GAO

United States General Accounting Office

Report to the Chairman, Subcommittee

on Social Security, Committee on Ways

and Means, House of Representatives

September 2000 SOCIAL SECURITY

ADMINISTRATION

Longstanding

Problems in SSA’s

Letters to the Public

Need to Be Fixed

GAO/HEHS-00-179

Page 1 GAO/HEHS-00-179 SSA’s Letters to the Public

Contents

Letter 3

Appendixes Appendix I: Scope and Methodology 30

Appendix II: Comments From the Social Security Administration 33

Appendix III: GAO Contacts and Staff Acknowledgments 36

Tables Table 1: The Most Significant Problems in Four Categories of

SSA Letters and Their Estimated Frequency 9

Table 2: Comprehensive Improvements Needed for Selected

SSA Letters 23

Figures Figure 1: A Social Security Benefit Adjustment Letter in Which

SSA’s Decision Is Unclear 11

Figure 2: An SSI Award Letter in Which the Basis for SSA’s

Decision Is Unclear 14

Figure 3: A Social Security Benefit Adjustment Letter in Which

the Financial Effect of SSA’s Decision Is Unclear 16

Figure 4: An Unclear SSI Award Letter 19

Abbreviations

HHS Department of Health and Human Services

SSA Social Security Administration

SSI Supplemental Security Income
Page 2 GAO/HEHS-00-179 SSA’s Letters to the Public
Page 3 GAO/HEHS-00-179 SSA’s Letters to the Public

United States General Accounting Office

Washington, D.C. 20548

Health, Education, and

Human Services Division

B-284086 Letr

September 26, 2000

The Honorable E. Clay Shaw

Chairman, Subcommittee on Social Security

Committee on Ways and Means

House of Representatives

Dear Mr. Chairman:

The Old Age and Survivors Insurance and Disability Insurance programs,

commonly referred to as Social Security, and the Supplemental Security

Income (SSI) program provide monthly cash benefits to about 50 million

beneficiaries. The Social Security Administration (SSA), which administers

both programs, mails millions of letters each year to notify Social Security

and SSI applicants and recipients about its decisions regarding their

eligibility to receive benefits or changes in the amount of their benefits—

important issues that have a bearing on their everyday lives. Because these

letters serve as SSA’s official means of communicating this information to

the public, it is important that they be clearly written and easy to

understand. If they are not clear, the public may miss important

information about their eligibility, the continuation of their payments, or

the recourse available to them if they disagree with SSA’s decisions.

We have long been critical of SSA’s letters. For example, in 1994, we

reported that many SSA letters, particularly those dealing with Social

Security overpayments, were difficult to understand.1 Specifically, we

found that SSA’s letters excluded essential details needed to understand its

decisions, presented information in an illogical order, and required

complex analyses to reconstruct how SSA had made adjustments to benefit

payments. To help you assess SSA’s progress in improving its letters, you

asked us to provide updated information on their quality. This report

addresses (1) the problems that make SSA’s letters difficult to understand

and (2) the status of SSA’s actions to fix the problems.

To address these issues, we interviewed SSA officials responsible for

improving SSA’s letters and reviewed documents on past and current

1

Social Security Administration: Many Letters Difficult to Understand (GAO/T-HEHS-94-126,

Mar. 22, 1994).
B-284086

Page 4 GAO/HEHS-00-179 SSA’s Letters to the Public

evaluations of the agency’s letters and its initiatives to improve them. We

focused our review on four categories of automated letters—Social

Security award letters, SSI award letters, Social Security benefit

adjustment letters, and SSI benefit adjustment letters—because these

letters reach a large number of people and convey important information

on their eligibility for benefits or changes in their benefit amounts that can

significantly affect their lives.2 SSA mails about 14.2 million of these letters

each year. We used writing consultants to help us develop criteria to assess

whether the letters communicated clearly and to verify our assessment of

the types of problems that occur. To quantify the frequency of the problems

we found in Social Security and SSI benefit adjustment letters, we reviewed

a statistical sample of 1 day’s production of letters. For Social Security and

SSI award letters, we identified specific problems with the letters and

obtained information from SSA about the number or percentage of letters

that included problems we identified. We conducted our work between

June 1999 and July 2000 in accordance with generally accepted government

auditing standards. For more details about our scope and methodology, see

appendix I.

Results in Brief The majority of letters in each of the four categories we reviewed did not

clearly communicate at least one of the following key points: (1) SSA’s

decision (that is, the action SSA was taking on a claim that prompted the

agency to send the letter), (2) the basis for SSA’s decision, (3) the financial

effect of SSA’s decision on the person addressed in the letter, or (4) the

recourse the person could take in response to SSA’s decision. The lack of

clarity was caused by one or more problems, such as illogically sequenced

information, incomplete or missing explanations, contradictory

information, and confusing numerical information. An unclear explanation

of the basis for SSA’s decision was the most widespread problem among the

four categories of letters. For example, it was difficult to understand the

basis for SSA’s decision in SSI award letters because the letters did not

explain the relationship between program rules and the amount of the SSI

benefit. Finally, a subgroup of SSI award letters—those sent to about 13 to

2

SSA characterizes its letters as automated or manual. SSA considers a letter automated if

its personnel input transaction data, such as a death or earnings report, and SSA’s systems

generate the letter without any other human intervention. If SSA personnel were involved in

selecting paragraphs or providing individualized data, then SSA considers the letter to have

been manually prepared.
B-284086

Page 5 GAO/HEHS-00-179 SSA’s Letters to the Public

15 percent of SSI awardees who are eligible for previous but not a future

month’s benefits—were unclear in communicating all four key points.

SSA acknowledges that these letters contain the problems we identified;

however, for many of the problems, the agency has not taken any

corrective action. Many of the problems we identified are not amenable to

quick fixes but, rather, will require a comprehensive revision of the

language used in the letters and rewriting the agency’s software

applications that generate them. The agency has repeatedly rescheduled

plans to make comprehensive changes to its Social Security benefit

adjustment letters because of competing demands for computer systems

resources; the agency allocated resources to other priorities, such as

making computer system changes that resulted from legislation. Recently,

however, the agency announced plans to make significant changes to this

category of letter, but few details are yet available. Major improvements to

SSI letters were also delayed, but in this case SSA was waiting for

resolution of a nationwide court case involving these letters. In September

1999, a federal court ordered SSA to develop and implement a plan to

improve its SSI letters, prompting SSA to begin a major, multiyear initiative

to improve its SSI award and benefit adjustment letters. This initiative is

still in the early phase.

