SSAS OBLIGATION TO ENSURE THAT

THE PUBLICS FUNDS ARE RESPONSIBLY

COLLECTED AND EXPENDED

Social Security Advisory Board

March 2002
The Magnitude of SSAs Operations

SSAs operations are large and complex. At the end of fiscal year 2001, the agency was paying

benefits to about 46 million beneficiaries of Old-Age, Survivors, and Disability Insurance, and about

6.7 million beneficiaries of the Supplemental Security Income (SSI) program.

In addition, during fiscal year 2001, SSA:

• processed 18.1 million applications for Social Security cards;

• received applications from 3.1 million Retirement and Survivors Insurance applicants and

dependents, 1.7 million Disability Insurance applicants and dependents, 1.6 million

Supplemental Security Income (SSI) disability applicants, and 160,000 SSI aged applicants;

• took action on 11.6 million changes of address and 4.3 million overpayments; and

• conducted 1.7 million continuing disability reviews.

During fiscal year 2001, 85.9 million calls were placed to SSAs 800 number. SSA actually

served 59.3 million of those calls  41.6 million by an SSA representative, and 17.7 million by

automated attendant.

SSA is also responsible for a number of other vital functions. These include:

• Maintaining wage records. SSA maintains records of the lifetime earnings of all workers

who are covered by Social Security. In 2001, SSA posted 252 million tax year 2000 wage

items for 148 million workers. In calculating benefits, both the amount and the number of

years of earnings are considered.

• Delivery of related beneficiary services. SSA determines eligibility for Medicare, and also

performs work on behalf of the Medicaid, Food Stamp, Railroad Retirement, and Black Lung

programs. Field offices provide beneficiaries with information regarding other public and

private programs available in their communities, such as vocational rehabilitation and welfare.

• Providing public information. SSA employees prepare pamphlets, use the public media, and

give speeches in local communities to communicate with the public. Beginning in fiscal year

2000, SSA began annual mailing of Social Security Statements to all taxpayers age 25 and

over showing the amount of Social Security taxes they and their employers paid and their

earnings and estimated benefits. In fiscal year 2001, SSA mailed out about 136 million of

these statements.

• Developing program policy. SSA adopts rules and regulations to ensure its programs are

administered according to law. It conducts research and analysis to help policy makers

address problems and develop proposals for change.

• Resolving disputes. Individuals may appeal Social Security decisions through an

administrative appeals process, including a hearing before an administrative law judge. In

fiscal year 2001, SSAs hearing offices prepared 465,228 case dispositions and issued 401,283

hearing decisions.

Social Security Advisory Board

An independent, bipartisan Board created by the Congress and appointed by the

President and the Congress to advise the President, the Congress, and the Commissioner of

Social Security on matters related to the Social Security and Supplemental Security Income programs
TABLE OF CONTENTS

EXECUTIVE SUMMARY.....................................................................................................................i

I. SSAS RESPONSIBILITY TO ENSURE

PROGRAM INTEGRITY.....................................................................................................1

II. THE NEED FOR BETTER STEWARDSHIP

WILL CONTINUE TO GROW...............................................................................................7

A. SSAs workloads are massive and will become more so.......................................................7

B. While the agencys workload has grown, its resources have

been drastically reduced..............................................................................................9

C. Major areas of the agencys work need to be strengthened..................................................9

1. Integrity of the Social Security number................................................................10

2. Accuracy of disability determinations...................................................................14

3. Accuracy of SSI payments...........................................................................18

4. Collection of overpayments......................................................................20

5. Accountability of representative payees.............................................................23

6. Proper reporting and posting of wages................................................................26

7. Issues related to systems security........................................................................29

III.WHAT NEEDS TO BE DONE TO FULFILL THE AGENCYS

STEWARDSHIP RESPONSIBILITIES......................................................................31

A. Improve SSI and disability program policies.........................................................31

B. Improve the tools the agency uses to measure performance

 and quality..................................................................................................................34

C. Accelerate systems improvements.....................................................................................36

D. Expedite decision making...................................................................................................37

E. Become more aggressive in working with other agencies..................................................38

F. Ensure that maintaining the integrity of the agencys

 work is in practice a priority.......................................................................................39

G. Ensure that the agency has sufficient staff with the right skills

 to do the job right .......................................................................................................40

IV. CONCLUSION: SSAS STEWARDSHIP PROBLEMS

REQUIRE PROMPT AND AGGRESSIVE ACTION..........................................................45

THE SOCIAL SECURITY ADVISORY BOARD.....................................................................................46

REPORTS AND STATEMENTS ISSUED BY THE BOARD.................................................................49

ACRONYMS USED IN THIS REPORT...................................................................................................50
Financial Impact of Social Security

Administration Programs

The programs administered by SSA are among the largest in the Federal government. In fiscal year

2002, benefits and administrative expenses of the Old-Age, Survivors, and Disability Insurance

(OASDI) and Supplemental Security Income (SSI) programs are expected to be about $490 billion, or

about 24 percent of all Federal expenditures. This includes $451 billion in OASDI benefits,

$31 billion in SSI benefits, and nearly $8 billion in administrative expenses for the two programs.

(Data are derived from the Administrations budget submission for fiscal year 2003.)

Income

• Income to the OASDI trust funds in fiscal year 2002 is expected to total about $617 billion, of

which about $528 billion will be from payroll taxes and about $77 billion will be from interest

on the investments of the trust funds. Additional funds come from taxation of benefits and

general revenue transfers for special programs.

Benefits

• Benefits paid to retired and disabled workers and their dependents and survivors in 2002 will total

$451 billion, which includes $384 billion in retirement and survivors benefits and $67 billion in

disability benefits. More than $31 billion in Federal benefits will be paid to SSI recipients.

• About $157 billion will be added to trust fund reserves to pay future OASDI benefits.

Administrative Costs

• SSA expects to spend $7.7 billion for administrative costs in fiscal year 2002. About 60 percent

of administrative costs are used for personnel compensation and benefits.

• Of the $7.7 billion SSA expects to spend for administrative expenses, about 47 percent will be

expended from the OASDI trust funds for retirement, survivors and disability program expenses,

36 percent will come from general revenues for SSI program expenses, roughly 16 percent will

be expended from the HI and SMI trust funds for work related to the Medicare program, and

about 1 percent will be expended from user fees paid by States for the administration of State

supplements to the SSI program.

• More than $5 billion of SSAs administrative budget will support the agencys disability

programs  including both the DI program and the SSI disability program. This amount is

about two-thirds of the agencys administrative budget.

• Total administrative expenses are expected to be about 1.6 percent of total outlays for the agency.

As a percentage of benefits, administrative costs for the OASDI program are under 1 percent.

OASI trust fund costs are about .5 percent and DI costs are about 4 percent of expenditures. For

SSI, administrative outlays are about 9 percent of benefits, reflecting the more labor-intensive

nature of SSI workloads and the fact that most SSI benefits are disability, as compared to old age.
EXECUTIVE SUMMARY

The care with which the Social Security Administration carries out its responsibilities is important

to almost everyone. Today, about 154 million workers, or 96 percent of the workforce, are engaged in

employment covered by Social Security and, together with their employers, are paying the taxes that are

used to support the system. Nearly 33 million individuals, or 91 percent of those age 65 and over, are

receiving retirement benefits. About 90 percent of those age 21 to 64 who worked in covered

employment in 2001 can count on monthly cash benefits in the event of a severe and prolonged

disability. About 6.7 million needy individuals are receiving Supplemental Security Income (SSI)

benefits based on old age or disability.

Over the last five years much of the Boards work has been directed at evaluating the quality of

service that SSA provides to the public and we have issued several reports with recommendations for

how service can be improved. The purpose of this report is to set forth for the President, the Congress,

and the agency our serious concerns that major changes must be made to improve the integrity of SSAs

operations. Ensuring program integrity is an inherent aspect of the agencys responsibility to provide

good service to the public. Taxpayers who support the Social Security and SSI programs must be

confident that their tax dollars are accurately collected and expended. Claimants and beneficiaries must

believe that program rules and procedures are rigorously followed and that the benefits they and others

receive are accurate. A full reporting of SSAs use of taxpayers dollars is essential to meeting these

objectives, as the Board has noted in its earlier reports.

SSAs employees understand and want to meet the publics expectations and needs, and one of the

agencys stated objectives is to ensure program integrity. But as workloads have grown and resources

have declined, managers and employees throughout the agencys administrative structure are

increasingly frustrated that they lack both the time and the tools they need to do the high quality work

that the agency expects and that they expect of themselves.

This report describes aspects of the agencys work that urgently need improvement. The most

critical is to improve the integrity of SSAs enumeration process. An unknown number of Social

Security numbers are being issued on the basis of fraudulent documents. Fraudulent use of the SSN

has become a significant public policy issue, an issue that is expected to grow as the number of SSNrelated crimes continues to escalate. Other areas of the agencys work that need strengthening include

the accuracy of disability determinations, accuracy of SSI payments, collection of overpayments,

accountability of representative payees, posting and reporting of wages, and systems security.

SSA needs to improve both policies and practices. The culture of the agency needs to be changed

to strengthen teamwork and speed up decision making so that program integrity issues can be addressed

promptly and forthrightly. The agency also needs sufficient staff with the right skills. SSAs budget

proposals should reflect the staffing levels and the staff qualifications that the agency needs to serve the

public appropriately and to meet its stewardship responsibilities. SSAs administrative budget for

Social Security should be excluded from any cap that sets an arbitrary limit on discretionary spending.

In addition, as a way of addressing immediate needs, there should be a separate funding mechanism 

outside of the spending cap  to enable the agency to implement program integrity initiatives that will

pay for themselves, such as the current funding arrangement for conducting continuing disability

reviews (CDRs). In the longer term, the new budget process that the Commissioner is developing can

integrate the agencys stewardship activities with overall service requirements.

i
ii

Over the last five years the Board has conducted an extensive study of

SSAs service to the public, of which program integrity is an integral part. Our

study has taken us to offices in cities throughout the countryAtlanta, Austin,

Baton Rouge, Birmingham, Boston, Brooklyn, Chicago, Dallas, Detroit,

Fort Lauderdale, Fort Worth, Harrisburg, Kansas City, Lansing, Los Angeles,

Miami, New Orleans, New York City, Newark, Philadelphia, Raleigh,

Richmond, San Francisco, Seattle, and Trentonand to offices in rural and

suburban areas as well. We have met with employees in field offices, hearing

offices, regional offices, program service centers, teleservice centers and State

disability determination agencies. We have also met with executives at SSAs

Baltimore, Washington, and Falls Church, Virginia headquarters, and consulted

with SSAs Office of the Inspector General and its Office of General Counsel.

We have consulted with a number of other organizations, both public and

private. These include the Federal Trade Commission, the General Accounting

Office, and the Internal Revenue Service.

Our work also reflects comments and suggestions we have received from the

Congress.

We have held public hearings in San Francisco, Dallas, Chicago,

Philadelphia, and Seattle, at which time we heard from Social Security officials,

advocates for the elderly and disabled, State government officials, academics,

legal services and private attorneys, representatives from private and non-profit

organizations concerned with Social Security and Supplemental Security Income

program issues, and members of the public.

HOW THE BOARD

CONDUCTED ITS STUDY
The care with which the Social Security

Administration performs its responsibilities is

important to almost everyone. Today, about

154 million workers, or 96 percent of the

workforce, are engaged in employment covered

by Social Security and, together with their

employers, are paying the taxes that are used to

support the system. Nearly 33 million

individuals, or 91 percent of those age 65 and

over, are receiving retirement benefits. About

90 percent of those age 21 to 64 who worked in

covered employment in 2001 can count on

monthly cash benefits in the event of a severe

and prolonged disability. About 6.7 million

needy individuals are receiving Supplemental

Security Income (SSI) benefits based on old age

or disability.

The care with which

the Social Security

Administration performs

its responsibilities is

important to almost

everyone.

1

I. SSAS RESPONSIBILITY TO

ENSURE PROGRAM INTEGRITY

In fiscal year 2002, the Social Security

trust funds are expected to collect $617 billion

in payroll taxes, interest, and other income, and

pay $451 billion in benefits. SSA will pay

another $31 billion in SSI benefits, which are

financed out of general revenues. This year,

SSAs outlays for the Social Security and SSI

programs will account for about 24 percent of

all Federal expenditures.

As the steward of these large and critically

important programs, the Social Security

Administration has an obligation to ensure that

they are administered with the utmost care and

accuracy. How well it fulfills this obligation

has a major influence on the publics trust in

government.

The 1994 law that established the Social

Security Advisory Board charged the Board

with the responsibility of recommending how

SSA can improve its service to the public. In

responding to this charge, the Board has issued

a number of reports that analyze where the

agency needs to make improvements and what

it can and should do to improve the quality of

the service that it provides to the public.

We have urged SSA to develop a service

delivery plan that will clarify the agencys

priorities and the reasons for them so that they

can be understood by the agencys own

employees as well as by policy makers and the

public. We believe that SSA currently has

inadequate resources to carry out its many

complex responsibilities, and have recommended

As the steward of these large and critically important programs,

the Social Security Administration has an obligation to ensure

that they are administered with the utmost care and accuracy.

How well it fulfills this obligation has a major influence

on the publics trust in government.
to provide good service to the public. Taxpayers

who support the Social Security and SSI

programs must be confident that their tax dollars

are accurately collected and expended.

Claimants and beneficiaries must believe that

program rules and procedures are rigorously

followed and that the benefits they and others

receive are accurate. Full accountability is

critical to the integrity of SSAs programs. Just

as efficiency and accuracy are an essential

concern of beneficiaries, the efficient and

effective use of worker contributions to Social

Security is essential to those who are supporting

the system. The amounts involved are

significant from the standpoint of taxpayers. In

fiscal year 2002, Social Security payroll taxes

are expected to amount to $528 billion, or 27

percent of all taxes taken in by the Federal

government. The workers and employers who

pay these taxes deserve to know how their

dollars are being used.

Since the early years of the Social Security

program, SSA has faced the challenge of striking

a balance among all of these aspects of the

agencys work. Throughout its earlier history,

SSA was generally successful in meeting this

challenge, earning the reputation of being one of

the most efficient, courteous, and accurate

providers of service in the government. Its longstanding commitment has been the right check,

to the right person, on time.

From the beginning, the administrators of

the Social Security program worked to create an

agency-wide culture that would ensure high

2

that the agency develop a budget that is workbased and more coherent. We have noted that

SSA needs to change the way it measures its

performance and we have recommended

improvements in many areas of the agencys

work, including providing easier access to its

800 telephone number and shorter waiting times

in field offices. We have urged the agencys

leadership to address longstanding institutional

problems. These problems include a culture

that discourages open discussion and timely

resolution of problems, weaknesses in

communication between SSAs headquarters

and operations in the field, and inadequate

teamwork.

Providing high quality service to the public

requires SSA to carry out a broad range of

responsibilities. Good service includes

providing prompt, courteous, and helpful

service to the public at large, including workers

and employers as well as beneficiaries and

claimants. It includes helping the public to

understand Social Securitys principles,

benefits, and costs, and what they need to do to

ensure their economic security in retirement.

These aspects of service to the public have been

the subject of Advisory Board reports over the

last five years.

In this report, we focus on program

integrity. Ensuring program integrity is an

inherent aspect of the agencys responsibility

A complete listing of the Boards reports and

statements can be found on p. 49 of this report.

1

1

In this report, we focus on program integrity. Ensuring program

integrity is an inherent aspect of the agencys responsibility to

provide good service to the public. Taxpayers who support the

Social Security and SSI programs must be confident that their

tax dollars are accurately collected and expended. Claimants

and beneficiaries must believe that program rules and

procedures are rigorously followed and that the

benefits they and others receive are accurate.
The Board has heard this view from

employees in Social Security and State

disability agency offices throughout the country.

