MODERNIZING SSA 

DISABILITY PROGRAMS

Preliminary Observations 

on Updates of Medical and 

Occupational Criteria 

Statement of Daniel Bertoni, Director 

Education, Workforce, and Income Security

Testimony 

Before the Subcommittee on Social 

Security, Committee on Ways and Means, 

House of Representatives

For Release on Delivery 

Expected at 10:30 a.m. EDT

Tuesday, March 20, 2012

GAO-12-511T

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-511T, a testimony to the

Subcommittee on Social Security, Committee 

on Ways and Means, House of 

Representatives 

March 20, 2012 

MODERNIZING SSA DISABILITY PROGRAMS

Preliminary Observations on Updates to Medical and 

Occupational Criteria

Why GAO Prepared This 

Testimony

SSA administers two of the largest 

disability programs, with annual 

benefit payments that have grown 

fivefold over the last 20 years—from 

$35 billion in 1990 to over $164 

billion in 2010—and the agency 

receives millions of new applications 

annually. GAO has designated 

federal disability programs as a highrisk area, in part because eligibility 

criteria have not been updated to 

reflect medical and technological 

advances and labor market changes. 

Given the size and cost of its 

disability programs, SSA needs

updated criteria to appropriately 

determine who qualifies for benefits.

In this statement, GAO discusses 

initial observations from its ongoing 

review and assessment of SSA’s 

efforts to (1) update its medical 

criteria and (2) develop a new 

occupational information system. To 

do this, GAO reviewed prior GAO 

and SSA Inspector General reports; 

relevant federal laws and 

regulations; program documentation 

including policies, procedures, 

strategic goals, and supporting 

project plans; and cost estimates. 

GAO also interviewed SSA officials, 

project stakeholders, experts, and 

representatives from other agencies 

that administer disability programs. 

This work is ongoing and GAO has 

no recommendations at this time. 

GAO plans to issue its final report 

later in 2012.

What GAO Found

The Social Security Administration (SSA) has made several changes to improve 

the process it uses for updating its medical criteria, but continues to face 

challenges ensuring timely updates. SSA’s medical criteria for adults are in the 

form of listings of medical conditions and impairments organized under 14 body 

systems, which SSA periodically updates. To help ensure timely, periodic 

updates of a body system’s listings, SSA is moving away from comprehensively 

revising a body system’s listings toward a more targeted approach, wherein SSA 

selects for revision those impairment listings most in need of change. To date, 

SSA has completed comprehensive revisions of listings for 8 of the 14 body 

systems and now is in the process of reviewing them to determine whether and 

which targeted revisions are appropriate. In 2010, the SSA Commissioner set a 

5-year cycle time for updating listings for each body system, replacing the 

agency’s prior practice of setting expiration dates for listings that ranged from 3 

to 8 years and then frequently extending them. To further increase the timeliness 

and accuracy of decisions, SSA has sought recommendations from the Institute 

of Medicine and has acted on some of them, such as creating a standing 

committee to provide advice on updating the listings. However, SSA continues to 

face challenges keeping its listings up to date. For example, SSA is still working 

on completing comprehensive revisions of listings for six body systems that have 

been ongoing for 19 to 33 years. SSA staff told us that a lack of staff and 

expertise, along with the complexity and unpredictability of the regulatory 

process, have made it challenging to maintain its schedule of periodic updates 

for all listings. 

SSA has embarked on an ambitious plan to produce by 2016 an occupational 

inventory database to support its disability benefit decisions, but it is too soon to 

determine if SSA will meet key time frames. SSA currently relies on an 

occupational information source developed by the Department of Labor that was 

updated for the last time in 1991 and is viewed by many as outdated. In 2008, 

SSA initiated a project to develop its own occupational information system (OIS), 

which SSA expects will provide up-to-date information on the physical and 

mental demands of work, and in sufficient detail to support its disability benefit 

decisions. To guide the creation of its OIS, SSA established an advisory panel, 

collaborated with outside experts and other agencies, and in July 2011 issued a 

research and development plan detailing all relevant activities and goals between 

2010 and 2016. As of February 2012, SSA had completed many initial research 

efforts, including investigating other types of occupational information systems 

and identifying job analysis methods. Despite preliminary progress, it is too early 

to determine if SSA will meet its target implementation date. SSA officials told us 

that due to staffing shortages it did not meet all initial goals on time and may 

need to adjust its time frames for future activities. While GAO is still evaluating 

SSA’s schedule and cost estimates against best practices, we have preliminarily 

identified some potential gaps in SSA’s approach, such as not reflecting the 

costs to both implement and maintain a new OIS. 

