GAO Criticizes CBSV

     From Social Security Administration: Actions Needed to Help Ensure Success of Electronic Verification Service, a report by the Government Accountability Office (GAO):

The Social Security Administration (SSA) launched the Electronic Consent Based Social Security Number Verification service in June 2020. The service seeks to reduce synthetic identity fraud, which combines fictitious and real information to fabricate an identity. The service allows authorized entities—generally financial institutions and their service providers—to verify an individual's name, Social Security number, and date of birth electronically. SSA spent about $62 million from fiscal year (FY) 2018 through FY 2023, based on SSA data. ...

SSA is required to fully recover the service's costs and collected about $25 million in user fees (40 percent of $62 million total costs) as of the end of FY 2023. SSA has not met its projections for fee collections due to lower-than-expected industry participation. SSA will need to collect about $14 million annually to meet its goal to recover all costs by the end of FY 2027, based on GAO's analysis (see figure). But it is unclear if SSA can meet its goal without increasing users or fees. Subscription data through December 2023 demonstrate that the service has not significantly increased users since enrollment opened in FY 2022, and fee collections decreased after SSA increased fees in July 2023.

 SSA officials told GAO they did not plan to take significant steps to increase use of the service. Industry participants GAO interviewed cited several factors limiting their use, such as difficult-to-interpret verification results. SSA also had not established performance measures and goals for the service's use and benefit. SSA could better ensure the service achieves its intended purpose of reducing synthetic identity fraud by developing strategies and assessing tradeoffs for expanding its use and establishing related performance measures and goals. ...

GAO is making seven recommendations to SSA, including that it implements appropriate controls over IT investments, updates cost estimation guidance, develops strategies to expand use of the service, and establishes related performance measures and goals. SSA concurred with all seven recommendations and stated that it will evaluate its policies and processes to determine how to address them. ...

    Note that the synthetic identity theft being discussed here isn't being directed at Social Security. It's directed at private financial institutions.

GAO Report On Covid

    The Government Accountability Office (GAO) has issued a report titled Social Security: Remote Service Delivery Increased During COVID-19, But More Could Be Done To Assist Vulnerable Populations. It's primarily a history of how Social Security reacted to Covid making it not too interesting to those of us who have lived and worked through it. The recommendations were pretty much worthless other than one to develop online applications in Spanish. That has nothing to do with Covid directly but certainly needs to be done.

Recommendations From GAO

     The Government Accountability Office (GAO) has some recommendations for Social Security. As is usual, they're vague, hardly actionable, little more than an exhortation to do better. I guess the GAO must do some valuable work but you seldom see evidence of it when it comes to Social Security.

Heavy Telework Usage At Social Security Compared To Other Agencies With Predictable Results

     From a recent report by the Government Accountability Office GAO:

 

Click on image to view full size

... The Social Security Administration (SSA), for example, reported that it faced challenges transitioning the work of its call center operators to a telework environment. According to SSA, nearly 4,000 of its customer call center agents did not telework prior to the COVID-19 pandemic. SSA explained that it was in the initial stages of replacing its telephone infrastructure at the onset of the pandemic and the transition to maximum telework required the agency to re-engineer the way it used current technology to provide all customer call center agents the ability to answer calls until its new agency-wide telephone system could be installed. When SSA transitioned to maximum telework in March 2020, the agency said it had enough equipment for only about one-third of these agents to perform their duties while teleworking.

SSA officials told us that call center agents without remote equipment were placed on administrative leave or weather and safety leave. Additionally, it took a couple of weeks for the agency to provide the customer call center agents on leave with the essential equipment that allowed them to telework. However, SSA officials reported that internet connectivity issues created challenges for employees receiving calls on its 800-customer service number. As a result, SSA operated with a limited number of employees available to respond to the 800 number calls from the public. This resulted in longer-than-normal call-wait times. SSA officials said that by June 2020, they had equipped employees with necessary technology to answer the increasing number of calls while teleworking.

SSA’s Office of the Inspector General reported that only 27 percent of teleservice center employees were answering calls on the national 800-number in mid-March of 2020. As of October 2020, according to the report, nearly all call center employees were answering calls, with approximately 1 percent on weather and safety leave who were unable to answer calls remotely due to internet connectivity issues. The report also stated that while SSA reduced the amount of callers receiving a busy message, this was partially enabled by reducing hours for the national 800-number. ...

