SOCIAL SECURITY 

ADMINISTRATION

Long-Term Strategy 

Needed to Address 

Key Management 

Challenges

Report to the Chairman, Subcommittee 

on Social Security, Committee on Ways 

and Means, House of Representatives

May 2013

GAO-13-459

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-459, a report to the 

Chairman, Subcommittee on Social Security, 

Committee on Ways and Means, House of 

Representatives

May 2013

SOCIAL SECURITY ADMINISTRATION

Long-Term Strategy Needed to Address Key 

Management Challenges

Why GAO Did This Study

SSA is responsible for providing 

benefits and services that affect the 

lives of nearly every American. In 

calendar year 2012, SSA paid over 62 

million people more than $826 billion in 

Social Security retirement and 

disability benefits and Supplemental 

Security Income payments. However, 

SSA faces increased workloads and 

large numbers of potential employee 

retirements in the long term. It is 

expected that a new Commissioner will 

soon be leading the agency. GAO was 

asked to describe issues confronting 

SSA. This report examines (1) key 

management challenges SSA faces in 

meeting its mission-related objectives, 

and (2) the extent to which SSA’s 

planning efforts address these 

challenges. To do this, GAO reviewed 

relevant planning documents and 

reports from SSA and others as well as 

SSA management information and 

data on workload and staffing 

projections, and applicable federal 

laws and regulations; and interviewed 

SSA headquarters and regional 

officials, representatives of employee 

groups, and other experts.

What GAO Recommends

To address SSA’s key management 

challenges, the agency should (1) 

consider having an entity or individual 

dedicated to strategic planning, (2) 

develop a long-term strategy for 

service delivery, (3) take steps to 

update its succession plan, and (4) 

explore the utility and feasibility of 

realigning its headquarters, regional, 

and field office structure. SSA agreed 

with our recommendations and 

outlined plans for implementation.

What GAO Found

The Social Security Administration (SSA) will experience management 

challenges in four key areas over the next decade. 

Human capital. SSA has not updated its succession plan since 2006 although the 

agency faces an ongoing retirement wave and hiring freeze which will make it 

difficult to respond to growing workload demands.

Disability program issues. SSA faces ongoing challenges incorporating a more 

modern concept of disability into its programs, while balancing competing needs 

to reduce backlogs of initial and appealed claims and ensure program integrity. 

Information technology (IT). SSA has made strides in modernizing its IT systems 

to address growing workload demands, but faces challenges with these 

modernization efforts and correcting internal weaknesses in information security. 

Physical infrastructure. SSA is moving toward centralized facilities management, 

but the agency lacks a proactive approach to evaluating its office structure that 

will identify potential efficiencies, such as consolidating offices.

Long-Term Projected Growth in SSA’s Workload Coincides with Large Numbers of Potential 

Employee Retirements

SSA has ongoing planning efforts, but they do not address the long-term nature 

of these management challenges. For example, SSA is finalizing a service 

delivery plan, but it only includes detailed plans for the next 5 years and focuses 

on existing initiatives rather than articulating specific long-term strategies for the 

agency’s service delivery model. Its current strategic plan also largely describes 

the continuation, expansion, or enhancement of ongoing activities, rather than 

proposing broad changes to address emerging issues. Since 2008, SSA has not 

had an entity or individual dedicated to strategic planning. Various groups have 

called on SSA to articulate a longer-term strategy, which it last did in 2000, 

motivated by many conditions which remain true today—such as increasing 

workloads, advances in technology, and employee retirements—and which will 

need to be addressed in the future. Strategic planning literature and experts cite 

key long-term planning practices such as planning for different scenarios and 

aligning interim plans with the long-term strategy as necessary for success. 

View GAO-13-459. For more information, 

contact Daniel Bertoni at (202) 512-7215 or 

bertonid@gao.gov
Page i GAO-13-459 SSA Management Challenges

Letter 1 

Background 2

SSA Faces Key Management Challenges in Human Capital, 

Disability Program Issues, Information Technology, and Physical 

Infrastructure 8

SSA’s Planning Efforts Are Not Adequate to Address the LongTerm Nature of Its Management Challenges 29

Conclusions 33

Recommendations for Executive Action 34

Agency Comments 35

Appendix I Objectives, Scope, and Methodology 37

Appendix II Key Questions to Consider When Evaluating Consolidation 

Proposals 39

Appendix III Comments from the Social Security Administration 44

Appendix IV GAO Contact and Staff Acknowledgments 48

Related GAO Products 49

Table

Table 1: Selected Aspects of SSA’s Workload and Volume, Fiscal 

Year 2012 6

Figures

Figure 1: Beneficiaries of Old-Age and Survivors Insurance, 

Disability Insurance, and Supplemental Security Income 

Programs in Payment Status as of the End of the Year 3

Contents 
Page ii GAO-13-459 SSA Management Challenges

Figure 2: Federal Benefit Outlays for Old-Age and Survivors 

Insurance, Disability Insurance, and Supplemental 

Security Income Programs 4

Figure 3: Administrative Expenses for Old-Age and Survivors 

Insurance, Disability Insurance, and Supplemental 

Security Income Programs in Fiscal Year 2012 5

Figure 4: Actual and Projected Retirements of SSA Staff, Fiscal 

Years 2009-2020 9

Figure 5: Percentage of Non-Supervisors and Supervisors at SSA

Eligible for Retirement, Fiscal Years 2011–2020 10

Figure 6: Average Wait Time for SSA Disability Claim Hearings 

from Request to Decision and Percentage of Offices with 

Longest Wait Times 17

Figure 7: Weaknesses Identified in SSA’s Information Security 

Program, Fiscal Years 2009–2012 22

Figure 8: Number of SSA Facilities by Component and Type (as of 

Fiscal Year 2012) 24
Page iii GAO-13-459 SSA Management Challenges

Abbreviations

CDR continuing disability reviews

CIO Chief Information Officer

COBOL Common Business Oriented Language

DDS Disability Determination Services 

DI Disability Insurance 

FISMA Federal Information Security Management Act of 2002

GSA General Services Administration

GPRA Government Performance and Results Act

IT information technology 

O*NET Occupational Information Network

OASI Old-Age and Survivors Insurance 

OFSM SSA’s Office of Facilities and Supply Management

OIG SSA’s Office of the Inspector General 

OMB Office of Management and Budget

RRB Railroad Retirement Board 

SNAP Supplemental Nutrition Assistance Program 

SSA Social Security Administration 

SSI Supplemental Security Income

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Page 1 GAO-13-459 SSA Management Challenges

441 G St. N.W.

Washington, DC 20548

May 29, 2013

The Honorable Sam Johnson

Chairman

Subcommittee on Social Security

Committee on Ways and Means

House of Representatives

Dear Mr. Chairman:

The Social Security Administration (SSA) is responsible for providing 

benefits and services that affect the lives of nearly every American. In 

calendar year 2012, SSA paid over 62 million people more than $826 

billion in Social Security retirement and disability benefits and 

Supplemental Security Income payments. As more members of the baby 

boom generation become eligible for retirement benefits and individuals 

under age 62 reach their disability-prone years, a surge in benefit 

applications is expected. Evolving technology will affect service delivery 

expectations, and SSA’s own workforce may also change and decrease 

in the coming years. At the same time, SSA’s expanded use of electronic 

services will affect how the agency should deploy and use its workforce. 

In addition, the agency will need to operationalize any legislative changes 

that may be made in an effort to avoid the projected exhaustion of the 

Social Security trust funds. As a result of these realities, SSA will 

encounter increased pressure to serve the public while still ensuring 

program integrity. Moreover, SSA will likely continue to experience budget 

constraints.

A new Commissioner will soon be leading the agency and will face these 

many interrelated issues.1 Decisions made early in the Commissioner’s 

term could help set the course for the agency over the long term and 

determine how well-positioned it is to adapt to changing realities.2

 

1

The SSA Commissioner is appointed for a 6-year term. 42 U.S.C. § 902(a)(3). The last 

Commissioner’s term expired on January 19, 2013, and an acting commissioner is 

currently leading the agency. As of May 2013, a new Commissioner had not yet been 

appointed.

GAO 

was asked to describe issues confronting SSA. This report addresses (1) 

2

In this report, when referring to short-term, we generally mean up to 5 years out and by 

long-term we mean more than 5 years.

 
 

Page 2 GAO-13-459 SSA Management Challenges

key management challenges SSA faces in meeting its mission-related 

objectives and (2) the extent to which SSA’s planning efforts address 

these challenges.

To examine these issues, we obtained SSA management information and 

administrative data related to workload and staffing projections. We 

assessed the reliability of the data by reviewing related documentation 

and interviewing knowledgeable agency officials and determined they 

were sufficiently reliable to describe agency projections. We also 

reviewed key agency planning and other documents, such as SSA’s 

strategic plan, strategic human capital plan, strategic leadership 

succession plan, information technology strategic plan, facilities 

standards, and agency-wide draft service delivery plan. We conducted indepth interviews with SSA officials, including regional commissioners, and 

other experts, including representatives of the Social Security Advisory 

Board and others familiar with long-term planning. We reviewed GAO 

internal control standards and relevant GAO, SSA Office of the Inspector 

General (OIG), and Social Security Advisory Board reports, as well as 

applicable federal laws and regulations and SSA’s policies and 

procedures.3

We conducted this performance audit from September 2012 to May 2013

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

See appendix I for more on our scope and methodology.

SSA provides financial assistance to eligible individuals through three 

major benefit programs:

• Old-Age and Survivors Insurance (OASI)—provides retirement 

benefits to older workers and their families and to survivors of 

deceased workers.

 

3

For relevant prior GAO work on this topic, see the Related GAO Products list. 

Background 
 

Page 3 GAO-13-459 SSA Management Challenges

• Disability Insurance (DI)—provides benefits to eligible workers who 

have qualifying disabilities, and their eligible family members.

• Supplemental Security Income (SSI)—provides income for aged, 

blind, or disabled individuals with limited income and resources.

SSA projects that the number of beneficiaries and benefit payments for 

the three programs will increase over the next several years (see figures 

1 and 2). DI and SSI are the nation’s largest federal disability programs, 

and applications for benefits have grown significantly over the last 5 

years, due in part to baby boomers reaching their disability-prone years, 

as well as a sustained economic downturn and high unemployment. 

Retirement claims have also steadily increased in recent years.

Figure 1: Beneficiaries of Old-Age and Survivors Insurance, Disability Insurance, 

and Supplemental Security Income Programs in Payment Status as of the End of 

the Year

a

The total refers to the number of individuals with either an OASI, DI, or federal SSI benefit. 

Concurrent beneficiaries are excluded from the total to avoid double-counting.

b

According to SSA, some individuals are ineligible for federal SSI benefits due to excess income, but 

are eligible for State supplementation. These individuals are not included in these recipient counts.

c

Concurrent recipients are those receiving federal SSI benefits and benefits from either the OASI or 

DI program. These figures are included in the OASI, DI, and SSI counts above.
 

