United States General Accounting Office

GAO Report to the Chairman, Special

Committee on Aging, U.S. Senate

August 1995 SUPPLEMENTAL

SECURITY INCOME

Disability Program

Vulnerable to Applicant

Fraud When

Middlemen Are Used

GAO/HEHS-95-116

GAO United States

General Accounting Office

Washington, D.C. 20548

Health, Education, and

Human Services Division

B-257888 

August 31, 1995

The Honorable William S. Cohen

Chairman, Special Committee on Aging

United States Senate

Dear Mr. Chairman:

Recent media reports and congressional hearings have focused attention

on allegedly fraudulent claims for disability benefits that have been filed

by legal immigrants under the Supplemental Security Income (SSI)

program. Such fraudulent claims have been facilitated by middlemen1

 who

provided translation services and involved themselves in the SSI

application process of non-English-speaking immigrants. It has been

alleged that middlemen have coached SSI claimants on how to appear

mentally disabled, have used dishonest health care providers to submit

false medical evidence to those determining eligibility for benefits, and

have provided false information on claimants’ medical and family

histories. As a result of these allegedly fraudulent activities, people have

obtained SSI disability benefits to which they are not entitled.

Given your concern about this issue, we agreed to (1) determine the extent

of fraudulent applications submitted by non-English-speaking immigrants

using middlemen, (2) describe factors that contribute to the SSI program’s

vulnerability to such fraudulent applications, and (3) describe federal and

state initiatives to combat such fraudulent activities.

To meet our objectives, we interviewed officials from, and reviewed

available data provided by, Social Security Administration (SSA)

headquarters, regional offices, and several field offices, as well as

disability determination services (DDS) offices in three states. We also met

with representatives from California’s Medicaid Fraud Control Unit and

with officials in the U.S. Attorney’s Office in Seattle, Washington. We

coordinated our study with then-Department of Health and Human

Services’ (HHS) Office of Inspector General (OIG) and discussed with them

their efforts to investigate cases of suspected fraud involving middlemen.

Our work was conducted from May 1994 through June 1995 in accordance

with generally accepted government auditing standards.

1

In this report, “middleman” refers to a person or organization that provides translation and/or other

services for a fee, to help individuals apply for SSI.

Page 1 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

Results in Brief Although some ineligible non-English-speaking applicants have obtained

SSI benefits illegally by using middlemen, the actual number of people who

have done so is unknown. We do know that the number of immigrants

receiving SSI disability benefits rose from 45,000 in 1983 to 267,000 in 1993.

Those immigrants unable to speak English needed translating help to

communicate with the SSI system. By 1990, SSA had become aware of

allegations of SSI fraud related to the use of middlemen. For example, a

Washington State middleman arrested for fraud had helped at least 240

immigrants obtain $7 million in SSI benefits by coaching them on which

medical symptoms to claim and providing false information on their

medical conditions and family histories.2

 In California, about 6,000

potentially fraudulent applications have been identified. Of these 6,000

applications, about 30 percent represent SSI claims currently being paid.3

Mistakes in accurately determining eligibility are costly: We estimate that a

single ineligible SSI recipient can receive a total of about $113,000 from SSI,

Medicaid, and the Food Stamps program by the time he or she is 65 years

old.4

SSI’s vulnerability to fraudulent applications involving middlemen is the

product of a combination of factors. First, SSA management practices and

bilingual staff shortages enable applicants to use middlemen. For example,

under SSA regulations and SSA customer service standards, applicants may

apply for benefits at the field office of their choice—SSA does not restrict

applicants to offices in which SSA has staff that speak their language. In

addition, the unavailability of documentation for applicants’ medical

histories and the applicants’ need for translators at medical examinations

enhance SSI’s vulnerability to fraud. Furthermore, SSA’s vulnerability to

fraud when middlemen are involved has been compounded by SSA’s limited

monitoring of middlemen, HHS OIG’s limited funds for investigations, and

the lack of coordination between the efforts of SSA and state Medicaid

agencies. Finally, SSA needs a more comprehensive, programwide strategy

for keeping ineligible applicants from ever being accepted on the SSI rolls.