How Long Can Kijakazi Stay As Acting Commissioner?

      Questions have been asked about the length of time that Kililo Kijakazi has served as Acting Commissioner of Social Security. The Vacancies Reform Act places limits on the length of time that a person can serve in an acting capacity as head of a federal agency. The contrary argument has been that the Vacancies Reform Act doesn't apply to an Acting Commissioner of Social Security since the Social Security Act itself has a specific provision concerning the designation of an Acting Commissioner which supersedes the Vacancies Reform Act. For whatever reason, the job of deciding how the Vacancies Reform Act applies to various positions has been lodged with the Government Accountability Office (GAO). The GAO has now issued an official ruling on the question. Kijakazi can continue to serve as Acting Commissioner because the Vacancies Reform Act doesn't apply to Social Security.

     The GAO ruling, of course, gives no answer to the question of why the President hasn't nominated a Commissioner. My guess is that because of the firing of Andrew Saul that Republicans would mount a pitched battle against the confirmation of anyone as Commissioner and the President, or more likely Senate Democratic leaders, don't want to waste the time on it. 

    I don't like the idea that only Republicans can be confirmed as Commissioner of Social Security.

Little Screening For Medical Consultants

      From Actions Needed by SSA to Ensure Disability Medical Consultants Are Properly Screened and Trained, a report by the Government Accountability Office:

SSA cannot be sure that the state agencies’ consultants are qualified and trained to appropriately inform decisions on disability claims. SSA policy requires state agencies to screen their consultants by checking them against a database of individuals barred from participating in federal programs. Also, SSA policy sets requirements for state agencies to provide initial and follow-up training. However, state agencies told us they do not always do so.  

Of the 52 agencies:
• 14 said they did not consistently perform required checks on consultants either when hiring or annually, and

• Nine said they did not give consultants some element of required initial or refresher training.

     The only requirement is that they not have a history of involvement in defrauding the federal government and they don't always enforce even that minimal standard? Is that how you run a quality program? Are opinions from such consultants entitled to deference?

Ticket To Work Doesn't Work

      From a recent report by the Government Accountability Office (GAO):

Disability beneficiaries participate in the Social Security Administration’s (SSA) Ticket to Work and Self-Sufficiency program (Ticket to Work) by assigning a "ticket" to service providers who, in turn, provide help with employment. SSA compensates the service providers when Ticket to Work participants achieve designated levels of work and earnings. Using SSA data from 2002, when the program began, through 2018, the most recent year available, GAO estimated that 5 years after starting Ticket to Work, participants’ average earnings were $2,451 more per year than that of similar nonparticipants. However, the majority of participants remained unemployed 5 years after starting Ticket to Work. 

Based on GAO’s analysis, the costs of Ticket to Work exceeded the savings in disability benefits to SSA by an estimated $806 million from 2002 through 2015, the most recent year with reliable savings data. Savings accrue when Ticket to Work participants receive lower benefits or leave the disability rolls due to earnings from work. GAO estimates that participants were slightly more likely to leave the rolls (9.7 percent) than nonparticipants who are similar across a range of characteristics such as age, gender, disability type, and education level (8.6 percent). A greater percentage of participants left the disability rolls due to work rather than for other reasons, such as medical improvement ...

GAO estimates that SSA incurred an additional $133 million to $169 million in costs (above the $806 million) from disability benefit overpayments to Ticket to Work participants. Overpayments can occur when beneficiaries who work do not report earnings to SSA or SSA delays in adjusting their benefit amounts. ...

     This report ignores an important reality.  No one makes claimants participate in the Ticket to Work program. Those who do participate are saying they believe they may have some capacity for work, meaning that they have better prospects for returning to work than claimants generally. Comparing the results in this group to claimants generally makes the Ticket to Work results look better than they are. Some of those who volunteered for Ticket to Work would have returned to work with or without Ticket to Work. We can't tell how many were only able to return to work due to Ticket to Work. If there were a control group, it would be some who volunteered for Ticket to Work but were arbitrarily denied Ticket to Work help but there is no such control group because none were turned away.

     Note the ridiculous level of overpayments associated with Ticket to Work even among a group of beneficiaries who told Social Security they planned to return to work. Don't blame claimants for this. Social Security's system for handling reports of return to work just doesn't work. 