Overall, SSA has not placed a high priority on improving its letters to the

public, and it will be years before the improvements are completed to most

of these letters, even if there are no more delays and SSA adheres to its

current plans. Because of past delays to letter improvement initiatives, we

are recommending that SSA develop performance measures to monitor the

agency’s progress in making the necessary comprehensive improvements

to these letters.

Background The Social Security program and the SSI program provide monthly cash

benefits to persons who meet the programs’ eligibility requirements. In

fiscal year 1999, 38 million persons received a total of $332.4 billion in Old

Age and Survivors Insurance benefits, 6.5 million persons received $50.4

billion in Disability Insurance benefits, and 6.6 million persons received

$28.1 billion in SSI benefits. The rules affecting eligibility and benefit

amounts in these programs can be complex. Once individuals are

determined to be eligible for Social Security or SSI benefits, changes in

their circumstances, such as changes in the amount of their income,

disability, or marital status, can affect their continuing eligibility for
B-284086

Page 6 GAO/HEHS-00-179 SSA’s Letters to the Public

benefits or the amount of their benefits.3 When SSA learns of these

changes—either through its own review processes or from individuals

reporting changes in their circumstances to the agency—SSA adjusts

individuals’ eligibility status or benefit amounts accordingly.

The Social Security programs provide protection to insured workers and

their dependents against the loss of earnings because of workers’

retirement, disability, and death. The monthly cash benefits, which are

intended to replace a portion of lost earnings, are financed through payroll

taxes. The monthly benefit amount to which workers (and their

dependents) are entitled is based on workers’ lifetime earnings covered by

Social Security. Individuals can begin receiving partial retirement benefits

due them at age 62, or they can receive full benefits beginning at full

retirement age, which is currently age 65. In addition, some individuals

continue to work after they start receiving benefits. SSA continues to credit

these earnings to the individuals’ Social Security accounts, and their

monthly benefits may increase as a result. However, once individuals

receive retirement benefits, an earnings limit applies to persons who have

retired and are younger than full retirement age. If earnings exceed

established limits, SSA reduces the benefit amount. To determine whether

and by how much to reduce benefit amounts, SSA requests individuals to

provide estimates of their annual earnings. If their actual earnings are less

than they estimated, SSA will have underpaid them and will need to adjust

their payments. Monthly benefits paid to workers who retired before

reaching full retirement age and their dependents are reduced by $1 for

every $2 earned over the $10,080 annual limit for 2000.4 For individuals

receiving Social Security benefits based on disability, different rules govern

subsequent earnings. During a trial work period, no earnings limit applies

to disabled workers. But disabled workers who have completed the trial

work period generally stop receiving benefits if their monthly earnings

continue to exceed $700 as of 1999. For all these reasons, a person’s

earnings after he or she becomes disabled or retires before the full

retirement age can result in overpayments, underpayments, or both.

3

Our review did not include letters sent to persons whose benefits were terminated because

they had been determined to be no longer disabled.

4

In 1999, an earnings limit also applied to retired workers aged 65 to 69 and their

dependents. Benefits were reduced by $1 for every $3 over $15,500. On April 7, 2000, Public

Law 106-182, the Senior Citizens’ Freedom to Work Act of 2000, eliminated the earnings limit

for retired workers between full retirement age and age 70, effective January 1, 2000.
B-284086

Page 7 GAO/HEHS-00-179 SSA’s Letters to the Public

SSI, in contrast, is a means-tested program funded from general tax

revenues designed to provide a minimum level of income to individuals

with limited income and resources who are 65 or older or blind or disabled,

including children. To qualify for benefits, individuals must have income

and resources below the SSI program’s limits. Qualified recipients receive

monthly cash payments sufficient to raise their income to the level

guaranteed by the federal SSI program. The amount of the SSI benefit

varies according to income. Persons who have no income receive the

maximum federal SSI benefit—currently $512 per month for an individual

and $769 for a couple.5 SSI recipients with income, including those

receiving Social Security benefits, receive less.

Letters are one of SSA’s primary means of communicating with the public.

SSA estimates that each year it issues approximately 250 million letters and

forms to the public, including claimants, workers, employers, and

government agencies. These letters deal with a wide range of issues. SSA

sends letters to Social Security and SSI applicants and recipients notifying

them about their eligibility for benefits or changes in their eligibility or

benefit amounts. SSA sends annual statements to Social Security

beneficiaries documenting, for tax purposes, the amount of Social Security

benefits received; annual estimates to current workers of future Social

Security benefits; letters to employers about workers’ Social Security

numbers; letters to SSI recipients verifying, for other means-tested

programs, the amount of their SSI benefits; and many other types of

letters.6 SSA has pledged to the public that its letters will clearly explain the

agency’s decisions so that the public can understand how and why SSA

made them and what to do if it disagrees.

Responsibility for improving letters is shared among various SSA offices,

including the office responsible for customer service, which helps identify

problems, and the program offices, which are responsible for further

analyzing problems and drafting revised language. The Office of Systems,

5

States have the option of supplementing the federal SSI benefit with state payments. Fortyfour states provide such a supplement to at least some SSI recipients.

6

In 1996, we reviewed SSA’s statements estimating current workers’ future Social Security

benefits based on their earnings. We identified problems that made the statements difficult

to understand and recommended that SSA make several improvements to them. (See SSA

Benefit Statements: Well Received by the Public but Difficult to Comprehend (GAO/HEHS97-19, Dec. 5, 1996).) SSA subsequently revised the statements, consistent with our

recommendations. We found the revised statements to be much improved. (See Social

Security: Providing Useful Information to the Public (GAO/T-HEHS-00-01, Apr. 11, 2000).)
B-284086

Page 8 GAO/HEHS-00-179 SSA’s Letters to the Public

however, plays a key role because implementing changes often requires

systems programmers to rewrite one of the multiple software applications

that SSA uses to generate letters. SSA’s Social Security program is currently

supported by a new, redesigned system and about 25 separate systems

applications, each dedicated to processing a specific type of transaction.

