Remote Service Delivery Increased during COVID-19, but More Could Be Done to Assist Vulnerable Populations (GAO-23-104650)
Summary
A GAO report to congressional addressees, GAO-23-104650, dated November 2022, on the Social Security Administration (SSA). It notes that in 2020 SSA provided benefits to nearly 70 million individuals and that under the CARES Act SSA received $300 million to prevent, prepare for and respond to COVID-19. GAO reports that on March 17, 2020 SSA closed its offices to the public, providing limited in-person visits for individuals with certain critical needs, and expanded remote service delivery. Its title states that remote service delivery increased during COVID-19, but more could be done to assist vulnerable populations.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Full text
United States Government Accountability Office
Report to Congressional Addressees
SOCIAL SECURITY
November 2022
ADMINISTRATION
Remote Service
Delivery Increased
during COVID-19, but
More Could Be Done
to Assist Vulnerable
Populations
GAO-23-104650
November 2022
SOCIAL SECURITY ADMINISTRATION
Remote Service Delivery Increased during COVID-19,
but More Could Be Done to Assist Vulnerable
Highlights of GAO-23-104650, a report to
Populations
congressional addressees
Why GAO Did This Study What GAO Found
In 2020, SSA provided benefits to COVID-19 prompted the Social Security Administration (SSA) to make dramatic
nearly 70 million individuals. Under the changes in the way it delivers services and administers its programs. On March
CARES Act, SSA received $300 million 17, 2020, SSA closed its offices to the public—providing limited in-person visits
to prevent, prepare for, and respond to for individuals with certain critical needs—and expanded remote service delivery
COVID-19. The CARES Act includes a options. SSA increased its use of telephone, mail, video, and online services.
provision for GAO to monitor federal Through 2021, SSA established policies at field offices to increase the use of in-
efforts to respond to the COVID-19 office appointments. SSA also worked with state agencies that process claims for
pandemic. GAO was also asked to disability benefits to offer video options for certain medical exams. In April 2022,
review SSA’s response.
the agency reopened field offices to walk-in visits from the public.
This report examines (1) changes SSA
The public filed fewer benefit claims with SSA during the pandemic, on average,
made to its delivery of key services; (2)
the effect of these changes on the
compared to the prior 2 years, particularly for certain benefits and among certain
public, including certain vulnerable vulnerable populations, according to GAO’s analysis of SSA data. For example,
populations; and (3) how SSA compared to the 2 years before the pandemic began, average monthly claims
addressed challenges it faced and were lower from March 2020 through December 2021 for several SSA benefits.
identified lessons learned. GAO Specifically, they were 18 percent lower for Supplemental Security Income
analyzed summary and administrative disability benefits, 12 percent lower for Disability Insurance, and 8 percent lower
SSA data from March 2018 to for Supplemental Security Income Old-Age, though Supplemental Security
December 2021, and reviewed the Income claims rebounded in late 2021. Some types of benefits claims declined
agency’s plans, policies, and guidance more for certain populations, such as Spanish speakers.
documents. GAO also conducted
group interviews with SSA staff at Changes in SSA Benefit Claims (January 2020-December 2021)
various levels and offices; and
interviewed SSA officials and external
stakeholders, including disability
advocates and employee groups.
What GAO Recommends
GAO is making five recommendations,
including that SSA develop detailed
plans to enable claimants to apply for
SSI online, evaluate the feasibility of
making existing online applications
available in Spanish, and implement a
coordinated process for assessing
lessons learned from the COVID-19
pandemic and incorporating them into
future plans. SSA agreed with our SSA took steps to address a range of challenges with providing services
recommendations. remotely, but gaps remain in delivering services online and assessing lessons
learned. SSA targeted outreach to certain vulnerable populations and expanded
the use of third parties to help the underserved access benefits and services.
However, not all claimants are able to apply for SSI online and applications in
Spanish cannot be submitted online. As a result, SSA cannot fulfill its mission to
ensure that its services are equitable and accessible, and some eligible
individuals may not apply for benefits. Some SSA offices have assessed specific
View GAO-23-104650. For more information, service delivery changes, but the agency does not have a coordinated process
contact Elizabeth H. Curda at (202) 512-7215
or curdae@gao.gov. for assessing lessons learned from the COVID-19 pandemic and taking related
corrective actions, which could leave SSA vulnerable to other crises in the future.
United States Government Accountability Office
Contents
Letter 1
Background 3
SSA Expanded Remote Service Delivery Options during the
Pandemic 7
More Individuals Accessed SSA Services by Phone or Internet,
but Benefit Claims and SSA’s Productivity Declined in Some
Areas 16
SSA Took Steps to Mitigate a Range of Service Delivery
Challenges during the Pandemic, but Gaps Remain 29
Conclusions 43
Recommendations for Executive Action 44
Agency Comments 44
Appendix I Objectives, Scope, and Methodology 48
Appendix II Challenges in Assessing the Effect of SSA Service Delivery Changes
by Race and Ethnicity 54
Appendix III Comments from the Social Security Administration 61
Appendix IV GAO Contact and Staff Acknowledgments 62
Tables
Table 1: Changes in Policies for In-Office Appointments at Social
Security Administration (SSA) Field Offices during the
COVID-19 Pandemic, 2020–2021 8
Table 2: Online Social Security Card Service Changes during the
COVID-19 Pandemic, 2020–2022 14
Table 3: Percentage of Study Population Covered by the Social
Security Administration’s Race and Ethnicity Data 55
Table 4: Social Security Administration’s (SSA) Race and Ethnicity
Categories over Time 56
Page i GAO-23-104650 Social Security Administration
Figures
Figure 1: Timeline of Social Security Administration (SSA) Field
Office Service Delivery Changes during the COVID-19
Pandemic, January 2020–April 2022 7
Figure 2: Social Security Administration (SSA) Field Office and
National 800 Number Telephone Calls Compared to Pre-
Pandemic Levels (March 2018-December 2021) 17
Figure 3: Social Security Administration (SSA) Old-Age, Survivors,
and Disability Insurance program (OASDI) Claims, by
Method, Compared to Pre-Pandemic Levels (March
2018-December 2021) 18
Figure 4: Average Monthly Wait Times on Social Security
Administration (SSA) Telephone Lines (March 2018-
December 2021) 19
Figure 5: Monthly Busy Rates on Social Security Administration
(SSA) Telephone Lines (March 2018-December 2021) 20
Figure 6: Monthly Applications for Social Security Administration
(SSA) Benefits (March 2018–December 2021) 21
Figure 7: Initial Social Security Administration (SSA) Disability
Claims Processing (March 2018–December 2021) 27
Figure 8: Number of Social Security Administration (SSA)
Disability Appeals Hearings Requested and Held (March
2018 – December 2021) 28
Page ii GAO-23-104650 Social Security Administration
Abbreviations
ACS American Community Survey
CARES Act Coronavirus Aid, Relief, and Economic Security Act
BISG Bayesian Improved Surname Geocoding
CDR continuing disability review
COVID-19 Coronavirus Disease 2019
DDS Disability Determination Services
DI Disability Insurance
EO Executive Order
FY fiscal year
OASI Old-Age and Survivors Insurance
OASDI Old-Age, Survivors, and Disability Insurance
OIG Office of Inspector General
OMB Office of Management and Budget
PFB People Facing Barriers
RECS Race and Ethnicity Collection System
RUCA Rural-Urban Commuting Area Codes
SNAP Supplemental Nutrition Assistance Program
SSN Social Security number
SSA Social Security Administration
SSI Supplemental Security Income program
TPA Third Party Assistance
UI Unemployment Insurance
VPE Vulnerable Population Expert
VPL Vulnerable Population Liaison
This is a work of the U.S. government and is not subject to copyright protection in the
United States. The published product may be reproduced and distributed in its entirety
without further permission from GAO. However, because this work may contain
copyrighted images or other material, permission from the copyright holder may be
necessary if you wish to reproduce this material separately.
Page iii GAO-23-104650 Social Security Administration
Letter
441 G St. N.W.
Washington, DC 20548
November 17, 2022
Congressional Addressees
The COVID-19 pandemic prompted the Social Security Administration
(SSA) to make dramatic changes in the way it delivers services and
administers its programs, which provided benefits to nearly 70 million
Americans in 2020. Most notably, SSA closed all of its offices to the
public on March 17, 2020 and directed agency employees to work from
home, an unprecedented move designed to protect the health of the
public and SSA staff. SSA historically has provided in-person services to
those who need them or prefer them. During the pandemic, the agency
limited in-person services to only the most critical circumstances, a
significant shift in SSA’s typical approach to serving its customers.
The CARES Act includes a provision for us to monitor and oversee the
federal government’s efforts to prepare for, respond to, and recover from
the COVID-19 pandemic. 1 We also were asked to examine SSA’s service
delivery during the COVID-19 pandemic. This report: (1) describes how
SSA changed its delivery of key services during the COVID-19 pandemic;
(2) describes what is known about the effect of these service delivery
changes on the public, including certain vulnerable populations; and (3)
examines how SSA addressed any challenges with remote service
delivery and identified lessons learned during the pandemic.
To address the first objective, we focused on policy updates and changes
from the onset of the pandemic until field offices reopened (March 2020 to
April 2022) that relate to two areas: (1) applications and appeals for the
Old-Age, Survivors, and Disability Insurance program (OASDI) and the
Supplemental Security Income program (SSI); and (2) enumeration (the
issuance of Social Security numbers). We obtained and reviewed
documentation that SSA developed during the pandemic to communicate
policy changes, such as new or revised procedures. We also reviewed
publicly available documentation and obtained written responses from
SSA officials to clarify the timing and details of policy changes when
necessary.
1Pub. L. No. 116-136, § 19010(b), 134 Stat. 281, 580 (2020). All of GAO's reports related
to the COVID-19 pandemic are available on GAO's website at
https://www.gao.gov/coronavirus.
Page 1 GAO-23-104650 Social Security Administration
To address the second objective, we obtained and analyzed
administrative and summary data to describe monthly trends in the
public’s access to SSA services and benefits and agency performance
from the 2 years before the pandemic began through the end of 2021
(March 2018-December 2021). These were the most recent available
data at the time of our review. Specifically:
• We analyzed SSA administrative data on benefit claims and appeals
filed for SSA’s primary benefit programs: OASDI and SSI. We
obtained variables associated with biographic and demographic
information (e.g., date of birth and zip code of claimants) as well as
information about claims and appeals (e.g., filing dates for claims and
appeals actions and type of benefits involved).
• We analyzed these administrative data based on population
characteristics associated with increased vulnerability, such as
individuals’ age, residence, disability status, low-income status, and
limited English proficiency.
• We also analyzed monthly summary data on a variety of topics related
to SSA workloads and service delivery performance from March 2018
through December 2021, including telephone service delivery and
disability case processing.
For each dataset, we conducted a data reliability assessment of selected
variables by conducting electronic data tests for completeness and
accuracy, reviewing documentation on the dataset, and interviewing
knowledgeable agency officials. Unless otherwise noted, we found all of
these administrative and summary datasets to be reliable for the
purposes of our reporting objectives. 2
To address the third objective, we reviewed and analyzed SSA
documentation on challenges faced during the pandemic, steps taken to
address those challenges, and any efforts to identify lessons learned. We
also interviewed SSA headquarters and component-level officials and
representatives from four major SSA employee organizations. To obtain
the perspective of front-line agency officials, we conducted semi-
structured group interviews with a non-generalizable sample of SSA field
office claims specialists, field office and call center managers, and
2As discussed later in the report, we also obtained SSA data on claimants’ race and
ethnicity but determined they were not reliable enough for us to report. We determined
that SSA’s administrative race and ethnicity data, and agency data on the number of daily
visits to field offices during the pandemic, were not sufficiently reliable for our reporting
purposes. See app. I and app. II for more information.
Page 2 GAO-23-104650 Social Security Administration
administrative law judges, as well as state Disability Determination
Services (DDS) supervisors. Participants for these group interviews were
randomly selected to represent urban and rural offices, and different SSA
regions. We also interviewed representatives and stakeholders with five
selected organizations that work with and advocate on behalf of people in
need of SSA benefits and services. See appendix I for more information.
We conducted this performance audit from November 2020 to November
2022 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.
Background
SSA Programs and SSA provides financial assistance to eligible individuals through its major
Services benefit programs:
• Old-Age and Survivors Insurance (OASI)—provides retirement
benefits to eligible older individuals and their families and to survivors
of deceased workers.
• Disability Insurance (DI)—provides benefits to eligible individuals who
have qualifying disabilities, and their eligible family members.
• Supplemental Security Income (SSI)—provides benefits for aged,
blind, or disabled individuals with limited income and resources. 3
In fiscal year 2021, SSA paid over $1.1 trillion in OASDI benefits to a
monthly average of about 65 million individuals. Also in fiscal year 2021,
3In this report we use the term “disability” (e.g., disability benefits, disability claims,
disability hearings) to refer collectively to SSA’s different benefits that are paid due to an
individual’s disability. Those include DI benefits as well as SSI benefits that are paid due
to an individual’s disability (which we refer to as “SSI disability”) and SSI benefits that are
paid due to an individual’s blindness (which we refer to as “SSI blindness”). We also
include in this category benefits and claims for children that are based on their parent’s
eligibility for DI. We use the term “SSI Old-Age” to refer to SSI benefits that are paid due
to an individual’s age (referred to by SSA as “SSI Aged Benefits”). We employ the term
“retirement benefits” for benefits to eligible older individuals and their families under the
OASI program, and the term “survivors benefits” for benefits to survivors of deceased
workers under the OASI program.
Page 3 GAO-23-104650 Social Security Administration
SSA paid over $58 billion in SSI benefits to a monthly average of 8 million
individuals.
In addition to administering these benefit programs, SSA’s other
responsibilities include issuing Social Security numbers (SSN), which are
used to monitor SSA benefits as well as for many non-Social Security
purposes. Most original Social Security cards are issued at birth during
the Enumeration at Birth process, which is completely electronic and
allows parents to submit SSN applications for newborns as part of the
hospital birth registration process. SSA also issues original cards for
applicants who are not enumerated at birth, as well as replacement cards.
The agency also assists individuals with applications for other federal
programs and benefits. 4
Disability Determination Determining eligibility based on disability for DI and SSI may involve
several levels of administrative review, discussed further below. The
determination process is as follows:
• Field office. Staff in field offices review applications from individuals
who want to claim disability benefits (claimants) and determine
whether they meet nonmedical eligibility requirements. If they do, staff
forward the applications to state Disability Determination Services
offices for a medical determination.
• Disability Determination Services (DDS) office. DDS staff review
initial-level claims forwarded by field offices based on medical and
vocational requirements. Specifically, DDS examiners assemble a
team consisting of a disability examiner and a medical or
psychological consultant to determine whether the claimant is
disabled under the Social Security Act.
• Consultative examination. If recent medical records to support a
claim are insufficient to make a determination, a DDS examiner
may order a consultative examination for the claimant. This is a
physical or mental examination or test purchased from a medical
source at SSA’s request and expense to provide evidence for a
claimant’s disability or blindness claim.
