Report to the Subcommittee on Social 

Security, Committee on Ways and Means, 

House of Representatives 

United States Government Accountability Office

GAO 

September 2009 SOCIAL SECURITY 

DISABILITY 

Additional Outreach 

and Collaboration on 

Sharing Medical 

Records Would 

Improve Wounded 

Warriors’ Access to 

Benefits 

GAO-09-762 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

September 2009

SOCIAL SECURITY DISABILITY 

Additional Outreach and Collaboration on Sharing

Medical Records Would Improve Wounded Warriors’ 

Highlights of GAO-09-762, a report to the Access to Benefits

Subcommittee on Social Security, 

Committee on Ways and Means, House of 

Representatives 

As of December 2008, about 7,600 of the16,000 wounded warriors who have 

applied for SSA disability benefits since 2001 have been approved. The 

majority filed their applications since 2007. Also, a sizable minority of 

approved claimants filed long enough after injury that they lost some 

retroactive benefits; SSA is considering a legislative proposal to change the 

retroactive period for wounded warriors. Among wounded warriors receiving 

DOD or VA disability benefits, 4 percent were receiving SSA benefits. In 

addition, more than 6 percent had applied but were not receiving SSA 

benefits; some still had claims pending. Those with higher disability ratings 

from DOD or VA were more likely to receive SSA benefits. 

Number of Wounded Warrior Applicants for SSA Disability Benefits 

Calendar year

Source: GAO analysis of SSA data.

Number of wounded warrior applicants

4 93 217

481

1,330

5,200

8,652

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

9,000

2002 2003 2004 2005 2006 2007 2008

To varying degrees, SSA, DOD, and VA have increased outreach to help 

wounded warriors learn about and apply for SSA disability benefits. Since 

2007, SSA has increased its outreach to DOD and VA medical facilities and has 

tailored benefit information for wounded warriors. DOD—and to some extent 

VA—have incorporated SSA information into their case management practices 

as well. Locally, DOD and SSA staff have worked together to reach 

servicemembers, but collaboration has been less common at VA hospitals. 

Meanwhile, there are challenges to reaching and working with this population. 

Many of the wounded warriors may not be ready or able to hear about SSA 

benefits early in their recovery. Also, brain injuries and mental health 

disorders can impede many wounded warriors’ ability to absorb outreach 

information and complete the benefit application. 

With help from DOD and VA, SSA has been able to expedite processing of 

wounded warrior claims. SSA has established a nationwide policy requiring 

its offices to give priority to wounded warrior claims. For their part, DOD 

helps SSA identify claimants who are wounded warriors, and VA has 

expedited the transfer of its medical records and histories to SSA. However, 

DOD’s paper-based transfer of medical records to SSA is slow, which can 

prolong the process by weeks or months, according to claims processing staff.

Disability benefits available 

through the Social Security 

Administration (SSA) can be an 

important source of financial 

support for some wounded 

warriors, and Congress has 

mandated that the Departments of 

Defense (DOD) and Veterans 

Affairs (VA) help them learn about 

and apply for such benefits. GAO 

was asked to determine: (1) how 

many wounded warriors have 

applied and been approved for SSA 

benefits and the extent to which 

they are receiving benefits from 

across the three agencies; (2) what 

steps DOD, VA, and SSA have taken 

to inform wounded warriors about 

SSA benefits, and the challenges 

that confront this process; and (3) 

steps taken by all three agencies to 

facilitate the processing of 

wounded warrior disability claims. 

Focusing on those wounded since 

2001, GAO reviewed policy 

documents, contacted DOD and VA 

medical facilities, surveyed 

wounded warriors, and analyzed 

administrative data. 

What GAO Recommends

GAO recommends that SSA move 

ahead with its consideration of a 

legislative proposal on retroactive 

benefits, VA work with SSA to 

improve outreach to veterans on 

SSA benefits, and DOD work with 

SSA to meet SSA’s need for timely 

medical records. In their 

comments on our draft report, SSA 

and VA agreed with our findings 

and recommendations and noted 

actions they plan to take to address 

our recommendations. DOD did 

not provide formal comments. 

View GAO-09-762 or key components. 

For more information, contact Daniel Bertoni 

at (202) 512-7215 or bertonid@gao.gov. 
Page i GAO-09-762 

Contents 

Letter 1

Background 3 

Thousands of Wounded Warriors Have Applied and Been Approved 

for SSA Disability Benefits, and Relatively Few Receiving DOD 

or VA Benefits Also Receive SSA Benefits 9 

Agencies Have Taken Steps to Conduct Outreach to Wounded 

Warriors on SSA Benefits but a Number of Challenges Exist 19 

SSA Is Expediting Wounded Warrior Claims With Assistance From 

DOD and VA, but The Transfer Of DOD Medical Records Can 

Prolong Decision-Making 33 

Conclusions 40 

Recommendations for Executive Action 41 

Agency Comments 42 

Appendix I Objectives, Scope, and Methodology 43 

Appendix II Summary of Major Disability Benefit Programs 

Available to Wounded Warriors 53 

Appendix III Complete Results of Wounded Warrior Survey 55 

Appendix IV VA Standard Summary 61 

Appendix V Comments from the Social Security Administration 64 

Appendix VI Comments from the Department of Veterans Affairs 67 

Appendix VII GAO Contact and Staff Acknowledgments 69 

 Social Security Disability 
Related GAO Products 70 

Tables 

Table 1: Summary of Outreach Activities at DOD and VA Medical 

Facilities 28 

Table 2: Local Offices Contacted 46 

Figures 

Figure 1: Number of Wounded Warrior Applicants for SSA’s DI or 

SSI Benefits, by Year in Which Applications Were 

Submitted 11 

Figure 2: Length of Time from Disability Onset to Application 

Filing Date for Wounded Warrior Applicants Approved at 

the Initial Stage 12 

Figure 3: Claim Outcomes for Wounded Warrior Applicants at 

Initial, Reconsideration, and Hearing Stages 14 

Figure 4: Body System Category of Primary Impairment, for 

Wounded Warriors with Allowed Claims at Initial and 

Reconsideration Stages 16 

Figure 5: Wounded Warriors’ Receipt of Disability Benefits by 

Agency, as of July 2008 18 

Figure 6: Percentage of Wounded Warriors Receiving DOD or VA 

Disability Benefits Who Had Applied for and were 

Receiving SSA Disability Benefits by Disability Percentage 

Rating, as of July 2008 19 

Figure 7: Sample Page from SSA Publication 21 

Figure 8: Sample Page from Army Wounded Warrior Patient Intake 

Form that Includes SSA 23 

Figure 9: Excerpts from the Customized Walk-Through 

Presentation 27 

Figure 10: Estimated Length of Time for Wounded Warriors to First 

Learn about SSA Disability Benefits After Onset of 

Medical Condition 30 

Figure 11: How Wounded Warriors’ First Learned of SSA Disability 

Benefits (Estimated) 31 

Figure 12: Difficulties Wounded Warriors Had with Completing the 

SSA Disability Benefits Application 32 

Page ii GAO-09-762 Social Security Disability
Figure 13: Median Days from Application to Initial Decision for 

Wounded Warriors’ DI Claims Versus All DI Claims 38 

Figure 14: Locations Contacted During Study 45 

Figure 15: VA Standard Summary 62 

Page iii GAO-09-762 Social Security Disability
Abbreviations 

AAJ administrative appeals judge 

ALJ administrative law judge 

DDS Disability Determination Services 

DI Disability Insurance 

DMDC Defense Manpower Data Center 

DOD Department of Defense 

IU Individual Unemployability 

MBR Master Beneficiary Record 

MEB medical evaluation board 

MTF military treatment facility 

NHIN Nationwide Health Information Network 

ODAR Office of Disability Adjudication and Review 

OEF Operation Enduring Freedom 

OIF Operation Iraqi Freedom 

PDRL Permanent Disability Retired List 

PEB physical evaluation board 

PTSD post traumatic stress disorder 

SDR Structured Data Repository 

SSA Social Security Administration 

SSI Supplemental Security Income 

SSR Supplemental Security Record 

TBI traumatic brain injury 

TDRL Temporary Disability Retired List 

VA Department of Veterans Affairs 

VASRD Department of Veterans Affairs Schedule for Rating 

 Disabilities 

VBA Veterans Benefits Administration 

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Page iv GAO-09-762 Social Security Disability
Page 1 GAO-09-762 

 

United States Government Accountability Office

Washington, DC 20548 

 

September 16, 2009 

The Honorable John S. Tanner 

Chairman 

The Honorable Sam Johnson 

Ranking Member 

Subcommittee on Social Security 

Committee on Ways and Means 

House of Representatives 

Since October 2001, more than 1.6 million military personnel have been 

deployed in support of Operation Enduring Freedom (OEF) and Operation 

Iraqi Freedom (OIF).1

 Estimates of the number wounded in these conflicts 

vary widely depending, for example, on the medical conditions counted. 

Due to advances in battlefield medicine, a larger proportion of military 

personnel are surviving their wounds than in previous years, though often 

with serious medical conditions including amputations, traumatic brain 

injury (TBI), and post traumatic stress disorder (PTSD). For those 

servicemembers and veterans who were wounded, injured, or became ill 

while on active duty since 2001—also called wounded warriors—a range 

of financial benefits are available. The Department of Defense (DOD) and 

the Department of Veterans Affairs (VA) provide disability benefits that 

are linked to military service. In addition, the Social Security 

Administration (SSA) administers disability benefit programs that are not 

tied to military service, but may still be an important part of a wounded 

warrior’s total package of financial assistance—if they are aware of and 

apply for these benefits. Wounded warriors may receive certain benefits 

from SSA while receiving DOD or VA disability benefits. 

Some reports issued in 2007 raised questions concerning whether the 

federal government had been sufficiently focused on helping wounded 

warriors access SSA disability benefits. For example, the Veterans’ 

Disability Benefits Commission report suggested that many veterans who 

may be eligible for SSA disability benefits are not receiving such benefits, 

and that outreach to disabled veterans regarding SSA benefits may be 

1

OEF, which began in October 2001, supports combat operations in Afghanistan and other 

locations, and OIF, which began in March 2003, supports combat operations in Iraq and 

other locations. 

 Social Security Disability 
 

inadequate.2 Partly as a result of the controversy surrounding conditions at 

the Walter Reed Army Medical Center, Congress has focused increased 

attention on the care that recovering servicemembers and veterans 

receive, including efforts to ensure they receive their entitled benefits. The 

National Defense Authorization Act for Fiscal Year 2008 requires DOD and 

VA to develop, in consultation with other relevant federal agencies, a 

comprehensive policy for the improvement of case management for 

recovering servicemembers and veterans.3

 This plan is to include 

connecting wounded warriors with SSA benefits, although the statute does 

not formally specify a role for SSA in the case management process. In 

accordance with increased congressional attention and statutory 

requirements, DOD and VA have developed several new programs 

designed to help wounded warriors heal and transition back to their 

military duties or to civilian life. These and other programs may potentially 

help wounded warriors learn about and apply for SSA benefits. However, 

while a number of studies have looked at DOD and VA efforts to help 

recovering servicemembers and veterans, these studies have not focused 

on how SSA benefits have been provided to wounded warriors and the 

challenges in doing so. 

Given this context, you asked us to determine (1) the number of wounded 

warriors who have applied and been approved for SSA disability benefits, 

and the extent to which wounded warriors who receive DOD or VA 

disability benefits also receive SSA benefits; (2) the extent to which SSA, 

DOD, and VA have worked to inform wounded warriors about and help 

them apply for SSA disability benefits, and the challenges confronting this 

outreach effort; and (3) whether the agencies have taken any steps to 

facilitate the processing of wounded warriors’ SSA disability benefit 

claims. 

In addressing these questions, we have focused our research on wounded 

warriors who were wounded, injured, or ill while on active duty since 

2001. More specifically, to answer the questions, we reviewed policy and 

other documents from SSA, DOD, and VA, and interviewed officials 

responsible for outreach and case management policies at each agency. 

We selected seven DOD and five VA medical treatment facilities in order to 

examine local-level activities and collaboration. We selected several of 

 

2

Veterans’ Disability Benefits Commission, Honoring the Call to Duty: Veterans’ Disability 

Benefits in the 21st Century (Washington, D.C., October 2007), 279. 

3

Pub. L. No. 110-181, § 1611 

Page 2 GAO-09-762 Social Security Disability
 

these sites because they serve a majority of the severely wounded 

servicemembers. The remaining sites were selected based on factors 

including the number of pending SSA claims submitted by wounded 

warriors in the region in which the facility is located and the number of 

recovering servicemembers assigned to each facility. For each selected 

location, we generally interviewed staff from the DOD or VA facility, an 

SSA district office, and the state office responsible for medical evaluation 

of SSA claims; at some sites we also interviewed servicemembers. In 

addition, we obtained and analyzed administrative data from SSA, DOD, 

and VA on wounded warriors’ utilization of financial benefits from all 

three agencies. We found the administrative data to be sufficiently reliable 

for the purposes of our report. Finally, to gain a broader understanding of 

the experiences and opinions of wounded warriors, we conducted a mail 

survey of a sample of wounded warriors who had applied for SSA 

disability benefits during fiscal year 2008. The survey attained a 53 percent 

response rate. While a nonresponse bias analysis revealed that older and 

more educated individuals were more likely to respond to our survey than 

younger and less educated individuals, it did not reveal large or systematic 

bias in our overall survey results. Unless otherwise noted, percentage 

estimates from the survey have 95 percent confidence intervals within plus 

or minus 8 percentage points or less of the estimate, and are generalizable 

to the entire population of fiscal year 2008 applicants. 

We conducted this performance audit from March 2008 through 

September 2009 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives. (See app. I for 

more details on our objectives, scope, and methodology.) 

Military personnel wounded since 2001—the exact number is not known—

may qualify for financial benefits from several federal agencies. While SSA, 

VA, and DOD each provide disability benefits that are available to 

wounded warriors, these programs have different eligibility criteria and 

serve different purposes. SSA has two programs, Disability Insurance (DI) 

and Supplemental Security Income (SSI), to provide benefits for those 

whose disabilities prevent them from working. VA’s disability 

compensation program and DOD’s disability retirement program provide 

benefits to those with service-connected disabilities. (See app. II for a 

table summarizing the three agencies’ disability programs.) 

Background 

Page 3 GAO-09-762 Social Security Disability
 

Estimates of the number of military personnel wounded, ill, or injured 

since 2001 vary widely depending on what conditions are counted and the 

source of data used. DOD has reported that about 34,000 servicemembers 

have been wounded in action in the OEF/OIF campaigns through the 

beginning of June 2009. On the other hand, our analysis of VA data shows 

that almost 250,000 OEF/OIF veterans were receiving VA disability 

compensation benefits as of July 2008. This figure may be larger than 

DOD’s estimate because, for example, some wounded warriors’ servicerelated medical conditions may have only appeared or been recognized 

after they separated from the military. Yet another estimate comes from a 

2008 study by the RAND Corporation.4

 Based on a survey of individuals 

deployed in support of OEF and OIF, this study estimated that more than 

500,000 OEF/OIF veterans and servicemembers likely suffer from at least 

one of three mental health or cognitive conditions—PTSD, major 

depression, and probable TBI—that are likely linked to combat 

experience. The RAND estimate, unlike the VA estimate, includes 

wounded warriors whose medical conditions may not even have been 

medically diagnosed. 

