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Mar 6, 2009

Simplifying SSI

It is nearly certain that change is coming for the Supplemental Security Income (SSI) program administered by Social Security. Income and resource requirements have not been adjusted for inflation in decades. There is widespread agreement that things have to change. The change may go well beyond an inflation adjustment. I have been hearing for some time that the Social Security Administration wants simplification of SSI, but I have heard little about exactly what Social Security wants. The latest issue of the Social Security Bulletin is out. The Bulletin is mostly a tedious statistical journal, but this issue has an article about what may be at the top of Social Security's list of desired SSI changes, a change in the in kind support and maintenance rules. Here is an excerpt from the article:
... [S]implifying policy on food or shelter support to recipients from family and friends is especially compelling. Current policy on such in-kind support requires that recipients answer detailed questions about household composition, household expenses, and any contributions from the recipient and members of the household toward household expenses. This detailed household information is collected not only for initial applications, but also when there are changes in address, household composition, or household expenses. Moreover, although this information is collected for most recipients, much of it is unverifiable. ... [T]here is a consensus among policymakers and program administrators that current SSI policies on in-kind support and maintenance (ISM) are complex, intrusive, and sometimes inequitable. In addition, these policies create a disincentive for families and friends who might otherwise increase food or shelter support to recipients. Finally, year-after-year ISM is shown to be a major source of payment error ...

Over the years, policymakers have evaluated several alternatives to ISM ... Of these alternatives, benefit restructuring has emerged as an interesting option because it simply eliminates all ISM-related benefit reductions, assuring program simplification. The benefit restructuring options considered here incorporate a cost neutrality constraint; that is, the cost of increasing benefits to recipients with ISM is fully offset by other benefit reductions. ...

Under benefit restructuring, benefit reductions for ISM recipients would be eliminated and, to offset the program cost increases, a smaller benefit reduction would be implemented for the large number of adult recipients who live with other adults.

7 comments:

  1. I forget the name of the pilot project...but one idea to change the SSI system was to incorporate SGA. That recipient's payments under SSI would not be adjusted due to earned income until after they reach SGA - at which point the normal calcs. would be applied.

    It would be nice - but wouldn't address the elephant in the room...the asset limit.

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  2. Good grief, the desire to get rid of ISM--or simplify it greatly--has been at the top of SSA's wish list for 30 plus years. It has always run into two lines of opposition: 1) the additional program cost, a primary concern for OMB, and 2) the policy goal of perfect equity--and by that I mean, everyone must be treated equitably, and if someone gets an advantage from ISM, that someone shouldn't do better than the person who isn't lucky enough to have ISM. Some day, maybe, policy makers will realize the administrative impossibility of achieving perfect equity.

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  3. I've no insight to offer about SSA management. But the comment above about the impossibility of perfect equity echoes what the Supreme Court had to say in 2005, for Thomas. This was that elevator operator case that ended up being SSR 05-1c. One of the issues had to do with whether the ability to do past relevant work could legitimately be taken as a proxy for the ability to do jobs in significant numbers. The details of what went into this argument aren't that important. But consider this for how the Supremes approached the issue:



    The Third Circuit rejected this proxy rationale because it would produce results that “may not always be true, and . . . may not be true in this case.” 294 F. 3d, at 576. That logic would invalidate a vast number of the procedures employed by the administrative state. To generalize is to be imprecise. Virtually every legal (or other) rule has imperfect applications in particular circumstances. Cf. Bowen v. Yuckert, 482 U.S. 137, 157 (1987) (O.CONNOR, J., concurring) (“To be sure the Secretary faces an administrative task of staggering proportions in applying the disability benefits provisions of the Social Security Act. Perfection in processing millions of such claims annually is impossible”).

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  4. I have said this before,i will continue to speak accordingly on this matter.The law needs to change in regard to the disabled.People who could not work gainfully should not be punished by having income resource limits placed on them.My hope is someone influential reading this comment could have the law or restriction changed.

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  5. The only way to administer any payment program is to have invariable, defined payments that apply in every case, just like T2. Any attempt to apply an equity concept to a needs program runs up against the need to keep costs down. If everyone who lived in the household of another received the same benefit, we wouldn't be having this conversation.

    We could reduce total SSI payments by limiting family payment amounts in cases involving eligible parent(s) and one or more children. Now, we have an add on system with the eligible couple receiving the couple's rate, and each additional eligible child receiving a additonal amount until s/he reaches age 18. Or, we could just pay a fixed rate per eligible individual up to a family max.

    We will end up paying 7 times as much to administer SSI as T2 forever unless we decide what kind of program we are running. One that's cost effective and has some relationship to need, or one in which the perfect will forever be the enemy of the good.

    Just me doin', I'd make everyone living in "Household of Another" in LAB, set a family max for an all eligible family groups, and update the resources rate, give OP Supps back to the states, and leave it at that. OMB would have a fit, but old field folks like me never liked OMB anyway. Lots of little changes could also make a big difference, but this program will never be "simple."

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  6. First of all, income limits are adjusted annnually as part of the COLA. This includes deemed income limits and income exclusions. So, that is absolutely not even an issue.
    Secondly, the resource limits are rarely relevant in SSI disability cases. It is most relevant in aged cases, where people have saved over a lifetime and now need to file for SSI to enter some sort of assisted living. So, yes, it would be useful and helpful to adjust the resource limits.
    The most hoped for and desirable change to SSI would be to eliminate the ISM issue and living arrangement variations. This would save big administrative bucks without much real additional cost. Everyone hates living arrangement development and it is the source of most abuse, by claimants and claims reps alike.

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  7. Having worked many years as an SSI claims representative, I agree that the two most needed changes in SSI would be to elimnate ISM computations and pay just three rates (own household, household of another and medicaid facility) and cap payments to a family unit. The resource limit should also be adjusted for inflation, but I don't feel this is as crucial.

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