SUPPLEMENTAL 

SECURITY INCOME

SSA Has Taken Steps 

to Prevent and Detect 

Overpayments, but 

Additional Actions 

Could Be Taken to 

Improve Oversight

Report to Congressional Requesters

December 2012

GAO-13-109

United States Government Accountability Office

GAO
Page i GAO-13-109 Supplemental Security Income 

Letter 1 

Conclusions 4

Recommendations for Executive Action 5

Agency Comments and Our Evaluation 5

Appendix I SSI Overpayments and Recovery Presentation 7

Appendix II Comments from the Social Security Administration 46

Appendix III GAO Contact and Staff Acknowledgments 48

Contents 

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Page 1 GAO-13-109 Supplemental Security Income 

United States Government Accountability Office 

Washington, DC 20548

December 14, 2012

The Honorable Erik Paulsen

Acting Chairman

Subcommittee on Human Resources

Committee on Ways and Means

House of Representatives

The Honorable Scott P. Brown

United States Senate

The Social Security Administration’s (SSA) Supplemental Security 

Income program (SSI) provides cash assistance for eligible aged, blind, 

and disabled individuals with limited financial means. In fiscal year 2011, 

the SSI program paid about $46 billion in benefits to approximately 9 

million beneficiaries. The program has grown substantially in recent 

years, and is expected to grow more in the near future, placing added 

pressure on already stretched federal budgets. Given the size of the SSI 

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

loss of taxpayer dollars, and financial hardships for individuals of limited 

means who have to repay the overpayment. In fiscal year 2010, SSA 

reported that overpayments to program recipients exceeded $3.3 billion. 

Agency data also showed that the amount of SSI debt recovered was less 

than half the amount of new debt detected.

To determine an individual’s ongoing financial eligibility for SSI program 

payments, SSA conducts periodic “redeterminations.” During a 

redetermination, field office staff perform a variety of activities to verify 

recipients’ income, resources, living arrangements, and other factors to 

determine their continued SSI program eligibility. These activities may 

include querying internal and external databases, checking with 

employers and banks, and performing interviews with recipients to obtain 

current information. In fiscal year 2011, SSA conducted more than 2.4 

million redeterminations—an increase of about 136 percent over the 

number conducted in fiscal year 2007—that it estimates will prevent or 

recover about $3.2 billion in lifetime overpayments.

In fiscal year 2012, recipients with countable income that exceeds $698 

per month ($1,048 for couples) are generally ineligible for SSI payments. 

In addition, recipients who have countable assets of more than $2,000 

($3,000 for couples) are also ineligible for SSI payments. SSA may 

overpay beneficiaries if it does not obtain timely and accurate information 

 
 

Page 2 GAO-13-109 Supplemental Security Income 

regarding their earnings and assets, and act expeditiously to discontinue 

payments to recipients who exceed income or asset thresholds. These 

overpayments adversely impact program integrity, and may create 

economic hardship for beneficiaries who have to repay them. Moreover, 

the potential burden of having to repay SSI overpayments could create, 

for some, a disincentive to work.

Given the importance of verifying the continued eligibility of SSI 

recipients, and identifying and recovering potential SSI benefit 

overpayments, you asked us to study the extent to which SSA makes 

overpayments to and recovers overpayments from SSI beneficiaries. 

Specifically, we answered the following questions: (1) What are the major 

factors associated with SSI overpayments, and what actions has SSA 

taken to address them? and (2) What is known about SSA’s recovery of 

overpayments from SSI recipients, including those not currently receiving 

SSI payments?

We used multiple data collection methods to obtain this information. We 

analyzed SSI overpayment debt and collection data for fiscal year 2011 to 

identify trends in the identification and recovery of SSI overpayments. We 

also worked with SSA staff to review a nongeneralizable random sample 

of 105 cases of SSI recipients who had an overpayment detected in fiscal 

year 2011 to better understand the characteristics associated with 

overpayments. We reviewed documentation on SSA’s policies and 

procedures for identifying and recovering SSI benefit overpayments, prior 

reports by SSA and its Office of the Inspector General, relevant federal 

laws and regulations, and prior GAO studies of the SSI program. In 

addition, we conducted in-depth interviews with management and staff 

from SSA headquarters, selected regions, and field offices. We also 

examined initiatives developed by SSA to improve the identification and 

recovery of SSI overpayments. Finally, we report estimates of 

overpayment deficiency dollars that are published in SSA’s annual 

Supplemental Security Income stewardship reports. These estimates are 

based on random samples of approximately 4,300 cases each year, and 

consequently are subject to sampling error. Although the stewardship 

reports do include confidence intervals for the overall overpayment 

accuracy rates, SSA does not provide confidence intervals for the 

overpayment deficiency dollar estimates. Based on available information 

in these reports in combination with conservative assumptions, we placed 

approximate bounds on the size of these sampling errors for overpayment 

deficiency dollar estimates. In particular, we believe that the 95 percent 

confidence intervals for the overpayment deficiency estimates we present 

do not exceed plus or minus 20 percent of the estimates themselves.
 

Page 3 GAO-13-109 Supplemental Security Income 

We conducted this performance audit from September 2011 to October 

2012 in accordance with generally accepted government auditing 

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

obtain sufficient, appropriate evidence to provide a reasonable basis for 

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

the evidence obtained provides a reasonable basis for our findings based 

on our audit objectives.

