SUPPLEMENTAL 

SECURITY INCOME

An Overview of Program 

Integrity and Management 

Challenges

Statement of Daniel Bertoni, Director

Education, Workforce, and Income Security

Testimony 

Before the Subcommittee on Human 

Resources, Committee on Ways and 

Means, House of Representatives

For Release on Delivery 

Expected at 10 a.m. ET

Wednesday, June 3, 2015

GAO-15-632T

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-15-632T, a testimony 

before the Subcommittee on Human 

Resources, Committee on Ways and Means, 

House of Representatives

June 2015

SUPPLEMENTAL SECURITY INCOME

An Overview of Program Integrity and Management 

Challenges

Why GAO Did This Study

The SSI program, administered by 

SSA, provides cash assistance to 

eligible aged, blind, and disabled 

individuals with limited financial means. 

In fiscal year 2014, the program paid 

nearly $56 billion in federally funded 

benefits to about 8.2 million individuals. 

The program has grown substantially 

in recent years, and is expected to 

grow more in the near future. SSA has 

a stewardship responsibility to guard 

against improper payments and to 

address program integrity issues that if 

left unchecked could increase the 

potential for waste, fraud, and abuse.

SSA estimated that it made $5.1 billion 

in improper payments in fiscal year 

2014. In addition, SSA’s management 

concerns are wide ranging and include 

ensuring its workforce is able to meet 

service delivery needs.

In this statement, GAO describes 

SSA’s challenges with 1) ensuring SSI 

program integrity and 2) managing the 

program. This testimony is primarily 

based on GAO products issued from 

2002 to 2015, which used multiple 

methodologies, including analyses of 

SSI administrative data from fiscal 

years 2000 to 2011; reviews of

relevant federal laws, regulations, and 

guidance; and interviews of SSA 

officials. In May 2015, GAO obtained 

current data on improper payments 

and updates from SSA reports and 

guidance on actions taken to address 

GAO’s past recommendations.

What GAO Recommends

GAO has previously made 

recommendations to help SSA 

strengthen its program oversight and 

address management challenges. In 

response, the agency has taken some 

steps and plans to do more. 

What GAO Found

The Social Security Administration (SSA) faces challenges with ensuring the 

integrity of the Supplemental Security Income (SSI) program’s processes for 

preventing, detecting, and recovering overpayments. For example, SSA is 

required in certain circumstances to periodically review SSI recipients’ medical 

and financial eligibility, yet the lack of timely reviews and difficulty getting 

complete financial information hinder SSA’s ability to prevent and detect 

overpayments to recipients. SSA estimated that $4.2 billion of the payments it 

administered to SSI recipients in fiscal year 2013 were overpayments. In June 

2012, GAO found that SSA had accumulated a substantial backlog of recipients’ 

medical eligibility reviews, including for over 23,000 children with mental 

impairments who were deemed likely to medically improve when initially 

determined eligible for benefits. GAO recommended that SSA eliminate its 

backlog for these children and conduct timely reviews going forward, estimating 

based on fiscal year 2011 data that these actions could save more than $3.1 

billion over 5 years by preventing related overpayments. SSA recently reported 

that it has increased the number of medical eligibility reviews conducted for SSI 

children in each year since 2012, completing nearly 90,000 reviews in fiscal year 

2014—in contrast to the 25,000 reviews completed in fiscal year 2011—and 

plans to continue these efforts. In December 2012, GAO also reported that a lack 

of comprehensive, timely information on SSI recipients’ financial accounts and 

wages led to overpayments. GAO noted that SSA had recently developed 

electronic tools to address these issues, and SSA reported that the agency is 

gaining experience using them. However, despite these efforts, in May 2015, the 

SSA Office of the Inspector General found that overpayments associated with 

financial account information have increased in recent years and recommended 

SSA continue researching initiatives that will help to reduce improper payments 

in the SSI program. SSA agreed to this recommendation.

SSA faces several management challenges in administering SSI related to 

workload, service delivery, and program complexity. In 2013, GAO reported that 

as a result of an ongoing retirement wave, SSA faced a loss of institutional 

knowledge and expertise, which may result in increased review backlogs and 

improper payments. GAO recommended that SSA update its succession plan, in 

line with federal internal controls guidance that states that management should 

plan for succession and ensure continuity of needed skills and abilities. In 

response, SSA published a human capital document detailing its succession 

plans. Federal internal controls guidance also states that agencies should 

comprehensively identify and manage risks, and GAO also recommended SSA 

develop a long-term service delivery plan to determine, among other things, how 

SSA will address both program integrity and other workloads. In response, SSA 

published an April 2015 description of its vision for future service delivery and 

indicated it plans to develop a strategy for achieving this vision moving forward. 

SSA also noted the importance of simplifying its policies and procedures to meet 

its service delivery goals and SSA has plans to do so. Program complexity is a 

long-standing challenge that contributes to administrative expenses and potential 

overpayments. GAO is beginning work for this subcommittee related to how 

benefit amounts are calculated for multiple SSI recipient households, an area 

that SSA has considered for program simplification.