• Reconsideration. Claimants who are dissatisfied with the initial-
level DDS eligibility determination may request a “reconsideration”
of their claim. The reconsideration is conducted by a DDS
4SSA supports federal programs administered by other federal and state agencies such
as Medicare, Supplemental Nutrition Assistance Program (SNAP), State Children’s Health
Insurance Program, E-Verify, Medicaid, and federal benefits for veterans.
Page 4 GAO-23-104650 Social Security Administration
examiner and a medical or psychological consultant who were not
involved in the initial determination.
• Administrative law judge hearing. Claimants who are dissatisfied
with the DDS’s initial determination and with the reconsideration
decision may appeal by requesting a hearing before an SSA
administrative law judge. The judge will consider all issues raised in
the initial, reconsidered, or revised determination that were not
decided entirely in the claimant’s favor, and also may consider new
issues. The judge also may review new evidence and ask other
witnesses, such as medical and vocational experts, to testify at the
hearing.
• Appeals Council and Federal Court. Claimants whose applications
for benefits are denied at the hearings level may appeal the decision
to SSA’s Appeals Council—comprising administrative appeals judges
and appeals officers—and subsequently in federal court. 5
Service Delivery Channels Under normal operations, customers access SSA services primarily
through five delivery channels:
• In-person. Customers can access a wide range of services at SSA’s
field offices, including applying for benefits, managing benefits, and
obtaining Social Security cards. Customers also can obtain Social
Security cards at SSA’s dedicated card-issuing centers.
Administrative law judges also hold in-person hearings in SSA hearing
offices. 6
• By phone with field office staff. Many of the services that normally
are available to customers in person at field offices can be handled by
phone with field office staff, including receiving assistance applying for
and managing benefits.
• By phone through the national 800 number. Customers can
manage their benefits and obtain information through the national 800
number. They have the option of conducting business through an
automated system or by speaking directly with an SSA staff person at
a teleservice center. In addition, the Office of Hearings Operations
5A claimant who has exhausted their appeals may file a civil action in federal court within
60 days of the date the claimant receives notice of the Appeals Council’s action on the
claim, unless the claimant obtains an extension of time.
6Prior to COVID-19, video-teleconference was a normal service delivery channel for
hearings. These video-teleconference hearings are held in an SSA space, with the
claimant and their representative in one location, and the administrative law judge in
another location.
Page 5 GAO-23-104650 Social Security Administration
conducts business by phone with the public, answering questions for
individuals who may have a hearing pending or scheduled.
• Online. In recent years, SSA has expanded its remote service
delivery by making some services accessible online. For example,
since 2000, SSA has introduced online options to apply for retirement
benefits, DI, and, in some cases, SSI payments. Eligible individuals in
most states and the District of Columbia can request a replacement
Social Security card online. Individuals also can use an online portal,
called my Social Security, to check account information, manage their
benefits, and access other services. As of 2017, we found that the
overall demand for field office services had not decreased even with
the increased availability of online services. 7
• By mail. SSA exchanges communications with customers through the
U.S. Postal Service. In addition, under normal operations, field offices
periodically receive applications for benefits and replacement Social
Security cards in the mail.
CARES Act Funding for SSA In March 2020, the Coronavirus Aid, Relief, and Economic Security Act
(CARES Act) was enacted. The Act provided funding and other
emergency assistance for individuals, families, and businesses affected
by COVID-19. Under the CARES Act, SSA received $300 million to
prevent, prepare for, and respond to the COVID-19 pandemic. 8 According
to SSA officials, SSA used most of this money to pay the salaries and
benefits of staff who normally conduct program integrity work that was
suspended for the first several months of the pandemic. 9 Officials also
reported using the CARES Act funding to cover leave for staff unable to
telework, as well as other COVID-19 related expenses, including
information technology to expand telework.
7GAO, Social Security Administration: Improvements Needed in Facilities Planning and
Service Delivery Evaluation, GAO-17-597 (Washington, D.C.: July 25, 2017).
8Pub. L. No. 116-136, div. B, tit. VIII, 134 Stat. 281, 572 (2020).
9Specifically, SSA suspended continuing disability reviews (CDR), in which the agency
examines whether current beneficiaries continue to meet the eligibility criteria for disability
benefits. The agency received funding for fiscal year 2020 for program integrity efforts,
including CDRs. According to SSA officials, the agency would have used this funding to
pay the salaries of staff conducting CDRs. The officials stated, however, that the agency
was not able to use this funding fully in fiscal year 2020 because the agency conducted
fewer CDRs than planned. The officials stated that the staff who normally perform CDRs
performed other assigned workloads, and SSA paid a portion of those staff’s salaries with
the CARES Act funding.
Page 6 GAO-23-104650 Social Security Administration
SSA Expanded
Remote Service
Delivery Options
during the Pandemic
SSA Increased the Use of SSA initially responded to the pandemic by closing its field and hearing
Phone, Mail, and Video after offices to the public. The agency increased the use of telephone, mail,
Closing Its Offices and Limiting drop boxes, and fax as service channels, and created alternatives for
In-person Services customers to submit sensitive identity-verification documents. SSA also
began to offer telephone and online video hearing options for claimants
that could be conducted remotely by SSA staff. In addition, SSA
expanded the circumstances under which customers could qualify for in-
person appointments. The agency reopened field offices to the public in
April 2022, again allowing walk-in visitors with and without appointments.
Field Offices At the start of the pandemic, SSA closed its approximately 1,235 field
offices to the general public—with limited exceptions for customers with
dire needs—and expanded remote customer service options by
publishing more local area phone numbers and making greater use of
mail to receive forms and original documents. The agency later
established policies at field offices to increase the use of in-office
appointments, and developed alternatives for customers seeking to avoid
mail service channels. After 2 years, the agency reopened field offices to
the general public in April 2022 (see fig. 1).
Figure 1: Timeline of Social Security Administration (SSA) Field Office Service Delivery Changes during the COVID-19
Pandemic, January 2020–April 2022
a
Policies for in-office appointments evolved throughout the rest of 2020 and early 2021 to add
eligibility criteria for other individuals in limited situations.
b
This quicker appointment format further expanded who could qualify for in-office services.
Page 7 GAO-23-104650 Social Security Administration
• Limited in-person appointments. At the start of the pandemic, SSA
provided limited in-person appointments for certain customers whose
requests could not be completed remotely. For example, the agency
permitted appointments for some individuals who needed to submit
original Social Security card applications and for benefit recipients
who were eligible to have their payments expedited due to dire need.
Over time, the agency expanded the criteria for its appointment
eligibility policy (see table 1).
Table 1: Changes in Policies for In-Office Appointments at Social Security Administration (SSA) Field Offices during the
COVID-19 Pandemic, 2020–2021
Date Policy change Eligibility criteria
March 2020 Closed field offices and allowed limited in- Individuals age 12 or older submitting original Social Security
office appointments for certain customers in card applications, and benefit recipients in dire need of
limited situations expedited paymentsa
March 2020 Expanded in-office appointments for Cases in which the benefit recipient was accidentally
additional cases requiring face-to-face determined to be deceased
appointments
October 2020 Expanded appointment eligibility for certain Individuals needing to update their personal record who
Social Security card customers required a replacement card to obtain vital services or benefits,
such as those related to income or medical careb
February 2021 Expanded in-office appointments for certain Individuals with a retroactive benefits claim that required the
benefit claimants required to present agency to review documentary evidence
documents in person
May 2021 Introduced express interviews—a single- Individuals needing to submit necessary evidence in person to
subject interview intended to last 5 to 7 apply for an original or replacement Social Security card, those
minutes—as an alternative format to full in- needing to submit additional evidence for processing claims and
office appointmentsc other workloads, and those in certain limited, critical situationsd
September 2021 Encouraged in-office appointments for Individuals required to provide original documents, such as
individuals requiring a review of sensitive driver’s licenses, passports, or immigration documents
documentse
Source: GAO review of Social Security Administration documentation and agency responses. | GAO-23-104650
a
Expedited payments were for beneficiaries who had an immediate need for food, shelter, or medical
care that could not reasonably be met through other resources available in the community.
b
At this time, all other replacement Social Security card requests were handled through the mail,
requiring the customer to send an application and requisite documentation to their local field office.
c
SSA officials said the agency developed a pilot program to test multiple prototypes for express
interviews from January 2021 through March 2021 at 81 field offices, and ultimately implemented the
one with the most favorable customer and field office responses.
d
Though the policy provided general guidelines for interview eligibility, the agency ultimately gave
local field office managers the discretion to determine necessary criteria to schedule these interviews
based on staffing and other office considerations.
e
In September 2021, field office technicians began discouraging customers from submitting sensitive
documents by mail or drop box, and offered them in-office appointments if they required a review of
such documents. Prior to September 2021, these same customers would have qualified for an in-
office appointment due to a critical need or an express interview to submit evidence.
Page 8 GAO-23-104650 Social Security Administration
• Expanded telephone service channels. Prior to the pandemic, most
of SSA’s 1,235 field offices had a local phone number publicly
available on the agency’s field office locator webpage, though nearly
500 listed only the agency’s national 800 line. 10 SSA published all
field office phone numbers on its field office locator webpage in June
2020, providing the public with an alternative to the agency’s 800
number. 11 Advocates reported advantages to customers accessing
field offices directly, such as customers being able to receive more
individualized customer service. Once offices reopened to walk-in
visitors with and without appointments, the agency reinstated its pre-
pandemic policy to publish a select group of field office phone
numbers on its website. As a result, the nearly 500 field offices
reverted to listing only the national 800 line on their locator
webpage. 12
• Drop boxes and fax. After the pandemic began, SSA established
alternatives to mailing processes, in part because some customers
hesitated to mail their original documents as required for certain
Social Security card and benefit claims services. For instance, agency
officials said SSA expanded the use of drop boxes at field offices in
late 2020, providing the public with an alternative method for
submitting documents to their local offices. By March 2021, the
agency had installed drop boxes at nearly 1,000 field offices across
the country. 13 In April 2021, SSA also changed its policy to accept
faxed applications for its benefit programs on a temporary basis, a
practice that agency officials said is ongoing.
• Alternate identification options. The agency also temporarily
adjusted its evidence policies to provide flexibility for customers
seeking to avoid mailing sensitive documents to field offices. In March
2021, SSA temporarily granted U.S. citizens who required a
10According to SSA officials, agency notices to customers generally include the telephone
number for their local office.
11The local field office phone numbers also were available through online search engines.
12According to SSA officials, the agency reverted to its pre-pandemic policy to prepare for
potential surges in field office visitors, and shifted some staff who had been providing
telephone service to provide face-to-face service. They said this better positioned their
field offices to provide balanced service to customers who use either service channel.
13SSA officials said the agency developed and tested drop boxes in fall 2020 at 100 field
offices. In March 2021, the agency surveyed 1,231 field offices and reported that 985 had
implemented drop boxes, while 52 were unable to accommodate one. In March 2022, an
agency official reported to us that SSA planned to continue drop box services after it
restored in-person services for the general public at field offices.
Page 9 GAO-23-104650 Social Security Administration
replacement Social Security card and were unable to visit a field office
due to pandemic restrictions the flexibility to submit secondary proof
of identity documents as an alternative to required primary
documents. Prior to this policy change, customers who required a
replacement card would typically have to submit their driver’s license
for identity verification through the mail or, if available, a field office
drop box. With the change, customers could submit a less sensitive
document, such as an employer ID, a marriage document, or a
certified copy of a medical record when appropriate. 14
• Reopening field offices. After 2 years of limited in-person services,
SSA reopened field offices to the general public in April 2022 and
restored in-person services throughout the country for individuals with
and without an appointment. At that time, the agency planned to
continue requiring certain pandemic safety measures, including
masking, physical distancing, and self-health checks for COVID-19
symptoms. In July 2022, the agency reported that, on any given day,
50 to 60 percent of field office staff worked on site, while 40 to 50
percent teleworked.
State Disability Determination In November 2020, we reported that DDS offices varied by state in their
Services (DDS) Offices initial response to the pandemic and the extent to which they were able to
provide continuous service delivery. 15 All DDSs shifted to alternative
staffing arrangements at the start of the pandemic, which led to some
temporary office closures. SSA initially instructed DDS offices to suspend
referrals for in-person consultative exams, though it offered offices the
option to reinstate them a few months afterward. In response to delays
associated with these exams, the agency also temporarily expanded
telehealth exams for a limited group of disability cases. According to SSA
officials, in April 2022, the DDS offices returned to pre-pandemic policies
and procedures.
• Staffing and closing. DDS offices experienced staffing changes and
closures at the start of the pandemic, though their initial pandemic
14With field offices closed during the pandemic, U.S. citizens seeking a replacement
Social Security card who did not meet the criteria to be able to apply through the agency’s
online system were required to mail in their application along with the required proof of
identity evidence, typically their driver’s license or other ID. The agency reported to us in
June 2022 that it has no plans to continue the alternative secondary proof of identity
documentation policy.
15GAO, COVID-19: Urgent Actions Needed to Better Ensure an Effective Federal
Response, GAO-21-191 (Washington, D.C.: November 2020).
Page 10 GAO-23-104650 Social Security Administration
response and the extent to which they were able to continue
processing disability benefit claims varied by location. 16 As we
reported in November 2020, according to our July 2020 survey of all
52 DDS administrators, nine DDS offices reported closing for some
period of time because of the pandemic. All DDS offices reported
reducing the number of staff on site, with 27 reporting their staff
worked alternative shifts and 51 reporting their staff teleworked off
site. One DDS administrator reported expanding the hours during
which staff could telework or work on site. 17
• In-person consultative exams. In March 2020, the agency
suspended in-person consultative exams to ensure that DDS offices
could follow Center for Disease Control and Prevention and local
public safety guidelines. 18 In May 2020, SSA provided a framework for
DDS offices to resume in-person exams on a voluntary basis, as long
as the exam providers took steps to minimize risk of exposure to
COVID-19. Within this framework, SSA called on each DDS office to
determine and manage the reinstatement of in-person exams in its
service region in accordance with CDC, state, tribal, local, and
territorial government guidelines regarding non-essential medical
appointments and physical distancing requirements. However, many
medical providers did not offer in-person services in the pandemic
environment, resulting in delays in scheduling exams that varied by
region. 19
• Telehealth consultative exams. In response to scheduling delays
associated with consultative exams, SSA temporarily expanded the
availability of telehealth exams for a limited number of cases. SSA
had since 2014 permitted certain psychiatric and psychological
examinations to be conducted using secure audio and video
technology at select locations arranged by DDSs. However, in April
2020 the agency established procedures temporarily allowing
providers to use additional telehealth technology to conduct these
exams, so long as the claimant voluntarily agreed to a telehealth
16There are 52 DDS offices: one in each of the 50 states, the District of Columbia, and
Puerto Rico.
17GAO-21-191.
18Consultative exams are conducted for benefit claimants requiring additional medical
evidence for a disability determination.
19SSA considered COVID-19 pandemic-related concerns to be valid reasons for missing,
canceling, postponing, or rescheduling exams. DDS offices paused disability cases where
an exam was required but could not be completed due to pandemic concerns.
