a

GAO

United States Government Accountability Office

Report to the Chairman, Committee on 

Finance, U.S. Senate

September 2005 ELECTRONIC 

DISABILITY CLAIMS 

PROCESSING

SSA Is Proceeding 

with Its Accelerated 

Systems Initiative but 

Needs to Address 

Operational Issues

GAO-05-97
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-97.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Linda Koontz at 

(202) 512-6240 or koontzl@gao.gov. 

Highlights of GAO-05-97, a report to the 

Chairman, Committee on Finance, 

U.S. Senate 

September 2005

ELECTRONIC DISABILITY CLAIMS 

PROCESSING 

SSA Is Proceeding with Its Accelerated 

Systems Initiative but Needs to Address 

Operational Issues 

Since January 2004, SSA has been implementing its electronic disability 

system at 53 state disability determination services and 85 Office of Hearings 

and Appeals sites. It plans to complete implementation in all state sites by 

October 2005 and all hearings and appeals sites by November 2005. 

Nonetheless, considerable work is needed before these entities will be ready 

to process all initial claims electronically. SSA’s effort to certify all state 

offices to electronically process claims and maintain the electronic folder as 

an official claims record is not expected to be completed until January 2007. 

In addition, state disability officials expressed concerns about the system’s 

operations and reliability and about limitations in their electronic processing 

capabilities. Accordingly, a number of the offices reported varying levels of 

system usage (see table), and their officials said that processing claims 

electronically generally took longer and consumed more resources than the 

previous method. Further, SSA and the state disability determination 

services lacked continuity of operations plans for ensuring that states could 

continue to process disability claims during emergencies. 

As SSA has implemented its system, it has taken actions that supported three 

of GAO’s five prior recommendations. It has initiated studies that could help 

validate AeDib planning assumptions, costs, and benefits. It has also 

approved new software and certified its systems for production. In addition, 

according to state disability officials, the agency had improved its 

communications with them. However, SSA did not demonstrate action on 

two recommendations calling for thorough testing of its interrelated system 

components before implementation and completion of risk mitigation 

strategies for the projects supporting the initiative. Thorough testing and risk 

mitigation strategies could have helped limit problems with the system’s 

operation and other circumstances that could impede the project’s success. 

Reported Use of the Electronic Disability System in Selected Disability Determination 

Services as of Late June 2005 

Disability 

determination services 

office Implementation date

Percentage of 

examiners using 

new system 

Percentage of initial 

disability cases being 

processed electronically

North Carolina July 2003 100 100

Illinois September 2003 100 100

California October 2003 100 8

Mississippi January 2004 100 100

South Carolina March 2004 100 100

Florida September 2004 31 4–5

Delaware May 2005 100 19

Nebraska June 2005 5 4

Source: GAO analysis of SSA and disability determination service data. 

Note: The last column represents initial disability cases being processed electronically. However, as 

of late June 2005, California, Florida, Delaware, Nebraska, and North Carolina had not yet received 

all of the software they needed to be certified to perform exclusively electronic processing. 

Through an initiative known as 

AeDib, the Social Security 

Administration (SSA) is 

implementing a system in which 

medical images and other 

documents that have traditionally 

been kept in paper folders will be 

stored in electronic folders, 

enabling disability offices—

including SSA’s 144 Office of 

Hearings and Appeals sites and 54 

state disability determination 

services—to process disability 

claims electronically. This initiative 

supports a program that, in 2004, 

made payments of approximately 

$113 billion to more than 14 million 

beneficiaries and their families. In 

March 2004, GAO recommended 

that SSA take steps to ensure the 

successful implementation of the 

electronic disability system. 

GAO was asked to assess SSA’s 

status in implementing AeDib and 

the actions the agency has taken in 

response to GAO’s prior 

recommendations on this initiative. 

What GAO Recommends

GAO is making recommendations 

to the Commissioner of Social 

Security that focus on resolving 

operational problems with the 

electronic disability system and 

ensuring the continuity of 

electronic disability claims 

processing. In commenting on this 

report, SSA disagreed with GAO’s 

recommendation for resolving 

problems with the electronic 

system, but agreed to implement 

plans for ensuring the continuity of 

disability claims processing. 
Page i GAO-05-97 Electronic Disability Claims Processing

Contents

Letter 1

Results in Brief 2

Background 4

SSA Is Meeting Its Overall AeDib Implementation Schedule, but 

Operational and Other Concerns Could Impact the Success of the 

Initiative 11

SSA’s Actions toward Implementing AeDib Have Addressed Some, 

but Not All, of Our Prior Recommendations for Improvement 25

Conclusions 27

Recommendations for Executive Action 28

Agency Comments and Our Evaluation 28

Appendixes

Appendix I: Objectives, Scope, and Methodology 34

Appendix II: Comments from the Social Security Administration 36

Appendix III: GAO Contact and Staff Acknowledgments 42

Tables Table 1: Scheduled Certification of State DDSs as of June 30, 

2005 15

Table 2: Reported Use of the Electronic Disability System in 

Selected DDS Offices as of Late June 2005 20

Figure Figure 1: SSA’s Electronic Disability Claims Processing System 9

Abbreviations

DDS Disability Determination Services

DMA Document Management Architecture

EDCS Electronic Disability Collect System

GAO Government Accountability Office

OHA Office of Hearings and Appeals

SSA Social Security Administration

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Page 1 GAO-05-97 Electronic Disability Claims Processing

United States Government Accountability Office

Washington, D.C. 20548

A

September 23, 2005 Letr

The Honorable Charles E. Grassley

Chairman 

Committee on Finance

United States Senate

Dear Mr. Chairman:

This report responds to your request concerning the Social Security 

Administration’s (SSA) ongoing accelerated initiative to establish an 

electronic disability claims processing capability—known as AeDib. With 

this initiative, the agency is implementing a paperless system, in which the 

large volumes of medical images, files, and other documents that 

traditionally have been maintained in paper folders will be stored in 

electronic folders, enabling the disability claims processing offices to 

electronically view, process, and share claims information. The disability 

claims processing offices include SSA’s field offices, where individuals 

apply for claims; state disability determination services (DDS) offices, 

which determine claimants’ medical eligibility for disability benefits; and 

SSA’s Office of Hearings and Appeals (OHA), which processes appeals of 

claims that have been denied. SSA began its national rollout of the key 

system components needed to electronically process an entire disability 

case in late January 2004.

In pursuing this electronic capability, SSA has taken a positive and 

necessary step toward more efficiently delivering benefits payments to an 

increasing beneficiary population. However, we previously pointed out that 

the agency’s accelerated strategy for developing and implementing the 

electronic disability system involved risks that threatened the agency’s 

complete and successful transition to this capability. In reporting on AeDib 

in March 2004, for example, we noted that the agency had begun its 

national rollout without conducting essential testing to assess how the 

multiple interrelated system components for this initiative would function 

in an integrated environment.1

 To address such deficiencies, we 

recommended that the Commissioner of Social Security take several 

actions to reduce the risks associated with the agency’s strategy for 

1

GAO, Electronic Disability Claims Processing: SSA Needs to Address Risks Associated 

with Its Accelerated Systems Development Strategy, GAO-04-466 (Washington, D.C.: Mar. 

26, 2004).
Page 2 GAO-05-97 Electronic Disability Claims Processing

developing the electronic disability system. At your request, this report 

discusses (1) the current status of SSA’s implementation of AeDib and 

(2) the actions SSA has taken in response to our prior recommendations on 

this initiative.

To address these objectives, we analyzed project management and 

technical documentation describing SSA’s plans and progress related to 

implementing its electronic disability system. In addition, we reviewed 

relevant documents that describe the state DDSs’ implementation and use 

of the system, including reports of the National Council of Disability 

Determination Directors—an organization representing the state DDSs. We 

also obtained and reviewed relevant documentation describing SSA’s 

actions toward implementing our prior recommendations on AeDib. 

Further, we interviewed key officials in SSA’s Offices of Operations, 

Systems, Disability and Income Security Programs, and Hearings and 

Appeals to determine the current status of the system’s implementation and 

to discuss issues that the agency has identified during the implementation. 

We also interviewed DDS officials in nine states—California, Delaware, 

Florida, Illinois, Mississippi, Nebraska, New York, North Carolina, and 

South Carolina—and the President of the National Council of Disability 

Determination Directors, to obtain their views on implementing the 

electronic disability system. To supplement the interviews, we visited DDS 

and OHA sites in Mississippi and South Carolina, where we observed the 

operations of the electronic disability system and discussed these offices’ 

implementations of and experiences in using it. We conducted our work 

from October 2004 to July 2005, in accordance with generally accepted 

government auditing standards. Appendix I contains a more detailed 

discussion of the objectives, scope, and methodology.

