oversight

Accuracy of Supplemental Security Income Recipients' Reports of Separation

Published by the Social Security Administration, Office of Inspector General on 2020-07-30.

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

             Audit Report



Accuracy of Supplemental Security
  Income Recipients’ Reports of
           Separation




       A-02-14-31417 | July 2020
MEMORANDUM


Date:      July 30, 2020                                                    Refer To:

To:        The Commissioner
From:      Inspector General
Subject:   Accuracy of Supplemental Security Income Recipients’ Reports of Separation (A-02-14-31417)

           The attached final report presents the results of the Office of Audit’s review. The objective was
           to determine whether the Social Security Administration could more effectively determine the
           accuracy of Supplemental Security Income recipients’ reports of separation from individuals
           whose income could affect their eligibility for payments

           Please provide within 60 days a corrective action plan that addresses each recommendation. If
           you wish to discuss the final report, please call me or have your staff contact
           Michelle L. Anderson, Assistant Inspector General for Audit, at 410-965-9700.




                                                          Gail S. Ennis

           Attachment
Accuracy of Supplemental Security Income Recipients’
Reports of Separation
A-02-14-31417
July 2020                                                                   Office of Audit Report Summary

Objective                                   Findings

To determine whether the Social             SSA may be able to more effectively use information in its records
Security Administration (SSA) could         to determine the accuracy of SSI recipients’ reports of separation
more effectively determine the              from ineligible deemors. For example, SSA staff has access to
accuracy of Supplemental Security           deemors’ Forms W-2, Wage and Tax Statement, which are stored in
Income (SSI) recipients’ reports of         SSA’s Online Retrieval System. These Forms may be able to help
separation from individuals whose           establish whether deemors’ addresses changed after reported
income could affect their eligibility for   separations. While information in SSA’s records will not allow
payments.                                   SSA staff to definitively prove the legitimacy of reported
                                            separations, it may alert staff to situations where additional
Background                                  questions and development are needed to accurately process
                                            recipients’ living arrangements. Also, the information should help
SSI recipients may live with                staff provide the Office of Investigations more informed referrals
individuals, such as a spouse or parent,    should it conclude recipients have likely falsely reported
who themselves are not eligible for SSI     separations from ineligible deemors whose income could affect the
payments. SSA refers to these               recipients’ SSI eligibility or payment amounts.
individuals as ineligible deemors, and
their income can affect the recipients’     For 39 of the 100 recipients we reviewed, the deemors’ income
SSI eligibility and payment amounts.        would have affected the recipients’ SSI payment amounts had the
Past investigations have shown that         recipients and deemors continued or resumed living together after
some recipients have falsely reported       their reported separations. For 20 of the 39 cases, SSA found
separations from deemors when their         information in its systems to support, or our Office of the
income could adversely affect the           Investigations concluded, the recipients and deemors continued or
recipients’ SSI payments. Given that        resumed living together. SSA paid the 20 recipients approximately
recipients self-report their living         $496,000 in SSI payments after their reported separations.
arrangements, it is difficult to            Estimating our results to the population, approximately
differentiate false from legitimate         2,800 recipients may have falsely reported their separations from
reports of separations.                     the deemors, and SSA paid them approximately $69 million after
                                            their reported separations.
From 1 segment of the Supplemental
Security Record, we identified              Recommendations
691 recipients who reported they had
separated from ineligible deemors.          We made five recommendations, including that SSA create an alert
However, their addresses still matched      to prompt staff to verify living arrangements and question the
the deemors’ addresses at least 1 year      accuracy of reported separations when evidence in SSA’s records
after the reported separation, and the      suggest recipients and deemors had the same address after
deemors had at least a $2,000 increase      separating. We also recommended that SSA change its policy to
in wages in at least 1 year before or       require that recipients provide evidence to support their separations
after the year of the reported              whenever such evidence can reasonably be expected to be
separation. We reviewed a random            available. SSA agreed with two of our recommendations and
sample of 100 of the 691 recipients.        disagreed with three. The report includes the full text of the
                                            Agency’s comments as well as our response.
TABLE OF CONTENTS
Objective ..........................................................................................................................................1
Background ......................................................................................................................................1
     Ineligible Deemors .....................................................................................................................1
     False Reports of Separation .......................................................................................................2
     Audit Population ........................................................................................................................2
Results of Review ............................................................................................................................3
     W-2 Address Information ..........................................................................................................3
     Office of Investigations Review ................................................................................................4
Conclusions ......................................................................................................................................4
Recommendations ............................................................................................................................5
Agency Comments ...........................................................................................................................5
OIG Response ..................................................................................................................................6
                    – Scope and Methodology ..................................................................................... A-1
                    – Sampling Methodology and Results ................................................................... B-1
                    – Agency Comments .............................................................................................. C-1