Varying Estimates of the 

Total Number of Wounded 

Warriors Since 2001 

SSA Disability Benefits To be eligible for either DI or SSI, an adult must be unable to engage in 

“substantial gainful activity”—typically work that results in earnings above 

a monthly threshold established each year by SSA—because of a medically 

determinable physical or mental impairment that is expected to last at 

least 12 months or result in death.5

 Established in 1956, the DI program 

provides monthly benefits to individuals (and sometimes their 

dependents) whose work history qualifies them for disability benefits and 

whose impairment is disabling. To qualify for DI, individuals must have 

worked a certain minimum amount of time in employment covered by 

Social Security; the monthly amount of DI benefits is based on the 

worker’s past average monthly earnings. In fiscal year 2008, the average 

monthly DI benefit payment was $997. SSI is a means-tested income 

assistance program created in 1972 that provides a financial safety net for 

people who are aged, blind, or disabled, and have low incomes and limited 

assets. Unlike the DI program, SSI has no prior work requirements. The 

basic federal SSI benefit is the same for all individual beneficiaries.6

 This 

 

4

RAND Corporation, Invisible Wounds of War: Psychological and Cognitive Injuries, 

Their Consequences, and Services to Assist Recovery (2008), xxi. 

5

In 2009, the substantial gainful activity income level is $980 per month. 

6

In 2009, the basic maximum SSI payment is $674 per month for an individual. 

Page 4 GAO-09-762 Social Security Disability
 

basic, monthly SSI benefit may be reduced if an individual has other 

income or receives in-kind (noncash) support or maintenance. In fiscal 

year 2008, the average monthly SSI benefit payment was $476. Some 

individuals with disabilities can receive both DI and SSI benefits if they 

meet both DI’s work history requirements and SSI’s income and asset 

limits. 

The process to determine a claimant’s eligibility for SSA disability benefits 

is complex, involving several state and federal offices. A claimant first 

completes an application, or claim, for DI or SSI benefits, which includes 

information regarding illnesses, injuries, or conditions and a signature 

giving SSA permission to request medical records from medical care 

providers. Once the SSA field office staff verify that nonmedical eligibility 

requirements are met, the claim is sent to the state’s Disability 

Determination Services (DDS) office for determination of medical 

disability.7

 If the claim is approved, a claimant will be notified and will 

receive benefits, including limited retroactive benefits for some DI 

claimants.8

 If the claim is rejected, a claimant has 60 days to request that 

the DDS reconsider its decision. If the DDS reconsideration determination 

concurs with the initial denial of benefits, the claimant has 60 days to 

appeal and request a hearing before an SSA administrative law judge 

(ALJ). A claimant may appeal an unfavorable ALJ decision to SSA’s 

Appeals Council—which includes administrative appeals judges (AAJ) and 

appeals officers—and, finally, to the federal courts. SSA and DDS officials 

(for example. disability examiners, ALJs, and AAJs) determine disability 

based on evidence, such as medical findings and statements of functional 

capacity, obtained during the initial determination process and updated as 

necessary at each appeal level. 

VA Disability 

Compensation Benefits 

VA’s disability compensation program compensates veterans for the 

average loss in civilian earning capacity that results from injuries or 

 

7

SSA verifies different nonmedical requirements for the DI and SSI programs; for example 

SSA field offices verify, among other things, age, work credits, and current earnings for DI 

claimants and income and assets for SSI claimants. DDSs are state agencies with guidance 

and oversight provided by SSA. 

8

Approved DI claimants must wait 5 months after disability onset before they can start 

receiving benefits, regardless of when they apply and are approved for benefits. When they 

do start receiving benefits, they may be eligible for retroactive benefits for months between 

the end of this 5-month waiting period and their application date, up to a maximum of 12 

months of retroactive benefits. 

Page 5 GAO-09-762 Social Security Disability
 

diseases incurred or aggravated during military service, regardless of 

current employment status or income. VA uses the Department of 

Veterans Affairs Schedule for Rating Disabilities (VASRD) as criteria to 

determine the disability percentage rating. Disability ratings range from 0 

(least severe) to 100 percent (most severe) in increments of 10 percent. 

For example, an amputation of a thumb could result in a 40 percent rating, 

while an amputation of a ring finger could result in a 20 percent rating. If 

the veteran is found to have one or more service-connected disabilities 

with a combined rating of at least 10 percent, VA will pay monthly 

compensation, with amounts higher for those with higher ratings. As of 

December 2008, a veteran without dependents rated at 20 percent disabled 

receives monthly compensation of $243, whereas a veteran without 

dependents rated at 100 percent disabled receives $2,673 monthly. The 

veteran can be re-evaluated if the extent of the veteran’s disability changes 

or if new or newly recognized medical conditions or illnesses occur and 

are determined to have been caused or aggravated by military service. The 

veteran may, upon re-evaluation, receive a different percentage rating than 

they initially received. 

DOD Disability Retirement 

Benefits 

DOD’s disability system awards compensation to those servicemembers 

who are found to be no longer medically fit for duty, and, if they do not 

recover, separates them from the military. Like VA, DOD uses the VASRD 

as criteria to determine the disability percentage rating. The amount of 

DOD disability payment is based on whether the disability is servicerelated, the years of service, and the disability rating percentage. 

Servicemembers who receive a disability rating of 30 percent or higher—

regardless of their years of service—generally will be retired and may be 

eligible for lifelong benefits, including retirement pay and health insurance 

for the servicemember and their family. These servicemembers are placed 

on the Permanent Disability Retired List (PDRL). Servicemembers with 

fewer than 20 years of service who are separated with a disability rating of 

20 percent or less receive a single lump-sum severance payment; those 

with at least 20 years of service who receive a disability rating under 30 

percent are placed on the PDRL and receive on-going monthly benefits. 

Servicemembers may also be placed on the Temporary Disability Retired 

List (TDRL) if they are found to be medically unfit for duty by military 

examiners, but their service-related illnesses or injuries are not stable 

enough to assign them a permanent disability rating. Once a permanent 

disability rating can be assigned, depending on the rating and the 

servicemember’s years of military service, DOD may place those on the 

TDRL on the PDRL, grant them a one-time severance payment, or find 

them fit to return to military service. 

Page 6 GAO-09-762 Social Security Disability
 

Military servicemembers pay Social Security payroll taxes and may qualify 

for DI benefits on the basis of their service if they have a sufficient number 

of work quarters. Military service, for Social Security purposes, includes 

service in the Army, Navy, Air Force, Marines, and Coast Guard, including 

service in the Reserves and National Guard. Those who served in the 

military during certain periods of time are given credits that increase the 

earnings that SSA looks at in determining DI eligibility and benefit levels. 

Individuals are considered to have earned an additional $300 per quarter 

for military service between 1957 and 1977, and an additional $100 for 

every $300 actually earned—up to a maximum of $1,200—per calendar 

year between 1978 and 2001. In addition to DI benefits, wounded warriors 

may qualify for SSI benefits if they have low income and assets. 

SSA Disability Coverage 

for Wounded Warriors 

Furthermore, active duty servicemembers may receive DI benefits while 

also receiving military pay. Social Security law gives SSA the discretion to 

determine when an individual is actually performing work at the 

substantial gainful activity level, regardless of the individual’s income. 

Accordingly, in determining eligibility for benefits in cases when an 

applicant is receiving military pay, but is also receiving medical treatment 

or is on limited duty status, SSA assesses not the servicemember’s actual 

earnings, but rather what the servicemember would be paid in the civilian 

labor market for their work. If the wage that the servicemember could 

theoretically receive in the civilian workforce is less than SSA’s substantial 

gainful activity level, then SSA will not automatically disqualify the 

servicemember from receiving disability benefits.9

Impact of VA and DOD 

Disability Decisions on 

SSA Decisions 

Given that the SSA, VA, and DOD disability programs have different 

purposes and eligibility criteria, not all wounded warriors found to be 

disabled by VA or DOD—even those found 100 percent disabled—will 

necessarily qualify for SSA disability benefits. SSA’s DI program, for 

example, is an insurance program designed to replace workers’ income if 

they become unable to work due to disability. If an individual can perform 

any kind of work in the U.S. economy, then this person is not eligible for 

DI benefits.10 By contrast, VA’s disability compensation program is 

 

9

In deciding whether earnings show that an applicant has done substantial gainful activity, 

SSA considers only the income directly related to the applicant’s productivity. 20 C.F.R. § 

404.1574. 

10In assessing whether an applicant can perform any work in the national economy, SSA 

takes into account the applicant’s age, education, and work experience. 20 C.F.R. § 

404.1520. 

Page 7 GAO-09-762 Social Security Disability
 

designed to compensate veterans for the average loss of earnings resulting 

from a particular disability—regardless of the actual effect on an 

individual veteran’s capacity to work. A veteran could be rated 100 percent 

disabled under the VASRD by VA and receive VA disability benefits, but 

also be working and earning more than SSA’s substantial gainful activity 

level, and therefore be ineligible for SSA benefits. 

While SSA programs have different eligibility criteria than VA or DOD 

programs, and SSA makes its own disability decisions separate from those 

of VA or DOD, SSA regulations state that SSA eligibility determinations are 

to take disability decisions by other agencies into account. SSA regulations 

specify that the agency must evaluate all the evidence in a case record that 

may have a bearing on its disability decision, including decisions by other 

governmental and nongovernmental agencies. SSA has issued guidance to 

its adjudicative staff—including DDS claims examiners and SSA ALJs and 

AAJs—that when making a disability decision they must consider all the 

evidence in the case file, including a finding of disability by another agency 

such as VA. Adjudicators should explain the consideration given to a 

finding of disability by another agency in the case record for initial and 

reconsideration claims or in the notice of decision for hearing claims. 

However, the SSA regulations also note that a finding of disability by 

another government agency, related to a different benefit program, is not 

binding on SSA’s own disability determination. 

Financial Interaction of 

SSA, DOD, and VA Benefits 

Depending on their circumstances, wounded warriors may receive cash 

benefits simultaneously from SSA and from DOD or VA. However, receipt 

of DOD or VA benefits sometimes affects the amount of SSA benefits that 

a wounded warrior may receive. Specifically, SSI benefits are reduced if 

the beneficiary also receives benefits from certain other government 

programs such as DOD or VA benefits. On the other hand, DI benefits are 

not offset by VA or DOD disability benefits, so wounded warriors may 

receive their full DI benefits along with benefits from these other agencies. 

By contrast, DOD disability retirement benefits and VA disability 

compensation benefits are awarded on the basis of the content of 

disabilities incurred during military service rather than on the basis of 

Page 8 GAO-09-762 Social Security Disability
 

income. Wounded warriors may receive their full DOD or VA disability 

benefits along with any SSA benefits.11

More than 16,000 wounded warriors have applied for SSA disability 

benefits and their approval rate has been about 60 percent; in addition, 

about 4 percent of wounded warriors receiving DOD or VA disability 

benefits are also receiving SSA disability benefits. At least 16,000 wounded 

warriors have applied for SSA disability benefits since 2001, with close to 

90 percent of applications submitted in 2007 and 2008. A sizable minority 

of wounded warriors submitted their applications more than a year after 

injury, often foregoing some retroactive benefits because of this delay in 

applying. About 60 percent of the applicants with no pending claims have 

been approved for benefits by SSA, with a majority of the approved 

claimants having a mental health disorder as their primary impairment. 

Among wounded warriors who were receiving disability benefits from 

DOD or VA, about 10 percent had applied for SSA disability benefits, and 

about 4 percent of the total cohort of wounded warriors receiving DOD or 

VA benefits were also receiving SSA benefits. Wounded warriors with 

higher disability ratings were more likely to have applied and to be 

receiving SSA disability benefits. 

Thousands of 

Wounded Warriors 

Have Applied and 

Been Approved for 

SSA Disability 

Benefits, and 

Relatively Few 

Receiving DOD or VA 

Benefits Also Receive 

SSA Benefits 

At Least 16,000 Wounded 

Warriors Have Applied for 

SSA Disability Benefits—

Often A Year Or More After 

Injury—and Their 

Approval Rate Has Been 60 

Percent 

Since 2001, at least 16,000 wounded warriors have applied for SSA 

disability benefits.12 This figure represents the number of applicants whom 

SSA has identified in its systems as wounded warriors, but because of 

limitations with SSA’s data sources the total number of applicants is likely 

higher. In its databases, SSA identifies wounded warriors as those 

applicants who were disabled while in active military service on or after 

October 1, 2001, regardless of where the disability occurred. SSA uses two 

sources of information to identify wounded warrior applicants. First, DOD 

provides SSA with a list every week of military personnel who have been 

 

11In general, veterans cannot receive both DOD disability retirement and VA disability 

compensation benefits concurrently, as their DOD disability benefits are offset on a dollar 

for dollar basis by any VA disability benefits they receive. However, veterans with 20 years 

or more of service who have a service-connected disability that is rated at 50 percent or 

higher may qualify to receive concurrent benefits, subject to certain phase-in requirements 

through the year 2013. 

12The data presented on the number of wounded warrior applicants identified by SSA, their 

characteristics, and their outcomes reflect wounded warrior claims filed through 

December 8, 2008, when the data were extracted from SSA’s databases. 

Page 9 GAO-09-762 Social Security Disability
 

wounded, injured, or become ill while in support of the OEF/OIF 

campaigns. According to DOD, though, while this list is the only data they 

have available, it is not necessarily a comprehensive list of all military 

personnel wounded, ill, or injured in OEF/OIF. In addition, applicants may 

self-identify as wounded warriors when they submit their applications. 

However, SSA only started collecting this information from applicants in 

2005, so wounded warriors who applied before 2005 and are not in DOD’s 

data would have been missed.13

Meanwhile, we found that of the more than 16,000 wounded warriors 

appearing in SSA’s data as having applied for SSA benefits, virtually all had 

submitted claims for DI benefits, with many also submitting a claim for 

SSI. (Applicants may file claims for DI benefits on the basis of their past 

work history or SSI benefits on the basis of low income and assets.)14

Among these 16,000 applicants, about 53 percent had applied for both DI 

and SSI benefits concurrently, another 47 percent applied for DI benefits 

only, and less than 1 percent applied for SSI benefits only. 

We also found that the vast majority of the applicants submitted their 

claims within the last two calendar years. Although wounded warriors 

who have served since 2001 have applied for SSA disability benefits in 

every year dating back to 2002, the number of claims submitted has 

increased each year—almost 90 percent of the applicants submitted their 

claims in 2007 or 2008 (see fig. 1). 

 

13It is difficult to determine the proportion of all wounded warriors who have applied for 

SSA disability benefits, not only because of uncertainty about the number of applicants for 

SSA benefits, but also because of the varying estimates of the total number of wounded 

warriors since 2001. 

14When an applicant files a claim for disability benefits, SSA evaluates the applicant’s 

potential entitlement for DI benefits based on a wage earner’s earnings history and their 

potential eligibility for SSI benefits based on SSI income and resource limits. 

Page 10 GAO-09-762 Social Security Disability
 

Figure 1: Number of Wounded Warrior Applicants for SSA’s DI or SSI Benefits, by 

Year in Which Applications Were Submitted 

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

9,000

2002 2003 2004 2005 2006 2007 2008

Calendar year

Source: GAO analysis of SSA data.

Number of wounded warrior applicants

4 93 217 481

1,330

5,200

8,652

Note: This figure reflects data for more than 99 percent of the 16,005 wounded warrior applicants. 

Data on the remaining applicants were missing or miscoded in SSA’s database. 