As one field office manager recently asked

rhetorically: What am I to do when the goal is

not quality, but numbers for quantity and

processing times?

In its 2000  2005 strategic plan, SSA sets

out as two of its five goals the delivery of

customer-responsive, world-class service and

ensuring the integrity of Social Security programs,

with zero tolerance for fraud and abuse.

The reality, however, is that with the current

level of resources these two goals do not appear

to be attainable in any meaningful way. In our

observation, managers and employees throughout

SSAs administrative structure are being forced

to look the other way, and ignore their instincts

to do the job right. Without sufficient staff to meet

stated objectives, they are forced to decide which

aspects of their work should have priority.

Not unreasonably, the choice is most often

to try to address the immediate crisis  to speed

up interviews in order to reduce the crowd in the

waiting room, or speed up the processing of

disability applications to reduce the time a

claimant may have to wait to receive a benefit

check. Actions that are important to program

integrity, such as careful cross checking of

documentation to prevent incorrect payments,

are put aside for later action, or, in some cases,

not taken at all. An SSA area director told the

Board, There is a real and palpable sense of

anxiety in the field over stewardship issues. The

field is meeting its measured goals and

objectives, but there is anxiety over the things

that are not measured, such as quality.

3

quality service. They instructed employees at

all levels of the organization to treat everyone

who communicated with the agency with respect

and to provide helpful service to all. They also

stressed the need to protect the trust funds against

improper payments and earn the publics

respect for the integrity of their administration.

In more recent decades, as the agencys

mission has expanded and become more complex

and staffing levels have been reduced,

employees have found it increasingly difficult to

meet what many have come to view as

There is a widely held

perception that although

the agencys stated objectives

continue to express sound

principles, there is an emphasis

on speed of processing over all

else, including quality and

accuracy. Program integrity,

while a stated agency objective,

is not a priority that in practice

is given adequate weight.

In our observation, managers and employees throughout

SSAs administrative structure are being forced to look the

other way, and ignore their instincts to do the job right.

Without sufficient staff to meet stated objectives, they are forced

to decide which aspects of their work should have priority.

conflicting objectives. There is a widely held

perception that although the agencys stated

objectives continue to express sound principles,

there is an emphasis on speed of processing over

all else, including quality and accuracy. Program

integrity, while a stated agency objective, is not a

priority that in practice is given adequate weight.
4

As we pointed out in our September 1999

report, How the Social Security Administration

Can Improve Its Service to the Public, the kind

of tradeoff employees must now make has not

always been routinely required. In an earlier

time, adequate funding for Social Securitys

programs was a higher priority than it has been

in more recent years. There was a widely

accepted view in the Congress and elsewhere

that, because Social Security was separately

financed, with funding coming out of

contributions by workers and employers, the

agency should be given adequate resources to

administer the program properly. When the

agency made a case for additional funding, the

Administration and the Congress gave the

agency the funding that it urged was needed.

Illustrating the high priority that early

leaders of SSA placed on the funding issue, a

1958 agency statement of objectives cited as

inherent to the rights of the public the obligation

to obtain and maintain adequate resources to

do the work, and to develop sound budget

estimates based on firm documentation so as to

ensure that the Congress would provide the

funds that were needed.

Pressures over the last two decades to

downsize government have left SSA with a staff

in the field that is nearly 30 percent smaller than

it was 20 years ago when workloads were far

smaller than they are today. The universal view

heard by the Board in its meetings with

employees across the country and expressed by

The universal view heard by

the Board in its meetings

with employees across the

country and expressed by

witnesses at our public

hearings is that SSA no

longer has adequate

resources to do the work

that should be done.

witnesses at our public hearings is that SSA no

longer has adequate resources to do the work

that should be done.

If employees in the field are to be able to carry out the

additional work that is required...the agency will

need a higher level of funding for staff and systems

than it is currently receiving. The Board has urged

SSA to develop a service delivery budget that reflects

the agencys work requirements and provides the

resources that are needed to meet those requirements.

In testimony before the Congress and in its

reports, SSAs Office of the Inspector General

has been placing increasing emphasis on the

need by the agency to focus greater attention on

program integrity, pointing to agency

vulnerabilities in such areas as SSI, disability,

and issuance of Social Security numbers. The

Inspector General recently told the House Ways

and Means Social Security Subcommittee that

the agency is faced with balancing speed and

convenience on the one hand and accuracy and

security on the other.
required for the proper administration of the Social

Security program, which is funded out of dedicated

taxes paid by workers and employers.

While SSAs administrative budget is large in

absolute terms, $7.7 billion for the current fiscal

year, it is small in relationship to program

expenditures, about 1.6 percent. It is also

relatively small compared with social security

agencies in other developed countries, which

generally operate with a larger expense ratio. It

is smaller yet in comparison to the operating

costs of private sector insurance companies,

where cost ratios of 10 or 20 percent or more are

not uncommon. Most importantly, it is

demonstrably inadequate to meet not only

existing needs, but also future challenges facing

the agency.

SSAs administrative budget for Social Security, like its program

budget, should be explicitly excluded from any spending cap that

imposes a limit on the amount of discretionary government

spending. It is inappropriate to apply a discretionary spending

cap to spending required for the proper administration of the

Social Security program, which is funded out of dedicated

taxes paid by workers and employers.

5

As this report makes clear, there are a

number of steps SSA should take to ensure that

program integrity receives the attention that it

deserves. These include underscoring to

employees the high value that the agency places

on stewardship work by rewarding it through

new performance and quality measures,

speeding up decision making within the agency,

becoming more aggressive in working with

other agencies to address difficult workloads,

accelerating systems improvements, and

reducing policy and program complexities

wherever possible.

If employees in the field are to be able to

carry out the additional work that is required,

however, the agency will need a higher level of

funding for staff and systems than it is currently

receiving. The Board has urged SSA to develop

a service delivery budget that reflects the

agencys work requirements and provides the

resources that are needed to meet those

requirements. The new Commissioner has

made a commitment to develop a budget along

the lines the Board has recommended. This new

budget process should enable the Administration

and the Congress to make better informed

decisions about the level of funding that is

needed to carry out appropriately all of the

agencys responsibilities, including its important

stewardship responsibilities.

SSAs administrative budget for Social

Security, like its program budget, should be

explicitly excluded from any spending cap that

imposes a limit on the amount of discretionary

government spending. It is inappropriate to

apply a discretionary spending cap to spending

While SSAs administrative

budget is large in absolute

terms, $7.7 billion for the

current fiscal year, it is small

in relationship to program

expenditures,

about 1.6 percent.

As a way of addressing immediate needs for

greater stewardship activities, we urge policy

makers to establish a separate funding

mechanism  outside of the spending cap  that

will enable the agency to implement initiatives

that will pay for themselves. This should include

funds for activities that have been demonstrated

to be cost effective, such as conducting thorough
6

In the longer term, the new budget process that the

Commissioner is developing can integrate the agencys

stewardship activities with overall service requirements.

We strongly endorse this new approach to budgeting and look

forward to working with the agency and the Congress to produce

once again a budget that meets demonstrable public needs

and rightful expectations for high quality service.

periodic redeterminations of SSI eligibility and

collecting overpayments. For the last several

years the Congress has provided funding

outside the cap for continuing disability

reviews (CDRs) to determine whether

individuals who are on the disability rolls

continue to be disabled. These reviews are

currently showing a savings of $10 in benefits

for each $1 of administrative costs. SSA

should be given the funds that are needed to

perform these kinds of program integrity

efforts without sacrificing other critical aspects

of service to the public.

We recognize that when the agency has

insufficient resources to do all of its work,

authorizing funds to be used for specific types

of activities has the potential for causing

important work to be put aside in favor of the

work that has been funded. As an example,

State disability administrators have expressed

concern that, because of the special funding for

CDRs that the agency has been given, they are

being asked to give priority to conducting

CDRs rather than determining eligibility for

new claimants at a time when initial

applications for benefits are growing.

We have heard from many within SSA that

too often the agency has lurched from one

priority workload to another, causing

confusion among employees in the field and

distortions in work processes. It is critically

important that the agencys priorities be

established coherently so as to prevent such

distortions. The legislation for special funding

that we advocate should be carefully crafted with

the objective of achieving both efficiency and

service quality.

In the longer term, the new budget process

that the Commissioner is developing can

integrate the agencys stewardship activities with

overall service requirements. We strongly

endorse this new approach to budgeting and look

forward to working with the agency and the

Congress to produce once again a budget that

meets demonstrable public needs and rightful

expectations for high quality service.

We have heard from many

within SSA that too often

 the agency has lurched

from one priority workload

to another, causing

confusion among employees

in the field and distortions

in work processes. It is

critically important that the

agencys priorities be

established coherently so as

to prevent such distortions.
Few outside of the Social Security

Administration have a good understanding of

the massive scale of the work that the agency

performs. Most think of the agency as a

simple check writing operation. The reality is

far different.

A. SSAs workloads are

massive and will become

more so

In fiscal year 2001, the agency processed

18.1 million applications for Social Security

cards. It received 3.1 million applications for

Retirement and Survivors Insurance, and

1.7 million applications for Disability

Insurance. SSA also received about

1.6 million applications for SSI disability and

160,000 applications for SSI benefits based on

age. It conducted 1.7 million continuing

disability reviews and made 11.6 million

changes of address.

The agencys 1,300 field offices had

26.5 million visitors. About 86 million calls

were placed to the agencys 800 number, and

approximately an equal number went to field

offices.

Simple workload numbers such as these do

not fully convey the magnitude of the effort

that is required to carry them out. Most of the

work performed by SSA and State disability

agency employees demands a high level of

knowledge and skill and close attention to

detail. For example, although processing a

retirement claim is often relatively

straightforward, many involve complex or timeconsuming actions, such as establishing spousal

relationships in cases involving common-law

marriage or proof of age for claimants born

outside of the United States.

Processing a disability claim is nearly

always complex, requiring establishment of a

date of onset of the disability, the gathering of

medical evidence and work history, and sifting

through and rationalizing any conflicts in

evidence. Applications for SSI benefits always

require determining the claimants income,

assets, citizenship, place of residence, and

living arrangements. Processing applications

for Social Security cards for individuals born

outside the United States requires authenticating

documentation that proves they have a right to

a card issued in their name.

As shown below, the agencys current

workload statistics reflect the rapid growth that

has been occurring and is expected to accelerate

in the decades to come.

II. THE NEED FOR BETTER STEWARDSHIP

WILL CONTINUE TO GROW

Simple workload numbers...do not fully convey the magnitude

of the effort that is required to carry them out. Most of the

work performed by SSA and State disability agency

employees demands a high level of knowledge and

skill and close attention to detail.

7
Recent program growth

Over the last decade, the number of people

receiving Social Security and SSI benefits grew

at a rate significantly faster than the population

as a whole. In 2001, about 46 million people

received Social Security benefits, including

about 39 million beneficiaries of retirement or

survivors benefits and about 6.8 million DI

beneficiaries. This represented growth of about

14 percent over the number of beneficiaries in

1990, compared with a growth of 10.7 percent

for the population as a whole.

The growth in beneficiaries was largely

accounted for by the DI portion of the program.

Over the period 1990-2001, the rate of growth in

the number of retirement and survivors

beneficiaries was slightly less than for the

population as a whole. But the growth in the DI

rolls was dramatic. The number of beneficiaries

receiving DI benefits grew by 61 percent during

this time period. Growth in the number of

individuals receiving Federally administered SSI

benefits was also dramatic, increasing from

4.8 million in 1990 to 6.7 million in 2001, an

increase of 39 percent.

Projected future growth

This rapid growth in the rolls will accelerate

as the baby boom generation ages. Between

2000 and 2020 the general population is

expected to grow by about 16 percent, but the

number of Social Security beneficiaries is

expected to grow by 53 percent. (Chart 1)

The growth in the SSI program is projected

to be considerably slower, at 21 percent. More

than 9 out of 10 applications for SSI are for

disability, however, so even a moderate rate of

growth has important consequences for SSAs

administrative resources because of the laborintensive nature of making complex disability

determinations.

8

...growth in the rolls will accelerate as the baby boom generation

ages. Between 2000 and 2020 the general population is

expected to grow by about 16 percent, but the number of Social

Security beneficiaries is expected to grow by 53 percent.

Another factor affecting SSAs workloads

is the increasing diversity of the population,

requiring a wider range of language skills than

the agency has had in the past. The size of the

U.S. population that is foreign-born grew from

14.1 million in 1980 to 19.8 million in 1990

and 28.4 million in 2000. Field offices all

across the country, even in rural areas, are

finding it necessary to hire bilingual employees

or to contract with interpreters. SSA now has

employees who speak more than 90 languages.

60

50

40

30

20

10

0

 1980 1990 2000 2010 2020

Chart 1. Number of OASI,

DI and SSI Beneficiaries*

CY 1980 - 2020

(in millions)

OASI

DI

SSI

* SSI and OASDI numbers are not additive.

Some individuals receive benefits under

both programs.
As recommended by the National

Performance Review in 1993, SSA has also

reduced its management-staff ratio, from 1:7 in

1993 to 1:14 in 2001. We have heard from

many employees in the field that the agencys

current dearth of managers and supervisors is

having a significant and negative impact on the

quality of work, particularly in the agencys

field offices. As one field office manager told

the Board, Employees are making more

mistakes because managers are not available to

answer questions, provide training, and review

work. The heavy burden that some managers

now carry is making their jobs unattractive to

the point that recruiting able replacements for

those who choose to retire is becoming

increasingly difficult.

C. Major areas of the

 agencys work need to

 be strengthened

Taxpayers who support SSAs programs

want and deserve to know that their tax dollars

are being accurately accounted for and

expended. Beneficiaries want their payments to

be accurate so that they do not have the

inconvenience or hardship of dealing with either

an overpayment or an underpayment.

SSAs dedicated employees understand and

want to meet these public expectations and

needs. A field office manager told the Board:

Quality of work is a big issue for us. No one

has told us not to value quality. But pressure

for speed and volume now predominates.

B. While the agencys

workload has grown, its

resources have been

drastically reduced

Since 1982, SSA has experienced a 26

percent decline in the number of employees.

SSAs field operations have experienced an

even greater reduction. Between 1982 and

2001, the number of employees in regional and

field offices, teleservice centers, and program

service centers fell by 28 percent, from 60,000

to 43,000. (Chart 2)

100

90

80

70

60

50

40

30

20

10

0

Total

 * Includes full-time, part-time, temporary,

 seasonal, and student employees as of the end

 of the fiscal year.

**Includes employees in regional and field offices,

program service centers, and teleservice centers.

FY 1975 - 2001

(in thousands)

 Chart 2. SSA On-Duty Employment* 1975 1980 1985 1990 1995 2001

Field**

9

Taxpayers who support SSAs programs want and deserve to

know that their tax dollars are being accurately accounted

for and expended. Beneficiaries want their payments to be

accurate so that they do not have the inconvenience or hardship

of dealing with either an overpayment or an underpayment.
The agency has undertaken a number of

initiatives aimed specifically at improving

management and reducing error and fraud. It

has issued reports on the disability and SSI

programs that describe the initiatives the

agency is making to improve program

management and integrity. Software

improvements have been made to increase the

speed and accuracy of wage reporting by

employers. The agency has supported staff

increases for the Office of the Inspector

General, enhancing its capacity to focus on

program integrity issues. Recent anti-fraud

initiatives by the OIG include projects being

conducted with the Immigration and

Naturalization Service (INS) and the

Department of the Treasury to detect incidents

where individuals have concealed assets or

foreign travel during the SSI redetermination

interviews, or have applied for a new or

replacement Social Security card using

fraudulent documentation of identity.

Despite the many important efforts that the

agency has been making, however, there are

critical areas where vast improvements remain

to be made. The following are among the most

urgent.

