SSA DISABILITY 

BENEFITS

Enhanced Policies 

and Management 

Focus Needed to 

Address Potential 

Physician-Assisted 

Fraud

Report to Congressional Requesters

November 2014

GAO-15-19

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-15-19, a report to 

congressional requesters

November 2014

SSA DISABILITY BENEFITS

Enhanced Policies and Management Focus Needed to 

Address Potential Physician-Assisted Fraud

Why GAO Did This Study

SSA relies on medical evidence to 

determine whether the millions of new 

claimants each year qualify for 

disability benefits. This evidence—and 

those who provide it—have been the 

subject of intense scrutiny as questions 

have been raised about the potential 

for fraud schemes that include falsified 

medical evaluations. GAO was asked 

to study physician-assisted fraud in 

SSA’s disability programs.

GAO reviewed (1) how well SSA’s 

policies and procedures are designed 

and implemented to detect and prevent 

physician-assisted fraud, and (2) the 

steps SSA is taking to improve its 

ability to prevent physician-assisted 

fraud. GAO reviewed relevant federal 

laws and regulations, visited 5 of the 

54 DDS offices that were selected to 

obtain geographic and office structure 

variation, and analyzed DDS data to 

identify whether federally sanctioned 

physicians (as of the end of January

2014) may have submitted evidence 

on behalf of claimants. GAO also 

interviewed SSA officials, as well as 

private disability insurers and others 

knowledgeable about SSA’s programs 

to identify key practices for fraud 

prevention.

What GAO Recommends

GAO recommends SSA identify ways 

to remove potential disincentives for 

detecting and referring potential fraud, 

enhance its training efforts, evaluate 

the threat of physician-assisted fraud, 

and ensure that new and existing fraud 

efforts are coordinated. SSA agreed 

with four of our five recommendations, 

partially agreed with one, and noted 

plans to address all of them.

What GAO Found

The Social Security Administration (SSA) has policies and procedures in place 

for detecting and preventing fraud with regard to disability benefit claims. 

However, GAO identified a number of areas that could leave the agency 

vulnerable to physician-assisted fraud and other fraudulent claims:

• SSA relies heavily on front-line staff in the offices of its disability 

determination services (DDS)—which have responsibility for reviewing 

medical evidence—to detect and prevent potential fraud. However, staff said 

it is difficult to detect suspicious patterns across claims, as directed by SSA 

policy, given the large number of claims and volume of medical information 

they review. Moreover, DDS offices generally assign claims randomly, so 

staff said it would only be by chance that they would review evidence from 

the same physician. 

• SSA and, in turn, DDS performance measures that focus on prompt

processing can create a disincentive for front-line staff to report potential 

fraud because of the time it requires to develop a fraud referral. Four of the 

five DDS offices GAO visited count time that staff spend on documenting 

potential fraud and developing fraud referrals against their processing time. 

Some staff at these DDS offices said this creates a reluctance to report 

potential fraud. 

• The extent of anti-fraud training for staff varied among the five offices GAO

visited and was often limited. SSA requires all DDSs to provide training to 

newly hired staff that includes general information on how to identify potential 

fraud, but does not require additional training. The five DDS offices GAO

visited varied in whether staff received refresher training and its content—

such as how to spot suspicious medical evidence from physicians—and staff 

at all levels said they needed more training on these issues.

• SSA has not fully evaluated the risk associated with accepting medical 

evidence from physicians who are barred from participating in federal health 

programs. Although information from these physicians is not necessarily 

fraudulent, it could be associated with questionable disability determinations.

SSA has launched several initiatives to detect and prevent potential fraud, but 

their success is hampered by a lack of planning, data, and coordination. For 

instance, SSA is developing computer models that can draw from recent fraud 

cases to anticipate potentially fraudulent claims going forward. This effort has the 

potential to address vulnerabilities with existing fraud detection practices by, for 

example, helping to identify suspicious patterns of medical evidence. However,

SSA has not yet articulated a plan for implementation, assigned responsibility for 

this initiative within the agency, or identified how the agency will obtain key 

pieces of data to identify physicians who are currently not tracked in existing 

claims’ management systems. Furthermore, SSA is developing other initiatives, 

such as a centralized fraud prevention unit and analysis to detect patterns in 

disability appeals cases that could indicate fraud. However, these initiatives are

still in the early stages of development and it is not clear how they will be 

coordinated or work with existing detection activities.

View GAO-15-19. For more information, 

contact Daniel Bertoni at (202) 512-7215 or 

bertonid@gao.gov
Page i GAO-15-19 Potential Physician-Assisted Fraud

Letter 1

Background 4

Despite Anti-Fraud Policies and Procedures, SSA Remains 

Vulnerable to Potential Physician-Assisted Fraud 10

SSA Has Launched Several Initiatives to Better Detect Fraud 

but Faces a Number of Implementation Challenges 20

Conclusions 26

Recommendations for Executive Action 27

Agency Comments and Our Evaluation 28

Appendix I Objectives, Scope, and Methodology 30

Interviews and Site Visits 30

Analysis of Medical Provider Data 32

Identification of Key Practices for Implementing Fraud Analytics 

Systems 35

Appendix II Comments from the Social Security Administration 36

Appendix III GAO Contact and Staff Acknowledgments 40

Related GAO Products 41

Tables

Table 1: Overview of Disability Insurance and Supplemental 

Security Income Programs 5

Table 2: Sanctioned Physicians Who Submitted Medical 

Evidence, Calendar Years 2010- 2014 18

Table 3: Key Practices for Agencies to Consider When 

Implementing Fraud Analytics Systems 24

Table 4: Key Characteristics of GAO Site Visit Locations 31

Table 5: Data Sources Used in GAO’s Analysis 33

Contents
Page ii GAO-15-19 Potential Physician-Assisted Fraud

Figures

Figure 1: Social Security Administration’s Disability Determination 

Process 6

Figure 2: Social Security Administration’s Fraud Detection and 

Referral Process 9

Figure 3: Range of Fraud Allegations from State Disability 

Determination Services, 2013 15

Figure 4: Example of How Predictive Analytics Can Be Used to 

Detect Potential Fraud 21

Abbreviations

ALJ Administrative Law Judge

CDI Cooperative Disability Investigations 

DDS Disability Determination Services

DI Disability Insurance

HHS Department of Health and Human Services

LEIE List of Excluded Individuals and Entities

ODAR Office of Disability Adjudication and Review

OIG Office of the Inspector General

SSA Social Security Administration

SSI Supplemental Security Income

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-15-19 Potential Physician-Assisted Fraud

441 G St. N.W.

Washington, DC 20548

November 10, 2014

The Honorable Orrin Hatch

Ranking Member

Committee on Finance

United States Senate

The Honorable Sam Johnson

Chairman

Subcommittee on Social Security

Committee on Ways and Means 

House of Representatives

The Social Security Administration (SSA) provides cash benefits to 

millions of Americans with disabilities who are unable to work, with total 

payments estimated to exceed $200 billion in fiscal year 2015. To 

determine whether claimants qualify for disability compensation, federal 

law requires evidence of a medically determinable impairment, which 

SSA obtains from the claimant’s medical providers or by paying for its 

own medical evaluations. This medical evidence—and those who either 

provide or review it—has been the subject of intense scrutiny as some 

alleged fraud schemes have recently been uncovered.

These alleged schemes not only include physicians, but typically consist 

of other individuals who are knowledgeable about SSA’s disability 

programs and eligibility criteria.

1

 1 Several of the cases that allege physicians assisted claimants in fraudulently obtaining 

disability benefits are still under investigation, limiting our ability to report on the nature 

and outcome of these specific cases.

For example, in August 2013, 75 

individuals in Puerto Rico were arrested and indicted for Social Security 

fraud. It is alleged that a former SSA employee serving as a 

representative for the claimants colluded with several physicians to 

provide documentation of non-existent impairments in return for kickbacks 

from claimants who were granted benefits. While the full extent and 

nature of physician-assisted fraud is difficult to measure, each fraudulent 

claim allowed by SSA has the potential to cost the government several 

hundred thousand dollars over the life of the claimant and places an 

additional financial burden on these programs at a time when SSA 
Page 2 GAO-15-19 Potential Physician-Assisted Fraud

estimates that its disability trust fund will be depleted and unable to pay 

full benefits to individuals starting in 2016.

Given the potential harm that physician-assisted fraud can cause to 

SSA’s disability programs, you asked us to study this topic. In this report, 

we examine (1) how well SSA’s policies and procedures are designed 

and implemented to detect and prevent physician-assisted fraud,2

To address these objectives, we reviewed relevant federal laws and 

regulations and SSA program documentation including policies, 

procedures, training manuals, and performance plans, as well as reports 

and testimonies from SSA and SSA’s Office of the Inspector General 

(SSA OIG) on fraud detection and prevention efforts. We evaluated SSA’s 

efforts against its own policies and procedures, federal internal control 

standards, and other promising fraud detection and prevention practices 

that include data analytics. In our previous work, we identified promising 

fraud analytics practices,

and (2) 

the steps SSA is taking to improve its ability to prevent physician-assisted 

fraud.

