Social Security Administration: Strategic Workforce Planning Needed to Address Human Capital Challenges Facing the Disability Determination Services
Published: 2004-01-27T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: SSA oversees and fully funds primarily state-operated DDSs that determine whether applicants are eligible for disability benefits. The disability examiners employed by the DDSs play a key role in determining benefit eligibility. This report examines (1) the challenges the DDSs face today in retaining and recruiting examiners and enhancing their expertise; (2) the extent to which the DDSs engage in workforce planning and encounter obstacles in doing so; and (3) the extent to which SSA is addressing present and future human capital challenges in the DDSs.
section_title: What GAO Found
paragraphs: GAO found--through its survey of 52 of the 54 Disability Determination Service (DDS) directors and interviews with SSA officials and DDS staff--that the DDSs face three key challenges in retaining examiners and enhancing their expertise. High turnover: Over half of all DDS directors surveyed said that examiner turnover was too high in their offices. We found that examiner turnover was about twice that of federal employees performing similar work. Nearly twothirds of all directors reported that turnover has increased SSA's hiring and training costs and claims-processing times. And two-thirds of all directors cited stressful workloads and noncompetitive salaries as major factors that contributed to turnover. Recruiting and hiring difficulties: More than three-quarters of all DDS directors said they had difficulties over a three-year period in recruiting and hiring examiners. Of these, more than three-quarters said these difficulties contributed to increases in claims-processing times, examiner caseload levels, backlogs, and turnover. More than half of all directors reported that state-imposed compensation limits contributed to hiring difficulties. Gaps in key skills: Nearly one-half of all DDS directors said that at least a quarter of their examiners needed additional training in areas critical to disability decision-making. Over half of all directors cited factors related to high workload levels as obstacles to examiners' receiving additional training. Despite the workforce challenges facing them, a majority of DDSs do not conduct long-term, comprehensive workforce planning. In prior reports, GAO found that such planning should include key strategies for recruiting, retaining, training, and otherwise developing a workforce capable of meeting long-term agency goals. However, of the DDSs that engage in longer-term workforce planning, a majority have plans that lack such key workforce planning strategies. Directors cited numerous obstacles to long-term workforce planning, such as lengthy state processes to approve DDS human capital changes. SSA's workforce efforts have not sufficiently addressed current and future DDS human capital challenges. Federal law requires agencies to include in their annual performance plans a description of the human capital strategies needed to meet their strategic goals. However, GAO's review of key SSA planning documents shows they do not include a strategic human capital plan that addresses current and future DDS human capital needs. Thus, SSA does not link its strategic objectives to a workforce plan that covers the very people who are essential to accomplishing those objectives. GAO also found that SSA has not provided human capital assistance in a consistent manner across the DDSs and that SSA's effectiveness in helping the DDSs negotiate human capital changes with the states can be limited by such factors as state budget problems and personnel rules. Finally, SSA has not used its authority to establish uniform human capital standards, such as minimum qualifications for examiners, which would address, on a nationwide basis, some of the DDS challenges.

section_title: Letter
paragraphs: In 2002, the Social Security Administration’s (SSA) Disability Insurance  (DI) and Supplemental Security Income (SSI) programs paid about $74.1  billion to about 8.5 million individuals with disabilities. Under the Social  Security Act, SSA oversees and fully funds 54 primarily state-operated  Disability Determination Service (DDS) offices that determine whether  applicants are eligible for disability benefits. Key to the accuracy and  timeliness of these disability determinations are the more than 6,500  disability examiners employed by the DDSs to review medical and  vocational evidence and help decide eligibility for disability benefits. The  critical role played by the examiners will likely increase in the future, with  the projected dramatic growth over the next decade in the number of  applications for disability benefits as baby boomers enter their disability- prone years.
In our prior work, we have noted that the DDSs are confronting an  impending retirement wave of skilled staff and stiff competition in the  labor market for qualified staff. At the same time, SSA is facing problems  with the accuracy and timeliness of its disability determinations. Beyond  these immediate challenges, the design of SSA’s disability programs  remains grounded in outmoded concepts of disability that persist despite  scientific advances and economic and social changes that have redefined  the relationship between impairments and the ability to work. Because  other federal disability programs are also not in line with the current  status of science and the labor market, we designated modernizing federal  disability programs—including SSA’s DI and SSI programs—as a high-risk  area in 2003. In September 2003, the Commissioner unveiled her vision of  a long-term strategy for improving the disability claims process to enhance  timeliness and accuracy of decisions and for testing work incentives and  opportunities aimed at helping people with disabilities return to work.  The success of such a fundamental reorientation of SSA’s disability  determination process will depend greatly on having the staff with the  right skill mixes and areas of expertise available when and where needed.  DDS workforces will be a critical component in any future restructuring  undertaken by SSA to modernize its disability programs.
In view of the significance of human capital management in the DDSs, this  report addresses (1) the challenges the DDSs face today in retaining and  recruiting examiners and enhancing their expertise, (2) the extent to  which the DDSs engage in workforce planning and encounter obstacles in  doing so, and (3) the extent to which SSA is addressing present and future  human capital challenges in the DDSs.
To address these issues, we surveyed directors of 52 of the 54 primarily  state-operated DDSs. Our survey included questions about long-term  workforce planning, recruiting and hiring, compensation, training and  development, and retention of disability examiners. We also collected  human capital data from the federal DDS, which provides case-processing  assistance to state DDSs during periods of high workload demands, among  other responsibilities.
For the purposes of this report, strategic workforce planning is a  framework for decision-making that aims to ensure that an organization  has the people with the right skills, available when and where needed, to  respond to change and accomplish the agency’s strategic goals. To be  effective, workforce planning must be fully integrated with the agency’s  mission and goals and must be based on accurate and comprehensive  workforce data. While such planning can include a range of programs and  strategies, our prior work has found that the following strategies are key  to effective workforce planning, including  recruiting strategies,  retention strategies,  training and professional development strategies,    compensation strategies,    performance expectation and evaluation strategies,    employee-friendly workplace strategies,    succession planning and strategies for maintaining expertise in the long    contingency plans, in the event that resource levels do not meet  expectations.
In addition, we reviewed relevant documents, including SSA laws,  regulations, and procedures, and other pertinent laws. We also obtained  and analyzed human capital data from DDSs, SSA, and other federal  agencies. We interviewed disability examiners and their managers at two  DDSs to gain an in-depth understanding of the issues related to our  objectives. We also visited three SSA regional offices, interviewing  officials who are responsible for DDS management assistance and serve as  liaisons between SSA regional offices, the DDSs, and their respective state  governments. In addition, we interviewed SSA officials at headquarters  and a variety of key stakeholders such as officials of the National Council  of Disability Determination Directors, the National Association of  Disability Examiners, and staff of the Social Security Advisory Board. We  performed our work in accordance with generally accepted government  auditing standards between September 2002 and October 2003. For more  details about our scope and methods, see appendix I. For a copy of our  survey, see appendix II.
subsections: section_title: Background
paragraphs: The DI and SSI programs are the two largest federal programs providing  cash assistance to people with disabilities. The DI program, established in  1956 by the Social Security Act, provides monthly cash benefits to workers  with disabilities (and their dependents and survivors) whose employment  history qualifies them for disability benefits. In 2002, SSA paid about $55.5  billion in DI benefits to 5.5 million workers with disabilities (age 18 to 64).  SSI is a means-tested income assistance program created in 1972 that  provides a financial safety net for individuals who are aged or blind or  have other disabilities and who have low income and limited resources.  Unlike the DI program, SSI has no prior work requirement. In 2002, SSA  paid about $18.6 billion in SSI federal benefits to about 3.8 million people  with disabilities (age 18 to 64).
subsections: section_title: SSA’s Disability Determination Process
paragraphs: To be considered eligible for benefits for either SSI or DI as an adult, a  person must be unable to perform any substantial gainful activity by  reason of a medically determinable physical or mental impairment that is  expected to result in death or that has lasted or can be expected to last for  a continuous period of at least 12 months. Work activity is generally  considered to be substantial and gainful if the person’s earnings exceed a  particular level established by statute and regulations.
To obtain disability benefits, a claimant must file an application online, by  phone or mail, or in person at any of SSA’s field offices. If the claimant  meets the non-medical eligibility criteria, the field office staff forwards the  claim to the appropriate DDS office. DDS staff—generally a team  composed of disability examiners and medical consultants—obtains and  reviews medical and other evidence as needed to assess whether the  claimant satisfies program requirements, and makes the initial disability  determination. If the claimant is not satisfied with the decision, the  claimant may ask the DDS to reconsider its finding. If the claimant is not  satisfied with the reconsideration, the claimant may request a hearing  before one of SSA’s federal administrative law judges in an SSA hearing  office. If the claimant is still dissatisfied with the decision, the claimant  may request a review by SSA’s Appeals Council.
section_title: The Federal-State Relationship
paragraphs: The 1954 amendments to the Social Security Act specified that disability  determinations would be made by state agencies under individual  contractual agreements with SSA. Under these agreements, SSA’s primary  role was to fund the states’ disability operations. However, following  criticism from GAO and others about the quality and uniformity of the  disability determination process, Congress amended the Social Security  Act in 1980 to strengthen SSA management of the disability programs and  allow greater SSA control and oversight of the DDSs. The 1980  amendments directed SSA to issue regulations specifying performance  standards and administrative requirements to be followed to assure  effective and uniform administration of disability determinations across  the nation.
The regulations issued by SSA, which established the current federal-state  relationship, allow SSA to remove the disability determination function  from a state if the DDS fails to make determinations that meet thresholds  for performance accuracy and processing time. SSA’s regulations give  DDSs maximum managerial flexibility in meeting the performance  standards, allowing them to retain substantial independence in how they  manage their workforce. For example, under the regulations, the DDSs  are to follow state personnel standards in selection, tenure, and  compensation of DDS employees.
