Progress Report on Development of a Redesigned Method of Evaluating Disability in Social Security Claims

SOCIAL SECURITY ADMINISTRATION

Progress Report on Development of a Redesigned Method of

Evaluating Disability in Social Security Claims

AGENCY: Social Security Administration.

ACTION: Notice and solicitation of comments.

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SUMMARY: This notice updates and requests further comment on SSA's

research plan for developing a new method for determining whether an

individual is ``disabled,'' as defined in the Social Security Act (the

Act), for purposes of entitlement or eligibility to disability benefits

under titles II or XVI. Notice of the original research plan, including

a request for comments, was published in the Federal Register on

September 9, 1996 (61 FR 47542). This notice discusses:

Preliminary research that has been conducted on functional

assessment tools and occupational classification systems;

Independent review and oversight of the research,

including the related disability evaluation study (DES), by the

National Academy of Sciences (NAS);

Expert, technical guidance being provided by outside

consultants; and

The role of external stakeholders.

In addition, this notice describes SSA's plans for future research

and development activities.

DATES: Comments should be received in writing on or before August 8,

1997.

ADDRESSES: Please submit comments on the Research Plan or requests to

be placed on the External Stakeholder

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mailing list (see External Stakeholders, below) in one of the following

manners:

By E-mail, to [email protected].

By telefax, to 410-966-0148.

By mail, to Disability Process Redesign Staff, Office of

Disability, Social Security Administration, 6401 Security Boulevard,

Room 560 Altmeyer, Baltimore MD 21235.

FOR FURTHER INFORMATION CONTACT: David Barnes, 410-965-9121.

SUPPLEMENTARY INFORMATION:

Background

On September 9, 1996, SSA published, in the Federal Register,

notice of the Research Plan For the Development of a Redesigned Method

of Evaluating Disability in Social Security Claims (61 FR 47542). That

notice described SSA's research plan for developing a new method for

deciding whether an individual is ``disabled'' for purposes of Social

Security disability program claims, but without changing the statutory

definition of disability. The notice also discussed integration of the

DES and the disability decision methodology research. (A summary of the

research plan may also be accessed on the Internet at: http://

www.ssa.gov/DPRT/research.html.)

In the September 1996 notice, SSA also stated its intention to

publish future notices to update the research plan at major milestones

in the research and development process. This is the first of these

intended notices.

Research Plan To Develop Redesigned Disability Decision Methodology

The current research plan includes three steps: (1) Initial

Research; (2) Integration of Initial Research and Development of a

Prototype Disability Decision Process (including DES Stage 1 activity);

and (3) Final Testing (including DES Stage 2 activity). The research

plan also calls for independent review and oversight; use of outside

technical expert consultants; and use of stakeholder input.

Step 1: Initial Research

A. Four Reviews of Current Literature

The research plan calls for four literature reviews to gather

background information and data in subject areas of importance to the

disability decision process. The four reviews, two of which have been

completed, are described below.

1. Functional Assessment Instruments

The purpose of the functional assessment research was to define the

state of the art in assessing functional capacity, and to identify

instruments that might be used in, or adapted for, a new decision

process.

This review has already been conducted by Virginia Commonwealth

University (VCU). It involved thoroughly researching the literature

about systems, methods, and instruments for measuring functional

ability and capacity to perform activities and tasks, and developing a

systematic method of describing, categorizing, comparing, and

evaluating those systems, methods, and instruments for the purpose of

determining their potential application in the disability decision

process.

VCU began research in August 1995. In March 1996, VCU completed its

work and issued its report, titled Summary Report. At SSA's request,

VCU prepared a follow-up report, Report on Findings and Recommendations

for Future Directions which was issued in July 1996. These reports are

available on the Internet (http://www.ssa.gov/DPRT/

functional__assessment.html) and are summarized below.

Summary Report. In the Summary Report, issued in March 1996, VCU

reported that its initial search of literature and other sources

identified approximately 700 functional assessment instruments. In

conjunction with SSA, VCU developed selection criteria in order to

focus on those instruments most appropriate to SSA's needs. Forty-six

(46) instruments met the criteria and were further reviewed and

analyzed. VCU described the 46 instruments and made the following

findings from its analysis of those instruments.

Finding #1: The search yielded a large number of instruments

currently in use.

Finding #2: The search yielded no truly global measure of function.

Finding #3: Most functional assessments in use relied upon self-

reported data.

Finding #4: Self-report scales offer few mechanisms for validation

of data.

Finding #5: Automated functional capacity systems offer more

mechanisms for validation of data, but require more time and equipment.

Finding #6: Self-report questionnaires can be modified to offset

potential exaggeration of symptoms.

Finding #7: Predictive and concurrent validity of clinical

instruments may not generalize to SSA claimant populations.