Accuracy of Supplemental Security Income Recipients’ Reports of Separation (A-02-14-31417)
ABBREVIATIONS
OI                   Office of Investigations

OIG                  Office of the Inspector General

POMS                 Program Operations Manual System

SSA                  Social Security Administration

SSI                  Supplemental Security Income




Accuracy of Supplemental Security Income Recipients’ Reports of Separation (A-02-14-31417)
OBJECTIVE
Our objective was to determine whether the Social Security Administration (SSA) could more
effectively determine the accuracy of Supplemental Security Income (SSI) recipients’ reports of
separation from individuals whose income could affect their eligibility for payments.

BACKGROUND
SSA administers the SSI program under Title XVI of the Social Security Act. 1 The SSI program
provides monthly payments to individuals with limited income and resources who are aged,
blind, or disabled. In Fiscal Year 2019, the Agency paid about $52 billion in SSI Federal and
State supplementary payments to a monthly average of approximately 8 million recipients.

Ineligible Deemors
SSI recipients may live with individuals, such as a spouse or parent, who are not eligible for SSI
payments. SSA refers to these individuals as ineligible deemors. 2 Because SSI is a means-tested
program, deemors’ income can affect recipients’ SSI eligibility and/or payment amount. SSI
recipients must report changes to SSA that would affect their eligibility or payment amounts,
including separations from ineligible deemors. 3 SSA may use Form SSA-795, Statement of
Claimant or Other Person, to document recipients’ reports of separation, which acknowledges
the recipient’s understand that knowingly providing false statements about material facts is a
crime and can result in a fine or imprisonment. 4

SSA accepts recipients’ self-reporting of their living arrangements unless there is information to
the contrary. Also, while recipients must report changes of address or residences because such
changes may affect their SSI eligibility or payment amount, SSA policy neither requires
evidence nor lists specific types of documents proving residency when accepting reports of
changes of address. 5 While SSA policy does not require evidence, staff may request additional
information. 6 However, an ineligible deemor who has moved out of a recipient’s residence is not
required to comply with SSA’s requests.




1
    Social Security Act, 42 U.S.C. § 1381 (govinfo.gov 2018).
2
    As of January 2020, approximately 1.2 million out of 8.1 million SSI recipients resided with deemors.
3
    SSA, POMS, SI 02301.005, A and B.2 (September 30, 2016).
4
    SSA, POMS, GN 04105.005, A and C (April 19, 2017) and SI 02301.005, B.4 and D.3 (September 30, 2016).
5
    SSA, POMS, SI 02306.010, A and B.1 (September 26, 2006).
6
 If there is not documentation to prove a change in living arrangement, SSA can document that change with Form
SSA-795, Statement of Claimant or Other Person. By signing Forms SSA-795, recipients acknowledge they
understand that providing false statements about material facts is a crime and can result in a fine or imprisonment.