On October 19, 2012, we briefed your staff on the results of our study of 

the extent to which SSA makes overpayments to and recovers 

overpayments from SSI beneficiaries. In summary, we found that 

cumulative SSI overpayment debt nearly doubled from $3.8 billion in 

fiscal year 2002 to $7.3 billion in fiscal year 2011. SSI overpayment debt 

recovery also increased from $860 million to almost $1.2 billion during the 

same time period. For fiscal year 2011, the unreported value of recipients’ 

financial institution accounts, such as checking and savings accounts, 

and unreported wages were the major factors associated with causes of 

overpayments, and were associated with about $1.7 billion (37 percent) of 

all SSI overpayments.1

We also found that in fiscal year 2011, 75 percent of SSI overpayment 

debt that was recovered was obtained by withholding a portion of 

recipients’ ongoing Title XVI (SSI) payments, or by withholding of Title II 

(Old-Age, Survivors, and Disability Insurance) payments. Recipients can 

SSA lacks comprehensive, timely information on 

SSI recipients’ financial institution accounts and wages, but has 

developed new tools to improve its information in these areas: Access to 

Financial Institutions (AFI) and Telephone Wage Reporting (TWR). The 

AFI initiative conducts electronic searches of about 96 percent of the 

financial institutions where SSI recipients have a direct deposit account, 

and provides SSA with independent data on a recipient’s financial 

institution accounts to use when periodically redetermining a recipient’s 

eligibility for payments. The TWR system allows recipients to call into an 

automated telephone system to report their monthly wages. Agency 

officials reported that the TWR system should ease the burden of 

reporting wages for some recipients and save time for SSA staff since 

wage data will be input directly into SSA’s computer system.

 

1

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

FY 2011. 
 

Page 4 GAO-13-109 Supplemental Security Income 

request a waiver of repayment under certain circumstances.2 According 

to the standards for internal control in the federal government, agencies 

must have controls in place to ensure that no individual can control all key 

aspects of a transaction or event.3 SSA, however, does not require 

supervisory review or approval for overpayment waivers of $2,000 or 

less;4 and claims representatives, who are located in SSA’s more than 

1,260 field offices, have the authority to unilaterally approve such waivers.

In fiscal year 2011, SSA approved about 76 percent of all SSI 

overpayment waivers requested by recipients. Management oversight of 

the SSI overpayment waiver decision process is limited. The agency does 

not routinely analyze collected SSI waiver data to identify potential 

negative trends in the implementation of SSA’s waiver policies and 

procedures, such as the type, number, and dollar value of the waivers 

granted, including those waivers below the $2,000 approval threshold that 

SSA staff can unilaterally approve, and whether there are waiver patterns 

specific to SSA offices, regions, or individual staff.

SSA has made progress in improving SSI program integrity through the 

increased use of redeterminations to detect and prevent overpayments, 

the AFI initiative to obtain more accurate information on recipients’ 

financial institution accounts, and its continued efforts to obtain more 

timely recipient wage information. Despite this progress, SSA efforts to 

recover identified overpayment debts are constrained by SSA policies 

and criteria that allow claims representatives to unilaterally waive the 

repayment of overpayment amounts up to $2,000 without supervisory 

review and approval. SSA also lacks comprehensive management 

information with which to oversee the waiver process through the tracking 

 

2

The statute requires that SSA waive overpayments if a recipient is not at fault and 

recovering an overpayment would 1) defeat the purpose of the SSI program, 2) be against 

equity and good conscience, or 3) impede the effective administration of SSI due to the 

small amount involved. 42 U.S.C. § 1383(b)(1)(B)(i). 

3

The standards for internal control in the federal government provide the overall 

framework to assist federal agencies in establishing and maintaining internal control and 

for identifying and addressing major performance and management challenges and areas 

at greatest risk of fraud, waste, abuse, and mismanagement. For more information see 

GAO, Standards for Internal Control. GAO/AIMD-00-21.3.1 (Washington, D.C.: 

November 1999). 

4

SSA’s Program Operations Manual System gives claims representatives the authority to 

waive overpayment amounts up to $2,000 without supervisory review and approval. 

Conclusions
 

Page 5 GAO-13-109 Supplemental Security Income 

of waiver approval rates, amounts, and patterns specific to SSA offices, 

regions, or individual staff. According to the standards for internal control 

in the federal government, agencies must have controls in place to 

ensure that no individual can control all key aspects of a transaction or 

event. Without the necessary oversight and controls in place, SSA will be 

unable to identify trends in the waiver process that could jeopardize the 

agency’s ability to maximize its overpayment recovery efforts and 

safeguard taxpayer dollars.

To enhance SSA’s ability to recover SSI overpayment debt, we 

recommend that the Commissioner of Social Security

• Review the agency’s policy concerning the supervisory review and 

approval of overpayment waiver decisions of $2,000 or less, to 

determine if the policy is still appropriate given that federal agencies 

must have controls in place to ensure that no individual can control all 

key aspects of a transaction or event. Such a review should include 

collecting the information needed to determine the impact of this 

policy on the agency’s financial stewardship of SSI program dollars.

• Explore ways to strengthen the agency’s oversight of the 

overpayment waiver process through the analysis of data to identify 

waiver trends, such as approval rates, amounts, and patterns specific 

to SSA offices, regions, or individual staff that the agency may wish to 

track more closely.