While most of the wounded warriors for whom SSA has determined a 

disability onset date submitted their applications to SSA within a year of 

sustaining their wound, injury, or illness, a substantial number submitted 

applications a year or more after injury. Among wounded warriors whose 

claims were approved at the initial stage of adjudication and for whom 

SSA has established a disability onset date,15 more than half submitted 

their applications within a year of this onset date. But about 40 percent 

submitted claims at least 12 months after disability onset, and almost a 

quarter submitted claims at least 18 months after onset. (See fig. 2.) DI 

claimants who file an application more than 17 months after disability 

onset will forego some retroactive benefits, because their 12-month 

retroactive benefit period will not extend all the way back to the end of 

the 5-month waiting period (between the disability onset date and the date 

a claimant can start receiving DI benefits). SSA has for some time been 

 

15Applicants provide an alleged disability onset date when they file a claim for DI or SSI. 

The established disability onset date is the date on which SSA has determined that a 

disability actually began, based on the medical and other evidence. 

Page 11 GAO-09-762 Social Security Disability
 

considering a legislative proposal to change or waive the statutory 

retroactive benefit period specifically for wounded warriors to help those 

who may not apply soon enough after disability onset. An SSA official 

reported that the agency’s consideration of such a proposal is based in 

part on anecdotal evidence from local offices about wounded warriors not 

applying for benefits in a timely manner. SSA has not provided us with any 

further details about their potential proposal. 

Figure 2: Length of Time from Disability Onset to Application Filing Date for 

Wounded Warrior Applicants Approved at the Initial Stage 

Source: GAO analysis of SSA data.

18 to 23 months

24 months or more

Under 6 months

6 to 11 months

17% 12 to 17 months

15% 9%

34%

25%

Note: Established onset date was not available for 12 percent of wounded warrior applicants who 

were approved at the initial stage. 

Turning to the claim outcomes for wounded warrior applicants identified 

in SSA’s data, we found that the approval rate for these wounded warriors 

was 60 percent.16 By comparison, among all individuals who filed a claim 

 

16We are defining the approval rate as the percentage of wounded warrior applicants with 

final decisions on their claims, and with no claims pending, who had an allowed claim. 

Page 12 GAO-09-762 Social Security Disability
 

for DI benefits in 2007, 32 percent had a claim approved by August 2008.17

Specifically, about 7,600 of the wounded warrior applicants had at least 

one claim allowed for either DI or SSI. The vast majority of these claim 

allowances have come at the initial stage of adjudication. Of the 

approximately 7,600 claimants with allowed claims, 96 percent had claims 

allowed at the initial stage, and 4 percent at the hearings level.18 Of the 

remaining wounded warriors with no allowed claim, the majority had their 

claims denied, though many still had at least one claim pending a final 

decision. (See fig. 3.) 

 

17SSA calculates this 32 percent rate by dividing the number of claim allowances at all 

levels of adjudication by the number of claims (minus claims pending a final decision). One 

factor contributing to the different rates for all claimants and wounded warrior claimants is 

that a much higher percentage of all DI claimants, compared to wounded warrior DI 

claimants, were denied for technical—nonmedical—reasons), such as insufficient recent 

credits. Setting aside these technical denials, SSA calculates that 51 percent of 2007 DI 

claimants had claims allowed. 

18Of wounded warriors denied at the initial stage, 1,960 requested a reconsideration of this 

denial by the DDS, and 1,077 appealed their claims to SSA’s Office of Disability 

Adjudication and Review (ODAR) for a hearing before an ALJ. Some applicants appeal a 

denial at the initial level of adjudication directly to ODAR, without requesting a 

reconsideration by the DDS. 

Page 13 GAO-09-762 Social Security Disability
 

Figure 3: Claim Outcomes for Wounded Warrior Applicants at Initial, 

Reconsideration, and Hearing Stages 

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

Source: GAO analysis of SSA data.

Number of wounded warrior applicants

286

7,569

5,067

2,963

No determination or dismissal

Pending

Denial

Allowance

Note: Outcome data were missing for less than 1 percent of wounded warrior claimants. Also, 

according to SSA officials, sufficient data were not available on how many wounded warriors 

appealed their claims to the Appeals Council and to the federal courts. 

Breaking out DI and SSI claims, we found that wounded warriors were 

much more likely to have claims allowed for DI than for SSI, and a major 

reason was that many wounded warriors exceeded SSI income and asset 

requirements. Of the almost 16,000 wounded warriors who submitted a 

claim for DI, about 7,500 had a DI claim allowed. Of the roughly 8,500 who 

submitted a claim for SSI—often concurrently with their DI claim—fewer 

than 900 had an SSI claim allowed. Wounded warriors’ SSI claims were 

much more likely to be denied for technical—nonmedical—reasons. Of 

those who applied for SSI, 64 percent were denied for technical reasons, 

particularly for having income or resources above the program’s limits. In 

contrast, of those who applied for DI, less than 1 percent were denied for 

technical reasons, such as insufficient work history. 

Finally, looking at the medical conditions of wounded warriors whose 

claims were allowed, we found that the majority were found eligible on the 

basis of mental health disorders. That is, the primary medical impairment 

for about 60 percent of wounded warriors allowed at the initial or 

Page 14 GAO-09-762 Social Security Disability
 

reconsideration stages, fell into the overall category of mental disorders 

(see fig. 4).19 By contrast, among all disabled workers who had DI claims 

allowed in 2008, 23 percent had a mental disorder. Among wounded 

warriors with mental disorders, the three most common specific 

conditions—accounting for more than half of all the wounded warriors 

with allowed claims—were anxiety disorders, mood or affective disorders, 

and chronic brain syndrome. According to SSA officials, wounded 

warriors with PTSD are included in either the anxiety disorder category or 

the mood or affective disorder category. Also, those with TBI may be 

classified as having chronic brain syndrome, or as having any of a number 

of neurological conditions depending on their symptoms. Aside from 

mental disorders, most of the remaining wounded warriors with allowed 

claims had a musculoskeletal condition as their primary impairment. The 

most common musculoskeletal conditions—accounting for about 13 

percent of all wounded warriors with allowed claims—were back 

disorders, amputations, and lower limb fractures. 

 

19Data are not available on the body system category for claimants allowed at the hearing 

level. 

Page 15 GAO-09-762 Social Security Disability
 

Figure 4: Body System Category of Primary Impairment, for Wounded Warriors with 

Allowed Claims at Initial and Reconsideration Stages 

0

10

20

30

40

50

60

70

80

90

100

Source: GAO analysis of SSA data.

Percentage

6

2 111 1 1 1

59

21

7

Immune

Cardiovascular

Special and Other

Digestive

Skin

Special senses

and speech

neoplastic

diseases

Malignant

Neurological

Unknown

Musculos

Mental

keletal 

Note: Percentages add to more than 100 because of rounding. Also, several additional body system 

categories each included less than 1 percent of wounded warriors’ primary impairments. 

A Small Percentage of 

Wounded Warriors 

Receiving DOD or VA 

Benefits Also Receive SSA 

Benefits, and Those With 

Higher Disability Ratings 

Are More Likely to Receive 

Benefits From SSA 

Among almost 251,000 wounded warriors receiving DOD or VA disability 

benefits, we found that about 26,000 (10 percent) of this cohort had 

applied for SSA disability benefits and about 9,000 (4 percent) were 

receiving SSA benefits as of July 2008. It is likely that some applicants still 

had claims pending as of July 2008—the cut-off date for our analysis—and 

could have eventually been approved for benefits. It is also possible that 

some of the applicants had been approved for SSA benefits in the past, but 

were no longer receiving them in July 2008.20 Our analysis focused on 

wounded warriors receiving DOD disability retirement VA disability 

compensation benefits, or both, in July 2008 who had served in active duty 

 

20Our data do not tell us conclusively whether these applicants have ever had SSA claims 

approved, only whether they have ever applied and whether they were receiving benefits in 

July 2008. 

Page 16 GAO-09-762 Social Security Disability
 

at any point since September 2001.21 The vast majority (92 percent) of the 

cohort of 251,000 wounded warriors received benefits only from VA. 

Another 2 percent received benefits only from DOD. The remaining 

wounded warriors received benefits from more than one agency.22 

(See fig. 5.) 

 

21These wounded warriors were included in data provided by DOD and VA. The DOD 

provided data on wounded warriors assigned to the TDRL or PDRL as of July 2008. We 

analyzed these data to identify individuals placed on the TDRL or PDRL after October 2001, 

who had served in active duty in October 2001 or later. The VA provided data on all 

veterans receiving VA disability compensation benefits in July 2008 who were identified in 

VA’s database as OEF/OIF veterans. OEF/OIF veterans include those who were physically 

based within the OEF/OIF combat zones, as well as those who directly supported the 

OEF/OIF campaign outside the combat zones. Many of the 26,000 DOD or VA benefit 

recipients who have applied for SSA benefits are not identified as wounded warriors in 

SSA’s database and therefore are not included in our estimate of 16,000 wounded warrior 

applicants reported above, which is based on applicants identified as wounded warriors by 

SSA. 

22Of those receiving SSA disability benefits, virtually all received DI benefits, with only a 

small percentage receiving SSI benefits. 

Page 17 GAO-09-762 Social Security Disability
 

Figure 5: Wounded Warriors’ Receipt of Disability Benefits by Agency, as of July 

2008

Source: GAO analysis of data from SSA, DOD, and VA.

0.5%

VA, DOD, and SSA

0.1%

DOD and SSA

3.0%

VA and SSA

3.3%

VA and DOD

1.5%

DOD only

91.6% VA only

We also found that among wounded warriors receiving DOD or VA 

disability benefits those with higher disability ratings were more likely to 

have applied for and been receiving SSA disability benefits. Among the 

approximately 7,400 wounded warriors rated as 100 percent disabled by 

DOD or VA, 63 percent had applied for SSA benefits and 41 percent—of 

the entire group of 7,400—were receiving them in July 2008. By 

comparison, among those rated as less than 50 percent disabled, fewer 

than 10 percent had applied for and fewer than 2 percent were receiving 

SSA disability benefits. (See fig. 6.) Importantly, not all wounded warriors 

rated as 100 percent disabled by DOD or VA will necessarily qualify for 

SSA disability benefits, given differences in the purposes and eligibility 

criteria between the agencies’ programs. Similarly, some wounded 

warriors rated as less severely disabled by DOD or VA could qualify for 

SSA benefits. DOD disability retirement and VA disability compensation 

benefits —unlike SSA benefits—are awarded on the basis of servicePage 18 GAO-09-762 Social Security Disability
 

connected disabilities. According to SSA officials, some veterans found by 

DOD or VA to have only moderate service-connected disabilities could 

have experienced an additional injury or illness after separating from the 

military, which later qualified them for SSA benefits. 

Figure 6: Percentage of Wounded Warriors Receiving DOD or VA Disability Benefits Who Had Applied for and were Receiving 

SSA Disability Benefits by Disability Percentage Rating, as of July 2008

Source: GAO analysis of SSA, DOD, and VA data.

Percentage

10

41

15

63

34

9

3 3 3 4 2 2 1 2 0

24

12

18

6 6 8 8

0

10

20

30

40

50

60

70

80

90

100

Receiving SSA disability benefits

Applied for SSA disability benefits

100 90 80 70 60 50 40 30 20 10 0

VA or DOD disability percentage rating

Outreach to help wounded warriors learn about and apply for disability 

benefits under SSA has increased in recent years as a result of both agency 

actions at the national level and local initiative taken at major medical 

facilities for the wounded. The agencies involved— SSA, DOD, and VA—

have taken individual and joint steps to specifically target this population, 

tailor information to military needs, and, in effect, re-enforce the message 

that wounded warriors may qualify for SSA benefits. At the local level we 

found many instances of DOD staff and local SSA representatives working 

in concert at DOD treatment facilities to convey this information to the 

wounded. However, collaboration between VA and SSA was less prevalent 

at VA medical centers. A number of challenges can affect agency efforts to 

Agencies Have Taken 

Steps to Conduct 

Outreach to Wounded 

Warriors on SSA 

Benefits but a 

Number of Challenges 

Exist 

Page 19 GAO-09-762 Social Security Disability
 

reach out and assist this population, particularly for those diagnosed with 

PTSD and TBI. 

SSA, DOD, and VA Have 

Developed Programs and 

Initiatives to Reach 

Wounded Warriors, 

Particularly since 2007 

SSA, DOD, and VA have taken individual and collaborative steps at the 

national level to establish and maintain outreach to wounded warriors 

who may qualify for SSA disability benefits. 

Since 2007, SSA has increased its outreach efforts to wounded warriors by 

initiating contact with DOD and VA medical facilities and tailoring its 

information about disability benefits to meet their needs. SSA officials 

reported that they had begun to specifically target the wounded warrior 

population partly as a result of their participation in a 1-year pilot project 

with the U.S. Navy. Conducted from 2006 to 2007, the pilot was designed 

to help reduce the time it was taking for information to be disseminated 

and decisions to be made on SSA benefits for servicemembers.23 Following 

this project, SSA headquarters directed its field offices to increase their 

efforts to work with DOD and VA medical facilities to conduct outreach. 

SSA officials reported that their field offices have subsequently been in 

contact with wounded warriors or staff at almost 30 DOD facilities and 

more than 50 VA facilities across the country. In addition, the agency has 

developed publications and established a Web site with SSA disability 

benefits information that has been customized for wounded military 

personnel and veterans. These resources explain, for example, how 

military pay affects eligibility for SSA’s programs and how to apply. (See 

fig. 7.) SSA officials told us although SSA does not have any formal 

practices in place to determine whether or not outreach has been 

effective, there is an internal workgroup—consisting of staff from 

headquarters, regional, district, and DDS offices—that meets quarterly to 

discuss and share successful local efforts in serving wounded warriors, as 

well as best practices for reaching wounded warriors. 

SSA 

 

23The Severely Injured Marines and Sailors pilot program worked with a small number of 

servicemembers to bring all relevant federal agencies together in a coordinated way to help 

injured servicemembers understand and apply for appropriate benefits. According to the 

program’s final report, the pilot examined the pros and cons of accelerating disability 

retirement for severely injured servicemembers who are not expected to return to duty 

within 12 months and would need financial support. 

Page 20 GAO-09-762 Social Security Disability
 

Figure 7: Sample Page from SSA Publication 

Source: SSA as of August 2007.

Page 21 GAO-09-762 Social Security Disability
 

DOD has taken a number of steps to help wounded warriors learn about 

and apply for SSA disability benefits, particularly since 2007. The 

department has incorporated information about SSA benefits into the 

many case management programs run by the service branches—programs 

already providing a range of advice and assistance to wounded warriors 

and their families. We found that these programs—the Army Wounded 

Warrior Program, the Warrior Transition Brigade, the Marine Wounded 

Warrior Regiment, and the Navy Safe Harbor Program—covered SSA 

benefits in their case management review materials or list SSA as a 

resource on their Web sites.24 (See fig. 8 for an example of one of the 

assessment tools used in the case management programs to help ensure 

SSA disability benefits are discussed.) Additionally, DOD case managers 

for these programs received briefings from SSA as part of their training 

regimen, according to DOD officials. A DOD official told us the agency has 

also included SSA disability programs in the portfolio of information to be 

disseminated through its Recovery Coordination Program, which was 

included in the comprehensive recovery plan for wounded warriors 

developed in response to the National Defense Authorization Act for 

Fiscal Year 2008.25 This recovery plan does not formally spell out how 

DOD case managers should conduct outreach on SSA benefits or work 

with S

DOD 

SA. 

 

24According to DOD officials, the Army Wounded Warrior Program was established in 2004 

and has 51 locations across the country. The program serves wounded warriors who are 

likely to be medically discharged due to the severity of their medical condition. The 

Warrior Transition Brigade was established in 2007 and is located at 35 Army military 

treatment facilities in the United States and abroad. The Brigade serves any wounded, ill, or 

injured servicemember from any branch of service, including the Reserves and National 

Guard, who requires at least 6 months of treatment. 