As employees of the state, DDS staff are subject to the rules and  regulations of each state’s individual personnel classification system.  Classification systems generally categorize positions on the basis of job  responsibilities and the knowledge, skills, and competencies required to  perform them. Within a classification system, a group of positions that  have sufficiently similar responsibilities are put in the same class.  Arranging positions in classes with common levels of difficulty and  responsibility makes it possible to set ranges of compensation for whole  classes of jobs across multiple state agencies. Specifying the  responsibilities of each position also allows the state to identify and  develop effective hiring qualifications, promotion criteria, and training  requirements. The development and operation of such a classification  system depend upon the adequacy of information about individual  positions.
section_title: Description of the DDSs and the Disability Examiner Position
paragraphs: Within the federal-state relationship, each DDS reports to its own state  government, usually to a parent agency such as the state vocational  rehabilitation agency. DDS staff generally include a variety of positions,  such as medical consultants, vocational specialists, quality assurance  personnel, as well as disability examiners. The number of disability  examiners varies substantially among the DDSs. Data from our survey  show that the number of full-time permanent examiners in each DDS  ranged from 9 to 529 at the end of fiscal year 2002. Our prior work has  found that the examiner’s job—which involves working with medical  consultants to determine impairment severity, ability to function, and  disability benefit eligibility—requires considerable expertise and  knowledge of complex regulations and policies. And according to the  Social Security Advisory Board, changes in agency rules and in the types  of disability claims received by the DDSs have made disability   decision-making more subjective and difficult. In addition, as part of its  efforts to reduce claims-processing times, SSA has been testing a new  disability examiner position called the single decision-maker (SDM),  which would expand an examiner’s authority to independently decide  claimants’ eligibility for benefits. 20 DDSs are testing this new position.
Qualification requirements for new examiner hires vary substantially  among the states. While five DDSs require a master’s or a registered  nursing degree for certain new examiner hires, figure 1 shows that over  one-third of all DDSs can hire new examiners with either a high school  diploma or less. In addition, data show that examiners in nearly one-half  of all DDSs are covered by union agreements, and issues related to  compensation levels, hiring and promotion procedures, and weekly hours  worked are open to union negotiation in the majority of these DDSs.
To enhance the skills of both new and experienced examiners, SSA  provides a number of optional training tools to the DDSs, including written  materials covering new examiner basic training, interactive video  programs supplementing basic training and providing refresher training  and updates on policy changes, and materials and presentations provided  by the regional offices and SSA headquarters. However, states have  primary responsibility for training examiners, and many DDSs adapt or  supplement SSA’s training to meet their examiners’ training needs. DDSs  generally provide new examiners with SSA’s basic examiner training,  followed by extensive on-the-job training, including mentoring by  experienced examiners who guide the less experienced examiners in  becoming more proficient in the disability claims process. New hires  generally are not considered fully proficient until after one to two years of  experience.
The DDSs’ ability to hire examiners is affected by both SSA and state  government funding decisions and hiring policies. SSA determines the  funding available for each DDS and advises the DDSs about the number of  full-time equivalent staff supported by this funding, and SSA adjusts these  levels throughout the fiscal year based on workload fluctuations and  funding availability. Normally SSA allows DDSs to replace staff who leave  the DDS as long as they remain within authorized staffing levels, but for  over half of fiscal year 2003, SSA froze DDS hiring, preventing DDSs from  hiring new examiners or replacing those who had left. SSA officials told us  that the temporary freeze was necessary to ensure that SSA’s expenditures  did not exceed authorized levels and to avoid future layoffs of DDS staff.
DDSs also have experienced state government hiring restrictions in recent  years. Despite full federal funding, under the current federal-state  relationship, DDSs generally cannot spend funds for new personnel  without the approval of their state governments. States currently are  facing severe budget crises, causing them to cut their payrolls for most  state government functions. When states use methods such as hiring  freezes, reductions in force, and early retirement incentives to limit  spending on state employee payrolls, these policies sometimes prevent  DDSs from hiring and retaining examiners at levels authorized by SSA.
section_title: Modernizing Federal Disability Programs Designated as a High-Risk Area
paragraphs: In earlier reports, we have noted that SSA’s disability determination  process is mired in concepts from the past and needs to be brought into  line with the current state of science, medicine, technology, and labor  market conditions. With other federal disability programs similarly  structured around outmoded concepts, we designated modernizing federal  disability programs—including SSA’s DI and SSI disability programs—as a  high-risk area in 2003. (See appendix III for a list of GAO reports on  modernizing federal disability programs.) We made this designation owing  in part to SSA’s (1) outmoded concepts of disability, (2) lengthy  processing times, and (3) decisional inconsistencies:    SSA’s outmoded concepts of disability. While technological and  medical advances and societal changes have increased the potential for  some people with disabilities to participate in the labor force, few DI and  SSI beneficiaries leave the disability rolls to work. Our prior work shows  that, unlike some private sector disability insurers and social insurance  systems in other countries, SSA does not incorporate into its disability  eligibility assessment process an evaluation of what is needed for an  individual to return to work. These private insurers and other social  insurance systems have access to staff with a wide range of expertise to  apply, not only in making eligibility decisions, but also in providing return- to-work assistance. We have recommended that SSA develop a  comprehensive return-to-work strategy that integrates earlier  identification of work capacities and the expansion of such capacities by  providing return-to-work assistance for applicants and beneficiaries.  Adopting such a strategy is likely to require fundamental changes to the  disability determination process, as well as changes to staff skill mixes and  areas of expertise.
Lengthy processing times for disability claims. The disability claims  process can be lengthy, with many individuals who appeal SSA’s initial  decision waiting a year or longer for final decisions on their benefit claims.  According to SSA, a claimant can wait as long as 1,153 days from initial  claim through a decision from the Appeals Council. As one means of  reducing its claims-processing time, SSA aims to eliminate backlogs for  initial disability claims, hearings, and appeals by 2008. Nevertheless,  growth in the disability claims workload is likely to exacerbate SSA’s  claims-processing challenges: SSA expects the DI rolls to grow by 35  percent between 2002 and 2012.
Inconsistencies in disability decisions. SSA has had difficulty ensuring  that decisions regarding a claimant’s eligibility for disability benefits are  accurate and consistent across adjudicative levels and locations, raising  questions about the fairness, integrity, and cost of these programs. For  example, the Social Security Advisory Board has shown wide variances  among the DDSs in rates of allowances and denials of disability benefits.  The Advisory Board has cited differences in state-established personnel  policies such as salaries, training, and qualifications of disability  examiners across the DDSs, along with state economic and demographic  differences, as some of the key factors that may affect the consistency of  disability decision-making.
section_title: SSA’s New Long-Term Strategy for Improving Its Disability Programs
paragraphs: The Commissioner’s September 2003 testimony sets forth her long-term  strategy for improving the timeliness and accuracy of the disability claims  process and fostering return to work for people with disabilities. For  example, to speed decisions for some claimants, the Commissioner  intends to initiate an expedited decision for claimants with more easily  identifiable disabilities, such as aggressive cancers. Under this new  approach, special units located primarily in SSA’s regional offices would  handle the expedited claims, leaving DDS examiners responsible for  evaluating the more complex claims. The Commissioner’s strategy also  aims to increase decisional accuracy by, among other approaches,  requiring DDS examiners to develop more complete documentation of  their disability determinations, including explaining the basis for their  decisions. Beyond steps to improve the timeliness and accuracy of the  process, the Commissioner also plans to conduct several demonstrations  aimed at helping people with disabilities return to work by providing work  incentives and opportunities earlier in the disability process.
In addition, to improve the disability decision process, the Commissioner  has implemented some shorter-term remedies while developing her  longer-range strategies. For example, SSA is accelerating its transition to  an electronic disability claims folder, through which the DDSs, the field  offices, and the Office of Hearings and Appeals are to be linked to one  another. The folder is being designed to transmit case file data  electronically from one claims-processing location to another and to serve  as a data repository—storing documents that are keyed in, scanned, or  faxed. According to the Commissioner, successful implementation of the  electronic folder is essential for improving the disability process. In our  prior work, we have cautioned SSA to ensure that it has the right mix of  skills and capabilities to support this major technological transition.
section_title: Strategic Human Capital Management Designated a High-Risk Area
paragraphs: Recognizing the importance of people to the success of any organization in  managing for results, GAO designated strategic human capital  management a government-wide high-risk area in 2001. In prior reports  on this high-risk area, we identified strategic workforce planning as  essential to effective performance and stated that it should be a priority of  agency leaders. We also noted that effective workforce planning must be  fully integrated with an agency’s mission and program goals and be based  on accurate and comprehensive workforce data. We recently identified a  few key principles for strategic workforce planning. These principles  include  involving top management, employees, and other key stakeholders in  developing, communicating, and implementing the workforce plan;   determining the critical skills and competencies needed to achieve current  and future program goals, and developing strategies to fill identified gaps;   building the capability necessary to address administrative, educational, or  other requirements to support the workforce strategies; and   monitoring and evaluating progress in meeting workforce goals and how  well the workforce plan has contributed to reaching overall program goals.
Congress has additionally recognized the importance of workforce  planning and, in 2002, added to the Government Performance and Results  Act a provision requiring agencies to include human capital strategies  needed to meet their strategic goals in their annual performance plans.  We have found that high-performing organizations use workforce planning  as a management tool to develop a compelling case for human capital  investments and to anticipate and prepare for upcoming human capital  issues that could jeopardize accomplishment of the organizations’ goals.  (See appendix III for a list of GAO reports on human capital management.)
section_title: DDSs Face High Turnover, Recruiting and Hiring Difficulties, and Gaps in Key Knowledge and Skill Areas
paragraphs: The DDSs face several key challenges in retaining disability examiners and  enhancing their expertise: high turnover, difficulties in recruiting and  hiring, and gaps in key knowledge and skill areas. The DDSs are  experiencing high and costly turnover of examiners, which data from our  survey show is fostered in part by stressful workloads and noncompetitive  salaries. DDSs need to recruit and hire sufficient numbers of qualified new  examiners to fill the vacancies resulting from the high turnover. Yet more  than three-quarters of DDS directors reported recruiting and hiring  difficulties. Directors said such difficulties were due in part to state- imposed personnel restrictions, such as state limits on examiner salaries  and hiring. Finally, directors reported that many examiners need  additional training in key analytical areas that are critical to disability  decision-making, including assessing credibility of medical information,  evaluating applicants’ symptoms, and analyzing applicants’ ability to  function.
subsections: section_title: DDSs Face High and Costly Turnover Fostered by Stressful Workloads and Noncompetitive Salaries
paragraphs: Over half of all DDS directors responding to our survey said that examiner  turnover in their offices was too high. Our analysis of data from our survey  and from federal agencies shows that, over fiscal years 2000 through 2002,  DDS examiner turnover was about twice that of Veterans Benefits  Administration (VBA) disability examiners with responsibilities similar to  those of DDS examiners. For example, DDS examiner turnover averaged  13 percent over fiscal years 2000 to 2002, compared with 6 percent for VBA  disability examiners. (See table 1.) In addition, during the same period, the  turnover rate of DDS examiners was substantially greater than that of all  SSA employees as well as that of all federal government employees. DDS  examiner turnover has been even higher among new hires: turnover of  examiners hired in fiscal year 2001 was 25 percent, compared with 14  percent among all DDS examiners. Moreover, while it is typical for new  hires to leave at higher rates than other employees, turnover of new DDS  examiners was considerably higher than that of new VBA examiners, new  SSA employees, and all new federal government employees in fiscal years  2000 and 2001.
