SSA 

REPRESENTATIVE 

PAYEE PROGRAM

Addressing Long-Term 

Challenges Requires a 

More Strategic 

Approach

Report to Congressional Requesters

May 2013

GAO-13-473

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-473, a report to 

congressional requesters

May 2013

SSA REPRESENTATIVE PAYEE PROGRAM

Addressing Long-Term Challenges Requires a More 

Strategic Approach

Why GAO Did This Study

Representative Payees—persons who 

SSA staff appoint to manage Social 

Security benefits for those unable to do 

so for themselves—play an important 

role in ensuring that beneficiary needs 

are met. In fiscal year 2012, about 5.9 

million payees managed $72 billion in 

annual benefits for nearly 8.4 million 

beneficiaries, a number that is likely to 

grow as the population ages. Congress 

and others have expressed concerns 

that SSA may not be well positioned to 

administer the Representative Payee 

Program, as currently structured, in the 

future. This report examines (1) 

administrative challenges facing the 

program and steps SSA has taken to 

address them and (2) long-term 

challenges and actions SSA has taken 

or could take to address them.

To answer these objectives, GAO 

reviewed relevant research, policies, 

federal laws and regulations, and other 

documents. GAO interviewed SSA 

officials and other parties, and visited

the Philadelphia Regional Office. GAO 

also reviewed program trend data and 

studies on challenges associated with 

an aging population. GAO reviewed 

options SSA could consider to address 

program challenges and conducted 

interviews to identify the strengths and 

weaknesses of these options.

What GAO Recommends

GAO recommends that SSA (1) 

evaluate the effectiveness of its 

criminal bar pilot, (2) estimate longterm program needs, and (3) develop a 

long-term strategy for addressing 

challenges that includes assessing 

options to streamline the program. 

SSA agreed with all three 

recommendations. 

What GAO Found

The Social Security Administration (SSA) struggles to effectively administer its 

Representative Payee Program, despite steps taken to address its challenges in 

identifying, selecting, and monitoring representative payees. For example, due to 

increasing workloads and staff attrition, SSA field office managers in some 

offices said they sometimes have to perform payee program duties that lower 

level staff typically handle. SSA has also experienced an increasing number of 

beneficiaries who may not have a suitable payee available. In an effort to 

address this challenge, SSA hosted a webinar to recruit additional payees. 

However, SSA officials said this effort did not result in the addition of any new 

payees. SSA also faces challenges ensuring that payees who are selected are 

suitable for the task. To help address this challenge, SSA implemented a pilot 

program in its Philadelphia region to screen and bar payee applicants who have 

been convicted of certain crimes. The pilot relies on self-reported information

from payee applicants, but SSA plans to screen applicants by accessing a 

commercial database that contains state-level criminal information. This 

database, however, does not contain information from every state and it is not 

clear how SSA will address this limitation. SSA also faces challenges monitoring 

payees’ use of beneficiaries’ SSA funds—a time-consuming process. SSA

developed an electronic accounting process that allows payees to submit reports 

online, which saves SSA time on handling the reports and scanning paper 

reports. However, it does not lessen the need for SSA staff to review some of 

these reports. SSA has also taken other steps to improve the administration of 

the program, but the SSA Office of the Inspector General (OIG) nonetheless 

continues to identify the program as a major SSA management challenge.

Although changing demographics and resource constraints will challenge the 

future administration of the Representative Payee Program, SSA has done little 

to position itself for the long term. The projected growth in the aged population, 

as well as the incidence of individuals with dementia, will have implications for 

the program, as SSA will have to spend more resources finding and monitoring 

payees. These challenges are exacerbated by staff and resource constraints, 

which could make SSA less able to identify and address payee benefit misuse. 

Some of the steps SSA has taken align with goals in the agency’s Strategic Plan. 

For example, SSA’s piloting of a new payee screening and selection process is 

an effort to better protect the program from fraud, waste, and abuse—one of the 

objectives included in the plan. Nonetheless, SSA does not plan to assess 

whether the pilot actually reduces the incidence of benefit misuse in the long run. 

Further, SSA has not projected the future need for payees, the likely 

characteristics of beneficiaries, or the resources needed to administer the 

program. Others have identified a range of options that could help SSA address 

its long-term challenges by increasing its pool of payees and better targeting its 

monitoring practices. Experts and stakeholders we interviewed identified tradeoffs for each of these options, citing the need to balance the potential benefit of 

reducing SSA’s workloads with the possible increased risk of benefit misuse by 

payees. SSA has considered some options, but it has not fully assessed and 

compared the potential benefits and feasibility of implementing these options. 

View GAO-13-473. For more information, 

contact Daniel Bertoni at (202) 512-7215 or 

bertonid@gao.gov.
Page i GAO-13-473SSA Representative Payee Program

Letter 1 

Background 3

SSA Has Taken Some Steps to Address the Current Challenges It 

Faces in Identifying, Selecting, and Monitoring Representative 

Payees 8

SSA Has Done Little to Position Itself to Address the Program’s 

Long-Term Challenges 12

Conclusions 23

Recommendations for Executive Action 24

Agency Comments 24

Appendix I Methodology for Identifying Options and Their Strengths 

and Weaknesses 27

Appendix II Comments from the Social Security Administration 29

Appendix III GAO Contact and Staff Acknowledgments 33

Related GAO Products 34

Tables

Table 1: Potential Options to Address SSA Challenges 16

Table 2: List of Entities Interviewed 28

Figures

Figure 1: Proportion of Beneficiaries with Payees in December 

2012, by Benefit Type and Age 4

Figure 2: Past and Future Number of SSA Beneficiaries 13

Contents 
Page ii GAO-13-473SSA Representative Payee Program

Abbreviations

OASDI Old-Age, Survivors, and Disability Insurance

OIG Office of the Inspector General 

NDRN National Disability Rights Network

NRC National Research Council

SSA Social Security Administration

SSI Supplemental Security Income

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Page 1 GAO-13-473 SSA Representative Payee Program

441 G St. N.W.

Washington, DC 20548

May 29, 2013

Congressional Requesters

The Social Security Administration’s (SSA) Representative Payee 

Program appoints representative payees (payees) to manage the OldAge, Survivors, and Disability Insurance (OASDI)1 and Supplemental 

Security Income (SSI)2

In addition to the broader implications of sustained program growth, 

Congress and others have expressed concerns that SSA may not be well 

positioned to administer the Representative Payee Program, as currently 

structured, in the future. In light of these concerns, this report examines 

the

benefits received by individuals who are unable to 

do so for themselves. Typically, SSA appoints a spouse, parent, or other 

close relative to be the payee, but may also appoint another individual, a 

public or nonprofit agency, or another organization, depending on the 

beneficiary’s circumstances. Payees can only use SSA benefits to 

provide beneficiaries with food, clothing, shelter, medical care, and 

personal comfort items. SSA reported that, in fiscal year 2012, about 5.9 

million payees managed $72 billion in annual benefits for nearly 8.4 

million beneficiaries (14 percent of all SSA beneficiaries). Consistent with 

the growth in the overall number of SSA beneficiaries, the number of 

beneficiaries needing a payee has grown over the years—by nearly 20 

percent between 2002 and 2011.

