendix III: Related GAO Reports 80

Modernizing Federal Disability Programs 80

General Human Capital Management 80

Strategic Workforce Planning 80

Organizational Transformation 81

Training and Development 82

Appendix IV: Comments from the Social Security Administration 83

GAO Comments 87

Appendix V: GAO Contacts and Staff Acknowledgments 93

GAO Contacts 93

Staff Acknowledgments 93

Contents 
Page ii GAO-04-121 Social Security Administration 

Tables 

Table 1: Turnover Rates for DDS Examiners, VBA Examiners, SSA 

Employees, and All Federal Employees 17

Figures 

Figure 1: Percentage of DDSs by Type of Minimum Education 

Requirement for New Disability Examiners 11

Figure 2: Three-Year Average Examiner Turnover Rates for 

Individual DDSs (Fiscal Years 2000 to 2002) 18

Figure 3: Distribution of Average State DDS Examiner Salaries as a 

Percentage of Average VBA Examiner Salaries 22

Figure 4: Percentage of DDSs by their Workforce Planning Time 

Horizons 27

Figure 5: Means and Strategies Addressing the DDS Workforces 

Are Largely Absent from SSA’s Strategic and Workforce 

Plans 32

Abbreviations 

DDS Disability Determination Service 

DE disability examiners 

DI Disability Insurance 

NGA National Governors Association 

OPM Office of Personnel Management 

SDM single decision-maker 

SSA Social Security Administration 

SSI Supplemental Security Income 

VBA Veterans Benefits Administration 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 
Page 1 GAO-04-121 Social Security Administration 

January 27, 2004 

The Honorable E. Clay Shaw, Jr. 

Chairman, Subcommittee on Social Security 

Committee on Ways and Means 

House of Representatives 

Dear Mr. Chairman: 

In 2002, the Social Security Administration’s (SSA) Disability Insurance 

(DI) and Supplemental Security Income (SSI) programs paid about $74.1 

billion to about 8.5 million individuals with disabilities. Under the Social 

Security Act, SSA oversees and fully funds 54 primarily state-operated 

Disability Determination Service (DDS) offices that determine whether 

applicants are eligible for disability benefits. Key to the accuracy and 

timeliness of these disability determinations are the more than 6,500 

disability examiners employed by the DDSs to review medical and 

vocational evidence and help decide eligibility for disability benefits. The 

critical role played by the examiners will likely increase in the future, with 

the projected dramatic growth over the next decade in the number of 

applications for disability benefits as baby boomers enter their disabilityprone years. 

In our prior work, we have noted that the DDSs are confronting an 

impending retirement wave of skilled staff and stiff competition in the 

labor market for qualified staff.1

 At the same time, SSA is facing problems 

with the accuracy and timeliness of its disability determinations. Beyond 

these immediate challenges, the design of SSA’s disability programs 

remains grounded in outmoded concepts of disability that persist despite 

scientific advances and economic and social changes that have redefined 

the relationship between impairments and the ability to work. Because 

other federal disability programs are also not in line with the current 

status of science and the labor market, we designated modernizing federal 

disability programs—including SSA’s DI and SSI programs—as a high-risk 

 1

U.S. General Accounting Office, SSA Customer Service: Broad Service Delivery Plan 

Needed to Address Future Challenges, GAO/T-HEHS/AIMD-00-75 (Washington, D.C.: 

February 10, 2000). 

United States General Accounting Office 

Washington, DC 20548 
Page 2 GAO-04-121 Social Security Administration 

area in 2003.2 In September 2003, the Commissioner unveiled her vision of 

a long-term strategy for improving the disability claims process to enhance 

timeliness and accuracy of decisions and for testing work incentives and 

opportunities aimed at helping people with disabilities return to work.3

The success of such a fundamental reorientation of SSA’s disability 

determination process will depend greatly on having the staff with the 

right skill mixes and areas of expertise available when and where needed. 

DDS workforces will be a critical component in any future restructuring 

undertaken by SSA to modernize its disability programs. 

In view of the significance of human capital management in the DDSs, this 

report addresses (1) the challenges the DDSs face today in retaining and 

recruiting examiners and enhancing their expertise, (2) the extent to 

which the DDSs engage in workforce planning and encounter obstacles in 

doing so, and (3) the extent to which SSA is addressing present and future 

human capital challenges in the DDSs. 

To address these issues, we surveyed directors of 52 of the 54 primarily 

state-operated DDSs.4

 Our survey included questions about long-term 

workforce planning, recruiting and hiring, compensation, training and 

development, and retention of disability examiners. We also collected 

human capital data from the federal DDS, which provides case-processing 

assistance to state DDSs during periods of high workload demands, among 

other responsibilities. 

For the purposes of this report, strategic workforce planning is a 

framework for decision-making that aims to ensure that an organization 

has the people with the right skills, available when and where needed, to 

 2

U.S. General Accounting Office, High-Risk Series: An Update, GAO-03-119 (Washington, 

D.C.: January 2003). 

3

Statement of the Honorable Jo Anne B. Barnhart, Commissioner, Social Security 

Administration: Testimony before the Subcommittee on Social Security of the House 

Committee on Ways and Means, September 25, 2003. 

4

The 54 DDSs include one in each state and in the District of Columbia, Guam, and Puerto 

Rico, as well as a DDS for the Blind in South Carolina. We excluded the Guam DDS and the 

South Carolina DDS for the Blind from the survey, because they each employ only one 

person. Throughout this report, we refer to the Puerto Rico and the District of Columbia 

DDSs as state agencies. 
Page 3 GAO-04-121 Social Security Administration 

respond to change and accomplish the agency’s strategic goals.5 To be 

effective, workforce planning must be fully integrated with the agency’s 

mission and goals and must be based on accurate and comprehensive 

workforce data. While such planning can include a range of programs and 

strategies, our prior work6

 has found that the following strategies are key 

to effective workforce planning, including 

• recruiting strategies, 

• retention strategies, 

• training and professional development strategies, 

• compensation strategies, 

• performance expectation and evaluation strategies, 

• employee-friendly workplace strategies, 

• succession planning and strategies for maintaining expertise in the long 

term, and 

• contingency plans, in the event that resource levels do not meet 

expectations. 

In addition, we reviewed relevant documents, including SSA laws, 

regulations, and procedures, and other pertinent laws. We also obtained 

and analyzed human capital data from DDSs, SSA, and other federal 

agencies. We interviewed disability examiners and their managers at two 

DDSs to gain an in-depth understanding of the issues related to our 

objectives. We also visited three SSA regional offices, interviewing 

officials who are responsible for DDS management assistance and serve as 

liaisons between SSA regional offices, the DDSs, and their respective state 

governments. In addition, we interviewed SSA officials at headquarters 

and a variety of key stakeholders such as officials of the National Council 

of Disability Determination Directors, the National Association of 

Disability Examiners, and staff of the Social Security Advisory Board. We 

performed our work in accordance with generally accepted government 

auditing standards between September 2002 and October 2003. For more 

details about our scope and methods, see appendix I. For a copy of our 

survey, see appendix II. 

 5

The Government Performance and Results Act established a planning time horizon of at 

least five years for agency strategic plans. We have reported that the act’s strategic 

planning requirements provide a useful framework for agencies to integrate their human 

capital strategies with their strategic and programmatic planning. See U.S. General 

Accounting Office, High-Risk Series: An Update, GAO-01-263 (Washington, D.C.: January 

2001). 

6

GAO-01-263. 
Page 4 GAO-04-121 Social Security Administration 

DDSs face three key challenges in retaining examiners and enhancing their 

expertise: (1) high turnover, (2) recruiting and hiring difficulties, and 

(3) gaps in key knowledge and skills: 

• High turnover. Results from GAO’s survey of 52 DDSs show that over 

half of all DDS directors surveyed said that examiner turnover was too 

high in their offices. We also found that examiner turnover was about 

twice that of federal employees performing similar work. Nearly twothirds of all directors reported that turnover has increased SSA’s hiring 

and training costs, decreased overall staff skill levels, and increased 

claims-processing times. In addition, two-thirds of all DDS directors cited 

stressful workloads and noncompetitive salaries as major factors that 

contributed to turnover. 

• Recruiting and hiring difficulties. More than three-quarters of all DDS 

directors (43) reported experiencing difficulties over a three-year period in 

recruiting and hiring enough people who could become successful 

examiners. Of these directors, more than three-quarters reported that such 

difficulties contributed to increases in claims-processing times, examiner 

caseload levels, backlogs, and turnover. In addition, more than half of all 

directors reported that state-imposed compensation limits contributed to 

these hiring difficulties, and more than a third of all directors attributed 

hiring difficulties to other state restrictions, such as hiring freezes. 

• Gaps in key knowledge and skills. Nearly one-half of all DDS directors 

said that at least a quarter of their examiners need additional training in 

areas critical to disability decision-making, such as assessing symptoms 

and credibility of medical information, weighing medical opinions, and 

analyzing a person’s ability to function. Over half of all directors cited 

factors related to high workload levels that limit trainer and trainee time 

as obstacles to examiners’ receiving additional training. 

Despite the workforce challenges facing the DDSs, data from our survey 

show that the majority of DDSs do not undertake long-term, 

comprehensive workforce planning, citing numerous obstacles to doing 

so. More than half of all the DDSs have workforce planning time horizons 

of less than two years. Moreover, among the DDSs that engage in 

workforce planning that is longer-term than one year, the majority have 

plans that lack key workforce planning strategies, such as those for 

recruiting, retention, or succession planning. The directors who report 

that they do not engage in workforce planning that is longer-term than one 

year instead mainly rely on SSA’s annual budget process for their 

workforce planning, even though GAO’s research shows that the budget 

process does not constitute comprehensive workforce planning. 

Results in Brief 
Page 5 GAO-04-121 Social Security Administration 

Moreover, over half of all the DDSs do not make projections of retirements 

and other separations. DDS directors cited a number of obstacles that 

made long-term workforce planning more difficult than it would be 

otherwise. For example, two-thirds of all DDS directors reported that longterm planning is made more difficult by inconsistencies between state and 

SSA human capital policies and uncertainties about future resource levels 

from SSA. Further, three-quarters of all directors said that they had 

insufficient time to attend to future problems because of the need to focus 

on current human capital challenges. 

SSA’s workforce efforts have not sufficiently addressed present and future 

DDS human capital challenges. The Government Performance and Results 

Act now requires agencies to include in their annual performance plans a 

description of the human capital strategies needed to meet their strategic 

goals. However, GAO’s review of SSA’s planning documents shows that 

neither SSA’s strategic plan, nor its annual performance plan, nor its 

workforce plan contains a strategic human capital plan that addresses 

current and future DDS human capital needs. Thus SSA does not link its 

strategic objectives (such as making the right decision in the disability 

process as early as possible) to a workforce plan that covers the very 

people who are essential to accomplishing those objectives. In addition, 

one-half or more of DDS directors reported being dissatisfied with the 

adequacy of training that SSA provides to the DDSs in a number of key 

knowledge and skill areas. Beyond training, an analysis of GAO’s survey 

data shows that SSA has not provided other human capital assistance in a 

consistent manner across the DDSs. For example, of the DDS directors 

who reported wanting help from SSA with negotiating human capital 

changes with the states (for example, in negotiating salary increases for 

examiners), more than half (24 DDSs) said that they had not received it. 

Moreover, more than half of the DDS directors who received such 

assistance (11 DDSs) said it was of limited effectiveness. Regional office 

officials and DDS directors explained in interviews, however, that the 

effectiveness of SSA and its regional offices in providing such help can be 

limited by such factors as state budget problems, political concerns, and 

personnel rules. Finally, SSA has not used the statutory authority it has to 

establish uniform human capital standards, such as minimum 

qualifications for disability examiners, which would address, on a 

nationwide basis, some of the human capital challenges facing the DDSs. 

The agency has instead allowed the states to retain maximum flexibility in 

the human capital management arena, citing potential difficulties inherent 

in changing the federal-state relationship. For example, some SSA officials 

expressed concern that states might perceive the establishment of uniform 

human capital standards as an unwelcome federal intrusion into state 
Page 6 GAO-04-121 Social Security Administration 

operations. While acknowledging these and other significant difficulties, 

several DDS and SSA officials interviewed by GAO expressed the view that 

uniform standards could help address the human capital challenges 

confronting the DDSs. 

GAO is making several recommendations in this report to the 

Commissioner of Social Security to improve SSA’s strategic workforce 

planning to address present and future human capital challenges facing 

the DDSs. These recommendations include that SSA work in partnership 

with the DDSs to develop a nationwide strategic workforce plan to 

address present and future human capital challenges facing the DDSs, 

establish uniform minimum qualifications for new examiners, and work 

with the DDSs to close gaps between current and required examiner skills. 

In commenting on a draft of this report, SSA officials generally agreed with 

the intent of our recommendations but stated that the report does not 

fairly address or adequately discuss the many sides of DDS human capital 

management issues. In particular, SSA criticized some of our study’s 

methods and expressed concern that we did not sufficiently acknowledge 

the difficulties involved in making changes to the federal-state 

relationship. For example, SSA said that we relied heavily on opinions of 

DDS directors and that we did not sufficiently acknowledge the attitudes 

of the states toward modifying federal regulations to establish uniform 

human capital standards and the complexities involved. We surveyed DDS 

directors because they are some of the most knowledgeable respondents 

about human capital challenges facing their organizations. But in addition 

to our survey, we gathered information from a variety of sources, 

including site visits to three SSA regional offices, interviews with SSA 

officials at headquarters, and analyses of human capital data. In addition, 

our report acknowledged the difficulties SSA has encountered in 

convincing the DDSs to comply with SSA guidelines on personnel issues 

and stressed that establishing uniform qualifications for examiners will be 

difficult. But we maintain that, despite such difficulties, as the agency with 

fiduciary responsibility for administering multibillion dollar disability 

programs that are nationwide in scope, SSA is obligated to address the 

human capital challenges facing the DDSs. We continue to believe that the 

report presents a fair and balanced portrayal of the multifaceted issue of 

human capital management in the DDSs. Our summary evaluation of the 

agency’s comments begins on page 44. SSA’s comments and our responses 

are provided in full in appendix IV. 
Page 7 GAO-04-121 Social Security Administration 

The DI and SSI programs are the two largest federal programs providing 

cash assistance to people with disabilities. The DI program, established in 

1956 by the Social Security Act, provides monthly cash benefits to workers 

with disabilities (and their dependents and survivors) whose employment 

history qualifies them for disability benefits. In 2002, SSA paid about $55.5 

billion in DI benefits to 5.5 million workers with disabilities (age 18 to 64).7

SSI is a means-tested income assistance program created in 1972 that 

provides a financial safety net for individuals who are aged or blind or 

have other disabilities and who have low income and limited resources. 

Unlike the DI program, SSI has no prior work requirement. In 2002, SSA 

paid about $18.6 billion in SSI federal benefits to about 3.8 million people 

with disabilities (age 18 to 64). 

To be considered eligible for benefits for either SSI or DI as an adult, a 

person must be unable to perform any substantial gainful activity by 

reason of a medically determinable physical or mental impairment that is 

expected to result in death or that has lasted or can be expected to last for 

a continuous period of at least 12 months. Work activity is generally 

considered to be substantial and gainful if the person’s earnings exceed a 

particular level established by statute and regulations.8

To obtain disability benefits, a claimant must file an application online, by 

phone or mail, or in person at any of SSA’s field offices.9

 If the claimant 

meets the non-medical eligibility criteria, the field office staff forwards the 

claim to the appropriate DDS office. DDS staff—generally a team 

composed of disability examiners and medical consultants—obtains and 

reviews medical and other evidence as needed to assess whether the 

claimant satisfies program requirements, and makes the initial disability 

determination. If the claimant is not satisfied with the decision, the 

 7

DI beneficiaries with low income and assets can also receive SSI benefits. Of the 5.5 

million DI beneficiaries, about 800,000 also received SSI in 2002. 