Results in Brief SSA is proceeding with its implementation of its electronic disability claims 

process, which involves installing a data repository and the capability to 

scan and image claimants’ information and medical evidence,2

 enhancing

2

The data repository and the capability to scan images, documents, and forms that 

previously have been contained in paper folders comprise the Document Management 

Architecture infrastructure project. This system will enable disability-related information to 

be viewed and shared electronically by all disability processing components and is a 

fundamental element needed to achieve the electronic folder processing environment. 
Page 3 GAO-05-97 Electronic Disability Claims Processing

existing claims processing systems in DDS offices, and installing software 

that will enable DDS and OHA systems to interface with electronic folders.3

The agency had planned to equip all DDS offices and OHA sites with these 

electronic capabilities by June 2005 and October 2005, respectively, and 

since beginning the national rollout in late January 2004 has largely met its 

implementation schedule. As of June 30, 2005, it had, as planned, fully or 

partially implemented the electronic capabilities in 53 of the 54 state DDS 

offices and in 85 of the 144 OHA sites. Nonetheless, the agency still has 

considerable work to accomplish before it will be effectively positioned to 

fully process disability claims in an electronic environment. As of early July 

2005, it had certified only three DDSs to process all initial disability claims 

electronically and to maintain the electronic folder as an official record; it 

does not expect to complete all certifications until January 2007. In 

addition, officials in a number of the DDSs expressed concerns about the 

operations and reliability of the electronic disability system, stating, for 

example, that inadequacies in the electronic forms and the computer 

monitors used to view claims information had slowed systems 

performance and impeded their productivity. Consequently, these officials 

reported varying levels of system usage and stated that processing claims 

electronically had thus far taken longer and consumed more resources than 

prior to the system’s implementation. Further, although SSA is moving to 

fully implement its system, the agency and state DDSs have not yet 

developed continuity of operations plans for mutually ensuring the 

continuity of this vital disability benefits service during short- or long-term 

disruptions to their electronic claims processing capabilities. Until SSA 

adequately resolves the concerns surrounding its electronic disability 

system, it jeopardizes its progress toward successfully achieving a more 

efficient means of delivering disability benefits payments to its increasing 

beneficiary population.

In proceeding with the AeDib initiative, SSA has taken actions related to 

three of five recommendations we made in our prior report. For example, it 

has initiated studies to help validate its planning assumptions supporting 

the initiative’s costs and benefits, begun ensuring users’ approval of new 

software and the certification of its systems for production, and improved 

its communications about the initiative with DDS officials. However, the 

3

The electronic folder interface software is electronically linked to the claims processing 

system and allows for the transfer of data between the electronic folder and the Document 

Management Architecture data repository. The electronic folder is an information storage 

system that electronically houses claimant information and medical evidence previously 

maintained in the paper folder (for example, data, images, and forms).
Page 4 GAO-05-97 Electronic Disability Claims Processing

agency did not demonstrate any action on two other recommendations—to 

conduct essential end-to-end testing to determine how the interrelated 

system components would work together prior to their implementation and 

to complete strategies for mitigating risks to the projects supporting the 

initiative. Thorough testing and risk mitigation strategies could have helped 

limit problems with the system’s operation and prevented circumstances 

that could impede the project’s success.

To further reduce risks to SSA’s progress in achieving its electronic 

disability claims processing capability, we are recommending that the 

Commissioner of Social Security (1) develop and implement a strategy that 

articulates milestones, resources, and priorities for resolving operational 

problems with the electronic disability system and (2) ensure that state 

DDSs develop and implement continuity of operations plans that address 

the continuation of disability claims processing in emergency situations.

In written comments on a draft of our report (reprinted in app. II), SSA 

agreed to ensure that state DDSs develop and implement continuity of 

operations plans for continuing essential disability claims processing 

functions during emergencies. However, the agency disagreed with our 

recommendation that it develop and implement a strategy that articulates 

milestones, resources, and priorities for efficiently and effectively resolving 

problems with the electronic disability system’s operations. The agency 

stated that it already had plans in place and had taken various actions to 

improve the electronic disability system’s operations by, for example, 

establishing a work group to identify software improvements for its 

electronic forms and hiring a contractor to test new computer monitor 

configurations. However, during our review, SSA could not provide a time 

table for the work group’s efforts, and it does not anticipate a final report 

on its tests of monitor configurations until January 2007. As SSA moves 

forward with actions to improve the electronic disability system, a strategy 

that articulates clear milestones, resources, and priorities will be essential 

to guide the agency’s efforts and ensure that all operational concerns are 

fully and effectively addressed. 

Background SSA’s Disability Insurance and Supplemental Security Income programs are 

the nation’s largest providers of federal income assistance to disabled 

individuals, with the agency making payments of approximately $113 

billion to more than 14 million beneficiaries and their families in 2004. Yet, 

over the years, it has become more challenging for the agency to ensure an 

acceptable level of service—in terms of both the quality and the timeliness 
Page 5 GAO-05-97 Electronic Disability Claims Processing

of its support to these individuals. In January 2003, we designated disability 

benefits programs across the federal government as high risk—in need of 

urgent attention and transformation.4

The process through which SSA approves or denies disability benefits is 

complex and involves multiple partners at both the federal and state levels 

in determining a claimant’s eligibility. SSA’s 1,300 field offices are the initial 

points of contact for individuals applying for benefits.5

 SSA also depends 

on 54 state DDS offices to provide crucial support to the claims process 

through their role in determining an individual’s medical eligibility for 

disability benefits. DDSs make initial determinations regarding disability 

claims in accordance with federal regulations and policies; the federal 

government reimburses 100 percent of all costs incurred by states to make 

disability determinations. Physicians and other members of the medical 

community provide the DDSs with medical evidence to help them evaluate 

disability claims. When disability claims have been denied by the DDSs, 

claimants can appeal to SSA’s OHA.6

The process begins when individuals apply for disability benefits at an SSA 

field office, where determinations are made about whether they meet 

nonmedical criteria for eligibility.7

 If the claimant is eligible, the field office 

forwards the application to the appropriate state DDS, where a disability 

examiner collects the necessary medical evidence to make the initial 

determination of whether the claimant’s condition meets the definition of 

disability. Once the claimant’s medical eligibility is determined, the DDS 

returns the claim folder to SSA for final processing.

A claimant who is initially denied benefits can ask the DDS to reconsider its 

determination. If the DDS denies the claim again, the claimant can request 

a hearing before a federal administrative law judge at an SSA hearings 

office and, if still dissatisfied, can request a review of the claim by SSA’s 

Appeals Council. Upon exhausting these administrative remedies, the 

claimant may file a complaint in federal district court. Each level of appeal 

4

GAO, Major Management Challenges and Program Risks: Social Security 

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

5

Nationwide, about 2.6 million initial disability claims were filed in fiscal year 2004. 

6

SSA maintains 144 Office of Hearings and Appeals (OHA) sites.

7

Nonmedical eligibility criteria may include an individual’s age, employment, marital status, 

or Social Security coverage information. 
Page 6 GAO-05-97 Electronic Disability Claims Processing

involves multistep procedures for collecting evidence, reviewing 

information, and making the decision. Many individuals who appeal the 

initial determination on their claims will wait a year or longer—perhaps up 

to 3 years—for a final decision.

To address concerns regarding the program’s efficiency, in 1992, SSA 

initiated its Modernized Disability System project, intending to redesign the 

disability claims process emphasizing the use of automation to achieve an 

electronic (paperless) processing capability. This project, which in 1994 

was renamed the Reengineered Disability System, was to automate the 

entire disability claims process—from the initial claims intake in the field 

office to the gathering and evaluation of medical evidence by the state 

DDSs, to payment by the field office or processing center. The system also 

was intended to automate the handling of appeals by SSA’s hearings offices. 

However, as our prior work noted, SSA encountered performance and 

other problems during its initial pilot testing of the system and, after 

spending more than $71 million, suspended this project in 1999.

In August 2000, SSA renewed its commitment to developing an electronic 

disability system by the end of 2005. The agency worked on this initiative 

through the spring of 2002, at which time the Commissioner of Social 

Security announced an accelerated electronic disability initiative—

AeDib—to more quickly move to an automated process. Under the 

accelerated strategy, the agency planned to begin implementing its 

electronic disability system by January 2004. SSA anticipated that the 

electronic disability system would enable the disability offices to achieve 

processing efficiencies, improve data completeness, reduce keying errors, 

and save time and money. With technologically enhanced claims processing 

offices, the agency projected that it could realize benefits of more than $1 

billion—at an estimated cost of approximately $900 million—over the 10-

year life of the initiative.8

 SSA reported actual AeDib costs of 

approximately $215 million through fiscal year 2004 for planning, hardware 

and software acquisition, maintenance, and personnel.