(1) administrative challenges facing the Representative Payee Program 

and steps SSA has taken to address them, and

 

1

The OASDI program provides monthly benefits to qualified retired and disabled workers 

and their dependents and to survivors of insured workers. Eligibility and benefit amounts 

are determined by the worker’s contributions to Social Security. For additional information 

about the legal requirements pertaining to representative payees for the OASDI program, 

see 42 U.S.C. § 405(j) and 20 C.F.R. § 404.2001 et seq. 

2

The SSI program provides income support to persons aged 65 or older, blind or disabled 

adults, and blind or disabled children. In order to qualify for benefits, an individual’s 

income and resource levels must be below certain amounts. For additional information 

about the legal requirements pertaining to representative payees for the SSI program, see 

42 U.S.C. § 1383(a) and 20 C.F.R. § 416.601 et seq.

 
 

Page 2 GAO-13-473 SSA Representative Payee Program

(2) long-term challenges and actions SSA has taken or could take to 

address them.

To identify the administrative challenges facing the Representative Payee 

Program, we reviewed reports by SSA’s Office of the Inspector General 

(OIG), the National Research Council (NRC), and others.3 We 

interviewed SSA officials, including field office managers from 6 of SSA’s 

10 regions,4

To identify the long-term challenges facing the Representative Payee 

Program, we reviewed reports on the payee program and interviewed 

SSA, NRC, and Social Security Advisory Board officials, as well as 

experts and members of organizations knowledgeable about the program. 

To determine the actions SSA has taken or could take to position itself to 

address the program’s long-term challenges, we reviewed relevant 

program policies and procedures and interviewed SSA officials. In 

and others knowledgeable about the program such as staff 

from the Social Security Advisory Board (SSAB). We also visited the 

Philadelphia Regional Office to learn about SSA’s ongoing pilot initiative 

to screen and bar certain types of criminals from becoming payees. We 

obtained more detailed information from the OIG on their past findings 

and recommendations relevant to the administration of the program and 

met with members of the NRC to better understand the impetus for their 

recommendations in this area. Furthermore, we reviewed beneficiary and 

payee data from annual SSA reports to describe beneficiary and payee 

trends. We assessed the reliability of the data by reviewing the 

methodology used to develop them and determined that the data were 

sufficiently reliable to describe payee trends and beneficiary trends and 

projections.

 

3

See for example SSA Office of the Inspector General, Annual Representative Payee 

Accounting Report Non-responders, A-06-10-11069 Audit Report (March 2011); National 

Research Council, Committee on Social Security Representative Payees, Improving the 

Social Security Representative Payee Program: Serving Beneficiaries and Minimizing 

Misuse (Washington, D.C.: 2007); and Social Security Advisory Board, Social Security 

Advisory Board Issue Brief Series: Disability Programs in the 21st Century: The 

Representative Payee Program (Washington, D.C.: September 2010).

4

We asked the National Council of Social Security Management Associations, an 

organization that represents SSA field office managers nationwide, to arrange a meeting 

with field office managers. The Council subsequently reached out to field office managers 

nationwide and arranged for us to meet with managers from the Denver, New York, 

Atlanta, San Francisco, Boston, and Dallas regions. Since we did not systematically select 

these managers, the results of these meetings are not generalizable to all SSA regions. 
 

Page 3 GAO-13-473 SSA Representative Payee Program

addition, we reviewed relevant federal laws and regulations governing the 

Representative Payee Program to gain a further understanding of 

program requirements. We also reviewed reports on the payee program, 

as well as literature on similar programs, to identify options SSA could 

consider to address the long-term challenges facing the program.5

We conducted this performance audit from April 2012 to May 2013 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 findings and 

conclusions based on our audit objectives.

We 

interviewed experts and members of organizations knowledgeable about 

the program to obtain their views on the potential strengths and 

weaknesses of each option identified. Although these views represent 

many points of view, they are not representative of all potential views. 

Beneficiaries needing a payee fall into one of three basic categories: (1) 

child beneficiaries—almost all children under age 18 have payees,6

 

5

For more information on how we identified options and their potential strengths and 

weaknesses, see appendix I.

(2) 

those who are legally incompetent or mentally incapable of managing 

benefit payments, and (3) beneficiaries who are physically incapable of 

managing or directing the management of their benefit payments. SSA 

claims representatives determine whether a beneficiary needs a 

representative payee by reviewing court determinations of legal 

incompetency, medical evidence, or statements of relatives, friends, or 

others who know and observe the beneficiary concerning the 

beneficiary’s ability to manage or direct the management of his or her 

benefits. In December 2012, over 8.6 million individuals had a 

representative payee—over 5.3 million received only OASDI benefits, 

almost 2.5 million received only SSI benefits, and over 830,000 received 

6

For beneficiaries under age 18, SSA generally will pay benefits to a representative 

payee. However, in certain situations, SSA may make direct payments to a beneficiary 

under age 18 who shows the ability to manage the benefits. In addition, SSA generally will 

withhold benefit payments to beneficiaries under the age of 15 until a representative 

payee is appointed. 

Background 
 

Page 4 GAO-13-473 SSA Representative Payee Program

OASDI and SSI concurrently. See figure 1 for an overview of the 

percentage of beneficiaries with a payee, by benefit type and age.

Figure 1: Proportion of Beneficiaries with Payees in December 2012, by Benefit Type and Age

According to SSA data, about 76 percent of SSI recipients and Disability 

Insurance beneficiaries who had a payee in 2011 suffered from a mental 

health condition. The most prevalent condition for each of these 
 

Page 5 GAO-13-473 SSA Representative Payee Program

beneficiary groups was intellectual disability. As of January 2013, family 

members served as representative payees for about 85 percent of 

beneficiaries who had a payee.

SSA may appoint an individual or organization to be a representative 

payee. Organizational payees—which can include social service 

agencies, state mental institutions, and state or local government 

agencies—may offer their services free of charge or they may collect a 

capped fee, provided they meet certain conditions.7 Certain individuals 

are not eligible to serve as representative payees. For example, in order 

to be eligible to serve as a representative payee, an individual cannot be 

a fugitive felon8 or have been convicted of certain felonies, including 

those related to Social Security fraud, misuse of SSA benefits, or 

concealing or failing to disclose knowledge of events affecting entitlement 

to or payment of Social Security benefits.9

SSA administers the Representative Payee Program through a network of 

over 1,200 field offices located across the country.10

 

7

To qualify as a fee-for-service payee, an organization must (1) be a state or local 

government agency with fiduciary responsibilities whose mission is to carry out income 

maintenance, social service, or health care-related activities or (2) be a tax exempt 

community-based nonprofit social service organization that is bonded and licensed 

(provided licensing is available) in the state where it serves as a payee. The organization 

must regularly provide payee services concurrently to at least five beneficiaries and 

generally may not be a creditor of the beneficiary. 

According to SSA 

and NRC officials, the process for administering the program consists of 

many time-consuming and often complicated steps, guided largely by 

8

Based on the settlement agreement reached in the Martinez et. al v. Astrue case, 

effective April 1, 2009, a person who has an unsatisfied felony warrant issued for any of 

these offenses is considered a fugitive felon and is prohibited from serving as a payee: (1) 

escape from custody; (2) flight to avoid prosecution or confinement; or (3) flight-escape.

9

In addition, when considering payee applicants with a past history of criminal behavior, 

SSA staff are advised to consider the type of crime and when the crime was committed, 

along with the applicant’s relationship to the beneficiary. Individuals with a criminal past 

are not to be appointed as payees unless SSA determines that there is not a more 

suitable payee available and that the applicant does not pose a risk to the beneficiary and 

will act in the best interests of the beneficiary. 

