GAO

September 2004 DISABILITY 

INSURANCE 

SSA Should 

Strengthen Its Efforts 

to Detect and Prevent 

Overpayments 

GAO-04-929 

United States Government Accountability Office

Report to the Chairman, Committee on 

Finance, U.S. Senate 
www.gao.gov/cgi-bin/getrpt?GAO-04-929.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Robert E. 

Robertson at (202) 512-7215 or 

robertsonr@gao.gov. 

Highlights of GAO-04-929, a report to the 

Chairman, Committee on Finance, U.S. 

Senate 

September 2004

DISABILITY INSURANCE 

SSA Should Strengthen Its Efforts to 

Detect and Prevent Overpayments 

Overpayment detections in the DI program increased from $772 million in 

fiscal year 1999 to about $990 million in 2003. The true extent of 

overpayments resulting from earnings that exceed agency guidelines is 

currently unknown. Based on available data from SSA, GAO found that 

about 31 percent of all DI overpayments are attributable to DI beneficiaries 

who worked and earned more than allowed. Moreover, GAO found that 

these overpayments contributed to mounting financial losses in the program. 

From 1999 to 2003, total overpayment debt increased from about $1.9 billion 

to nearly $3 billion. 

Three basic weaknesses impede SSA’s ability to prevent and detect earningsrelated overpayments. First, the agency lacks timely data on beneficiaries’ 

earnings and work activity. Second, SSA uses inefficient processes to 

perform work continuing disability reviews (work CDRs). Third, the agency 

relies on potentially inaccurate management information to effectively 

monitor and oversee some parts of this workload. These weaknesses 

contributed to some work CDR cases GAO identified that were as much as 

7 years old, resulting in potential and established overpayments as large as 

$105,000 per beneficiary. In addition, GAO found that SSA relies on 

potentially inaccurate management information to administer its work CDR 

workload. SSA is developing new automated systems that may potentially 

address some of these problems and could help the agency balance the 

important goals of encouraging individuals with disabilities return to work, 

while also ensuring program integrity. However, it is too early to determine 

how effective such systems will be. 

Total Overpayment Debt Is Increasing (1999–2003) 

Source: Falls in this space.

Dollars in millions

 0

 500

1,000

1,500

2,000

2,500

3,000

1999 2000 2001 2002 2003

Year

Source: GAO analysis based on SSA data.

The Social Security 

Administration’s (SSA) Disability 

Insurance (DI) program is one of 

the nation’s largest cash assistance 

programs for disabled workers. In 

fiscal year 2003, the DI program 

provided about $70 billion in 

financial assistance to 

approximately 7.5 million disabled 

workers, their spouses, and 

dependent children. This program 

has grown in recent years and is 

poised to grow further as the baby 

boom generation ages. The Senate 

Committee on Finance asked GAO 

to (1) determine the amount of 

overpayments in the DI program, 

particularly those attributable to 

earnings or work activity, and (2) 

identify any vulnerabilities in SSA’s 

processes and policies for verifying 

earnings that may contribute to 

work-related overpayments. 

GAO is making recommendations 

to the Commissioner of Social 

Security directing the agency to 

explore new tools and data sources 

that can be used to more effectively

detect and prevent earnings-related 

overpayments. SSA agreed with 

GAO’s recommendations and 

provided information on several 

initiatives that are planned or 

underway to address them, such as 

a new computer match using 

information from the Office of 

Child Support Enforcement’s 

National Directory of New Hires to 

verify beneficiaries’ earnings in a 

more timely manner. 
Page i GAO-04-929 SSA Should Strengthen Its Efforts 

Letter 1

Results in Brief 3 

Background 4 

Overpayments in the DI Program Are Substantial and Have 

Increased in Recent Years 7 

Lack of Timely Data on Beneficiary Earnings and Other 

Vulnerabilities Impede SSA’s Ability to Detect and Prevent DI 

Overpayments 10 

Conclusions 17 

Recommendations 18 

Agency Comments and Our Evaluation 19 

Appendix I Scope and Methodology 22 

Appendix II Comments from the Social Security Administration 25 

Appendix III GAO Contacts and Staff Acknowledgment 31 

GAO Contacts 31 

Staff Acknowledgments 31 

Related GAO Products 32 

Figures 

Figure 1: Total DI Overpayment Detections Have Increased (1999–

2003) 8 

Figure 2: Total Overpayment Debt Is Increasing (1999–2003) 9 

Contents 
Page ii GAO-04-929 SSA Should Strengthen Its Efforts 

Abbreviations 

CDR continuing disability review 

DDS Disability Determination Service 

DI Disability Insurance 

IRS Internal Revenue Service 

NDNH National Directory of New Hires 

OCO Office of Central Operations 

OCSE Office of Child Support Enforcement 

OIG Office of Inspector General 

PSC Program Service Center 

SSA Social Security Administration 

SGA substantial gainful activity 

SSI Supplemental Security Income 

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Page 1 GAO-04-929 SSA Should Strengthen Its Efforts 

September 10, 2004 

The Honorable Charles E. Grassley 

Chairman, Committee on Finance 

United States Senate 

Dear Mr. Chairman: 

The Social Security Administration’s (SSA) Disability Insurance (DI) 

program is one of the nation’s largest cash assistance programs for 

disabled workers. In fiscal year 2003, the DI program provided about $70 

billion in financial assistance to approximately 7.5 million disabled 

workers, their spouses, and dependent children. This program has grown 

in recent years and is poised to grow further as the baby boom generation 

ages. Given the concerns about the long-term solvency of the DI trust fund, 

it is important for SSA to ensure that only truly eligible individuals receive 

benefits. 

SSA guidelines state that DI beneficiaries are permitted to earn up to $810 

per month in calendar year 2004—a level of earnings referred to as 

substantial gainful activity (SGA)1

—for a limited period of time without 

losing eligibility for benefits. After completing a 9-month “trial work 

period,” beneficiaries who earn more than SGA are generally ineligible for 

future DI payments, and may be overpaid if SSA does not stop their 

benefits in a timely manner. The potential of having to repay a large 

overpayment may discourage some beneficiaries from continuing to work, 

thus running contrary to SSA’s goal of helping such individuals become 

self-sufficient. SSA conducts continuing disability reviews (CDR) of 

beneficiaries’ earnings and work activity to determine whether a claimant 

remains financially eligible for DI benefits.2

 The agency refers to these 

reviews as “work CDRs.” These reviews generally require SSA staff to 

perform several steps to assess beneficiaries’ continuing eligibility for 

benefits, including mailing notices to beneficiaries requesting information 

about their work activity, contacting the beneficiaries’ employer(s) to 

 1

The SGA level changes annually. For example, SGA in calendar year 2003 was $800 per 

month. 

2

SSA also conducts “medical” CDRs to evaluate whether a beneficiary has medically 

improved to the point where they are able to work. 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-04-929 SSA Should Strengthen Its Efforts 

verify their monthly earnings, and assessing several variables that can 

affect eligibility, including employer subsidies and work-related expenses. 

