DISABILITY INSURANCE

Preliminary Observations 

on Overpayments and 

Beneficiary Work 

Reporting

STATEMENT OF DANIEL BERTONI, DIRECTOR 

EDUCATION WORKFORCE AND INCOME SECURITY

Testimony 

Before the Subcommittee on Social 

Security, Committee on Ways and 

Means, House of Representatives

For Release on Delivery 

Expected at 2:00 p.m. EDT

Tuesday, June 16, 2015

GAO-15-673T

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-15-673T, a testimony 

before the Subcommittee on Social Security, 

Committee on Ways and Means, House of 

Representatives

June 16, 2015

DISABILITY INSURANCE:

Preliminary Observations on Overpayments and

Beneficiary Work Reporting

Why GAO Did This Study

SSA’s DI program is one of the 

nation’s largest cash assistance 

programs. To ensure that beneficiaries 

remain eligible, SSA regulations 

require that beneficiaries promptly

report their work activity—including 

starting a job or a change in wages—to 

the agency in a timely manner. If the 

beneficiary does not report changes or 

if SSA does not properly process 

reported work information, SSA may 

pay out benefits in excess of what is 

due, resulting in an overpayment. In 

fiscal year 2014, SSA identified $1.3

billion in DI benefit overpayments. 

Avoiding overpayments is imperative 

as they pose a burden for beneficiaries 

who must repay excess benefits and 

result in the loss of taxpayer dollars 

when they cannot be repaid. 

In this statement based on ongoing 

work, GAO discusses preliminary 

observations regarding: 1) what is 

known about the extent of work-related 

DI overpayments; and 2) factors 

affecting SSA’s handling of work 

activity reported by beneficiaries. GAO 

reviewed relevant federal laws, 

policies, and procedures, and prior 

GAO, OIG and SSA reports; analyzed 

10 years of SSA data on 

overpayments; interviewed staff at 

SSA headquarters and at field offices 

and teleservice centers for three

regions, selected to represent a range 

of relevant DI workloads.

What GAO Recommends

As GAO finalizes its work for issuance 

later this year, it will consider making 

recommendations, as appropriate.

GAO sought SSA’s views on 

information included in this statement, 

but SSA was unable to provide its 

views in time to be incorporated.

What GAO Found

Over the last decade, preliminary data provided by the Social Security 

Administration (SSA) indicate that more than half of the $20 billion overpaid in 

the Disability Insurance (DI) program was associated with beneficiary work 

activity. Specifically, SSA’s data indicate that between fiscal years 2005 and 

2014, a total of $11 billion in DI overpayments were paid to beneficiaries with 

work earnings that exceeded program limits, with an annual average of 96,000 DI 

beneficiaries incurring an average work-related overpayment of $12,000. In its 

last 6 annual stewardship reports, SSA attributed some improper payments to its 

not taking appropriate action when notified of beneficiaries’ work activity.

GAO identified a number of factors that affect handling of work activity reports by 

beneficiaries—factors that stem from weaknesses in SSA’s policies and 

procedures that are inconsistent with federal internal control standards. Such 

weaknesses increase the risk that overpayments may occur even when DI 

beneficiaries diligently try to follow program rules and report work and earnings. 

These weaknesses include:

• Vulnerabilities in processing work reports. Based on interviews with SSA

staff, GAO identified process vulnerabilities that could result in staff not: (1) 

issuing a receipt that proves the beneficiary’s work was reported—one of two 

criteria a beneficiary must meet for SSA to waive an overpayment; and (2) 

initiating tracking of work activity, which would help prevent overpayments. 

Data are not available to determine the extent to which this might occur.

• Limited guidance for processing and monitoring work reports. While 

SSA has metrics to ensure that staff take action on work reports in a timely 

manner, it lacks procedures detailing steps staff must take in screening these 

reports and for ensuring that pending work reports are systematically 

reviewed and closed with appropriate action, consistent with federal internal 

control standards.

• Not leveraging technology. In contrast to SSA’s Supplemental Security 

Income (SSI) program—a means-tested disability benefits program—the DI 

program lacks automated tools for beneficiaries to report work. SSI recipients 

can report wages through an automated telephone reporting system and a 

smartphone app. SSA cited complex DI program rules and an unclear return 

on investment for not pursuing these options. However, this conclusion was 

based on a limited evaluation of costs. Meanwhile, SSA’s current manual

approach is vulnerable to error and may discourage reporting by 

beneficiaries who experience long wait times when they try to report work in 

person at offices or by telephone.