Page 4 GAO-13-459 SSA Management Challenges

Figure 2: Federal Benefit Outlays for Old-Age and Survivors Insurance, Disability 

Insurance, and Supplemental Security Income Programs

a

This figure includes federal SSI outlays only. It excludes state supplementation benefits. Federal SSI 

outlays reflect actual timing of payments. For any calendar year, outlays exclude payments due on 

January 1 of the given year but include payments due on January 1 of the following year.

b

This figure includes an offset for reimbursements due to un-negotiated checks and payments to 

providers of vocational rehabilitation services.

Although SSA’s disability programs account for only about 23 percent of 

its total benefit outlays, they represent 66 percent of the administrative 

expenses for these 3 programs (see fig. 3). Complex eligibility rules and 

many layers of review with multiple handoffs from one person to another 

make the disability programs complicated, and therefore costly, to 

administer. After the field office determines that an applicant has met 

SSA’s nonmedical eligibility requirements for disability benefits,4

 

4

For example, SSA will ensure that an SSI applicant meets income requirements and 

determine if a DI applicant has a sufficient work history.

the 

applicant’s claim is sent to the state Disability Determination Services 
 

Page 5 GAO-13-459 SSA Management Challenges

(DDS) for a review of the claimant’s medical eligibility.5

Figure 3: Administrative Expenses for Old-Age and Survivors Insurance, Disability 

Insurance, and Supplemental Security Income Programs in Fiscal Year 2012 

After assembling 

all medical and vocational information for the claim, a DDS examiner in 

consultation with appropriate medical staff determines whether the 

claimant meets the requirements of the law for having a disability. 

Claimants who are dissatisfied with the initial DDS determination have up 

to three levels of appeal, including a “reconsideration” of the claim, 

conducted by DDS personnel who were not involved in the original 

decision; a hearing before an administrative law judge; and a review of 

the claim by the Appeals Council, which is comprised of administrative 

appeals judges and appeals officers. 

a

Administrative expenses such as personnel and physical infrastructure associated with OASI, DI and 

SSI programs account for approximately 86 percent of the agency’s total administrative budget. Other 

administrative expenses not associated with programs include research and operations for SSA’s 

Office of the Inspector General.

 

5

SSA generally considers individuals disabled if they cannot do work that they did before; 

they cannot adjust to other work because of their medical condition(s); and their disability 

has lasted or is expected to last for at least 1 year or to result in death. See 42 U.S.C. §

423(d). Although SSA is responsible for the program, the law generally calls for initial 

determinations of disability to be made by state DDS agencies. See 42 U.S.C. §

421(a)(1).The work performed at DDS offices is federally financed and carried out under 

SSA disability program regulations, policies, and guidelines. 
 

Page 6 GAO-13-459 SSA Management Challenges

Both OASI and DI face long-term financial challenges. SSA’s Office of the 

Chief Actuary has reported that OASI cannot sustain projected long-run 

program costs under currently scheduled financing, and that legislative 

modifications are necessary to avoid disruptive consequences for 

beneficiaries and taxpayers. In 2012, SSA’s Office of the Chief Actuary 

projected that the DI and OASI Trust Funds would be exhausted in 2016 

and 2035, respectively. If the trust funds are depleted before legislative 

changes are made to restore long-term solvency, the agency projects that 

it will be able to pay benefits only to the extent that funds are available.6

In support of its mission and programs, SSA’s basic functions include 

maintaining earnings information, making initial eligibility determinations 

for program payments, making changes to beneficiaries’ accounts that 

affect their benefit payments, and issuing Social Security numbers.7 SSA 

also provides administrative support to the Medicare program, partners 

with the Department of Homeland Security in verifying employment 

eligibility for new hires, and assists with the administration of other 

programs, such as the Supplemental Nutrition Assistance Program 

(SNAP) and Railroad Retirement Board (RRB) benefits program.8

Table 1: Selected Aspects of SSA’s Workload and Volume, Fiscal Year 2012

Table 1 

includes volume data on some key aspects of SSA’s workload for fiscal 

year 2012.

Maintaining earnings information

Earnings items posted to workers’ records 220 million

Making initial eligibility determinations for program payments

Retirement, survivor, and Medicare applications received 5 million

Initial disability applications received 3.2 million

Denied disability applications reconsidered 809,000

Hearings conducted 672,000

Appeals Council reviews completed 166,000

 

6

While money would still be coming in from the Social Security taxes paid by current 

workers, the agency projects that it would not be sufficient for beneficiaries to receive their 

full benefit.

7

Social Security numbers have become the universal identifier of choice for government 

agencies and are currently used for many non-Social Security purposes.

8

SSA offices take applications for SNAP and certify Social Security benefits for the RRB.
 

Page 7 GAO-13-459 SSA Management Challenges

Making changes to beneficiaries’ accounts that affect benefit payments

Overpayment actions completed 3.2 million

SSI non-disability redeterminations completed 2.6 million

Continuing disability reviews completed 443,000

Issuing Social Security numbers 

New and replacement Social Security cards issued 16 million

Other functions

Automated Social Security number verifications performed 1.5 billion

Transactions completed on National 800 Number 56 million

Visitors assisted 45 million

Source: GAO analysis of SSA data from SSA’s FY 2012 Performance Accountability Report.

SSA has over 80,000 state and federal employees9

SSA is operating in an environment of constrained resources and 

budgetary uncertainty. According to a former SSA commissioner and 

agency budget documents, while SSA’s administrative budget increased 

about 32 percent from fiscal year 2001 to 2010,

to administer SSA 

programs in about 1,700 facilities nationwide. These facilities include 

regional offices, field offices, teleservice centers, processing centers, 

hearings offices, the Appeals Council, and SSA’s headquarters in 

Baltimore, Maryland. Almost 182,000 people visit one of the nearly 1,300 

SSA field offices daily, and more than 445,000 people call the offices 

daily to file applications, ask questions, or update their information.

10 much of this funding 

has been used to keep up with increases in expenses such as personnel 

costs, rent, and security. Furthermore, for several years Congress has 

passed continuing resolutions to prevent funding gaps when regular 

appropriations bills have not been enacted by the start of a fiscal year. As 

we have previously reported, operating under a continuing resolution may 

limit agencies’ management options and lead to incremental planning and 

repetitive activities, resulting in inefficiencies.11

 

9

SSA funds DDSs, which are state agencies, to process disability applications and 

conduct continuing disability reviews in accordance with SSA policies and procedures.

10This figure has been adjusted for inflation. The nominal increase between fiscal years 

2001 and 2010 was about 61 percent.

11GAO, Continuing Resolutions: Uncertainty Limited Management Options and Increased 

Workload in Selected Agencies, GAO-09-879 (Washington, D.C.: September 24, 2009).
 

Page 8 GAO-13-459 SSA Management Challenges

Over the next decade, SSA will experience management challenges in 

four key areas: 1) human capital, 2) disability program issues, 3) 

information technology, and 4) physical infrastructure. 

Over the next decade SSA’s ongoing retirement wave, coupled with a 

hiring freeze that has been in place since 2010, will create significant 

management challenges for the agency in meeting its projected growth in 

work demands. Although not all employees will necessarily retire when 

eligible, nearly 7,000 headquarters employees and more than 24,000 field 

employees will become retirement eligible between 2011 and 2020. The 

agency projects that it could lose nearly 22,500 employees, or nearly onethird of its workforce, during this time due to retirement—its primary 

source of attrition (see fig. 4).12

 

12Data reflect SSA’s most recent projections from its September 2011 Retirement Wave 

Report, which only includes actual retirement figures through fiscal year 2010. Officials 

told us that they previously produced this report annually but currently produce it every 

other year. 

Officials told us that as a result of the 

hiring freeze, they have been unable to back-fill positions vacated by 

retiring employees. The Commissioner stated in SSA’s fiscal year 2012 

budget overview that as a result of attrition, some offices could become 

understaffed, and that without a sufficient number of skilled employees, 

backlogs and wait times could significantly increase and improper 

payments could grow. As SSA’s workforce decreases and its workload 

increases, the agency’s strategies for preventing a loss of leadership and 

skills may prove insufficient for a variety of reasons.

SSA Faces Key 

Management 

Challenges in Human 

Capital, Disability 

Program Issues, 

Information 

Technology, and 

Physical 

Infrastructure

SSA’s Strategies to Prevent 

a Leadership and Skills 

Shortage May Be 

Insufficient During a Time 

of Increasing Workloads
 

Page 9 GAO-13-459 SSA Management Challenges

Figure 4: Actual and Projected Retirements of SSA Staff, Fiscal Years 2009-2020

Note: Numbers refer to retirements of full-time and part-time permanent employees. Data reflect 

SSA’s most recent projections from its September 2011 Retirement Wave Report, which only 

includes actual retirement figures through fiscal year 2010.

Retaining institutional knowledge and developing new leaders. SSA 

could face a significant loss of institutional knowledge and expertise in the 

coming years. An estimated 43 percent of SSA’s non-supervisory 

employees and 60 percent of its supervisors will be eligible to retire by 

2020 (see fig. 5). The high percentage of supervisors who are eligible to 

retire could leave a gap in terms of certain skills or institutional 

knowledge. For example, regional and district managers told us they have 

lost staff experienced in handling the most complex disability cases and 

providing guidance on policy compliance.13

 

13According to SSA, DDS staff are state employees and are subject to state furloughs. 

SSA officials and DDS 

managers told us that it typically takes 2 to 3 years for new employees to 

become fully proficient and that new hires benefit from mentoring by 

veteran employees. Because of budget cutbacks, SSA has also curtailed 

its leadership development programs, which have historically been used 

to establish a pipeline of future leaders. According to SSA officials, the 
 

Page 10 GAO-13-459 SSA Management Challenges

pressure to keep up with workload demands in the face of staff losses 

and the loss of leadership development programs will likely negatively 

affect employee morale. Some officials also said low morale and a feeling 

of being stretched too thin are hastening retirement among those who are 

eligible. Employees rated the agency lower on the Office of Personnel 

Management’s Federal Employee Viewpoint Survey in 2012 than in 2011 

in terms of the extent to which they think the agency has the talent 

necessary to achieve organizational goals (59 percent compared to 62 

percent) and the extent to which they are satisfied with their jobs (68 

percent compared to 72 percent).14

Figure 5: Percentage of Non-Supervisors and Supervisors at SSA Eligible for 

Retirement, Fiscal Years 2011–2020

Note: Numbers refer to retirements of full-time and part-time permanent employees. Eligibility figures 

are cumulative.

Succession planning. SSA’s most recent succession plan was issued in 

2006, even though the agency has experienced significant changes since 

that time, including a hiring freeze and greater movement toward online 

 

14The Federal Employee Viewpoint Survey is a tool that measures employees’ 

perceptions of whether, and to what extent, conditions that characterize successful 

organizations are present in their agencies. Agency results have a margin of error of less 

than plus or minus 1 percentage point. Data collected from survey respondents were 

weighted to produce estimates that represent the agency population. Office of Personnel 

Management, 2012 Federal Employee Viewpoint Survey Results: Employees Influencing 

Change, Governmentwide Management Report. (Washington, D.C.).
 