     I'll make a modest suggestion. Social Security should almost completely stop relying upon wage reports from claimants because they do a poor job of reporting and Social Security does a worse job of recording what they report. We should define Substantial Gainful Activity on a quarterly basis and base work deductions on quarterly wages reported by employers. This can mostly be done by the computers. Yes, there will be problems with "wages" that are reported for work done earlier (such as sick pay, vacation pay and residual commissions) and yes, there will be problems with self-employment income but we'd be in a much better place than we're in now if those are the only problems we have to deal with.

GAO Report On Telework Security

      The Government Accountability Office (GAO) has issued a report on telework security at several agencies, including Social Security. The report is short on specifics, probably to avoid pointing out areas to attack, but Social Security comes in for mild criticism. I can’t tell whether it’s quibbles over the dotting of i’s and crossing of t’s or whether there have been substantive dangers.

GAO Report On ALJ Productivity Expectations

 

      From Process Needed to Review Productivity Expectations for Administrative Law Judges by the Government Accountability Office (GAO):

The Social Security Administration’s (SSA) administrative law judges review, process, and adjudicate requests for hearings on disability benefits. In 2007, the agency set an expectation—which SSA reported was based on trend data and some regional managers’ input—for judges to issue 500-700 dispositions(decisions and dismissals) each year, and the extent to which they have met this expectation has varied over time. SSA did not document the expectation-setting process in 2007, nor has it formally reviewed the expectation since. Judges in discussion groups held by GAO questioned the basis of the expectation and 87 percent of judges GAO surveyed (47 of 54) said the expectation was too high. ...  

Judges in selected hearing offices cited a variety of factors affecting their ability to meet the annual expectation. The top factor cited by judges GAO surveyed was the size of case files, which have increased five-fold on average since the expectation was established, according to SSA data. ...  

SSA monitors judges’ productivity and takes various actions when expectations are not met, ranging from informal conversations to formal discipline. In addition, judges in 11 of 13 discussion groups viewed telework restrictions as a consequence for not meeting expectations. Additionally, judges GAO surveyed reported feeling pressured to meet the expectations. For instance, 87 percent ofjudges surveyed (47 of 54) said that SSA placed too much emphasis on productivity, and some expressed concerns about their work quality and work-life balance. SSA officials said they do not formally seek feedback from judges onthe expectations. However, without feedback or other gauges of pressure, SSA lacks information that could help it appropriately balance timely case processing while maintaining high-quality work and employee morale. ...

      Social Security cannot continue to ignore the dramatic changes in disability claim files nor can they continue to blindly pressure ALJs to do the impossible.

     It's not just ALJs who are affected by the dramatic increase in the size of Social Security disability claim files. It's also the attorneys who represent the claimants. We not only have to read all those records but we have to obtain many of them. And we have to do this at a time when our fees have been effectively cut by the failure to increase the fee cap. If there is a dramatic increase in the number of Social Security disability claims filed next year, as seems likely, I'm not at all sure that there will be attorneys available to represent them. The pandemic plus the effective decrease in attorney fees have left Social Security attorneys in a seriously weakened financial position and unlikely to increase their staffing.

GAO Study Requested

      The Chairman of the House Social Security Subcommittee plus the Chairman of the Subcommittee having jurisdiction over the SSI program have asked the Government Accountability Office (GAO) to perform a study on service delivery at Social Security during the pandemic.

     That's fine but I'd prefer a hearing.

Need To Have Defined Roles When You're Being Agile

      From Fed Scoop:

The Social Security Administration can avoid confusion and bottlenecks on IT modernization projects by identifying roles for contracting officials in the agile software development process, according to the Government Accountability Office.

SSA adopted an agile approach to software development — characterized by incremental or iterative improvements to software — in 2017 to help meet its modernization goals, but those projects continue to see delays due to the murky roles of contracting officials, GAO says in a new report.

While SSA issued guidance on agile team members like project owners, developers and testers, it failed to do so for contracting officers (COs) and contracting officer’s representatives (CORs) within the context of agile projects.

“SSA officials told us they did not think they needed to specify the roles given that the contractors were only responsible for providing services,” reads GAO’s report released Monday. “However, according to leading practices for agile adoption, key roles in agile IT development include the program office, product owner, contracting personnel, and development team.” ...

