oversight

Supplemental Security Income: SSA Has Taken Steps to Prevent and Detect Overpayments, but Additional Actions Could Be Taken to Improve Oversight

Published by the Government Accountability Office on 2012-12-14.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                United States Government Accountability Office

GAO             Report to Congressional Requesters




                SUPPLEMENTAL
December 2012



                SECURITY INCOME

                SSA Has Taken Steps
                to Prevent and Detect
                Overpayments, but
                Additional Actions
                Could Be Taken to
                Improve Oversight




GAO-13-109
Contents


Letter                                                                                                    1
               Conclusions                                                                                4
               Recommendations for Executive Action                                                       5
               Agency Comments and Our Evaluation                                                         5

Appendix I     SSI Overpayments and Recovery Presentation                                                 7



Appendix II    Comments from the Social Security Administration                                          46



Appendix III   GAO Contact and Staff Acknowledgments                                                     48




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               Page i                                           GAO-13-109 Supplemental Security Income
United States Government Accountability Office
Washington, DC 20548




                                   December 14, 2012

                                   The Honorable Erik Paulsen
                                   Acting Chairman
                                   Subcommittee on Human Resources
                                   Committee on Ways and Means
                                   House of Representatives

                                   The Honorable Scott P. Brown
                                   United States Senate

                                   The Social Security Administration’s (SSA) Supplemental Security
                                   Income program (SSI) provides cash assistance for eligible aged, blind,
                                   and disabled individuals with limited financial means. In fiscal year 2011,
                                   the SSI program paid about $46 billion in benefits to approximately 9
                                   million beneficiaries. The program has grown substantially in recent
                                   years, and is expected to grow more in the near future, placing added
                                   pressure on already stretched federal budgets. Given the size of the SSI
                                   program, even small errors in benefit payments can result in a significant
                                   loss of taxpayer dollars, and financial hardships for individuals of limited
                                   means who have to repay the overpayment. In fiscal year 2010, SSA
                                   reported that overpayments to program recipients exceeded $3.3 billion.
                                   Agency data also showed that the amount of SSI debt recovered was less
                                   than half the amount of new debt detected.

                                   To determine an individual’s ongoing financial eligibility for SSI program
                                   payments, SSA conducts periodic “redeterminations.” During a
                                   redetermination, field office staff perform a variety of activities to verify
                                   recipients’ income, resources, living arrangements, and other factors to
                                   determine their continued SSI program eligibility. These activities may
                                   include querying internal and external databases, checking with
                                   employers and banks, and performing interviews with recipients to obtain
                                   current information. In fiscal year 2011, SSA conducted more than 2.4
                                   million redeterminations—an increase of about 136 percent over the
                                   number conducted in fiscal year 2007—that it estimates will prevent or
                                   recover about $3.2 billion in lifetime overpayments.

                                   In fiscal year 2012, recipients with countable income that exceeds $698
                                   per month ($1,048 for couples) are generally ineligible for SSI payments.
                                   In addition, recipients who have countable assets of more than $2,000
                                   ($3,000 for couples) are also ineligible for SSI payments. SSA may
                                   overpay beneficiaries if it does not obtain timely and accurate information


                                   Page 1                                   GAO-13-109 Supplemental Security Income
regarding their earnings and assets, and act expeditiously to discontinue
payments to recipients who exceed income or asset thresholds. These
overpayments adversely impact program integrity, and may create
economic hardship for beneficiaries who have to repay them. Moreover,
the potential burden of having to repay SSI overpayments could create,
for some, a disincentive to work.

Given the importance of verifying the continued eligibility of SSI
recipients, and identifying and recovering potential SSI benefit
overpayments, you asked us to study the extent to which SSA makes
overpayments to and recovers overpayments from SSI beneficiaries.
Specifically, we answered the following questions: (1) What are the major
factors associated with SSI overpayments, and what actions has SSA
taken to address them? and (2) What is known about SSA’s recovery of
overpayments from SSI recipients, including those not currently receiving
SSI payments?

We used multiple data collection methods to obtain this information. We
analyzed SSI overpayment debt and collection data for fiscal year 2011 to
identify trends in the identification and recovery of SSI overpayments. We
also worked with SSA staff to review a nongeneralizable random sample
of 105 cases of SSI recipients who had an overpayment detected in fiscal
year 2011 to better understand the characteristics associated with
overpayments. We reviewed documentation on SSA’s policies and
procedures for identifying and recovering SSI benefit overpayments, prior
reports by SSA and its Office of the Inspector General, relevant federal
laws and regulations, and prior GAO studies of the SSI program. In
addition, we conducted in-depth interviews with management and staff
from SSA headquarters, selected regions, and field offices. We also
examined initiatives developed by SSA to improve the identification and
recovery of SSI overpayments. Finally, we report estimates of
overpayment deficiency dollars that are published in SSA’s annual
Supplemental Security Income stewardship reports. These estimates are
based on random samples of approximately 4,300 cases each year, and
consequently are subject to sampling error. Although the stewardship
reports do include confidence intervals for the overall overpayment
accuracy rates, SSA does not provide confidence intervals for the
overpayment deficiency dollar estimates. Based on available information
in these reports in combination with conservative assumptions, we placed
approximate bounds on the size of these sampling errors for overpayment
deficiency dollar estimates. In particular, we believe that the 95 percent
confidence intervals for the overpayment deficiency estimates we present
do not exceed plus or minus 20 percent of the estimates themselves.


Page 2                                  GAO-13-109 Supplemental Security Income
We conducted this performance audit from September 2011 to October
2012 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
the evidence obtained provides a reasonable basis for our findings based
on our audit objectives.