Page 11 GAO-13-459 SSA Management Challenges

services. The most recent succession plan established a target of 

evaluating and updating the plan by the end of 2007. GAO’s Standards 

for Internal Control in the Federal Government state that management 

should ensure that skill needs are continually assessed and that the 

organization is able to obtain a workforce with those required skills to 

achieve organizational goals.15 GAO’s internal controls guidance also 

states that management should consider how best to retain valuable 

employees, plan for their eventual succession, and ensure continuity of 

needed skills and abilities. Leading organizations use succession 

planning to identify, develop, and select successors who are the right 

people, with the right skills, at the right time for leadership and other key 

positions.16 Other key principles of strategic workforce planning include 

determining critical skills and competencies that will be needed to achieve 

current and future programmatic results and developing strategies to 

address gaps in these skills and competencies.17

SSA’s 2006 succession plan states that without sound succession 

planning, SSA’s loss of leadership would result in a drain on institutional 

knowledge and expertise at a time when workloads are growing. This loss 

of knowledge and expertise could result in increasing workloads, 

backlogs, and improper payments. Several SSA officials told us the lack 

of proper succession planning can be detrimental to future agency 

operations. For example, they said individuals with less experience and 

training are beginning to assume supervisory roles and some have made 

poor decisions related to such things as employee contract issues and 

providing reasonable accommodations to employees with disabilities. 

Some officials also told us that inexperienced managers are less 

proficient at supervising others, which leads to inefficiencies in managing 

 

15GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1, 1999).

16See GAO, Human Capital: Succession Planning and Management Is Critical Driver of 

Organizational Transformation, GAO-04-127T (Washington, D.C.: October 1, 2003) and 

GAO, Human Capital: Selected Agencies Have Opportunities to Enhance Existing 

Succession Planning and Management Efforts, GAO-05-585 (Washington, D.C.: June 30, 

2005).

17Strategic workforce planning addresses two critical needs: (1) aligning an organization’s 

human capital program with its current and emerging mission and programmatic goals and 

(2) developing long-term strategies for acquiring, developing, and retaining staff to achieve 

programmatic goals. GAO, Human Capital: Key Principles for Effective Strategic 

Workforce Planning, GAO-04-39 (Washington, D.C.: December 11, 2003).
 

Page 12 GAO-13-459 SSA Management Challenges

increasing workloads. Moreover, SSA employees’ perceptions of agency 

leaders’ ability to motivate staff, communicate goals and priorities, and 

demonstrate other leadership behaviors diminished from 2011 to 2012 

among those responding to the Office of Personnel Management’s 

Federal Employee Viewpoint Survey.18

SSA’s Strategic Human Capital Plan does not establish an explicit 

requirement for how frequently the agency will update its succession plan, 

but it identifies the succession plan as one component for determining 

how SSA makes data-driven decisions to continuously improve the 

agency’s human capital practices. Senior SSA officials told us that the 

agency’s succession plan has not been updated more recently because 

the analyst staff who were responsible for preparing it have been 

reassigned to other duties that the agency considered more urgent, such 

as managing personnel programs. SSA officials also noted that in the 

current budgetary environment, conducting succession planning has 

become a luxury.

Forecasting workforce needs. Findings from OIG reports raise 

additional concerns about SSA’s ability to accurately forecast workload 

demands and workforce needs.19 These reports found methodological 

flaws in the workload and work year data SSA uses to formulate and 

execute its budget. For example, the reports concluded that the internal 

controls and main processes related to work sampling—which SSA uses 

to measure work and assign direct and indirect costs to workloads—did 

not ensure the completeness and reliability of data in SSA’s Cost Analysis 

System.20

 

18In response to a combination of questions designed to assess employee’s perceptions 

of the integrity of leadership, as well as leadership behaviors such as communication and 

workforce motivation, 66 percent of SSA employees had a favorable view of agency 

leadership in 2011, compared to 62 percent of employees in 2012. 

The reports found that work samples were not consistently 

19SSA’s OIG contracted with Grant Thornton LLP to conduct the following reviews of 

SSA’s Cost Analysis System and cost allocation methodology: SSA OIG, Cost Analysis 

System Background Report and Viability Assessment, A-15-10-20149 (April 20, 2011); 

SSA OIG, Office of Disability Adjudication and Review Cost Allocation Process, A-15-10-

20150 (May 5, 2011); SSA OIG, The Social Security Administration Cost Allocation 

Process, A-15-10-20151 (Dec. 7, 2011); and SSA OIG, The Social Security Administration 

Cost Allocation Methodology, A-15-10-20152 (June 18, 2012).

20SSA’s Cost Analysis System is used to allocate (1) administrative costs to Trust Fund 

and general fund programs administered by SSA and (2) reimbursable work performed by 

SSA for outside organizations.
 

Page 13 GAO-13-459 SSA Management Challenges

performed. Furthermore, they noted no instances of peer or management 

review, which could improve the accuracy of the workload data 

collected.21 SSA is taking steps to improve data sampling in response to 

these findings.

Modernizing disability programs. We designated federal disability 

programs as a high-risk area in 2003, in part because these programs 

emphasize medical conditions in assessing an individual’s work 

incapacity without adequate consideration of the work opportunities 

afforded by advances in medicine, technology, and job demands.22

Concerns have been raised that the medical listings being used lack 

current and relevant criteria to evaluate disability applicants’ inability to 

work, and that by failing to consider the role of assistive devices, and 

workplace accommodations, SSA may be missing opportunities to help 

individuals with disabilities return to work. In 2012, we noted that resource 

constraints have impeded SSA’s efforts to ensure timely updates to its 

medical criteria.23 However, SSA has recently taken steps toward 

comprehensively updating the medical and labor market information that 

underlie its disability criteria. As of March 2013, SSA had completed 

comprehensive revisions of its medical criteria for 10 of the 14 adult body 

systems and initiated targeted reviews of certain conditions under these 

systems, as appropriate, according to SSA officials.24

SSA has also recently made progress toward replacing its outdated 

occupational information system, including signing an interagency 

 

21SSA officials told us that these data are statistically reliable at a national level and are 

combined with other data sources to forecast workloads. However, SSA has not yet 

assessed enough work sampling data to produce a refined estimate of the statistical 

reliability of workload calculations based on work sampling data. 

22GAO, High-Risk Series: An Update, GAO-13-283 (Washington, D.C.: February 14, 

2013).

23GAO, Modernizing SSA Disability Programs: Progress Made, but Key Efforts Warrant 

More Management Focus, GAO-12-420 (Washington, D.C.: June 19, 2012).

24To determine an applicant’s eligibility for disability benefits, SSA examiners assess the 

applicant’s medical impairments against the Listings of Impairments, also known as the 

medical listings, which are organized into 14 major body systems for adults and reflect 

medical conditions that have been determined by the agency to be severe enough to 

qualify an applicant for benefits. According to SSA officials, there are almost 300 medical 

impairments organized in 119 listings under the 14 major body systems for adults.

SSA Continues to Face 

Challenges in Modernizing 

Its Disability Programs, 

While Seeking a Balance 

Between Reducing 

Backlogs and Ensuring 

Program Integrity
 

Page 14 GAO-13-459 SSA Management Challenges

agreement with the Department of Labor’s Bureau of Labor Statistics to 

design, develop, and carry out pilot testing to assess the feasibility of 

using an existing survey25 to collect data for an updated system.26

SSA has also taken steps to more fully consider individuals’ ability to 

function with medical impairments in their work or other environments, 

which is consistent with modern views of disability. For example, SSA has 

incorporated into some of its medical criteria an assessment of whether a 

claimant’s impairments result in functional limitations that can limit the 

ability to work and is sponsoring research to more broadly consider how 

to incorporate these types of assessments in determining disability. 

However, SSA disagreed with our prior recommendation to conduct 

limited, focused studies on how to more fully consider factors such as 

assistive devices and workplace accommodations in its disability 

determinations,

SSA 

previously determined that the Department of Labor’s existing 

occupational database, the Occupational Information Network (O*NET), 

was not sufficiently detailed for evaluating DI and SSI claims, so it would 

need to develop its own occupational information system. According to 

SSA officials, the agency still needs to determine exactly how many 

occupations it will include in its new system, the extent to which it might 

leverage aspects of O*NET, and the extent to which the new system will 

include cognitive information. In addition, officials told us that while SSA is 

currently developing a research plan for fiscal year 2014 and expects that 

its current approach will cost less and take less time than previously 

expected, the agency has not yet finalized a cost estimate. 

27

 

25Specifically, the Bureau of Labor Statistics is assessing the feasibility of using the 

National Compensation Survey. 

stating that such studies would be inconsistent with 

Congress’ intentions. We noted that Congress has not explicitly prohibited 

SSA from considering these factors and we believe that conducting these 

studies would put SSA in a better position to thoughtfully weigh the costs 

and benefits of these various policy options before deciding on a course 

of action. After reviewing a draft of our report, the agency said that it 

would explore the possibility of conducting research in the area of 

26SSA evaluates claimants’ ability to work in the national economy as part of its disability 

decision-making process. See 42 U.S.C. §§ 423(d), 1382c(a).The occupational 

information system provides information on jobs in the national economy.

27GAO-12-420. 
 

Page 15 GAO-13-459 SSA Management Challenges

assistive devices but noted that this research would require the 

involvement of highly specialized medical professionals.

Managing workloads to reduce disability initial claims and hearings 

backlogs. Although SSA has reported progress with its disability 

hearings backlog reduction plan, the agency still faces challenges 

managing significant and persistent disability workload increases, both in 

terms of initial claims and hearings for appealed claims. SSA has 

generally increased the number of initial disability claims it has processed 

annually—completing over 3 million claims each year since fiscal year 

2010—but the number of initial claims submitted by applicants has 

outpaced SSA’s effort. Thus, the number of claims awaiting a decision is 

also growing. SSA’s 707,700 initial claims pending in fiscal year 2012 

were 27 percent higher than fiscal year 2008 levels. The number of 

disability beneficiaries is projected to grow about 15 percent between 

2012 and 2025. To help manage workloads, Disability Determination 

Services share work nationally by shifting resources among DDSs on a 

weekly basis, and dedicated teams in certain states assist by taking 

claims from states with the highest levels of pending claims. SSA also 

identifies claimants with the most severe disabilities and expedites 

decisions on these cases,28 although they represented less than 6 

percent of all initial determinations in September 2012.29 Most of SSA’s 

regional commissioners told us that simplifying disability policy, such as 

by streamlining work incentive and work reporting rules, could also help 

staff better manage disability workloads. Under its regulations, SSA has 

set forth procedures for testing certain streamlining modifications to its 

disability determination process.30

 

28SSA has two initiatives to expedite cases for the most severely disabled individuals: 

Quick Disability Determination and Compassionate Allowances. Using predictive modeling 

and computer-based screening tools to screen initial applicants, the Quick Disability 

Determination identifies cases where a favorable disability determination is highly likely 

and medical evidence is readily available, such as with certain cancers and end-stage 

renal disease. With Compassionate Allowances, SSA targets the most obviously disabled 

applicants based on available medical information and generally awards benefits if there is 

objective medical evidence to confirm the diagnosis and the applicant also meets SSA’s 

non-disability criteria.