Finding #8: Specialized training for administering instruments

needs to be a consideration in selection.

Finding #9: Functional assessments often include performance of

social roles and expectations, not just symptoms.

Report on findings and recommendations for future directions. After

receiving the initial report, SSA asked VCU to use the knowledge gained

in their research on functional capacity assessment instruments to

expand and elaborate on their analysis. In July 1996, VCU issued the

Report on Findings and Recommendations for Future Directions.

In this follow-up report, VCU expressed the opinion that the

addition of functional assessment strategies to the SSA disability

determination process would greatly enhance the effectiveness and

efficiency of current assessment strategies. The report stated that the

development and use of appropriate functional assessment instruments

for screening and as domain-specific batteries could complement

clinical assessment, increase the accuracy of residual functional

capacity assessments, and potentially reduce cost related to

administrative reviews and litigation. However, VCU also said that,

currently, there is no one functional assessment instrument which will

measure the effects of all types of impairments on mental and physical

functioning and that the present status of functional assessment is not

sufficiently refined to allow a total reliance on this approach. The

VCU report identified six functional domains that the authors felt

should be addressed in an SSA-devised instrument for the measurement of

general function:

Activities of Daily Living.

Mental Functioning Limitations.

Physical Functioning Abilities.

Psychiatric or Mental Health Status.

Medical Information.

Social Support Networks.

The VCU report recommended that SSA undertake the following

activities as the next steps in the methodology research and

development process:

a. SSA should develop a global functional assessment screening

instrument that could be standardized and validated on the SSA

applicant pool. SSA should directly develop or coordinate the

development of a functional assessment instrument for use in the

disability determination process. The following steps should be

completed.

Determine the domains to be included in the assessment.

Develop a draft instrument for subsequent standardization

and validation.

Standardize and validate the instrument on a

representative sample of SSA applicants.

Based on the results of the initial analyses, develop a

``second draft'' of

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the instrument for additional, more advanced, validation analyses.

Based on the results of the second round of validation

analyses, the instrument can then be readied for large scale field-test

implementation within the national disability determination system.

b. SSA should directly develop or coordinate the development of

detailed assessment batteries in each of the domains identified above.

Initial batteries should be developed in each of the

domains.

Particular care should be given to the development of

batteries in the areas of Mental Functioning Limitations and

Psychiatric or Mental Health Status.

The domain-specific functional batteries should be

prepared for a series of validation analyses.

2. Occupational Classification Systems

The purpose of the review of occupational classification systems

was to review existing systems and methods of classifying occupations,

particularly in terms of the physical and mental capacities required to

do those occupations, and evaluate such systems and methods in terms of

their potential applicability to the redesigned Social Security

disability decision process.

This research related to one of the key concepts in the disability

decision process proposed in the disability process redesign--

``baseline work.'' The redesign plan called for determining disability

in some cases by comparing an individual's functional ability to a

baseline of work that represents substantial gainful activity. This

baseline was expected to describe the basic physical and mental demands

of work (i.e., a range of functional activities that realistically

reflects the demands of occupations that can be performed in the

absence of prior skills or formal job training). The baseline would be

used to evaluate whether an individual's functional ability is

consistent with the ability to perform substantial gainful work

activity.

The review was designed to assist SSA in determining whether there

exists a standard to describe basic physical and mental demands of a

baseline of work (or whether it is feasible to develop such a

standard). If such a standard were not found to exist and could not be

developed, the research should assist in determining an alternative

process(es) determining whether an individual is unable to do not only

his or her previous work, but also unable to engage in any other kind

of substantial gainful work which exists in the national economy.

This research was begun in May of 1996 by the American Institutes

for Research (AIR). In November 1996, AIR issued the Final Report:

Identification and Analysis of Occupational Classification Systems.

This report is available on the Internet at: http://www.ssa.gov/DPRT/

execsum.html.

The initial search yielded 126 documents identifying and describing

33 occupational classifications systems of 5 different types. Although

AIR did not find a candidate system that was exactly or ideally suited

to SSA's needs, it did find one database that closely matches SSA's

needs--the Department of Labor's (DOL's) Occupational Information

Network (O*NET), which is currently under development.

Based on discussions with SSA, together with its review and

analysis of occupational classification systems, AIR made five

recommendations:

Recommendation 1: Use O*NET;

Recommendation 2: Establish a working relationship with the

Department of Labor;

Recommendation 3: Compare the occupational classification and

functional assessment taxonomies before the Disability Evaluation

Study;

Recommendation 4: Conduct analyses of the O*NET database; and

Recommendation 5: Develop a prototype.