On October 19, 2012, we briefed your staff on the results of our study of
the extent to which SSA makes overpayments to and recovers
overpayments from SSI beneficiaries. In summary, we found that
cumulative SSI overpayment debt nearly doubled from $3.8 billion in
fiscal year 2002 to $7.3 billion in fiscal year 2011. SSI overpayment debt
recovery also increased from $860 million to almost $1.2 billion during the
same time period. For fiscal year 2011, the unreported value of recipients’
financial institution accounts, such as checking and savings accounts,
and unreported wages were the major factors associated with causes of
overpayments, and were associated with about $1.7 billion (37 percent) of
all SSI overpayments. 1 SSA lacks comprehensive, timely information on
SSI recipients’ financial institution accounts and wages, but has
developed new tools to improve its information in these areas: Access to
Financial Institutions (AFI) and Telephone Wage Reporting (TWR). The
AFI initiative conducts electronic searches of about 96 percent of the
financial institutions where SSI recipients have a direct deposit account,
and provides SSA with independent data on a recipient’s financial
institution accounts to use when periodically redetermining a recipient’s
eligibility for payments. The TWR system allows recipients to call into an
automated telephone system to report their monthly wages. Agency
officials reported that the TWR system should ease the burden of
reporting wages for some recipients and save time for SSA staff since
wage data will be input directly into SSA’s computer system.

We also found that in fiscal year 2011, 75 percent of SSI overpayment
debt that was recovered was obtained by withholding a portion of
recipients’ ongoing Title XVI (SSI) payments, or by withholding of Title II
(Old-Age, Survivors, and Disability Insurance) payments. Recipients can




1
 Amounts are annual estimates based on 5-year averages from FY 2007 through
FY 2011.




Page 3                                      GAO-13-109 Supplemental Security Income
              request a waiver of repayment under certain circumstances. 2 According
              to the standards for internal control in the federal government, agencies
              must have controls in place to ensure that no individual can control all key
              aspects of a transaction or event. 3 SSA, however, does not require
              supervisory review or approval for overpayment waivers of $2,000 or
              less; 4 and claims representatives, who are located in SSA’s more than
              1,260 field offices, have the authority to unilaterally approve such waivers.
              In fiscal year 2011, SSA approved about 76 percent of all SSI
              overpayment waivers requested by recipients. Management oversight of
              the SSI overpayment waiver decision process is limited. The agency does
              not routinely analyze collected SSI waiver data to identify potential
              negative trends in the implementation of SSA’s waiver policies and
              procedures, such as the type, number, and dollar value of the waivers
              granted, including those waivers below the $2,000 approval threshold that
              SSA staff can unilaterally approve, and whether there are waiver patterns
              specific to SSA offices, regions, or individual staff.


              SSA has made progress in improving SSI program integrity through the
Conclusions   increased use of redeterminations to detect and prevent overpayments,
              the AFI initiative to obtain more accurate information on recipients’
              financial institution accounts, and its continued efforts to obtain more
              timely recipient wage information. Despite this progress, SSA efforts to
              recover identified overpayment debts are constrained by SSA policies
              and criteria that allow claims representatives to unilaterally waive the
              repayment of overpayment amounts up to $2,000 without supervisory
              review and approval. SSA also lacks comprehensive management
              information with which to oversee the waiver process through the tracking



              2
               The statute requires that SSA waive overpayments if a recipient is not at fault and
              recovering an overpayment would 1) defeat the purpose of the SSI program, 2) be against
              equity and good conscience, or 3) impede the effective administration of SSI due to the
              small amount involved. 42 U.S.C. § 1383(b)(1)(B)(i).
              3
               The standards for internal control in the federal government provide the overall
              framework to assist federal agencies in establishing and maintaining internal control and
              for identifying and addressing major performance and management challenges and areas
              at greatest risk of fraud, waste, abuse, and mismanagement. For more information see
              GAO, Standards for Internal Control. GAO/AIMD-00-21.3.1 (Washington, D.C.:
              November 1999).
              4
               SSA’s Program Operations Manual System gives claims representatives the authority to
              waive overpayment amounts up to $2,000 without supervisory review and approval.




              Page 4                                          GAO-13-109 Supplemental Security Income
                      of waiver approval rates, amounts, and patterns specific to SSA offices,
                      regions, or individual staff. According to the standards for internal control
                      in the federal government, agencies must have controls in place to
                      ensure that no individual can control all key aspects of a transaction or
                      event. Without the necessary oversight and controls in place, SSA will be
                      unable to identify trends in the waiver process that could jeopardize the
                      agency’s ability to maximize its overpayment recovery efforts and
                      safeguard taxpayer dollars.


                      To enhance SSA’s ability to recover SSI overpayment debt, we
Recommendations for   recommend that the Commissioner of Social Security
Executive Action
                      •   Review the agency’s policy concerning the supervisory review and
                          approval of overpayment waiver decisions of $2,000 or less, to
                          determine if the policy is still appropriate given that federal agencies
                          must have controls in place to ensure that no individual can control all
                          key aspects of a transaction or event. Such a review should include
                          collecting the information needed to determine the impact of this
                          policy on the agency’s financial stewardship of SSI program dollars.
                      •   Explore ways to strengthen the agency’s oversight of the
                          overpayment waiver process through the analysis of data to identify
                          waiver trends, such as approval rates, amounts, and patterns specific
                          to SSA offices, regions, or individual staff that the agency may wish to
                          track more closely.

                      We obtained written comments on a draft of this report from the Office of
Agency Comments       the Commissioner of the Social Security Administration. The comments
and Our Evaluation    are reproduced in appendix II. The agency also provided general and
                      technical comments, which have been incorporated into the report as
                      appropriate. SSA agreed with our first recommendation to review the
                      agency’s policy concerning the supervisory review and approval of
                      overpayment waiver decisions of $2,000 or less. SSA disagreed with our
                      second recommendation to explore ways to strengthen the agency’s
                      oversight of the overpayment waiver process through the analysis of data
                      to identify waiver trends, such as approval rates, amounts and patterns to
                      specific SSA offices, regions, or individual staff. SSA noted that while the
                      agency continues to strengthen its oversight of the SSI program, it does
                      not currently have the resources available to create and analyze data at
                      the level of detail specified in the recommendation. The agency also cited
                      the national and regional information for waiver transaction approval and
                      denials that it compiles as part of its ongoing review of SSI overpayments.
                      This information is discussed on page 42 of the report. We recognize


                      Page 5                                   GAO-13-109 Supplemental Security Income
SSA’s efforts and the agency’s ongoing resource constraints. However,
we continue to believe that, short of additional steps to better compile and
track additional data on waiver patterns specific to SSA offices and
individuals, SSA will be constrained in its efforts to recover identified
overpayments.


