Electronic Disability Claims Processing: SSA Is Proceeding with Its Accelerated Systems Initiative but Needs to Address Operational Issues
Published: 2005-09-23T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Through an initiative known as AeDib, the Social Security Administration (SSA) is implementing a system in which medical images and other documents that have traditionally been kept in paper folders will be stored in electronic folders, enabling disability offices--including SSA's 144 Office of Hearings and Appeals sites and 54 state disability determination services--to process disability claims electronically. This initiative supports a program that, in 2004, made payments of approximately $113 billion to more than 14 million beneficiaries and their families. In March 2004, GAO recommended that SSA take steps to ensure the successful implementation of the electronic disability system. GAO was asked to assess SSA's status in implementing AeDib and the actions the agency has taken in response to GAO's prior recommendations on this initiative.
section_title: What GAO Found
paragraphs: Since January 2004, SSA has been implementing its electronic disability system at 53 state disability determination services and 85 Office of Hearings and Appeals sites. It plans to complete implementation in all state sites by October 2005 and all hearings and appeals sites by November 2005. Nonetheless, considerable work is needed before these entities will be ready to process all initial claims electronically. SSA's effort to certify all state offices to electronically process claims and maintain the electronic folder as an official claims record is not expected to be completed until January 2007. In addition, state disability officials expressed concerns about the system's operations and reliability and about limitations in their electronic processing capabilities. Accordingly, a number of the offices reported varying levels of system usage, and their officials said that processing claims electronically generally took longer and consumed more resources than the previous method. Further, SSA and the state disability determination services lacked continuity of operations plans for ensuring that states could continue to process disability claims during emergencies. As SSA has implemented its system, it has taken actions that supported three of GAO's five prior recommendations. It has initiated studies that could help validate AeDib planning assumptions, costs, and benefits. It has also approved new software and certified its systems for production. In addition, according to state disability officials, the agency had improved its communications with them. However, SSA did not demonstrate action on two recommendations calling for thorough testing of its interrelated system components before implementation and completion of risk mitigation strategies for the projects supporting the initiative. Thorough testing and risk mitigation strategies could have helped limit problems with the system's operation and other circumstances that could impede the project's success.

section_title: Letter
paragraphs: This report responds to your request concerning the Social Security  Administration’s (SSA) ongoing accelerated initiative to establish an  electronic disability claims processing capability—known as AeDib. With  this initiative, the agency is implementing a paperless system, in which the  large volumes of medical images, files, and other documents that  traditionally have been maintained in paper folders will be stored in  electronic folders, enabling the disability claims processing offices to  electronically view, process, and share claims information. The disability  claims processing offices include SSA’s field offices, where individuals  apply for claims; state disability determination services (DDS) offices,  which determine claimants’ medical eligibility for disability benefits; and  SSA’s Office of Hearings and Appeals (OHA), which processes appeals of  claims that have been denied. SSA began its national rollout of the key  system components needed to electronically process an entire disability  case in late January 2004.
In pursuing this electronic capability, SSA has taken a positive and  necessary step toward more efficiently delivering benefits payments to an  increasing beneficiary population. However, we previously pointed out that  the agency’s accelerated strategy for developing and implementing the  electronic disability system involved risks that threatened the agency’s  complete and successful transition to this capability. In reporting on AeDib  in March 2004, for example, we noted that the agency had begun its  national rollout without conducting essential testing to assess how the  multiple interrelated system components for this initiative would function  in an integrated environment. To address such deficiencies, we  recommended that the Commissioner of Social Security take several  actions to reduce the risks associated with the agency’s strategy for  developing the electronic disability system. At your request, this report  discusses (1) the current status of SSA’s implementation of AeDib and  (2) the actions SSA has taken in response to our prior recommendations on  this initiative.
To address these objectives, we analyzed project management and  technical documentation describing SSA’s plans and progress related to  implementing its electronic disability system. In addition, we reviewed  relevant documents that describe the state DDSs’ implementation and use  of the system, including reports of the National Council of Disability  Determination Directors—an organization representing the state DDSs. We  also obtained and reviewed relevant documentation describing SSA’s  actions toward implementing our prior recommendations on AeDib.  Further, we interviewed key officials in SSA’s Offices of Operations,  Systems, Disability and Income Security Programs, and Hearings and  Appeals to determine the current status of the system’s implementation and  to discuss issues that the agency has identified during the implementation.  We also interviewed DDS officials in nine states—California, Delaware,  Florida, Illinois, Mississippi, Nebraska, New York, North Carolina, and  South Carolina—and the President of the National Council of Disability  Determination Directors, to obtain their views on implementing the  electronic disability system. To supplement the interviews, we visited DDS  and OHA sites in Mississippi and South Carolina, where we observed the  operations of the electronic disability system and discussed these offices’  implementations of and experiences in using it. We conducted our work  from October 2004 to July 2005, in accordance with generally accepted  government auditing standards. Appendix I contains a more detailed  discussion of the objectives, scope, and methodology.
subsections: section_title: Background
paragraphs: SSA’s Disability Insurance and Supplemental Security Income programs are  the nation’s largest providers of federal income assistance to disabled  individuals, with the agency making payments of approximately $113  billion to more than 14 million beneficiaries and their families in 2004. Yet,  over the years, it has become more challenging for the agency to ensure an  acceptable level of service—in terms of both the quality and the timeliness  of its support to these individuals. In January 2003, we designated disability  benefits programs across the federal government as high risk—in need of  urgent attention and transformation.
The process through which SSA approves or denies disability benefits is  complex and involves multiple partners at both the federal and state levels  in determining a claimant’s eligibility. SSA’s 1,300 field offices are the initial  points of contact for individuals applying for benefits. SSA also depends  on 54 state DDS offices to provide crucial support to the claims process  through their role in determining an individual’s medical eligibility for  disability benefits. DDSs make initial determinations regarding disability  claims in accordance with federal regulations and policies; the federal  government reimburses 100 percent of all costs incurred by states to make  disability determinations. Physicians and other members of the medical  community provide the DDSs with medical evidence to help them evaluate  disability claims. When disability claims have been denied by the DDSs,  claimants can appeal to SSA’s OHA.
The process begins when individuals apply for disability benefits at an SSA  field office, where determinations are made about whether they meet  nonmedical criteria for eligibility. If the claimant is eligible, the field office  forwards the application to the appropriate state DDS, where a disability  examiner collects the necessary medical evidence to make the initial  determination of whether the claimant’s condition meets the definition of  disability. Once the claimant’s medical eligibility is determined, the DDS  returns the claim folder to SSA for final processing.