We obtained written comments on a draft of this report from the Office of 

the Commissioner of the Social Security Administration. The comments 

are reproduced in appendix II. The agency also provided general and 

technical comments, which have been incorporated into the report as 

appropriate. SSA agreed with our first recommendation to review the 

agency’s policy concerning the supervisory review and approval of 

overpayment waiver decisions of $2,000 or less. SSA disagreed with our 

second recommendation to explore ways to strengthen the agency’s 

oversight of the overpayment waiver process through the analysis of data 

to identify waiver trends, such as approval rates, amounts and patterns to 

specific SSA offices, regions, or individual staff. SSA noted that while the 

agency continues to strengthen its oversight of the SSI program, it does 

not currently have the resources available to create and analyze data at 

the level of detail specified in the recommendation. The agency also cited 

the national and regional information for waiver transaction approval and 

denials that it compiles as part of its ongoing review of SSI overpayments. 

This information is discussed on page 42 of the report. We recognize 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 6 GAO-13-109 Supplemental Security Income 

SSA’s efforts and the agency’s ongoing resource constraints. However, 

we continue to believe that, short of additional steps to better compile and 

track additional data on waiver patterns specific to SSA offices and 

individuals, SSA will be constrained in its efforts to recover identified 

overpayments. 

We are sending copies of this report to the Commissioner of Social 

Security, appropriate congressional committees, and other interested 

parties. This report is also available at no charge on GAO’s website at 

http://www.gao.gov. 

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

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

Offices of Congressional Relations and Public Affairs may be found on 

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

report are listed in appendix III.

Daniel Bertoni

Director, Education, Workforce,

 and Income Security Issues
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 7 GAO-13-109 Supplemental Security Income 

Supplemental Security Income: SSA Has Taken Steps to Prevent and Detect 

Overpayments, but Additional Actions Could Be Taken to Improve Oversight

Staff Briefing for Acting Chairman of the Subcommittee on Human Resources, 

Committee on Ways and Means, and Senator Scott Brown

October 2012

For more information, contact Daniel Bertoni. Page 1

Appendix I: SSI Overpayments and Recovery 

Presentation 
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 8 GAO-13-109 Supplemental Security Income 

Introduction

• The Supplemental Security Income (SSI) program, administered by the Social Security 

Administration (SSA), provides cash payments from general tax revenues to eligible 

aged,1 blind, and, disabled persons with limited financial means—including adults and 

children.

• Applicants with income or resources over certain statutory thresholds are not eligible for 

SSI even if they are aged, blind, or disabled.

• In 2011, SSI paid about $46 billion in payments to 9 million recipients.2

• SSI eligibility is determined and periodically redetermined by complex factors that can 

be difficult to verify, including recipients’ income, resources, and living arrangements.3

1The term “aged” refers to individuals who are 65 years of age or older.

2This includes all recipients who received at least one federal SSI payment during 2011.

3There are income and asset thresholds that can preclude individuals from SSI program eligibility. 

.

Page 2 .
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 9 GAO-13-109 Supplemental Security Income 

Objectives

Given the importance of verifying the continued eligibility of SSI recipients, and identifying 

and recovering potential SSI benefit overpayments, we addressed the following questions:

1) What are the major factors associated with SSI overpayments, and what actions has 

SSA taken to address them?

2) What is known about SSA’s recovery of overpayments from SSI recipients, including 

those not currently receiving SSI payments?

Page 3
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 10 GAO-13-109 Supplemental Security Income 

Scope and Methodology

To answer our questions, we:

• Analyzed SSI overpayment debt and collection data for fiscal year 2011.

• Worked with SSA staff to review a nongeneralizable random sample of 105 cases of 

SSI recipients who had an overpayment detected in fiscal year 2011 to better 

understand the characteristics associated with overpayments.

• Reviewed documentation on SSA’s policies and procedures for identifying and 

recovering SSI benefit overpayments, prior reports by SSA and its Office of the 

Inspector General, relevant federal laws and regulations, and our prior reviews of the 

SSI program.

• Conducted in-depth interviews with management and staff from SSA headquarters, 

selected regions, and field offices.

Page 4
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 11 GAO-13-109 Supplemental Security Income 

Scope and Methodology (continued)

• Examined initiatives developed by SSA to improve the identification and recovery of SSI 

overpayments.

• Examined estimates of overpayment deficiency dollars that are published in SSA’s 

annual SSI stewardship reports. These estimates are based on random samples of 

approximately 4,300 cases each year, and consequently are subject to sampling error. 

Although the stewardship reports do include confidence intervals for the overall 

overpayment accuracy rates, SSA does not provide confidence intervals for the 

overpayment deficiency dollar estimates. Based on available information in these 

reports in combination with conservative assumptions, we placed approximate bounds 

on the size of these sampling errors for overpayment deficiency dollar estimates. In 

particular, we believe that the 95 percent confidence intervals for the overpayment 

deficiency estimates we present do not exceed plus or minus 20 percent of the 

estimates themselves.

Page 5
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 12 GAO-13-109 Supplemental Security Income 

Scope and Methodology (continued)

• We conducted this performance audit from September 2011 to October 2012 in 

accordance with generally accepted government auditing standards. These standards 

require that we plan and perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based on our audit 

objectives. We believe the evidence obtained provides a reasonable basis for our 

findings based on our audit objectives.

Page 6
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 13 GAO-13-109 Supplemental Security Income 

Summary of Results

• Cumulative SSI overpayment debt has nearly doubled from $3.8 billion in fiscal year 

2002 to $7.3 billion in fiscal year 2011.

• SSI overpayment debt recovery increased from $860 million in fiscal year 2002 to 

almost $1.2 billion in fiscal year 2011. 

• From fiscal year 2007 through fiscal year 2011, the unreported value of recipients’ 

financial institution accounts, such as checking and savings accounts, and unreported 

wages were associated with about 37 percent or about $1.7 billion in annual SSI 

overpayments.4, 5

• SSA lacks comprehensive, timely information on financial institution accounts and 

wages, but has developed new tools to improve its information in these areas: Access to 

Financial Institutions (AFI) and Telephone Wage Reporting (TWR). 