10SSA staff in the Office of the Deputy Commissioner, Retirement and Disability Policy is 

responsible for developing Representative Payee Program policies and procedures while 

staff in the Office of the Deputy Commissioner, Operations supports field office staff by 

addressing representative payee business process and automation issues. 
 

Page 6 GAO-13-473 SSA Representative Payee Program

requirements in statute and SSA regulations.

11 These steps are primarily 

completed by field office claims representatives who are also responsible 

for other work processes, such as interviewing individuals to determine 

their eligibility for OASDI and SSI benefits. According to SSA’s 

guidance,12

1. Identify Potential Payees

once a beneficiary is determined to need a representative 

payee, SSA staff perform the following activities: 

SSA claims representatives use a variety of approaches to identify 

prospective payees, including asking the beneficiary if there is an 

individual whom he or she trusts; reviewing beneficiary claims files and 

any available medical records; and consulting with local government, 

social service, and other providers who can often provide payee contacts. 

If no payee is readily available, the claims representative tries to find a 

payee by consulting the list of payee sources (e.g., local organizations 

with volunteers who can serve as payees) that each field office is required 

to maintain.

2. Screen Potential Payees

After identifying prospective payees, claims representatives interview 

them to assess their suitability, considering factors such as the nature of 

their relationship to the beneficiary and whether they are knowledgeable 

about the beneficiary’s needs. In addition, claims representatives receive 

automated messages during the screening process that show whether a 

prospective payee is a fugitive felon or otherwise prohibited by law from 

serving as a representative payee.

3. Appoint a Payee

SSA’s guidance includes preference lists to assist claims representatives 

in selecting a payee when more than one candidate is available. For 

example, the preference list for adults is as follows:13

 

11With respect to OASDI, see 42 U.S.C. § 405(j) and 20 C.F.R. § 404.2001 et seq., and 

with respect to SSI, see 42 U.S.C. § 1383(a) and 20 C.F.R. § 416.601 et seq.

12SSA Program Operations Manual System (POMS), sections GN 00501.015, GN 

00502.000, GN 00604.001, GN 00605.001, GN 00605.005, GN 00605.067, and GN 

00605.400. 

13SSA also has separate preference lists for (1) adults who are disabled and who have a 

drug addiction or alcoholism condition and (2) beneficiaries under age 18.
 

Page 7 GAO-13-473 SSA Representative Payee Program

(1) a spouse, parent or other relative with custody or who shows 

strong concern; 

(2) a legal guardian/conservator with custody or who shows strong 

concern;

(3) a friend with custody;

(4) a public or nonprofit agency or institution;

(5) a federal or state institution;

(6) a statutory guardian;

(7) a voluntary conservator;

(8) a private, for-profit institution with custody and is licensed

under state law;

(9) a friend without custody, but who shows strong concern for the 

beneficiary’s well-being, including persons with power of 

attorney; 

 

(10) anyone not listed above who is qualified and able to act as 

payee, and who is willing to do so; and

(11) an organization that charges a fee for its service.

Although claims representatives are generally expected to select payees 

in the order in which they are listed, they may deviate from this order 

based on their assessment of the beneficiary’s individual circumstances. 

In selecting a payee, claims representatives are primarily concerned with 

identifying someone who will best serve the beneficiary’s interest.

4. Monitor Payees

SSA staff monitor payees to identify potential misuse—the use of SSA 

funds for purposes other than the needs of the beneficiary. SSA field 

office and other staff monitor payees by reviewing the annual accounting 

reports that payees submit to document how the payee spent Social 

Security funds on behalf of the beneficiary. Certain payees are also 

subject to periodic site reviews. For example, individuals serving as a 

payee for 15 or more beneficiaries and certain organizational payees, 
 

Page 8 GAO-13-473 SSA Representative Payee Program

including agencies that serve 50 or more beneficiaries, are subject to 

these reviews.14

SSA has faced challenges identifying, selecting, and monitoring 

representative payees. For example, field office managers said that some 

field offices have been struggling to keep up with payee program 

workloads due to staff attrition and that managers themselves sometimes 

have to perform payee program duties that claims representatives 

typically handle, such as processing payee applications. In addition, SSA 

has experienced an increasing number of beneficiaries, such as persons 

suffering from mental health conditions or the elderly, who may not have 

a suitable payee readily available. Recognizing the challenges associated 

with finding payees for some beneficiaries, SSA attempted to identify and 

recruit individuals and organizations who would be willing to serve as 

payees. For example, SSA partnered with the National Alliance on Mental 

Illness in 2012 to host a webinar to recruit additional payees for 

beneficiaries suffering from mental health conditions. However, as of April 

4, 2013, SSA officials said this effort did not result in the addition of any 

new payees. SSA officials told us that they posted the webinar to 

YouTube in an effort to reach a larger segment of the population.

SSA has also taken steps to address challenges it has had with ensuring 

that payees who are assigned are suitable for the task. For instance, in 

June 2012, SSA initiated a pilot in its Philadelphia region to screen and 

block payee applicants who have been convicted of any 1 of 12 types of 

felonies.15

 

14SSA conducts several different types of reviews based on factors such as the type of 

payee and number of beneficiaries served. 

Under the pilot, SSA field staff are required to bar certain 

15For this pilot, applicants who have been convicted of the following felonies may not 

serve as payees: human trafficking, false imprisonment, kidnapping, rape/sexual assault, 

first degree homicide, robbery, fraud to obtain governmental assistance, fraud by scheme, 

theft of government funds, abuse/neglect, forgery, and identity theft. Although the pilot 

procedures only apply to payee applicants located in SSA’s Philadelphia region, by law, 

certain types of fugitive felons and other groups are prohibited from serving as payees 

nationwide. In addition, SSA has the discretion to determine on a case by case basis 

whether certain other types of crimes disqualify individuals from serving as payees. 

SSA Has Taken Some 

Steps to Address the 

Current Challenges It 

Faces in Identifying, 

Selecting, and 

Monitoring 

Representative 

Payees 
 

Page 9 GAO-13-473 SSA Representative Payee Program

payee applicants who have committed one or more of these crimes.16

According to SSA officials, as of January 23, 2013, SSA staff in the 

Philadelphia region barred 108 out of 10,291 applicants from serving as 

payees as a result of the pilot.17 SSA said that the pilot primarily relies on 

self-reported information from payee applicants. In our past work, we 

found that reliance on self-reported information alone can be problematic 

because it may not be accurate.

18 In April 2013, SSA published a notice 

in the Federal Register that agency officials said would allow them to 

collect data necessary to use Lexis/Nexis Accurint, a database that 

contains state-level felony and misdemeanor information, to perform 

criminal background checks on payee applicants.19

 

16Under the pilot, SSA does not automatically bar the custodial parent, custodial spouse, 

or custodial court-appointed legal guardian of the beneficiary for whom the applicant is 

applying to serve as the payee when such individuals have been convicted of one of the 

felonies included in the pilot. In these cases, and consistent with SSA’s guidance for its 

staff, SSA staff weigh various factors, including the payee’s criminal history and 

relationship to and custody of the beneficiary, before deciding whether to appoint them to 

serve as a payee. 