A claimant who is initially denied benefits can ask the DDS to reconsider its  determination. If the DDS denies the claim again, the claimant can request  a hearing before a federal administrative law judge at an SSA hearings  office and, if still dissatisfied, can request a review of the claim by SSA’s  Appeals Council. Upon exhausting these administrative remedies, the  claimant may file a complaint in federal district court. Each level of appeal  involves multistep procedures for collecting evidence, reviewing  information, and making the decision. Many individuals who appeal the  initial determination on their claims will wait a year or longer—perhaps up  to 3 years—for a final decision.
To address concerns regarding the program’s efficiency, in 1992, SSA  initiated its Modernized Disability System project, intending to redesign the  disability claims process emphasizing the use of automation to achieve an  electronic (paperless) processing capability. This project, which in 1994  was renamed the Reengineered Disability System, was to automate the  entire disability claims process—from the initial claims intake in the field  office to the gathering and evaluation of medical evidence by the state  DDSs, to payment by the field office or processing center. The system also  was intended to automate the handling of appeals by SSA’s hearings offices.  However, as our prior work noted, SSA encountered performance and  other problems during its initial pilot testing of the system and, after  spending more than $71 million, suspended this project in 1999.
In August 2000, SSA renewed its commitment to developing an electronic  disability system by the end of 2005. The agency worked on this initiative  through the spring of 2002, at which time the Commissioner of Social  Security announced an accelerated electronic disability initiative— AeDib—to more quickly move to an automated process. Under the  accelerated strategy, the agency planned to begin implementing its  electronic disability system by January 2004. SSA anticipated that the  electronic disability system would enable the disability offices to achieve  processing efficiencies, improve data completeness, reduce keying errors,  and save time and money. With technologically enhanced claims processing  offices, the agency projected that it could realize benefits of more than $1  billion—at an estimated cost of approximately $900 million—over the 10- year life of the initiative. SSA reported actual AeDib costs of  approximately $215 million through fiscal year 2004 for planning, hardware  and software acquisition, maintenance, and personnel.
The AeDib strategy focuses on developing the capability to electronically  process claimant information and large volumes of medical images, files,  and other documents that are currently maintained in paper folders. Stored  in electronic folders, this information could then be accessed, viewed, and  shared among the disability claims processing offices. The initiative to  achieve this electronic capability involves five key projects:  an Electronic Disability Collect System that would provide the  capability for SSA field offices to capture electronically, in fixed data  fields, information about a claimant’s disability that previously had been  contained on paper disability forms (structured data) and to store it in  databases for later use by the SSA and DDS offices responsible for  processing disability claims;  a Document Management Architecture to provide a data repository and  scanning and imaging capabilities that would allow unstructured  claimant and medical data, such as images or information not found in  fixed data fields (e.g., a hospital report, doctors’ notes, or an x-ray  report), to be stored, indexed, and shared among the disability  processing offices;  Internet applications to enable the public to submit disability claims and  medical information to SSA via the Internet (all data keyed into the  Internet applications would be transmitted directly into the Electronic  Disability Collect System);  a systems migration and electronic folder software interface to position  DDS offices to operate on a common IBM-series hardware platform and  enhance their existing claims systems to process the electronic claims  information and to enable the DDS systems to access information in the  electronic folder; and  a Case Processing Management System that would interface with the  electronic folder and enable OHA’s staff to track, manage, and complete  case-related tasks electronically.
According to SSA, the Electronic Disability Collect System and the  Document Management Architecture are the two fundamental components  needed to create the electronic disability folder. Via their claims processing  systems, SSA and DDS users would be able to access and pull the  structured and unstructured claimant data into appropriate computer screens, organized as electronic folders of information. The agency’s  electronic disability claims processing system is depicted in figure 1.
By mid-January 2004, SSA had implemented all planned releases of the  Electronic Disability Collect System and had completed and placed into  production Internet applications to aid claimants in filing online for  disability benefits and services. It also had enhanced the DDSs’ claims  processing systems by migrating and upgrading hardware to allow these  offices to operate on a common IBM-series platform and by upgrading the  claims processing software in all but 3 state DDS offices that used the  standard disability claims processing systems. In addition, SSA had begun  pilot testing OHA’s Case Processing Management System in a standalone  environment at five sites. Further, the agency was pilot testing the  Document Management Architecture in three state DDS locations—North  Carolina, Illinois, and California. However, it had not yet implemented the  Document Management Architecture repository and scanning and imaging  capabilities and related DDS software enhancements or the software to  enable DDS and OHA systems to interface with the electronic folders. SSA  began its national rollout of these remaining system components at the  Mississippi DDS on January 26, 2004.
When we last reported on the initiative in late March 2004, SSA was  proceeding with its implementation of its electronic disability system.  However, our work had noted that the agency’s strategy for developing the  system components involved risks that threatened the success of the  project. For example, we determined that the agency (1) had begun the  national rollout without conducting testing that was adequate to evaluate  the performance of all system components collectively, (2) could not  provide evidence that it was consistently applying established procedures  to guide the AeDib software development or had developed risk mitigation  strategies, (3) had not validated its analysis to ensure the reasonableness of  estimated AeDib costs and benefits, and (4) had not articulated a  comprehensive plan for ensuring that state DDSs’ concerns about the  initiative were addressed. In view of the risks and the technological  complexity, scope, and size of the initiative, we had recommended that the  Commissioner of Social Security, before continuing with the national  rollout of AeDib,  ensure that all critical problems identified in pilot testing of the  electronic disability system were resolved and that end-to-end testing of  the interrelated systems was performed,  ensure that the software that had been developed was approved and  that the systems had been certified for production,  establish a revised time frame for and expedite actions toward finalizing  AeDib risk mitigation strategies,  validate all AeDib cost and benefit estimates, and  implement a communications plan to clearly and comprehensively  convey SSA’s approach for effectively addressing disability  stakeholders’ and users’ concerns and ensuring their full involvement in  the AeDib initiative.
section_title: SSA Is Meeting Its Overall AeDib Implementation Schedule, but Operational and Other Concerns Could Impact the Success of the Initiative
paragraphs: SSA is proceeding with a national rollout of its electronic disability system  and has generally met its schedule for implementing the remaining key  components—the Document Management Architecture and the electronic  folder interface software—that are required to process an entire disability  case electronically. Nonetheless, the agency has considerable work to  accomplish before it will be effectively positioned to fully process all  disability claims in an electronic environment. Among the critical tasks that  remain are certifying all state DDS offices and OHA sites to electronically  process claims and addressing operational and other concerns that  threaten to undermine the reliability and use of the system. Until SSA has  effectively addressed these matters, it remains uncertain when and to what  degree the agency will realize the full benefits of its electronic processing  capability.