GAO Report Critical Of Social Security's Treatment Of Disability Claims Complicated By Substance Abuse

     From a recent report by the Government Accountability Office (GAO):

... This report examines (1) what is known about the relationship between trends in prescription opioids and DI claims, and (2) how SSA [Social Security Administratino] considers potential prescription opioid misuse in its DI [Disability Insurance] eligibility decisions. GAO analyzed county-level data on opioid prescriptions and DI claims from 2006 through 2017; interviewed program staff involved in DI eligibility decisions in Alabama, Kentucky, and West Virginia, selected because of their high rates of opioid prescriptions and percentage of the adult population on DI; and reviewed case files for DI beneficiaries identified by the Centers for Medicare & Medicaid Services as being at risk for prescription opioid misuse or abuse. ... 

The numbers of opioid prescriptions and claims for the Social Security Administration’s (SSA) Disability Insurance (DI) program have each declined nationally in recent years, but rates vary widely across the country. National trends show both peaking between 2010 and 2014 and then declining. GAO’s analysis shows counties with the highest rates of both were concentrated in the Southeast (see figure). After accounting for economic, demographic, and other factors, GAO found that counties with higher rates of opioid prescriptions tended to have higher rates of DI claims from 2010 through 2017. These rates were also correlated with other factors. For example, counties with higher rates of each tended to have higher poverty rates. However, GAO was unable to determine whether there is a causal relationship between rates of opioid prescriptions and DI claims or other factors, given readily available data.

Program staff are required to evaluate and document substance use disorders (including opioids not taken as prescribed) when making certain DI eligibility decisions. Specifically, staff are required to evaluate potential substance use disorders for certain DI claims and deny benefits, for example, if the claimant would not be considered disabled if they stopped using drugs or alcohol. In addition, staff are generally required to document the rationale for their decision so that another reviewer can understand how they made the decision. However,staff in five of the six offices GAO visited in three states were confused about when to evaluate substance use disorders, and nine of 15 case files that GAO reviewed in which an evaluation was conducted did not have a documented rationale. SSA officials acknowledged the need to clarify policies on when to evaluate substance use disorders, and that a poorly documented rationale could lead to reversals or remands of decisions. Without ensuring that SSA’s policies are understood and that staff document their rationale, the agency may expend resources re-working cases and, in turn, delay benefits to individuals eligible for assistance.  ...

     I imagine that Social Security will find a simple way of responding to GAO's findings. They'll just make the current rule -- when in doubt, deny -- even more explicit. They certainly won't do anything to help people with dual diagnoses -- substance abuse plus another physical or mental impairment. If anything, the GAO report seems only to be telling Social Security to find a better way of checking off boxes rather than encouraging them to take a serious look at the problem.
     The GAO itself could have taken a more in-depth look at the problem. They fail to mention that the dual diagnosis issue primary concerns one psychiatric illness -- bipolar disorder -- which has a dramatic overlap with substance abuse strongly suggesting a genetic link. It's literally impossible to tease out what's caused by bipolar disorder from what's caused by substance abuse because it's all one disease entity. The GAO investigators also failed to understand that the Social Security Administration itself changed its policies in 2013 to put the burden on the claimant to prove a negative -- that their substance abuse isn't material to the determination of disability. If you're not a lawyer, let me clue you in on something well understood by lawyers. It's impossible to prove a negative. For instance, I can tell you that I've never used crack cocaine -- I haven't -- but how can I prove it? That's the whole point of Social Security's current policies. Put an impossible burden on the claimants and then deny them. The GAO report says in a footnote that Social Security told them that Social Security Ruling 13-2p, the policy change I mentioned earlier, really didn't change anything. That's seriously revisionist history. The policy in effect before the ruling was 180 degrees different. It's like this every time Social Security changes its policies. The agency insists that it hasn't changed its policies when it's obvious that it has.

Social Security Online System Vulnerable

     From ZDNet:

The 2017 Equifax security breach has thrown a wrench in the process used by US government agencies to verify the identity of US citizens applying for various benefits via its online portals.

This process, called online identity verification or remote identity proofing, relied on data provided by credit reporting agencies (CRAs) like Equifax, as a proof of the applicant's identity. ... 

In 2017, the National Institute of Standards and Technology (NIST) reacted to this hack by issuing guidance to government agencies, with recommendations on replacing the CRA-based online identity proofing with other solutions like sending an SMS to a user's phone, or having the user send/upload a scan of a physical ID to the government agency, as a proof of identity. ... 