3

 2 For the purposes of this report, we define physician-assisted fraud as any instance in 

which a physician colludes with a claimant or other interested parties to provide false 

medical evidence in support of a Social Security disability claim. This could include 

organized schemes where attorneys or third-party representatives funnel their clients to 

physicians with the intent of receiving false medical evidence in support of claims. We are 

not including instances where a claimant exaggerates an ailment to a physician in order to 

obtain a medical diagnosis. We define physicians as individuals such as doctors, 

psychologists, optometrists, podiatrists, speech language pathologists, chiropractors, 

physicians’ assistants, and other medical sources, or entities such as clinics or hospitals 

that submit accepted medical evidence in a claim for SSA’s Disability Insurance or 

Supplemental Security Income programs.

which we validated with disability insurance 

companies to ensure they were relevant to our review. We also 

interviewed SSA officials across headquarters’ components, SSA OIG 

officials, and national organizations that represent SSA managers and 

disability examiners. Additionally, we interviewed individuals from the 

private insurance industry and other organizations knowledgeable about 

fraud analytics and the disability determination process to identify key 

practices for fraud analytics and assessed whether SSA is incorporating 

these practices as it begins to develop its own analytics.

3 GAO, Medicare Fraud Prevention: CMS Has Implemented a Predictive Analytics 

System, but Needs to Define Measures to Determine Its Effectiveness. GAO-13-104 

(Washington, D.C.: Oct. 15, 2012).
Page 3 GAO-15-19 Potential Physician-Assisted Fraud

To gain additional perspectives on how SSA policies are implemented 

and any challenges to detecting physician-assisted fraud, we conducted 

site visits to 5 of the 54 Disability Determinations Services (DDS) offices 

in Alabama, California, Illinois, Maryland, and West Virginia. We selected 

these sites to obtain variation in regional office and DDS operations (e.g., 

case management systems, office structure, and case processing). Given 

the key role that SSA OIG Cooperative Disability Investigations (CDI) 

units4

Additionally, we conducted in-depth testing of data from two states to 

identify whether SSA is following its requirement not to allow certain 

sanctioned medical providers to conduct exams on behalf of the agency. 

We also sought to identify the extent to which sanctioned doctors may be 

providing medical evidence on behalf of claimants. We matched provider 

data from two of the states we visited—California and Illinois—with the 

Department of Health and Human Services OIG’s List of Excluded 

Individuals and Entities. This list identifies federally-sanctioned medical 

providers, and SSA regulations prohibit DDSs from using these providers 

to conduct exams on behalf of the agency. We selected California and 

Illinois because we were able to more readily obtain lists of vendors and 

because they use two different case management systems, allowing us to 

identify differences in what information is captured by DDSs. We obtained 

lists of providers as of February 2014 for California and April 2014 for 

Illinois and matched these against a list of providers who were sanctioned 

as of the end of January 2014. The results of our data matching are not 

generalizable to other states or to the wider population of disability claims. 

We conducted electronic testing and interviewed knowledgeable officials 

to assess the reliability of these data. We determined that they were 

play in identifying potential fraud, we selected offices in states with 

and without a CDI presence. During our site visits, we interviewed DDS 

management, medical relations professionals, disability examiners, and 

medical consultants. Additionally, we interviewed officials in the 

corresponding regional offices, including those who oversee initial and 

appeals determinations, as well as CDI unit staff. We conducted 

additional interviews with the Michigan DDS which has its own fraud unit 

and the NY regional office which oversees two DDSs—New York and 

Puerto Rico—where recent instances of fraud allegedly occurred.

 4 SSA OIG’s CDI units investigate disability claims that have been identified as suspicious

by state disability examiners. The program currently consists of 27 units covering 23 

states and the Commonwealth of Puerto Rico.
Page 4 GAO-15-19 Potential Physician-Assisted Fraud

sufficiently reliable for our purposes. See appendix I for a detailed 

description of our scope and methodology.

We conducted this performance audit from July 2013 to November 2014 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

SSA administers two main programs under the Social Security Act that 

provide benefits to individuals with disabilities—Disability Insurance (DI) 

and Supplemental Security Income (SSI). Individuals are generally 

considered disabled if they are unable to do their previous work, and 

considering age, education and work experience, engage in any other 

kind of substantial gainful work and their disability has lasted or is 

expected to last at least 1 year or is expected to result in death.

5 See 

table 1 for additional key features and requirements of the DI and SSI 

programs.

 5 42 U.S.C. §§ 423(d), 1382c(a).

Background

SSA’s Disability Programs
Page 5 GAO-15-19 Potential Physician-Assisted Fraud

Table 1: Overview of Disability Insurance and Supplemental Security Income Programs

Disability Insurance (DI) Supplemental Security Income (SSI)

Purpose Provides benefits to persons who become 

unable to work because of disability. 

Provides benefits for disabled, blind, or aged people 

who have low income and limited resources. 

Work requirement Requirement depends on age of claimant, 

but is generally 40 quarters of coverage.a No prior work requirement. 

Number of recipients (estimated 

fiscal year 2015)

11 million 8.5 million

Benefits paid (estimated fiscal 

year 2015)

$147 billionb $60 billionc

Medical Benefits DI beneficiaries qualify for Medicare health 

benefits after 2 years.

Most states automatically enroll SSI recipients in 

Medicaid, according to SSA.

Source: GAO analysis of relevant federal laws and SSA data. | GAO-15-19

a Generally, individuals need 40 work quarters (credits) to qualify, 20 of which must have been earned 

in the 10 years prior to becoming disabled. Individuals may earn up to four work credits per year, and 

the amount of earnings needed for a credit is calculated using the national average wage index. In 

2014, $1,200 is needed for each credit.

b This includes both persons with disability and their family members who receive benefits.

c This includes federal benefits and state supplementary payments per month.

SSA’s process for determining medical eligibility for disability benefits is 

complex and can involve several state and federal offices. The 

determination process—which is the same for both DI and SSI 

claimants—involves an initial determination at a DDS office. SSA funds 

the 54 DDSs, which are operated by state agencies, to process disability 

claims in accordance with SSA policies and procedures.6

 6 There are 54 DDSs located in 50 states, the District of Columbia, Guam, Puerto Rico, 

and the Virgin Islands.

If a claim is 

denied, claimants have several opportunities for appeal within SSA, 

starting with a reconsideration at the state level; then a hearing before an 

administrative law judge (ALJ); and finally at the Appeals Council, which 

is SSA’s final administrative appeals level. Claimants can generally 

submit new medical evidence throughout the disability determination 

process. Claimants must file any further action in federal court. Claims at 

all levels for which the claimant is determined to be eligible for DI or SSI, 

also called favorable claims, are forwarded to other SSA offices for 

payment. (See fig. 1.)
Page 6 GAO-15-19 Potential Physician-Assisted Fraud

Figure 1: Social Security Administration’s Disability Determination Process

a In 1999, SSA eliminated the reconsideration step in 10 states (Alabama, Alaska, Colorado, 

Louisiana, Michigan, Missouri, New Hampshire, New York, Pennsylvania, and in the Los Angeles

area of California) as part of the Prototype Initiative. In these states, claimants who wish to appeal 

their initial DDS determination must appeal for review before an ALJ.

b If parties are not satisfied with the Appeals Council decision, they may pursue the matter further in 

federal district court.

Generally, DDSs are required to develop a complete medical history for 

each claimant for at least a 12-month period prior to the application. SSA 

guidance directs DDSs to request medical evidence records from all 

providers who treated or evaluated the individual for the alleged or 

documented impairment during this time period. For example, a DDS may 

Development of Medical 

Evidence
Page 7 GAO-15-19 Potential Physician-Assisted Fraud

request laboratory reports; X-rays; doctor’s notes; and other information 

used in assessing the claimant’s health and functioning from many types 

of providers, including physicians or psychologists, hospitals, or 

community health centers. According to SSA, DDSs generally pay 

providers for these records in accordance with required state fee 

schedules.

In claims where the evidence gathered is insufficient to make a 

determination or where no evidence is present, the DDS may order its 

own tests or evaluations—called consultative examinations—from 

medical providers. SSA regulations specify the types of providers who 

can perform consultative exams and require DDSs to recruit, train, and 

oversee these providers in their states.7 State DDSs pay providers to 

conduct exams and set the rates of payments for these exams.8 SSA’s 

regulations prohibit DDSs from purchasing consultative exams from 

medical providers who are excluded, suspended, or otherwise barred 

from participation in the Medicare or Medicaid programs, or any other 

federal or federally-assisted program, which includes providers on the List 

of Excluded Individuals and Entities maintained by the Department of 

Health and Human Services (HHS) Office of Inspector General (OIG).

9

SSA regulations also prohibit the agency from purchasing exams from 

certain providers whose license to practice has been revoked by any 

state licensing authority. HHS is legally required to exclude from 

participating in federal health care programs individuals and entities 

convicted of certain criminal offenses, such as defrauding Medicare, 

Medicaid, or other federal or state health programs; patient abuse or 

neglect; and felony convictions related to controlled substances.10

 7 20 C.F.R. §§ 404.1513, 404.1519g, 404.1519s, 416.913, 416.919g, 416.919s.

This 

function is performed by the HHS OIG. The OIG also has discretion to 

exclude individuals and entities based on a number of other grounds—

8 Rates paid for consultative examinations may not exceed the highest rate paid by 

federal or other agencies in the state for the same or similar type services. 20 C.F.R. §§ 

404.1624, 416.1024. 

9 See 20 C.F.R. §§ 404.1503a, 416.903a. 

10 42 U.S.C. § 1320a-7(a).
Page 8 GAO-15-19 Potential Physician-Assisted Fraud

both related and unrelated to programmatic fraud.