Integrity of the Social Security

number

Many of those who crowd into SSAs field

office waiting rooms across the country have

come to apply for a new or  more often  a

replacement Social Security card. In fact,

handling applications for new and replacement

cards is the largest category of work that field

offices perform. In fiscal year 2001, the

agency issued 18.1 million cards, a 16 percent

increase since 1997. Currently, about

32 percent of all Social Security numberrelated requests are for new cards and about

68 percent are for replacement cards for people

with existing numbers. (Chart 3)

The importance of the Social Security card

(or number) to the government and to any

individual who wants to work or transact some

other kind of business in the United States

cannot be overstated. Employers are required

to ask for an individuals Social Security

number (SSN) before hiring, and the number is

the identifier used in all claims for Social

Security or SSI benefits as well as for many

other Federal and State programs, such as

Medicare, Medicaid, and public assistance

20

15

10

5

0 1997 1998 1999 2000 2001

 Replacement New at Birth Other New

Chart 3. Social Security Cards Issued

FY 1997 - 2001

(in millions)

2.0 1.7 1.7 1.8 2.0

2.7 3.8 3.8

4.0 3.8

10.9 10.7 10.9 11.3 12.3

10

...handling applications for new and replacement cards is the

largest category of work that field offices perform. In fiscal

year 2001, the agency issued 18.1 million cards,

a 16 percent increase since 1997.
benefits. The IRS uses the SSN as an

identifier for most individual taxpayers, for

identifying taxpayer dependents, and for

tracking income and payroll tax contributions.

Many States use it in their individual drivers

license systems. Many businesses and

organizations in the private sector, including

banks and credit card companies, also depend

on the Social Security number as an identifier

for maintaining their records.

SSAs performance standards for issuing

cards reflect a concern for both speed of

issuance and accuracy. With regard to speed,

the agencys statistics show that in fiscal year

2001, 96.8 percent of SSN applicants were

advised of their assigned SSN within 24 hours

of initial processing. Agency statistics for

2000 show that 99.8 percent of numbers were

issued accurately.

Nonetheless, SSAs Office of the Inspector

General has expressed a high level of concern

about the integrity of the agencys enumeration

process. It points out that given the

importance of the Social Security number,

many unscrupulous individuals have a strong

motive for fraudulently acquiring a number and

using it for illegal purposes. According to the

OIG, Social Security numbers have been

associated with all 19 of the September 11

hijackers. Although the investigation is

continuing, it has been determined that at least

five of them had multiple Social Security

numbers. It is not yet known whether SSA

assigned any of these numbers. Invalid or

nonexistent SSNs have been associated with the

names of the 14 other hijackers. As the IG noted

in the most recent semiannual report to

Congress, It quickly became apparent just how

instrumental the use of fraudulent Social

Security numbers has been for these individuals,

who rely on aliases and assumed identities to

integrate themselves anonymously into our

society.

Problems that the OIG has identified include

use of an illegally obtained number to receive

government services or benefits, obtain

employment, or enter the country. They also

include identity fraud  the use of another

individuals number to steal their identity and

commit crimes, usually financial crimes, in that

persons name.

Among other concerns, the OIG has

criticized the agencys procedures for validating

identity documents that are used by individuals

to illegally obtain cards. In 1999,

PriceWaterhouseCoopers conducted an

independent study that also found that SSAs

front-end controls for enumeration were

deficient. In one recent review the OIG

conducted, it found that significant numbers of

cards had been issued based on invalid or

inappropriate evidentiary documents presented

as evidence of age, identity, citizenship, or legal

alien status. These included INS forms that were

never issued, and forms that INS had issued to

individuals other than the SSN applicants, or

had issued with a different alien classification.

SSA had also assigned many SSNs to applicants

whose U. S. birth certificates were counterfeit.

...SSAs Office of the Inspector General has expressed a high

level of concern about the integrity of the agencys

enumeration process. It points out that given the importance

of the Social Security number, many unscrupulous

individuals have a strong motive for fraudulently acquiring

a number and using it for illegal purposes.

11
The OIG concluded that SSA employees in

the field do not have adequate training or the tools

they need to determine the validity of evidentiary

documents. Some within SSA have observed,

however, that SSA employees should not be

expected to be experts in identifying the highly

sophisticated false documents that are now

commonly available.

One SSA executive observed that new

approaches are needed for functions like

enumeration, recommending that the agency

consider establishing enumeration centers  local

offices that would specialize in enumeration and

have staff with the appropriate expertise to do the

job thoroughly and accurately. Others have

recommended that SSA and INS offices be

co-located, so that SSA could benefit from the

expertise that is available in INS.

The Board has heard repeated complaints

about the poor coordination that now exists

between SSA and INS. SSA employees are

instructed to check with an online INS system to

determine whether the documents that an alien

SSN applicant has presented are valid, but the

INS verification system is not up-to-date and is

limited in scope, often requiring that suspect

documents be sent to INS for validation. This

manual process can take several months.

The Inspector General has identified

replacement Social Security cards as an area of

special concern. The number of replacement

cards issued annually has grown by more than

25 percent since 1991. A recent OIG report noted

that over a recent one-year period in which SSA

issued over 11 million replacement cards, the

agency issued three or more cards to more than

35,000 people. In notable examples, the OIG

reported that SSA had issued 20 replacement

cards to a two-year-old child and 10 to a 90-

year-old woman, speculating that in both cases

someone else was obtaining the cards for their

own purposes. A field office employee told the

Board, We have people who come in week after

week.

12

The Board has heard repeated complaints about the poor

coordination that now exists between SSA and INS. SSA

employees are instructed to check with an online INS system

to determine whether the documents that an alien SSN

applicant has presented are valid, but the INS verification

system is not up-to-date and is limited in scope....

According to an OIG audit

of 1998 data, if the agency

included major errors in its

calculations, the SSN accuracy

rate would have been

90.7 percent rather than

the 99.8 percent that was

claimed by the agency

for that year.

 The OIG has also criticized the manner in

which SSA has used its performance measures.

The SSN accuracy rate reported by the agency,

for example, excludes major categories of errors,

such as inaccurate names, dates of birth, and

coding errors. In identifying erroneous SSNs,

SSA does not test the validity of evidence

presented by SSN applicants. According to an

OIG audit of 1998 data, if the agency included

major errors in its calculations, the SSN

accuracy rate would have been 90.7 percent

rather than the 99.8 percent that was claimed by

the agency for that year.
 SSA managers and employees have told

the Board of their own concerns about the

integrity of the SSN. They believe that many

of the documents they are seeing are not valid,

but as one field office employee noted, the

policy is, Unless you have a specific reason to

suspect the validity of a document, you should

go ahead and process. A field office manager

told the Board that false identity documents are

easily obtained. For example, a false drivers

license can be bought down the street, and

there is no cross check with the Department of

Motor Vehicles. Employees in one office the

Board visited recently observed that every

office follows its own processing procedures.

Some are stricter than others, and the result is

that people shop around for the office that is

most likely to issue a card.

One SSA executive told the Board that in

his area the selling of SSNs is one of the

agencys biggest stewardship problems. There

are gangs who routinely approach SSA

employees who might be vulnerable. These

gangs are sophisticated in finding out about

employees personal situations and they use this

information as leverage to coerce or entice

employees to steal SSNs or provide them with

personal information from SSAs databases

information that can then be used to establish

fraudulent identities.

Another problem that concerns many

employees is that, without a photo ID or some

form of biometric identification, neither of

which is required, there is no way they can be

sure that individuals who come into the office

are who they say they are. This is an issue that

goes beyond the issuance of an SSN and

includes individuals who claim benefits as well.

In response to the events of September 11,

the Acting Commissioner of Social Security

appointed an Enumeration Task Force to develop

proposals for strengthening the enumeration

process and a number of changes are being

implemented. One change the agency is

implementing is that an SSN will not be issued

to an alien who is not authorized to work but

only wants it to apply for a drivers license.

Field office employees are also receiving

refresher training on enumeration policy and

procedures.

The agency has stated that it will work with

the INS and with the Department of State to

implement an enumeration-at-entry program to

allow non-citizens to apply for an SSN as a part

of the immigration process. In addition, the

agency and the INS are developing several pilot

projects to allow employers to verify SSNs of

newly hired employees through automated

systems. Software changes planned for 2002-

2003 are being designed to interrupt issuances of

a Social Security card in certain abnormal

circumstances. In its performance plan for fiscal

year 2002, SSA states that it will reexamine the

enumeration process to determine how best to

balance its commitment to assign numbers

quickly with ensuring the integrity of the SSN.

For many years, Committees and Members

of Congress have emphasized the importance of

the integrity of the Social Security number and

the Social Security card. Hearings have been

held, and bills have been introduced. During the

last session of Congress the Chairman and

Ranking Minority Member of the House Social

Security Subcommittee, along with other

Members of Congress, introduced a bill to limit

the display by public and private entities of the

13

Another problem that concerns many employees is that, without

a photo ID or some form of biometric identification, neither of

which is required, there is no way they can be sure that

individuals who come into the office are who they say they are.
Social Security number, including on motor

vehicle licenses and registrations. It provided for

making refusal to do business without receipt of

an SSN an unfair or deceptive act or practice,

and provided new criminal penalties for misuse

of SSNs. In earlier years, the Congress passed

legislation requiring SSA to study the feasibility

of issuing a secure Social Security card. The

agency issued a report, but no action was taken.

SSAs reluctance to implement initiatives

that would slow down SSN processing likely

reflects a fear that such a move would be

unpopular with some employers and workers.

Employees in field offices have told the Board

that interviews with individuals who are applying

for SSNs  and who want them right away  are

the most contentious that they must face. There

is also a fear within the agency that more careful

checking of documentation or developing a more

secure card would require substantial additional

resources, which the agency does not currently

have.

Fraudulent use of the SSN has become a

significant public policy issue, an issue that is

expected to grow as the number of SSN-related

crimes continues to escalate. The FBI recently

recognized identity fraud as the fastest growing

white-collar crime in America and since

September 11 it has become a national security

concern as well. The Social Security number is

widely used and considered by many to be a

de facto national identification number.

Although many oppose the concept of a national

ID, the reality is that ensuring the integrity of the

SSN has become critically important to both

individuals and the government. SSA and policy

makers need to address the SSN integrity issue

more directly and forthrightly than they have

heretofore.

To improve the integrity of Social Security

cards issued to aliens, many in SSA believe that

Accuracy of disability

determinations

Of all the functions performed by SSA, none

is more complex and labor intensive than

determining whether an individual is eligible for

disability benefits. State disability agencies,

14

Enumeration is basically an

SSA responsibility and the

agency has an obligation to

develop a comprehensive

action plan to improve the

integrity of the process.

the INS is the appropriate government agency to

do the job. At the present time, however, the INS

appears to be unable to meet its current

responsibilities, much less take on new ones. In

addition, as indicated above, the problems related

to enumeration go beyond validating INS

documents for incoming aliens. Use of false

documents such as U.S. birth certificates is

reportedly becoming increasingly common, as is

acquiring multiple Social Security cards for a

child. As one field office manager stated, If we

tighten up on the foreign born procedures, well

just see a switchover to more fraud involving U.S.

born documentation.

Enumeration is basically an SSA

responsibility and the agency has an obligation to

develop a comprehensive action plan to improve

the integrity of the process. The consequences of

particular actions should be explicitly set forth so

that the merits can be openly debated. If the

agency finds that it will need additional resources

to carry out new initiatives, it should make the

urgency of its needs known to the President and

the Congress.

SSA and policy makers need to address the SSN integrity

issue more directly and forthrightly than they have heretofore.
circumstances, the fact that the claimant has no

opportunity to meet with the decision maker until

the face-to-face hearing at the ALJ level, and the

fact that the record remains open throughout the

appeals process.

But there is a widely held belief among

disability adjudicators and others who have

studied the disability programs that the agencys

own policies and procedures, as well as

organizational structure, are also significant

causes of inconsistency in decision making.

The question of whether the agencys

disability decisions are fair and accurate involves

large sums of money, both from the standpoint of

individual claimants and from the standpoint of

the government. According to SSAs actuaries,

the value to an individual over a lifetime of being

awarded Disability Insurance benefits is about

$80,000 in cash and $45,000 in Medicare

benefits. The value of SSI benefits is $40,000.

When Medicaid is included the value increases to

$60,000. In fiscal year 2002, estimated total

Federal expenditures for DI and SSI disability

cash benefits are estimated at nearly $95 billion.

Although SSA has no statistics as to the dollar

value of incorrect decisions either before or after

the appeals process, the cost of the agencys

incorrect decisions is likely quite high to the

government, in the case of incorrect allowances,

and to disabled individuals, in the case of

incorrect denials.

under regulations of SSA, make more than two

million initial disability determinations a year.

About half a million decisions are made each year

at the administrative law judge hearing level.

Disability work accounts for two-thirds of SSAs

administrative budget. It dominates the attention

of management at all levels of the organization.

15

Of all the functions performed

by SSA, none is more complex

and labor intensive than

determining whether an

individual is eligible for

disability benefits.

Providing the highest

possible quality of disability

decision making constitutes

one of the agencys most

difficult stewardship

challenges. As the Board has

emphasized in reports on SSAs

disability programs...there is

urgent need for improvement.

Providing the highest possible quality of

disability decision making constitutes one of the

agencys most difficult stewardship challenges.

As the Board has emphasized in reports on SSAs

disability programs issued in August 1998 and

January 2001, there is urgent need for

improvement.

Data developed by the Board show large

inconsistencies in decision making over time,

among regions of the country, and between State

agency and ALJ levels of adjudication.

Allowance and denial rates, both overall and for

specific impairment categories, vary widely from

State to State and region to region.

The inconsistencies that the Board has

documented raise fundamental questions about

whether claimants are being treated fairly. As the

Board has emphasized, some degree of

inconsistency can be explained by such factors as

differences in economic and demographic

See How SSAs Disability Programs Can Be

Improved, August 1998; Charting the Future of

Social Securitys Disability Programs: The Need for

Fundamental Change, January 2001; and Disability

Decision Making: Data and Materials, January

2001. These reports are available on the Boards

Web site at www.ssab.gov.

2

2
The complex disability adjudication process

is slow and difficult for claimants to negotiate.

As shown in Chart 4, a claimant who chooses to

appeal an initial decision to the reconsideration

and administrative law judge levels of appeal

will likely wait more than another year to get a

decision. Appeals are costly to claimants, most

of whom turn to an attorney to assist them with

their claim. They are also costly to the agency

16

and ultimately to taxpayers. In 2001, a decision

made at the ALJ level cost $2,157, more than

three and a half times the cost of an initial

decision at the State agency level ($583).

The Boards reports referenced above

describe the major shortcomings that we have

found in the present disability determination

system and our recommendations for how these

shortcomings could be addressed. As we make

clear, there is no simple fix.

SSAs administrative structure needs to be

strengthened to improve the agencys capacity to

provide appropriate leadership in areas of both

Chart 4. DI and SSI Claims Process:

Steps and Average Processing Time*

FY 2001

SOCIAL SECURITY

ADMINISTRATION

SSA Field Offices**

DI: 24.0 days

SSI: 32.2 days

Claimant starts here

STATE AGENCIES

Disability

Determination Services

Initial Decision***

DI: 90.3 days

SSI: 93.1 days

SSA Field Offices

Reconsideration 

DI: 25.8 days

Disability

Determination Services

Reconsideration** **

DI: 68.8 days Office of Hearings and Appeals:

Administrative Law Judges

 308 days 

Office of Hearings and Appeals:

Appeals Council

447 days

FEDERAL COURTS

18 months

 * Processing times shown above are additive.

 ** Field office processing time includes all components of the field office work, including taking the

 claim and processing it after the State agency makes a determination.

*** SSA reports DDS initial processing time by programs; average total processing time (DI and SSI)

 is not available.