One such modification is the ‘‘single 

29SSA derives this percentage by dividing the total number of initial disability claims 

identified as Quick Disability Determinations, Compassionate Allowances, or both, by the 

total number of electronic initial disability claims filed in September, the last month of the 

fiscal year. 

3020 C.F.R. §§ 404.906, 416.1406.
 

Page 16 GAO-13-459 SSA Management Challenges

decisionmaker’’ approach that allows a disability examiner to make an 

initial disability determination in most cases without obtaining the 

signature of a medical or psychological consultant.31 For example, the 

examiner can deny an individual whose physical impairments are not 

expected to meet the duration requirement of 12 months—such as a 26-

year-old accident victim who is recovering normally from a recently 

fractured arm and leg—without the involvement of a medical or 

psychological consultant. Further, in 10 “prototype” states, in addition to 

the “single decisionmaker” approach described above, the 

reconsideration level has been eliminated from the administrative review 

process.32

With regard to the single decisionmaker approach, many SSA officials 

told us that it reduces processing time and administrative costs by 

reserving expensive medical and psychological consultant resources for 

reviews of more complex cases. With regard to the elimination of 

reconsiderations, some officials felt that this approach decreases 

processing time and saves DDS resources, while others feel it contributes 

to the hearings backlog by adding to the administrative law judges’ 

workloads. Overall, some officials raised concerns that having some 

states with single decisionmaker authority or no reconsiderations leads to 

a lack of national uniformity. One association noted that the practice of 

sharing workloads between states heightens the need for national 

uniformity. SSA reports that it plans to extend these changes until 

September 2014, but after that time, the agency will again need to decide 

whether to extend—and possibly expand—these changes.

A claimant who is dissatisfied with the initial determination may 

request a hearing before an administrative law judge. Without 

reconsiderations, claimants’ cases move more quickly to the appeal 

stage.

While SSA is processing more initial claims annually, claims denied at the 

initial level can be appealed and often result in a request for a hearing 

before an administrative law judge. To reduce its hearings backlog, SSA 

has used strategies such as hiring additional administrative law judges 

and support staff, opening more hearings offices, and conducting more 

 

31Medical consultants generally certify all SSI childhood disability claims and all less than 

fully favorable decisions on DI and SSI claims involving an indication of a mental 

impairment.

32The prototype states also have single decisionmaker authority.
 

Page 17 GAO-13-459 SSA Management Challenges

hearings via video conference. Although SSA completed more hearing 

requests in fiscal year 2012 than in previous years, the agency fell short 

of its hearings completion target by more than 54,000 hearings and the 

average wait time for hearings exceeded the agency’s target of 321 days 

by 41 days. SSA officials attribute this missed target and longer wait 

times for hearings to the increase in claims and delays in the hiring of 

qualified administrative law judges. At the same time, the agency 

eliminated most of its oldest pending hearing requests (see fig. 6).

Figure 6: Average Wait Time for SSA Disability Claim Hearings from Request to Decision and Percentage of Offices with 

Longest Wait Times

Note: Processing time data refer to the year in which hearing requests were completed.

Ensuring disability program integrity. SSA also faces disability 

program integrity challenges due to budget decisions and the way it 

prioritizes competing workload demands such as processing initial claims. 

Continuing disability reviews (CDR) are periodic reviews that the agency 

is required to perform to verify that certain recipients still meet SSA 

disability rules. SSA performs two types of CDRs: medical CDRs to verify 

that the recipient meets medical criteria and work CDRs to determine if an 

individual’s earnings meet financial criteria. SSA reported that in fiscal 

year 2010, the agency did not conduct 1.4 million CDRs that were due for 
 

Page 18 GAO-13-459 SSA Management Challenges

review, in part because of competing workloads. In June 2012, we also 

found that more than 400,000 medical CDRs were overdue for children 

with mental impairments receiving SSI, with some pending by as many as 

13 years or more.33

When CDRs are not conducted as scheduled, some recipients may 

receive benefits for which they are no longer eligible, and the agency may 

forgo future program savings. For fiscal year 2010, SSA estimated that 

every $1 spent on CDRs yielded $9.30 in savings, amounting to a total 

future savings to federal programs of $3.5 billion.

Childhood CDRs overall fell from more than 150,000 

in fiscal year 2000 to about 45,000 in fiscal year 2011 (a 70 percent 

decrease). During this time, the number of adult CDRs fell from 584,000 

to 179,000.

34 We have previously 

found that medical and work-related overpayments in the DI program 

detected by SSA grew from about $860 million in fiscal year 2001 to 

about $1.4 billion in fiscal year 2010.35 Despite an increase in DI debt 

collections—$340 million to $839 million from fiscal year 2001 through 

fiscal year 2010—outstanding DI debt grew from $2.5 billion to $5.4 billion 

during this time, including a $225 million increase in fiscal year 2010.36

 

33GAO, Supplemental Security Income: Better Management Oversight Needed for 

Children’s Benefits, 

Although CDRs are a cost-effective way to help ensure that only those 

eligible for benefits continue to receive them, SSA officials reported that 

resource constraints have made it more difficult to remain current on the 

millions of CDRs it is required to conduct each year, and to balance the 

GAO-12-497 (Washington, D.C.: June 26, 2012).

34This figure represents the present value of future benefits saved for OASDI, SSI, 

Medicare, and Medicaid. The estimate includes savings to Medicare and Medicaid 

because in some cases eligibility for SSI and DI confers eligibility for certain Medicare or 

Medicaid benefits.

35GAO, Disability Insurance: SSA Can Improve Efforts to Detect, Prevent, and Recover 

Overpayments, GAO-11-724 (Washington, D.C.: July 27, 2011).

36When a DI work-related overpayment is identified, the beneficiary is notified of the 

overpayment and may request reconsideration or waiver of that overpayment. If SSA 

denies a reconsideration or waiver request, full repayment is requested. If the beneficiary 

is receiving DI or certain other SSA benefits, SSA may withhold partial payment of these 

benefits to recover the debt. However, if no SSA benefits are being received, or if the 

beneficiary asserts that the proposed withholding amount is too large, the agency 

generally requests repayment over 12 to 36 months. SSA policy requires a minimum 

monthly payment of $10. SSA may also attempt to recover payments due from the 

individual’s estate or subsequent survivor’s benefits. 
 

Page 19 GAO-13-459 SSA Management Challenges

competing goals of processing initial claims and reducing its backlogs 

with ensuring program integrity.

IT modernization efforts. SSA has begun to take action on several of 

our prior recommendations to improve the way it modernizes its IT 

systems.37 For example, in May 2012, SSA released its Capital Planning 

and Investment Control guide. The guide describes the roles and 

responsibilities of staff under the agency’s realigned IT organizational 

structure38 and requires that the business case for each of the agency’s 

major IT program include performance measures that will assist the 

agency in evaluating the program’s effectiveness in achieving its goals.39

SSA also issued an updated IT strategic plan that covers 2012-2016 and 

supports the updated agency-wide strategic plan.40 Furthermore, SSA 

officials told us that they intend to revisit the IT strategic plan annually and 

refresh it as appropriate. Our prior work indicates that SSA has not 

always had an updated IT strategic plan to guide its modernization 

efforts.41

 

37GAO, Social Security Administration: Improved Planning and Performance Measures 

Are Needed to Help Ensure Successful Technology Modernization, 

In the absence of regular updates, SSA based its IT 

modernization efforts on program activities that were tied to short-term 

budget cycles and not developed in the context of a long-term strategic 

plan. While we are encouraged that SSA issued an updated IT strategic 

plan, at present, it is too soon to assess the extent to which SSA will 

adhere to the plan and annual reevaluation cycle.

GAO-12-495. 

(Washington, D.C.: April 26, 2012).

38In 2011, SSA significantly realigned its IT organizational structure—consolidating its 

Chief Information Officer (CIO) office with its Systems office—but did not conduct an 

analysis of the realigned functions and how the newly assigned roles and responsibilities 

would carry out the former Office of CIO functions. Prior to the reorganization, the Office of 

the CIO’s responsibilities included some oversight activities, while the Office of Systems’ 

responsibilities focused more on developing and implementing SSA’s systems and 

enterprise architecture. We previously recommended that SSA define the roles and 

responsibilities of realigned staff. See GAO-12-495. 

39We recommended that, for each ongoing modernization initiative, SSA establish 

performance measures in each of the Office of Management and Budget’s (OMB) 

measurement areas that identify and measure how the investment contributes to meeting 

goals of the project and of overall modernization efforts.

40An in-depth analysis of the plan’s technical content was beyond the scope of our review.

41GAO-12-495. 

SSA Has Taken Steps to 

Modernize Its IT Systems 

to Keep Pace with 

Workload Demands, but 

Concerns Remain
 

Page 20 GAO-13-459 SSA Management Challenges

SSA is modernizing its IT systems, in part, to support a shift toward 

offering more online services. As we previously reported, SSA officials 

have noted that the agency faces several challenges in successfully 

carrying out IT modernization efforts, including devoting significant 

resources to the maintenance of existing legacy systems.42 The agency’s 

expenditures for operations and maintenance increased from $348 million 

in 2004 to $875 million in 2011.43 Moreover, SSA’s OIG has expressed 

concerns that the agency is continuing to rely on its legacy applications.44

For example, many of its programs are written in COBOL,45 which is one 

of the oldest computer programming languages and is difficult to modify 

and update. The OIG noted also that the agency risks losing key 

institutional knowledge related to COBOL programming and 

documentation of SSA’s increasingly complex information systems. This 

is of particular concern given the high levels of retirements and attrition 

the agency has recently experienced and will likely continue to 

experience. For example, one regional commissioner told us that when 

an experienced staff person left the region, the remaining staff lacked 

adequate knowledge of COBOL programming. According to the OIG, 

SSA has indicated that modernizing its legacy applications will ultimately 

reduce operating costs and improve service delivery. However, agency 

officials told us they have conducted analyses that show the costs of 

moving away from using COBOL currently outweigh the benefits. 

Accordingly, the OIG found in May 2012 that SSA has developed an 

approach to gradually reduce its reliance on COBOL for core processing 

transactions but has not yet articulated a formal strategy for converting its 

legacy programs to a more modern programming language.46

 

42GAO, Social Security Administration: Technology Modernization Needs Improved 

Planning and Performance Measures, GAO-12-723T. (Washington, DC: May 9, 2012).

SSA 

officials disagree that such a strategy is needed because they consider 

this programming language to be sufficient for their needs and point out 

that it is still used by other businesses. 

43GAO-12-495.

44SSA OIG, The Social Security Administration’s Software Modernization and Use of 

Common Business Oriented Language, A-14-11-11132. (Baltimore, MD: May 17, 2012).