View GAO-15-632T. For more information, 

contact Daniel Bertoni at (202) 512-7215 or 

bertonid@gao.gov.
Letter

Page 1 GAO-15-632T 

Chairman Boustany, Ranking Member Doggett, and Members of the 

Subcommittee:

I am pleased to be here today to discuss our work on the Supplemental 

Security Income (SSI) program, including issues affecting program 

integrity—which left unchecked, increase the potential for waste, fraud, 

and abuse. As you know, the Social Security Administration’s (SSA) SSI 

program provides cash assistance for eligible aged, blind, and disabled 

individuals with limited financial means. In fiscal year 2014, the SSI 

program paid almost $56 billion in federally funded benefits to about 8.2 

million individuals. The program has grown substantially in recent years, 

and is expected to grow more in the near future, in part because of 

population growth. SSA’s strategic goals and objectives for fiscal year 

2015 reflect a wide range of management concerns, ranging from 

ensuring that SSA has a workforce with the competence and agility to 

address service demands to creating new opportunities for individuals 

with disabilities to return to work. SSA also has a stewardship 

responsibility to guard against improper payments. Given the size of the 

SSI program, even small errors in benefit payments can result in a 

significant loss of taxpayer dollars.

My testimony—based primarily on reports we issued from 2002 to

20151

—describes SSA’s challenges with (1) ensuring SSI program 

integrity and (2) managing the program. We used multiple methodologies 

 1

This statement is also based on a review of current related data on improper payments 

and updates on actions taken to address past GAO recommendations obtained from 

reviewing SSA reports and guidance in May 2015. Reports are cited throughout and 

include GAO, Supplemental Security Income: Progress Made in Detecting and Recovering 

Overpayments, but Management Attention Should Continue, GAO-02-849 (Washington, 

D.C.: Sept. 16, 2002); Social Security Disability: Ticket to Work Participation Has 

Increased, but Additional Oversight Needed, GAO-11-324 (Washington, D.C.: May 6, 

2011); Modernizing SSA Disability Programs: Progress Made, but Key Efforts Warrant 

More Management Focus, GAO-12-420 (Washington, D.C.: June 19, 2012); Supplemental 

Security Income: Better Management Oversight Needed for Children's Benefits,

GAO-12-497 (Washington, D.C.: June 26, 2012); Supplemental Security Income: SSA 

Has Taken Steps to Prevent and Detect Overpayments, but Additional Actions Could Be 

Taken to Improve Oversight, GAO-13-109 (Washington, D.C.: Dec. 14, 2012); Social 

Security Administration: Long-Term Strategy Needed to Address Key Management 

Challenges, GAO-13-459 (Washington, D.C.: May 29, 2013); Social Security Disability 

Programs: SSA Could Take Steps to Improve Its Assessment of Continued Eligibility, 

GAO-14-492T (Washington, D.C.: Apr. 9, 2014); Supplemental Security Income: Wages 

Reported for Recipients Show Indications of Possible SSN Misuse, GAO-14-597

(Washington, D.C.: Jul. 16, 2014); and High-Risk Series: An Update, GAO-15-290

(Washington, D.C.: Feb. 11, 2015). 

Letter
Page 2 GAO-15-632T 

to conduct the work for these reports. For example, we reviewed and 

analyzed SSI administrative data from fiscal years 2000 to 2011; 

reviewed relevant federal laws, regulations, and guidance; reviewed key 

agency documents, such as SSA’s strategic plan, human capital plan, 

strategic leadership succession plan, and annual SSI stewardship 

reports; and interviewed management and staff from SSA headquarters, 

selected regions, and field offices. We assessed the data we received 

and concluded that the data were sufficiently reliable for the purposes of 

our reports. More information on the scope and methodology of our work 

is contained within our published reports.

We conducted the work on which this statement is based 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.

The SSI program was established in 1972 under Title XVI of the Social 

Security Act and provides payments to low-income aged, blind, and 

disabled persons—both adults and children—who meet the financial 

eligibility requirements.2 A disability is defined for adults as the inability to 

engage in any substantial gainful activity because of any medically 

determinable physical or mental impairment(s) that can be expected to 

result in death, or has lasted or can be expected to last for a continuous 

period of not less than 12 months.3

 2

The SSI program was established by the Social Security Amendments of 1972 and 

became effective in 1974. Pub. L. No. 92-603, §301, 86 Stat. 1329, 1465 (codified as 

amended at 42 U.S.C. § 1381-1383f).

3

42 U.S.C. § 1382c(a)(3). Individuals under age 18 are considered disabled if they have a 

medically determinable physical or mental impairment or combination of impairments that 

causes marked and severe functional limitations, and that can be expected to result in

death or has lasted or can be expected to last for a continuous period of not less than 12 

months. 20 C.F.R. § 416.906 (2012).

Background
Page 3 GAO-15-632T 

To meet financial eligibility requirements, in fiscal year 2014, an 

individual’s or married couple’s monthly countable income4 had to be less 

than the monthly federal SSI benefit rate of $721 per month for an 

individual and $1,082 per month for a married couple. Further, countable 

resources (such as financial institution accounts) had to be $2,000 or less 

for individuals and $3,000 or less for married couples. Recipients are to 

report changes in their income and financial resources to SSA as soon as 

they occur and a penalty may be deducted from the recipient’s benefit if 

the report is not made within 10 days after the close of the month in which 

they change.5 In addition, to determine an individual’s ongoing financial 

eligibility for SSI program payments, SSA conducts periodic 

“redeterminations.”