The AeDib strategy focuses on developing the capability to electronically 

process claimant information and large volumes of medical images, files, 

and other documents that are currently maintained in paper folders. Stored 

in electronic folders, this information could then be accessed, viewed, and 

8

The 10-year life of the AeDib initiative covers the time frame from 2002 through 2011. 
Page 7 GAO-05-97 Electronic Disability Claims Processing

shared among the disability claims processing offices. The initiative to 

achieve this electronic capability involves five key projects:

• an Electronic Disability Collect System that would provide the 

capability for SSA field offices to capture electronically, in fixed data 

fields, information about a claimant’s disability that previously had been 

contained on paper disability forms (structured data) and to store it in 

databases for later use by the SSA and DDS offices responsible for 

processing disability claims;

• a Document Management Architecture to provide a data repository and 

scanning and imaging capabilities that would allow unstructured 

claimant and medical data, such as images or information not found in 

fixed data fields (e.g., a hospital report, doctors’ notes, or an x-ray 

report), to be stored, indexed, and shared among the disability 

processing offices;

• Internet applications to enable the public to submit disability claims and 

medical information to SSA via the Internet (all data keyed into the 

Internet applications would be transmitted directly into the Electronic 

Disability Collect System);

• a systems migration and electronic folder software interface to position 

DDS offices to operate on a common IBM-series hardware platform and 

enhance their existing claims systems to process the electronic claims 

information and to enable the DDS systems to access information in the 

electronic folder; and

• a Case Processing Management System that would interface with the 

electronic folder and enable OHA’s staff to track, manage, and complete 

case-related tasks electronically.

According to SSA, the Electronic Disability Collect System and the 

Document Management Architecture are the two fundamental components 

needed to create the electronic disability folder. Via their claims processing 

systems, SSA and DDS users would be able to access and pull the 

structured and unstructured claimant data into appropriate computer
Page 8 GAO-05-97 Electronic Disability Claims Processing

screens, organized as electronic folders of information.9 The agency’s 

electronic disability claims processing system is depicted in figure 1.

9

Conceptually, the Electronic Disability Collect System and Document Management 

Architecture provide the capability to hold an aggregation of both the structured and 

unstructured data so that all of a claimant’s information can be organized in a virtual folder 

and then viewed collectively and shared electronically. A virtual folder is a type of folder 

that is dynamically assembled at the time of the request. The virtual folder may represent a 

subset of a static folder or a cross-section of static folders. 
Page 9 GAO-05-97 Electronic Disability Claims Processing

Figure 1: SSA’s Electronic Disability Claims Processing System

By mid-January 2004, SSA had implemented all planned releases of the 

Electronic Disability Collect System and had completed and placed into 

production Internet applications to aid claimants in filing online for 

disability benefits and services. It also had enhanced the DDSs’ claims 

processing systems by migrating and upgrading hardware to allow these 

offices to operate on a common IBM-series platform and by upgrading the 

Source: GAO analysis of agency data.

Electronic Disability Collect System (EDCS) 

(provides capability for SSA field offices to electronically capture 

structured data about claimants that previously was contained in 

paper disability forms and store it for later use by DDS and OHA)

Internet

Internet applications

(enable disability claimants to send 

information and claims via the Internet 

directly into EDCS)

Document Management Architecture (DMA)

(provides a data repository to capture unstructured data, such as 

hospital reports, doctors' notes, and x-ray reports to be stored, 

indexed, and shared among the disability processing components)

Input from medical and other 

various sources including OHA, 

DDS, and SSA field offices

Electronic folder

(virtual folder accessed and updated 

by DDS, OHA, and SSA field offices)

EDCS

(structured data)

DMA

(unstructured data)

SSA field office populated database

OHA Case Processing and Management System

(tracks, manages, and completes case-related 

tasks electronically and interfaces with the 

electronic folder allowing staff to access, update, 

and share information in the electronic folder)

Office of Hearings and Appeals (OHA)

DDS systems

(interfaces with the electronic folder to allow staff 

to access, update, and share claims information 

used in making disability determinations)

Disability Determination Service (DDS) offices
Page 10 GAO-05-97 Electronic Disability Claims Processing

claims processing software in all but 3 state DDS offices that used the 

standard disability claims processing systems.10 In addition, SSA had begun 

pilot testing OHA’s Case Processing Management System in a standalone 

environment at five sites. Further, the agency was pilot testing the 

Document Management Architecture in three state DDS locations—North 

Carolina, Illinois, and California. However, it had not yet implemented the 

Document Management Architecture repository and scanning and imaging 

capabilities and related DDS software enhancements or the software to 

enable DDS and OHA systems to interface with the electronic folders. SSA 

began its national rollout of these remaining system components at the 

Mississippi DDS on January 26, 2004.

When we last reported on the initiative in late March 2004, SSA was 

proceeding with its implementation of its electronic disability system.11

However, our work had noted that the agency’s strategy for developing the 

system components involved risks that threatened the success of the 

project. For example, we determined that the agency (1) had begun the 

national rollout without conducting testing that was adequate to evaluate 

the performance of all system components collectively, (2) could not 

provide evidence that it was consistently applying established procedures 

to guide the AeDib software development or had developed risk mitigation 

strategies, (3) had not validated its analysis to ensure the reasonableness of 

estimated AeDib costs and benefits, and (4) had not articulated a 

comprehensive plan for ensuring that state DDSs’ concerns about the 

initiative were addressed. In view of the risks and the technological 

complexity, scope, and size of the initiative, we had recommended that the 

Commissioner of Social Security, before continuing with the national 

rollout of AeDib,

• ensure that all critical problems identified in pilot testing of the 

electronic disability system were resolved and that end-to-end testing of 

the interrelated systems was performed,

• ensure that the software that had been developed was approved and 

that the systems had been certified for production,

10The majority of DDSs use standard claims processing systems that are provided by three 

sources: iLevy, Versa, and MIDAS. Two DDSs—Nebraska and New York—use systems 

developed by their own offices. 

11GAO-04-466.
Page 11 GAO-05-97 Electronic Disability Claims Processing

• establish a revised time frame for and expedite actions toward finalizing 

AeDib risk mitigation strategies,

• validate all AeDib cost and benefit estimates, and

• implement a communications plan to clearly and comprehensively 

convey SSA’s approach for effectively addressing disability 

stakeholders’ and users’ concerns and ensuring their full involvement in 

the AeDib initiative.

SSA Is Meeting Its 

Overall AeDib 

Implementation 

Schedule, but 

Operational and Other 

Concerns Could 

Impact the Success of 

the Initiative

SSA is proceeding with a national rollout of its electronic disability system 

and has generally met its schedule for implementing the remaining key 

components—the Document Management Architecture and the electronic 

folder interface software—that are required to process an entire disability 

case electronically. Nonetheless, the agency has considerable work to 

accomplish before it will be effectively positioned to fully process all 

disability claims in an electronic environment. Among the critical tasks that 

remain are certifying all state DDS offices and OHA sites to electronically 

process claims and addressing operational and other concerns that 

threaten to undermine the reliability and use of the system. Until SSA has 

effectively addressed these matters, it remains uncertain when and to what 

degree the agency will realize the full benefits of its electronic processing 

capability.

AeDib Implementation 

Schedule Was Generally Met 

through June 2005

The AeDib implementation schedule had called for all state DDSs and OHA 

sites to be equipped with the electronic disability claims processing 

capability by June 27, 2005, and October 3, 2005, respectively. Since 

beginning the national rollout of the Document Management Architecture 

and related DDS software enhancements and the electronic folder interface 

software in late January 2004,12 the agency has largely met its 

implementation schedule. As of late June 2005, SSA had fully or partially 

implemented the electronic disability system in 53 of the 54 state DDS 

offices and in 85 of the 144 OHA sites, as planned. The agency reported that 

12Three states included in the national roll-out—North Carolina, Illinois, and California—

actually began their implementation of the Document Management Architecture as part of 

SSA’s pilot tests of this technology in 2003.
Page 12 GAO-05-97 Electronic Disability Claims Processing

it expected to finish implementing the electronic disability system in the 

one remaining DDS—New York—in October 2005.

SSA officials attributed the 4-month delay in the planned implementation at 

the New York DDS to the need for additional time to interface the 

electronic disability system with that state’s existing claims processing 

capabilities. New York and Nebraska are the only two DDSs in which the 

states’ claims processing capabilities are not supported by the common 

hardware platform that the majority of DDSs use and that have developed 

and rely on disability claims processing software that is unique to their 

processing environments. As a result of New York’s efforts to develop and 

test an electronic disability claims process, it had achieved a level of 

electronic processing, including the capability to scan medical evidence 

into its system, prior to SSA’s completion of the electronic disability 

system. SSA and New York DDS officials agreed to interface the new 

electronic disability system with portions of that state’s existing claims 

processing capabilities.13

In addition, SSA officials reported, as of early July 2005, that they expected 

to meet the scheduled completion date of October 3, 2005, for 115 of the 

144 OHA sites. They stated that the agency expected to complete 

implementation of the electronic disability system at the remaining 29 OHA 

sites approximately 1 month later, in November 2005. According to agency 

officials, 10 of the 29 sites support claims that are processed by the New 

York DDS. The agency delayed implementation at these sites in order to be 

more in step with New York’s revised implementation schedule and with 

anticipated time frames for when the DDS will be positioned to process 

disability cases using the electronic folder. Regarding the remaining 19 

sites, officials explained that the agency did not wish to train staff and 

provide the electronic folder capability to OHA sites too far in advance of 

when these offices expected to receive electronic cases from the DDSs, 

believing that too much lag time between training and actual use of the 

system could result in the staffs’ losing some of the knowledge and skills 

they need to process cases electronically.

