I Have Been Seeing More Of This Problem In The Last Year

      From a recent report by Social Security’s Office of Inspector General (OIG):

… [W]e reviewed a sample of 274 cases from a population of 1.5 million recipients SSA placed in non-payment status codes from March 2020 through May 2022 after determining the recipients failed to provide requested information or take requested actions. Additionally, we identified 61,176 recipients who were placed into 7 non­payment status codes during periods SSA had prohibited their use. 

Results 

SSA did not act in accordance with its policy and procedures when it processed SSI ineligibility determinations and suspensions based on applicants’, recipients’, or representative payees’ failure to provide information. SSA’s employees did not complete all required steps for 156 (57 percent) of the 274 sampled cases placed in non-payment status, which led to 96 of the 156 recipients not receiving $203,133 in SSI payments they should have received. Projecting these results to our population, we estimate SSA did not follow its policy before it denied or suspended SSI payments for 871,330 recipients. Of these recipients, we estimate 536,203 did not receive $647 million in SSI payments they should have received. …

     It’s way too easy for field office employees to deny on the basis of failure to provide information without making any serious effort to contact the claimant.

It’s Hard To Administer SSI

      From a recent report by Social Security’s Office of Inspector General:

… SSA’s SSI financial account validation process for applicants and recipients who alleged having less than $400 in financial accounts did not always lead to accurate SSI determinations. SSA’s process led it to make inaccurate SSI resource determinations for 27 of the 140 recipients reviewed. Based on these determinations, SSA paid the recipients $130,430 in SSI payments they were not eligible to receive. Based on these sample results, we estimate SSA incorrectly made SSI resource determinations that led to 198,960 recipients receiving $718 million in SSI payments for which they were not eligible because applicants/recipients under­reported their financial account balances by $100 or more. 

SSA’s policy did not require that it validate the recipients’ financial account balances because they alleged they had less than $400 in liquid resources. The AFI reports we requested identified 102 of 140 applicants/recipients under-reported their financial account balances by $100 or more. Additionally, the AFI reports showed 28 of the applicants/recipients owned financial accounts of which SSA was unaware. Based on these sample results, we estimate 800,140 applicants/recipients under-reported their financial account balances by $100 or more, with 219,640 failing to report all the financial accounts they owned to SSA. ..

 

Rep Payee Problems

     From a recent report by Social Security’s Office of Inspector General:

SSA did not ensure employees made complete and accurate capability determinations for disabled beneficiaries who previously had payees.  We estimate, for approximately 19,000 disabled beneficiaries who previously had payees, there was no evidence SSA determined the beneficiaries were capable of managing, or directing the management of, their benefits.  In addition, there was no evidence SSA performed proper follow-up development.  SSA paid approximately $887 million in benefits directly to these beneficiaries without evidence to show they were capable of, or were, using the benefits to meet their basic needs.  Finally, we estimate SSA did not properly document capability determinations for approximately 6,700 beneficiaries. 

This occurred because SSA did not have effective system controls to ensure employees properly documented their capability determinations.  Additionally, SSA did not have controls to ensure employees authorized direct payments to incapable beneficiaries in accordance with SSA’s policy and properly performed the follow-up reviews after they made interim direct payment to those 

A 73% Error Rate?

    From Follow-up on the Accuracy of the Social Security Administration’s Manual Billing Process to Collect Medicare Premiums, a report by Social Security's Office of Inspector General:

...  When a Medicare Part B recipient receives a monthly Social Security benefit, SSA deducts the monthly Medicare premium from the benefit. Some individuals’ monthly Social Security benefit is lower than the monthly Medicare premium. SSA bills these individuals for the balance of the premium. Each year, SSA uses its Benefit Rate Increase (BRI) program to generate an alert for individuals whose Social Security benefit is lower than their monthly Medicare premium. SSA considers this alert to be a high priority because SSA must bill beneficiaries the remaining Medicare premium as soon as possible and timely issue benefit statements.

In a 2016 report on the Accuracy of the Social Security Administration’s Manual Billing Process to Collect Medicare Premiums, we concluded SSA incorrectly calculated the Medicare premium owed for 48 percent of the sampled beneficiaries we reviewed. For this audit, we reviewed a random sample of 100 beneficiaries from a population of 111,976 beneficiaries SSA’s BRI program identified in November 2022.