SSA has one application that, among other transactions, processes claims

for benefits and generates automated eligibility award or denial letters;

another application processes transactions such as reports of work-related

earnings and generates automated benefit adjustment letters. For the SSI

program, the agency has one major system to process transactions for the

program and produce automated SSI letters. Each software application has

its own programmed logic to generate letters and its own language

database. Depending on the particulars of the transaction, each application

is programmed to select appropriate paragraphs from among the numerous

paragraphs in its language database, many of which were written to be

used in multiple situations. Once the paragraphs are selected, the software

is programmed to complete paragraphs by filling in case-specific

information from SSA’s master records and sequence paragraphs to

assemble letters. These master records contain account data for every

beneficiary.

Problems in SSA’s

Letters Limit Their

Understandability

Many of the letters in our review do not meet the agency’s own

communication standard or generally accepted principles of good

communication. Social Security award letters, Social Security benefit

adjustment letters, SSI award letters, and SSI benefit adjustment letters do

not clearly communicate one or more of the following key points: SSA’s

decision (that is, the action SSA is taking on a claim that necessitated the

letter), the basis for its decision (that is, the program rules and facts on

which SSA based its decision), the financial effect of its decision on

payments to the individual, and the recourse the individual has in response

to SSA’s decision. In addition, a subgroup of SSI award letters—those sent

to about 13 to 15 percent of awardees who were found eligible for benefits

for previous but not future months—were especially difficult to

understand. These letters had problems that made it difficult to understand

each of the four key points. The unclear communication in the four

categories of letters we reviewed was caused by many of the same

problems we identified in SSA’s letters in 1994, such as illogically

sequenced information, incomplete or missing explanations, contradictory

information, and confusing numerical information.
B-284086

Page 9 GAO/HEHS-00-179 SSA’s Letters to the Public

Table 1 presents what we consider to be the most significant problems

because of their frequency or their potential to adversely affect the

individuals receiving the letters.

Table 1: The Most Significant Problems in Four Categories of SSA Letters and Their Estimated Frequency

Note: The percentages for the Social Security and SSI award letters are based on information that

SSA provided to quantify the frequency of the problems we found with these letters. The percentages

for the Social Security and SSI benefit adjustment letters are based on the sample of letters we

reviewed.

Some SSA Decisions Can Be

Difficult to Understand

Because of Incomplete

Information

SSA’s decision to award benefits or to adjust the amount of individuals’

benefits was generally stated clearly in three of the four categories of

letters. However, letters sent to inform Social Security beneficiaries of

adjustments in their benefit amounts were not clear. In most of these

letters, information necessary to understand SSA’s decisions was buried in

the letters’ attachments or was not mentioned at all.

Most letters adjusting Social Security benefits consist of a cover sheet

acknowledging earnings that individuals recently reported to SSA and

sometimes a lengthy attachment. Information about possible changes in

payments are detailed in the attachment and in worksheets that are often a

part of the attachment. SSA’s decision was unclear in 80 percent of the

letters we sampled, most often because the cover sheets did not disclose all

decisions discussed in the attachments. In these situations, the attachment

may have also discussed other decisions SSA made about (1) amounts it

Key point Social Security letter SSI letter

Award Benefit adjustment Award Benefit adjustment

Decision 80% of cover sheets do not

include all decisions that affect

payments

Basis for decision 100% illogically sequence

explanations of SSA’s decisions

100% do not explain

relationship between

program rules and benefit

amounts

86% do not clearly explain

relationship between program

rules and changes in benefit

amounts

Financial effect 86% lack clear explanations of

adjustments

55% lack clear statement of

timing or amount of change in

benefits or other problems

Recourse 95% do not state

how to appeal

24% do not fully state options for

repaying overpayments or how

to appeal
B-284086

Page 10 GAO/HEHS-00-179 SSA’s Letters to the Public

had overpaid or underpaid individuals or (2) its plans to withhold payments

to recover amounts overpaid or both. For example, one cover sheet

informed a beneficiary that she had been overpaid $607 but requested that

she repay $2,213 (see fig. 1). This could confuse the reader until she read

the attachment, which explained SSA’s plans to also recover a prior

overpayment. The explanation of the difference between the $607

overpayment and the $2,213 to be repaid was not given until later in the

attachment.
B-284086

Page 11 GAO/HEHS-00-179 SSA’s Letters to the Public

Figure 1: A Social Security Benefit Adjustment Letter in Which SSA’s Decision Is Unclear
B-284086

Page 12 GAO/HEHS-00-179 SSA’s Letters to the Public

In some cases, however, the attachment did not explain the decision stated

in the cover letter. We found a case in which the cover sheet informed an

individual that (1) on the basis of his work report, SSA had determined that

he had been overpaid $2,083.00 but that (2) after all adjustments, he had

been overpaid $2,055.00, and (3) he should refund the $2,009.50

overpayment within 30 days. In this case, the attachment did not explain

these differences.

Our finding is similar to one included in a 1992 study done under contract

for SSA that cited cover sheets as not disclosing all essential actions

addressed in attachments.7 Such letters could conceivably cause the

persons receiving them to call or visit SSA offices for explanations. This

creates additional work for SSA employees that would not have been

necessary had the letters completely and clearly stated all decisions up

front.

The Basis for Most SSA

Decisions Is Difficult to

Understand Because of

Multiple Problems

The basis for SSA’s decisions—that is, the program rules and facts on which

SSA based its decisions—was usually clear in the Social Security award

letters but unclear in the three other categories of letters. In some cases,

the basis for SSA’s decisions was not clear because the rules were

explained in complex language that was difficult to follow, or the rules

were presented in an illogical order scattered throughout the letters. In

other cases, the program rules or facts on which the decisions were based

were not fully explained, and the relationship between an individual’s

income and adjustments to benefits could not be easily understood. SSA

officials acknowledged that the latter situation occurs in all SSI award

letters. In our review of SSI award letters, we found that these letters do

not clearly show how income affects the amount of the SSI benefit, and the

information provided on an individual’s benefit amount and income is not

organized in a way that enables the reader to easily understand the

connection between the two. Given this limitation, the basis for SSA’s

decisions can be difficult to understand, even in a relatively simple award

letter.