13SSA also interfaced the electronic disability system with Nebraska’s independent disability 

claims processing system, although Nebraska’s system included fewer automated 

capabilities than did New York’s system. This action was completed as scheduled in late 

June 2005. 
Page 13 GAO-05-97 Electronic Disability Claims Processing

Operational and Other 

Concerns Could Impact the 

Electronic Disability 

System’s Reliability and Use

Although the roll out of the electronic disability system is moving toward 

completion, the agency still has considerable work to accomplish before it 

will be effectively positioned to process all disability claims in a fully 

electronic environment. After implementing the electronic system, each 

DDS must undergo an assessment of the quality and accuracy of its 

electronic processing capabilities and must be certified by SSA to use the 

electronic folder as its official disability claims record. This assessment, 

referred to as the Independence Day Assessment, is intended to validate 

that an office is ready to process 100 percent of the initial disability claims 

and any reconsiderations that it receives in the electronic environment and 

that the electronic folder can serve as the official disability claims record.14

According to SSA Operation’s staff, the assessment involves examining the 

disability office’s operations and claims processing tasks to ensure that 

(1) the business process (e.g., the way in which the disability claims office 

is organized to do its work) and the electronic processing environment are 

compatible; (2) existing claims processing systems have the necessary 

functionality to process electronic folders; and (3) staff can, when using 

the electronic disability system, produce complete information that equals 

what is contained in the paper folders.

As of early July 2005, SSA reported that only three state DDSs—Mississippi, 

Illinois, and Hawaii—had completed assessments and been certified to 

process all initial disability claims in a paperless electronic environment in 

which the electronic folder is recognized as the official disability claims 

record. SSA reported that it had certified Mississippi—the first state under 

the national rollout—to process all of its initial disability claims 

electronically by February 2005; the agency further reported that it had 

completed certifications in June 2005 for Illinois—one of the three states 

that had participated in a pilot test of the Document Management 

Architecture in 2003—and for Hawaii, one of the smallest states (consisting 

of 15 disability claims examiners), which completed its system’s 

implementation in February 2005.

In discussing Mississippi’s certification, the DDS director stated that the 

approximately 1-year time frame between the implementation and the 

certification of the office’s system had been devoted to such tasks as 

updating and testing software versions in order to give the office the full 

14An initial disability claim is one that is filed for the first time by a disability claimant, 

versus, for example, reconsiderations and continuing disability reviews of claims that have 

already been decided.
Page 14 GAO-05-97 Electronic Disability Claims Processing

complement of functionality that it would need to use the electronic folder 

and to ensuring that the office’s business processes effectively supported 

electronic processing by, for example, familiarizing staff with the electronic 

capabilities, training them in using the capabilities, and testing the use of 

scanning equipment in the office. The director added that, since Mississippi 

was the first state to be assessed and certified, SSA had reviewed a 

substantially larger number of disability cases (approximately 300) than it 

intends to review in the assessments of other states using the same claims 

processing software.

SSA officials said that, following Mississippi’s certification, the 

Commissioner of Social Security had placed a moratorium on any 

additional certifications pending SSA’s review of the assessment that had 

been undertaken in that state. They said that the commissioner had wanted 

to capture lessons learned from Mississippi’s assessment to identify any 

needed improvements in the assessment process and to ensure that any 

business or user concerns about the assessments were resolved before 

they applied the process broadly across all DDSs and OHA sites. For 

example, according to the officials, they learned that a smaller sample of 

disability cases could be examined in subsequent offices using the same 

software as Mississippi’s without diminishing the integrity of the 

assessment and the related certification.

As of July 2005, SSA officials told us that they had resumed the 

assessments and that the agency’s plans called for a total of seven state 

DDSs to be certified to process claims electronically by the end of fiscal 

year 2005.15 However, as indicated in table 1, not all of the 54 state DDSs are 

expected to be certified to process initial disability claims and to use the 

electronic folder as the official record until January 2007.

15The seven states are Mississippi, Illinois, Hawaii, South Carolina, Missouri, Wyoming, and 

Nevada. 
Page 15 GAO-05-97 Electronic Disability Claims Processing

Table 1: Scheduled Certification of State DDSs as of June 30, 2005

Implementation date DDS office Certification date

January 2004 Mississippi February 2005

September 2003 Illinois June 2005

February 2005 Hawaii June 2005

March 2005 Nevada August 2005

March 2004 South Carolina September 2005

October 2004 Wyoming September 2005

October 2003 California October 2005

September 2004 Maine October 2005

October 2004 Minnesota October 2005

November 2004 Oklahoma October 2005

January 2005 Oregon October 2005

June 2005 Guam October 2005

March 2005 Virgin Islands November 2005

May 2005 Delaware November 2005

October 2004 Texas December 2005

June 2005 Alaska December 2005

July 2003 North Carolina January 2006

May 2005 New Hampshire January 2006

June 2005 North Dakota January 2006

April 2004 Tennessee February 2006

August 2004 Idaho February 2006

October 2004 Connecticut February 2006

November 2004 Iowa February 2006

December 2004 Arizona February 2006

March 2005 Vermont February 2006

April 2005 Massachusetts February 2006

June 2004 Alabama March 2006

June 2004 Georgia March 2006

January 2005 Missouri March 2006

April 2005 New Jersey March 2006

April 2005 Rhode Island March 2006

July 2004 Utah April 2006

December 2004 Michigan April 2006

January 2005 Wisconsin April 2006

January 2005 Louisiana April 2006
Page 16 GAO-05-97 Electronic Disability Claims Processing

Source: GAO analysis of SSA information.

According to OHA’s deputy director, SSA expects to certify each OHA site 

shortly after certifying the corresponding DDS office. The official noted 

that because all OHA sites will rely on the same standard system (the Case 

Processing Management System), their certification process is expected to 

be less complicated than the process for the DDSs. Until they are certified, 

offices that have already implemented the electronic disability system are 

expected to maintain paper folders as well as electronic ones for any initial 

disability cases that they process electronically. The paper folders will 

continue to serve as the official records for these cases.

Operational Concerns Exist Even as the agency proceeds in certifying states’ electronic capabilities, 

however, operational concerns associated with the electronic disability 

system could undermine its reliability and use. Officials in seven of the nine 

DDS offices that we contacted (California, Delaware, Florida, Illinois, 

Mississippi, North Carolina, and South Carolina) stated that operational 

problems they had encountered while using the electronic disability system 

September 2004 Florida May 2006

September 2004 Ohio May 2006

November 2004 South Dakota May 2006

January 2005 Arkansas May 2006

February 2005 Washington May 2006

April 2005 Indiana May 2006

September 2004 West Virginia June 2006

December 2004 Puerto Rico June 2006

December 2004 Kentucky June 2006

June 2005 Nebraska June 2006

March 2005 Pennsylvania July 2006

March 2005 Maryland July 2006

April 2005 Kansas July 2006

April 2005 New Mexico July 2006

May 2005 Montana August 2006

March 2005 Colorado September 2006

January 2005 Virginia October 2006

June 2005 Washington, DC November 2006

October 2005 New York January 2007

(Continued From Previous Page)

Implementation date DDS office Certification date
Page 17 GAO-05-97 Electronic Disability Claims Processing

had affected its performance and raised doubts about its reliability in 

supporting their processing needs.

DDS officials stated, for example, that as SSA had brought the system 

online at the different DDS offices and/or added new software to enhance 

functionality, their staffs had encountered various operating problems that 

affected the performance of the system. They stated that their offices had 

experienced problems such as computer screen freezes, system 

slowdowns, and system access issues—all of which had disrupted the 

offices’ processing of claims. They described these problems as 

unpredictable and random because they did not always occur consistently 

among all of the offices using the same claims processing software or even 

among examiners in a particular office. The officials added that although 

SSA has been able to resolve many of the problems that affected their 

ability to process claims, additional instances of screen freezes, system 

slowdowns, and access issues have continued to occur throughout the 

system’s implementation.

According to the manager of the South Carolina DDS, which implemented 

the electronic disability system in March 2004, that office’s productivity had 

been adversely affected by system slowdowns that resulted from having 

inadequate network bandwidth to support its disability claims processing 

operations. In July 2005, the manager stated that SSA had recently made 

modifications to the office’s network architecture and had increased its 

bandwidth by installing two additional communications lines; at that time, 

the office was in the process of testing these enhancements. The manager 

said that all of the office’s disability claims examiners had begun 

processing all initial disability claims electronically and that, as a result of 

the enhancements, they expected the office’s claims processing efficiency 

and productivity to increase.

