From a recent report by Social Security's Office of Inspector General (OIG):
... If a family member of a wage earner is eligible for OASDI [Old Age, Survivors and Disability Insurance] benefits and is not a U.S. citizen, he/she may need to meet a 5-year residency requirement. To fulfill the residency requirement, the beneficiary must establish a physical residence in the United States, while in a qualifying relationship with the wage earner, with the intent to reside for a cumulative period of at least 5 years. SSA uses the automated Regular Transcript Attainment and Selection Pass (RETAP) process to prompt benefit suspension for non-citizen beneficiaries who have not meet their 5-year residency requirement and have been outside the United States for longer than 6 consecutive months. ...
Of the 200 non-citizen beneficiaries we reviewed, SSA did not properly suspend benefits to 26 (13 percent). SSA should have suspended these beneficiaries because they had not met their 5-year residency requirement and lived outside the United States for longer than 6 consecutive months. Of the 26 beneficiaries, 23 met the criteria for the RETAP process to prompt benefit suspension. However, RETAP did not identify these beneficiaries for suspension. According to SSA, a RETAP programming limitation prevented these beneficiaries from being identified for benefit suspension. SSA employees omitted information from the remaining three beneficiaries’ Master Beneficiary Records required for RETAP to prompt benefit suspensions.
By not appropriately suspending benefits, SSA overpaid these 26 beneficiaries approximately $332,000. Accordingly, we project SSA overpaid nearly $29 million to approximately 2,300 non-citizen OASDI beneficiaries. ...Is RETAP a State Department database?
OMB directed SSA to develop a corrective action plan to mitigate improper payments in the administration of the Windfall Elimination Provision and Government Pension Offset provisions. As part of the action plan SSA implemented RETAP, which flags dual-entitlement cases involving WEP or GPO that the processing centers are supposed to investigate further.
ReplyDeleteFrom the verbiage stated here, it sounds like RETAP is an SSA program, likely batch.
ReplyDeleteRETAP and an agency acronym for "Regular Transcript Attainment and Selection Pass Alerts".
ReplyDeleteSimply put, it is a mainframe job application that is run through all Title II master beneficiary records each month. Its purpose is to look for defined combinations of record coding that, together, indicate that an action should be taken on a record. When it finds a matching case, it generates alerts for a PSC technician to review the case and tickles for subsequent followup alerts to be generated until the case is worked.
In this case, RETAP should have alerted for development of suspension of the beneficiaries at issue due to them potentially no longer meeting eligibility requirements based upon alien status factors. However, it failed to generate alerts to suspend this particular group of non-citizens either due to a programming glitch or due to the MBR not being correctly coded at the time it was initially established.
This is dependent on the beneficiary reporting their departure from the U.S. Quite a few do not report their departure and will have their mailing address changed to a friend's or family member's residence. Based on experience, this often happens when an alien returns to their country of origin to die, but payments continue to be issued. Brief departures less than 6 months do not require a beneficiary completing SSA-21 or reporting.
ReplyDeleteThe bigger problem stems from employees keeping the confusing rules and exceptions for the following straight:
1.) Alien Taxation
2.) Alien Suspension
3.) Lawful Presence
The more common aliens likely meet a 202(t) exception, but there is minimal training on these issues in region where immigration is low. San Francisco, New York and Dallas regions are probably the only ones that actively push these issues in the field. Richmond, New York and International PSCs may be the only ones to give adequate training on the matter.
Just my experience, not the whole story.