11 SSA instructs DDSs 

to review the HHS list and verify medical licenses and credentials before 

using the services of any consultative exam provider. DDSs are also 

required to review the list for each existing exam provider at least 

annually. DDSs are not required to check the status of the claimant’s 

treating physician or other medical providers that submit evidence since 

they are obtaining existing medical records and not paying for medical 

services.

SSA has guidance on how examiners should document and report 

suspected fraud. According to SSA’s policy, fraud generally occurs when 

an individual makes or causes to be made false statements of material 

facts or conceals such facts for use in determining rights to benefits, with 

the intent to defraud. SSA employees should gather enough information 

to either remove suspicion or determine that there is potential fraud. They 

are also expected to develop the referral with as much information as 

possible, including who allegedly committed fraud, how, when, and why. If 

they determine that potential fraud exists, they should refer it to the SSA 

OIG. For states with a CDI unit, cases can be referred directly to the CDI. 

SSA and the OIG jointly established the CDI Program, in conjunction with 

DDSs and state or local law enforcement agencies, to effectively pool 

resources and expertise and prevent fraud in SSA’s disability programs. 

The Units investigate disability claims under DI and SSI programs that 

state disability examiners believe are suspicious.12

Referral processes can vary by DDS. For example, some DDSs may 

require management approval before referring a case to the SSA OIG. 

Once a case is referred to the SSA OIG, that office determines whether it

 11 Examples include misdemeanor convictions related to health care fraud; fraud in a 

program funded by any federal, state, or local government agency; suspension or 

revocation of medical license for reasons related to professional competence, professional 

performance, or financial integrity; defaulting on health education loans or scholarships; or 

engaging in unlawful kickback arrangements. 42 U.S.C. § 1320a-7(b).

12CDI units also receive fraud referrals from SSA’s Office of Disability Adjudication and 

Review, private citizens, anonymous sources, and other law enforcement agencies.

Fraud Identification and 

Referral Process
Page 9 GAO-15-19 Potential Physician-Assisted Fraud

will investigate the case.13

Figure 2: Social Security Administration’s Fraud Detection and Referral Process

Investigations often happen in coordination 

with other federal, state, and local agencies. See figure 2 for an overview 

of SSA’s fraud referral process.

a

OIG may work with local, state, and other federal entities to investigate fraud allegations.

 13 In fiscal year 2013, the OIG reported that it received 141,088 fraud referrals, with about 

75,656 coming from SSA employees across components (e.g., field offices, DDSs, 

appeals). The OIG does not report on the number of allegations received from each 

component. The number of referrals that included physicians is not completely known 

because the OIG’s data does not consistently capture the type of person suspected of 

fraud. 
Page 10 GAO-15-19 Potential Physician-Assisted Fraud

SSA’s program operations manual outlines high risk factors that 

employees, such as DDS and field office staff, should consider when 

reviewing cases, including several related to medical evidence. Such risk 

factors include identifying patterns of similar medical histories across 

claims, conflicting medical evidence, and anomalies such as claimants 

providing medical evidence from physicians in a different geographic area 

without the appearance of a logical reason for doing so.

SSA relies heavily on front-line staff in DDS offices—those who are 

responsible for reviewing medical evidence—to detect and prevent 

potential physician-assisted fraud.14

Although SSA relies on front-line staff as their first line of defense to 

detect potential fraud, it can be difficult for them to identify potential fraud 

in claims. Instead of systematically using data systems or analytics to 

The employees in the five DDS 

offices we visited, however, said that they are not well-positioned to 

identify signs of potential fraud, such as similar medical evidence across 

multiple claims. Further, the performance measures used by the agency 

and the DDSs may serve as a disincentive for front-line staff to spend 

additional time documenting and reporting fraud allegations, and limited 

training also reduces front-line staff’s ability to identify such fraud.

 14 Throughout this report, we use the term front-line staff to mean examiners and medical 

consultants who review medical evidence to make disability determinations at the DDS 

level. We recognize that field office and other SSA staff also play a critical role in 

identifying potential fraud. However, our report focuses primarily on the DDS role because 

DDS staff are responsible for reviewing medical evidence.

Despite Anti-Fraud 

Policies and 

Procedures, SSA 

Remains Vulnerable 

to Potential 

Physician-Assisted 

Fraud

Staff Reported Difficulty 

Identifying Potential Fraud 

and Lack Sufficient 

Incentives and Training

Identifying Patterns of Potential 

Fraud
Page 11 GAO-15-19 Potential Physician-Assisted Fraud

detect patterns of potential fraud, SSA’s guidance instructs front-line staff 

to identify suspicious patterns of medical evidence—such as boilerplate 

or similar language from the same physician across multiple claims—as 

well as other factors that may indicate potential fraud. However, SSA 

regional officials, DDS management, and front-line staff said that it is 

difficult to detect these patterns because staff may review claims 

originating anywhere in the state or across a large geographic area, 

leaving it in part to chance that staff would see evidence from a single 

physician on more than one claim. As a result, DDS staff stated that they 

must rely on coincidence—such as the receipt of consecutive claims with 

evidence from the same physician—to be able to identify a suspicious 

pattern. Additionally, single applications are generally seen by multiple 

staff in the course of development and determinations. DDS and SSA 

regional officials stated that, irrespective of how claims are distributed 

amongst staff, the volume of claims and associated medical evidence 

they review makes it difficult to detect patterns of potential fraud. Frontline staff are expected to review multiple claims every day, each of which 

may be supported by medical evidence from multiple physicians. One 

DDS director stated that the sheer number of physicians who submit 

medical evidence make it challenging to identify suspicious patterns from 

any one physician.

SSA and DDS performance measures incentivize processing claims 

quickly and may pose a barrier to front-line staff’s willingness to develop 

referrals and report potential fraud. SSA assesses DDS performance, in 

part, based on the length of time it takes to process claims.

15 In turn, all 

five DDSs we visited assess front-line staff on the speed by which they 

process claims. According to SSA, disability applicants file at vulnerable 

times in their lives and the agency and DDS offices focus on making 

timely and fully considered objective decisions on applications and 

develop performance measures in support of this objective. Our previous 

work has found that there are positive aspects of aligning individual 

performance expectations with organizational goals.16

 15 SSA regulations set performance standards for the DDSs based on their initial 

processing time and the performance accuracy of claims. 20 C.F.R. §§ 404.1641, 

416.1041.

We have also 

noted the importance of balancing quality and timeliness goals, with the 

16 GAO, Results-Oriented Cultures: Insights for U.S. Agencies from Other Countries’

Performance Management Initiatives, GAO-02-862 (Washington, D.C.: Aug. 2, 2002). 

Possible Disincentives to 

Identify and Report Potential 

Fraud
Page 12 GAO-15-19 Potential Physician-Assisted Fraud

potential for unintended perverse incentives.17

SSA’s focus on timeliness may also create a disincentive for front-line 

staff to report sources of questionable information in claims that they have 

denied. SSA guidance directs DDS staff to report all suspicious claims, 

even if the claim is denied.

When potential fraud is 

suspected, SSA policy states that staff should develop evidence to 

support their suspicions and prepare referral forms that explain the basis 

for their concern. During our site visits, some front-line staff stated that 

they do not report suspicious physicians or potential fraud because 

developing the evidence to report the allegation adversely affects their 

ability to process claims promptly. Only one DDS we visited lessened the 

potential disincentives to reporting suspected fraud by not counting the 

time spent developing allegations of fraud against the employees’ claims 

processing time. This DDS also provided recognition to staff when their 

fraud allegation resulted in conviction or a denial of benefits. Front-line 

staff we met with at this DDS stated that this recognition incentivized 

them to be more vigilant about identifying and reporting suspicious 

claims.

18

 17 For examples of how performance measures can potentially create perverse incentives, 

see GAO, Federal Transit Programs: Federal Transit Administration Has Opportunities to 

Improve Performance Accountability, 

However, staff in three of the five DDSs we 

visited said they may not always report potentially fraudulent information 

to the OIG if there is already sufficient evidence to make a denial because 

of the additional time required to process the fraud referral. One DDS 

director stated that denied claims are typically not reported to the OIG 

because an investigation would be redundant and wasteful considering 

that it would produce the same result—a denied claim. Nevertheless, 

there is merit in reporting these denied claims with suspicious evidence 

because they could either be appealed or the claimant could reapply at a 

later date and there may not be any indication to the subsequent reviewer 

that suspicious evidence exists. Moreover, without these referrals of 

GAO-11-54 (Washington, D.C.: Nov. 17, 2010) and 

GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing Season Performance 

Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002).

18 SSA guidance instructs front-line staff to refer all fraud or similar fault issues for 

investigation even when staff disregard the questionable evidence or make a 

determination based on other evidence. Staff should not initiate further development solely 

to resolve these potential issues, but should refer all questionable issues after the 

disability determination has been made. “Similar fault” is involved in situations in which an 

incorrect or incomplete statement material to the determination is knowingly made, or 

information that is material to the determination is knowingly concealed.
Page 13 GAO-15-19 Potential Physician-Assisted Fraud

suspicious claims, SSA is missing key information that could help them 

identify patterns of potential physician-assisted fraud.

DDS staff in some of the offices we visited also told us that they were 

reluctant to report potential fraud because of a perceived lack of 

communication from the OIG regarding the status or outcome of their 

fraud referrals. According to the OIG, the office communicates the status 

of investigations to DDS management approximately 1 month after the 

fraud referral is received. However, staff in four of the five DDSs we 

visited stated that the communication they receive from the OIG is

inadequate. For example, some staff reported that when cases were 

denied for investigation, the OIG did not sufficiently explain the reason for 

the denial. In some instances, staff never received a response about the 

status of their referral. Some front-line staff we spoke to said that they 

would report more cases of potential fraud if they received better 

feedback on the outcome of their referrals.