8

The Commissioner of Social Security has the authority to set the substantial and gainful 

activities level for individuals who have disabilities other than blindness. In December 

2000, SSA finalized a rule calling for the annual indexing of the nonblind level to the 

average wage index of all employees in the United States. The 2004 nonblind level is set at 

$810 a month. The level for individuals who are blind is set by statute and is also indexed to 

the average wage index. In 2004, the level for blind individuals is $1,350 of countable 

earnings. 

9

SSA permits DI, but not SSI, applicants to file for benefits online. 

Background 

SSA’s Disability 

Determination Process 
Page 8 GAO-04-121 Social Security Administration 

claimant may ask the DDS to reconsider its finding.10 If the claimant is not 

satisfied with the reconsideration, the claimant may request a hearing 

before one of SSA’s federal administrative law judges in an SSA hearing 

office. If the claimant is still dissatisfied with the decision, the claimant 

may request a review by SSA’s Appeals Council.11

The 1954 amendments to the Social Security Act specified that disability 

determinations would be made by state agencies under individual 

contractual agreements with SSA. Under these agreements, SSA’s primary 

role was to fund the states’ disability operations. However, following 

criticism from GAO and others about the quality and uniformity of the 

disability determination process, Congress amended the Social Security 

Act in 1980 to strengthen SSA management of the disability programs and 

allow greater SSA control and oversight of the DDSs. The 1980 

amendments directed SSA to issue regulations specifying performance 

standards and administrative requirements to be followed to assure 

effective and uniform administration of disability determinations across 

the nation.12

The regulations issued by SSA, which established the current federal-state 

relationship, allow SSA to remove the disability determination function 

from a state if the DDS fails to make determinations that meet thresholds 

for performance accuracy and processing time.13 SSA’s regulations give 

DDSs maximum managerial flexibility in meeting the performance 

standards, allowing them to retain substantial independence in how they 

 10In 2002, the DDSs made 2.3 million initial disability determinations and over 484,000 

reconsiderations. In September 2003, the Commissioner testified before the House 

Committee on Ways and Means, saying that she intended to revise the disability 

determination process. For example, she proposed eliminating the reconsideration and the 

Appeals Council stages of the current process. 

11If the claimant is not satisfied with the Appeals Council decision, the claimant may appeal 

to a federal district court. The claimant can continue legal appeals, as needed, to the U.S. 

Circuit Court of Appeals and ultimately to the Supreme Court of the United States. 

12See Pub. L. No. 96-265, Sec. 304(a) (1980). 

13See 20 C.F.R. Sec. 404.1503(a) and 416.903(a) (2003). 

The Federal-State 

Relationship 
Page 9 GAO-04-121 Social Security Administration 

manage their workforce.14 For example, under the regulations, the DDSs 

are to follow state personnel standards in selection, tenure, and 

compensation of DDS employees.15

As employees of the state, DDS staff are subject to the rules and 

regulations of each state’s individual personnel classification system. 

Classification systems generally categorize positions on the basis of job 

responsibilities and the knowledge, skills, and competencies required to 

perform them. Within a classification system, a group of positions that 

have sufficiently similar responsibilities are put in the same class. 

Arranging positions in classes with common levels of difficulty and 

responsibility makes it possible to set ranges of compensation for whole 

classes of jobs across multiple state agencies. Specifying the 

responsibilities of each position also allows the state to identify and 

develop effective hiring qualifications, promotion criteria, and training 

requirements. The development and operation of such a classification 

system depend upon the adequacy of information about individual 

positions. 

Within the federal-state relationship, each DDS reports to its own state 

government, usually to a parent agency such as the state vocational 

rehabilitation agency.16 DDS staff generally include a variety of positions, 

such as medical consultants, vocational specialists, quality assurance 

personnel, as well as disability examiners. The number of disability 

examiners varies substantially among the DDSs. Data from our survey 

show that the number of full-time permanent examiners in each DDS 

ranged from 9 to 529 at the end of fiscal year 2002. Our prior work has 

found that the examiner’s job—which involves working with medical 

consultants to determine impairment severity, ability to function, and 

disability benefit eligibility—requires considerable expertise and 

 14In the preamble to these regulations, SSA stated that it did not define DDS administrative 

requirements in detail and instead elected to regulate only to the extent necessary to 

ensure effective and uniform administration of the disability program. (46 Fed. Reg. 29,190, 

29,198 (1981). SSA also stated that, overall, the states supported the agency's proposed 

regulatory approach. (Id. at 29,196.) 

15The regulations also encourage the states to refrain from imposing state personnel freezes 

and restrictions against overtime work on the DDSs to the extent possible. See 20 C.F.R. 

Sec. 404.1621(b) and 416.1021(b). 

16Our survey data show that 50 out of 52 DDSs report to a state parent agency, and among 

these, 28 DDSs report to the state’s vocational rehabilitation agency. 

Description of the DDSs 

and the Disability 

Examiner Position 
Page 10 GAO-04-121 Social Security Administration 

knowledge of complex regulations and policies.17 And according to the 

Social Security Advisory Board, changes in agency rules and in the types 

of disability claims received by the DDSs have made disability 

decision-making more subjective and difficult.18 In addition, as part of its 

efforts to reduce claims-processing times, SSA has been testing a new 

disability examiner position called the single decision-maker (SDM), 

which would expand an examiner’s authority to independently decide 

claimants’ eligibility for benefits.19 20 DDSs are testing this new position. 

Qualification requirements for new examiner hires vary substantially 

among the states. While five DDSs require a master’s or a registered 

nursing degree for certain new examiner hires, figure 1 shows that over 

one-third of all DDSs can hire new examiners with either a high school 

diploma or less.20 In addition, data show that examiners in nearly one-half 

of all DDSs are covered by union agreements, and issues related to 

compensation levels, hiring and promotion procedures, and weekly hours 

worked are open to union negotiation in the majority of these DDSs. 

 17See GAO/T-HEHS/AIMD-00-75. 

18For example, due to changes in agency rules, examiners must now adhere to more 

complex requirements regarding such matters as determining the weight that should be 

given to the opinion of a treating source and making a finding as to the credibility of 

claimants’ statements about the effect of pain on functioning. See Social Security Advisory 

Board, Agenda for Social Security: Challenges for the New Congress and the New 

Administration (February 2001). 

19Expansion of an examiner’s authority would bypass the current need for a medical 

consultant to certify the decision unless the law mandates otherwise. Medical consultants 

are required to certify all SSI childhood disability claims and all less than fully favorable 

decisions on DI and SSI claims involving an indication of a mental impairment. 

20Some DDSs may have higher educational requirements for some applicants or may use 

standards other than, or in addition to, education—such as relevant skills, previous 

equivalent experience, or some type of selection examination for which a qualifying score 

or ranking is needed for hiring eligibility. The minimum education requirements shown in 

this figure do not necessarily reflect the actual credentials of DDS examiners hired by the 

DDSs. For example, one DDS director explained in an interview that, despite the lack of 

any educational requirements for new examiner hires in the state, most examiners 

employed by the DDS had four-year college degrees, and several had masters’ degrees. 
Page 11 GAO-04-121 Social Security Administration 

Figure 1: Percentage of DDSs by Type of Minimum Education Requirement for New 

Disability Examiners 

Note: These figures represent the lowest possible educational level a DDS requires for a new 

examiner, regardless of the type of applicant for the job. Data provided in the figure do not add to 100 

percent due to rounding. One DDS did not answer this question. 

To enhance the skills of both new and experienced examiners, SSA 

provides a number of optional training tools to the DDSs, including written 

materials covering new examiner basic training, interactive video 

programs supplementing basic training and providing refresher training 

and updates on policy changes, and materials and presentations provided 

by the regional offices and SSA headquarters. However, states have 

primary responsibility for training examiners, and many DDSs adapt or 

supplement SSA’s training to meet their examiners’ training needs. DDSs 

generally provide new examiners with SSA’s basic examiner training, 

followed by extensive on-the-job training, including mentoring by 

experienced examiners who guide the less experienced examiners in 

becoming more proficient in the disability claims process. New hires 

generally are not considered fully proficient until after one to two years of 

experience. 

The DDSs’ ability to hire examiners is affected by both SSA and state 

government funding decisions and hiring policies. SSA determines the 

funding available for each DDS and advises the DDSs about the number of 

full-time equivalent staff supported by this funding, and SSA adjusts these 

levels throughout the fiscal year based on workload fluctuations and 

22%

4%

10%

8%

57%

No educational

requirements

General Educational

Development (GED)

High school diploma

4-year college degree

(bachelor)

Source: GAO analysis of responses to its survey of DDS directors, April 2003.

2-year college degree

(associate)

Combined

amounts to

over one-third

of the DDSs
Page 12 GAO-04-121 Social Security Administration 

funding availability. Normally SSA allows DDSs to replace staff who leave 

the DDS as long as they remain within authorized staffing levels, but for 

over half of fiscal year 2003, SSA froze DDS hiring, preventing DDSs from 

hiring new examiners or replacing those who had left. SSA officials told us 

that the temporary freeze was necessary to ensure that SSA’s expenditures 

did not exceed authorized levels and to avoid future layoffs of DDS staff.21 

DDSs also have experienced state government hiring restrictions in recent 

years. Despite full federal funding, under the current federal-state 

relationship, DDSs generally cannot spend funds for new personnel 

without the approval of their state governments. States currently are 

facing severe budget crises, causing them to cut their payrolls for most 

state government functions. When states use methods such as hiring 

freezes, reductions in force, and early retirement incentives to limit 

spending on state employee payrolls, these policies sometimes prevent 

DDSs from hiring and retaining examiners at levels authorized by SSA. 

In earlier reports, we have noted that SSA’s disability determination 

process is mired in concepts from the past and needs to be brought into 

line with the current state of science, medicine, technology, and labor 

market conditions.22 With other federal disability programs similarly 

structured around outmoded concepts, we designated modernizing federal 

disability programs—including SSA’s DI and SSI disability programs—as a 

high-risk area in 2003.23 (See appendix III for a list of GAO reports on 

modernizing federal disability programs.) We made this designation owing 

in part to SSA’s (1) outmoded concepts of disability, (2) lengthy 

processing times, and (3) decisional inconsistencies: 

• SSA’s outmoded concepts of disability. While technological and 

medical advances and societal changes have increased the potential for 

some people with disabilities to participate in the labor force, few DI and 

SSI beneficiaries leave the disability rolls to work. Our prior work shows 

that, unlike some private sector disability insurers and social insurance 

systems in other countries, SSA does not incorporate into its disability 

 21SSA officials said the agency’s policy was to avoid layoffs of DDS employees. 

22See, for example, U.S. General Accounting Office, SSA and VA Disability Programs: 

Re-Examination of Disability Criteria Needed to Help Ensure Program Integrity, 

GAO-02-597 (Washington, D.C.: August 9, 2002). 

23GAO-03-119. 

Modernizing Federal 

Disability Programs 

Designated as a High-Risk 

Area 
Page 13 GAO-04-121 Social Security Administration 

eligibility assessment process an evaluation of what is needed for an 

individual to return to work.24 These private insurers and other social 

insurance systems have access to staff with a wide range of expertise to 

apply, not only in making eligibility decisions, but also in providing returnto-work assistance. We have recommended that SSA develop a 

comprehensive return-to-work strategy that integrates earlier 

identification of work capacities and the expansion of such capacities by 

providing return-to-work assistance for applicants and beneficiaries. 

Adopting such a strategy is likely to require fundamental changes to the 

disability determination process, as well as changes to staff skill mixes and 

areas of expertise. 

• Lengthy processing times for disability claims. The disability claims 

process can be lengthy, with many individuals who appeal SSA’s initial 

decision waiting a year or longer for final decisions on their benefit claims. 

According to SSA, a claimant can wait as long as 1,153 days from initial 

claim through a decision from the Appeals Council. As one means of 

reducing its claims-processing time, SSA aims to eliminate backlogs for 

initial disability claims, hearings, and appeals by 2008. Nevertheless, 

growth in the disability claims workload is likely to exacerbate SSA’s 

claims-processing challenges: SSA expects the DI rolls to grow by 35 

percent between 2002 and 2012.25

• Inconsistencies in disability decisions. SSA has had difficulty ensuring 

that decisions regarding a claimant’s eligibility for disability benefits are 

accurate and consistent across adjudicative levels and locations, raising 

questions about the fairness, integrity, and cost of these programs.26 For 

example, the Social Security Advisory Board has shown wide variances 

among the DDSs in rates of allowances and denials of disability benefits.27

The Advisory Board has cited differences in state-established personnel 

policies such as salaries, training, and qualifications of disability 

examiners across the DDSs, along with state economic and demographic 

 24GAO-01-153. 

25Social Security Administration, Strategic Plan 2003-2008. 

26The cost of administering the DI and SSI programs reflects the demanding nature of the 

process. Although SSI and DI program benefits account for less than 20 percent of the total 

benefit payments made by SSA, they consume nearly 55 percent of SSA’s annual 

administrative resources. 

27Social Security Advisory Board, Charting the Future of Social Security’s Disability 

Programs: The Need for Fundamental Change (Washington, D.C.: January 2001). 
Page 14 GAO-04-121 Social Security Administration 

differences, as some of the key factors that may affect the consistency of 

disability decision-making.28

The Commissioner’s September 2003 testimony sets forth her long-term 

strategy for improving the timeliness and accuracy of the disability claims 

process and fostering return to work for people with disabilities. For 

example, to speed decisions for some claimants, the Commissioner 

intends to initiate an expedited decision for claimants with more easily 

identifiable disabilities, such as aggressive cancers. Under this new 

approach, special units located primarily in SSA’s regional offices would 

handle the expedited claims, leaving DDS examiners responsible for 

evaluating the more complex claims. The Commissioner’s strategy also 

aims to increase decisional accuracy by, among other approaches, 

requiring DDS examiners to develop more complete documentation of 

their disability determinations, including explaining the basis for their 

decisions. Beyond steps to improve the timeliness and accuracy of the 

process, the Commissioner also plans to conduct several demonstrations 

aimed at helping people with disabilities return to work by providing work 

incentives and opportunities earlier in the disability process. 

In addition, to improve the disability decision process, the Commissioner 

has implemented some shorter-term remedies while developing her 

longer-range strategies. For example, SSA is accelerating its transition to 

an electronic disability claims folder, through which the DDSs, the field 

offices, and the Office of Hearings and Appeals are to be linked to one 

another. The folder is being designed to transmit case file data 

electronically from one claims-processing location to another and to serve 

as a data repository—storing documents that are keyed in, scanned, or 

faxed. According to the Commissioner, successful implementation of the 

electronic folder is essential for improving the disability process. In our 

prior work, we have cautioned SSA to ensure that it has the right mix of 

skills and capabilities to support this major technological transition.29

 28Social Security Advisory Board, Disability Decision-Making: Data and Materials 

(Washington, D.C.: January 2001). 

29U.S. General Accounting Office, Major Management Challenges and Program Risks: 

Social Security Administration, GAO-03-117 (Washington, D.C.: January 2003). 