Page 11 GAO-23-104650 Social Security Administration
format. Later in 2020, SSA expanded its guidance to allow claimants
to attend telehealth exams from their homes or other private locations.
In December 2021, SSA also permitted certain speech and language
telehealth exams. Agency officials told us that SSA would continue to
explore other ways to expand telehealth exam options. 20
Hearing Offices SSA’s hearing offices pivoted to remote service delivery at the start of the
pandemic, offering a telephone hearing format option for claimants and
temporarily suspending some casework involving paper records. The
offices later added an online video hearing option, and reintroduced in-
person hearings in March 2022.
• Office closures and casework suspensions. In March 2020, the
agency closed hearing offices to the public, suspending in-person
hearings and video teleconference hearings conducted from agency
facilities. 21 It also suspended processing for some hearings cases
involving paper records if they required staff to be in the office to
develop the case. In July 2022, SSA reported to us that the paper
cases associated with this delay in processing represented
approximately 3 percent of SSA’s total pending cases at the hearings
level. 22 After developing a method to work on these cases remotely,
hearings operations staff resumed processing non-disability paper
cases in June 2020 and disability paper cases in December 2020. 23
• Telephone and online video hearings. At the start of the pandemic,
SSA initially offered claimants the option to appear at a hearing by
telephone, though the agency would defer scheduling a hearing until
an in-person format was reinstated if the claimant did not agree to a
20In March 2022, an SSA official said there was a working group that included physicians
and SSA officials charged with identifying additional impairments, including physical ones
that would be suitable for telehealth exams.
21SSA’s OIG reported that, under normal operations, administrative law judges conducted
video teleconference hearings in a hearing office or another hearings operation facility
while the other parties connected from a separate location, such as a different hearing
office or a claimant representative’s office. According to SSA, in-person hearings were the
default and video teleconference hearings were an option for appellants.
22We previously reported on delays regarding these paper cases. See GAO-21-191.
23In the months leading up to December 2020, SSA developed a new electronic repository
for appeal documents to allow hearings operation staff to work on paper cases remotely.
Page 12 GAO-23-104650 Social Security Administration
remote option. 24 At the end of calendar year 2020, SSA began
conducting online video hearings using software that allowed
administrative law judges, claimants, and their representatives to
participate in a hearing from any private location. 25 In terms of the
volume of hearings deferrals, SSA officials said approximately 20,000
to 30,000 claimants had declined a remote hearing as of March 2022.
• Return of in-person hearings. In spring 2022, SSA reintroduced in-
person hearings in a limited capacity for claimants who chose not to
have a remote hearing during the pandemic. According to an SSA
memo, the agency prioritized disability cases that met a combination
of criteria, such as cases that were determined to be critical in terms
of the severity of the claimant’s medical condition or were at least 190
days old. It also prioritized certain cases from groups facing barriers to
equitable service, such as older claimants, children, homeless
individuals, veterans, and individuals with limited English proficiency.
SSA Expanded Online SSA had made several services available online prior to the pandemic.
Services for Social For instance, eligible individuals in most states and the District of
Columbia could request a replacement Social Security card online. The
Security Card Customers
agency had introduced online options to apply for retirement benefits, DI,
and Benefit Claimants and, in some limited cases, SSI benefits. Customers also could use an
online portal, called my Social Security, to manage their benefits and view
information online such as their earnings record.
Social Security Card Services During the pandemic, SSA expanded online services for Social Security
card customers, in part by partnering with non-federal entities to provide
virtual identity verification (see table 2).
24SSA had a policy in place to hold telephone hearings under certain circumstance. The
agency’s hearings operations office had employed telephone hearings in the past when
extraordinary circumstances prevented the claimant from appearing in person or by video
teleconference, such as when the claimant was incarcerated or during natural disasters.
25SSA began offering the online video hearings option during the pandemic in a few
hearing offices in September 2020, and expanded online video hearings to all offices in
early December 2020. Hearing offices would delay scheduling a hearing or postpone it
until normal operations resumed if SSA was (1) unable to reach a party to a hearing, (2) a
party did not agree to appear by telephone or by online video, or (3) a party revoked their
previous agreement to appear by telephone or online video.
Page 13 GAO-23-104650 Social Security Administration
Table 2: Online Social Security Card Service Changes during the COVID-19 Pandemic, 2020–2022
Date Service addition
Since March 2020 Added five states—Alabama, Minnesota, Nevada, Ohio, and Oregon—to SSA’s preexisting online SSN
replacement card application, which expanded the service to residents in 47 states and the District of
Columbiaa
June 2020 Began accepting credentials issued by ID.me, a certified credential provider, to serve as an alternative
identity verification mechanism for accessing online services
November 2020 Began testing a new service delivery option to process certain Social Security card replacement
requests for qualifying U.S. citizens remotely, which involves an interview with the applicant via Microsoft
Teams and verification of the applicant’s U.S. driver’s license or other ID card through a data exchange
with the American Association of Motor Vehicle Administrators (Association)b
December 2020 Formed an agreement with the Association to allow SSA to verify driver’s license data directly with 48
states and the District of Columbia by mid-2021
April 2022 Released a web application that allows customers to start and submit their applications for original and
replacement cards online, which informs the customer of the evidence SSA requires before visiting a
field office to complete their requestc
April 2022 Introduced a feature that allows some customers to request a replacement Social Security card with a
name change due to marriage through the online SSN replacement card applicationd
Source: GAO review of Social Security Administration (SSA) documentation and agency responses. | GAO-23-104650
a
This online service is for customers seeking a card replacement requiring no change to their SSN
record and, as of April 2022, certain customers seeking a name-change replacement card due to
marriage. The service is not currently available for residents in Alaska, New Hampshire, and
Oklahoma. In June 2022, SSA reported to us that it plans to expand its internet replacement card
program to the remaining three states.
b
The service is for card replacements that require no change to the customer’s SSN record. In June
2022, the agency reported to us that 1,170 field offices were testing the use of Microsoft Teams for
these requests based on the availability of the Association’s data verification service. The agency
discontinued the pilot in July 2021 and resumed the service with modifications in March 2022.
c
In addition, the agency reported to us that as of June 2022 it is working with U.S. Citizenship and
Immigration Services to automate the assignment and issuance of Social Security cards to noncitizen
applicants who applied and were approved as naturalized U.S. citizens.
d
As of June 2022, individuals with a marriage certificate issued by Arkansas, Georgia, Missouri, and
South Dakota can also apply online for a name-change replacement Social Security card. SSA
officials said the agency plans to expand this feature to additional states in 2022.
Benefit Applications Throughout the pandemic, SSA expanded online capabilities for benefit
applicants through the my Social Security online portal, according to SSA
officials. In January 2021, the agency added the capability to share
benefit claimants’ folders with them through their my Social Security
account or an encrypted email attachment to facilitate remote access to
claims materials during the disability hearings process. Upon request,
claimants also could be granted access to their electronic folder contents
at any time in the disability application and determination process. During
the pandemic, SSA also expanded my Social Security capabilities in a
number of ways to facilitate the remote benefit claims process,
introducing the following items:
Page 14 GAO-23-104650 Social Security Administration
• Claim status tracker that provides claim status information,
• Preferences application that allows users to set notice delivery
preferences online, and
• Social Security statement fact sheets.
The agency added several functionalities to the my Social Security portal
for benefit recipients as well, many of which were intended to make it
easier for individuals or organizations who manage payments for a
beneficiary to communicate with SSA. 26
The agency added two online tools in the second year of the pandemic to
help individuals apply remotely to the SSI program. In summer 2021, SSA
helped SSI claimants file for benefits by granting certain claimant
advocacy organizations in local communities access to new electronic,
fillable applications for SSI benefits for individuals who qualify due to their
age or disability. 27 In March 2022, SSA also implemented an online tool
that enables SSI applicants and third-parties to register a start date for
their application—a “protective filing date”—and request an appointment
to apply for SSI. 28 According to SSA, individuals who cannot or choose
not to contact the agency by phone or through other online services may
use the web-based tool to submit a request for an appointment to file for
benefits.
26In cases where beneficiaries are incapable of managing their OASDI or SSI payments,
the agency appoints a suitable representative payee who manages the payments on
behalf of the beneficiaries, typically a family member or friend. Some new my Social
Security functionalities for benefit recipients include a message center inbox for individual
representative payees, the ability for representative payees to change address information
online, and individual representative payee access to request a Medicare replacement
card.
27Earlier in the pandemic, SSA also collaborated with the Centers for Medicaid and
Medicare Services to implement a new online tool to allow beneficiaries to enroll in
Medicare Part B.
28A protective filing date establishes a date that can be used as the application filing date
based on an oral inquiry about SSI eligibility or a written statement of the claimant’s intent
to file for SSI. It establishes the earliest possible date from which the claimant can become
eligible for SSI benefits, so long as the claimant or a proper applicant submits a valid SSI
application within a prescribed time frame.
Page 15 GAO-23-104650 Social Security Administration
More Individuals
Accessed SSA
Services by Phone or
Internet, but Benefit
Claims and SSA’s
Productivity Declined
in Some Areas
Individuals Increased In the general absence of in-person services during the pandemic, the
Phone and Internet Use to public’s use of both phone and internet services grew, particularly calls to
field offices. 29 Specifically, the average number of general calls answered
Access SSA Services and
by field offices and the national 800 number phone lines each month was
Benefits, and SSA’s 70 percent higher during the pandemic than in the 2 years prior to the
Phone Service Slowed in pandemic (see fig. 2). This increase was almost entirely in the field office
2021 phone lines, some of whose contact numbers were not publicly available
until June 2020.
29According to SSA’s Annual Performance Report for Fiscal Years (FY) 2021-2023, the
number of successfully completed online transactions in FY 2020 was 221 million, a 28
percent increase over FY 2019. In FY 2021, there were 290 million successfully
completed online transactions, a 31 percent increase over FY 2020.
Page 16 GAO-23-104650 Social Security Administration
Figure 2: Social Security Administration (SSA) Field Office and National 800 Number Telephone Calls Compared to Pre-
Pandemic Levels (March 2018-December 2021)
a
Some field office phone lines were not made publicly available until June 2020.
Similarly, while the number of OASDI benefit claims filed online and by
phone increased during the pandemic, telephone claims increased
substantially. Specifically, the average number of claims filed by
telephone each month more than doubled compared to the 2 years prior
to the pandemic and became the predominant application method. 30 By
comparison, the average number of claims filed by internet increased by
10 percent, from about 300,000 to more than 330,000 over the same
period (see fig. 3). 31
30We did not obtain data on the methods used to apply for SSI benefits because SSA said
they are not collected, according to SSA officials knowledgeable about SSI program data
systems.
31Not all benefit programs have an online application. For example, it is not possible to
apply for Survivors Insurance online as of the end of June 2022.
Page 17 GAO-23-104650 Social Security Administration
Figure 3: Social Security Administration (SSA) Old-Age, Survivors, and Disability Insurance program (OASDI) Claims, by
Method, Compared to Pre-Pandemic Levels (March 2018-December 2021)
Telephone service delivery. Data from SSA on caller wait times indicate
that the agency’s telephone service during 2020 generally improved or
stayed the same as the 2 years before the pandemic. However, callers
began to experience longer wait times and busy rates in 2021. In 2021,
SSA transitioned its national 800 number from what had been two
separate systems into one, unified system. According to SSA, the
unification led to system instability that increased wait times. In response,
the agency temporarily reverted to one of the prior legacy systems that in
turn led to service issues for field office telephone lines. According to
SSA’s data, average wait times for the national 800 number increased
substantially from 7.9 minutes in June 2021 to 36.2 minutes in December
2021. Average wait times on the field office phone lines remained
relatively low for much of the pandemic, but rose steadily in 2021, hitting
a pandemic high of 5.2 minutes in December 2021 (see fig. 4).
Page 18 GAO-23-104650 Social Security Administration
Figure 4: Average Monthly Wait Times on Social Security Administration (SSA) Telephone Lines (March 2018-December 2021)
a
Agency officials said SSA published all field office phone numbers on its field office locator webpage
in June 2020, providing the public with an alternative to the agency’s 800 number.
b
In May 2021, SSA consolidated its two legacy 800 number systems into a single unified system.
SSA’s telephone busy rates—the percentage of callers getting a “busy”
signal—generally were lower during most of the pandemic than in the 2
years prior (see fig. 5). 32
32Callers receive a busy message when the system has reached capacity. A message
informs callers to call back later.
Page 19 GAO-23-104650 Social Security Administration
Figure 5: Monthly Busy Rates on Social Security Administration (SSA) Telephone Lines (March 2018-December 2021)
a
SSA refers to this metric as its “busy rate.”
For example, the national 800 phone line had a busy rate below 1.5
percent from May 2020 through December 2021, well below pre-
pandemic levels. 33 Field office phone lines had lower busy rates during
most of the pandemic before experiencing a sustained increase beginning
in the spring of 2021, and exceeding 10 percent in November and
December 2021.
However, the phone delivery performance measures discussed above do
not fully capture the customer service experience for those calling SSA.
The data do not include calls that are abandoned while waiting to speak
to an operator. According to data reported by the SSA Office of Inspector
General (OIG), the average number of calls abandoned each month at
the 800 line and field office phone lines was 10 percent higher from
March 2020 through September 2020 compared to October 2019 through
February 2020, with approximately 133,000 additional calls abandoned in
33While outside of our reporting timeframe, the busy rate on the 800 phone line increased
to approximately 15 percent in January 2022, which represents a significant change from
the December 2021 busy rate of 1.2 percent.
Page 20 GAO-23-104650 Social Security Administration
each of those 7 months. 34 SSA’s OIG told us in May 2022 that it is
planning an in-depth review of these telephone service disruptions.
Claims for Disability and During the pandemic, some benefit programs experienced an increase in
SSI Benefits Declined, claims while others saw a decline. Overall, individuals filed fewer claims,
and the average number of benefit claims filed each month from March
Particularly among Some
2020 to December 2021 across all programs was 5 percent lower
Vulnerable Populations, compared to the 2 years before the pandemic began. According to our
but Data on Race and analysis of SSA administrative claims data, the overall decline in average
Ethnicity Are Limited monthly claims was driven by the decline in the average number of DI
and SSI claims per month compared to the 2 years before the pandemic
(see fig. 6).
Figure 6: Monthly Applications for Social Security Administration (SSA) Benefits (March 2018–December 2021)
Note: “Pre-pandemic average” refers to the monthly average for the 2 years prior to the pandemic,
March 2018–February 2020.
a
Includes both Old-Age and Survivors Insurance, which provides retirement benefits to eligible older
individuals and their families and to survivors of deceased workers.
b
Includes SSI claims on the basis of disability or blindness.
c
Includes SSI claims on the basis of age.
34See SSA OIG, Congressional Response Report: The Social Security Administration’s
Telephone Service Performance, A-05-20-50999 (Nov. 2021), fig. 7 on page 15.