Staff from four of the five DDSs we visited stated that the anti-fraud 

training they received was infrequent, insufficient, and that additional 

training was needed. As part of their new employee training, front-line 

staff receive a short segment of anti-fraud instruction. This training 

defines fraud and provides an overview of SSA’s anti-fraud policies and 

procedures. However, subsequent anti-fraud training is not mandatory 

and varies by state. Federal internal control standards state that 

management needs to identify appropriate knowledge and skills needed 

for various jobs, such as identifying and preventing potential fraud, and 

provide appropriate training.

19

 19

SSA does not require DDS employees to 

receive training on fraud identification or reporting beyond their initial 

training courses and SSA officials stated that DDSs are primarily 

responsible for determining the training needs of their staff. We found that 

additional anti-fraud training at the five DDSs we visited often occurred 

infrequently or not at all. Without additional training, front-line staff may 

not have the skills and knowledge to identify and report potential fraud. 

For example, front-line staff at one DDS had not received any anti-fraud 

training since their initial basic training and stated that they did not know 

how to identify or report potential fraud. At another DDS, some staff 

indicated they had not received training in several years.

GAO/AIMD-00-21.3.1.

Lack of Training on How to 

Identify or Report Potential 

Fraud
Page 14 GAO-15-19 Potential Physician-Assisted Fraud

Data we reviewed suggests that DDSs in states with CDI units are likely 

to receive more training on how to identify and report potential fraud, 

contributing to more referrals from these DDSs. According to OIG data, 

28 of the 32 states and territories without a CDI unit did not refer any 

suspicious claims to the OIG in 2013 compared to an average of 216 

referrals from DDSs in states with a CDI unit, including the 

Commonwealth of Puerto Rico (see fig. 3 for CDI unit and fraud referral 

information).20 Front-line staff in the two states we visited with CDI units—

California and Illinois—also noted the benefits of additional anti-fraud 

training, including a better understanding of the fraud referral process. 

Further, Illinois officials said that the number of suspicious claims referred 

by staff increased after receiving training from the CDI unit. Nonetheless, 

DDS staff in both states said that training was not provided regularly and 

that they would like to receive additional training that includes examples 

of fraud investigations—such as cases in which medical providers and 

others may have colluded to help claimants obtain benefits—and 

strategies to prevent similar events from occurring in the future. OIG 

officials stated that they are reluctant to provide additional training to 

states without established CDI units because they do not have the 

resources to investigate the expected increase in fraud referrals from 

those states.21

 20 Our analysis is based on 2013 data, at which time there were 25 CDI units in 21 states 

and Puerto Rico.

21 According to SSA, the agency is working toward opening CDI units in six additional 

states and the District of Columbia, bringing the total number of units to 32. One of these 

new units was opened in August 2014 in Detroit, Michigan. A second unit opened in 

Baltimore, Maryland in September 2014. In addition, SSA is expanding the capacity of 

several of the existing 25 units by increasing the number of law enforcement investigators 

in the units. 
Page 15 GAO-15-19 Potential Physician-Assisted Fraud

Figure 3: Range of Fraud Allegations from State Disability Determination Services, 2013

Note: The figure represents fraud allegations reported to the Social Security Administration (SSA) 

Office of Inspector General from Disability Determination Services in calendar year 2013. Fraud 

allegations reported by other SSA components were not included in the data.

Potential vulnerabilities exist in how DDSs screen and use medical 

evidence from sanctioned physicians. SSA regulations prohibit DDSs 

from purchasing consultative exams from medical providers who are 

currently barred from participation in federal or federally-assisted 

programs.22

 22 See 20 C.F.R. §§ 404.1503a, 416.903a.

To comply with these regulations, SSA instructs DDSs to 

screen medical providers who conduct consultative exams against a list 

of sanctioned providers maintained by the Department of Health and 

SSA Policies and 

Procedures Allow Some 

Sanctioned Physicians to 

Provide Medical Evidence
Page 16 GAO-15-19 Potential Physician-Assisted Fraud

Human Services Office of Inspector General.23 Regarding medical 

records, federal law generally requires SSA to review all available 

evidence and make every reasonable effort to obtain medical evidence 

from the claimant’s treating physician and other treating health care 

providers.

24 However, under the Social Security Act, the agency is 

required to disregard any evidence reviewed when there is reason to 

believe that fraud or “similar fault” is involved with the determination.25

The agency is also required to exclude from participation in SSA 

programs, representatives and health care providers convicted of 

violations of specific criminal offenses related to SSA programs.26 Such 

offenses include making false statements related to DI or SSI 

applications. SSA regulations set forth factors for how medical evidence 

should be considered and weighted by DDS staff when making a 

disability determination.27

 23 The HHS OIG excludes individuals and entities from federal health care programs and 

maintains the list of excluded individuals and entities, also known as the sanctioned list. 

Physicians may be sanctioned for numerous reasons, including health care fraud or 

suspension of a medical license. In addition to reviewing the sanctioned list for physicians 

that conduct consultative exams, SSA policy requires DDSs to verify their medical 

providers’ current licensure and credentials with the State Medical Board. Throughout this 

report, we generally use the term “sanctioned” to refer to individuals on the HHS list, or 

individuals who are prohibited from providing services in the SSI or DI programs under 

SSA regulations.

DDSs that we visited do not, however, screen 

physicians who submit medical evidence on behalf of a claimant against 

the sanctioned list and therefore front-line staff do not know whether the 

medical evidence they are basing their disability determination on came 

from a sanctioned physician. While being on the sanctioned list does not 

mean that a physician submitted fraudulent evidence to SSA, it could be 

an indicator that the claim includes questionable evidence.

24 42 U.S.C. §§ 423(d)(5)(B), 1382c(a)(3)(H)(i).

25 42 U.S.C. §§ 405(u), 1383(e)(7). 

26 42 U.S.C. § 1320b-6. 

27 20 C.F.R. §§ 404.1527, 416.927. In particular, SSA will consider any factors brought to 

the agency’s attention, or of which the agency is aware, which tend to support or 

contradict the medical opinion. Some of the other factors that the agency will consider in 

evaluating medical opinion evidence include: (1) the examining relationship; (2) treatment 

relationship; (3) supportability of the opinion with medical signs and laboratory findings; (4) 

consistency of the medical opinion with the record as a whole; and (5) whether the source 

is a specialist.
Page 17 GAO-15-19 Potential Physician-Assisted Fraud

After matching vendor files from California and Illinois against the 

sanctioned list, we found that neither state purchased consultative exams 

from sanctioned physicians since 2010.28 In the same time period, 

however, at least 37 sanctioned physicians in these states provided 

medical evidence to the agency on behalf of claimants and 22 of these 

physicians provided such evidence after they had been sanctioned, 

potentially affecting the validity of those claims (see table 2).29 Our results 

demonstrate that, in some instances, SSA is accepting medical evidence 

from potentially questionable and unreliable physicians.30

 28 Vendor files are maintained by each DDS and lists the individuals or entities who were 

paid for conducting consultative examinations or providing medical evidence in support of 

disability claims.

We identified 

sanctioned physicians who were convicted of health care fraud or other 

program-related crimes who submitted medical evidence on behalf of 

claimants. For example, one physician, who was placed on the 

sanctioned list in 2011 for smuggling over $1 million in foreign 

misbranded and unapproved drugs into the United States and 

administering them to his patients, submitted evidence for at least 33 

disability claimants in the past 2 years. Such information could be useful 

to front-line workers in that they would be able to better determine 

whether more scrutiny of the medical evidence may be warranted, 

potentially resulting in a reduced risk of fraud. Further, front-line staff said 

it would be helpful to have a list of suspicious physicians available when 

reviewing claims. One DDS created such a list that includes physicians 

who DDS staff identified as providing suspect evidence—such as a 

pattern of exaggerated medical findings—in the past. However, frontline 

staff who we spoke with said they were unaware of this list.

29 There may have been sanctioned physicians who conducted consultative exams or 

submitted medical evidence to these DDSs on behalf of a claimant that we were not able 

to identify due to limitations of our analysis. We identified sanctioned physicians by their 

Social Security or tax employer identification number as recorded in the DDS vendor files. 

However, SSA and DDS staff told us that this personally identifiable information may not 

be captured in the vendor files if they work for clinics, hospitals, or other institutions. As a 

result, we may not have identified sanctioned physicians who work in these institutions, 

but DDS officials in California and Illinois stated that they match the names of all 

physicians who conduct consultative exams and work for institutions against the 

sanctioned list. 