6 During a redetermination, field office staff perform a 

variety of activities to verify recipients’ income, resources, living 

arrangements, and other factors to determine their continued SSI 

program eligibility. These activities may include querying internal and 

external databases, checking with employers and banks, and performing 

interviews with recipients to obtain current information.

To ensure that only recipients who remain disabled continue to receive 

benefits, SSA is required to conduct periodic continuing disability reviews 

(CDR) in certain circumstances.7 These reviews assess whether 

recipients are still eligible for benefits based on several criteria, including 

their current medical condition. During the CDR process, SSA applies a 

medical improvement standard. Under this standard, SSA may 

discontinue benefits for an individual if it finds substantial evidence 

 4

Certain types of income are excluded under the SSI program by the Social Security Act. 

42 U.S.C. § 1382a(b). For a list of types of income excluded under the SSI program as 

provided by federal laws other than the Social Security Act, see the appendix to 20 C.F.R. 

part 416, subpart K. 

5

20 C.F.R. §§ 416.708(c) and (d) and 416.714.

6

The length of time between scheduled redeterminations varies depending on the 

likelihood that a recipient’s situation may change in a way that affects his or her benefits. 

SSA may also redetermine eligibility when the agency learns of a change in the recipient’s 

situation that affects eligibility or the benefit amount. 20 C.F.R. § 416.204(b).

7

SSA’s regulations pertaining to CDRs for SSI can be found at 20 C.F.R. § 416.989 et 

seq. CDRs may be conducted generally every 6 to 18 months, 3 years, or 5 to 7 years, 

depending on the nature of the recipient’s disability. 20 C.F.R. § 416.990(d).
Page 4 GAO-15-632T 

demonstrating both that a beneficiary’s medical condition has improved8

and that the individual is able to engage in substantial gainful activity.9 If 

SSA determines that these conditions have not been met in the course of 

conducting a CDR, the recipient may continue to receive benefits until the 

individual receives a subsequent CDR (which potentially could result in a 

discontinuation of benefits), dies, or transitions to Social Security 

retirement benefits.

Multiple entities are involved in determining recipients’ initial and 

continued eligibility. After an SSA field office determines that an SSI 

applicant meets the program’s financial requirements, a state Disability 

Determination Services agency reviews the applicant’s medical eligibility. 

Similarly, SSA field offices conduct redeterminations of recipients’

financial eligibility, and state Disability Determination Services agencies 

assess continued medical eligibility.

Complex eligibility rules and many layers of review with multiple handoffs 

from one person to another make the SSI program complicated and also 

costly to administer. During fiscal year 2014, SSA estimated that it made 

$5.1 billion in improper payments in the program. As our prior work has 

shown, improper payments, including overpayments, may result, in part, 

because eligibility reviews are not conducted when scheduled, 

information provided to SSA is incomplete or outdated, or errors are 

made in applying complex program rules.

 8

The relevant regulations define medical improvement as any decrease in the medical 

severity of the recipient’s impairment(s) since the last time SSA reviewed his or her 

disability favorably, based on improvements in symptoms, signs, or laboratory findings. 20 

C.F.R. § 416.994(b)(1)(i).

9

42 U.S.C. § 1382c(a)(4)(A)(i). The medical improvement standard for individuals under 

the age of 18 who receive SSI benefits is different. See 42 U.S.C. § 1382c(a)(4)(B). The 

law also identifies certain other circumstances under which benefits may be discontinued, 

besides the medical improvement standard. See 42 U.S.C. § 1382c(a)(4)(A) and (C). 
Page 5 GAO-15-632T 

Because CDRs are a key mechanism for ensuring continued medical 

eligibility, when SSA does not conduct them as scheduled, program 

integrity is affected and the potential for overpayments increases as some 

recipients may receive benefits for which they are no longer eligible. SSA 

reported in January 2014 that it is behind schedule in assessing the 

continued medical eligibility of its disability program recipients10 and has 

accumulated a backlog of 1.3 million CDRs. In recent years, SSA has 

cited resource limitations and a greater emphasis on processing other 

workloads as reasons for the decrease in the number of reviews 

conducted. From fiscal years 2000 to 2011, the number of adult and 

childhood CDRs fell approximately 70 percent, according to our analysis 

of SSA data.11 More specifically, CDRs for children under age 18 with 

mental impairments—a group that comprises a growing majority of all 

child SSI recipients—declined by 80 percent.12

Children make up about 15 percent of all SSI recipients, and we reported 

in 2012 that CDRs for 435,000 child recipients with mental impairments 

were overdue, according to our analysis of SSA data.13 Of these, nearly 

half had exceeded their scheduled CDR date by 3 years, and 6 percent 

 10This includes recipients of SSI, as well as Disability Insurance (DI), a cash assistance 

program for individuals with disabilities who have a qualifying work history. 