Page 21 GAO-23-104650 Social Security Administration
d
In July 2021, SSA created two field office roles: Vulnerable Population Liaison and Vulnerable
Population Expert to take and submit applications for SSI, refer potential applicants to third-party
partners, and conduct quality control reviews on claims submitted by those partners.
Specifically, compared to the 2 years before the pandemic began,
average monthly claims from March 2020 to December 2021 declined 12
percent for DI, while SSI disability claims (those made on the basis of
disability or blindness) fell 18 percent, and SSI old-age claims fell 8
percent. In contrast, the average number of monthly claims for retirement
benefits and survivors benefits increased by 6 percent. In the second half
of 2021, however, claims for some types of benefits that had declined
during the pandemic were rebounding. For example, SSI claims for old-
age and disability began to increase in the summer and fall of 2021.
While these trends in claims coincided with a range of SSA’s service
delivery changes, they also could be related to factors beyond SSA—
such as the economic downturn and the availability of other federal
benefits during the pandemic. For example, the federal response to the
pandemic expanded eligibility and the availability of some types of
benefits, such as expanded eligibility for Unemployment Insurance (UI). 35
Conversely, while the economic downturn may have driven more
individuals into retirement, 36 claims for retirement benefits were also on
an upward trend before the pandemic.
According to our analysis, individuals also filed fewer disability appeals
during the pandemic, both at the reconsideration and hearing stages.
According to SSA, the reduced number of appeals filed can be attributed
both to the increased availability of other benefits as well as delays in
SSA’s processing of initial claims. Requests for disability reconsiderations
were lower, particularly among SSI applicants, which were down 20
percent compared to 5 percent among DI cases. Similarly, requests for
disability hearings fell during the pandemic, continuing a decline that pre-
35Research shows that when the duration of UI benefits is extended, the number of
unemployed workers that use DI to replace lost income declines. See Fatih Karahan &
Yusuf Mercan, 2019. "UI and DI: Macroeconomic Implications of Program Substitution,"
2019 Meeting Papers 1076, Society for Economic Dynamics, and Maestas, Nicole and
Mullen, Kathleen J., "Economic Conditions, the COVID-19 Pandemic Recession, and
Implications for Disability Insurance in the United States" (2022). Wharton Pension
Research Council Working Papers. 733. https://repository.upenn.edu/prc_papers/733.
36Fry, Richard, “Amid the pandemic, a rising share of older U.S. adults are now retired.”
Pew Research Center (Nov. 4, 2021). Accessed from
https://www.pewresearch.org/fact-tank/2021/11/04/amid-the-pandemic-a-rising-share-of-ol
der-u-s-adults-are-now-retired/ on June 4, 2022.
Page 22 GAO-23-104650 Social Security Administration
dated the pandemic. Among requests for disability hearings, the decline
in the 2 years prior to the pandemic was more pronounced in the SSI
program than in DI, and that trend carried through to the pandemic. 37
During the pandemic, our analysis of SSA data showed that some
vulnerable populations 38 experienced greater declines in applying for
benefits compared to the general population:
• The overall decline in disability and SSI claims demonstrated that
fewer individuals with a disability or very low incomes (as indicated by
qualifying for SSI benefits) were accessing benefits. For example,
average monthly claims for disability benefits (DI, SSI blindness, SSI
disability) were down 15 percent during the pandemic compared to
the 2 years beforehand. Similarly, average monthly claims for all SSI
benefits were down 17 percent during the pandemic.
• The number of claims among non-English speakers generally
declined more substantially than among English speakers. For
example, average monthly SSI old-age claims fell 9 percent among
those whose primary language is Spanish and 16 percent among
those with other languages, compared to 3 percent among those
whose primary language is English. 39 Among those filing claims for
any of SSA’s disability benefits (DI, SSI blindness, and SSI disability),
average monthly claims fell 22 percent among those whose primary
language is Spanish compared to 14 percent among those whose
primary language is English (see interactive graphic).
SSA_COVID_interactive_graphic.html
37According to SSA officials, the decline in hearing requests was due in part to claimants’
reluctance to participate in remote hearings, particularly as new methods of conducting
hearings were introduced. The agency’s OIG also reported that the decline in disability
hearing requests may be partially driven by delays in reconsideration decisions at the
DDSs. SSA OIG, The Office of Hearings Use of Video and Telephone Hearings, A-05-18-
50615 (July 2022).
38We examined several demographic dimensions of vulnerability, including age, disability
status, low income, urban or rural residency, level of English proficiency, and
race/ethnicity. See app. I for more information about these dimensions of vulnerability.
39We analyzed Spanish speakers separately because they were the largest group
reporting a preferred language other than English, among the claimant population we
analyzed.
Page 23 GAO-23-104650 Social Security Administration
• Disability claims (those for DI, SSI disability, and SSI blindness) fell
more for children than for adults ages 18-64. 40 For example, the
average monthly disability claims for children, up to age 17,
decreased by 23 percent during the pandemic, compared to a
decrease of 13 percent among disability claims filed for adults. 41
We also attempted to include race and ethnicity in our analysis of
vulnerable populations but encountered challenges because the agency
does not routinely collect these data (see app. II). For example, SSA
reported in February 2022 that the agency has race and ethnicity data for
59 percent of Social Security number holders. Although SSA maintains
race and ethnicity data on some SSN holders, the agency is not currently
well-positioned to assess the race and ethnicity of its entire claimant
population. 42
The agency has taken steps to improve its race and ethnicity data. In
February 2022, SSA published an Equity Action Plan, which was
developed in response to Executive Order (EO) 13985 on Advancing
Racial Equity and Support for Underserved Communities. Executive
Order 13985 states that each agency must assess whether certain of its
programs and policies deliver benefits and opportunities equitably to
people of color and other underserved groups. The Equity Action Plan
identified a number of steps SSA plans to take to improve its race and
40In addition to the factors mentioned above, there are several other factors that might
have affected claims for children’s disability benefits. For example, with the expanded
child tax credit and other COVID relief measures, parents may not have needed to rely on
disability programs for financial support. In addition, advocates told us about barriers that
might exist in the case of parents wanting to apply for benefits on behalf of their children,
such as difficulties obtaining supporting documentation from education and medical
providers for children’s disability claims.
41In the event that an individual with enough Social Security credits to entitle them to
certain OASDI benefits has a dependent child who (1) becomes disabled before the age
of 22 or, (2) is under age 18 or is a full-time student under age 19, that child may qualify to
receive benefits. In these instances, the child qualifies for the benefit on the basis of their
parent’s disability.
42Since the 1930s, SSA has collected, on a voluntary basis, information on the race and
ethnicity of applicants for new or replacement Social Security cards. This is done using the
form SS-5, which is the paper application for a new or replacement Social Security card.
Beginning in 1987, however, SSA began to introduce automated processes to assign
SSNs such as Enumeration at Birth and Enumeration at Entry–which do not provide the
agency with race or ethnicity data. Over time, these automated processes became more
prevalent. According to SSA, less than 5 percent of new Social Security card applications
are submitted on the form SS-5. See app.1 for more information on SSA’s history of
collecting race and ethnicity information.
Page 24 GAO-23-104650 Social Security Administration
ethnicity data and its ability to conduct analysis on the race and ethnicity
of program applicants and beneficiaries. 43 These steps include increasing
the amount of race and ethnicity data the agency collects itself, exploring
options for obtaining data from other sources, and conducting or
supporting additional research related to race and ethnicity.
Though SSA has defined goals and timeframes for some of these efforts,
the agency has not developed detailed plans to guide other efforts,
particularly those in earlier stages. For example, in June 2022, SSA
provided a detailed plan, including clear steps and performance goals, for
the agency’s ongoing efforts to increase race and ethnicity data collection
through applications for new or replacement Social Security cards filed in
the office or online. However, since most SSN applications are filed
though automated processes that do not collect race and ethnicity data,
these efforts are not likely to result in sufficiently reliable data for use in
statistical analyses. In contrast, using data available from other state and
federal agencies could provide SSA with more comprehensive data on
race and ethnicity. According to SSA, its efforts to obtain additional race
and ethnicity data from other federal entities through expanded or new
agreements are in early stages, but those plans lack timelines and other
key details. SSA told us that they have engaged in discussions with
federal agencies about the possibility of establishing data exchange
partnerships, but that such plans require an examination of requirements
involved with data sharing across federal agencies. 44
Nonetheless, SSA has engaged in similar data exchanges with federal
and state entities in the past. For example, to analyze earnings data for
men and women by race and ethnicity, SSA matched its earnings data
with Census data on race and ethnicity. 45 Further, SSA has ongoing
electronic data exchanges with states for use in determining entitlement
and eligibility for federally funded benefit programs, such as Medicare and
Medicaid. SSA also receives data from states to verify eligibility and
benefit payment amounts under certain SSA administered programs.
43SSA, Equity Action Plan in Agreement with EO 13985 (February 2022).
44Specifically, SSA identified the Privacy Act (5 U.S.C. § 552a), the Social Security Act (42
U.S.C. § 1306), and SSA’s privacy regulations (20 C.F.R. Part 401).
45SSA, Research, Statistics, & Policy Analysis. “Statistics at a Glance: Earnings of Men
Aged 20-59, by Race and Ethnicity, 2055-2020,” June 2022.
Page 25 GAO-23-104650 Social Security Administration
SSA also has undertaken efforts to collect race and ethnicity data in the
past that have not come to fruition. For example, in 2003, we reported
that SSA had decided to collect race data from individuals applying for
disability or for other benefits at the time of application. 46 We found that
SSA had set up a task force to explore implementation issues, but had
not yet set a start date to begin collecting the data. Ultimately, the agency
decided not to move forward with its plan to collect race data from
individuals applying for benefits due to concerns about possible
misperceptions that race might play a role in SSA’s decisions to award
benefits.
Federal internal control standards state that defining project objectives—
such as through clear steps, goals, performance measures, and
timelines—supports successful outcomes for the agency. 47 In light of the
complexity of this effort and SSA’s past experience with similar efforts,
without detailed plans—that contain clear steps, goals, metrics, and
timelines—to evaluate the feasibility of obtaining additional race and
ethnicity data from other state and federal entities, SSA may not
adequately track its progress or be held accountable for meeting goals in
its Equity Action Plan. Ultimately, without comprehensive data on the race
and ethnicity of applicants, SSA lacks the capacity to assess and ensure
racial equity in the public’s access to and receipt of SSA benefits and
services.
SSA’s Service Delivery During the pandemic, SSA’s processing of its workloads declined in some
Productivity during the areas in comparison to the 2 years prior to the pandemic—including initial
claims processing—while in other areas, such as the processing of
Pandemic Declined for
appeals, SSA’s productivity was mixed.
Initial Claims Processing
and Was Mixed for Initial disability claims processing. Between March 2020 and
Processing Appeals December 2021, the number of initial disability claims that SSA decided
declined. The number of pending claims—those awaiting decisions—
rose. Overall, the average number of disability cases being completed
monthly at the DDS level declined 17 percent compared to the previous 2
years (see fig. 7).
46GAO, SSA Disability Decision Making: Additional Steps Needed to Ensure Accuracy and
Fairness of Hearing Decisions, GAO-04-14 (Washington, D.C.: Nov. 12, 2003).
47GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington, D.C.: September 2014), Principle 6.
Page 26 GAO-23-104650 Social Security Administration
Figure 7: Initial Social Security Administration (SSA) Disability Claims Processing (March 2018–December 2021)
Note: “Pre-pandemic average” refers to the monthly average for the 2 years prior to the pandemic,
March 2018–February 2020.
There was a temporary decline in the number of completed initial claims
at the DDS level in the early months of the pandemic, before they
rebounded to align more closely with the number of claims received.
However, in early 2021, the number of completed claims began to decline
again, falling below the number of claims received. This contributed to an
increase in the number of pending initial disability claims at the end of
2021. In addition, the average processing time for initial disability
decisions at the DDS level increased from 132 days in March 2020 to 171
in December 2021.
Appeals processing. SSA’s processing of appeals during the pandemic
was mixed. For example, the number of disability reconsiderations
pending at the DDS level grew during the pandemic from 174,000 in
March 2020 to 195,000 in December 2021, which indicates that SSA was
unable to keep pace with the number of requests received. In contrast,
the number of pending hearings decreased during the pandemic. 48
48Pending hearings decreased, in part, because of the decline in hearing requests.
According to SSA, pending disability hearings and wait times also fell due to strategic
efforts to reduce the agency’s hearings backlog that began in 2016.
Page 27 GAO-23-104650 Social Security Administration
Although the average number of total hearings completed each month
during the pandemic was lower than during the 2 years beforehand, it
generally kept pace with the number of hearings requested (see fig. 8). 49
Figure 8: Number of Social Security Administration (SSA) Disability Appeals Hearings Requested and Held (March 2018 –
December 2021)
Note: “Pre-pandemic average” refers to the monthly average for the 2 years prior to the pandemic,
March 2018–February 2020.
Social Security card service delivery. SSA faced backlogs in
processing Social Security cards during the pandemic. SSA’s OIG
reported that SSA saw a decrease of about 4 million applications for
Social Security cards in 2020 compared to 2019. Despite the decrease in
the number of applications, the OIG’s interim findings in July 2021
suggested there were some backlogs of unprocessed paper applications
for new or replacement Social Security cards. The OIG found that in fiscal
year 2021, SSA processed approximately 12 million applications for
original and replacement SSN cards, which is approximately 1 million
49This remained true even when the number of hearings completed declined in the second
half of 2021.These data represent hearings on all types of benefit claims, including OASI
and other non-disability benefits.
Page 28 GAO-23-104650 Social Security Administration
fewer than it processed in FY 2020 and 5 million fewer than in FY 2019. 50
After field offices reopened to walk-in visits from the general public, an
SSA official reported in May 2022 that the agency was focused on
addressing pent-up demand for Social Security card requests.
SSA Took Steps to
Mitigate a Range of
Service Delivery
Challenges during the
Pandemic, but Gaps
Remain
SSA Used Technology and Telephone challenges. According to SSA officials, the agency faced
Adapted Procedures to several challenges as its staff quickly transitioned to telework and the
agency enhanced its ability to provide services to the public by telephone.
Contend with Challenges
These challenges included:
Providing Most Services
Remotely • Availability of equipment and technology. SSA offices that had
experience with telework prior to the pandemic had more robust
telephone equipment and resources in place that made the transition
to full telework easier, according to SSA staff we spoke with.
However, field office staff we spoke with who had not teleworked prior
to COVID-19 generally lacked this technology, and in some cases
reported initially using personal cellphones for appointments with
customers.
• Reliability of telephone systems. The agency encountered
functionality and reliability problems as the influx of calls and
technology changes strained the agency’s telephone systems.
Telephone mitigation efforts. The agency took several steps to address
these challenges, and agency officials said further actions are planned.
These steps include:
50SSA OIG, “Interim Report: The Social Security Administration’s Processing of Mail and
Enumeration Services During the COVID-19 Pandemic,” A-08-21-51036 & A-15-21-51015
(July 29, 2021).