According to SSA 

officials, the agency is currently testing an automated tool to query the 

Accurint database as well as developing field office procedures and 

training materials. SSA plans to begin using the database to screen 

payee applicants in the summer of 2013. Although the database could 

help SSA staff in the Philadelphia region better screen payee applicants, 

it is limited because it does not contain data from every state. It is not 

clear how, if at all, SSA is going to address these limitations. SSA said 

the focus of the pilot is to determine how easily these additional controls 

can be implemented. For example, SSA is interested in determining how 

difficult it is for field staff to find a suitable alternative payee after they bar 

17According to SSA, the 10,291 payees include all payee applicants since the pilot began, 

including those who were exempt from the pilot such as custodial parents. SSA does not 

have data on the proportion of beneficiaries for whom a prospective payee was not 

selected based on the pilot restrictions or the number of payees who were already 

assigned and subsequently had to be removed from serving as a payee. 

18GAO, Social Security Disability: Ticket to Work Participation Has Increased, but 

Additional Oversight Needed, GAO-11-324 (Washington, D.C.: May 6, 2011) and 

Supplemental Security Income: SSA Could Enhance Its Ability to Detect Residency 

Violations, GAO-03-724 (Washington, D.C.: July 29, 2003). 

19 Privacy Act of 1974; Proposed New Routine Uses and System of Records Alterations, 

78 Fed. Reg. 23,811 (April 22, 2013). 
 

Page 10 GAO-13-473 SSA Representative Payee Program

a payee applicant.20

SSA has also taken steps to improve its ability to monitor payee activities. 

Generally, all representative payees are required to file an annual 

accounting report that shows how they spent beneficiaries’ SSA funds. 

According to SSA officials and the OIG, obtaining these reports, reviewing 

them, and following-up on delinquent reports is extremely time-consuming 

for staff. For example, the OIG found that SSA staff expend considerable 

effort to obtain accountings, which sometimes required multiple mailings, 

telephone calls, and face-to-face meetings, and, in some instances, took 

several months to complete.

According to SSA, if the pilot is successful it will be 

implemented nationwide in fiscal year 2014.

21

In 2011, to better leverage its resources, SSA replaced its discretionary, 

special reviews of a random sample of organizational payees with 

reviews targeting payees at higher risk of misusing benefits. SSA 

expanded this approach in fiscal year 2012 to include higher risk 

individual payees, not including custodial parents or custodial spouses, 

serving 14 or fewer beneficiaries.

SSA developed an electronic accounting 

process that allows payees to submit reports online, which saves SSA 

time on handling the reports and scanning paper reports. However, it 

does not lessen the need for SSA staff to review some of these reports.

22

 

20On February 11, 2013, SSA published a notice in the Federal Register to solicit 

feedback from the public on whether it has selected the appropriate types of crimes and 

whether there are other crimes that should be considered, among other things. Individuals 

with Certain Criminal Convictions as Representative Payees, 78 Fed. Reg. 9766 (Feb. 11, 

2013).

SSA identifies these payees using a 

misuse predictive model that relies on certain payee and beneficiary 

characteristics, as recommended by the NRC and OIG. These reviews 

complement those that SSA is required to perform on organizational 

payees serving 50 or more beneficiaries and individual payees serving 15 

or more beneficiaries, in accordance with Social Security Act 

requirements. According to SSA, it used the model to select 557 

organizations and 256 individual payees for review in fiscal year 2012 

21SSA OIG, Annual Representative Payee Accounting Report Non-responders, A-06-10-

11069 (March 2011). 

22According to SSA officials, custodial parents and spouses generally serve appropriately 

as payees. 
 

Page 11 GAO-13-473 SSA Representative Payee Program

(nearly 40 percent of all reviews).23

SSA has taken other steps to help it improve the management and 

operations of the Representative Payee Program. For example, SSA is in 

the process of redesigning its Representative Payee System—the 

electronic system used to record payee applications, payee performance, 

and any significant information about the payee, among other things. SSA 

has also provided additional guidance and training to payees and field 

office staff to help them better understand their roles and responsibilities, 

as well as implemented other actions to address numerous 

recommendations made by the SSA OIG. Nonetheless, the OIG 

continues to identify the program as a major management challenge 

facing SSA.

Based on their testing of the model, 

SSA officials expect it to identify many more instances of payee benefit 

misuse than random reviews. However, SSA officials said they have not 

yet completed a sufficient number of reviews to determine whether the 

model is performing as expected. 

24

 

23SSA, Annual Report on the Results of Periodic Representative Payee Site Reviews and 

Other Reviews for Fiscal Year 2012 (Jan. 31, 2013). 

24SSA OIG, Fiscal Year 2012 Inspector General Statement on the Social Security 

Administration’s Major Management and Performance Challenges, A-02-13-13041 (Nov. 

8, 2012).
 

Page 12 GAO-13-473 SSA Representative Payee Program

Changing demographics will challenge SSA’s ability to effectively 

administer its Representative Payee Program in the future. The 

proportion of elderly individuals is projected to grow to nearly 20 percent 

of the total population over the next two decades. As a result, it is 

estimated that not only could the number of SSA beneficiaries grow by as 

much as 55 percent, but that the number of aged beneficiaries could 

increase from over 38 million in 2012 to over 72 million in 2035. This 

projected growth in the number of beneficiaries, especially the increase in 

the proportion of aged beneficiaries, will have implications for the 

Representative Payee Program (see fig. 2).

SSA Has Done Little 

to Position Itself to 

Address the 

Program’s Long-Term 

Challenges 

Changing Demographics 

and Resource Constraints 

Pose Long-Term 

Challenges for the 

Representative Payee 

Program
 

Page 13 GAO-13-473 SSA Representative Payee Program

Figure 2: Past and Future Number of SSA Beneficiaries

Notes: Some beneficiaries may receive more than one type of SSA benefit. These projections do not 

separate out concurrent beneficiaries.

Some of these beneficiaries receive auxiliary benefits which are monthly benefits payable to a spouse 

or child of a retired or disabled worker, or to a survivor of a deceased worker.

While age alone does not determine one’s capability to manage personal 

finances, research shows that the incidence of Alzheimer’s and other 

forms of dementia that undermine judgment increases with age.25

 

25Hebert et al., “Alzheimer Disease in the US Population,” Archives of Neurology, 60 

(August 2003): 1119-1122. Agarwal et al., “The Age of Reason: Financial Decisions over 

the Life Cycle and Implications for Regulation,” Brookings Papers on Economic Activity 

(Washington, D.C.: 2009): 51-117. 

Researchers estimate that, by 2025, the number of people aged 65 years 

and older with Alzheimer’s could increase by as much as 30 percent—
 

Page 14 GAO-13-473 SSA Representative Payee Program

from the 5.2 million persons affected in 2012 to 6.7 million.26 Given the 

projected growth in the aged population, SSA will likely be challenged to 

locate more payees as well as monitor a greater number of them in the 

future.27

Staff and resource constraints also present challenges for the future 

administration of the Representative Payee Program. For example, the 

impacts of a hiring freeze and anticipated retirements of SSA staff will 

further impair the agency’s ability to effectively manage the program—a 

problem common to other SSA workloads, such as claims processing. In 

fact, in 2009 we reported that staffing constraints were having adverse 

effects on SSA field office services and that field office staff were having 

to defer some of the work they considered of lower priority.28 More 

recently, field office managers we spoke with said that, to the extent that 

SSA field offices are required to do progressively more with limited staff 

and resources, they will be less likely to identify and address instances of 

payee benefit misuse.

SSA has not developed a comprehensive plan for addressing the 

challenges the Representative Payee Program faces over the long term. 