11From fiscal years 2000 to 2011, the number of adult CDRs fell from more than 580,000 

to about 180,000 and the number of childhood CDRs fell from more than 150,000 to about 

45,000.

12CDRs for children under age 18 with mental impairments declined from more than 

84,000 to about 16,000.

13GAO-12-497. A total of about 861,000 child recipients with mental impairments were 

receiving SSI benefits as of December 2011.

SSA Faces Program 

Integrity Challenges 

in Preventing, 

Detecting, and 

Recovering 

Overpayments

SSA Could Prevent 

Billions of Dollars in 

Overpayments by 

Conducting More Disability 

Reviews and Could 

Ensure Review 

Consistency by Improving 

Guidance
Page 6 GAO-15-632T 

exceeded their scheduled date by 6 years.14 Of the 24,000 childhood 

CDRs pending 6 years or more, we found that about 70 percent were for 

children who, at initial determination, SSA classified as likely to medically 

improve within 3 years of their initial determination. Twenty-five percent—

over 6,000—of these pending CDRs were for children medically expected 

to improve within 6 to 18 months of their initial determination.15 Reviews 

of children who are expected to medically improve are more productive 

than reviews of children who are not expected to improve because they 

have a greater likelihood of benefit cessation and thus yield higher cost 

savings over time. SSA officials report that the agency has placed a 

higher priority on conducting CDRs for populations other than SSI 

children that they believe will result in greater savings over time.16

However, our analysis of SSA’s data showed that SSI child claims that 

received a CDR in fiscal year 2011 were ceased at a higher rate than 

other claims.

In our June 2012 report, we recommended that SSA eliminate the 

existing CDR backlog of cases for children with impairments who are 

likely to improve and, on an ongoing basis, conduct CDRs at least every 3 

years for these children. If this recommendation were implemented, SSA 

could potentially save $3.1 billion over 5 years by preventing 

 14Specifically, about 344,000 exceeded the scheduled date by at least a year, about 

205,000 exceeded their date by 3 years, and about 24,000 exceeded the scheduled date 

by 6 years.

15In total, we found reviews for more than 23,000 children who were expected to medically 

improve when they were initially determined eligible for benefits that were pending for 6 

years or more. We also found reviews for about 1,000 children who were not expected to 

medically improve when they were initially determined eligible for benefits that were 

pending for 6 years or more.

16According to SSA officials, when CDR funding is less than what is needed to conduct all 

CDRs at the scheduled intervals, the agency has historically given priority to (1) 

conducting CDRs for DI recipients, (2) performing statutorily mandated SSI age 18 and 

low birth weight reviews, and (3) performing reviews considered most cost-effective.
Page 7 GAO-15-632T 

overpayments to children with mental impairments, according to our 

analysis of fiscal year 2011 data.17

SSA generally agreed that it should complete more CDRs for SSI children 

but emphasized that it is constrained by limited funding and competing

workloads. Moving forward, one of the goals in SSA’s Fiscal Year 2014-

2018 Strategic Plan is to strengthen the integrity of the agency’s 

programs. In line with this goal, SSA requested additional program 

integrity funding for fiscal year 2015 to enable the agency to conduct 

more CDRs, and Congress made these funds available. SSA recently 

reported that in each year since 2012, it has increased the number of 

reviews conducted for SSI children, completing nearly 90,000 reviews in 

fiscal year 2014, in contrast to the 25,000 reviews it completed in fiscal 

year 2011, the year prior to GAO’s audit. The agency stated it will 

continue to work toward eliminating its CDR backlog for SSI children if it 

receives sustained and predictable funding. While additional funding may 

help address the backlog, we continue to have concerns about the 

agency’s ability to manage its resources in a manner that adequately 

balances its service delivery priorities with its stewardship responsibility. 

Because SSA has noted that it considers SSI childhood CDRs to be a 

lower priority than other CDRs, it is unclear whether the agency will 

continue to use new increases in funding to review children most likely to 

medically improve—reviews that could yield a high return on investment.

As a result of CDRs, disability recipients that SSA determines have 

improved medically may cease receiving benefits; however, several 

factors may hinder SSA’s ability to make this determination. In prior 

work,18 our analysis of SSA data showed that 1.4 percent of all people 

 17This estimate pertains only to children with mental impairments. Implementing the 

recommendation would also likely result in additional cost savings from preventing 

overpayments to children with physical impairments. To perform this analysis, we

considered two potential sources of cost savings: (1) addressing the CDR backlog for 

children with mental impairments who are expected to medically improve or for whom 

medical improvement is possible and (2) conducting future CDRs for these recipients, as 

scheduled. We considered such factors as the average cessation rate after appeals, 

average benefit amount, average amount of time in benefit receipt before age 18, and 

average cost of performing a CDR. See GAO, 2015 Annual Report: Additional 

Opportunities to Reduce Fragmentation, Overlap, and Duplication and Achieve Other 

Financial Benefits, GAO-15-404SP (Washington, D.C.: Apr. 14, 2015). 