SSA’s New Long-Term 

Strategy for Improving Its 

Disability Programs 
Page 15 GAO-04-121 Social Security Administration 

Recognizing the importance of people to the success of any organization in 

managing for results, GAO designated strategic human capital 

management a government-wide high-risk area in 2001.30 In prior reports 

on this high-risk area, we identified strategic workforce planning as 

essential to effective performance and stated that it should be a priority of 

agency leaders.31 We also noted that effective workforce planning must be 

fully integrated with an agency’s mission and program goals and be based 

on accurate and comprehensive workforce data. We recently identified a 

few key principles for strategic workforce planning.32 These principles 

include 

• involving top management, employees, and other key stakeholders in 

developing, communicating, and implementing the workforce plan; 

• determining the critical skills and competencies needed to achieve current 

and future program goals, and developing strategies to fill identified gaps; 

• building the capability necessary to address administrative, educational, or 

other requirements to support the workforce strategies; and 

• monitoring and evaluating progress in meeting workforce goals and how 

well the workforce plan has contributed to reaching overall program goals. 

Congress has additionally recognized the importance of workforce 

planning and, in 2002, added to the Government Performance and Results 

Act a provision requiring agencies to include human capital strategies 

needed to meet their strategic goals in their annual performance plans.33

We have found that high-performing organizations use workforce planning 

as a management tool to develop a compelling case for human capital 

investments and to anticipate and prepare for upcoming human capital 

 30GAO-01-263. 

31GAO-01-263 and U.S. General Accounting Office, Human Capital: Key Principles for 

Effective Strategic Workforce Planning, GAO-04-39 (Washington, D.C.: December 11, 

2003). 

32GAO-04-39. 

33See 31 U.S.C. Sec. 1115(a)(3) and (f) (2003). 

Strategic Human Capital 

Management Designated a 

High-Risk Area 
Page 16 GAO-04-121 Social Security Administration 

issues that could jeopardize accomplishment of the organizations’ goals.34

(See appendix III for a list of GAO reports on human capital management.) 

The DDSs face several key challenges in retaining disability examiners and 

enhancing their expertise: high turnover, difficulties in recruiting and 

hiring, and gaps in key knowledge and skill areas. The DDSs are 

experiencing high and costly turnover of examiners, which data from our 

survey show is fostered in part by stressful workloads and noncompetitive 

salaries. DDSs need to recruit and hire sufficient numbers of qualified new 

examiners to fill the vacancies resulting from the high turnover. Yet more 

than three-quarters of DDS directors reported recruiting and hiring 

difficulties. Directors said such difficulties were due in part to stateimposed personnel restrictions, such as state limits on examiner salaries 

and hiring. Finally, directors reported that many examiners need 

additional training in key analytical areas that are critical to disability 

decision-making, including assessing credibility of medical information, 

evaluating applicants’ symptoms, and analyzing applicants’ ability to 

function. 

Over half of all DDS directors responding to our survey said that examiner 

turnover in their offices was too high. Our analysis of data from our survey 

and from federal agencies shows that, over fiscal years 2000 through 2002, 

DDS examiner turnover was about twice that of Veterans Benefits 

Administration (VBA) disability examiners with responsibilities similar to 

those of DDS examiners.35 For example, DDS examiner turnover averaged 

13 percent over fiscal years 2000 to 2002, compared with 6 percent for VBA 

 34U.S. General Accounting Office, A Model of Strategic Human Capital Management, 

GAO-02-373SP (Washington, D.C.: March 15, 2002). 

35VBA employs 5,000 disability claims examiners, called veterans service representatives 

(VSRs) and ratings veterans service representatives (RVSRs), in 57 offices covering each 

state. Because the Office of Personnel Management’s Central Personnel Data File groups 

both positions together, our comparisons include both groups. Both positions have certain 

responsibilities similar to those of DDS examiners. For example, RVSRs and DDS 

examiners are responsible for analyzing disability claims to determine disability benefit 

eligibility. Moreover, VSRs and DDS examiners are responsible for investigating disability 

claims and serving as the primary contact for claimants and health providers. However, 

when compared with the DDS examiner, RVSRs have the additional responsibility of 

determining whether claimants’ impairments are related to their military service, and VSRs 

have the added task of conducting initial interviews with applicants. In this report, we are 

referring to both RVSRs and VSRs as VBA examiners. 

DDSs Face High 

Turnover, Recruiting 

and Hiring 

Difficulties, and Gaps 

in Key Knowledge and 

Skill Areas 

DDSs Face High and 

Costly Turnover Fostered 

by Stressful Workloads and 

Noncompetitive Salaries 
Page 17 GAO-04-121 Social Security Administration 

disability examiners. (See table 1.) In addition, during the same period, the 

turnover rate of DDS examiners was substantially greater than that of all 

SSA employees as well as that of all federal government employees.36 DDS 

examiner turnover has been even higher among new hires: turnover of 

examiners hired in fiscal year 2001 was 25 percent, compared with 14 

percent among all DDS examiners.37 Moreover, while it is typical for new 

hires to leave at higher rates than other employees, turnover of new DDS 

examiners was considerably higher than that of new VBA examiners, new 

SSA employees, and all new federal government employees in fiscal years 

2000 and 2001. 

Table 1: Turnover Rates for DDS Examiners, VBA Examiners, SSA Employees, and All Federal Employees 

National turnover ratesa

Experienced staff and new hiresbNew hires onlyc

Fiscal 

year 

DDS 

examiners 

VBA 

examiners 

SSA 

employees

All federal 

employees

DDS 

examiners

VBA 

examiners 

SSA 

employees

All federal 

employees

2000 15% 5% 6% 8% 31% 19% 16% 24%

2001 14 6 5 7 25 18 14 21

2002 12 7 5 7 d d d d 

Averagee 13 6 5 7 28 18 15 22

Source: GAO analysis of data from our survey of DDS directors, April 2003, and from the U.S. Office of Personnel Management’s Central Personnel Data File. 

a

The calculation of the annual turnover rate and the new hire turnover rate for SSA and VBA 

examiners included transfers to other agencies within the federal government, but such transfers 

were not included in the turnover rate calculation for federal employees government-wide. In addition, 

some DDSs did not provide complete turnover data for all three years. The fiscal year 2000 turnover 

rate for experienced DDS staff is based on data from 47 DDSs; the fiscal year 2001 rate is based on 

data from 49 DDSs; and the fiscal year 2002 rate is based on data from 52 DDSs. The average 

turnover rate accounts for these differences in number of DDSs and total employees across years. 

b

We based our calculation of the annual turnover rate for DDS examiners, VBA examiners, and SSA 

employees on the total number of retirements and other separations during a fiscal year, divided by 

the average number of permanent employees. We calculated the number of permanent employees 

by averaging the total number employed at the beginning and the end of the fiscal year. 

c

We based our calculation of the yearly new hire turnover rate on the total number of new hires 

separating in the fiscal year following their year of hire, divided by the total number hired in that year. 

 36We were unable to obtain data on turnover rates of private sector employees who 

perform work similar to that of DDS examiners that was comprehensive enough to allow 

valid comparisons. We were also unable to obtain recent data on the turnover rates of state 

employees other than DDS employees. 

37According to human resource experts, it is typical for new employees to leave at higher 

rates than all other employees. See U.S. General Accounting Office, Veterans Benefits 

Administration: Better Collection and Analysis of Attrition Data Needed to Enhance 

Workforce Planning, GAO-03-491 (Washington, D.C.: April 28, 2003). 
Page 18 GAO-04-121 Social Security Administration 

d

No data available. 

e

Average turnover rates for experienced staff and new hires are based on fiscal years 2000, 2001, 

and 2002. Average turnover rates for new hires only are based on fiscal years 2000 and 2001. 

Our survey results also show that examiner turnover is particularly high in 

some DDSs. An examination of three-year averages (fiscal years 2000 to 

2002) of DDS turnover rates showed that one DDS had a turnover rate of 

43 percent, and a quarter of the DDSs had turnover rates of 20 percent or 

greater. (See fig. 2.) 

Figure 2: Three-Year Average Examiner Turnover Rates for Individual DDSs (Fiscal 

Years 2000 to 2002) 

Note: Three-year average turnover rates are based on data from 47 DDSs. Five DDSs did not provide 

turnover data for all three fiscal years (2000, 2001, and 2002). The highest three-year turnover rate 

was 43 percent. 

When we asked DDS directors in our survey about the consequences of 

turnover, they told us that examiner turnover increased hiring and training 

costs and hindered claims processing by decreasing overall examiner skill 

0

5

10

15

20

25

40% or

greater

0-9% 10-19% 20-29% 30-39%

DDSs

15

20

10

1 1

DDS 3-year average turnover rate

Sources: GAO analysis of survey of DDS directors, April 2003, and GAO analysis of OPM’s Central Personnel Data File.
Page 19 GAO-04-121 Social Security Administration 

levels, and increasing examiner caseloads, claims-processing times, and 

backlogs, as follows:38

• Increased hiring and training costs. Nearly two-thirds of all DDS 

directors reported in our survey that turnover had increased SSA’s 

recruiting, hiring, or training costs. Directors and other DDS officials 

explained in interviews why these costs had increased as a result of 

turnover. Some DDS directors said that they must invest time in reviewing 

applications, interviewing candidates, and making hiring decisions. They 

also said they have to provide inexperienced new hires with 12 to 18 

months of extensive training and mentoring. SSA estimates the cost of 

turnover of its own employees at 1.5 times average annual salary. Using 

this rate, we estimate that the cost of DDS examiner turnover in fiscal year 

2002 was in the tens of millions of dollars. 

• Decreased overall examiner skill levels. Two-thirds of all DDS 

directors reported that losses of experienced staff due to turnover have 

decreased overall examiner skill levels. While SSA officials told us that 

one to two years of experience is generally required to become proficient 

in the examiner role, our survey data show that, in two-thirds of the DDSs, 

at least a quarter of examiners had two years or less experience at the end 

of fiscal year 2002. 

• Increased examiner caseloads. Nearly two-thirds of all DDS directors 

we surveyed said turnover had increased examiner caseload levels. DDS 

directors and SSA officials explained in interviews and survey comments 

that the caseloads of examiners who leave the DDS have to be 

redistributed among those who remain. Some directors told us that these 

higher caseloads created a more stressful work environment for the 

remaining employees. 

• Increased claims-processing times and backlogs. Our survey results 

showed that over one-half of all directors said that turnover had increased 

DDS claims-processing times and backlogs. DDS directors and SSA 

officials we spoke with explained that turnover increased claimsprocessing times because new examiners hired to fill vacancies are less 

productive due to their inexperience and time spent in training. These 

officials also told us that the productivity of experienced staff is lowered 

while they are training and mentoring the new examiners. SSA itself 

 38We categorized these conditions as consequences of turnover if directors reported that 

they had occurred to a moderate to very great extent as a result of turnover. 
Page 20 GAO-04-121 Social Security Administration 

acknowledged the potential impact on service in a 2001 internal document. 

This document noted that the need to replace retiring managers, by 

drawing from an examiner pool already diminished by turnover, would 

further reduce the examiner ranks and exacerbate the challenge of 

processing the growing claims workload. In addition, we noted in a prior 

report that a majority of DDS directors expressed the view that examiner 

turnover is likely to jeopardize their ability to complete periodic reviews of 

beneficiaries’ disability status, known as continuing disability reviews, 

potentially contributing to backlogs of these reviews.39

When we asked DDS directors about causes of examiner turnover, more 

than two-thirds identified each of the following as contributing factors: 

(1) large examiner caseloads along with workplace stress, high production 

expectations, and highly complex work and (2) noncompetitive pay.40

• High caseloads, stress, production expectations, and highly 

complex work. Over two-thirds of all DDS directors identified large 

examiner caseloads, a stressful workplace, high production expectations 

for the number of cases completed, and the highly complex nature of the 

work as factors contributing to examiner turnover. DDS directors 

explained in interviews that the combination of growth in the claims 

workloads and increasingly complex examiner responsibilities is making 

the examiner position more challenging and stressful. DDS directors also 

noted in our survey and in interviews that insufficient staffing had 

increased the caseloads and stress levels of their examiners. Nearly 9 out 

of 10 DDS directors surveyed reported that the number of examiners in 

their DDSs had not been sufficient for their workload in at least one of the 

past three fiscal years, and nearly all of these directors said that this 

understaffing had resulted in a more stressful work environment. 

• Noncompetitive pay. Two-thirds of all directors stated that 

noncompetitive pay had contributed to examiner turnover. Our survey 

data showed that many state DDS examiners were paid substantially less 

than examiners employed by the federal DDS in 2002 despite comparable 

 39U.S. General Accounting Office, Social Security Disability: Reviews of Beneficiaries’ 

Disability Status Require Continued Attention to Achieve Timeliness and CostEffectiveness, GAO-03-662 (Washington, D.C.: July 24, 2003). 

40We categorized factors as contributing to examiner turnover if DDS directors reported 

that these factors contributed to turnover to a moderate to very great extent. 
Page 21 GAO-04-121 Social Security Administration 

skills and experience.41 Specifically, all of the state DDSs for which we 

have data have average examiner salaries that are less than the federal 

DDS average salary, and over half of the DDSs (31) have an average 

examiner salary that is less than two-thirds of the federal DDS average 

salary. In addition, we found that DDS examiner salaries are substantially 

lower than those of VBA examiners nationwide. For example, the average 

salary for DDS examiners was $40,464 in 2002, compared with $49,684 for 

VBA examiners.42 Specifically, we found that average DDS examiner 

salaries are less than those of VBA examiners in 47 states. (See fig. 3.) 

Several DDS directors told us in interviews that examiners have left some 

DDSs to accept higher salaries in federal agencies, particularly in SSA 

offices. For example, our analysis of selected case data provided by two 

DDS directors showed that, between 2000 and 2003, 13 former examiners 

received pay increases ranging from 9 to 48 percent when they moved 

from their DDSs to positions in SSA offices.43

 41We collected average examiner salary data from the federal DDS administered by SSA, 

adjusted it to reflect locality pay in each state, and compared it with average DDS examiner 

salary data from our survey. One DDS was excluded because it did not provide examiner 

salary data. While the federal DDS examiner position carries responsibilities beyond those 

of the state DDS examiners, state DDS examiners do not receive additional training in 

order to perform the federal examiner job. 

42We analyzed salary data from our survey and from VBA in order to compare DDS 

examiner and VBA examiner salaries. We were unable to obtain information on experience 

levels of VBA examiners and the distribution of their experience levels across the states. It 

is possible that these factors could help explain some of the differences between the 

average salaries of VBA examiners and DDS examiners. 

43See appendix I for an explanation of our methods for this analysis. 
Page 22 GAO-04-121 Social Security Administration 

Figure 3: Distribution of Average State DDS Examiner Salaries as a Percentage of 

Average VBA Examiner Salaries 

Note: One DDS did not provide examiner salary data. 

In addition to facing high turnover and growing caseloads, more than 

three-quarters of all DDS directors (43) reported experiencing difficulties 

over a three-year period in recruiting and hiring enough people who could 

become successful examiners.44 Of these directors, more than threequarters said that such difficulties contributed to decreased accuracy in 

disability decisions or to increases in job stress, claims-processing times, 

examiner caseloads, backlogs, or turnover.45 For example, one SSA official 

explained that, because of state-imposed hiring restrictions, one DDS 

 44DDS directors responding to this survey question had experienced recruiting and hiring 

difficulties for any of fiscal years 2000, 2001, or 2002. We characterized DDSs as having 

difficulty if the director reported having some to very great difficulty in recruiting and 

hiring. 