SSA’s Strategic Plan notes the future challenges, including growing 

workloads and limited resources, facing all of its programs. Even though 

representative payee activities are not specifically mentioned in the plan, 

according to SSA, these activities align with the plan’s goal to preserve 

the public’s trust in its programs by (1) simplifying and streamlining how 

SSA does its work and (2) protecting programs from waste, fraud, and 

abuse. SSA officials said, for example, the Philadelphia criminal bar pilot 

and the application of a misuse predictive model to select payees for 

review using selected beneficiary and payee characteristics are steps the 

agency is taking to better safeguard beneficiaries. While SSA plans to 

 

26Alzheimer’s Association, 2012 Alzheimer’s Disease Facts and Figures, Alzheimer’s & 

Dementia, Vol. 8, Issue 2.

27While the scope of our report does not include a review of SSA’s process to determine a 

beneficiary’s competence, in 2010 the OIG reported that there may be about 1 million 

beneficiaries over age 85 who are incapable of managing their benefits and are in need of 

payees but do not have one. SSA OIG, Aged Beneficiaries in Need of Representative 

Payees, A-09-09-29002 (Apr. 5, 2010).

28GAO, Social Security Administration: Service Delivery Plan Needed to Address Baby 

Boom Retirement Challenges, GAO-09-24 (Washington, D.C.: Jan. 9, 2009). 

SSA Has Not Engaged in 

Long-Term Planning for 

the Representative Payee 

Program
 

Page 15 GAO-13-473 SSA Representative Payee Program

assess how easily the pilot can be implemented, it has no plans to 

determine whether the pilot actually reduces the incidence of benefit 

misuse by payees in the long-run. We have previously reported that 

program evaluation can play a key role in long-term planning efforts by 

providing feedback on both program design and execution, including 

whether an agency’s efforts are effective in resolving a problem or filling a 

need.29

Furthermore, SSA has done little long-term planning to address the 

workload challenges the Representative Payee Program faces. SSA 

acknowledged the need to better understand the future needs of the 

program, but it has not determined how many beneficiaries will likely need 

payees in the future and their characteristics. GAO’s standards for 

internal control state that an agency should assess the risks it faces from 

both external and internal sources.30

Through our review of prior reports on the payee program and similar 

programs, we identified several options proposed by various experts and 

stakeholders that might help SSA address its growing workload demands 

by increasing its pool of payees, targeting its monitoring activities, or both. 

(See table 1.) We conducted 14 interviews with experts and members of 

organizations who are knowledgeable about the payee program 

(interviewees) to gain their perspectives on the potential strengths and 

weaknesses of these options.

While the reasons for the potential 

growth in the program fall beyond SSA’s control, such as an increase in 

older beneficiaries, assessing this growth can affect the program’s 

chances for success. Agencies can use such assessments to assist them 

in determining how to best manage risk, as well as the staff skills and 

resources needed to address operational challenges for the short- and 

long-term. Some experts have suggested that the payee program does 

not garner attention from SSA because the agency considers it a lower 

priority than other SSA activities such as claims processing.

31

 

29GAO, Designing Evaluations: 2012 Revision, 

Interviewees identified trade-offs with 

GAO-12-208G (Washington, D.C.: January 

2012). 

30GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

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

31See appendix I for further information on the methodology used to identify the options 

and a list of experts and organizations. We did not conduct an independent review of the 

feasibility or potential impact of any of these options.

Others Have Identified a 

Range of Options That 

Could Address SSA’s LongTerm Challenges
 

Page 16 GAO-13-473 SSA Representative Payee Program

each of the options, mostly related to balancing SSA’s efforts to 

streamline and simplify the program while adequately protecting 

beneficiaries from fraud and abuse. Additionally, more than one 

programmatic change may be necessary to best position SSA to meet its 

growing workload demands. These options, as well as interviewees’ 

views on them, are described below.

Table 1: Potential Options to Address SSA Challenges 

Option Description

Options to increase the pool of payees 

Develop and maintain a group of readily available 

certified payees

SSA, or an entity under contract to SSA, could develop a program to identify, 

train, and certify payees who would then be available on an as-needed basis 

when SSA has difficulty finding a payee for a beneficiary. 

Permit a broader range of organizations to collect a 

fee for serving as a payee

Change the requirements in the law that organizations need to meet to collect 

a fee for their payee services by, for example, allowing for-profit organizations 

to collect a fee or changing the requirement that an organization serve at least 

five beneficiaries.

Select individuals appointed by other entities Automatically appoint an individual and organization as a beneficiary’s payee if 

they are already designated by one of a range of legal authorities and entities 

to oversee the beneficiary’s assets. 

Options to further target monitoring activities

Reduce monitoring requirements for custodial parents 

and spouses 

Change the law to eliminate or lessen monitoring requirements for payees who 

are the custodial parent of the beneficiary for whom they are payee and for 

spousal payees who live with a beneficiary. 

Reduce monitoring requirements for individuals 

appointed by other entities

Change the law to eliminate or lessen monitoring practices for payees if they 

are already designated by one of a range of legal authorities and entities to 

oversee the beneficiary’s assets.

Expand “risk-based targeting” approach to exempt 

some payees from annual accountings 

Change the law to allow SSA the flexibility to select payees who would be 

required to file accountings based on indicators of misuse.

Expand use of outside organizations for monitoring Expand the current contract with the National Disability Rights Network to have 

it conduct additional reviews that are currently completed by SSA staff.

Options to potentially address challenges with finding and monitoring payees

Drop payee requirement for children Allow custodial parents to automatically receive benefits on behalf of their 

children and not require the custodial parent to apply or be designated as a 

payee. 

Enhance coordination with entities that serve similar 

populations 

Further develop relationships on payee matters with state Adult Protective 

Service agencies, state courts, state protection and advocacy agencies, Area 

Agencies on Aging, Aging and Disability Resource Centers, and state foster 

care agencies, and to the extent practical and permissible, share information 

with them on payee matters.

Source: GAO analysis.
 

Page 17 GAO-13-473 SSA Representative Payee Program

Develop and maintain a group of readily available certified payees

As noted earlier, SSA’s most recent efforts to recruit more payees have 

not been very successful. The lack of additional payee volunteers may be 

because local service providers, such as those that serve individuals with 

developmental disabilities or the elderly, are facing similar resource 

constraints as SSA. Many interviewees said that it might not be costeffective for SSA to invest its scarce resources on an effort that would 

likely yield few volunteers. Two interviewees suggested that, if SSA were 

to pursue this option, the agency should pilot it first. Most interviewees 

agreed that contracting out responsibility for developing and maintaining a 

pool of payees would be more cost-effective for SSA than performing 

these activities itself. Using an outside entity would also allow SSA staff to 

focus on other tasks, and the agency could hold the contractor 

accountable for maintaining a pool of qualified payees. For example, SSA 

could require the contractor to find qualified payees who would commit to 

serving as payees for a specified amount of time. Additionally, SSA could 

structure the contract so that it emphasizes the need to find payees for 

certain beneficiary groups such as the elderly or persons with 

developmental disabilities.