In addition, DDS officials in six offices (California, Delaware, Florida, 

Mississippi, North Carolina, and South Carolina) reported problems with 

the electronic forms that SSA had installed to facilitate the processing of 

disability claims.16 The officials explained that, while using the electronic 

forms, disability claims examiners had experienced slow system response 

times or system freezes that had contributed to increased claims 

16Some of the electronic forms used by the DDSs include the Disability and Determination 

Transmittal Form (SSA Form 831) and the Authorization to Disclose Information to the 

Social Security Administration (SSA Form 827). 
Page 18 GAO-05-97 Electronic Disability Claims Processing

processing times. Officials in California stated that they had stopped using 

the electronic forms as a result of the problems that their staff had 

encountered and instead were continuing to rely on paper forms. In a 

February 2005 survey, the National Council of Disability Determination 

Directors found that 22 DDSs had experienced problems with the 

electronic forms and had reported that the slow pace involved in loading 

and using these forms was barely tolerable. Further, based on its May 2005 

quarterly evaluation of the electronic disability system, SSA reported that 

one of the systems-related problems that disability processing offices 

identified most frequently was the slow response times and lack of userfriendliness of the electronic forms.

Further, officials in five of the DDSs that we contacted among those that 

had implemented the electronic disability system (California, Illinois, 

Mississippi, North Carolina, and South Carolina) stated that their disability 

examiners faced difficulties in reading medical evidence on screen and 

performing certain case development or adjudication tasks because the 

size of the computer monitors that they had been provided to process 

medical evidence had proven inadequate. Users of the system—including 

managers, claims examiners, and medical consultants—reported difficulty 

with simultaneously viewing two documents on their monitors; some staff 

reported that they had resorted to printing out or toggling between 

documents to avoid using the split screen to review them. As a result of the 

inadequacies associated with using the existing monitors, the users 

reported that they needed longer periods of time to perform certain claims 

adjudication tasks and that they had been unable to complete as many 

cases per day as they could before they had the electronic disability 

system.

Beyond these concerns, officials in four of the DDSs that we contacted told 

us that, although their electronic capability had been implemented, they 

had not been provided certain software enhancements that they needed to 

fully process a claim electronically and that were critical to improving the 

efficiency of their offices’ claims processing capabilities. Specifically, 

Florida officials stated that their claims processing software did not 

provide the capability to electronically notify staff of the actions that were 

required to process a claim. As a result, the staff had to expend additional 

time notifying each other of actions needed to process the claim by, for 

example, sending e-mail notices. In addition, the director of the North 

Carolina DDS stated that that office lacked the necessary software to 

enable staff to electronically send claims files to SSA’s Disability Quality 

Branch, which is responsible for conducting quality reviews of the 
Page 19 GAO-05-97 Electronic Disability Claims Processing

accuracy of DDSs’ disability determinations. The director added that staff 

could not yet respond electronically to SSA components that requested 

information on a particular claim that had been processed in their office. 

Further, in Nebraska, the DDS manager stated that that office was in need 

of additional software modifications to provide the functionality required 

to electronically import all required documents into the electronic folder. 

Finally, the manager of the California DDS stated that his office had lacked 

the capability to electronically process nonmedical claims data that were 

required to be included in the disability claims folders, such as a claimant’s 

work history. The manager stated that they also had lacked the 

functionality to electronically refer claims to medical consultants for 

consultative examinations.

In light of the operational and other concerns that have been encountered 

in using the electronic disability system, coupled with factors such as 

having to concurrently maintain paper and electronic claims folders while 

awaiting certification, both SSA and DDS managers acknowledged that the 

DDS offices had exercised wide discretion in their use of the new system. 

The President of the National Council of Disability Determination Directors 

stated that two key factors had affected some DDSs’ decisions about 

ramping up to full use of the system: (1) concerns about a drop in 

productivity in a fully electronic environment and (2) the instability of the 

electronic disability processing environment, particularly in terms of 

system performance and software reliability. In this regard, officials in 

eight DDS offices that we contacted—all of which had implemented the 

electronic disability system by the end of June17—reported varying levels of 

usage, as shown in table 2.

17The New York DDS had not yet implemented the electronic disability system. 
Page 20 GAO-05-97 Electronic Disability Claims Processing

Table 2: Reported Use of the Electronic Disability System in Selected DDS Offices 

as of Late June 2005

Source: GAO analysis of SSA and DDS data.

Note: The last column represents initial disability cases being processed electronically. However, as 

of late June 2005, California, Florida, Delaware, Nebraska, and North Carolina had not yet received all 

of the software they needed to be certified to perform exclusively electronic processing.

Regarding the extent of their usage, managers in the Mississippi and Illinois 

DDSs acknowledged that problems had been encountered following their 

implementation of the electronic disability system but stated that they had 

nonetheless chosen to expedite efforts to achieve full electronic processing 

of disability claims in an attempt to minimize the inefficiencies associated 

with having to maintain both paper and electronic disability folders. 

Further, to help bring their states to full electronic processing, the 

managers of the Mississippi and Illinois DDSs stated that they had 

expended additional resources on overtime pay to disability examiners and 

on additional support from the software vendor to alleviate and/or 

establish workarounds for the operational problems that their examiners 

had encountered. While Mississippi officials said that they were unable to 

provide a dollar amount for their overtime usage, an Illinois DDS official 

provided documentation indicating that between September 2003 and May 

2005, that office had spent over $2 million on overtime, which assisted 

them in processing disability claims in the electronic environment.

However, DDS managers in several other offices that we contacted stated 

that, as a result of the problems with and the resulting unpredictability of 

the electronic disability system, they had been reluctant to bring the system 

to full use. They expressed reluctance to increase their use of the system 

Disability 

determination 

services office

Implementation 

date

Actual/planned 

certification

Percentage

of examiners

using new

system

Percentage of

initial disability

cases being

processed

electronically

North Carolina July 2003 January 2006 100 100

Illinois September 2003 June 2005 100 100

California October 2003 October 2005 100 8

Mississippi January 2004 February 2005 100 100

South Carolina March 2004 September 2005 100 100

Florida September 2004 May 2006 31 4–5

Delaware May 2005 November 2005 100 19

Nebraska June 2005 June 2006 5 4
Page 21 GAO-05-97 Electronic Disability Claims Processing

until a more reliable level of performance has been sustained, stating 

generally that the current problems with the system could hamper their 

ability to maintain their productivity levels.

For example, officials in the California DDS told us that the electronic 

disability system had not been used to fully process any of the 

approximately 450,000 initial claims that the office had received since it 

had implemented the system in October 2003.18 The officials stated that 

they had chosen not to ramp up the system until it proved to be more stable 

and all critical processing capabilities had been delivered. The manager 

believed that trying to use the system to process all of the office’s initial 

disability claims before the problems affecting their system’s operations 

were resolved and before all critical processing capabilities were delivered 

would prevent the office from maintaining its productivity levels. In midJuly 2005, California DDS officials stated that the vendor supporting their 

disability claims processing system19 had recently provided a software 

enhancement that gave them the capability to fully process claims and that 

the agency would begin a phased increase in the number of initial disability 

claims it would process in the electronic environment. According to the 

manager, each examiner would initially be assigned one disability case per 

week to process electronically.

In addition, in Florida, DDS officials stated that they had limited the 

number of claims being processed by their disability examiners until SSA 

was able to enhance their software to achieve better user efficiency. As a 

result, at the time of our review, only 109 of the office’s 487 disability 

examiners were using the electronic system to process cases, and only 

about 4 to 5 percent of initial disability claims were being processed 

electronically. Further, while the Nebraska DDS’s electronic capabilities 

were implemented in late June 2005, officials in that office stated that they 

did not plan to ramp up their use of the system until about September 2005. 

They explained that, lacking the software modifications required to 

electronically import all documents into the electronic folder, the office 

was reluctant to increase its use of the electronic disability system. They 

stated that doing so would require them to commit additional resources to 

scan documents that could not automatically be entered into the electronic 

18The California DDS was one of the three offices where SSA had initially piloted the 

Document Management Architecture hardware and software in 2003. Its implementation of 

the Document Management Architecture was completed in September 2004. 

19California uses MIDAS software, which is supported by SSA. 
Page 22 GAO-05-97 Electronic Disability Claims Processing

system. The officials added that they expect to receive additional software 

modifications that they need to improve the efficiency of the office’s 

electronic processing capability in the September 2005 time frame.

Given the current status of the electronic disability system, neither SSA nor 

the state offices had yet been able to effectively assess or quantify benefits 

resulting from its use. All of the managers of the DDS offices that we 

contacted stated that they saw the potential for realizing substantial claims 

processing improvements from using the system; nonetheless, these 

managers—including the managers of the Mississippi and Illinois DDSs—

stated that it was too early to determine whether and to what extent the 

electronic disability system would contribute to processing improvements 

in their offices. In their view, the system had not yet reached a level of 

maturity where it was feasible to quantify the benefits of its use, due in 

large measure to factors such as (1) the learning curve associated with 

using the system; (2) current inefficiencies involved in having to maintain 

paper folders until an office is certified to electronically process claims; 

(3) certain DDSs’ decisions to not fully utilize the system until further 

problem resolution; and (4) certain offices’ use of additional resources, 

such as overtime and temporary hires, to support their processing of claims 

following the system’s implementation. The managers added that 

processing claims electronically had thus far taken longer and consumed 

more resources than before the electronic system was implemented. In 

addition, because of ongoing system implementation in the OHA sites, 

along with the normal processing delays associated with bringing disability 

claims to the appeals stage, these sites had not yet accrued enough 

experience in using the electronic folder to make a reasonable assessment 

of processing improvements.