Given the importance of verifying DI beneficiaries’ earnings to ensure they 

receive the correct amount of benefits, the Senate Committee on Finance 

asked us to (1) determine the amount of overpayments in the DI program, 

particularly those attributable to earnings or work activity, and (2) identify 

any vulnerabilities in SSA’s processes and policies for verifying earnings 

that may contribute to work-related overpayments. To answer these 

questions, we used an approach similar to the methodology in our prior 

reviews of SSA’s Supplemental Security Income (SSI) program.3

 In 

particular, we reviewed DI performance data, prior reports by SSA and its 

Office of Inspector General (OIG), external research studies, and our prior 

reviews on the program. We analyzed DI payment data over a 5-year 

period from 1999 to 2003 and examined between 5 and 7 work CDR cases 

from each of the SSA field offices and program service centers we visited. 

In addition, we randomly selected and reviewed 71 work CDR cases from 

one of SSA’s program service centers to determine if they were processed 

in accordance with program guidelines. Finally, we conducted in-depth 

interviews with 230 management and line staff from SSA’s headquarters; 

its regional offices in New York and San Francisco; 18 field offices in 6 

states—California, Florida, Maryland, Massachusetts, New York, and 

Virginia; and 3 out of 8 regional program service centers.4

 During our 

meetings, we (1) examined existing work CDR procedures; (2) 

documented management and staff views on the effectiveness of SSA’s 

work CDR processes for detecting and preventing earnings-related 

overpayments; and (3) discussed potential improvements to existing 

program processes, systems, and policies. We assessed the reliability of all 

databases used in our review, and found them to be sufficiently reliable for 

the purposes of this report. See appendix I for details on the scope and 

methodology of our review. We performed our work from September 2003 

through June 2004 in accordance with generally accepted government 

auditing standards. 

 3

We designated SSI a high-risk program in 1997 after several years of reporting on specific 

instances of abuse and mismanagement, increasing overpayments, and poor recovery of 

outstanding debt. SSA subsequently made several changes to improve SSI program 

integrity. We removed SSI from our high–risk list in 2003. 

4

The program service centers (PSC) are responsible for a variety of activities, including 

work CDRs. 
Page 3 GAO-04-929 SSA Should Strengthen Its Efforts 

Overpayment detections in the DI program increased from about 

$772 million in fiscal year 1999 to about $990 million in 2003. The true 

extent of overpayments resulting from earnings that exceed agency 

guidelines is currently unknown, but could be higher than available data 

indicate. On the basis of data from a recent SSA study, we estimate that 

about 31 percent of all DI overpayments are attributable to DI 

beneficiaries who worked and earned more than SGA. Moreover, we found 

that these overpayments contributed to mounting overpayment debt, 

which increased from about $1.9 billion to nearly $3 billion during the 

same period. Although SSA increased overpayment collections during this 

time, our analysis shows that overpayment waivers (overpayments that 

SSA decides not to collect) and write-offs (overpayments that SSA 

determines cannot be collected) also increased. Thus, financial losses are 

mounting, contributing to a widening gap between total overpayment debt 

and annual overpayment collections. 

Three basic weaknesses impede SSA’s ability to prevent and detect 

earnings-related overpayments: The agency (1) lacks timely data on 

beneficiaries’ earnings and work activity, (2) uses inefficient processes to 

perform work CDRs, and (3) relies on potentially inaccurate management 

information to manage a portion of its work CDR workload. First, SSA’s 

main source of earnings verification for the DI program is derived from 

matching its own earnings database with Internal Revenue Service (IRS) 

wage data, which is typically 12-18 months old when it is first available to 

SSA. The agency does not currently have the authority to conduct 

computer matches with the Office of Child Support Enforcement’s 

National Directory of New Hires—a database with more timely wage 

information. Second, SSA uses inefficient processes to perform work 

CDRs. In particular, the agency lacks an effective screen to help identify 

cases most likely to result in large overpayments. Nor does the agency 

have an automated alert system that could notify field offices and program 

service centers about cases at high-risk for overpayments. Finally, SSA 

relies on potentially inaccurate management information to effectively 

administer its CDR workload. In particular, its data may not accurately 

reflect the age and disposition of its work CDR workload, or the time it 

actually takes to process them. These vulnerabilities may contribute to the 

“old” cases we identified in many SSA field offices, some of which were as 

much as 7 years old, resulting in large individual overpayments totaling 

between $28,000 and $105,000. Moreover, we found that SSA has difficulty 

balancing competing workloads—particularly in its field offices where 

staff resources are limited and staff have numerous different duties—that 

may contribute to some of the old cases we observed. SSA is developing 

new automated systems that could potentially address some of these 

Results in Brief 
Page 4 GAO-04-929 SSA Should Strengthen Its Efforts 

problems by helping the agency manage its disability workload more 

efficiently, but it is too early to determine if these initiatives will address 

the weaknesses we identified. 

Work CDRs can be complex and time-consuming for SSA staff to perform. 

We recognize that ensuring program integrity while focusing on the 

important goal of returning individuals with disabilities to work presents 

additional challenges for SSA. However, there are several areas where we 

believe SSA can make improvements. Accordingly, we are recommending 

that the Commissioner of Social Security direct the agency to explore new 

tools and more timely data sources that can be used to more effectively 

detect and prevent earnings-related overpayments. 

SSA agreed with our recommendations and provided information on 

several initiatives that are planned or underway to address them. 

The DI program was established in 1956 to provide monthly cash benefits 

to individuals who were unable to work because of severe long-term 

disability. In fiscal year 2003, SSA paid about $70 billion to 7.5 million 

disabled workers, their spouses, and dependents, with average monthly 

cash benefits of about $723 per beneficiary.5

 To be eligible for benefits, 

individuals with disabilities must have a specified number of recent work 

credits under Social Security when they first became disabled. Individuals 

may also be able to qualify based on the work record of a deceased, 

retired, or disabled parent, or a deceased spouse. Benefits are financed by 

payroll taxes paid into the Federal Disability Insurance Trust Fund by 

covered workers and their employers, based on the worker’s earnings 

history. To meet the definition of disability under the DI program, an 

individual must have a medically determinable physical or mental 

impairment that (1) has lasted or is expected to last at least 1 year or to 

result in death and (2) prevents the individual from engaging in substantial 

gainful activity. Individuals are engaged in SGA if they have earnings 

above $810 per month in calendar year 2004.6

 Program guidelines require 

DI beneficiaries to report their earnings to SSA in a timely manner in order 

to ensure that they remain eligible for benefits. 

 5

Average benefit figure was reported for December 2003. 

6

SGA for blind beneficiaries is $1,350 per month. 

Background 
Page 5 GAO-04-929 SSA Should Strengthen Its Efforts 

SSA conducts work issue CDRs to determine if beneficiaries are working 

above the SGA level.7

 SSA initiates a work CDR only after the beneficiary 

has completed a 9-month trial work period, during which the beneficiary is 

allowed to earn more than the SGA level without affecting their eligibility 

for benefits.8

 The trial work period is one of several provisions in the DI 

program intended to encourage beneficiaries to return to work. The trial 

work period begins with the first month a beneficiary is eligible for DI 

benefits. Once the trial work period is completed, beneficiaries are 

generally ineligible for future DI benefits unless their earnings fall below 

the SGA level.9

Work CDRs are triggered by several types of events, although most are 

generated by SSA’s Continuing Disability Review Enforcement Operation 

(enforcement operation). This process involves periodic computer 

matches between SSA’s administrative data and IRS wage data. The 

enforcement operation generates notices for cases that exceed specified 

earnings thresholds,10 which are forwarded to 1 of 8 program service 

centers for additional examination.11 The cases at each program service 

center are then temporarily housed in a central repository (called the 

computer output section) and are released to “earnings reviewers” for 

 7

We use the term “work CDRs” to describe instances in which SSA staff perform limited 

development of beneficiary earnings because they determine that a full work CDR is not 

necessary (an activity that SSA refers to as a “work CDR action”), as well as “full” work 

CDRs in which a case is fully developed and staff fill out specific forms to receive work 

credit for completing a work CDR. 