We are sending copies of this report to the Commissioner of Social
Security, appropriate congressional committees, and other interested
parties. This report is also available at no charge on GAO’s 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 bertonid@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 III.




Daniel Bertoni
Director, Education, Workforce,
  and Income Security Issues




Page 6                                   GAO-13-109 Supplemental Security Income
Appendix I: SSI Overpayments and Recovery
                                 Appendix I: SSI Overpayments and Recovery
                                 Presentation



Presentation




     Supplemental Security Income: SSA Has Taken Steps to Prevent and Detect
     Overpayments, but Additional Actions Could Be Taken to Improve Oversight




    Staff Briefing for Acting Chairman of the Subcommittee on Human Resources,
               Committee on Ways and Means, and Senator Scott Brown

                                            October 2012




 For more information, contact Daniel Bertoni.                                                         Page 1




                                 Page 7                                      GAO-13-109 Supplemental Security Income
                                                       Appendix I: SSI Overpayments and Recovery
                                                       Presentation




Introduction




•       The Supplemental Security Income (SSI) program, administered by the Social Security
        Administration (SSA), provides cash payments from general tax revenues to eligible
        aged,1 blind, and, disabled persons with limited financial means—including adults and
        children.

•       Applicants with income or resources over certain statutory thresholds are not eligible for
        SSI even if they are aged, blind, or disabled.

•       In 2011, SSI paid about $46 billion in payments to 9 million recipients.2

•       SSI eligibility is determined and periodically redetermined by complex factors that can
        be difficult to verify, including recipients’ income, resources, and living arrangements.3


1 The term “aged” refers to individuals who are 65 years of age or older.
2This  includes all recipients who received at least one federal SSI payment during 2011.
3There are income and asset thresholds that can preclude individuals from SSI program eligibility.

.

                                                                                                                              Page 2
                                                                             .




                                                       Page 8                                        GAO-13-109 Supplemental Security Income
                               Appendix I: SSI Overpayments and Recovery
                               Presentation




Objectives




Given the importance of verifying the continued eligibility of SSI recipients, and identifying
and recovering potential SSI benefit overpayments, we addressed the following questions:

1)   What are the major factors associated with SSI overpayments, and what actions has
     SSA taken to address them?



2)   What is known about SSA’s recovery of overpayments from SSI recipients, including
     those not currently receiving SSI payments?




                                                                                                     Page 3




                               Page 9                                      GAO-13-109 Supplemental Security Income
                               Appendix I: SSI Overpayments and Recovery
                               Presentation




Scope and Methodology




To answer our questions, we:

  • Analyzed SSI overpayment debt and collection data for fiscal year 2011.

  • Worked with SSA staff to review a nongeneralizable random sample of 105 cases of
    SSI recipients who had an overpayment detected in fiscal year 2011 to better
    understand the characteristics associated with overpayments.

  • Reviewed documentation on SSA’s policies and procedures for identifying and
    recovering SSI benefit overpayments, prior reports by SSA and its Office of the
    Inspector General, relevant federal laws and regulations, and our prior reviews of the
    SSI program.

  • Conducted in-depth interviews with management and staff from SSA headquarters,
    selected regions, and field offices.



                                                                                                     Page 4




                               Page 10                                     GAO-13-109 Supplemental Security Income
                              Appendix I: SSI Overpayments and Recovery
                              Presentation




Scope and Methodology (continued)



•   Examined initiatives developed by SSA to improve the identification and recovery of SSI
    overpayments.

•   Examined estimates of overpayment deficiency dollars that are published in SSA’s
    annual SSI stewardship reports. These estimates are based on random samples of
    approximately 4,300 cases each year, and consequently are subject to sampling error.
    Although the stewardship reports do include confidence intervals for the overall
    overpayment accuracy rates, SSA does not provide confidence intervals for the
    overpayment deficiency dollar estimates. Based on available information in these
    reports in combination with conservative assumptions, we placed approximate bounds
    on the size of these sampling errors for overpayment deficiency dollar estimates. In
    particular, we believe that the 95 percent confidence intervals for the overpayment
    deficiency estimates we present do not exceed plus or minus 20 percent of the
    estimates themselves.




                                                                                                    Page 5




                              Page 11                                     GAO-13-109 Supplemental Security Income
                               Appendix I: SSI Overpayments and Recovery
                               Presentation




Scope and Methodology (continued)




•   We conducted this performance audit from September 2011 to October 2012 in
    accordance with generally accepted government auditing standards. These 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 the evidence obtained provides a reasonable basis for our
    findings based on our audit objectives.




                                                                                                     Page 6




                               Page 12                                     GAO-13-109 Supplemental Security Income
                                                        Appendix I: SSI Overpayments and Recovery
                                                        Presentation




Summary of Results




•       Cumulative SSI overpayment debt has nearly doubled from $3.8 billion in fiscal year
        2002 to $7.3 billion in fiscal year 2011.

•       SSI overpayment debt recovery increased from $860 million in fiscal year 2002 to
        almost $1.2 billion in fiscal year 2011.

•       From fiscal year 2007 through fiscal year 2011, the unreported value of recipients’
        financial institution accounts, such as checking and savings accounts, and unreported
        wages were associated with about 37 percent or about $1.7 billion in annual SSI
        overpayments.4, 5

•       SSA lacks comprehensive, timely information on financial institution accounts and
        wages, but has developed new tools to improve its information in these areas: Access to
        Financial Institutions (AFI) and Telephone Wage Reporting (TWR).

4Amounts     are annual estimates based on 5-year averages from FY 2007 through FY 2011.
5This   estimated overpayment is based on a sample and has 95 percent confidence intervals within plus or minus 20 percent of the estimate itself.