18GAO, Social Security Disability Programs: Clearer Guidance Could Help SSA Apply the 

Medical Improvement Standard More Consistently, GAO-07-8 (Washington, D.C.: Oct. 3, 

2006). 
Page 8 GAO-15-632T 

who left the agency’s disability programs between fiscal years 1999 and 

2005 did so because SSA found that they had improved medically; 

however, recipients more commonly left for other reasons, including 

conversion to Social Security retirement benefits or death.19 At that time, 

we identified a number of factors that challenged SSA’s ability to assess 

disability program recipients using the medical improvement standard, 

including (1) limitations in SSA guidance for applying the standard; (2) 

inadequate documentation of prior disability determinations; (3) failure to 

abide with the requirement that CDR decisions be made on a neutral 

basis—without a presumption that the recipient remained disabled; and 

(4) the judgmental nature of the process for assessing medical 

improvement. For example, we noted that—based on a review of the 

same evidence—one examiner may determine that a recipient has 

improved medically and discontinue benefits, while another examiner may 

determine that medical improvement has not been shown and will 

continue the individual’s benefits. Furthermore, we concluded that the 

amount of judgment involved in the decision-making process increases 

for certain types of impairments, such as psychological impairments, 

which are more difficult to assess than others, such as physical 

impairments.

These issues have implications for the consistency and fairness of SSA’s 

medical improvement decision-making process, as well as program 

integrity, and in 2006, we recommended that SSA clarify several aspects 

of its policies for assessing medical improvement. Since then, SSA has 

taken some steps that may help address the issues we raised but has not 

fully implemented our recommendation. For example, SSA began 

implementing an electronic claims analysis tool for use during initial 

disability determinations to (a) document a disability adjudicator’s detailed 

analysis and rationale for either allowing or denying a claim, and (b) 

ensure that all relevant SSA policies are considered during the disability 

adjudication process. In addition, SSA reported in its fiscal year 2016 

annual performance plan that it will continue to expand the use and 

functionality of this analysis tool to help hearing offices standardize and 

better document the hearing decision process and outcomes. However, 

SSA’s guidance for assessing medical improvement may continue to 

present challenges when applying the standard. As of May 2015, the 

guidance does not provide any specific measures for what constitutes a 

 19 This includes recipients of SSI, as well as DI.
Page 9 GAO-15-632T 

“minor” change in medical improvement,20 and it instructs examiners to 

exercise judgment in deciding how much of a change justifies an increase 

in the ability to work.21 We continue to believe that SSA should fully 

implement the actions we previously recommended to improve guidance 

in this area.

In light of the questions that have been raised about SSA’s ability to 

conduct and manage timely, high-quality CDRs for its disability programs, 

we are currently undertaking a study of SSA’s CDR policies and 

procedures for this Subcommittee. More specifically, we are examining 

how SSA prioritizes CDRs, the extent to which SSA reviews the quality of 

CDR decisions, and how SSA calculates cost savings from CDRs. We 

look forward to sharing our findings once our audit work is complete.

In addition to overpayments that result when CDRs are not conducted as 

scheduled, overpayments may result when financial information provided 

to SSA is incomplete or outdated. In December 2012, we reported that

SSA lacks comprehensive, timely information on SSI recipients’ financial 

institution accounts and wages.22 For fiscal year 2011, the unreported 

value of recipients’ financial institution accounts, such as checking and 

savings accounts, and unreported wages were the major factors 

associated with causes of overpayments, and were associated with about 

$1.7 billion (37 percent) of all SSI overpayments.23 Specifically, 

overpayments occurred because recipients did not report either the 

existence of financial institution accounts, increases in account balances, 

or monthly wages.

 20See SSA Program Operations Manual System (POMS) section DI 28010.015. The 

standards state that “although the decrease in severity may be of any quantity or degree, 

we will disregard minor changes in your signs, symptoms, and laboratory findings that 

obviously do not represent medical improvement and could not result in a finding that your 

disability has ended.” 

21See POMS section DI 28015.320. 

22GAO-13-109.

23Amounts are annual estimates based on 5-year averages from fiscal year 2007 through 

fiscal year 2011. Cumulative SSI overpayment debt nearly doubled from $3.8 billion in 

fiscal year 2002 to $7.3 billion in fiscal year 2011.

A Lack of Comprehensive 

and Timely Financial 

Information Contributes to 

Overpayments
Page 10 GAO-15-632T 

SSA has developed tools in recent years to obtain more comprehensive 

and timely financial information for SSI recipients, but these tools have 

limitations:

• The Access to Financial Institutions initiative, which SSA implemented 

in all states in June 2011, involves electronic searches of about 96 

percent of the financial institutions where SSI recipients have a direct 

deposit account. This initiative therefore provides SSA with 

independent data on a recipient’s financial institution accounts for use 

in periodically redetermining their eligibility for payments. However, in 

our December 2012 report, we found that this initiative does not 

capture all relevant financial institutions, and SSA staff were generally 

not required to conduct these searches for recipients who, for 

example, report a lesser amount of liquid resources or do not report 

any financial accounts.