**** SSA does not have data available for SSI reconsideration processing times.

SSA has the responsibility of paying attorney fees on

behalf of Social Security claimants. Fee amounts are

deducted from the benefit that is owed to the claimant.

In calendar year 2000, SSA paid fees to attorneys

totaling $512 million.

3

3
17

As noted above, the Administration and the

Congress should continue to provide the agency

with the funding it needs to conduct continuing

disability reviews to ensure that those who are on

the disability rolls continue to meet the Social

Security criteria for eligibility. SSA will be

required to conduct 11.6 million CDRs over the

next seven years if it is to comply with the law.

It is critical to the integrity of the program that

the agency conduct the reviews that the law

requires. The CDR process is highly cost

effective. SSAs actuaries estimate that it will

have saved $7.7 billion for the Disability

Insurance and SSI disability programs over the

seven-year period 1996-2002.

policy and procedure. The agencys current

quality assurance system is of limited value in

analyzing overall performance and in providing

information that can be used to improve the

quality of the work that is being performed. The

agency needs to replace it with a new quality

management system that will produce the

comprehensive program information that policy

makers need to guide disability policy and

procedures and to ensure accuracy and

consistency in decision making. This information

should be available on an ongoing basis to all

those working within the system so that they can

identify problems early and do what is needed to

correct them.

Fundamental structural problems in the

current disability adjudication system need to be

addressed. Communication among the various

components of the system is poor. Field offices,

State disability agencies, hearing offices, and the

appeals council operate independently of one

another, with little or no feedback on how the

action of one level affects the efficiency or quality

of the process as a whole.

The Federal-State relationship needs to be

strengthened. Regulations should be revised to

require States to follow specific Federal guidelines

relating to educational requirements and salaries

for staff, training, carrying out quality assurance

procedures, and other areas that have a direct

impact on the quality of their employees and their

ability to make decisions that are both of high

quality and timely.

Reform of the hearing process needs to be

considered, including having the agency

represented at the hearing, closing the record after

the ALJ decision, and establishing new rules for

claimant representatives. The establishment of a

Social Security Court or Social Security Court of

Appeals should also be considered.

The Administration and the

Congress...need to address

the fundamental issue of the

current lack of alignment

between disability policy and

administrative capacity.

SSAs administrative structure needs to be strengthened to

improve the agencys capacity to provide appropriate

leadership in areas of both policy and procedure.

The Administration and the Congress also

need to address the fundamental issue of the

current lack of alignment between disability policy

and administrative capacity. Over the last decade

and a half SSA has issued numerous regulations

and rulings that require more time and expertise

on the part of disability adjudicators than was the

case in the past. The number of cases being

appealed to the Federal courts has been increasing

rapidly, and the courts have been remanding

growing numbers of cases to the agency. Some

agency executives have expressed their concerns

to the Board that SSAs credibility before the

Courts is in jeopardy. The concern the Board has

heard is that the agency needs to do a better job of

following its own rules and regulations.
18

But adjudicators in both State agencies and

hearing offices are faced with the fact that their

workloads are also growing rapidly and

resources are constrained. The result is that

there is a large gap between policy requirements

and the agencys capacity to meet these

requirements. To bridge it will require changes

in policy, structure, or resources, or  more

likely  in all three of these interrelated aspects

of the disability system.

Accuracy of SSI payments

Since 1997, when the General Accounting

Office added the SSI program to its list of

government programs at high risk of fraud,

waste, abuse, and mismanagement, SSA has

given increased attention to the problem of

inaccuracy in SSI payments. Despite SSAs

efforts to improve the SSI determination and

redetermination processes, however, the 2000

overpayment accuracy rate of 93.6 percent is

only fractionally above the 1998 level of 93.5

percent. Both of these rates are below those

reported in earlier years. For example, in fiscal

year 1991, the SSI overpayment accuracy rate

stood at 96.3 percent. Underpayments are also

a problem, although of lesser magnitude. The

underpayment accuracy rate for 2000 was

 98.6 percent. In 1991, it was 98.9 percent.

In 2001 SSA detected overpayments of

nearly $2 billion. In 2000 (the last year for

which data are available) underpayments were

estimated at $440 million. (Chart 5)

SSAs payment accuracy reviews show that

wages are the leading cause of overpayments,

accounting for about one-fourth of all

...adjudicators in both State agencies and hearing offices are

faced with the fact that their workloads are...growing rapidly

and resources are constrained. The result is that there is a large

gap between policy requirements and the agencys

capacity to meet these requirements.

overpayment dollars in 2000. Most of these

overpayment dollars are due to fluctuating

wages. Financial accounts represent another 18

percent of overpayment dollars, most of which

result from the increasing value of the account

since the last field office contact. Changes in

living arrangements and wages together account

for nearly 60 percent of underpayment

deficiencies.

Although overpayments and underpayments

are a more readily identifiable problem, there is

also concern about SSI fraud. Studies by the

Office of Inspector General show that the use of

representative payees, middlemen, and third

party facilitators is a particularly troublesome

area, with representative payees improperly

collecting benefits on deceased recipients

records, and middlemen providing false

information to get non-English speaking

applicants on the SSI rolls. Fraud also occurs

through avoidance of reporting receipt of child 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001

Chart 5. SSI Overpayments*

and Underpayments

FY 1990 - 2001

(in billions of dollars)

* Overpayments shown have been detected by SSA.

Underpayments are estimated from samples.

Underpayments

2.5

2.0

1.5

1.0

0.5

0

Overpayments
19

support and providing false residency

information. Some prisoners and fugitive felons

are also illegally collecting benefits.

The agency points to a number of initiatives

that it is pursuing to improve payment accuracy,

including gaining easier access to bank account

balance information; improving the quality of

SSI adjudications, particularly redeterminations;

and improving efficiency in identifying and

processing changes that affect payments.

But as the agency has acknowledged, up to

now the initiatives it has taken have been offset

by resource constraints, which have limited its

ability to take the corrective actions that are

necessary to avoid payment errors. For

example, in April 2000 fifty of SSAs field

offices participated in a pilot program that

involved matching wage data contained in the

database of the Office of Child Support

Enforcement (OCSE). A match with SSI

records can reveal possible undisclosed income.

A cost-benefit analysis showed that requiring all

field offices to use the OCSE online database for

redeterminations would yield a benefit to cost

ratio of 8.5 to 1. However, it would require an

additional 300 work years. SSA therefore

decided to limit its use to certain initial claims,

where it was found to have a benefit-cost ratio

of only 3.6 to 1. This example illustrates the

incongruity of the agencys actions when its

resources are too limited to do the necessary

work.

...as the agency has

acknowledged, up to now the

initiatives it has taken have

been offset by resource

constraints, which have

limited its ability to take

the corrective actions that

are necessary to avoid

payment errors.

Although conducting redeterminations is

one of the most useful mechanisms that the

agency has to prevent and identify SSI

payment errors, over the last decade program

growth has far outstripped the growth in the

number of redeterminations. Over the period

1990  2001, the number of SSI beneficiaries

increased by 39 percent, but the number of

redeterminations increased by only 10 percent.

(Chart 6) In recent years, however, the agency

has attempted to make the redetermination

process more efficient by increasing the

number of redeterminations of cases that it

believes are at high risk of error. The agency

reportedly has concluded that field offices do

not have sufficient resources to handle more

redeterminations than they are currently

assigned.

Chart 6. Number of SSI Beneficiaries

and Number of Redeterminations

FY 1990 - 2001

(in millions)

199019911992199319941995199619971998199920002001

8

6

4

2

0

Beneficiaries

Redeterminations

Some employees have told the Board that the

profiles SSA has been using to identify the

individuals who should be called into the office

for a redetermination need to be improved and

the agency is working to refine its criteria. The

agency has stated that its data also indicate the

need to do a more thorough job of conducting

redeterminations than has been done in the past,

so that errors are more likely to be found and

rectified.
higher priority on processing and paying claims

than on controlling expenditures by verifying

financial eligibility and deterring fraud and abuse.

Both the GAO and the OIG have stated that

SSA needs to commit more time and energy to

training field office employees who do the

frontline work of obtaining and verifying

information from SSI applicants. Both have also

urged the agency to change the way it measures

work so as to provide rewards for preventing

overpayments and fraud as well as rewarding the

processing of claims.

As the result of its own work, the Board

believes that the concerns of the GAO and OIG

are well-founded, and that the agency needs to

take appropriate action.

Collection of overpayments

Although the percentage of Social Security

benefits that SSA reports as being paid in error is

very small, even small percentages of error

translate into billions of dollars paid incorrectly.

In fiscal year 2001, the amount of overpayments

to beneficiaries of the Old-Age, Survivors, and

Disability Insurance programs totaled $1.6 billion.

Together with the SSI overpayments noted above,

SSA paid a total of $3.5 billion in error in that

year. (Chart 7)

Between 1991 and 2001, the annual amount

of overpayments collected by the agency grew

from $1.1 billion to $1.9 billion, but the amount

of overpayments detected more than doubled,

from $1.4 billion to $3.5 billion. During this

period the amount of SSAs total outstanding

overpayments grew by 133 percent, from $3

billion in 1991 to $7 billion in 2001. (Chart 8)

Throughout SSAs field operations there is widespread concern

about the agencys capacity to properly administer the SSI

program. In a 1999 survey of field office managers, half of

those who responded rated the quality of the SSI claims work

that was being done in their offices as only fair or poor.

20

Throughout SSAs field operations there is

widespread concern about the agencys capacity

to properly administer the SSI program. In a

1999 survey of field office managers, half of

those who responded rated the quality of the SSI

claims work that was being done in their offices

as only fair or poor. Sixty percent rated SSI

postentitlement work as fair or poor.

In our visits to field offices, employees have

told the Board that they sometimes do not

pursue certain lines of questioning, such as the

details of an individuals living arrangements,

because it takes too long to resolve the issues

that may be raised. They have told us that they

are also unable to process reports of earnings or

changes in living arrangements as promptly as

they should because interviewing claimants who

are sitting in an overcrowded waiting room is a

higher priority.

A number of agency employees have told

the Board that many SSI claims are currently

being paid based largely on allegations. They

recommended that more information be obtained

at the initial interview to ensure correct

entitlement to benefits.

These comments reflect the fact that policies

relating to eligibility for SSI, like those for most

means-tested programs, are complex and

difficult to administer. The General Accounting

Office has criticized the agency for failing to be

more proactive in dealing with SSI problems and

in carrying out its planning and policy

development role.

The GAO has also observed that the agency

harbors an organizational culture that places a
1991

1992199319941995199619971998199920002001

8

7

6

5

4

3

2

1

0

Chart 8. Overpayment Balance At

End of Fiscal Year

1991-2001

(in billions of dollars)

21

Chart 9. Number of Overpayments Pending

in Field Offices at End of Fiscal Year

1990-2001

(in thousands)

Both field offices and program service

centers have responsibility for taking actions to

collect overpayments. SSA field offices are

responsible for actions related to overpayments

to current SSI beneficiaries and to Social

Security beneficiaries who request a waiver,

reconsideration, or an explanation of the

overpayment. The number of individuals who

were overpaid but whose cases were pending

action in field offices at the end of the fiscal

year grew by 72 percent between 1990 and

Chart 7. Annual Amount of

Overpayments Detected

FY 1990-2001

(in billions of dollars)

199019911992199319941995199619971998199920002001

4.0

3.5

3.0

2.5

2.0

1.5

1.0

0.5

0

OASI

DI

SSI

2001. Despite this growing workload, the

number of field office work years devoted to

working on overpayments declined by 23

percent. (Charts 9 and 10)

Debts to the government such as the amount

of overpayments owed to SSA have prompted

Congressional action. Over the last decade the

Congress has authorized government agencies to

use a number of collection tools that have

increased substantially their ability to collect

debt. SSA has been gradually implementing

these tools, beginning with the implementation of

the tax refund offset program in 1992, which is

now being used to collect delinquent debts for

both the Social Security and SSI programs. The

tax refund offset program was later expanded to

allow the collection of a Social Security debt

from a Federal payment other than a tax refund.

To date, these two devices have produced $535

million in debt collections.

OASI

DI

SSI

Another tool that has been authorized and is

being used for both the Social Security and SSI

programs is reporting delinquent debts to credit

bureaus. In addition, SSA expects to implement

a pilot of administrative wage garnishment for

both programs in the relatively near future.

This will allow SSA to serve garnishment orders

directly upon a debtors employer.

350

300

250

200

150

100

50

0

199019911992199319941995199619971998199920002001
22

With respect to SSI, the agency recently

implemented two new tools: collection of a debt

from another Federal payment an individual is

due, and cross program recovery. Cross

program recovery will allow SSA to collect the

debt owed by a former SSI beneficiary from

any Social Security benefits due that person.

Three tools that have been authorized for

Social Security and SSI but for which

implementation is not yet scheduled include

collecting debt from an individual who is a

Federal employee by withholding from the

employees salary, charging interest, and using

private collection agencies.

 SSA has told the Board that

implementation of the numerous tools that have

been authorized is labor intensive, requiring

Debts to the government such as the amount of overpayments

owed to SSA have prompted Congressional action. Over the

last decade the Congress has authorized government agencies

to use a number of collection tools that have increased

substantially their ability to collect debt. SSA has

been gradually implementing these tools....

Because of resource

limitations, SSA has followed

a policy of implementing

those collection tools that the

agency thinks will have the

biggest payoff, but progress

has been too slow.

199019911992199319941995199619971998199920002001

5

4

3

2

1

0

Chart 10. Number of Work Years

Used On Overpayment Actions

FY 1990-2001

(in thousands)

coordination among components of SSA and

between SSA and other agencies. Implementing

these new collection tools also requires new

systems developments. Because of resource

limitations, SSA has followed a policy of

implementing those collection tools that the

agency thinks will have the biggest payoff, but

progress has been too slow.

Not all overpayments are subject to the use

of SSAs collection tools. The law provides that

Social Security and SSI beneficiaries who are

overpaid may request a waiver. Under the statute

SSA has authority to grant a waiver and forego

recovery if it finds that the beneficiary is without

fault in causing the overpayment and that

recovery of the overpayment would defeat the

purpose of the Social Security Act or is against

equity and good conscience. If a debt has been

waived there are no additional attempts to collect it.

As a result of granting waivers or of a

determination by the agency that for various

reasons the debt cannot be collected, the amount of

debt written off by the agency each year has
more than tripled over the last decade, from

$293 million in 1991 to $940 million in 2001.

(Chart 11)

The Office of Inspector General has raised

questions about SSAs waiver practices. In a

sample review of Social Security waivers

granted by the agency between August 1996 and

June 1997, the OIG found that nearly nine

percent of the waivers were incorrectly granted

and half were inadequately supported. An SSA

executive recently told the Board that field

offices often do not pursue overpayment

collection because the staffs are too busy. It is

easier for them to waive the debt.

Collecting overpayments is highly

cost-effective. According to SSA, the cost of

collecting a dollar of overpayments is currently

about 11 cents. SSA should be moving much

more effectively and aggressively to collect

overpayments if it is to properly discharge its 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001

1.0

0.8

0.6

0.4

0.2

0

SSI

DI

OASI

Chart 11. Overpayments Written Off

FY 1990 - 2001

(in billions of dollars)

23

stewardship responsibilities. It should move

rapidly to implement fully all existing authorities.

Collecting overpayments promptly is in the

interests of both taxpayers and future

beneficiaries.

Accountability of representative

payees

Currently, about 6.5 million, or 13 percent of

Social Security and SSI beneficiaries, have their

benefits paid to representative payees. About 4.2

million representative payees manage benefit

payments for these beneficiaries.

Since 1939, the law has authorized the

agency to appoint a representative payee if it

determines that payment of the benefit in this

form is in a beneficiarys interest. Beneficiaries

who have representative payees are generally

those who have mental or physical impairments,

are incapable of exercising good financial

judgment, or are a minor child.