4Amounts are annual estimates based on 5-year averages from FY 2007 through FY 2011.

5This estimated overpayment is based on a sample and has 95 percent confidence intervals within plus or minus 20 percent of the estimate itself. 

Page 7
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 14 GAO-13-109 Supplemental Security Income 

Summary of Results (continued)

• In fiscal year 2011, 75 percent of SSI overpayment debt that was recovered was 

obtained by withholding a portion of recipients’ ongoing payments. However, recipients 

can request a waiver of repayment under certain circumstances.6

• SSA does not require supervisory review or approval for overpayment waivers of $2,000 

or less; claims representatives, who are located in SSA’s more than 1,260 field offices, 

have the authority to unilaterally approve such waivers. 

• SSA approved about 76 percent of the 276,226 SSI overpayment waivers requested by 

recipients in fiscal year 2011. 

• Management oversight of the SSI overpayment waiver decision process, including the 

trending and tracking of waiver approval rates and amounts, is limited.

6The statute required that SSA make provision to waive overpayments if the recipient is not at fault and recovering an overpayment would (1) defeat the purpose of 

the SSI program, (2) be against equity and good conscience, or (3) impede the effective administration of SSI due to the small amount involved. 42 U.S.C. §

1383(b)(1)(B)(i).

Page 8
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 15 GAO-13-109 Supplemental Security Income 

Background

• Since 1974, when the SSI program was established under Title XVI of the Social 

Security Act, it has provided payments to low-income aged, blind, and disabled 

persons—both adults and children—who met the financial eligibility requirements.7

• A disability is defined for adults as the inability to engage in any substantial gainful 

activity because of a medically determinable physical or mental impairment(s) that:

• can be expected to result in death, or

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

months.8

7The SSI program was established by the Social Security Amendments of 1972 and became effective in 1974. Pub. L. No. 92-603, §301, 86 Stat. 1329, 1465-78 

(codified as amended at 42 U.S.C. §1381-1383f).

820 C.F.R. §416.905 (2012). Individuals under age 18 are considered disabled if they have a medically determinable physical or mental impairment or combination of 

impairments that causes marked and severe functional limitations, and that can be expected to cause death or has lasted or can be expected to last for a continuous 

period of not less than 12 consecutive months. 20 C.F.R. §416.906 (2012).

Page 9
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 16 GAO-13-109 Supplemental Security Income 

Background (continued)

• In fiscal year 2012, an eligible individual or couple could have, in any month:

• countable income that was less than the monthly federal SSI benefit rate of 

$698 per month for an individual and $1,048 per month for a couple, and

• countable resources (such as financial institution accounts) of $2,000 or less for 

individuals and $3,000 or less for couples.

• Recipients are required to report changes in their income and financial resources to the 

agency as soon as they occur and a penalty may be deducted from the recipient’s 

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

occurred.9

920 C.F.R. §§416.708(c) and (d) and 416.714 (2012).

Page 10
Appendix I: SSI Overpayments and Recovery 

Presentation

Page 17 GAO-13-109 Supplemental Security Income 

Background (continued)

• To determine the continuing eligibility of SSI beneficiaries, SSA conducts periodic 

“redeterminations”10 that review recipients’ non-medical eligibility factors, such as 

income, resources, and living arrangements.11

• When an SSI overpayment is identified, the beneficiary is notified of the overpayment 

and may request a waiver of that overpayment (thus relieving the recipient of 

responsibility for repayment).12

• SSA may grant a waiver request if the agency finds that the beneficiary was not at fault 

for the overpayment, and recovery or adjustment would defeat the program’s purpose 

(to provide basic cash payments to aged, blind and disabled persons—both adults and 

children—with income and resources below specified thresholds), be against equity and 

good conscience, or impede the effective or efficient administration of the SSI program 

because of the small amount of the overpayment involved.

10For purposes of this report, we use “redeterminations” to refer to full redeterminations as well as limited issue reviews that focus on particular factors of eligibility, 

such as wages or financial institution accounts, and are selected differently. 

11The amount of a recipient’s SSI benefit is determined in part by the recipient’s living arrangements—that is, the extent to which the recipient contributes to his/her 

food and shelter costs on a monthly basis. 20 C.F.R §§416.420 and 416.1121(h). 

1220 C.F.R.§416.550 (2012).

Page 11
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 18 GAO-13-109 Supplemental Security Income 

Background (continued)

• If SSA denies a waiver request, full repayment is required.13

• If the beneficiary is currently receiving SSI or certain other SSA payments, SSA may 

withhold partial payment of these benefits to recover the debt.14

• If no SSA payments are currently being received, or if the beneficiary asserts that the 

proposed withholding amount is too large, the agency generally permits repayment over 

12 to 36 months.

• When an individual is no longer receiving payments, SSA can also recover debt through 

several external collection tools (fig p.13).15

1320 C.F.R. §416.560 (2012).

1420 C.F.R. §§416.570 and 416,571 (2012). 

1520 C.F.R. §§416.572 and 416.580 (2012).

Page 12
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 19 GAO-13-109 Supplemental Security Income 

Background (continued)

SSA’s Debt Recovery Process (For Those Not Currently Receiving SSI Payments) 

Page 13

Source: SSA officials and guidance.
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 20 GAO-13-109 Supplemental Security Income 

Objective One

What are the major factors associated with SSI overpayments, and

what actions has SSA taken to address them?