45SSA relies on legacy applications programmed with Common Business Oriented 

Language, or COBOL. COBOL was introduced in 1959 and became the first widely used, 

high-level programming language for business applications. 

46SSA OIG, A-14-11-11132.
 

Page 21 GAO-13-459 SSA Management Challenges

Information security weaknesses. In recent years, SSA has been 

challenged to effectively protect its computer systems and networks, 

particularly with regard to internal security weaknesses. SSA uses and 

stores a great deal of sensitive information, including financial and 

medical information and Social Security numbers. Our prior work states 

that it is essential for agencies to have information security controls that 

ensure sensitive information is adequately protected from inadvertent or 

deliberate misuse, fraudulent use, and improper disclosure, modification, 

or destruction.47 However, in fiscal year 2012, SSA’s OIG identified 

weaknesses in some of the agency’s information security program 

components that limited SSA’s overall effectiveness in protecting the 

agency’s information and information systems.48 For example, auditors 

were able to gain access to Social Security numbers and other sensitive 

information through an SSA intranet search engine. According to the OIG, 

these weaknesses constituted a significant deficiency in the agency’s 

information security program under the Federal Information Security 

Management Act of 2002 (FISMA).49

 

47GAO, Transportation: Key Issues and Management Challenges, GAO-12-581T. 

(Washington, D.C., March 29, 2012).

In addition, in its fiscal year 2012 

report on SSA’s major management challenges, the OIG stated that 

weaknesses in certain elements of the agency’s information security 

program may challenge the agency’s ability to use its IT infrastructure to 

support current and future workloads. Furthermore, in the same year, the 

agency’s independent financial auditor also identified a material 

weakness in information systems controls over financial management 

48These weaknesses were identified in the areas of continuous monitoring, configuration 

management, identity and access management, risk management, and contractor 

systems oversight. See SSA OIG, The Social Security Administration’s Compliance with 

the Federal Information Security Management Act of 2002 for Fiscal Year 2012, A-14-12-

12120. (Baltimore, MD: November 15, 2012).

49FISMA was enacted as title III of the E-Government Act of 2002, Pub. L. No. 107-347, 

116 Stat. 2899, 2946. According to OMB, a significant deficiency is a weakness in an 

agency’s overall information systems security program or management control structure, 

or within one or more information systems, that significantly restricts the capability of the 

agency to carry out its mission or compromises the security of its information, information 

systems, personnel, or other resources, operations, or assets. In this context, the risk is 

great enough that the agency head and outside agencies must be notified and immediate 

or near-immediate corrective action must be taken. See OMB, “Memorandum for Heads of 

Executive Departments and Agencies: FY 2012 Reporting Instructions for the Federal 

Information Security Management Act and Agency Privacy Management,” (September 27, 

2012).
 

Page 22 GAO-13-459 SSA Management Challenges

statements based on several concerns, many of which have been 

longstanding (see fig. 7).50

Figure 7: Weaknesses Identified in SSA’s Information Security Program, Fiscal Years 2009–2012 

SSA is implementing a multi-year plan of corrective actions to address 

many of these weaknesses. For example, while SSA is currently 

reviewing access rights for different types of system users51 to identify 

any cases where employees have inappropriate access to sensitive 

information, officials told us the process is very time-consuming and the 

agency does not expect to complete its review of the highest-risk profiles 

until 2014.52

 

50In this context, the external auditors, Grant Thornton, LLP, defined a material weakness 

as one or more deficiencies in internal controls such that there is a reasonable possibility 

that a material misstatement of the entity’s financial statements will not be prevented or 

detected and corrected on a timely basis. A deficiency in internal control exists when the 

design or operation of a control does not allow management or employees, in the normal 

course of performing their assigned functions, to prevent, or detect and correct 

misstatements on a timely basis.

In addition to reviewing access rights, SSA officials told us 

the agency purchased software in 2011 that monitors the agency’s 

information systems to detect potential data breach incidents. Agency 

51SSA employees are granted access to different aspects of SSA’s system depending on 

the nature of the work they do. 

52There are 702 profiles which are considered to be the highest-risk. The highest-risk 

profiles are those for users of applications that support the agency’s financial 

management systems. 
 

Page 23 GAO-13-459 SSA Management Challenges

officials told us they are currently in the process of implementing and finetuning the software.

However, the OIG raised concerns about how the agency has previously 

prioritized information security within its larger IT budget. Specifically, it 

stated that one of the underlying causes for these weaknesses is that 

SSA needed to strategically allocate sufficient resources to resolve or 

prevent high-risk security weaknesses in a more timely fashion.53 For 

example, SSA officials told us that, in some cases, security employees’ 

time is primarily spent performing duties that do not address the IT 

security weaknesses identified by external financial auditors and OIG.54

Though SSA officials emphasized that the information security risks 

identified were internal,55 inappropriate internal access to or misuse of 

sensitive information can have a significant impact. For example, 

according to the OIG, in 2012, a former SSA employee was found to have 

used her position to provide personally identifiable information to a person 

outside the agency, who is accused of using the information for criminal 

purposes.

Centralizing facilities management. SSA is beginning to centralize its 

facilities management, but officials indicated it may lead to a trade-off 

between efficiency and flexibility. The agency administers its programs 

and services through a network of over 1,700 facilities, consisting of 

government-owned and leased buildings, which costs approximately $700 

million annually, according to SSA.

56

 

53SSA OIG, A-14-12-12120.

As shown in Figure 8, these facilities 

fall into three categories: headquarters facilities located predominantly in 

the Baltimore/Washington, D.C. metropolitan area, an extensive network 

of field-based facilities used to process initial claims and post-entitlement 

54Such tasks include establishing a formalized process to test transactions associated 

with access profiles. 

55The OIG and external auditors did not perform external penetration tests during their 

audits.

56SSA leases all of its space, approximately 30 million square feet as of the end of fiscal 

year 2012, from the General Services Administration (GSA). Approximately one-third of 

that space is in government-owned buildings and the remaining two-thirds in governmentleased buildings. 

SSA Is Taking Steps to 

Centralize Facilities 

Management but Lacks a 

Proactive Approach to 

Evaluate Its Office Space
 

Page 24 GAO-13-459 SSA Management Challenges

actions,57

Figure 8: Number of SSA Facilities by Component and Type (as of Fiscal Year 2012)

and a network of facilities that carry out the agency’s disability 

adjudication and review process. The agency has had a more 

decentralized facilities management process, but officials told us they are 

currently moving all facilities management under SSA’s Office of Facilities 

and Supply Management (OFSM). Some officials have told us that this 

centralization can lead to greater efficiencies and standardization, but 

cautioned that there may be a trade-off in terms of flexibility and 

awareness of local circumstances at the regional level. For example, 

some regional commissioners told us that facilities decisions made at the 

headquarters level may not take into account the layout of specific 

buildings or how construction seasons vary in different locations.

 

57Post-entitlement actions include such things as address changes and updating 

beneficiary earnings. 
 

Page 25 GAO-13-459 SSA Management Challenges

a

SSA’s data center, the National Computer Center, and its backup, the Second Support Center, store 

data and house the backbone of the agency’s automated systems. SSA is currently constructing a 

new data center to replace the National Computer Center, which was built in 1979.

b

Teleservice centers handle general inquiries from the public, simple post-entitlement actions, and 

referrals from field offices.

c

Program service centers handle complex claims and post-entitlement actions.

d

Among other responsibilities, the data operations center handles various customer service 

workloads, including providing technical and benefit information on SSA programs by phone. 

e

National hearing centers handle workloads from backlogged hearing offices.

f

Satellite offices provide support to their parent hearing offices.

g

At permanent remote sites, hearings are held in person with a traveling administrative law judge or 

by video. Of the 160 permanent remote sites, SSA told us that 148 are located within SSA field 

offices.

Limited facilities planning efforts. A contractor hired by the General 

Services Administration is currently working on a long-term plan for SSA’s 

headquarters facilities, the Master Housing Plan.58 An SSA official told us 

that the contractor has solicited input and feedback from the agency on 

the draft plan. According to the National Research Council, a free 

exchange of information among the various stakeholders can make 

decision-making for facilities investments more accurate and effective.59

Efforts to reduce office space. SSA officials told us the agency is 

engaged in ongoing efforts to reduce the footprint of its headquarters 

facilities. According to a senior SSA official, vacant space in headquarters 

facilities has increased during the past few years as a result of the 

shrinking workforce.

However, an SSA official told us the agency lacks a comprehensive 

planning effort that encompasses all of the agency’s facilities.

60 Using the agency’s Large Site Space Standards,61

 

58Earlier drafts of the Master Housing Plan were developed by GSA and OFSM. For the 

current stage, GSA engaged a contractor to carry out the study, according to SSA 

officials. 

59The National Research Council is part of the National Academy of Sciences. See 

National Research Council. Investments in Federal Facilities: Asset Management 

Strategies for the 21st Century. (Washington, D.C.: 2004).

60This official estimated that, as of February 28, 2013, there were approximately 800-

1,000 vacant workspaces in SSA headquarters facilities. 

61SSA’s Large Site Space Standards lay out the criteria for allocating space according to 

staffing levels and other factors.
 

Page 26 GAO-13-459 SSA Management Challenges

SSA officials told us that OFSM is analyzing the space needs of all offices 

in the headquarters area and will reassign space according to these 

criteria. A senior official told us that SSA’s efforts were motivated by 

several factors, including an OMB directive to make more efficient use of 

federal office space;62

In addition to these headquarters-focused efforts, SSA is reducing office 

space in the field as opportunities arise, but it lacks a proactive plan to 

assess field facilities for potential space reductions. When OFSM reviews 

a field-based space action (e.g., lease renewal, move, renovation), an 

SSA official told us that the proposed action is assessed to identify if 

there are opportunities to reduce or otherwise change the facility’s space 

allocation. For example, after such an assessment, the Denver regional 

office space was reduced by one-third. However, OFSM’s standards do 

not call for wholesale reductions or reconfigurations of existing space. 

SSA has established a workgroup that is developing guidance to help 

identify opportunities to reduce space by co-locating certain field-based 

facilities, such as field offices and video-based disability hearing offices.

Officials told us that in January 2013, they endorsed the workgroup’s final 

recommendations and proposals as the formal agency policy.

the agency’s ultimate goal of terminating 

commercial leasing for most office space in the headquarters area; and, 

to a lesser degree, reducing current vacancies in headquarters.

Considerations for realigning the facilities structure. SSA has been 

advised to consider aligning its facilities structure with its changing 

methods of providing services. For example, SSA’s OIG reported in 2011 

that SSA’s long-term planning efforts should assess whether the number, 

size, geographic coverage, and staffing of the agency’s existing office 

structure are in line with future methods of providing customer service.63

 

62In May 2012, OMB’s Acting Director released a memo, which calls for agencies to make 

more efficient use of the government’s real estate assets and generally prohibits agencies 

from increasing their real estate inventory, or footprint. See OMB, “Memorandum to the 

Heads of Executive Agencies and Departments: Promoting Efficient Spending to Support 

Agency Operations,” (May 11, 2012). 