8

The trial work period allows beneficiaries to work for 9 months (not necessarily 

consecutive) within a 60-month rolling period during which they may earn any amount 

without affecting benefits. 

9

To provide additional incentives to encourage work, beneficiaries who have completed 

their trial work period are entitled to a 36-month extended period of eligibility during 

which they may receive benefits for any month in which their earnings fall below SGA. 

Other work incentive provisions allow SSA to deduct certain impairment-related work 

expenses and employer subsidies from beneficiaries’ earnings determination. SSA staff 

must consider all these provisions when assessing whether beneficiaries’ earnings 

constitute SGA. 

10SSA currently uses six times the SGA amount, or $4,860 as the annual test level to screen 

out beneficiaries whose earnings amount would not likely affect their DI benefits. 

11Most cases (about 60 percent) are sent to the program center in SSA’s Office of Central 

Operations (OCO). OCO is responsible for handling beneficiaries who are less than 

55 years of age. According to SSA officials, these beneficiaries tend to work more 

frequently and have more employers than older beneficiaries, thus making the cases more 

complicated to process. The remaining cases for beneficiaries older than 55 are sent to one 

of the remaining 7 program service centers. 
Page 6 GAO-04-929 SSA Should Strengthen Its Efforts 

development of work activities. Cases are generally released for 

development on a first-in-first-out basis, based on how long they have been 

in the central repository, and according to staff workloads. After initial 

review, cases for which individuals may require cessation of benefits are 

generally forwarded to a “disability processing specialist” for additional 

development.12

Work CDRs can also be triggered by other events. For example, SSA 

requires beneficiaries to undergo periodic medical examinations to assess 

whether they continue to be physically disabled.13 During such reviews, 

Disability Determination Service staff sometimes discover evidence that 

indicates the beneficiary may be working and usually forwards the case to 

an SSA field office or program service center for earnings/work 

development. Additional events that may trigger a work CDR include 

reports from state vocational rehabilitation agencies, other federal 

agencies, and anonymous tips. Finally, DI beneficiaries may voluntarily 

report their earnings to SSA by visiting an SSA field office, or calling the 

agency’s toll free “800” number. 

Several SSA components are involved in processing work CDRs. While 

most are initially sent to SSA’s program service centers as a result of the 

enforcement operation, some cases are referred to any one of SSA’s more 

than 1,300 field offices for more in-depth development. Field offices also 

tend to be the focal points for work CDRs generated by events other than 

the enforcement operation. Work CDRs can entail labor-intensive, timeconsuming procedures such as reviewing folders, performing in-person 

interviews, and contacting beneficiaries and their employers to verify their 

monthly earnings. Staff are also required to take into consideration several 

complex work incentive provisions when calculating whether earnings 

 12“Disability processing specialists” work in SSA’s program service centers and are 

responsible for determining if benefits should be discontinued and whether an 

overpayment exists. “Earnings reviewers” in the program centers are generally responsible 

for initial analysis of a beneficiary’s earnings; however, only disability processing 

specialists have the authority to cease benefits. In SSA’s field offices, the claims 

representatives are responsible for the duties performed by both the disability processing 

specialist and the earnings reviewer. 

13SSA contracts with state Disability Determination Services (DDS) that are responsible for 

assessing whether an individual is medically disabled (a “medical” CDR). During the course 

of a medical CDR, DDS examiners sometimes find evidence that a beneficiary may be 

working. Medical CDRs are costly to perform and such cases are typically referred to an 

SSA field office or PSC for financial development before additional medical development is 

performed. 
Page 7 GAO-04-929 SSA Should Strengthen Its Efforts 

exceed SGA.14 In addition, staff—particularly in SSA field offices—are also 

required to balance numerous competing workloads, including processing 

initial claims, serving individuals who walk into the field office without an 

appointment, meeting with beneficiaries who have requested an 

appointment, and processing a “special disability workload.”15

DI overpayment detections increased from about $772 million to about 

$990 million between fiscal years 1999 and 2003. These overpayments 

included a substantial amount due to beneficiaries who worked and 

earned more than SGA. Our analysis of available overpayment data shows 

that, on average, beneficiaries with earnings over program guidelines 

constitute about 31 percent of all DI overpayments. These overpayments 

also contributed to mounting financial losses in the DI program. Total 

overpayment debt increased from about $1.9 billion to nearly $3 billion 

from fiscal years 1999 to 2003. SSA overpayment collections increased 

from about $269 million to about $431 million during the same period. 

However, our analysis shows that waivers and write-offs also increased 

during this period. 

Total DI overpayment detections increased from about $772 million to 

about $990 million between fiscal year 1999 to 2003 (see fig. 1) including a 

substantial proportion due to beneficiary earnings.16 On the basis of data in 

a recent study from SSA, we calculated that overpayments attributable to 

work and earnings averaged about 31 percent of all DI overpayments 

annually between 1999 and 2002. We consulted SSA officials about our 

calculations to determine if they were accurate. These officials agreed that 

the estimate is generally accurate based on limited available data, but 

likely understates the true extent of the problem. In particular, SSA 

officials acknowledged that their study only examined beneficiaries who 

had their benefits suspended or terminated following a work CDR; it did 

 14These provisions include tracking the 9-month “trial work period” and an “extended 

period of eligibility,” as well as calculating “impairment related work expenses” and 

“employer subsidies.” 

15This workload is comprised of about 500,000 SSI recipients who at some point became 

eligible for DI. However, the SSI administrative systems failed to identify these cases. SSA 

is now focusing resources on processing this workload. 

16Overpayments may also be caused by other types of events, including receipt of workers 

compensation benefits, being in prison while receiving benefits, and medical improvement 

to the point where the individual is no longer disabled. 

Overpayments in the 

DI Program Are 

Substantial and Have 

Increased in Recent 

Years 

Overpayments Due to 

Beneficiary Earnings 

above SGA May Be More 

Prevalent than SSA 

Currently Detects 
Page 8 GAO-04-929 SSA Should Strengthen Its Efforts 

not consider individuals who may have been overpaid but continued to 

receive benefits. A beneficiary may be overpaid, but not placed in 

suspended or terminated status because (1) SSA waived the overpayment, 

(2) the case was still being processed, or (3) the individual became 

unemployed and returned to the DI rolls. Our review identified several 

such cases in numerous field offices. For example, one case we examined 

involved a beneficiary who was selected for review by the enforcement 

operation every year from 1998 to 2001. Other than notations on the 

individual’s account that the case was selected for review, there was no 

evidence that a work CDR was ever conducted. In February 2003, program 

service center staff transferred the case to a field office to have the 

recipient’s earnings reviewed. However, field office staff were unable to 

contact the recipient and the case was transferred back to the program 

service center in August 2003. As of March 2004, the case was still being 

reviewed and waiting final SSA action. SSA officials told us that this 

individual should have had an overpayment listed for the time between 

December 1999 and September 2001. However, at the time of our review, 

no overpayment had yet been established and, therefore did not appear in 

SSA’s overpayment detection data for those years. Ultimately, we estimate 

that this case will likely result in a $64,000 overpayment once it is fully 

developed and completed. 