Permit a broader range of organizations to collect a fee for serving 

as a payee

Under federal law, a payee can only qualify to collect a fee from a 

beneficiary if the payee is (1) a state or local government agency with 

fiduciary responsibilities whose mission is to carry out income 

maintenance, social service, or health care-related activities or (2) a taxexempt community-based nonprofit social service organization that is 

bonded and licensed (provided licensing is available) in the state where 

they serve as a payee. The organization must also regularly provide 

payee services concurrently to at least five beneficiaries and generally 

may not be a creditor of the beneficiary. In 2013, fee-for-service payees 

could collect up to 10 percent of a beneficiary’s benefit up to a maximum 

of $39 per month, and up to $76 if they serve as a payee for a person 

suffering from drug addiction or alcoholism.32

 

32By law, the fee amount qualified organizations may collect for providing representative 

payee services is limited. Each year, the fee amount is subject to an increase in 

December by the same percentage as the cost-of-living adjustment. However the 

organization may not collect the increased fee until the January payment.

Changing the law to allow 

Options to Increase the Pool of 

Payees 
 

Page 18 GAO-13-473 SSA Representative Payee Program

more organizations to collect a fee could enable SSA to access a larger 

pool of potential payees. Some interviewees cautioned that permitting a 

broader range of organizations to collect a fee could, however, create a 

perverse incentive for organizations to create a payee “business” where 

the focus would be on serving a larger number of beneficiaries rather than 

the best interests of beneficiaries. Lastly, this option could negatively 

affect beneficiaries since the fee is deducted from their SSA benefit. 

Some interviewees suggested that SSA could offset this potentially 

negative effect on beneficiaries by paying the fee from SSA funds, 

although SSA noted that this would require a statutory change.

Select individuals appointed by other entities

Courts in each state have the authority to appoint a guardian or 

conservator for individuals the court determines to be incapacitated. 

Generally, guardianships are legal relationships created when a state 

court grants one person or entity the authority and responsibility to make 

decisions in the best interest of an incapacitated individual concerning his 

or her person or property.33

 

33States use a variety of terms and somewhat different definitions to assess whether 

someone is in need of a guardian. In this report, we use the term “guardian” to refer to 

both guardians and conservators. See GAO, Incapacitated Adults: Oversight of Federal 

Fiduciaries and Court-Appointed Guardians Needs Improvement, 

Automatically selecting a person legally 

designated to manage the beneficiary’s assets, such as a guardian, to 

serve as a representative payee would not only lessen the time staff 

spend on screening payees, but could also reduce potential redundancies 

in screening procedures between SSA and state courts. However, the 

potential benefit of this option cannot be fully assessed because SSA 

officials said they do not have data on the number of guardians who 

currently serve as payees. Despite its potential benefits, this option could 

also face implementation challenges because some guardians may not 

want to serve as payees due to administrative program requirements. 

Further, automatically appointing individuals to serve as payees without 

screening them could be problematic because screening and eligibility 

GAO-11-678 

(Washington, D.C.: July 22, 2011). 
 

Page 19 GAO-13-473 SSA Representative Payee Program

criteria for guardians vary by state with some states having more stringent 

procedures than others.34

Reduce monitoring requirements for custodial parents and spouses

In 2009, SSA submitted a legislative proposal to Congress to eliminate 

the statutory requirement that payees who are custodial parents of 

children who receive benefits, or spouses who live with a beneficiary, file 

annual accountings. If enacted, such a change could reduce SSA’s 

workload because, as noted earlier, SSA spends a considerable amount 

of time obtaining and reviewing accounting reports and family members, 

primarily parents and spouses, serve 85 percent of beneficiaries who 

have payees. Nonetheless, annual accounting reports serve as an 

important reminder that SSA funds should be used for the beneficiary. An 

alternative that would lessen SSA’s workload burden while maintaining a 

level of accountability would be for SSA to reduce the frequency of 

accountings for custodial parents and spouses. To date, Congress has 

not enacted SSA’s legislative proposal.

Reduce monitoring requirements for individuals appointed by 

other entities

Eliminating or limiting monitoring practices for payees who already 

oversee a beneficiary’s assets by virtue of their status as a guardian or 

power of attorney could create many of the same challenges that might 

exist if SSA were to automatically appoint these groups without screening 

them. For example, although SSA initially might be able to save 

resources by not monitoring selected categories of payees, there could 

be long-term costs resulting from increased instances of payee fraud, 

waste, and abuse. Relying on state court monitoring also replaces a 

national framework with a variety of state practices, which could result in 

different standards for oversight and potentially make some beneficiaries 

more vulnerable to having their funds misused. Further, we previously 

 

34 We have also reported on the limited safeguards to protect persons from potential 

misuse and financial exploitation by guardians and persons with power of attorney. See 

GAO, Elder Justice: National Strategy Needed to Effectively Combat Elder Financial 

Exploitation, GAO-13-110 (Washington, D.C.: Nov. 15, 2012).

Options to Further Target 

Monitoring Activities
 

Page 20 GAO-13-473 SSA Representative Payee Program

reported that states face challenges adequately monitoring guardians and 

that persons with power of attorney can easily exploit beneficiaries.35

Expand “risk-based targeting” approach to exempt some payees 

from annual accountings

As previously noted, all payees are generally required by law to submit 

annual accounting reports for review by SSA. To better target its 

accounting reviews to payees who are most likely to misuse benefits 

based on the misuse predictive model described earlier, SSA could seek 

legislative changes to this requirement. This could allow SSA to focus its 

attention on areas of greater risk. During our review, SSA said that it is 

too soon to determine whether expansion of the risk-based targeting 

approach would be effective.

Expand use of outside organizations for monitoring

SSA currently contracts with the National Disability Rights Network 

(NDRN) to coordinate and oversee the completion of onsite reviews of 

selected organizational payees by state protection and advocacy 

agencies.

36

 

35See for example, 

As of November 2, 2012, SSA had received 557 payee 

review reports from the protection and advocacy agencies under this 

contract. As a result of these reviews, SSA referred 356 cases to the field 

offices to follow up on a range of payee issues, including incorrect bank 

account titling and payees not properly documenting beneficiary 

expenses. SSA also began investigating 13 payees for benefit misuse. 

Some experts have suggested that expanding NDRN’s contract to have it 

conduct site reviews for other payees, such as individuals, could help 

lessen the challenges SSA faces in conducting these reviews. Another 

alternative, which is being used by some courts are volunteer 

guardianship monitoring programs, would be to identify and train a pool of 

GAO-11-678 and Guardianships: Collaboration Needed to Protect 

Incapacitated Elderly People, GAO-04-655 (Washington, D.C.: July 13, 2004). 

36NDRN is the nonprofit membership organization for the federally mandated Protection 

and Advocacy Systems and Client Assistance Programs. The initial contract between SSA 

and NDRN was for the protection and advocacy agencies to conduct periodic site reviews 

of payees who also employ beneficiaries they serve as payee for. The contract has since 

been expanded to include other organizational payees. In 2012, SSA began to select the 

payees for review based on the misuse predictive model discussed earlier in this report. 

As part of this contract, protection and advocacy agencies are required to refer problems 

outside of SSA’s purview to other federal, state, or local agencies.
 

Page 21 GAO-13-473 SSA Representative Payee Program

volunteers to assist with monitoring. Under such an approach, SSA could 

work with volunteer organizations to train and certify individuals to monitor 

payees.37

Drop payee requirement for children

With both of these options, SSA would still have to devote 

some level of staff and resources to addressing any findings identified 

during the reviews.