25The Recovery Coordination Program began its operations in 2008 with 32 Recovery Care 

Coordinators. In the policy that established the Recovery Coordination Program, it states 

Recovery Care Coordinators should ensure that recovering servicemembers are afforded 

the opportunity to be engaged by SSA’s disability programs. 

Page 22 GAO-09-762 Social Security Disability
 

Figure 8: Sample Page from Army Wounded Warrior Patient Intake Form that 

Includes SSA 

Source: Army Wounded Warrior program.

DOD has also added SSA benefit information to a variety of resources 

available to wounded warriors—for example, DOD’s Compensation and 

Benefits Handbook dedicates a section to the subject. DOD also has Web 

Page 23 GAO-09-762 Social Security Disability
 

sites that contain some information about SSA and it has added links to 

SSA’s own wounded warrior Web site. Meanwhile, information about SSA 

disability benefits has also been included in joint briefings that DOD, VA, 

and other agencies conduct at all DOD bases and military treatment 

facilities for servicemembers who are being discharged from the military.26

VA has also taken some steps to inform and help wounded warriors apply 

for SSA disability benefits. In 2007, the agency, working with DOD, 

established the Federal Recovery Coordination Program, which is a 

counterpart to DOD’s Recovery Coordination Program, to provide a case 

management framework for ensuring that the most severely wounded 

warriors are engaged by SSA’s benefit programs, as well as by other 

support services.27 Additionally, VA case managers for the Federal 

Recovery Coordination Program have received information from SSA 

specialists regarding SSA disability benefits. Meanwhile, staff from other 

VA programs in existence prior to 2007, such as the Office of Seamless 

Transition, told us they sometimes include the topic of SSA benefits when 

case managers interview veterans about their clinical and nonclinical 

needs.28 VA has also included SSA disability information in other resources 

that are available to wounded warriors, such as VA’s Federal Benefits for 

Veterans and Dependents and VA’s Web site. This Web site also has links 

to SSA’s Web site. In addition, the agency’s Veterans Benefits 

Administration (VBA), which administers VA disability compensation 

benefits, includes on its application forms some limited information about 

SSA benefits and SSA contact information. VBA officials told us, however, 

that their disability compensation claims representatives do not have any 

particular guidance or training for how or whether to refer wounded 

warriors to SSA when they apply for VA benefits. According to a VA 

official, while VA began a phone outreach campaign in 2006 to OEF/OIF 

VA 

 

26The Transition Assistance Program and Disabled Transition Assistance Program are 

regularly scheduled briefings conducted by DOD and VA to servicemembers at DOD’s 

military installations which include SSA information. 

27The Federal Recovery Care Coordination Program was established in 2007 and by 2008 

nine Federal Recovery Coordinators had begun serving DOD military treatment facilities 

and VA medical centers located across the country. It became part of the DOD and VA 

comprehensive recovery plan in 2008. 

28According to a VA official, the OEF/OIF Program was established to specifically serve 

veterans from the OEF/OIF campaigns. Staff are located at each of the Veterans Health 

Administration’s more than 150 medical centers across the country. Within this program, 

VA also operates the Transition Patient Advocate Program that serves wounded warriors 

with severe medical conditions. 

Page 24 GAO-09-762 Social Security Disability
 

veterans to remind them about VA’s health and benefit services, this 

campaign has not included information about SSA’s programs and 

benefits. 

Turning to the sites we contacted, we often found that DOD medical 

treatment facilities were working with local SSA offices to better inform 

wounded warriors about SSA disability benefits and help them apply. This 

level of interaction was less common at VA sites. At all of the DOD military 

treatment facilities we visited, including the four major facilities that treat 

the most severely wounded warriors,29 SSA representatives were coming 

onto the base to conduct briefings and field questions about SSA disability 

benefits from wounded warriors and staff. At many of these locations, SSA 

representatives had also taken benefit applications. For example, at Walter 

Reed Army Medical Center, SSA representatives were holding office hours 

twice a week to take applications, and provide regular briefings to 

wounded warriors and case managers. At Brooke Army Medical Center, 

SSA claims representatives were conducting presentations at weekly 

briefings for recovering servicemembers and also taking benefit 

applications. Moreover, according to our survey of wounded warriors who 

had applied for SSA disability benefits they faced few obstacles to finding 

SSA representatives, if and when they did seek help.30 Based on the survey, 

we estimate that almost three quarters—73 percent—of wounded warrior 

applicants found it was easy to make initial contact with an SSA 

representative. Most of the local SSA staff we spoke with told us that in 

recent years they have reached out to local DOD personnel to obtain 

access to DOD’s facilities where potentially eligible wounded warriors can 

be found. Some of the local SSA offices we spoke with noted that it had 

taken some time to establish working relationships at some of the DOD 

bases they contacted. For example, they said certain DOD personnel at the 

Brooke Army Medical Center had not been routinely cooperative until the 

base commander issued an order. In addition, several local SSA officials 

Local Agency Outreach Efforts 

at Treatment Facilities 

 

29The four sites were: Walter Reed Army Medical Center, Washington D.C.; National Naval 

Medical Center, Bethesda, Maryland; Brooke Army Medical Center, San Antonio, Texas; 

and Naval Medical Center San Diego, San Diego, California. 

30We surveyed a random sample of wounded warriors who applied for SSA benefits during 

fiscal year 2008 and received a response rate of 53 percent. A nonresponse bias analysis 

revealed that older and more educated individuals were more likely to respond to our 

survey than younger and less educated individuals, but did not reveal systemic bias in our 

survey results. Unless otherwise noted, the margin of error for percentage estimates from 

this survey is plus or minus 8 percentage points or less at the 95 percent level of 

confidence. See appendix I for more details on our survey methodology and our 

nonresponse bias analysis, and appendix III for the questions and complete results. 

Page 25 GAO-09-762 Social Security Disability
 

told us that staff turnover at DOD facilities creates a challenge. For 

example, officials from the Colorado Springs SSA office told us that 

because of frequent staff turnover at Evans U.S. Army Hospital (Fort 

Carson), new DOD staff are often unaware of SSA benefits and as a result 

do not refer servicemembers to SSA who might be eligible for SSA 

disability benefits. 

In the course of our site visits, we also learned that in serving DOD 

facilities and the wounded warrior population, most of the SSA offices we 

conducted interviews at had representatives who had developed some 

expertise in working with military personnel. Some local SSA officials told 

us these representatives know what questions to ask and what documents 

to collect to support wounded warriors’ claims. Wounded warriors also 

reported that they found SSA officials helpful. Based on our survey, we 

estimate that about 63 percent found the information they received from 

SSA representatives to be helpful. In one location where SSA did not 

employ specialized claims representatives, DOD case managers had 

become more familiar with SSA disability benefits and had developed a 

customized walk-through presentation to help wounded warriors better 

navigate SSA’s application process. See figure 9 for an excerpt from this 

presentation. 

Page 26 GAO-09-762 Social Security Disability
 

Figure 9: Excerpts from the Customized Walk-Through Presentation 

Click Yes! (you received military pay).

Luke Skywalker

Click No, if you didn’t or have not returned to full 

duty or have not been employed as a civilian.

This doesn’t refer to TSGLI. Estimate all military pay that 

you have received from the date of your injury up to the 

date that you returned to full duty or were employed. If 

you haven’t returned to full duty (Working in your MOS) 

estimate all military pay that you have received from the 

date of injury up to the present day.

A period is referring to active 

duty enlistment dates or dates

when you were on orders.

Click Other for regular military pay.

Military or Civilian pay (this doesn’t refer to TSGLI; 

TSGLI is not your employer).

Click Other for regular military pay.

Example: Input your 1st 

enlistment dates (when 

you joined the Marine 

Corps and your EAS)

Source: Marine Wounded Warrior Battalion, Marine Corps Base Camp Pendleton.

On the other hand, at the medical centers operated by VA through its 

Veterans Health Administration, we found less contact underway between 

local SSA and VA staff. According to VA officials at the medical centers we 

contacted, none of them had an SSA representative onsite to answer 

questions or take applications, though some of the VA officials we spoke 

with thought it would be a good idea. Case managers at three of the five 

Page 27 GAO-09-762 Social Security Disability
 

sites we contacted said they refer veterans to a specific point of contact at

a local SSA office who may specialize in wounded warrior claims. Officials 

at the other two sites did not always have a point of contact at all of the 

local SSA offices in the area. Case managers at one of these sites said tha

when they refer veterans to SSA without a specific point of contact, the 

veterans have challenges navigating SSA’s automated phone system or 

reaching a live representative. In addition, case managers at two sites to

us that they had received some training from SSA on SSA’s disability 

benefits. However, case managers at the other sites told us they had n

received training from SSA on SSA disability benefits and believed having

such training would be beneficial. Table 1 summarizes the outreach 

activities at DOD and VA medical facilities we contacted. 

t 

ld 

ot 

Table 1: Summary of Outreach Activities at DOD and VA Medical Facilities 

Location

SSA holds 

regular office 

a SSA takes 

applications 

SSA gives 

warriors on site 

Case managers 

s

Case managers 

warriors to SSA 

SSA conducts 

t

hours to take 

pplications or 

answer 

questions on site 

briefings to 

wounded 

refer wounded 

warriors to 

pecific point of 

contact at SSA 

local office 

only refer 

wounded 

without a 

specific point of 

contact raining for staff

Military treatment facilities 

Carl R. Darnall 

Army Medical 

Center 

• • • • 

Evans US Army • • • • • 

Hospital 

Camp Pendleton • •

Naval Hospital 

•

National Naval 

Medical Center 

(Bethesda) 

• • •

National Naval 

Medical Center San 

Diego (Balboa) 

 • • •

Brooke Army 

Medical Center 

• • • • •

Walter Reed Army • • • • •

Medical Center 

VA medical centers

Audie L. Murphy 

VA Hospital 

• 

Fayetteville VA 

Medical Center 

 • 

Page 28 GAO-09-762 Social Security Disability
 

Location

SSA holds 

regular office 

hours to take 

applications or 

answer 

questions 

SSA takes 

applications 

on site 

SSA gives 

briefings to 

wounded 

warriors on site 

Case managers 

refer wounded 

warriors to 

specific point of 

contact at SSA 

local office 

Case managers 

only refer 

wounded 

warriors to SSA 

without a 

specific point of 

contact 

SSA conducts 

training for staff

Hunter Holmes 

McGuire VA 

Medical Center 

• 

Olin E. Teague

Veterans’ Center 

 • 

VA Palo Alto He

Care System 

alth • •

Source: GAO analysis. 

ional VBA offices, officials at the offices we contacted said 

eir claims staff sometimes refer wounded warriors to SSA when they 

th 

Agency efforts to help wounded warriors learn about and apply for SSA 

isability benefits early in the recovery process can be affected by 

challenges, including some servicemembers not being ready to apply and 

misinformation that may be passed among wounded warriors. According 

to local officials from all three agencies we spoke with, wounded warriors 

may not be ready or able to learn about SSA disability benefits early in 

 

As for the reg

th

apply for VA benefits. For example, officials at one regional office we 

contacted said veterans applying for certain types of benefits are also 

referred to SSA.31 However, according to officials at two of the sites we

contacted, they generally do not provide any SSA literature or work wi

SSA personnel in local outreach efforts such as VA’s Stand Down event 

and its Welcome Home event.32 When wounded warriors ask about SSA at

these outreach events, regional office officials said they will generally 

respond by providing SSA’s phone number. 

d

A Number of Challenges 

Affect Agencies’ Outreach 

Efforts to Wounded 

Warriors, Especially for 

Those with TBI and PTSD 

31When veterans apply for pension benefits at this office, VA staff ask them if they are 

receiving SSA benefits, because eligibility for VA’s pension program is affected by receipt 

of income from other sources. If a veteran is not receiving SSA benefits, VA staff may refer 

the veteran to SSA. VA’s pension benefits are available to veterans who have low incomes 

and are either aged or have a disability that is not related to military service. 

32VA’s Welcome Home program are events that provide information on VA’s health and 

benefit services, services from the OEF/OIF program, and other supportive services. Stand 

Down events provide services to homeless veterans such as food, shelter, clothing, health 

screenings, VA and SSA benefits counseling, and referrals to other services. 

Page 29 GAO-09-762 Social Security Disability
 

their recovery. Some may not have yet accepted the severity of their 

injuries, while others have physical or psychological conditions tha

not stabilized. Case managers told us the timing of when they inform 

wounded warriors about SSA disability benefits is therefore determined on

a case-by-case basis. Based on our survey, we estimate that the timing of 

when wounded warriors first learned about SSA disability benefits varie

widely, with 44 percent reporting they first heard about the benefit 12

months or longer after injury (see fig. 10). 

Figure 10: Estimated Length of Time for Wounded Warriors to First Learn about 

t have 

d 

SSA Disability Benefits After Onset of Medical Condition 

0

10

20

30

40

50

60

70

80

90

100

Source: GAO survey of wounded warriors who applied for SSA benefits during fiscal year 2008.

Percentage

15% 9%

15%

7%

44%

9%

6 months

less than From 3 to

9 months

less than From 6 to

or more 12 months

remember Do not

12 months

less than

Le

From 9 to

ss than

3 months

Note: Error bars display 95 percent confidence intervals for estimates. 

It was also suggested by case managers and some recovering 

servicemembers that wounded warriors may be hesitant to apply for SSA 

benefits because of misinformation about SSA disability benefits given by 

their colleagues. Wounded warriors were just as likely to first hear about 

 DOD or VA case 

anagers, according to our survey estimates (see fig. 11). Moreover, both 

SSA disability benefits from their peers as from their

m

wounded warriors and agency officials told us that the information about 

SSA benefits that gets passed among military personnel is not always 

accurate. For example, some recovering servicemembers said their peers 

Page 30 GAO-09-762 Social Security Disability
 

had told them they would not qualify for SSA disability benefits and others

said they had heard that in order to avoid paying retroactive benefits, S

initially denies benefits to servicemembers who have been hospitalized for

long periods of time. 

Figure 11: How Wounded Warriors’ First Learned of SSA Disability Benefits 

SA 

(Estimated) 

0

10

20

30

40

50

60

70

80

90

100

Source: GAO survey of wounded warriors who applied for SSA benefits during fiscal year 2008.

Percentage

Another

servicemember

DOD

VA

personnel

personnel

Family

SSA

representative

Other

Internet

11% 8% 8% 2%

20%

27% 25%

Note: Error bars display 95 percent confidence intervals for estimates. 

Another challenge with regard to wounded warriors applying for SSA 

disability benefits is reported to be the benefit application itself, which 

reflects civilian more than military careers. At some of the sites we 

contacted, case managers and wounded warriors themselves said it was 

difficult for wounded warriors to complete the employment section of the 

pplication because it does not take into account, for example, the 

res 

ed 

anding 

a

difference between a civilian 8-hour day and military duty, which requi

a 24-hour obligation. Of all the aspects of the application process we ask

about in our survey, wounded warriors most often reported underst

the SSA application to be difficult (see fig. 12). 

Page 31 GAO-09-762 Social Security Disability
 

Figure 12: Difficulties Wounded Warriors Had with Completing the SSA Disability 

Benefits Application 

Source: GAO survey of wounded warriors who applied for SSA benefits during fiscal year 2008.

