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Dec 1, 2011

Windfall Offsets Remain A Quagmire

From a recent audit report of Social Security's Office of Inspector General (OIG):
Our objective was to determine whether the Social Security Administration (SSA) had adequate controls to ensure Old-Age, Survivors and Disability Insurance (OASDI) benefits that had been withheld pending a Supplemental Security Income (SSI) windfall offset determination were paid accurately and timely. ...
Based on our random sample, we estimate that:
  • 35,398 beneficiaries had SSI windfall offset actions that were not processed. As a result, SSA withheld about $306 million in OASDI benefits, of which we estimate approximately $232 million is payable to these beneficiaries.
  • 17,067 beneficiaries had SSI windfall offset actions that were incorrectly processed. As a result, SSA improperly withheld or overpaid about $51.5 million in OASDI benefits for these beneficiaries.
  • 60,051 beneficiaries had SSI windfall offset actions that were correctly processed but not in a timely manner. As a result, these beneficiaries did not promptly receive about $725.9 million in OASDI benefits

7 comments:

  1. The lesson is that if you want your Title II benefits paid correctly, do not apply for SSI.

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  2. I worked on automating this in SSI for too many years in the 1980s and always thought that while teh concept isn't hat hard, the actual process was simply too complex for CRs to understand. Because SSI is always a moving target to begin with, having to address PE events during the offset period gets into deciding what was paid, what should have been paid and what would have been paid if the T2 was paid on time. Not terribly complex by itself, but welded ontop of SSIs inherant complexity it just becomes tedious. Windfall isn't that complex mathmatically, but having to explain calculations for PE events that use absolute value and you lose a surprising number of employees, and 95% of the public. The fact that 30 years later it remains a mess actually speaks to the fact it's simply not that easy to do.

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  3. SSA's failure to automate this process is egregious. It has always been a backlogged and highly error-prone workload which requires difficult manual computations that staff does not have time or training for. I hope this investigation results in some action to really resolve the process rather than just more unrealistic pressure on over-burdened staff to do the work quickly and correctly.

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  4. These days the claimant is seldom given the option of not filing for SSI as the common practice is to take technical denials from every claimant to secure work credit. The Windfall Offset code often remains on the record and underpayments are erroneously witheld sometimes for years as noted by OIG. The PSCs also seem to stop the tracking of processing of ALJ reversals based on the issuance of the first check. These leaves large underpayments as orphans in that it is only what gets measured that matters.
    SSA should review instructions to insure that the WF code is removed timely and that ALJ reversals are tracked until the full underpayments are released.

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  5. When the ALJ award is input by the PC, then the case should be cleared.
    The ALJ's are a high priority workload and at least the claimant is in current pay even if a WF adjustment is still pending.
    We can't put the WF adjustments on as high of a priority level as an unprocessed ALJ award, or we would fall further behind in our ALJ processing.

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  6. All measurement systems should take into consideration the claimants perspective. The first payment does little to alleviate many years of debts that have accumulated.

    The OIG reports clearly indicates that the WF underpayments are ignored under the current tracking system. SSA strives to get the first check out to "put food on the table" but fails to recognize that the house will be lost to foreclosure without timely release of these underpayments.

    SSA is renowned for creating measurements systems that scream "Success" while ignoring the realities experienced by the claimant. The clearance of ALJ cases with the release of the first check ignoring the large underpayments is a prime example.

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  7. To 1:06pm comment;

    That is bogus. It may vary amongst the PSCs, but here the WF workload is just as high a priority as appeals and clearance of field office critical payments.

    The fact is, a large number of technicians post WF codes and withhold benefits 'just to be safe' without realizing that the claimant's DIB or RSI benefit alone is enough to preclude any possible T16 payments.

    The claim technicians who prepare the appeal awards have policy on how to avoid erroneously withholding past due benefits for offset. They either end up rushed because of other goals or really are clueless on how to read a T16 record and realize SSI has never been paid and will not be paid.

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