The Congress, SSA, and several states have initiated efforts to prevent or

detect fraudulent SSI claims involving middlemen. Federal legislation has

2

The 240 cases are being reviewed by an intergovernmental task force formed in 1992 to investigate

middleman fraud in one county in Washington.

3

About 1,800 of the 6,000 applications represent cases that could be subject to continuing disability

reviews. SSA has completed about 400 of these reviews to date; more will be done as resources permit.

4

The actual total amount of $112,805 represents $50,688 from SSI, $55,396 from Medicaid, and $6,721

from food stamps. Some applicants ineligible for SSI could still be eligible for Medicaid, food stamps,

or both.

Page 2 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

made SSI fraud a felony and has given SSA access to information from the

Immigration and Naturalization Service (INS) and the Centers for Disease

Control. SSA established a task force in April 1993 to combat fraudulent

applications involving middlemen that has suggested initiatives such as

developing and managing an interpreter database. Also as a result of the

task force, SSA’s San Francisco regional office is conducting continuing

disability reviews of possibly fraudulent cases involving middlemen. As of

April 26, 1995, this effort had resulted in terminations of benefits for 207

recipients, although 60 percent of these terminations have been appealed.

Because many of the task force initiatives are in the planning stages or the

early stages of implementation, it is too soon to evaluate their

effectiveness. Several states are also attempting to address the problem.

While SSA has several planned or early-stage initiatives to prevent or detect

SSI fraud when middlemen are used, more could be done. A more

aggressive, programwide strategy for improving the quality of information

obtained from applicants would increase SSA’s ability to make better

disability determination decisions, thereby keeping ineligible applicants

from ever getting on the SSI rolls. A comprehensive strategy should include

cost-benefit analyses of (1) SSA’s alternatives for addressing the problem as

well as (2) SSA’s resource limitations and applicants’ need for expedient

and convenient service. Such a strategy should include components to

better manage SSA’s resources to improve communication with applicants.

SSA could require that its own bilingual staff or contractors conduct

interviews with non-English-speaking applicants and explore the use of

videoconferencing technology, which would maximize the use of SSA

bilingual staff. SSA should also share among its field offices information it

has already gathered about interpreters and middlemen, until the planned

automated database is established. Also, SSA should institute a mechanism

by which it obtains regular access to investigative results of state Medicaid

agencies.

Background Authorized in 1972 under title XVI of the Social Security Act, the SSI

program is administered by SSA. Until recently, SSA was an agency within

HHS. Effective March 31, 1995, it became an independent agency.5 SSI

provides cash benefits to aged, blind, or disabled individuals whose

income and resources are below certain levels. Individuals seeking SSI

benefits on the basis of disability must meet financial eligibility

requirements and disability criteria. SSI is federally funded, and most states

provide recipients a supplement. SSA determines applicants’ financial

5

Social Security Independence and Program Improvements Act of 1994 (P.L. 103-296).

Page 3 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

eligibility; DDS offices, which are state agencies funded and overseen by

SSA, make the initial determination of applicants’ medical eligibility. In

1994, more than 6 million SSI recipients received nearly $22 billion in

federal benefits and $3 billion in state benefits. The maximum federal SSI

monthly benefit in 1995 is $458 for an individual and $687 for a couple if

both spouses are eligible.

To be eligible for SSI, individuals must be U.S. citizens or legal immigrants.6

Also eligible for SSI benefits are certain other immigrants, classified by

public assistance programs as permanently residing in the United States

under color of law (PRUCOL).7

 Under the SSI program, the PRUCOL category

includes refugees, defined by INS as people who are outside their country

of nationality and unable or unwilling to return to that country because of

persecution or a well-founded fear of persecution. Refugees are eligible to

become lawful permanent residents after 1 year of continuous presence in

the United States, and most do.

Most SSI recipients are also eligible for Medicaid and food stamps.

Medicaid is a federal/state matching entitlement program administered by

HHS’ Health Care Financing Administration (HCFA). Medicaid provides

medical assistance to low-income aged, blind, or disabled individuals;

members of families with dependent children who receive benefits from

the Aid to Families With Dependent Children program; and certain other

children and pregnant women. The Food Stamp program, administered by

the Department of Agriculture’s Food and Nutrition Service, is a federally

funded entitlement program that provides food stamp coupons to

low-income families.