subsections: section_title: AeDib Implementation Schedule Was Generally Met through June 2005
paragraphs: The AeDib implementation schedule had called for all state DDSs and OHA  sites to be equipped with the electronic disability claims processing  capability by June 27, 2005, and October 3, 2005, respectively. Since  beginning the national rollout of the Document Management Architecture  and related DDS software enhancements and the electronic folder interface  software in late January 2004, the agency has largely met its  implementation schedule. As of late June 2005, SSA had fully or partially  implemented the electronic disability system in 53 of the 54 state DDS  offices and in 85 of the 144 OHA sites, as planned. The agency reported that  it expected to finish implementing the electronic disability system in the  one remaining DDS—New York—in October 2005.
SSA officials attributed the 4-month delay in the planned implementation at  the New York DDS to the need for additional time to interface the  electronic disability system with that state’s existing claims processing  capabilities. New York and Nebraska are the only two DDSs in which the  states’ claims processing capabilities are not supported by the common  hardware platform that the majority of DDSs use and that have developed  and rely on disability claims processing software that is unique to their  processing environments. As a result of New York’s efforts to develop and  test an electronic disability claims process, it had achieved a level of  electronic processing, including the capability to scan medical evidence  into its system, prior to SSA’s completion of the electronic disability  system. SSA and New York DDS officials agreed to interface the new  electronic disability system with portions of that state’s existing claims  processing capabilities.
In addition, SSA officials reported, as of early July 2005, that they expected  to meet the scheduled completion date of October 3, 2005, for 115 of the  144 OHA sites. They stated that the agency expected to complete  implementation of the electronic disability system at the remaining 29 OHA  sites approximately 1 month later, in November 2005. According to agency  officials, 10 of the 29 sites support claims that are processed by the New  York DDS. The agency delayed implementation at these sites in order to be  more in step with New York’s revised implementation schedule and with  anticipated time frames for when the DDS will be positioned to process  disability cases using the electronic folder. Regarding the remaining 19  sites, officials explained that the agency did not wish to train staff and  provide the electronic folder capability to OHA sites too far in advance of  when these offices expected to receive electronic cases from the DDSs,  believing that too much lag time between training and actual use of the  system could result in the staffs’ losing some of the knowledge and skills  they need to process cases electronically.
section_title: Operational and Other Concerns Could Impact the Electronic Disability System’s Reliability and Use
paragraphs: Although the roll out of the electronic disability system is moving toward  completion, the agency still has considerable work to accomplish before it  will be effectively positioned to process all disability claims in a fully  electronic environment. After implementing the electronic system, each  DDS must undergo an assessment of the quality and accuracy of its  electronic processing capabilities and must be certified by SSA to use the  electronic folder as its official disability claims record. This assessment,  referred to as the Independence Day Assessment, is intended to validate  that an office is ready to process 100 percent of the initial disability claims  and any reconsiderations that it receives in the electronic environment and  that the electronic folder can serve as the official disability claims record.  According to SSA Operation’s staff, the assessment involves examining the  disability office’s operations and claims processing tasks to ensure that  (1) the business process (e.g., the way in which the disability claims office  is organized to do its work) and the electronic processing environment are  compatible; (2) existing claims processing systems have the necessary  functionality to process electronic folders; and (3) staff can, when using  the electronic disability system, produce complete information that equals  what is contained in the paper folders.
As of early July 2005, SSA reported that only three state DDSs—Mississippi,  Illinois, and Hawaii—had completed assessments and been certified to  process all initial disability claims in a paperless electronic environment in  which the electronic folder is recognized as the official disability claims  record. SSA reported that it had certified Mississippi—the first state under  the national rollout—to process all of its initial disability claims  electronically by February 2005; the agency further reported that it had  completed certifications in June 2005 for Illinois—one of the three states  that had participated in a pilot test of the Document Management  Architecture in 2003—and for Hawaii, one of the smallest states (consisting  of 15 disability claims examiners), which completed its system’s  implementation in February 2005.
In discussing Mississippi’s certification, the DDS director stated that the  approximately 1-year time frame between the implementation and the  certification of the office’s system had been devoted to such tasks as  updating and testing software versions in order to give the office the full  complement of functionality that it would need to use the electronic folder  and to ensuring that the office’s business processes effectively supported  electronic processing by, for example, familiarizing staff with the electronic  capabilities, training them in using the capabilities, and testing the use of  scanning equipment in the office. The director added that, since Mississippi  was the first state to be assessed and certified, SSA had reviewed a  substantially larger number of disability cases (approximately 300) than it  intends to review in the assessments of other states using the same claims  processing software.
SSA officials said that, following Mississippi’s certification, the  Commissioner of Social Security had placed a moratorium on any  additional certifications pending SSA’s review of the assessment that had  been undertaken in that state. They said that the commissioner had wanted  to capture lessons learned from Mississippi’s assessment to identify any  needed improvements in the assessment process and to ensure that any  business or user concerns about the assessments were resolved before  they applied the process broadly across all DDSs and OHA sites. For  example, according to the officials, they learned that a smaller sample of  disability cases could be examined in subsequent offices using the same  software as Mississippi’s without diminishing the integrity of the  assessment and the related certification.
As of July 2005, SSA officials told us that they had resumed the  assessments and that the agency’s plans called for a total of seven state  DDSs to be certified to process claims electronically by the end of fiscal  year 2005. However, as indicated in table 1, not all of the 54 state DDSs are  expected to be certified to process initial disability claims and to use the  electronic folder as the official record until January 2007.
According to OHA’s deputy director, SSA expects to certify each OHA site  shortly after certifying the corresponding DDS office. The official noted  that because all OHA sites will rely on the same standard system (the Case  Processing Management System), their certification process is expected to  be less complicated than the process for the DDSs. Until they are certified,  offices that have already implemented the electronic disability system are  expected to maintain paper folders as well as electronic ones for any initial  disability cases that they process electronically. The paper folders will  continue to serve as the official records for these cases.
subsections: section_title: Operational Concerns Exist
paragraphs: Even as the agency proceeds in certifying states’ electronic capabilities,  however, operational concerns associated with the electronic disability  system could undermine its reliability and use. Officials in seven of the nine  DDS offices that we contacted (California, Delaware, Florida, Illinois,  Mississippi, North Carolina, and South Carolina) stated that operational  problems they had encountered while using the electronic disability system  had affected its performance and raised doubts about its reliability in  supporting their processing needs.