Accuracy of Supplemental Security Income Recipients’ Reports of Separation (A-02-14-31417)                             1
SSA completes redeterminations to review SSI recipients’ non-medical eligibility factors to
determine whether they continue to be eligible for, and/or are receiving, the correct payments.
SSA policy requires that eligibility factors be reviewed when it completes redeterminations,
including a recipient’s living arrangements. 7 SSA completed 2.67 million non-medical
redeterminations in Fiscal Year 2019.

False Reports of Separation
Past investigations have shown that some SSI recipients falsely reported they had separated from
deemors when the deemors’ income could adversely affect the recipients’ payments. Given that
SSA accepts recipients self-reporting their living arrangements, it can be difficult to differentiate
false from legitimate reports.

When SSA staff suspects a recipient has falsely reported a separation, SSA policy instructs them
to evaluate evidence using their “best judgment” to determine whether the recipient knowingly
made a false statement or omitted material facts and refer the allegation to the Office of the
Inspector General (OIG) for possible investigation. 8 If the investigation finds evidence a
recipient provided false statements about material facts related to his/her living arrangements, it
can refer cases to the Department of Justice for prosecution. Examples of successful
prosecutions follow.

     In April 2019, an SSI recipient pleaded guilty to one count of theft of Government funds and
      one count of Social Security fraud for providing false statements concerning her living
      arrangement with her spouse, who had substantial income. The recipient was sentenced to
      1 year and 1 day incarceration and 2 years’ supervised released as well as ordered to pay
      SSA $167,529 in restitution.

     An individual applied for SSI payments, but, because of her husband’s income, SSA denied
      her claim. She reapplied 2 months later, claiming she had separated from her husband. An
      investigation revealed they had not separated. She pleaded guilty to theft of Government
      funds and, in March 2019, was sentenced to 3 years’ probation. She was also ordered to pay
      SSA $48,414 in restitution.

Audit Population
From 1 segment of the Supplemental Security Record, we identified 10,162 individuals who
were receiving SSI payments and reported a separation from a deemor effective January 2009
through December 2015. From this population, we identified 3,812 recipients who reported
separations from deemors who had at least a $2,000 increase in wages in 1 or more years before




7
    SSA, POMS, SI 02305.001, A and C.1 (August 29, 2014).
8
    SSA, POMS, GN02604.410, A.1. and A.3 (April 25, 2017).



Accuracy of Supplemental Security Income Recipients’ Reports of Separation (A-02-14-31417)          2
or after the year of the alleged separation. 9 Using the deemors’ addresses on their Form W-2,
Wage and Tax Statement, we identified 691 recipients whose addresses in SSA’s systems
matched the deemors’ addresses for 1 year or longer after the reported separation. We reviewed
a random sample of 100 of these 691 cases.

RESULTS OF REVIEW
SSA staff has access to records—including deemors’ Forms W-2 10—that can provide
information about recipient and deemors’ addresses. Using these records, we were able to more
effectively determine the accuracy of SSI recipients’ reports of separation from individuals
whose incomes affected their eligibility for benefits.

W-2 Address Information
We reviewed a random sample of 100 recipients whose address matched a deemor’s W-2 address
for 1 year or longer after they reportedly separated and after the deemor had at least a $2,000
increase in wages in 1 or more years before or after the alleged separations. We determined the
deemors’ wages would have caused overpayments in 39 cases had the recipients and deemors
continued living together. 11 At our request, SSA reviewed the 39 recipients’ records and did not
question the legitimacy of 23 reported separations noting, for example, that there was a
reasonable explanation the separating deemor’s address matched the recipient’s. However, for
the remaining 16 cases, SSA questioned or provided information that initially led us to question
whether the recipients and deemors continued or resumed living together after the separation
report based on information in its records. SSA later provided information that led us to
conclude 2 of the 16 separations were not questionable. Examples of information in SSA’s
records that led us to question the reported separations follow.

      A recipient stated at a consultative medical examination after the reported separation that she
       lived with her husband.

      After their reported separation, a recipient and spouse disclosed to SSA in a telephone call
       that they were both living with the spouse’s mother. Additionally, when the deemor filed for
       Medicare after the reported separation, he used the recipient’s address as his own.