45We categorized a condition as a consequence of recruiting and hiring difficulties if DDS 

directors reported that the difficulties had contributed to the condition from some to a very 

great extent. 

DDSs Face Difficulties in 

Recruiting and Hiring 

Partly Due to StateImposed Personnel 

Restrictions 

0

5

10

15

100% or

greater

40-49% 50-59% 60-69% 70-79% 80-89% 90-99%

DDSs

2

6

11 11 11

6

4

DDS examiner salaries as a percentage of VBA salaries

Sources: GAO analysis of survey of DDS directors, April 2003, and GAO analysis of OPM’s Central Personnel Data File.
Page 23 GAO-04-121 Social Security Administration 

developed a large backlog of cases that negatively affected its 

productivity. 

When we asked DDS directors what made it difficult for their DDSs to 

recruit and hire, they said that the following factors, many of which were 

related to state personnel restrictions, made it moderately to much more 

difficult than it would be otherwise to recruit and hire: 

• state limits on examiner salaries and other forms of compensation, 

• restrictive job classification system for state employees, 

• state-imposed hiring limitations or hiring freezes and lengthy time periods 

for the state to hire DDS examiners, and 

• SSA-imposed hiring restrictions and budget allocations limiting DDS 

staffing levels. 

State limits on examiner salaries and other forms of compensation. 

More than two-thirds of all directors reported that state limits on examiner 

salaries hindered recruiting and hiring, and the same proportion reported 

that noncompetitive salaries were insufficient to recruit or retain staff with 

the skills necessary to assume enhanced examiner responsibilities.46 One 

DDS director noted in survey comments that the low entry-level salary for 

examiners in that particular state no longer attracted “...the caliber of 

employees needed to perform the increasingly complex [examiner] job.” 

Another commented that, owing to noncompetitive salaries, job 

candidates “...who have the requisite combination of skills needed as a 

[disability examiner] will find better offers of employment, [with] either 

better pay or less workload stress.” And officials we spoke with in an SSA 

regional office said that low examiner salaries in still another DDS have 

meant that this DDS has been unable to recruit candidates with strong 

analytical skills. They noted that the DDS has, therefore, had difficulty 

training its new examiners in such challenging tasks as weighing the 

credibility of medical and other evidence. In addition to citing limits on 

salaries, more than half of all directors reported that state limits on other 

forms of compensation, such as performance-based pay and hiring 

bonuses, also contributed to recruiting and hiring difficulties. 

 46Specifically, the DDS directors said that noncompetitive salaries that were insufficient to 

attract or retain staff with skills to become SDMs were or were likely to be a moderate to 

very serious challenge for their DDSs in making the transition to the SDM position. Under 

the SDM position, examiners would be given expanded authority for making disability 

decisions, allowing them in many cases to independently decide claimants’ eligibility for 

benefits without the need for medical consultant approval. The agency is currently testing 

this position. 
Page 24 GAO-04-121 Social Security Administration 

Restrictive job classification system. Nearly one-half of all DDS 

directors attributed difficulties in recruiting and hiring examiners to their 

restrictive state job classification systems. Close to a third of all states 

place disability examiners in the same classification as other positions—

such as a vocational rehabilitation specialist—and some DDS officials we 

interviewed said this made it difficult to attract people with skills 

appropriate to the disability examiner position. 

State-imposed hiring limitations and lengthy time for hiring. Nearly 

one-half of all DDS directors cited state hiring limitations or hiring 

freezes—and more than one-third reported lengthy hiring processes—as 

impediments to acquiring qualified examiners. For instance, officials we 

interviewed in one DDS explained that their state government had capped 

the number of staff the DDS could hire. These officials noted that, while 

SSA was willing to fund hiring above that level, it could take three years to 

obtain the state legislature’s approval to increase the DDS staffing level. 

SSA officials told us that another DDS could only hire individuals who 

have taken a required state test. They explained that, because the state 

administers the test only two times a year, the requirement hampers DDS 

hiring efforts. 

SSA-imposed hiring restrictions and budget allocations. Close to 

two-thirds of all DDS directors said that, over the past three fiscal years, 

SSA-imposed hiring restrictions and budget allocations that limit DDS 

staffing levels have presented recruiting and hiring challenges for the 

DDSs. DDS managers explained in interviews and in survey comments 

that, given the one to two years it takes for an examiner to become fully 

trained, DDSs that are restricted from quickly replacing staff lost to 

attrition will not have sufficient numbers of experienced examiners to 

process future claims. 

In addition to high turnover and difficulties in recruiting and hiring, the 

DDSs are also experiencing gaps in key knowledge and skills areas. When 

we surveyed all DDS directors about specific knowledge and skill needs, 

nearly one-half said that at least a quarter of their examiners needed 

additional training or mentoring in each of the following areas to 

successfully assume expanded responsibilities under an enhanced 

examiner position in either the present or the future:47

 47The question excluded trainee examiners. 

Many Examiners Need 

Additional Training in Key 

Analytical Areas 
Page 25 GAO-04-121 Social Security Administration 

• assessment of an applicant’s symptoms and evaluation of the credibility of 

medical and other evidence, 

• evaluation of the weight to be given to medical evidence from a treating 

physician, 

• assessment and documentation of an applicant’s ability to function, 

• assessment of vocational factors, 

• updates on policies and procedures, and 

• assessment of childhood disabilities. 

Even for those 19 DDSs in our survey that were testing the enhanced 

examiner position at the time of our study, over half (11 DDSs) reported 

that at least a quarter of the examiners with expanded responsibilities 

needed additional training or mentoring in two or more of these same 

knowledge and skill areas, and eight of these directors reported needs in 

four or more of these areas.48

But regardless of whether a DDS was testing this enhanced position, these 

areas are critical to the examiner’s task of disability decision-making in 

general. Indeed, one DDS director explained in an interview that, while 

that DDS was not officially testing this position, over the last several years 

it had hired examiners who were able to function in a manner that was 

increasingly independent of the medical consultant. This director noted 

that, as a result, it was becoming more difficult to distinguish the 

responsibilities of the disability examiner from those of an examiner with 

enhanced authority. Moreover, under SSA’s new approach for improving 

the disability determination process, these same knowledge and skill areas 

will be even more critical as DDS examiners take responsibility for 

evaluating only the more complex claims and as they are required to fully 

document and explain the basis for their decision.49

 48Twenty DDSs were testing the SDM position at the time of our study. We administered 

our survey to 19 of these DDSs. We excluded one of the DDSs that was testing the SDM 

position—the Guam DDS—from this survey. 

49These new examiner responsibilities were outlined by the Commissioner in her testimony 

before the Subcommittee on Social Security of the House Committee on Ways and Means, 

September 25, 2003. 
Page 26 GAO-04-121 Social Security Administration 

DDS directors cited several obstacles to examiners receiving needed 

training or mentoring.50 These obstacles primarily involved high workload 

levels that limited the time available to either provide or receive training 

or mentoring. Specifically, more than 70 percent of all DDS directors 

reported that work demands impeded mentors from providing examiners 

with needed on-the-job training.51 In addition, about two-thirds of all DDS 

directors reported that either the large size of examiners’ caseloads or 

high expectations for completing those cases did not allow examiners 

enough time to attend training. And more than half of all directors cited 

high work levels as a barrier to examiners seeking mentoring assistance. 

Despite the workforce challenges facing them, a majority of DDSs do not 

conduct long-term, comprehensive workforce planning. Of the DDSs that 

engage in workforce planning that is longer-term, a majority have plans 

that lack key workforce planning strategies, such as those for recruiting, 

retention, or succession planning. Directors identified numerous obstacles 

to long-term workforce planning, such as a lengthy state process to 

approve DDS human capital changes. 

The majority of DDSs do not conduct long-term, comprehensive 

workforce planning. As figure 4 shows, more than half of all the DDSs 

have workforce planning time horizons of less than two years, and almost 

one-half have a time horizon of no longer than a year (the time horizon of 

SSA’s annual budget process for the DDSs). 

 50We asked whether various factors were obstacles to nontrainee examiners receiving 

additional mentoring or refresher training over the next two years to successfully perform 

the SDM role or to become successful SDMs. However, as discussed above, the skills 

needed to perform the SDM role apply more broadly. We categorized a factor as an 

obstacle if DDS directors deemed it to be a moderate to very serious obstacle to receiving 

needed training or mentoring. 

51Current and former DDS officials told us that on-the-job training provided by mentors was 

essential to learning to successfully perform the examiner job. 

The Majority of DDSs 

Do Not Conduct LongTerm, Comprehensive 

Workforce Planning, 

and DDSs Cite 

Numerous Obstacles 

to Doing So 

The Majority of DDSs Do 

Not Conduct Long-Term, 

Comprehensive Workforce 

Planning 
Page 27 GAO-04-121 Social Security Administration 

Figure 4: Percentage of DDSs by their Workforce Planning Time Horizons 

Note: Data provided in the figure do not add to 100 percent due to rounding. 

10%

33%

12%

46% No longer than 

1 year

13 months to less

than 2 years

2 years to less than 4 years

4 years to less than 6 years

Source: GAO survey of DDS directors, April 2003.

Over half of

the DDSs

have workforce

planning time

horizons of

less than

2 years
Page 28 GAO-04-121 Social Security Administration 

DDS directors who reported that their workforce planning time horizons 

are no longer than a year mainly rely on SSA’s annual budget process for 

the DDSs for their workforce planning. However, SSA officials told us in 

interviews that their budget process is not designed to serve as a long-term 

strategic workforce planning process. These officials said that the 

following strategies of comprehensive, long-term workforce planning are 

generally not part of the budget process but rather are left to the states: 

• recruiting strategies, 

• retention strategies, 

• training and professional development strategies, 

• compensation strategies, 

• performance expectation and evaluation strategies, 

• employee-friendly workplace strategies, 

• succession planning and strategies for maintaining expertise in the long 

term, and 

• contingency plans, in the event that resource levels do not meet 

expectations.52

In addition, even among the 28 DDSs that engage in workforce planning 

that is longer-term than one year, the majority (18) lack one or more of 

these key workforce planning strategies.53

Furthermore, many DDSs do not collect the data needed to develop 

effective workforce plans.54 Although DDSs face high turnover and are 

expected by SSA to experience a retirement wave in the next decade, over 

half of all DDS directors said they had not made projections of expected 

retirements and other separations for examiners and related staff within 

the last two fiscal years. 

Although the majority of DDSs do not conduct comprehensive, long-term 

workforce planning, some state governments do engage in strategic 

workforce planning efforts that encompass DDS employees. For example, 

 52While other strategies also may be included in workforce planning efforts, our prior work 

has found that the strategies listed are key to effective workforce planning. See 

GAO-01-263. 

53We found that only 10 of the 28 DDSs that conduct workforce planning efforts longerterm than SSA’s annual budget process include all 8 key planning strategies. 

54Our prior work has shown that accurate, comprehensive human capital data are essential 

to good workforce planning. See GAO-02-373SP. 
Page 29 GAO-04-121 Social Security Administration 

the state parent agency of one DDS has produced reports identifying the 

workforce risks faced by the DDS (such as a coming retirement wave) and 

has assisted the director with succession planning. However, ongoing 

studies of state government workforce planning efforts have found that 

formal strategic workforce planning is not taking place in all states.55

During an interview with several DDS directors, we were told that even 

states with sophisticated long-term workforce planning efforts are not 

necessarily focusing on ensuring that their DDSs have the workforces 

needed to accomplish SSA goals, such as reducing claims-processing 

times. 

DDS directors noted in interviews that they face unique challenges related 

to the federal-state relationship that compound the difficulties of planning 

for future workforce needs. We asked DDS directors in our survey to what 

extent they had experienced various factors that might make workforce 

planning more difficult than it would be otherwise. Directors identified the 

following as major obstacles to long-term workforce planning:56

• Lengthy state processes to approve DDS human capital changes. 

Over half of all DDS directors said that lengthy state processes to approve 

DDS human capital changes made statewide DDS long-term workforce 

planning more difficult. For example, an SSA official said it took over a 

year to obtain approval to hire seven DDS staff due to a state hiring freeze. 

In addition, a 2001 audit by SSA’s Office of the Inspector General found 

that the parent agency of one DDS had failed to provide sufficient staffing 

resources, such as timely permission to fill vacancies, for the DDS to 

efficiently process its disability workload.57

• Inconsistencies between state and SSA human capital policies. 

Two-thirds of all DDS directors reported that long-term planning is made 

more difficult than it would be otherwise due to inconsistencies between 

state and SSA human capital policies, such as those related to staffing 

 55Syracuse University, Maxwell School of Citizenship and Public Affairs, Government 

Performance Project, Paths to Performance in State & Local Government (Syracuse, NY: 

2002). 

56We categorized these factors as obstacles to long-term workforce planning if directors 

reported that they had experienced them to a moderate to very great extent. 

57Management Advisory Report, Single Audit of the State of Louisiana for the Fiscal Year 

Ended June 30, 2001, Office of the Inspector General, Social Security Administration 

(December 2002). 

DDS Directors Cited 

Numerous Obstacles to 

Long-term Workforce 

Planning 
Page 30 GAO-04-121 Social Security Administration 

levels. For example, a former DDS director we spoke with explained that 

directors have had difficulties planning for future needs because of 

discrepancies between hiring levels authorized by SSA and those approved 

by their states. One DDS director told us that after working for two years 

to obtain state approval to hire additional examiners initially authorized by 

SSA, the DDS lost permission from SSA to fill the positions. 

• Directors’ concern that SSA does not incorporate DDS workforce 

plans when making resource decisions. When asked in our survey what 

makes long-term planning more difficult, over two-thirds of DDS directors 

reported their concern that SSA does not incorporate the DDSs’ workforce 

plans when making resource decisions. Moreover, 45 DDS directors 

responded that they had only some or no opportunity to factor future DDS 

human capital needs into SSA’s spending projections beyond the 

upcoming fiscal year. Several DDS officials explained in interviews that 

long-term planning seemed futile if SSA was not going to use the results of 

the DDS planning efforts when making resource decisions. SSA officials, 

however, told us that they consider input from the DDSs related to funding 

decisions on a regular basis. SSA officials explained that the agency must 

disperse funds within its own overall budget allocation, and this often 

does not allow for meeting all DDS funding requests. 

• Uncertainty about future resource levels from SSA and stateimposed hiring restrictions or separation incentives. Over threequarters of all DDS directors we surveyed reported that long-term 

planning is made more difficult by uncertainty about future resource levels 

from SSA, as well as uncertainty about resources needed to implement 

major changes in SSA policies, procedures, and systems. In addition, onehalf of DDS directors surveyed said that DDS long-term workforce 

planning was made more difficult by uncertainty about state-imposed 

hiring restrictions or separation incentives. 

• Insufficient time to attend to future problems and insufficient data 

for workforce planning. Three-quarters of all directors surveyed said 

that they had insufficient time to attend to future problems because of the 

need to focus on current human capital challenges. One DDS director said 

in an interview that the day-to-day demands of directors’ jobs, such as 

managing high caseloads and hiring and training new examiners, often 

prevent them from planning for future workforce needs. Other DDS 

directors and officials told us that, when planning does take place, it is 

generally crisis-driven and reactive rather than long-term and strategic. In 

addition, over half of the directors reported in our survey that insufficient 

data for workforce planning makes DDS long-term workforce planning 

more difficult. Moreover, DDSs that do not engage in workforce planning 
Page 31 GAO-04-121 Social Security Administration 

longer-term than one year were more likely than other DDSs surveyed to 

cite insufficient data and planning tools, such as statistical software and 

information technology systems, as challenges that make long-term 

workforce planning more difficult. 