                                                                                                                                                     Page 7




                                                        Page 13                                                         GAO-13-109 Supplemental Security Income
                                                      Appendix I: SSI Overpayments and Recovery
                                                      Presentation




Summary of Results (continued)




•      In fiscal year 2011, 75 percent of SSI overpayment debt that was recovered was
       obtained by withholding a portion of recipients’ ongoing payments. However, recipients
       can request a waiver of repayment under certain circumstances.6

•      SSA does not require supervisory review or approval for overpayment waivers of $2,000
       or less; claims representatives, who are located in SSA’s more than 1,260 field offices,
       have the authority to unilaterally approve such waivers.

•      SSA approved about 76 percent of the 276,226 SSI overpayment waivers requested by
       recipients in fiscal year 2011.

•      Management oversight of the SSI overpayment waiver decision process, including the
       trending and tracking of waiver approval rates and amounts, is limited.


6The statute required that SSA make provision to waive overpayments if the recipient is not at fault and recovering an overpayment would (1) defeat the purpose of
the SSI program, (2) be against equity and good conscience, or (3) impede the effective administration of SSI due to the small amount involved. 42 U.S.C. §
1383(b)(1)(B)(i).


                                                                                                                                                           Page 8




                                                      Page 14                                                          GAO-13-109 Supplemental Security Income
                                                     Appendix I: SSI Overpayments and Recovery
                                                     Presentation




Background




•      Since 1974, when the SSI program was established under Title XVI of the Social
       Security Act, it has provided payments to low-income aged, blind, and disabled
       persons—both adults and children—who met the financial eligibility requirements.7

        •     A disability is defined for adults as the inability to engage in any substantial gainful
              activity because of a medically determinable physical or mental impairment(s) that:

                • can be expected to result in death, or

                • has lasted or can be expected to last for a continuous period of not less than 12
                  months.8



7The  SSI program was established by the Social Security Amendments of 1972 and became effective in 1974. Pub. L. No. 92-603, §301, 86 Stat. 1329, 1465-78
(codified as amended at 42 U.S.C. §1381-1383f).
820 C.F.R. §416.905 (2012). Individuals under age 18 are considered disabled if they have a medically determinable physical or mental impairment or combination of

impairments that causes marked and severe functional limitations, and that can be expected to cause death or has lasted or can be expected to last for a continuous
period of not less than 12 consecutive months. 20 C.F.R. §416.906 (2012).


                                                                                                                                                         Page 9




                                                     Page 15                                                        GAO-13-109 Supplemental Security Income
                                                        Appendix I: SSI Overpayments and Recovery
                                                        Presentation




Background (continued)




•       In fiscal year 2012, an eligible individual or couple could have, in any month:

                  • countable income that was less than the monthly federal SSI benefit rate of
                    $698 per month for an individual and $1,048 per month for a couple, and

                  • countable resources (such as financial institution accounts) of $2,000 or less for
                    individuals and $3,000 or less for couples.

•       Recipients are required to report changes in their income and financial resources to the
        agency as soon as they occur and a penalty may be deducted from the recipient’s
        benefit if the report is not made within 10 days after the close of the month in which they
        occurred.9




920   C.F.R. §§416.708(c) and (d) and 416.714 (2012).


                                                                                                                           Page 10




                                                        Page 16                                     GAO-13-109 Supplemental Security Income
                                                        Appendix I: SSI Overpayments and Recovery
                                                        Presentation




Background (continued)




•       To determine the continuing eligibility of SSI beneficiaries, SSA conducts periodic
        “redeterminations”10 that review recipients’ non-medical eligibility factors, such as
        income, resources, and living arrangements.11

•       When an SSI overpayment is identified, the beneficiary is notified of the overpayment
        and may request a waiver of that overpayment (thus relieving the recipient of
        responsibility for repayment).12

•       SSA may grant a waiver request if the agency finds that the beneficiary was not at fault
        for the overpayment, and recovery or adjustment would defeat the program’s purpose
        (to provide basic cash payments to aged, blind and disabled persons—both adults and
        children—with income and resources below specified thresholds), be against equity and
        good conscience, or impede the effective or efficient administration of the SSI program
        because of the small amount of the overpayment involved.

10For purposes of this report, we use “redeterminations” to refer to full redeterminations as well as limited issue reviews that focus on particular factors of eligibility,
such as wages or financial institution accounts, and are selected differently.
11The amount of a recipient’s SSI benefit is determined in part by the recipient’s living arrangements—that is, the extent to which the recipient contributes to his/her

food and shelter costs on a monthly basis. 20 C.F.R §§416.420 and 416.1121(h).
1220 C.F.R.§416.550 (2012).




                                                                                                                                                                   Page 11




                                                        Page 17                                                           GAO-13-109 Supplemental Security Income
                                            Appendix I: SSI Overpayments and Recovery
                                            Presentation




Background (continued)




•      If SSA denies a waiver request, full repayment is required.13

•      If the beneficiary is currently receiving SSI or certain other SSA payments, SSA may
       withhold partial payment of these benefits to recover the debt.14

•      If no SSA payments are currently being received, or if the beneficiary asserts that the
       proposed withholding amount is too large, the agency generally permits repayment over
       12 to 36 months.

•      When an individual is no longer receiving payments, SSA can also recover debt through
       several external collection tools (fig p.13).15




1320 C.F.R. §416.560 (2012).
1420 C.F.R. §§416.570 and 416,571 (2012).
1520 C.F.R. §§416.572 and 416.580 (2012).


                                                                                                                 Page 12




                                            Page 18                                     GAO-13-109 Supplemental Security Income
                                       Appendix I: SSI Overpayments and Recovery
                                       Presentation




Background (continued)

SSA’s Debt Recovery Process (For Those Not Currently Receiving SSI Payments)




 Source: SSA officials and guidance.

                                                                                                           Page 13




                                       Page 19                                     GAO-13-109 Supplemental Security Income
                          Appendix I: SSI Overpayments and Recovery
                          Presentation




Objective One




          What are the major factors associated with SSI overpayments, and
                    what actions has SSA taken to address them?




                                                                                              Page 14




                          Page 20                                     GAO-13-109 Supplemental Security Income
                                                     Appendix I: SSI Overpayments and Recovery
                                                     Presentation




Total SSI Overpayment Debt Is Increasing




• Cumulative SSI overpayment debt nearly doubled over 10 years, from $3.8 billion to
  $7.3 billion.16
  Cumulative SSI Debt                                                              Total Annual SSI Payments




• Program participation has increased by about 18 percent, and the average payment
  made to beneficiaries has risen 23 percent over the same period.
Source: GAO analysis of SSA data.