View GAO-12-511T. For more information, 

contact Daniel Bertoni at (202) 512-7215 or 

bertonid@gao.gov. 
 

Page 1 GAO-12-511T 

Chairman Johnson, Ranking Member Becerra, and Members of the 

Subcommittee:

I am pleased to be here today to discuss our preliminary observations on 

efforts by the Social Security Administration (SSA) to modernize its 

disability criteria. In the last 20 years, SSA disability benefit payments to 

beneficiaries and their dependents have increased almost fivefold, from 

$35 billion in 1990 to over $164 billion in 2010. The number of workingage beneficiaries also grew from about 9 million in 2000 to almost 12 

million in 2010, and, as more baby boomers enter their disability-prone 

years, SSA expects the number of claims to grow.1

My statement today focuses on initial observations from our ongoing 

review for this subcommittee and examines the status and management 

of SSA’s efforts to (1) update its medical listings to reflect current medical 

knowledge and (2) develop its own occupational information system (OIS) 

to reflect labor market changes. To examine these issues we reviewed 

prior GAO and SSA Office of Inspector General reports; relevant federal 

laws and regulations; program documentation including policies, 

procedures, strategic goals, and supporting project plans and cost 

estimates; and position papers and testimonies from disability groups and 

commissions. We interviewed SSA officials, key project contractors and 

stakeholders, disability experts, and representatives of other agencies 

that administer disability programs. In our ongoing work, we will further 

evaluate SSA’s plan to develop its own OIS against best practices for 

cost estimating and scheduling. We will also review more broadly other 

steps SSA is taking to incorporate modern concepts of disability into its 

programs. We plan to issue our final report later in 2012 in accordance 

Given the extensive 

size and cost of its disability programs, SSA must have current and 

appropriate criteria by which to assess whether an applicant’s medical 

conditions affect his or her ability to perform work in the national 

economy. GAO has designated SSA’s federal disability program as a 

high-risk area; in 2008, we reported that the agency’s medical criteria did 

not fully reflect medical and technological advances, and the occupational 

criteria it used from the Department of Labor (Labor) had not been 

updated since 1991, despite the trend away from manual labor jobs and 

towards service- and knowledge-based jobs.

 

1

In fiscal year 2010, SSA received 6.3 million benefit claims from either workers with 

disabilities or their dependents, up from 3.1 million in 2000.

 
 

Page 2 GAO-12-511T 

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.

SSA administers two of the largest disability programs: the Disability 

Insurance (DI) program, enacted in 1956, and the Supplemental Security 

Income (SSI) program, enacted in 1972.2 In order to be eligible for DI or 

SSI benefits based on a disability, an individual must meet the definition 

of disability for these programs—that is, they must have a medically 

determinable physical or mental impairment that (1) prevents the 

individual from engaging in any substantial gainful activity, and (2) has 

lasted or is expected to last at least one year or result in death.3

To determine eligibility, SSA uses a five-step sequential process that is 

intended, in part, to expedite disability decisions when possible and limit 

administrative costs by conducting less intensive assessments at earlier 

steps (see fig. 1).4 At steps 1 and 2 of the process, SSA determines 

whether an applicant is working and meets income thresholds as well as 

the medical severity of impairments. If so, the applicant moves to step 3 

of the process. At this step, SSA examiners assess the applicant’s 

medical impairment(s) against the Listings of Impairments, also known as 

the medical listings, which are organized into 14 major body systems for 

adults and reflect medical conditions that have been determined by the 

agency to be severe enough to qualify an applicant for benefits.5

 

2

The DI program provides monthly cash benefits to eligible applicants who have a 

sufficient work record. The SSI program provides monthly benefits to eligible applicants 

with limited income and resources who are disabled, blind, or age 65 or older.