• The Telephone Wage Reporting system, implemented in fiscal year 

2008, allows recipients to call into an automated telephone system to 

report their monthly wages. Agency officials reported that this system 

should ease the burden of reporting wages for some recipients and 

save time for SSA staff since wage data is input directly into SSA’s 

computer system. At the same time, the accuracy and completeness 

of information obtained through this system is limited because it relies 

on self-reported data and the system is unable to process wage 

information for individuals who work for more than one employer.

SSA recently reported that it is continuing to gain experience using these 

tools and is studying the effects of recent expansions to the Access to 

Financial Institutions initiative. In May 2015, the SSA Office of the 

Inspector General (OIG) noted that despite SSA’s implementation of the 

Access to Financial Institutions initiative, the dollar amount of 

overpayments associated with financial account information has 

increased over the last few fiscal years. The OIG recommended that SSA 

continue (1) monitoring Access to Financial Institutions to ensure a 

positive return on investment and (2) researching other initiatives that will 

help to reduce improper payments in the SSI program. SSA agreed with 

the OIG’s recommendations and noted that it is studying the effects of 

recent expansions of the initiative, including an increase in the number of 

undisclosed bank account searches performed and inclusion of more 

recipients with lower levels of liquid resources.

Over the years, we have also identified issues with inaccurate wage 

reporting by employers that have contributed to improper payments. We 

and the SSA OIG have previously identified patterns of errors and 
Page 11 GAO-15-632T 

irregularities in wage reporting, such as employers using one Social 

Security number for more than one worker in multiple tax years. 

Inaccurate wage information can lead SSA to make either overpayments 

or underpayments to SSI recipients. In July 2014, we identified indications 

of possible Social Security number misuse in wage data used by SSA for 

the SSI program.24 In one case, an individual in California had wages 

reported from 11 different employers in seven other states during the 

same quarter of calendar year 2010, suggesting that multiple individuals 

may have been using the SSI recipient’s Social Security number and 

name for work.25 According to SSA, Social Security number misuse can 

cause errors in wage reporting when earnings for one individual are 

incorrectly reported to the record of another person having a similar 

surname.26 However, we found that the prevalence of such Social 

Security number misuse in SSA’s wage data was unclear.

When an SSI overpayment is identified, recipients are generally required 

to repay the overpaid amount, although they can request a waiver of 

repayment under certain circumstances. We reported in December 2012 

that SSA increased its recovery of SSI overpayment debt by 36 percent 

from $860 million to $1.2 billion from fiscal year 2002 to fiscal year 2011. 

However, SSA grants most overpayment waiver requests, and waiver 

documentation and oversight was limited.27 Specifically, in fiscal year 

2011, SSA approved about 76 percent of all SSI overpayment waivers 

requested by recipients. Claims representatives, who are located in 

SSA’s approximately 1,230 field offices, have the authority to approve 

such waivers, and SSA does not require supervisory review or approval 

for overpayment waivers of $2,000 or less. According to the standards for 

internal control in the federal government, agencies must have controls in 

place to ensure that no individual can control all key aspects of a 

 24GAO-14-597.

25There are instances when individuals could work for multiple employers simultaneously, 

but it is questionable that one person could work for multiple employers simultaneously in 

different regions of the country during the same quarter.

26According to SSA policy, if earnings are identified that do not belong to the number 

holder, the individual may submit a signed statement “disclaiming” the wages as his or her 

own and have the earnings removed from his or her Master Earnings File—the main 

source of SSA’s earnings data.

27GAO-13-109.

SSA’s Oversight and 

Documentation of 

Overpayment Waivers Is 

Limited
Page 12 GAO-15-632T 

transaction or event. We recommended that SSA review the agency’s 

policy concerning the supervisory review and approval of overpayment 

waiver decisions of $2,000 or less. SSA agreed with this recommendation 

and subsequently convened a workgroup to evaluate this policy and 

review the payment accuracy of a random sample of waiver decisions. 

SSA found that the dollar accuracy rate of the randomly selected waiver 

transactions it reviewed in the SSI program was nearly 99 percent. 

However, in a more recent review of 5,484 SSI waiver decisions of less 

than $2,000, SSA found that 50 percent of decisions were processed 

incorrectly.28 In light of this finding, we continue to believe that additional 

supervisory review may improve program integrity. However, as a result 

of its earlier study findings, SSA decided to continue its current policy for 

waiver decisions of $2,000 or less.

Beyond SSA’s field offices, we also found limited oversight of the waiver 

process on a national basis. In our December 2012 report, we concluded 

that management oversight of the SSI overpayment waiver decision 

process is limited. Specifically, SSA did not analyze trends in the type, 

number, and dollar value of waivers granted, including those waivers 

below the $2,000 approval threshold that SSA staff can unilaterally 

approve, or determine whether there were waiver patterns specific to SSA 

offices, regions, or individual staff. Without such oversight and controls in 

place, SSA is unaware of trends in the waiver process that may 

jeopardize the agency’s ability to maximize its overpayment recovery 

efforts and safeguard taxpayer dollars. We recommended that SSA 

explore ways to strengthen its oversight of the overpayment waiver 

process. While the agency agreed with the intent of this recommendation, 

it cited resource constraints to creating and analyzing data at the level of 

detail specified in our recommendation. However, we continue to believe 

that, short of additional steps to better compile and track additional data 

on waiver patterns specific to SSA offices and individuals, SSA will be 

constrained in its efforts to recover identified overpayments.