0

10

20

30

40

50

60

70

80

90

100

Percentage

28%

49%

40%

32% 30%

22%

15%

understanding

understanding

SSA application

SSA letters

Difficulty in

Difficulty in

understanding how

SSA could impact other benefits

Difficulty in

maintaining

contact with SSA

Difficulty in

obtaining

medical records

Difficulty in

making initial contact with SSA

Difficulty in

receiving mail at DOD or VA hosipital

Difficulty in

Agency officials told us that in addition to the above challenges, TBI and 

PTSD— signature disabilities of the recent conflicts—can further 

challenge their outreach efforts and may contribute to some wounded 

warriors applying a number of months after disability onset. According to 

one DOD official, these conditions tend to impede wounded warriors’ 

an have 

ds. 

 this 

nd 

 who have yet to be diagnosed with TBI and PTSD are not 

ability to absorb and retain information. Some agency officials and 

wounded warriors also told us that individuals with TBI or PTSD c

trouble going to SSA offices as they have become anxious around crow

Also, some wounded warriors we interviewed found SSA’s benefits 

application to be lengthy and complex and became frustrated trying to

complete it. In addition, agency officials and wounded warriors said

population may also forget to complete the application, due to a short 

attention span. 

Finally, outreach efforts face an elusive target at times, given that TBI a

PTSD are conditions that are not necessarily diagnosed early and that can

develop months or years later. According to some agency officials, 

servicemembers

Page 32 GAO-09-762 Social Security Disability
 

likely to receive information on all of the services, programs, or benefits to 

which they could be entitled. Several agency officials reported they have 

challenges in diagnosing TBI and PTSD, because these conditions ar

often not as clearly apparent as some other physical disabilities. Wounded 

warriors also may not realize they have these conditions and as such, may 

not have sought out medical attention. A RAND study reported that 57 

percent of wounded warriors who probably have undiagnosed TBI had

been evaluated by a physician for brain injury.

e 

 not 

ses in the transfer of DOD 

medical records to SSA can prolong decision-making for some cases. SSA 

as established a nationwide policy requiring its district offices, the state 

d 

use 

 any servicemember 

wounded, injured, or taken ill during military service since October 1, 

001, regardless of whether the disabling event occurred domestically or 

as 

ed 

 

33

SSA has expedited the processing of wounded warrior benefit claims, with 

assistance from VA and DOD; however, weaknes

Social Security Disability

h

DDS offices, hearing offices, and the Appeals Council to give priority to 

wounded warrior claims. For its part, DOD has worked with SSA by 

sharing wounded warriors’ key identification information that SSA can use

to target their claims for expedited processing. VA has also worked with 

SSA to accelerate information sharing to DDS offices. However, wounde

warrior claim decisions can still be prolonged in some instances beca

of challenges in receiving DOD medical records. DOD medical records are 

transferred to SSA as paper documents, a process which can take weeks 

or months, according to DDS officials. Although DOD stores some medical

records electronically, DOD and SSA have not developed the capacity for 

DOD to transfer its records electronically to SSA. 

Since 2005, SSA has identified wounded warrior applicants for the purpose

of expediting their claims. SSA attempts to identify

2

overseas. In order to give priority to these cases, SSA identifies wounded 

warriors in two ways. First, starting in 2005, applicants can self identify 

a wounded warrior when submitting the disability application. SSA add

questions on its disability claims application to enable servicemembers or

veterans to identify themselves as having served in the military and to 

indicate their dates of service. Secondly, in a 2008 memorandum of 

understanding, DOD agreed to send weekly electronic updates to SSA with

the key identification information of servicemembers who were wounded, 

SSA Is Expediting 

Wounded Warrior 

OD 

OD 

-

OD 

and VA, SSA Has Taken 

Steps to Expedite 

Claims With 

Assistance From D

and VA, but The 

Transfer Of D

Medical Records Can 

Prolong Decision

Making 

With Assistance from D

Wounded Warrior Claims 

33RAND Corporation, Invisible Wounds of War, 23. 

Page 33 GAO-09-762 
 

injured or became ill in the OEF/OIF theaters, to further assure that 

military applicants are identified. Any applicant is automatically iden

as a wounded warrior if their name appears on the DOD list. 

The agency requires that its district offices, DDS offices, and hearing

offices give priority to wounded warrior claims. SSA uses a process 

originally developed to expedite terminally ill (critical) case a

tified 

djudication 

for all wounded warrior disability claims. For such cases, SSA staff who 

hin 3 

n, 

 the different stages of the disability 

determination process, including appeals. One SSA regional office, for 

n 

s 

ssarily 

DS staff, including information about TBI and PTSD. According 

 

receive a disability claim request via SSA’s toll free phone number are

required to schedule an applicant interview at an SSA field office wit

working days, if possible, to take the full application.34 Then the SSA field 

office refers the application to a state DDS office for review, and follows 

up within 7 days to ensure receipt by the DDS system. DDS staff, in tur

are required to prioritize wounded warrior cases, by considering them as 

early as possible. Moreover, DDS staff are instructed to comprehensively 

consider these cases by exploring all potential physical and mental 

impairments, including those that may be suggested by any of the medical

evidence, such as signs of PTSD. Lastly, as with critical cases, SSA staff at

the hearing stage are required to schedule wounded warrior cases in the 

first available open hearing slots. 

Additionally, SSA and DDS offices track and monitor wounded warrior 

cases to ensure that they receive expedited handling. SSA’s regional 

offices track these claims through

example, generates reports listing all wounded warrior cases, including 

the level of adjudication for each claim and its status. Also, officials i

some DDS offices told us that they generate reports on processing time

specifically for wounded warrior cases, such as reports that list the 

pending wounded warrior cases, which may include other details of the 

claim. Officials in one DDS office stated that they monitor all wounded 

warrior cases at specific intervals after they have been received from 

SSA—30 days, 45 days, and 90 days—to ensure cases are not unnece

delayed. 

To support agency processing of wounded warrior cases, SSA officials

reported that they have created specific training and briefing materials for 

SSA and D

34For nonpriority claims, SSA staff are instructed to offer an applicant the first available 

appointment. 

Page 34 GAO-09-762 Social Security Disability
 

to an SSA official, the agency provided on-site training at local offices a

through videoconferences, and instructed staff to be alert to reported 

symptoms that may be related to TBI and PTSD. The SSA official told us 

that within DDS offices, all disability examiners received some training on 

TBI and PTSD. In addition to training, SSA reported that it provides 

training materials and guidance for staff to use when handling wounded 

warrior cases. For example, SSA issued guidance in August 2007 that cites 

indicators of possible TBI conditions, such as exposure to an improv

explosive device blast, a motor vehicle accident, or a fall. This policy also

specifies clinical markers, such as the loss of consciousness for more than 

6 hours following traumatic brain injury. At several DDS offices, DDS staff

reported that they received training material from SSA on TBI and PTSD. 

Finally, SSA issued guidance and reminders to staff on the proper 

treatment of wages for active duty soldiers. 

In spite of their wounded warrior training, all of the nine DDS offic

contacted reported difficulties, for several re

nd 

ised 

es we 

asons, in making 

determinations on TBI and PTSD cases. First, though officials at almost all 

ilities, this 

re 

ding 

taff 

If a 

 

the DDS offices we spoke with reported that DOD and VA records 

generally provide enough information regarding physical disab

is not necessarily the case regarding psychological problems. The DDS 

officials told us that, consequently, they generally need to order mo

consultative exams35 to assess potential cases of TBI or PTSD. Secondly, 

some DDS officials also reported that servicemembers sometimes ask 

them not to include a diagnosis of TBI or PTSD in their records. Accor

to officials in two of these DDS offices, servicemembers have either been

reluctant to discuss symptoms of PTSD with DDS staff, or asked DDS s

not to pursue a mental health disability claim. Finally, because PTSD and 

in some cases, TBI, may take several months to manifest, and because 

these conditions may improve over time, officials in some DDS offices said 

it can be difficult to determine whether they meet the 12-month duration 

requirement.36 To address this challenge, SSA has a specific TBI policy: 

TBI disability determination is not possible within 3 months of injury, SSA 

and DDS staff are required to defer adjudication until at least 3 months 

35A consultative exam is a medical examination, performed by a physician at SSA or DDS’ 

request, to gather additional information to enable DDS examiners to make a determination 

on a claimant’s medical condition. 

36To qualify for SSA benefits, a claimant’s condition must have lasted or be expected to last 

for 12 consecutive months. 

Page 35 GAO-09-762 Social Security Disability
 

after injury, and may defer again until at least 6 months after injury, in 

order to observe and evaluate the claimant’s condition. 

Given these challenges, eight of the nine DDS offices we visited had 

assigned specific, experienced examiners to process wounded warrior 

n 

g. 

t 

 to 

, 

other 

 and 

r expedite claims processing for wounded warriors, SSA has 

worked with VA to improve the quality of and speed with which VA 

 of 

rdized 

ch 

e 

e 

claims. An SSA official stated that those DDS examiners who focus o

wounded warrior cases—ranging between three and five specialists at 

each of several DDS offices we visited—received more extensive trainin

These officials reported employing special techniques for working with

wounded warriors. For example, some officials told us they can draw 

conclusions from pieces of evidence in DOD and VA medical records tha

indicate possible PTSD or TBI, and then collect additional information

make a determination regarding the presence of those conditions, even if 

such conditions have not been officially diagnosed. Also, an official in one

DDS office reported that she looks at the VA disability evaluation decision

when available, for useful information about an applicant’s medical 

condition; though officials in that office and several others said VA’s actual 

disability decisions do not affect their own determinations. Further, 

officials told us they work aggressively to obtain medical records from the 

VA, DOD, or private medical facilities. Officials in one DDS office said they

conduct a special review of any wounded warrior claim that is going to be 

denied to ensure that all the evidence was considered appropriately. 

Lastly, because wounded warrior claimants may take more time to 

respond to information requests, one DDS official typically gives them

more time, and will do more to track down their needed information

records. 

To furthe

forwards veterans’ medical records to the DDS offices. According to an

SSA official, due to DDS concerns about the timeliness and condition

VA medical records, SSA and VA began to work together in 1999 to 

improve data sharing. A period of pilot testing resulted in the creation of 

the Standard Summary, which is an electronic extraction of a standa

set of pertinent medical records from a patient’s overall records that is 

transmitted electronically to DDS offices upon request. In 2006, VA issued 

a directive to formalize use of the Standard Summary by VA medical 

facilities. Generally, the Standard Summary includes 2 years of patient 

health information and 4 years of major exams and patient discharge 

summaries. Specifically, the Standard Summary includes information su

as the onset dates of all known health problems for a patient, the futur

clinic appointments scheduled for a patient with VA providers, and all 

outpatient medical visits. (See app. IV for a list of elements included in th

Page 36 GAO-09-762 Social Security Disability
 

Standard Summary.) In order to establish usage of the Standard Summa

the appropriate local VA staff are encouraged to work with local DDS staff 

to enter an agreement and ensure that their computer systems are 

compatible. Individual DDS offices may also work with VA hospitals to 

tailor the data extracted by the Standard Summary for their needs. 

official told us that, as of June 2009, roughly 75 percent of VA hospitals 

nationwide were using the Standard Summary to send information to DDS 

offices. 

Accordin

ry, 

An SSA 

g to many DDS officials we interviewed, use of the Standard 

Summary has accelerated VA’s responses to DDS requests and made it 

y 

ion. 

an 

 an increasing number of wounded warrior 

applications, SSA has handled these applications more quickly than those 

rom 

e, in 

g 

 

somewhat easier to review VA records. Although not all sites nationall

are using the Standard Summary, most of the DDS offices we visited 

reportedly were using it. DDS officials in several offices reported that 

generally, the Standard Summary contains relevant or useful informat

Also, officials in several DDS offices told us that their receipt of VA’s 

electronic transfer of medical records via the Standard Summary averages 

1 to 2 weeks after the request is made, a significantly shorter period th

before it was used. 

Over time, even with

from the general public. Since fiscal year 2004, the median time f

application to initial decision for wounded warriors’ DI claims has been 

consistently faster than for other DI claims.37 (See fig. 13.) For exampl

fiscal year 2008, the processing time was 84 days for wounded warriors, 

compared to 101 days for all DI applicants. Since it was implemented in 

2005, SSA’s expedited procedures may have helped to make the processin

faster over time for wounded warriors. 

37Because there were so few wounded warrior SSI applications that progressed to the DDS 

level for medical evaluation during 2001 to 2008, we decided to focus our analysis on 

wounded warriors’ DI processing times only. 

Page 37 GAO-09-762 Social Security Disability
 

Figure 13: Median Days from Application to Initial Decision for Wounded Warriors’ 

DI Claims Versus All DI Claims 

0

20

40

60

80

100

120

All DI claims

Wounded warrior DI claims

2003 2004 2005 2006 2007 2008

Median days

Source: GAO analysis of SSA data.

Fiscal year

88

92 94

80 84

88

75

92

102

107 104 101

Note: These cases represent claims decided by SSA during each fiscal year. The number of 

wounded warrior cases decided per year has risen steadily from fiscal year 2003 (72 cases) to fiscal 

year 2008 (8,593 cases). 

Delays in Obtaining DOD 

Records Can Slow SSA’s 

Eligibility Determinations 

Wounded warrior claim decisions are prolonged in some instances 

because of difficulties in obtaining DOD medical records, most DDS 

officials reported. Generally, DOD military treatment facilities (MTF) 

provide paper-based records to DDS offices. Many of the DDS offices we 

visited reported lengthy wait times—ranging from a few weeks to a few 

months—to receive paper records from MTFs. Corroborating this point, 

DOD case managers at several MTFs also reported delays in obtaining 

wounded warrior medical records. Several DDS officials we spoke with 

said such delays can slow down the disability determination process. DDS 

staff in some locations reported that local MTFs had made efforts to 

reduce these delays. For example, an official in the Texas DDS office 

noted that the Carl R. Darnall Army Medical Center and Brooke Army 

Medical Center (the local MTFs) agreed to allow a DDS staffer onsite full 

time in the records office to respond to DDS medical record requests. At 

Page 38 GAO-09-762 Social Security Disability
 

several other DDS offices, staff reported that local MTFs responded to 

their requests for faster records response by designating a point of contact 

to handle all DDS requests, which has improved response time. 

Decision making can also be affected by the cumbersome nature of DOD 

records. Many DDS staff said DOD records are lengthy, and can number 

hundreds, if not thousands, of pages. They also noted that some medical 

documents that are referenced in the records are missing when received 

by DDS offices, or can sometimes be redundant. 

DOD has, in recent years, begun to computerize military medical records 

and make them transferable to VA, in part due to a recent statutory 

requirement. According to DOD officials, DOD currently stores certain 

types of information—such as patient consultations and evaluation 

notes—in electronic medical records at 21 MTFs, representing more than 

half of DOD’s inpatients. The agency is working toward storing more 

records electronically. Furthermore, after a 10 year joint effort, DOD is 

transferring some medical records electronically to VA. For example, since 

January 2009, DOD and VA have been electronically exchanging drug 

allergy information on more than 27,000 shared patients. Ultimately, better 

exchange of electronic medical records could allow servicemembers to 

transition seamlessly between the two departments with a single, 

comprehensive medical record. In part, DOD and VA’s electronic records 

exchange is spurred by recent legislation. Congress has mandated that 

DOD and VA jointly develop and implement, by September 30, 2009, 

electronic health record systems or capabilities that are fully 

interoperable38 and comply with applicable federal interoperability 

standards.39

By comparison, DOD and SSA’s electronic exchange efforts are far less 

developed. An SSA official told us the agency would like to work with 

DOD to develop some mechanism for obtaining medical records 

electronically. For their part, DOD officials also expressed interest in 

working with SSA to resolve the issue of electronic records transfer. 