Applying for SSI Benefits To apply for SSI disability benefits, an individual must generally file a

claim, in person, by telephone, or by mail, with an SSA field office. Usually,

an SSA field office claims representative interviews the claimant in person

or by telephone to determine whether the claimant’s income and

resources meet SSI financial eligibility criteria and to obtain information

about the claimant’s disability. In the case of a non-English-speaking

claimant, if the claims representative does not speak the claimant’s

language, an interpreter participates in the interview. The SSA claims

6

Legal immigrants include those classified by INS as lawful permanent residents—people lawfully

accorded the privilege of residing permanently in the United States.

7

SSI regulations define a PRUCOL immigrant as an alien residing in the United States with the

knowledge and permission of INS whose departure INS does not contemplate enforcing (20 C.F.R.

416.1618).

Page 4 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

representative is also available to help the claimant complete the

application form. If the claimant is deemed financially eligible, the SSA field

office refers his or her claim to the state DDS for a medical review.

DDS decides whether a claimant’s physical or mental impairment meets SSI

disability criteria. To be considered disabled, a claimant must be unable to

engage in any substantial gainful activity because of a physical or mental

impairment that is expected to last at least 12 months or to result in death.

To make a determination, DDS obtains and reviews medical evidence from

health care providers who have treated the claimant. If DDS finds the

medical evidence insufficient or possibly fraudulent, it orders a medical

consultative examination (CE). DDS is generally responsible for ensuring

that there is no language barrier between the claimant and the CE provider.

If the CE provider does not speak the claimant’s language, DDS can either

arrange for an interpreter or allow the claimant to use his or her own

interpreter. If the claim is denied, an appeals process is available.

SSA conducts a redetermination on each case periodically to ensure that

recipients continue to be eligible for SSI according to financial eligibility

criteria. The frequency of redeterminations varies based on anticipated

changes in income and other factors; however, a redetermination is

performed on every case at least once every 6 years. SSA has also been

authorized to conduct periodic continuing disability reviews (CDR) to

ensure that people whose medical condition has improved and who are no

longer disabled leave SSI’s rolls. We previously reported that SSA had

conducted relatively few CDRs for several years.8

 In 1994, to increase the

number of CDRs that SSA conducted under the SSI program (only 11,000

were conducted in 1994) the Congress instituted a requirement that SSA

conduct at least 100,000 CDRs on SSI cases each year for the next 3 years,

beginning with fiscal year 1996. SSA is also required to conduct CDRs on at

least one-third of disabled SSI recipients who turn 18 years old in each of

the next 3 years.

If an SSA or DDS office suspects that a claim is fraudulent and the CE does

not refute that suspicion, that claim is referred to the OIG for investigation.9

Generally, the function of the OIG is to work with SSA to develop evidence

to establish potential violations of the Social Security Act; decide whether

suspected fraud cases meet federal, state, or county guidelines for criminal

8

Social Security: New Continuing Disability Review Process Could Be Enhanced (GAO/HEHS-94-118,

June 27, 1994).

9

Until March 31, 1995, cases of suspected fraud were referred to the HHS OIG; the independent SSA

now has its own OIG.

Page 5 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

or civil prosecution; and formally prepare and present cases for

prosecution to the U.S. Attorney or the District Attorney.

The Congress is considering legislation that could have a significant

impact on both immigrants already receiving SSI benefits and those

applying for SSI benefits. The House of Representatives passed H.R. 4 in

1995, which includes a provision that would generally bar legal

immigrants, except for lawful permanent residents who are 75 years old or

older and who have lived in the United States for at least 5 years and

refugees in the country fewer than 6 years, from receiving certain welfare

benefits, including SSI benefits. The Senate is considering a similar

measure that would eliminate eligibility for all noncitizens except for legal

immigrants who have worked in the United States long enough to qualify

for Social Security disability benefits—at least 10 years—and recent

refugees and veterans.

Extent of Fraudulent

Applications by

Non-English-Speaking

Immigrants Using

Middlemen Is

Unknown

Although some ineligible non-English-speaking immigrants obtain SSI

benefits by using middlemen, the actual number of people who do so is

unknown. During the past decade, the SSI immigrant caseload has grown

dramatically, as compared with the U.S. citizen caseload. To serve those

immigrants who do not speak English, interpreters were introduced to the

SSI application process. By 1990, SSA was aware that some

non-English-speaking applicants were using middlemen to defraud the SSI

program and were collecting SSI benefits for which they were ineligible.