In speaking to the concerns that were raised about the reliability and use of 

the electronic disability system, SSA officials acknowledged the problems 

that had been identified by the DDSs, and that as a result, current use of the 

system among those offices varied considerably. However, these officials 

said they believed that the majority of the DDS offices would be able to 

bring their systems to full use with only a minimum of complications; they 

viewed California’s concerns, in particular, as not having been 

representative of other states’ experiences. Nonetheless, the officials said 

that the agency had initiated a number of measures to address the 

problems that had been encountered in using the system. For example, 

they stated that the agency had established a new help desk to more readily 

support those offices experiencing specific hardware and software 

problems while using the electronic disability system. In addition, they 
Page 23 GAO-05-97 Electronic Disability Claims Processing

stated that SSA had assembled a work group to examine the DDSs’ use of 

the electronic forms, with the intent of determining whether a more 

suitable commercial-off-the-shelf product was available that could address 

the problems currently being encountered with these forms. Regarding the 

size of the computer monitors that disability examiners use, the officials 

stated that the agency planned to conduct a pilot test to address concerns 

with and identify a solution for ensuring that users have the monitors they 

need.

SSA’s actions to address the outstanding concerns with its electronic 

disability system represent a positive step toward achieving success in the 

use of the new system. However, as of July 2005, the agency did not have an 

overall strategy—articulating milestones, resources, and priorities—to 

guide its efforts in efficiently and effectively resolving the operational 

problems and system limitations being experienced with the electronic 

disability system. For example, although the agency had established a work 

group to explore options for resolving problems being encountered with 

the electronic forms, it had not yet established plans and a time frame for 

completing actions to address this concern. In addition, although the 

agency planned to conduct a pilot test of computer monitors, it did not yet 

have essential information to determine what type of equipment would best 

meet the needs of the electronic disability system users or the resources 

and time that it would need to devote to resolving this matter. Adequately 

resolving the concerns with and gaining full acceptance and use of its 

electronic capabilities will be essential to SSA’s achieving a more efficient 

means of delivering disability benefits payments to its increasing 

beneficiary population.

The Lack of Continuity of 

Operations Plans for the 

Electronic Disability System 

Places Claims Processing at 

Increased Risk

In addition to ensuring the immediate availability of the electronic 

disability claims processing system by preventing operational problems 

that could impact its performance and use, it is essential that SSA and the 

DDSs have plans for mutually ensuring the continuity of this vital disability 

benefits service in emergency situations. Federal law and guidance require 

that agencies develop plans for dealing with emergency situations involving 

maintaining services and protecting vital assets that could result from 

disruptions, such as localized shutdowns due to severe weather
Page 24 GAO-05-97 Electronic Disability Claims Processing

conditions, building-level emergencies, or terrorist attacks.20 Moreover, this 

guidance notes, a key element in developing a viable continuity capability 

is identifying interdependencies among agencies that support the 

performance of essential functions and ensuring the development of 

complementary continuity of operations plans by those agencies that 

provide information or data integral to the delivery of essential functions. 

Such planning would include developing and documenting procedures for 

continued performance of essential functions, identifying alternates to fill 

key positions in an emergency and delegating decision-making authority, 

and identifying vital electronic and paper records—along with measures 

for ensuring their protection and availability.

However, SSA and the DDSs currently lack continuity of operations plans 

to ensure that the DDS offices could continue to process disability claims 

in the event of a short- or long-term disruption to the electronic disability 

system. A September 2004 report, issued by SSA’s Acting Inspector General, 

noted that the agency’s existing continuity of operations plan did not 

address the information or the electronic disability claims processing 

systems managed by the DDSs.21 The report further noted that, in relying 

heavily on the DDSs, SSA would lack certainty about the availability of 

information from these offices in the event of a disaster. Based on its 

findings, the Acting Inspector General recommended that SSA implement a 

complete and coordinated continuity of operations plan for the agency.

Officials in the nine DDSs that we contacted further stated that their offices 

had not developed continuity of operations plans covering the electronic 

disability claims processing capabilities; yet, in discussing this matter, 

officials considered such plans to be vital to successfully ensuring the 

continued processing of disability claims. Officials in the Mississippi DDS 

stressed, for example, that in the event of a disruption to their system’s 

communications with SSA’s headquarters computer facilities, disability 

examiners would be unable to access the Document Management 

Architecture repository, send or receive faxes via the electronic system, or 

access the electronic forms they needed to support their work. In addition, 

20Federal Information Security Management Act of 2002, P. L. 107-347, Title III, Sec. 301, 44 

U.S.C. §3544(b) (8), Presidential Decision Directive 67, Enduring Constitutional 

Government and Continuity of Government Operations, October 21, 1998.

21Fiscal Year 2004 Evaluation of the Social Security Administration’s Compliance with the 

Federal Information Security Management Act, September 30, 2004 (A-14-04-14040).
Page 25 GAO-05-97 Electronic Disability Claims Processing

they stated that medical examiners would be unable to perform tasks in 

support of disability determinations.

In discussing this matter, SSA officials acknowledged that their existing 

plan had not addressed the electronic claims processing functions of the 

DDSs. They stated that the agency had recently initiated actions to help 

resolve this limitation by having a contractor develop a business continuity 

planning strategy. According to the officials, the contractor began work on 

this strategy in May 2005 and is expected to deliver an initial report in 

September 2005. However, the officials did not articulate the agency’s 

specific plans or a time frame for ensuring that its continuity of operations 

plan addresses the electronic claims processing functions of the DDS 

offices or for ensuring that these offices develop and implement 

complementary plans for continuing essential functions to support the 

disability claims process in an emergency situation.

As SSA moves toward full implementation and use of the electronic 

disability system, the capability to continue essential electronic disability 

claims processing functions in any emergency or situation that may disrupt 

normal operations becomes increasingly important. In view of the fact that 

three states have already begun using electronic folders as official 

disability claims records, it is imperative that both SSA and the DDSs have 

plans that address the state systems’ interdependencies with the electronic 

disability claims processing components and that include preparations for 

continuing to provide critical claims processing services in the event of a 

disaster. Without continuity of operations plans, SSA will lack assurance 

that it is positioned to successfully sustain the essential delivery of 

disability benefits during unforeseen circumstances.

SSA’s Actions toward 

Implementing AeDib 

Have Addressed Some, 

but Not All, of Our 

Prior 

Recommendations for 

Improvement

As discussed earlier, in reporting on this initiative in March 2004, we 

recommended that the agency take measures to reduce the risks associated 

with its electronic disability strategy before continuing with its national 

rollout of this capability. These recommendations called for the agency to 

(1) resolve critical problems that it had identified in pilot testing of the 

electronic disability system and conduct end-to-end testing of the 

interrelated system components, (2) ensure that users approved the 

software being developed and that systems were certified for production, 

(3) finalize AeDib risk mitigation strategies, (4) validate AeDib cost and 

benefit estimates, and (5) improve communications with and effectively 

address the concerns of disability stakeholders and users involved in the 

initiative.
Page 26 GAO-05-97 Electronic Disability Claims Processing

In proceeding with the implementation of its electronic disability system, 

SSA has taken actions related to three of the five recommendations. 

Specifically, SSA officials provided evidence indicating that the agency has 

taken measures to ensure that users approve new software and that it 

certifies its systems for production. For instance, we reviewed agency 

documentation reflecting disability system users’ approval of new software 

and SSA’s certification of over 50 cases where software was put into 

production from February 2004 (shortly after the national rollout of the 

electronic disability system began) through October 2004. By continuing to 

validate its software and certify its systems, SSA should be able to better 

ensure that its systems are ready for production and will be acceptable to 

their end users.

In addition, regarding our recommendation that it validate AeDib cost and 

benefit estimates, SSA has initiated studies, including quarterly evaluations 

of the initiative, that could help it assess the electronic disability system’s 

performance, costs, and processing times. The agency also has plans for 

conducting post-implementation reviews of the system, which include 

comparing baseline and current information to evaluate the system’s 

impact on performance, productivity, and cost—measures that if 

implemented fully and effectively could help validate AeDib’s costs and 

benefits.

Further, although the agency has not implemented a communications plan, 

DDS officials, including the President of the National Council of Disability 

Determination Directors, told us that SSA had improved its 

communications with these offices and had made progress in including 

DDS officials in AeDib decision making. Such action reflects a positive 

move toward involving stakeholders in the agency’s efforts. Nonetheless, 

we continue to advocate the importance of having a clear and 

comprehensive plan for communicating with stakeholders to sustain vital 

user acceptance and achieve full use of the electronic disability system.