SSA’s workforce efforts have not sufficiently addressed both present and 

future DDS workforce challenges. Neither SSA’s strategic plan, nor its 

annual performance plan, nor its workforce plan adequately addresses the 

human capital challenges facing the DDSs. In addition, in our survey, DDS 

directors reported being dissatisfied with the adequacy of the training that 

SSA provides to the DDSs. Beyond training, SSA has not consistently 

provided other human capital assistance across the DDSs and faces 

difficulties negotiating human capital changes, such as increases in 

examiner salaries, with state governments. Finally, SSA has not used the 

statutory authority it has to set standards for the DDS workforce. 

SSA has not developed a nationwide strategic workforce plan that 

addresses present and future human capital challenges in the DDSs. As 

shown in figure 5, SSA does recognize a need to have higher-skilled and 

better-compensated DDS employees. In addition, SSA’s strategic plan for 

2003-2008 places a high priority on improving the accuracy and the 

timeliness of the disability decision-making process. While 

accomplishment of this objective depends to a great extent on the DDS 

workforce, the plan cautions that the DDSs, like SSA, will face a 

continuing challenge of hiring and retaining a highly skilled workforce in a 

competitive job market. Nevertheless, SSA’s strategic plan, as well as the 

agency’s annual performance plan and workforce plan, are all largely 

silent on the means and strategies the agency will use to recruit, develop, 

and retain a high-performing DDS workforce, even though the 

Government Performance and Results Act now requires agencies to 

include in their annual performance plans a description of the human 

capital strategies needed to meet their strategic goals. 

SSA’s Workforce 

Efforts Have Not 

Sufficiently 

Addressed Present 

and Future Human 

Capital Challenges in 

the DDSs 

SSA’s Strategic and 

Workforce Plans Do Not 

Adequately Address DDS 

Human Capital Challenges 
Page 32 GAO-04-121 Social Security Administration 

Figure 5: Means and Strategies Addressing the DDS Workforces Are Largely Absent from SSA’s Strategic and Workforce 

Plans 

a

SSA officials said in interviews that SSA is no longer pursuing two proposed strategies for improving 

training for disability examiners. 

Absent any strategic workforce plan addressing DDS employees, SSA does 

not use data that it collects on the DDS workforces in a strategic manner. 

Improving the initial disability determination process.

Accelerating the electronic disability initiative.

Eliminating backlogs.

Improving training of disability examiners.a

Service Staff

Strategic Goals:

To deliver high-quality, citizen-centered service. To strategically manage and align staff to support

SSA’s mission.

Key Outcomes:

Demonstrate an improvement in the retention rate.

Ensure ongoing job enrichment opportunities and training.

SSA’s 2010 Vision

SSA’s Future Workforce Transition Plan

“The Agency’s focus on the front-end of the disability processes...required a corresponding investment in the SSA and

DDS employees involved in those processes; both workforces needed to be higher skilled and compensated.” 

“SSA’s Future Workforce Transition Plan was created...as a requirement of SSA’s strategic plan to outline

how SSA will transition from the workforce we have today to the workforce we will need in the future.”

No initiatives addressing DDS employees in the workforce plan

Reduce significantly the time it takes for a disability claimant to receive a

final agency decision.

Eliminate backlogs for initial disability claims, hearings, and appeals by

2008.

No means and strategies addressing DDS

employees

Recruit, develop and retain a high-performing

workforce.

“SSA and the State DDSs will be faced with the continuing

challenge of hiring and retaining a highly skilled and diverse

workforce in what is expected to be a very competitive job

market.”

Source: GAO analysis of SSA documentation.

Strategic Objectives:

Make the right decision in the disability process as

early as possible.

Examples of Means and Strategies Involving DDS Employees:

Key Elements of SSA’s Strategic Plan, 2003-2008

“One of SSA’s highest priorities is to improve service to

the public in the disability programs from the initial claim

through the final... appeal... The length of time it takes to 

process these claims is unacceptable.”
Page 33 GAO-04-121 Social Security Administration 

While SSA routinely gathers certain DDS employee data—such as salaries, 

turnover rates, and the number of new hires and experienced disability 

examiners—the agency primarily uses these data in connection with its 

annual budget process. Moreover, SSA does not regularly collect many 

other key indicators of DDS human capital performance, such as gaps in 

basic skills relative to specific competencies, despite SSA’s acknowledging 

the importance of investing in and retaining a skilled DDS workforce in 

the face of an anticipated retirement wave. 

When we asked SSA officials how workforce planning for the DDSs was 

conducted, they said that they consider DDS workforce matters to be, in 

general, a state government and DDS responsibility, particularly in light of 

the variations in state personnel systems and political concerns. One of 

these officials explained that SSA takes DDS workforce needs into 

account within SSA’s annual budget process and through the consultation 

that occurs between the DDSs and SSA’s regional offices. The regional 

office staff—and in particular, the disability program administrators 

assigned as SSA’s liaisons with each DDS—are responsible for providing 

human capital assistance to the DDSs as needed. However, as noted 

earlier, SSA’s annual budget process lacks key components of 

comprehensive, long-term workforce planning. In addition, officials we 

interviewed in one regional office said that they lacked the tools and the 

time to assist the DDSs with long-term strategic workforce planning, and 

SSA officials we spoke with questioned whether disability program 

administrators were sufficiently trained in strategic workforce planning 

techniques. 

Several regional office and former and current DDS officials we spoke 

with expressed a desire for greater SSA leadership in terms of long-term 

strategic workforce planning focusing on DDS human capital challenges. 

One of these officials observed that SSA is already active in a variety of 

DDS human capital areas—such as determining appropriate DDS staffing 

levels, imposing a nationwide DDS hiring freeze, and providing national 

human capital guidance for implementing the electronic disability 

initiative—and could appropriately assist with strategic workforce 

planning. 

DDS directors are dissatisfied with the adequacy of SSA-provided training. 

Specifically, when we asked DDS directors whether they found SSA’s 

training to be adequate to prepare examiners to be proficient in the claims 

process, half or more of the directors responded that they were 

Directors Expressed 

Dissatisfaction with the 

Adequacy of SSA’s Training 

for the DDSs 
Page 34 GAO-04-121 Social Security Administration 

dissatisfied with the adequacy of SSA’s training in each of the following 

knowledge and skill areas:58

• medical knowledge about body systems (32 DDSs), 

• specific knowledge about the disability program (30 DDSs), 

• assessment of vocational factors (29 DDSs), 

• basic claim development techniques (29 DDSs), 

• evaluation of the weight to be given to medical evidence from a treating 

physician (28 DDSs), 

• updates on policies and procedures (28 DDSs), 

• assessment of childhood disabilities (28 DDSs), 

• assessment of an applicant’s symptoms and evaluation of the credibility of 

medical and other evidence (27 DDSs), and 

• use of computers and technologies (26 DDSs). 

Moreover, nearly half of the directors (25 DDSs) reported that they were 

dissatisfied with SSA’s basic training materials for new disability 

examiners, and over one-third (19 DDSs) reported dissatisfaction with 

training on the assessment and documentation of an applicant’s ability to 

function. 

In addition, nearly all DDS directors (49) reported that they had adapted 

(or wanted to adapt) SSA’s training in one or more of these knowledge and 

skill areas to make it adequate.59 When we asked these DDS directors why 

they had adapted or wanted to adapt SSA’s training, more than half cited 

each of the following reasons pertaining to the quality, completeness, and 

timeliness of SSA’s training approach as contributing factors:60

 58In the survey, we explained that SSA’s training included written materials, interactive 

video training technology, and videos. The survey question covered new examiner basic 

training and other training that SSA provides beyond basic training. 

59The survey asked whether the DDS: (1) had adapted SSA training to make it adequate, and 

had offered this training in the past 24 months; or (2) planned to—or wanted to but was 

unable to—adapt SSA training to make it adequate and offer it in the next 12 months. 

Adapting training could involve editing or revising SSA’s training materials, not using some 

of the materials, or offering a substitute course. 

60We categorized factors as reasons for adapting SSA’s training if DDS directors deemed 

them to be a moderately to very important reason. Beyond issues pertaining to quality, 

completeness, and timeliness of SSA’s training, DDS directors who adapted SSA’s training 

cited operating procedures and training preferences that are unique to the DDS as reasons 

for adapting SSA’s training. The question asked about procedures other than those that 

respond to court decisions and laws. 
Page 35 GAO-04-121 Social Security Administration 

• Training is too conceptual and not sufficiently linked to day-to-day case 

processing (44 DDSs). 

• Training provides insufficient opportunity to interact with the trainer (40 

DDSs). 

• Training provides insufficient opportunity to practice skills taught (38 

DDSs). 

• Certain types of training over-rely on the interactive video training 

technology (37 DDSs). 

• Training content is incomplete (32 DDSs). 

• Training presenters lack effective presentation skills (31 DDSs). 

• Training lacks sufficient written materials, such as handouts and desk aids 

(30 DDSs). 

• Training is delivered too early or too late (28 DDSs). 

In interviews, DDS officials expressed some particular concerns about 

video training. Some DDS officials told us that, because presenters lack 

sufficient hands-on case-processing experience, the training that SSA 

provided through its video training technology was too theoretical. In 

addition, other DDS officials described SSA’s video training technology as 

not allowing sufficient opportunity for clarification and follow-up with the 

presenter. Some officials explained that technical problems with the 

technology impeded interaction with the trainers. For example, they told 

us that, while staff are supposed to be able to use a keypad to call in and 

question the presenters during a class broadcast, it is often difficult to 

obtain access to the presenters. Further, some former DDS officials said 

that SSA applies its video training technology to many types of 

instructional needs for which it may not be appropriate. Yet, in our prior 

work, we have noted that, to be effective, the training method used needs 

to be tailored to the nature of the training content.61

We asked SSA officials we spoke with to comment on the DDS directors’ 

views on the quality of SSA-provided training. While an SSA official 

explained that the video training technology helps SSA to provide 

consistent training across the entire country quickly, she acknowledged 

that the training is sometimes too general and explained that SSA is 

attempting to improve the presentations. SSA officials also told us that 

they tap the expertise of the DDS community, among other agency 

 61U.S. General Accounting Office, Human Capital: A Guide for Assessing Strategic 

Training and Development Efforts in the Federal Government, GAO-03-893G

(Washington, D.C.: July 2003). 
Page 36 GAO-04-121 Social Security Administration 

components, to help develop and improve training materials and identify 

training needs. 

However, despite such efforts, nearly 85 percent of all DDS directors 

reported in our survey that they would be able to spend fewer resources 

adapting SSA’s training for use in their individual DDSs if SSA were to 

improve the quality, completeness, and timeliness of its training.62 Our 

survey data show that, in fiscal year 2002, the 52 DDSs used, in total, the 

equivalent of nearly 150 full-time DDS employees in preparing and 

delivering examiner training related to disability claims processing. 

Moreover, staff resources devoted to training may constitute a significant 

portion of total examiner staff in some DDSs. To illustrate, the director of 

one DDS with 83 disability examiners reported in our survey using the 

equivalent of about 12 full-time employees in fiscal year 2002 to prepare 

and deliver examiner training. SSA and DDS officials explained in 

interviews that, while some larger DDSs have staff who are dedicated 

solely to training, smaller DDSs generally use their most experienced, and 

hence most productive, examiners to prepare training and deliver it to 

their staff. 

Beyond training, information from our survey and interviews shows that 

SSA has not consistently provided other human capital assistance across 

the DDSs and faces difficulties negotiating human capital changes, such as 

increases in examiner salaries, with state governments. SSA provides 

many types of human capital assistance to the DDSs through its regional 

offices and its headquarters. For example, SSA regional office officials we 

interviewed explained that they have attempted to persuade state 

governments to exempt examiners from state hiring restrictions and to 

reclassify DDS examiner positions and increase examiner salaries in light 

of new responsibilities. In addition to the assistance provided by regional 

offices, SSA officials said that SSA headquarters has provided human 

capital assistance to the DDSs, such as sponsoring a study that identified 

the knowledge, skills, and abilities required for the disability examiner 

position, among other positions. 

But in our survey of the DDS directors who said they wanted particular 

types of human capital assistance from SSA headquarters and its regions, 

 62We included in this calculation those DDS directors who responded that they would be 

able to spend fewer resources in adapting SSA’s training from some to a very great extent. 

SSA Has Not Consistently 

Provided Other Human 

Capital Assistance across 

the DDSs and Faces 

Difficulties Negotiating 

Key Human Capital Issues 

with State Governments 
Page 37 GAO-04-121 Social Security Administration 

more than half said that they had not received assistance in each of the 

following areas:63

• help with regular nationwide surveys of examiners’ issues and concerns 

(32 out of 36 DDSs), 

• help in negotiating increases in examiner salaries with state government 

officials (24 out of 36 DDSs), 

• guidance on roles and responsibilities for examiners with enhanced 

responsibilities (22 out of 42 DDSs), 

• help in designing training and developing training materials for examiners 

with enhanced responsibilities and the staff who will be supporting them 

(22 out of 42 DDSs), 

• help with workforce planning, including projecting turnover and 

developing succession plans (21 out of 31 DDSs), 

• guidance on how to determine which examiners have sufficient skills to 

take on enhanced examiner responsibilities (15 out of 20 DDSs), and 

• help in identifying gaps in examiner skills (15 out of 21 DDSs). 

In interviews, some DDS directors specifically cited surveys of examiners’ 

issues and concerns as an area with which they wanted assistance. They 

explained that such surveys could be used to identify and share DDS best 

practices in managing staff, including how different DDSs manage 

examiner caseloads and train examiners. One director noted that 

information on DDS best practices in human capital management is not 

currently available and that only SSA can “survey the landscape 

nationally.” Moreover, a former DDS director explained that directors view 

nationwide surveys as a means for communicating to SSA their human 

capital challenges. 

We also asked DDS directors about the effectiveness of various types of 

human capital assistance that they did receive from SSA and its regional 

offices, including assistance in negotiating human capital changes with 

state governments. We found that more than half of the DDS directors who 

received assistance said that such assistance was of limited effectiveness 

in each of the following areas:64

 63We categorized these types of assistance as ones that DDS directors wanted if the 

directors said that they wanted them from some to a very great extent. 

64We categorized an area of assistance as being of limited effectiveness if DDS directors 

deemed it to be moderately to not effective. 
Page 38 GAO-04-121 Social Security Administration 

• helping project trends in the nature of the disability workload (24 out of 34 

DDSs); 

• assisting in negotiating easing of state restrictions (e.g., on hiring and 

travel) with the state government (19 out of 24 DDSs); 

• providing guidance on roles and responsibilities for examiners with 

enhanced responsibilities (18 out of 26 DDSs); 

• helping to design training and developing training materials for examiners 

with enhanced responsibilities and the staff who will be supporting them 

(16 out of 22 DDSs); 

• assisting in allowing DDSs to reduce the total caseload level for examiners 

taking on enhanced responsibilities (13 out of 24 DDSs); 

• helping in assessing readiness for transition to an examiner role with 

enhanced responsibilities (12 out of 14 DDSs); 

• helping with workforce planning, including projecting separations and 

developing succession plans (11 out of 13 DDSs); and 

• providing help in negotiating increases in examiner salaries with the state 

government (11 out of 16 DDSs). 