Page 14
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 21 GAO-13-109 Supplemental Security Income 

Total SSI Overpayment Debt Is Increasing

Page 15

• Cumulative SSI overpayment debt nearly doubled over 10 years, from $3.8 billion to 

$7.3 billion.16

• Program participation has increased by about 18 percent, and the average payment 

made to beneficiaries has risen 23 percent over the same period.

Source: GAO analysis of SSA data.

16The total SSI overpayment debt figures do not include the amount of overpayment dollars waived in a given year. Waived debts are total write-offs and are not 

collected.

Cumulative SSI Debt Total Annual SSI Payments
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 22 GAO-13-109 Supplemental Security Income 

SSA Performs Periodic Redeterminations to Ensure the Continuing Eligibility of 

Program Participants and Prevent Overpayments

Page 16

• SSA uses a risk-based approach to target redeterminations to recipients most likely to 

incur an overpayment, and the majority of redeterminations in fiscal year 2011 were 

done on such recipients.

• SSA estimates that every dollar spent on redeterminations yields about $6 in program 

savings over 10 years, including savings accruing to Medicaid.17

• In fiscal year 2011, SSA conducted more than 2.4 million redeterminations—an 

increase of about 136 percent since fiscal year 2007.

• SSA estimates that the fiscal year 2011 redeterminations will prevent or recover about 

$3.2 billion in lifetime SSI overpayments.18

17Medicaid is a state-run medical program that is federally funded and pays for medical assistance for adults and children with income and resources below 

specified thresholds. 42 U.S.C. §§1396-1396w-5. Usually, a person receiving SSI is also eligible for Medicaid. 18This estimate is from SSA’s 2011 change rate study based on a random sample. Although that study did not publish confidence intervals, based on conservative 

assumptions we are 95 percent confident that the actual value is within approximately plus or minus 13 percent of the estimate itself. 
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 23 GAO-13-109 Supplemental Security Income 

Unreported Financial Institution Accounts and Unreported Wages Were Leading 

Factors Associated with Overpayments

Page 17

• From fiscal year 2007 through fiscal year 2011, the unreported value of recipients’ 

financial institution accounts and unreported wages were associated with about 37 

percent or about $1.7 billion in annual SSI overpayments.19

Primary Factors Associated with Overpayments

Source: GAO Analysis of SSA data.

Note: Amounts are annual estimates based on 5-year averages from fiscal year 2007 through fiscal year 2011 and have 95 percent confidence intervals within plus 

or minus 20 percent of the estimates themselves. In-kind support and maintenance is unearned, non-cash income, such as rental subsidies or food. Other real 

property includes some type of real property other than the recipient’s primary residence. All other causes included life insurance, child support, and living 

arrangements. 

19The sum of the dollars for particular causes exceeds the total estimated overpayment dollars due to cases having more than one overpayment cause.
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 24 GAO-13-109 Supplemental Security Income 

SSA Historically Has Relied on Outdated Internal Revenue Service Data to Detect 

Changes in Financial Institution Accounts

• According to SSA figures, from fiscal year 2007 through fiscal year 2011 about 96 

percent of the approximately $1 billion in annual overpayments associated with financial 

institution accounts were made because recipients failed to report either the existence of 

financial institution accounts or increases in account balances.20, 21

• SSA conducts periodic computer matches with the Internal Revenue Service’s (IRS)

Form 1099 interest income data to independently verify recipients’ financial accounts 

that may not have been reported.

• While the match provides SSA with more information than if it relied exclusively on 

recipients to self-report their financial information, our prior work indicates that the 

IRS data can be up to roughly 2 years old by the time the match is conducted and 

the results reach SSA staff for follow-up. During this time overpayments may 

accrue and become larger.

20For reporting financial institution accounts, recipients or representative payees are required to timely report changes in resources of recipients or deemors (those 

whose resources are deemed in part to be resources of the recipient, such as a parent or ineligible spouse living with the recipient). 20 C.F.R. §416.708(d) (2012). 

Representative payees are persons who receive SSI payments on behalf of SSI recipients who are incapable of managing or directing the management of their 

benefits. 20 C.F.R. § 416.601 (2012). 

21This estimated overpayment is based on a sample and has 95 percent confidence intervals within plus or minus 20 percent of the estimate itself. 

Page 18
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 25 GAO-13-109 Supplemental Security Income 

SSA Implemented the Access to Financial Institutions Initiative to Improve Financial 

Institution Account Information

Page 19

• To improve its ability to detect and verify recipients’ financial institution accounts, SSA 

implemented the Access to Financial Institutions (AFI) initiative that conducts electronic 

searches of about 96 percent of the financial institutions where SSI recipients have a 

direct deposit account. 

• AFI provides the agency with independent data on a recipient’s financial institution 

accounts that SSA can utilize when determining or periodically redetermining a 

recipient’s eligibility for payments. 

• In January 2012, for example, SSA reported using AFI to identify where a recipient 

had 6 unreported financial institution accounts that each had balances of nearly 

$25,000. The recipient, however, reported having only one financial institution 

account that was under the resource limit.

• The agency completed its AFI rollout to all states in June 2011. 
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 26 GAO-13-109 Supplemental Security Income 

SSA Implemented the Access to Financial Institutions Initiative to Improve Financial 

Institution Account Information (continued)

Page 20

• The agency generally requires that AFI be used during initial claims processing and 

periodic redeterminations of program eligibility if the recipient reports $750 or more in 

liquid resources.22 For recipients who report a lesser amount of liquid resources, who do 

not report any accounts, or who fail to disclose other accounts they may have, SSA staff 

are generally not required to use AFI, but have the discretion to do so.