 28SSA, Continuous Quality Area Director Review: Data Analysis Report Findings and 

Recommendations (January 2015).
Page 13 GAO-15-632T 

SSA faces management challenges that may constrain its ability to 

ensure program integrity. As mentioned above, SSA has cited challenges 

with balancing the demands of competing workloads, including CDRs, 

within its existing resources. In February 2015, we reported that SSA has 

taken a number of steps toward managing its workload and improving the 

efficiency of its operations, but capacity challenges persist, and delays in 

some key initiatives have the potential to counteract efficiency gains.29

SSA is also facing succession planning challenges in the coming years 

that could affect program integrity. In 2013, we reported that SSA projects 

that it could lose nearly 22,500 employees, or nearly one-third of its 

workforce, due to retirement—its primary source of attrition—between 

2011 and 2020.30 An estimated 43 percent of SSA’s non-supervisory 

employees and 60 percent of its supervisors will be eligible to retire by 

2020. During this same time, workloads and service delivery demands 

are expected to increase. The high percentage of supervisors who are 

eligible to retire could result in a gap in certain skills or institutional 

knowledge. For example, regional and district managers told us they had 

lost staff experienced in handling the most complex disability cases and 

providing guidance on policy compliance. SSA officials and Disability 

Determination Services managers also told us that it typically takes 2 to 3 

years for new employees to become fully proficient and that new hires 

benefit from mentoring by more experienced employees. SSA’s 

Commissioner also noted that as a result of attrition, some offices could 

become understaffed, and that without a sufficient number of skilled 

employees, backlogs and wait times could significantly increase and 

improper payments could grow. Federal internal controls guidance states 

that management should consider how best to retain valuable employees, 

 29GAO-15-290.

30GAO-13-459.

SSA Faces Several 

Management 

Challenges in 

Administering SSI

SSA Is Taking Some Steps 

to Address Ongoing 

Workload and Service 

Delivery Challenges
Page 14 GAO-15-632T 

plan for their eventual succession, and ensure continuity of needed skills 

and abilities. Thus, we recommended that SSA update its succession 

plan to mitigate the potential loss of institutional knowledge and expertise 

and help ensure leadership continuity. In response to our 

recommendation, SSA published a human capital operating plan, 

detailing specific workforce management and succession planning steps 

SSA will take across the organization. We believe this is an important 

step in addressing the upcoming workload and workforce challenges.

In our 2013 report, we also concluded that SSA’s long-term strategic 

planning efforts did not adequately address the agency’s wide-ranging 

challenges. For example, in the absence of a long-term strategy for 

service delivery, the agency would be poorly positioned to make 

decisions about its critical functions. Such decisions include how the 

agency will address disability claims backlogs while ensuring program 

integrity, how many and what type of employees SSA will need for its 

future workforce, and how the agency will more strategically use its 

information technology and physical infrastructure to best deliver 

services. Federal internal controls guidance states that federal agencies 

should comprehensively identify risks, analyze and decide how to 

manage these risks, and establish mechanisms to deal with continual 

changes in governmental, economic, industry, regulatory, and operating 

conditions. We recommended that SSA develop a long-term strategy for 

service delivery. We also noted that without a dedicated entity to provide 

sustained leadership, SSA’s planning efforts would likely remain 

decentralized and short-term. We recommended that SSA consider 

having an entity or individual dedicated to ensuring that SSA’s strategic 

planning activities are coordinated agency-wide.

In response to these recommendations, SSA appointed a chief strategic 

officer responsible for coordinating agency-wide planning efforts. SSA 

has also recently taken a key step toward developing a long-range 

strategic plan to address wide-ranging management challenges. In April 

2015, SSA published Vision 2025, which incorporates input from 

employees, advocates, members of Congress, and other stakeholders 

and articulates a vision of how SSA will serve its customers in the future. 

As a next step, SSA has indicated that it will create working groups 

representing a cross-section of SSA staff. Under the leadership of SSA’s 

Chief Strategic Officer, they will be charged with developing a strategic 

roadmap for the next 10 years that will define actions SSA will need to 

take and resources required to achieve SSA’s vision for 2025. Moving 

forward, SSA will need to implement the steps outlined in its long-term 

strategic plan—as well as those in its human capital plan—to ensure it 
Page 15 GAO-15-632T 

has the capacity and resources needed to manage future workloads while 

making quality decisions.

