oversight

Social Security Administration: Information on Monitoring 800 Number Telephone Calls

Published by the Government Accountability Office on 1997-12-08.

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

      UnitedStates
GAO   GeneralAccomtingOffIce
      Wmhin#on,D.C.20648


                                                                                            w


      B-278086                                                                              -’   I




      December8, 1997
      The Honorable Barbara B. Ke~elly
      Ranking Minority Member, Subcommittee on Social Security
      Committee on Ways and Means
      House of Representatives
      Subject: Social Securitv AdminWration: Information on Monitoring 8OQ
               Number Telenhone Calls

      Dear Ms. Ke~elly:

      In 1988,the Social Security AdmirU&ion (SSA) establisheda toll-free 800
      number to improve the public’s abihty to contact SSA by telephone. The public
      can reach SSAthrough that number from anywhere in the country. Teleservice
      representatives(TSR) at the 800 number answer beneficiary inquiries, schedule
      appointments,and correct benefit records.

      Public use of the 800 number grew from more than 41 million calls in fiscal
      year 1989to more than 76 million in fkxal year 1997. As of January 1997,SSA
      employed more than 4,000 TSRs at 37 teleservice centers (‘IX) throughout the
      country. On high-volumedays, an additional 2,460technical staff are available
      to assist TSRsin answering 800 number calls. These employeesare known as
      “Spikes”becausethey provide this support on the busiest days with the highest
      peaks, or spikes, in call volume.
      SSAmonitors its 800 number telephone calls to ensure,good customer service
      under a program referred to as Senriceobsetion, in which SSA employees -
      listen to TSRs during their calls. The purpose of this observation is to assess
      the accuracy and courtesy of the ‘ISRs who provide information to the public,
      to identi@ training needs, and to gather statistical information on calls received.

      In July 1997,the SSA Office of the Inspector General (OIG) issued a report that
      criticized SSA’sservice observation program.’ This report stated that the
      program did not fully comply with federal laws and regulations, in part because

      ‘See SSA, Office of the Inspector General: The Social Securitv Administration’s
      Program for Monitoring the Qualitv of Telenhone Service Provided to the
      Public, A-13-96-52001 (Baltimore, Md.: July 1997).
                                       GAO/HEHS-98456R SSA 800 Number Calls
the OIG questioned whether SSA had properly obtained the consent of the
public or its employees for its observation during calls. _The report also
criticized SSA for not adhering to a regulation that had been designedto ensure
proper monitoring practices. However, when the OIG’s report was published,
this regulation was no longer in effect.2 Given your concern about protecting
the privacy of the public and of SSA employees,you asked us to answer the
following questions: (1) What do the laws and regulations require and what has
SSA done to gain consent for telephone monitoring from the public and its
employees? (2) To what extent is SSA following private industry’s best
practices for telephone monitoring? To respond to your request, we reviewed
and analyzed relevant laws and regulations, and we located best practices in
telephone monitoring. We also interviewed SSA officials, a representative of
the American Federation of Government Employees (AFGE), and SSA members
of an interagency team that conducted a study of best practices in telephone
service. We conducted our review in accordance with generally accepted
government auditing standards from September through December 1997.
In summary, we found that under current law, SSA cannot monitor telephone
calls unless its monitoring practices fall within a statutory exception. One
exception generally relates to the type of telephone equipment provided to a
business and whether it is used for businesspurposes. Another exception
requires the consent of at least one party to a conversation. The OXGdid not
determine whether SSA meets the first exception, but SSA believes it does.
Also, the agency has taken steps to gain consent for telephone monitoring born
the public and its employees. SSA has negotiated agreementswith AFGE to
more often notify employees when particular calls will be monitored and has
added a recorded messageto its 860 number to notify callers that their calls
may be monitored? SSA is also developing a new regulation that will formally
notify its employees and the public of its monitoring practices. Regarding best
practices, there are some similarities and differences between SSA’stelephone
monitoring practices and those idenaed in a key study of private companies

!Ihe statutory basis for this regulation was repealed effective August 8,1996,
and, effective the same date, the General ServicesAdministration (GSA)
specifically removed this regulation from the Code of Federal Regulations.
However, the OIG reported that this regulation was still relevant to the study
because it provided guidance for monitoring practices and becauseSSA officials
told OIG officials that the agency planned to continue to follow the regulation
until SSA’sown regulation is developed. -*
3As of November 21, 1997, SSA’srecorded messagewas not yet reaching all 800
number callers who spoke directly to a representative. SSA officials told us
that they are looldng at options to resolve this issue.