In 2011, the Social Security Advisory Board suggested that as SSA 

continues to increase electronic service delivery, the agency should adapt 

its organizational structure to maximize the effectiveness of the agency’s 

transformation. At the same time, SSA has long considered face-to-face 

63SSA OIG, The Social Security Administration’s Customer Service Delivery Plan, A-07-

11-01125. (Baltimore, MD: July 2011).
 

Page 27 GAO-13-459 SSA Management Challenges

interaction to be the gold standard of customer service, and an official has 

told us that any changes away from that model would represent a major 

cultural shift for the agency.

In prior work, we have reported that federal agencies may be able to 

increase efficiency and effectiveness by consolidating physical 

infrastructure or management functions, and several agencies have 

already undertaken consolidation efforts.64

SSA has begun to take advantage of opportunities to consolidate or colocate offices in the regions. SSA regional commissioners told us that 

field offices have been consolidated in most of its 10 regions.

For example, in 2000, the 

Internal Revenue Service began consolidating its individual paper 

processing centers to reduce overhead and real estate costs and improve 

efficiency in response to increases in electronic filing; the agency 

estimates that the initiative saved $175 million through 2011. Over the 

past 6 years, the U.S. Postal Service has taken several actions to reduce 

the footprint of its retail space, including two nationwide initiatives to 

review its facilities for possible closure. The Census Bureau announced 

plans in 2011 to close 6 of its 12 regional offices by 2013 to reduce the 

cost and improve the quality of surveys the Census Bureau conducts 

annually; the Census Bureau estimates the initiative will save $15-18 

million annually beginning in fiscal year 2014. SSA officials told us they 

have spoken with GSA officials about consolidation, but have not

consulted with any of these agencies to learn about their experiences in 

considering and implementing significant changes to their facilities 

structures.

65

 

64GAO, Streamlining Government: Questions to Consider When Evaluating Proposals to 

Consolidate Physical Infrastructure and Management Functions, 

Regional 

commissioners told us that consolidations reduce such expenses as rent 

and guard services, and a single office consolidation can save as much 

as $2-3 million dollars over a 10-year period. Furthermore, regional 

commissioners told us that several regions have co-located with the 

Office of Disability Adjudication and Review to provide space to hold 

GAO-12-542. 

(Washington, D.C.: May 23, 2012).

65SSA officials told us that offices are consolidated by closing an office and moving its 

staff into another office. Consolidations often occur by merging two offices that are located 

very close together, or when staffing in one office has fallen below levels needed to 

sustain the office. In cases where offices are closed because of prohibitively low staffing 

levels, the remaining staff are generally absorbed into nearby offices.
 

Page 28 GAO-13-459 SSA Management Challenges

hearings within field offices. A regional commissioner told us that when 

these co-located offices share space, such as waiting areas, SSA saves 

money on guard services and rent.

Despite these actions, an SSA official told us that the agency has not 

engaged in a systematic analysis of potential approaches for 

consolidating its facilities or realigning its facilities with the agency’s 

evolving service delivery model. The National Research Council 

recommends that federal agencies use their organizational mission to 

guide facilities investment decisions and then integrate these investments 

into their strategic planning processes. We previously reported that 

agencies should consider the potential costs and benefits of consolidation 

over the long term.66 For example, consolidation is not beneficial in all 

instances, such as in rural areas where people would have to travel a 

considerable distance to reach the nearest office. Therefore, it is 

important to evaluate the goals of the consolidation against the realistic 

possibility of the extent to which those goals would be achieved. 

Furthermore, our previous work suggests that consolidation initiatives can 

be immensely complex, politically charged, and costly; even decisions to 

consolidate individual offices can create challenges. For example, a 

regional commissioner told us that a recent proposal to save money by 

consolidating two nearby offices in a major urban area was met with 

substantial resistance from the community and elected officials. Our prior 

work states that decision makers need to balance the benefits of 

consolidation against the physical, up-front financial, bureaucratic, and 

political costs, while considering alternatives. To assess the potential 

impact and challenges of consolidation, we suggested that agencies 

consider likely costs and benefits of the consolidation, how to fund upfront costs associated with consolidation, and the effect on various 

stakeholders. (See app. II for a list of key questions that can be used to 

assess potential consolidation initiatives.)

 

66GAO-12-542. 
 

Page 29 GAO-13-459 SSA Management Challenges

SSA has ongoing planning efforts, but we have identified two major areas 

in which these efforts have fallen short in addressing the long-term nature 

of the agency’s management challenges: (1) its planning efforts are shortterm and do not adequately address emerging issues, and (2) it lacks 

continuity in its strategic planning leadership. As the prior section 

discussed, over the next decade, the agency’s workloads will increase 

while its workforce will likely decrease, raising questions about how SSA 

can best deploy its human capital and information technology resources 

and best align its disability policy and physical infrastructure to meet 

these demands. Practices such as involving stakeholders and planning 

for different scenarios are considered key for successful long-term 

planning efforts, which SSA’s current planning efforts do not include.

Need for longer-term efforts to address emerging issues. SSA’s 

planning efforts, from an overall strategic plan to its service delivery plan, 

typically look no more than 5 years out. For example, SSA is finalizing a 

service delivery plan, but the draft document primarily contains detailed 

plans for the next 5 years and focuses on existing initiatives rather than 

articulating specific long-term strategies for the agency’s service delivery 

model. The plan was developed as a companion to the agency’s strategic 

plan,67 which defines the agency’s goals for the next 4 years.68

 

67SSA addresses core IT updates separately in a 5-year IT strategic plan.

While the 

draft service delivery plan acknowledges the need to assess the agency’s 

workforce structure, it stops short of providing a vision for how the 

workforce structure should best make use of expanded virtual and 

automated service delivery channels. The draft raises the possibility of 

developing a more generalized workforce by training employees to handle 

a variety of different workloads or centralizing the most complex 

workloads by assigning them to technical staff specifically trained to 

handle them, but it does not advocate for either of these approaches or 

provide a detailed analysis of their relative merits. Similarly, the plan 

states that the following issues will need to be considered over the next 6 

to 10 years, but it does not provide a specific strategy for how to resolve 

the need to:

68OMB guidance directs agencies to have strategic plans covering a period of no less than 

4 years. Agencies may set strategic plan goals for longer periods of time. 

SSA’s Planning Efforts 

Are Not Adequate to 

Address the LongTerm Nature of Its 

Management 

Challenges 
 

Page 30 GAO-13-459 SSA Management Challenges

• strategically develop and place self-service options, such as electronic 

kiosks;

• determine whether the Internet should be the primary service delivery 

mechanism for certain services; and

• standardize fees SSA already charges and determine whether it is 

appropriate for the agency to charge fees for additional services.69

Further, the plan does not articulate SSA’s long-term costs and benefits 

for its investments, such as the specific impact that moving to online 

services is expected to have on backlogs and workforce needs. For many 

years, we have recommended that SSA develop a comprehensive 

service delivery plan that outlines how it will deliver quality service while 

managing growing work demands within a constrained budget.70

Similarly, SSA’s current strategic plan largely describes the continuation, 

expansion, or enhancement of existing activities, rather than proposing 

new initiatives or broad changes to address emerging issues. One of the 

goals of the agency’s strategic plan is to increase the public’s use of 

online services, but several SSA officials and representatives of one SSA 

management group told us that this shift will not be sufficient to address 

growing service demands. For example, as discussed earlier, to meet 

service challenges, some officials said the agency will also need to 

simplify its disability policy. They also told us the agency will need to 

develop a strategy for meeting the needs of vulnerable populations who 

may not have access to computers at home or who may not be computer 

literate. At the same time, however, some SSA officials noted that the 

agency may need to limit the number of days per week that field offices 

are open to the public to contain costs.

 

69Examples of services for which SSA may charge a standard fee include copying folders, 

forwarding letters, manually performing a Social Security number verification for a third 

party, and responding to requests for a W-2 or W-3 for Social Security benefits received.

70See GAO, Social Security Administration: Service Delivery Plan Needed to Address 

Baby Boom Retirement Challenges, GAO-09-24 (Washington, D.C.: Jan. 9, 2009); Social 

Security: Sustained Effort Needed to Improve Management and Prepare for the Future, 

GAO/HRD-94-22 (Washington, D.C.: Oct. 27, 1993); SSA’s Management Challenges: 

Strong Leadership Needed to Turn Plans Into Timely Meaningful Action, 

GAO/T-HEHS-98-113 (Washington, D.C.: Mar. 12, 1998); and Social Security 

Administration: Effective Leadership Needed to Meet Daunting Challenges, 

GAO/HEHS-96-196 (Washington, D.C.: Sept.12, 1996).
 

Page 31 GAO-13-459 SSA Management Challenges

Various groups have called on SSA to acknowledge emerging long-term 

issues by articulating them in a longer-term strategy. In 2011, the Social 

Security Advisory Board called for SSA to develop a strategy for service 

delivery through 2020 that will serve as the cornerstone for its IT, human 

capital, policy review, and organizational restructuring plans.71 The SSA 

OIG also called on SSA to prepare a longer-term vision to ensure that it 

has the programs, processes, staff, and infrastructure necessary to 

provide service in the future.72 Regional commissioners and field 

managers said that a long-term service delivery plan could help to clarify 

issues such as what services will be available online in the future, how 

these services will be implemented, how IT modernization will support 

service delivery, which offices will have responsibility for different 

workloads, how the agency will use telework, and how the agency will 

approach workload sharing. In addition, GAO’s internal controls guidance 

states that federal agencies should comprehensively identify risks, 

analyze and decide how to manage these risks, and establish 

mechanisms to deal with continual changes in governmental, economic, 

industry, regulatory, and operating conditions.73

Senior agency officials told us that as an agency, SSA generally views 

long-term planning as a secondary responsibility and is more focused on 

addressing short-term, tactical issues. As one official said, agency 

officials are addressing immediate concerns and not thinking, for 

example, about what the agency’s field operations should look like in 10 

years. Several officials also noted that uncertainty about budget 

resources has made it difficult for SSA to engage in multi-year planning. 

SSA prepared its last 

long-term agency vision—which covered a 10-year period—in 2000, 

motivated by many conditions which remain true today, such as 

increasing workloads, advances in technology, and employee 

retirements. A former SSA official knowledgeable about the development 

of the 2010 Vision told us that unlike the agency’s strategic plan, which 

addressed incremental changes, the long-term vision addressed broader 

issues and allowed the agency to consider more transformative changes.

 

71Social Security Advisory Board. A Vision of the Future for the Social Security 

Administration, (Washington, D.C.: March 2011). 

72SSA OIG. Fiscal Year 2012 Inspector General Statement on the Social Security 

Administration’s Major Management and Performance Challenges, A-02-13-13041 (Nov. 

8, 2012).

73GAO/AIMD-00-21.3.1.
 