• Confusing work incentive rules. The DI program has complex work 

incentive rules, such that SSA staff interviewed by GAO had varying

interpretations of program rules and gave beneficiaries differing instructions 

on how often to report their work and earnings. In 2012, SSA developed a 

proposal to simplify program rules, but stated that it does not currently have 

the authority to test or implement such changes. SSA requested authority 

that would allow it to conduct such tests in its 2016 budget proposal.

View GAO-15-673T. For more information, 

contact Daniel Bertoni at (202) 512-7215 or 

bertonid@gao.gov.
Letter

Page 1 GAO-15-673T 

Chairman Johnson, Ranking Member Becerra and Members of the 

Subcommittee:

I’m pleased to discuss the Social Security Administration’s (SSA) efforts 

to address overpayments and reported work activity for the Disability 

Insurance (DI) program. The DI program is one of the nation’s largest 

cash assistance programs. In fiscal year 2014, about 11 million 

individuals with disabilities and their dependents received approximately 

$143 billion in DI benefits. During the same year, SSA reported detecting 

$1.3 billion in new DI benefit overpayments,1 which occur when SSA pays 

benefits in excess of what is due, or continues to pay those who are no 

longer eligible. Overpayments often result when beneficiary work and 

earnings activity—which can affect program eligibility—is not properly 

reported to or processed by SSA. Overpayments can pose a financial 

hardship for beneficiaries responsible for repaying the debt, or result in 

the loss of taxpayer dollars when beneficiaries are unable to repay. 

Unrecovered overpayments may also have implications for the long-term 

solvency of the DI trust fund, which DI Trustees project will be exhausted 

in 2016. In addition, researchers and others have noted that 

overpayments may also create a disincentive to beneficiaries who might 

otherwise wish to work.2

My statement today provides preliminary observations from our ongoing 

review for this subcommittee and discusses (1) what is known about the 

extent of work-related DI overpayments; and (2) factors affecting the 

handling of work activity reported by beneficiaries. To examine these 

issues, we reviewed 10 years of SSA data on overpayment debt 

identified, collected, or written off, which includes waivers and 

overpayments for which collection activities have been terminated. We 

 1 SSA provided GAO summary data on new debt detected each fiscal year for fiscal years 

2005 through 2014. SSA cites the source of this data as the fourth quarter report of the 

Treasury Report on Receivables for each fiscal year.

2 For example, The Social Security Administration’s Employment Support Programs for 

Disability Beneficiaries, 111th Cong. 24-25 (2009)(statement of Cheryl Bates-Harris, 

Senior Disability Advocacy Specialist, National Disability Rights Network, on behalf of the 

Consortium for Citizens with Disabilities Employment and Training Task Force and Social 

Security Task Force) and Gina A. Livermore, Cornell Center for Policy Research, Wage 

Reporting and Earnings-Related Overpayments in the Social Security Disability Programs: 

Status, Implications, and Suggestions for Improvement, a report prepared at the request 

of Ticket to Work and Work Incentives Advisory Panel, Social Security Administration, 

May 5, 2003.

Letter
Page 2 GAO-15-673T 

reviewed relevant federal laws and regulations. In addition, we identified 

agency policies and procedures for processing work reports and 

assessed these against federal internal control standards.3 We also 

identified management strategies and tools used to oversee these 

processes, and assessed them against federal internal control standards. 

We examined prior relevant reviews by SSA, GAO and SSA’s Office of 

Inspector General, interviewed managers and staff in headquarters and at 

several offices in three regions, selected to reflect a range of workloads, 

and spoke with a national disability rights network representing groups 

that assist disability beneficiaries. Findings presented here are 

preliminary, and we will issue a final report later this year. GAO sought 

SSA’s views on information included in this statement, but SSA was 

unable to provide its views in time to be incorporated.

We are conducting our work 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 will provide a 

reasonable basis for our findings and conclusions based on our audit 

objectives.

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

to individuals unable to work because of severe long-term disability. To 

meet the definition of disability under the DI program, an individual must 

have a medically determinable physical or mental impairment that (1) has 

lasted or is expected to last at least one year or to result in death and (2) 

prevents the individual from engaging in substantial gainful activity 

(SGA).4 In addition, to be eligible for benefits, workers with disabilities 

must have a specified number of recent work credits under Social 

Security when they acquired a disability. Spouses and children of workers 

may also receive benefits. Benefits are financed by payroll taxes paid into 

the DI Trust Fund by covered workers and their employers, and the 

benefit amount is based on a worker’s earnings history. In November 

 3 Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999).