Nevertheless, the agencies have no formal plans to do so. SSA and DOD 

have told us that one approach for sharing records electronically could be 

through the Nationwide Health Information Network (NHIN), an emerging 

 

38Interoperability is the ability of two or more systems or components to exchange 

information and to use the information that has been exchanged. 

39Pub. L. No. 110-181, § 1635 (2008). 

Page 39 GAO-09-762 Social Security Disability
 

new federal technology. 40 Although SSA, DOD, and VA are all participating 

in this technology initiative, the NHIN is still under development in a pilot 

testing phase. 

Wounded warriors with severe disabilities, who have made significant 

sacrifices in the line of duty, may face challenges in supporting themselves 

financially. Disability benefits available through SSA can be a critical part 

of the financial assistance they receive. Congress has required that DOD 

and VA help wounded warriors gain access to the benefits and services 

they need, including SSA disability benefits, and to consult with other 

relevant federal agencies in doing so. Outreach to wounded warriors about 

SSA benefits has, in fact, been stepped up since 2007, particularly by SSA 

and DOD in several key sites where there has been a well-coordinated 

message reinforced by each agency. These efforts may well have 

contributed to the substantial increase in wounded warrior applications 

for SSA disability benefits since 2007. Certainly, significant challenges 

remain to reaching those warriors who are currently being discharged, as 

evidenced by the numbers who have reported to us difficulties with the 

SSA benefit application, or the fact that nearly one in four of those with 

approved claims has foregone retroactive benefits because they did not 

apply soon enough after their injury. The sooner that SSA completes its 

analysis of whether a legislative fix to the retroactive benefits formula is 

warranted, the sooner this information can be brought to the Congress for 

consideration. 

Conclusions 

While VA has also taken steps to help wounded warriors who have 

become veterans, collaboration between VA and SSA at VA medical 

centers has not been consistent. Furthermore, VA does not provide its 

claims processing staff with any guidance on referring veterans to SSA 

when they apply for veterans’ benefits. Yet the risk of not reaching 

wounded warriors is greater once they are discharged and re-enter civilian 

life. Absent a commensurate level of outreach on the part of VA and SSA, 

it seems likely that some veterans who are, in fact, severely disabled, will 

not receive all the financial support to which they are entitled. Of 

particular concern are veterans discharged prior to 2007—when the focus 

on outreach increased—and those with impairments such as PTSD and 

 

40The Department of Health and Human Services is coordinating the NHIN. The agency is 

advancing the NHIN as a “network of networks”, which will connect diverse entities—such 

as federal agencies and health care providers—to exchange patients’ health information. 

Page 40 GAO-09-762 Social Security Disability
 

TBI, which may emerge after discharge from the military. While not all 

veterans rated as 100 percent disabled by DOD or VA will necessarily be 

eligible for SSA benefits, the fact that more than one-third of these 

severely disabled veterans have not even applied for SSA disability 

benefits suggests there is more to be done in this area. 

Finally, SSA policies for accelerating the processing of wounded warrior 

applications appear to have had a positive effect. Yet some wounded 

warriors will still experience a long wait for an eligibility determination if 

their DOD medical records are slow to be transferred. The inability of 

DOD and SSA to share records electronically undermines SSA’s ability to 

fully expedite the process. Yet SSA and DOD lack a strategy for integrating 

their systems to enable such transfers. Fortunately, electronic records 

exchange is an issue that has attention across a number of federal 

agencies, and current technology initiatives may present models for DOD 

and SSA to consider using. 

To improve wounded warriors’ access to SSA disability benefits, we are 

making the following recommendations: 

1. The Commissioner of Social Security should move ahead with his 

consideration of the need for a legislative proposal to amend the DI 

program’s retroactive benefit period for wounded warriors, given the 

unique challenges faced by this population in applying for benefits in a 

timely manner. 

Recommendations for 

Executive Action 

2. The Secretary of Veterans Affairs and the Commissioner of Social 

Security should work together to improve outreach to veterans on SSA 

disability benefits. In doing so, the VA and SSA should, in particular, 

seek to reach veterans who either were discharged between 2001 and 

2007; have disabilities that manifest after service such as PTSD; or 

were assigned a 100 percent disability rating. Specific actions that VA 

could take include issuing guidance to VA medical centers and regional 

offices for referring veterans to SSA and including information about 

SSA disability benefits in VA’s phone outreach campaign to OEF/OIF 

veterans. In addition, SSA could work with VA to ensure stronger 

coordination between local SSA offices and VA medical facilities, for 

example by making sure that VA medical centers have a point of 

contact at a local SSA office or receive training from SSA staff on SSA 

benefits. 

3. The Secretary of Defense and the Commissioner of Social Security 

should work together to better meet SSA’s need for obtaining military 

medical records in a timely manner for processing DI and SSI 

Page 41 GAO-09-762 Social Security Disability
 

Page 42 GAO-09-762 Social Security Disability 

applications from wounded warriors. This effort should consider how 

to ensure records that are stored electronically are also electronically 

transferable. 

We provided a draft of this report to the Secretary of Defense, the 

Secretary of Veterans Affairs, and the Commissioner of Social Security for 

review and comment. In their comments, SSA and VA agreed with our 

findings and recommendations and noted actions they plan to take to 

address our recommendations. For example, SSA indicated that it plans to 

move ahead with a legislative proposal to amend the disability benefit 

retroactive period for wounded warriors, and VA indicated that VBA 

officials plan to meet with SSA officials to discuss how the two agencies 

can ensure that veterans receive information about SSA disability benefits. 

DOD provided no formal comments. All three agencies also provided 

technical comments, which were incorporated as appropriate. SSA’s and 

VA’s comments are reproduced in appendices V and VI. 

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

this report early, we plan not to further distribute until 30 days from the 

report date. We are sending copies of this report to the Secretary of 

Defense, the Secretary of Veterans Affairs, the Commissioner of Social 

Security, relevant congressional committees, and others who are 

interested. We will also provide copies to others on request. The report is 

also available at no charge on GAO’s Web site at http://www.gao.gov/. 

Please contact me at (202) 512-7215 or bertonid@gao.gov if you or your 

staff have any questions about this report. Contact points for the Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. Key contributors are listed in appendix VII. 

Daniel Bertoni 

Director, Education, Workforce, and Income Security Issues 

Agency Comments 
Appendix I: 

Methodology 

Objectives, Scope, and 

Page 43 GAO-09-762 

Appendix I: Objectives, Scope, and 

Methodology 

We were asked to examine (1) the number of wounded warriors who have 

applied and been approved for Social Security Administration (SSA) 

disability benefits, and the extent to which wounded warriors who receive 

Department of Defense (DOD) or Department of Veterans Affairs (VA) 

disability benefits also receive SSA benefits; (2) the extent to which SSA, 

DOD, and VA have worked to inform wounded warriors about and help 

them apply for SSA disability benefits, and the challenges that confront 

this outreach effort; and (3) whether the agencies have taken any steps to 

facilitate the processing of wounded warriors’ SSA disability benefit 

claims. In addressing these questions, we have focused our research on 

wounded warriors who have become wounded, injured, or ill while in 

active duty since 2001. More specifically, to answer the questions, we 

reviewed policy and other documents from SSA, DOD, and VA and 

interviewed officials responsible for outreach or case management 

policies at each agency. We also interviewed officials from several 

organizations that represent veterans, including Disabled American 

Veterans, Paralyzed Veterans of America, Vietnam Veterans of America, 

and the United Spinal Association. To learn about agencies’ efforts at the 

local level, we interviewed staff—and sometimes recovering 

servicemembers—at a number of DOD and VA medical facilities, SSA field 

offices, Disability Determination Services (DDS) offices, and VA regional 

offices. We obtained and analyzed administrative data from SSA, DOD, and 

VA on wounded warriors’ utilization of financial benefits from all three 

agencies. Finally, we conducted a mail survey of wounded warriors who 

had applied for SSA disability benefits during fiscal year 2008. We 

conducted this performance audit from March 2008 through September 

2009 in accordance with generally accepted government auditing 

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

obtain sufficient, appropriate evidence to provide a reasonable basis for 

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

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

Interviews with Local Staff 

and Recovering 

Servicemembers 

To learn about local efforts by SSA, DOD, and VA to conduct outreach to 

wounded warriors and facilitate claims processing, we selected 12 sites 

where wounded warriors receive medical care—7 DOD medical treatment 

facilities (MTF) and 5 VA medical centers (see fig. 14). We selected these 

locations based on several factors. First, we selected the four military 

treatment facilities that serve most of the severely wounded 

servicemembers: Walter Reed Army Medical Center, National Naval 

Medical Center (Bethesda), Naval Medical Center San Diego, and Brooke 

Army Medical Center. We also selected two of the four VA polytrauma 

 Social Security Disability 
Appendix I: Objectives, Scope, and 

Methodology 

centers that serve severely wounded servicemembers and veterans: VA 

Palo Alto Health Care System and Hunter Holmes McGuire VA Medical 

Center. We then selected additional sites (1) that are in regions of the 

country where varying numbers of wounded warriors had SSA disability 

benefit claims pending between July 2007 and March 2008, (2) that have 

varying numbers of recovering servicemembers in affiliated Army warrior 

transition brigades, and (3) that according to SSA have varying levels of 

collaboration with local SSA offices. 

Page 44 GAO-09-762 Social Security Disability
Appendix I: Objectives, Scope, and 

Methodology 

Figure 14: Locations Contacted During Study 

Florida

Louisiana

Mississippi

Georgia Alabama

South

Carolina

Arkansas

Texas

North Carolina Tennessee

New Mexico

Arizona Oklahoma

Kentucky

Virginia

Maryland

Delaware

Kansas District of Columbia Missouri

West

Virginia

Colorado

New Jersey

Indiana Ohio

Nevada

Utah

California

Connecticut Rhode Island

Pennsylvania

Illinois

Massachusetts

Nebraska

Iowa

Wyoming New York

Vermont

New

Hampshire

Michigan

South Dakota

Oregon

Wisconsin

Maine

North Dakota

Idaho

Montana

Washington

Minnesota

12

10

3

5

2

1 11

6 8

4

9

7

1

2

3

4

5

Carl R. Darnall Army Medical Center

Evans US Army Hospital, Fort Carson

Camp Pendleton Naval Hospital

National Naval Medical Center

Naval Medical Center San Diego

6

7

8

9

10

11

12

Brooke Army Medical Center

Walter Reed Army Medical Center

Audie L. Murphy VA Hospital

Fayetteville VA Medical Center

Hunter Holmes McGuire VA Medical Center

Olin E. Teague Veterans’ Center

VA Palo Alto Health Care System

Sources: GAO analysis; Map Resources (map).

At the selected locations, we conducted on-site or telephone interviews 

with a range of local staff from different agencies. We spoke with DOD and 

VA case managers, hospital management staff, VA liaisons, and medical 

records personnel about their practices for informing wounded warriors 

about SSA benefits, helping them apply, or both. At almost every site we 

Page 45 GAO-09-762 Social Security Disability
Appendix I: Objectives, Scope, and 

Methodology 

also contacted the SSA district offices and DDS offices that serve the 

medical facility. At the SSA and DDS offices, we spoke with office 

managers and other staff, including public affairs staff, claims examiners, 

and claims representatives about their practices for informing wounded 

warriors about SSA benefits, helping them apply, and processing wounded 

warrior claims. 

At five of the MTFs we also held discussion groups with recovering 

servicemembers to learn about their experiences in hearing about and 

applying for SSA disability benefits. We interviewed a total of 45 

servicemembers and 1 veteran at these five sites. At each of these sites, we 

asked MTF personnel to identify servicemembers who were wounded, ill, 

or injured since October 2001 and had applied, or were in the process of 

applying, for SSA benefits. See table 2 for the list of offices we contacted. 

Table 2: Local Offices Contacted 

DOD or VA medical 

facilities selected 

SSA district offices 

serving DOD or VA 

medical facilities 

DDS offices serving DOD 

or VA medical facilities 

Carl R. Darnall Army Medical 

Center (Fort Hood, Texas 

Temple, Texas Austin, Texas 

Evans US Army Hospital 

(Colorado Springs, 

Colorado) 

Colorado Springs, Colorado Denver, Colorado 

Camp Pendleton Naval 

Hospital 

(Camp Pendleton, California)

Oceanside, California San Diego, California 

La Jolla, California 

National Naval Medical 

Center (Bethesda, Maryland)

Silver Spring, Maryland District of Columbia 

Fairfax, Virginia 

Naval Medical Center San 

Diego (San Diego, 

California) 

San Diego (Front Street), 

California 

Kearney Mesa, California 

La Jolla, California 

Brooke Army Medical 

Center (San Antonio, Texas 

San Antonio (East 

Durango), Texas 

Austin, Texas 

Walter Reed Army Medical 

Center (District of Columbia) 

Shepherd Park, Maryland District of Columbia 

Fairfax, Virginia 

Audie L. Murphy VA Hospital 

(San Antonio, Texas) 

n/aaAustin, Texas 

Fayetteville VA Medical 

Center 

(Fayetteville, North Carolina)

Fayetteville, North Carolina Raleigh, North Carolina 

Page 46 GAO-09-762 Social Security Disability
Appendix I: Objectives, Scope, and 

Methodology 

DOD or VA medical 

facilities selected 

SSA district offices 

serving DOD or VA 

medical facilities 

DDS offices serving DOD 

or VA medical facilities 

Hunter Holmes McGuire VA

Medical Center (Richmond, 

Virginia) 

Richmond, Virginia Richmond, Virginia 

Olin E. Teague Veterans’ 

Center 

(Temple, Texas) 

Temple, Texas Austin, Texas 

VA Palo Alto Health Care 

System (Palo Alto, 

California) 

Mountain View, California Roseville, California 

Source: GAO. 

a

We did not interview an SSA office that served the Audie L. Murphy VA Hospital. 

We also contacted three Veterans Benefits Administration (VBA) regional 

offices that administer VA disability compensation benefits—Atlanta, 

Georgia; Waco, Texas; and San Diego, California. We selected these 

locations based primarily on their proximity to DOD and VA sites we 

contacted. At these locations we spoke with VBA public liaisons or 

regional office management staff about their practices for informing 

discharged veterans about SSA benefits and helping them apply. 

Analysis of Administrative 

Data 

To examine wounded warriors’ utilization of SSA disability benefits, we 

obtained and analyzed administrative data from several SSA databases. We 

analyzed data from the electronic folder’s Structured Data Repository 

(SDR) on wounded warriors’ claims at the initial, reconsideration, and 

hearing stages of adjudication, including claimant demographic 

information, date of disability onset, date of application, primary 

diagnosis, and the decision on the claim. We analyzed data from the 

Master Beneficiary Record (MBR) on Disability Insurance (DI) claims that 

were denied for technical—nonmedical—reasons, including the 

application date and the reason for denial. We analyzed data from the 

Supplemental Security Record (SSR) on Supplemental Security Income 

(SSI) claims that were denied for technical reasons, again including 

application date and reason for denial. Finally, we used data from SSA’s 

831 file to analyze the elapsed time from application date to DDS decision 

date, both for wounded warriors and for SSA’s overall DI and SSI 

caseloads. SSA provided us with data on all applicants who have been 

flagged in its systems as wounded warriors. Applicants have been flagged 

as wounded warriors when they self-identify (since 2005) or when they 

appear on a list of wounded warriors provided weekly by DOD (since 

2008). In addition, SSA identified wounded warriors who appear on the 

Page 47 GAO-09-762 Social Security Disability
Appendix I: Objectives, Scope, and 

Methodology 

DOD list—which is cumulative and includes those wounded in Operation 

Enduring Freedom (OEF) and Operation Iraqi Freedom (OIF)1

—but who 

applied prior to 2008, when SSA started using this list to flag applicants. To 

assess the reliability of these SSA data, we reviewed agency documents, 

interviewed agency officials, and performed electronic testing of certain 

data. We found several limitations with the data, including the lack of 

complete data on claims at the Appeals Council and federal court stages of 

adjudication, and unreliable application date data for claims beyond the 

initial stage. However, we found the data we used to be sufficiently 

reliable for our reporting objectives. 