If the 

individual’s impairment meets or is equal in severity to one or more of 

3

42 U.S.C. §§ 423(d)(1)(A) and 1382c(a)(3)(A). Substantial gainful activity is generally 

work activity involving significant physical or mental activities that are done for pay or 

profit, whether or not a profit is realized. 20 C.F.R. §§ 404.1572 and 416.972. In 2012, the 

substantial gainful activity threshold is $1,690 per month for blind recipients and $1,010 

per month for individuals with other disabilities. 

4

See 20 C.F.R. §§ 404.1520 and 416.920.

5

According to agency officials, there are almost 300 medical impairments organized in 119 

listings under the 14 major body systems for adults.

Background
 

Page 3 GAO-12-511T 

those in the listings, the individual is determined to have a disability. If 

not, SSA performs an assessment of the individual’s physical and mental 

residual functional capacity.6

Figure 1: SSA’s Five-Step Sequential Evaluation Process for Determining Disability

Based on this assessment, SSA determines 

whether the individual is able to perform past relevant work (step 4) or 

any work that is performed in the national economy (step 5). To inform 

determinations at steps 4 and 5, SSA uses a Department of Labor 

database—known as the Dictionary of Occupational Titles (DOT)—for an 

inventory of occupations performed in the national economy.

 

6

SSA’s physical and mental residual functional capacity assessments establish the extent 

to which an individual’s medically determinable impairment(s), including any related 

symptoms, such as pain, may cause physical or mental limitations or restrictions that may 

affect his or her capacity to do work-related physical and mental activities. 
 

Page 4 GAO-12-511T 

Since 2003, SSA’s and other federal disability programs have remained 

on our high-risk list, in part, because their programs emphasize medical 

conditions in assessing work capacity without adequate consideration of 

work opportunities afforded by advances in medicine, technology, and job 

demands. Since the 1990s, we, along with SSA’s Office of Inspector 

General and the Social Security Advisory Board, have expressed 

concerns that the medical listings being used no longer provide sufficient 

criteria to evaluate disability applicants’ inability to work and that SSA was 

simply extending the listings instead of periodically updating them. In 

2008, we reported that SSA had established a new process for revising 

the listings—referred to by SSA as the “business process”—to better 

incorporate feedback into its continuous updates.7 This process, which 

has been in effect since 2003, includes incorporating feedback from 

multiple parties, including medical experts and claims examiners, to 

update their medical criteria. SSA should also gather external feedback 

through comments associated with regulatory actions, such as the 

publication of advanced notices of proposed rulemaking (advanced 

notices) and notices of proposed rulemaking (notices) in the Federal 

Register.8

With respect to information on jobs in the national economy that supports 

SSA’s occupational criteria, we and others have reported that the DOT, 

which SSA still relies on to assess eligibility at steps 4 and 5 of the 

process, is outdated. The DOT has not been updated since 1991, and 

Labor has since replaced the DOT with a new database called the 

In addition, one year after a revision is made, SSA should 

conduct a study reviewing the changes. According to SSA 

documentation, this internal case study, now referred to as the 

postimplementation study, should involve surveying the field regarding 

the results of the regulation and areas to improve, as well as reviewing 

the data to determine whether expectations from the revision have been 

proven.

 

7

GAO, Federal Disability Programs: More Strategic Coordination Could Help Overcome 

Challenges to Needed Transformation, GAO-08-635 (Washington, D.C.: May 20, 2008).

8

Any changes to the medical listings have to proceed according to an established process 

for rulemaking outlined in federal law. As such, when changes are made to the listings, a 

notice of proposed rulemaking must generally be published in the Federal Register with a 

public comment period before the final rule is issued. 5 U.S.C. § 553.
 

Page 5 GAO-12-511T 

Occupational Information Network (O*NET).9 However, SSA has 

determined that O*NET is not sufficiently detailed for evaluating DI and 

SSI disability claims and therefore has begun developing its own OIS in 

order to better reflect the physical and mental demands of work in the 

national economy.