4 The SGA monthly earnings limit in 2015 is $1,090 ($1,820 for blind beneficiaries).

Background
Page 3 GAO-15-673T 

2014, the program’s average monthly benefit for disabled workers was 

about $1,146.

Historically, very few DI beneficiaries have left the program to return to 

work. To encourage work, the DI program offers various work incentives 

to reduce the risk a beneficiary faces in trading guaranteed monthly 

income and subsidized health coverage for the uncertainties of 

employment—including a trial work period, and an extended period of 

eligibility for DI benefits. These incentives safeguard cash and health 

benefits while a beneficiary tries to return to work. For example, the trial 

work period allows DI beneficiaries to work for a limited time without their 

earnings affecting their disability benefits. Each month in which earnings 

are more than $780 is counted as a month of the trial work period. When 

the beneficiary has accumulated 9 such months (not necessarily 

consecutive) within a period of 60 consecutive months, the trial work 

period is completed. The extended period of eligibility begins the month 

after the trial work period ends, during which a beneficiary is entitled to 

benefits so long as he or she continues to meet the definition of disability 

and his or her earnings fall below the SGA monthly earnings limit.

SSA regulations require all DI beneficiaries to promptly notify SSA when:

their condition improves, they return to work, or they increase the amount 

they work or their earnings.5 Program guidance directs DI beneficiaries to 

report to SSA right away if work starts or stops; if duties, hours or pay 

change; or they stop paying for items or services needed for work due to 

a disability. Beneficiaries may report work by fax, mail, phone, or in 

person at an SSA field office. SSA staff are required by law and 

regulation to issue a receipt acknowledging that the beneficiary (or 

representative) has given SSA information about a change in work or 

earnings, and documenting the date that SSA received the work report. 

After receiving information about work activity or a pay stub from a 

beneficiary, SSA staff have five days to input the information into the 

system—which creates a pending work report or pay stub report—and 

hand or mail a receipt to the beneficiary.6 Staff then have an additional 30 

days to review the pending work report to determine if an additional 

 5 20 C.F.R. § 404.1588(a).

6 SSA guidance directs staff to give or mail the receipt immediately if beneficiary work 

reports are made in person or by phone; for mailed or faxed reports, or reports dropped off 

in the field office, staff are directed to input the information into the system and mail the 

receipt within 5 days of receipt of the information.
Page 4 GAO-15-673T 

action, such as a work continuing disability review (CDR),7 is needed to 

assess the beneficiary’s continued eligibility for DI benefits. See figure 1. 

SSA processes over 100,000 work reports or pay stubs annually.

Figure 1: SSA’s Procedures for Processing DI Beneficiary Work Reports

 7 Work CDRs are reviews of beneficiary earnings to determine continued eligibility for 

benefits. These reviews typically involve SSA staff querying centralized agency data 

systems to identify earnings, sending forms to a beneficiary requesting information about 

work activity and earnings that may affect eligibility for DI benefits, contacting employers 

to verify earnings amounts, and assessing other factors such as employer subsidies and 

impairment-related work expenses.
Page 5 GAO-15-673T 

a SSA staff also input pay stub information into eWork within 5 days, but the resulting pay stub reports 

are not subject to the 30-day time frame that applies to work reports.

Benefit overpayments can occur when beneficiaries do not report work or 

SSA does not take action on work reports in an appropriate or timely 

manner. When a DI work-related overpayment is identified, the 

beneficiary is notified of the overpayment and may request 

reconsideration or waiver of that overpayment.8 SSA may grant a waiver 

request if the agency finds the beneficiary was not at fault AND recovery 

or adjustment would either defeat the purpose of the program or be 

against equity and good conscience, as defined by SSA.9

SSA’s DI cumulative overpayment debt has almost doubled over the last 

decade, growing from $3.2 billion at the end of fiscal year 2004 to $6.3 

billion at the end of fiscal year 2014, according to SSA data.10,11

Cumulative overpayment debt is comprised of existing debt carried 

forward from prior years, new debt, reestablished debts (debts reactivated 

for collection due to re-entitlement or another event) and adjustments, 

 8 A beneficiary requests reconsideration when he or she disputes the occurrence of the 

overpayment itself, 20 C.F.R. § 404.907, and requests a waiver when asserting he or she 

is both not at fault for the overpayment and incapable of repaying the debt, 20 C.F.R. § 

404.506. A waiver permanently terminates collection of a debt and removes the debt from 

SSA’s balance sheet.