Figure 1: Total DI Overpayment Detections Have Increased (1999–2003) 

Dollars in millions

 0

 100

 200

 300

 400

 500

 600

 700

 800

 900

1,000

1999 2000 2001 2002 2003

Year

772

859 859 887

990

Source: GAO analysis based on data from SSA's Office of Finance, Assessment, and Management.
Page 9 GAO-04-929 SSA Should Strengthen Its Efforts 

The increase in DI overpayments from 1999 to 2003 has contributed to 

mounting financial losses in the program. Total DI overpayment debt17

increased from about $1.9 billion in 1999 to nearly $3 billion in 2003. 

During this same period, SSA’s overpayment collections increased from 

about $269 million to about $431 million. Agency officials attributed the 

increase in collections in part to new initiatives they have made use of. For 

example, SSA has conducted debt management workshops to (1) develop 

new ideas on collecting the agency’s mounting outstanding debt and (2) 

identify and prioritize debt that the agency should concentrate on 

collecting. In addition, SSA is in the process of developing new collection 

tools, such as wage garnishment to recoup overpayments, and has 

published final regulations to implement this tool.18 However, these 

improvements notwithstanding, the total overpayment debt is increasing. 

(See fig. 2.) 

Figure 2: Total Overpayment Debt Is Increasing (1999–2003) 

 17Total overpayment debt is comprised of existing debt carried forward from prior years, 

and newly detected overpayments, net of collections, waivers, and write-offs in each fiscal 

year. 

18 68 Fed. Reg. 74117 (to be codified at 20 C.F.R. pt. 422 subpt. E ). 

Although SSA Has 

Improved Its Collection 

Efforts, Financial Losses 

Are Mounting 

Dollars in millions

 0

 500

1,000

1,500

2,000

2,500

3,000

1999 2000 2001 2002 2003

Year

Source: GAO analysis based on SSA data.
Page 10 GAO-04-929 SSA Should Strengthen Its Efforts 

Increases in waivers and write-offs19 during this period have also 

contributed, in part, to the DI program’s growing overpayment debt. SSA 

must waive collection of an overpayment if SSA determines that the 

beneficiary was not at fault in causing the overpayment and either the 

beneficiary would be financially unable to repay the overpayment or 

recovery would be against equity and good conscience. The agency may 

also write-off overpayments for various reasons, including when the 

agency is unable to locate an individual for a prolonged period of time. 

Waivers and write-offs increased from about $222 million in 1999 to about 

$325 million in 2003. The increase in waivers and write-offs is attributable, 

in part, to increases in total program outlays during this period.20

Ultimately, our review suggests that overpayments not only contribute to 

increasing overpayment debt, but also may be a disincentive for 

individuals with disabilities to return to work. In particular, the potential 

of having to repay a large overpayment may discourage some beneficiaries 

from continuing to work, thus running contrary to SSA’s goal of helping 

such individuals become self-sufficient. 

SSA’s ability to detect and prevent earnings-related overpayments is 

hindered by a lack of timely wage data, inefficient processes for 

conducting work CDRs, and potentially inaccurate management 

information. First, the earnings data produced by the enforcement 

operation are typically 12-18 months old when SSA first receives it, thus 

making some overpayments inevitable. Second, SSA lacks the means to 

systematically screen and identify beneficiaries most likely to incur large 

overpayments. Moreover, even if such a screen existed, SSA currently 

lacks an automated alert mechanism for notifying its field office and 

program service center staff about such cases. Third, SSA relies on 

management information data that may not accurately reflect the age of 

 19 According to SSA, some waivers are beyond the agency’s control, such as those 

attributable to bankruptcy, Tax Refund Offsets, and Administrative Law Judge decisions 

instructing the agency to waive overpayments. Moreover, some debt that is written-off may 

ultimately be reestablished if the beneficiary returns to the DI rolls. In addition, SSA 

continues recovery efforts of qualified written-off debts via the Treasury Offset Program, 

credit bureau reporting, and mandatory cross-program recovery. 

20 Total DI program outlays increased from about $50.4 billion in fiscal year 1999 to about 

$70 billion in fiscal year 2003. 

Lack of Timely Data 

on Beneficiary 

Earnings and Other 

Vulnerabilities Impede 

SSA’s Ability to Detect 

and Prevent DI 

Overpayments 
Page 11 GAO-04-929 SSA Should Strengthen Its Efforts 

work CDR cases—the time it actually takes to review and complete them. 

Inaccurate management data can impede the agency’s ability to effectively 

monitor program activities and make corrections, when necessary. These 

weaknesses may contribute to some cases becoming old and resulting in 

large overpayments. We identified several cases in which as much as 

7 years had passed between the point at which the case was initially 

selected for development and the time it was completed. 

SSA currently relies on outdated information to verify DI beneficiaries’ 

eligibility for benefits.21 The agency conducts periodic matches between its 

earnings records and IRS wage data to determine if beneficiaries have 

earnings above the SGA level. The Continuing Disability Review 

Enforcement Operation (enforcement operation) is generally conducted 

three times annually—a principal match in May, and two supplemental 

matches in August, and February of the following year. According to some 

SSA officials, earnings data from the enforcement operation are generally 

about 12-18 months old by the time the cases are selected for review and 

arrive in the program service center. SSA officials told us that the age of 

the earnings data impedes the agency’s ability to effectively detect 

potential overpayments in a timely manner. Moreover, because a 

substantial proportion of all work CDRs in any given year are generated by 

these enforcement matches, a large proportion of this workload is 

dependent on outdated earnings information. Thus, some cases with 

potentially large overpayments may not be detected for extended periods 

of time. 

SSA lacks access to more timely sources of wage data for verifying DI 

beneficiaries’ earnings, such as the Office of Child Support Enforcement’s 

National Directory of New Hires (NDNH). This database contains quarterly 

state wage and new hires data that could be used to help evaluate 

beneficiaries’ continuing eligibility for benefits more quickly than the 

enforcement operation. While SSA currently uses this database to 

periodically monitor the earnings of SSI recipients, it lacks similar 

authority for the DI program. In particular, SSA currently lacks the 

 21Beneficiaries are required to report earnings to SSA that may affect their eligibility for 

benefits, and SSA relies on beneficiaries to report such information in a timely manner. 

However, our review found that individuals sometimes do not report their earnings as 

required. 

SSA Lacks Timely Data to 

Detect Overpayments 
Page 12 GAO-04-929 SSA Should Strengthen Its Efforts 

authority to conduct “batch file” computer matches22 with the NDNH—-

similar to the types of matches it routinely uses to verify SSI recipients’ 

continuing eligibility for benefits. Although the agency recently obtained 

“online access” to the NDNH for the DI program, this type of access only 

allows SSA to obtain wage data on case-by-case basis; it does not permit 

the agency to systematically match all DI beneficiaries against the NDNH 

to identify those with high levels of earnings—a potentially valuable, costeffective means of identifying beneficiaries who may be at risk for large 

overpayments. 