Since our last review in 2008, SSA has made several changes that hold 

promise for improving medical listings updates. First, the agency is using 

a two-tiered system for ongoing revisions to the listings. Under this 

system, SSA first completes a comprehensive listings update for a body 

system that reviews all the diseases and disorders listed within that 

system and makes revisions it determines are needed. For subsequent 

updates of listings for a body system that underwent a comprehensive 

revision, SSA will pursue a more targeted approach—that is, SSA will 

conduct ongoing reviews with the expectation of making targeted 

revisions for a small number of medical diseases or disorders that need to 

be updated. Agency officials told us that targeted updates should be 

completed more quickly than comprehensive updates, allowing them to 

focus on the most critical changes needed. However, officials also noted 

that these ongoing reviews could result in major or even no changes, as 

appropriate. As of early March 2012, SSA had begun the ongoing review 

process to consider opportunities for targeted revisions for 8 out of 14 

adult body systems that were recently comprehensively revised. Also as 

of early March 2012, the agency had not yet completed comprehensive 

revisions for the six remaining systems, which the agency expects to do 

before they conduct subsequent reviews under the targeted approach.

 

9

Labor launched O*NET, a general purpose occupational information database used for 

workforce development, economic development, career exploration, academic and policy 

research, in 1998. 

SSA Has Improved Its 

Process for Updating 

Medical Listings, but 

Faces Challenges 

Completing Updates

SSA Has Improved Its 

Strategy to Update Medical 

Listings
 

Page 6 GAO-12-511T 

Another change, according to agency officials, is that in 2010 the SSA 

Commissioner set a 5-year cycle time for updating listings for each body 

system.10

 

10The 5-year expiration period will be applied to listings under a body system upon 

completion of their current revision. SSA began applying the 5-year expiration period in 

2011 when it comprehensively updated the endocrine body system listings. For other body 

systems listings updated prior to 2011, SSA generally assigned expiration periods 

extending beyond 5 years. 

Previously, SSA set expiration dates for periodically updating 

listings according to each body system, ranging from 3 to 8 years, but 

frequently extended them. SSA officials believe that conducting targeted 

reviews will generally allow the agency to conclude any necessary 

revisions prior to the 5-year expiration period. Additionally, they expect 

that using the “business process,” which requires early public notification 

of changes and obtaining necessary data and feedback from internal and 

external parties, should help keep continuous reviews on track. See figure 

2 for the status and expiration dates of listings for the 14 adult body 

systems, undergoing review for either comprehensive or possible 

targeted revisions, as of early March 2012.
 

Page 7 GAO-12-511T 

Figure 2: Status of Revisions for SSA’s Adult Body System Listings

a

For the two-tiered revision process, the beginning point is the date of the last comprehensive or 

targeted revision.

b

SSA officials told us they have grouped the disorders in the special senses and speech listings into 

two broad sections—vision and hearing—and two standalone medical conditions. SSA has not yet 

comprehensively revised the two standalone medical conditions that cover speech and disturbances 

of labyrinthine-vestibular function. The two sections have undergone comprehensive revisions and 

are undergoing reviews that began in 2007 for the vision section and in 2010 for the hearing section. 

Special senses and speech listings are set to expire in 2015. 

c

SSA published limited revisions for the hematological disorders listings in 1988, the mental disorders 

listings in 2000, and the musculoskeletal system listings in 2002. 

SSA has made another change by more extensively engaging the 

medical community to identify ways to improve the medical listings. For 

example, SSA contracted with the Institute of Medicine to study its 
 

Page 8 GAO-12-511T 

medical criteria for determining disability and to make recommendations 

for improving the timeliness and accuracy of its disability decisions, 

resulting in a 2007 report with recommendations11 and a symposium of 

experts in 2010. SSA has addressed some of the institute’s 

recommendations, such as making better use of its administrative data to 

update criteria and creating a standing committee through the institute to 

provide recommendations for listings revisions.

SSA continues to face delays in completing both comprehensive and 

other ongoing updates. For example, as of early March 2012, SSA 

officials told us they still needed to complete comprehensive revisions for 

listings of six body systems that have been ongoing for the last 19 to 33 

years, after numerous extensions beyond the original expiration periods 

(see table 1). Two of the remaining six body system listings—mental and 

neurological disorders, which are among those SSA uses most frequently 

in its eligibility determination process—have not been comprehensively 

revised for 27 years.12 Four of the remaining body system listings are set 

to expire in 2012. Of these four, SSA is developing a notice of proposed 

rulemaking for three of them and has issued a notice on the fourth.