2                                GAOMEHS-98-66B SSA800 NumberCalls
B-278085
considered to be the best in the 800 number business. For example, the
approach SSA supervisors use to monitor TSR calls and the approach managers         .-
use to monitor broader unit-level performance are sin-& to private sector best           I
practices. Finally, SSA’s approach to quality monitoring differs from private
industry’s best practices. Rather than immediate supervisors’ performing the
quality monitoring function, SSA maintains a separate unit to monitor for
quality to ensure that benefits are paid accurately.

REQUIREMENTS FOR TELEPHONE MONITORING
AND SSA ACTIONS TO GAIN CONSENT

Current law limits federal agencies when they monitor telephone calls. The
Omnibus Crime Control and Safe Streets Act of 1968 prohibits intercepting
telephone conversations by electronic or mechanical devices except under
certain exceptions4 Under the business-use exception, telephone monitoring is
permitted in a business setting when the telephone equipment is provided by
the telephone company in the ordinary course of business and is used for
monitoring business-related calls. Under the consent exception, intercepting
telephone conversations is permitted when at least one party to the
conversation consents, either explicitly or implicitly, to the monitoiing of the
Cdl.

The July 1997 OIG report did not determine whether SSA met the business-use
exception for its telephone monitoring program, but it raised questions about
whether SSA had gained the consent of either the public or its employees. At
the time of the OIG audit, SSA’s practice was to notify SSA customers and the
public of its service observation program through statements in documents and
pamphlets it distributed. The OIG did not believe that this practice ensured
that every person who called SSA had implicitly consented to being monitored.
Also, the OIG questioned whether SSA had obtained the consent of its
employees because it did not notify them every time it monitored their calls.
The OIG cited language in a memorandum of understanding between SSA and
AFGE that stated that an employee’s using a telephone that was subject to
service observation would not be construed as the employee’s consenting to
being observed.

SSA officials told us that they believe their monitoring of telephone calls would
fall under both exceptions. Regarding the consent exception, SSA officials said
that SSA can infer that callers have given their consent through the pamphlets
it distributes to SSA customers and the public. ln addition, SSA officials said
that they notify their employees of the monitoring program by designating the


‘18 U.S.C. Sets. 2510-2522.

3                                 GAOIHEHS-98-56R SSA 800 Number Calls
B-278086
telephones and telephone lines that will be monitored and by engaging in
extensive negotiations with AFGE representatives on the procedures for
telephone monitoring. SSA believes that employees who remain in their
positions while they know that monitoring is a condition of their employment
and who use the designatedequipment have implicitly consented to monitoring.

SSA officials disagree with the emphasisthe OIG’s report gives to the statement
in the memorandum of understandingthat an employee’susing a telephone that
was subject to observation would not be construed as the employee’s
consenting to being observed. Officials pointed out that the purpose of the
memorandum is to set forth the parties’agreementthat monitoring will occur
only under specified conditions. In addition, SSA officials said that they have
changed the agency’sservice observation program in recent years. In 1996, SSA
officials agreed to notify TSRSbefore immediate supervisors monitor their
calls! This change was made as a result of cooperative efforts between SSA
managementand national officials of AFGE.
SSA Is Notif@ingthe Public
The OIG concluded that its concern over whether SSA had gained consent for
telephone monitoring would be satisfied if SSA modified the memorandum of
understanding or included a messageon the 800 number requesting callers to
consent to monitoring. In October 1997,SSA instituted a recorded messageon
its 800 number designedto notify all callers who speak live to representatives
of the telephone monitoring program! The messagestates, “To ensure that you
receive accurate and courteous service, your call may be monitored.” SSA
officials told us that they chose to provide this notice to callers in order to
better inform the public of its monitoring program. They also stated that many
major businessesuse such messages. A recent survey of SSA’sregional offices
showed support for the message. SSA estimates that it wUl cost approximately
$393,000per year to extend the length of the automated menu and about
$361,000per year to pay for the time TSRs will spend talking to the callers who
ask questions about the message.