Page 29 GAO-23-104650 Social Security Administration
• Deployment of telephone hardware and software. Agency officials
reported that the agency provided softphones 51 to any staff doing
business with the public, implemented hardware and software
changes, and provided headsets to staff working from home. In an
April 2021 report, SSA’s OIG reported that the agency had equipped
employees with necessary technology to answer the increasing
number of calls while teleworking. 52 For example, at the hearings
level, officials told us that new software allowed the remote recording
of telephone hearings.
• Transition to unified telephone system. As of June 2022, SSA
transitioned to an interim unified platform for its 800 number. 53
Officials said the new system enables SSA to route calls to any
available teleservice center employee in any location. As of July 2022,
SSA reported that as part of this system, the agency plans to enhance
the voice recognition capabilities of the national 800 number. This is
intended to improve the caller experience and increase the number of
calls handled by automated services.
Computer challenges. The agency had a range of computer technology
in place prior to the pandemic as part of its resiliency and continuity of
operations planning, such as virtual private networks and single-device
laptops, but SSA officials told us the agency had to scale these
technologies quickly when it moved to remote service delivery. The
agency faced resulting challenges, including:
• Availability of equipment and technology. According to SSA
officials we interviewed, certain SSA offices were not equipped with
the computer technology necessary for telework, such as agency-
issued laptops. For example, some field office staff reported to us
facing challenges using older laptops early in the pandemic, such as
needing to restart them multiple times a day. In addition, some offices
lacked internet supporting technology, such as wireless routers, signal
boosters, and network cables.
51A softphone is a computer application that allows employees to access their office
phones and voicemail on their desktops or laptops anywhere they have internet
connectivity.
52SSA OIG. Congressional Response Report: The Social Security Administration’s
Telephone Services during June 2020. (A-05-20-50998) April 2021.
53This unified system is a precursor to the Next Generation Telephony Project, which SSA
started developing before the COVID-19 pandemic. It is designed to combine the national
800 number, field office, and SSA headquarters telephone systems.
Page 30 GAO-23-104650 Social Security Administration
• Internet speed and bandwidth. Agency staff we interviewed,
particularly in rural areas, described challenges with slow internet
speeds and low bandwidth. They reported dealing with system
freezes and told us that internet-based systems were particularly
error-prone. These challenges slowed SSA’s delivery of services to
customers, according to multiple groups of SSA staff we interviewed.
Computer mitigation efforts. According to SSA officials, the agency was
able to address most challenges associated with scaling its computer
technology by taking certain steps, including:
• Deployment of computer technology. As of March 2021, the
agency had procured and deployed expanded equipment, bandwidth,
and software licenses to support its expanded remote service
delivery. Field office managers reported receiving newer laptops that
generally addressed problems with older models that they had been
using for telework. Hearings officials also said that in cases where
staff had internet or bandwidth issues, SSA had provided internet hot
spots.
Mail and paper claims challenges. At the beginning of the pandemic,
SSA did not have the infrastructure or operating procedures in place to
handle the influx of mail received during COVID-19, and faced associated
challenges. These challenges included:
• Document management and processing. According to SSA, during
the pandemic, SSA offices had to scan and upload approximately one
million paper documents weekly, a substantial increase from the
150,000 documents a week the agency handled prior to COVID-19. 54
According to front-line staff, SSA provided no guidance on handling
the influx of mail at the beginning of the pandemic, while continuing to
require offices to reach pre-pandemic document timeliness goals.
Between national mail delays and the delays caused by the process
of scanning documents that were sent to the office and then
transmitting them electronically to staff working remotely, stakeholders
told us that it often took weeks for SSA staff to receive and process
paperwork, including faxes. Several field office managers told us that
54Whereas a customer used to walk into a field office and hand SSA staff a paper
document to scan or copy, during the pandemic, document processing became a multi-
step process that took more time, according to SSA field office managers we interviewed.
In addition, the field office managers reported that these workloads shifted primarily to
them, since most support staff were teleworking.
Page 31 GAO-23-104650 Social Security Administration
mail got lost and customers sometimes did not receive original
paperwork back.
• Staffing and workforce planning. Due to COVID-19 public and
worker safety measures and office closures, field office managers
generally were the only staff permitted in SSA offices for most of the
pandemic and took responsibility for mail processing duties. Several
field office managers we spoke with characterized the handling of mail
as an overwhelming task, as they were required to go to the office
every day to process mail in addition to their other duties. One
manager estimated spending about 75 percent of her time on mail
and clerical work, while another manager told us that she was
responsible for opening, scanning, and returning more than 200
pieces of mail her office received each day during the pandemic.
Mail and paper claims mitigation efforts. SSA implemented a number
of efforts intended to address its challenges with processing mail and
paper claims. These efforts included:
• Mail processing plan. To improve management of its mail traffic, in
September 2021 SSA published and began implementing a new
plan—in the form of a business process document—outlining
procedures for handling mail. Among other goals, the new business
process focuses on processing original documents within 3 business
days and all other mail within 5 business days. 55
• Alternative document delivery methods. To provide the public with
alternative ways to submit documentation and original evidence to
their local field offices, SSA expanded the availability of drop boxes at
field offices in late 2020. In addition, the ability to submit documents
through in-office appointments during the pandemic helped SSA
address its challenges with mail.
• Agency-wide mail and printing initiatives. In response to findings
by SSA’s OIG, SSA implemented two initiatives aimed at providing
short-term solutions to its mail challenges. Specifically, the agency
launched a centralized mail project designed to streamline handling
procedures and find a more permanent solution. The agency also
deployed a centralized printing and distribution initiative intended to
limit the need for field office staff to process SSA notices to customers
55According to SSA, the agency is considering pursuing a modern and more permanent
mail processing solution, the goal of which is to provide a robust mail management
platform and infrastructure that permits central processing, digitization, and management
of mail across agency components.
Page 32 GAO-23-104650 Social Security Administration
in their local offices. These efforts are intended to reduce the need for
managers to handle outgoing mail.
• Electronic appeals documentation initiative. In September 2020,
SSA field offices adopted a process to convert some paper workloads
to an electronic format. Specifically, they began scanning and
uploading documentation and related files for certain types of appeals
using an electronic repository. This repository can currently be used
for non-disability (i.e., non-medical) appeals, including those for
benefit overpayments, fraud, and general eligibility issues. Prior to the
pandemic this workload was entirely paper-based. After the agency
resumed processing pending paper cases in December 2020, staff
continued to use this electronic repository to process these non-
disability appeals remotely.
SSA Took Steps to Challenges for vulnerable populations. SSA has offered an
Address Challenges unprecedented level of remote access to telephone and online services
during the COVID-19 pandemic. However, the agency faces challenges
Serving Vulnerable
reaching and providing services to certain groups who may face
Populations and Expand disproportionate barriers, including lack of consistent access to
Online Applications, but technology. These vulnerable populations include older adults, those with
Gaps Remain in Online limited English proficiency, those experiencing homelessness, those in
Services for Certain rural areas, individuals with low incomes, individuals with disabilities, and
those without legal representation in the disability appeals process. 56 The
Populations transition to remote services disproportionately affected vulnerable
groups, according to those we interviewed, because of their previous
reliance on in-person services. 57
Challenges serving vulnerable populations affected service delivery
across the agency, including:
56According to SSA staff and experts we interviewed, claimants represented by law firms
were not affected as much by technology. In contrast, those who were unrepresented and
who lacked or did not know how to use equipment were underserved. In addition, we
attempted to include race and ethnicity in our analysis of vulnerable populations but
encountered challenges because the agency does not routinely collect these data (see
app. II for a discussion of our attempts to analyze race and ethnicity, as well as the related
challenges).
57During the pandemic, some of these populations showed greater declines in applying for
benefits compared to the general population. In particular, the overall decline in disability
and SSI claims demonstrated that fewer individuals with low incomes or disabilities were
applying for benefits during the pandemic compared to beforehand.
Page 33 GAO-23-104650 Social Security Administration
• Field offices. Disability advocates we spoke with emphasized that the
pandemic represented a fundamental shift in how many customers
conducted business with field offices. For example, individuals who
were used to bringing in a paper SSA notice to their local field office
for explanation or translation no longer had that option. In addition,
while the expansion of telephone services generally was received as
a positive development, many individuals who previously had
conducted business with SSA in person had difficulty completing
certain SSA applications and conducting other critical business by
phone, according to advocates and SSA staff we spoke with. They
added that it generally was unrealistic to expect these individuals to
navigate the complicated SSA phone system.
• Disability determination services. DDSs significantly decreased the
use of in-person consultative examinations in response to the
pandemic, though SSA told us that their capacity to conduct these
exams has improved. Consultative exams are often needed for those
who are uninsured, underinsured, or otherwise without regular
medical care. DDS staff we spoke with reported ongoing challenges
related to scheduling consultative exams, partly because many
medical providers did not offer services in the pandemic environment.
As of December 2021, the percentage of healthcare providers who
were available to schedule exams rose to about 85 percent, from 70
percent as reported in March 2021. Nonetheless, DDS supervisors we
interviewed in February 2022 said it was taking their office between
90 and 110 days to schedule a consultative exam, versus 45-60 days
prior to the pandemic.
• Hearing offices. At the hearings level, administrative law judges
reported challenges accommodating customers who were less
technologically literate or who did not have a computer or smartphone
for an online video hearing. These challenges were particularly acute
for claimants without representatives, who often help their clients
overcome technological barriers. One administrative law judge
reported challenges serving Spanish-speaking customers, who often
were unable to go into an office to have notices and documents
translated.
Mitigation efforts for vulnerable populations. SSA officials said that
certain vulnerable populations faced challenges accessing services, and
noted several SSA actions directed at improving access. 58 In addition to
targeted actions intended to improve service to vulnerable populations,
58For example, SSA recognizes that not everyone is willing or able to use the internet or
phone for service and not everyone is willing to have a telephone or video hearing.
Page 34 GAO-23-104650 Social Security Administration
SSA also took general steps during the pandemic that officials said
benefitted these groups. As mentioned above, SSA implemented dire-
need appointments, and later offered express interviews at field offices.
Additional steps SSA took that could improve services to vulnerable
populations included:
Targeted outreach. In fiscal year 2021, SSA initiated a special mailer
project to encourage potentially eligible individuals to apply for SSI. 59
As of mid-February 2022, SSA had mailed approximately 665,000
notices, and expected to release an additional 735,000 mailers to
potential applicants throughout calendar year 2022. To promote SSI
for both children and general audiences, SSA launched a social
media campaign in English and Spanish. As of October 2022, ads
promoting SSI generated over 3.5 million visits to SSA’s website. In
addition, during the pandemic, SSA’s hearing offices conducted
enhanced outreach specifically to unrepresented claimants before
their hearings. 60 During this outreach, staff reminded claimants of their
right to representations, discussed the option to appear at a hearing
by telephone or online video, and asked whether the claimant agreed
to appear by telephone or online video.
• New policies. SSA also adopted new policies at different adjudicative
levels that officials said could benefit vulnerable populations, including
those for some physical impairments. For example, SSA issued an
emergency message in December 2021 that expanded the use of
telehealth appointments to include speech and language consultative
exams. Consultative exams are a vital service for benefit claimants
requiring additional medical evidence for disability determination. SSA
officials told us that the agency continues to explore ways to expand
telehealth consultative, including those for some physical
impairments, and SSA convened a workgroup including agency policy
staff and health care professionals that made recommendations
currently under consideration. At the hearings level, the agency
59The agency identified OASDI beneficiaries age 18 and older whose monthly benefits are
less than the maximum SSI benefit to encourage these beneficiaries to apply for SSI.
60Under this initiative, SSA also allowed the sharing of claims files electronically as a new
feature specific to its enhanced outreach efforts.
Page 35 GAO-23-104650 Social Security Administration
allowed for greater flexibility when claimants missed the deadline to
request a hearing or failed to appear for a scheduled hearing. 61
• Third Party Assistance. In response to declines in disability and SSI
applications and concerns that certain populations faced challenges
reaching SSA, the agency developed an agency-wide People Facing
Barriers (PFB) initiative, according to officials. The PFB initiative is a
series of targeted strategies to simplify and expand access to SSA
programs for underserved individuals. A sub-initiative under the PFB
banner is the Third Party Assistance (TPA) initiative, the goal of which
is to assist certain vulnerable populations with applying for SSI. 62
Under the TPA initiative, SSA partnered with third-party organizations
that work closely with vulnerable populations. SSA trained
representatives from these organizations to assist their clients with
SSI applications. 63 In 2021, SSA created two field office roles:
Vulnerable Population Liaison (VPL) and Vulnerable Population
Expert (VPE). These roles were designed to take and submit
applications for SSI, refer potential applicants to third-party partners,
and conduct quality control reviews on claims submitted by those
partners.
Agency officials said that by February 2022, SSA had recruited 650
field office employees to serve as VPLs and designated 100 field
office employees to serve as VPEs. By October 2022 the agency had
established partnerships with approximately 5,000 organizations that
agreed to submit disability claim applications, provide leads, or refer
people who may be eligible for disability benefits. The agency
reported that these outreach efforts helped SSA obtain 3,131 claims
between March 2021 and May 2022. SSA also provided training on
taking SSI claims to more than 1,754 organizations and over 8,140
individuals. Advocates we spoke with said that many of them have
had good experiences with the VPL/VPE effort.
Even with these reported accomplishments, some SSA staff and
disability advocates told us that the agency’s TPA efforts have in
61SSA staff, stakeholders, and advocates reported that these outcomes were more
common for individuals who were unrepresented or who lacked access to technology.
62Populations targeted by SSA under this initiative include the aged, children with
disabilities, individuals with limited English proficiency, individuals experiencing
homelessness, individuals diagnosed with mental illness, individuals recently released
from incarceration, and veterans applying for SSI benefits.
63The agency is tracking progress by asking technicians to code “Vulnerable Populations
Application” on these claims, according to SSA.
Page 36 GAO-23-104650 Social Security Administration
some cases had limited success due to attrition and capacity
constraints. Specifically, the TPA program lacked dedicated funding
for the VPL and VPE roles. Consequently, existing SSA employees
took on these roles in addition to their usual responsibilities. SSA staff
reported that with the added responsibilities, staff in some of these
positions left the agency, and there was little effort to refill vacancies.
In addition, advocates pointed to their own capacity challenges.
Specifically, the TPA program relied on third-party organizations to
perform tasks that normally were conducted by SSA staff, and the
program did not provide funding to those third parties. Many of these
organizations did not have the capacity to take on greater workloads.
Advocates and staff cited other challenges with the program. For
example, advocates we spoke with noted that SSA had not published
a list of VPLs, making it difficult for advocates to reach them. One field
office manager we interviewed noted that many third-party
organizations also were closed during the pandemic. Moreover, some
SSA field office staff we spoke with said that attrition among
VPLs/VPEs was a challenge to maintaining connections with third-
party organizations.
Agency officials said that in 2022, the agency is planning to evaluate
the TPA program, which could present an opportunity to address
some of these challenges. As part of this evaluation, SSA plans to
survey partner organizations to identify challenges they have
encountered serving SSA customers. As the agency resumes in-
person services and continues to refine its strategy for outreach to
vulnerable populations, this evaluation represents an opportunity for
SSA to assess the program and identify ways to improve its
effectiveness.