However, it is unclear whether SSA will complete the revisions before 

they are set to expire.

 

11Institute of Medicine, Improving the Social Security Disability Decision Process

(Washington, D.C.: 2007). 

12According to SSA officials, the agency made limited, but not comprehensive, revisions to 

the mental disorders listings in 2000.

SSA Has Experienced 

Delays with Its Revision 

Process
 

Page 9 GAO-12-511T 

Table 1: Key Dates for Comprehensive Revisions to Body System Listings

Body system and section

Year 

comprehensive 

revision last 

published

Years since 

comprehensive 

revision last 

publisheda

Current 

expiration 

dateb

Special senses and speechc

• Speech

• Disturbances of labyrinthine-vestibular 

function

1979 33 2015

Neurological disorders 1985 27 2012

Mental disorders 1985 27 2012

Hematological disorders 1985 27 2012

Musculoskeletal system 1985 27 2013

Respiratory system 1993 19 2012

Source: GAO analysis based on information provided by SSA officials.

a

SSA published limited revisions to listings for the hematological disorders in 1988, the mental 

disorders in 2000, and the musculoskeletal system in 2002. 

b

SSA has continually extended the expiration dates of the listings. 

c

The special senses and speech listings have two sections—vision and hearing—which have been 

comprehensively revised. 

While ongoing reviews involving SSA’s targeted approach seem to be 

moving at a faster pace than the comprehensive revisions, SSA has 

already extended the expiration date for its review of the cardiovascular 

system. SSA may also need to extend expiration dates for listings under 

two other body systems set to expire in 2012, according to agency 

officials. Extensions may be needed because SSA has not yet published 

the notice of proposed rulemaking for those two body system listings and 

may not have time to publish these notifications, respond to comments, 

and complete the final updates of the listings by their current expiration 

date.

At the same time that SSA has been experiencing delays completing 

timely revisions, agency officials reported challenges with other steps in 

the business process. Whereas they always intended to review data at 

the one year mark to determine whether expectations from a revision 

were met, SSA officials told us they only began conducting these reviews 

in 2010. Specifically, they completed one postimplementation study in 

2011 that involved a targeted sample of 175 cases, and they are 

conducting and planning to conduct two more studies at the one year 

mark. While disability experts we interviewed spoke highly of SSA’s 

business and targeted review processes to obtain feedback early on and 

update the listings more promptly, recent delays raise questions 
 

Page 10 GAO-12-511T 

regarding the agency’s ability to follow its current business process while 

completing continuous and timely revisions for all 14 body systems.

SSA officials offered two key reasons for the delays in updating the 

listings: limitations in the number and expertise of staff and the complexity 

and unpredictability of the regulatory process. According to SSA officials, 

revising the medical listings requires research, deliberation, testing, 

regulatory review, and consensus with many stakeholders, and 

consequently is difficult and time-consuming to achieve. In addition, 

according to an SSA official in the Office of Medical Listings 

Improvement, the office is short-staffed and some staff lack the expertise 

necessary to perform this work. To address these constraints, SSA has 

contracted with the Institute of Medicine to review and develop 

recommendations for revising two of the body system listings.13 However, 

SSA officials told us that the agency does not currently have a plan to 

renew this contract after it expires in 2012, nor use any other contractor to 

address staffing shortfalls due to budget constraints. Also contributing to 

delays is the time required for internal review and public comment under 

the regulatory process that depends largely on the number and the 

substance of comments received, according to an SSA official. For

example, SSA officials told us that the advanced notice of proposed 

rulemaking to the listings of mental disorders in 2003 resulted in 500 

comments, which took SSA 5 years to incorporate into a draft notice of 

proposed changes for regulatory review.

 

13The institute provided recommendations for changes to the cardiovascular and the 

Human Immunodeficiency Virus listings in two reports. For the reports see, Institute of 

Medicine, Cardiovascular Disability: Updating the Social Security Listings (Washington, 

D.C.: 2010) and HIV and Disability: Updating the Social Security Listings (Washington, 

D.C.: 2010).
 