But a report from the US Government Accountability Office (GAO), a bi-partisan government agency that provides auditing, evaluation, and investigative services for Congress, has found that only two of six of the government agencies they tested had followed the NIST guidance. 

GAO found that the Centers for Medicare and Medicaid Services (CMS), the Social Security Administration (SSA), the US Postal Service (USPS), and the Department of Veterans Affairs (VA) were still relying on the old CRA databases for online identity verification. ... 

The agencies who were part of the GAO inquiry said that one of the reasons they haven't migrated to a new system yet, as per the NIST guidance, is because of "high costs and implementation challenges for certain segments of the public," which the agencies fear might prevent certain US citizens from being able to use their online portals. ... 

The Social Security Administration (SSA) and the United States Postal Service (USPS) intend to reduce or eliminate their use of knowledge-based verification some time in the future but do not yet have specific plans for doing so. ..

SSA Makes Top Ten List

     The Social Security Administration has made a top ten list — the top ten of agencies with critical federal agency legacy information technology systems in need of modernization, according to the Government Accountability Office (OMB).

GAO Criticizes SSA Online Verification

     From a recent Government Accountability Office (GAO) report:

Remote identity proofing is the process federal agencies and other entities use to verify that the individuals who apply online for benefits and services are who they claim to be. To perform remote identity proofing, agencies that GAO reviewed rely on consumer reporting agencies (CRAs) to conduct a procedure known as knowledge-based verification. This type of verification involves asking applicants seeking federal benefits or services personal questions derived from information found in their credit files, with the assumption that only the true owner of the identity would know the answers. If the applicant responds correctly, their identity is considered to be verified. For example, the Social Security Administration (SSA) uses this technique to verify the identities of individuals seeking access to the “My Social Security” service, which allows them to check the status of benefit applications, request a replacement Social Security or Medicare card, and request other services. 

However, data stolen in recent breaches, such as the 2017 Equifax breach, could be used fraudulently to respond to knowledge-based verification questions. The risk that an attacker could obtain and use an individual’s personal information to answer knowledge-based verification questions and impersonate that individual led the National Institute of Standards and Technology (NIST) to issue guidance in 2017 that effectively prohibits agencies from using knowledge- based verification for sensitive applications. Alternative methods are available that provide stronger security, as shown in Figure 1. However, these methods may have limitations in cost, convenience, and technological maturity, and they may not be viable for all segments of the public. ...

GAO Report Pans Idea Of Mandating Increased Private Disability Insurance

     Some right wing "think tanks" have been promoting the notion that mandatory private disability benefits could somehow substitute for or augment Social Security disability benefits. I wouldn't call the ideas even half baked. It's been more like vague notions. The proponents of these ideas got Senator Orrin Hatch to ask the Government Accountability Office (GAO) to do a report on their ideas, to the extent that GAO could even identify what the ideas were. Predictably, the GAO report wasn't encouraging for these reasons:

• Insurers told GAO that is was unclear how expanding PDI [Private Disability Insurance] would affect PDI premiums and the impact this would have on enrollment.
• Employers told GAO they were concerned about potential additional requirements or administrative burdens that would be placed on them if PDI were expanded.
• Employee and disability advocacy groups told GAO they were concerned about whether PDI expansion would provide standard services or employee protections currently available under SSDI, especially with respect to PDI expansion proposals that would replace SSDI for 2 year.

     One enormous problem is that long term disability insurance (LTD) as we know it is reduced by the amount that Social Security pays. That means that LTD just pays the full rate until a claimant is approved by Social Security and then supplements the Social Security disability benefits thereafter. There's only a handful of LTD recipients who never get approved for Social Security disability benefits and continue to receive the full unreduced LTD payment indefinitely. Making LTD the primary payor would completely change the insurance product and make it much, much more expensive. It's never been clear to me whether the think tank proponents of private disability insurance understand just how different what they're asking for would be from any product that exists now. The LTD carriers might like to get big contracts for helping Social Security administer its disability benefits programs but I've never seen evidence that the LTD carriers actually want to be the insurers. Apparently, that's what GAO heard directly from the insurance companies.

What's The Alternative?