The agency lacks the means to identify beneficiaries who are most likely 

to incur large overpayments. SSA currently uses the enforcement 

operation to select individuals with more than $4,860 in annual earnings 

for a work CDR. While periodic computer matches with the NDNH would 

help provide more timely, comprehensive earnings data to SSA, some SSA 

officials told us that the agency would still need the ability to 

systematically screen the cases to identify those at high-risk for large 

overpayments. The agency currently uses a screen for its medical CDR 

reviews, which helps the agency identify beneficiaries who are most (or 

least) likely to have medically improved.23 This screen helps SSA prioritize 

the use of limited staff resources by scheduling beneficiaries who are 

identified as least likely to improve for less frequent medical CDRs, and 

using forms that are periodically mailed to them requesting information on 

their medical condition. While our prior work has identified some 

problems with this screening mechanism,24 in general SSA believes that, in 

many instances, it helps the agency mitigate the need for costly, timeconsuming medical examinations that may not be necessary. However, the 

agency does not currently have a similar tool for its work CDRs to identify 

 22Batch file computer matches would allow SSA to periodically match all DI beneficiaries 

against wage and new hires data in the NDNH, thus helping the agency identify individuals 

with high levels of earnings (those who may be likely to incur large overpayments). 

23This mechanism involves the application of statistical formulas that use data on 

beneficiary characteristics contained in SSA’s computerized records—such as age, 

impairment type, length of time on the disability rolls, previous CDR activity and reported 

earnings—to predict the likelihood of medical improvement and, therefore, benefit 

cessation. 

24 GAO, Social Security Disability: Reviews of Beneficiaries’ Disability Status Require 

Continued Attention to Achieve Timeliness and Cost-Effectiveness, GAO-03-662

(Washington, D.C.: July 24, 2003). 

SSA Lacks an Effective 

Screening Mechanism to 

Identify Cases Most Likely 

to Incur Large 

Overpayments 
Page 13 GAO-04-929 SSA Should Strengthen Its Efforts 

beneficiaries with high levels of earnings or other characteristics that may 

contribute to large overpayments. 

One program service center we visited is considering the use of a screen 

that would give higher priority to developing cases for beneficiaries with 

higher earnings, and thus the potential for larger overpayments.25 Some 

SSA officials we interviewed told us that such a screen would help the 

agency prioritize this workload and make better use of limited resources, 

particularly in field offices where staff are often constrained by several 

competing workloads, such as processing initial claims. Further, one 

official in this program service center told us some of the other program 

centers were considering implementing this screen. 

Even if a screen existed that would allow SSA to identify cases with the 

greatest potential for large overpayments, the agency still lacks a timely 

alert mechanism to notify field offices and program service centers about 

such cases.26 According to some SSA officials, such a mechanism, if 

created, could allow the agency to quickly notify field offices and program 

service centers about cases that have been identified as high-priority for 

work CDRs. SSA currently uses an alert mechanism in its SSI program to 

rapidly notify field offices about recipients with high levels of earnings or 

other factors that may affect their eligibility for benefits. These alerts are 

generated centrally from SSA’s match with the NDNH and sent 

electronically to field office staff, telling them which recipients should 

have their cases reviewed. However, a similar alert system does not 

currently exist in the DI program. Instead, SSA field offices rely on daily 

workload management listings of potential work CDR cases that are 

relayed via existing agency systems. These lists summarize the cases that 

are awaiting review, including the “age” of the case. On the basis of such 

lists obtained from several field offices, we found that half of the cases 

were at least 117 days old. Moreover, cases that were transferred from 

program service centers were generally older—some were listed as being 

999 days old. In addition, because the data field for measuring the age of 

cases on the workload management lists only holds a maximum of 3 

 25 According to SSA, the agency is currently developing a scoring mechanism that would 

help the agency better manage overpayment-related workloads in its program service 

centers and field offices. 

26SSA’s enforcement operation does generate alerts for cases that should be reviewed. 

However, this alert is not as timely as the wage alerts generated in the SSI program that 

notify staff about cases that should be examined due to recipient earnings. 
Page 14 GAO-04-929 SSA Should Strengthen Its Efforts 

characters, SSA officials told us that these cases were likely older than 

indicated on the lists. In addition, we found that these lists do not allow 

managers to identify cases with the greatest potential for overpayments. 

As a result, staff generally review cases as they are released by managers 

to be developed. While some managers and staff we interviewed told us 

that they make a concerted effort to review the oldest cases first, others 

told us that they generally process the cases on a “first-in-first-out” basis, 

which is not necessarily related to the age of the case. 

Our review suggests that SSA relies on potentially inaccurate data to 

manage its work CDR workload. In particular, our work shows that highlevel management information data on the age of work CDR cases may not 

accurately reflect the true age of cases (i.e. the actual time it took to 

complete these cases) and may result in cases being counted more than 

once, thus distorting the information that SSA relies on to measure the 

number of cases that are reviewed and completed. To test the accuracy of 

high-level management data for this workload, we conducted an in-depth 

examination of 71 randomly selected cases27 that were “cleared” from 

SSA’s Processing Center Action Control System28 (the system) during a 1-

week period in April 2004. On the basis of our sample we estimate that, 

overall, 49 percent29 of these cases were improperly cleared from this 

system. This means that the cases were listed as having been fully 

reviewed and completed, when in fact they still required additional 

development. Improperly cleared cases can have several negative impacts 

according to SSA officials, including the potential for contributing to large 

overpayments. For example, on the basis of our sample, we estimate that 

13 percent of the cases were improperly cleared from the system because 

 27We worked with SSA to select a 1 percent sample of cases that were cleared from its 

Processing Center Action Control System over a 1-week period in April 2004. This 1 percent 

sample included a total of 151 cases. We then randomly sampled 71 of these cases for 

review. For this file review, the margin of error for all percentage estimates does not 

exceed plus or minus 10 percentage points at the 95 percent confidence level, unless 

otherwise noted. 

28This system is used by SSA to produce management information in its “Workload Status 

Report” used by the agency to track the disposition of cases that are sent to the program 

service centers for development as a result of the enforcement operation. According to SSA 

officials, cases should only be listed as “cleared” in this system if they have been fully 

developed and completed in accordance with agency guidelines for processing work CDRs. 

29The 95 percent confidence interval surrounding this estimate ranges from 37 to 61 

percent. 

Weaknesses in SSA’s 

Management Information 

Hinder Its Ability to 

Effectively Monitor Work 

CDR’s 
Page 15 GAO-04-929 SSA Should Strengthen Its Efforts 

they were not fully developed and did not have a “diary” attached to 

them—an automated notice that reminds staff to review the case after a 

specified period of time. Such cases might not be selected for review again 

until the next enforcement match—which could be as much as 1 year—

and result in overpayments if the beneficiary had earnings that exceeded 

the SGA level. Most importantly, because they did not have a diary, SSA 

did not have any way of monitoring these cases or ensuring that they were 

properly completed. This weakness may partially explain the type of old 

cases with large overpayments we identified in several SSA field offices. 