9
  We excluded child recipients who received child support, recipients whose separated deemors were deceased, and
recipients our Office of Investigations previously investigated.
10
     SSA employees who work with the public have access to W-2 records through SSA’s Online Retrieval System.
11
   For the remaining 61 records, the wages would not have affected the recipient’s SSI payments because the
deemor’s earnings were under the threshold to affect the recipient’s payment; SSA’s records support a separation,
such as a divorce; or the recipient’s record had been updated where deeming was no longer applicable, such as the
recipient reached age 18 and the parent’s income was no longer deemed to the recipient; or the recipient’s payments
terminated.



Accuracy of Supplemental Security Income Recipients’ Reports of Separation (A-02-14-31417)                         3
    Both the recipient and deemor’s addresses changed to a matching address after their reported
     date of separation.

SSA paid the 14 recipients approximately $420,000 12 that they would not have been eligible to
receive had they lived with the deemors after their reported separations.

Office of Investigations Review
We referred to our Office of Investigations (OI) the 23 cases where SSA did not initially find
contrary evidence to question the reported separations. We asked OI to determine whether the
recipients and deemors lived together after the dates they reportedly separated. As of July 2020,
the status of the 23 cases was as follows.

    In nine cases, OI concluded the recipients and deemors had separated as reported.

    In six cases, OI determined the recipients and deemors had not separated or did not remain
     separated as reported. The recipients received approximately $76,000 in SSI payments for
     which they were not eligible.

    In eight cases, OI’s review is ongoing. To date, OI has seven ongoing investigations and is
     collecting evidence for the remaining case to determine whether an official investigation is
     warranted.

In total, SSA found information in its systems to suggest, or OI concluded, that 20 of the
39 recipients and deemors continued or resumed living together after their reported separations.
SSA paid these recipients approximately $496,000 that they would not have been eligible to
receive had they continued living with the deemors. Estimating our results to the population,
approximately 2,800 recipients may have falsely reported separations and, as a result, SSA may
have paid them approximately $69 million that they would not have been eligible to receive.

CONCLUSIONS
While we understand the challenges SSA faces in identifying and proving false reports of
separations, the Agency has the opportunity to better use available resources to question
recipients about suspicious allegations and/or better develop cases before referring them for
investigation.




12
  We referred 1 of the 14 cases to OI. OI investigated and determined the recipient and deemor never separated. OI
referred the case to SSA, and SSA posted a $36,230 overpayment.



Accuracy of Supplemental Security Income Recipients’ Reports of Separation (A-02-14-31417)                      4
RECOMMENDATIONS
We recommend that SSA:

1. Complete redeterminations for the 20 cases 13 we or the Agency identified as questionable.

2. Review the remaining cases in our population 14 and determine whether the Agency should
   complete redeterminations for them.

3. Revise its redetermination policy to instruct staff to review ineligible deemors’ earnings and
   historical W-2 information, as well as any other address-related information in SSA’s records
   or available to SSA staff, to determine whether reported separations from SSI recipients are
   questionable.

4. Create an alert to prompt staff to verify living arrangements and question the accuracy of
   reported separations when separated deemors’ earnings are above the deeming threshold and
   their Form W-2 addresses continue to match the recipients’ addresses from whom they
   reportedly separated.

5. Revise its policy to require that recipients provide evidence to support their reported
   separations from ineligible deemors when such evidence can be reasonably expected to be
   available. For example, when the recipient has moved from the household, require that
   he/she provide evidence of his/her new address.

AGENCY COMMENTS
SSA agreed with Recommendations 1 and 2 but disagreed with Recommendations 3, 4, and 5.
In disagreeing, SSA stated it believed W-2 information was generally an unreliable source of
residential address information, and it has an alert in place that requires that staff verify
household composition and review the accuracy of reported changes in living arrangements.
Further, in disagreeing with requiring evidence to support reported separations, SSA stated
recipients and other individuals who provide the Agency information must submit
documentation to support their statements and affirm, under penalty of perjury, that their
statements are true and correct. The full text of SSA’s comments is included in Appendix C.