SSA timely processed the cases in our sample; however, it incorrectly processed or calculated the Medicare premium owed for 73 of the 100 beneficiaries we reviewed where their Medicare premium was higher than their SSA benefit payments. This included approximately $147,000 in processing errors where employees did not correctly credit monthly benefits to Medicare billing information and $102,000 in payment errors where beneficiaries were not correctly billed for Medicare premiums, which led to overages and arrearages.

Based on the results for our sample, we project SSA did not correctly update records or calculate Medicare premiums owed for approximately 82,000 beneficiaries, which resulted in approximately $76 million in billing errors and $91 million in processing errors. ...

Report On Priority Cases

    From The Social Security Administration’s Processing of Priority Cases, a report by Social Security's Office of Inspector General (OIG):

... Each year, SSA identifies at least 200,000 (10 percent) of the initial disability applications as priority cases. SSA identifies priority cases for expedited processing through a combination of automated and manual means. Policy requires that SSA develop and process cases identified as priority expeditiously.

We reviewed 668,352 claimants whose initial disability applications SSA selected for priority processing. We also reviewed 153,964 claimants who had initial disability applications that may have been eligible for priority processing.

Generally, SSA properly identified, expedited, and processed initial disability applications that qualified as a priority case. SSA’s selection of cases for priority processing was proper for over 96.1 percent of claimants we reviewed.

However, SSA did not expeditiously develop and process initial disability applications for 11 (6.1 percent) of 180 sampled claimants. Delays occurred because SSA did not always monitor the processing of the 11 cases that were selected for priority processing to ensure they were processed expeditiously. Further, SSA’s policy does not specify overall processing timeframes and/or goals for priority cases. As a result, we estimate SSA delayed case development and processing for 40,844 claimants with priority cases.

I Thought That Job One At The Payment Centers Was To Pay People

     From Reducing Processing Centers’ Pending Actions, a report by Social Security's Office of Inspector General (OIG):

...  SSA met its annual PC [Payment Center] pending actions performance measure goal in 4 of the 6 FYs [Fiscal Years] between FY 2018 through 2023. SSA reported it did not meet its goals in the remaining 2 FYs because of unexpected staff reductions, increased workloads, and less than expected overtime funding it would have used to pay employees to process more PC pending actions.

Although SSA achieved its PC pending actions performance goals in 4 of the last 6 FYs, there was no overall reduction in PC pending actions over those 6 years. In fact, the PC pending actions backlog increased from 3.2 million in FY 2018 to 4.6 million in FY 2023. As the backlog grows, many PC pending actions remain unresolved for long periods of time. From a sample of 139 pending actions, 102 (73 percent) were pending for 300 days or more, with 60 of the 102 pending for 500 days or more.

Delays in processing PC pending actions can lead to higher improper payments, which increased some beneficiaries’ financial burden as they waited longer for underpayments or were charged with increased overpayment amounts. If SSA resolved the PC pending actions we reviewed at the earliest possible instance, we estimate it would have determined approximately 528,000 beneficiaries were improperly paid approximately $534 million. After the pending actions were not processed for 12 months, the improper payment amount for those same beneficiaries rose to approximately $756 million. By the time of our review, many of the PC pending actions had been pending for longer than 12 months, and the improper payment amount had increased to approximately $1.1 billion.

    Notice that it didn't seem to bother OIG that the payment centers were frequently failing to pay benefits for long periods of time. The only thing they seemed to have been concerned about was an increase in overpayments. This in a nutshell is the OIG outlook on the Social Security world -- It doesn't matter when or if you pay claimants what they're due; the only thing that counts is that you not overpay them. That outlook is a prescription for disaster for claimants.

Belated OIG Report On Field Office Waiting Times

Photo taken on May 7 outside Raleigh FO

    From Customer Wait Times in the Social Security Administration’s Field Offices and Card Centers, a report by Social Security's Office of Inspector General:

... In February and March 2023, we visited 76 FOs [Field Offices] and SSCCs [Social Security Card Centers]. During these visits, we observed customer wait times and interviewed office management regarding best practices for reducing customer wait times. We also interviewed SSA staff to determine Agency initiatives to enhance the customer experience and reduce wait times.

During our office visits, we observed the wait times of customers throughout their visit for services. For the 76 FOs and SSCCs we visited, we observed the average wait time for customers before check-in ranged from 5 to 12 minutes, depending on the method of check-in. The check-in method(s) used varied, based on management’s discretion. Once checked in, customers waited an average of 32 to 45 minutes to receive services. We do not assert, and the reader should not infer, that our observations during our visits represent all SSA offices. ...