Because SSI recipients generally remain on the rolls for a long time, the

cost of a single mistake in determining eligibility is high: We estimate that

one ineligible recipient could improperly receive a total of about $113,000

in federal benefits by the time he or she is 65 years old.

As mentioned previously, little is known about the actual number of

non-English-speaking immigrants receiving SSI as a result of fraudulent

applications made with the assistance of middlemen. Most of the

suspected cases of middleman fraud identified so far have been in

California and Washington—about 6,500 cases. In both states, there has

been a concerted effort to uncover fraudulent claims facilitated by

middlemen. Washington’s intergovernmental task force on SSI middleman

fraud, for instance, identified the following case:10 A Washington

middleman who ran a business submitting fraudulent SSI claims was

convicted of fraud. For a fee of between $2,000 and $3,000 from each

10In 1992, Washington formed an intergovernmental task force to investigate middleman fraud in one

county.

Page 6 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

applicant, he had provided inaccurate information on their SSA forms,

coached them to feign mental impairments, and provided false translations

at their medical examinations. At least 500 of the more than 1,000

immigrants he had coached qualified for benefits; as of November 1994, 95

of these recipients had received about $3.2 million in benefits. Three of the

500 have been convicted of fraud. The SSI claims of these 500 recipients, as

well as other potentially fraudulent claims that have been identified, are

subject to SSA reviews. SSA has begun implementing reviews of 460

suspected fraudulent claims in Washington.

Immigrant Caseload and

Need for Interpreters Have

Risen Dramatically

During the past decade, the immigrant portion of the SSI disability caseload

rose much more rapidly than the U.S. citizen portion of the caseload.

Between 1983 and 1993, the number of U.S. citizens receiving SSI disability

benefits rose from approximately 2.3 million to 4.2 million—less than a

twofold increase. In comparison, during the same period, the number of

immigrants receiving SSI disability benefits rose from 45,000 to

267,000—approximately a sixfold increase.11 This increase is particularly

dramatic when contrasted with the increase in the number of immigrants

admitted annually to the United States in the past decade; that is, 628,132

were admitted in 1983, compared with 1,000,630 in 1993.12

The immigrant component of the SSI disability caseload is important

because it is different from the rest of the caseload in one obvious, but

significant, way: Many immigrants do not speak or understand English. As

a result, when they apply for SSI benefits, they need someone to translate

for them during their interactions with the English-language SSI system. SSA

field offices often maintain interpreters on staff for the languages that are

prevalent in their geographical areas, but sometimes field offices are

unable to meet the need for interpreters. As a result, non-English-speaking

applicants have been free to involve their own interpreters in the

application process except where fraud is suspected.

Fraud Problem Had

Surfaced by 1990

Many of the SSA and DDS offices we visited had recognized middleman

fraud as a problem by 1990. Some middlemen were suspected of taking

advantage of non-English-speaking claimants’ lack of sophistication and

11Charles Scott and Elsa Ponce, Aliens Who Receive SSI Payments, SSA, Office of Supplemental

Security Income (Mar. 1994). Included with disabled immigrant recipients are blind recipients, who

represent 1.4 percent of all SSI recipients.

12Excluded from the 1993 figure are 24,278 former illegal immigrants who were legalized under the

Immigration Reform and Control Act of 1986; included are an estimated 113,152 refugees. In view of

the way in which the data were collected, this 1993 figure may be overstated.

Page 7 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

apprehensions about being in a new country, thus leading claimants to

believe that middleman services were an essential support in navigating

the SSI system. Middlemen were known to have coached claimants to feign

forms of mental impairment, such as delayed stress syndrome or

depression; controlled SSA interviews by answering all questions asked of

claimants; prepared applications for numerous claimants using identical

wording to describe the same mental impairments; and established

relationships with unscrupulous doctors who helped them defraud the SSI

program by submitting false medical evidence.