Page 32 GAO-13-459 SSA Management Challenges

One official commented that as a result of its budget situation, the agency 

has been reactive and failed to consider big picture issues.

Need for continuity in strategic planning leadership. Senior officials 

said that SSA should dedicate a position, such as a chief strategic officer, 

that will report directly to the Commissioner and be solely responsible for 

strategic planning in order to bring sustained, focused attention to longterm management challenges. The GPRA Modernization Act of 2010 

charges top agency leadership with improving agency management and 

performance.74

Key long-term planning practices that could be employed. Strategic 

planning literature and experts cite the following as key long-term 

planning practices that could be employed by SSA to successfully 

address these issues:

Agency leaders are responsible for setting near-term and 

long-term goals; conducting data-driven progress reviews; and assuring 

that decision-makers at all levels of the organization have timely, 

actionable performance information. SSA previously had an Office of the 

Chief Strategic Officer, which was responsible for overseeing strategic 

planning. This office worked with all SSA components to prioritize 

initiatives that would help the agency meet its goals and determined how 

to link these initiatives to the agency’s budget. However, the office was 

dissolved in May 2008 and since that time, the agency has not had an 

office dedicated to strategic planning. Deputy commissioners with 

temporary responsibility for strategic planning have led the efforts to 

develop SSA’s last two strategic plans. One senior official told us that 

efforts to develop component-level plans, such as the strategic human 

capital plan and IT strategic plan, have not been well coordinated with the 

development of the agency-wide strategic plan. Another senior official 

said that a chief strategic officer could think about the agency in totality, 

building connections across organizational silos, in part because this 

individual would not have a stake in a particular component. For example, 

such a leader could consider interconnections between the agency’s IT 

capabilities and its human capital structure when planning for the future.

• Begin early in a new leader’s tenure. Several SSA officials we 

spoke with told us that developing a long-term service delivery plan 

should be the next commissioner’s top priority. One former senior 

 

74Pub. L. No. 111-352, § 8, 124 Stat. 3866, 3878 (2011).
 

Page 33 GAO-13-459 SSA Management Challenges

SSA official familiar with the development of 2010 Vision told us that 

the document was developed during a former commissioner’s final 

year in office. Consequently, it was not embraced by the next 

leadership team, who wanted to create their own vision. This official 

recommended that the next commissioner develop a long-term vision 

early in his or her term.

• Involve stakeholders from across the agency to obtain buy-in.

The long-term plan should be developed with input from key 

stakeholders and constituents, such as employee unions, who will be 

affected by the plan, and the organization should ensure that 

communication is open and two-way throughout the process. 

Otherwise, these groups could resist the plan’s implementation.

• Develop performance goals and measures. The long-term vision 

should be linked to short-term goals and a system for accountability. 

Performance measures also allow officials to consider the relative 

merits of alternative strategies if the stated objective is not met.

• Leadership should support the plan. The long-term plan needs 

backing from top agency management. Leadership support is 

demonstrated by allocating appropriate resources. For example, the 

office leading the planning effort should have sufficient standing within 

the organization, as well as staff dedicated to the effort on a day-today basis.

• Prepare for different scenarios. Several officials raised concerns 

that variability in the agency’s budget and IT developments make it 

difficult to plan for the future. However, strategic planning literature 

touts the success of organizations that are flexible and adaptive. 

These organizations consider plausible future alternatives and use 

them to generate strategic options.

• Align interim plans to the long-term strategy. Concepts in the longterm plan should drive the agency’s other plans (e.g., human capital, 

information technology, facilities).

The challenges SSA faces will substantially affect its ability to address 

critical concerns in the coming years. SSA’s efforts to meet many of its 

management challenges have been complicated by budgetary constraints 

and continued uncertainty about the current and future fiscal environment. 

Despite these constraints, the agency will need to balance competing 

demands for resources—both in terms of managing day-to-day budget 

Conclusions 
 

Page 34 GAO-13-459 SSA Management Challenges

decisions and planning for emerging and long-term budget issues. SSA 

already manages a substantial and diverse workload and the demands on 

SSA from new retirees and individuals with disabilities will continue to 

grow. Without prompt action to address these challenges, the agency 

jeopardizes its ability to provide quality service to the public while meeting 

other critical responsibilities such as ensuring program integrity and 

administering any changes made to protect the solvency of the Social 

Security trust funds. In particular, if the agency does not develop specific 

strategies to address attrition, including ongoing retirements, it risks 

losing institutional knowledge and expertise at a time when workloads 

and service demands are increasing. Moreover, while SSA has increased 

the proportion of its services that it delivers electronically, it has not 

conducted an analysis to determine whether realigning its existing and 

future headquarters, region, and field office structure could more 

effectively and efficiently support the agency’s mission.

SSA’s new commissioner will face wide-ranging challenges that will 

require a comprehensive, long-range strategy that current planning efforts 

do not adequately address. The interrelated nature of SSA’s challenges 

reinforces the need for a long-term and integrated strategy to help ensure 

that future actions are coordinated and efficient. Also, without a dedicated 

entity to provide sustained leadership, SSA’s planning efforts will likely 

remain decentralized and short-term. In the absence of a long-term 

strategy for service delivery, the agency will be poorly positioned to make 

needed well-informed decisions about its critical functions, including how 

many and what type of employees SSA will need for its future workforce, 

how the agency will address disability claims backlogs while ensuring 

program integrity, and how the agency will more strategically use its 

information technology and physical infrastructure to best deliver 

services. Given its budget constraints, SSA needs a solid, long-term 

strategy to guide decisions about how to best leverage its limited 

resources.

We recommend that the incoming Commissioner of Social Security:

1. Elevate the agency’s strategic planning efforts by considering having 

an entity or individual dedicated to ensuring that these activities are 

coordinated agency-wide.

2. Prepare for wide-ranging management challenges by developing a 

long-term strategy for service delivery.

Recommendations for 

Executive Action
 

Page 35 GAO-13-459 SSA Management Challenges

3. Mitigate the potential loss of institutional knowledge and expertise and 

help ensure leadership continuity by directing the Deputy 

Commissioner of Human Resources to update the agency’s 

succession plan.

4. Determine if realigning the agency’s headquarters, regional, or field 

office structure could yield increases in the agency’s effectiveness 

and efficiency by launching an exploratory effort to assess the utility 

and feasibility of such a realignment or consolidation. These efforts 

could include holding discussions with other federal agencies, such as 

the Census Bureau and the Internal Revenue Service, to learn about 

their experiences undergoing similar transformations and studying the 

likely costs and benefits of consolidation, as well as other potential 

impacts.

We provided a draft of this report to SSA for review and comment. In its 

written comments, reproduced in appendix III, SSA agreed with our 4 

recommendations. In responding to a copy of our draft report, SSA noted 

that the agency recently appointed a Chief Strategic Officer who reports 

directly to the Commissioner and will be responsible for coordinating 

agency-wide strategic planning efforts. SSA told us that this official will 

also lead an agency-wide effort to develop a long-range strategic plan 

that will integrate information technology, service delivery, and human 

capital plans. They told us they will seek input from various stakeholders, 

including employees, advocates, and Congress, and expect to complete 

the long-range plan by February 2015 and to release it with the 

President’s Budget for fiscal year 2016. In addition, SSA told us that they 

re-implemented their national Leadership Development Program in spring 

2013 and plan to update their succession plan in calendar year 2013. 

Finally, the agency has agreed to begin exploring its field, regional, and 

headquarters organizational structures to find ways to increase efficiency 

and effectiveness and to initiate discussions with other federal agencies 

to learn about their experiences with similar efforts. SSA also provided 

technical comments that we have incorporated, as appropriate.

We are sending copies of this report to the Commissioner of Social 

Security, appropriate congressional committees, and other interested 

parties. In addition, the report is available at no charge on the GAO 

website at http://www.gao.gov. 

Agency Comments 
 

Page 36 GAO-13-459 SSA Management Challenges

If you or your staff have any questions about this report, please contact 

me at (202) 512-7215 or bertonid@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made major contributions to 

this report are listed in appendix IV.

Sincerely yours,

Daniel Bertoni

Director

Education, Workforce,

 and Income Security Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-13-459 SSA Management Challenges

The objectives of this review focused on (1) key management challenges 

SSA faces in meeting its mission-related objectives and (2) the extent to 

which SSA’s planning efforts address these challenges.

To identify SSA’s key management challenges, we conducted in-depth 

interviews with the SSA Office of the Inspector General (OIG) and the 

Social Security Advisory Board. We also reviewed SSA OIG’s “Statement 

on SSA’s Major Management and Performance Challenges” reports from 

fiscal years 2001-2012. In addition, we reviewed relevant reports from 

GAO, SSA OIG, and the Social Security Advisory Board. We also 

reviewed the SSA’s agency-wide strategic plan.

To learn about SSA’s key management challenges and the extent to 

which SSA’s planning efforts address these challenges, we conducted indepth interviews with SSA officials from headquarters and in the field. At 

SSA headquarters, we interviewed officials from the Office of the Chief 

Actuary; the Office of Budget, Finance, and Management; the Office of 

Disability Adjudication and Review; the Office of Human Resources; the 

Office of Operations; the Office of Quality Performance; the Office of 

Retirement and Disability Policy; the Office of Systems; and the Office of 

the Commissioner. We also conducted semi-structured interviews with 

SSA’s regional commissioners and officials from groups that represent 

state and federal SSA employees, including the National Council of Social 

Security Administration Field Operations Locals (American Federation of 

Government Employees), the National Council of Social Security 

Management Associations, the National Council of Disability 

Determination Directors, and the National Association of Disability 

Examiners. During these semi-structured interviews, we asked each 

interviewee the same series of questions addressing each of the agency’s 

major long-term management challenges (human capital, disability 

programs, information technology, and physical infrastructure) and 

service delivery. We also reviewed applicable federal laws and 

regulations.

To learn about the extent to which SSA’s planning efforts address 

management challenges, we reviewed key agency planning and other 

documents, such as SSA’s current strategic plan, strategic human capital 

plan, most recent Retirement Wave report, strategic leadership 

succession plan, IT strategic plan, IT capital investment process guide, 

facilities standards, and the agency-wide draft service delivery plan. We 

also reviewed GAO’s internal control standards; Executive Order 13,327, 

entitled “Federal Real Property Asset Management;” the GPRA 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 38 GAO-13-459 SSA Management Challenges

Modernization Act of 2010; and relevant GAO, SSA OIG, and Social 

Security Advisory Board reports.

To better understand the key management challenges facing the agency, 

we obtained SSA data from a number of administrative and management 

information systems. We obtained background data about the actual and 

projected number of benefit outlays, beneficiaries, and claimants from the 

Office of the Chief Actuary. We also obtained data about actual and 

projected retirements and retirement eligibility of headquarters and field 

managers, supervisors, and staff from SSA’s Human Resources 

Operational Data Store. To learn about the agency’s disability claims 

backlog and hearings wait time, we obtained agency data from the 

agency’s fiscal year 2012 Performance and Accountability Report and 

Case Processing and Management System. We also obtained data about 

the SSA’s administrative expenditures for its major benefit programs from 

the Office of Budget. In addition, we obtained data on SSA’s facilities by 

type from the Office of Facilities and Supply Management. To learn about 

SSA employee morale, we also obtained data from the Office of 

Personnel Management’s Federal Employee Viewpoint Survey. We 

assessed the reliability of these data by reviewing related documentation 

and interviewing knowledgeable agency officials, and we determined 

these data were sufficiently reliable for our needs.