DDS officials stated, for example, that as SSA had brought the system  online at the different DDS offices and/or added new software to enhance  functionality, their staffs had encountered various operating problems that  affected the performance of the system. They stated that their offices had  experienced problems such as computer screen freezes, system  slowdowns, and system access issues—all of which had disrupted the  offices’ processing of claims. They described these problems as  unpredictable and random because they did not always occur consistently  among all of the offices using the same claims processing software or even  among examiners in a particular office. The officials added that although  SSA has been able to resolve many of the problems that affected their  ability to process claims, additional instances of screen freezes, system  slowdowns, and access issues have continued to occur throughout the  system’s implementation.
According to the manager of the South Carolina DDS, which implemented  the electronic disability system in March 2004, that office’s productivity had  been adversely affected by system slowdowns that resulted from having  inadequate network bandwidth to support its disability claims processing  operations. In July 2005, the manager stated that SSA had recently made  modifications to the office’s network architecture and had increased its  bandwidth by installing two additional communications lines; at that time,  the office was in the process of testing these enhancements. The manager  said that all of the office’s disability claims examiners had begun  processing all initial disability claims electronically and that, as a result of  the enhancements, they expected the office’s claims processing efficiency  and productivity to increase.
In addition, DDS officials in six offices (California, Delaware, Florida,  Mississippi, North Carolina, and South Carolina) reported problems with  the electronic forms that SSA had installed to facilitate the processing of  disability claims. The officials explained that, while using the electronic  forms, disability claims examiners had experienced slow system response  times or system freezes that had contributed to increased claims  processing times. Officials in California stated that they had stopped using  the electronic forms as a result of the problems that their staff had  encountered and instead were continuing to rely on paper forms. In a  February 2005 survey, the National Council of Disability Determination  Directors found that 22 DDSs had experienced problems with the  electronic forms and had reported that the slow pace involved in loading  and using these forms was barely tolerable. Further, based on its May 2005  quarterly evaluation of the electronic disability system, SSA reported that  one of the systems-related problems that disability processing offices  identified most frequently was the slow response times and lack of user- friendliness of the electronic forms.
Further, officials in five of the DDSs that we contacted among those that  had implemented the electronic disability system (California, Illinois,  Mississippi, North Carolina, and South Carolina) stated that their disability  examiners faced difficulties in reading medical evidence on screen and  performing certain case development or adjudication tasks because the  size of the computer monitors that they had been provided to process  medical evidence had proven inadequate. Users of the system—including  managers, claims examiners, and medical consultants—reported difficulty  with simultaneously viewing two documents on their monitors; some staff  reported that they had resorted to printing out or toggling between  documents to avoid using the split screen to review them. As a result of the  inadequacies associated with using the existing monitors, the users  reported that they needed longer periods of time to perform certain claims  adjudication tasks and that they had been unable to complete as many  cases per day as they could before they had the electronic disability  system.
Beyond these concerns, officials in four of the DDSs that we contacted told  us that, although their electronic capability had been implemented, they  had not been provided certain software enhancements that they needed to  fully process a claim electronically and that were critical to improving the  efficiency of their offices’ claims processing capabilities. Specifically,  Florida officials stated that their claims processing software did not  provide the capability to electronically notify staff of the actions that were  required to process a claim. As a result, the staff had to expend additional  time notifying each other of actions needed to process the claim by, for  example, sending e-mail notices. In addition, the director of the North  Carolina DDS stated that that office lacked the necessary software to  enable staff to electronically send claims files to SSA’s Disability Quality  Branch, which is responsible for conducting quality reviews of the  accuracy of DDSs’ disability determinations. The director added that staff  could not yet respond electronically to SSA components that requested  information on a particular claim that had been processed in their office.  Further, in Nebraska, the DDS manager stated that that office was in need  of additional software modifications to provide the functionality required  to electronically import all required documents into the electronic folder.  Finally, the manager of the California DDS stated that his office had lacked  the capability to electronically process nonmedical claims data that were  required to be included in the disability claims folders, such as a claimant’s  work history. The manager stated that they also had lacked the  functionality to electronically refer claims to medical consultants for  consultative examinations.
In light of the operational and other concerns that have been encountered  in using the electronic disability system, coupled with factors such as  having to concurrently maintain paper and electronic claims folders while  awaiting certification, both SSA and DDS managers acknowledged that the  DDS offices had exercised wide discretion in their use of the new system.  The President of the National Council of Disability Determination Directors  stated that two key factors had affected some DDSs’ decisions about  ramping up to full use of the system: (1) concerns about a drop in  productivity in a fully electronic environment and (2) the instability of the  electronic disability processing environment, particularly in terms of  system performance and software reliability. In this regard, officials in  eight DDS offices that we contacted—all of which had implemented the  electronic disability system by the end of June—reported varying levels of  usage, as shown in table 2.
Regarding the extent of their usage, managers in the Mississippi and Illinois  DDSs acknowledged that problems had been encountered following their  implementation of the electronic disability system but stated that they had  nonetheless chosen to expedite efforts to achieve full electronic processing  of disability claims in an attempt to minimize the inefficiencies associated  with having to maintain both paper and electronic disability folders.  Further, to help bring their states to full electronic processing, the  managers of the Mississippi and Illinois DDSs stated that they had  expended additional resources on overtime pay to disability examiners and  on additional support from the software vendor to alleviate and/or  establish workarounds for the operational problems that their examiners  had encountered. While Mississippi officials said that they were unable to  provide a dollar amount for their overtime usage, an Illinois DDS official  provided documentation indicating that between September 2003 and May  2005, that office had spent over $2 million on overtime, which assisted  them in processing disability claims in the electronic environment.
However, DDS managers in several other offices that we contacted stated  that, as a result of the problems with and the resulting unpredictability of  the electronic disability system, they had been reluctant to bring the system  to full use. They expressed reluctance to increase their use of the system  until a more reliable level of performance has been sustained, stating  generally that the current problems with the system could hamper their  ability to maintain their productivity levels.