     From Salon:

Nearly five months after an unprecedented security breach at the credit rating firm Equifax exposed Social Security numbers and other data, making some 147 million Americans vulnerable to potential identity theft and fraud attacks, the Social Security Administration continues to use an identity security system devised by Equifax for the MySocialSecurity online portal.

Equifax was awarded a no-bid $10 million contract back in early 2016, as the company boasted at the time, “to help the SSA manage risk and mitigate fraud for the mySocialSecurity system, a personalized portal for customers to access some of SSA’s services such as the online statement.”  ...

[Social Security] Press officer Mark Hinkle would only tell Salon that “Equifax is not, and has never been, responsible for the authentication of mySocialSecurity users, or building, maintaining or supporting any of Social Security’s platforms.” 

That response suggests that, in fact, all the financially strapped SSA actually got from Equifax for its $10 million was a bunch of security questions to ask those trying to prove their identity before accessing the online customer portal.... Based on the questions actually found on the site, it would appear that Equifax offered a duplicate version of the questions it uses for its own flawed and hacked customer access security system for use by the SSA’s MySocialSecurity Portal, and no doubt the IRS’ online portal too. ...

     The Social Security Administration has been under enormous pressure to move its operations online. There are Congressional hearings where members of Congress seem incredulous that the agency even has field offices. The Government Accountability Office (GAO) keeps pressing to move everything online. If Uber can do it, why can't Social Security? This is based upon a naive belief that Social Security's operations are relatively simple which they might be if the agency only had to take retirement claims. However, many of Social Security's operations -- like disability, survivor and SSI claims -- are way too complicated to be handled online. It's sort of like insisting that a funeral parlor move all its operations online. Sorry, but there's that pesky body you have to deal with somehow as well as bereaved relatives who demandTLC.
     The EquiFax situation isn't as dire as this article suggests. EquiFax isn't getting any data from Social Security. It all goes in one direction from EquiFax to Social Security. =
     I can't say whether the authentication process Social Security is using is adequate but I don't know what the alternative would be other than to give up on online services. That would be fine with me as long as Congress gives Social Security adequate resources but that's not going to happen.

SSA Office Space Declining

     From a study by the Government Accountability Office (GAO):

The Social Security Administration (SSA) has reduced its physical footprint and expanded delivery of services remotely, including online. SSA reduced the total square footage of its facilities by about 1.4 million square feet (or about 5 percent) from fiscal years 2012 to 2016, according to GAO's analysis, by applying new standards for determining the size of offices and consolidating facilities. ... SSA has also expanded the services it offers remotely, and online use has increased for certain services such as disability and retirement applications. Despite this increase, in-person contacts at field offices have not changed substantially, with about the same number in fiscal year 2016 as in fiscal year 2007 (approximately 43 million). This may be due to growing demand for services as well as certain services not yet being fully available online. ...

SSA is taking steps to make remote services easier to use, for example by adding new features to its website and offering alternate approaches for accessing services, but does not consistently evaluate them, which could limit its ability to shift more services online and further reconfigure its footprint. For example, SSA has added features allowing online customers to interact directly with SSA staff. However, SSA does not track staff follow-ups to deal with any errors in online benefit applications in order to improve them, as called for by federal internal control standards. To enhance access to remote services, SSA has introduced alternate service approaches such as videoconferencing in third-party sites; however, it does not have performance goals for these approaches. GAO has previously identified performance goals as a best practice, which may help agencies improve their customer service. ...

We're Doing A Poor Job Of Helping Disabled Young People Make The Transition From School To Work

     From a recent report by the Government Accountability Office (GAO):

The Social Security Administration’s (SSA) primary approach for encouraging employment for transition-age youth (ages 14 to 17) with disabilities who receive Supplemental Security Income (SSI) is work incentives that allow them to keep at least some of their SSI benefits and Medicaid coverage while they work. But few transition-age youth benefit from these incentives. ... The work incentive targeted specifically to younger SSI recipients is the Student Earned Income Exclusion (SEIE), which allows income to be excluded from benefits calculations if a recipient is a student under age 22. However, less than 1.5 percent of all transition-age youth — and generally less than half of those with earnings —benefited from SEIE in 2012 through 2015. ... Data also show that almost no youth benefited from other incentives that allow them to exclude earnings used for specific purposes, such as the Impairment-Related Work Expenses incentive. The effectiveness of SSA-administered work incentives may be further limited because, according to SSA and other officials, youth and their families are often unaware of or do not understand them, and may fear that work will negatively affect their benefits or eligibility. ... 