30 As noted earlier, SSA is statutorily obligated to consider all available evidence 

regardless of the provider’s status, with some exceptions.
Page 18 GAO-15-19 Potential Physician-Assisted Fraud

Table 2: Sanctioned Physicians Who Submitted Medical Evidence, Calendar Years 

2010- 2014

State Disability 

Determination 

Services (DDS)a

Sanctioned physicians 

submitting medical 

evidence after being placed 

on the sanctioned list

Sanctioned physicians 

submitting medical 

evidence before being 

placed on the sanctioned 

listb

California 19 7

Illinois 3 8

Source: GAO analysis of state DDS vendor data and Department of Health and Human Services, Office of Inspector General’s 

sanctioned provider list. | GAO-15-19

Note: Total number of sanctioned physicians who submitted medical evidence could be an 

undercount. DDS vendor files may only collect information for the individual or entity they pay for the 

medical record – which may be a clinic, hospital or third-party company that manages medical 

records or payments on behalf of physicians – instead of the name of the individual physician who 

developed the medical record. In these instances, the vendor data would not allow us to determine if 

a sanctioned physician submitted the medical evidence used in a disability claim. Additionally, we did 

not attempt to determine whether identified physicians committed disability fraud.

a California data are for providers who submitted evidence as of August 2014 and Illinois data are for 

providers who submitted evidence as of June 2014.

b

These physicians were not sanctioned at the time they submitted medical evidence to SSA on behalf 

of a claimant.

SSA faces barriers to identifying and addressing the potential risks 

associated with medical evidence submitted by sanctioned physicians. 

According to SSA officials, the agency has explored whether it would be 

beneficial to consider physicians’ licensing status when making a 

disability determination. The agency identified several logistical barriers to 

checking licensure status for all physicians who submit medical evidence, 

and also cited complex policy implications that they believe could result in 

increased appeals and potentially disadvantage claimants, among other 

challenges. For example, SSA would have to determine when and what 

evidence from a physician to exclude and the type of sanctions to 

consider, among other things. The SSA OIG also reported in 2013 on 

hurdles regarding screening evidence against the sanctioned list.31

 31 Social Security Administration, Office of the Inspector General, Quick Response 

Evaluation Report, Sanctioned Medical Providers and Medical Evidence of Record, A-01-

13-23064 (Feb. 8, 2013).

According to SSA’s OIG, SSA and the DDSs request more than 15 million 

health records from over 500,000 physicians every year. Further, the SSA 

OIG also reported that because the sanctioned list generally contains the 

names of individual physicians, a sanctioned physician who provides 
Page 19 GAO-15-19 Potential Physician-Assisted Fraud

medical evidence on behalf of a claimant may not be detected by the 

DDS if they work for a hospital or clinic.32

Despite these barriers, as SSA moves forward on key information 

technology initiatives, the agency has an opportunity to assess several 

risk factors, including whether sanctioned physicians are providing 

medical evidence, and the likelihood that such evidence could be 

fraudulent. Federal internal control standards state that agencies should 

identify and analyze the relevant risks from external sources, such as 

potentially questionable evidence from sanctioned physicians.

We found similar limitations with 

the data that DDSs currently collect. For instance, SSA does not require 

DDSs to routinely and uniformly record the names and addresses of 

physicians who submit medical evidence on behalf of claimants. As a 

result, DDSs collect inconsistent and incomplete data on medical 

providers, which limits SSA’s ability to identify sanctioned physicians. For 

example, hospitals or similar institutions that employ hundreds of 

individuals may have only one source recorded in DDS vendor files.

33 SSA is in 

the process of transferring state vendor information from 54 distinct DDS 

data systems into a National Vendor File that will include information on

all medical providers whom the agency pays for medical evidence.34 Such 

a consolidation may present an opportunity for the agency to better 

assess the threat of sanctioned physicians submitting medical evidence 

on behalf of claimants and reduce the administrative cost of identifying 

such physicians on a DDS by DDS basis. Having national-level data 

could help SSA better determine risk factors for potential fraud as well as 

what medical evidence should be subject to additional scrutiny. 

Additionally, consolidating vendor data gives the agency an opportunity to 

gain a better understanding of the inconsistencies in the information 

collected at the DDS level and determine whether it should implement 

more uniform data collection and policy requirements.

 32 Social Security Administration, Office of the Inspector General, Quick Response 

Evaluation Report, Sanctioned Medical Providers and Medical Evidence of Record, A-01-

13-23064 (Feb. 8, 2013).

33 GAO/AIMD-00-21.3.1.

34 The National Vendor File is a data warehouse that stores medical and non-medical 

information from DDSs. As of July 2014, the file included data from 20 DDSs. 
Page 20 GAO-15-19 Potential Physician-Assisted Fraud

Recognizing that it must do more to systematically detect potential fraud, 

SSA is in the early stages of exploring the use of computerized tools to 

enhance its efforts. Known as predictive analytics, these are automated 

systems and tools that can help identify patterns of potentially fraudulent 

claims—such as patterns of suspicious behavior involving physicians and 

claimants—before claims are paid. A system such as this would give SSA 

the ability to systematically check large numbers of claims for potential 

fraud in addition to using front-line staff to spot suspicious patterns in 

claims. Staff from SSA’s Office of Information Security began this 

analytics effort in February 2014 and piloted these capabilities in two 

stages. In the first stage, SSA developed its initial computer model and 

identified existing sources of data within the agency. SSA tested and 

refined its model by using recent cases of alleged fraud in Puerto Rico, 

New York, and West Virginia to determine whether it would have detected 

characteristics of potential fraud in those cases. SSA reported that it 

completed this stage in May 2014 and that its efforts were successful. In 

the second stage, SSA will explore purchasing a tool from a vendor and 

using analytics to spot suspicious claims in other locations. SSA will also 

explore purchasing data—such as arrest records—from an external 

vendor to integrate into its system that could help SSA to identify links 

between disability claims, physicians, and attorney representatives 

through social network analysis35

 35 Social network analysis involves the use of public records and other data to 

demonstrate social linkages between individuals and entities to draw connections between 

parties potentially involved in fraud schemes.

that may not be apparent from existing 

SSA data. For example, SSA staff said these data could identify 

individuals who are seemingly unconnected but who shared an address in 

the past. External data also proved to be helpful in the recent case of 

suspected fraud in New York, where investigators made use of local 

SSA Has Launched 

Several Initiatives to 

Better Detect Fraud 

but Faces a Number 

of Implementation 

Challenges

SSA Is Developing a 

Fraud Analytics Model, but 

Lacks an Implementation 

Plan
Page 21 GAO-15-19 Potential Physician-Assisted Fraud

government data to determine that beneficiaries made false statements 

when applying for benefits. SSA told us that while it completed its second 

phase of testing, which consisted of a preliminary risk-scoring model for 

disability claims, significant work remains to be done before it has a 

working analytics system in place. See figure 4 for an illustration of how a 

predictive model would differ from SSA’s current approach.

Figure 4: Example of How Predictive Analytics Can Be Used to Detect Potential 

Fraud

SSA’s analytics efforts have potential, but we have concerns regarding 

the agency’s ability and capacity to implement such a system on a large 

scale going forward. For example, SSA does not consistently collect 

some data that may aid in its analytics effort. As part of its analytics 

efforts, SSA plans to look for relationships between physicians who 

provide medical evidence and potentially fraudulent claims. However, as 

we noted earlier, SSA and DDS officials told us that existing data systems 

often do not identify individual physicians. Instead, the systems may 

capture the hospital or clinic that provided medical records, or in some 

cases, a third-party company that manages medical records or payments 

on behalf of physicians. An SSA official working on analysis efforts noted 

that SSA currently lacks the ability to distinguish between individual 

physicians and clinics or hospitals. Without the ability to consistently 

identify individual physicians, SSA’s ability to detect potential physicianassisted fraud may be hampered. SSA must also contend with obtaining 

physician data from a number of case management systems. For 

Alleged New York City Disability Fraud 

Scheme

In early 2014, 130 disability beneficiaries and 

four middlemen were indicted for allegedly 

defrauding Social Security. The beneficiaries, 

many of whom were former firefighters and 

police officers, were supposedly coached by 

these middlemen on how to fail mental health 

exams, and many of the disability applications 

had nearly identical descriptions of mental 

ailments. In return for their assistance, the 

middlemen are reported to have received 

payments of up to $45,000 for helping to 

obtain unwarranted benefits. This 

investigation continues, but the OIG reports 

that the amount of benefits received by the 

beneficiaries named in the indictments is 

almost $30 million.

Source: GAO review of publically available OIG documents.
Page 22 GAO-15-19 Potential Physician-Assisted Fraud

example, the agency is in the process of transitioning DDSs from five 

different legacy case management systems to a unified Disability Case 

Processing System that will be used by all DDSs.36 SSA officials stated 

that the National Vendor File that will be linked to this system has the 

ability to capture individual physician license numbers. This vendor file 

currently only collects the same information as the DDS’s existing legacy 

systems, which may or may not include this information because SSA 

does not require DDSs to collect unique identifiers for physicians. Further, 

while SSA is also pursuing external data sources to perform social 

network analysis, its ability to fully make use of this information could be 

limited by its inability to readily identify the physicians involved in disability 

claims.

Moreover, SSA has yet to detail how it will first operationalize any 

analytics efforts into its ongoing business practices and then investigate 

potential leads generated. Officials we spoke with at the Centers for 

Medicare & Medicaid Services (CMS)—who implemented their own fraud 

analytics program in 2011—and several private disability insurers told us 

that analytics are helpful for determining which claims are at risk for 

potential fraud and where to focus investigative resources. However, they 

noted that organizations cannot rely on analytics alone to determine 

whether fraud is occurring and that considerable staff resources are often 

needed to develop leads that result from the initial analysis. For instance, 

officials at one private disability insurer said that analysts may spend half 

a day examining a claim before deciding whether additional investigation 

is warranted. This sentiment was shared by participants at a 2013 GAO 

forum on data analytics who noted that having knowledgeable staff was 

critical for interpreting the results of analytics and identifying investigative 

leads.37

 36 The development of this system has been delayed and may not be operational as 

planned in fiscal year 2016.

