I'll explain below but this is just awful. It's no surprise to me but it's still awful. From a recent report by Social Security's Office of Inspector General (OIG):
We continue to find that SSA [Social Security Administration] needs to improve controls to ensure it accurately and timely pays OASDI [Old Age, Survivors and Disability Insurance] benefits withheld pending a windfall offset determination. We estimate thatLet me explain. Supplemental Security Income (SSI) benefits are based, in major part, on how much income you had during a month. What about months in which you are approved after the fact for both SSI and Disability Insurance Benefits (DIB) which are not based upon income? You didn't receive the DIB at the time but the law requires that the SSI benefits be reduced as if you had. That's the Windfall Offset. It may not sound that complicated but it is. It's been an enormous mess for Social Security even since it was enacted. The agency has made two separate efforts to implement software to automate the windfall offset. Both were expensive failures. My recollection is that the cost of the last software failure was over $100 million. The process remains a thorn in Social Security's side. It involves co-ordination between Social Security field offices where SSI benefits are computed and authorized and Social Security payment centers where DIB is computed and authorized. The process is tedious and highly error prone as this report shows. How error prone? So error prone that even after OIG pointed out that the agency had made a mistake, that half the time the agency still failed to correct the mistake! Note that the mistake is always to fail to pay claimants all the money they're due in a timely manner.
In addition, SSA incorrectly processed the windfall offset determinations for five beneficiaries. As a result, SSA improperly withheld $12,775 in OASDI benefits for these beneficiaries. Finally, SSA did not take corrective actions for 50.6 percent of the beneficiaries we identified during our 2011 audit.
- 13,141 beneficiaries’ windfall offset actions were not processed and therefore SSA withheld about $113.2 million in OASDI benefits, of which we estimate approximately $ 71.9 million was payable to these beneficiaries, and
- 19,587 beneficiaries’ windfall offset actions were correctly processed but not in a timely manner; therefore, these beneficiaries did not promptly receive about $195.2 million in OASDI ben efits .
I think that agency management has long since thrown up its hands and decided not to even bother to try to improve the situation. Why bother? It's only the claimants that are being hurt. This Congress won't complain about that. Even past Democratic Congresses didn't complain because they didn't understand the problem.
If you think this is all way too technical to bother thinking about, look at the charts below. Over half the time, Social Security fouls up the windfall offset. Once they foul it up it's often years before they get it straightened out, if they ever do.
7 comments:
Very few people in a field office know how to process an offset. There aren't too many that fit a cookie cutter training method, so it becomes cumbersome to train new people with all the variables involved with an offset. Actually, the automation programs developed for offsets have help with the more simple, basic offsets, but that means the messy, complicated ones remain.
Why the field office is left to do this, is beyond comprehension. The payment centers have all of the T2 payment information that their fingertips and the T16 record is almost always built and paid before the T2 is paid. The PC would have a much better chance at withholding the proper amount.
Another OIG report cherry picking cases and info to make themselves look good. If OIG and Quality Analysis Branch--or whatever they like to call themselves now--actually got involved in solutions and real work problems would lessen. 35 year SSA vet.
You could pay the retro T2 DIB first and then offset the T16 SSI. However, if I correctly recollect, the payment of the SSI first and the offset against DIB reduces the past-due available for attorney fees. And the time it takes to manually do the SSI offset delays payment of the retro DIB and can sometimes cause a hardship.
I always understood that payment of SSI first was to be sure that claimant received the medicaid benefit. Inconsistent application of DIB first in some places and SSI first in others meant some did not get the benefit of medicaid, even temporarily. It has nothing to do with attorney fees.
I also agree that OIG cherry picked these cases. I have decades (literally since the early 1980's) of hands on experience working windfall offset cases and it is my observation that the majority of windfall offset cases will now automate correctly and relatively quickly - an incredible increase in correctness with the advent of Direct SSR inputs in MSSICS and eComps for manual windfall offsets. But of course, the correctness always does depend upon the skill and ability of the user and their ability to understand and recognize when they have made an error. I do not think that the PC employees have the SSI knowledge that will help them compute more accurate manual offset comps but unless the FO considers offsets to be a higher priority, then two or three out of ten will probably take longer than 90 days. The complicated offsets come from complicated manual SSI payment computations which stem usually from the systems limitations inherent in MSSICS for cases with certain characteristics. The same stuff that kicks a case out of the electronic file will also kick it out of automated windfall offset processing - start date records for couples with different filing dates and reopenings of prior denials. I also know that most of my coworkers cannot do the windfall offset comps and have a hard time explaining them. But I don't want to die at my desk waiting for them to learn, so I guess they will have to struggle.
I don't think cherry picked applies to over 19,00 cases. This is not like the congressional review a year or so ago when one congressman's staff "reviewed" 100 cases. Offset cases are difficult and SSA really could use more skilled staff when processing them. But that takes money and SSA and congress prefer to throw money at CDRs. I am seeing terminations that remind me of the Regan years. Maybe OIG should conduct a study on how much money SSA really needs per year and ask congress to fund it.
Would it be stating the ovious that Congress/SSA need to change laws, rules and computer systems in order to make it much easier and cheaper to administer?
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