16The  total SSI overpayment debt figures do not include the amount of overpayment dollars waived in a given year. Waived debts are total write-offs and are not
collected.

                                                                                                                                                         Page 15




                                                     Page 21                                                          GAO-13-109 Supplemental Security Income
                                                    Appendix I: SSI Overpayments and Recovery
                                                    Presentation




SSA Performs Periodic Redeterminations to Ensure the Continuing Eligibility of
Program Participants and Prevent Overpayments



• SSA uses a risk-based approach to target redeterminations to recipients most likely to
  incur an overpayment, and the majority of redeterminations in fiscal year 2011 were
  done on such recipients.

• SSA estimates that every dollar spent on redeterminations yields about $6 in program
  savings over 10 years, including savings accruing to Medicaid.17

• In fiscal year 2011, SSA conducted more than 2.4 million redeterminations—an
  increase of about 136 percent since fiscal year 2007.

• SSA estimates that the fiscal year 2011 redeterminations will prevent or recover about
  $3.2 billion in lifetime SSI overpayments.18



17Medicaid  is a state-run medical program that is federally funded and pays for medical assistance for adults and children with income and resources below
specified thresholds. 42 U.S.C. §§1396-1396w-5. Usually, a person receiving SSI is also eligible for Medicaid.
18This estimate is from SSA’s 2011 change rate study based on a random sample. Although that study did not publish confidence intervals, based on conservative

assumptions we are 95 percent confident that the actual value is within approximately plus or minus 13 percent of the estimate itself.

                                                                                                                                                     Page 16




                                                    Page 22                                                        GAO-13-109 Supplemental Security Income
                                                     Appendix I: SSI Overpayments and Recovery
                                                     Presentation




Unreported Financial Institution Accounts and Unreported Wages Were Leading
Factors Associated with Overpayments



• From fiscal year 2007 through fiscal year 2011, the unreported value of recipients’
  financial institution accounts and unreported wages were associated with about 37
  percent or about $1.7 billion in annual SSI overpayments.19
                                                      Primary Factors Associated with Overpayments




                                                                 Source: GAO Analysis of SSA data.

Note: Amounts are annual estimates based on 5-year averages from fiscal year 2007 through fiscal year 2011 and have 95 percent confidence intervals within plus
or minus 20 percent of the estimates themselves. In-kind support and maintenance is unearned, non-cash income, such as rental subsidies or food. Other real
property includes some type of real property other than the recipient’s primary residence. All other causes included life insurance, child support, and living
arrangements.
19The   sum of the dollars for particular causes exceeds the total estimated overpayment dollars due to cases having more than one overpayment cause.

                                                                                                                                                        Page 17




                                                     Page 23                                                        GAO-13-109 Supplemental Security Income
                                                       Appendix I: SSI Overpayments and Recovery
                                                       Presentation




SSA Historically Has Relied on Outdated Internal Revenue Service Data to Detect
Changes in Financial Institution Accounts



•    According to SSA figures, from fiscal year 2007 through fiscal year 2011 about 96
     percent of the approximately $1 billion in annual overpayments associated with financial
     institution accounts were made because recipients failed to report either the existence of
     financial institution accounts or increases in account balances.20, 21

•    SSA conducts periodic computer matches with the Internal Revenue Service’s (IRS)
     Form 1099 interest income data to independently verify recipients’ financial accounts
     that may not have been reported.

         •     While the match provides SSA with more information than if it relied exclusively on
               recipients to self-report their financial information, our prior work indicates that the
               IRS data can be up to roughly 2 years old by the time the match is conducted and
               the results reach SSA staff for follow-up. During this time overpayments may
               accrue and become larger.

20For reporting financial institution accounts, recipients or representative payees are required to timely report changes in resources of recipients or deemors (those

whose resources are deemed in part to be resources of the recipient, such as a parent or ineligible spouse living with the recipient). 20 C.F.R. §416.708(d) (2012).
Representative payees are persons who receive SSI payments on behalf of SSI recipients who are incapable of managing or directing the management of their
benefits. 20 C.F.R. § 416.601 (2012).
21This estimated overpayment is based on a sample and has 95 percent confidence intervals within plus or minus 20 percent of the estimate itself.




                                                                                                                                                             Page 18




                                                       Page 24                                                          GAO-13-109 Supplemental Security Income
                              Appendix I: SSI Overpayments and Recovery
                              Presentation




SSA Implemented the Access to Financial Institutions Initiative to Improve Financial
Institution Account Information


• To improve its ability to detect and verify recipients’ financial institution accounts, SSA
  implemented the Access to Financial Institutions (AFI) initiative that conducts electronic
  searches of about 96 percent of the financial institutions where SSI recipients have a
  direct deposit account.

• AFI provides the agency with independent data on a recipient’s financial institution
  accounts that SSA can utilize when determining or periodically redetermining a
  recipient’s eligibility for payments.

  • In January 2012, for example, SSA reported using AFI to identify where a recipient
    had 6 unreported financial institution accounts that each had balances of nearly
    $25,000. The recipient, however, reported having only one financial institution
    account that was under the resource limit.

• The agency completed its AFI rollout to all states in June 2011.



                                                                                                  Page 19




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                                                    Presentation




SSA Implemented the Access to Financial Institutions Initiative to Improve Financial
Institution Account Information (continued)



• The agency generally requires that AFI be used during initial claims processing and
  periodic redeterminations of program eligibility if the recipient reports $750 or more in
  liquid resources.22 For recipients who report a lesser amount of liquid resources, who do
  not report any accounts, or who fail to disclose other accounts they may have, SSA staff
  are generally not required to use AFI, but have the discretion to do so.

• According to SSA officials, it would not be possible to expand the use of AFI to
  periodically match the SSI rolls against a comprehensive financial institution accounts
  database because no such database exists. In addition, such a match would require
  greater staff resources to follow up on any discrepancies that could result from the
  match and determine how the information would affect the recipients’ eligibility for
  payments.