Regional office officials and DDS directors explained in interviews that the 

effectiveness of SSA and its regional offices in helping the DDSs negotiate 

human capital changes with the states can be limited by such factors as 

state budget problems, political concerns, and personnel rules. For 

example, some officials said in interviews that state budget crises had 

created political pressure to limit or prevent increases in state employee 

salaries. Other DDS directors told us that state officials were concerned 

that raising examiner salaries would prompt increases in the salaries of 

other state employees, such as employees within the same job 

classification. In addition, although 19 DDS directors reported in our 

survey that DDS salary levels are open to negotiation with unions, some 

regional office officials said in interviews that obtaining salary increases 

for disability examiners apart from other state employees covered by 

union contracts could be difficult. 

In light of such difficulties in negotiating human capital changes with the 

states, one key regional office official we spoke to said that “all the 

regional office can do is cajole” the state governments about DDS human 

capital issues, since under the regulations the authority in this arena 

generally remains with the states. Similarly, another top regional official 

cautioned that, while the regional office tries to help the DDSs address the 

human capital challenges they face, it is difficult to do so. This official 

stated that the federal-state relationship is “unwieldy,” explaining that it is 

easier for state governments to apply state human capital policies—such 

as hiring freezes—to all state personnel than to make exceptions for DDS 
Page 39 GAO-04-121 Social Security Administration 

employees, despite SSA’s full reimbursement of DDS expenses. The 

official said that, because the regional office must continually educate and 

explain to each newly elected state governor’s administration that the DDS 

is federally funded, the regional office is seeking ways to make such 

education more effective and less labor-intensive. Indeed, current and 

former DDS directors we spoke with said that outreach from SSA to state 

governors through such national groups as the National Governors 

Association (NGA) is needed to foster an appreciation of the importance 

of a highly qualified DDS workforce to improving service to disability 

claimants.65

SSA has not used the statutory authority it has to set standards for the 

DDS workforce. Although amendments to the Social Security Act in 1980 

granted SSA the authority to issue regulations to ensure effective and 

uniform administration of the national disability programs, SSA has not 

used this authority to address wide variations in staff salaries, entry-level 

qualification requirements, and training for different DDSs. The Social 

Security Advisory Board, in 2001, called these variations potential 

contributors to inconsistencies in SSA’s disability decisions.66 Emphasizing 

that the disability programs are national in scope and that equal treatment 

for all claimants wherever they reside is essential, the Advisory Board 

recommended that SSA revise its regulations to establish guidelines for 

salaries, entry-level qualification requirements, training, and other factors 

 65While some regional office officials said that they interact at the governors’ level in the 

individual states and, in at least one instance according to SSA, with a regional governors’ 

association, we could find, to date, no record from the NGA of discussions or forums in 

recent years focusing on the topic of the DDS workforce issues under the federal-state 

relationship regarding SSA’s disability programs. We asked staff of the NGA whether, 

during the last five years, NGA staff had met with representatives of SSA’s Office of the 

Commissioner or received communications from SSA on issues related to the DDSs and 

their employees. We also asked whether issues related to SSA’s disability decision-making 

had appeared on the agenda of NGA official meetings over the last five years. 

66Social Security Advisory Board, Disability Decision Making: Data and Materials 

(Washington, D.C.: January 2001). 

SSA Has Not Used Its 

Statutory Authority to 

Address DDS Workforce 

Needs 
Page 40 GAO-04-121 Social Security Administration 

affecting the ability of DDS staff to make quality and timely decisions.67

SSA has not acted on the Advisory Board’s recommendations, however. 

While SSA officials acknowledged in interviews that the agency has the 

authority to establish uniform minimum human capital standards, they 

told us that the agency has chosen not to exercise this authority because 

of concerns about the difficulties such actions could raise in terms of the 

federal-state relationship. For example, they explained that requiring 

uniform human capital standards might be perceived by some states as 

unwelcome federal interference in state operations and could raise the 

prospect of states withdrawing their participation in making disability 

determinations for the disability programs. Indeed, in a prior report, we 

noted that, in the late 1970s, SSA could get only 21 of the 54 DDSs to revise 

their operating agreements with SSA, partly because the states regarded 

the revisions as infringements on their traditional prerogatives. The 

revised agreements required DDSs to comply with guidelines issued by 

SSA with regard to personnel matters, among other administrative 

requirements.68

Many DDS and SSA officials we spoke with acknowledged the difficulties 

that would be involved with implementing uniform standards for DDS 

personnel. Nevertheless, the National Council of Disability Determination 

Directors and several DDS and SSA officials we interviewed (including 

some top regional office officials) expressed the view that uniform 

standards for DDS employees could help address the human capital 

challenges confronting the DDSs.69 Some referred to the vocational 

 67Social Security Advisory Board, Charting the Future of Social Security’s Disability 

Programs: The Need for Fundamental Change (Washington, D.C.: January 2001). The 

Advisory Board also recommended that regulations be revised to ensure that state hiring 

freezes would not apply to the DDS workforce. In making its recommendations, the 

Advisory Board stated that if any state withdrew from the DDS program, the agency should 

be prepared to take over that responsibility from the state. 

68U.S. General Accounting Office, Current Status of the Federal/State Arrangement for 

Administering the Social Security Disability Programs, GAO/HRD-85-71 (Washington, 

D.C.: September 30, 1985). 

69In questions and answers submitted for the record to the Subcommittee on Social 

Security, Committee on Ways and Means, House of Representatives, the National Council 

of Disability Determination Directors stated that they agreed with the Social Security 

Advisory Board’s recommendation that SSA’s regulations be revised to require states to 

follow specific federal guidelines pertaining to human capital management in the DDSs. 

The council submitted these questions and answers on August 29, 2002, as follow-up to 

their June 11, 2002, testimony. 
Page 41 GAO-04-121 Social Security Administration 

rehabilitation program administered by the Department of Education’s 

Rehabilitation Services Administration in partnership with the states as an 

example of a federal-state program that has set qualification standards for 

state employees.70

DDS disability examiners are essential to SSA’s meeting its strategic goal 

for better serving disability claimants by making the right decision in the 

disability process as early as possible. Yet SSA has not developed a 

nationwide strategic workforce plan to address the very personnel who 

will be crucial to meeting that goal. The immediate challenges that DDS 

directors face today in maintaining and improving the examiner workforce 

are unlikely to lessen with time and will likely have even more severe 

consequences as the DDSs confront increasing numbers of applicants for 

disability benefits. The critical task of making disability decisions is 

complex, requiring strong analytical skills and considerable expertise, and 

it will become even more demanding with the implementation of the 

Commissioner’s new long-term improvement strategy and the projected 

growth in workload. Moreover, because SSA has not set uniform minimum 

qualifications for examiners, some DDSs may find it difficult to justify an 

appropriate job classification and level of compensation needed to recruit 

and retain these critical employees. 

Without a plan to develop and maintain a skilled workforce—as well as 

measures to establish uniform minimum qualifications for examiners, 

close critical skill gaps, and improve training—SSA’s ability to provide 

high-quality service to disability claimants could be further weakened by 

gaps in critical competency areas and the loss of experienced DDS 

examiners due to high turnover. As vacancies are filled by new hires and 

trainees who need one to two years to become fully productive, the DDSs 

will likely have difficulty maintaining skill levels and successfully coping 

with expected high growth in workloads. The combination of decreased 

overall skill levels and increased workload could make the work 

 70The Rehabilitation Act requires state vocational rehabilitation agencies to establish 

personnel standards for rehabilitation counselors that are consistent with the degree 

standards of the highest licensing, certification, or registration requirement in the state, or 

the degree standards of the national certification program. As a result, vocational 

rehabilitation counselors in most states must hold a master’s degree in rehabilitation 

counseling or certain comparable qualifications. A few states require a bachelor’s degree. 

States must report annually on the number of rehabilitation counselors who meet their 

established standards and on their plans to train counselors who do not meet the 

standards. 

Conclusions 
Page 42 GAO-04-121 Social Security Administration 

environment even more stressful, further increasing turnover. This 

spiraling effect, if not addressed, could undermine the agency’s efforts to 

ensure that disability decisions are made accurately, consistently, and in a 

timely manner. 

A strategic workforce plan is even more critical to the Commissioner’s 

long-term strategy for improving the disability claims process and her 

ability to bring SSA’s approach to disability decision-making in line with 

the current state of science, medicine, technology, and labor market 

conditions. Failure to look ahead and plan to ensure that the appropriate 

mix of skills and capabilities are available when and where needed could 

obstruct SSA’s progress as it seeks to fundamentally restructure its 

disability programs to improve the accuracy and timeliness of decisions 

and focus on identifying and enhancing claimants’ productive capacities. 

Given such a profound transition in an environment of constrained 

resources, SSA must be able to plan effectively if it is to anticipate how its 

requirements for DDS staff will change and be convincing about the need 

for increased human capital investments. 

It will not be simple to implement a nationwide strategic workforce plan 

for a program that is administered in partnership with the states. 

Negotiating changes in state human capital policies, such as restrictive job 

classifications or hiring limitations, will be difficult. Improving the content 

and delivery of SSA-provided training and closing gaps in examiner skills 

across the DDSs will be challenging and potentially costly. Establishing 

uniform minimum qualifications for examiners throughout the DDSs will 

also be a difficult task, requiring delicate and time-consuming discussions 

with some state governments. However, despite the acknowledged 

difficulties, SSA cannot afford to forgo developing an overarching, guiding 

framework to use as a basis for making short- and long-term human capital 

decisions for the DDSs. As an agency with fiduciary responsibility for 

administering multibillion dollar disability programs that are nationwide in 

scope, SSA has an obligation to take a leadership role in planning—

together with its state partners—to address both the immediate and future 

workforce needs in the DDSs. 

We recommend that SSA take the following actions: 

1. Develop a nationwide strategic workforce plan that addresses present 

and future human capital challenges in the DDSs. This plan should 

enable SSA to identify the key actions needed to deal with immediate 

DDS problems with recruiting and hiring, training, retention, and 

Recommendations to 

the Commissioner of 

SSA 
Page 43 GAO-04-121 Social Security Administration 

succession planning in support of SSA’s strategic plan. It should 

additionally enable SSA to anticipate and plan for the future workforce 

that will be needed as SSA modernizes and fundamentally transforms 

its approach to disability decision-making. To develop and implement 

this comprehensive workforce plan, SSA should work in partnership 

with the DDSs and their parent agencies. As part of the planning 

process, SSA should: 

a. Identify a small number of key DDS indicators of human capital 

performance, including recruiting and hiring measures, level of stress 

in the workplace, training needs, and turnover. SSA should establish 

standards for acceptable performance on these indicators, routinely 

collect and analyze the data to identify trends, and use this information 

to guide decisions regarding future DDS workforce needs and the 

strategies to meet them. 

b. Provide necessary tools and technical assistance to the DDSs to 

enable them to conduct long-term workforce planning. SSA should 

ensure that SSA staff responsible for providing this assistance are well 

trained in the tenets of workforce planning. 

c. Require each DDS to develop its own long-term workforce plan that 

is linked to the nationwide long-term DDS workforce plan. SSA should 

work in partnership with the DDSs and their parent agencies to 

develop these plans. 

d. Establish an ongoing program of outreach from SSA’s leadership to 

state governors and national associations of state government officials 

to discuss the benefits and challenges of the federal-state relationship 

and encourage them to address human capital challenges identified by 

DDS directors, such as salary limits and hiring freezes. 

e. Link performance expectations of appropriate SSA executives to 

their efforts in accomplishing goals and objectives of the workforce 

plan. 

2. Issue regulations that establish uniform minimum qualifications for 

new disability examiners. The minimum qualifications should be based 

on an analysis of the position that identifies the examiner’s 

responsibilities and the minimum knowledge, skills, and competencies 

necessary to adequately perform them. The minimum qualifications for 

the examiner’s position should take into account any changes in the 

complexity of the tasks required for this position stemming from the 

Commissioner’s new long-term strategy. 
Page 44 GAO-04-121 Social Security Administration 

3. Work with DDSs to close the gaps between current examiner skills and 

required job skills. To do so, SSA should work with the DDSs to: 

a. analyze examiner training needs, using as a foundation the analysis 

of job responsibilities and related minimum knowledge, skills, and 

competencies recommended above; 

b. improve training content and delivery to meet these needs, basing 

such efforts on analyses of training content and appropriateness of 

training delivery methods; and 

c. develop performance measures to track effectiveness of these 

improvements to training. 

We provided a draft of this report to SSA for comment. SSA generally 

agreed with the intent of the recommendations in the report but stated 

that the report does not fairly address or adequately discuss the many 

sides of the DDS human capital management issues. In particular, SSA 

criticized some of our study’s methods and expressed concern that we did 

not sufficiently acknowledge the difficulties involved in making changes to 

the federal-state relationship. We continue to believe, however, that the 

report presents a fair and balanced portrayal of the multifaceted issue of 

human capital management in the DDSs. 

Generally agreeing with the intent of our recommendations, SSA said it 

would consider incorporating a nationwide strategic workforce plan for 

the DDSs into its current strategy to improve the disability determination 

process. To do so will be essential, since the Government Performance 

and Results Act now requires agencies to report annually, as we noted in 

our report, on human capital strategies needed to meet their strategic 

goals. Regarding our recommendation on improving training, SSA said that 

it would continue ongoing efforts to improve examiner job skills. Results 

from our survey of DDS directors, however, revealed gaps in critical 

examiner knowledge and skills and a large proportion of DDS directors 

who would be able to spend fewer resources on adapting SSA’s training if 

SSA were to improve the quality, completeness, and timeliness of its 

training. Given such results, our report recommended that SSA go beyond 

its current efforts and base its training improvement initiatives on a 

systematic assessment of the examiner’s job responsibilities and related 

knowledge, skills, and competencies. In terms of our recommendation on 

outreach, SSA said that it is already conducting an outreach program to 

state officials and that it intends to engage in discussions with the NGA on 

Agency Comments 

and Our Evaluation 
Page 45 GAO-04-121 Social Security Administration 

DDS issues. While we noted efforts on the part of SSA’s regional offices to 

negotiate human capital changes with state governments, we maintain that 

SSA’s outreach program requires the sustained attention of SSA’s 

leadership at the national level. SSA’s expressed intent to pursue such 

discussions with the NGA is therefore a step in the right direction.

SSA criticized some of our study methods, saying that we relied heavily on 

opinions of DDS directors and used rather leading and ambiguous survey 

questions. In terms of survey design, we surveyed DDS directors because 

their first-hand experiences make them some of the most knowledgeable 

respondents about human capital challenges experienced in their 

organizations. In addition, our survey was developed in accordance with 

GAO’s guidance on survey design and development,71 including extensive 

pretesting with current and former DDS directors to identify potential 

question bias and to clarify wording. We also gave SSA disability program 

officials, on two occasions, the opportunity to review and comment on the 

survey. Following the second review, the SSA official coordinating the 

review said that, while some of the questions might be difficult for the 

DDS directors to answer, we should go ahead with the survey as it stood. 

The official did not refer to any bias in the survey questions. SSA also was 

concerned that we administered the survey at a time of budget constraint 

that SSA said influenced some of the directors’ responses. Our survey, 

however, reflects ongoing challenges facing the DDSs and was not limited 

to the particular circumstances of 2003. Further, our study findings did not 

rest solely on the opinions expressed in our survey of DDS directors. In 

addition to the survey, we gathered information through interviews with 

several other sources as well, including officials at two DDSs, three SSA 

regional offices, and SSA headquarters; officials of the National Council of 

Disability Determination Directors and the National Association of 

Disability Examiners; and staff of the Social Security Advisory Board. We 

also reviewed pertinent laws, regulations, and procedures, and obtained 

and analyzed human capital data from several sources. 