However, SSA did not demonstrate any actions on two of the 

recommendations. As we previously noted, SSA did not take steps to 

resolve all of the critical problems that had been identified during pilot 

testing of the Document Management Architecture or to conduct end-toend testing of the interrelated electronic disability system components 

before continuing with the national rollout of this system. Resolving all 

critical problems and conducting end-to-end testing of the interrelated 

system components prior to their implementation could have limited the 

problems that SSA and the DDSs have encountered with the electronic 
Page 27 GAO-05-97 Electronic Disability Claims Processing

disability system’s operation. In the absence of such testing, as SSA moves 

to achieve certification and full use of the system, it will be essential that 

the agency work diligently to identify and alleviate the problems that could 

impact the successful outcome of this technically complex initiative. 

Further, while our earlier work noted that the agency had identified the 

risks associated with the AeDib initiative and the related automation 

projects, SSA has not provided any evidence that it has yet completed risk 

mitigation strategies for these projects. Best practices and federal guidance 

advocate risk management—including mitigation strategies—to reduce 

risks and achieve schedule and performance goals.22 Among the high-level 

risks identified, SSA noted that the overall availability of the Document 

Management Architecture might not meet service-level commitments to its 

users. Because the DDSs could not effectively perform their work if the 

data repository or document scanning and imaging capabilities provided by 

the architecture were not available, it is critical that SSA have mitigation 

strategies in place to reduce this risk and to help ensure that the DDSs can 

meet their performance goals. In the continued absence of risk mitigation 

strategies, the agency lacks a critical means of ensuring that it can prevent 

circumstances that could impede a successful project outcome.

Conclusions SSA is relying on its electronic disability system to play a vital role in 

improving service delivery to disabled individuals under its disability 

programs, and the agency has made considerable progress in implementing 

this system. However, even as the agency moves closer to achieving full 

systems implementation, important work still needs to be accomplished to 

ensure the system’s success. Among the agency’s critical tasks will be 

certifying that all of the SSA and state DDS offices are prepared to process 

all disability claims electronically. Yet, a number of DDSs have concerns 

about the operations and reliability of the electronic disability system, 

noting, for example, inadequacies in electronic forms and the computer 

monitors used to view claims information, as well as limitations in 

electronic processing capabilities—factors that they say have slowed 

system performance and impeded their productivity, and that have resulted 

in the levels of system usage varying among the DDSs. Further, as the 

agency moves to complete the system’s implementation, it will be essential 

that SSA and the DDSs have plans for mutually ensuring the continuity of 

22Software Acquisition Capability Maturity Modelsm (CMU/SEI-99-TR-002, April 1999); 

OMB Circular A-130 (November 30, 2000). 
Page 28 GAO-05-97 Electronic Disability Claims Processing

this vital disability benefits service in emergency situations. The absence of 

a defined strategy or plans for ensuring that the electronic disability system 

will operate and will meet users’ needs as intended could threaten the 

continued progress and success of this initiative and make it uncertain 

when the agency will realize the full benefits of the AeDib initiative.

Recommendations for 

Executive Action

To further reduce the risks to SSA’s progress in successfully achieving its 

electronic disability claims processing capability, we recommend that the 

Commissioner of Social Security take the following two actions:

• develop and implement a strategy that articulates milestones, resources, 

and priorities for efficiently and effectively resolving problems with the 

electronic disability system’s operations, including (1) identifying and 

implementing a solution to improve the use of electronic forms, (2) 

identifying and implementing a solution to address concerns with 

existing computer monitors, and (3) ensuring that the DDSs have the 

necessary software capabilities to fully and efficiently process initial 

claims in the electronic processing environment; and

• ensure that the state DDSs develop and implement continuity of 

operations plans that complement SSA’s plans for continuing essential 

disability claims processing functions in any emergency or other 

situation that may disrupt normal operations.

Agency Comments and 

Our Evaluation

In written comments on a draft of this report, the Commissioner of Social 

Security expressed concern about our references to the agency’s testing of 

its electronic disability system and offered additional views regarding our 

discussion of the state disability determination services’ use of overtime to 

assist in electronically processing disability claims. In addition, the agency 

disagreed with one of our recommendations and agreed with the other. 

Regarding the testing of its electronic disability system, SSA questioned 

why our report had concluded—months after the agency’s rollout of the 

system—that performing end-to-end testing of the interrelated system 

components was still critical to the initiative’s success. The agency 

believed that we should delete references to the criticality of such testing 

for this initiative so as not to lend confusion to and cast doubt on its rollout 

experience. 
Page 29 GAO-05-97 Electronic Disability Claims Processing

In discussing SSA’s decision not to conduct end-to-end testing before 

rolling out the electronic disability system, our report responds to one of 

the two stated objectives of our study—to determine the actions that SSA 

has taken in response to our prior recommendations on the AeDib 

initiative. In doing so, we did not conclude that it remains critical for SSA 

to perform end-to-end testing at this stage in the system’s implementation. 

Rather, in speaking to this issue, we described the agency’s response to our 

prior recommendation that it conduct end-to-end testing before proceeding 

with the national roll out, and we emphasized the importance of such 

testing as a means of limiting the types of problems that DDS officials told 

us they have encountered with the system’s operation. As our report 

stresses, in the absence of end-to-end testing, it is essential that SSA remain 

diligent in identifying and alleviating the problems that could impact the 

successful outcome of the AeDib initiative as the agency moves to achieve 

full certification and use of the electronic disability system.

Concerning the DDSs’ reported cost and use of overtime, SSA emphasized 

its belief that a number of factors other than the electronic disability 

system had contributed to the Illinois DDS’s increased use of overtime. For 

example, the agency said that overtime had been used to compensate for 

the loss of DDS employees that had accepted the state’s offer of early 

retirement. Based on our discussions with Illinois DDS officials, we 

understand that the office may not have used overtime solely to support its 

electronic processing of disability claims. However, as noted in our report, 

the Illinois officials told us that they had relied on overtime to assist in 

bringing their office to full electronic processing of disability claims using 

the new system. We have included language in the report to more clearly 

reflect this point.

Beyond these points of discussion, SSA disagreed with our 

recommendation that they develop and implement a strategy that 

articulates milestones, resources, and priorities for efficiently and 

effectively resolving problems with the electronic disability system’s 

operations, including (1) identifying and implementing a solution to 

improve the use of electronic forms, (2) identifying and implementing a 

solution to address concerns with existing computer monitors, and

(3) ensuring that the DDSs have the necessary software capabilities to fully 

and efficiently process initial claims in the electronic processing 

environment. Specifically, the agency stated that it had substantially 

improved its electronic forms and already has a strategic project plan to 

address residual issues concerning them. It noted that a work group 

established in January 2005 had examined this issue and that many key 
Page 30 GAO-05-97 Electronic Disability Claims Processing

recommendations had been adopted to improve the performance of and 

customer satisfaction with the electronic forms. SSA added that it is using a 

contractor to examine alternatives and determine if more robust software 

is available to better meet users’ needs, and that it may incorporate new 

software into the electronic disability claims process.

Our report recognized that SSA had established a work group to explore 

options for resolving problems with the electronic forms. However, during 

our study, SSA officials could not provide a time table for the work group’s 

efforts and, despite our inquiries, gave no indication that the agency had a 

defined strategy for addressing this area of concern. Further, SSA did not 

inform us of a specific contract to examine software alternatives or of the 

specific recommendations that have been made to correct problems with 

the forms and the improvements in performance and customer satisfaction 

that have been achieved. Thus, we did not have an opportunity to evaluate 

and comment on the agency’s actions in this regard. Given the DDSs’ 

expressed concerns about the electronic forms throughout the course of 

our study and as reflected in SSA’s own quarterly evaluation of the 

electronic disability system, we continue to stress the importance of SSA 

developing and implementing a strategy to guide its efforts toward 

efficiently and effectively resolving problems with this important electronic 

capability. 

Regarding its existing computer monitors, SSA stated that it already has a 

plan in place to evaluate this issue and potential ergonomic solutions. The 

agency stated that it had awarded a contract to conduct a controlled test of 

the impact of various monitor configurations on ergonomics and 

productivity for all primary users of the electronic disability system, and 

that a final report is due in January 2007. It added that when final decisions 

are made regarding the appropriate monitor requirements, a business plan 

will be deployed if warranted. As noted in our report, SSA officials did 

inform us of their intent to conduct a pilot test to identify potential 

solutions for ensuring that users have appropriate monitors. However, the 

officials could not provide contractual and other pertinent documents 

explaining the pilot study and did not inform us of any plan that the agency 

had developed to guide this effort. Given that SSA does not anticipate its 

final report on its test of the monitor configurations until January 2007, and 

does not intend to consider the deployment of a business plan until final 

decisions are made regarding the monitor requirements, we believe that the 

agency could benefit from a strategy articulating clear milestones, 

resources, and priorities to guide its efforts toward finalizing decisions on 
Page 31 GAO-05-97 Electronic Disability Claims Processing

its computer monitors and ensure that all users’ concerns are fully and 

effectively addressed. 

