Feb 14, 2024

NPRM On Use Of Payroll Data Provider Info

     From a Notice of Proposed Rule-Making (NPRM) that the Social Security Administration will publish in the Federal Register tomorrow:

... We are proposing these rules ... for implementing the access to and use of the information held by payroll data providers. ...

We use wage and employment information to decide who can receive OASDI [Old Age, Survivors and Disability Insurance] disability benefits and SSI payments. We also use it to determine SSI payment amounts. Receiving complete, accurate, and timely wage and employment information allows us to administer our programs efficiently and to avoid improper payments that can occur when we do not have such information. Reviews of post-entitlement cases show that substantial gainful activity (SGA)4 continues to be the leading cause of overpayments in the OASDI disability program. In fact, SGA-related overpayments in the OASDI program averaged approximately $500 million annually as of fiscal year 2022.5 Further, wage discrepancies, which reached an annual average of approximately $1.4 billion in improper payments as of fiscal year 2022, have been a leading cause of improper payments in the SSI program for more than a decade. ...


4 comments:

Anonymous said...

In trying to address overpayments, SS wants to establish an information exchange with Equifax most likely, that verifies wages. Claimants would have to agree to terms of arrangement to get benefits. Test runs showed some errors but not enough to cause concern, but they did say it may be a burden for those having wage mismatches. They’d have to sort it out. But, overall it means less reliance on claimants to provide wage info, so it’s worth it? I didn’t see anything on possible data security breaches.
The comment period ends April 15 2024.

Anonymous said...

It is worth it, so long as claimants sign the 8240 giving permission. However, the article (and any seasoned CS can tell you) that Equifax doesn’t have all possible wages. There are discrepancies between what SSA can see in the DEQY/NDNH and sometimes it’s not even listed in the WorkNumber (Equifax). So will this help? Of course, is it as big of a deal as it’s cooked up to be? Not particularly.

Another thing to note is that claimants will be confused about the idea of having to report new employers but not necessarily their wages. They will assume SSA will just know when they start and stop working. It’s going to be a headache to handle that too.

Anonymous said...

So this automatic wage reporting only works if the claimant reports to SSA what employer they work for...and if they switch employers they need to report again? Yeah I can imagine that causing problems. The type of person who ends up with a massive overpayment from SGA earnings is not reporting their earnings monthly. What makes SSA think they will comply with new employment reporting?

But I guess perfection should not be the enemy of the good. This system should significantly reduce the most common forms of work related overpayments.

Anonymous said...

Correct. Unless I confused reading what was posted. As long as claimants would sign an 8240, they wouldn’t need to necessarily report wages. But they still have the responsibility of reporting new employers and when they start/stop work.