SSA was also concerned that we did not sufficiently acknowledge the 

attitudes of the states toward modifying federal regulations to establish 

uniform human capital standards and the complexities involved in such 

regulatory changes, such as the problems that SSA says it would face if a 

large state declined to make disability determinations and transferred 

 71U.S. General Accounting Office, Developing and Using Questionnaires, 

GAO/PEMD-10.1.7 (Washington, D.C.: October 1993). 
Page 46 GAO-04-121 Social Security Administration 

these responsibilities to the federal government. We acknowledged in our 

report the difficulties SSA has encountered in convincing the DDSs to 

comply with SSA guidelines on personnel issues, due in part to the states’ 

perceptions of infringements on traditional state responsibilities. We also 

stressed that establishing uniform minimum qualifications for examiners 

will be difficult, requiring delicate and time-consuming discussions with 

some state governments. But we maintain that, despite the difficulties, 

SSA is obligated to address the human capital challenges facing the DDSs. 

An outreach program involving SSA’s leadership and a close working 

partnership among SSA, the DDSs, and their state parent agencies will be 

vital to help ensure the success of SSA’s efforts. 

In addition, SSA expressed a number of other concerns about the draft 

report. These concerns, as well as our comments on them, are provided in 

full in appendix IV. 

Copies of this report are being sent to the Commissioner of SSA, 

appropriate congressional committees, and other interested parties. The 

report is also available at no charge on GAO’s Web site at 

http://www.gao.gov. If you have any questions about this report, please 

contact me at (202) 512-7215. Other contacts and staff acknowledgments 

are listed in appendix V. 

Sincerely yours, 

Robert E. Robertson 

Director, Education, Workforce, 

 and Income Security Issues 
Appendix I: Scope and Methods 

Page 47 GAO-04-121 Social Security Administration 

The following describes the methods we used to survey Disability 

Determination Service (DDS) offices as well as the methods we used to 

compare some of our survey data with data from other sources. 

We surveyed all state DDS directors as well as the DDS directors in the 

District of Columbia, Puerto Rico, and the federal DDS office. We did not 

survey directors in Guam and the South Carolina Office for the Blind 

because these offices each had only one disability examiner. We mailed 

surveys to 53 DDS directors and received responses from all of them. 

However, because most of the questions in our survey do not apply to the 

federal DDS, we reported results for 52 DDSs. Our survey included 

questions about long-term workforce planning, recruiting and hiring, 

compensation, training and development, and retention of disability 

examiners.1

 The survey results in this report represent the views of the 

DDS directors and do not necessarily represent the views of examiners or 

other DDS staff or the views of Social Security Administration (SSA) 

officials. 

The practical difficulties of conducting any survey introduce various types 

of errors related to survey responses. For example, differences in how a 

particular question is interpreted and differences in the sources of 

information available to respondents can be sources of error. In addition, 

respondents might not be uniformly conscientious in expressing their 

views or they may be influenced by concerns about how their answers 

might be viewed by GAO, SSA, or the public. We included steps in both the 

data collection and analysis stages for the purpose of minimizing such 

errors. For example, to address differences in how questions were 

interpreted, we asked two members of the Social Security Advisory Board, 

as well as current and past officers of the National Council of Disability 

Determination Directors and the National Association of Disability 

Examiners, to review and critique the survey questions before pretesting. 

SSA disability program officials also reviewed our survey on two 

occasions. In addition, we pretested the survey with four former DDS 

directors and four current DDS directors. We modified the survey 

questions based on the results of these pretests. 

 1

While we have focused this report specifically on disability examiners, other positions 

employed by the DDSs, such as medical consultants and vocational experts, are also 

critical to the disability determination process. 

Appendix I: Scope and Methods 

Survey of Disability 

Determination Service 

Offices 
Appendix I: Scope and Methods 

Page 48 GAO-04-121 Social Security Administration 

Because we conducted our survey while 20 DDSs were testing the 

feasibility of implementing an examiner position with enhanced 

responsibilities, we tailored a few of the survey questions to be relevant 

for those DDSs testing these enhanced positions as well as for those not 

testing such positions. We also tailored questions for California’s survey, 

which had separate offices testing and not testing the enhanced examiner 

position. In addition, we tailored questions for the survey that went to the 

federal DDS. 

To address possible director concerns about how their answers might be 

viewed, we stated in the introduction to the survey that their responses 

would be reported in summary form only, without being individually 

identified, and that their responses would not be released unless requested 

by a member of Congress (see appendix II for a copy of our survey). 

When we analyzed the data from our survey, where possible, we checked 

survey answers involving numbers and percentages to ensure they 

summed correctly. When we identified a discrepancy, we contacted the 

relevant DDS director to resolve the discrepancy.2

We wanted to determine how turnover rates (overall and for new hires) 

for DDS examiners compared with those for selected groups of federal 

employees. To do this, we compared the turnover rate of DDS examiners 

with that of Veterans Benefits Administration (VBA) examiners, SSA 

employees, and all federal employees. VBA examiners were selected 

because they perform duties similar to DDS examiners, such as developing 

claims using medical and disability program knowledge. We compared 

DDS examiner turnover rates with SSA turnover rates because SSA fully 

funds the DDSs to achieve its disability program mission. The federal 

employee turnover rate was selected as a general baseline.3

We used data from the Office of Personnel Management’s (OPM) Central 

Personnel Data File (CPDF) to calculate turnover rates for VBA 

examiners, SSA employees, and all federal employees.4

 We counted how 

 2

We also recorded all notes and comments from respondents that qualified their responses. 

3

We were unable to obtain comprehensive turnover data for private insurers who employ 

disability examiners. 

4

VBA disability examiners were identified by using their unique occupational code. 

Analysis of Data from 

Our Survey and Other 

Sources 
Appendix I: Scope and Methods 

Page 49 GAO-04-121 Social Security Administration 

many permanent employees in each group left their position in each of 

fiscal years 2000, 2001, and 2002. For VBA examiners and SSA employees, 

transfers to other agencies were counted as separations. For all federal 

employees, only separations from federal service were counted as 

separations. To calculate overall turnover, we divided the number 

separated each year by the average of the number of staff (which we 

obtained by averaging the number of staff at the beginning of the fiscal 

year and the number of staff at the end of the fiscal year).5

We also calculated a new hire turnover rate. We defined a new hire 

separation as a separation of an employee hired in one fiscal year who left 

before the end of the following fiscal year (for example, hired in fiscal year 

2000 and left before the end of fiscal year 2001). To determine the turnover 

rate for new hires, we counted all career and career conditional 

appointments for each fiscal year 2000 and 2001. We then determined how 

many of these separated before the end of the following fiscal year and 

divided this by the number of new hires in the prior fiscal year. We also 

calculated turnover rates for DDS examiners using the same formulas. 

We also compared DDS examiner salaries with VBA examiner salaries. We 

analyzed data from OPM’s CPDF to calculate the average base salary, 

including locality adjustments, for VBA examiners state by state. We 

divided each DDS’s average examiner salary by the average VBA examiner 

salary for each state, the District of Columbia, and Puerto Rico. This 

resulted in a measure of DDS average salary relative to average VBA 

examiner salaries for each location. 

When we analyzed salaries of examiners who left DDSs to accept higher 

salaries in federal agencies, directors of two DDSs provided information 

on both the salaries of these examiners while they were employed by the 

DDSs, and on the federal General Schedule (GS) grade levels for their new 

SSA positions. To determine SSA salaries, we used the 2002 federal 

government GS pay scale, including locality adjustments. For cases in 

which the directors provided us with two possible SSA grade levels, we 

used the first step of the lower grade in our analysis. Three of these 

disability examiners also served as quality assurance reviewers, hearing 

officers, or trainers while employed in their DDS. Positions accepted at 

SSA by the departing examiners included regional office disability quality 

 5

The results of these calculations were multiplied by 100 to express turnover rates as 

percentages. 
Appendix I: Scope and Methods 

Page 50 GAO-04-121 Social Security Administration 

branch analyst, regional office program specialist, and field office claims 

representative, as well as posts in the federal DDS. 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 51 GAO-04-121 Social Security Administration 

Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

We sent this version of 

the survey to the DDSs 

that were not testing the 

single decision-maker 

(SDM) position. We have 

annotated this version to 

indicate how the survey 

that we sent to the DDSs 

that were testing the SDM 

position differed from this 

version. 

In addition, the survey we 

sent to the California 

DDS contained questions 

both for DDSs that were 

testing the SDM position, 

and for those not testing 

the SDM position, 

because some of the 

California DDS branches 

were testing the SDM, 

and some were not. 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 52 GAO-04-121 Social Security Administration 

In the survey sent to 

DDSs that were testing 

the SDM position, the 

definitions and questions 

referred, where 

appropriate, to both 

SDMs as well as disability 

examiners (DEs), so that 

the survey questions 

would cover all 

examiners. 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 53 GAO-04-121 Social Security Administration 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 54 GAO-04-121 Social Security Administration 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 55 GAO-04-121 Social Security Administration 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 56 GAO-04-121 Social Security Administration 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 57 GAO-04-121 Social Security Administration 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 58 GAO-04-121 Social Security Administration 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 59 GAO-04-121 Social Security Administration 

In the survey sent to 

DDSs that were testing 

the SDM position, 

Question 17 referred to 

“current SDMs (excluding 

trainees) who need 

additional mentoring 

and/or refresher training 

to successfully perform 

the SDM role.” 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 60 GAO-04-121 Social Security Administration 

In the survey sent to 

DDSs that were testing 

the SDM position, 

Question 18 referred to 

“obstacles to your SDMs 

receiving needed 

additional mentoring 

and/or refresher training.” 

The question asked: “To 

what extent, if any, is 

each of the following an 

obstacle to your current 

SDMs (excluding 

trainees) receiving, over 

the next two years, 

additional mentoring 

and/or refresher training 

needed to successfully 

perform the SDM role?” 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 61 GAO-04-121 Social Security Administration 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 62 GAO-04-121 Social Security Administration 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 63 GAO-04-121 Social Security Administration 

In the survey sent to 

DDSs that were testing 

the SDM position, 

Question 22 was 

phrased: “To what extent, 

if any, were the following 

factors a challenge for 

your DDS in making the 

transition to the SDM 

position?” 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 64 GAO-04-121 Social Security Administration 

Question 23 was not 

included in the survey 

that was sent to the 

DDSs that were testing 

the SDM position, since 

those DDSs had already 

made the transition to the 

SDM position. 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 65 GAO-04-121 Social Security Administration 

In the survey sent to the 

DDSs that were testing 

the SDM position, the 

“Yes/No” part of Question 

24 was not included. 

Thus, the second part of 

Question 24 was asked 

generally of all DDSs 

testing the SDM position. 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 66 GAO-04-121 Social Security Administration 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 67 GAO-04-121 Social Security Administration 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 68 GAO-04-121 Social Security Administration 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 69 GAO-04-121 Social Security Administration 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 70 GAO-04-121 Social Security Administration 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 71 GAO-04-121 Social Security Administration 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 72 GAO-04-121 Social Security Administration 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 73 GAO-04-121 Social Security Administration 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 74 GAO-04-121 Social Security Administration 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 75 GAO-04-121 Social Security Administration 

In the survey sent to the 

DDSs that were testing 

the SDM, Part II, 

Question 1, did not 

indicate “N/A” in row b. 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 76 GAO-04-121 Social Security Administration 

In the survey sent to the 

DDSs that were testing 

the SDM, Part II, 

Question 3, did not 

indicate “N/A” in row b. 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 77 GAO-04-121 Social Security Administration 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 78 GAO-04-121 Social Security Administration 

In the survey sent to the 

DDSs that were testing 

the SDM, Part II, 

Question 11, row a 

indicated “DEs and/or 

SDMs.” 

In the survey sent to the 

DDSs that were testing 

the SDM, Part II, 

Question 9, row a 

indicated “DEs and/or 

SDMs.” 
Appendix II: Survey of DDS Directors’ Views 

on Human Capital Challenges 

Page 79 GAO-04-121 Social Security Administration 

This question was only 

included in the survey 

sent to the DDSs that 

were testing the SDM 

position. It was not 

included in the survey 

sent to the DDSs that 

were not testing the SDM 

position. 
Appendix III: Related GAO Reports 

Page 80 GAO-04-121 Social Security Administration 

Social Security Disability: Reviews of Beneficiaries’ Disability Status 

Require Continued Attention to Achieve Timeliness and CostEffectiveness. GAO-03-662. Washington, D.C.: July 24, 2003. 

High-Risk Series: An Update. GAO-03-119. Washington, D.C.: January 1, 

2003. 

SSA Disability: Other Programs May Provide Lessons for Improving 

Return-to-Work Efforts. GAO-01-153. Washington, D.C.: January 12, 2001. 

Social Security Disability Insurance: Multiple Factors Affect 

Beneficiaries’ Ability to Return to Work. GAO/HEHS-98-39. Washington, 

D.C.: January 12, 1998. 

SSA Disability: Return-to-Work Strategies from Other Systems May 

Improve Federal Programs. GAO/HEHS-96-133. Washington, D.C.: July 11, 

1996. 

SSA Disability: Program Redesign Necessary to Encourage Return to 

Work. GAO/HEHS-96-62. Washington, D.C.: April 24, 1996. 

Human Capital: Opportunities to Improve Executive Agencies’ Hiring 

Processes. GAO-03-450. Washington, D.C.: May 30, 2003. 

Results-Oriented Cultures: Creating a Clear Linkage between Individual 

Performance and Organizational Success. GAO-03-488. Washington, D.C.: 

March 14, 2003. 

High-Risk Series: Strategic Human Capital Management. GAO-03-120. 

Washington, D.C.: January 2003. 

A Model of Strategic Human Capital Management. GAO-02-373SP. 

Washington, D.C.: March 15, 2002. 

Human Capital: A Self-Assessment Checklist for Agency Leaders. 

GAO/OCG-00-14G. Washington, D.C.: September 2000. 

Human Capital: Key Principles for Effective Strategic Workforce 

Planning. GAO-04-39. Washington, D.C.: December 11, 2003. 

Appendix III: Related GAO Reports 

Modernizing Federal 

Disability Programs 

General Human 

Capital Management 

Strategic Workforce 

Planning 
Appendix III: Related GAO Reports 

Page 81 GAO-04-121 Social Security Administration 

Foreign Assistance: Strategic Workforce Planning Can Help USAID 

Address Current and Future Challenges. GAO-03-946. Washington, D.C.: 

August 22, 2003. 

Tax Administration: Workforce Planning Needs Further Development for 

IRS’s Taxpayer Education and Communication Unit. GAO-03-711. 

Washington, D.C.: May 30, 2003. 

Human Capital Management: FAA’s Reform Effort Requires a More 

Strategic Approach. GAO-03-156. Washington, D.C.: February 3, 2003. 

HUD Human Capital Management: Comprehensive Strategic Workforce 

Planning Needed. GAO-02-839. Washington, D.C.: July 24, 2002. 

NASA Management Challenges: Human Capital and Other Critical Areas 

Need to be Addressed. GAO-02-945T. Washington, D.C.: July 18, 2002. 

Air Traffic Control: FAA Needs to Better Prepare for Impending Wave of 

Controller Attrition. GAO-02-591. Washington, D.C.: June 14, 2002. 