• SSA projects that if AFI’s current account verification process is used on a long-term
  basis, fiscal year 2013 verifications would yield an estimated $365 million in lifetime
  Federal SSI program savings consistent with a return on investment of $9 to $1.23
22AFIis also used for other situations, such as when an SSA data match identifies a discrepancy that needs to be reconciled.
23SSA officials reported that in fiscal year 2013, the agency plans to conduct more rigorous checks of alleged financial assets using the AFI process dependent
upon adequate resources.
.
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                                                     Presentation




SSA Lacks Timely Information on Recipients’ Wages




 • According to SSA figures, from fiscal year 2007 through fiscal year 2011, about 90
   percent of the approximately $671 million in overpayments resulting from wages were
   made because recipients failed to report their monthly earnings.24, 25

            •     For example, we found that a recipient received an overpayment of $3,695 due to
                  unreported wages that were earned over a year and a half.

 • In addition to recipient reported wage information, SSA uses independent data from
   certain federal databases to detect wages.

            •     SSA also conducts semiannual data matches between SSI records and the
                  annual wage data in the agency's Master Earnings File (MEF).26 The MEF data
                  can be up to 1-2 years old, however, when SSA field offices are notified of
                  detected wages that need to be reconciled.
 24Recipients   and representative payees are required to timely report changes in income of recipients and deemors. 20 C.F.R. § 416.708(c) (2012).
 25This   estimated overpayment is based on a sample and has 95 percent confidence intervals within plus or minus 20 percent of the estimate itself.
 26The    Master Earnings File is an SSA database that includes IRS Form W-2 wage data.


                                                                                                                                                       Page 21
 .




                                                     Page 27                                                        GAO-13-109 Supplemental Security Income
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                                                    Presentation




SSA Lacks Timely Information on Recipients’ Wages (continued)




        •       The agency conducts quarterly matches between SSI records and the National
                Directory of New Hires’ (NDNH)27 quarterly wage data. While the wage information
                obtained from this match is significantly more timely than the information obtained
                from the IRS data match, the NDNH data can be about 6 months old when SSA field
                offices are notified of the detected wages that need to be reconciled.

•       During an initial application or SSI redetermination, SSA staff generally verify wages
        reported by applicants and recipients, or detected by SSA by obtaining additional
        information, such as the applicant’s or recipient’s pay slips or information from
        employers.

            •    SSA staff can use wage verification companies, such as The Work Number,28 to
                 verify recipient wages. These companies provide wage information to SSA for
                 participating employers rather than SSA contacting the specific employer.

27The Department of Health and Human Services’ Office of Child Support Enforcement’s NDNH contains quarterly state wage information, which is more recent than
the annual wage information that SSA obtains through its current IRS data match.
28The Work Number is a national payroll provider with wage information for over 2,000 participating employers. SSA recently obtained immediate online access to
wage information from The Work Number.


                                                                                                                                                     Page 22




                                                    Page 28                                                       GAO-13-109 Supplemental Security Income
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                             Presentation




SSA Lacks Timely Information on Recipients’ Wages (continued)




    •   Staff also have online access to databases, including NDNH or SSA’s Master
        Earnings File, and access to the agency’s online verifications with The Work
        Number to investigate individual instances of potentially unreported wages. These
        sources provide amounts of quarterly or annual wages as a way to verify
        recipients’ monthly wages. As previously discussed, the information obtained from
        these sources can range from 6 months to 2 years old.




                                                                                                 Page 23




                             Page 29                                     GAO-13-109 Supplemental Security Income
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                                                  Presentation




SSA Implemented the Telephone Wage Reporting System to Improve Wage Data,
but Its Use Is Limited



•    To help improve its ability to gather information on recipients’ wages, SSA implemented
     the Telephone Wage Reporting (TWR) system in fiscal year 2008 to allow recipients to
     call into an automated telephone system to report their monthly wages.29

•    SSA officials reported that the TWR system should ease the burden of reporting wages
     for some recipients and save time for SSA staff since wage data will be input directly
     into SSA’s computer system.

•    TWR is one of several options to report wages (e.g., calling a field office or teleservice
     center, or mailing or bringing pay slips to a field office).

•    While a TWR pilot conducted in 2003 found that recipient self-reported wage
     information was 92 percent accurate, the pilot did not provide information concerning
     the accuracy of self-reported wage information for recipients opting not to use TWR for
     comparison purposes.

29SSA verifies wages reported through TWR during a redetermination in certain circumstances, such as when data matches comparing recipient records and federal
databases on wages show differences in amounts of wages.

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                                                  Page 30                                                       GAO-13-109 Supplemental Security Income
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                               Presentation




SSA Implemented the Telephone Wage Reporting System to Improve Wage Data, but
Its Use Is Limited (continued)



 •   The TWR pilot also differed from the agency’s current wage verification practices in that
     SSA staff verified wages at the end of the pilot for all participants, while recipient wage
     information submitted through TWR is generally not verified during a redetermination.

 •   TWR has several limitations that restrict its effectiveness. For example, TWR

      • relies on self-reported data, which GAO has found to be a key vulnerability leading
        to overpayments.

      • is not intended or appropriate for all recipients with wages, including recipients who
        speak in a foreign language or who are unable to follow simple directions, and only
        a limited number of recipients have used the system, according to SSA officials.

      • is unable to process wage information for individuals who work for more than one
        employer.


                                                                                                   Page 25




                               Page 31                                     GAO-13-109 Supplemental Security Income
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                                                         Presentation




    SSA Implemented the Telephone Wage Reporting System to Improve Wage Data, but
    Its Use Is Limited (continued)



    •       The SSA officials we interviewed said that they do not have plans to address language
            barriers, and did not know the extent of recipients with wages who were excluded from
            TWR due to various technological limitations.30

    •       According to agency officials, the monthly use of the TWR system increased to over
            36,000 successful wage reports per month, for September 2012.31

    •       SSA estimates that about 600,000 recipients and deemors32 have wages.