3. Other Disability Programs Systems and Methods

The purpose of the third review is to:

Survey existing systems and methods of deciding disability

in other public and private programs, both domestic and foreign; and

Identify methods, instrumentation, criteria, research

findings or other features that may be appropriate to incorporate into,

or otherwise be used in developing, our new decision process.

There are many disability benefit programs and other similar

programs, worldwide, that evaluate individuals to determine whether or

not they have an impairment and to determine the extent to which such

impairment(s) limit their ability to function, particularly in relation

to work. These programs use their own methods, instrumentation, and

criteria to make decisions. Despite significant differences between

other programs' standards or purposes and those established by law for

SSA's disability programs, some other programs may have features that

can be adapted to SSA's new disability decision process, resulting in

time and cost savings.

This research has not been conducted yet. We expect to initiate

this research in the near future. The research should be completed in

early 1998.

Note: This notice does not constitute a request for proposals or

grant applications. Any unsolicited proposals or applications

submitted to SSA at this time, related to this notice, will not be

considered nor will their receipt be acknowledged. Any acquisitiion

or grant activity will be undertaken under the normal procedures for

such activity.

4. Vocational Factors Research

The final review is expected to be a survey and analysis of the

literature on the relationship between what SSA calls ``vocational

factors'' (i.e., age, education, and work experience) and an

individual's ability to work. The statutory definition of disability

specifies that these vocational factors are to be considered when

assessing disability:

An individual shall be determined to be under a disability only

if his physical or mental impairment or impairments are of such

severity that he is not only unable to do his previous work but

cannot, considering his age, education, and work experience, engage

in any other kind of substantial gainful work which exists in the

national economy * * * (Section 223(d)(2)(A) of the Act. Emphasis

added.)

The purpose of the research is to review current thinking on the

actual effects of age, education, and work experience on the ability to

work. With this knowledge base, we will be able to begin developing an

appropriate way to account for those effects in a new decision process.

This research has not been conducted yet. We expect to initiate

this research in the near future. The research should be completed

early in 1998.

Note: This notice does not constitute a request for proposals or

grant applications. Any unsolicited proposals or applications

submitted to SSA at this time, related to this notice, will not be

considered nor will their receipt be acknowledged. Any acquisition

or grant activity will be undertaken under the normal procedures for

such activity.

B. Independent Review and Oversight

On September 26, 1996, SSA awarded a four-year contract to the

Institute of Medicine and the Committee on National Statistics of the

National Academy of Sciences (NAS) to conduct an independent,

scientific review of SSA's research and development of a new disability

decision process, including the DES.

In November 1996, NAS established a committee of 14 experts, the

Committee to Review the Social Security Administration's Disability

Decision Process Research (the committee), which first met in January

1997. The committee's review (study) will provide

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independent scientific analysis of all aspects of SSA's approach and

methods for researching and developing the new decision process and

conducting relevant DES research activities.

Consistent with the need for independence and impartiality, final

decisions about study management and work plan reside with the

committee, which has authority and responsibility for the conduct and

oversight of the study. The committee determines the best means to

approach the conduct of the study, sets its own agenda, and designs its

plan of work.

Study activities may include (but will not be limited to) the

following broad issues:

Review of SSA's research plan and timeline for developing

a new disability decision process;

Review of SSA's DES design and activity;

Review of other related SSA sponsored research, including

research findings; and

A final report containing the committee's findings and

recommendations.

C. Consultants

In September 1996, SSA began consultation with three outside

experts in the subject areas of functional assessment of physical

impairments, occupational analysis, and health measurement. In March

1997, SSA added consultants in two additional subject areas: functional

assessment of mental impairments and research methodology. The five

consultants will provide technical guidance in their respective

specialties to SSA's research workgroup.

D. Internal and External Stakeholders

SSA is committed to conducting this research in an inclusive

environment. To that end, SSA is providing updated information to, and

requesting comments of, the general public in this notice. In addition,

SSA is sending the same notice and request for comments to a

comprehensive list of internal and external stakeholders.

External stakeholders are individuals and organizations with a

special interest in SSA disability programs. By directing updates and

requests for comments not only to the general public, but to a list of

individuals and organizations who have expressed a particular interest

in this project, we hope to receive more specific feedback and

commentary than might be received by simply publishing notices to the

general public. Individuals or organizations interested in being

considered external stakeholders should submit their request as

explained in ADDRESSES, above.

The role of the external stakeholder is to comment on the research,

but not to be an active participant in any research or testing. A

number of individuals and organizations who responded to the September

9, 1996 notice, appear to have misinterpreted the request for comment

as a solicitation of potential sources for research grants or

contracts. Any grant or contracting activity will be clearly described

as such and conducted under the usual grant or contracting procedures

with appropriate public and industry notice.