In 1990, for example, SSA’s San Francisco regional office sent a

memorandum to SSA headquarters, describing trends in disability claims

involving suspected middleman fraud. The memorandum highlighted the

following trends: claimants often alleged mental disorders; the same

middleman represented many claimants at their SSA field office interviews

and at their CEs; and the same physician provided essentially identical

medical reports for many claimants. One California DDS branch office

identified 176 claimants who had used the same middleman, who was

suspected of routinely providing false information and coaching claimants,

and the same treating doctor, who allegedly provided “interchangeable”

medical reports.

Fraudulent Applications

Are Costly

The result of such middleman involvement in the SSI application process is

that some non-English-speaking immigrants collect SSI benefits to which

they are not entitled. This situation is especially problematic because we

estimate that each person collecting illegal SSI benefits costs the program

thousands of dollars a year. Moreover, once claimants are accepted into

the SSI program, it is likely that they will remain on the rolls for a long

time.

On the basis of a recent study of the duration of stay on SSI disability rolls,

SSA reported that the expected mean lifetime disability stay of new SSI

recipients before they reach age 65 is about 11 years.13 Thus, given the

average federal monthly SSI benefit in December 1994 of $384, a recipient

improperly admitted to the program could collect about $51,000 in SSI

benefits to which he or she was not entitled. Moreover, the cost to the

government could be higher than just the SSI payments, because in most

states, Medicaid benefits and food stamps are automatically provided to SSI

13Data are not available on the expected mean lifetime disability stay of immigrants.

Page 8 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

recipients. As a result, the recipient could improperly receive total federal

benefits worth about $113,000.14

Several Factors

Contribute to SSI’s

Vulnerability to

Applicant Fraud When

Middlemen Are Used

There are various reasons for which SSI is vulnerable to fraudulent

applications when middlemen are involved. First, some SSA management

practices permit middleman involvement. In addition, SSA has a shortage of

bilingual staff to handle non-English-speaking applicants. Third,

unavailable documentation of applicants’ medical histories as well as

translations provided by interpreters at applicants’ medical examinations

make disability determinations difficult. Moreover, SSA’s monitoring of

middlemen remains limited until SSA’s planned interpreter database is

developed and completed, and HHS OIG investigations of cases of suspected

fraud involving middlemen were hampered by a lack of resources. In

addition, SSA has no formalized procedures for regularly working with

state Medicaid agencies—a type of coordination that could help SSA

identify cases of suspected fraud. Finally, SSA needs a more effective

programwide strategy for keeping ineligible SSI applicants off the rolls.

Some SSA Management

Practices Enable

Applicants to Use

Middlemen

Some of SSA’s current management practices—in particular, certain

provisions of SSA guidance and procedures—enable non-English-speaking

applicants to use middlemen. For example, SSA guidance states that if an

applicant does not have an interpreter, SSA will provide one. This practice

places secondary responsibility for providing translation services on SSA

field offices. The result is that SSA field offices are not generally required to

use their bilingual staff for translating in interviews unless an applicant

does not provide his or her own interpreter. When the applicant does

provide an interpreter, SSA will generally use the applicant’s interpreter as

long as there is no reason to suspect that he or she is unreliable. SSA also

allows applicants to use their relatives or friends as interpreters, even

though unscrupulous middlemen sometimes pose as relatives or friends.

Moreover, SSA’s broad definition of a qualified or reliable interpreter

enables an applicant to use almost any interpreter he or she chooses.

Finally, SSA procedures allow claimants to apply for SSI at any SSA field

office, even though doing so enables them to abuse the system. When

some middlemen or claimants learn that a certain SSA field office has staff

who can speak the language of the claimant, they can go instead to a

different field office, where no employees speak the language, thereby

retaining control of the interview portion of the application process.

14We estimate that an SSI recipient’s annual Medicaid and Food Stamp benefits are $5,036 and $611,

respectively.