• According to SSA officials, it would not be possible to expand the use of AFI to 

periodically match the SSI rolls against a comprehensive financial institution accounts 

database because no such database exists. In addition, such a match would require 

greater staff resources to follow up on any discrepancies that could result from the 

match and determine how the information would affect the recipients’ eligibility for 

payments. 

• SSA projects that if AFI’s current account verification process is used on a long-term 

basis, fiscal year 2013 verifications would yield an estimated $365 million in lifetime 

Federal SSI program savings consistent with a return on investment of $9 to $1.23

22AFI is also used for other situations, such as when an SSA data match identifies a discrepancy that needs to be reconciled.

23SSA officials reported that in fiscal year 2013, the agency plans to conduct more rigorous checks of alleged financial assets using the AFI process dependent 

upon adequate resources.

.
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 27 GAO-13-109 Supplemental Security Income 

SSA Lacks Timely Information on Recipients’ Wages

Page 21

• According to SSA figures, from fiscal year 2007 through fiscal year 2011, about 90 

percent of the approximately $671 million in overpayments resulting from wages were 

made because recipients failed to report their monthly earnings.24, 25

• For example, we found that a recipient received an overpayment of $3,695 due to 

unreported wages that were earned over a year and a half.

• In addition to recipient reported wage information, SSA uses independent data from 

certain federal databases to detect wages. 

• SSA also conducts semiannual data matches between SSI records and the 

annual wage data in the agency's Master Earnings File (MEF).26 The MEF data 

can be up to 1-2 years old, however, when SSA field offices are notified of 

detected wages that need to be reconciled.

24Recipients and representative payees are required to timely report changes in income of recipients and deemors. 20 C.F.R. § 416.708(c) (2012). 25This estimated overpayment is based on a sample and has 95 percent confidence intervals within plus or minus 20 percent of the estimate itself. 26The Master Earnings File is an SSA database that includes IRS Form W-2 wage data.

. 
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 28 GAO-13-109 Supplemental Security Income 

SSA Lacks Timely Information on Recipients’ Wages (continued)

• The agency conducts quarterly matches between SSI records and the National 

Directory of New Hires’ (NDNH)27 quarterly wage data. While the wage information 

obtained from this match is significantly more timely than the information obtained 

from the IRS data match, the NDNH data can be about 6 months old when SSA field 

offices are notified of the detected wages that need to be reconciled. 

• During an initial application or SSI redetermination, SSA staff generally verify wages 

reported by applicants and recipients, or detected by SSA by obtaining additional 

information, such as the applicant’s or recipient’s pay slips or information from 

employers. 

• SSA staff can use wage verification companies, such as The Work Number,28 to 

verify recipient wages. These companies provide wage information to SSA for 

participating employers rather than SSA contacting the specific employer.

27The Department of Health and Human Services’ Office of Child Support Enforcement’s NDNH contains quarterly state wage information, which is more recent than 

the annual wage information that SSA obtains through its current IRS data match.

28The Work Number is a national payroll provider with wage information for over 2,000 participating employers. SSA recently obtained immediate online access to 

wage information from The Work Number. 

Page 22
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 29 GAO-13-109 Supplemental Security Income 

SSA Lacks Timely Information on Recipients’ Wages (continued)

• Staff also have online access to databases, including NDNH or SSA’s Master 

Earnings File, and access to the agency’s online verifications with The Work 

Number to investigate individual instances of potentially unreported wages. These 

sources provide amounts of quarterly or annual wages as a way to verify 

recipients’ monthly wages. As previously discussed, the information obtained from 

these sources can range from 6 months to 2 years old. 

Page 23
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 30 GAO-13-109 Supplemental Security Income 

SSA Implemented the Telephone Wage Reporting System to Improve Wage Data, 

but Its Use Is Limited

Page 24

• To help improve its ability to gather information on recipients’ wages, SSA implemented 

the Telephone Wage Reporting (TWR) system in fiscal year 2008 to allow recipients to 

call into an automated telephone system to report their monthly wages.29

• SSA officials reported that the TWR system should ease the burden of reporting wages 

for some recipients and save time for SSA staff since wage data will be input directly 

into SSA’s computer system.

• TWR is one of several options to report wages (e.g., calling a field office or teleservice 

center, or mailing or bringing pay slips to a field office).

• While a TWR pilot conducted in 2003 found that recipient self-reported wage 

information was 92 percent accurate, the pilot did not provide information concerning 

the accuracy of self-reported wage information for recipients opting not to use TWR for 

comparison purposes.

29SSA verifies wages reported through TWR during a redetermination in certain circumstances, such as when data matches comparing recipient records and federal 

databases on wages show differences in amounts of wages.
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 31 GAO-13-109 Supplemental Security Income 

SSA Implemented the Telephone Wage Reporting System to Improve Wage Data, but 

Its Use Is Limited (continued)

Page 25

• The TWR pilot also differed from the agency’s current wage verification practices in that 

SSA staff verified wages at the end of the pilot for all participants, while recipient wage 

information submitted through TWR is generally not verified during a redetermination. 

• TWR has several limitations that restrict its effectiveness. For example, TWR

• relies on self-reported data, which GAO has found to be a key vulnerability leading 

to overpayments.

• is not intended or appropriate for all recipients with wages, including recipients who 

speak in a foreign language or who are unable to follow simple directions, and only 

a limited number of recipients have used the system, according to SSA officials. 