sEmployeesare still sometimes not notified in advance, as when TSRs have
exhibited conduct problems or when unit managersmonitor calls to assess
overall unit operations. These instances are discussedlater in this letter.
% its 800 number service, SSA provides a;( extensive menu of automated
options from which callers may choose. The agency intends to provide
notification of monitoring to all callers who opt to speak to a live
representative (about 86 percent of the callers).
4                                GAO/HEHS-98-66R SSASOONumber Calls
B-278085

Even this new step to inform the public may not be reaching all callers. We
made a small number of test calls and, depending on the menu selections we
made, found that we did not consistently receive the new recorded message.
SSA is aware of this problem and is analyzing how it may be corrected.

SSA Is Drafting New Regulations

Until August 1996, a regulation promulgated by GSA and known as the Federal
Information Resources Management Regulation (FIRMR) governed the
government agency practice of listening in on or recording telephone
conversations.’ The OIG criticized SSA for not complying with provisions in
this regulation that detailed the controls, policies, and procedures needed for
agencies’proper public service monitoring. However, effective August 8, 1996,
the Information Technology Management Reform Act repealed the statutory
authority for the regulation.* Accordingly, GSA removed J?iRMR from the Code
of Federal Regulations9

In the absence of a regulation to guide telephone monitoring throughout the
government, SSA concluded that it should promulgate its own regulation. This
regulation is now in draft Officials told us that with some exceptions, they
used F’IRMR as a basis for their draft When it is final, this regulation will
formally notify SSA employees and the public of the agency’s monitoring
practices. Until then, SSA may choose to use aspects of FIRMR as guidance.




‘GSA was authorized to regulate many aspects of electronic equipment
procurement and use for the federal government under section 111 of the
Federal Property and Administrative Services Act of 1949, as amended
(40 U.S.C. Sec. 759) commonly known as the Brooks Act. FIRMR is in 41
C.F.R. Chapter 201.

‘See Defense Authorization Act, P.L. 104-106, Division E, Sec. 5101.
%e OIG report also criticized SSA for having iimited or no controls to ensure
that telephone monitoring is being used for its authorized purpose, as required
under Office of Management and Budget Circular A-123. For example, the OIG
reported that SSA does not maintain a record, or audit trail, of the calls
monitored and lacks adequate controls to prevent unauthorized monitoring.
SSA has analyzed these issues and responded to the OIG, however, we did not
analyze these issues in this letter because they were beyond the scope of our
work.

5                                 GAOLEEHS-98-56R SSA 800 Number Calls
B-278086
COMPARISONOF SSA CALL-MONlTORING
PRACTICESWlTH PRIVATE SECTORBEST PRACTICES
Telephone monitoring is an accepted and common practice among businesses
that provide telephone tices.    The National Performance Review’s (NPR)
                                                                        .
February 1996 report entitled Serving the American Public: Best l%acttces    in
Telephone Service identified a set of best practices for service observation, and
SSA follows some of these,notably when supervisors perform service
observation.lo However, SSA has decided not to follow the industry best
practices that the agency has determined are not consistent wlth its public
mandate.

The study team for the NPR report, composed of staff from SSA and nine other
federal agencies,reviewed the operations of eight companies that have been
considered the best in the 800 number business, or world class, by their
customers and found an amazing degree of simihuity among the industry’s
best.” Study participants told us that the culture of an organization affects its
Venice observation approach. The study found that worldclass telephone
service companies
- have a strong corporate culture that focuses on customers,
- view their frontline workers as the primary link to these customers, and
- strive to create a climate that fosters trust, teamwork, and shared
  communication.
Given these features, world&ass telephone service companies conduct service
observation of customer calls in au open and supportive environment.