More than half of all beneficiaries with a payee are under the age of 18 

and nearly 90 percent of these beneficiaries had their parent as a payee 

in 2011.38 According to SSA, custodial parents generally serve 

appropriately as payees for their children. Allowing custodial parents to 

automatically receive benefits on behalf of their children would reduce 

SSA staffs’ responsibility to screen and monitor parent payees, thus 

potentially freeing up staff and program resources to focus on aspects of 

the program SSA considers high need or high risk. This option would also 

decrease the burden on parents by not requiring them to apply to be their 

child’s payee or file annual accounting reports. According to a 

Department of Veterans Affairs’ (VA) official, the department does not 

require custodial parents to serve as payees for minors who receive 

monthly benefits. Nonetheless, eliminating the requirement that parents 

be assigned as payees also eliminates any safeguards—screening and 

monitoring—that would help to ensure that children’s benefits are being 

used on their behalf.39

 

37A study of this approach shows, however, that while the program could be successful, a 

volunteer program is not free because there are costs associated with training, 

supervising, and retaining volunteers, among other costs. Further, most of the programs 

that ended did so because they lacked volunteers and a mechanism to recruit them. Ellen 

Klem, Volunteer Guardianship Monitoring Programs: A Win-Win Solution. American Bar 

Association Commission on Law and Aging (2007).

 

38SSA, Annual Statistical Supplement to the Social Security Bulletin, 2012 (Feb. 2013); 

SSA,SSI Annual Statistical Report, 2011. 

39We have previously reported on some of the issues related to SSA’s oversight of the 

SSI program as it relates to children, including instances where SSA examiners lack 

complete information to inform their decision making. See GAO, Supplemental Security 

Income: Better Management Oversight Needed for Children’s Benefits, GAO-12-497 

(Washington, D.C.: June 26, 2012). 

Options to Potentially Address 

Challenges with Finding and 

Monitoring Payees 
 

Page 22 GAO-13-473 SSA Representative Payee Program

Enhance coordination with entities that serve similar populations

GAO and various experts have long recognized the need for better 

coordination and exchange of information between SSA and other entities 

that serve SSA beneficiaries and have made recommendations for SSA 

to share information with these entities to the extent permitted by law. For 

example, we reported in 2004 that the lack of systematic coordination 

weakens the oversight of incapacitated people and may leave them at 

risk of not being assigned a payee or guardian despite having been 

identified as needing one. We further reported that insufficient 

interagency coordination may leave incapacitated people more vulnerable 

to abuse or neglect.40

SSA has acknowledged that changes to the Representative Payee 

Program are needed to address its growing workloads and effectively 

manage the program, but told us that few of the options identified are 

currently under consideration by the agency. For example, SSA has 

recognized the potential benefits of some of these options, such as 

limiting parental accounting requirements and developing a pool of 

payees for hard to serve beneficiaries, and has taken steps toward 

implementing them. Nonetheless, SSA officials said they cannot 

implement several options, such as automatically assigning payees 

without screening them or limiting accounting requirements for certain 

groups of payees because they are statutorily required to conduct these 

activities. They also indicated that some of these options would not help 

Interviewees generally agreed that developing 

better relationships on payee matters with state and local entities is an 

important step toward helping SSA manage the program and leverage its 

constrained resources; however, several interviewees said there may be 

some challenges to sharing information on payee matters such as privacy 

issues and developing a data sharing mechanism. Sharing information 

could lessen the time SSA staff spend on screening payees and following 

up on delinquent accounting reports. For example, SSA could use 

information from state courts to determine whether or not to appoint a 

guardian as a payee or to better target its monitoring practices.

 

40See, for example, GAO-11-678 and GAO-04-655. More recently, we recommended that 

the Office of Management and Budget take an active role in considering additional 

opportunities to identify and disseminate useful data sharing practices and tools that 

address privacy requirements among human service programs. See GAO, Human 

Services: Sustained and Coordinated Efforts Could Facilitate Data Sharing While 

Protecting Privacy, GAO-13-106 (Washington, D.C: Feb. 8, 2013).
 

Page 23 GAO-13-473 SSA Representative Payee Program

SSA administer the program more effectively or would be too costly. For 

example, SSA said that creating a data sharing mechanism with state 

courts would cost too much; however, it has not formally or systematically 

estimated the cost of sharing this information. Some experts we spoke 

with highlighted the need for SSA to examine alternatives to manage the 

payee program. Further, GAO’s internal controls guidance states that 

agencies should determine what actions they should take to manage 

program risk.41 GAO has also reported that without effective short- and 

long-term planning, which takes into account the changing environment, 

federal agencies risk delivering programs and services that may not meet 

critical needs.42 SSA has not fully assessed the potential benefits and 

feasibility of these options or begun to explore other alternatives that 

could help it address the current and growing demands of the program. 

Such an assessment would inform the types of actions that SSA should 

take, including whether the agency should pursue developing legislative 

proposals for changes.

Given the significant role that payees play in the lives of many SSA 

beneficiaries, it is imperative for SSA to take a long-term strategic 

approach to position itself to administer the Representative Payee 

Program effectively in the future. Over the years, SSA has taken 

important steps to improve the program in an effort to prevent misuse of 

benefits by payees. However, if SSA fails to evaluate the effectiveness of 

these changes, such as those in its Philadelphia pilot, in actually 

preventing misuse, SSA runs the risk of wasting its scarce resources on 

activities that may be ineffective over the long term.

SSA’s lack of long-term planning could also render it unable to effectively 

administer the program and expose an already vulnerable population to 

misuse of their benefits. Without a clearer assessment of the future need 

for payees, SSA runs the risk of not being prepared to serve a growing 

number of aged beneficiaries whose needs often differ from those of 

beneficiaries typically served by SSA staff. In addition, SSA may be 

unable to ensure that there are enough payees available and that 

beneficiaries’ funds will be adequately protected from misuse. Lastly, 

 

41GAO/AIMD-00-21.3.1.

42GAO, Results-Oriented Government: GPRA Has Established a Solid Foundation for 

Achieving Greater Results, GAO-04-38 (Washington, D.C.: Mar. 10, 2004).

Conclusions 
 

Page 24 GAO-13-473 SSA Representative Payee Program

because of its lack of long-term planning, SSA may be limited in its ability 

to make effective decisions about how to modify the program going 

forward.

While there are no simple fixes to help SSA manage its growing program 

workloads, SSA has demonstrated that it cannot effectively administer the 

program within its current resources and structure. Experts have identified 

a range of possible options that SSA could consider to meet its goals of 

streamlining the program and protecting beneficiaries from misuse. 

Nonetheless, if SSA does not assess the potential costs and benefits of 

different alternatives and pursue operational and program design 

changes the agency deems to be feasible and cost-effective, it will miss 

an opportunity to better position itself to meet its service delivery 

challenges in the future.

To better position itself to address its growing challenges with 

administering the program while protecting individuals’ benefits from 

misuse, we recommend that the Commissioner of SSA direct the Deputy 

Commissioner, Retirement and Disability Policy, to work with relevant 

SSA offices to

1. systematically evaluate the effectiveness of SSA’s criminal bar pilot to 

help ensure that it meets its intended purpose of preventing misuse;

2. estimate the long-term increase in the number of individuals who will 

need a payee and their demographic characteristics, as well as the 

resources that will be needed to meet this increase in demand; and

3. develop a long-term strategy for addressing these challenges that 

includes developing and testing a range of alternatives that could 

streamline program processing to determine and compare their 

feasibility and their potential impact on processing times and risk of 

benefit misuse.