In addition, to determine the extent to which wounded warriors receiving 

DOD or VA disability benefits also receive SSA disability benefits, we 

obtained data from DOD and VA and asked SSA to match these data 

against its databases. DOD provided us with monthly data from the Retired 

Pay File for the period January 2000 to September 2008, on individuals 

who were first on the Temporary Disability Retired List (TDRL) or 

Permanent Disability Retired List (PDRL) in January 2000 or later. These 

data included the individuals’ social security numbers, DOD disability 

rating, and monthly benefit amount received. We created a customized file 

of DOD data by extracting the data only for those individuals who were on 

the TDRL or PDRL in July 2008 and first appeared on the TDRL or PDRL in 

November 2001 or later, i.e. who were in active duty in October 2001 or 

later. (The Retired Pay File does not include an indicator of whether an 

individual is disabled as a result of service in the OEF/OIF campaigns.) VA 

provided us with data from its VETSNET system on veterans receiving VA 

disability compensation benefits as of July 2008, who were identified in 

VETSNET as being OEF/OIF veterans. OEF/OIF veterans are identified by 

VA in two ways: (1) through a regular match of VA data with a Defense 

Manpower Data Center (DMDC) file containing the social security 

numbers of OEF/OIF veterans, and (2) by VA staff when they take 

disability benefit applications from veterans. The data file provided by VA 

included veterans’ social security number, disability ratings,2

 and benefit 

amounts received in July 2008. We then asked SSA to match the social 

security numbers contained in the DOD and VA files against its MBR and 

 

1

According to DOD, this list is not definitive, but is the only available data it can provide to 

SSA. 

2

Veterans granted Individual Unemployability (IU) by VA were included in the data we 

analyzed, but there was no indicator in these data of which veterans were classified as IU. 

The data we used only indicated these veterans’ combined disability rating. 

Page 48 GAO-09-762 Social Security Disability
Appendix I: Objectives, Scope, and 

Methodology 

SSR databases, to determine whether these individuals had ever applied 

for SSA disability benefits and if they were receiving SSA benefits in July 

2008. To assess the reliability of the VA and DOD data, we interviewed 

agency officials, reviewed agency documents, and performed electronic 

testing of certain data. We found several limitations with the data, 

including the fact that those identified as OEF/OIF veterans in VA’s data 

may not include all veterans who served since 2001 and are receiving VA 

disability compensation benefits. However, we found the data we used to 

be sufficiently reliable for our reporting objectives. 

Survey of Wounded 

Warriors 

To learn about the experiences and opinions of wounded warriors who 

have applied for SSA disability benefits, we conducted a survey of a 

random sample of wounded warriors who had applied for SSA disability 

benefits during fiscal year 2008. We conducted this mail survey from 

December 2008 to March 2009. The survey included questions on topics 

such as how wounded warriors learned about SSA disability benefits, 

when they learned about SSA benefits, and what challenges, if any, they 

faced in completing the SSA application. 

To identify our sample of wounded warriors, we used SSA’s SDR, MBR, 

and SSR databases, which contain data on SSA applicants who have been 

identified as wounded warriors. We drew a random sample of 350 

wounded warriors out of a total universe of 10,438 wounded warriors who 

SSA’s databases indicated had applied for disability benefits in fiscal year 

2008. We considered respondents to be in scope for our survey if they had 

applied for disability benefits in fiscal year 2008 and had not separated 

from the military prior to 2001. 

Developing the Survey Sample 

Survey results based on probability samples are subject to sampling error. 

The sample is only one of a large number of samples we might have drawn 

from the respective population. Because each sample could have provided 

different estimates, we express our confidence in the precision of our two 

particular samples’ results as 95 percent confidence intervals. These are 

intervals that would contain the actual population values for 95 percent of 

the samples we could have drawn. As a result, we are 95 percent confident 

that each of the confidence intervals in this report will include the true 

values in the respective study populations. Unless otherwise noted, the 

margin of error for percentage estimates from this survey is plus or minus 

8 percentage points or less at the 95 percent level of confidence. 

Confidence Intervals in Survey 

Response and Nonresponse 

Bias Analysis 

Page 49 GAO-09-762 Social Security Disability
Appendix I: Objectives, Scope, and 

Methodology 

The overall response rate for our survey was 53 percent.3 To assess the 

potential for bias in our estimates, we used SSA administrative data to 

examine differences between the respondents and nonrespondents to our 

survey. Our analysis showed that respondents to our survey were typically 

older and more educated than individuals in our sample who did not 

respond to the survey; these differences were significant at the 95 percent 

confidence level. In light of these results, we conducted three separate 

sets of tests to compare individuals in different age and education 

categories. The first set of tests examined demographic and usage 

variables from the survey—that is, whether or not wounded warrior had 

received information or application assistance, or had taken certain steps 

in the course of completing the SSA disability application. The second set 

of tests examined wounded warriors’ opinions about sources of 

information or assistance and steps taken in the course of applying for 

benefits. The third set of tests examined item nonresponse for each item in 

the survey. Only two of the initial differences we observed persisted after 

adjusting for multiple comparisons.4

 First, we found that older 

respondents were more likely to have served in the Reserves or National 

Guard than their younger counterparts. However, we did not find any 

significant differences in demographics, usage of specific resources, 

opinions, or item nonresponse between respondents that served in the 

Reserves or National Guard and those that did not. Second, we found that 

college-educated individuals were more likely than those without a college 

degree to have found information from VA personnel helpful—of 

individuals with an opinion, 100 percent of college educated individuals 

found VA personnel to be very or somewhat helpful, compared to 76 

percent of those without a college degree. 

Our failure to detect systematic differences does not guarantee that our 

results are free from potential nonresponse bias; as with any survey, to the 

extent respondents differ from nonrespondents in undetected ways, our 

results should be interpreted with caution. However, with the exception of 

 

3

Our response rate was calculated using the American Association for Public Opinion 

Research’s response rate number three. Of 187 respondents to our survey, 4 respondents 

separated from the military prior to 2001 and 1 individual had applied for SSA retirement 

but not disability benefits; these five individuals were considered out of scope. 

Additionally, in the course of fielding our survey we discovered that 2 individuals in our 

sample were deceased; we treated these individuals as nonrespondents for the purposes of 

response rate calculations. 

4

These differences were significant at the 95 percent confidence level after an adjustment 

to account for the three different sets of tests we used. 

Page 50 GAO-09-762 Social Security Disability
Appendix I: Objectives, Scope, and 

Methodology 

the two items noted above, we were unable to detect large or systematic 

differences in the reported experiences and opinions of individuals in 

different age or education categories, and believe it is not misleading to 

generalize the results to the population of wounded warrior SSA disability 

applicants in fiscal year 2008. 

The practical difficulties of conducting any survey may also introduce 

other types of errors, commonly referred to as nonsampling errors. For 

example, difficulties in how a particular question is interpreted, in the 

sources of information that are available to respondents, or in how the 

data were entered into a database or were analyzed can introduce 

unwanted variability into the survey results. With this survey, we took 

steps to minimize these nonsampling errors. For example, GAO staff with 

subject matter expertise designed the questionnaires in collaboration with 

GAO survey specialists. Then the draft questionnaires were pretested with 

wounded warriors to ensure that the questions were relevant and clearly 

stated—with the purpose of reducing nonsampling error. When the data 

were analyzed, a second, independent GAO analyst independently verified 

all analysis. 

Efforts to Minimize 

Nonsampling Errors 

We took several steps to enhance our response rate. We resent the survey 

to nonrespondents after about 5 weeks, and conducted follow-up phone 

calls to nonrespondents encouraging them to complete the survey, with 

the option to complete the survey over the phone with GAO staff, after 

about 7 weeks. If in the course of our phone calling we learned a correct 

address, we sent another copy of the survey to the current address. These 

comprehensive nonrespondent follow-up efforts, as well as our 

nonresponse bias analysis, give us confidence that our overall survey 

results can be generalized to the population of wounded warriors applying 

for SSA disability benefits in fiscal year 2008. 

Efforts to Increase Response 

Rate for Survey of Wounded 

Warriors 

Important Outreach 

Practices 

We used a set of six important outreach practices as criteria for assessing 

the three agencies’ outreach to wounded warriors regarding SSA disability 

benefits: 

• outlining of strategic goals for the campaign and determination of a 

desired response; 

• identification and researching of the target audience to understand some 

of its key characteristics, such as size of the population, ethnic and racial 

composition, linguistic groups, geographic location, and awareness or 

knowledge of the outreach subject; 

Page 51 GAO-09-762 Social Security Disability
Appendix I: Objectives, Scope, and 

Methodology 

• establishment of strategic partnerships with other entities that are 

stakeholders in the issue to get help with planning and implementing the 

outreach campaign; 

• targeting of the outreach message with audience specific, culturally 

sensitive content and use of mediums and languages that are the most 

appropriate for the audience; 

• reinforcement of the message with repetition and different mediums, 

especially when targeting people who may be challenging to serve; and 

• development and implementation of measures for evaluating the 

effectiveness of the outreach campaign. 

We identified these practices through a review of prior GAO and external 

reports that addressed outreach campaigns primarily for social and 

employment programs. We also contacted several external organizations 

that have some expertise in outreach for social programs to obtain their 

feedback on the identified practices. Comments were received from the 

National Association of Social Workers and the National League of Cities, 

and these comments were incorporated into our final set of practices. 

Page 52 GAO-09-762 Social Security Disability
Appendix II: Summary of Major Disability 

Benefit Programs Available to Wounded 

Warriors 

 SSA VA DOD 

Purpose and 

target 

population 

DI: Replace lost income for workers 

under age 65 who have paid into 

Social Security but can no longer 

work because of a disability. 

SSI: Provide cash payments assuring 

a minimum income for aged, blind, or 

disabled individuals who have very 

limited income and assets. 

Disability compensation.

Compensate veterans for average 

reduction in earnings capacity due to 

their disabilities. 

Disability retirement. Provide 

financial support to servicemembers 

whose disabling conditions render 

them unable to perform their military 

duties. 

Eligibility 

criteria 

DI and SSI (adult disability).

Applicant is unable to perform 

substantial gainful activity due to 

condition, which is expected to last at 

least a year or to result in death. 

DI. Must have worked a minimum 

amount of time in employment 

covered by Social Security. 

SSI. Total earned and unearned 

countable income must be below the 

federal benefit rate. First $20 of 

unearned income and various types 

of public assistance are not counted. 

Also, must have less than $2,000 in 

countable resources for an individual. 

Applicant must be a veteran with a 

diagnosis of an injury or disease that 

is found to be disabling. Also, there 

must be evidence of an in-service 

occurrence or aggravation of the 

injury or disease. 

Servicemembers must have a 

permanent disability that renders 

them unfit to perform their military 

duties. Also, the injury must be 

connected to service in the military. 

Possible 

outcomes of 

eligibility 

determination 

Individuals are deemed disabled or 

not disabled. No percentage ratings 

or partial disability determinations. 

Claimant is assigned a rating for 

each service-connected disability 

based on the VA’s Schedule for 

Rating Disabilities (VASRD). Ratings 

range from 0 to 100 percent. 

Individual unemployability (IU) 

benefits provide certain veterans with 

compensation at the 100-percent 

level if their disabilities prevent them 

from working, even though their 

disability was rated below 100 

percent under the VASRD. 

Servicemembers are assigned a 

rating for each unfitting condition 

based on the VASRD, with ratings 

ranging from 0 to 100 percent. 

If the disabilities are deemed 

noncompensable, because they were 

not in the line of duty, 

servicemembers are separated 

without benefits. If servicemembers 

receive a disability rating of less than 

30 percent, they receive a lump sum 

payment upon separation. (If 

servicemembers have 20 or more 

years of service and a disability 

rating below 30 percent, they could 

still be eligible for disability 

retirement.) If servicemembers have 

a disability rating of 30 percent or 

greater, they will be separated from 

the military and receive monthly cash 

benefit payments (PDRL) unless 

conditions are not stable, whereas 

the servicemembers are placed on 

TDRL. 

Appendix II: Summary of Major Disability 

Benefit Programs Available to Wounded 

Warriors 

Page 53 GAO-09-762 Social Security Disability 
Appendix II: Summary of Major Disability 

Benefit Programs Available to Wounded 

Warriors 

 SSA VA DOD 

How benefits 

are calculated 

DI. Based on past average monthly 

earnings. 

SSI. Basic monthly payment is the 

same for all beneficiaries. This basic 

amount is reduced when beneficiary 

receives certain types of earned and 

unearned income. 

If the veteran is found to have one or 

more service-connected disabilities 

with a combined rating of at least 10 

percent, VA will pay monthly 

compensation. The benefits range by 

rating, with a higher rating resulting in 

greater compensation. Veterans with 

severe disabilities may be entitled to 

special monthly compensation, which 

provides payments greater than the 

compensation payable under the 

VASRD for the disability. 

If the unfitting disabilities are 

determined to be service-connected, 

DOD takes into account the years of 

service and the disability rating 

percentage. 

Disability 

determination 

process 

One of about 1,300 SSA field offices 

assesses a claimant’s nonmedical 

eligibility. If the claimant meets these 

criteria, a state DDS office evaluates 

the claimant’s medical eligibility. 

Claimants may appeal an initial DDS 

decision back to the DDS, then to an 

administrative law judge (ALJ), the 

SSA appeals council, and ultimately 

the federal court. 

One of VA’s 57 regional offices 

assesses eligibility and assists in 

obtaining relevant evidence to 

substantiate the claim. Such 

evidence includes veterans’ military 

service records (including medical 

records), medical examinations, and 

treatment records from VA medical 

facilities and private medical service 

providers. Claimants may appeal an 

initial VA decision to the Board of 

Veterans’ Appeals, then, ultimately, 

to different levels of federal courts. 

The servicemember goes through a 

medical evaluation board (MEB) 

proceeding, where medical evidence 

is evaluated, and potentially unfit 

conditions are identified. The 

member then goes through an 

informal physical evaluation board 

(PEB) process, where a 

determination of fitness or unfitness 

for duty is made and, if found unfit for 

duty, a combined percentage rating 

is assigned for all unfit conditions and 

the servicemember is discharged 

from duty. If servicemembers 

disagree with the informal PEB’s 

findings and recommendations, they 

can, under certain conditions, appeal 

to the formal PEB’s reviewing 

authority The services differ in how 

many opportunities they offer 

servicemembers to appeal.a

Source: GAO analysis. 

a

DOD and VA are piloting a joint disability evaluation system to improve the timeliness and resource 

use of DOD’s and VA’s separate disability evaluation systems. Key features of the pilot include a 

single physical examination conducted to VA standards as part of the MEB, and disability ratings 

prepared by VA, for use by both DOD and VA in determining disability benefits. 