9 20 C.F.R. § 404.509.

10 GAO previously reported that cumulative DI overpayment debt is understated due to a 

limitation in SSA’s Recovery of Overpayments, Accounting and Reporting (ROAR) 

system. Used to track overpayments and collections, ROAR cannot capture and track 

debt scheduled to be collected beyond the year 2049. As a result, the amount scheduled 

to be collected after that year is not reflected in current totals even as it annually 

increases. GAO recommended that SSA correct the ROAR 2049 system limitation so that 

debt scheduled for collection after 2049 is included in the system and available for SSA 

management, analysis, and reporting. SSA agreed with this recommendation. For more 

information see GAO, Disability Insurance: SSA Can Improve Efforts to Detect, Prevent, 

and Recover Overpayments, GAO-11-724 (Washington, DC: July 27, 2011).

11 SSA provided summary data on cumulative debt, new debt detected, adjustments, 

collections, and write-offs for each fiscal year for fiscal years 2005 through 2014. SSA 

cites the source of this data as the fourth quarter report of the Treasury Report on 

Receivables for each fiscal year.
Page 6 GAO-15-673T 

minus debts that are collected or written off by SSA.12 Cumulative DI 

overpayment debt has continued to grow because in nine of the last ten 

years the debt added exceeded the total debt collected and written off. 

Specifically, over the 10 years reviewed, SSA added about $15.4 billion in 

debt,13 while collecting and writing-off $12.3 billion.14

According to preliminary data provided by SSA, the agency overpaid DI

beneficiaries a total of about $20 billion during fiscal years 2005 through 

2014, and more than half of this total ($11 billion) was a result of 

beneficiaries’ work-related earnings exceeding program limits.15

According to these data, each fiscal year an average of about 96,000 DI 

beneficiaries (or 28 percent of all beneficiaries overpaid each year) 

received excess benefits totaling $1.1 billion because their work activity 

exceeded program limits. The average work-related overpayment per 

beneficiary was almost $12,000 during this time period, ranging from 

$10,456 in fiscal year 2014 to $14,208 in fiscal year 2011. We are 

continuing to assess the reliability of these data as part of our ongoing 

work.

 12 Write-offs include waivers and terminated collections. Waivers represent money the 

agency will never recover because they permanently remove overpayments from SSA’s 

accounts receivable balance. Terminated collections conditionally remove debts from 

SSA’s accounts receivable balance, as the agency has ceased active internal collection 

efforts, but they are available for future collection if the debtor becomes re-entitled to 

benefits. SSA will re-establish the debt and resume recovery through benefit withholding. 

SSA will also reestablish the debt if it receives a collection from one of its external 

collection methods such as tax refund offset.

13 New debt accounted for about $14 billion, or about 91 percent of the total added debt. 

Reestablished debts, which are debts reactivated for collection due to re-entitlement or 

other event, and adjustments accounted for about $686 million and $667 million of the 

total respectively.

14 During this period, SSA collected $7.8 billion and wrote off $4.5 billion. 

15 These preliminary data on overpayments during fiscal years 2005 through 2014 were 

extracted from SSA’s Recovery of Overpayments, Accounting and Reporting system 

(ROAR) master file on May 11, 2015, and do not match information on new debt found in 

the fourth quarter Treasury Report on Receivables for those years which contain data as 

of the end of each fiscal year. SSA attributes the difference to the fact that the ROAR 

master file is continuously updated, including debt established in prior years. GAO will 

continue to review the reliability of the ROAR data and include the results in our final 

report expected to be issued later this year.

Most DI Overpayment 

Amounts Are 

Associated with 

Work-Related Activity 

That Exceeds 

Program Limits
Page 7 GAO-15-673T 

SSA’s annual stewardship reviews provide limited insight into the causes 

of overpayments. Stewardship reviews are based on a sample of cases, 

and are used by the agency to report on the accuracy of benefit 

payments.16 In its stewardship reports, SSA uses the term deficiency 

dollars to quantify the effect of each individual deficiency in a case which 

could cause an improper payment.17 In its last six stewardship reports, 

SSA reported that deficiency dollars related to beneficiaries’ incomes 

being above DI program limits were consistently a leading cause of 

improper overpayments in the DI program.18 SSA also attributed some of 

these deficiencies to not taking appropriate or timely action to adjust 

payments when it was notified of beneficiaries’ work activity. However, 

GAO has not yet fully evaluated SSA’s methodology for conducting these 

reviews.