    Why did it take more than a year after the data was collected for OIG to issue a report?

Detecting Overpayments Due To Marriage

     From Impact of Undetected Marriages on Social Security Administration Payments, a report by Social Security's Office of Inspector General:

... Marriage can impact a Supplemental Security Income (SSI) or Old-Age, Survivors, and Disability Insurance (OASDI) beneficiary’s payment. We randomly selected 1 of 20 segments from the Supplemental Security Record (SSR) and Master Beneficiary Record (MBR). We identified 3 populations with name changes and sampled 250 individuals ...

SSA did not always take the necessary manual actions to properly update 38 of the 250 payment records for SSI recipients or OASDI beneficiaries when there was a name change because of marriage. Furthermore, SSA had not taken manual action on 11 SSI recipients or OASDI beneficiaries who changed their name via the iSSNRC application. We estimate SSA improperly paid 16,631 SSI recipients and OASDI beneficiaries approximately $240.9 million when there was a name change because of marriage. ...

When a person changes their name, SSA systems do not automatically determine whether they are receiving benefits. SSA does not know about a marriage until an individual reports it. ...

SSA explored the feasibility of using electronic marriage data to determine if OASDI beneficiaries changed their marital status. However, not all states/jurisdictions have a central repository of electronic marriage data, and many do not require, or collect, the marriage applicants’ Social Security number. ...

    There's a lot that Social Security could do to prevent overpayments if it had an adequate workforce. A different Inspector General might want to issue a report detailing how much money is being wasted due to inadequate staffing at the Social Security Administration.

    By the way, there's also the question of whether marriage should have as many effects as it does on Social Security and SSI benefits but that's another topic.

Problems With Retirement Earnings Test

     From The Social Security Administration’s Enforcement of the Earnings Test, a report by Social Security's Office of Inspector General:

The earnings test is a provision of the Social Security Act that requires that SSA withhold payments from beneficiaries who are under full retirement age (FRA) if their earnings exceed a certain limit. ...

SSA did not accurately or timely pay beneficiaries subject to the earnings test. As a result, we estimate SSA:

• inaccurately calculated approximately 47,000 of the 294,000 earnings-test overpayments established in FY 2021, totaling more than $148 million;
• inaccurately paid approximately 9,000 beneficiaries approximately $29 million based on estimated earnings that were more or less than their actual earnings; and
• did not timely pay approximately 176,000 beneficiaries approximately $81 million in monthly benefit increases. ...

    And to think that the retirement earnings test used to apply to all retirees regardless of age.

Improvement In Mail Processing But Some Problems Persist

    From Follow-up: The Social Security Administration’s Implementation of Mail Procedures, a report by Social Security's Office of Inspector General (footnotes omitted):

...  Mail processing at SSA offices is primarily a manual workload. This requires that managers and employees open each mail item, scan the program-related documents into a workload management system, and assign to staff. SSA’s regional offices are responsible for monitoring the status of mail handling in their region ...

In September 2021, SSA issued a Mail Handling BPD that focused on 10 key issues significant to mail processing. ...

We judgmentally selected and visited 87 SSA offices throughout the continental United States. At each office, we interviewed management and observed the mail handling process. ...

SSA offices had improved mail processing since our July 2021 review. SSA offices we visited generally complied with the requirements in the Agency’s Mail Handling BPD.While most offices were meeting the requirements of 6 of the 10 BPD key issues, some offices did not always meet the requirements ...

Of the 87 offices visited, the following offices complied with the timeliness metrics established:

• 86 (98.9 percent) received mail directly from mail carriers,

• 84  (96.6 percent) opened mail within 1 business day of receipt,

• 81 (93.1 percent) processed all Social Security number applications within 5 business days of receipt, and

• 79 (90.8 percent) returned all original primary evidence documents to customers within 3 business days  of receipt and kept a log of the returned documents.  ...

• 73 (83.9 percent) processed their undeliverable returned mail within 5 business days of receipt, as required. However, the remaining 14 offices had undeliverable returned mail over 30-days-old. Moreover, three of these offices had mail dated back to January 2022, and one with mail dated back to September 2019. ... 
  