Most representative payees are relatives of

the beneficiary. Others are unrelated individuals

and governmental or non-profit organizations.

There are 850 non-profit social service

organizations that charge beneficiaries a fee for

the representative payee services that they

provide. Their fees are limited by statute to the

lesser of 10 percent of an individuals monthly

benefit or, in 2002, $30 a month ($57 a month

for alcoholics and addicts).

The number of representative payees

appointed by the agency has been growing

rapidly. Between 1990 and 2000, there was a

23 percent increase in the number of Social

Security beneficiaries who have representative

An SSA executive recently told the Board that field offices often

do not pursue overpayment collection because the staffs

are too busy. It is easier for them to waive the debt.
24

payees. The number of SSI beneficiaries with

payees rose 67 percent. (Chart 12)

According to SSA, the growth in payees

reflects the increase in the number of beneficiaries

who have been diagnosed with mental impairments.

In addition, for the SSI program, the trend reflects

an increase in the number of children receiving

SSI payments. (After 1996, however, the number

of SSI beneficiaries declined because of legislative

changes that reduced the number of children, drug

addicts and alcoholics, and aliens who are eligible

to receive benefits.)

Chart 12. Number of Beneficiaries With

Representative Payees*

CY 1985 - 2000

(in millions)

8

7

6

5

4

3

2

1

0

1985199019952000

SSI

OASDI

representative payees. For example, legislation

enacted in 1990 required SSA to make a more

extensive investigation of representative payee

applicants than the agency had done in the past. It

specified strict standards for the agency to follow

in determining the fitness of individuals who apply

to serve as a representative payee.

Despite these statutory protections, a

1995-96 Representative Payment Advisory

Committee established by SSA raised concerns

about the agencys policies for determining whether

payees are needed, how payees are selected, and

how SSA educates payees about their

responsibilities. In its 1996 report the Committee

stated, It is clear that SSA places a premium on

speedy case processing to get payments out quickly.

In a December 2001 report the OIG similarly

observed that SSA is not performing background

checks of payees to determine whether they have

financial problems, bad credit, or have been

convicted of a felony. In addition, it noted that

SSAs systems do not effectively track payees who

do not respond to and complete the required

representative payee reports.

In May 2000, the Inspector General told the

House Ways and Means Social Security

Subcommittee that representative payee activities

are a workload that gets deferred in field offices.

It is not addressed because there are other

priorities that interfere.

* Both sets of numbers include beneficiaries who receive

benefits from both programs concurrently. Data for the

total number of beneficiaries with representative payees

(OASDI and SSI combined) are not available on a

historical basis.

Under the law, representative payees must  ̄

• expend funds only for the beneficiarys

use and benefit,

• report any event that will affect the

benefit amount or eligibility, and

• provide an annual written report

explaining how benefits were used.

The agencys implementation of

representative payee requirements has been

problematic for many years. The Congress has

tried to build in statutory protections to guard

against harmful or fraudulent actions by

In May 2000, the Inspector

General told the House

Ways and Means Social

Security Subcommittee that

representative payee activities

are a workload that gets

deferred in field offices.

It is not addressed

because there are other

priorities that interfere.
SSAs own employees have also raised

concerns about the quality of representative

payees. They have told the Board that pressures

to move the work make it difficult or impossible

for them to spend the time they need to

investigate carefully the qualifications of

potential payees, and applicants claims are

ordinarily not verified. The Board has heard the

recommendation that SSA establish standardized

procedures for selecting payees and provide

better orientation for payees concerning their

responsibilities.

In recent years there have been notorious

cases of abuse. The Aurora Foundation, a feefor-service payee servicing disabled individuals

in West Virginia, embezzled over $300,000 in

Social Security benefit funds between April

1995 and May 1999. SSA never performed an

onsite review of the company. Another fee-forservice organization operating in Phoenix and

Denver misused $275,000 of 330 beneficiaries

payments.

SSA has recently taken steps to improve its

administration of the representative payee

program. It has initiated a program of triennial

on-site reviews of all fee-for-service payees, all

other organizational payees serving 100 or more

beneficiaries, and all individual payees serving

20 or more beneficiaries. It has also said that it

will conduct a sample review of other volume

payees. In addition, the agency has begun to

verify annually that fee-for-service payees meet

the statutory requirement that they be licensed or

bonded. An agency executive told the Board,

however, that SSA is just scratching the surface

on organizational payee problems. The

problems are deep and it will take a tremendous

amount of staff time to resolve them.

25

SSAs own employees have also raised concerns about the quality

of representative payees. They have told the Board that pressures

to move the work make it difficult or impossible for them to spend

the time they need to investigate carefully the qualifications of

potential payees, and applicants claims are ordinarily not verified.

An agency executive told the

Board...that SSA is just

scratching the surface on

organizational payee

problems. The problems are

deep and it will take a

tremendous amount of staff

time to resolve them.

Chart 13. Number of Work Years Used

On Representative Payee Actions

FY 1990 - 2001

199019911992199319941995199619971998199920002001

3,500

3,000

2,500

2,000

1,500

1,000

500

0

The initiatives that SSA has undertaken to

provide better oversight of institutional and

other large-scale payees are urgently needed. In

addition, however, there are 5.5 million

beneficiaries whose well being is dependent

upon the diligence and integrity of individual

payees. It is a matter of concern that although

the agencys representative payee workload

grew by 28 percent between 1990 and 2001, the

number of work years devoted to handling that

workload declined by 20 percent. (Chart 13)
26

1991 $10,095 3.4

1992 $11,795 4.0

1993 $15,180 4.8

1994 $16,671 5.1

1995 $19,059 5.6

1996 $22,748 6.1

1997 $26,779 6.5

1998 $31,998 7.1

1999 $41,636 8.4

 Tax Year Suspended Number of

 Wages Suspended

 Wage Items

Table 1. Uncredited Wages Added to

SSAs Earnings Suspense File

1991-1999

(in millions)

It seems clear that if vulnerable beneficiaries

are to be protected from misuse of benefits, the

agency will need to devote considerably more

resources to the task of screening and monitoring

payees than it has done heretofore.

The agency urgently needs to determine the

steps it needs to take to improve the quality of its

work with respect to representative payees. It

also needs to make the case for the additional

funding it needs to do a proper job.

Proper reporting and posting of

wages

The accuracy of the wage records

maintained by SSA is critically important to

workers. These records determine whether an

individual has earned enough wage credits to be

eligible for benefits and the amount that will be

paid. SSA has always regarded the collection and

maintenance of wage records as a matter of the

highest importance and has handled them with

care.

SSA is able to credit the great majority of

wages to the correct workers record.

According to SSA, about 99 percent of earnings

and 98 percent of individual wage items (W-2s)

have been posted correctly to a workers

earnings record.

The accuracy of the wage

records maintained by SSA

is critically important to

workers. These records

determine whether an

individual has earned

enough wage credits to be

eligible for benefits and the

amount that will be paid.

...the amount of wages that

cannot be assigned is

substantial and

has been growing.

Despite this, the amount of wages that

cannot be assigned is substantial and has been

growing. SSA maintains a record of all wages

reported by employers that the agency has been

unable to credit to an individual worker due to

inadequate or incorrect information. SSAs

record, called the Earnings Suspense File (ESF),

covers the period from 1937 to the present. At

the end of tax year 1999, there were more than

227 million wage items in the ESF.

These wage items represented $328 billion

in wages that have not been credited to a

workers record. In 1999, about 8.4 million

wage items, involving $41.6 billion in wages,

went into the ESF, compared to 3.4 million wage

items and $10.1 billion, in 1991. (Table 1)
The information that SSA uses to credit

wages comes from wage reports submitted

annually by employers using the Treasury

Departments W-2 forms. If the name and

Social Security number reported by an

employer exactly match a record for a worker

in SSAs Master Earnings File, SSA posts the

wages that are reported to that workers file.

As indicated by the numbers cited above,

however, the number of instances in which this

cannot be done has been growing rapidly.

There are various reasons for the errors

that are being made. Some are due to simple

mistakes in reporting, such as an employers

misstatement of the workers Social Security

number or misspelling the name. Others may

represent situations in which workers do not

want to be identified and give the employer

inaccurate information. This may be because

they are working illegally or because they do

not want to be identified for income tax

purposes. In still other cases, employers appear

to be knowingly making erroneous reports.

SSA, both on its own and in conjunction

with the Internal Revenue Service, conducts

seminars around the country to assist employers

in learning to file wage records and taxes

accurately. In addition, SSA will provide

employers with software to help them submit

their wage reports electronically. The agency

operates an Enumeration Verification Service

that allows employers to verify the validity of

names and Social Security numbers given to

them by employees.

Most employers, about 88 percent, report

their workers earnings accurately. Another

nine percent submit reports with five or fewer

errors. However, a relatively small number of

employers (about 3,000 in 1997) submit reports

with 200 or more errors. These 3,000

employers accounted for 30 percent of wage

items reported in error and 20 percent of the

dollars that went into the agencys Earnings

Suspense File because they could not be

attributed to a workers account. Some of these

27

Most employers, about 88

percent, report their workers

earnings accurately.

Another nine percent submit

reports with five or fewer

errors. However, a relatively

small number of employers

(about 3,000 in 1997)

submit reports with

200 or more errors.

reports unquestionably reflect simple error, but

work by the OIG has shown highly disturbing

patterns of reporting by certain employers.

In a study of the 100 employers with the

largest number of wage items going into the

Earnings Suspense File during the period 1993-

1996, the OIG identified a number of suspicious

patterns of reporting errors. Ninety-six of the

employers reported workers Social Security

numbers that have not been assigned. One

employer submitted 663 records with an SSN of

000-00-0000. Another pattern involved the use

of duplicate numbers for different workers. For

example, a temporary services agency reported

the same Social Security number for 215

employees and another number for 50 or more.

SSA has established several routines to try to

resolve discrepancies in wage reports. The first

is a purely electronic routine that assumes that

the name is correct and that the Social Security

number is scrambled. It reconfigures the digits in

the SSN and looks for a match with a name and

SSN in its Master Earnings File. If one and only

one exact match is found, the wages are posted to

that file. This routine resolves about 80 percent

of the errors and allows these earnings to be

posted to a workers record.
Wage items not resolved by this routine are

placed in the Earnings Suspense File. For tax

year 1999, this was 3.4 percent of all items

received, up from 2.6 percent in 1994. (Table 2)

These unresolved items are sent to SSAs

Wilkes-Barre, Pennsylvania Data Operations

Center where additional routines are tried.

Some of these are performed only once a year.

One of them assumes that the SSN is correct

and that the name is improperly recorded. Staff

attempt to find a name in the files that the wage

item goes with. This would include such things

as misspelled names, names recorded in the

wrong order, and use of nicknames on the W-2.

Another routine involves mailing letters to

employees for whom there is a name and address

notifying them of the discrepancy. If there is no

address for the employee, the letter is sent to the

employer.

28

For tax year 1999, after all routines were

completed, the agency was still unable to credit

to a workers account more than 8 million of the

wage items submitted by employers. Some of

these, however, may yet be identified after

additional information is received or after the

development and application of new screening

routines.

The cost of processing a wage item that is

not correctly submitted is high. The OIG, using

a statement in 1998 by SSAs senior financial

executive, has cited an estimate of $300 per

item. While there is some disagreement about

whether this number is still accurate, it

nonetheless far exceeds the cost of a correctly

submitted item, which is about 23 cents.

Over the last two years the OIG has issued

five reports on the problems that exist with the

Earnings Suspense File and related SSN issues.

It is working on another six reports. The OIG

has recommended that SSA seek authority to

apply substantial monetary penalties to

employers who repeatedly submit large

numbers of invalid wage items. SSA has

declined to seek this authority on the grounds

that IRS already has it and is the appropriate

agency to take this action. It has written to the

IRS urging it to consider imposing penalties on

problem employers. The IRS has expressed

concern about applying penalties because of the

complexity and difficulty in determining

whether an employer has exercised appropriate

diligence in obtaining the necessary

information.

The OIG has also recommended that SSA

seek legislative authority to share SSAs

information with INS regarding chronic

employer offenders, many of whom the OIG

and others believe to be employers of illegal

aliens. The implicit assumption is that, along

with improving the accuracy of reporting, the

information would be used by INS in enforcing

immigration law. SSA has disagreed with this

recommendation, suggesting that this would be

inconsistent with the purposes of the Social

Security program and SSAs disclosure

policies.

The fact that the amount of uncredited

wages is growing so rapidly is cause for

concern, and both SSA and the IRS need to

take responsibility for reversing this trend. The

work of the OIG indicates clear and deliberate

disregard of reporting requirements on the part

of some employers, which in some instances is

undoubtedly covering up the hiring of

individuals who are not eligible to work in the

United States. The growth in uncredited wages

 Tax Year Number Percent

 of Items Placed in

 Reported Suspense File

Table 2. Percent of Wage Items

Added to Earnings Suspense File

1994 - 1999

(Items in millions)

1994 226.5 2.6%

1995 228.9 2.7%

1996 232.2 2.8%

1997 238.3 2.8%

1998 245.3 3.0%

1999 248.0 3.4%
also means that a substantial number of

potential future beneficiaries will be

shortchanged. This situation requires the close

attention of both the Administration and the

Congress. The Federal government needs to be

far more aggressive than it has been in the past

in dealing with this problem.

SSA has undertaken several initiatives that,

although they are unlikely to reduce significantly

the size of the ESF, should facilitate and

improve the reporting process. It is encouraging

employers to file their reports electronically. In

2001, more than a quarter of all reports were

filed this way. It is also planning to expand the

use of its voluntary Employee Verification

Service, which is available to employers to help

them in verifying the names and SSNs of new

hires. New internal data matching routines are

being developed to assist in posting wages to the

appropriate record.

The problem of uncredited wages may be

alleviated to some degree by the fact that SSA is

now sending an annual Social Security Statement

to all workers age 25 and over for whom they have

an address. This will give these workers an

opportunity to review their records and to ask

SSA to make any necessary corrections.

Making these corrections may be problematic,

however, if employers records are not properly

maintained.

Although SSA, IRS, and INS all have a

role, it is incumbent on SSA to show leadership

on this issue. It must assess what it needs in

terms of additional authorities and resources and

make the effort needed to secure them. SSA

29

SSA needs to be a more

forceful advocate for the

contributors to the Social

Security program, getting

the earnings records that

will be the basis for

their benefits right.

SSAs massive and complex computer system contains

confidential information related to every Social Security

and SSI beneficiary and every employee who has wages that

are covered by Social Security. Preventing illegal access

to this confidential information and protecting it from

fraudulent use is of the highest importance.

needs to be a more forceful advocate for the

contributors to the Social Security program,

getting the earnings records that will be the basis

for their benefits right.

Issues related to systems security

SSAs massive and complex computer

system contains confidential information related

to every Social Security and SSI beneficiary

and every employee who has wages that are

covered by Social Security. Preventing illegal

access to this confidential information and

protecting it from fraudulent use is of the

highest importance.

SSA is continually working to address

systems vulnerabilities that could lead to

unauthorized access to, or sabotage of, its

records. Its security program includes an

authentication process that users must complete

prior to accessing SSA systems, an audit trail

system that can identify individuals who have

accessed or processed specific records and

identify suspected problems, firewall
30

SSAs regional Centers for Security and

Integrity carry out their security and integrity

responsibilities nationwide. It will be the

responsibility of the Chief Information Officer,

once one has been appointed for the agency, to

provide oversight and guidance for systems

security agency-wide.

Systems security is an area to which the agency must devote

a high level of attention and effort. If additional expertise

is needed in either SSAs headquarters or the field,

it should be secured by the agency as promptly as possible.

technology to protect the network, and

continuous monitoring of the network.