The specific best practices for service observation can be grouped by type of
observation: supervisory, unit, or quality assurance. Table 1 identifies the type
and purpose of the observation and the related best practices.



?‘he NPR report was based on a benchmarking study conducted by a federal
consortium under the direction of NPR. Study team members surveyed world-
class customer service telephone operations to identify practices that can be
applied in government to raise the level of service to equal the best in business.
It identified a whole set of best practices, of which those dealing with
monitoring calls are only a part. We did riot validate these practices.
“n\e eight companies were American Express Travel Related Services, AT&T
Universal Card Services, Bell Canada,Citibank, Duke Power Company, GE
Answer Center, Saturn Corporation, and USAA Insurance.

6                                 GAOMEHS-9%66R SSA 800 Number Calls
R-278086
                                         .
Table 1: Kev Service Obsemtion Rest Practrces in World-Class Comnanies

    Type and purpose of                Key best practice
    observation
    Supervisory obsemon:               Focus is on an open and constructive
    - to assesshow well frontline      relationship between supervisors and frontline
      workers are serving              workers. Supervisors offer constructive and
      customers                        immediate feedback.’ Monitoring is both remote
    - to identify training needs as    and side by side, although we were told side-by-
      part of a continuous             side monitoring is believed to be the more
      improvement effort               effective.
    Unit observation: to collect   Unit managers regularly listen in on live calls in
    information on how well a call order to stay in touch with customers and
    center or unit is performing   monitor the effectiveness of a center’s
                                   operations.
    Quality assurance                  Quality assuranceis performed by means of
    observations: to assessthe         supervisory observation. World-class companies
    accuracy and quality of            have moved away from using a separate,formal
    program operations                 quality-monitoring group for service observations.

The next section gives a more detailed list of the supervisory observauon best
practices.
@A’s Practices for Suuervisorv Observation Are Similar to Rest Practices
SSA’scurrent practices for supervisory review of TSRs are similar to the best
practices identified in the NPR report.12 In fact, some of S&I’s current
practices for supervisory observation are guided, in part, by the NPR study.
SSA formed a work group to discuss the lessons learned from the study and
how well S&I’s telephone service compared with that of the companiesthe
NPR team visited. As a result, SSA signed an agreement with AFGE in 1996to
include some of the best practices in its service observation program. Table 2
compares the best practices for supervisory observations with SSA’scurrent
practices.



‘%~pervisory observation is conducted for TSRs only. Spikes are excluded at
this time, although SSA officials told us that they would like to include Spikes
in the future.


7                                     GAO/HEHS-98-66B SSA800 Number&Us
        B-278086
        Table 2: Comnarison of Rest Practices for Sunetisorv Observation With SSA
        -                                                    __


Rest practices for supervisory observation SSA’spractices for supervisory
                                           observauon
The purpose of supervisory observation is The purpose of supervisory observation is
to identify training needs and provide    to assessthe training needs of the TSR
coaching or helpful suggestionsfor        and to ensure courteous, accurate, and
improving service                         professional service without a punitive
                                          environment
Observations are not necessarily linked to     Observationsare not linked to individual
performance assessment                         performance appraisals
Supervisor or coach typically monitors 5       Supervisor monitors l-6 calls per
10 calls per frontline worker per month        experienced TSR per month; for trainees
                                               (workers with less than 1 year of
                                               experience), supervisors may monitor an
                                               unlimited number of calls
Workers are to receive immediate               Workers are to receive immediate
feedback                                       feedback
Observation may be made from remote            Workers are notified in advance and given
locations or side by side, but side-by-side    a choice of remote or side-by-side
observation is seen as the most effective      observation; unannouncedobservation is
way to foster open communication               permitted only for workers who have
                                               conduct problems

        While world-class companies observe calls either from a remote location or side
        by side, the NPR study participants we talked to emphasizedthat side-by-side
        monitorjng was seen as the most effective way to provide immediate and useful
        feedback and to foster open communication with employees. Before the 1996
        agreement with AF’GEto change certain observation practices, SSA’s
        observation of TSRs did not provide for side-by-sideobservation. Monitoring
        was remote, workers were not informed in advance,feedback was given within
        24 hours, and the monitoring was used for performance appraisals. The focus
        of observation was on identifying errors that related to whether TSRs
        conformed to operating procedures. Ac&ding to SSA and union officials, this
        approach did not foster trust and open communication.