• 67 (77 percent) complied with the requirements for remittances and returned unendorsed Treasury checks. Specifically, the offices processed to completion all remittances and returned unendorsed Treasury checks within 1 business day of receipt, 16 recorded receipt in the office’s remittance log, and secured 17 checks that could not be processed to completion the same day. The remaining 20 offices had the following issues:
  

• 17 did not process remittances within the required timeframe. Of these, 15 offices had checks that remained unprocessed 3 to 31 days after the 1-business-day requirement. Additionally, two offices had unprocessed checks that dated back to July 2020 and November 2021. The banks could return these checks as non-negotiable since they were not endorsed within 6 months, as required by banks.,
  

• 5 did not use remittance logs, as required. For example, 1 office had 77 unprocessed checks that were unsecured and accessible to office staff. In fact, 1 office had 58 checks dating back to October 2022 with no record they existed. The new remittance manager was unaware these unprocessed checks were locked in a safe because they were not recorded in the office’s remittance log.
  

• 2 did not properly secure the unprocessed checks. For example, 1 office had 77 unprocessed checks that were unsecured and accessible to office staff.

• 36 (41.4 percent) scanned and profiled mail within 5 business days of receipt, as required. The remaining 51 offices, on average, scanned and profiled mail within 10 business days of receipt. ...

Administering SSI Is Difficult

     From a recent report by Social Security's Office of Inspector General (OIG):

... Homes that SSI applicants and recipients own and reside in do not count toward SSI resource limits. The current market values of any properties other than their owned primary residences, referred to as non-home real properties (NHRP), are generally considered countable resources for SSI eligibility purposes.

In 2017, SSA introduced an electronic search application that employees are required to use in most cases to identify applicants’ and recipients’ real-property information. We reviewed 400 applicants/recipients who had real properties identified through the search application. Of these, properties were a determining factor for SSI eligibility and payments in 122 cases.

SSA employees did not accurately determine property ownership and/or values for 17 (14 percent) of 122 SSI applicants/recipients. As a result, applicants were possibly denied SSI when they should not have been, and recipients received SSI payments for which they were not eligible. Of the 17 applicants/recipients:

• 4 applicants may have been incorrectly denied SSI. SSA needs to further develop these cases to verify the applicants’ SSI eligibility, and
• 13 recipients received over $180,000 in SSI payments for which they were not eligible.We determined employees did not correctly determine the applicants’/recipients’ countable resources, including reviewing for prior ownership. In addition, SSA employees did not add required documentation in SSA’s records to support their real-property determinations for these 17, and 43 other, cases.

We project 1,204 applicants may have been improperly denied SSI eligibility, and 35,885 recipients were improperly paid because SSA employees made inaccurate real-property determinations. ...

Speech Analytics Technology In Use At SSA

     Social Security's Office of Inspector General (OIG) has issued a report on Controls over the Social Security Administration’s National 800-number Service During the COVID-19 Pandemic. It should surprise no one that the controls started off rough and got better with time. What I found interesting is information about a method the agency is using to evaluate telephone service:

... Speech analytics is a method, separate from service observation, designed to improve the efficiency and quality of service 800-number employees provide to the public. SSA’s speech analytics technology, which it began using in April 2017, converts recorded 800-number calls to a text format. SSA uses it to pinpoint patterns for further research and analysis via manual process. Employees in the Office of Customer Service and/or teleservice centers apply such criteria as words, phrases, or duration of calls to search the converted text to identify calls that should be referred to regional management for further evaluation. Calls can be identified through speech analytics based on the use of derogatory terms, a disconnected call that did not assist callers, and employees not responding to callers during the call. ...

ALJ Trends

     Social Security's Office of Inspector General has issued a report on Administrative Law Judge Trends.

    Below are three charts from the report. As always, click on the image to view full size.

Fee Payments Have Declined

     Social Security's Office of Inspector General (OIG) has issued a report on payments to attorneys and others for representing claimants before the agency. The data was already available but they've added charts. Below are a couple of them.

Can't Say Whether Some Automation Projects Have Helped

      From Manual Processes for Resource-intensive Workloads, a report by Social Security's Office of  Inspector General

Our objective was to determine whether the Social Security Administration’s (SSA) automation enhancements (1) reduced manual processing for resource-intensive workloads and (2) were cost-effective. ...

SSA’s automation enhancements reduced the need for manual processing for some workloads from FYs 2019 to 2021. These initiatives aimed to improve the efficiency and effectiveness of SSA’s operations; however, they were not always immediately cost-effective. Additionally, SSA could not identify cost or savings estimates for some enhancements; thus, we could not determine whether they were cost-effective.  ......