For example, officials in the California DDS told us that the electronic  disability system had not been used to fully process any of the  approximately 450,000 initial claims that the office had received since it  had implemented the system in October 2003. The officials stated that  they had chosen not to ramp up the system until it proved to be more stable  and all critical processing capabilities had been delivered. The manager  believed that trying to use the system to process all of the office’s initial  disability claims before the problems affecting their system’s operations  were resolved and before all critical processing capabilities were delivered  would prevent the office from maintaining its productivity levels. In mid- July 2005, California DDS officials stated that the vendor supporting their  disability claims processing system had recently provided a software  enhancement that gave them the capability to fully process claims and that  the agency would begin a phased increase in the number of initial disability  claims it would process in the electronic environment. According to the  manager, each examiner would initially be assigned one disability case per  week to process electronically.
In addition, in Florida, DDS officials stated that they had limited the  number of claims being processed by their disability examiners until SSA  was able to enhance their software to achieve better user efficiency. As a  result, at the time of our review, only 109 of the office’s 487 disability  examiners were using the electronic system to process cases, and only  about 4 to 5 percent of initial disability claims were being processed  electronically. Further, while the Nebraska DDS’s electronic capabilities  were implemented in late June 2005, officials in that office stated that they  did not plan to ramp up their use of the system until about September 2005.  They explained that, lacking the software modifications required to  electronically import all documents into the electronic folder, the office  was reluctant to increase its use of the electronic disability system. They  stated that doing so would require them to commit additional resources to  scan documents that could not automatically be entered into the electronic  system. The officials added that they expect to receive additional software  modifications that they need to improve the efficiency of the office’s  electronic processing capability in the September 2005 time frame.
Given the current status of the electronic disability system, neither SSA nor  the state offices had yet been able to effectively assess or quantify benefits  resulting from its use. All of the managers of the DDS offices that we  contacted stated that they saw the potential for realizing substantial claims  processing improvements from using the system; nonetheless, these  managers—including the managers of the Mississippi and Illinois DDSs— stated that it was too early to determine whether and to what extent the  electronic disability system would contribute to processing improvements  in their offices. In their view, the system had not yet reached a level of  maturity where it was feasible to quantify the benefits of its use, due in  large measure to factors such as (1) the learning curve associated with  using the system; (2) current inefficiencies involved in having to maintain  paper folders until an office is certified to electronically process claims;  (3) certain DDSs’ decisions to not fully utilize the system until further  problem resolution; and (4) certain offices’ use of additional resources,  such as overtime and temporary hires, to support their processing of claims  following the system’s implementation. The managers added that  processing claims electronically had thus far taken longer and consumed  more resources than before the electronic system was implemented. In  addition, because of ongoing system implementation in the OHA sites,  along with the normal processing delays associated with bringing disability  claims to the appeals stage, these sites had not yet accrued enough  experience in using the electronic folder to make a reasonable assessment  of processing improvements.
In speaking to the concerns that were raised about the reliability and use of  the electronic disability system, SSA officials acknowledged the problems  that had been identified by the DDSs, and that as a result, current use of the  system among those offices varied considerably. However, these officials  said they believed that the majority of the DDS offices would be able to  bring their systems to full use with only a minimum of complications; they  viewed California’s concerns, in particular, as not having been  representative of other states’ experiences. Nonetheless, the officials said  that the agency had initiated a number of measures to address the  problems that had been encountered in using the system. For example,  they stated that the agency had established a new help desk to more readily  support those offices experiencing specific hardware and software  problems while using the electronic disability system. In addition, they  stated that SSA had assembled a work group to examine the DDSs’ use of  the electronic forms, with the intent of determining whether a more  suitable commercial-off-the-shelf product was available that could address  the problems currently being encountered with these forms. Regarding the  size of the computer monitors that disability examiners use, the officials  stated that the agency planned to conduct a pilot test to address concerns  with and identify a solution for ensuring that users have the monitors they  need.
SSA’s actions to address the outstanding concerns with its electronic  disability system represent a positive step toward achieving success in the  use of the new system. However, as of July 2005, the agency did not have an  overall strategy—articulating milestones, resources, and priorities—to  guide its efforts in efficiently and effectively resolving the operational  problems and system limitations being experienced with the electronic  disability system. For example, although the agency had established a work  group to explore options for resolving problems being encountered with  the electronic forms, it had not yet established plans and a time frame for  completing actions to address this concern. In addition, although the  agency planned to conduct a pilot test of computer monitors, it did not yet  have essential information to determine what type of equipment would best  meet the needs of the electronic disability system users or the resources  and time that it would need to devote to resolving this matter. Adequately  resolving the concerns with and gaining full acceptance and use of its  electronic capabilities will be essential to SSA’s achieving a more efficient  means of delivering disability benefits payments to its increasing  beneficiary population.
section_title: The Lack of Continuity of Operations Plans for the Electronic Disability System Places Claims Processing at Increased Risk
paragraphs: In addition to ensuring the immediate availability of the electronic  disability claims processing system by preventing operational problems  that could impact its performance and use, it is essential that SSA and the  DDSs have plans for mutually ensuring the continuity of this vital disability  benefits service in emergency situations. Federal law and guidance require  that agencies develop plans for dealing with emergency situations involving  maintaining services and protecting vital assets that could result from  disruptions, such as localized shutdowns due to severe weather conditions, building-level emergencies, or terrorist attacks. Moreover, this  guidance notes, a key element in developing a viable continuity capability  is identifying interdependencies among agencies that support the  performance of essential functions and ensuring the development of  complementary continuity of operations plans by those agencies that  provide information or data integral to the delivery of essential functions.  Such planning would include developing and documenting procedures for  continued performance of essential functions, identifying alternates to fill  key positions in an emergency and delegating decision-making authority,  and identifying vital electronic and paper records—along with measures  for ensuring their protection and availability.
However, SSA and the DDSs currently lack continuity of operations plans  to ensure that the DDS offices could continue to process disability claims  in the event of a short- or long-term disruption to the electronic disability  system. A September 2004 report, issued by SSA’s Acting Inspector General,  noted that the agency’s existing continuity of operations plan did not  address the information or the electronic disability claims processing  systems managed by the DDSs. The report further noted that, in relying  heavily on the DDSs, SSA would lack certainty about the availability of  information from these offices in the event of a disaster. Based on its  findings, the Acting Inspector General recommended that SSA implement a  complete and coordinated continuity of operations plan for the agency.
Officials in the nine DDSs that we contacted further stated that their offices  had not developed continuity of operations plans covering the electronic  disability claims processing capabilities; yet, in discussing this matter,  officials considered such plans to be vital to successfully ensuring the  continued processing of disability claims. Officials in the Mississippi DDS  stressed, for example, that in the event of a disruption to their system’s  communications with SSA’s headquarters computer facilities, disability  examiners would be unable to access the Document Management  Architecture repository, send or receive faxes via the electronic system, or  access the electronic forms they needed to support their work. In addition,  they stated that medical examiners would be unable to perform tasks in  support of disability determinations.
