After a long break, the Social Security Administration is advancing proposed regulations. The agency has now asked the Office of Management and Budget to approve regulations to "implement the Commissioner’s access to and use of wage and employment information held by payroll data providers ... to help administer the title II Disability Insurance (DI) and title XVI Supplemental Security Income (SSI) programs and prevent improper payments."
13 comments:
Don't we already due this through NDNH reports ?
I hope this aimed at preventing huge overpayments by identifying them much quicker. If SSA can effectively track payroll month month with an automated system that would be huge. Many claimant's simply do not understand the trial work period rules, and this is especially true for unrepresented claimants.
I had one recent client come to me with a 70K over-payment, which resulted from an single month above SGA by less than $300. They identified this overpayment 5-6 years later -- and no he did not continue to earn SGA for any period after this, which likely made it harder to identify.
They’re getting rid of NDNH and need a replacement
3:55, was your client a DAC? Otherwise, wouldn't they be either in the TWP, or if they had exhausted their TWP months with sub-SGA work, in the EPE?
@12:23, I may be mistaken (and I hope someone sets me straight if I am), but my understanding is that the NDNH is pulling wage reporting information through 50 state employment systems. This proposal sound more like giving SSA access to wage information directly from the companies that process payroll, bypassing the state reporting level and, presumably, getting data quicker and more accurately.
NDNH is quarterly and usually at least a month or two after the quarter before the data posts. At best you /3 and apply same amount for each of the three months. The payroll exchange gives SSA the data as soon as the payroll company process and the interface posts. Gives monthly accuracy.
Until T2 can post wages and take adverse action instantly you will forever have people with these absurdly large overpayments. The process is too long and full of if/then routes.
My guess with no other details is that the EPE had ended. Once your 36 month EPE ends, the first dollar over SGA causes termination of benefits. And since most claimants do not report their pay stubs monthly, we retroactively terminate them and cause enormous overpayments.
Totally agree. Even if SSA receives the wages they need to take action, something they have problems doing.
This would dramatically decrease work for SSI CS's who still get paper wages for some claimants month to month. Remember this includes Disabled Children who may have two parents working. Sometimes you get all the wages for a complete month and sometimes you don't. That's if you get them at all. The FO spends time inputting, following up on, answering the phone about wages missing and oh yeah all the letters that go out for even the slightest change. Many times the system can't automatically generate a SSI OP letter so the CS in the FO has to make one. Did I mention we are a SSI staff of 6 servicing 5000 active SSI recipients? Now... I also need to answer the GI line (which is always ringing), and squeeze at least 3-4 Redets in between (30 min each and wages are also needed). All of this assuming nobody calls off. If they do it is off to the front to do Social Security Cards because the agency doesn't hire Service Reps anymore Whats that...you want your Attorney Fee and Windfall Offset done? Ha...get in line
I think that @9:53 has the right idea.
This will work great for people who truly work under SGA every month without issue.
There needs to be more changes in SSA Work CDR policy for this to be effective though. The vast majority of work CDRs that I have done, people do not even return the SSA-821, nor do they report paystubs. So effectively, we use what we have on the record. Send out the Due Process letter if their benefits are getting affected, again, they don't respond. Benefits terminate and the very first check they miss, guess who IMMEDIATELY calls/visits an office? Yeah, the non-reporter who could have solved all this by reporting it. Turns out, they have an IRWE, or a Subsidy, or they stopped working that job and didn't tell SSA and it should have been an UWA. Now the CR has to spend the time reopening the CDR, getting the correct form from the claimant, getting PC involved to fix the record. and that's just for ONE work CDR. On any given day, each CR in my office easily has 15-20 work CDRs pending. Policy (and systems) are a nightmare/joke at this point.
10:23, good point. It seems like if the termination is done retroactively, policy should be changed as needed to allow retroactive expedited reinstatements where the person would have qualified for one.
If it’s a “work termination” the get a pre-decisions notice before the the action is effectuated.
If they’ve exhausted their 36 month EPE, they could qualify for an expedited reinstatement if they reduce or stop their work due to their medical condition.
However, many stop just because their benefits got cut, not because they couldn’t continue working.
Great to have the wages but it does not mean work reviews will be completed timely.
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