Page 9 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

SSA Has a Bilingual Staff

Shortage

SSA’s bilingual staffing problems exacerbate program vulnerabilities that

arise because of some of SSA’s management practices. HHS OIG reported in

1990 that the number of bilingual SSA employees was insufficient to

provide adequate service to non-English-speaking individuals. As a result,

SSA has hired more bilingual staff.15 However, some SSA field offices remain

without enough staff who can speak the languages needed. According to

1993 and 1994 SSA data, at least 45 field offices at which

non-English-speaking individuals represented 10 percent or more of the

workload needed additional bilingual staff. Furthermore, an SSA San

Francisco regional office study of 1,198 cases from 1992 and 1993 found

that when an interpreter was required, field office personnel were able to

interpret in less than an estimated 5 percent of the cases when the

language was other than Spanish. One California field office we visited had

encountered 127 people speaking 19 languages in a single day. Because of

the shortage of SSA staff who can speak the necessary languages, there

may be more instances of SSI applicants using middlemen than would

otherwise be necessary.16

Difficulties in Obtaining

Adequate Medical

Information Heighten

Chances for Fraud

SSI’s vulnerability to fraud when middlemen are used is enhanced by

difficulties in obtaining adequate medical information and other kinds of

information useful to the disability determination process of

non-English-speaking claimants. Documentation of the individual

claimant’s medical history from the claimant’s home country may be

limited or nonexistent. As a result, there is little longitudinal history of the

claimant’s health before his or her arrival in the United States.

Furthermore, when a claimant undergoes a medical examination in the

United States with a provider who does not speak his or her language, the

claimant needs an interpreter.

When claimants are allowed to provide their own interpreters at medical

examinations, SSI becomes more vulnerable to fraud. If a middleman

provides a false translation of a claimant’s symptoms or coaches the

claimant on how to behave during the examination, the provider could

make an incorrect medical assessment and submit inaccurate medical

evidence to the state DDS. Moreover, some middlemen bring claimants to

dishonest providers who are willing to submit false medical evidence to

DDS.

15SSA reported that in fiscal year 1993, 266 of permanent field office hires were bilingual; in fiscal year

1994, 481 of such hires were bilingual.

16Other federal agencies with bilingual staff shortages may have similar problems with implementing

their programs.

Page 10 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

Although DDS can order a CE if the applicant’s medical information is

inconclusive, the middleman may be able to manipulate this exam if the

provider does not speak the applicant’s language or have his or her own

translator. In addition, DDS may be hindered in collecting essential

information on the claimant’s education and work experience. Taken

together, these information deficits can seriously impede the DDS as it

attempts to accurately assess the claimant’s ability to work.

SSA Monitoring of

Applicants’ Use of

Middlemen Is Limited

Despite recent changes in some SSA procedures, SSA’s monitoring of

middlemen is limited. Although data on interpreters are being collected,

they are not currently being incorporated into a central database. Rather,

hard copy data are being maintained in the case files of individual

claimants. SSA is beginning to design an automated system for tracking

middlemen. However, it may not be completed for several years, and SSA

has no interim monitoring procedures in place.

As a result of congressional hearings in February 1994 and the Social

Security Independence and Program Improvements Act of 1994, SSA now

requires all non-SSA interpreters to complete and sign a form containing

their name, address, and relationship to the applicant. These forms are

maintained in applicants’ files, providing a potentially valuable body of

information. But because the data collected on these forms are not being

entered into an automated database, no central file exists to help SSA

identify and track middlemen suspected of fraud. Thus, when an SSA field

office encounters a new interpreter, it has no easy means to determine his

or her reliability or whether he or she has a record with other field offices.

SSA recently began developing a nationwide database of interpreter

information that will identify reliable interpreters and flag middlemen who

are convicted or suspected of fraud. According to SSA, this database could

be operational in 1996 or 1997. But we believe it could be some time after

that before users will be able to retrieve comprehensive interpreter data

from this database, because SSA will probably have to compile and input

considerable information, such as the signed interpreter forms previously

discussed. Furthermore, work to develop the interpreter database has

been somewhat slow to date, according to one SSA official, because some

SSA automated systems are still being modernized.

In the interim, SSA has no formal procedures in place to monitor

middlemen. Two of the California field offices we visited maintained their

own lists of suspect middlemen, but these lists were not being regularly

Page 11 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

shared with other SSA offices. The California DDS also maintains a list of

suspect middlemen that it has submitted to the SSA regional office, but that

office has not distributed the list to SSA field offices.