In discussing this matter, SSA officials acknowledged that their existing  plan had not addressed the electronic claims processing functions of the  DDSs. They stated that the agency had recently initiated actions to help  resolve this limitation by having a contractor develop a business continuity  planning strategy. According to the officials, the contractor began work on  this strategy in May 2005 and is expected to deliver an initial report in  September 2005. However, the officials did not articulate the agency’s  specific plans or a time frame for ensuring that its continuity of operations  plan addresses the electronic claims processing functions of the DDS  offices or for ensuring that these offices develop and implement  complementary plans for continuing essential functions to support the  disability claims process in an emergency situation.
As SSA moves toward full implementation and use of the electronic  disability system, the capability to continue essential electronic disability  claims processing functions in any emergency or situation that may disrupt  normal operations becomes increasingly important. In view of the fact that  three states have already begun using electronic folders as official  disability claims records, it is imperative that both SSA and the DDSs have  plans that address the state systems’ interdependencies with the electronic  disability claims processing components and that include preparations for  continuing to provide critical claims processing services in the event of a  disaster. Without continuity of operations plans, SSA will lack assurance  that it is positioned to successfully sustain the essential delivery of  disability benefits during unforeseen circumstances.
section_title: SSA’s Actions toward Implementing AeDib Have Addressed Some, but Not All, of Our Prior Recommendations for Improvement
paragraphs: As discussed earlier, in reporting on this initiative in March 2004, we  recommended that the agency take measures to reduce the risks associated  with its electronic disability strategy before continuing with its national  rollout of this capability. These recommendations called for the agency to  (1) resolve critical problems that it had identified in pilot testing of the  electronic disability system and conduct end-to-end testing of the  interrelated system components, (2) ensure that users approved the  software being developed and that systems were certified for production,  (3) finalize AeDib risk mitigation strategies, (4) validate AeDib cost and  benefit estimates, and (5) improve communications with and effectively  address the concerns of disability stakeholders and users involved in the  initiative.
In proceeding with the implementation of its electronic disability system,  SSA has taken actions related to three of the five recommendations.  Specifically, SSA officials provided evidence indicating that the agency has  taken measures to ensure that users approve new software and that it  certifies its systems for production. For instance, we reviewed agency  documentation reflecting disability system users’ approval of new software  and SSA’s certification of over 50 cases where software was put into  production from February 2004 (shortly after the national rollout of the  electronic disability system began) through October 2004. By continuing to  validate its software and certify its systems, SSA should be able to better  ensure that its systems are ready for production and will be acceptable to  their end users.
In addition, regarding our recommendation that it validate AeDib cost and  benefit estimates, SSA has initiated studies, including quarterly evaluations  of the initiative, that could help it assess the electronic disability system’s  performance, costs, and processing times. The agency also has plans for  conducting post-implementation reviews of the system, which include  comparing baseline and current information to evaluate the system’s  impact on performance, productivity, and cost—measures that if  implemented fully and effectively could help validate AeDib’s costs and  benefits.
Further, although the agency has not implemented a communications plan,  DDS officials, including the President of the National Council of Disability  Determination Directors, told us that SSA had improved its  communications with these offices and had made progress in including  DDS officials in AeDib decision making. Such action reflects a positive  move toward involving stakeholders in the agency’s efforts. Nonetheless,  we continue to advocate the importance of having a clear and  comprehensive plan for communicating with stakeholders to sustain vital  user acceptance and achieve full use of the electronic disability system.
However, SSA did not demonstrate any actions on two of the  recommendations. As we previously noted, SSA did not take steps to  resolve all of the critical problems that had been identified during pilot  testing of the Document Management Architecture or to conduct end-to- end testing of the interrelated electronic disability system components  before continuing with the national rollout of this system. Resolving all  critical problems and conducting end-to-end testing of the interrelated  system components prior to their implementation could have limited the  problems that SSA and the DDSs have encountered with the electronic  disability system’s operation. In the absence of such testing, as SSA moves  to achieve certification and full use of the system, it will be essential that  the agency work diligently to identify and alleviate the problems that could  impact the successful outcome of this technically complex initiative.
Further, while our earlier work noted that the agency had identified the  risks associated with the AeDib initiative and the related automation  projects, SSA has not provided any evidence that it has yet completed risk  mitigation strategies for these projects. Best practices and federal guidance  advocate risk management—including mitigation strategies—to reduce  risks and achieve schedule and performance goals. Among the high-level  risks identified, SSA noted that the overall availability of the Document  Management Architecture might not meet service-level commitments to its  users. Because the DDSs could not effectively perform their work if the  data repository or document scanning and imaging capabilities provided by  the architecture were not available, it is critical that SSA have mitigation  strategies in place to reduce this risk and to help ensure that the DDSs can  meet their performance goals. In the continued absence of risk mitigation  strategies, the agency lacks a critical means of ensuring that it can prevent  circumstances that could impede a successful project outcome.
section_title: Conclusions
paragraphs: SSA is relying on its electronic disability system to play a vital role in  improving service delivery to disabled individuals under its disability  programs, and the agency has made considerable progress in implementing  this system. However, even as the agency moves closer to achieving full  systems implementation, important work still needs to be accomplished to  ensure the system’s success. Among the agency’s critical tasks will be  certifying that all of the SSA and state DDS offices are prepared to process  all disability claims electronically. Yet, a number of DDSs have concerns  about the operations and reliability of the electronic disability system,  noting, for example, inadequacies in electronic forms and the computer  monitors used to view claims information, as well as limitations in  electronic processing capabilities—factors that they say have slowed  system performance and impeded their productivity, and that have resulted  in the levels of system usage varying among the DDSs. Further, as the  agency moves to complete the system’s implementation, it will be essential  that SSA and the DDSs have plans for mutually ensuring the continuity of  this vital disability benefits service in emergency situations. The absence of  a defined strategy or plans for ensuring that the electronic disability system  will operate and will meet users’ needs as intended could threaten the  continued progress and success of this initiative and make it uncertain  when the agency will realize the full benefits of the AeDib initiative.
section_title: Recommendations for Executive Action
paragraphs: To further reduce the risks to SSA’s progress in successfully achieving its  electronic disability claims processing capability, we recommend that the  Commissioner of Social Security take the following two actions:  develop and implement a strategy that articulates milestones, resources,  and priorities for efficiently and effectively resolving problems with the  electronic disability system’s operations, including (1) identifying and  implementing a solution to improve the use of electronic forms, (2)  identifying and implementing a solution to address concerns with  existing computer monitors, and (3) ensuring that the DDSs have the  necessary software capabilities to fully and efficiently process initial  claims in the electronic processing environment; and  ensure that the state DDSs develop and implement continuity of  operations plans that complement SSA’s plans for continuing essential  disability claims processing functions in any emergency or other  situation that may disrupt normal operations.
section_title: Agency Comments and Our Evaluation
paragraphs: In written comments on a draft of this report, the Commissioner of Social  Security expressed concern about our references to the agency’s testing of  its electronic disability system and offered additional views regarding our  discussion of the state disability determination services’ use of overtime to  assist in electronically processing disability claims. In addition, the agency  disagreed with one of our recommendations and agreed with the other.