 16 Due to small sample sizes, SSA reports its findings on deficiencies in five year 

increments. Its 2014 report includes results for fiscal years 2010 through 2014 while its 

2013 report includes 2009 through 2013 results.

17 An improper payment is any payment that should not have been made or that was 

made in an incorrect amount under statutory, contractual, administrative, or other legally 

applicable guidance. According to SSA, certain overpayments are unavoidable and not 

improper if the payment is required by statute, regulations, or court order. SSA refers to 

each error in a case which causes an improper payment as a deficiency. 

18 Deficiency dollars track the individual effect of each separate deficiency. Because SSA 

may identify more than one error causing the same improper payment in some cases it 

reviews, deficiency dollars can be greater than the total overpayment for each case. 

Process 

Vulnerabilities and 

Complex Program 

Rules May Pose 

Challenges to 

Correctly Handling 

Work Reports
Page 8 GAO-15-673T 

Based on our discussions with SSA staff in field offices and teleservice 

centers, we identified a number of situations where beneficiaries report 

work or earnings, but staff may not enter information into the system, 

which is inconsistent with federal internal control standards,19 or may not 

provide a receipt, as mandated by law.20 Whether DI beneficiaries report 

work information in person or by fax, mail, or telephone to SSA field 

offices or the agency’s 800 teleservice line, in accordance with 

procedures, staff must manually enter the information into the system to 

initiate tracking and issue a receipt. Specifically, SSA representatives 

have five days to manually enter the information into the eWork21 system, 

which also generates a receipt to be mailed or given to the beneficiary. 

Issuing a receipt is required by law and valuable to the beneficiary for two 

reasons: (1) the beneficiary can review the receipt to ensure that the 

information is correct; and (2) a beneficiary who later receives an 

overpayment can produce work report receipts to prove that he/she 

properly reported work activity.22 This system also tracks pending work 

reports to ensure completion within 30 days. Tracking is critical for 

ensuring SSA promptly processes the work report and takes the actions 

needed to adjust a beneficiary’s benefits and minimize the chance of 

overpayments.

However, in our work at several locations, SSA staff told us that if the 

eWork system is unavailable, or if the representative is busy, he or she 

may not enter the information and issue a receipt to the beneficiary. In 

addition, at one location, we learned that, until recently, SSA teleservice 

staff were using an alternate approach for sending work reports to the 

 19 In accordance with federal internal control standards, agencies should ensure that all 

transactions are recorded promptly and accurately to help management control operations 

and make decisions. Standards for Internal Control in the Federal Government, 

GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999).

20 As noted earlier, SSA staff are required by law and regulation to issue a receipt 

acknowledging that the beneficiary (or representative) has given SSA information about a 

change in work or earnings, and documenting the date that SSA received the work report.

21 In 2004, SSA implemented the eWork system, which is the primary system for 

processing work CDR cases in headquarters and field locations.

22 Being able to demonstrate that a beneficiary is “without fault” for an overpayment is the 

first criterion that must be met when SSA decides whether an overpayment can be waived 

and work report receipts can provide verification that the beneficiary has properly fulfilled 

the obligation to report.

Vulnerabilities in 

Processing DI Work 

Reports
Page 9 GAO-15-673T 

field office for manual entry and processing,23 instead of directly entering 

the information into the eWork system themselves. Work reports handled 

this way lack the controls in eWork; for example, they are not 

automatically tracked against the 30-day goal for work report completion. 

As such, they can be more easily missed or overlooked, and could be 

deleted or marked as completed without action being taken. Finally, 

claims representatives in the field office may also bypass the work report 

process entirely and initiate a work continuing disability review (CDR) 

instead. Some SSA claims representatives we interviewed told us that 

they skip the work report step and do a CDR instead because it is more 

efficient, but this means that the beneficiary does not receive a receipt.

Stakeholder groups we interviewed have also observed problems with 

receipts, but SSA has limited data to assess this and other vulnerabilities 

in the work reporting process. In particular, stakeholders said that 

beneficiaries they work with do not always receive receipts, especially 

when reporting work by calling the 800 teleservice line. However, SSA’s 

ability to determine the extent of these vulnerabilities is hindered, in part, 

due to data limitations. SSA’s eWork system does not capture data that 

would help the agency determine how many work reports are filed by fax, 

mail, or in person. This system also does not allow SSA to determine how 

often staff go directly to a CDR without first completing a work report and 

issuing a receipt. Moreover, while SSA’s system archives copies of 

printed receipts, it does not provide aggregate data on receipts provided. 