13
     OIG concluded its investigation on three of these cases and referred them to SSA for redeterminations.
14
  Our population comprised 691 recipients. We reviewed 100 randomly selected recipients from the population. Of
the remaining 591 recipients not reviewed, 446 remain in current pay status as of January 2020.


Accuracy of Supplemental Security Income Recipients’ Reports of Separation (A-02-14-31417)                    5
OIG RESPONSE
We successfully used W-2 and earnings information within SSA records to identify recipients
who inaccurately reported separations from deemors whose income affected the recipients’ SSI
eligibility. Accordingly, we concluded SSA could use this information to better evaluate the
accuracy of recipients’ reports of separation from deemors. While SSA’s alert to verify living
arrangements is a helpful reminder for staff when it processes a reported separation, the alert
does not use available address and earning information to better identify inaccurate reports of
separation that would affect recipients’ SSI eligibility. Also, when we asked the Agency for
policy or training references that further explained the alert it referenced in its comments, the
Agency reported it did not have any policy or training references that detailed the actions staff
should take to address the alert.

Finally, OI investigations have provided many examples of recipients inaccurately reporting
separations from deemors, demonstrating recipients’ ability to provide false information to SSA
that allows them to receive SSI payments for which they were not eligible. Requiring evidence
to support reported changes whenever such evidence can reasonably be expected to exist would
help prevent false reports of separation and strengthen the integrity of the SSI program.




                                                   Michelle L. Anderson
                                                   Assistant Inspector General for Audit




Accuracy of Supplemental Security Income Recipients’ Reports of Separation (A-02-14-31417)          6
                                       APPENDICES




Accuracy of Supplemental Security Income Recipients’ Reports of Separation (A-02-14-31417)
                     – SCOPE AND METHODOLOGY
To accomplish our objective, we:

   Reviewed the Social Security Act and Social Security Administration’s (SSA) Program
    Operations Manual System.
   Identified 10,162 Supplemental Security Income (SSI) recipients from segment 14 of the
    Supplemental Security Record who were in current pay and reported a separation from a
    deemor effective January 2009 through December 2015.
   From this population, identified recipients whose separated deemor had a $2,000 or more
    increase in wages in at least 1 of the years from the year before to the year after the
    separation allegation.
   Before sampling, identified 3,812 recipients by excluding child recipients who received child
    support, recipients whose separated deemor was deceased, and recipients already referred to
    the Office of Investigations (OI) in our prior survey work.
   Requested the deemor’s Form W-2, Wage and Tax Statement, earnings statement for 2009
    through 2016.
   Matched the deemors’ 2016 W-2 address to the SSI recipient’s address on the Supplemental
    Security Record. We found 691 matches.
   Randomly sampled 100 of the 691 cases with matching addresses.
   Examined the W-2 address of the deemor and the recipients’ historical current addresses in
    the SSI Claims system starting with the year of separation.
   Determined the funds at risk per month through December 2018 by using the Supplemental
    Security Record’s current monthly payment in the Computation History field.
   Referred to SSA 39 cases we identified where the deemors’ income would have affected the
    recipients’ SSI payment amounts if the recipients and deemors continued living together.
   SSA identified evidence in its records that suggested 16 of the 39 recipients lived with their
    deemors after their reported date of separation. SSA later provided additional information
    that led us to conclude that 2 of the 16 separations were not questionable. We referred the
    remaining 23 cases to our OI for its review.

We conducted this audit in New York, New York, between October 2018 and February 2020.
The entity reviewed was the Office of the Deputy Commissioner for Operations. We determined
the computer-processed data were sufficiently reliable for our intended use. We conducted tests
to determine the completeness and accuracy of the data. These tests allowed us to assess the
reliability of the data and achieve our audit objective.