As noted above, this notice does not constitute a request for

proposals or grant applications. Any unsolicited proposals or

applications submitted to SSA at this time, related to this notice,

will not be considered nor will their receipt be acknowledged. Any

acquisition or grant activity will be undertaken under the normal

procedures for such activity.

Step 2: Integration of Initial Research and Development of a Prototype

Disability Decision Process, Including Stage 1 of the DES

After step one activities are completed, the next step will be to

review the findings of the four initial research surveys (i.e.,

functional assessment instruments, occupational classification systems,

other program methodologies, and vocational factors) and begin the

development of a prototype of a new decision process. This will require

coordination and integration of the knowledge acquired in the

preliminary research, development of proposals for a new disability

decision process, and conceptualization of testing scenarios.

Stage 1 of the Disability Evaluation Study (DES) (for a detailed

explanation of the DES, refer to the notice published in the Federal

Register (61 FR 47542) on September 9, 1996) can provide the facility

to test proposed components of a new decision process (e.g., specific

functional assessment tools), with appropriate control and sampling

techniques. In addition, SSA envisions methodology laboratories within

which other potential components of a new disability decision process

may be tested in a controlled setting.

Step 3: Final Testing and Stage 2 of the DES

The purposes of this final step will be to:

Refine the prototype decision process and develop data

about the potential effects and consequences of implementation of the

prototype; and

specify the precise features of a new decision process and

identify all the likely costs and benefits of implementing that

process.

This will involve additional testing to address scaling,

thresholds, validity, and reliability as well as the potential effects

of a new disability decision method on both applicants and the

adjudication process, e.g., potential changes in decision outcomes in

individual cases or for certain kinds of cases, workload, short and

long-term administrative expenses, trust fund expenditures, and

timeliness of decisions. Analysis of the testing must address: whether

the new process is accurate; whether it changes decision outcomes;

whether it is simple to administer and facilitates consistent decisions

at each adjudicative level; and whether claimants, advocates, and

stakeholders view the new method as straightforward, understandable,

and fair.

The DES will play an important role in gathering test data.

However, it will not be the only source of data. We expect to need

other sources of test data, and these will have to be developed. The

envisioned methodology laboratories may provide controlled settings and

representative samples within which data may be gathered and a new

disability decision process may be tested.

Comments on the September 1996 Notice

The SSA received comments from 27 individuals or groups in response

to the September 1996 Notice concerning the Research Plan. We found the

comments that related to the research plan or to the development of a

new disability decision process very helpful.

Not all of the comments related to the research plan or decision

process. Some comments related to other aspects of SSA's disability

redesign, to rehabilitation or return-to-work issues, or to other

matters beyond the scope of this project.

SSA considered all the comments received, although it does not plan

to respond directly to each comment. Many of the suggestions were

already part of the research plan and added weight for their inclusion

as integral parts of the plan; some of the suggestions are still under

consideration; and others are beyond the scope of this project.

We appreciate all of the input we have received and we encourage

comments on this notice and on future notices, which will update the

status of the research.

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Timeline

A timeline of research plan actions and completion date goals is

shown below.

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Action Date

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Development of Research Plan.................. Completed.

Initial Research on Functional Assessment Completed.

Instruments.

Publication of Research Plan in Federal Completed.

Register; Request for Internal and External

Stakeholder Comments.

Completion of Initial Research on Occupational Completed.

Classification Systems..

Publication of Federal Register Notice 06/97.

Describing Initial Research Products and

Updating Research Plan.

Other Disability Programs Research............ 09/97-02/98.

Vocational Factors Research................... 09/97-02/98.

Integration and Prototype Development......... 09/97-09/98.

Award of DES Contract......................... 12/97.

Federal Register Notice Updating Research 12/97.

Plan; Request for Internal and External

Stakeholder Comments.

Supplemental Research (as needed) and Testing. 04/98-04/99.

DES Stage 1 Planning and Pilot for Field Work 01/98-06/98.

Begins..

Federal Register Notice Updating Research 10/98.

Plan; Request for Internal and External

Stakeholder Comments.

Review of All Research, Comments, and Testing 05/99-10/99.

in Conjunction with DES Stage 1 Data; DES

Stage 2 Pilot.

DES Stage 2 Field Work........................ 10/99-09/00.

Federal Register Notice Updating Research 10/99.

Plan, Including Any Interim Results; Request

for Internal and External Stakeholder

Comments.

Final Review of All Research, Testing, 10/99-12/00

Comments, and DES Data; Recommendations for

Possible New Final Disability Decision

Process.

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Dated: June 16, 1997.

Carolyn W. Colvin,

Deputy Commissioner for Programs and Policy.

[FR Doc. 97-16490 Filed 6-23-97; 8:45 am]

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