Page 11 GAO-12-511T 

In 2008, SSA began a multiyear project to develop a new source of 

occupational information that will replace the outdated information 

currently being used to determine if claimants are able to do their past 

work or any other work in the national economy. Since the 1960s, SSA 

has been using the DOT, which contains a list of job titles found in the 

national economy and was last updated in 1991.14

 

14The DOT provides a wide range of occupational information that could be used for job 

placement, occupational research, career guidance, labor-market information, curriculum 

development, and long-range job planning.

The DOT provides 

SSA with descriptions of the physical demands of work—such as 

climbing, balancing, and environmental requirements—for each of the 

more than 12,000 occupations listed. According to SSA, these 

descriptions have been essential to its evaluations of how much a 

claimant can do despite his or her impairment and whether this level of 

functioning enables the claimant to do his or her past work or any other 

work. After its last limited update, Labor decided to replace the DOT with 

O*NET, which has far fewer job titles compared with the DOT, but has 

served Labor’s purposes more efficiently. According to an SSA report, 

after investigating potential alternatives, SSA decided that O*NET and 

other existing databases with occupational information were not 

sufficiently detailed and able to withstand legal challenges for use in its 

decision-making process. SSA further decided to develop its own 

occupational information system, which would contain detailed 

information as in the DOT, but would also include additional information, 

such as the mental demands of work. In addition, the OIS should (1) meet 

SSA’s legal, program, and data requirements; (2) be flexible enough to 

incorporate changes in SSA’s policies and processes; and (3) be able to 

be updated to reflect the evolving workplace environment.

SSA Has Begun an 

Ambitious Project to 

Develop Its Own 

Source of 

Occupational 

Information

SSA is in the Preliminary 

Stage of Developing a New 

Up-to-Date Source of 

Occupational Information
 

Page 12 GAO-12-511T 

In 2008, SSA began taking several steps to guide the development of its 

OIS. SSA created an internal office and working group, as well as an

Occupational Information Development Advisory Panel, comprised of 

external experts in areas related to the development of occupational 

information systems.15

To further inform its efforts, SSA has sought input from agencies or 

organizations that either collect occupational information or also use the 

DOT. For example, SSA officials held initial meetings with Labor and U.S. 

Census Bureau officials to gain information on sampling methods used for 

the O*NET, the Occupational Employment Statistics program, and 

Census Bureau’s household surveys.

The advisory panel holds quarterly public meetings 

and has several subcommittees that review material and make 

recommendations to SSA on developing various components of the OIS.

For example, in a 2009 report, the advisory panel supported the need for 

SSA to develop a new source of occupational information, rather than 

adapt O*NET, and recommended the type of data SSA should collect, as 

well as suggested ways to classify occupations.

16

In July 2011, SSA published a detailed research and development plan 

outlining all activities related to researching, developing, and testing the 

Additionally, SSA and Labor are 

in the process of completing a Memorandum of Understanding that will 

formalize their collaboration efforts on the new OIS. According to an SSA 

official, as the OIS project progresses, SSA plans to convene ad hoc 

roundtables with experts and other agency officials to explore specific 

subject areas, such as sampling issues. Besides working with Labor and 

Census Bureau officials, SSA officials and panel members have sought 

input from other experts and current users of the DOT, such as SSA 

disability adjudicators and external rehabilitation professionals, by 

conducting a user needs analysis in 2009 and presenting the OIS project 

at events and conferences.

 

15The Occupational Information Development Advisory Panel was formed in December 

2008 under the Federal Advisory Committee Act.

16The Occupational Employment Statistics program produces employment and wage 

estimates for approximately 800 occupations. The Census Bureau’s household surveys 

include (1) the American Community Survey, which is an ongoing survey that provides 

annual data on demographics such as age, education, and disabilities, and (2) the Current 

Population Survey , which is primarily a labor force survey, conducted every month by the 

Census Bureau for the Bureau of Labor Statistics and provides data such as the national 

unemployment rate. 
 