In addition to the cases without any diary, an estimated 37 percent30 of the 

cases were incorrectly shown as cleared while still being developed in 

various locations such as field offices.31 Although these cases had a diary—

thus giving SSA some level of internal control over them—our analysis 

shows they could still result in management information that does not 

show the true age of work CDR cases. More specifically, these types of 

cases would likely result in management information that understates the 

true age of such cases, and would distort the overall measurement of 

progress in handling work CDR workloads. Such cases could also result in 

the double counting of work CDRs. For example, if a single case was 

cleared in the program center and subsequently developed and cleared in a 

field office, it could be incorrectly listed as two separate work CDRs. SSA 

officials also acknowledged that some of the cases we reviewed which 

showed indications of being cleared multiple times could result in their 

being counted as numerous separate work CDRs. Thus, existing high-level 

management data may not accurately capture how many work CDRs have 

actually been completed. 

We also found that SSA does not currently have the capability to track the 

disposition of work CDR cases. For example, the agency is unable to 

systematically track how many work CDR cases involve overpayments. 

Because it lacks sufficient management information data on this workload, 

the agency also does not have performance goals for work CDRs similar to 

measures it maintains for its medical CDR workloads, such as the number 

 30The 95 percent confidence interval surrounding this estimate ranges from 26 to 49 

percent. 

31We estimate that 28 percent of the cases were properly cleared (the 95 percent 

confidence interval surrounding this estimate ranges from 18 to 40 percent). In addition to 

the 49 percent that were improperly cleared, an additional 14 percent had some other 

processing problem, while 6 percent could not be completed on the basis of available 

information, and 3 percent did not have any work issue involved. 
Page 16 GAO-04-929 SSA Should Strengthen Its Efforts 

of work CDRs that should be completed each year. Moreover, given the 

problems we identified with potential double or multiple counting of work 

CDR cases, it is unclear whether SSA could establish meaningful 

performance goals at this time. 

The vulnerabilities we identified have likely contributed to old work CDR 

cases and large earnings-related overpayments in the DI program. We 

identified several examples of cases that took years to develop and 

complete. Some of these cases were as much as 7 years old and involved 

large overpayments. The following are examples of some of these cases: 

• One case we observed was initially selected for review in 1997 by the 

enforcement operation. Although the recipient’s benefits should have 

been discontinued in 1997 according to SSA officials, payments 

continued until March 2000. Agency officials could not explain why no 

action was taken on this case between 1997 and 2000. As a result, this 

beneficiary incurred a $28,000 overpayment. 

• Another case was selected for review each year from 1997 to 2001 by 

the enforcement operation. However, there was no evidence in the file 

that a work CDR was conducted until February 2004, and SSA officials 

were unable to explain why no action was taken after several 

consecutive enforcement matches. This beneficiary incurred an 

estimated $105,000 overpayment between April 1997 and 

December 2003. 

• Another case involved a beneficiary who had earnings well above SGA 

in 1998 when they first became eligible for DI benefits. However, the 

case only arrived in the field office for action in March 2003. SSA 

discontinued the recipient’s benefits in 2003, but SSA officials could 

not explain why the case took 5 years to arrive at the field office for 

action. As a result, the recipient incurred a $32,000 overpayment. 

• An additional case we identified involved a beneficiary with earnings 

well above SGA for several years and who incurred a prior earningsrelated overpayment. SSA subsequently waived the overpayment. 

However, the recipient continued to work without reporting the 

earnings to SSA. The agency eventually discontinued the individual’s 

benefits in September 2003. At the time of our review, SSA officials 

estimated that the beneficiary had incurred a $102,000 overpayment. 

Identified Vulnerabilities 

Contribute to Some Large 

Overpayments 
Page 17 GAO-04-929 SSA Should Strengthen Its Efforts 

Further compounding the vulnerabilities that contribute to aged cases and 

large overpayments, our review suggests that SSA has difficulty balancing 

competing workloads. In particular, SSA field office staff are required to 

perform numerous duties, including processing initial claims, serving 

individuals who walk into the field office without an appointment, meeting 

with beneficiaries who have requested an appointment, and processing the 

“special disability workload.” Many managers and staff we interviewed 

told us that work CDRs generally receive lower priority than some of these 

other activities, such as processing initial claims. In several offices we 

visited, we observed lists of pending work CDRs, sometimes stored in file 

cabinets for extended periods of time. 

SSA is currently implementing a new automated system that may address 

some of the vulnerabilities we identified. This system, called “eWork,” is 

intended to simplify how SSA manages and processes its disability cases. 

In particular, according to documentation provided by SSA, this system 

will establish program controls for all work CDR cases and help the 

agency identify higher priority cases. Once fully implemented, eWork will 

combine data from several different SSA databases and will automate the 

processing of numerous forms commonly used in developing and 

documenting disability cases, according to SSA. One field office we visited 

was piloting this system. Management and staff in this office generally 

reported that the system was an improvement over existing systems. In 

particular, officials reported that the system was useful in helping them 

track the age of work CDR cases, especially older cases that should 

potentially receive higher priority. Overall, SSA management and line staff 

expressed confidence that this new system will improve the agency’s 

ability manage its disability cases, including work CDRs. However, 

because the system is new and is not yet fully implemented nationwide, 

we were unable to evaluate how effective it may be for addressing some of 

the weaknesses we identified. 

We recognize that ensuring program integrity while focusing on the 

important goal of returning individuals with disabilities to work presents 

challenges for SSA. However, the weaknesses we identified in SSA’s 

existing work CDR processes continue to expose the program to 

overpayments and abuse. In particular, SSA’s reliance on outdated 

earnings information has contributed to overpayments and forced staff to 

investigate cases that are old and thus difficult and time-consuming to 

process. Without the ability to conduct batch file computer matches with 

Conclusions 
Page 18 GAO-04-929 SSA Should Strengthen Its Efforts 

the National Directory of New Hires, the agency will remain vulnerable to 

large earnings-related overpayments. Similarly, the lack of a screen to 

systematically identify beneficiaries more likely to incur overpayments 

means that SSA cannot target cases that should receive higher priority. 

Even if such a screen existed, SSA would not be able to make the best use 

of it given the lack of an automated alert system to notify field offices and 

program service centers about which cases should be reviewed. Moreover, 

without accurate, reliable management data on the age and status of work 

CDR cases, SSA will find it difficult to effectively monitor this workload, 

identify areas that require continued improvement, and develop 

meaningful work performance measures. 

In an environment of limited budgetary and staff resources, federal 

agencies such as SSA will be required to take a more strategic approach to 

servicing ever-increasing workloads. The magnitude of earnings-related 

overpayments indicates that SSA should take additional steps to 

strengthen DI program integrity. Moreover, the potential of having to repay 

a large overpayment may discourage some beneficiaries from continuing 

to work, thus working contrary to SSA’s goal of helping individuals 

become self-sufficient. Ultimately, without a concerted effort to increase 

management focus on this key workload and to reengineer existing 

processes, SSA’s ability to ensure that trust fund dollars are protected and 

reserved for those who are truly eligible will continue to be compromised. 