Challenges with Online SSI SSI Applications
and Spanish-language Benefit
Applications It is not yet possible for most claimants to apply for SSI benefits online.
Currently, only SSI applicants who also are filing concurrently for DI are
able to file for SSI online. 64 The agency has indicated that it has plans to
expand the availability of the online SSI application, and has included
certain components of this expansion in its multi-year effort to modernize
64According to SSA, in fiscal year 2021, the agency received approximately 130,000 SSI
applications online out of about 1.4 million total SSI disability/blindness applications. The
total number of all SSI applications received, including aged claims, was approximately
1.6 million applications.
Page 37 GAO-23-104650 Social Security Administration
the agency’s legacy SSI information technology system and simplify the
SSI application. However, SSA lacks a documented, comprehensive
plan—with clear steps, goals, metrics, and timelines—for the expansion
of these online application capabilities for claimants. Instead, the agency
has implemented incremental actions to put the application online. For
example, in summer 2021 SSA granted certain third-party organizations
access to new electronic, fillable applications for SSI disability and SSI
Old-Age benefits. In March 2022, SSA implemented an online tool that
enables individuals and third-parties to request an appointment and
establish a protective filing date for SSI.
Advocates we spoke with have encouraged SSA to provide claimants
with the ability to apply for SSI benefits online. In addition, in SSA’s 2022
SSI Statement, the Social Security Advisory Board urged SSA to
introduce a separate online application for certain adults applying for SSI,
which the Board said would greatly simplify the lengthy process.
SSA mentions expanding online services in several recent planning
efforts, including its ongoing effort to simplify the SSI application.
According to SSA’s recent Equity Action Plan, the agency seeks to
improve its service delivery by providing alternatives to in-person visits
and increasing the number of online forms (e.g., SSI). The Fiscal Years
2018 – 2022 Agency Strategic Plan states that SSA aims to achieve its
core objective of improving service delivery by increasing the use of
online services. However, SSA has not developed a comprehensive plan
for implementing online SSI applications. Federal internal control
standards state the importance of defining an effort’s objectives—such as
through clear steps, goals, performance measures, and timelines—to
support successful outcomes. 65 Without developing and documenting
comprehensive plans for expanding online SSI applications, SSA cannot
adequately plan for and track its progress toward its goal of providing
alternatives to in-person visits and increasing the number of online forms.
Furthermore, without the ability to apply online, some individuals may not
apply for SSI benefits for which they are eligible.
Spanish-Language Applications
SSA provides a range of Spanish-language resources for customers, but
it is currently not possible to apply in Spanish for those SSA programs
with existing online applications. The agency previously offered a Spanish
65GAO-14-704G, principle 6.
Page 38 GAO-23-104650 Social Security Administration
language option with its online claims application system from November
2011 through March 2017, but the agency decommissioned the service
due to low usage. Currently, SSA has a Spanish-language SSA.gov
website, which has printable Spanish versions of OASDI application
forms. However, the agency’s Spanish-language website directs
customers to a page where it informs them, in Spanish, that certain online
services and information are only available in English. SSA officials
explained that online SSA applications are not available in Spanish
because, in order for the information to enter SSA’s system, the
applications currently must be completed in English. If completed in a
different language, SSA told us that the information in the online
application needs to be translated by an authorized employee in order to
input the information into SSA’s system in English. 66 SSA officials also
told us that the availability of translators to perform this work was a barrier
to expanding Spanish-language resources for claimants. 67 However,
given the widespread availability of translation software, this may be less
of a challenge moving forward, and SSA has not explored the feasibility of
using these tools to replace or supplement the services of authorized
employees. In addition, while the agency previously offered and
discontinued certain online Spanish applications, the greater declines in
claims from Spanish speakers and the dramatic expansion of online
services during the pandemic present an opportunity for the agency to
evaluate the feasibility of again offering this option. Certain other major
federally funded benefit programs currently offer the public the option to
apply in Spanish.
The agency’s stated mission is to ensure equity and accessibility in
delivering services by improving the customer experience and addressing
systemic barriers to participation in its programs. Furthermore, the
agency’s stated mission in its fiscal years 2022-2023 Language Access
Plan is to ensure access to quality SSA services and program benefits
regardless of an individual’s ability to communicate in English. Benefit
applications from Spanish-speaking populations declined more than those
66According to SSA, the exception is Puerto Rico, where SSA field offices are able to
accept and process forms in Spanish. However, the information in the forms is still entered
into SSA’s system in English. According to the agency’s Language Access Plan, SSA also
provides an interpreter free of charge to any person who requests language assistance or
whom the agency believes could benefit from an interpreter. To ensure quality
interpretation, SSA encourages customers to use the agency’s free interpreter services.
67According to SSA, if a claimant currently submits an application in a language other than
English, the agency will seek translation assistance and still proceed to process that claim.
Page 39 GAO-23-104650 Social Security Administration
from English speakers during the pandemic. According to an SSA
analysis, the Spanish-speaking population tended to be a relatively small
but growing fraction of the OASDI beneficiary population. 68 However, the
representation of Spanish speakers in the SSI program approximated that
of their representation in the overall population. Furthermore, the Census
Bureau estimated that by 2050, Spanish speakers will account for an
estimated one in every four persons in the United States. According to
SSA, as this relatively young population ages, more Spanish speakers
will become eligible for the retirement, disability, and survivor benefits
available under OASDI. Without evaluating the feasibility of enabling
claimants to apply online in Spanish for those SSA benefit programs with
existing online applications, SSA may miss an opportunity to expand
access to Spanish-speaking populations and save resources.
SSA Lacks a Coordinated
Plan for Leveraging
Lessons Learned from the
Pandemic and Managing
Increasing Workloads
Lessons Learned As of June 2022, SSA had not implemented a coordinated, systematic
process to evaluate lessons learned from the agency’s response to
COVID-19 and incorporated those lessons into future contingency
planning. According to SSA officials we interviewed, rather than conduct a
comprehensive review of lessons learned, specific SSA offices have
taken informal steps to assess certain pandemic-related service delivery
changes, or are planning to do so. For example, officials from SSA’s
policy office said that operations staff examined lessons learned from mail
processing during the pandemic that bolstered the case for continuing
certain protocols that originally were intended to be temporary. SSA also
partnered with an independent contractor to review the internal controls
affected by COVID-19 emergency measures. The results of this review
also will be used to conduct a risk assessment and plan for the future. In
addition, as the agency was reopening offices to the public, SSA officials
told us that they would evaluate, on an ongoing basis, the agency’s
service delivery changes to determine whether to extend them
temporarily, revert to pre-pandemic policies, or pursue permanent
changes. Other SSA offices, such as its operations office, reported that
68Patricia P. Martin, Office of Retirement Policy, Office of Policy, Social Security
Administration, Hispanics, Social Security, and Supplemental Security Income. Social
Security Bulletin, vol. 67, No. 2. (2007).
Page 40 GAO-23-104650 Social Security Administration
they had not evaluated the policy changes that were implemented during
COVID-19 because the changes were intended to be temporary.
As we have reported in the past, it is important for agencies to identify
lessons learned and take corrective actions in a formal, centralized way. 69
Key practices in a comprehensive lessons-learned process include
developing clear plans for timing and execution, documenting and
disseminating this information to stakeholders, and implementing
corrective actions. 70 Federal internal control standards also state that
documentation is a necessary part of an effective internal control system,
and that management should evaluate and document the results of
ongoing monitoring and evaluations. 71
While the efforts SSA has undertaken to evaluate parts of its service
delivery changes during the COVID-19 pandemic likely will yield important
insights, its fragmented approach to evaluating policy changes could
result in missed opportunities to share and address lessons learned
across the agency. Further, SSA’s approach might prevent the agency
from effectively incorporating lessons learned into existing continuity of
operations plans or developing an agency-wide “playbook” for handling
future crises. Without implementing a formal process to identify,
disseminate, and incorporate lessons learned into future planning, SSA
may miss an opportunity to maximize the value of its lessons learned
from its experiences during the COVID-19 pandemic and improve its
ability to respond to other crises in the future.
Future Planning As of July 2022, SSA did not have a documented plan for managing a
possible future increase in its workloads across the agency and its
various service delivery methods. Disability advocates we spoke with
anticipate an increase in disability benefit applications after the pandemic
because individuals may have been unable or reluctant to apply by phone
69See GAO, Household Hazardous Waste Removal: EPA Should Develop a Formal
Lessons Learned Process for Its Disaster Response, GAO-22-104276 (Washington, D.C.:
March 2022).
70See GAO, Federal Real Property Security: Interagency Security Committee Should
Implement A Lessons-Learned Process, GAO-12-901 (Washington, D.C.: September
2012) and GAO, Project Management: DOE and NNSA Should Improve Their Lessons-
Learned Process for Capital Asset Projects, GAO-19-25 (Washington, D.C.: December
2018), which identified key lessons-learned practices for program and project
management based on our prior reports.
71GAO-14-704G, principle 16.
Page 41 GAO-23-104650 Social Security Administration
or online. Recent research also has suggested that there may be pent-up
demand for DI benefits as normal operations resume. 72 In addition, some
disability experts have noted that it is possible that many individuals
experiencing continued COVID-19 infection symptoms—or “long
COVID”—will meet SSA’s disability standards, and that SSA should
expect additional cases due to the lasting effect of COVID-19. A survey
conducted from June to July 2022 by the Census Bureau found that 16.3
million people (around 8 percent of working-age Americans) currently
have long COVID. 73 There also have been reported instances of long
COVID patients struggling to secure approval for DI benefits. 74
Some SSA officials recognized this potential growth in demand for their
services. For example, to prepare for reentry, the agency’s operations
office prepared a memorandum outlining certain flexibilities for overtaxed
field offices. The agency’s annual budget request, meanwhile, states that
it anticipates an increase in demand for services as the pandemic
improves and forecasts rising demand in future years. 75 Administrative
law judges told us they expect an eventual increase in hearings for
individuals who did not or were not able to apply during the pandemic. In
addition, according to the 2021 Social Security Trustees Report, there
likely will be a temporary increase in disability applications following the
reduced levels experienced during the pandemic.
Both SSA and GAO have reported on SSA’s ongoing challenges
managing workloads. In May 2022, SSA’s deputy commissioner for
operations testified that employee attrition was compounding growing
backlogs in disability workloads, and that the agency needed to address
72Maestas, Nicole and Mullen, Kathleen J., "Economic Conditions, the COVID-19
Pandemic Recession, and Implications for Disability Insurance in the United States"
(2022). Wharton Pension Research Council Working Papers. 733.
https://repository.upenn.edu/prc_papers/733.
73Brookings, “New data shows long Covid is keeping as many as 4 million people out of
work,” August 24, 2022.
https://www.brookings.edu/research/new-data-shows-long-covid-is-keeping-as-many-as-4
-million-people-out-of-work/
74https://www.washingtonpost.com/business/2022/03/08/long-covid-disability-benefits/
75SSA disability claims may subsequently rise if claims follow the pattern of the 2007-2009
Great Recession, when new disability claims reached peak levels well after the technical
end of the recession. Disability applications peaked in October 2010 and plateaued at high
levels through 2012.
Page 42 GAO-23-104650 Social Security Administration
pent-up demand for Social Security card requests. 76 At that time, the
agency was at its lowest staffing level in 25 years, and employees
overwhelmingly reported that their workloads were unreasonable. Since
2003, we have included SSA’s challenges managing disability-related
workloads in our High-Risk List. 77
Our prior work cites key long-term planning practices that could be
employed by SSA to address some of these issues. These practices
include preparing for different scenarios to stay flexible and adaptive, and
to consider plausible future alternatives and use them to generate
strategic options. 78
Without a documented plan for managing the anticipated surge in
demand across its various modes of service delivery, SSA is poorly
positioned to make well-informed decisions about its critical functions.
These functions include how many and what types of employees will be
needed for its future workforce, how the agency will address disability
claims backlogs while ensuring program integrity, and how the agency will
more strategically use its information technology and physical
infrastructure to best deliver services. As a result, SSA’s challenges
managing its disability-related workloads may be exacerbated.
SSA’s sudden cessation of nearly all in-person services in response to
Conclusions the COVID-19 pandemic represented a significant shift in its traditional
service delivery model and affected millions of SSA claimants. Closing
field offices, limiting in-person services to all but a few exceptions, and
expanding telephone and online services presented challenges for many
claimants, particularly certain vulnerable populations who were
accustomed to walking into SSA offices for in-person assistance. SSA is
aware that certain groups have been affected disproportionately by the
agency’s pandemic-related service delivery changes. Taking steps to
obtain additional data on race and ethnicity will better position the agency
to ensure equitable access to benefits. In addition, although the agency
has launched several new initiatives aimed at reaching certain vulnerable
76Strengthening Social Security’s Customer Service, Hearing Before the Soc. Sec.
Subcomm. of the H. Ways & Means Comm.,117th Cong. (2022) (statement of Grace Kim,
Deputy Comm’r. for Operations, Soc. Sec. Admin.).
77GAO, High-Risk Series: Substantial Efforts Needed to Achieve Greater Progress on
High-Risk Areas, GAO-19-157SP (Washington, D.C.: Mar. 6, 2019) and GAO, Social
Security Administration: Long-Term Strategy Needed to Address Key Management
Challenges, GAO-13-459 (Washington, D.C.: May 2013).
78GAO-13-459.
Page 43 GAO-23-104650 Social Security Administration
populations, it is not possible for most individuals to apply for SSI online.
Furthermore, for programs with existing online applications, individuals
currently cannot complete and submit those applications in Spanish.
Without these additional online services, many individuals who would be
capable of using SSA’s online services may not be able to do so, and the
agency may devote scarce staff resources to assist individuals who
otherwise might apply independently online. Finally, as the agency
considers the future of its in-person and remote service delivery model in
the context of its experience during COVID-19, it has not implemented a
process for assessing lessons learned from the pandemic, nor has it
developed a plan to manage a possible surge in COVID-related disability
claims. As a result, SSA may continue to face challenges delivering
services to those populations most in need of them.
We are making the following five recommendations to SSA:
Recommendations for
Executive Action The Commissioner of SSA should develop a plan—with clear steps,
goals, metrics, and timelines—to evaluate the feasibility of obtaining
additional race and ethnicity data from other state and federal entities in
support of its Equity Action Plan goals. (Recommendation 1)
The Commissioner of SSA should develop a plan—with clear steps,
goals, metrics, and timelines—for enabling claimants to apply for
Supplemental Security Income (SSI) benefits online. (Recommendation
2)
The Commissioner of SSA should evaluate the feasibility of making online
Spanish applications available again for those SSA benefit programs with
existing online applications. (Recommendation 3)
The Commissioner of SSA should implement a coordinated process for
assessing lessons learned from the COVID-19 pandemic that includes
documentation and dissemination, implementation of corrective action,
and incorporation into future contingency planning. (Recommendation 4)
The Commissioner of SSA should develop an agency-wide plan for
managing anticipated increases in SSA’s disability workloads.