• is unable to process wage information for individuals who work for more than one 

employer. 
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 32 GAO-13-109 Supplemental Security Income 

SSA Implemented the Telephone Wage Reporting System to Improve Wage Data, but 

Its Use Is Limited (continued)

• The SSA officials we interviewed said that they do not have plans to address language 

barriers, and did not know the extent of recipients with wages who were excluded from 

TWR due to various technological limitations.30

• According to agency officials, the monthly use of the TWR system increased to over 

36,000 successful wage reports per month, for September 2012.31 

• SSA estimates that about 600,000 recipients and deemors32 have wages.

• SSA officials reported that to increase the volume of representative payees who report 

wages via the TWR program, the agency mailed over 30,000 TWR recruitment notices 

to representative payees of SSI recipients in September 2012, asking them to use the 

TWR program to report the recipient’s monthly wages to the agency. As a result, SSA 

hopes that at least 4,800 representative payees will use TWR in fiscal year 2013 in at 

least 1 month. 30For those unable to report wages by telephone using TWR because of the language barrier, SSA provides interpreter services through a toll-free telephone 

number.

31One caller may make more than one wage report, such as a representative payee who handles payments for more than one working recipient. Representative 

payees are persons who receive SSI payments on behalf of SSI recipients who are incapable of managing their finances. 

32Deemors are individuals whose resources are deemed in part to be resources of the recipient, such as a parent or ineligible spouse living with the recipient.

. Page 26
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 33 GAO-13-109 Supplemental Security Income 

SSA Implemented the Telephone Wage Reporting System to Improve Wage Data, but 

Its Use Is Limited (continued)

• SSA officials told us that the agency is developing a smart phone wage reporting 

application known as the SSI Mobile Wage Reporting (SSIMWR) to allow SSI recipients 

to report their wages via smart phones. According to SSA officials, this mobile 

application will serve as another alternative for representative payees, SSI recipients, 

and deemors, to report SSI wages. 

• SSA officials also reported that the agency plans to conduct a 6-month rollout of the 

SSIMWR application to 50 SSA field offices nationwide, and hopes that SSI recipients, 

deemors, and representative payees will be able to submit their wages using the 

application beginning in December 2012. 

Page 27
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 34 GAO-13-109 Supplemental Security Income 

Objective Two

Page 28

What is known about SSA’s recovery of overpayments from SSI recipients, including 

those not currently receiving SSI payments?
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 35 GAO-13-109 Supplemental Security Income 

Detection and Recovery of SSI Overpayment Debt Has Increased Over the Last 10 

Years

Page 29

From fiscal year 2002 to 

2011:

• New SSI overpayments 

detected increased by 28 

percent from $2 billion to 

$2.6 billion.

• SSI overpayments 

recovered increased by 36 

percent from $860 million 

to $1.2 billion.

Detection and Recovery of SSI Overpayments, Fiscal Years 

2002- 2011

Source: GAO analysis of SSA data
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 36 GAO-13-109 Supplemental Security Income 

Debt Recovery Options Depend on Whether an Individual Receives Payments

Page 30

• In fiscal year 2011, SSA reported that:

• 75 percent of the SSI overpayment debt that was recovered—approximately $874 

million—was recovered by withholding some portion of the recipients’ ongoing Title 

XVI (SSI)33 or Title II (OASDI) payments. 

• Of that amount, approximately 65 percent of the SSI overpayment debt was 

recovered by withholding SSI payments and 10 percent by withholding Title II 

payments.34

• about 25 percent of the SSI overpayment debt that was recovered—about $298 

million—was recovered through SSA’s use of external collection tools.

33 The statute limits the SSA’s ability to collect overpayments from SSI recipients to the lesser of the benefit amount for the month or 10 percent of the recipient’s 

income for the month federal benefit rate or the entire benefit if it is less than 10 percent of the full rate. 42 U.S.C. §1383(b)(1)(B)(ii). 34 Some individuals are dually entitled to SSI under Title XVI of the Social Security Act (42 U.S.C. §§ 1381-1385) and Old-Age, Survivors, and Disability Insurance 

under title II of the act (42 U.S.C. §§401-434).
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 37 GAO-13-109 Supplemental Security Income 

Debt Recovery Options Depend on Whether an Individual Receives Payments 

(continued) 

Page 31

• External debt collection tools include:

• tax refund offset, which withholds or reduces federal tax refunds;

• federal salary offset, which withholds or reduces wages and payments to a federal 

employee;

• administrative offset (against other than SSA payments), which withholds or reduces 

federal payments other than tax refunds or salary;

• administrative garnishment of wages and payments from private employers or state 

and local governments;

• credit bureau referral, which refers delinquent accounts to credit bureaus.
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 38 GAO-13-109 Supplemental Security Income 

SSI Overpayment Recovery Tools and Results, Fiscal Year 2011

Page 32

SSI Overpayment Recovery Efforts

(in millions of dollars)

Use of External Collection Tools

(in millions of dollars)

Source: GAO analysis of SSA data.

a: Treasury Offset Program includes refund recovery and credit bureau reporting

b: Other tools include refund recovery, and other collections.

• SSA’s primary tools 

for recovering SSI 

overpayment debt 

are the withholding 

of SSA payments, 

the withholding of 

Title II (OASDI) 

payments, and 

through the 

Treasury Offset 

Program for 

individuals who are 

not receiving SSA 

payments. 
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 39 GAO-13-109 Supplemental Security Income 

SSA Grants Most SSI Overpayment Waiver Requests, and Waiver Documentation 

and Oversight Is Limited

Page 33

• In fiscal year 2011, SSA approved approximately 76 percent of recipients’ requests to 

waive their SSI overpayment debt.