Regarding the testing of its electronic disability system, SSA questioned  why our report had concluded—months after the agency’s rollout of the  system—that performing end-to-end testing of the interrelated system  components was still critical to the initiative’s success. The agency  believed that we should delete references to the criticality of such testing  for this initiative so as not to lend confusion to and cast doubt on its rollout  experience.
In discussing SSA’s decision not to conduct end-to-end testing before  rolling out the electronic disability system, our report responds to one of  the two stated objectives of our study—to determine the actions that SSA  has taken in response to our prior recommendations on the AeDib  initiative. In doing so, we did not conclude that it remains critical for SSA  to perform end-to-end testing at this stage in the system’s implementation.  Rather, in speaking to this issue, we described the agency’s response to our  prior recommendation that it conduct end-to-end testing before proceeding  with the national roll out, and we emphasized the importance of such  testing as a means of limiting the types of problems that DDS officials told  us they have encountered with the system’s operation. As our report  stresses, in the absence of end-to-end testing, it is essential that SSA remain  diligent in identifying and alleviating the problems that could impact the  successful outcome of the AeDib initiative as the agency moves to achieve  full certification and use of the electronic disability system.
Concerning the DDSs’ reported cost and use of overtime, SSA emphasized  its belief that a number of factors other than the electronic disability  system had contributed to the Illinois DDS’s increased use of overtime. For  example, the agency said that overtime had been used to compensate for  the loss of DDS employees that had accepted the state’s offer of early  retirement. Based on our discussions with Illinois DDS officials, we  understand that the office may not have used overtime solely to support its  electronic processing of disability claims. However, as noted in our report,  the Illinois officials told us that they had relied on overtime to assist in  bringing their office to full electronic processing of disability claims using  the new system. We have included language in the report to more clearly  reflect this point.
Beyond these points of discussion, SSA disagreed with our  recommendation that they develop and implement a strategy that  articulates milestones, resources, and priorities for efficiently and  effectively resolving problems with the electronic disability system’s  operations, including (1) identifying and implementing a solution to  improve the use of electronic forms, (2) identifying and implementing a  solution to address concerns with existing computer monitors, and (3) ensuring that the DDSs have the necessary software capabilities to fully  and efficiently process initial claims in the electronic processing  environment. Specifically, the agency stated that it had substantially  improved its electronic forms and already has a strategic project plan to  address residual issues concerning them. It noted that a work group  established in January 2005 had examined this issue and that many key  recommendations had been adopted to improve the performance of and  customer satisfaction with the electronic forms. SSA added that it is using a  contractor to examine alternatives and determine if more robust software  is available to better meet users’ needs, and that it may incorporate new  software into the electronic disability claims process.
Our report recognized that SSA had established a work group to explore  options for resolving problems with the electronic forms. However, during  our study, SSA officials could not provide a time table for the work group’s  efforts and, despite our inquiries, gave no indication that the agency had a  defined strategy for addressing this area of concern. Further, SSA did not  inform us of a specific contract to examine software alternatives or of the  specific recommendations that have been made to correct problems with  the forms and the improvements in performance and customer satisfaction  that have been achieved. Thus, we did not have an opportunity to evaluate  and comment on the agency’s actions in this regard. Given the DDSs’  expressed concerns about the electronic forms throughout the course of  our study and as reflected in SSA’s own quarterly evaluation of the  electronic disability system, we continue to stress the importance of SSA  developing and implementing a strategy to guide its efforts toward  efficiently and effectively resolving problems with this important electronic  capability.
Regarding its existing computer monitors, SSA stated that it already has a  plan in place to evaluate this issue and potential ergonomic solutions. The  agency stated that it had awarded a contract to conduct a controlled test of  the impact of various monitor configurations on ergonomics and  productivity for all primary users of the electronic disability system, and  that a final report is due in January 2007. It added that when final decisions  are made regarding the appropriate monitor requirements, a business plan  will be deployed if warranted. As noted in our report, SSA officials did  inform us of their intent to conduct a pilot test to identify potential  solutions for ensuring that users have appropriate monitors. However, the  officials could not provide contractual and other pertinent documents  explaining the pilot study and did not inform us of any plan that the agency  had developed to guide this effort. Given that SSA does not anticipate its  final report on its test of the monitor configurations until January 2007, and  does not intend to consider the deployment of a business plan until final  decisions are made regarding the monitor requirements, we believe that the  agency could benefit from a strategy articulating clear milestones,  resources, and priorities to guide its efforts toward finalizing decisions on  its computer monitors and ensure that all users’ concerns are fully and  effectively addressed.
Further, regarding the DDSs’ software capabilities, SSA stated that it had  established a help desk to provide support for specific hardware and  software issues associated with the electronic disability system, and that it  had no information that there are outstanding issues concerning DDS  software support. Moreover, the agency stated that our report had  inaccurately described supposed issues related to implementing the  electronic disability system in light of some states having not yet been  certified to fully process cases electronically. For example, SSA  commented that because Florida had not yet been certified to fully process  cases electronically, it was premature to expect that the electronic  disability system would notify staff of actions to process claims. Similarly,  SSA stated that because Nebraska had not been certified to process cases  electronically, it was premature to indicate that the state needed additional  software modifications to electronically import all required documents into  the electronic folder. Further, the agency said that it was inaccurate for us  to report that the North Carolina DDS lacked the necessary software to  enable staff to electronically send claim files to SSA’s Disability Quality  Branch, since all but two states—New York and Nebraska—had this  software. It added that the agency’s planning and electronic disability  system roll out had addressed software capabilities and other issues  impacting individual DDSs, negating the need for a formal strategy, as we  have recommended.