         8                                    GAOIHEHS-98-66B SSA 800 Number Calls
B-278086
In addition to their supervisory monitoring, team leaders in the world-class
companies listen to live calls as a group, score the calls-individually, and then
compare their scores to ensure consistency of measurement. SSA does not
currently follow this best practice, nor does it plan to in the near future,
according to an SSA official.
                           .
    ts Unit-Level Obsexvauons                              .
                                Are similar to Rest Practrces

SSA’sobservations at the TSC or unit level are similar to the best practices
listed in table 1.13In the companies studied by the NPR team, unit managers         f
regularly listen in on live calls in order to stay in touch with customers and to
monitor the effectivenessof a center’s operations. In SSA, supervisors and          r,
managers at TSCs monitor calis in order to obtain aggregatedata and stat&i&
information on a particular type of call or to assesstraining needs at the local
‘ISC or other SSA unit. The information collected is also used to assesshow
well the unit is meeting the public’s needs. This type of observation is not to
be used to assessindividual employee performance.
                                                                                    i
Despite the simiMty between SSA’sunit-level call monitoring and best
practices, an SSA union represent&ve told us that she believes that this call
monitoring is subject to abuse shxe it is unannounced,remote, and performed
at the discretion of the managersand supeMsors. Workers fear that unlike
supervisory monitoring, which must be announced, managers could use this
type of obsewahionto inappropriately monitor TSRs. An SSA official told us
that SSA is working with union representatives to develop controls to ensure
that this monitoring approach is not used inappropriately. For example, they
are developing procedures that will allow for the random selection of the
particular calls to be monitored. They plan to implement this process after the
peak calling seasonin 1998.
                                  .                          .
SSA’s Qualitv Assurance ObservauonDiffers From Rest Practrces
SW% service observationsfor agencywide quality assurance differ from best
practices. According to the NPR report, world-class organizations ensure
quality control by making regular supervisory observations. These
organizations have moved away from using a separate, formal quality-
monitoring group for service obsmons; separate groups have been dissolved.
In SSA, the Office of Program and Integrity Review (OPIR), a separate entity,
performs service observationsfor the purpose of quality assurance.


%pikes are included in this level of observation, and managers may monitor
calls for a particular ‘EC or for an SSA unit where Spikes are located.
                                  GAO/HEHS-98-66B SSASOO NumberCaDs
B-278086
The purpose of OPlR’s service observation is to assessthe accuracy and quality
of 800 number telephone service, and the focus is on regional and national T!3C
performance.” Data are collected on the reason for and type of calls, the
accuracy of the information TSRs give, benefit programs involved, and TSR&
types of response and courtesy. Quality observation is unannounced, and the
results are not to be used to assessindividusl performance. SSA officials told
us that the agencyneeds a separate formal quality group to ensure that services
are consistent with SSA policies on a regional and national level and that callers
receive highquality service. SSA officials told us that since TSRs give callers
vital information that may affect their eligibility for or level of benefits, giving
accurate information is part of their responsibility to help the public and to
safeguard the SSAtrust funds. SSA has no current plans to eliminate this type
of monitoring. In fact, SSA recently entered into a new agreement with APGE
to conduct a pilot study in which OPIR will monitor calls to 60 of SSA’sfield
offices.
In world&ass organizations,not only do supervisors provide feedback on how
well workers are serving the customer; the organizations also collect customer
feedback on the service that has been provided by conducting postcall mail and
telephone surveys. Customer responsesare shared with the &ox&line workers
who handled the calls so that they may better understand a customer’s point of
view, and the responsesbecome part of a worker’s performance assessment.
SSA’sOPIR conducts ongoing evaluations of the SSA’s 800 number service
through semiannualrecontact surveys of callers’experience and satisfaction
with the300 number se.Mce. However, SSA does not yet collect suffMent
information at the time of a call to link a survey response to the individual TSR
who handled the call. Thus, the results of these surveys cannot be used to
provide feedback to individual ‘ISRs.16
AGENCY COMMENTS