• SSA’s Program Operations Manual System gives claims representatives located in the 

agency’s approximately1,260 field offices the authority to waive overpayment amounts 

up to $2,000 without supervisory review and approval. 

• However, the standards for internal control in the federal government35 state that federal 

agencies must ensure that no one individual controls all key aspects of a transaction or 

event. 

35The standards for internal control in the federal government provide the overall framework to assist federal agencies in establishing and maintaining internal 

control and for identifying and addressing major performance and management challenges and areas at greatest risk of fraud, waste, abuse, and mismanagement. 

GAO, Standards for Internal Control. GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999).
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 40 GAO-13-109 Supplemental Security Income 

SSA Grants Most SSI Overpayment Waiver Requests, and Waiver Documentation 

and Oversight Is Limited (continued)

Page 34

• Moreover, SSA claims representatives may, on behalf of the agency, waive an 

overpayment debt only if the liable individual is without fault in causing the 

overpayment, and recovery or adjustment would:

• defeat the purpose of the program, 

• be against equity and good conscience, or

• impede effective or efficient administration of Title XVI of the Social Security Act 

because of the small amount involved.36

3642 U.S.C. §1383(b)(1)(B)(i).
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 41 GAO-13-109 Supplemental Security Income 

SSA Grants Most SSI Overpayment Waiver Requests, and Waiver Documentation 

and Oversight Is Limited (continued)

Page 35

• However, in fiscal year 2011, a high number of waiver requests were granted even 

though many recipients or their representative payees failed to fulfill their financial 

institution account and wage reporting responsibilities. 

• The amount of SSI overpayment dollars waived has risen 38 percent, from $122 

million in fiscal year 2008 to $167 million in fiscal year 2011, and

• The average amount of an overpayment waiver granted has risen about 20 percent, 

from $665 in fiscal year 2008 to $795 in fiscal year 2011. 
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 42 GAO-13-109 Supplemental Security Income 

SSA Grants Most SSI Overpayment Waiver Requests, and Waiver Documentation 

and Oversight Is Limited (continued)

Page 36

• SSA monitors some management information data and conducts limited oversight of the 

waiver process. For example, the agency:

• retains recipients’ waiver information in individual records,

• tracks the number of waivers requested and granted nationally and by SSA region, 

and

• conducts a limited quality review of approved waivers to identify cases where field 

office staff and regions have improperly granted waivers.
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 43 GAO-13-109 Supplemental Security Income 

SSA Grants Most SSI Overpayment Waiver Requests, and Waiver Documentation 

and Oversight Is Limited (continued)

Page 37

• The agency, however, does not routinely: 

• analyze collected SSI waiver data to identify potential negative trends in the 

application of SSA’s waiver requirements, such as:

• the type, number, and dollar value of the waivers granted, including those waivers 

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

• whether there are waiver patterns specific to SSA offices, regions, or individual 

staff.
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 44 GAO-13-109 Supplemental Security Income 

Conclusions

Page 38

• SSA has made progress in improving SSI program integrity through the increased use of 

redeterminations to detect and prevent overpayments, the AFI initiative to obtain more 

accurate information on recipients’ financial institution accounts, and its continued efforts 

to obtain more timely recipient wage information.

• The agency’s efforts to recover identified overpayment debts, however, are constrained 

by SSA policies and criteria that allow claims representatives to unilaterally waive the 

repayment of overpayment amounts up to $2,000 without supervisory review and 

approval, and SSA’s lack of comprehensive management information with which to 

oversee the waiver process through the tracking of waiver approval rates, amounts, and 

patterns specific to SSA offices, regions, or individual staff.

• Federal agencies must have controls in place to ensure that no individual can control all 

key aspects of a transaction or event.

• Without the necessary oversight and controls in place, SSA will be unable to identify 

trends in the waiver process that could jeopardize the agency’s ability to maximize its 

overpayment recovery efforts and safeguard taxpayer dollars.
Appendix I: SSI Overpayments and Recovery 

Presentation 

Page 45 GAO-13-109 Supplemental Security Income 

Recommendations

Page 39

To enhance SSA’s ability to recover SSI overpayment debt, we recommend that the 

Commissioner of Social Security

• Review the agency’s policy concerning the supervisory review and approval of 

overpayment waiver decisions of $2,000 or less, to determine if the policy is still 

appropriate given that federal agencies must have controls in place to ensure that 

no individual can control all key aspects of a transaction or event. Such a review 

should include collecting the information needed to determine the impact of this 

policy on the agency’s financial stewardship of SSI program dollars. 

• Explore ways to strengthen the agency’s oversight of the overpayment waiver 

process through the analysis of data to identify waiver trends, such as approval 

rates, amounts, and patterns specific to SSA offices, regions, or individual staff 

that the agency may wish to track more closely. 
Appendix II: Comments from the Social 

Security Administration 

Page 46 GAO-13-109 Supplemental Security Income 

Appendix II: Comments from the Social 

Security Administration
Appendix II: Comments from the Social 

Security Administration

Page 47 GAO-13-109 Supplemental Security Income 
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 48 GAO-13-109 Supplemental Security Income 

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

Jeremy Cox (Assistant Director) and Arthur T. Merriam Jr (Analyst-inCharge) managed all aspects of this assignment. James Bennett, Jessica 

Botsford, David Chrisinger, Danielle Giese, Jason S. Palmer, Mark 

Ramage, Matthew Saradjian, Vanessa Taylor, Walter Vance, Craig 

Winslow, and Jill Yost made significant contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Staff

Acknowledgments

(131123)
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