However, we and the SSA OIG have previously reported on 

challenges facing SSA, including declining staff levels at DDSs and 

37 GAO, Highlights of a Forum: Data Analytics For Oversight and Law Enforcement. 

GAO-13-680SP (Washington, D.C.: July 15, 2013).

Alleged Puerto Rico Disability Fraud 

Scheme

In August 2013, 75 individuals in Puerto Rico 

were indicted for disability fraud. This included 

a claimant representative (and former Social 

Security employee), three physicians, and 71 

claimants. The representative allegedly 

conspired with three doctors to fabricate and 

submit false medical evidence to support 

unwarranted disability claims for his clients. 

According to the Department of Justice (DOJ), 

these physicians received kickbacks of 

between $150 and $500 to submit false 

medical evidence to SSA, and the 

representative received a lump-sum payment. 

Although the investigation continues, 34 of the 

75 individuals charged have pled guilty as of 

March 2014.

Source: GAO review of publically available OIG and DOJ 

reports.
Page 23 GAO-15-19 Potential Physician-Assisted Fraud

difficulty in meeting SSA performance goals.38 We also recommended 

that SSA develop a long-term plan to address service delivery challenges, 

including those related to human capital and information technology 

initiatives.39

Additionally, without more details on its plans, it is unclear whether SSA 

can adhere to key practices that organizations must use to successfully 

implement fraud analytics. We identified these practices in past work and 

by interviewing other organizations that have implemented analytics (see 

table 3).

The agency has noted the benefit of using data analytics to 

prevent fraud and has mentioned data analytics in its Strategic Plan, 2015 

budget request, and Information Resource Management Strategic Plan. 

However, these agency documents do not provide concrete steps or 

identify the needed resources to make this undertaking successful. 

Additionally, staff working on the analytics pilot told us that SSA has yet to 

determine which component of SSA will ultimately have responsibility for 

following up on leads. One analytics firm cautioned that analytics cannot 

just be a software tool, but must fit into a larger cultural change regarding 

fraud and how business is conducted. It added that an organization that 

jumps into analytics without a clear plan and goals risks failure.

40 In its early efforts, SSA has so far followed some key practices. 

For example, SSA has publicized its efforts, including announcing its 

plans during a congressional hearing. SSA has also consulted with other 

organizations, such as CMS, which already have analytics in place. 

Agency officials identified other steps they have taken that align with 

these key practices, but when we requested additional details on how it 

will carry out these efforts, SSA did not yet have any concrete plans.

 38 For example, GAO, Social Security Administration: Long-term Strategy Needed to 

Address Key Management Challenges. GAO-13-459 (Washington, D.C.: May 29, 2013); 

SSA OIG, Fiscal Year 2013 Inspector General Statement on the Social Security 

Administration’s Major Management and Performance Challenges. A-02-14-14056 

(Baltimore, MD: Dec. 6, 2013).

39 GAO-13-459.

40 GAO-13-104.

Alleged West Virginia Disability Fraud 

Scheme

SSA is investigating claims stemming from 

West Virginia. According to a staff report from 

the Senate Committee on Homeland Security 

and Government Affairs, an attorney 

conspired with an SSA administrative law 

judge (ALJ) to allow disability benefits for 

undeserving claimants. As part of this alleged 

scheme, the ALJ’s office would schedule 

exams with doctors favored by the attorney. 

The attorney is said to have provided pre-filled 

medical forms to these doctors, which often 

contained similar language. The ALJ was 

placed on administrative leave and later 

retired, and the attorney continues to practice 

disability law.

Source: GAO review of SSA testimony and staff report from 

the Senate Committee on Homeland Security and 

Governmental Affairs.
Page 24 GAO-15-19 Potential Physician-Assisted Fraud

Table 3: Key Practices for Agencies to Consider When Implementing Fraud 

Analytics Systems

Key practice Description

Utilizing a variety of data 

sources

Using a number of sources for analytics, such as criminal, 

death, and corporate records, can improve results. 

Social network analysis This is emerging as an important tool to combat organized 

fraud since it can be used to demonstrate linkages among 

individuals involved in fraud schemes.a

Close and continuing 

collaboration

Feedback from the end users of analytics systems (such as 

investigators) can improve analysis, help refine predictive 

models, and limit false positives.

Collaboration with external 

stakeholders

Working with outside organizations, including other insurers 

and government health programs, can aid in the detection of 

fraudulent providers and leverage resources.

Publicizing the use of 

predictive analytics

Advertising analytic technologies may deter providers from 

committing fraud.

Mining text data Using systems to search through the text in claims and 

related medical reports to detect instances of suspicious 

language or unwarranted similarities between claims.

Source: GAO analysis of our prior work on key practices to detect and prevent fraud. | GAO-15-19

a

Social network analysis may or may not include the use of information from social media 

sites. Any use of such sites, including the use of information obtained from such sites,

must be consistent with applicable federal laws and regulations. 

In addition to predictive analytics, other SSA components are 

implementing several efforts that may have the potential to detect and 

prevent potential physician-assisted fraud.

SSA OIG Disability Fraud Pilot: The SSA OIG is piloting an effort to 

augment its CDI units and target organized fraud schemes, such as 

those that allegedly occurred in New York and Puerto Rico. OIG 

officials told us that this effort will differ from existing CDI efforts, 

which generally investigate potential fraud before SSA makes a 

disability determination and are focused on claimants. The fraud pilot 

will instead focus on third-party facilitators—including physicians and 

attorneys—and their involvement in systematic efforts to defraud 

SSA’s disability programs. OIG officials noted that the pilot 

incorporates new performance measures that allow for prolonged 

investigations as opposed to the quicker investigations normally 

conducted by CDI units. The OIG began the pilot in the summer of 

2013 in four locations and will consider expanding the effort in fiscal 

year 2015 after evaluating the success of the pilot and the effect it has 

had on SSA disability programs.

The Effectiveness of 

Recent Fraud Detection 

Initiatives Could Be 

Hindered by SSA’s 

Management Approach
Page 25 GAO-15-19 Potential Physician-Assisted Fraud

• Disability Fraud Prevention Units: SSA established a centralized 

fraud prevention unit based in New York City to identify instances of 

potential fraud and look for trends nationwide. Initially, this unit will 

utilize 20 disability examiners with experience in investigating claims 

associated with the New York City and Puerto Rico fraud cases. SSA 

recently established additional units in Kansas City and San 

Francisco. SSA expects that these units will provide ongoing 

investigative support to the OIG as well as analytical and 

programmatic support to federal and local prosecutors pursuing cases 

of potential fraud.

• Office of Disability Adjudication Review (ODAR) data analysis 

efforts: ODAR—which is responsible for overseeing the claims 

appeals process—has an ongoing effort analyzing data from claims 

decided at the appeals level. ODAR officials told us that this effort was 

intended to provide better oversight of administrative law judges, as 

well as to identify errors in decisions to be better able to target training 

resources. ODAR is also using these data to look for irregularities—

such as repeated instances of similar language from a physician—and 

identify potential fraud, referring those cases to the OIG. Additionally, 

ODAR is working with the OIG disability fraud pilot to provide data in 

support of their efforts.

Although SSA officials indicated that several of these efforts will be under 

the purview of the recently reinstituted National Anti-Fraud Committee,41

the agency lacks detailed plans describing how these various efforts will 

be implemented or how they will relate to each other. In prior work, we 

have reported that clearly delineating activities and timelines, and defining 

problems and goals, are key elements of sound planning. Specifically, 

agencies should identify activities needed to complete projects and be 

able to describe how these activities are related to each other.42

 41 According to SSA, the committee is co-chaired by the Deputy Commissioner for 

Budget, Finance, Quality, and Management, and the Inspector General. The committee 

will serve as a forum for senior executives to collaborate on anti-fraud efforts across the 

agency. The committee was originally formed in 1996, but met on an ad-hoc basis after 

2003. It was reinstated in January 2014 and held its first meeting in March 2014.

However, 

SSA has yet to articulate how these efforts will relate to each other. For 

example, while the fraud analytics pilot, the OIG disability fraud pilot, the 

disability fraud prevention units, and ODAR’s efforts all involve some 

42 GAO, VA Disability Compensation: Actions Needed to Address Hurdles Facing 

Program Modernization, GAO-12-846 (Washington, D.C.: Sept. 10, 2012).
Page 26 GAO-15-19 Potential Physician-Assisted Fraud

analysis of disability claims data, SSA’s plans do not address how these 

efforts will support each other or how it will avoid duplication across 

efforts. Additionally, SSA was unable to provide us with detailed 

information regarding the development of these initiatives or describe how 

they differed from each other.

Competing priorities may compromise SSA’s ability to follow through on 

plans to enhance fraud detection and maintain this focus. As stated 

earlier, SSA has not sufficiently balanced the need to quickly process 

claims and pay benefits with the need to ensure program integrity. 

Moreover, SSA officials told us that the role of the agency and DDSs is to 

help claimants navigate a complex application process and that searching 

out fraud—while a concern—does not align with SSA’s core mission. In 

addition, employees at two of the DDSs we visited told us that SSA only 

began to emphasize the need to look for potential fraud after the 

announcement of alleged schemes; and they were concerned about the 

agency’s ability to maintain a sustained focus in this area. One DDS 

director added that SSA needs to build fraud detection into its regular 

business operations in order to sustain it. The director added that SSA 

currently budgets only enough resources to its DDSs to maintain their 

current business practices.