    •       SSA officials reported that to increase the volume of representative payees who report
            wages via the TWR program, the agency mailed over 30,000 TWR recruitment notices
            to representative payees of SSI recipients in September 2012, asking them to use the
            TWR program to report the recipient’s monthly wages to the agency. As a result, SSA
            hopes that at least 4,800 representative payees will use TWR in fiscal year 2013 in at
            least 1 month.
    30Forthose unable to report wages by telephone using TWR because of the language barrier, SSA provides interpreter services through a toll-free telephone
    number.
    31One caller may make more than one wage report, such as a representative payee who handles payments for more than one working recipient. Representative

    payees are persons who receive SSI payments on behalf of SSI recipients who are incapable of managing their finances.
    32Deemors are individuals whose resources are deemed in part to be resources of the recipient, such as a parent or ineligible spouse living with the recipient.




.                                                                                                                                                           Page 26




                                                         Page 32                                                         GAO-13-109 Supplemental Security Income
                              Appendix I: SSI Overpayments and Recovery
                              Presentation




SSA Implemented the Telephone Wage Reporting System to Improve Wage Data, but
Its Use Is Limited (continued)



•   SSA officials told us that the agency is developing a smart phone wage reporting
    application known as the SSI Mobile Wage Reporting (SSIMWR) to allow SSI recipients
    to report their wages via smart phones. According to SSA officials, this mobile
    application will serve as another alternative for representative payees, SSI recipients,
    and deemors, to report SSI wages.

•   SSA officials also reported that the agency plans to conduct a 6-month rollout of the
    SSIMWR application to 50 SSA field offices nationwide, and hopes that SSI recipients,
    deemors, and representative payees will be able to submit their wages using the
    application beginning in December 2012.




                                                                                                  Page 27




                              Page 33                                     GAO-13-109 Supplemental Security Income
                           Appendix I: SSI Overpayments and Recovery
                           Presentation




Objective Two




 What is known about SSA’s recovery of overpayments from SSI recipients, including
                   those not currently receiving SSI payments?




                                                                                               Page 28




                           Page 34                                     GAO-13-109 Supplemental Security Income
                               Appendix I: SSI Overpayments and Recovery
                               Presentation




Detection and Recovery of SSI Overpayment Debt Has Increased Over the Last 10
Years




From fiscal year 2002 to          Detection and Recovery of SSI Overpayments, Fiscal Years
2011:                             2002- 2011

• New SSI overpayments
  detected increased by 28
  percent from $2 billion to
  $2.6 billion.

• SSI overpayments
  recovered increased by 36
  percent from $860 million
  to $1.2 billion.




                                                       Source: GAO analysis of SSA data


                                                                                                          Page 29




                               Page 35                                            GAO-13-109 Supplemental Security Income
                                                     Appendix I: SSI Overpayments and Recovery
                                                     Presentation




Debt Recovery Options Depend on Whether an Individual Receives Payments




•     In fiscal year 2011, SSA reported that:

         •     75 percent of the SSI overpayment debt that was recovered—approximately $874
               million—was recovered by withholding some portion of the recipients’ ongoing Title
               XVI (SSI)33 or Title II (OASDI) payments.

                  •     Of that amount, approximately 65 percent of the SSI overpayment debt was
                        recovered by withholding SSI payments and 10 percent by withholding Title II
                        payments.34

         •     about 25 percent of the SSI overpayment debt that was recovered—about $298
               million—was recovered through SSA’s use of external collection tools.



33 The statute limits the SSA’s ability to collect overpayments from SSI recipients to the lesser of the benefit amount for the month or 10 percent of the recipient’s

income for the month federal benefit rate or the entire benefit if it is less than 10 percent of the full rate. 42 U.S.C. §1383(b)(1)(B)(ii).
34 Some individuals are dually entitled to SSI under Title XVI of the Social Security Act (42 U.S.C. §§ 1381-1385) and Old-Age, Survivors, and Disability Insurance

under title II of the act (42 U.S.C. §§401-434).


                                                                                                                                                            Page 30




                                                     Page 36                                                           GAO-13-109 Supplemental Security Income
                              Appendix I: SSI Overpayments and Recovery
                              Presentation




Debt Recovery Options Depend on Whether an Individual Receives Payments
(continued)



• External debt collection tools include:

  •   tax refund offset, which withholds or reduces federal tax refunds;

  •   federal salary offset, which withholds or reduces wages and payments to a federal
      employee;

  •   administrative offset (against other than SSA payments), which withholds or reduces
      federal payments other than tax refunds or salary;

  •   administrative garnishment of wages and payments from private employers or state
      and local governments;

  •   credit bureau referral, which refers delinquent accounts to credit bureaus.




                                                                                                  Page 31




                              Page 37                                     GAO-13-109 Supplemental Security Income
                          Appendix I: SSI Overpayments and Recovery
                          Presentation




SSI Overpayment Recovery Tools and Results, Fiscal Year 2011




• SSA’s primary tools    SSI Overpayment Recovery Efforts                                   Use of External Collection Tools
                                   (in millions of dollars)
  for recovering SSI                                                                               (in millions of dollars)

  overpayment debt
  are the withholding
  of SSA payments,
  the withholding of
  Title II (OASDI)
  payments, and
  through the
  Treasury Offset
  Program for
  individuals who are
  not receiving SSA
  payments.
                           Source: GAO analysis of SSA data.
                           a: Treasury Offset Program includes refund recovery and credit bureau reporting
                           b: Other tools include refund recovery, and other collections.




                                                                                                                              Page 32




                          Page 38                                                            GAO-13-109 Supplemental Security Income
                                                    Appendix I: SSI Overpayments and Recovery
                                                    Presentation




SSA Grants Most SSI Overpayment Waiver Requests, and Waiver Documentation
and Oversight Is Limited



 • In fiscal year 2011, SSA approved approximately 76 percent of recipients’ requests to
   waive their SSI overpayment debt.

 • SSA’s Program Operations Manual System gives claims representatives located in the
   agency’s approximately1,260 field offices the authority to waive overpayment amounts
   up to $2,000 without supervisory review and approval.

 • However, the standards for internal control in the federal government35 state that federal
   agencies must ensure that no one individual controls all key aspects of a transaction or
   event.