We disagree that our report inaccurately described issues related to  implementing the electronic disability system or that it prematurely  highlighted limitations in certain states’ use of the system. A primary aspect  of our review involved examining SSA’s progress in rolling out the  electronic disability system, including the state DDSs’ experiences in  implementing and using the system. In this regard, DDS officials apprised  us of their electronic disability claims processing capabilities, and in  certain instances, of their need for additional software capabilities that  they deemed essential to improving their offices’ processing efficiency and  sustaining productivity in the electronic environment. As of mid-July 2005,  North Carolina DDS officials told us that they lacked the necessary  software to enable staff to electronically send claim files to SSA’s Disability  Quality Branch. We recognize that SSA does not expect to complete all  states’ certifications until early 2007. However, in our view, until the agency  ensures that all DDSs have full electronic processing capabilities, it will not  be positioned to effectively assess the extent to which the electronic  disability system can contribute to a more efficient and effective disability  claims process.
SSA further stated that system availability issues had been addressed, as  evidenced by its current fiscal year data on key electronic disability system  components (e.g., the Electronic Disability Collect System, the Case  Processing Management System, and the Document Management  Architecture). However, our report does not convey that these key  electronic disability system components were not available for use. Rather,  the concerns discussed in our report pertain to the inefficiencies that DDS  officials said they had encountered in using the electronic disability  system. For example, DDS officials pointed to the continuing instances in  which they had experienced processing slowdowns when using electronic  forms, which ultimately had impeded their disability claims processing  capability. Thus, we stand by our recommendation that SSA develop and  implement a strategy to ensure that the DDSs have the necessary software  capabilities to fully and efficiently process claims in the electronic  environment.
Regarding our second recommendation, the agency agreed to ensure that  the state DDSs develop and implement continuity of operations plans that  complement SSA’s plans for continuing essential disability claims  processing functions during emergencies or other disruptions to normal  operations. In this regard, the commissioner stated that SSA is highly  committed to providing uninterrupted services to the public and had hired  a contractor to develop business continuity plans for the DDSs that  document how these offices would respond to long- and short-range  disruptive events. The actions that SSA stated that it is taking should help  improve the agency’s and the DDSs’ ability to ensure the continuity of vital  disability benefits services in emergency situations.
In addition to the aforementioned comments, SSA provided technical  comments, which we have incorporated, as appropriate. Appendix II  reproduces the agency’s comments on our draft report.
As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of this report to the  Commissioner of Social Security and the Director, Office of Management  and Budget. Copies will also be available at no charge on our Web site at  www.gao.gov.
Should you have any questions on matters contained in this report, please  contact me at (202) 512-6240. I can also be reached by email at  koontzl@gao.gov. Contact points for our Offices of Congressional Relations  and Public Affairs may be found on the last page of this report. Key  contributors to this report are listed in appendix III.
section_title: Objectives, Scope, and Methodology
paragraphs: Our objectives were to (1) assess the current status of SSA’s accelerated  implementation of its electronic disability system—the initiative known as  AeDib and (2) identify actions the agency has taken in response to our  prior recommendations on this initiative. To assess the agency’s status in  implementing its electronic disability system, we analyzed relevant project  management documentation including schedules, project plans, and  reports documenting the status of the system’s rollout to the 54 state  disability determination service (DDS) offices and SSA’s 144 Office of  Hearings and Appeals (OHA) sites. In addition, we reviewed technical  documentation, such as software project scope agreements and software  development plans, to assess the development, implementation, and  operation of the electronic disability system. We also reviewed system  release certifications to ensure that systems had been validated and  certified.
To identify issues that arose during the AeDib implementation process, we  reviewed problems reported by the DDSs via SSA’s Change Asset Problem  Reporting System. We also reviewed the results of the National Council of  Disability Determination Directors’ February 2005 survey of its member  DDS offices on their experiences in implementing the electronic disability  system, as a means of identifying any problems and issues that the states  had encountered. In addition, we reviewed reports on the system’s  implementation, performance, and capacity that had been prepared by the  Council and the DDSs.
We supplemented our analysis with interviews of SSA officials in the  Offices of Operations, Systems, Disability and Income Security Programs,  and Hearings and Appeals. We also interviewed DDS officials in nine states:  California, Delaware, Florida, Illinois, Mississippi, Nebraska, New York,  North Carolina, and South Carolina. In addition, we interviewed the  President of the National Council of Disability Determination Directors, an  organization that represents the DDSs.
Our selection of the nine states was based on the following criteria:  The Mississippi DDS was the first state to which the electronic disability  system was rolled out, as well as the first state to achieve total  electronic processing of initial disability cases.
The California, Illinois, and North Carolina DDSs had participated in  initial pilot tests of the electronic processing system, which had  included assessing use of the Document Management Architecture.
The Florida and South Carolina DDSs were states that received the  electronic disability system early in the implementation schedule.
The New York and Nebraska DDSs posed potential unique challenges as  the only two “independent” states, in which their existing claims  processing capabilities were not supported by the common hardware  platform that the majority of DDSs used and that had developed and  were relying on disability claims processing software that was unique to  their processing environments.
The Delaware DDS was managed by the President of the National  Council of Disability Determination Directors.
We conducted site visits at two DDSs—Mississippi and South Carolina—to  observe the electronic processing system in operation, and at OHA sites in  these same states to discuss their experiences in implementing and using  the electronic folder and their preparation for receiving appeals of initial  claims that had been processed electronically in the respective state DDS  offices.
To determine what actions SSA had taken toward implementing our prior  recommendations on the electronic disability system, we obtained and  reviewed software project scope agreements, software development plans,  user validation and system certification plans, and AeDib component  security risk assessment documentation. We also interviewed agency  officials regarding the status of their actions on each of the  recommendations made in our March 2004 report on AeDib. In addition, we  discussed SSA’s efforts to improve communications on the initiative’s  implementation with DDS officials in each of the offices that we contacted  and with the President of the National Council of Disability Determination  Directors.
We conducted our work at SSA’s headquarters in Baltimore, Maryland, and  at selected DDS and OHA offices in Jackson, Mississippi, and Columbia,  South Carolina, from October 2004 to July 2005, in accordance with  generally accepted government auditing standards.
section_title: Comments from the Social Security Administration
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Valerie C. Melvin, Assistant  Director; Michael A. Alexander; J. Michael Resser; and Eric L. Trout made  significant contributions to this report. Neil J. Doherty and Joanne Fiorino  also contributed to the report.