SSA does not have a systematic way to connect transition-age youth on SSI to state Vocational Rehabilitation (VR) agencies that provide training and employment services under the VR State Grants program administered by the Department of Education (Education). Although youth receiving SSI are generally presumed to be eligible for VR services, GAO found that less than 1 percent had an open VR service record in 2015 in four of the five states from which GAO collected VR data. ...

We recommend that the Acting Commissioner of the Social Security Administration take the following actions: 

1. Analyze the SEIE data to determine why a large proportion of transition- age youth on SSI with reported earnings did not benefit from the SEIE and, if warranted, take actions to ensure that those eligible for the incentive benefit from it. 
2. Analyze options to improve communication about SSA-administered work incentives and the implications of work on SSI benefits, with a goal of increasing understanding of SSI program rules and work incentives among transition-age youth and their families. This should include, but not necessarily be limited to, updating SSAs procedures for staff meeting with SSI applicants, recipients, and their families to regularly and consistently discuss – when applicable—how work incentives can prevent reductions in benefit levels and how work history is considered during eligibility redeterminations. 
3. Work with the Secretary of Education to determine the extent to which youth on SSI are not receiving transition services through schools that can connect them to VR agencies and services. 
4. Explore various options for increasing connections to VR agencies and services , including their potential costs and benefits. One option, among others, could be to expand the Ticket to Work program to include youth.

     The report addresses an important topic. I have a few thoughts on this:

• Transition services are vitally important to disabled youths who are about to leave school. I have seen far too many cases where young people who urgently needed VR had no idea that VR exists. When I see clients in this situation, I tell them and their parents about VR but, of course, most disabled young people never see a Social Security attorney.
• Some years ago, at least in North Carolina, schools worked with VR to identify disabled young people in need of help and made sure they were offered that help. That seemed extremely effective. That's not happening now. (What about other states?) I'm pretty sure the problem is lack of VR funding. I'm not sure why the school systems don't at least give the disabled young people and their families the phone number for VR although as I discuss below state Vocational Rehabilitation may be of only limited value at this point.
• Sheltered workshops are a vital part of vocational rehabilitation for disabled young people trying to make the transition from school to work. Sheltered workshops have almost completely disappeared in North Carolina. I'm pretty sure it's due to lack of funding. (What about other states?)
• What I've seen over the last decade or two is declining effectiveness of North Carolina VR. They seem to be able to do little other than pay for community college courses. Disabled young people trying to make the transition from school to work typically need far more help. (What about other states?)
• Social Security's work incentives are far, far too complicated. That's not the agency's fault. Congress wrote the work incentives, not Social Security, but don't expect simplification to help much. There's plenty of evidence that work incentives have little value.
• Social Security lacks funding to do much to help disabled young people making the transition from school to work. I suppose the agency could send out mailings but they would need additional appropriations to do anything more. I think the money might be better spent elsewhere.
• I think additional funding for VR along with provisions requiring VR to coordinate with school systems would work better than anything the Social Security Administration can do.
• Finally, don't expect miracles. Most disabled children won't work on a regular basis no matter what anyone does. Many people who work at the Office of Disability Adjudication and Review (ODAR) or who represent claimants get the mistaken impression that almost all children receiving SSI benefits have psychiatric or cognitive impairments that are of less than overwhelming severity. That's because that group is vastly over-represented in the population requesting hearings on SSI child disability claims. Most disabled children on SSI have physical problems and most of those problems are so overwhelming that the disability claims are approved quickly. Work is unlikely to ever be in the picture for most of these children. Many of those suffering from psychiatric disability have schizophrenia. While Social Security is denying too many schizophrenics, it's still a fact that most schizophrenia claims are being approved fairly quickly. The vast majority of schizophrenics won't be able to work no matter what anyone does for them.

Student Loan Offset Problems

     The Government Accountability Office (GAO) has issued a 90 page report on the offsets applied to Social Security benefits due to unpaid student loans. Even though the GAO seems to me to try to downplay the problem, it's still clear that it's real and serious. Many people are being thrown into poverty by the offsets as shown by the chart below, even though many of the student loans went to pay for nearly worthless online education.

Click on chart to view full size