The new automated system that SSA is developing may help the agency 

address some of the weaknesses we identified, but it is too early to 

determine how effective it will be. A conscious management decision to 

use this system to improve DI program integrity in conjunction with more 

accurate management information will be required to help detect and 

prevent large overpayments. 

To enhance SSA’s ability to detect and prevent overpayments in the DI 

program, we recommend that the Commissioner of Social Security take 

the following actions to improve the agency’s work CDR processes: 

1. Initiate action to develop a data sharing agreement with the Office of 

Child Support Enforcement to conduct batch-file periodic computer 

matches with the National Directory of New Hires (NDNH). Such 

matches would provide SSA with more timely data to help the agency 

systematically identify DI beneficiaries who are most likely to incur 

overpayments. Such a tool could also allow SSA to perform a one-time, 

comprehensive match against all DI beneficiary records to identify 

individuals who may be overpaid but have not yet been detected. 

Recommendations 
Page 19 GAO-04-929 SSA Should Strengthen Its Efforts 

2. Consider developing an enhanced screening mechanism that would 

enable the agency to more effectively identify DI beneficiaries who are 

most likely to incur earnings-related overpayments. This would help 

the agency make more efficient use of limited staff and budgetary 

resources. 

3. Study the potential for creating an alert system similar to that used in 

the SSI program for alerting field offices about recipients at high risk 

for earnings-related overpayments. Such a system would allow SSA to 

notify field offices and program service centers about beneficiaries the 

agency identifies as most likely to incur large overpayments. 

4. Consider ways to improve the accuracy and usefulness of existing 

management information data. Improvements may include modifying 

how the agency measures the age of work CDR cases to more 

accurately reflect how long they are in process. 

5. Once the eWork system is fully implemented, SSA should consider 

how it could be used to help the agency create performance goals for 

its work CDR workload. 

We provided a draft of this report to SSA for review and comment. SSA 

agreed with our recommendations and, in some instances, outlined initial 

plans for their implementation. 

SSA agreed with our first recommendation to develop a data-sharing 

agreement with the Office of Child Support Enforcement to conduct 

batch-file computer matches with the NDNH. The agency noted that it 

pursued online access to the NDNH first because it was more cost 

effective and expeditious. The agency also indicated that it is developing a 

new computer matching agreement that supports SSA’s use of the NDNH 

in the DI program for purposes of identifying potential overpayments. We 

encourage SSA to ensure that any new agreement will provide for 

periodic, batch-file matches to verify beneficiaries’ earnings at regular, 

specified intervals. 

SSA also agreed with our second recommendation to consider developing 

an enhanced screening mechanism to help the agency more effectively 

identify DI beneficiaries most likely to incur earnings-related 

overpayments. In particular, SSA agreed that it should pursue a screening 

system similar to that currently used for medical CDRs to determine if 

there is an increased likelihood of earnings-related overpayments based on 

particular diagnosis codes. It also noted that it should study ways to 

Agency Comments 

and Our Evaluation 
Page 20 GAO-04-929 SSA Should Strengthen Its Efforts 

improve the effectiveness of existing systems (such as the Continuing 

Disability Review Enforcement Operation and the Disability Control File) 

to help the agency focus on beneficiaries with the greatest potential for 

overpayments. We agree that these are positive steps and that the agency 

should consider how improvements to such systems might be 

incorporated to emerging systems such as “eWork”. 

With respect to our third recommendation that SSA develop an alert 

system similar to that currently used in the SSI program for alerting staff 

to cases at risk for earnings-related overpayments, SSA agreed and noted 

that an alert system such as the “S2” alert used for SSI wage discrepancies 

could provide a useful model. The agency noted that such an alert could 

reduce the amount of time in which a claimant would continue to receive 

payments while work development is initiated. Moreover, since these 

reports include the employer’s name, address, and a quarterly breakdown 

of the beneficiary’s earnings, this detailed information would provide SSA 

staff with more specific information than is currently available. SSA also 

said that an alert system could also be generated from the NDNH match 

proposed in our first recommendation. We agree that an alert system 

would help identify potential overpayments more quickly, particularly if it 

were generated from data produced by periodic computer matches with 

the NDNH. 

SSA agreed with our fourth recommendation to improve the accuracy and 

usefulness of existing management information data. SSA said that it is 

working on a plan to unify the manner in which it identifies and counts 

work and medical CDRs. The agency believes that it will be able to more 

accurately capture workload counts and employee time consistently, 

regardless of where the work is performed. While we agree that efforts to 

improve existing processes and systems are necessary, it is too early to 

determine if the proposed modifications will address the problems we 

identified with high level management information, such as potential 

double-counting of work CDRs. 

SSA also agreed with our fifth recommendation to consider how it could 

use the eWork system to create performance goals for work CDRs once it 

is fully implemented. The agency commented that such a measure would 

give field offices and program service centers a better indication of what is 

expected of them regarding processing this workload and would help 

them balance the time needed to process competing workloads. 
Page 21 GAO-04-929 SSA Should Strengthen Its Efforts 

SSA’s formal comments appear in appendix II. SSA also provided 

additional technical comments that we have incorporated in the report as 

appropriate. 

Unless you publicly announce its contents earlier, we plan no further 

distribution until 30 days after the date of this report. At that time, we will 

send copies of this report to the House and Senate Committees with 

oversight responsibility for the Social Security Administration. We will 

also make copies available to other parties upon request. In addition, the 

report will be available at no charge on GAO's Website at 

http//:www.gao.gov. If you have any questions concerning this report, 

please contact me at (202) 512-7215. 

Sincerely yours,

Robert E. Robertson 

Director, Education, Workforce, 

 and Income Security Issues 
Appendix I: Scope and Methodology 

Page 22 GAO-04-929 SSA Should Strengthen Its Efforts 

This appendix provides additional details about our analysis of the 

Disability Insurance (DI) program’s work continuing disability review 

(work CDR) process, including potential weaknesses in the Social Security 

Administration’s (SSA) existing procedures and policies. To meet the 

objectives of the review, we examined DI performance data, prior reports 

by SSA and its Office of Inspector General (OIG), external research 

studies, and our prior reviews of the program. We analyzed DI payment 

data over a 5-year period from 1999 to 2003, and examined cases from 14 

out of 18 SSA field offices we visited and 3 program service centers. In 

addition, we randomly selected and reviewed 71 cases with earnings to 

determine if they were reviewed and processed in accordance with 

program guidelines. Finally, we conducted in-depth interviews with 230 

management and line staff from SSA’s headquarters; its regional offices in 

New York and San Francisco; 18 field offices in 6 states; and 3 out of 8 

regional program service centers. During our meetings, we (1) examined 

existing work CDR procedures; (2) documented management and staff 

views on the effectiveness of SSA’s work CDR processes for detecting and 

preventing earnings-related overpayments; and (3) discussed potential 

improvements to existing program processes, systems, and policies. 

We conducted independent audit work in six states (California, Florida, 

Maryland, Massachusetts, New York, and Virginia) to examine SSA’s 

policies and procedures for conducting work CDRs, and to identify any 

common weaknesses in SSA’s work CDR processes. We selected locations 

for field visits based on several criteria, including geographic dispersion, 

states with an SSA program service center, states with large numbers of DI 

beneficiaries, and states with large DI expenditures. In total, we visited 18 

field offices and interviewed 161 SSA field office managers and line staff 

responsible for the DI program. We visited a mix of large offices in 

metropolitan areas as well as smaller offices located in the suburbs. In 

addition, we visited three program service centers in Richmond, 

California; Queens, New York; and Baltimore, Maryland. These program 

centers were responsible for the majority of all work CDRs identified by 

the enforcement operation. Where appropriate, we also visited field offices 

or program centers that were conducting special initiatives or piloting 

emerging computer systems that could impact how SSA conducts work 

CDRs (such as the “eWork” system). 