Our survey results also show that examiner turnover is particularly high in  some DDSs. An examination of three-year averages (fiscal years 2000 to  2002) of DDS turnover rates showed that one DDS had a turnover rate of  43 percent, and a quarter of the DDSs had turnover rates of 20 percent or  greater. (See fig. 2.)
When we asked DDS directors in our survey about the consequences of  turnover, they told us that examiner turnover increased hiring and training  costs and hindered claims processing by decreasing overall examiner skill  levels, and increasing examiner caseloads, claims-processing times, and  backlogs, as follows:    Increased hiring and training costs. Nearly two-thirds of all DDS  directors reported in our survey that turnover had increased SSA’s  recruiting, hiring, or training costs. Directors and other DDS officials  explained in interviews why these costs had increased as a result of  turnover. Some DDS directors said that they must invest time in reviewing  applications, interviewing candidates, and making hiring decisions. They  also said they have to provide inexperienced new hires with 12 to 18  months of extensive training and mentoring. SSA estimates the cost of  turnover of its own employees at 1.5 times average annual salary. Using  this rate, we estimate that the cost of DDS examiner turnover in fiscal year  2002 was in the tens of millions of dollars.
Decreased overall examiner skill levels. Two-thirds of all DDS  directors reported that losses of experienced staff due to turnover have  decreased overall examiner skill levels. While SSA officials told us that  one to two years of experience is generally required to become proficient  in the examiner role, our survey data show that, in two-thirds of the DDSs,  at least a quarter of examiners had two years or less experience at the end  of fiscal year 2002.
Increased examiner caseloads. Nearly two-thirds of all DDS directors  we surveyed said turnover had increased examiner caseload levels. DDS  directors and SSA officials explained in interviews and survey comments  that the caseloads of examiners who leave the DDS have to be  redistributed among those who remain. Some directors told us that these  higher caseloads created a more stressful work environment for the  remaining employees.
Increased claims-processing times and backlogs. Our survey results  showed that over one-half of all directors said that turnover had increased  DDS claims-processing times and backlogs. DDS directors and SSA  officials we spoke with explained that turnover increased claims- processing times because new examiners hired to fill vacancies are less  productive due to their inexperience and time spent in training. These  officials also told us that the productivity of experienced staff is lowered  while they are training and mentoring the new examiners. SSA itself  acknowledged the potential impact on service in a 2001 internal document.  This document noted that the need to replace retiring managers, by  drawing from an examiner pool already diminished by turnover, would  further reduce the examiner ranks and exacerbate the challenge of  processing the growing claims workload. In addition, we noted in a prior  report that a majority of DDS directors expressed the view that examiner  turnover is likely to jeopardize their ability to complete periodic reviews of  beneficiaries’ disability status, known as continuing disability reviews,  potentially contributing to backlogs of these reviews.  When we asked DDS directors about causes of examiner turnover, more  than two-thirds identified each of the following as contributing factors:   (1) large examiner caseloads along with workplace stress, high production  expectations, and highly complex work and (2) noncompetitive pay.
High caseloads, stress, production expectations, and highly  complex work. Over two-thirds of all DDS directors identified large  examiner caseloads, a stressful workplace, high production expectations  for the number of cases completed, and the highly complex nature of the  work as factors contributing to examiner turnover. DDS directors  explained in interviews that the combination of growth in the claims  workloads and increasingly complex examiner responsibilities is making  the examiner position more challenging and stressful. DDS directors also  noted in our survey and in interviews that insufficient staffing had  increased the caseloads and stress levels of their examiners. Nearly 9 out  of 10 DDS directors surveyed reported that the number of examiners in  their DDSs had not been sufficient for their workload in at least one of the  past three fiscal years, and nearly all of these directors said that this  understaffing had resulted in a more stressful work environment.
Noncompetitive pay. Two-thirds of all directors stated that  noncompetitive pay had contributed to examiner turnover. Our survey  data showed that many state DDS examiners were paid substantially less  than examiners employed by the federal DDS in 2002 despite comparable  skills and experience. Specifically, all of the state DDSs for which we  have data have average examiner salaries that are less than the federal  DDS average salary, and over half of the DDSs (31) have an average  examiner salary that is less than two-thirds of the federal DDS average  salary. In addition, we found that DDS examiner salaries are substantially  lower than those of VBA examiners nationwide. For example, the average  salary for DDS examiners was $40,464 in 2002, compared with $49,684 for  VBA examiners. Specifically, we found that average DDS examiner  salaries are less than those of VBA examiners in 47 states. (See fig. 3.)  Several DDS directors told us in interviews that examiners have left some  DDSs to accept higher salaries in federal agencies, particularly in SSA  offices. For example, our analysis of selected case data provided by two  DDS directors showed that, between 2000 and 2003, 13 former examiners  received pay increases ranging from 9 to 48 percent when they moved  from their DDSs to positions in SSA offices.
section_title: DDSs Face Difficulties in Recruiting and Hiring Partly Due to State- Imposed Personnel Restrictions
paragraphs: In addition to facing high turnover and growing caseloads, more than  three-quarters of all DDS directors (43) reported experiencing difficulties  over a three-year period in recruiting and hiring enough people who could  become successful examiners. Of these directors, more than three- quarters said that such difficulties contributed to decreased accuracy in  disability decisions or to increases in job stress, claims-processing times,  examiner caseloads, backlogs, or turnover. For example, one SSA official  explained that, because of state-imposed hiring restrictions, one DDS  developed a large backlog of cases that negatively affected its  productivity.
When we asked DDS directors what made it difficult for their DDSs to  recruit and hire, they said that the following factors, many of which were  related to state personnel restrictions, made it moderately to much more  difficult than it would be otherwise to recruit and hire:    state limits on examiner salaries and other forms of compensation,   restrictive job classification system for state employees,    state-imposed hiring limitations or hiring freezes and lengthy time periods  for the state to hire DDS examiners, and    SSA-imposed hiring restrictions and budget allocations limiting DDS  staffing levels.
State limits on examiner salaries and other forms of compensation.  More than two-thirds of all directors reported that state limits on examiner  salaries hindered recruiting and hiring, and the same proportion reported  that noncompetitive salaries were insufficient to recruit or retain staff with  the skills necessary to assume enhanced examiner responsibilities. One  DDS director noted in survey comments that the low entry-level salary for  examiners in that particular state no longer attracted “…the caliber of  employees needed to perform the increasingly complex  job.”  Another commented that, owing to noncompetitive salaries, job  candidates “…who have the requisite combination of skills needed as a   will find better offers of employment,  either  better pay or less workload stress.” And officials we spoke with in an SSA  regional office said that low examiner salaries in still another DDS have  meant that this DDS has been unable to recruit candidates with strong  analytical skills. They noted that the DDS has, therefore, had difficulty  training its new examiners in such challenging tasks as weighing the  credibility of medical and other evidence. In addition to citing limits on  salaries, more than half of all directors reported that state limits on other  forms of compensation, such as performance-based pay and hiring  bonuses, also contributed to recruiting and hiring difficulties.
Restrictive job classification system. Nearly one-half of all DDS  directors attributed difficulties in recruiting and hiring examiners to their  restrictive state job classification systems. Close to a third of all states  place disability examiners in the same classification as other positions— such as a vocational rehabilitation specialist—and some DDS officials we  interviewed said this made it difficult to attract people with skills  appropriate to the disability examiner position.
State-imposed hiring limitations and lengthy time for hiring. Nearly  one-half of all DDS directors cited state hiring limitations or hiring  freezes—and more than one-third reported lengthy hiring processes—as  impediments to acquiring qualified examiners. For instance, officials we  interviewed in one DDS explained that their state government had capped  the number of staff the DDS could hire. These officials noted that, while  SSA was willing to fund hiring above that level, it could take three years to  obtain the state legislature’s approval to increase the DDS staffing level.  SSA officials told us that another DDS could only hire individuals who  have taken a required state test. They explained that, because the state  administers the test only two times a year, the requirement hampers DDS  hiring efforts.
SSA-imposed hiring restrictions and budget allocations. Close to  two-thirds of all DDS directors said that, over the past three fiscal years,  SSA-imposed hiring restrictions and budget allocations that limit DDS  staffing levels have presented recruiting and hiring challenges for the  DDSs. DDS managers explained in interviews and in survey comments  that, given the one to two years it takes for an examiner to become fully  trained, DDSs that are restricted from quickly replacing staff lost to  attrition will not have sufficient numbers of experienced examiners to  process future claims.
section_title: Many Examiners Need Additional Training in Key Analytical Areas
paragraphs: In addition to high turnover and difficulties in recruiting and hiring, the  DDSs are also experiencing gaps in key knowledge and skills areas. When  we surveyed all DDS directors about specific knowledge and skill needs,  nearly one-half said that at least a quarter of their examiners needed  additional training or mentoring in each of the following areas to  successfully assume expanded responsibilities under an enhanced  examiner position in either the present or the future:    assessment of an applicant’s symptoms and evaluation of the credibility of  medical and other evidence,    evaluation of the weight to be given to medical evidence from a treating    assessment and documentation of an applicant’s ability to function,    assessment of vocational factors,    updates on policies and procedures, and    assessment of childhood disabilities.
Even for those 19 DDSs in our survey that were testing the enhanced  examiner position at the time of our study, over half (11 DDSs) reported  that at least a quarter of the examiners with expanded responsibilities  needed additional training or mentoring in two or more of these same  knowledge and skill areas, and eight of these directors reported needs in  four or more of these areas.
But regardless of whether a DDS was testing this enhanced position, these  areas are critical to the examiner’s task of disability decision-making in  general. Indeed, one DDS director explained in an interview that, while  that DDS was not officially testing this position, over the last several years  it had hired examiners who were able to function in a manner that was  increasingly independent of the medical consultant. This director noted  that, as a result, it was becoming more difficult to distinguish the  responsibilities of the disability examiner from those of an examiner with  enhanced authority. Moreover, under SSA’s new approach for improving  the disability determination process, these same knowledge and skill areas  will be even more critical as DDS examiners take responsibility for  evaluating only the more complex claims and as they are required to fully  document and explain the basis for their decision.
DDS directors cited several obstacles to examiners receiving needed  training or mentoring. These obstacles primarily involved high workload  levels that limited the time available to either provide or receive training  or mentoring. Specifically, more than 70 percent of all DDS directors  reported that work demands impeded mentors from providing examiners  with needed on-the-job training. In addition, about two-thirds of all DDS  directors reported that either the large size of examiners’ caseloads or  high expectations for completing those cases did not allow examiners  enough time to attend training. And more than half of all directors cited  high work levels as a barrier to examiners seeking mentoring assistance.
section_title: The Majority of DDSs Do Not Conduct Long- Term, Comprehensive Workforce Planning, and DDSs Cite Numerous Obstacles to Doing So
paragraphs: Despite the workforce challenges facing them, a majority of DDSs do not  conduct long-term, comprehensive workforce planning. Of the DDSs that  engage in workforce planning that is longer-term, a majority have plans  that lack key workforce planning strategies, such as those for recruiting,  retention, or succession planning. Directors identified numerous obstacles  to long-term workforce planning, such as a lengthy state process to  approve DDS human capital changes.
subsections: section_title: The Majority of DDSs Do Not Conduct Long-Term, Comprehensive Workforce Planning
paragraphs: The majority of DDSs do not conduct long-term, comprehensive  workforce planning. As figure 4 shows, more than half of all the DDSs  have workforce planning time horizons of less than two years, and almost  one-half have a time horizon of no longer than a year (the time horizon of  SSA’s annual budget process for the DDSs).
DDS directors who reported that their workforce planning time horizons  are no longer than a year mainly rely on SSA’s annual budget process for  the DDSs for their workforce planning. However, SSA officials told us in  interviews that their budget process is not designed to serve as a long-term  strategic workforce planning process. These officials said that the  following strategies of comprehensive, long-term workforce planning are  generally not part of the budget process but rather are left to the states:  recruiting strategies,  retention strategies,  training and professional development strategies,    compensation strategies,    performance expectation and evaluation strategies,    employee-friendly workplace strategies,    succession planning and strategies for maintaining expertise in the long    contingency plans, in the event that resource levels do not meet  expectations.
In addition, even among the 28 DDSs that engage in workforce planning  that is longer-term than one year, the majority (18) lack one or more of  these key workforce planning strategies.
Furthermore, many DDSs do not collect the data needed to develop  effective workforce plans. Although DDSs face high turnover and are  expected by SSA to experience a retirement wave in the next decade, over  half of all DDS directors said they had not made projections of expected  retirements and other separations for examiners and related staff within  the last two fiscal years.
Although the majority of DDSs do not conduct comprehensive, long-term  workforce planning, some state governments do engage in strategic  workforce planning efforts that encompass DDS employees. For example,  the state parent agency of one DDS has produced reports identifying the  workforce risks faced by the DDS (such as a coming retirement wave) and  has assisted the director with succession planning. However, ongoing  studies of state government workforce planning efforts have found that  formal strategic workforce planning is not taking place in all states.  During an interview with several DDS directors, we were told that even  states with sophisticated long-term workforce planning efforts are not  necessarily focusing on ensuring that their DDSs have the workforces  needed to accomplish SSA goals, such as reducing claims-processing  times.
section_title: DDS Directors Cited Numerous Obstacles to Long-term Workforce Planning
paragraphs: DDS directors noted in interviews that they face unique challenges related  to the federal-state relationship that compound the difficulties of planning  for future workforce needs. We asked DDS directors in our survey to what  extent they had experienced various factors that might make workforce  planning more difficult than it would be otherwise. Directors identified the  following as major obstacles to long-term workforce planning:    Lengthy state processes to approve DDS human capital changes.
Over half of all DDS directors said that lengthy state processes to approve  DDS human capital changes made statewide DDS long-term workforce  planning more difficult. For example, an SSA official said it took over a  year to obtain approval to hire seven DDS staff due to a state hiring freeze.  In addition, a 2001 audit by SSA’s Office of the Inspector General found  that the parent agency of one DDS had failed to provide sufficient staffing  resources, such as timely permission to fill vacancies, for the DDS to  efficiently process its disability workload.
Inconsistencies between state and SSA human capital policies.
Two-thirds of all DDS directors reported that long-term planning is made  more difficult than it would be otherwise due to inconsistencies between  state and SSA human capital policies, such as those related to staffing  levels. For example, a former DDS director we spoke with explained that  directors have had difficulties planning for future needs because of  discrepancies between hiring levels authorized by SSA and those approved  by their states. One DDS director told us that after working for two years  to obtain state approval to hire additional examiners initially authorized by  SSA, the DDS lost permission from SSA to fill the positions.
Directors’ concern that SSA does not incorporate DDS workforce  plans when making resource decisions. When asked in our survey what  makes long-term planning more difficult, over two-thirds of DDS directors  reported their concern that SSA does not incorporate the DDSs’ workforce  plans when making resource decisions. Moreover, 45 DDS directors  responded that they had only some or no opportunity to factor future DDS  human capital needs into SSA’s spending projections beyond the  upcoming fiscal year. Several DDS officials explained in interviews that  long-term planning seemed futile if SSA was not going to use the results of  the DDS planning efforts when making resource decisions. SSA officials,  however, told us that they consider input from the DDSs related to funding  decisions on a regular basis. SSA officials explained that the agency must  disperse funds within its own overall budget allocation, and this often  does not allow for meeting all DDS funding requests.
Uncertainty about future resource levels from SSA and state- imposed hiring restrictions or separation incentives. Over three- quarters of all DDS directors we surveyed reported that long-term  planning is made more difficult by uncertainty about future resource levels  from SSA, as well as uncertainty about resources needed to implement  major changes in SSA policies, procedures, and systems. In addition, one- half of DDS directors surveyed said that DDS long-term workforce  planning was made more difficult by uncertainty about state-imposed  hiring restrictions or separation incentives.
Insufficient time to attend to future problems and insufficient data  for workforce planning. Three-quarters of all directors surveyed said  that they had insufficient time to attend to future problems because of the  need to focus on current human capital challenges. One DDS director said  in an interview that the day-to-day demands of directors’ jobs, such as  managing high caseloads and hiring and training new examiners, often  prevent them from planning for future workforce needs. Other DDS  directors and officials told us that, when planning does take place, it is  generally crisis-driven and reactive rather than long-term and strategic. In  addition, over half of the directors reported in our survey that insufficient  data for workforce planning makes DDS long-term workforce planning  more difficult. Moreover, DDSs that do not engage in workforce planning  longer-term than one year were more likely than other DDSs surveyed to  cite insufficient data and planning tools, such as statistical software and  information technology systems, as challenges that make long-term  workforce planning more difficult.
section_title: SSA’s Workforce Efforts Have Not Sufficiently Addressed Present and Future Human Capital Challenges in the DDSs
paragraphs: SSA’s workforce efforts have not sufficiently addressed both present and  future DDS workforce challenges. Neither SSA’s strategic plan, nor its  annual performance plan, nor its workforce plan adequately addresses the  human capital challenges facing the DDSs. In addition, in our survey, DDS  directors reported being dissatisfied with the adequacy of the training that  SSA provides to the DDSs. Beyond training, SSA has not consistently  provided other human capital assistance across the DDSs and faces  difficulties negotiating human capital changes, such as increases in  examiner salaries, with state governments. Finally, SSA has not used the  statutory authority it has to set standards for the DDS workforce.
subsections: section_title: SSA’s Strategic and Workforce Plans Do Not Adequately Address DDS Human Capital Challenges
paragraphs: SSA has not developed a nationwide strategic workforce plan that  addresses present and future human capital challenges in the DDSs. As  shown in figure 5, SSA does recognize a need to have higher-skilled and  better-compensated DDS employees. In addition, SSA’s strategic plan for  2003-2008 places a high priority on improving the accuracy and the  timeliness of the disability decision-making process. While  accomplishment of this objective depends to a great extent on the DDS  workforce, the plan cautions that the DDSs, like SSA, will face a  continuing challenge of hiring and retaining a highly skilled workforce in a  competitive job market. Nevertheless, SSA’s strategic plan, as well as the  agency’s annual performance plan and workforce plan, are all largely  silent on the means and strategies the agency will use to recruit, develop,  and retain a high-performing DDS workforce, even though the  Government Performance and Results Act now requires agencies to  include in their annual performance plans a description of the human  capital strategies needed to meet their strategic goals. “The Agency’s focus on the front-end of the disability processes…required a corresponding investment in the SSA and DDS employees involved in those processes; both workforces needed to be higher skilled and compensated.”
To deliver high-quality, citizen-centered service.
To strategically manage and align staff to support SSA’s mission. “One of SSA’s highest priorities is to improve service to the public in the disability programs from the initial claim through the final... appeal... The length of time it takes to  process these claims is unacceptable.” “SSA and the State DDSs will be faced with the continuing challenge of hiring and retaining a highly skilled and diverse workforce in what is expected to be a very competitive job market.”
subsections: section_title: SSA’s Future Workforce Transition Plan
paragraphs: “SSA’s Future Workforce Transition Plan was created…as a requirement of SSA’s strategic plan to outline how SSA will transition from the workforce we have today to the workforce we will need in the future.”
SSA officials said in interviews that SSA is no longer pursuing two proposed strategies for improving  training for disability examiners.
Absent any strategic workforce plan addressing DDS employees, SSA does  not use data that it collects on the DDS workforces in a strategic manner.
While SSA routinely gathers certain DDS employee data—such as salaries,  turnover rates, and the number of new hires and experienced disability  examiners—the agency primarily uses these data in connection with its  annual budget process. Moreover, SSA does not regularly collect many  other key indicators of DDS human capital performance, such as gaps in  basic skills relative to specific competencies, despite SSA’s acknowledging  the importance of investing in and retaining a skilled DDS workforce in  the face of an anticipated retirement wave.
When we asked SSA officials how workforce planning for the DDSs was  conducted, they said that they consider DDS workforce matters to be, in  general, a state government and DDS responsibility, particularly in light of  the variations in state personnel systems and political concerns. One of  these officials explained that SSA takes DDS workforce needs into  account within SSA’s annual budget process and through the consultation  that occurs between the DDSs and SSA’s regional offices. The regional  office staff—and in particular, the disability program administrators  assigned as SSA’s liaisons with each DDS—are responsible for providing  human capital assistance to the DDSs as needed. However, as noted  earlier, SSA’s annual budget process lacks key components of  comprehensive, long-term workforce planning. In addition, officials we  interviewed in one regional office said that they lacked the tools and the  time to assist the DDSs with long-term strategic workforce planning, and  SSA officials we spoke with questioned whether disability program  administrators were sufficiently trained in strategic workforce planning  techniques.
Several regional office and former and current DDS officials we spoke  with expressed a desire for greater SSA leadership in terms of long-term  strategic workforce planning focusing on DDS human capital challenges.  One of these officials observed that SSA is already active in a variety of  DDS human capital areas—such as determining appropriate DDS staffing  levels, imposing a nationwide DDS hiring freeze, and providing national  human capital guidance for implementing the electronic disability  initiative—and could appropriately assist with strategic workforce  planning.
section_title: Directors Expressed Dissatisfaction with the Adequacy of SSA’s Training for the DDSs
paragraphs: DDS directors are dissatisfied with the adequacy of SSA-provided training.  Specifically, when we asked DDS directors whether they found SSA’s  training to be adequate to prepare examiners to be proficient in the claims  process, half or more of the directors responded that they were  dissatisfied with the adequacy of SSA’s training in each of the following  knowledge and skill areas:    medical knowledge about body systems (32 DDSs),    specific knowledge about the disability program (30 DDSs),    assessment of vocational factors (29 DDSs),    basic claim development techniques (29 DDSs),    evaluation of the weight to be given to medical evidence from a treating  physician (28 DDSs),    updates on policies and procedures (28 DDSs),    assessment of childhood disabilities (28 DDSs),    assessment of an applicant’s symptoms and evaluation of the credibility of  medical and other evidence (27 DDSs), and    use of computers and technologies (26 DDSs).
Moreover, nearly half of the directors (25 DDSs) reported that they were  dissatisfied with SSA’s basic training materials for new disability  examiners, and over one-third (19 DDSs) reported dissatisfaction with  training on the assessment and documentation of an applicant’s ability to  function.
In addition, nearly all DDS directors (49) reported that they had adapted  (or wanted to adapt) SSA’s training in one or more of these knowledge and  skill areas to make it adequate. When we asked these DDS directors why  they had adapted or wanted to adapt SSA’s training, more than half cited  each of the following reasons pertaining to the quality, completeness, and  timeliness of SSA’s training approach as contributing factors:    Training is too conceptual and not sufficiently linked to day-to-day case  processing (44 DDSs).
Training provides insufficient opportunity to interact with the trainer (40  DDSs).
Training provides insufficient opportunity to practice skills taught (38  DDSs).
Certain types of training over-rely on the interactive video training  technology (37 DDSs).
Training content is incomplete (32 DDSs).    Training presenters lack effective presentation skills (31 DDSs).    Training lacks sufficient written materials, such as handouts and desk aids  (30 DDSs).
Training is delivered too early or too late (28 DDSs).
In interviews, DDS officials expressed some particular concerns about  video training. Some DDS officials told us that, because presenters lack  sufficient hands-on case-processing experience, the training that SSA  provided through its video training technology was too theoretical. In  addition, other DDS officials described SSA’s video training technology as  not allowing sufficient opportunity for clarification and follow-up with the  presenter. Some officials explained that technical problems with the  technology impeded interaction with the trainers. For example, they told  us that, while staff are supposed to be able to use a keypad to call in and  question the presenters during a class broadcast, it is often difficult to  obtain access to the presenters. Further, some former DDS officials said  that SSA applies its video training technology to many types of  instructional needs for which it may not be appropriate. Yet, in our prior  work, we have noted that, to be effective, the training method used needs  to be tailored to the nature of the training content.
We asked SSA officials we spoke with to comment on the DDS directors’  views on the quality of SSA-provided training. While an SSA official  explained that the video training technology helps SSA to provide  consistent training across the entire country quickly, she acknowledged  that the training is sometimes too general and explained that SSA is  attempting to improve the presentations. SSA officials also told us that  they tap the expertise of the DDS community, among other agency  components, to help develop and improve training materials and identify  training needs.
However, despite such efforts, nearly 85 percent of all DDS directors  reported in our survey that they would be able to spend fewer resources  adapting SSA’s training for use in their individual DDSs if SSA were to  improve the quality, completeness, and timeliness of its training. Our  survey data show that, in fiscal year 2002, the 52 DDSs used, in total, the  equivalent of nearly 150 full-time DDS employees in preparing and  delivering examiner training related to disability claims processing.  Moreover, staff resources devoted to training may constitute a significant  portion of total examiner staff in some DDSs. To illustrate, the director of  one DDS with 83 disability examiners reported in our survey using the  equivalent of about 12 full-time employees in fiscal year 2002 to prepare  and deliver examiner training. SSA and DDS officials explained in  interviews that, while some larger DDSs have staff who are dedicated  solely to training, smaller DDSs generally use their most experienced, and  hence most productive, examiners to prepare training and deliver it to  their staff.
section_title: SSA Has Not Consistently Provided Other Human Capital Assistance across the DDSs and Faces Difficulties Negotiating Key Human Capital Issues with State Governments
paragraphs: Beyond training, information from our survey and interviews shows that  SSA has not consistently provided other human capital assistance across  the DDSs and faces difficulties negotiating human capital changes, such as  increases in examiner salaries, with state governments. SSA provides  many types of human capital assistance to the DDSs through its regional  offices and its headquarters. For example, SSA regional office officials we  interviewed explained that they have attempted to persuade state  governments to exempt examiners from state hiring restrictions and to  reclassify DDS examiner positions and increase examiner salaries in light  of new responsibilities. In addition to the assistance provided by regional  offices, SSA officials said that SSA headquarters has provided human  capital assistance to the DDSs, such as sponsoring a study that identified  the knowledge, skills, and abilities required for the disability examiner  position, among other positions.
But in our survey of the DDS directors who said they wanted particular  types of human capital assistance from SSA headquarters and its regions,  more than half said that they had not received assistance in each of the  following areas:    help with regular nationwide surveys of examiners’ issues and concerns  (32 out of 36 DDSs),    help in negotiating increases in examiner salaries with state government  officials (24 out of 36 DDSs),    guidance on roles and responsibilities for examiners with enhanced  responsibilities (22 out of 42 DDSs),    help in designing training and developing training materials for examiners  with enhanced responsibilities and the staff who will be supporting them  (22 out of 42 DDSs),    help with workforce planning, including projecting turnover and  developing succession plans (21 out of 31 DDSs),    guidance on how to determine which examiners have sufficient skills to  take on enhanced examiner responsibilities (15 out of 20 DDSs), and    help in identifying gaps in examiner skills (15 out of 21 DDSs).
In interviews, some DDS directors specifically cited surveys of examiners’  issues and concerns as an area with which they wanted assistance. They  explained that such surveys could be used to identify and share DDS best  practices in managing staff, including how different DDSs manage  examiner caseloads and train examiners. One director noted that  information on DDS best practices in human capital management is not  currently available and that only SSA can “survey the landscape  nationally.” Moreover, a former DDS director explained that directors view  nationwide surveys as a means for communicating to SSA their human  capital challenges.
We also asked DDS directors about the effectiveness of various types of  human capital assistance that they did receive from SSA and its regional  offices, including assistance in negotiating human capital changes with  state governments. We found that more than half of the DDS directors who  received assistance said that such assistance was of limited effectiveness  in each of the following areas:    helping project trends in the nature of the disability workload (24 out of 34    assisting in negotiating easing of state restrictions (e.g., on hiring and  travel) with the state government (19 out of 24 DDSs);    providing guidance on roles and responsibilities for examiners with  enhanced responsibilities (18 out of 26 DDSs);    helping to design training and developing training materials for examiners  with enhanced responsibilities and the staff who will be supporting them  (16 out of 22 DDSs);    assisting in allowing DDSs to reduce the total caseload level for examiners  taking on enhanced responsibilities (13 out of 24 DDSs);    helping in assessing readiness for transition to an examiner role with  enhanced responsibilities (12 out of 14 DDSs);    helping with workforce planning, including projecting separations and  developing succession plans (11 out of 13 DDSs); and    providing help in negotiating increases in examiner salaries with the state  government (11 out of 16 DDSs).
Regional office officials and DDS directors explained in interviews that the  effectiveness of SSA and its regional offices in helping the DDSs negotiate  human capital changes with the states can be limited by such factors as  state budget problems, political concerns, and personnel rules. For  example, some officials said in interviews that state budget crises had  created political pressure to limit or prevent increases in state employee  salaries. Other DDS directors told us that state officials were concerned  that raising examiner salaries would prompt increases in the salaries of  other state employees, such as employees within the same job  classification. In addition, although 19 DDS directors reported in our  survey that DDS salary levels are open to negotiation with unions, some  regional office officials said in interviews that obtaining salary increases  for disability examiners apart from other state employees covered by  union contracts could be difficult.
In light of such difficulties in negotiating human capital changes with the  states, one key regional office official we spoke to said that “all the  regional office can do is cajole” the state governments about DDS human  capital issues, since under the regulations the authority in this arena  generally remains with the states. Similarly, another top regional official  cautioned that, while the regional office tries to help the DDSs address the  human capital challenges they face, it is difficult to do so. This official  stated that the federal-state relationship is “unwieldy,” explaining that it is  easier for state governments to apply state human capital policies—such  as hiring freezes—to all state personnel than to make exceptions for DDS  employees, despite SSA’s full reimbursement of DDS expenses. The  official said that, because the regional office must continually educate and  explain to each newly elected state governor’s administration that the DDS  is federally funded, the regional office is seeking ways to make such  education more effective and less labor-intensive. Indeed, current and  former DDS directors we spoke with said that outreach from SSA to state  governors through such national groups as the National Governors  Association (NGA) is needed to foster an appreciation of the importance  of a highly qualified DDS workforce to improving service to disability  claimants.
section_title: SSA Has Not Used Its Statutory Authority to Address DDS Workforce Needs
paragraphs: SSA has not used the statutory authority it has to set standards for the  DDS workforce. Although amendments to the Social Security Act in 1980  granted SSA the authority to issue regulations to ensure effective and  uniform administration of the national disability programs, SSA has not  used this authority to address wide variations in staff salaries, entry-level  qualification requirements, and training for different DDSs. The Social  Security Advisory Board, in 2001, called these variations potential  contributors to inconsistencies in SSA’s disability decisions. Emphasizing  that the disability programs are national in scope and that equal treatment  for all claimants wherever they reside is essential, the Advisory Board  recommended that SSA revise its regulations to establish guidelines for  salaries, entry-level qualification requirements, training, and other factors  affecting the ability of DDS staff to make quality and timely decisions.  SSA has not acted on the Advisory Board’s recommendations, however.
While SSA officials acknowledged in interviews that the agency has the  authority to establish uniform minimum human capital standards, they  told us that the agency has chosen not to exercise this authority because  of concerns about the difficulties such actions could raise in terms of the  federal-state relationship. For example, they explained that requiring  uniform human capital standards might be perceived by some states as  unwelcome federal interference in state operations and could raise the  prospect of states withdrawing their participation in making disability  determinations for the disability programs. Indeed, in a prior report, we  noted that, in the late 1970s, SSA could get only 21 of the 54 DDSs to revise  their operating agreements with SSA, partly because the states regarded  the revisions as infringements on their traditional prerogatives. The  revised agreements required DDSs to comply with guidelines issued by  SSA with regard to personnel matters, among other administrative  requirements.
Many DDS and SSA officials we spoke with acknowledged the difficulties  that would be involved with implementing uniform standards for DDS  personnel. Nevertheless, the National Council of Disability Determination  Directors and several DDS and SSA officials we interviewed (including  some top regional office officials) expressed the view that uniform  standards for DDS employees could help address the human capital  challenges confronting the DDSs. Some referred to the vocational  rehabilitation program administered by the Department of Education’s  Rehabilitation Services Administration in partnership with the states as an  example of a federal-state program that has set qualification standards for  state employees.
section_title: Conclusions
paragraphs: DDS disability examiners are essential to SSA’s meeting its strategic goal  for better serving disability claimants by making the right decision in the  disability process as early as possible. Yet SSA has not developed a  nationwide strategic workforce plan to address the very personnel who  will be crucial to meeting that goal. The immediate challenges that DDS  directors face today in maintaining and improving the examiner workforce  are unlikely to lessen with time and will likely have even more severe  consequences as the DDSs confront increasing numbers of applicants for  disability benefits. The critical task of making disability decisions is  complex, requiring strong analytical skills and considerable expertise, and  it will become even more demanding with the implementation of the  Commissioner’s new long-term improvement strategy and the projected  growth in workload. Moreover, because SSA has not set uniform minimum  qualifications for examiners, some DDSs may find it difficult to justify an  appropriate job classification and level of compensation needed to recruit  and retain these critical employees.
Without a plan to develop and maintain a skilled workforce—as well as  measures to establish uniform minimum qualifications for examiners,  close critical skill gaps, and improve training—SSA’s ability to provide  high-quality service to disability claimants could be further weakened by  gaps in critical competency areas and the loss of experienced DDS  examiners due to high turnover. As vacancies are filled by new hires and  trainees who need one to two years to become fully productive, the DDSs  will likely have difficulty maintaining skill levels and successfully coping  with expected high growth in workloads. The combination of decreased  overall skill levels and increased workload could make the work  environment even more stressful, further increasing turnover. This  spiraling effect, if not addressed, could undermine the agency’s efforts to  ensure that disability decisions are made accurately, consistently, and in a  timely manner.
A strategic workforce plan is even more critical to the Commissioner’s  long-term strategy for improving the disability claims process and her  ability to bring SSA’s approach to disability decision-making in line with  the current state of science, medicine, technology, and labor market  conditions. Failure to look ahead and plan to ensure that the appropriate  mix of skills and capabilities are available when and where needed could  obstruct SSA’s progress as it seeks to fundamentally restructure its  disability programs to improve the accuracy and timeliness of decisions  and focus on identifying and enhancing claimants’ productive capacities.  Given such a profound transition in an environment of constrained  resources, SSA must be able to plan effectively if it is to anticipate how its  requirements for DDS staff will change and be convincing about the need  for increased human capital investments.
It will not be simple to implement a nationwide strategic workforce plan  for a program that is administered in partnership with the states.  Negotiating changes in state human capital policies, such as restrictive job  classifications or hiring limitations, will be difficult. Improving the content  and delivery of SSA-provided training and closing gaps in examiner skills  across the DDSs will be challenging and potentially costly. Establishing  uniform minimum qualifications for examiners throughout the DDSs will  also be a difficult task, requiring delicate and time-consuming discussions  with some state governments. However, despite the acknowledged  difficulties, SSA cannot afford to forgo developing an overarching, guiding  framework to use as a basis for making short- and long-term human capital  decisions for the DDSs. As an agency with fiduciary responsibility for  administering multibillion dollar disability programs that are nationwide in  scope, SSA has an obligation to take a leadership role in planning— together with its state partners—to address both the immediate and future  workforce needs in the DDSs.
section_title: Recommendations to the Commissioner of SSA
paragraphs: We recommend that SSA take the following actions:  1.  Develop a nationwide strategic workforce plan that addresses present  and future human capital challenges in the DDSs. This plan should  enable SSA to identify the key actions needed to deal with immediate  DDS problems with recruiting and hiring, training, retention, and  succession planning in support of SSA’s strategic plan. It should  additionally enable SSA to anticipate and plan for the future workforce  that will be needed as SSA modernizes and fundamentally transforms  its approach to disability decision-making. To develop and implement  this comprehensive workforce plan, SSA should work in partnership  with the DDSs and their parent agencies. As part of the planning  process, SSA should:  a. Identify a small number of key DDS indicators of human capital  performance, including recruiting and hiring measures, level of stress  in the workplace, training needs, and turnover. SSA should establish  standards for acceptable performance on these indicators, routinely  collect and analyze the data to identify trends, and use this information  to guide decisions regarding future DDS workforce needs and the  strategies to meet them.  b. Provide necessary tools and technical assistance to the DDSs to  enable them to conduct long-term workforce planning. SSA should  ensure that SSA staff responsible for providing this assistance are well  trained in the tenets of workforce planning.  c. Require each DDS to develop its own long-term workforce plan that  is linked to the nationwide long-term DDS workforce plan. SSA should  work in partnership with the DDSs and their parent agencies to  develop these plans.  d. Establish an ongoing program of outreach from SSA’s leadership to  state governors and national associations of state government officials  to discuss the benefits and challenges of the federal-state relationship  and encourage them to address human capital challenges identified by  DDS directors, such as salary limits and hiring freezes.  e. Link performance expectations of appropriate SSA executives to  their efforts in accomplishing goals and objectives of the workforce  plan.  2.  Issue regulations that establish uniform minimum qualifications for  new disability examiners. The minimum qualifications should be based  on an analysis of the position that identifies the examiner’s  responsibilities and the minimum knowledge, skills, and competencies  necessary to adequately perform them. The minimum qualifications for  the examiner’s position should take into account any changes in the  complexity of the tasks required for this position stemming from the  Commissioner’s new long-term strategy.  3.  Work with DDSs to close the gaps between current examiner skills and  required job skills. To do so, SSA should work with the DDSs to:  a. analyze examiner training needs, using as a foundation the analysis  of job responsibilities and related minimum knowledge, skills, and  competencies recommended above;  b. improve training content and delivery to meet these needs, basing  such efforts on analyses of training content and appropriateness of  training delivery methods; and  c. develop performance measures to track effectiveness of these  improvements to training.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to SSA for comment. SSA generally  agreed with the intent of the recommendations in the report but stated  that the report does not fairly address or adequately discuss the many  sides of the DDS human capital management issues. In particular, SSA  criticized some of our study’s methods and expressed concern that we did  not sufficiently acknowledge the difficulties involved in making changes to  the federal-state relationship. We continue to believe, however, that the  report presents a fair and balanced portrayal of the multifaceted issue of  human capital management in the DDSs.
Generally agreeing with the intent of our recommendations, SSA said it  would consider incorporating a nationwide strategic workforce plan for  the DDSs into its current strategy to improve the disability determination  process. To do so will be essential, since the Government Performance  and Results Act now requires agencies to report annually, as we noted in  our report, on human capital strategies needed to meet their strategic  goals. Regarding our recommendation on improving training, SSA said that  it would continue ongoing efforts to improve examiner job skills. Results  from our survey of DDS directors, however, revealed gaps in critical  examiner knowledge and skills and a large proportion of DDS directors  who would be able to spend fewer resources on adapting SSA’s training if  SSA were to improve the quality, completeness, and timeliness of its  training. Given such results, our report recommended that SSA go beyond  its current efforts and base its training improvement initiatives on a  systematic assessment of the examiner’s job responsibilities and related  knowledge, skills, and competencies. In terms of our recommendation on  outreach, SSA said that it is already conducting an outreach program to  state officials and that it intends to engage in discussions with the NGA on  DDS issues. While we noted efforts on the part of SSA’s regional offices to  negotiate human capital changes with state governments, we maintain that  SSA’s outreach program requires the sustained attention of SSA’s  leadership at the national level. SSA’s expressed intent to pursue such  discussions with the NGA is therefore a step in the right direction.
SSA criticized some of our study methods, saying that we relied heavily on  opinions of DDS directors and used rather leading and ambiguous survey  questions. In terms of survey design, we surveyed DDS directors because  their first-hand experiences make them some of the most knowledgeable  respondents about human capital challenges experienced in their  organizations. In addition, our survey was developed in accordance with  GAO’s guidance on survey design and development, including extensive  pretesting with current and former DDS directors to identify potential  question bias and to clarify wording. We also gave SSA disability program  officials, on two occasions, the opportunity to review and comment on the  survey. Following the second review, the SSA official coordinating the  review said that, while some of the questions might be difficult for the  DDS directors to answer, we should go ahead with the survey as it stood.  The official did not refer to any bias in the survey questions. SSA also was  concerned that we administered the survey at a time of budget constraint  that SSA said influenced some of the directors’ responses. Our survey,  however, reflects ongoing challenges facing the DDSs and was not limited  to the particular circumstances of 2003. Further, our study findings did not  rest solely on the opinions expressed in our survey of DDS directors. In  addition to the survey, we gathered information through interviews with  several other sources as well, including officials at two DDSs, three SSA  regional offices, and SSA headquarters; officials of the National Council of  Disability Determination Directors and the National Association of  Disability Examiners; and staff of the Social Security Advisory Board. We  also reviewed pertinent laws, regulations, and procedures, and obtained  and analyzed human capital data from several sources.
SSA was also concerned that we did not sufficiently acknowledge the  attitudes of the states toward modifying federal regulations to establish  uniform human capital standards and the complexities involved in such  regulatory changes, such as the problems that SSA says it would face if a  large state declined to make disability determinations and transferred  these responsibilities to the federal government. We acknowledged in our  report the difficulties SSA has encountered in convincing the DDSs to  comply with SSA guidelines on personnel issues, due in part to the states’  perceptions of infringements on traditional state responsibilities. We also  stressed that establishing uniform minimum qualifications for examiners  will be difficult, requiring delicate and time-consuming discussions with  some state governments. But we maintain that, despite the difficulties,  SSA is obligated to address the human capital challenges facing the DDSs.   An outreach program involving SSA’s leadership and a close working  partnership among SSA, the DDSs, and their state parent agencies will be  vital to help ensure the success of SSA’s efforts.
In addition, SSA expressed a number of other concerns about the draft  report. These concerns, as well as our comments on them, are provided in  full in appendix IV.