HHS OIG Lacked Funds for

Sufficient Investigations

During the last several years that HHS OIG was responsible for investigating

SSI middleman fraud, it investigated very few cases.17 In fact, SSA field

offices said they had become hesitant to forward suspect claims because

of what they perceived as a lack of interest by HHS OIG. According to HHS

OIG, it had too few resources to perform more SSI investigations and was

concentrating its resources on cases with a larger payoff.

HHS OIG, which was responsible for investigating fraudulent SSI claims until

March 31, 1995, completed 10 middleman fraud investigations between

1987 and April 1995. These investigations resulted in the conviction of five

middlemen. HHS OIG also participated with other federal and state

investigators in some joint investigations of middleman fraud.

SSA field office staff told us they had become reluctant to refer suspect

claims to HHS OIG because they expected that little or no action would be

taken. According to results of an informal SSA survey, in February 1994, the

San Francisco regional office had referred at least 600 claims involving

suspected middleman fraud to the HHS OIG, and the Seattle regional office

had referred between 200 and 300. These numbers represent referrals

made since October 1992. The California claims were subject to selection

for the CDRs being conducted currently on potentially fraudulent cases

involving middlemen. The Washington claims will be examined by the

intergovernmental task force.

Between 1990 and 1994, HHS OIG investigative resources declined about

17 percent—from 469 staff to 390. In 1994, the HHS Inspector General

reported that a lack of resources—specifically, limited federal

investigative and prosecutive resources—posed an “obstacle” to the

pursuit of middleman fraud. At that time, the HHS OIG was also responsible

for investigating fraud in the much larger Medicare and Medicaid

programs, as well as in the SSI program. Furthermore, some threats

allegedly made by middlemen on SSA field staff may have contributed to a

lower number of referrals to the HHS OIG for investigation of middleman

fraud.

17Within the HHS OIG, the specific component responsible for investigations is the Office of

Investigations.

Page 12 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

Beginning March 31, 1995, SSA has had its own OIG solely dedicated to SSA

programs. SSA is adding 50 positions in fiscal year 1996 to augment the staff

who transferred from the HHS OIG.

Coordination Between SSA

and State Medicaid

Agencies Is Not Routine

One way for SSA to extend its resources would be to work more regularly

with state Medicaid agencies. When one state shared information during

its Medicaid fraud investigations, SSA eventually identified nearly 2,000

possibly fraudulent claims associated with illegal middleman activity. But

coordination between SSA and state Medicaid agencies is not a regular

practice.

At the federal level, HCFA, within HHS, funds and oversees the Medicaid

program. Federal law requires that a single state agency be charged with

administration of the Medicaid program. Each state’s own Medicaid

agency is variously situated in departments such as health, welfare, or

human services. The state Medicaid agency may contract with other state

entities to conduct some program functions.

The state Medicaid agency is responsible for program integrity. In a case

of health care provider abuse, the state Medicaid agency is authorized to

take certain administrative actions. Where provider fraud is suspected, the

state Medicaid agency in most states refers cases for investigation to

Medicaid Fraud Control Units (MFCU). MFCUs investigate selected providers

suspected of overbilling Medicaid for the services they provide to eligible

patients or for billing for services that they never provided. States report

the names of prosecuted or sanctioned providers to the HHS OIG so that the

OIG can take appropriate action to exclude these providers from

participation in other federal health programs, such as Medicare. In the

course of their investigations of providers, it is possible for states to obtain

information that could be useful to SSA, such as the lists of patients

maintained by suspect providers, some of whom are associated with

middlemen.

In California, for example, an investigation initiated by the state and

assisted by the HHS OIG yielded information that, when passed on to SSA, led

to SSA’s identification of 1,981 SSI recipients associated with potentially

fraudulent claims involving middlemen. Routine coordination of efforts

with state Medicaid agencies could enhance SSA’s ability to identify

potentially fraudulent SSI claims. For example, state investigative

information could be helpful to SSA in meeting the 1994 congressional

requirement that SSA conduct at least 100,000 SSI CDRs each year for the

Page 13 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

next 3 years, beginning in 1996. SSA could use state investigative

information to help it identify high-priority cases for these CDRs.

To date, however, coordination between SSA and state Medicaid agencies

has been ad hoc. When SSA was part of HHS, according to SSA officials, SSA

generally did not contact state Medicaid agencies on a regular basis

because Medicaid fell under the administrative jurisdiction of HCFA.