It is even more difficult to understand the basis for SSA’s decisions when an

individual is to be awarded several months’ past due benefits and the

benefit amount changes during the months covered by the award letter. An

7

QS & A Research & Strategy, Comprehension of Two Notices: Overpayment Notice and Due

Process Notice (Fairfax, Va.: Dec. 17, 1992).
B-284086

Page 13 GAO/HEHS-00-179 SSA’s Letters to the Public

award letter to a disabled individual illustrates this point. In October 1999,

SSA notified an SSI applicant that she had been eligible for monthly

benefits of $175.92 for July through September 1999 and $130.92 for

October and November 1999. This information was presented on the first

page of the letter. The facts on which SSA based the benefit amount—

including the amount of her income—are described separately on the

letter’s second page (see fig. 2). It was not clear from the facts as presented

on that page—which was the only explanation SSA gave for its decision in

this letter—why this individual’s benefits were reduced. No explanation

was given for the change in the benefit amount for October and November

1999.
B-284086

Page 14 GAO/HEHS-00-179 SSA’s Letters to the Public

Figure 2: An SSI Award Letter in Which the Basis for SSA’s Decision Is Unclear
B-284086

Page 15 GAO/HEHS-00-179 SSA’s Letters to the Public

SSA has long been aware that its SSI award letters do not clearly show the

relationship between program rules and the amount of an SSI benefit. For

example, an SSA document cites participants in a 1992 focus group as

criticizing SSI award notices for not clearly explaining how SSA calculates

benefit amounts and, in particular, for not explaining variations in the

amount of monthly benefits. Also in 1992, the Office of Inspector General in

the Department of Health and Human Services (HHS) recommended that

SSA revise its SSI award letters to include a worksheet to show how SSA

determined the benefit amount.8 More recently, in January 2000, the U.S.

District Court for the Eastern District of New York similarly instructed SSA

to revise its SSI award letters to provide information necessary to permit a

reasonable person to understand the basis for the agency’s action on a

number of subjects, including worksheets to show how benefits were

computed.9

The Financial Effect of

Many SSA Decisions Is

Difficult to Understand

Because of Confusing Time

Periods and Numerical

Information

The financial effect of SSA’s decision was generally clear in the letters

awarding Social Security and SSI benefits but not clear in letters adjusting

them. In some cases, the letters contained conflicting information about

when adjustments would occur and, additionally, in some cases it was not

clear whether benefits were increasing or decreasing. Letters also

contained confusing numerical information involving the computation of

payment adjustments. For example, the financial effect of SSA’s decision on

amounts payable to or owed by individuals was unclear in 86 percent of the

letters we sampled that involved adjustments of Social Security benefits.

We found that worksheets, which were intended to show how SSA

computed amounts overpaid or underpaid to individuals, used unexplained

amounts. As shown in figure 3, one worksheet showed SSA’s computations

to support the fact that the agency should have withheld $2,714 of an

individual’s benefits because his yearly earnings were $8,142 over the limit.

However, on the next line, the worksheet shows the amount that should

have been withheld as $1981.50—an amount that the attachment did not

explain. No explanation is given of the difference in the two amounts cited

as “should be withheld.”

8

HHS, Office of Inspector General, Examples of Revised Supplemental Security Income

Notices, OEI-07-9002461 (Sept. 1992).

9

Ford et al. v. Apfel, No. CV-94-2736 (E.D.N.Y., Jan. 13, 2000).
B-284086

Page 16 GAO/HEHS-00-179 SSA’s Letters to the Public

Figure 3: A Social Security Benefit Adjustment Letter in Which the Financial Effect of SSA’s Decision Is Unclear
B-284086

Page 17 GAO/HEHS-00-179 SSA’s Letters to the Public

In some cases, a worksheet adequately explained SSA’s computations for

amounts it underpaid individuals; however, the worksheet then listed an

adjustment to the underpayment by an amount that it did not explain. In

one particular example, a worksheet explained how SSA computed that it

had underpaid an individual $17 by stating that the individual had an

earnings limit of $17,000 for 2000. It then stated, “because of other

adjustments, you are due an additional $17.00.”

Claimant’s Recourse Is

Difficult to Understand

Because of Incomplete

Information

SSA’s explanations of the recourse available to individuals who disagree

with SSA’s decisions on their claims were generally clear in SSI award and

benefit adjustment letters but, to varying degrees, were unclear in the

Social Security award and benefit adjustment letters because of incomplete

information. Most Social Security award letters did not clearly explain how

to appeal SSA’s decisions, and almost a quarter of the letters adjusting

Social Security benefits did not fully inform individuals of all options for

repaying overpayments or how to appeal SSA’s decisions.

Data on the frequency of the use of certain paragraphs in Social Security

award letters showed that 95 percent of these letters sent during a recent 3-

month period did not inform individuals that if they chose to appeal SSA’s

decision, they had to do so in writing. SSA officials were unaware that

letters omitted this information and said that under the discussion of

appeal rights, letters should have instructed individuals to request a

specific form for making their appeals.

Twenty-four percent of the Social Security benefit adjustment letters in our

sample did not fully inform individuals at the beginning of the letter of the

recourse available to them. The cover sheet for some letters instructed

individuals to immediately repay the full overpayment amount without also

informing them of the other repayment options discussed in the

attachment. The attachment informs them that they can either have SSA

withhold benefits until the amount is fully repaid or, if they cannot afford

this, request SSA to withhold smaller amounts over a longer period of time.

Focus group participants in SSA’s 1992 study indicated a preference for

placing such information in the cover sheet. It was thought that when

people largely depend on Social Security payments, it would be helpful to

let them know immediately that they have other options for making

repayment. In other cases, the cover sheets referred individuals to the

attachment for an explanation of their appeal rights; however, no language

addressing appeal rights could be found in the attachment.
B-284086

Page 18 GAO/HEHS-00-179 SSA’s Letters to the Public

Some SSI Award Letters Are

Especially Difficult to

Understand

One particular group of SSI award letters—those sent to notify SSI

applicants that they have been awarded benefits for previous but not future

months—proved particularly confusing, because they contained numerous

contradictions, illogically sequenced explanations, and incorrect

statements.10 As a result, none of the four key points—SSA’s decision, the

basis for the decision, the financial effect on the individual, and the

recourse available to the claimant—are clear. Key excerpts from a typical

letter that awarded benefits only for previous months illustrate these

letters’ many problems, as seen in figure 4 (in which we have highlighted

passages with bold type). This letter was sent on October 13, 1999, to a

disabled adult. In 1998 and 1999, more than 100,000 individuals, or about 13

to 15 percent of all SSI awardees, received benefits only for previous

months and thus would have gotten a similar letter.