To identify key long-term planning practices, we conducted a literature 

search. We sought documents that describe the benefits of long-term 

planning, the elements of a long-term vision, and the process for 

developing such a plan. To identify relevant literature, we searched 

bibliographic databases covering scholarly and peer-reviewed material; 

trade and industry articles; and publications from associations and 

nonprofit and think tank organizations, such as ProQuest, WorldCat, 

ECO/ArticleFirst/PapersFirst, and Dialog. We restricted our search to 

U.S.-based materials published between 2002 and 2012. The search 

identified over 900 articles, of which 28 were deemed to be relevant to 

our work. We also consulted with long-term planning experts.

We conducted this performance audit from September 2012 to May 2013

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Key Questions to Consider When 

Evaluating Consolidation Proposals

Page 39 GAO-13-459 SSA Management Challenges

In 2012, we reported a list of key questions for federal agencies to 

consider when evaluating proposals to consolidate physical infrastructure 

and management functions.1

What are the goals of the consolidation? What opportunities will be 

addressed through the consolidation and what problems will be 

solved? What problems, if any, will be created?

The key questions and additional subquestions listed below address the ideas, strategies, and leading 

practices that may facilitate consolidations. However, the list is not 

exhaustive, nor is it necessary for an agency to consider every listed 

question.

• Have agency leaders identified specific goals to be achieved through 

consolidation?

• Have agency leaders assessed how consolidation can help an agency 

incorporate changes in technology, business processes, or the needs 

of customers or clients?

• How have agency leaders weighed the importance of achieving the 

goals against a realistic assessment of the effort that will be required 

to achieve them?

• How have agency leaders considered the risks to consolidation that 

could prevent the achievement of goals and planned for ways to 

manage them?

• Are agency leaders defining the benefits associated with consolidation 

and describing how the future will be both different from and better 

than the past?

• Are agency leaders providing a clear and compelling picture of what 

will constitute success?

 

1

See GAO, Streamlining Government: Questions to Consider When Evaluating Proposals 

to Consolidate Physical Infrastructure and Management Functions, GAO-12-542. 

(Washington, D.C.: May 23, 2012). These questions were identified based on GAO’s 

extensive body of work on government reform, a literature review on public sector 

consolidations, and interviews with practitioners and academic experts in public 

management and government reform.

Appendix II: Key Questions to Consider 

When Evaluating Consolidation Proposals
Appendix II: Key Questions to Consider When 

Evaluating Consolidation Proposals

Page 40 GAO-13-459 SSA Management Challenges

What will be the likely costs and benefits of the consolidation? Are 

sufficiently reliable data available to support a business-case 

analysis or cost-benefit analysis?

• What data on the likely costs and benefits of a consolidation are 

available?

• Are the data sufficiently accurate and reliable? What data on the likely 

costs and benefits of a consolidation are unavailable, and has a plan 

been developed to mitigate the unavailability or unreliability of certain 

data?

• On the basis of the data available, can a reasonable expectation of a 

consolidation’s costs and benefits be drawn?

• Have the likely costs and benefits been subjected to a sensitivity 

analysis? How sensitive are the estimated costs and benefits to 

variation in less reliable data or other key assumptions?

How can the up-front costs associated with the consolidation be 

funded?

• Can immediate efficiencies or uncommitted funds in other areas be 

redirected to pay for the up-front costs of a consolidation?

• Has the agency considered how it will assess return on investment for 

any funding for up-front costs?

• Can a working capital fund or other funds be drawn on as a funding 

mechanism?

• Is Congress amenable to establishing a funding mechanism for a 

consolidation and appropriating funds for it?

Who are the consolidation stakeholders, and how will they be 

affected? How have the stakeholders been involved in the decision, 

and how have their views been considered? On balance, do 

stakeholders understand the rationale for consolidation?

• Have agency leaders identified affected stakeholders?

• Have agency leaders determined the necessary frequency and timing 

of communication about the consolidation to internal and external 

stakeholders?
Appendix II: Key Questions to Consider When 

Evaluating Consolidation Proposals

Page 41 GAO-13-459 SSA Management Challenges

• Does the communication strategy allow for a two-way exchange of 

information between management and stakeholders?

• How is the agency planning to involve employees to obtain their ideas 

and get their support? Have union representatives been consulted? 

Are there employee task teams responsible for developing and 

proposing common solutions to particular issues related to the 

consolidation?

• How does the agency plan to provide information to employees about 

how their jobs might be affected, what their rights and protections 

might be, or how their responsibilities might change with the new 

organization?

• Is the agency planning to communicate information through different 

channels such as e-mail, face-to-face meetings, large and small group 

meetings, intranet websites, and town hall meetings?

To what extent do plans show that change management practices2

will be used to implement the consolidation?

Will top leadership be engaged in driving the consolidation plan?

• Do agency leaders have plans to move deliberately to demonstrate 

their conviction and commitment to making the needed changes?

• Do agency leaders have plans to provide clear guidance to 

employees about how to conduct business during a potentially 

turbulent period?

Will a dedicated implementation team lead the consolidation?

• Will the implementation team have strong program management skills 

and a proven record of successfully working through or overseeing 

major transformations?

 

2

Change management practices can be used to minimize the duration and significance of 

any reduced productivity and effectiveness that might occur during organizational 

transformations. These practices include active engaged leadership of executives at the 

highest possible levels; a dedicated implementation team that can be held accountable for 

change; and a strategy for capturing best practices, measuring progress toward the 

established goals of the consolidation, retaining key talent, and assessing and mitigating 

risk. 
Appendix II: Key Questions to Consider When 

Evaluating Consolidation Proposals

Page 42 GAO-13-459 SSA Management Challenges

• Are there networks such as senior executive councils, functional 

teams, or cross-cutting teams that can ensure that changes are 

thoroughly implemented and sustained over time?

Will the implementation plan include metrics to measure progress toward 

the consolidation’s goals?

• Will there be an action plan with goals and milestones to track 

progress and identify any needed mid-course adjustments?

• Will an action plan identify critical phases and the essential activities 

that need to be completed by and on any given date? Are there plans 

to publicize and report progress on specific goals for each phase of 

the initiative?

• Is there a strategy for tracking employee attitudes toward the 

consolidation and identifying any morale or productivity issues?

• Will the implementation plan include a strategy for attracting and 

retaining key talent?

Will the implementation plan include a strategy for assessing and 

mitigating risk?

• Will the implementation plan be informed by a risk assessment that 

includes the following five steps?

• Set strategic goals and objectives, and determine constraints

• Assess risks

• Evaluate alternatives for addressing these risks

• Select the appropriate alternatives

• Implement the alternatives and monitor progress made and results 

achieved

Is there a strategy for using the consolidation experiences of other 

organizations and lessons learned?

• Have agency officials involved with the consolidation initiative 

identified and consulted with other agencies or organizations that 

planned for or implemented a similar consolidation effort?
Appendix II: Key Questions to Consider When 

Evaluating Consolidation Proposals

Page 43 GAO-13-459 SSA Management Challenges

• Is there a process for capturing lessons learned after each phase of 

the consolidation and using the information to improve the 

management of subsequent phases?
Appendix III: Comments from the Social Security 

Administration

Page 44 GAO-13-459 SSA Management Challenges

Appendix III: Comments from the Social 

Security Administration
Appendix III: Comments from the Social Security 

Administration

Page 45 GAO-13-459 SSA Management Challenges

This space intentionally 

left blank. Pages 2-3 

included technical 

comments that have been 

incorporated throughout 

the report, as appropriate. 
Appendix III: Comments from the Social Security 

Administration

Page 46 GAO-13-459 SSA Management Challenges
Appendix III: Comments from the Social Security 

Administration

Page 47 GAO-13-459 SSA Management Challenges
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 48 GAO-13-459 SSA Management Challenges

Daniel Bertoni, Director, (202) 512-7215 or bertonid@gao.gov

In addition to the individual named above, key contributions to this report 

were made by Jeremy Cox, Assistant Director; Isabella Johnson; Kristen 

Jones; and Jill Yost. Michael Alexander, James Bennett, Larry Crosland, 

Elizabeth Curda, Alex Galuten, Anjalique Lawrence, Steven Lozano, 

Elizabeth Martinez, Sheila McCoy, Adam Miles, Christie Motley, Philip 

Reiff, Kathleen Van Gelder, and Walter Vance also contributed to this 

report.

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgements 
Related GAO Products

Page 49 GAO-13-459 SSA Management Challenges

Social Security Administration: Service Delivery Plan Needed to Address 

Baby Boom Retirement Challenges. GAO-09-24. Washington, D.C.: 

January 9, 2009.

Human Capital: Selected Agencies Have Opportunities to Enhance 

Existing Succession Planning and Management Efforts. GAO-05-585. 

Washington, D.C.: June 30, 2005.

Human Capital: Key Principles for Effective Strategic Workforce Planning. 

GAO-04-39. Washington, D.C.: December 11, 2003.

High-Risk Series: An Update. GAO-13-283. Washington, D.C.: February 

14, 2013.

Modernizing SSA Disability Programs: Progress Made, but Key Efforts 

Warrant More Management Focus. GAO-12-420. Washington, D.C.: June 

19, 2012.

Supplemental Security Income: Better Management Oversight Needed for 

Children’s Benefits. GAO-12-497. Washington, D.C.: June 26, 2012.

Social Security Disability: Management of Disability Claims Workload Will 

Require Comprehensive Planning. GAO-10-667T. Washington, D.C.: 

April 27, 2010.

Disability Insurance: SSA Can Improve Efforts to Detect, Prevent, and 

Recover Overpayments. GAO-11-724. Washington, D.C.: July 27, 2011.

Social Security Administration: Improved Planning and Performance 

Measures Are Needed to Help Ensure Successful Technology 

Modernization. GAO-12-495. Washington, D.C.: April 26, 2012.

Streamlining Government: Questions to Consider When Evaluating 

Proposals to Consolidate Physical Infrastructure and Management 

Functions. GAO-12-542. Washington, D.C.: May 23, 2012.

SSA’s Management Challenges: Strong Leadership Needed to Turn 

Plans Into Timely, Meaningful Action. GAO/T-HEHS-98-113. Washington, 

D.C.: March 12, 1998.

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Page 50 GAO-13-459 SSA Management Challenges

Social Security Administration: Status of Achieving Key Outcomes and 

Addressing Major Management Challenges. GAO-01-778. Washington, 

D.C.: June 15, 2001.

Major Management Challenges and Program Risks: Social Security 

Administration. GAO-03-117. Washington, D.C.: January 1, 2003.

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