We obtained written comments from SSA on a draft of this report, and we have
incorporated the agency’scomments where appropriate. In its written
comments, SSA reiterated its view that the agency is operating within legal
authority in its 800 number telephone monitoring. In addition, SSA further
explained its rationale for maintaining a separate quality monitoring unit. By
maintsining this independent and unannounced review of calls, the agency aims

‘“Spikes are also included in this level of observation.
‘%I the past, under FIRMR, SSA was p rohibited from obtaining personal
information that would identify callers. This is subject to change under SSA’s
new regulations, and any changesare also subject to discussion with the union.

10                                GAOEIEEIS-i8-66B SSA800NumberCaU
B-278085

to ensure that its monitoring is objective and standardized across the various
sites and that the results are valid. In this way, SSA believes it meets its
stewardship responsibilities and further ensures public‘contidence. The full
text of SSA’s comments appears in appendix I.



We will make copies of this correspondence available to those who are
interested upon request. If you or your staff have any questions, please call me
on (202) 512-7215. Other staff who contributed to this correspondence include
Kay Brown, Vernette Shaw, and Stefanie Weldon.

Sincerely yours,




Associate Director, Income Security Issues




11                                GAOMEHS-9846R         SSA 800 Number     Calls
ENCLOSURE I                                                                             ENcLosuF2E I


                                      COMMENTS FROM SSA




                                 SOCIAL SECURITY
                                     Offlceofthe CommlssIoncr


                                     December 3, 1997
     Ms. Jane L. Ross
     Director,   Income Security    Issues
     U.S. General Accounting     Office
     Washington,    D.C. 20548

     Dear Ms.    Ross
     Thank you for the opportunity      to comment on your proposed
     correspondence    "Information   on the Social Security
     Administration's     Program for Monitoring    800 Number Telephone
     Calls   (GAO/HRHS-95-56R)."      We would like   to address two specific
     matters contained     in your draft correspondence.
     First,     SSA is operating       within      legal authority     in the conduct of
     its BOO number telephone monitoring.                    As you accurately    state,
     monitoring      is permissible        if one of two statutory        exceptions     is
     met.     The first    exception,        the consent exception,       requires    that
     one party to the call consent to the monitoring.                     As you note, we
     meet the consent exception              given the knowledge of our employees
     about monitoring        and the recorded message now in place notifying
     callers     that their      calls may be monitored.           The second exception,
     the business use exception, requires                  that the equipment used to
     conduct the monitoring           be provided by a telephone          company in the
     ordinary      course of business and the call monitored be of a
     business nature.         Our Office        of General Counsel believes that
     SSA's monitoring        falls    within     the business use exception because
     it has determined,         even without         conducting   a survey of the SSA's
     equipment,      that it is reasonable            KO assume that:    1) SSA obtained
     its telephone       equipment from telephone‘companies;              and 2) the
     calls    received    on the 800 number are related             to SSA’s business.
     Second, with regard to quality            monitoring,     we believe that the
     best way to ensure that we are providing               accurate    information    to
     the public      is to engage in a program of independent              and
     unannounced monitoring.           If monitoring      were left   to supervisory
     personnel     in the component being assessed,            we would be concerned
     about assuring       ourselves    and the public about objectivity,
     standardization       of procedures      and validity     of the results
     obtained.       We do not believe      that this approach conflicts          with
     best-in-business        practices    because it is consistent         with SSA's
     additional      responsibility      of stewardship     for the programs we
     administer      and to further      ensure public confidence.




12                                            GAO/HEHS-9846B SSA 800 Number Calls
ENCLOSURE I                                                                            ENCLOSURE I




     Some additional   :echnical   points   related   to your draf:  letter
     have been transmitted     to your staff.      Thank you again for the
     opportunity   to comment.
                                 Sincerely,



                                 Acting      Principal         Deputy   Commissioner
                                   of     Social    Security        .




(207017)


13                                          GAOIHEHS-98-66B SSA 800 Number Calls
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