Interim Report: The Social Security Administration's Processing of Mail and Enumeration Services During the COVID-19 Pandemic

Published by the Social Security Administration, Office of Inspector General on 2021-07-29.

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

         Interim Report

      The Social Security
 Administration's Processing of
Mail and Enumeration Services
During the COVID-19 Pandemic

               July 29, 2021

 A-08-21-51036 & A-15-21-51015

Date:   July 29, 2021                                        Refer To: A-08-21-51036 & A-15-21-51015

To:     Kilolo Kijakazi
        Acting Commissioner

From:   Gail S. Ennis
        Inspector General

Subject: The Social Security Administration's Processing of Mail and Enumeration Services During the
        COVID-19 Pandemic

        The attached interim report presents preliminary findings related to two Office of Audit reviews.
        The objectives of these audits are to evaluate SSA’s management of mail and controls over its
        processing of Social Security card applications during the COVID-19 pandemic. If you wish to
        discuss the interim report, please contact me directly, or have your staff contact
        Michelle L. Anderson, Assistant Inspector General for Audit.

In March 2020, the Social Security Administration (SSA) suspended most in-person services in
response to the COVID-19 pandemic. Since then, the Agency has been primarily relying on its
customers to submit paperwork by mail so it may process critical workloads. We have initiated
two reviews to assess SSA’s management of mail and controls over its processing of Social
Security card applications during the COVID-19 pandemic. In support of the audits, Office of
the Inspector General personnel visited SSA offices to observe mail processes and the
Agency’s handling of the original documents submitted by individuals who requested Social
Security cards. As of July 28, 2021, we had visited 73 SSA facilities that included field offices,
program service centers (PSC), and Social Security Card Centers. We have identified critical
issues related to policy and practices that affect the timely and efficient processing of mail and
enumeration-related work that require immediate attention. We have been engaged with SSA
executives on addressing these issues since July 5, 2021, and briefed staff in the Office of the
Commissioner on these concerns before the current Acting Commissioner of SSA was

Key Concerns Related to the Agency’s Policies and Oversight of
   SSA has no performance metrics and does not maintain management information on the
    volume of incoming, outgoing, or pending mail. Consequently, the Agency does not have
    sufficient information to enable it to adjust staffing levels to ensure mail is processed timely. 1

   SSA lacks comprehensive policies and procedures to track and return original documents—
    including driver’s licenses, birth certificates, passports, and naturalization documents—that
    customers provide as proof of eligibility for benefits or a Social Security number card.

Effects of Inadequate Internal Controls over Mail Processing
   Some offices had backlogs of workloads that involved original documents. For example,
    one PSC had more than 9,000 unprocessed original documents it had received as early as
    November 2020. We found that some of these documents were necessary to establish
    individuals’ eligibility for benefit payments.

1 Conversely, SSA requires the Department of Health and Human Services, which manages SSA’s Mid-America PSC
mailroom, to process 95 percent of all properly addressed incoming and outgoing mail within one business day. As
we continue our audit fieldwork, we will determine the extent to which SSA monitors compliance with this

Mail and Enumeration Processing During the Pandemic (A-08-21-51036 & A-15-21-51015)                           1
   Some offices had backlogs of unprocessed applications for new or replacement Social
    Security cards. For example, one field office had 677 unprocessed applications dated as
    early as July 2020. We also observed a Social Security card center that had over
    9,000 unprocessed applications dated as early as May 2021. As a result, individuals have
    yet to receive their original documents or Social Security number card.

   Some locations had backlogs of remittances or un-negotiated benefit checks. 2 For example,
    one PSC had 247 unprocessed remittances or un-negotiated checks dated as far back as
    November 2019. Financial institutions are not obligated to cash uncertified checks that are
    more than six months old, which leaves the Agency at risk of not being able to collect the
    remittance check funds.

   There were large quantities of undeliverable mail at some PSCs. For example, at one PSC,
    auditors noted more than 200,000 pieces of returned mail, some of which were over one
    year old. Some of these pieces may require action, such as suspending or terminating
    beneficiaries’ payments. 3

   While all SSA facilities were locked, some offices stored original documents in unsecure
    locations, such as desks and bins. In addition, employees at three offices informed us the
    U.S. Postal Service or special carriers left mail or packages, which may have included
    original documents or personally identifiable information, outside the offices in publically
    accessible areas after business hours and over the weekends.

   Approximately 50 percent of field office managers reported they are overwhelmed by mail
    duties, and approximately 20 percent stated they are unable to keep up with mail workloads.
    Some office managers also told us they did not have adequate in-person staffing to keep up
    with mail duties while offices remained closed because of the COVID-19 pandemic. 4

2Un-negotiated benefit checks are paper checks issued by the Department of the Treasury that beneficiaries or the
U.S. Postal Service returned to SSA.
3 SSA has policies that provide guidance on actions that should be taken for undeliverable mail depending on the

type of mail. For example, when SSA receives undeliverable mail that contains original documents submitted with a
Social Security card application, policy instructs Agency personnel to conduct follow up procedures to identify the
applicants’ current address. If SSA personnel are unable to obtain a current address, they are to hold the
undeliverable mail and shred the contents if they have no further contact with the applicant within 30 days. We found
instances in which offices were not consistently following this policy; however, due to backlogs it seems reasonable to
preserve original documents to allow the Agency ample time to identify correct address information.
4 We based these figures on statements field office managers made to auditors prior to July 12, 2021. During our site
visits, we observed some offices that had large backlogs and other offices that had no backlogs. SSA implemented
technologies, such as WorkTrack and Paperless, which provide the opportunity to distribute workloads to remote
personnel after mail is electronically scanned. However, we found SSA personnel used these systems inconsistently.

Mail and Enumeration Processing During the Pandemic (A-08-21-51036 & A-15-21-51015)                                  2
Scope Limitation
Two to four weeks prior to each office visit conducted from June 16 through July 16, 2021, we
notified management of the date and time of our arrival. In some cases, SSA personnel took
actions to address backlogs in anticipation of our visit, which impaired our ability to gain an
understanding of the true state of the Agency’s mail and SSN card operations. We were not
assured that what we observed in the selected offices generally represented all offices.
Accordingly, our report will include a scope limitation to provide context for readers to
reasonably interpret our findings. To address these concerns, for the remaining site visits we
conducted after July 16, 2021, we provided no more than four hours advance notice before we
arrived on site.

We believe these deficiencies occurred because SSA does not have comprehensive, specific,
or detailed policies, management information, or performance metrics related to how it
processes mail. Without this information, SSA cannot know how much unprocessed mail it has,
what is in the mail, or how old the mail is. In addition, Agency leadership is unable to assess
staffing needs and distribute workloads. Without an effective system of internal control, there is
heightened risk that SSA may lose sensitive documents. Agency managers stated the volume
of mail exponentially increased during the COVID-19 pandemic. It is reasonable that it would
take weeks or months to adjust processes to account for these changes. However, given that
these conditions have existed for longer than 16 months, and Congress and the media have
raised similar concerns, the Agency has had sufficient time and notice to plan and respond to
these issues. As noted above, we are engaged with SSA management on addressing many of
the issues described in this report, and we plan to issue final reports before end of Calendar
Year 2021. That report will describe final findings and recommendations as well as Agency
actions taken to address these concerns.

Mail and Enumeration Processing During the Pandemic (A-08-21-51036 & A-15-21-51015)               3
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