During our meetings with SSA and OIG officials, we documented 

management and staff views on the effectiveness of work CDR policies 

and procedures and potential improvements to existing processes, 

policies, and systems. In particular, we documented management and staff 

views on (1) the timeliness of existing data sources to verify beneficiary 

Appendix I: Scope and Methodology 
Appendix I: Scope and Methodology 

Page 23 GAO-04-929 SSA Should Strengthen Its Efforts 

earnings, (2) the effectiveness of existing processes for identifying 

individuals at high-risk for large overpayments, (3) the effectiveness of 

existing computer systems for notifying staff responsible for conducting 

work CDRs about cases that should be reviewed, and (4) the accuracy of 

management information data used to monitor work CDRs in one large 

program service center. To further assess existing program processes and 

systems, at 10 offices and 3 service centers, we judgmentally selected 

between 5 and 7 pending or completed work CDR cases. We generally 

looked at older cases in order to understand where existing procedures 

may have weaknesses. We then conducted in-depth reviews of these case 

files to identify potential vulnerabilities in existing work CDR processes, 

policies, and systems. 

As part of our study, we worked with SSA to draw a 1 percent sample of 

all work CDR cases that were “cleared” from the agency’s Processing 

Center Action and Control System over a 1-week period in April 2004 (the 

“study population”). Our objective was to determine whether work CDR 

cases were cleared in accordance with agency guidelines and to assess the 

accuracy of high-level management data produced by this system. This 

sample resulted in a total of 151 cleared cases. We then randomly selected 

71 of these 151 cases for review. As part of our review, we discovered that 

there was a potential for cleared work CDR cases to appear multiple times 

in SSA’s Processing Center Action Control System. On the basis of our 

discussion with knowledgeable SSA officials, we determined it would be 

highly unlikely for cases to be listed as “cleared” multiple times in a 1-

week time period. Therefore, we assumed that cases did not appear more 

than once in the 1-week time period from which we drew our sample. 

Because we followed a probability procedure based on random selections, 

our sample is only one of a large number of samples that could have been 

drawn. Since each sample could have provided different estimates, we 

express our confidence in the precision of our particular sample’s results 

using 95 percent confidence intervals. A confidence interval is an interval 

that would contain the actual population value for 95 percent of the 

samples we could have drawn. As a result, we are 95 percent confident 

that each of the confidence intervals in this report will include the true 

values in the study population. For this file review, the margin of error for 

each percentage estimate does not exceed plus or minus 10 percentage 

points, unless otherwise noted. The margin of error is the distance from 

each estimate to the upper or lower boundaries of its 95 percent 

confidence interval.
Appendix I: Scope and Methodology 

Page 24 GAO-04-929 SSA Should Strengthen Its Efforts 

To assess the reliability of the databases we used, reviewed reports 

provided by SSA and its Office of Inspector General, which contained 

recent assessments of these databases. We also interviewed 

knowledgeable agency officials to further document the reliability of these 

systems. In addition, we checked the data for internal logic, consistency, 

and reasonableness. We determined that all the databases were 

sufficiently reliable for purposes of our review. 
Appendix II: Comments from the Social Security Administration 

Page 25 GAO-04-929 SSA Should Strengthen Its Efforts 

Appendix II: Comments from the Social 

Security Administration 
Appendix II: Comments from the Social Security Administration 

Page 26 GAO-04-929 SSA Should Strengthen Its Efforts 
Appendix II: Comments from the Social Security Administration 

Page 27 GAO-04-929 SSA Should Strengthen Its Efforts 
Appendix II: Comments from the Social Security Administration 

Page 28 GAO-04-929 SSA Should Strengthen Its Efforts 
Appendix II: Comments from the Social Security Administration 

Page 29 GAO-04-929 SSA Should Strengthen Its Efforts 
Appendix II: Comments from the Social Security Administration 

Page 30 GAO-04-929 SSA Should Strengthen Its Efforts 
Appendix III: GAO Contacts and Staff 

Acknowledgments 

Page 31 GAO-04-929 SSA Should Strengthen Its Efforts 

Daniel Bertoni, Assistant Director (202) 512-5988 

Jeremy D. Cox, Analyst-in-Charge (202) 512-5717 

In addition to those named above, Jeff Bernstein, Sue Bernstein, 

Dan Schwimer, Salvatore F. Sorbello, Sidney Schwartz, and Shana Wallace 

made important contributions to this report. 

Appendix III: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Staff 

Acknowledgments 
Related GAO Products 

Page 32 GAO-04-929 SSA Should Strengthen Its Efforts 

Social Security Disability: Reviews of Beneficiaries’ Disability Status 

Require Continued Attention to Achieve Timeliness and CostEffectiveness. GAO-03-662. Washington, D.C.: July 24, 2003. 

High-Risk Series: An Update. GAO-03-119. Washington, D.C.: 

January 2003. 

SSA Disability: Enhanced Procedures and Guidance Could Improve 

Service and Reduce Overpayments to Concurrent Beneficiaries. GAO-02-

802. Washington, D.C.: September 5, 2002. 

Social Security Administration: Agency Must Position Itself Now to Meet 

Profound Challenges. GAO-02-289T. Washington, D.C.: May 2, 2002. 

Social Security Disability: Disappointing Results from SSA’s Efforts to 

Improve the Disability Claims Process Warrant Immediate Attention.

GAO-02-322. Washington, D.C.: February 27, 2002. 

Social Security Administration: Status of Achieving Key Outcomes and 

Addressing Major Management Challenges. GAO-01-778. 

Washington, D.C.: June 15, 2001. 

High-Risk Series: An Update. GAO-01-263. Washington, D.C.: 

January 2001. 

Major Management Challenges and Program Risks: Social Security 

Administration. GAO-01-261. Washington, D.C.: January 2001. 

Social Security: Review of Disability Representatives. GAO/HEHS-99-

50R. Washington, D.C.: March 4, 1999. 

Major Management Challenges and Program Risks: Social Security 

Administration. GAO/OCG-99-20. Washington, D.C.: January 1999. 

High-Risk Program: Information on Selected High-Risk Areas. GAO/HR97-30. Washington, D.C.: May 16, 1997. 

High-Risk Series: An Overview. GAO/HR-97-1. Washington, D.C.: 

February 1997. 

Related GAO Products 

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Gloria Jarmon, Managing Director, JarmonG@gao.gov(202) 512-4400 

U.S. Government Accountability Office, 441 G Street NW, Room 7125 

Washington, D.C. 20548 

Jeff Nelligan, Managing Director, NelliganJ@gao.gov (202) 512-4800 

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548 

Washington, D.C. 20548 

GAO’s Mission 

Obtaining Copies of 

GAO Reports and 

Testimony 

Order by Mail or Phone 

To Report Fraud, 

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs