Social Security: New Functional Assessments for Children Raise Eligibility Questions

HEHS-95-66 March 10, 1995
Full Report (PDF, 37 pages)  

Summary

More than 200,000 children have been awarded federal disability benefits for mental or behavioral problems using new subjective criteria that allow benefits in cases that previously would have been rejected. GAO found fundamental flaws in the new process for assessing children's impairments. Specifically, each step of the process relies heavily on adjudicators' judgments, rather than on objective criteria from the Social Security Administration (SSA), to assess children's behavior. This calls into question SSA's ability to guarantee consistency in administering the program. At the same time, GAO discovered little evidence that parents are coaching their children to fake mental problems by misbehaving or doing poorly in school so that they can qualify for cash benefits.

GAO found that: (1) the judicial decision that required changes in IFA essentially made the process for determining disability in children analogous to the adult process; (2) the new process assesses how children's impairments limit their ability to act and behave like unimpaired children of similar age; (3) it has become important to obtain evidence of disability from nonmedical sources as part of the children's assessment; (4) although the court required a new type of assessment for disabled children, it did not define the degree of limitation necessary to qualify for SSI benefits; (5) before the IFA process was introduced in 1991, the national award rate for all types of childhood cases was 38 percent, but the award rate jumped to 56 percent in the first 2 years after IFA regulations were issued; (6) the non-medical aspects of the IFA evaluation rely heavily on adjudicator judgment; (7) while the Social Security Administration (SSA) has attempted to improve the process, and thereby reduce fraud and improve accuracy in awards, IFA has an underlying conceptual problem; (8) although the IFA process attempts to improve accuracy, the presence of coaching by parents is almost impossible to detect; and (9) more consistent eligibility decisions could be made if adjudicators based functional assessments of children on the functional criteria in SSA medical listings.