Accuracy of Supplemental Security Income Recipients’ Reports of Separation (A-02-14-31417)      A-1
We conducted this performance audit 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 and conclusions based on our audit objective.




Accuracy of Supplemental Security Income Recipients’ Reports of Separation (A-02-14-31417)   A-2
                      – SAMPLING METHODOLOGY AND RESULTS
From 1 segment of the Supplemental Security Record, we identified 10,162 Supplemental
Security Income (SSI) recipients who reported separating from deemors in Calendar Years 2009
through 2015. From this population, we identified the deemors who had increased wages of
$2,000 or more recorded in the Master Earnings File in the year before or after the reported
separation. Additionally, using the Online Retrieval System, we compared the addresses listed
on the deemors’ Forms W-2, Wage and Tax Statement, to the recipients’ addresses in the
Modernized SSI Claims System for the years after the reported separation and identified
691 1 recipients and deemors who appeared to still be living together. We selected and reviewed
a random sample of 100 cases from the population of 691 cases (see Table B–1).

                                Table B–1: Population and Sample Size
                                    Description                                          Recipients
         Population Size (identified in 1 segment of the Supplemental
                                                                                               691
         Security Record)
         Sample Size                                                                           100
         Total Estimated Population (Population Size x 20 segments)                        13,820

Using the Online Retrieval System and Modernized SSI Claims System to examine deemor and
recipient addresses, we identified 39 cases where we believe the deemor and recipient likely did
not remain separated after the reported separation, and the deemor’s earnings would either
reduce or eliminate a portion of the recipient’s payments. We referred these cases to SSA for its
review. SSA identified evidence in its records that suggested 16 of the 39 recipients lived with
their deemors after their reported date of separation. SSA later provided additional information
that led us to conclude that 2 of the 16 separations were not questionable. We referred the
remaining 23 cases to our Office of Investigations (OI) for review. In six cases, OI determined
the recipients and deemors had not separated or remained separated as reported.

In total, SSA found evidence in its systems to support, or OI concluded, that 20 of the
39 recipients and deemors may have continued to live together after the reported separations.
The 20 recipients were paid $496,382 in SSI payments they would not have been eligible for had
they continued living with the deemors. Estimating these results to all 20 segments, there are
2,760 cases with questionable separations and $68,600,000 at risk of having been paid
improperly (see Table B–2).




1
  We excluded child recipients who received child support, recipients whose separated deemors were deceased, and
recipients previously referred to OI.


Accuracy of Supplemental Security Income Recipients’ Reports of Separation (A-02-14-31417)                   B-1
                                         Table B–2: Funds at Risk
                                                             Number of Cases
                      Description                            with Questionable       Funds At Risk
                                                                Separations
 Sample Results (for 1 segment)                                     20                   $496,382
 Point Estimate (for 1 segment)                                    138                 $3,430,000
 Projection – Lower Limit                                           98                 $2,162,164
 Projection – Upper Limit                                          187                 $4,697,835
 Population Estimate (Point Estimate x
                                                                 2,760                $68,600,000
 20 segments)
Note: All projections are at a 90-percent confidence level




Accuracy of Supplemental Security Income Recipients’ Reports of Separation (A-02-14-31417)           B-2
                           – AGENCY COMMENTS




                                  SOCIAL SECURITY
                                    Office of the Commissioner

MEMORANDUM


Date:      July 10, 2020                                                       Refer To:

To:        Gail S. Ennis
           Inspector General


From:      Stephanie Hall
           Chief of Staff

Subject:   Office of the Inspector General Draft Report “Accuracy of Supplemental Security
           Income Recipients’ Reports of Separation” (A-02-14-31417) -- INFORMATION

           Thank you for the opportunity to review the draft report. Please see our attached
           comments.

           Please let me know if we can be of further assistance. You may direct staff inquiries to
           Trae Sommer at (410) 965-9102.