So even though SSA officials noted that local offices have procedures in 

place to ensure the timely processing of information received by mail or 

fax, data limitations prevent SSA from knowing the extent to which 

receipts are provided within five days. Further, according to SSA officials, 

determining the extent to which 800 teleservice staff might be using 

alternative approaches for sending work reports to field offices would 

require a significant effort to match data between two different systems.

Although the agency monitors work reports for timeliness, SSA lacks 

guidance for processing work reports through completion, and monitoring 

them for quality. SSA has set a 30-day time frame for staff to screen 

pending work reports, and decide whether further action is required in 

 23 Rather than eWork, teleservice staff may use Modernized Development Worksheets 

(MDW) to transmit beneficiary work information to a field office. MDWs are a type of interoffice message used to request assistance from another SSA office.

Limited Guidance for 

Processing and Monitoring 

Work Reports
Page 10 GAO-15-673T 

light of the information in the work report, or whether the work report can 

be closed without additional action. Field office managers who oversee 

field office workloads have access to management information showing 

the number and age of pending work reports, and those we interviewed 

indicated that they follow up on pending work reports approaching the 30-

day timeframe to ensure timely processing. However, the agency has not 

established policies or procedures detailing the steps staff must take in 

screening these reports. Federal internal control standards state that 

agencies’ policies and procedures should be clearly documented in 

administrative policies or operating manuals.24 Without explicit policies or 

procedures on how to screen a work report—that is, how to evaluate 

whether it should be closed or referred to a work CDR to determine 

whether the beneficiary’s benefits should be adjusted—there is an 

increased risk that a report could be improperly closed, and result in a 

beneficiary being overpaid. SSA also lacks guidance and processes for 

ensuring the accuracy and quality of its work report decisions. In our work 

at several field locations, we did not identify any processes that would 

have either assessed the accuracy or quality of the screening decision, or 

provide feedback to staff on how to improve their decision making.25 In 

accordance with federal internal control standards, agencies should 

assure that ongoing monitoring occurs in the course of normal operations, 

and assess the quality of performance over time.26 The absence of 

oversight and feedback increases the risk that the agency may not 

identify errors with work report decisions in a timely manner.

 24 GAO/AIMD-00-21.3.1

25 SSA’s policy manual states that all work activity should be evaluated during the work 

CDR process. This includes reviewing and, if necessary, correcting or updating the work 

report information previously provided by DI beneficiaries. However, this policy does not 

cover work reports that are closed without going through the CDR process, and does not 

establish guidance for how to review and provide feedback on the initial work report 

decision.

26 GAO/AIMD-00-21.3.1
Page 11 GAO-15-673T 

SSA does not offer automated reporting options for DI beneficiaries —

similar to those currently used in SSA’s Supplemental Security Income 

(SSI) program27— even though such options could address vulnerabilities 

we identified. According to SSA officials, SSA first piloted a telephone 

wage reporting system for SSI beneficiaries in 2003, and has used it 

nationally since 2008. In 2013, the agency also rolled out a mobile 

smartphone application for reporting work activity for SSI. Unlike the DI 

program’s manual process, both of these SSI reporting options assist with 

agency tracking and issue receipts to the beneficiary without staff 

intervention. SSA has also noted that these automated reporting tools 

make reporting easier and more convenient for beneficiaries, and reduce 

field office workloads. SSA reported that it processed over 44,000 SSI 

telephone wage reports in September 2013, surpassing its fiscal year 

2013 goal of 38,510 reports per month. In September 2013, the agency 

also received over 5,100 wage reports through its smartphone 

application. SSA continues to promote these methods and has stated that 

expanded use of automated reporting should help reduce improper 

payments in the SSI program.

Despite potential benefits to the DI program, SSA officials told us the 

agency has not used SSI reporting systems for DI beneficiaries. In 

October 2010, SSA created a work group to begin exploring the 

development of a telephone reporting system for the DI program but, 

according to SSA officials, the project was discontinued in February 

2011—after developing cost estimates for one year of development—due 

to lack of resources. They also told us these efforts were not resumed 

because the automated reporting in the DI program would not have the 

same return on investment as in the SSI program, due to the complexity 

of DI program rules. For example, officials stated determinations 

concerning DI work incentives—determinations that are currently a part of 

the work CDR process, not the DI work reporting process—cannot be 

easily automated.28 SSA officials also stated that they currently favor 

 27 The Supplemental Security Income (SSI) program, which is administered by the Social 

Security Administration (SSA), provides cash assistance to financially needy individuals 

who are aged, blind, or disabled. Although concurrent DI and SSI beneficiaries may report 

their wages using the SSI automated systems, DI-only beneficiaries are excluded.