We provided a draft of this report to the Commissioner of SSA for review 

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

agreed with all three of our recommendations. In responding to our draft 

report, SSA noted that the agency expects to complete an evaluation of 

the criminal bar pilot in fiscal year 2014, before implementing the policy 

nationwide. In addition, SSA said that it is currently working to estimate 

the number of beneficiaries who will need a payee and will use this 

information to develop long-term strategies for addressing Representative 

Payee Program challenges. Finally, SSA said it is considering alternatives 

Recommendations for 

Executive Action

Agency Comments
 

Page 25 GAO-13-473 SSA Representative Payee Program

to streamline its processes and improve its monitoring. SSA also provided 

technical comments that we have incorporated, as appropriate.

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

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

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

Social Security. In addition, the report will be available at no charge on 

the GAO website at http://www.gao.gov.

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

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

Offices of Congressional Relations and Public Affairs may be found on 

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

reported are listed in appendix III. 

Daniel Bertoni, Director

Education, Workforce, and Income Security Issues
 

Page 26 GAO-13-473 SSA Representative Payee Program

List of Requesters

The Honorable Sam Johnson

Chairman 

Subcommittee on Social Security 

Committee on Ways and Means

House of Representatives

The Honorable Kevin Brady

Chairman 

Subcommittee on Health 

Committee on Ways and Means

House of Representatives

The Honorable Pat Tiberi

Chairman

Subcommittee on Select Revenue Measures 

Committee on Ways and Means

House of Representatives

The Honorable Jim Gerlach

House of Representatives

The Honorable Aaron Schock

House of Representatives

The Honorable Adrian Smith

House of Representatives

The Honorable Patrick Meehan 

House of Representatives
Appendix I: Methodology for Identifying 

Options and Their Strengths and Weaknesses

Page 27 GAO-13-473 SSA Representative Payee Program

We identified options that the Social Security Administration (SSA) could 

consider to address the Representative Payee Program’s long-term 

challenges by reviewing prior reports on the program such as the National 

Research Council’s 2007 review of the program; Social Security Advisory 

Board reports, SSA Office of the Inspector General, and GAO reports; 

and other reports.1 We also sought input from experts, members of 

organizations familiar with the program, and SSA field office managers 

from 6 of the 10 regions (interviewees). These sources offered numerous 

options to address long-term challenges facing SSA’s Representative 

Payee Program. We selected options that could assist SSA in managing 

its growing workload, including options that directly address the growing 

need for payees and SSA’s challenges in monitoring these payees. We 

combined some options that were similar in nature to reduce the number 

of options to a reasonable amount for interviews. We also eliminated 

actions that SSA has already implemented.2

We selected a nongeneralizable sample of experts who had conducted 

research on the Representative Payee Program (or similar programs 

such as guardianship programs), served on Advisory panels, or who are 

affiliated with an organization that represents persons who may need 

payee services (see table 2 for a list of entities). In addition, we selected a 

group of interviewees to help ensure a range of viewpoints. Specifically, 

we interviewed persons who work with different beneficiary groups such 

as the aged, persons with developmental disabilities, persons with 

substance abuse, and others. They also represented different interactions 

with the program such as the court perspective, SSA’s field office 

perspectives, beneficiary perspectives, and payee perspectives. Although 

many points of view were represented by our interviewees, they may not 

represent the complete range of views on the options.

 

1

Examples of reports we reviewed include: GAO-11-678, GAO-04-655; SSA OIG, Annual 

Representative Payee Accounting Report Non-responders; NRC, Improving the Social 

Security Representative Payee Program: Serving Beneficiaries and Minimizing Misuse; 

and the Social Security Advisory Board Issue Brief Series: Disability Programs in the 21st 

Century: The Representative Payee Program. 

2

For instance, we did not include using the misuse predictive model to determine payees 

for site reviews because SSA has already implemented this approach. 

Appendix I: Methodology for Identifying 

Options and Their Strengths and Weaknesses
Appendix I: Methodology for Identifying 

Options and Their Strengths and Weaknesses

Page 28 GAO-13-473 SSA Representative Payee Program

Table 2: List of Entities Interviewed

• American Bar Association, Commission on Law and Aging

• AARP 

• Disability Law Center

• National Academy of Elder Law Attorneys

• National Adult Protective Services Associations

• National Alliance on Mental Illness

• National Association of Disability Representatives

• National Association of State Long-term Care Ombudsman

• National Center for State Courts

• National Council of Social Security Management Associations

• National Disability Rights Network

• National Organization of Social Security Claimants’ Representatives

• The Arc of the United States

• Nancy Coleman, Lecturer, UCLA Luskin School of Public Policy and Social Welfare

Source: GAO. 

We conducted 14 semi-structured interviews to identify strengths and 

weaknesses of the options, including the likelihood that the option would 

help SSA address the growing demand for payees and increased staff 

workloads, their cost-effectiveness, and feasibility. In some instances, 

these interviews included several members from the organization and the 

views expressed were those of the individuals who participated in the 

interview, not those of their organizations. We did not conduct an 

independent review of the feasibility or potential impact of any of these 

options. GAO is not recommending or endorsing the adoption of any of 

these policy options in this report.

We conducted this performance audit from April 2012 to May 2013 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 findings and 

conclusions based on our audit objectives.
Appendix II: Comments from the Social 

Security Administration

Page 29 GAO-13-473 SSA Representative Payee Program

Appendix II: Comments from the Social 

Security Administration
Appendix II: Comments from the Social 

Security Administration

Page 30 GAO-13-473 SSA Representative Payee Program
Appendix II: Comments from the Social

Security Administration

Page 31 GAO-13-473 SSA Representative Payee Program
Appendix II: Comments from the Social 

Security Administration

Page 32 GAO-13-473 SSA Representative Payee Program
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 33 GAO-13-473 SSA Representative Payee Program

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

In addition to the contact named above, Clarita Mrena (Assistant 

Director), Sherwin Chapman, and Nyree Ryder Tee made significant 

contributions to this report, in all aspects of the work. Also contributing to 

the report were Rachel Beers, Gary Bianchi, David Chrisinger, Brittni 

Milam, Mimi Nguyen, Almeta Spencer, Vanessa Taylor, Roger Thomas, 

and Walter Vance.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments
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Page 34 GAO-13-473 SSA Representative Payee Program

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Elder Justice: National Strategy Needed to Effectively Combat Elder 

Financial Exploitation. GAO-13-110. Washington, D.C.: November 15, 

2012.

Supplemental Security Income: Better Management Oversight Needed for 

Children’s Benefits. GAO-12-497. Washington, D.C.: June 26, 2012.

Designing Evaluations: 2012 Revision. GAO-12-208G. Washington, D.C.: 

January 2012.

Incapacitated Adults: Oversight of Federal Fiduciaries and CourtAppointed Guardians Needs Improvement. GAO-11-678. Washington, 

D.C.: July 22, 2011.

Elder Justice: Stronger Federal Leadership Could Enhance National 

Response to Elder Abuse. GAO-11-208. Washington, D.C.: March 2, 

2011

Guardianships: Cases of Financial Exploitation, Neglect, and Abuse of 

Seniors. GAO-10-1046. Washington, D.C.: September 30, 2010.

Social Security Administration: Service Delivery Plan Needed to Address 

Baby Boom Retirement Challenges. GAO-09-24. Washington, D.C.: 

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Guardianships: Collaboration Needed to Protect Incapacitated Elderly 

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