Examination of SSAs system by outside

auditors, however, has indicated that there

continue to be security problems that need to be

addressed. An audit report issued by

PriceWaterhouseCoopers in November 2001

noted that although SSA has continued to make

improvements to its security program and

standards, there are several weaknesses that

could expose SSAs systems and networks to

unauthorized access to sensitive data. The report

included a number of recommendations for how

SSA should continue to improve its information

security framework. In a June 2001 report, the

General Accounting Office reported that

information infrastructure weaknesses persist

in SSAs systems.

The OIG has recommended measures that

the agency should take to improve security,

including performing background checks on SSA

employees and contractors to protect its most

sensitive data, limiting employee access to those

on a need to know basis, implementing more

stringent physical security measures at all SSA

facilities to protect employees, and continuing to

perform risk and possibly vulnerability

assessments.

Several components of the agency are

involved in systems security. The Office of

Finance, Assessment and Management is

responsible for systems security policy; the

Office of Systems is responsible for

implementing the policy; and the Office of

Operations is responsible for making sure that

Examination of SSAs

system by outside auditors...

has indicated that there

continue to be security

problems that need

to be addressed.

SSA employees have told the Board that the

agency needs to give people in the field more

guidance than they are currently providing.

Regional offices around the country vary in the

amount of resources they have available to deal

with systems security issues. They are

developing their own processes and procedures

for systems security, leading to different

processes and procedures in different regions.

There is concern that they lack the technical

expertise needed to carry out their

responsibilities as well as they should be doing.

Systems security is an area to which the

agency must devote a high level of attention and

effort. If additional expertise is needed in either

SSAs headquarters or the field, it should be

secured by the agency as promptly as possible.
A. Improve SSI and disability

program policies

For many years, the high level of

complexity of SSI and disability policies has

been a source of frustration for the workers

who are responsible for administering them.

The pressures for ever-faster processing of

caseloads mean that errors both of omission

and commission inevitably occur. Speed tends

to take precedence over quality and, most

importantly, production numbers take

precedence over substantive concerns.

III. WHAT NEEDS TO BE DONE TO FULFILL

THE AGENCYS STEWARDSHIP

RESPONSIBILITIES

For many years, the high

level of complexity of SSI

and disability policies has

been a source of frustration

for the workers who are

responsible for

administering them.

beneficiaries would also be receiving Social

Security benefits. During the discussions

leading up to enactment, the Congress was

assured that the agency would be able to take

on the additional administrative burden without

compromising its earlier high standards.

In fact, SSA badly underestimated the

difficulties it would experience in administering

the needs-based SSI program. At the time SSI

was enacted it was estimated that the aged

would constitute nearly three-quarters of the

caseload. In reality, in the early months of the

program approximately three out of every four

applications were for disability benefits, which

required far more work on the part of the

agency and the State Disability Determination

Services than had been anticipated.

Interviewing and making determinations of

income and resource eligibility for both aged

and disabled claimants required substantially

more time than had been budgeted by the

agency.

Responding to the crisis that ensued, SSA

requested a major increase in staffing (which

was partially granted) and instituted massive

use of overtime. Looking for ways to ease the

burden further, an SSI Study Group was

appointed, made up of a panel of specialists in

public administration and computer technology.

With staff support from SSA, the panel studied

SSIs policies, processes, and procedures.

This was the first of a series of special

panels or workgroups that over the last three

decades have been assigned the job of looking

for ways to simplify SSI policy. Although

some changes have been made as a result of

these efforts, through the years SSI policy has

tended to become more, rather than less,

complex. Some of this complexity has been

the result of legislative changes. Some has

Supplemental Security Income

program

When the Congress enacted the SSI

program in 1972, it gave SSA the responsibility

of administering the new program largely

because of the agencys record of providing

high quality service to aged and disabled

individuals and because it wanted the

individuals who were to become its beneficiaries

to receive this same high quality service. It was

assumed that SSA could fairly easily absorb

this new responsibility because estimates by the

agency indicated that a large portion of SSI

31
resulted from rules and regulations that the

agency itself has promulgated to address issues

that have arisen in administering the law.

 According to SSA, the initial interview for

some SSI applicants involves answering over

100 questions, and many answers require

supporting documentation. For beneficiaries,

eligibility and benefit amount may change with

changes in circumstances. Even small changes,

such as receipt of gifts of cash or clothing, must

be reported to the agency. In fiscal year 2001,

the agency processed over 8.2 million SSI

changes. As one field office manager

commented, It is ridiculous how we pursue the

minutiae of income and assets.

In fiscal year 2002, SSA is expected to

spend 36 percent of its total administrative

budget on administering the SSI program. But

despite the effort that the agency expends,

outstanding SSI debt and newly detected

overpayments continue to rise. Outstanding

debt totaled more than $3.4 billion at the end of

fiscal year 2001, compared with $1.1 billion at

the end of 1990.

As noted earlier in this report, wages are the

leading cause of SSI overpayment dollars and

resources are the second leading cause. SSAs

Office of Policy issued a detailed report in

December 2000 that analyzed options for

simplifying SSAs policies in both of these

areas. In January 2001, an agency-appointed

Unlike Social Security, which is funded out of

dedicated taxes paid by workers and employers, the

costs of SSI benefits and administration are paid

out of general revenues.

workgroup identified additional changes the

agency could implement to improve SSI

program integrity.

The options for change described by these

and previous agency-appointed study panels

have generally passed unnoticed by policy

makers. The limited changes that the agency

has implemented have most frequently involved

process changes, such as increased data

exchanges to identify unreported income and

assets, rather than changes in policy.

SSA needs to address the question of

whether continuing to rely on making relatively

easy to implement process changes like these

will achieve the improvements in payment

accuracy that the agency believes should be

made. It is our view that, in addition to such

changes, the agency should take the lead in

developing measures, however incremental, that

will change SSI policy rules so that they will be

less difficult for the agency to administer and

easier for applicants and beneficiaries to

understand and comply with. SSI rules are

currently causing considerable inconvenience

and hardship for many people. To the extent

possible, these problems should be alleviated.

Disability programs

The agency also urgently needs to conduct

a thorough review of disability policy rules and

regulations to determine where changes can and

should be made to improve the quality and

consistency of decision making. Attention

should be given to how these rules and

regulations can be written more clearly and

...the agency should take the lead in developing measures,

however incremental, that will change SSI policy rules

so that they will be less difficult for the agency to

administer and easier for applicants and

beneficiaries to understand and comply with.

32

4

4
The series of rulings issued by SSA in

1996 need close attention. These rulings are

commonly referred to as process unification

rulings, because they were aimed at bringing

State agency and ALJ decisions closer together.

Under these rulings adjudicators must

adhere to more detailed and intricate rules in

weighing the opinion of treating sources than

was the case in earlier years of the programs.

They must make a finding on the credibility of

claimants statements about the effect of pain

and other symptoms on their ability to function.

As we have emphasized in our earlier reports

on the disability programs, the effect of these

and other changes in policy is that disability

decision making by both State agency

examiners and administrative law judges has

become considerably more subjective and

complex.

The agency...urgently needs to

conduct a thorough review

of disability policy rules and

regulations to determine

where changes can and

should be made to improve

the quality and consistency

of decision making.

simply so that adjudicators in different regions

of the country and different levels of decision

making will interpret and use them in the same

way. Both medical listings and vocational

guidelines should be included in this review.

Adjudicators in State agencies have told the

Board that some of these rulings are so difficult

that State agency employees cannot adhere to

them without spending substantially increased

time on a large percentage of the cases they

are adjudicating. Some also require analytical

and writing skills that many employees do not

have.

The Board has also heard from

administrative law judges that the process

unification rulings establish standards for

developing cases that they believe over time will

be difficult for them to meet as well. The result

will likely be a continuing increase in the

number of cases taken to the courts on appeal.

The Board has previously recommended that

SSA bring together into a single policy unit

individuals with knowledge and experience in the

Office of Disability, the Office of Hearings and

Appeals, and the State disability agencies. If

employees who understand the work of these

offices participate in writing the agencys policy,

it is more likely to take into account the

important differences in the perspectives and

needs of adjudicators in both State agencies and

hearing offices. It is also more likely to be

interpreted and implemented uniformly

throughout the disability determination process.

We urge the agency to move forward as

expeditiously as possible in strengthening its

capacity to develop and oversee the

implementation of disability program policy.

In addition, given the history of the many

difficulties that SSA has had in carrying out the

disability policies that it has formulated, there is

a demonstrable need for the agency to institute a

policy of rigorously assessing the potential

impact of major policy changes before they are

We urge the agency to move forward as expeditiously as

possible in strengthening its capacity to develop and

oversee the implementation of disability program policy.

33
implemented. Over the last decade SSA has

tested many proposed changes in process, but it

has not tested important changes in policy for

their impact on claimants, on the administrative

structure, and on the integrity of the disability

programs.

The main point to be made is that SSAs

disability policies and procedures should be as

clear and administrable as possible so that

disability applicants are treated consistently and

fairly at all levels of adjudication and do not have

to wait an unreasonable time for a decision on

their claims.

B. Improve the tools the agency

uses to measure performance

and quality

A field office manager recently told the

Board, I like goals and objectives. Tell me what

it is the agency thinks is important, and we will

do it.

This can do attitude has long prevailed

throughout SSA and is an important source of the

agencys strength. But it can also be a weakness

if the agencys goals and objectives are not

realistic and carefully crafted.

As we have indicated elsewhere in this

report, many throughout SSAs organizational

structure believe that the measures the agency

uses are skewed toward speed and productivity

and away from other indicators that would

...many throughout SSAs organizational structure believe that

the measures the agency uses are skewed toward speed and

productivity and away from other indicators that would provide

a better approach to the work that the agency is doing.

Commenting on this problem, one agency executive told

the Board, Stewardship isnt part of service delivery yet.

We dont have qualitative standards.

provide a better approach to the work that the

agency is doing. Commenting on this problem,

one agency executive told the Board,

Stewardship isnt part of service delivery yet.

We dont have qualitative standards.

At the national level, SSA does have some

measures of the quality of work that is being

done in the field, but these are not what drive

performance. SSAs central office allocates

staffing among its regions on the basis of their

relative productivity, and regional offices in

turn rely largely on this same measure to

allocate staffing among field offices.

Managers throughout the system thus have an

overwhelming incentive to process work as

quickly as possible in order to protect their

staffing levels. There are no counterbalancing

measures of quality at the local level. Moving

the work is the guiding force, whether or not

the work is done well. Efficient processing is a

laudable objective, so long as quality of work

is also maintained.

Field office managers complain that they

rarely receive any information from the agency

that they can use to improve the quality of

work in their offices. Furthermore, because in

recent years the agency has greatly reduced the

number of managers and supervisors in the

field, they do not have time to review the work

that is being done in their offices and thus

cannot accurately assess the quality of work

that their employees are performing. This

means that they lack the information they need

to determine the kind of training they should be

providing.

34
In addition, experts from the private sector

whom the Board has consulted have advised us

that the agencys use of averages to measure

performance should be expanded to capture

information on a full range of performance.

This concern has also been raised by employees

in the field. A field office manager told the

Board, We are not very sophisticated in

analysis. Our data dont give us information on

outliers. By relying on averages, we dont get

an accurate picture. We need to understand the

effect of outliers.

It would seem essential that if SSA

genuinely wants to ensure the integrity of its

programs  which is one of the five goals set

forth in its strategic plan  it must put into

place a more useful set of measures to drive

performance in the field than it currently has.

It would seem essential that

if SSA genuinely wants to

ensure the integrity of its

programs  which is one of

the five goals set forth in

its strategic plan  it must

put into place a more

useful set of measures to

drive performance in the

field than it currently has.

Productivity is also a driving force in the

disability system, but here the situation is more

complicated. SSA constantly communicates to

the State disability agencies the need to meet

productivity goals, and the State agencies are

aware that how well they do in this regard will

influence the funding that the agency gives

them. But SSA also has a quality assessment

system that drives agency decision making.

Many who work in the disability system do

not believe that the current quality assessment

system accurately reflects the quality of the

work that is being done. They think that the end

of line review that the system provides is not

helpful in finding and correcting problems

before they occur.

An outside evaluation of this system by The

Lewin Group and Pugh Ettinger McCarthy

Associates completed last year concluded that

SSAs current system is of limited value in

analyzing overall performance and in providing

information that can be used to improve the

quality of decisions. What the evaluators

recommended, and the Board has supported, is

the replacement of the present quality assurance

system by a totally new quality management

system. The new system would require a

definition of quality that would have multiple

dimensions (accuracy, timeliness, efficiency,

customer service, due process), and would

provide information that can be used to improve

disability policy and the disability process. It

would identify variations in decision making by

various components in the system and provide

the information needed to address them.

Evaluation of SSAs Disability Quality Assurance

(QA) Processes and Development of QA Options

That Will Support the Long-Term Management of

the Disability Program, Final Report, Prepared by

The Lewin Group, Inc. and Pugh Ettinger

McCarthy Associates, L.L.C., March 16, 2001.

Many who work in the

disability system do not believe

that the current quality

assessment system

accurately reflects the quality

of the work that is being done.

They think that the end of

line review that the system

provides is not helpful

in finding and correcting

problems before they occur.

35

5

5
SSA has been making some tentative steps

toward endorsing the concepts of this kind of

quality management system, but thus far little

real progress has been made. The agency needs

to decide how it can employ the concepts of

quality management throughout the

organization, not simply with respect to the

disability system, and to follow through to do it.

We urge SSA to move forward promptly in this

effort and give it the high priority it deserves.

Again, if additional expertise is needed to

further this work, it should be provided.

SSAs leadership needs to make

fundamental changes in the way the agency

conducts its work so that quality becomes a

guiding principle for all aspects of its work.

C. Accelerate systems

improvements

In discussions with employees throughout

SSAs administrative system, the Board has

been told of many areas in which SSA could

expedite and improve the quality of its work if

its systems capabilities were improved.

One of the foremost examples is in the area

of disability. For many years SSA has been

working on developing and implementing the

capacity to create an electronic claims folder for

each person who applies for disability benefits.

The information in this electronic folder would

be accessible to adjudicators at each step of the

application and appeals process. The creation

of this new system would prevent lost

documents and speed up the transfer of

information from one level of the process to

another. SSA estimated in 1994 that it would

have a system in place by 2001, but it has had

to make fundamental changes in design and is now

suggesting that the new process will be ready in

2004, a full decade after it was first envisaged.

A major factor in the delay has been the

failure in the past to consult adequately with the

various components of the disability process so

that the needs and perspectives of each could be

taken fully into account. As the development of

the disability electronic folder system moves

forward, we strongly urge the agency to make

certain that all components are closely involved

in the design so that it will be developed

holistically and will facilitate the work of each

to the maximum extent possible.

There is widespread acknowledgement that

SSAs work measurement, management

information, customer satisfaction, and

performance measurement systems all need to be

improved, and all require significant systems

developments. New systems developments

would also be an integral part of the new quality

management system that the Board has

recommended, as described above.

In addition, there are many specific systems

tools that could be implemented or enhanced to

improve the integrity of the agencys work.

Among those that have been brought to the

attention of the Board are the ability to cross

check information about potential representative

payees, improve access to State birth and death

records, to military and Veterans Affairs

records, and numerous others.

Although these systems developments will

enable SSA to better manage its programs and

improve service to the public, it is unlikely that

As the development of the disability electronic folder system

moves forward, we strongly urge the agency to make certain

that all components are closely involved in the design so that it

 will be developed holistically and will facilitate the work

of each to the maximum extent possible.

36
37

they will result in significant reductions in the

agencys staffing needs.

In the past, SSA has generally justified its

systems investments to the Office of

Management and Budget and the Congress by

promising that they would increase production

and require fewer staff. We believe that the

agency should be cautious about expectations

for future large increases in productivity and

savings from systems improvements. SSAs

administrators and managers generally agree

that the steps that could produce a significant

payoff have already been taken.