28 In processing DI work reports, SSA staff may document various information relevant to 

DI work incentives, such as earnings and employment-related work expenses—but 

determinations concerning how that information impacts benefits are made during the 

work CDR process . 

SSA Has Not Automated 

DI Beneficiary Work 

Reporting
Page 12 GAO-15-673T 

using the www.mysocialsecurity.gov portal as the best approach for 

providing automated reporting options to DI beneficiaries. However, they 

did not provide any information on plans, timelines or costs associated 

with implementing such an approach. In the meantime, the current, 

manual DI work activity reporting options leave the process more 

vulnerable to error, provide less proof of beneficiaries’ due diligence, and 

subject beneficiaries to less convenient reporting mechanisms.29

Overpayments may arise because of unclear work reporting requirements 

and staff’s differing interpretations of complex DI program rules. For 

example, SSA’s regulations and its policy manual both state that DI 

beneficiaries should “promptly” report changes to work activity, but SSA 

has not defined this term, leaving this open to interpretation by both 

beneficiaries and SSA staff. Similarly, in its pamphlet “Working While 

Disabled,” beneficiaries are instructed to report changes in their work 

“right away.” However it does not prescribe a time period or frequency of 

reporting. During our site visits, we found variation in how staff instructed 

beneficiaries to report. For example, some staff said they instruct 

beneficiaries to report monthly, regardless of whether there are changes 

in their work, which is similar to the SSI program’s wage-reporting 

requirements. Others told us they tell beneficiaries to report 10 days after 

any change, which is also similar to another SSI reporting requirement. 

One staff person indicated that she instructs beneficiaries not to bother 

reporting earnings under $15,780 per year, even though this earnings 

limit applies to those receiving Social Security retirement benefits, not 

DI.30 Thus a DI beneficiary who relied on such information could incur an 

overpayment. According to federal internal control standards, federal 

agencies should ensure that pertinent information is distributed to the 

right people in sufficient detail and at the appropriate time to enable them 

to carry out their duties and responsibilities efficiently and effectively.

Further, our preliminary findings suggest that some SSA staff do not fully 

understand DI’s complex work incentive rules. Service representatives 

 29 In fiscal year 2014, SSA reported that its average speed of answer on the 800 

teleservice line was about 23 minutes. Similarly, DI beneficiaries may face long wait times 

in local field offices, particularly at the beginning of each month.

30 For some Social Security retirement beneficiaries, SSA deducts $1 in benefits for each 

$2 in earnings above the 2015 annual earnings limit of $15,720.

Unclear Guidance and 

Complex Program Rules 

May Result in Confusion 

Regarding Work Reporting 

Requirements
Page 13 GAO-15-673T 

who take work reports through SSA’s 800 teleservice line or at the 

window in an SSA office are generally less highly trained or specialized in 

their knowledge about work incentives and may not always provide 

accurate information. For example, several staff we spoke with confused 

the trial work period earnings threshold with substantial gainful activity 

(SGA) earnings limits.31 Such a mistake might result in beneficiaries—

who, for example, plan to return to work—being told not to report earnings 

that they should be reporting. Stakeholder groups we spoke with cited 

similar examples of SSA staff providing beneficiaries with incorrect 

information on work incentives. SSA officials told us that in fiscal year 

2013, the agency sampled calls received on its 800 teleservice line for 

quality review purposes, and found that calls regarding disabled work 

activity represented only 1 percent of the total call workload, but 2.3 

percent of all errors identified. Several SSA managers we spoke with said 

that training could be enhanced for those staff answering calls on SSA’s 

800 teleservice line.

SSA has developed a proposal to reduce complexity in the DI program, 

but has not tested or implemented this proposal to date. In its fiscal year 

2012 budget request, SSA proposed the Work Incentives Simplification 

Pilot (WISP), to test a streamlined approach to evaluating DI Program 

work activity and reduce administrative workloads by making it simpler 

and less time-consuming for staff to verify earnings and validate benefits. 