Page 13 GAO-12-511T 

key components of the OIS in order to implement the OIS by 2016 at an 

estimated cost of $108 million. For example, the plan includes several 

baseline activities to identify and study other occupational information 

systems and various approaches for analyzing occupations that may 

inform or could be leveraged in SSA’s OIS data collection. The plan also 

includes activities to identify the primary occupational, functional, and 

vocational characteristics of current beneficiaries. Other key components 

of the plan include developing descriptions of work requirements, such as 

the physical and mental demands for jobs, and data collection and 

analysis strategies. SSA also plans to develop a strategy for piloting data 

collection nationwide within this time frame.

As of February 2012, SSA had made progress on many of the baseline 

activities outlined in its research and development plan for the OIS.17

While SSA has made progress on several key activities, agency officials 

delayed 2011 completion dates for certain activities and anticipate making 

additional changes to its timeline as a result of not meeting its staffing 

goals for fiscal year 2011. For example, the activities that were delayed 

by several months included finalizing reports for the baseline studies and 

conducting a literature review that would inform how occupations might 

be analyzed for the OIS. SSA officials told us that they would have 

needed to have the full complement of projected 2012 staff by September 

2011 to complete all of the 2012 planned activities within the estimated 

For 

example, according to an SSA official, its investigation of existing 

occupational information systems, now complete, has resulted in useful 

information about design issues other organizations have confronted and 

mitigated when creating their own system. Additionally, SSA’s preliminary 

analysis of its own administrative data identified the most frequently cited 

occupations and functional and vocational characteristics of disability 

applicants. SSA officials told us the agency will target the occupations 

identified in this analysis for its pilot studies of the OIS. Also in 2011, SSA 

completed a comprehensive framework for assessing an individual’s 

capacity to work—key to informing the OIS content, according to SSA 

officials—which was based on recommendations of outside experts as 

well as SSA’s policy and program requirements.

 

17Some of the activities that were part of the research and development plan were 

completed in years prior to the plan’s issuance.

SSA Has Made Progress on 

Its OIS, but It Is Too Soon 

to Know if Project 

Timelines Will be Met
 

Page 14 GAO-12-511T 

schedule. However, SSA officials said they did not have the budget to 

hire new staff in September 2011. To address this challenge, SSA 

officials hired consultants to meet some of their needs. SSA officials also 

met with the Office of Personnel Management to explore the possibility of 

an interagency agreement that would allow SSA to use one or two of the 

Office of Personnel Management’s industrial organizational psychologists 

to help on a part-time basis.

As part of our ongoing work, we are assessing SSA’s current OIS project 

schedule and cost estimates against best practices, and have 

preliminarily identified some gaps in SSA’s approach. For example, best 

practices require cost estimates to be comprehensive and include 

information about life cycle costs—that is, how much the project is 

expected to cost over time. However, while SSA has estimated the cost to 

research and develop the OIS, the estimate does not project the future 

costs to implement or maintain the system. The cost of sustaining an OIS 

could be significant, based on other agencies’ experiences maintaining 

their systems for collecting national occupational information. We 

preliminarily identified other gaps, such as lack of documentation 

describing step by step how the cost estimate was developed so that 

those unfamiliar with the program could understand how it was created.

For our final report due later in 2012, we plan to deliver more 

comprehensive findings on how well SSA is managing the development 

of its OIS against best practices, such as estimating costs of the OIS and 

ensuring that the project schedule reliably estimates related activities, the 

length of time they will take, and how they are interrelated. We will also 

identify any mitigation strategies the agency may have to address project 

risks, such as the risk of the agency not receiving full funding.

Chairman Johnson, Ranking Member Becerra, and Members of the 

Subcommittee, this concludes my prepared statement. I will be happy to 

respond to any questions.

For further information regarding this testimony, please contact me at 

202-512-7215 or bertonid@gao.gov. In addition, contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this statement. Individuals who made key contributions to 

this testimony are Michele Grgich, Assistant Director, James Bennett, 

Kate Blumenreich, Julie DeVault, Alex Galuten, Sheila McCoy, Patricia M. 

Owens, Anjali Tekchandani, Kathleen Van Gelder, and Walter Vance.

Contact and 

Acknowledgments

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