But systems improvements that will enhance

the agencys stewardship of its programs are

critically needed, and we urge the agency, the

Administration, and the Congress to give them

the high priority that they deserve.

...systems improvements

that will enhance the agencys

stewardship of its programs

are critically needed, and we

urge the agency, the

Administration, and the

Congress to give them the

high priority that they deserve.

D. Expedite decision making

In our discussions with employees at all

levels of the agency we have heard many

recommendations for new approaches to

address stewardship responsibilities and some

of these have been formally proposed within

the agency. There is a high level of frustration,

however, about the fact that because the

agency is segmented into so many insular

components, it takes too long to decide whether

a proposal should be implemented, and even

after a decision is made, to put it into effect.

As one executive told the Board, We are too

stove-piped. It took SSA two and a half years

to implement a small pilot program.

Although we are not recommending the

implementation of any particular initiatives at

this time, we do urge the agency to work more

quickly and efficiently in assessing proposals

for change and in moving forward on those that

it finds worthwhile. This may require new

delineations of responsibility. Without

question, it will require better coordination and

teamwork. The complaint that the agency is

stove-piped and unable to take timely action

is one that the Board has heard many times

both within SSAs headquarters and in offices

throughout the country. It is a complaint that

needs to be addressed.

Many of the recommendations we have

heard from managers and employees relate to

changing business processes. One that the

Board has heard repeatedly is that the agency

should do more to identify problems before they

occur. For example, more thorough

interviewing and cross checking of data with the

IRS or other sources at the time of the initial

claimant interview would likely prevent many

overpayments, relieving the agency from the

time-consuming effort of trying to collect them

after they occur. An SSA executive told the

Board, The key is to prevent errors, not just to

find them.

One [recommendation] that

the Board has heard

repeatedly is that the agency

should do more to identify

problems before they

occur....The key is to

prevent errors, not just

to find them.
Particularly in the wake of the events of

September 11, many employees have a

heightened anxiety about the integrity of the

agencys work in issuing new and replacement

Social Security cards. As described earlier, the

Inspector General has made a number of

recommendations for enhancing SSN integrity

and the Board has also heard many

recommendations from employees in the field,

such as to require more reliable sources of

identification, validate the documentation that

is presented with issuing sources, limit the

number of replacement cards that an individual

can receive without special review, and charge

a fee for a replacement card.

The agency has already decided to

implement some short-term measures to tighten

up its SSN processes and has other, longerterm options under review. With respect to

these long-term options, the agencys

predilection for lengthy discussion and

protecting the turf of individual components

should be overcome so that decisions can be

swiftly made and implemented.

E. Become more aggressive in

working with other agencies

The agency should also determine how it

can enlist the help of other governmental and

non-governmental entities. There are many

recommendations for greater use of computer

matches to verify information. Clearly,

information in the records of the INS, the IRS,

and State welfare offices and departments of

vital statistics are extremely valuable to the

agency in conducting its work. Much

information is already being shared, but there

are areas in which processes could be greatly

improved. One example is acquiring electronic

38

access to up-to-date information from the INS

regarding individuals who have been admitted

to the United States so that SSAs employees

can quickly verify that applicants for Social

Security numbers are eligible to receive them.

As another example, electronic access to data

maintained by State Boards of Workers

Compensation would help the agency reduce

the number and size of overpayments and the

cost of developing and recovering those

overpayments. It could also speed the payment

of pending underpayments.

In addition to making greater use of data matching, SSA

should look for new ways to join with other agencies in

improving the quality and availability of services

to claimants and beneficiaries.

Greater access to electronic information from

other agencies and organizations may in some

instances raise concerns about privacy. SSA

should be prepared to work closely with these

other entities to ensure that privacy issues are

appropriately addressed.

In addition to making greater use of data

matching, SSA should look for new ways to join

with other agencies in improving the quality and

availability of services to claimants and

beneficiaries. In particular, in implementing the

new Ticket to Work program, the agency should

draw upon the expertise and resources of the

Departments of Education and Labor to the

maximum extent possible.

Clearly, information in the

records of the INS, the IRS,

and State welfare offices and

departments of vital statistics

are extremely valuable

to the agency in

conducting its work.
SSA, like most other government agencies,

has tended to look at its functions in isolation.

Although the agency has been making a greater

effort in recent years to build relationships with

other entities, this effort needs to be made a

higher priority so that these relationships will be

strengthened further. An agency executive has

commented to the Board that SSA is surprisingly

insular in the way it goes about its business.

This can and should be changed.

But other agencies will also have to be

convinced that working with SSA to better meet

the needs of the public is worthwhile. Where

warranted, the agency should turn to the

Congress and the Office of Management and

Budget for assistance in making interagency

cooperation and collaboration a high priority.

We urge the agency to take

the lead in identifying and

pursuing interagency efforts

that will provide better

service and also

be cost effective.

F. Ensure that maintaining the

integrity of the agencys

work is in practice a priority

When SSA issued its strategic plan for

2000  2005, it made ensuring the integrity of

Social Security programs, with zero tolerance

for fraud and abuse one of the agencys five

strategic goals. Yet many employees with

whom we have met have been outspoken in

their concern that the agency is not putting

sufficient emphasis on program integrity. They

hear a great deal from management about the

need to do a high quality job and they agree

with this objective. But in their understanding

of agency policy, processing cases quickly is a

higher priority.

In fact, the very wording of the goal

invokes cynicism. Given the level of resources

the agency has, employees in the field know

that zero tolerance for fraud and abuse is not

realistic. A goal that is honest rather than

rhetorical would be far preferable.

In addition, if the agency wants to convince

employees that program integrity is highly

valued, that message needs to be given real

substance. Perhaps the most effective way, as

we have noted above, is to make certain that

the work that is performed to improve program

integrity is reflected in the way the agency

measures performance and quality.

There are other things that the agency

should do as well. There should be more and

better training related to program integrity

39

When SSA issued its strategic plan for 2000  2005, it made

ensuring the integrity of Social Security programs, with zero

tolerance for fraud and abuse one of the agencys five strategic

goals. Yet many employees with whom we have met have been

outspoken in their concern that the agency is not putting

sufficient emphasis on program integrity.

We urge the agency to take the lead in

identifying and pursuing interagency efforts that

will provide better service and also be cost

effective. In some instances this effort would be

greatly expedited by having enabling legislation.

SSA should be forthright in asking the Congress

for new laws where it determines that this would

be helpful in improving the quality and integrity

of its work with respect to the issuance of Social

Security numbers and the administration of the

Social Security and SSI programs.
practice in their office. Nearly all employees

who made comments on quality and service

observed that there is far more emphasis on

doing the work quickly than on doing the work

right. Many commented that the loser here is

the public.

Actions by SSA such as those recommended

above should help to convince employees in the

field that the program integrity work that they

do is genuinely valued and is not a matter of

rhetoric. SSAs leadership throughout the

agency should reinforce this message by making

program integrity a consistent theme both in

their words and in their actions.

In a recent survey of

agency employees, 88 percent

agreed or strongly agreed

that To discharge faithfully

our role as guardians of the

public trust was an important

value for them. But only 63

percent agreed or strongly

agreed that it was currently a

normal practice in their office.

40

issues. This should begin with the initial

training that each employee receives and should

be reinforced by systematic follow up training

on an ongoing basis. The initial 13 to 14 weeks

of training that an SSA claims representative

currently receives includes only about two

hours specifically devoted to program integrity.

Although the agency has also developed special

Interactive Video Training (IVT) broadcasts for

the field, many employees say that their heavy

workloads make it difficult to find time to view

them. Managers and supervisors also lack the

time that is needed to reinforce IVT programs

and review the work that is done in their offices

to ensure that instructions are properly

followed.

Program integrity should also be made an

integral part of the agencys budget process.

Program integrity initiatives that the agency

proposes to carry out should be explicitly

identified and explained. Emphasizing program

integrity in this way will help to send a clear

signal both within and outside of the agency

that program integrity is a vital part of the

agencys operations.

The definition of program integrity that

SSA uses in its strategic plan currently includes

only payment accuracy. Given the importance

of the Social Security number to the integrity of

the Social Security and SSI programs, we

believe the agency should expand its definition

to include integrity in the issuance of Social

Security cards as well.

In our visits to field offices around the

country we have heard skepticism about the

sincerity of the agencys commitment to

program integrity. In a recent survey of agency

employees, 88 percent agreed or strongly agreed

that To discharge faithfully our role as

guardians of the public trust was an important

value for them. But only 63 percent agreed or

strongly agreed that it was currently a normal

G. Ensure that the agency has

sufficient staff with the right

skills to do the job right

If SSA is to be able to fulfill its stewardship

responsibilities, it needs to have sufficient staff

with the right skills to carry out the work that is

required. But as the Board has documented in

Organizational Culture Project, Final Report,

Office of Workforce Analysis, SSA, May 2000.

6

6
41

the reports it has issued over the last five years,

prolonged downsizing has resulted in serious

staffing shortfalls in key parts of the agency.

We have observed these shortfalls in offices

throughout the country, including field offices,

State disability agencies, hearing offices,

program service centers, and teleservice centers.

These are the offices that perform the

frontline work that is so vital to the integrity of

the Social Security and SSI programs. When

employees in these offices lack the time that is

needed to perform their work carefully and on

time, or when there are too few managers and

supervisors to train and mentor them, the quality

of the agencys work is immediately affected.

We have heard many examples of the

shortcuts that employees are often forced to make.

Employees in field offices have told us they

sometimes do not investigate the backgrounds of

prospective representative payees because their

first priority is to interview the claimants who

are sitting in the waiting room. They lack the

time to fully explain to persons applying for

retirement benefits how the month in which they

elect to begin benefits will affect the level of

benefits they will receive. Many field offices

have long waiting lines of applicants for Social

Security cards, making it difficult for employees

to spend the time that is necessary to thoroughly

check the validity of the documents that are

presented as proof of age, identity, citizenship,

or legal alien status.

As one of SSAs field office managers

summed up the current situation, We have

The agencys lack of sufficient staff to perform...basic

administrative functions is particularly frustrating and

counterproductive because often the inability to do work in a

timely way creates more work for the agency in the future.

embraced change. We are flexible and adaptable.

But we dont have enough people to do the job.

We have heard similar concerns in State

disability agencies, where examiners are pressed

to meet processing times that make it difficult or

impossible for them to gather all the evidence

that they should have to make accurate and fully

substantiated disability determinations.

SSA has instituted many rules and

procedures for finding and correcting errors

after they occur. For example, systems have

been designed to alert field office staff to take

action when unreported income is detected in the

cross checks of data that are conducted with

other Federal and State agencies. But pressures

to handle more urgent and immediate work make

it difficult for employees to find the time to

follow up on these alerts and take the action that

is required as promptly as they should.

 Often timely action is not taken even when

beneficiaries dutifully follow the agencys rules

and report changes in their circumstances. The

Board recently was told of a case in which an

SSI beneficiarys admission to a nursing facility

was reported to the agency both by telephone

and by letter. The law requires that when a

beneficiary is in a Medicaid nursing facility, the

benefit is automatically reduced to $30 a month.

But five months later, when the beneficiary left

the nursing home and returned to her own home,

the agency still had not acted to reduce the

benefit.

The agencys lack of sufficient staff to

perform these basic administrative functions is

particularly frustrating and counterproductive
Most of the agencys field office managers think that the

quality of the work their offices are performing is

declining. In addition to lacking sufficient staff to carry

out basic functions, they themselves have more

responsibilities than they can adequately handle.

because often the inability to do work in a timely

way creates more work for the agency in the

future. For example, as in the case cited above,

the agency could avoid having to go through the

labor-intensive and time consuming work of

collecting overpayments if employees were able

to take action immediately upon receiving

information relating to changes in income or

living arrangements.

If the agency had additional resources it

could also be performing work that would be

highly cost effective. Last year, agency officials

recommended a number of program integrity

initiatives that were estimated to save significant

amounts of program dollars at relatively low

administrative cost. Some are being

implemented, but others have been deferred

because of lack of staff to carry them out. One

of the proposals was to increase the number of

SSI redeterminations by one million. This was

projected to cost about $62 million. By targeting

the redeterminations on cases identified as prone

to high error, the agency expected to produce

$260 million in prevented or recoverable

overpayments, a return of more than 4:1.

The agency proposed to make an even larger

return on investment by providing enough staff

resources in field offices to speed up action on

computer alerts that identified increases in

income or assets that might affect benefit levels.

It was estimated that an investment of $5.2

million would produce taxpayer savings of $66

million, or a return of nearly 13:1. But both of

these actions had to be deferred because of lack

of sufficient staff to carry them out.

The agency recently appointed a workgroup

to identify workloads in field offices that are

underfunded. The objective was to develop

short-term tools for identifying these workloads

so that they can be considered in the budget

formulation process. Performing this kind of

research and analysis is important to the

credibility and usefulness of the agencys

budget submissions.

42

If the agency had additional

resources it could also be

performing work that would

be highly cost effective.

Most of the agencys field office managers

think that the quality of the work their offices are

performing is declining. In addition to lacking

sufficient staff to carry out basic functions, they

themselves have more responsibilities than they

can adequately handle. The drive over recent

years to reduce the agencys management-staff

ratio has left many field offices with a severe

deficiency in management and supervisory

capacity.

 In a survey conducted in March 2001 by the

National Council of Social Security Management

Associations (NCSSMA), more than 77 percent of

managers said that quality had declined in the last

five years. Over half of responding managers

attributed the decline to five factors, four of which

related to staffing limitations: reduction in the

number of supervisory management staff,

reduction or elimination of case reviews, decrease

in staff training time, and staff shortcuts. The

other reason given was the increasing complexity

of workloads.
A follow-up survey of field office and

teleservice management conducted in

December 2001 found that over 97 percent of

respondents agreed or strongly agreed that the

agencys emphasis on meeting processing goals

is causing burnout and affecting employee

morale, and that management lacks the time to

provide training or to perform the quality

reviews necessary to ensure the accuracy and

integrity of the Social Security and SSI

programs.

Although the most apparent staffing

deficiencies are in the field, staffing also needs

to be enhanced in other important areas of the

agencys responsibilities. The Board has noted

in its previous reports on the disability

programs the negative effect that downsizing

has had on the agencys capacity to develop

disability policy. SSA should put high priority

on strengthening its disability policy staff,

including staff that will increase the medical

and vocational expertise of the agency.

Other areas of policy development and

evaluation need to be strengthened, as does the

agencys capacity to develop and implement

systems improvements. Many who work in

State disability agencies and the Office of

Hearings and Appeals have told the Board that

they believe systems developments could be

accelerated if the agency would contract out

more of its work to the private sector,

particularly work relating to the disability

determination process. The agency should

consider how it can make more effective use of

outside expertise.

SSA is also sorely deficient in the number

of Senior Executive Service (SES) positions

that it needs to carry out the leadership

functions in the agency. When the Congress

enacted legislation in 1994 to make SSA an

independent agency, the House-Senate

conference committee noted in its report that

the number of SES positions the agency had at

that time was low in proportion to its

responsibilities and the size of its staff. It

stated that it expected that SSAs allotment

would increase as an independent agency,

commensurate with the agencys increased

stature and responsibilities.

Since that time, SSAs requests to the

Office of Personnel Management (OPM) for

additional SES slots have been extremely

modest. Even so, OPM has not granted the

full increases that have been requested. Thus

far, the number of SES positions the agency

has been given is well below the needs of an

independent agency with the wide-ranging and

complex responsibilities that SSA has. When

SSA was transferred out of the Department of

Health and Human Services in the Spring of

1995, it was given only 104 SES positions.

Over the last seven years OPM has slowly

raised the agencys allotment to 131 positions.