It was also intended to reduce improper payments and eliminate rules 

that confuse beneficiaries, such as different definitions for income for the 

DI versus SSI program.32 Ultimately the agency hopes such an effort will 

reduce incidences of overpayments that may serve as a disincentive to DI 

beneficiaries who wish to work. SSA convened a Technical Advisory 

Panel to design a demonstration of WISP, which issued a report with 

recommendations in 2012 but also noted that the agency lacks authority 

 31 During the trial work period, beneficiaries receive their full Social Security disability 

benefits regardless of how much they earn, as long as they report work activity and 

continue to have a disabling impairment. In 2015, a trial work period month is any month 

in which total earnings are over $780, and the trial work period continues until a 

beneficiary has worked nine months within a 60-month period. In contrast, the SGA 

monthly earnings limit in 2015 is $1,090 ($1,820 for blind beneficiaries) and is applicable 

after the 9-month trial work period is completed.

32 Under the DI program, earnings are counted when earned, while under the SSI 

program earnings are counted when paid. For beneficiaries who receive benefits from 

both programs, SSA may have to contact beneficiaries, employers, or both to obtain 

additional information in order to correctly calculate earnings both ways.
Page 14 GAO-15-673T 

to implement the proposed demonstration.33 However, the report also 

noted that SSA could conduct a pre-test to inform a large demonstration. 

This is an issue we will continue to explore in our ongoing work.

Despite the importance and challenges associated with work reporting, 

SSA provides beneficiaries with infrequent reminders, and those 

reminders it does provide contain limited information about potential 

liability for overpayments. GAO’s internal control standards state that 

management should ensure there are adequate means of communicating 

with, and obtaining information from, external stakeholders that may have 

a significant impact on the agency achieving its goals.34 SSA currently 

informs beneficiaries of reporting requirements when their benefit claim is 

initially approved; although it could be many years before a beneficiary 

returns to work. Nevertheless, one SSA representative/ manager 

indicated that the page signed by beneficiaries when they are initially 

approved for benefits could specifically include information about work 

reporting requirements, which would make it more difficult for 

beneficiaries who incur an overpayment to claim that they were unaware 

of their reporting responsibilities. SSA also sends an annual letter to 

beneficiaries regarding cost-of-living adjustments to their benefits that 

includes a reminder of their reporting responsibilities; however, several 

staff indicated that additional reminders would prompt more beneficiaries 

to report work. In contrast, in fiscal year 2014, SSA began providing a 

web-based service designed to prompt SSI beneficiaries to report wages, 

using notices, emails and reminders—an option not currently available for 

DI beneficiaries.35 SSA officials stated that the agency does not have 

near-term plans to provide additional notices to DI beneficiaries to 

encourage work reporting. Finally, although the initial application and 

annual letter mention potential liability for overpayments for beneficiaries 

who fail to report work, SSA’s “Working While Disabled” pamphlet—which 

 33 Since 1985, SSA’s demonstration authority has been extended five times. The most 

recent of these extensions expired in 2005. In 2008, GAO found that SSA’s demonstration 

projects had little impact on disability policy and the SSDI and SSI programs. (Social 

Security Disability: Management Controls Needed to Strengthen Demonstration Projects. 

GAO-08-1053 (Washington, D.C.: September 26, 2008). SSA’s 2016 budget proposal 

included a request to reauthorize and expand demonstration authority for the DI and SSI 

programs.

34 GAO/AIMD-00-21.3.1.

35 SSA established this web-based system because it deemed unreported and untimely 

reported wages to be a major source of SSI program payment errors.
Page 15 GAO-15-673T 

contains details about work incentives and is provided to beneficiaries 

who contact SSA about work—does not explain circumstances under 

which a beneficiary could be found liable for an overpayment. Some SSA 

staff we spoke with said they tell beneficiaries not to spend benefit checks 

or deposits that they believe were sent in error. However one stakeholder 

group we spoke with said that many beneficiaries mistakenly believe that, 

if they diligently report work and still receive benefits, then they must be 

entitled to those benefits. We will continue to assess the issues discussed 

in this statement and will report our final results later this year.

Chairman Johnson, Ranking Member Becerra, and members of the 

Subcommittee, this completes my prepared statement. I would be 

pleased to respond to any questions that you may have at this time.

If you or your staff have any questions about this testimony, 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 statement. GAO staff members who made key 

contributions to this testimony are Michele Grgich (Assistant Director), 

James Bennett, Daniel Concepcion, Julie DeVault, Dana Hopings, Arthur 

Merriam, Jean McSween, Ruben Montes de Oca, James Rebbe, Martin 

Scire, Charlie Willson, and Jill Yost.

GAO Contacts and 

Staff 

Acknowledgments

(131369)
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