While the full extent and nature of physician-assisted fraud is difficult to 

measure, any occurrence has the potential to undermine confidence in 

SSA’s ability to award benefits only to deserving individuals. The agency 

relies on front-line workers, including those who collect and assess 

claimants’ medical records at DDS offices, to be the first line of defense 

against potential fraud. They are also expected to make timely and 

accurate disability determinations. In some instances, the agency’s focus 

on making determinations quickly has been a disincentive to reporting 

suspicious physicians or potential fraud. Unless SSA and the DDSs work 

to remedy performance measures that primarily focus on and reward 

timeliness, possibly at the expense of delving into potentially problematic 

claims, the agency will remain vulnerable to potential fraud. Further, 

absent enhanced and consistent training, front-line staff may lack the 

expertise to identify and report potential fraud.

SSA has some controls in place to help ensure that sanctioned 

physicians do not perform exams on behalf of the agency. However, the 

agency could be exposing itself to risk by using medical evidence from 

physicians who are sanctioned by either federal or state governments. 

While there are numerous reasons a physician can be sanctioned, 

without knowing whether such physicians have provided medical 

Conclusions
Page 27 GAO-15-19 Potential Physician-Assisted Fraud

evidence and why they were sanctioned, SSA could be missing 

information needed to identify and flag for additional scrutiny potentially 

falsified medical evidence.

Lastly, as the agency begins to shift its focus to better detection and 

prevention of potential fraud through analytics, it will be important to 

balance these new efforts with the existing workload demands on frontline staff. Furthermore, even though substantial resources and 

collaboration will be needed to fully implement a successful analytics 

system and follow up on resulting leads, SSA has not systematically 

identified the data and actions needed to implement and make them 

successful. Given the lack of details that the agency was able to provide 

on its plans, we have concerns about their potential success. Absent a 

coordinated and cohesive effort, SSA could undermine the success of its 

new initiatives and remain vulnerable to physician-assisted fraud in the 

future.

We recommend that the Commissioner of the Social Security 

Administration take the following actions to improve the ability of the 

agency to detect and prevent potential physician-assisted fraud:

1. To address potential disincentives for staff to detect and prevent 

physician-assisted fraud, SSA should review the standards used to 

assess DDS performance; and develop and distribute promising 

practices to incentivize staff to better balance the goal of processing

claims promptly with the equally important goal of identifying and 

reporting evidence of potential fraud.

2. To ensure that the agency captures complete information on 

suspicious claims, SSA should issue guidance to remind DDSs of its 

existing policy to report all claims with potentially fraudulent medical 

evidence to the SSA OIG, even if sufficient evidence exists to deny a 

claim.

3. To help front-line staff identify potentially fraudulent activity, SSA 

should enhance its training efforts by ensuring it provides fraudrelated refresher training to all DDS employees on a regular basis. 

Such training should include the identification of suspicious medical 

evidence and providers, as well as the processes and procedures for 

reporting such information. To facilitate its efforts, the agency could 

coordinate with the SSA OIG and draw on the type of training 

provided by CDI units.

4. To address the potential risks associated with medical evidence 

submitted by sanctioned physicians, SSA should evaluate the threat 

Recommendations for 

Executive Action
Page 28 GAO-15-19 Potential Physician-Assisted Fraud

posed by this information and, if warranted, consider changes to its 

policies and procedures.

5. To help ensure new initiatives that use analytics to identify potential 

fraud schemes are successful, SSA should develop an 

implementation plan that identifies both short- and long-term actions, 

including:

• timeframes for implementation;

• resources and staffing needs;

• data requirements, e.g., the collection of unique medical provider 

information;

• how technology improvement will be integrated into existing 

technology improvements such as the Disability Case Processing 

System and National Vendor File; and

• how different initiatives will interact and support each other.

We provided a draft of this product to the Social Security Administration 

for comment. In its written comments, reproduced in appendix II, SSA

agreed with 4 of our 5 recommendations and partially agreed with one of 

them. SSA partially agreed with our recommendation to review its 

standards used to assess DDS performance; and develop and distribute 

promising practices to incentivize staff to better balance the goal of

processing claims promptly with the equally important goal of identifying 

and reporting evidence of potential fraud. SSA did not specify why it did 

not agree fully, but did outline the critical role that field and DDS office 

staff play in identifying and detecting potential fraud. In our report, we 

acknowledge that these employees are the first line of defense against

fraud. We also noted that based on our interviews, and review of agency 

and DDS performance standards, that there is a potential disincentive to 

report suspicious claims. If properly designed and managed, performance 

standards that include identifying and reporting suspicious claims could 

provide incentives to encourage staff to devote more time to program 

integrity issues while maintaining their ability to process claims in a timely 

manner. Such standards would also further demonstrate to DDS staff 

SSA management’s commitment to preventing potential physicianassisted fraud in its disability programs. 

SSA agreed with the remainder of our recommendations and provided 

additional information about the actions it has taken in the past year to 

enhance its fraud detection and prevention efforts and steps they will take 

going forward.

Agency Comments 

and Our Evaluation
Page 29 GAO-15-19 Potential Physician-Assisted Fraud

SSA also provided technical comments on our report, which we 

incorporated as appropriate. In these comments, the agency noted that

our report implies that fraud schemes are more commonplace than they 

actually are. Our report states that the full extent and nature of physicianassisted fraud is difficult to measure and that even one instance of this 

type of fraud could result in a large number of beneficiaries improperly 

receiving benefits, as well as substantial costs to the government. SSA 

also commented that our report overemphasized the potential utility of the 

List of Excluded Individuals and Entities for identifying potential physicianassisted fraud. In our report, we noted key limitations and challenges to 

using this list. Nonetheless, we maintain that some physicians—an 

important component of the disability determination process—have been 

at least suspected of fraudulent activities by others and this is important 

information for SSA to consider. We believe SSA can improve staffs’ 

ability to identify cases that deserve closer scrutiny by more fully 

assessing the potential threat posed by sanctioned physicians. Such an 

assessment would also help the agency identify actions that DDS offices 

could take to better track and screen for evidence from these providers. In 

the long-term it could also assist with the agency’s new fraud analytics 

efforts.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the Commissioner of 

Social Security and other interested parties. In addition, the report will be 

available at no charge on the GAO website at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-7215 or bertonid@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix III.

Daniel Bertoni

Director, Education, Workforce,

and Income Security
Appendix I: Objectives, Scope, and 

Methodology

Page 30 GAO-15-19 Potential Physician-Assisted Fraud

In conducting our review of potential physician-assisted fraud in the 

Social Security Administration’s (SSA) disability programs, our objectives 

were to examine (1) SSA’s policies and procedures for detecting and 

deterring physician assisted fraud, and (2) the steps SSA is taking to 

improve its ability to detect physician-assisted fraud. We reviewed 

relevant federal laws and regulations, as well as SSA program 

documentation including policies, procedures, training manuals, and 

performance plans, as well as reports and testimonies from SSA and the 

Office of the Inspector General (OIG) on fraud detection and prevention 

efforts. We evaluated SSA’s efforts against its own policies and 

procedures, federal internal control standards, and other key fraud 

analytics practices to detect and prevent potential fraud. We also 

interviewed key officials in SSA and conducted site visits to five states 

where we interviewed Disability Determination Services (DDS) and SSA 

regional office staff. Additionally, we interviewed organizations that 

represent DDS management and front-line SSA employees, in addition to 

meeting with private disability insurers and other organizations involved in 

preventing fraud. We compared the medical provider vendor lists in two 

states to a list of federally sanctioned doctors.

To understand SSA’s policies and efforts to improve fraud detection, we 

interviewed officials in a number of SSA components. These included:

• The Office of the Deputy Commissioner, Operations, which is 

responsible for overseeing the initial disability determination process 

and state DDS offices;

• The Office of Disability Adjudication and Review (ODAR), which is 

responsible for overseeing the disability appeals process;

• The Office of the Chief Strategic Officer;

• The Office of Information Security; and

• The Office of the Inspector General (OIG).

To gain additional perspectives on how SSA policies are implemented 

and challenges regarding detecting physician-assisted fraud, we 

conducted site visits to a non-generalizable sample of five states. We 

chose these states in order to provide diversity in terms of their 

geographic location, whether the state had a single or multiple DDS 

locations, the presence of an OIG Cooperative Disability Investigations 

(CDI) unit, and the data system used by a state. During our site visits, we 

interviewed DDS management, medical relations professionals, disability 

examiners and supervisors, and medical consultants. When possible, we 

Appendix I: Objectives, Scope, and 

Methodology

Interviews and Site 

Visits
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-15-19 Potential Physician-Assisted Fraud

randomly selected examiners and consultants, who worked with the DDS 

for at least 1 year, to interview based on rosters provided by DDS 

management. In three of the states, we met with examiners individually. 

In the other two states, we met with examiners in a group setting because 

of challenges with scheduling individual interviews. In addition to 

providing information on SSA’s policies and procedures, DDS officials 

and staff provided insights on SSA’s newer fraud detection initiatives. 

Additionally, we spoke with regional SSA officials in each of the regions 

that correspond with our site selection. We also spoke with OIG CDI staff 

in each location where they were present. The information we obtained at 

our site visits is illustrative and not intended to reflect the experiences of 

DDSs in other states. See table 4 for key characteristics of our site visit 

locations.