Securities and Exchange Commission: Human Capital Challenges 

Require Management Attention. GAO-01-947. Washington, D.C.: 

September 17, 2001. 

Human Capital: Implementing an Effective Workforce Strategy Would 

Help EPA to Achieve its Strategic Goals. GAO-01-812. Washington, D.C.: 

July 31, 2001. 

Single Family Housing: Better Strategic Human Capital Management 

Needed at HUD’s Homeownership Centers. GAO-01-590. Washington, 

D.C.: July 26, 2001. 

Results-Oriented Cultures: Implementation Steps to Assist Mergers and 

Organizational Transformations. GAO-03-669. Washington, D.C.: July 2, 

2003. 

Homeland Security: Management Challenges Facing Federal Leadership. 

GAO-03-260. Washington, D.C.: December 20, 2002. 

Highlights of a GAO Forum: Mergers and Transformation: Lessons 

Learned for a Department of Homeland Security and Other Federal 

Agencies. GAO-03-293SP. Washington, D.C.: November 14, 2002. 

Organizational 

Transformation 
Appendix III: Related GAO Reports 

Page 82 GAO-04-121 Social Security Administration 

Managing for Results: Using Strategic Human Capital Management to 

Drive Transformational Change. GAO-02-940T. Washington, D.C.: July 15, 

2002. 

FBI Reorganization: Initial Steps Encouraging but Broad 

Transformation Needed. GAO-02-865T. Washington, D.C.: June 21, 2002. 

Human Capital: A Guide for Assessing Strategic Training and 

Development Efforts in the Federal Government. GAO-03-893G. 

Washington, D.C.: July 1, 2003. 

Foreign Languages: Human Capital Approach Needed to Correct 

Staffing and Proficiency Shortfalls. GAO-02-375. Washington, D.C.: 

January 31, 2002. 

Human Capital: Design, Implementation, and Evaluation of Training at 

Selected Agencies. GAO/T-GGD-00-131. Washington, D.C.: May 18, 2000. 

Training and 

Development 
Appendix IV: Comments from the Social 

Security Administration 

Page 83 GAO-04-121 Social Security Administration 

Appendix IV: Comments from the Social 

Security Administration 

Note: GAO comments 

supplementing those in 

the report text appear at 

the end of this appendix. 

See comment 1. 

See comment 3. 

See comment 2. 
Appendix IV: Comments from the Social 

Security Administration 

Page 84 GAO-04-121 Social Security Administration 

See comment 7. 

See comment 6. 

See comment 5. 

See comment 4. 
Appendix IV: Comments from the Social 

Security Administration 

Page 85 GAO-04-121 Social Security Administration 

See comment 10. 

See comment 9. 

See comment 8. 
Appendix IV: Comments from the Social 

Security Administration 

Page 86 GAO-04-121 Social Security Administration 
Appendix IV: Comments from the Social 

Security Administration 

Page 87 GAO-04-121 Social Security Administration 

1. We believe that the report presents a fair and balanced portrayal of the 

multifaceted issue of human capital management in the DDSs. We 

designed the survey to obtain DDS directors’ opinions about the extent 

to which, if any, a DDS had experienced certain human capital 

challenges and the likely factors and consequences involved. 

Moreover, the opinions were obtained from directors whose first-hand 

experiences make them some of the most knowledgeable sources of 

information about such issues in their organizations. But in addition to 

our survey, our overall study methods relied on information and data 

from several other sources as well. For example, we interviewed 

disability examiners and their managers at two DDSs, officials 

responsible for DDS management assistance at three of SSA’s regional 

offices, SSA officials at headquarters, officials of the National Council 

of Disability Determination Directors and the National Association of 

Disability Examiners, and staff of the Social Security Advisory Board. 

We also reviewed pertinent laws, regulations, and procedures, and 

obtained and analyzed human capital data from the DDSs, SSA, and 

other federal agencies. 

Our survey was developed in accordance with GAO's guidance on 

survey design and development.1 To avoid the potential for questions 

to be leading, on every question in which we asked for directors’ 

opinions, we gave them the opportunity to say that they did not 

experience that particular challenge, contributing factor, or 

consequence. To this end, we constructed the questions so that the 

first response choice was “no extent” or equivalent wording. In 

addition, each question was specifically assessed for possible bias or 

problematic wording during extensive survey pretesting. We pretested 

the survey eight times—with four former DDS directors and four 

current directors. On the basis of these pretests, we modified the 

questions until pretesters raised no further issues. 

We also gave SSA disability program officials the opportunity, on two 

occasions, to review and comment on the survey. SSA officials first 

reviewed the survey prior to its pretesting. Among other suggestions, 

they noted that some survey questions were leading in nature and that, 

in addition, we should develop scaled responses to provide 

respondents with the opportunity to modulate their answers (e.g., from 

“no extent” to “very great extent”). We modified the survey on the 

basis of their comments, including revising or eliminating questions 

 1

U.S. General Accounting Office, Developing and Using Questionnaires, GAO/PEMD10.1.7 (Washington, D.C.: October 1993). 

GAO Comments 
Appendix IV: Comments from the Social 

Security Administration 

Page 88 GAO-04-121 Social Security Administration 

that they thought were leading and constructing scaled responses as 

suggested. After additionally incorporating comments of several 

pretesters, we provided SSA with the chance to review a revised 

version of the survey. The official coordinating SSA’s second review emailed us in reply, saying that, while some of the survey questions 

might be difficult for the DDS directors to answer, we should go ahead 

with the survey as revised. The official did not refer to any bias in the 

revised questions. 

Our survey questions and our findings reflect ongoing human capital 

challenges facing the DDSs and were not limited to the particular 

circumstances of fiscal year 2003. The survey questions themselves 

were generally not limited to the most recent year, and several 

explicitly asked for data for the past two or three fiscal years or for the 

future. While the impact of the continuing resolution and the related 

SSA hiring freeze that was in place throughout much of fiscal year 2003 

may have affected DDS directors’ responses, DDS and SSA officials 

have told us that resource constraints and budget uncertainties have 

been ongoing challenges for a number of years. Furthermore, certain 

aspects of the time period in which the survey was conducted likely 

downplayed some of the human capital challenges facing the DDSs. 

For example, DDS officials said in interviews that they expected 

examiner turnover to increase as economic conditions improved in the 

future. 

2. Our report acknowledges the efforts made by SSA regional offices to 

persuade state governments to increase examiner salaries in light of 

their new responsibilities. Our report, however, does not assert that 

24 DDSs were refused assistance with negotiating salary increases for 

examiners after they had requested it. Rather, we said that, of the DDS 

directors who reported wanting help from SSA with negotiating salary 

increases, more than half (24 DDSs) said they had not received this 

kind of help. (SSA interpreted wanting help and not receiving it as 

having requested help and been refused such assistance.) But 

regardless of whether directors have specifically requested this or 

another type of human capital assistance, they reported in their survey 

responses that they want active support from SSA on this and a 

number of other issues involving human capital management. 

3. Our report acknowledges that some states have strategic workforce 

planning initiatives that consider their DDS employees. However, the 

issue relevant to our study was not whether statewide human capital 

management offices were generally effective, as SSA suggests, but 

whether there were any workforce planning efforts by SSA or the 
Appendix IV: Comments from the Social 

Security Administration 

Page 89 GAO-04-121 Social Security Administration 

DDSs that were integral to and supportive of SSA’s mission and goals. 

As we noted in the report, even sophisticated statewide workforce 

planning efforts are not necessarily focused on ensuring that the DDSs 

have the workforces needed to accomplish such SSA goals as reducing 

claims-processing times. 

4. Our report acknowledges SSA’s current efforts at outreach to state 

officials. For example, our report describes efforts on the part of 

regional office officials to persuade state governments to exempt 

examiners from state hiring restrictions, reclassify DDS examiner 

positions, and increase examiner salaries. We also emphasize that SSA 

and its regional offices can be limited in their ability to help the DDSs 

negotiate changes by such factors as state political and budget 

concerns, as well as state personnel rules. However, as noted in our 

report, we found no record to date of any discussions with the 

National Governors Association (NGA) or of NGA focusing on this 

topic. Our recommendation that SSA reach out to national associations 

such as the NGA is an acknowledgment that the DDSs and SSA’s 

regional offices cannot successfully confront these difficult human 

capital challenges without the sustained attention of SSA’s leadership 

at the national level. For clarity, we have emphasized this point in the 

text of our recommendation. SSA’s expressed intent to pursue 

discussions on a national level with NGA is a step in the right 

direction. 

5. We recounted in our report the view of SSA officials that requiring 

uniform human capital standards might be perceived by some states as 

unwelcome federal interference and could raise the prospect of states 

withdrawing their participation in making disability determinations. 

We also noted the difficulties SSA has encountered in the past in 

convincing the DDSs to comply with SSA guidelines on personnel 

issues, due in part to the states’ perceptions of infringements on 

traditional prerogatives. Accordingly, we stressed in our report that 

establishing uniform minimum qualifications for examiners throughout 

the DDSs will be difficult, requiring delicate and time-consuming 

discussions with some state governments. However, establishing such 

qualifications will also be worthwhile, helping some DDSs justify an 

appropriate job classification and level of compensation needed to 

recruit and retain qualified disability examiners. As an agency with 

fiduciary responsibility for administering disability programs that are 

nationwide in scope, SSA has an obligation to do no less than take firm 

steps to address the human capital challenges facing the DDSs. We 

understand SSA’s concern about the difficulties it would face if states 

opted out of the disability program and transferred these
Appendix IV: Comments from the Social 

Security Administration 

Page 90 GAO-04-121 Social Security Administration 

responsibilities to the federal government.2 To help ensure the success 

of SSA’s efforts, outreach from SSA’s leadership to the state governors 

will be vital. Also essential will be a close working partnership among 

the immediate stakeholders—SSA, the DDSs, and their state parent 

agencies—in developing a nationwide strategic workforce plan. 

6. We did not examine the accuracy and timeliness of claims processing. 

Nevertheless, even had these measures of performance improved, the 

Commissioner noted in her September 25, 2003, testimony that SSA 

still has “a long way to go” in its efforts to be more timely and 

accurate, despite positive strides in the short term. Moreover, SSA’s 

own published strategic plan for 2003 to 2008 warns that “the length of 

time it [currently] takes to process these claims is unacceptable.” 

Results from our survey of DDS directors demonstrate the need to 

address such DDS human capital issues as high turnover and recruiting 

and hiring difficulties in order to improve the timeliness and accuracy 

of claims processing. Of the directors (43) who reported experiencing 

difficulties in recruiting and hiring enough people who could become 

successful examiners, more than three-quarters said that such 

difficulties contributed to decreased accuracy in disability decisions or 

to increases in claims-processing times. Moreover, over one-half of all 

directors reported that turnover had increased claims-processing 

times. 

7. Our report neither states nor assumes that higher salaries alone 

guarantee improved DDS performance. Rather, it states that, according 

to more than two-thirds of all DDS directors, noncompetitive pay was 

one of several factors contributing to examiner turnover. Moreover, 

our report emphasized the costly consequences of such turnover, 

noting that the estimated cost of examiner turnover in fiscal year 2002 

was in the tens of millions of dollars. (Our estimates show that this 

would be the case, regardless of whether the calculation is based on 

total turnover or turnover that is above that of the federal government 

as a whole.) SSA itself has been attempting to persuade state 

governments to increase examiner salaries to reflect new job 

responsibilities. Although increased compensation may increase costs, 

the turnover that can result from not addressing human capital 

 2

The Congress was also aware of these difficulties in 1980 when it required SSA to submit a 

detailed plan for how it would assume the functions and operations of a state disability 

determination function, were it necessary to do so. See discussion of Pub. L. No. 96-265, 

§ 304(b)(3) in S. Rep. No. 96-408, at 55 (1980) and in the Preamble to the 1981 Final Rule, 

46 Fed. Reg. 29,190, 29,191 (1981). 
Appendix IV: Comments from the Social 

Security Administration 

Page 91 GAO-04-121 Social Security Administration 

management concerns, such as not compensating employees 

appropriately, can be costly as well, as we note in the report. 

We agree with SSA that some attrition is desirable. But over half of all 

DDS directors told us in our survey that examiner turnover in their 

offices was too high, and we found that examiner turnover was about 

twice that of federal employees performing similar work. Because 

turnover is costly, we emphasize the importance of using data to 

identify current and future human capital needs. We have found in 

prior work that high-performing organizations analyze who is leaving, 

what skill gaps result, and how much turnover is desirable or 

acceptable. Organizations that fail to effectively manage their turnover 

risk not having the capacity to achieve their goals. A balance needs to 

be achieved between bringing in new employees with fresh and vibrant 

perspectives and retaining experienced employees whose institutional 

knowledge can maintain goals and help train others. 

8. We cited the Department of Education’s experience to show that 

establishing federal qualifications requirements for state employees, as 

we recommended that SSA do, can and has been done. While we have 

not studied federal experiences with workforce planning in an 

intergovernmental arena, the GAO reports we provide in appendix III 

highlight an array of initiatives on the part of federal agencies to 

embrace workforce planning, including SSA’s planning models for its 

own employees. SSA has been willing to take the lead and develop 

models in workforce planning for its own employees. It should 

therefore build on its own internal expertise and lessons learned in this 

field to develop models of workforce planning in the demanding 

intergovernmental context as well. Lack of an existing model for the 

range of changes we recommend may make implementation more 

challenging, but it is not a convincing argument for inaction. 

9. We support SSA’s leadership in its efforts to improve the disability 

determination process and to help people with disabilities remain in or 

return to the workforce. SSA said that it generally agreed with the 

intent of our recommendations and would consider incorporating a 

nationwide strategic workforce plan for the DDSs into its current 

strategy to improve disability determinations. To do so will be 

essential, since the Government Performance and Results Act now 

requires agencies to report annually, as we noted in our report, on 

human capital strategies needed to meet their strategic goals. While we 

did not provide an exhaustive treatment of states’ reactions to 

proposals for increased federal control, our report did note past 

opposition of some states to federal guidelines on personnel matters. 
Appendix IV: Comments from the Social 

Security Administration 

Page 92 GAO-04-121 Social Security Administration 

In addition, we have added further detail in the report about the 

regulatory development process. We acknowledge the complexities 

involved in pursuing regulatory change. But despite these difficulties, 

we maintain that SSA has an obligation to address DDS workforce 

needs. 

10. SSA said that it would continue ongoing efforts to improve examiner 

job skills. Results from our survey of DDS directors, however, revealed 

gaps in critical examiner knowledge and skills. Moreover, a large 

proportion of directors said they would be able to spend fewer 

resources on adapting SSA’s training if SSA were to improve the 

quality, completeness, and timeliness of this training. Given such 

results, our report recommended that SSA go beyond its current 

efforts and base its training improvement initiatives on a systematic 

assessment of the examiner’s job responsibilities and related 

knowledge, skills, and competencies. 
Appendix V: GAO Contacts and Staff 

Acknowledgments 

Page 93 GAO-04-121 Social Security Administration 

Robert E. Robertson (202) 512-7215 

Carol Dawn Petersen (202) 512-7215 

In addition to those named above, the following individuals made 

significant contributions to this report: Barbara Bordelon, Marissa Jones, 

Suit Chan, and Beverly Crawford, Education, Workforce, and Income 

Security Issues; Ellen Rubin, Strategic Issues; Gregory Wilmoth, Applied 

Research and Methods; and B. Behn Miller, General Counsel. 

Appendix V: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Staff 

Acknowledgments 

(130196) 
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