10This situation occurs when individuals’ cirsumstances change while they are waiting for

SSA’s eligibility decision on their application for benefits. Their change in circumstances

makes them eligible to receive benefits for one or more months after they applied for SSI

but ineligible for SSI benefits in the current month. A common scenario involves disabled

individuals who meet the SSI program’s income limit only until they receive Social Security

Disability Insurance benefits. Their SSI payments stop once their Social Security Disability

Insurance payments cause them to exceed the SSI program’s income limit.
B-284086

Page 19 GAO/HEHS-00-179 SSA’s Letters to the Public

Figure 4: An Unclear SSI Award Letter
B-284086

Page 20 GAO/HEHS-00-179 SSA’s Letters to the Public

SSA’s decision is unclear, because the letter shown in figure 4 goes back

and forth as to whether the applicant is eligible or ineligible for SSI. For

example, the first sentence in the letter (“A”) informs the applicant that she

is eligible for SSI benefits, as does the first sentence on the second page of

the letter (“E”). She is also told on a subsequent page that her benefits will

continue if she is still disabled in the future (“H”). But elsewhere in the

letter, she is told that she is not eligible for SSI (“F” and “G”) and that she

will not be receiving any more payments (“C,” “D,” and “E”).

The basis for SSA’s decision is unclear as well because the letter illogically

tells the applicant that she cannot receive any more payments because she

is disabled and living in Massachusetts (“E”). Also, this illogical reason for

nonpayment is listed before the actual reason for nonpayment—her

income (“F”).

The financial effect of SSA’s decision is unclear, because the letter makes

contradictory statements about the months for which benefits are payable.

First, the letter informs the reader that she will receive $3,367.36 in benefits

for March through October 1999 (“B” and “D”), but later it incorrectly states

that SSA can pay benefits for only 1 month—March 1999 (“E”).11

Finally, the recourse available to the claimant is unclear, because the letter

incorrectly informs her that she must file a new application before she can

receive any more benefits (“I”). The letter does not explain that under SSI

program rules, monthly benefits can resume without the need to file a new

application if the individual becomes eligible again within 12 months. The

letter is not clear about SSA’s decision, the basis for the decision, the

financial effect of the decision, or the applicant’s appeal rights.

Needed Improvements

Are Still Years Away

SSA has been aware for several years of the more serious problems we

found with three of the four categories of letters we reviewed—those

adjusting Social Security benefits, adjusting SSI benefits, and awarding SSI

benefits. The agency considers sending clear letters an important element

of customer service and specifically targeted these letters for

improvement, yet the actions it has taken to improve them have been

limited. Its efforts have primarily focused on the changes that are the

easiest to complete. The more serious problems we found require more

11This incorrect statement occurs in these letters only when individuals receive more than 1

month’s past due benefits—a common scenario, according to SSA.
B-284086

Page 21 GAO/HEHS-00-179 SSA’s Letters to the Public

comprehensive language revision and rewriting software applications, and

planned changes have been repeatedly rescheduled because SSA did not

have the computer systems resources available to implement them because

of other priorities. SSA has recently announced plans to make the needed

improvements to these three categories of letters. However, SSA has not

established meaningful performance measures to monitor its progress in

improving the letters.

SSA Has Made Little

Progress in Improving Three

Letter Categories

Since at least the early 1990s, SSA has known about problems with the

Social Security benefit adjustment letters, the SSI award letters, and the SSI

benefit adjustment letters, which we identified as being the most

problematic, and the agency agrees that they are among the least

understandable and most sensitive of the agency’s high-volume mailings.

Annually SSA sends out about 3.5 million Social Security benefit

adjustment letters, 0.6 million SSI award letters, and 3.3 million SSI benefit

adjustment letters.12 In various strategic and performance plans, SSA has

identified sending customers clear letters as an element of good service,

and beginning with its fiscal year 2000 performance plan, SSA specifically

targets improving these three letters as a strategy that would increase

customers’ overall satisfaction with the agency. Improving its letters is

listed as one of the agency’s key initiatives.

Despite acknowledging numerous problems with the three categories of

letters, SSA has completed only one minor improvement to one letter—the

Social Security benefit adjustment letter. In July 1999, SSA added a

worksheet to this letter to show how the agency computed amounts it

underpaid or overpaid individuals on the basis of their earnings. However,

SSA officials view the worksheet as an interim improvement because SSA

did not rewrite the master record to expand its capacity to hold additional

data so that it could provide the appropriate information to support the

worksheet. We drew our sample of Social Security benefit adjustment

letters after SSA began including worksheets with these letters. We found

the worksheets helpful to some extent in explaining how individuals’

earnings contributed to SSA’s decision that it had underpaid or overpaid

them. However, as previously discussed, the worksheets sometimes did not

12Because of recently enacted legislation, Public Law 106-182, that eliminated earningsrelated reductions in benefits for beneficiaries who have reached full retirement age, the

volume of Social Security benefit adjustment letters will decrease in the future, but SSA has

not determined by exactly how much.
B-284086

Page 22 GAO/HEHS-00-179 SSA’s Letters to the Public

adequately explain some of the adjustments SSA made when computing

underpayments or overpayments, in part because doing so would require

rewriting the master records.

In addition to the completed change described above, SSA recently began

to address two of the problems we identified during the course of our

present work. First, the agency has taken steps to respond to the lack of

language in Social Security award letters to inform individuals of the form

to use to appeal the agency’s decisions. After we brought this problem to

SSA’s attention, SSA officials told us the responsible program office has

developed revised language and has requested the Office of Systems to

implement the language change as soon as reasonably possible. In

commenting on a draft of this report, SSA informed us that it plans to

implement the change in November 2000. SSA has also initiated action to

correct the error in SSI award letters sent to individuals eligible for benefits

in previous months but not current benefits that states that they need to

make a new application. SSA officials told us that when the agency releases

its next set of SSI systems changes in October 2000, they plan to add

language to the letters to correct this problem.

Systems officials told us that from a systems standpoint, these types of

problems are the easiest to correct because they involve a straight

substitution of language—one paragraph replaces another paragraph that

had been used for the same situation. This type of revision is relatively

straightforward because the software logic for selecting the paragraph for

insertion into a letter does not have to be revised. Therefore, SSA could act

relatively quickly to address these two problems.

It Will Take SSA Years to

Make Comprehensive

Improvements to Letters

SSA has made less progress in correcting some of the problems that are

more difficult to fix. As shown in table 2, the other problems we found

would require significant work to revise the language used in the letters

and rewrite the master records and software applications.
B-284086

Page 23 GAO/HEHS-00-179 SSA’s Letters to the Public

Table 2: Comprehensive Improvements Needed for Selected SSA Letters

Systems officials told us that the actions the agency would need to take to

make the comprehensive changes the three letters need are the most

complicated from a systems perspective because they involve extensive

revision or development of new paragraph language; rewriting the software

application, including the selection and sequencing criteria for using the

language; and rewriting the programs’ master records to hold additional

data that may be necessary to support proposed language changes.

SSA’s ability to make these comprehensive improvements to the three

letters depends on the agency’s allocating significant systems resources.

When allocating systems resources, SSA appropriately gives highest

priority to projects that help the agency maintain operations essential to its

mission or that it needs to undertake in order to implement legislative

changes to the Social Security and SSI programs. Resources not committed

to these efforts are available for SSA to use for discretionary projects, such

as key initiatives that support one of its strategic goals. Improving letters is

a key initiative. SSA senior officials collectively determine which

discretionary projects the agency’s systems staff will work on, based on

each project’s ranking and expected contribution to SSA’s strategic

objectives. However, the relative priority SSA gives projects can change.

For example, SSA may decide to shift priorities and discontinue, delay, or

deemphasize a specific project to undertake others in cases in which SSA

does not have systems staff available.

Social Security Benefit

Adjustment Letters

SSA has long had plans to make comprehensive improvements to one of

the categories of letters—the Social Security benefit adjustment letter.

According to SSA documents, by 1996, SSA had developed and tested in

Letter Needed improvement

Social Security

benefit adjustment

Revise language, rewrite program’s master record, and rewrite software application so that

• ⋅Cover sheet discloses all decisions discussed in attachment

• ⋅Work-related earnings rules are co-located and logically sequenced

• ⋅Letter clearly explains decision’s effect on payment to individual, and

• ⋅Letter completely explains available recourse

SSI award Revise language, rewrite program’s master record, and rewrite software application so that

• ⋅Letter adequately explains the basis for the decision and

• ⋅Letter explains the relationship between program rules and benefit amount

SSI benefit adjustment Revise language, rewrite program’s master record, and rewrite software application so that

• ⋅Letter adequately explains a decision’s effect on payment, particularly how and when adjustments will

be made for overpayments or underpayments in the past months
B-284086

Page 24 GAO/HEHS-00-179 SSA’s Letters to the Public

focus groups comprehensive language changes for this letter. However,

SSA’s documents showed that since developing the language, the agency

has repeatedly rescheduled the systems work required to implement the

new language. SSA systems officials told us that their computer systems

staff did not work on projects at the scheduled times because the agency

had to divert computer programmers to other, more pressing projects, such

as those required to implement significant program changes resulting from

legislation and to ensure that SSA’s computer systems were year 2000

compliant.13 They told us that the agency, with the emergence of workloads

arising from legislative changes, had to shift priorities away from working

on improvements to letters.

Until recently, SSA’s progress in changing the Social Security benefit

adjustment letter was further limited by the agency’s decision to make

comprehensive changes to these letters a part of a broader multiyear

initiative to redesign its current systems for processing transactions for

Social Security programs. Under this redesign effort, SSA plans to develop

a single system that will use common code to process virtually all

transactions for the Social Security programs. SSA is taking a building

block approach to this significant change and is starting with the easier

applications in order to gain experience before merging other more

complex applications—such as the one that generates Social Security

benefit adjustment letters. SSA’s plans for having a single computer system

will allow the agency to rewrite the software more quickly and efficiently

and at less cost. Systems officials told us that the agency had planned that

as existing software applications were brought into the new redesigned

system, it would make language improvements as needed, retire the

respective language databases, and move the revised language into a

central language database.

In July 2000, SSA program and systems officials told us that the agency had

recently decided to move forward on making comprehensive

improvements to the Social Security benefit adjustment letters without

waiting to merge the respective software application under the new

redesigned system. An SSA official told us that the office that drafted the

proposed language changes had recently requested SSA senior officials to

13For example, the Personal Responsibility and Work Opportunity Reconciliation Act of 1996

(Public Law No. 104-193) made major changes to the SSI program. Among other things, it

revised the criteria under which children and noncitizens are eligible for benefits and added

restrictions governing the payment and use of certain large retroactive benefit amounts.
B-284086

Page 25 GAO/HEHS-00-179 SSA’s Letters to the Public

designate the project to improve Social Security benefit adjustment letters

as Customer Targeted Work. This is a relatively new category for the use of

discretionary resources that gives the project a higher priority than it has

been given before.14 Although SSA is in the early planning stage of this

effort, the Office of Systems has established a plan for completing the more

comprehensive improvements by July 2002. However, because SSA’s

decision is recent, we did not evaluate the approach.

SSI Letters SSA has not made comprehensive improvements to either type of SSI letter

and has only recently begun developing action plans for improving them.

SSA officials told us they postponed plans to improve SSI award and

benefit adjustment letters, pending the outcome of the recently decided

court case, a class action law suit that an SSI recipient initiated. In that

case, the court upheld the plaintiffs’ claim that SSA’s letters denied

recipients due process because the letters did not adequately explain the

basis for SSA’s decisions. The court ordered SSA to revise its automated SSI

financial eligibility letters—including its SSI award and benefit adjustment

letters—to more clearly communicate essential information to their

readers.15 SSA established a workgroup to review its SSI letters and

determine what changes were needed to improve them. In December 1999,

the SSA Commissioner signed a decision paper in which he approved the

workgroup’s recommendations to make comprehensive changes to SSI

letters.

Improving SSI letters will take time. The workgroup recommended that

SSA implement the recommendations in phases, concentrating first on

better explaining how benefit amounts are determined. SSA has begun

work on some of these changes. In February 2000, SSA drafted and tested

with some SSI recipients a prototype worksheet to be added to SSI award

and benefit adjustment letters showing how SSI benefits are computed.

The worksheet is intended to show how SSI benefits are computed in the

least complex cases—that is, the 90 percent of cases in which SSI

recipients have no income or only unearned income, such as Social

Security benefits. SSA plans to add the worksheet to the SSI letters by July

2002. By September 2004, SSA also plans to develop additional worksheets

14Key initiatives requiring systems work and Customer Targeted Work must provide a

significant return on investment or help meet agency strategic goals. However, to be given

the higher priority of Customer Targeted Work, a sponsoring component is required to

substantiate the need for extra attention and prioritization.

15Ford et al. v. Apfel, No. CV-94-2736 (E.D.N.Y., Jan. 13, 2000).
B-284086

Page 26 GAO/HEHS-00-179 SSA’s Letters to the Public

covering more complex situations, such as when persons have a

combination of earned and unearned income or when children receive

benefits based on parents’ income. The workgroup also recommended

other improvements such as revising letters so that the information in them

is logically ordered and adequately explains the factors that affect

eligibility and benefit amounts. SSA officials estimated that it could take 10

years to implement the full range of planned improvements.

SSA Does Not Have a Means

to Measure Progress in

Improving Letters

Despite acknowledging problems with its letters, SSA currently has no

performance measures for monitoring its progress toward improving them.

In the past, SSA surveyed customers about their overall satisfaction with

the agency’s letters and monitored the percentage of customers rating the

clarity of SSA’s notices as excellent, very good, or good. SSA found that the

information it collected, which was a measure of general satisfaction with

the letters, was not useful in identifying ways to improve letters, so it

discontinued these surveys. Instead, the agency now relies on a relatively

new Market Measurement Program to help it target a few specific types of

letters each year and develop action plans for improving them. This

program uses a variety of initiatives, such as special studies and focus

groups, to systematically gather information on the full range of services

SSA provides to help the agency improve customer service overall.

According to its fiscal year 2001 performance plan, the agency plans to

establish a new indicator to monitor improvements to its letters at a later

point.

Conclusion Although SSA has been aware for many years of some of the more serious

problems with its letters, it has not corrected them. The agency’s recently

announced plans to improve the Social Security benefit adjustment letter

and its SSI award and benefit adjustment letters will take years to complete

and will require significant computer systems resources. In view of the

agency’s past decisions to delay some planned changes to the letters

because of competing demands for its computer systems resources, we

believe that SSA needs to allocate the necessary systems resources for

these improvements. To do this, the agency will need to better anticipate

and plan for the varied demands on its computer systems’ resources and

place a higher priority on improving its letters. The agency will also need to

develop appropriate performance measures with which to hold itself

accountable to the public for achieving these improvements. These

measures should help SSA monitor its progress in adhering to the proposed

timetables to help the agency stay on track. In addition, because past
B-284086

Page 27 GAO/HEHS-00-179 SSA’s Letters to the Public

changes to letters have not always significantly improved clarity, SSA

should develop other measures to assess whether changes to the letters

have achieved the intended results. Failure to implement the needed

improvements will mean continued poor service to the public in this area.

Recommendation We recommend that the Commissioner of Social Security direct SSA

officials to develop performance measures to hold the agency accountable

for making the needed comprehensive changes to its Social Security

benefit adjustment letters and SSI award and benefit adjustment letters.

These measures should include indicators that clearly articulate the

timetables and basis against which progress to complete improvements can

be tracked and, as further progress is made, the effectiveness of the

improvements.

Agency Comments In commenting on a draft of this report, SSA generally agreed with our

findings, conclusions, and recommendation (see app. II). SSA expressed its

commitment to making the needed improvements to the letters addressed

by our report as quickly as possible and outlined its plan for developing

performance measures for beneficiary understanding of the problematic

letters. In addition, SSA mentioned other initiatives to improve this aspect

of its service. The agency stated that its efforts to improve letters have been

focused on changes that could be made quickly and have resulted in the

agency’s improving most of the other types of letters it sends to the public.

Indeed, as we mentioned previously, SSA improved the Social Security

Statement, which provides estimates of future Social Security benefits,

after we reported problems with it.16 However, we have not formally

evaluated the effectiveness of the other initiatives. Finally, SSA also made

several technical comments, which we incorporated in the report where

appropriate.

We are sending copies of this report to the Honorable Kenneth S. Apfel,

Commissioner of SSA, and others who are interested. Copies will also be

made available to others on request.

16GAO/T-HEHS-00-01, Apr. 11, 2000.
B-284086

Page 28 GAO/HEHS-00-179 SSA’s Letters to the Public

If you or your staff have any questions concerning this report, please call

me on (202) 512-7215. The major contributors to this report are listed in

appendix III.

Sincerely yours,

Barbara D. Bovbjerg

Associate Director, Education,

Workforce, and Income Security Issues
Page 29 GAO/HEHS-00-179 SSA’s Letters to the Public
Page 30 GAO/HEHS-00-179 SSA’s Letters to the Public

Appendix I

Scope and Methodology ApApenednxidexiIs

We identified problems with letters for the Old Age and Survivor Insurance

and Disability Insurance programs, commonly known as Social Security,

and the Supplemental Security Income (SSI) program from our earlier

work, by interviewing Social Security Administration (SSA) headquarters

and field office officials and by reviewing other related studies. We also

interviewed and obtained guidance documents from National Partnership

for Reinventing Government officials responsible for the governmentwide

initiative to have federal agencies improve their written communications to

the public. Before deciding the categories of letters we would select for a

detailed review, we performed a cursory review of several thousand that

had been generated by more than 17 different automated programs. We

also reviewed several types of letters prepared manually by the SSA offices

where we conducted our fieldwork. The automated letters we reviewed

represented the types of letters that are produced across SSA. We decided

to limit the focus of our work to letters produced by automated means and

exclude manually prepared letters because SSA lacked management

information that would allow us to identify and quantify them for sampling.

Given the range of issues that SSA’s letters address, we screened first for

letters that conveyed information on issues that in our view would more

likely affect recipients adversely if the letters were not understandable.

From among this group of letters, we selected categories that we believed

had the most serious problems. We chose four types of letters—an award

letter and a benefit adjustment letter for each of the two programs, Social

Security and SSI. On the basis of our preliminary screening, we judged

these letters to contain the most serious problems among all categories of

letters that convey SSA’s decision on individuals’ eligibility for benefits or

adjustments to their benefits.1

We used SSA’s customer service pledge, which promises that letters the

agency sends customers will meet certain standards, and our professional

judgment as the basis for deciding the issues that letters need to clearly

convey to individuals.2 We based our detailed assessment of the letters on

our premise that letters should

1

We excluded from detailed analysis (1) letters that SSA sent to government agencies or

businesses and (2) other types of letters that conveyed eligibility and benefit adjustment

decisions but appeared to have less serious problems with clarity.