Table 4: Key Characteristics of GAO Site Visit Locations

DDS SSA regional office CDI unit DDS structureb

Alabama Atlanta, GA Noa Decentralized

California San Francisco, CA Yes Decentralized

Illinois Chicago, IL Yes Centralized

Maryland Philadelphia, PA Noa Centralized

West Virginia Philadelphia, PA Noa Decentralized

Source: GAO review of SSA and OIG information. | GAO-15-19

a

SSA plans to start-up a CDI unit in this state.

b

Decentralized DDS structures are those that process claims through more than one office in a state.

We also interviewed officials from SSA’s New York regional office to 

better understand how recent alleged fraud cases in New York and 

Puerto Rico—both within that SSA region—were uncovered, as well as 

changes made in response to these incidents. In addition, we interviewed 

officials at the Michigan DDS because it has a dedicated fraud unit.

To supplement our site visits, we interviewed national organizations that 

represent DDS examiners, managers, and Administrative Law Judges, 

including:

• Association of Administrative Law Judges

• National Council of Social Security Management Associations

• National Association of Disability Examiners

• National Council of Disability Determination Directors
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-15-19 Potential Physician-Assisted Fraud

To provide additional context, we interviewed a number of other federal 

agencies, private insurers, and other organizations that are familiar with 

the disability determination process, detecting fraud, or with implementing 

predictive analytics. These organizations included:

• American Academy of Disability Evaluating Physicians (a professional 

organization serving physicians involved in disability management and 

evaluations)

• Coalition Against Insurance Fraud (an anti-fraud alliance that includes 

public and private insurers)

• Centers for Medicare and Medicaid Services

• Department of Health and Human Services, Office of Inspector 

General

• Elder Research Inc. (a consulting company focused on predictive 

analytics and data mining)

• The Recovery Accountability and Transparency Board

• Unum (a private insurer that uses predictive analytics to identify 

potential fraud)

We conducted data matching using information from California and Illinois 

to help determine the extent to which sanctioned medical providers 

submitted evidence in disability decisions. We attempted to find providers 

who appeared in both of these two data sources:

1. The List of Excluded Individuals and Entities (LEIE): The list is 

maintained by the Department of Health and Human Services OIG, 

and lists individuals who are excluded from federal health care 

programs for a number of reasons, including health care fraud.

2. State Vendor Files: Vendor files are maintained by each DDS and list 

medical providers who were reimbursed for providing medical 

evidence in support of disability claims. These vendors include 

claimants’ treating physicians who are reimbursed for providing copies 

of medical records, and consultative exam providers, who conduct 

medical exams for the DDS under contract, among others.

Analysis of Medical 

Provider Data
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-15-19 Potential Physician-Assisted Fraud

Table 5: Data Sources Used in GAO’s Analysis

Data sources used Entity responsible Population covered Timeframe of data analyzed

List of Excluded 

Individuals and Entities

HHS OIG Federally sanctioned medical providers As of the end of January 2014

California Vendor File CA DDS All individuals or entities paid for medical records 

by the CA DDS 

As of February 2014

Illinois Vendor File IL DDS All individuals or entities paid for medical records 

by the IL DDS

As of April 2014

Source: GAO review of relevant data systems. | GAO-15-19

We conducted matching between each state vendor file and the LEIE on 

the basis of tax identification numbers—Social Security Numbers or 

Employee Identification Numbers. In instances when we found a match 

between both sources, we gave the DDSs (through SSA) summary 

information on the providers and obtained information on when they last 

submitted evidence or conducted exams in support of claims. The Illinois 

DDS provided us with additional information on our matches in June 2014 

and the California DDS in August 2014. Providers can be sanctioned for a 

number of reasons not related to health care fraud; therefore, the results 

of our matching do not indicate that fraud occurred in either federal health 

care or disability programs. Additionally, the results of our data matching 

are not generalizable to other states or to the wider population of disability 

claims.

There were several limitations in both the state vendor files and the HHS 

LEIE that could have affected the results of our matching, including:

• DDS vendor data did not include all physicians who submitted medical 

evidence on behalf of claimants or individual physicians who 

performed consultative examinations on behalf of SSA. Since these 

files are used for payment purposes, DDSs only maintain tax 

identification numbers for vendors (e.g., physicians, clinics, or thirdparties managing records on behalf of physicians) who they pay for 

records or services; not necessarily the individual physicians who see 

claimants.

• According to the HHS OIG, the LEIE may not reflect all sanctioned 

medical providers, given limitations on OIG’s authorities, appeals of 

exclusions, and occasional delays in referrals to the OIG. The SSA 

OIG also noted that sanctioned physicians may move on and off the 

list depending on the outcome of appeals and reinstatements. 

Therefore, a doctor providing medical evidence to SSA on behalf of a 
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-15-19 Potential Physician-Assisted Fraud

disability claimant may be on the exclusions list one quarter and off 

the next.

As a result of these limitations, any results in matching are likely to be a 

lower bound.

We conducted data reliability assessments on both states’ vendor data 

and found these data sets to be sufficiently reliable for our analysis. We 

restricted these assessments to the specific variables and records that 

were pertinent to our analyses. We conducted interviews with SSA staff 

familiar with the data and requested additional information from the 

DDSs. We also assessed the completeness of the data, including 

frequency analysis of relevant fields, testing for population of variables, 

out of range values, and duplicate records. In both states, the data’s 

unique identifiers that we used for matching were not populated for all 

records. We followed up with SSA and the DDSs to gain an 

understanding of why some fields were not populated. Because the 

vendor files are used for payment purposes, the DDSs only collect tax 

identification numbers for entities they pay for medical records or 

consultative examinations. We restricted our matching to vendor data that 

we determined had a legitimate tax identification number and eliminated 

duplicates in the data. We then asked the DDSs to verify the last date of 

payment for providers whom we matched to assess whether they were 

receiving payment while they were sanctioned.

We conducted similar data reliability steps for the HHS LEIE, including 

electronic testing and interviews with the HHS OIG officials responsible 

for maintaining the list. We found these data to be sufficiently reliable for 

our analysis.
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-15-19 Potential Physician-Assisted Fraud

We identified a number of key practices that organizations should 

consider when implementing analytics to uncover potential fraud in 

disability claims. These practices are based on our past work that 

examined the use of analytics to detect Medicare fraud.1

We conducted this performance audit from July 2013 to November 2014 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings based 

on our audit objectives.

To validate 

these practices and determine their relevance for disability programs, we 

shared the list of practices with private sector entities that have 

experience implementing analytics for disability programs. We also asked 

these entities whether there were additional practices that should be 

added to our list. These entities generally agreed with the practices from 

our prior work and suggested that we add mining text data to our list 

because this capability is critical to identifying similar medical language 

across claims.

 1 GAO, Medicare Fraud Prevention: CMS Has Implemented a Predictive Analytics 

System, but Needs to Define Measures to Determine Its Effectiveness, GAO-13-104 

(Washington, D.C.: Oct. 15, 2012).

Identification of Key 

Practices for 

Implementing Fraud 

Analytics Systems
Appendix II: Comments from the Social 

Security Administration

Page 36 GAO-15-19 Potential Physician-Assisted Fraud

Appendix II: Comments from the Social 

Security Administration
Appendix II: Comments from the Social 

Security Administration

Page 37 GAO-15-19 Potential Physician-Assisted Fraud
Appendix II: Comments from the Social 

Security Administration

Page 38 GAO-15-19 Potential Physician-Assisted Fraud
Appendix II: Comments from the Social 

Security Administration

Page 39 GAO-15-19 Potential Physician-Assisted Fraud
Appendix III: GAO Contact and 

Staff Acknowledgments

Page 40 GAO-15-19 Potential Physician-Assisted Fraud

Daniel Bertoni, (202) 512-7215 or bertonid@gao.gov

In addition to the contact named above, Gretta L. Goodwin (Assistant 

Director), Nyree Ryder Tee (Analyst-in-Charge), Daniel Concepcion, 

Brian Schwartz, and Melinda Cordero made key contributions to this 

report. Additional contributors include: James Bennett, Sarah Cornetto, 

David Chrisinger, Alex Galuten, Sheila McCoy, Zachary Sivo, Almeta 

Spencer, Vanessa Taylor, and Walter Vance.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments
Related GAO Products

Page 41 GAO-15-19 Potential Physician-Assisted Fraud

Highlights of a Forum: Data Analytics for Oversight and Law 

Enforcement. GAO-13-680SP. Washington, D.C.: July 15, 2013.

Social Security Administration: Long-Term Strategy Needed to Address 

Key Management Challenges. GAO-13-459. Washington, D.C.: May 29, 

2013.

Medicare Fraud Prevention: CMS Has Implemented a Predictive 

Analytics System, but Needs to Define Measures to Determine Its 

Effectiveness. GAO-13-104. Washington, D.C.: October 15, 2012.

Social Security Disability: Collection of Medical Evidence Could Be 

Improved with Evaluations to Identify Promising Collection Practices. 

GAO-09-149. Washington, D.C.: December 17, 2008.

Results-Oriented Cultures: Insights for U.S. Agencies from Other 

Countries’ Performance Management Initiatives. GAO-02-862. 

Washington, D.C.: August 2, 2002.

Supplemental Security Income: Additional Actions Needed to Reduce 

Program Vulnerability to Fraud and Abuse. GAO/HEHS-99-151. 

Washington, D.C.: September 15, 1999.

Supplemental Security Income: Action Needed on Long-Standing 

Problems Affecting Program Integrity. GAO/HEHS-98-158. Washington, 

D.C.: September 14, 1998.

Related GAO Products

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