Deaths During Waiting Period

     From a recent report by Social Security's Office of Inspector General (footnotes omitted):

This report provides information on 610,219 Disability Insurance (DI) beneficiaries whose claims were approved at the initial claim level by various state disability determination services (DDS) during Calendar Years (CY) 2020 and 2021. In each case, disability examiners (1) determined the beneficiaries had disabling conditions that were permanent and that medical improvement was not expected, and (2) established a 7-year medical review diary. As of December 22, 2022, SSA had terminated the DI benefit payment status of only 319 (.05 percent) beneficiaries after determining they were no longer disabled. However, SSA had terminated the payment status of 75,857 beneficiaries who died after SSA approved their claims, including 4,444 beneficiaries who died during the 5-month DI waiting period. ...

Click on image to view full size

 

OIG Report On Pandemic Effect On DDS Processing Of Disability Claims

     From a report by Social Security's Office of Inspector General (OIG) on the effects of the pandemic on processing of Social Security disability claims:

While SSA received fewer initial claims during the pandemic, it took the DDSs [Disability Determination Services] longer to process them than the year before. Before the pandemic, DDS’ average processing time for an initial claim was 95.5 days. This increased to 139.4 days and 135.5 days, respectively, during the first and second years of the pandemic. Numerous factors contributed to this:

• CEs - The number of CEs [Consultative Examinations] performed during the pandemic decreased, as SSA suspended in-person CEs for a period of time. Once DDSs resumed in-person CEs, they still had issues scheduling CEs because for example, (1) not all CE providers returned to conducting CEs and (2) claimants refused to attend in-person CEs because of fear of exposure to COVID-19.
• DDS Staffing and Training – About 4,000 DDS employees resigned or retired during the pandemic, but DDSs hired 4,305 employees during this same time. However, it takes a newly hired disability examiner an average of 2 years to become proficient at processing most initial claim workloads.
• Telework and Communication with Claimants – During the pandemic, most DDS employees teleworked, so the DDSs needed to adjust to how they processed certain workloads. SSA provided the DDSs with basic cellular telephones to communicate with claimants, but claimants were wary of answering the calls as the telephones’ caller identification did not show the incoming call was from a state agency.
• Policies and Procedures – During the pandemic, SSA updated policies and procedures on how the DDS should operate. The updates included combined instructions with the field office, which confused some DDS employees about what pertained specifically to DDS processes.

Direct Express Problems

     The Office of Inspector General (OIG) has issued a report on the Direct Express Debit Card program. Claimants who don't have a financial account into which benefits can be deposited can receive their money through a Comerica Bank debit card. The Comerica deal, which is with the Department of the Treasury, not Social Security, has been criticized because of high fees to benefits recipients and because people complained that they were assigned a debit card without asking for one. The OIG report found that there were some Social recipients complaining about receiving a debit card without asking for one. The OIG report also found that there has been a fair amount of money returned to Social Security by Comerica because of unfinished enrollments and that Social Security has been slow in making sure the claimants involved received their money. OIG found 39 cases where a claimant had been owed over $100,000.

What's Going On At OIG?

     The leadership of Social Security's Office of Inspector General (OIG), primarily the Inspector General, Gail Ennis, has come under fire recently. 

    It's far from all that OIG does but they issue various reports, mostly about audits they have conducted. Here are the number of audits for recent years:

• 2020 -- 55
• 2021 -- 47
• 2022 -- 38
• 2023 (so far) -- 1
  

SSA Information Not So Secure?

     From a recent report by Social Security's Office of Inspector General (OIG):

Objective
To determine whether the Social Security Administration’s (SSA) overall information security program and practices were effective and consistent with the Federal Information Security Modernization Act of 2014 (FISMA) requirements, as defined in the Fiscal Year (FY) 2022 core Inspector General (IG) FISMA reporting metrics. ...

We engaged Grant Thornton LLP (Grant Thornton) to conduct this performance audit ...

Based on the FY 2022 core IG FISMA reporting metrics guidance, Grant Thornton concluded SSA’s overall security program was “Not Effective.” 

Although SSA had established an Agency-wide information security program and practices, Grant Thornton identified deficiencies that may limit the Agency’s ability to adequately protect its systems and information. While SSA continued executing its risk-based approach to strengthen controls over its information systems and address weaknesses, Grant Thornton’s audit continued to identify persistent deficiencies in both the design and operation of controls related to the FY 2022 core IG FISMA reporting metrics. ...