Page 54 GAO-09-762 Social Security Disability
Appendix III: Complete Re

Warri

sults of Wounded

or Survey 

Page 55 GAO-09-762 

Appendix III: Complete Results of Wounded 

Warrior Survey 

Below are the questions on our survey of wounded warriors, followed by 

the breakdown of answers we received. We received a total of 182 

responses from wounded warriors. All answers are generalizable to the 

overall population of wounded warriors who applied for SSA disability 

benefits during fiscal year 2008, with a margin of error of plus or minus 8 

percent or less, except questions 6g and 7f. A nonresponse bias analysis 

revealed that older and college educated individuals were more likely to 

respond to our survey than their younger and less-educated colleagues, 

but did not reveal systematic differences in wounded warriors’ overall 

experiences and opinions in applying for SSA benefits. For a complete 

description of our survey methods and nonresponse bias analysis, see 

appendix I. 

Section 1: Information 

about your military service 

1. In what branch of the military do/did you serve? 

Air Force 7%

Army 73%

Marine Corps 11%

Navy 4%

Combination of two Services 5%

Note: 182 wounded warriors responded to this question. 

2. Are you now or were you at any point a National Guard or Reserve 

member? 

Yes, I am or was in the National Guard 37%

Yes, I am or was in the Reserves 11%

No 48%

Both National Guard and Reserves 4%

Note: 180 wounded warriors responded to this question. 

3. As of today, have you separated from military service? 

Yes, I am separated 70%

No, I am not separated 30%

Note: 181 wounded warriors responded to this question. 

 Social Security Disability 
Appendix III: Complete Results of Wounded 

Warrior Survey 

If so, in what year did you separate from military service? 

2003 2%

2004 7%

2005 11%

2006 15%

2007 20%

2008 44%

2009 3%

Note: 123 wounded warriors responded to this question. Totals may not equal 100 percent due to 

rounding. 

Section 2: How you 

learned about SSA benefits 

4. After you were wounded, injured, or became ill, how did you first learn 

about Social Security disability benefits? (Check only one answer) 

The Internet 2%

Another servicemember or separated 

servicemember 27%

Family member 11%

Social Security Administration representative 8%

DOD medical center or DOD personnel (for 

example, nurse case manager, social worker, 

AW2 Advocate, WTU or WWR squad leader) 25%

VA medical center or other VA personnel (for 

example, nurse case manager, social worker, 

benefits counselor) 20%

Other: please specify 8%

Note: 173 wounded warriors responded to this question. Totals may not equal 100 percent due to 

rounding. 

5. How long after you were wounded, injured, or became ill did you first 

learn about Social Security disability benefits? (Check one answer) 

Less than 3 months 15%

From 3 to less than 6 months 9%

From 6 to less than 9 months 15%

From 9 to less than 12 months 7%

12 months or more 44%

Do not remember 9%

Note: 181 wounded warriors responded to this question. Totals may not equal 100 percent due to 

rounding. 

Page 56 GAO-09-762 Social Security Disability
Appendix III: Complete Results of Wounded 

Warrior Survey 

6. After you first learned about Social Security disability benefits, how 

helpful, if at all, was any of the additional information you may have 

received about Social Security disability benefits from any of the 

following sources? (Check one answer in each row. If you did not 

receive any information from a source, check the first column.) 

Very 

helpful 

Somewhat 

helpful

Not 

helpful

Did not 

receive 

information 

from this 

source 

Not 

sure

Number of 

wounded 

warrior 

respondents

6a. The Internet 16% 24% 5% 54% 1% 172

6b. Another 

servicemember(s) 

or separated 

servicemember(s) 31% 25% 8% 34% 1% 172

6c. Family 

member(s) 15% 10% 7% 64% 4% 168

6d. Social 

Security 

Administration 

representative (s) 43% 21% 13% 22% 2% 174

6e. DOD medical 

center or other 

DOD personnel 

(for example, 

nurse case 

manager, social 

worker, AW2 

Advocate, WTU 

or WWR squad 

leader) 22% 17% 10% 49% 1% 174

6f. VA medical 

center or other 

VA personnel (for 

example, nurse 

case manager, 

social worker, 

benefits 

counselor) 23% 14% 9% 51% 2% 169

6g. Someone 

else (please 

specify)a

n/a n/a n/a n/a n/a 22

a

Too few respondents answered 6g to calculate a percentage estimate. 

Note: Totals may not equal 100 percent due to rounding. 

Page 57 GAO-09-762 Social Security Disability
Appendix III: Complete Results of Wounded 

Warrior Survey 

Section 3: Your experience 

completing the application 

for SSA benefits 

7. How helpful, if at all, was any of the assistance you may have received 

from any of the following people in helping you complete your Social 

Security disability benefits application? (Check one answer in each 

row. If you did not receive any assistance from a person, check the 

first column.) 

Very 

helpful 

Somewhat 

helpful 

Not 

helpful 

Did not 

receive 

assistance 

from this 

person 

Not 

sure 

Number of 

wounded 

warrior 

respondents 

7a. Another 

servicemember(s) 

or separated 

servicemember(s) 9% 7% 8% 76% 1% 171

7b. Family 

member(s) 22% 9% 4% 64% 1% 170

7c. Social 

Security 

Administration 

representative 53% 17% 13% 17% 1% 172

7d. DOD medical 

center or other 

DOD personnel 

(for example, 

nurse case 

manager, social 

worker, AW2 

Advocate, WTU 

or WWR squad 

leader) 15% 8% 11% 65% 2% 172

7e. VA medical 

center or other 

VA personnel (for 

example, nurse 

case manager, 

social worker, 

benefits 

counselor) 14% 6% 9% 69% 2% 169

7f. Someone else 

(please specify)a

 n/a n/a n/a n/a n/a 17

a

Too few respondents answered 7f to calculate a percentage estimate. 

Note: Totals may not equal 100 percent due to rounding. 

Page 58 GAO-09-762 Social Security Disability
Appendix III: Complete Results of Wounded 

Warrior Survey 

8. How long after you were wounded, injured, or became ill did you first 

apply for Social Security benefits? 

Less than 3 months 9%

From 3 to less than 6 months 9%

From 6 to less than 9 months 11%

From 9 to less than12 months 7%

12 months or more 59%

Do not remember 6%

Note: 181 wounded warriors responded to this question. Totals may not equal 100 percent due to 

rounding. 

9. When completing the Social Security disability benefits application, 

how easy or difficult were the following? (Check one answer in each 

row. If you did not do this, check the first column.) 

Very 

easy 

Somewhat 

easy 

Very 

difficult

Somewhat 

difficult 

Did 

not do 

this 

Do not 

remember 

Number of 

wounded warrior 

respondents

9a. Making initial 

contact with Social 

Security Administration 

representative 48% 25% 7% 15% 3% 2% 181

9b. Maintaining contact 

with Social Security 

Administration 

representative 38% 24% 17% 14% 6% 2% 181

9c. Understanding the 

Social Security 

disability benefits 

application 22% 27% 18% 31% 1% 2% 181

9d. Obtaining copies of 

your medical records 

from military or VA 

health care providers 41% 23% 11% 18% 7% 2% 180

9e. Receiving your 

mail at a DOD or VA 

hospital in a timely 

manner 19% 18% 8% 7% 44% 4% 179

9f. Understanding 

information contained 

in letters sent from 

Social Security 

Administration 24% 34% 13% 27% 1% 2% 181

Page 59 GAO-09-762 Social Security Disability
Appendix III: Complete Results of Wounded 

Warrior Survey 

Very 

easy 

Somewhat 

easy 

Very 

difficult

Somewhat 

difficult 

Did 

not do 

this 

Do not 

remember 

Number of 

wounded warrior 

respondents

9g. Getting information 

about how receiving 

Social Security 

disability benefits could 

impact VA or DOD 

benefits 13% 13% 13% 18% 32% 9% 180

Note: Totals may not equal 100 percent due to rounding. 

10. Were you aware that if an application for Social Security disability 

benefits is denied, the decision can be appealed? 

Yes 84%

No 15%

Not sure/do not remember 1%

Note: 181 wounded warriors responded to this question. 

Page 60 GAO-09-762 Social Security Disability
Appendix IV: VA Standard Summary Appendix IV: VA Standard Summary 

We have reproduced the Standard Summary template as it appears in VA’s 

2006 directive, Veterans Health Administration Directive 2006-024, to 

formalize use of the Standard Summary. The VA SSA-DDS Standard 

Summary is an electronic extraction of a standardized set of pertinent 

medical records from a patient’s overall VA records. 

Page 61 GAO-09-762 Social Security Disability 
Appendix IV: VA Standard Summary 

Figure 15: VA Standard Summary 

1 BDEM (Brief demographics) Brief patient demographic information. Includes

address, phone number, age, sex, race, ethnicity,

mean test, and eligibility code and known VA

facilities that have provided care. 

Limits: not applicable (NA) 

2 

3 

4 

PLL (All Problems List) or PLA All known problems, active (PLA) and inactive (PLI)

for a patient. Includes provider narrative, date of

onset on active problems, date problem resolved on

inactive, date last modified, responsible provider and

all active comments for the problems (caution: list

may be incomplete).

(Active Problems) and PLI 

(Inactive Problems) 

Display ICD text =Yes, 

Display provider narrative =Yes

Limits: NA 

CVF (Future Clinic Visits) 

Limits: NA 

Displays future appointment dates and what VA

component the patient will see. Potential value in

lieu of consultative examination. 

OE (Outpatient Encounters) Concise listing of all outpatient events including

date, outpatient diagnosis (international

Classification of Diseases-9th edition (ICD-9), and

procedure (Current Procedural Terminology (CPT))

for each event. The complete VA record should have

a detailed Compensation and Pension or Progress

Note (PN) for each OE. If number of PNs exceeds

occurrence limit, OE will help target possible followup for older encounters. 

Display long text narrative 

Limits: Time = 2 years

Occurrences = 150 

(whichever comes first (WCF)) 

5 GAF (Global Assessment 

Functioning) 

Limits: Time = 2 years

Occurrences = no limit 

Displays score taken from the GAF Scale to evaluate

the psychological, social, and occupational

functioning on a hypothetical continuum of mental

health and/or illness. Also displayed is date of

assessment and name of health care professional

giving the score. Potential indicator of longitudinality

and decompensation.

Component 

Order Acronym, Name, and Limits Description 

6 DCS (Discharge Summaries) Inpatient discharge summaries, including report text

Limits: Time = 4 years for the time period.

Occurrences = five WCF 

7 CP (Compensation and Pension Compensation and pension exams for Veterans’

Exams) benefits.

Limits: Time = four years

Occurrences = five WCF 

8 PN (Progress Note) Includes: date and time, title, and text of note.

Limits: Time = 2 years NOTES: 

Occurrences = 40 WCF -- Need to assess local VA capabilities to distinguish 

types of PN and exclude unneeded PN (e.g., inpatient 

NOTE: Occurrences can be notes (captured in DCS), nurses notes, telephone 

reduced to 30, if the PNs can be triage, physical therapy) as possible.

pulled selectively (see description). -- Outpatient PNs that exceed the occurrence limit

are highlighted in OE for follow-up request as

needed.

Page 62 GAO-09-762 Social Security Disability
Appendix IV: VA Standard Summary 

Component 

Order Acronym, Name, and Limits Description 

9 SR (Surgery Report) Contains reports of operative procedures and nonoperative procedures. Includes: date, specialty, pre

and post operative diagnosis, procedures performed,

surgeon’s dictation, indications for procedure.

(OR (operating room)/NON (non 

operating room) 

Limits: Time = 2 years, 

Occurrences = 10 WCF 

10 SCD (Spinal Cord Dysfunction) Includes patient registration status, highest level of

injury, information source for SCD, completeness of

injury and extent of paralysis. Limits: N/A 

11 *MEDF (Medical Full Report ) This component provides a full report of procedures

(e.g., Electrocardiogram (ECG), Pulmonary Function

Tests (PFT), sleep studies) as defined by the

Medicine View file.

Limits: Time = two years, 

Occurrences = 15 WCF 

*If unavailable locally, determine 

best alternative (e.g., Clinical 

Procedures-Brief (CPB)). 

12 IP (Imaging Profile) Contains information from Radiology and/or Nuclear

Medicine. Includes: study date, procedure, status,

report status, staff and resident interpreting

physicians and history, report, diagnostic text and

impression. 

CPT modifiers = No 

Limits: Time = 2 years, 

Occurrences = 10 WCF 

13 CY (Cytopathology) Includes: collection date and time, specimen, gross

description, microscopic exam, brief clinical history,

and cytopathology diagnosis.

Limits: Time = 2 years, 

Occurrences = 10 WCF 

14 EM (Electron Microscopy) 

Limits: Time = 2 years, 

Occurrences = 10 WCF

15 MIC (Microbiology) 

Limits: Time = 2 years, 

Occurrences = 10 WCF

Includes: collection date and time, collection sample,

site and specimen, specimen comment, tests, urine

screen, sputum screen, sterility control, sterility

results, comments for reports, smear and/or prep, acid

fast stain Parasite Report, organism(s), Mycology

Report, Bacteriology Report, Mycobacteriology

Report, Gram Stain Result, Culture and

Susceptibility, Antibiotic Serum Level, and remarks.

Includes: collection date and time, specimen, gross

description, microscopic exam, brief clinical history,

supplemental report, and EM diagnosis.

16 SP (Surgical Pathology) Includes: collection date and time, specimen, gross

description, microscopic description, brief clinical

history, supplemental report, frozen section, and

surgical path diagnosis.

Limits: Time =2 years, 

Occurrences = 10 WCF 

17 ON (Oncology) Selected data elements from the Oncology Primary

Limits: Time = 2 years, file. 

Occurrences = NA 

18 CH (Chemistries and Hematology) Includes: collection date and time, specimen, test

name, results (with flag, either High, Low, or

Critical), units, and reference range. 

Display comments = Yes

Limits: Time = 2 years

Occurrences = 20 WCF 

Source: VA.

Page 63 GAO-09-762 Social Security Disability
Appendix V: Comments from the Social Appendix V: Comments from the Social Security Administration 

Security Administration 

Page 64 GAO-09-762 Social Security Disability 
Appendix V: Comments from the Social 

Security Administration 

Page 65 GAO-09-762 Social Security Disability
Appendix V: Comments from the Social 

Security Administration 

Page 66 GAO-09-762 Social Security Disability
Appendix VI: Comments from the Department Appendix VI: Comments from the of Veterans Affairs 

Department of Veterans Affairs 

Page 67 GAO-09-762 Social Security Disability 
Appendix VI: Comments from the Department 

of Veterans Affairs 

Page 68 GAO-09-762 Social Security Disability
Appendix VII: 

A

GAO Contact and Staff 

cknowledgments 

Page 69 GAO-09-762 

Appendix VII: GAO Contact and Staff 

Acknowledgments 

Daniel Bertoni, (202) 512-7215 or bertonid@gao.gov

In addition to the contact named above, Brett Fallavollita, Lorin Obler, 

David Forgosh, Rebecca Makar, and Joy Myers made major contributions 

to this report; Bonnie Anderson, Rebecca Beale, Elizabeth Curda, Patricia 

Owens, and Kelly Shaw provided guidance; Stuart Kaufman, Anna Maria 

Ortiz, Minette Richardson, Beverly Ross, Vanessa Taylor, and Walter 

Vance provided methodological support; Susan Bernstein helped draft the 

report; Jessica Botsford and Daniel Schwimer provided legal advice; and 

Matthew Goldstein provided research assistance. 

GAO Contact 

Staff 

Acknowledgments 

 Social Security Disability 
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(130837) Page 71 GAO-09-762 Social Security Disability
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