2

SSA pledges to customers that “We will clearly explain our decisions so you can understand

why and how we made them and what to do if you disagree.”
Appendix I

Scope and Methodology

Page 31 GAO/HEHS-00-179 SSA’s Letters to the Public

1. Clearly state SSA’s decision (that is, they should clearly communicate

the decision SSA made to award, deny, or adjust benefits or that it had

overpaid or underpaid individuals).

2. Sufficiently and clearly explain the basis for SSA’s decision.

3. Clearly explain the financial effect SSA’s decision will have on

payments to the individual and, if applicable, how SSA computed

payments or change in payments.

4. Clearly explain the actions the individual can take if he or she disagrees

with SSA’s decision.

We used the assistance of two writing consultants to identify writing

deficiencies in cases in which letters were unclear in any of the four areas.

We tested our methodology for assessing letters by applying it to a small

number of letters that contained a range of problems, and we had the

consultants also apply it to the same letters. We resolved differences in the

way the consultants and we assessed the letters. We used the agreed-upon

methodology to identify problems in the statistical sample of benefit

adjustment letters discussed below.

Because SSA’s electronic files for 1 day’s production of automated letters

are multiple and voluminous, and because SSA did not have resources

readily available to provide us with a computer-generated sample, we

consulted with SSA officials to determine the best sampling method. We

randomly sampled 1 day’s production of Social Security benefit adjustment

letters and 1 day’s production of similar SSI letters. Our sample of Social

Security letters consisted of 104 letters selected from among the first 933

(of a total of 3,910) that SSA produced on February 14, 2000. Our SSI

sample included all 64 letters that SSA produced on March 2, 2000 (of a

total of 9,448) for which the beneficiaries’ Social Security numbers ended

in a predetermined two-digit number. Our estimates of the frequency of

problems we found with the benefit adjustment letters in both samples can

be generalized to the universe of such letters that SSA produced on the

days the samples were drawn. On the basis of statements of SSA officials,

we believe that our sampling methodology produced a representative

selection of the sampled days’ workloads that were typical of workloads

throughout the year.

Because the estimates we report are based on a sample, a margin of error

or imprecision surrounds them. This imprecision is usually expressed as a
Appendix I

Scope and Methodology

Page 32 GAO/HEHS-00-179 SSA’s Letters to the Public

sampling error at a given confidence level. We calculated sampling errors

for our estimates of how frequently letters were unclear at the 95 percent

confidence level. The sampling error for percentage estimates we cite in

this report is plus or minus 12.1 percentage points at the 95 percent

confidence level.

We did not use random samples for our work on Social Security and SSI

award letters. After we reviewed a variety of these award letters and

identified specific problems with them, we were able to obtain information

from SSA officials to quantify the frequency of the problems without

sampling. SSA officials provided us information on how many of the Social

Security award letters were generated during a recent 3-month period—

December 1999 through February 2000—and how many of these letters

contained certain appeals language that we identified as problematic. We

discussed with SSA officials the problems we identified in the SSI award

letters, and they confirmed that these problems exist in all SSI award

letters because of shortcomings in their computer systems.

To determine SSA’s actions and plans to correct problems with the

categories of letters that were the subject of our work, we reviewed SSA’s 5-

year plan and annual plans to identify the agency’s objectives and goals. We

also interviewed SSA officials and reviewed the agency’s documents

relating to its initiatives to improve letters to determine what actions SSA

has proposed to address problems and its plans for implementing them. We

interviewed SSA officials to gain an understanding of the actions required

to correct the problems we identified and the SSA offices responsible for

initiating the actions, and we reviewed SSA’s process for implementing

actions that would improve letters.

We performed our work at SSA headquarters in Baltimore, Maryland, and

SSA field locations in Chicago, Illinois; Reisterstown, Maryland; and

Richmond, Virginia. We conducted our work between June 1999 and July

2000 in accordance with generally accepted government auditing

standards.
Page 33 GAO/HEHS-00-179 SSA’s Letters to the Public

Appendix II

Comments From the Social Security

Administration ApendxiI
Appendix II

Comments From the Social Security

Administration

Page 34 GAO/HEHS-00-179 SSA’s Letters to the Public
Appendix II

Comments From the Social Security

Administration

Page 35 GAO/HEHS-00-179 SSA’s Letters to the Public
Page 36 GAO/HEHS-00-179 SSA’s Letters to the Public

Appendix III

GAO Contacts and Staff Acknowledgments ApendxiI

GAO Contacts Barbara Bovbjerg, Associate Director, (202) 512-7215

Kay Brown, Assistant Director, (202) 512-3674

Staff

Acknowledgments

In addition to the persons named above, others made important

contributions to this report: Jacquelyn Stewart, Evaluator-in-Charge; Ellen

Habenicht, Senior Evaluator; Valerie Melvin and James Wright, Assistant

Directors; Michael Alexander, Senior Information Systems Analyst; Patrick

di Battista, Communications Analyst; Jay Smale, Social Science Analyst;

and Ann McDermott, Visual Communications Analyst.

(207069) Letr
Ordering Information The first copy of each GAO report is free. Additional copies of

reports are $2 each. A check or money order should be made out to

the Superintendent of Documents. VISA and MasterCard credit

cards are accepted, also.

Orders for 100 or more copies to be mailed to a single address are

discounted 25 percent.

Orders by mail:

U.S. General Accounting Office

P.O. Box 37050

Washington, DC 20013

Orders by visiting:

Room 1100

700 4th St. NW (corner of 4th and G Sts. NW)

U.S. General Accounting Office

Washington, DC

Orders by phone:

(202) 512-6000

fax: (202) 512-6061

TDD (202) 512-2537

Each day, GAO issues a list of newly available reports and

testimony. To receive facsimile copies of the daily list or any list

from the past 30 days, please call (202) 512-6000 using a touchtone

phone. A recorded menu will provide information on how to obtain

these lists.

Orders by Internet:

For information on how to access GAO reports on the Internet,

send an e-mail message with “info” in the body to:

info@www.gao.gov

or visit GAO’s World Wide Web home page at:

http://www.gao.gov

To Report Fraud,

Waste, or Abuse in

Federal Programs

Contact one:

• Web site: http://www.gao.gov/fraudnet/fraudnet.htm

• e-mail: fraudnet@gao.gov

• 1-800-424-5454 (automated answering system)


United States

General Accounting Office

Washington, D.C. 20548-0001

Official Business

Penalty for Private Use $300

Address Correction Requested

Bulk Rate

Postage & Fees Paid

GAO

Permit No. GI00