(Recommendation 5)
We provided a draft of this report to the Social Security Administration for
Agency Comments review and comment, and the agency’s written comments are reproduced
as appendix III in this report. SSA agreed with our recommendations. The
Page 44 GAO-23-104650 Social Security Administration
agency also provided technical comments, which we incorporated into the
report as appropriate.
We are sending copies of this report to the appropriate congressional
committees, the Acting Commissioner of the Social Security
Administration, and other interested parties. In addition, the report is
available at no charge on the GAO website at http://www.gao.gov.
If you or your staff have any questions about this report, please contact
me at (202) 512-7215 or curdae@gao.gov. Contact points for our Offices
of Congressional Relations and Public Affairs may be found on the last
page of this report. GAO staff who made key contributions to this report
are listed in appendix IV.
Elizabeth H. Curda
Director, Education, Workforce, and Income Security Issues
Page 45 GAO-23-104650 Social Security Administration
List of Addressees
The Honorable Patrick Leahy
Chairman
The Honorable Richard Shelby
Vice Chairman
Committee on Appropriations
United States Senate
The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate
The Honorable Patty Murray
Chair
The Honorable Richard Burr
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate
The Honorable Gary C. Peters
Chairman
The Honorable Rob Portman
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Rosa L. DeLauro
Chair
The Honorable Kay Granger
Ranking Member
Committee on Appropriations
House of Representatives
The Honorable Frank Pallone, Jr.
Chair
The Honorable Cathy McMorris Rodgers
Republican Leader
Committee on Energy and Commerce
House of Representatives
Page 46 GAO-23-104650 Social Security Administration
The Honorable Bennie G. Thompson
Chairman
The Honorable John Katko
Ranking Member
Committee on Homeland Security
House of Representatives
The Honorable Carolyn B. Maloney
Chairwoman
The Honorable James Comer
Ranking Member
Committee on Oversight and Reform
House of Representatives
The Honorable Richard E. Neal
Chair
The Honorable Kevin Brady
Republican Leader
Committee on Ways and Means
House of Representatives
The Honorable John B. Larson
Chairman
The Honorable David Schweikert
Republican Leader
Subcommittee on Social Security
Committee on Ways and Means
House of Representatives
The Honorable Danny K. Davis
Chairman
Subcommittee on Worker and Family Support
Committee on Ways and Means
House of Representatives
Page 47 GAO-23-104650 Social Security Administration
Appendix I: Objectives, Scope, and
Appendix I: Objectives, Scope, and
Methodology
Methodology
In this review we addressed: (1) how the Social Security Administration
(SSA) changed its delivery of key services during the COVID-19
pandemic; (2) what is known about the effect of these service delivery
changes on the public, including certain vulnerable populations; and (3)
how SSA addressed challenges with remote service delivery and
identified lessons learned during the pandemic.
This appendix provides information about the methods we used to answer
these questions. To inform all objectives, we reviewed relevant federal
laws, regulations, and policies; interviewed knowledgeable agency
officials and external stakeholders; and obtained documentation and
written responses from the agency. Sections 1, 2, and 3 describe
additional methods we used to address each research objective.
Section 1: Assessment of To address our first research objective, we focused on policy updates and
Service Delivery Changes changes from the onset of the pandemic until field offices reopened
(March 2020 to April 2022) that relate to two areas: (1) applications and
in Response to COVID-19
appeals for Old-Age, Survivors, and Disability Insurance (OASDI) and
Supplemental Security Income (SSI) benefits; and (2) enumeration. We
obtained and reviewed documentation that SSA developed during the
pandemic to communicate policy changes, such as new or revised
procedures. These included internal documents such as cross-agency
Emergency Messages, Disability Determination Services administrators’
letters, Chief Administrative Law Judge Bulletin messages, and Office of
Hearings Operations memos. We also reviewed public-facing
documentation on SSA.gov that articulated policy changes, including
Dear Colleague letters and the Program Policy Information Site that
contains the public version of the agency’s Program Operations Manual
System. In addition, we obtained written responses from SSA officials to
clarify the timing and details of policy changes when necessary.
Section 2: Analysis of the To address our second research objective, we obtained and analyzed
Effect on Public Access administrative and summary data to describe monthly trends in the
public’s access to SSA services and benefits and agency performance
and Agency Performance
that cover the 2 years before the pandemic and through the end of 2021
(March 2018-December 2021).
Administrative data: We obtained SSA administrative data on claims
and appeals from two systems. First, we analyzed management
information from the Modernized Claims System about OASDI claims and
appeals. Second, we analyzed data from the Supplemental Security
Record about SSI claims and appeals. Because of how these systems
are structured, it is possible for more than one record to be associated
Page 48 GAO-23-104650 Social Security Administration
Appendix I: Objectives, Scope, and
Methodology
with an individual’s claim and appeal path (e.g., if a person filed a claim
and at least one appeal for that claim during our timeframe). As a result,
our results show the number of claims and appeals filed, not the number
of individuals filing claims and appeals. For both of these systems, we
limited our analysis to initial benefit claims and appeals at the
reconsideration or hearing level that were filed between March 1, 2018
and December 31, 2021. We obtained variables associated with
biographic and demographic information (e.g., date of birth and zip code
of claimants) as well as claims and appeals (e.g., filing dates for claims
and appeals actions and type of benefits involved). In addition, for those
pursuing SSI benefits, we obtained variables about individual’s surname
and street address for use in an analytical technique to impute race and
ethnicity data (see app. II for more information).
To analyze these data based on population characteristics associated
with increased vulnerability, 1 we took the following steps.
• Age: We used date of birth to calculate an individual’s age as of their
earliest claim or appeal filing date during our timeframe. For most
individuals in our population, their age was calculated as of the date
they filed their initial claims. In the event that the initial claim was filed
prior to March 1, 2018, we used the filing date for the earliest appeal
filed during our timeframe.
• Geographic area type: To determine degree of urbanization, we used
zip codes and applied the Economic Research Service’s 2010 Rural-
Urban Commuting Area Codes (RUCA), which classify zip codes as
being associated with metropolitan, micropolitan, 2 small town, or rural
areas. In our analysis, codes associated with metropolitan areas were
deemed urban, while micropolitan, small town, and rural areas were
deemed rural.
1These populations were selected because they were identified as being more
significantly impacted by reductions in in-person service delivery. This could be due to
limited access to the internet or lower comfort levels using technology to access services
online or over the phone. In addition, some of these populations often relied more on in-
person services prior to the pandemic.
2Micropolitan is a geographic entity consisting of one or more counties with at least one
urban cluster with a population from 10,000-49,999. The designation was created by the
Office of Management and Budget for federal statistical agency use.
Page 49 GAO-23-104650 Social Security Administration
Appendix I: Objectives, Scope, and
Methodology
• Disability status: We used the act of filing a claim or appeal for any
type of SSA disability benefit—including disability insurance, SSI-
disability, or SSI-blindness as a proxy for disability status.
• Low-income status: We used the act of filing a claim or appeal for SSI
benefits as a proxy for low-income status.
• Limited English proficiency: We used variables indicating the
preferred written and spoken language for individuals filing claims or
appeals for benefits to determine English proficiency. Anyone whose
preferred written or spoken language had a value of non-English was
classified as having limited English proficiency. 3 We further separated
those with limited English proficiency into Spanish and all other
languages due to the relatively high prevalence of Spanish as a
preferred language.
• Race and ethnicity: See below and appendix II for more information
on race and ethnicity.
We obtained race and ethnicity data for these individuals from two SSA
administrative data systems. For those whose race and ethnicity
information was collected before 2009, the data came from the Numident,
which is a record of all Social Security Number holders and contains
historical race and ethnicity data collected prior to 2009. For those whose
race and ethnicity information was collected from 2009 on, the data came
from the Race and Ethnicity Collection System (RECS), which was
created to meet the Office of Management and Budget’s 1997 race and
ethnicity data collection standards. 4 In cases where race and ethnicity
data were available for the same person in both systems, we used the
data from RECS because it represents the most recent data available.
Due to how SSA collects race and ethnicity data, it is not available for all
individuals, which limited our ability to analyze it. See app. II for more
information.
Summary data: We also obtained summary data on a variety of topics
related to agency workloads and service delivery performance from
March 2018 through December 2021. Whenever possible, we used
publicly available data files downloaded from SSA’s Open Data website.
These publicly available files included monthly data associated with
3Knowledgeable SSA data experts explained that these variables are generally only filled
in if a person indicates a preference or need for a language other than English. Those
experts instructed us to consider a blank response as a preference for English.
4Office of Management and Budget, “Revisions to the Standards for Classification of
Federal Data on Race and Ethnicity,” Oct. 1997.
Page 50 GAO-23-104650 Social Security Administration
Appendix I: Objectives, Scope, and
Methodology
telephone service delivery at field offices and the national 800 phone line
and disability processing for initial claims and reconsiderations at the
state Disability Determination Services (DDS) offices. In addition, we
obtained other summary data directly from SSA, including data on
hearings (including hearing requests filed, hearings completed, and
pending hearings) and field office telephone service (including wait times
and number of calls handled). Finally, we used select data points
presented in SSA’s Annual Performance Report for fiscal years 2021-
2023.
Data reliability: For each of the administrative datasets described above,
we conducted a data reliability assessment of selected variables by
conducting electronic data tests for completeness and accuracy,
reviewing documentation on the dataset, and interviewing knowledgeable
officials about how the data were collected and maintained and their
appropriate uses. Specifically:
• We tested the completeness, consistency, and logic of the variables
we used to measure the number of claims and appeals filed for SSA’s
benefit programs, and other characteristics of claimants. Our analysis
of benefit claims and appeals generally included all individuals who
filed an initial claim, reconsideration request, or hearing request for
OASDI or SSI benefits between March 1, 2018 and December 31,
2021. We excluded a small number of claims or appeals in these files
that had missing values for key variables, but that amounted to less
than one-tenth of one percent of our records. We also excluded seven
records that had inconsistent values or were of questionable reliability,
such as when the data indicated that a claim was filed prior to a
child’s birth.
• We also assessed the completeness and consistency of SSA’s
administrative race and ethnicity data and identified some significant
limitations. As a result, we determined the data were not sufficiently
reliable for our purposes. See app. II for more information.
Last, we assessed the reliability of summary data by reviewing available
documentation about each source, which generally included descriptions
of the dataset and data collection procedures. We also assessed the
reliability of SSA data on the daily number of field office visits from March
2020 through June 2021. However, we determined that the type of data
being captured shifted over time from number of in-person visits to
number of interviews conducted, making the data inconsistent. Therefore,
we determined the field office visit data were not sufficiently reliable for
the purposes of this report.
Page 51 GAO-23-104650 Social Security Administration
Appendix I: Objectives, Scope, and
Methodology
Based on the data reliability assessment, we determined that the data
were sufficiently reliable for our use, except where noted above.
Section 3: Evaluation of To address our third research objective, we reviewed documentation from
Agency Challenges and SSA and other stakeholders and interviewed a range of experts.
Specifically, we reviewed and analyzed SSA documentation and written
Lessons Learned
responses on challenges faced during the pandemic, steps taken to
address those challenges, and any efforts to identify lessons learned. We
interviewed SSA officials from a range of components, including the
Office of Hearing Operations, Office of Customer Service, and Office of
Operations. We also interviewed employee organizations representing
different groups of SSA employees, including the National Association of
Disability Examiners and the Association of Administrative Law Judges.
We also interviewed representatives and stakeholders with organizations
that advocate on behalf of people eligible for SSA benefits and services,
including member organizations of the Consortium for Citizens with
Disabilities.
To obtain the perspective of front-line staff, we conducted semi-structured
group interviews with a non-generalizable sample of agency staff at
different levels: SSA field office claims specialists, field office managers,
call center managers, and administrative law judges (ALJ), as well as
state Disability Determination Service (DDS) supervisors. We used a
multi-step process to identify and select interviewees from each group of
employees.
• We obtained lists of SSA field offices, teleservice centers, state DDS
administrators, and ALJs, broken down by SSA’s 10 regions. 5 We
then categorized each field office and teleservice center by whether it
is classified as being in an urban or rural location. 6
• For field offices, we selected 1 office from each of the 10 regions, with
5 of those having been categorized as urban and 5 categorized as
rural. We obtained a list of employees at each office and randomly
selected 1 SSA field office claims specialist and 1 field office manager
from each selected office.
• We randomly selected 10 state DDS supervisors from the offices of
the selected DDS administrators, 1 from each of the 10 SSA regions.
We also randomly selected 10 ALJs, 1 from each SSA region.
5We ultimately interviewed 9 teleservice center supervisors.
6We used the RUCA codes to classify offices as being in urban or rural locations.
Page 52 GAO-23-104650 Social Security Administration
Appendix I: Objectives, Scope, and
Methodology
• We obtained lists of staff from each of our 9 selected teleservice
centers, and randomly selected 1 teleservice supervisor from each
location.
• Finally, we conducted pre-interview surveys of selected participants
via email to obtain information on their SSA career (e.g., duration and
different roles) and solicit input on the biggest challenges they faced
in delivering services during the pandemic. The most prevalent
challenges identified in a group’s pre-interview survey were used to
select questions for that group interview.
We conducted this performance audit from November 2020 to November
2022 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.
Page 53 GAO-23-104650 Social Security Administration
Appendix II: Challenges in Assessing the
Appendix II: Challenges in Assessing the
Effect of SSA Service Delivery Changes by
Effect of SSA Service Delivery Changes by
Race and Ethnicity
Race and Ethnicity
We considered three approaches to assess the effect of the Social
Security Administration’s (SSA) service delivery changes by claimants’
race and ethnicity, but we were ultimately unable to produce reliable
results due to challenges with each method. First, we obtained and
attempted to analyze SSA’s administrative race and ethnicity data, but
identified challenges with the data’s completeness and specificity.
Second, we evaluated the feasibility of matching SSA administrative data
to Census Bureau data but identified feasibility and potential
methodological limitations to such an analysis. Third, we pursued a
technique to estimate the race and ethnicity of benefit applicants within
our scope using the Bayesian Improved Surname Geocoding (BISG)
method, but identified some key limitations related to the claimant
populations that affected the accuracy of the estimates. Sections 1, 2,
and 3 of this appendix discuss the methods we considered, the data we
used, and challenges we identified.
Section 1: SSA’s As discussed in appendix I, we obtained race and ethnicity data from two
Administrative Race and SSA administrative data systems: the Numident (for data collected before
2009) and the Race and Ethnicity Collection System (RECS, for data
Ethnicity Data
collected from 2009-on). SSA provided us with the most recent race and
ethnicity data from these two systems that matched the Social Security
Numbers (SSN) for individuals in our population (those filing a claim or an
appeal for OASDI or SSI benefits between March 1, 2018 and December
31, 2021).
However, we encountered two key limitations with the completeness and
specificity of the agency’s race and ethnicity data. First, data were not
available for a significant portion of our population. In February 2022,
SSA reported having race and ethnicity for 59 percent of SSN holders, 1
which is consistent with the data we obtained (see table 3.)