As stated in Vision 2025, SSA plans to realize its service delivery vision in 

part by simplifying and streamlining its policies and procedures, and in 

2013, SSA formed an SSI Simplification Workgroup that is tasked with 

identifying promising proposals that could simplify the SSI program and 

reduce improper payments. Program complexity has been a longstanding challenge for SSI that contributes to administrative expenses 

and the potential for overpayments. In addition to collecting 

documentation of income and resources to determine SSI benefit 

amounts, SSA staff must also apply a complex set of policies to 

document an individual’s living arrangements and financial support being 

received.31 These policies depend heavily on recipients to accurately 

report a variety of information, such as whether they live alone or with 

others; the extent to which household expenses are shared; and exactly 

what portion of those expenses an individual pays. Over the life of the 

program, these policies have become increasingly complex. The 

complexity of SSI program rules pertaining to these areas of benefit 

determination is reflected in the program’s administrative costs. In fiscal 

year 2014, SSI benefit payments represented about 6 percent of benefits 

paid under all SSA-administered programs, but the SSI program 

accounted for 33 percent of the agency’s administrative expenditures. In 

our prior work, we noted that staff and managers we interviewed cited 

program complexity as a problem leading to payment errors, program 

abuse, and excessive administrative burdens.32 In December 2012, we 

also reported that the calculation of financial support received was a 

primary factor associated with SSI overpayments from fiscal year 2007 

through fiscal year 2011.33 The SSI Simplification Workgroup is 

considering options for simplifying benefit determination policies as well 

as adding a sliding scale for multiple SSI recipients in the same family.

In light of these long-standing issues, we have begun work for this 

Subcommittee that will provide information about SSI recipients who are 

 31GAO-02-849.

32GAO-02-849.

33GAO-13-459. 

SSI Program Complexity 

Is a Long-Standing 

Challenge
Page 16 GAO-15-632T 

often subject to complex benefit determination policies. Generally, if two 

members of a household receive SSI benefits, both members are eligible 

for the maximum amount of benefits, unless they are married. However, 

this benefit structure does not directly reflect savings that may result from 

multiple individuals sharing household expenses, and the policies SSA 

currently applies to address this issue are highly complex and 

burdensome. Over the last two decades, various groups have proposed 

applying a payment limit to the benefits received by more multiplerecipient households, which could be used in place of the more complex 

calculations SSA currently performs. Our new study is examining such 

households and the potential administrative or other barriers to 

implementing a change in the amount of benefits received by households 

with multiple recipients.

Another long-standing challenge for the SSI program is that once on 

benefits, few individuals leave the disability rolls, despite the fact that 

some may be able to do so through increased earnings and employment. 

Our prior work has noted that if even a small percentage of disability 

program recipients engaged in work, SSA’s programs would realize 

substantial savings that could offset program costs.34 To this end, the 

Ticket to Work and Work Incentives Improvement Act of 1999 provided 

for the establishment of the Ticket to Work and Self-Sufficiency Program 

(Ticket program) which provides eligible disability program recipients with 

employment services, vocational rehabilitation services, or other support 

services to help them obtain and retain employment and reduce their 

dependency on benefits.35 In May 2011, we reported that the Ticket 

program continued to experience low participation rates, despite revisions 

to program regulations that were designed to attract more disability 

program recipients and service providers. Further, although participants 

have a variety of differing needs, the largest service providers in the 

program focused on those who were already working or ready to work. 

One service provider told us that certain disability program recipients are 

often screened out because they lack the education, work experience, or 

transportation needed to obtain employment. We made several 

recommendations for improving program oversight in our May 2011 

 34GAO-11-324. When referring to disability program recipients, we are including SSI and 

DI recipients.

35Pub. L. No. 106-170, § 101, 113 Stat. 1860, 1863.

Promoting Employment 

and Self-Sufficiency 

Among Recipients Is a 

Long-Standing Challenge
Page 17 GAO-15-632T 

report, which the agency has since implemented.36 However, the number 

of individuals using the Ticket program who left the disability rolls 

because of employment remains low—under 11,000 in fiscal year 2014.

Individuals who start receiving SSI as children often collect benefits for 

the long term, potentially because they do not receive interventions that 

could help them become self-sufficient. Approximately two-thirds of child 

recipients remain on SSI after their age 18 redeterminations. Research 

has found that children who remain on SSI benefits into early adulthood 

have higher school dropout rates, lower employment rates, and lower 

postsecondary enrollment rates in comparison to the general young adult 

population. Additionally, these youth participate in vocational services at a 

low rate. In light of this, concerns have been raised that SSA is not doing 

enough to inform youth on SSI who are approaching age 18 about 

available employment programs. At the request of this Subcommittee, we 

will soon begin work to examine SSA’s efforts to promote employment 

and self-sufficiency among youth on SSI. 

Chairman Boustany, Ranking Member Doggett, 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 statement, 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 who made key contributions 

to this statement include Rachel Frisk, Alexander Galuten, Isabella 

Johnson, Kristen Jones, Phil Reiff, and Walter Vance.

 36We recommended that SSA should (1) prioritize and carry through with a study of 

participants’ exits from the rolls since revisions to the program's regulations took effect in 

2008, (2) adopt a strategy for compiling and using data on trends in service provision to 

determine whether service approaches are consistent with program goals, (3) develop a 

strategy to ensure on-time completion of timely progress reviews of participants and take 

steps to ensure the accuracy of information used to make timely progress determinations, 

and (4) move forward to develop certain performance measures consistent with the 

requirements of the Ticket law.

GAO Contacts and 

Staff 

Acknowledgments

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