Accuracy of Supplemental Security Income Recipients’ Reports of Separation (A-02-14-31417)        C-1
SSA COMMENTS ON THE OFFICE OF THE INSPECTOR GENERAL DRAFT
REPORT, “ACCURACY OF SUPPLEMENTAL SECURITY INCOME RECIPIENTS’
REPORTS OF SEPARATION” (A-02-14-31417)

GENERAL COMMENTS

Sometimes we must rely on individual reports about certain factors of entitlement, such as the
living arrangements of Supplemental Security Income (SSI) recipients. In those situations, we
ask appropriate questions and obtain documentation to determine the accuracy of a recipient’s
report. While we do not agree with recommendations 3, 4, and 5, we will remind employees of
existing policies for developing and documenting living arrangements when SSI recipients
separate from deemors. We will also consider how we can revise our quality review process to
monitor how well we process SSI recipients’ reports of separation and explore options to
improve our identification and referral of potential fraud among these cases to the Office of the
Inspector General for further investigation.

Our responses to the recommendations are below.

Recommendation 1

Complete redeterminations for the 20 cases we or the agency identified as questionable.

Response

We agree.

Recommendation 2

Review the remaining cases in our population and determine whether the agency should
complete redeterminations for them.

Response

We agree.

Recommendation 3

Revise its redetermination policy to instruct staff to review ineligible deemors’ earnings and
historical W-2 information, as well as any other address-related information in SSA’s records or
available to SSA staff, to determine whether reported separations from SSI recipients are
questionable.

Response

We disagree. We routinely use residential address information in our records and other
information available to us when we evaluate SSI recipients’ reports of separation. Further,
requiring technicians to review W-2 information for every reported separation would be an
inefficient use of agency resources because we consider W-2s a generally unreliable source of

Accuracy of Supplemental Security Income Recipients’ Reports of Separation (A-02-14-31417)      C-2
residential address information. The Internal Revenue Service relies on tax returns for address
information, and its publications allow employers to enter post office boxes and “in care of”
addresses on forms W-2.

Recommendation 4

Create an alert to prompt staff to verify living arrangements and question the accuracy of reported
separations when separated deemors’ earnings are above the deeming threshold and their W-2
addresses continue to match the recipients’ addresses from whom they reportedly separated.

Response

We disagree. As noted in our response to Recommendation 3, W-2s can be an unreliable source
of residential address information. Additionally, we currently have an alert in our system that
requires technicians to verify household composition and ensure removal of an individual from a
household conforms with policy including instances when a deemor’s income exceeds the
deeming threshold.

Recommendation 5

Revise its policy to require recipients to provide evidence to support their reported separations
from ineligible deemors when such evidence can be reasonably expected to be available. For
example, when it is the recipient who has moved from the household, require that he/she provide
evidence of his/her new address.

Response

We disagree. Our existing policy requires SSI recipients to report when they separate from
deemors. Existing policy also requires technicians to document a recipient’s residence address,
evaluate a recipient’s ability to pay his or her monthly rent, utility, and food expenses, and
identify anyone living in the home or contributing to the household expenses. If a recipient
moves into another person’s home, policy requires technicians to independently verify household
operating expenses and individual financial contributions with the homeowner or a
knowledgeable adult living in the household. Recipients and other individuals who provide
information to us must submit documentation to support their statements and affirm under
penalty of perjury that their statements are true and correct.




Accuracy of Supplemental Security Income Recipients’ Reports of Separation (A-02-14-31417)     C-3
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To report fraud, waste, and abuse, contact the Office of the Inspector General via
   Website:        oig.ssa.gov/report-fraud-waste-or-abuse
   Mail:           Social Security Fraud Hotline
                   P.O. Box 17785
                   Baltimore, Maryland 21235
   FAX:            410-597-0118
   Telephone:      1-800-269-0271 from 10:00 a.m. to 4:00 p.m. Eastern Standard Time
   TTY:            1-866-501-2101 for the deaf or hard of hearing