1Social Security Administration, Office of Retirement and Disability Policy, “Why
Researchers Now Rely on Surveys for Race Data on OASDI and SSI Programs: A
Comparison of Four Major Surveys”, Research and Statistics Note No. 2016-01
(Baltimore, MD: January 2016).
Page 54 GAO-23-104650 Social Security Administration
Appendix II: Challenges in Assessing the
Effect of SSA Service Delivery Changes by
Race and Ethnicity
Table 3: Percentage of Study Population Covered by the Social Security
Administration’s Race and Ethnicity Data
Individuals filing claims and appeals for SSA benefits
(March 1, 2018-December 31, 2021)
Program All OASDI SSI
Percentage with race and 64 65 57
ethnicity data
Source: GAO analysis of SSA race and ethnicity data. | GAO-23-104650
SSA’s race and ethnicity data are also incomplete due to changes in data
collection over time. Since the 1930s, SSA has collected, on a voluntary
basis, information on the race and ethnicity of applicants for new or
replacement Social Security cards. This is done using the form SS-5,
which is the paper application for a new or replacement Social Security
card. Beginning in 1987, however, SSA began to introduce automated
processes to assign SSNs such as Enumeration at Birth and Enumeration
at Entry, which do not provide the agency with race or ethnicity data. Over
time, these automated processes became more prevalent. According to a
2016 SSA article, nearly all individuals (96 percent) receive their original
SSNs as part of Enumeration at Birth. And qualified immigrants receive
most of the remaining new SSNs upon entry into the U.S. under
Enumeration at Entry. This means only a small percentage of new SSN
card applications are submitted on the form SS-5. 2 SSA reported in
February 2022 that the agency’s lack of complete race and ethnicity data
hampers its ability to assess whether its programs are equitably serving
beneficiaries and applicants. 3
Second, we identified challenges with the specificity of the data. Over
time, SSA’s data collection efforts changed to include a larger number of
available race and ethnicity categories (see table 4). For example, not
until September 2009 were individuals able to (a) select more than one
race and (b) separately report race and ethnicity. As a result of these
shifts over time, we had to limit our analysis to the few available race
options that were available over the entire duration of data collection:
Black/African American, White, and Other. Therefore, anyone who
2Office of Retirement and Disability Policy, “Why Researchers Now Rely on Surveys for
Race Data on OASDI and SSI Programs: A Comparison of Four Major Surveys”,
Research and Statistics Note No. 2016-01 (January 2016).
3SSA, “Equity Action Plan in Agreement with EO 13985” (Baltimore, MD: Feb. 10, 2022).
Page 55 GAO-23-104650 Social Security Administration
Appendix II: Challenges in Assessing the
Effect of SSA Service Delivery Changes by
Race and Ethnicity
reported a race or ethnicity option other than Black/African American or
White was categorized as Other for the purposes of our analysis.
Table 4: Social Security Administration’s (SSA) Race and Ethnicity Categories over Time
Select
Ethnicity more
Black/ as than
African- Hispanic/ Pacific American Alaska Native separate one
American White Latino Asian Islander Indian Native Hawaiian Other question race
1936-1979 Y Y - - - - - - Y - -
1980-August Y Y Ya Y Y - Y - -
2009 Categories Categories
combined combined
September Y Y Y Y Y Y Y Y - Y Yb
2009 to
present
Source: GAO analysis of SSA documentation and “Identifying the Race or Ethnicity of SSI Recipients,” Social Security Bulletin, Vol. 62 No. 4, 199. | GAO-23-104650
Note: A dash (-) indicates that the category did not exist and was therefore not a selectable option.
a
From 1980-August 2009, Hispanic/Latino was presented as a category “Hispanic” for the question
asking about race.
b
Since September 2009, anyone who indicates more than one race is categorized in the data system
as Multi-racial.
Because of the way that SSA collected and stored these data as available
race and ethnicity categories changed, some of the race categories are
not mutually exclusive over time. For example, individuals of Hispanic or
Latino origin may have selected different race options over time. As
shown in table 4, individuals had the option of choosing Hispanic as a
race option beginning in 1980. The Numident system, which contains
race data collected before 2009, uses the following categories:
Black/African-American (Non-Hispanic), White (Non-Hispanic), Hispanic,
and so on. Therefore, SSA’s data assumes that anyone of Hispanic or
Latino origin who provided race information before 1980 would have
selected Other, which may not be the case. For example, the results of
the 2020 Census shows that individuals of Hispanic or Latino origin
reported a range of different races, including White and Black/African-
American.
Due to these challenges with the completeness and specificity of SSA’s
administrative race and ethnicity data, we determined the data were not
sufficiently reliable for us to include in this report.
Page 56 GAO-23-104650 Social Security Administration
Appendix II: Challenges in Assessing the
Effect of SSA Service Delivery Changes by
Race and Ethnicity
Section 2: Matching At the outset of our work, we considered a range of quantitative
Census Data with SSA techniques to analyze the race and ethnicity of the claimant population.
First, we considered the potential to match SSA administrative claims files
Administrative Data
with a variety of Census data sources. However, several risks are
associated with using Census data to estimate race and ethnicity in the
SSA claimant population. For example:
• Potential for insufficient sample size: If we had tried to match SSA’s
data on benefit claims over our study period to survey data from one
of the Census surveys, such as the American Community Survey
(ACS), we likely would not have had enough matches for a
representative sample. The ACS is the largest household survey
administered by the Census Bureau, which surveys 295,000
households per month. However, that might not have captured a
representative sample of the approximately 45 million benefit claims
and appeals that were filed during our study period. 4 This is especially
true for the disability claimant population, who we expect to be
underrepresented in Census surveys due to higher rates of non-
response and out-of-scope rates, particularly since DI and SSI
claimants likely have higher rates of living in group quarters. If the
Census surveys did not have sufficient samples of SSA program
claimants, we would not have been able to do a robust race/ethnicity
analysis.
• Timeliness of the data: Instead of using a Census survey, we also
might have tried to use the 2020 Census data. However, much of
these data had not been released in 2021, when we were conducting
our analysis. The 2020 ACS data would also not have been ready.
For these reasons, combined with the considerable time and effort
required to establish two separate data exchange agreements with SSA
and Census, we decided that the high probability of undertaking a
matching process that ultimately might not provide a robust analysis was
not practical for the purposes of this report.
Nonetheless, such costs could be justified for longer-term arrangements
that involved ongoing data exchanges, such as an agreement with
Census whereby administrative data from SSA could be matched with
Census data on an ongoing basis. A similar investment, as SSA mentions
4This represents the total number of benefit claims and appeals filed during the period, not
the number of unique individuals who filed a claim or appeal.
Page 57 GAO-23-104650 Social Security Administration
Appendix II: Challenges in Assessing the
Effect of SSA Service Delivery Changes by
Race and Ethnicity
in its Equity Action Plan, could support the agency’s efforts to identify
potential inequities in programs and services.
Section 3: Estimating Given the challenges that we encountered when analyzing SSA’s
Race Using the Bayesian administrative race and ethnicity data, we used an alternative approach to
assess the effect of SSA’s service delivery changes by race and ethnicity.
Improved Surname
Specifically, we used the Bayesian Improved Surname Geocoding (BISG)
Geocoding Method method to estimate the race and ethnicity of SSI benefit applicants within
our scope. 5 However, we ultimately found that the results were not
sufficiently reliable for our purposes.
Literature review and prior use of BISG. To inform prior work on the
use of tax credits across racial and ethnic groups, we reviewed literature
on racial and ethnic imputation methods published since 2006, to assess
methods that could be applied with IRS tax data. 6 We specifically focused
that review on methods using surnames. We conducted systematic
database searches to identify literature. Our electronic search covered
several databases of peer-reviewed scholarly publications, conference
papers, working papers, government reports, and publications by
associations, non-profits, and think tanks. This research has found that
BISG accurately predicts race and ethnicity for people identifying as
Hispanic, Non-Hispanic White, Black or African American, and
Asian/Pacific Islander. Our prior work concluded that the BISG method
has been used widely and considered feasible to use with data that
includes individuals’ surname and residential location, such as SSA
claims data. Based on this prior work, we determined that BISG held
potential in light of our analytical goals and we tested the method on
these data and validated them against SSA’s administrative race and
ethnicity data.
Data and use of BISG for this report. For the purposes of this report,
we applied the BISG method to SSA claims data. SSA provided us with
data, including surname and physical address, from its Supplemental
5Bayesian Improved Surname Geocoding (BISG) uses individuals’ surnames and street
addresses, along with 2010 Decennial Census block group data, to estimate the race and
ethnicity of a population. Marc N. Elliott, et al., “Using the Census Bureau’s Surname List
to Improve Estimates of Race/Ethnicity and Associated Disparities,” Health Services,
Outcomes, and Research Methods 9 (2009): 69-83.
6For more information on the literature review, see GAO-22-104582 Tax Equity: Enhanced
Evaluation Could Improve Outreach to Small Business Owners (Washington, D.C. Aug. 3,
2022).
Page 58 GAO-23-104650 Social Security Administration
Appendix II: Challenges in Assessing the
Effect of SSA Service Delivery Changes by
Race and Ethnicity
Security Record system for all individuals filing SSI claims or appeals
between March 1, 2018 and December 31, 2021. Along with the claims
data, we used two public-use data files from the 2010 Census of
Population and Housing. 7 When we designed our analysis, the Census
Bureau had not published the equivalent files for the most recent 2020
census.
Limitations of estimated results. We identified certain limitations of the
estimations produced through the BISG method in the context of the SSA
claimant population, particularly among certain disability and SSI
claimants. First, estimation using surname, address, and 2010 Census
data tends to be more accurate at predicting Asian and Hispanic/Latino
race and ethnicity and less accurate for White and Black/African
American race. This is largely due to relying on surnames, which overlap
at higher rates for White and African American populations. For example,
for the third most common surname in the 2010 Census, 46 percent
reported their race as “White alone,” and 48 percent reported their race
as “Black/African American alone.”
Another key limitation was the accuracy of the address association for
certain SSA claimant populations. Specifically, a higher proportion of
individuals applying for disability and SSI benefits reside in nursing
homes or care facilities. 8 This could make the estimation of race and
ethnicity through address association less accurate, if the racial and
ethnic distribution of the facility’s population differs from that of the
surrounding Census block group. 9
As an initial validation test, we compared the consistency of the BISG
racial and ethnic probabilities and SSA’s administrative race and ethnicity
data. Some of the preliminary results conflicted with other sources of
data, especially among individuals identified as Black/African American in
SSA’s administrative data. However, the limitations of SSA’s data also
limit their potential to accurately validate BISG estimates. Inconsistencies
between the BISG estimates and SSA’s administrative data may simply
7For a full discussion of the Census data sources and estimation technique, see
GAO-22-104582, app. II.
8According to the 2020 Annual Report on People with Disabilities in America, 3.5 percent
of people with disabilities were living in institutional group settings, compared with less
than 1 percent of people without disabilities in 2019.
9Census block groups are the smallest geographic entities for which the decennial Census
tabulates and reports sample data.
Page 59 GAO-23-104650 Social Security Administration
Appendix II: Challenges in Assessing the
Effect of SSA Service Delivery Changes by
Race and Ethnicity
reveal limitations of one or both data sources. Ultimately, there is no
reliable benchmark data source for the race and ethnicity of the SSA
claimant population at the individual level.
Given these limitations and the results of our validation test, we
determined that the results of the BISG race and ethnicity estimation were
not sufficiently reliable for us to include in this report.
Page 60 GAO-23-104650 Social Security Administration
Appendix III: Comments from the Social
Appendix III: Comments from the Social
Security Administration
Security Administration
Page 61 GAO-23-104650 Social Security Administration
Appendix IV: GAO Contact and Staff
Appendix IV: GAO Contact and Staff
Acknowledgments
Acknowledgments
Elizabeth H. Curda, (202) 512-7215 or curdae@gao.gov
GAO Contact
In addition to the contact named above, Erin M. Godtland (Assistant
Staff Director), Kelly Snow (Analyst in Charge), Isabella Anderson, and Craig
Acknowledgments Comen made key contributions to all aspects of this report. Additional
contributors include James Bennett, Paulissa Earl, Alex Galuten, Nick
Graves, Christopher Gresh, Robert Letzler, Dan Luo, Grant Mallie, Joel
Marus, Kathleen McQueeney, Kevin Metcalfe, Jennifer Padgett, Monica
Savoy, Ronni Schwartz, Almeta Spencer, Scott Spicer, Breana Stevens,
Jeff Tessin, Kathleen van Gelder, and Adam Wendel.
(104650)
Page 62 GAO-23-104650 Social Security Administration
The Government Accountability Office, the audit, evaluation, and investigative
GAO’s Mission arm of Congress, exists to support Congress in meeting its constitutional
responsibilities and to help improve the performance and accountability of the
federal government for the American people. GAO examines the use of public
funds; evaluates federal programs and policies; and provides analyses,
recommendations, and other assistance to help Congress make informed
oversight, policy, and funding decisions. GAO’s commitment to good government
is reflected in its core values of accountability, integrity, and reliability.
The fastest and easiest way to obtain copies of GAO documents at no cost is
Obtaining Copies of through our website. Each weekday afternoon, GAO posts on its website newly
GAO Reports and released reports, testimony, and correspondence. You can also subscribe to
GAO’s email updates to receive notification of newly posted products.
Testimony
Order by Phone The price of each GAO publication reflects GAO’s actual cost of production and
distribution and depends on the number of pages in the publication and whether
the publication is printed in color or black and white. Pricing and ordering
information is posted on GAO’s website, https://www.gao.gov/ordering.htm.
Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537.
Orders may be paid for using American Express, Discover Card, MasterCard,
Visa, check, or money order. Call for additional information.
Connect with GAO on Facebook, Flickr, Twitter, and YouTube.
Connect with GAO Subscribe to our RSS Feeds or Email Updates. Listen to our Podcasts.
Visit GAO on the web at https://www.gao.gov.
Contact FraudNet:
To Report Fraud,
Website: https://www.gao.gov/about/what-gao-does/fraudnet
Waste, and Abuse in
Automated answering system: (800) 424-5454 or (202) 512-7700
Federal Programs
A. Nicole Clowers, Managing Director, ClowersA@gao.gov, (202) 512-4400, U.S.
Congressional Government Accountability Office, 441 G Street NW, Room 7125, Washington,
Relations DC 20548
Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800
Public Affairs U.S. Government Accountability Office, 441 G Street NW, Room 7149
Washington, DC 20548
Stephen J. Sanford, Managing Director, spel@gao.gov, (202) 512-4707
Strategic Planning and U.S. Government Accountability Office, 441 G Street NW, Room 7814,
External Liaison Washington, DC 20548
Please Print on Recycled Paper.
File and source
- File
- gao-23-104650.pdf
- Size
- 1,614,684 bytes
- SHA-256
- 01c50241f22d64decda33b78ca815c855def82ca2c921612bfdf46497a72bea3
- Our copy
- gao-23-104650.pdf
- Original
- www.gao.gov