Further, regarding the DDSs’ software capabilities, SSA stated that it had 

established a help desk to provide support for specific hardware and 

software issues associated with the electronic disability system, and that it 

had no information that there are outstanding issues concerning DDS 

software support. Moreover, the agency stated that our report had 

inaccurately described supposed issues related to implementing the 

electronic disability system in light of some states having not yet been 

certified to fully process cases electronically. For example, SSA 

commented that because Florida had not yet been certified to fully process 

cases electronically, it was premature to expect that the electronic 

disability system would notify staff of actions to process claims. Similarly, 

SSA stated that because Nebraska had not been certified to process cases 

electronically, it was premature to indicate that the state needed additional 

software modifications to electronically import all required documents into 

the electronic folder. Further, the agency said that it was inaccurate for us 

to report that the North Carolina DDS lacked the necessary software to 

enable staff to electronically send claim files to SSA’s Disability Quality 

Branch, since all but two states—New York and Nebraska—had this 

software. It added that the agency’s planning and electronic disability 

system roll out had addressed software capabilities and other issues 

impacting individual DDSs, negating the need for a formal strategy, as we 

have recommended. 

We disagree that our report inaccurately described issues related to 

implementing the electronic disability system or that it prematurely 

highlighted limitations in certain states’ use of the system. A primary aspect 

of our review involved examining SSA’s progress in rolling out the 

electronic disability system, including the state DDSs’ experiences in 

implementing and using the system. In this regard, DDS officials apprised 

us of their electronic disability claims processing capabilities, and in 

certain instances, of their need for additional software capabilities that 

they deemed essential to improving their offices’ processing efficiency and 

sustaining productivity in the electronic environment. As of mid-July 2005, 

North Carolina DDS officials told us that they lacked the necessary 

software to enable staff to electronically send claim files to SSA’s Disability 

Quality Branch. We recognize that SSA does not expect to complete all 

states’ certifications until early 2007. However, in our view, until the agency 

ensures that all DDSs have full electronic processing capabilities, it will not 

be positioned to effectively assess the extent to which the electronic 
Page 32 GAO-05-97 Electronic Disability Claims Processing

disability system can contribute to a more efficient and effective disability 

claims process.

SSA further stated that system availability issues had been addressed, as 

evidenced by its current fiscal year data on key electronic disability system 

components (e.g., the Electronic Disability Collect System, the Case 

Processing Management System, and the Document Management 

Architecture). However, our report does not convey that these key 

electronic disability system components were not available for use. Rather, 

the concerns discussed in our report pertain to the inefficiencies that DDS 

officials said they had encountered in using the electronic disability 

system. For example, DDS officials pointed to the continuing instances in 

which they had experienced processing slowdowns when using electronic 

forms, which ultimately had impeded their disability claims processing 

capability. Thus, we stand by our recommendation that SSA develop and 

implement a strategy to ensure that the DDSs have the necessary software 

capabilities to fully and efficiently process claims in the electronic 

environment. 

Regarding our second recommendation, the agency agreed to ensure that 

the state DDSs develop and implement continuity of operations plans that 

complement SSA’s plans for continuing essential disability claims 

processing functions during emergencies or other disruptions to normal 

operations. In this regard, the commissioner stated that SSA is highly 

committed to providing uninterrupted services to the public and had hired 

a contractor to develop business continuity plans for the DDSs that 

document how these offices would respond to long- and short-range 

disruptive events. The actions that SSA stated that it is taking should help 

improve the agency’s and the DDSs’ ability to ensure the continuity of vital 

disability benefits services in emergency situations. 

In addition to the aforementioned comments, SSA provided technical 

comments, which we have incorporated, as appropriate. Appendix II 

reproduces the agency’s comments on our draft report.

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the 

Commissioner of Social Security and the Director, Office of Management 

and Budget. Copies will also be available at no charge on our Web site at

www.gao.gov.
Page 33 GAO-05-97 Electronic Disability Claims Processing

Should you have any questions on matters contained in this report, please 

contact me at (202) 512-6240. I can also be reached by email at 

koontzl@gao.gov. Contact points for our Offices of Congressional Relations 

and Public Affairs may be found on the last page of this report. Key 

contributors to this report are listed in appendix III.

Sincerely yours,

Linda D. Koontz

Director, Information Management Issues
Page 34 GAO-05-97 Electronic Disability Claims Processing

Appendix I

Objectives, Scope, and Methodology ApApenednxidexiIs

Our objectives were to (1) assess the current status of SSA’s accelerated 

implementation of its electronic disability system—the initiative known as 

AeDib and (2) identify actions the agency has taken in response to our 

prior recommendations on this initiative. To assess the agency’s status in 

implementing its electronic disability system, we analyzed relevant project 

management documentation including schedules, project plans, and 

reports documenting the status of the system’s rollout to the 54 state 

disability determination service (DDS) offices and SSA’s 144 Office of 

Hearings and Appeals (OHA) sites. In addition, we reviewed technical 

documentation, such as software project scope agreements and software 

development plans, to assess the development, implementation, and 

operation of the electronic disability system. We also reviewed system 

release certifications to ensure that systems had been validated and 

certified.

To identify issues that arose during the AeDib implementation process, we 

reviewed problems reported by the DDSs via SSA’s Change Asset Problem 

Reporting System. We also reviewed the results of the National Council of 

Disability Determination Directors’ February 2005 survey of its member 

DDS offices on their experiences in implementing the electronic disability 

system, as a means of identifying any problems and issues that the states 

had encountered. In addition, we reviewed reports on the system’s 

implementation, performance, and capacity that had been prepared by the 

Council and the DDSs.

We supplemented our analysis with interviews of SSA officials in the 

Offices of Operations, Systems, Disability and Income Security Programs, 

and Hearings and Appeals. We also interviewed DDS officials in nine states: 

California, Delaware, Florida, Illinois, Mississippi, Nebraska, New York, 

North Carolina, and South Carolina. In addition, we interviewed the 

President of the National Council of Disability Determination Directors, an 

organization that represents the DDSs.

Our selection of the nine states was based on the following criteria:

• The Mississippi DDS was the first state to which the electronic disability 

system was rolled out, as well as the first state to achieve total 

electronic processing of initial disability cases.

• The California, Illinois, and North Carolina DDSs had participated in 

initial pilot tests of the electronic processing system, which had 

included assessing use of the Document Management Architecture.
Appendix I

Objectives, Scope, and Methodology

Page 35 GAO-05-97 Electronic Disability Claims Processing

• The Florida and South Carolina DDSs were states that received the 

electronic disability system early in the implementation schedule.

• The New York and Nebraska DDSs posed potential unique challenges as 

the only two “independent” states, in which their existing claims 

processing capabilities were not supported by the common hardware 

platform that the majority of DDSs used and that had developed and 

were relying on disability claims processing software that was unique to 

their processing environments.

• The Delaware DDS was managed by the President of the National 

Council of Disability Determination Directors.

We conducted site visits at two DDSs—Mississippi and South Carolina—to 

observe the electronic processing system in operation, and at OHA sites in 

these same states to discuss their experiences in implementing and using 

the electronic folder and their preparation for receiving appeals of initial 

claims that had been processed electronically in the respective state DDS 

offices.

To determine what actions SSA had taken toward implementing our prior 

recommendations on the electronic disability system, we obtained and 

reviewed software project scope agreements, software development plans, 

user validation and system certification plans, and AeDib component 

security risk assessment documentation. We also interviewed agency 

officials regarding the status of their actions on each of the 

recommendations made in our March 2004 report on AeDib. In addition, we 

discussed SSA’s efforts to improve communications on the initiative’s 

implementation with DDS officials in each of the offices that we contacted 

and with the President of the National Council of Disability Determination 

Directors.

We conducted our work at SSA’s headquarters in Baltimore, Maryland, and 

at selected DDS and OHA offices in Jackson, Mississippi, and Columbia, 

South Carolina, from October 2004 to July 2005, in accordance with 

generally accepted government auditing standards.
Page 36 GAO-05-97 Electronic Disability Claims Processing

Appendix II

Comments from the Social Security 

Administration ApendxiI
Appendix II

Comments from the Social Security 

Administration

Page 37 GAO-05-97 Electronic Disability Claims Processing
Appendix II

Comments from the Social Security 

Administration

Page 38 GAO-05-97 Electronic Disability Claims Processing
Appendix II

Comments from the Social Security 

Administration

Page 39 GAO-05-97 Electronic Disability Claims Processing
Appendix II

Comments from the Social Security 

Administration

Page 40 GAO-05-97 Electronic Disability Claims Processing
Appendix II

Comments from the Social Security 

Administration

Page 41 GAO-05-97 Electronic Disability Claims Processing
Page 42 GAO-05-97 Electronic Disability Claims Processing

Appendix III

GAO Contact and Staff Acknowledgments ApendxiI

GAO Contact Linda D. Koontz (202) 512-6240

Staff 

Acknowledgments

In addition to the individual named above, Valerie C. Melvin, Assistant 

Director; Michael A. Alexander; J. Michael Resser; and Eric L. Trout made 

significant contributions to this report. Neil J. Doherty and Joanne Fiorino 

also contributed to the report.

(310726)
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