Copies of this report are being sent to the Commissioner of SSA,  appropriate congressional committees, and other interested parties. The  report is also available at no charge on GAO’s Web site at  http://www.gao.gov. If you have any questions about this report, please  contact me at (202) 512-7215. Other contacts and staff acknowledgments  are listed in appendix V.
section_title: Appendix I: Scope and Methods
paragraphs: The following describes the methods we used to survey Disability  Determination Service (DDS) offices as well as the methods we used to  compare some of our survey data with data from other sources.
subsections: section_title: Survey of Disability Determination Service Offices
paragraphs: We surveyed all state DDS directors as well as the DDS directors in the  District of Columbia, Puerto Rico, and the federal DDS office. We did not  survey directors in Guam and the South Carolina Office for the Blind  because these offices each had only one disability examiner. We mailed  surveys to 53 DDS directors and received responses from all of them.  However, because most of the questions in our survey do not apply to the  federal DDS, we reported results for 52 DDSs. Our survey included  questions about long-term workforce planning, recruiting and hiring,  compensation, training and development, and retention of disability  examiners. The survey results in this report represent the views of the  DDS directors and do not necessarily represent the views of examiners or  other DDS staff or the views of Social Security Administration (SSA)  officials.
The practical difficulties of conducting any survey introduce various types  of errors related to survey responses. For example, differences in how a  particular question is interpreted and differences in the sources of  information available to respondents can be sources of error. In addition,  respondents might not be uniformly conscientious in expressing their  views or they may be influenced by concerns about how their answers  might be viewed by GAO, SSA, or the public. We included steps in both the  data collection and analysis stages for the purpose of minimizing such  errors. For example, to address differences in how questions were  interpreted, we asked two members of the Social Security Advisory Board,  as well as current and past officers of the National Council of Disability  Determination Directors and the National Association of Disability  Examiners, to review and critique the survey questions before pretesting.  SSA disability program officials also reviewed our survey on two  occasions. In addition, we pretested the survey with four former DDS  directors and four current DDS directors. We modified the survey  questions based on the results of these pretests.
Because we conducted our survey while 20 DDSs were testing the  feasibility of implementing an examiner position with enhanced  responsibilities, we tailored a few of the survey questions to be relevant  for those DDSs testing these enhanced positions as well as for those not  testing such positions. We also tailored questions for California’s survey,  which had separate offices testing and not testing the enhanced examiner  position. In addition, we tailored questions for the survey that went to the  federal DDS.
To address possible director concerns about how their answers might be  viewed, we stated in the introduction to the survey that their responses  would be reported in summary form only, without being individually  identified, and that their responses would not be released unless requested  by a member of Congress (see appendix II for a copy of our survey).
section_title: Analysis of Data from Our Survey and Other Sources
paragraphs: When we analyzed the data from our survey, where possible, we checked  survey answers involving numbers and percentages to ensure they  summed correctly. When we identified a discrepancy, we contacted the  relevant DDS director to resolve the discrepancy.
We wanted to determine how turnover rates (overall and for new hires)  for DDS examiners compared with those for selected groups of federal  employees. To do this, we compared the turnover rate of DDS examiners  with that of Veterans Benefits Administration (VBA) examiners, SSA  employees, and all federal employees. VBA examiners were selected  because they perform duties similar to DDS examiners, such as developing  claims using medical and disability program knowledge. We compared  DDS examiner turnover rates with SSA turnover rates because SSA fully  funds the DDSs to achieve its disability program mission. The federal  employee turnover rate was selected as a general baseline.
We used data from the Office of Personnel Management’s (OPM) Central  Personnel Data File (CPDF) to calculate turnover rates for VBA  examiners, SSA employees, and all federal employees. We counted how  many permanent employees in each group left their position in each of  fiscal years 2000, 2001, and 2002. For VBA examiners and SSA employees,  transfers to other agencies were counted as separations. For all federal  employees, only separations from federal service were counted as  separations. To calculate overall turnover, we divided the number  separated each year by the average of the number of staff (which we  obtained by averaging the number of staff at the beginning of the fiscal  year and the number of staff at the end of the fiscal year).
We also calculated a new hire turnover rate. We defined a new hire  separation as a separation of an employee hired in one fiscal year who left  before the end of the following fiscal year (for example, hired in fiscal year  2000 and left before the end of fiscal year 2001). To determine the turnover  rate for new hires, we counted all career and career conditional  appointments for each fiscal year 2000 and 2001. We then determined how  many of these separated before the end of the following fiscal year and  divided this by the number of new hires in the prior fiscal year. We also  calculated turnover rates for DDS examiners using the same formulas.
We also compared DDS examiner salaries with VBA examiner salaries. We  analyzed data from OPM’s CPDF to calculate the average base salary,  including locality adjustments, for VBA examiners state by state. We  divided each DDS’s average examiner salary by the average VBA examiner  salary for each state, the District of Columbia, and Puerto Rico. This  resulted in a measure of DDS average salary relative to average VBA  examiner salaries for each location.
When we analyzed salaries of examiners who left DDSs to accept higher  salaries in federal agencies, directors of two DDSs provided information  on both the salaries of these examiners while they were employed by the  DDSs, and on the federal General Schedule (GS) grade levels for their new  SSA positions. To determine SSA salaries, we used the 2002 federal  government GS pay scale, including locality adjustments. For cases in  which the directors provided us with two possible SSA grade levels, we  used the first step of the lower grade in our analysis. Three of these  disability examiners also served as quality assurance reviewers, hearing  officers, or trainers while employed in their DDS. Positions accepted at  SSA by the departing examiners included regional office disability quality  branch analyst, regional office program specialist, and field office claims  representative, as well as posts in the federal DDS.
section_title: Appendix II: Survey of DDS Directors’ Views on Human Capital Challenges
section_title: Appendix III: Related GAO Reports
subsections: section_title: Modernizing Federal Disability Programs
paragraphs: Social Security Disability: Reviews of Beneficiaries’ Disability Status  Require Continued Attention to Achieve Timeliness and Cost- Effectiveness. GAO-03-662. Washington, D.C.: July 24, 2003.
High-Risk Series: An Update. GAO-03-119. Washington, D.C.: January 1,  2003.
SSA Disability: Other Programs May Provide Lessons for Improving  Return-to-Work Efforts. GAO-01-153. Washington, D.C.: January 12, 2001.
Social Security Disability Insurance: Multiple Factors Affect  Beneficiaries’ Ability to Return to Work. GAO/HEHS-98-39. Washington,  D.C.: January 12, 1998.
SSA Disability: Return-to-Work Strategies from Other Systems May  Improve Federal Programs. GAO/HEHS-96-133. Washington, D.C.: July 11,  1996.
SSA Disability: Program Redesign Necessary to Encourage Return to  Work. GAO/HEHS-96-62. Washington, D.C.: April 24, 1996.
section_title: General Human Capital Management
paragraphs: Human Capital: Opportunities to Improve Executive Agencies’ Hiring  Processes. GAO-03-450. Washington, D.C.: May 30, 2003.
Results-Oriented Cultures: Creating a Clear Linkage between Individual  Performance and Organizational Success. GAO-03-488. Washington, D.C.:  March 14, 2003.
High-Risk Series: Strategic Human Capital Management. GAO-03-120.  Washington, D.C.: January 2003.
A Model of Strategic Human Capital Management. GAO-02-373SP.  Washington, D.C.: March 15, 2002.
Human Capital: A Self-Assessment Checklist for Agency Leaders.  GAO/OCG-00-14G. Washington, D.C.: September 2000.
section_title: Strategic Workforce Planning
paragraphs: Human Capital: Key Principles for Effective Strategic Workforce  Planning. GAO-04-39. Washington, D.C.: December 11, 2003.
Foreign Assistance: Strategic Workforce Planning Can Help USAID  Address Current and Future Challenges. GAO-03-946. Washington, D.C.:  August 22, 2003.
Tax Administration: Workforce Planning Needs Further Development for  IRS’s Taxpayer Education and Communication Unit. GAO-03-711.  Washington, D.C.: May 30, 2003.
Human Capital Management: FAA’s Reform Effort Requires a More  Strategic Approach. GAO-03-156. Washington, D.C.: February 3, 2003.
HUD Human Capital Management: Comprehensive Strategic Workforce  Planning Needed. GAO-02-839. Washington, D.C.: July 24, 2002.
NASA Management Challenges: Human Capital and Other Critical Areas  Need to be Addressed. GAO-02-945T. Washington, D.C.: July 18, 2002.
Air Traffic Control: FAA Needs to Better Prepare for Impending Wave of  Controller Attrition. GAO-02-591. Washington, D.C.: June 14, 2002.
Securities and Exchange Commission: Human Capital Challenges  Require Management Attention. GAO-01-947. Washington, D.C.:  September 17, 2001.
Human Capital: Implementing an Effective Workforce Strategy Would  Help EPA to Achieve its Strategic Goals. GAO-01-812. Washington, D.C.:  July 31, 2001.
Single Family Housing: Better Strategic Human Capital Management  Needed at HUD’s Homeownership Centers. GAO-01-590. Washington,  D.C.: July 26, 2001.
section_title: Organizational Transformation
paragraphs: Results-Oriented Cultures: Implementation Steps to Assist Mergers and  Organizational Transformations. GAO-03-669. Washington, D.C.: July 2,  2003.
Homeland Security: Management Challenges Facing Federal Leadership.  GAO-03-260. Washington, D.C.: December 20, 2002.
Highlights of a GAO Forum: Mergers and Transformation: Lessons  Learned for a Department of Homeland Security and Other Federal  Agencies. GAO-03-293SP. Washington, D.C.: November 14, 2002.
Managing for Results: Using Strategic Human Capital Management to  Drive Transformational Change. GAO-02-940T. Washington, D.C.: July 15,  2002.
FBI Reorganization: Initial Steps Encouraging but Broad  Transformation Needed. GAO-02-865T. Washington, D.C.: June 21, 2002.
section_title: Training and Development
paragraphs: Human Capital: A Guide for Assessing Strategic Training and  Development Efforts in the Federal Government. GAO-03-893G.  Washington, D.C.: July 1, 2003.
Foreign Languages: Human Capital Approach Needed to Correct  Staffing and Proficiency Shortfalls. GAO-02-375. Washington, D.C.:  January 31, 2002.