According to data for 2000 (the latest

available), SSA and the Departments of

Transportation and Health and Human

Services have roughly comparable staffing

levels, in the range of 63,000  64,500. But

SSA has only 131 SES positions, compared

with 246 for the Department of Transportation

and 540 for HHS.

Compounding the problem, data for 2000

show that SSA ranks at the bottom of all major

agencies in the number of GS-15 positions as a

proportion of employees. About 5.6 percent of

employees at the Department of Health and

Although the most apparent staffing deficiencies are in

the field, staffing also needs to be enhanced in other important

areas of the agencys responsibilities....SSA should put high

priority on strengthening its disability policy staff....

43
Human Services are GS-15s, but at SSA fewer

than one percent of employees have that rank.

Last year, SSA appealed to OPM to increase

its allocation of SES positions by an additional

39 positions, for a total of 170 agency-wide. The

agency provided OPM with detailed justification

for this increase, but so far its request has not

been granted.

the staff qualifications the agency believes that

it needs to serve the public appropriately and

meet its stewardship responsibilities. They

should reflect careful long-term planning and

should be fully documented so that OMB and

the Congress can understand the implications of

the funding decisions that they make.

As we observed earlier in this report, SSAs

administrative budget for Social Security, like

its program budget, should be excluded from

any cap that sets an arbitrary limit on

discretionary spending. This change in

accounting does not mean that the agencys

budget would be exempt from close scrutiny by

policy makers. It would continue to be subject

to the review of the Congress, which would

determine the agencys funding levels as part of

the regular appropriations process.

In addition, agreement should be reached to

provide funding outside the discretionary

spending cap for activities that are demonstrably

cost-effective. Spending caps should not apply

where savings in benefit outlays more than

offset administrative expenditures. Current

spending limitations are having the effect of

saving administrative dollars at the expense of

program dollars. This is counterproductive

from the standpoint of taxpayers, and

contributes to increases, rather than decreases,

in the Federal budget deficit.

...SSA is facing many urgent

policy and administrative

issues, and addressing these

issues will require strong

leadership. The Commissioner

cannot do the job alone. The

agency must have a strong

senior management team. We

urge OPM to act quickly to

meet SSAs needs by increasing

the agencys SES allotment to a

more reasonable number in

relation to its leadership

requirements.

44

...agreement should be reached

to provide funding outside the

discretionary spending cap for

activities that are demonstrably

cost-effective. Spending caps

should not apply where savings

in benefit outlays more than

offset administrative

expenditures.

As we have documented in our reports, SSA

is facing many urgent policy and administrative

issues, and addressing these issues will require

strong leadership. The Commissioner cannot do

the job alone. The agency must have a strong

senior management team. We urge OPM to act

quickly to meet SSAs needs by increasing the

agencys SES allotment to a more reasonable

number in relation to its leadership requirements.

Finally, the agencys budget proposals to the

Office of Management and Budget and the

Congress should reflect the staffing levels and
The Social Security Administration needs to have a more realistic view of its responsibilities. Although

its mission was expanded many years ago with the enactment of the Disability Insurance and SSI programs,

many in the agency still think of SSA primarily in terms of the Social Security retirement and survivors

program. While it is true that this aspect of the agencys work is still predominant in terms of the

magnitude of its benefit expenditures, most of SSAs management and operational challenges increasingly

relate to the DI and SSI programs.

The agency has been slow to acknowledge the fact that administering the DI and SSI programs is not

only more complex and labor intensive than administering the retirement and survivors program, but

requires a different approach as well. Employees need different skills. Claimants with mental or physical

impairments often require considerable assistance in documenting their claims. To determine eligibility and

benefit amounts accurately, interviews must be far more extensive and much of the information that is

provided should be verified.

Employees in the field who are responsible for doing the frontline work are deeply troubled by the fact

that staffing levels are inadequate, and the management information, systems, and other tools needed to do

high quality work are simply not available to them.

Without adequate resources and the right tools, field employees know they cannot do what the agency

says they should do. Although these employees remain highly dedicated and concerned about the public

they serve, there is increasing frustration at being caught in an anomalous situation that appears to be

without solution. All aspects of the agencys work are affected. The work required to perform good

stewardship is particularly likely to be short-changed in the effort to move the work.

It is vital that the agency face up to the reality of this situation. Most of SSAs service delivery

problems  of which stewardship problems are an integral part  are directly linked to the inability of

employees to spend the time they need to conduct interviews carefully, educate claimants about program

rules and options, and verify the information they are given.

The agency is devoting increasing attention and resources to solving problems after they occur, but

much more needs to be done to prevent them from occurring in the first place.

SSA will be better able to do this if it will adopt a culture of candor and openness so that problems will

be forthrightly acknowledged. There also needs to be a greater willingness to yield turf in the interest of

the needs and objectives of the agency as a whole, so that decisions can be reached more quickly.

Candor within the agency needs to carry over to the agencys relationship with the Office of

Management and Budget and the Congress as well. For many years, SSA has heralded what it can do, and

it can take justifiable pride in many aspects of its work. But it must also acknowledge what it cannot do, so

that it can explain to policy makers the improvements it needs to make and what will be required to make

them possible.

Addressing the agencys stewardship problems will require difficult decisions and setting new directions

as well as additional resources. We urge the Administration and the Congress to give the agency the

support it needs, so that it can move quickly and aggressively to fulfill its many responsibilities.

IV. CONCLUSION: SSAS STEWARDSHIP PROBLEMS

REQUIRE PROMPT AND AGGRESSIVE ACTION

45
Establishment of the Board

In 1994, when the Congress passed legislation establishing the Social Security Administration as an

independent agency, it also created a 7-member bipartisan Advisory Board to advise the President, the

Congress, and the Commissioner of Social Security on matters relating to the Social Security and

Supplemental Security Income (SSI) programs. The conference report on this legislation passed both

Houses of Congress without opposition. President Clinton signed the Social Security Independence and

Program Improvements Act of 1994 into law on August 15, 1994 (P.L. 103-296).

Advisory Board members are appointed to 6-year terms, made up as follows: 3 appointed by the

President (no more than 2 from the same political party); and 2 each (no more than one from the same

political party) by the Speaker of the House (in consultation with the Chairman and Ranking Minority

Member of the Committee on Ways and Means) and by the President pro tempore of the Senate (in

consultation with the Chairman and Ranking Minority member of the Committee on Finance). Presidential

appointees are subject to Senate confirmation. Board members serve staggered terms.

The Chairman of the Board is appointed by the President for a 4-year term, coincident with the term of

the President, or until the designation of a successor.

Members of the Board

Stanford G . Ross, Chairman

Stanford Ross is a partner in the law firm of Arnold & Porter, Washington, D.C. He has dealt

extensively with public policy issues while serving in the Treasury Department, on the White House

domestic policy staff, as Commissioner of Social Security, and as Public Trustee of the Social Security and

Medicare Trust Funds. He is a Founding Member and a former Director and President of the National

Academy of Social Insurance. Mr. Ross has provided technical assistance on Social Security and tax

issues under the auspices of the International Monetary Fund, World Bank, and U.S. Treasury Department

to various foreign countries. He has taught at the law schools of Georgetown University, Harvard

University, New York University, and the University of Virginia, and has been a Visiting Fellow at the

Hoover Institution, Stanford University. He is the author of many papers on Social Security and Federal

taxation subjects. Term of office: October 1997 to September 2002.

Hal Daub

Hal Daub is currently a partner with the law firm of Blackwell Sanders Peper Martin in Omaha,

Nebraska and Washington, D.C. Previously, he served as Mayor of Omaha, Nebraska from 1995 to 2000,

and as an attorney, principal, and international trade specialist with the accounting firm of Deloitte &

Touche from 1989 to 1994. Mr. Daub was elected to the United States House of Representatives in 1980,

and reelected in 1982, 1984, and 1986. While there he served on the Ways and Means Committee, the

Public Works and Transportation Committee, and the Small Business Committee. In 1990, Mr. Daub was

appointed by President George H.W. Bush to the National Advisory Commission on Public Service. From

1997 to 1999, he served on the Board of Directors of the National League of Cities, and from 1999 to 2001

served on the Leagues Advisory Council. He was also elected to serve on the Advisory Board of the

THE SOCIAL SECURITY ADVISORY BOARD

46
47

U.S. Conference of Mayors, serving a term from 1999 to 2001. From 1971 to 1980, Mr. Daub

was vice president and general counsel of Standard Chemical Manufacturing Company, an

Omaha-based livestock feed and supply firm. A former member of the U.S. Army, Mr. Daub is a

graduate of Washington University in St. Louis, Missouri, and received his law degree from the

University of Nebraska. Term of office: January 2002 to September 2006.

Martha Keys

Martha Keys served as a U.S. Representative in the 94th and 95th Congresses. She was a

member of the House Ways and Means Committee and its Subcommittees on Health and Public

Assistance and Unemployment Compensation. Ms. Keys also served on the Select Committee on

Welfare Reform. She served in the executive branch as Special Advisor to the Secretary of Health,

Education, and Welfare and as Assistant Secretary of Education. She was a member of the 1983

National Commission (Greenspan) on Social Security Reform. Martha Keys is currently

consulting on public policy issues. She has held executive positions in the non-profit sector,

lectured widely on public policy in universities, and served on the National Council on Aging and

other Boards. Ms. Keys is the author of Planning for Retirement: Everywomans Legal Guide.

First term of office: November 1994 to September 1999; current term of office: October 1999 to

September 2005.

David Podoff

David Podoff is visiting Associate Professor at the Department of Economics and Finance at

the Baruch College of the City University of New York. Previously he was Minority Staff Director

and Chief Economist for the Senate Committee on Finance. He also served as the Committees

Minority Chief Health and Social Security Counselor and Chief Economist. In these positions on

the Committee he was involved in major legislative debates with respect to the long-term solvency

of Social Security, health care reform, the constitutional amendment to balance the budget, the debt

ceiling, plans to balance the budget, and the accuracy of inflation measures and other government

statistics. Prior to serving with the Finance Committee he was a Senior Economist with the Joint

Economic Committee and directed various research units in the Social Security Administrations

Office of Research and Statistics. He has taught economics at the University of Massachusetts and

the University of California at Santa Barbara. He received his Ph.D. in economics from the

Massachusetts Institute of Technology and a B.B.A. from the City University of New York. Term

of office: October 2000 to September 2006.

Sylvester J. Schieber

Mr. Schieber is Director of the Research and Information Center at Watson Wyatt Worldwide,

where he specializes in analysis of public and private retirement policy issues and the development

of special surveys and data files. From 1981 to 1983, Mr. Schieber was the Director of Research

at the Employee Benefit Research Institute. Earlier, he worked for the Social Security

Administration as an economic analyst and as Deputy Director at the Office of Policy Analysis.

Mr. Schieber is the author of numerous journal articles, policy analysis papers, and several books

including: Retirement Income Opportunities in An Aging America: Coverage and Benefit

Entitlement; Social Security: Perspectives on Preserving the System; and The Real Deal: The

History and Future of Social Security. He served on the 1994-1996 Advisory Council on Social

Security. He received his Ph.D. from the University of Notre Dame. Term of office: January

1998 to September 2003.
48

Gerald M. Shea

Gerald M. Shea is currently assistant to the president for Government Affairs at the AFL-CIO. He

previously held several positions within the AFL-CIO, serving as the director of the policy office with

responsibility for health care and pensions, and also in various executive staff positions. Before joining the

AFL-CIO, Mr. Shea spent 21 years with the Service Employees International Union as an organizer and

local union official in Massachusetts and later on the national unions staff. He was a member of the

1994-1996 Advisory Council on Social Security. Mr. Shea serves as a public representative on the Joint

Commission on the Accreditation of Health Care Organizations, is a founding Board member of the

Foundation for Accountability, Chair of the RxHealth Value Project, and is on the Board of the Forum for

Health Care Quality and Measurement. He is a graduate of Boston College. First term of office: January

1996 to September 1997; current term of office: October 2000 to September 2004.

Members of the Staff

Margaret S. Malone, Staff Director

Michael Brennan

Beverly Rollins

George Schuette

Wayne Sulfridge

Jean Von Ancken

David Warner
Reports and Statements Issued By The Board

1. Challenges Facing the New Commissioner of Social Security, Statement by Stanford G. Ross,

December 2001.

2. Annual Report Fiscal Year 2001, October 2001.

3. Estimating the Real Rate of Return on Stocks Over the Long Term, Papers presented to the

Social Security Advisory Board, August 2001.

4. Social Security: Why Action Should Be Taken Soon (Revised Edition), July 2001.

5. Statement on the Supplemental Security Income Program, Additional Statement by the Social

Security Advisory Board in the Annual Report of the Supplemental Security Income Program,

Social Security Administration, May 2001.

6. Agenda for Social Security: Challenges for the New Congress and the New Administration,

February 2001.

7. Charting the Future of Social Securitys Disability Programs: The Need for Fundamental

Change, January 2001.

8. Disability Decision Making: Data and Materials, January 2001.

9. Annual Report Fiscal Year 2000, October 2000.

10. Selected Aspects of Disability Decision Making, September 2000.

11. Statement on the Supplemental Security Income Program, Additional Statement by the Social

Security Advisory Board in the Annual Report of the Supplemental Security Income Program,

Social Security Administration, May 2000.

12. The Technical Panel on Assumptions and Methods, Report to the Social Security Advisory

Board, November 1999.

13. Annual Report Fiscal Year 1999, October 1999.

14. How the Social Security Administration Can Improve Its Service to the Public, September 1999.

15. Forum on the Implications of Raising the Social Security Retirement Age, May 1999 (Staff

document).

16. Statement on the Supplemental Security Income Program, Additional Statement by the Social

Security Advisory Board in the Annual Report of the Supplemental Security Income Program,

Social Security Administration, May 1999.

17. Annual Report Fiscal Year 1998, October 1998.

18. How SSAs Disability Programs Can Be Improved, August 1998.

19. Social Security: Why Action Should Be Taken Soon, July 1998.

20. Statement on the Supplemental Security Income Program, Additional Statement by the Social

Security Advisory Board in the Annual Report of the Supplemental Security Income Program,

Social Security Administration, May 1998.

21. Strengthening Social Security Research: The Responsibilities of the Social Security

Administration, January 1998.

22. Increasing Public Understanding of Social Security, September 1997.

23. Forum on a Long-Range Research and Program Evaluation Plan for the Social Security

Administration: Proceedings and Additional Comments, June 24, 1997 (Staff document).

24. Developing Social Security Policy: How the Social Security Administration Can Provide

Greater Policy Leadership, March 1997.

49

Reports are available on the Boards Web site at www.ssab.gov
Acronyms Used in this Report

ALJ Administrative Law Judge

CDRs Continuing Disability Reviews

CY Calendar Year

DDS Disability Determination Services

DI Disability Insurance

ESF Earnings Suspense File

FBI Federal Bureau of Investigation

FY Fiscal Year

GAO General Accounting Office

HHS Health and Human Services

HI Hospital Insurance

ID Identification

IG Inspector General

INS Immigration and Naturalization Service

IRS Internal Revenue Service

IVT Interactive Video Training

NCSSMA National Council of Social Security Management Associations

OASDI Old-Age, Survivors, and Disability Insurance

OASI Old-Age and Survivors Insurance

OCSE Office of Child Support Enforcement

OIG Office of the Inspector General

OMB Office of Management and Budget

OPM Office of Personnel Management

QA Quality Assurance

SES Senior Executive Service

SMI Supplementary Medical Insurance

SSA Social Security Administration

SSI Supplemental Security Income

SSN Social Security Number

50
Social Security Advisory Board

400 Virginia Avenue, SW

Suite 625

Washington, D.C. 20024

Tel: (202) 475-7700

Fax: (202) 475-7715

E-mail: info@ssab.gov

www.ssab.gov