SSAB Encourages SSA to Use Data to Access Equity

Empire Justice Center October 31, 2022

The Social Security Advisory Board (SSAB) is a bipartisan, independent federal government agency established in 1994 to advise the President, the Congress, and the Commissioner of Social Security on matters of policy and administration of the Old-Age, Survivors, and Disability Insurance and the Supplemental Security Income programs. The Board has seven members, appointed by the President, Senate, and House of Representatives. Among its functions is analyzing the Social Security Administration’s (SSA’s) retirement and disability programs and making recommendations, including recommendations on the quality of services that SSA delivers to the public. In that role, the SSAB recently encouraged SSA to measure the impacts of service changes on different populations to inform program administration. See Using Evidence to Improve Service Equity (September 2022).


In its three-part paper, the SSAB reviewed federal management initiatives in the context of SSA. It described administration and agency priorities across customer experience, evidence, and equity. In December 2021, the Biden administration released an executive order (EO) on prioritizing customer experience. The EO required SSA to analyze all services that require original or physical documentation or an in-person appearance and recommend reforms where statutorily feasible. SSA was also directed to develop a mobile-accessible, online process so someone applying for or receiving services from SSA can upload any form, documentation, evidence, or correspondence without traveling to a field office. These changes should give SSA new and better data on how people interact with the agency over time. The Board encouraged SSA to examine the differences between people’s perceptions of the agency’s services and its performance metrics.


The paper also emphasized the Office of Management and Budget’s (OMB) 2021 emphasis on “learning agendas” to identify and prioritize strategies for answering critical policy questions relevant to the agency’s mission and operation. SSA published its learning agenda in March 2022, with six of its ten priority questions supporting the agency’s strategic goal to optimize customer service. The SSAB also reviewed the President’s and OMB’s executive orders (EO) to incorporate a comprehensive approach to equity in all planning. [President Biden’s EO and SSA’s reaction have been discussed in prior editions of this newsletter.]


In the second part, citing challenges faced by SSA during the COVID-19 pandemic, the SSAB noted significant downward trends in the numbers of people receiving benefits.  Disability (DI) awards fell 15 percent in 2021 after falling 11 percent in 2020. Supplemental Security Income (SSI) awards have fallen even more sharply – 27 percent in 2021 after falling 18 percent in 2020. [See the January 2021 edition of this newsletter for more on the decline in SSI applications.]  The SSAB encouraged SSA to review how barriers to non-in-person service affected access, quality, and perceptions among various population groups.  It recommended that SSA review, expand, and make public its research to examine how SSA’s program administration exacerbates or reduces existing disparities in its service delivery.


SSA needs to understand service channel preferences among the various populations served by the agency. Those channel preferences include on-line services such as mysocialsecurity, in-person field office service, 800 number and field office phone service, video services, mail services, and direct and third-party outreach. Each category presents challenges to some claimants, including lack of internet access or literacy, for example. SSAB recommended that before SSA implements any changes in service delivery, it should ensure it has collected the appropriate data to evaluate whether the service change affects how different people access and use its services.


Finally, the SSAB addressed opportunities SSA has to measure whether the intended impact of  its services is equitably distributed among the public. It acknowledged that assessing whether SSA provides services equitably is difficult when the agency does not comprehensively collect or publish program data by race, ethnicity, and other population characteristics that correlate with underserved populations. [See prior editions of this newsletter for further discussions of lack of SSA data.] While acknowledging that SSA is making slow progress with data exchanges and voluntary information to collect the data, it recommended that SSA also examine the share of service variations across socioeconomic groups that cannot be associated with observable applicant and case characteristics, such as individual LGBTQ+ communities and smaller racial and ethnic groups.


The SSAB made seven specific recommendations to SSA that are available in the report.