 35The standards for internal control in the federal government provide the overall framework to assist federal agencies in establishing and maintaining internal
 control and for identifying and addressing major performance and management challenges and areas at greatest risk of fraud, waste, abuse, and mismanagement.
 GAO, Standards for Internal Control. GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999).


                                                                                                                                              Page 33




                                                    Page 39                                                        GAO-13-109 Supplemental Security Income
                                    Appendix I: SSI Overpayments and Recovery
                                    Presentation




SSA Grants Most SSI Overpayment Waiver Requests, and Waiver Documentation
and Oversight Is Limited (continued)



 • Moreover, SSA claims representatives may, on behalf of the agency, waive an
   overpayment debt only if the liable individual is without fault in causing the
   overpayment, and recovery or adjustment would:

            • defeat the purpose of the program,

            • be against equity and good conscience, or

            • impede effective or efficient administration of Title XVI of the Social Security Act
              because of the small amount involved.36




 3642   U.S.C. §1383(b)(1)(B)(i).


                                                                                                         Page 34




                                    Page 40                                     GAO-13-109 Supplemental Security Income
                              Appendix I: SSI Overpayments and Recovery
                              Presentation




SSA Grants Most SSI Overpayment Waiver Requests, and Waiver Documentation
and Oversight Is Limited (continued)



• However, in fiscal year 2011, a high number of waiver requests were granted even
  though many recipients or their representative payees failed to fulfill their financial
  institution account and wage reporting responsibilities.

  • The amount of SSI overpayment dollars waived has risen 38 percent, from $122
    million in fiscal year 2008 to $167 million in fiscal year 2011, and

  • The average amount of an overpayment waiver granted has risen about 20 percent,
    from $665 in fiscal year 2008 to $795 in fiscal year 2011.




                                                                                                  Page 35




                              Page 41                                     GAO-13-109 Supplemental Security Income
                              Appendix I: SSI Overpayments and Recovery
                              Presentation




SSA Grants Most SSI Overpayment Waiver Requests, and Waiver Documentation
and Oversight Is Limited (continued)



 • SSA monitors some management information data and conducts limited oversight of the
   waiver process. For example, the agency:

   • retains recipients’ waiver information in individual records,

   • tracks the number of waivers requested and granted nationally and by SSA region,
     and

   • conducts a limited quality review of approved waivers to identify cases where field
     office staff and regions have improperly granted waivers.




                                                                                                  Page 36




                              Page 42                                     GAO-13-109 Supplemental Security Income
                             Appendix I: SSI Overpayments and Recovery
                             Presentation




SSA Grants Most SSI Overpayment Waiver Requests, and Waiver Documentation
and Oversight Is Limited (continued)



• The agency, however, does not routinely:

  • analyze collected SSI waiver data to identify potential negative trends in the
    application of SSA’s waiver requirements, such as:

      • the type, number, and dollar value of the waivers granted, including those waivers
        below the $2,000 approval threshold that SSA staff can unilaterally approve, and

      • whether there are waiver patterns specific to SSA offices, regions, or individual
        staff.




                                                                                                 Page 37




                             Page 43                                     GAO-13-109 Supplemental Security Income
                              Appendix I: SSI Overpayments and Recovery
                              Presentation




Conclusions




• SSA has made progress in improving SSI program integrity through the increased use of
  redeterminations to detect and prevent overpayments, the AFI initiative to obtain more
  accurate information on recipients’ financial institution accounts, and its continued efforts
  to obtain more timely recipient wage information.

• The agency’s efforts to recover identified overpayment debts, however, are constrained
  by SSA policies and criteria that allow claims representatives to unilaterally waive the
  repayment of overpayment amounts up to $2,000 without supervisory review and
  approval, and SSA’s lack of comprehensive management information with which to
  oversee the waiver process through the tracking of waiver approval rates, amounts, and
  patterns specific to SSA offices, regions, or individual staff.

• Federal agencies must have controls in place to ensure that no individual can control all
  key aspects of a transaction or event.

• Without the necessary oversight and controls in place, SSA will be unable to identify
  trends in the waiver process that could jeopardize the agency’s ability to maximize its
  overpayment recovery efforts and safeguard taxpayer dollars.
                                                                                                  Page 38




                              Page 44                                     GAO-13-109 Supplemental Security Income
                             Appendix I: SSI Overpayments and Recovery
                             Presentation




Recommendations




To enhance SSA’s ability to recover SSI overpayment debt, we recommend that the
Commissioner of Social Security

    •    Review the agency’s policy concerning the supervisory review and approval of
         overpayment waiver decisions of $2,000 or less, to determine if the policy is still
         appropriate given that federal agencies must have controls in place to ensure that
         no individual can control all key aspects of a transaction or event. Such a review
         should include collecting the information needed to determine the impact of this
         policy on the agency’s financial stewardship of SSI program dollars.

    •    Explore ways to strengthen the agency’s oversight of the overpayment waiver
         process through the analysis of data to identify waiver trends, such as approval
         rates, amounts, and patterns specific to SSA offices, regions, or individual staff
         that the agency may wish to track more closely.




                                                                                                 Page 39




                             Page 45                                     GAO-13-109 Supplemental Security Income
Appendix II: Comments from the Social
              Appendix II: Comments from the Social
              Security Administration



Security Administration




              Page 46                                 GAO-13-109 Supplemental Security Income
Appendix II: Comments from the Social
Security Administration




Page 47                                 GAO-13-109 Supplemental Security Income
Appendix III: GAO Contact and Staff
                  Appendix III: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  Daniel Bertoni, (202) 512-7215 or bertonid@gao.gov
GAO Contact
                  Jeremy Cox (Assistant Director) and Arthur T. Merriam Jr (Analyst-in-
Staff             Charge) managed all aspects of this assignment. James Bennett, Jessica
Acknowledgments   Botsford, David Chrisinger, Danielle Giese, Jason S. Palmer, Mark
                  Ramage, Matthew Saradjian, Vanessa Taylor, Walter Vance, Craig
                  Winslow, and Jill Yost made significant contributions to this report.




(131123)
                  Page 48                               GAO-13-109 Supplemental Security Income
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