Human Capital: Design, Implementation, and Evaluation of Training at  Selected Agencies. GAO/T-GGD-00-131. Washington, D.C.: May 18, 2000.
section_title: Appendix IV: Comments from the Social Security Administration
subsections: section_title: GAO Comments
paragraphs: 1.  We believe that the report presents a fair and balanced portrayal of the  multifaceted issue of human capital management in the DDSs. We  designed the survey to obtain DDS directors’ opinions about the extent  to which, if any, a DDS had experienced certain human capital  challenges and the likely factors and consequences involved.   Moreover, the opinions were obtained from directors whose first-hand  experiences make them some of the most knowledgeable sources of  information about such issues in their organizations. But in addition to  our survey, our overall study methods relied on information and data  from several other sources as well. For example, we interviewed  disability examiners and their managers at two DDSs, officials  responsible for DDS management assistance at three of SSA’s regional  offices, SSA officials at headquarters, officials of the National Council  of Disability Determination Directors and the National Association of  Disability Examiners, and staff of the Social Security Advisory Board.   We also reviewed pertinent laws, regulations, and procedures, and  obtained and analyzed human capital data from the DDSs, SSA, and  other federal agencies.
Our survey was developed in accordance with GAO's guidance on  survey design and development. To avoid the potential for questions  to be leading, on every question in which we asked for directors’  opinions, we gave them the opportunity to say that they did not  experience that particular challenge, contributing factor, or  consequence. To this end, we constructed the questions so that the  first response choice was “no extent” or equivalent wording. In  addition, each question was specifically assessed for possible bias or  problematic wording during extensive survey pretesting. We pretested  the survey eight times—with four former DDS directors and four  current directors. On the basis of these pretests, we modified the  questions until pretesters raised no further issues.
We also gave SSA disability program officials the opportunity, on two  occasions, to review and comment on the survey. SSA officials first  reviewed the survey prior to its pretesting. Among other suggestions,  they noted that some survey questions were leading in nature and that,  in addition, we should develop scaled responses to provide  respondents with the opportunity to modulate their answers (e.g., from  “no extent” to “very great extent”). We modified the survey on the  basis of their comments, including revising or eliminating questions  that they thought were leading and constructing scaled responses as  suggested. After additionally incorporating comments of several  pretesters, we provided SSA with the chance to review a revised  version of the survey. The official coordinating SSA’s second review e- mailed us in reply, saying that, while some of the survey questions  might be difficult for the DDS directors to answer, we should go ahead  with the survey as revised. The official did not refer to any bias in the  revised questions.
Our survey questions and our findings reflect ongoing human capital  challenges facing the DDSs and were not limited to the particular  circumstances of fiscal year 2003. The survey questions themselves  were generally not limited to the most recent year, and several  explicitly asked for data for the past two or three fiscal years or for the  future. While the impact of the continuing resolution and the related  SSA hiring freeze that was in place throughout much of fiscal year 2003  may have affected DDS directors’ responses, DDS and SSA officials  have told us that resource constraints and budget uncertainties have  been ongoing challenges for a number of years. Furthermore, certain  aspects of the time period in which the survey was conducted likely  downplayed some of the human capital challenges facing the DDSs.  For example, DDS officials said in interviews that they expected  examiner turnover to increase as economic conditions improved in the  future.  2.  Our report acknowledges the efforts made by SSA regional offices to  persuade state governments to increase examiner salaries in light of  their new responsibilities. Our report, however, does not assert that   24 DDSs were refused assistance with negotiating salary increases for  examiners after they had requested it. Rather, we said that, of the DDS  directors who reported wanting help from SSA with negotiating salary  increases, more than half (24 DDSs) said they had not received this  kind of help. (SSA interpreted wanting help and not receiving it as  having requested help and been refused such assistance.) But  regardless of whether directors have specifically requested this or  another type of human capital assistance, they reported in their survey  responses that they want active support from SSA on this and a  number of other issues involving human capital management.  3.  Our report acknowledges that some states have strategic workforce  planning initiatives that consider their DDS employees. However, the  issue relevant to our study was not whether statewide human capital  management offices were generally effective, as SSA suggests, but  whether there were any workforce planning efforts by SSA or the  DDSs that were integral to and supportive of SSA’s mission and goals.  As we noted in the report, even sophisticated statewide workforce  planning efforts are not necessarily focused on ensuring that the DDSs  have the workforces needed to accomplish such SSA goals as reducing  claims-processing times.  4.  Our report acknowledges SSA’s current efforts at outreach to state  officials. For example, our report describes efforts on the part of  regional office officials to persuade state governments to exempt  examiners from state hiring restrictions, reclassify DDS examiner  positions, and increase examiner salaries. We also emphasize that SSA  and its regional offices can be limited in their ability to help the DDSs  negotiate changes by such factors as state political and budget  concerns, as well as state personnel rules. However, as noted in our  report, we found no record to date of any discussions with the  National Governors Association (NGA) or of NGA focusing on this  topic. Our recommendation that SSA reach out to national associations  such as the NGA is an acknowledgment that the DDSs and SSA’s  regional offices cannot successfully confront these difficult human  capital challenges without the sustained attention of SSA’s leadership  at the national level. For clarity, we have emphasized this point in the  text of our recommendation. SSA’s expressed intent to pursue  discussions on a national level with NGA is a step in the right  direction.  5.  We recounted in our report the view of SSA officials that requiring  uniform human capital standards might be perceived by some states as  unwelcome federal interference and could raise the prospect of states  withdrawing their participation in making disability determinations.  We also noted the difficulties SSA has encountered in the past in  convincing the DDSs to comply with SSA guidelines on personnel  issues, due in part to the states’ perceptions of infringements on  traditional prerogatives. Accordingly, we stressed in our report that  establishing uniform minimum qualifications for examiners throughout  the DDSs will be difficult, requiring delicate and time-consuming  discussions with some state governments. However, establishing such  qualifications will also be worthwhile, helping some DDSs justify an  appropriate job classification and level of compensation needed to  recruit and retain qualified disability examiners. As an agency with  fiduciary responsibility for administering disability programs that are  nationwide in scope, SSA has an obligation to do no less than take firm  steps to address the human capital challenges facing the DDSs. We  understand SSA’s concern about the difficulties it would face if states  opted out of the disability program and transferred these  responsibilities to the federal government. To help ensure the success  of SSA’s efforts, outreach from SSA’s leadership to the state governors  will be vital. Also essential will be a close working partnership among  the immediate stakeholders—SSA, the DDSs, and their state parent  agencies—in developing a nationwide strategic workforce plan.  6.  We did not examine the accuracy and timeliness of claims processing.
Nevertheless, even had these measures of performance improved, the  Commissioner noted in her September 25, 2003, testimony that SSA  still has “a long way to go” in its efforts to be more timely and  accurate, despite positive strides in the short term. Moreover, SSA’s  own published strategic plan for 2003 to 2008 warns that “the length of  time it  takes to process these claims is unacceptable.”  Results from our survey of DDS directors demonstrate the need to  address such DDS human capital issues as high turnover and recruiting  and hiring difficulties in order to improve the timeliness and accuracy  of claims processing. Of the directors (43) who reported experiencing  difficulties in recruiting and hiring enough people who could become  successful examiners, more than three-quarters said that such  difficulties contributed to decreased accuracy in disability decisions or  to increases in claims-processing times. Moreover, over one-half of all  directors reported that turnover had increased claims-processing  times.    7.  Our report neither states nor assumes that higher salaries alone  guarantee improved DDS performance. Rather, it states that, according  to more than two-thirds of all DDS directors, noncompetitive pay was  one of several factors contributing to examiner turnover. Moreover,  our report emphasized the costly consequences of such turnover,  noting that the estimated cost of examiner turnover in fiscal year 2002  was in the tens of millions of dollars. (Our estimates show that this  would be the case, regardless of whether the calculation is based on  total turnover or turnover that is above that of the federal government  as a whole.) SSA itself has been attempting to persuade state  governments to increase examiner salaries to reflect new job  responsibilities. Although increased compensation may increase costs,  the turnover that can result from not addressing human capital  management concerns, such as not compensating employees  appropriately, can be costly as well, as we note in the report.
We agree with SSA that some attrition is desirable. But over half of all  DDS directors told us in our survey that examiner turnover in their  offices was too high, and we found that examiner turnover was about  twice that of federal employees performing similar work. Because  turnover is costly, we emphasize the importance of using data to  identify current and future human capital needs. We have found in  prior work that high-performing organizations analyze who is leaving,  what skill gaps result, and how much turnover is desirable or  acceptable. Organizations that fail to effectively manage their turnover  risk not having the capacity to achieve their goals. A balance needs to  be achieved between bringing in new employees with fresh and vibrant  perspectives and retaining experienced employees whose institutional  knowledge can maintain goals and help train others.  8.  We cited the Department of Education’s experience to show that  establishing federal qualifications requirements for state employees, as  we recommended that SSA do, can and has been done. While we have  not studied federal experiences with workforce planning in an  intergovernmental arena, the GAO reports we provide in appendix III  highlight an array of initiatives on the part of federal agencies to  embrace workforce planning, including SSA’s planning models for its  own employees. SSA has been willing to take the lead and develop  models in workforce planning for its own employees. It should  therefore build on its own internal expertise and lessons learned in this  field to develop models of workforce planning in the demanding  intergovernmental context as well. Lack of an existing model for the  range of changes we recommend may make implementation more  challenging, but it is not a convincing argument for inaction.   9.  We support SSA’s leadership in its efforts to improve the disability  determination process and to help people with disabilities remain in or  return to the workforce. SSA said that it generally agreed with the  intent of our recommendations and would consider incorporating a  nationwide strategic workforce plan for the DDSs into its current  strategy to improve disability determinations. To do so will be  essential, since the Government Performance and Results Act now  requires agencies to report annually, as we noted in our report, on  human capital strategies needed to meet their strategic goals. While we  did not provide an exhaustive treatment of states’ reactions to  proposals for increased federal control, our report did note past  opposition of some states to federal guidelines on personnel matters.
In addition, we have added further detail in the report about the  regulatory development process. We acknowledge the complexities  involved in pursuing regulatory change. But despite these difficulties,  we maintain that SSA has an obligation to address DDS workforce  needs.  10.  SSA said that it would continue ongoing efforts to improve examiner  job skills. Results from our survey of DDS directors, however, revealed  gaps in critical examiner knowledge and skills. Moreover, a large  proportion of directors said they would be able to spend fewer  resources on adapting SSA’s training if SSA were to improve the  quality, completeness, and timeliness of this training. Given such  results, our report recommended that SSA go beyond its current  efforts and base its training improvement initiatives on a systematic  assessment of the examiner’s job responsibilities and related  knowledge, skills, and competencies.
section_title: Appendix V: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: In addition to those named above, the following individuals made  significant contributions to this report: Barbara Bordelon, Marissa Jones,  Suit Chan, and Beverly Crawford, Education, Workforce, and Income  Security Issues; Ellen Rubin, Strategic Issues; Gregory Wilmoth, Applied  Research and Methods; and B. Behn Miller, General Counsel.