Consequently, SSA did not establish—and has not yet established since it

became an independent agency in March 1995—formal coordination

procedures for obtaining potentially helpful information from state

Medicaid agencies.

SSA Needs a More

Comprehensive

Programwide Strategy for

Keeping Ineligible

Non-English-Speaking

Applicants Off SSI

SSA has tried a few approaches for handling some of the individual factors

that contribute to SSI’s vulnerability to fraud, but needs to develop and

implement a more comprehensive, programwide strategy for ensuring that

only eligible applicants receive SSI benefits. For example, one SSA approach

for limiting the extent to which non-English-speaking applicants could use

middlemen was to disseminate its definition of a qualified interpreter to all

field staff. Furthermore, SSA disseminated a program circular in May 1995

to clarify procedures for conducting interviews with non-English-speaking

claimants. In addition, SSA’s approach to the bilingual staffing shortage has

been to encourage field offices to hire more staff, although, according to

SSA, this has been difficult for field offices to do because of recent

constraints on hiring. Moreover, SSA’s plan for tracking fraudulent

middlemen may not be fully implemented for several years; its OIG needs

more resources to perform investigations; and SSA does not routinely use

state investigative information to help identify fraudulent SSI applications.

A more comprehensive, programwide strategy for ensuring that only

eligible people receive SSI benefits could include, for example, requiring

that SSA’s own bilingual staff or contractors conduct interviews with

non-English-speaking applicants and exploring the use of

videoconferencing technology, which would maximize the use of SSA

bilingual staff, if SSA determines that the benefits outweigh the costs.

Some Initiatives

Address Middleman

Fraud

The Congress, SSA, and several states have initiated various efforts to

prevent or detect fraudulent SSI claims involving middlemen. Some of the

efforts, such as passage of new legislation, have been completed; others

are in progress. A discussion of some of these initiatives follows. (See app.

I for a detailed list of initiatives.)

Page 14 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

Congressional Initiatives The legislation that established SSA as an independent agency, the Social

Security Independence and Program Improvements Act of 1994, contained

provisions for expanding SSA’s authority to prevent, detect, and terminate

fraudulent claims for SSI benefits. Some of the law’s provisions did the

following: changed the federal crime of SSI fraud from a misdemeanor to a

felony; gave SSA the authority to impose civil penalties against any person

or organization determined to have knowingly caused a false statement to

be made in connection with an SSI claim; and gave SSA the authority to

request immigrant medical data and other information from INS and the

Centers for Disease Control for use in eligibility determinations.18 The

provisions of the law that relate to SSI reflect legislative recommendations

that were made by the Subcommittee on Oversight and the Subcommittee

on Human Resources, House Committee on Ways and Means, in

May 1994.19 The Subcommittees also made several administrative

recommendations to SSA.

20

SSA Initiatives SSA established a task force in April 1993 to combat middleman fraud. In

large part as a result of the work of the task force, SSA has initiated various

efforts to detect and prevent middleman fraud. Because many of these

initiatives are in the planning stages or the early stages of implementation,

however, it is too soon to evaluate their effectiveness.

One effort under way, as mentioned earlier, is the development of a

nationwide database to help SSA and DDS offices monitor middlemen. The

database is expected to be useful in identifying reliable interpreters and in

identifying and tracking middlemen whose activities are questionable.

Because all SSA and DDS offices are expected to have access to the

database, an office that encounters a new interpreter will be able to

determine from the database if other offices have had experience with the

same person.

18Prospective immigrants must meet certain medical criteria prescribed by the Centers for Disease

Control.

19The Subcommittees’ recommendations were provided in a May 12, 1994, report, Reforms to Address

Supplemental Security Income Fraud and Abuse Involving Middlemen.

20Administrative recommendations included that SSI establish a quality assurance program to ensure

accurate interpreter translations and that the agency develop a database of interpreters who are

available to all SSA field offices by telephone.

Page 15 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

A second task force initiative, which resulted largely from February 1994

hearings on middleman fraud,21 implements one of the provisions in the

legislation that established SSA as an independent agency. As of

March 1994, SSA requires that all non-SSA interpreters fill out a form on

which they provide their name, address, and relationship to the applicant

and sign a statement that they are providing an accurate translation. These

forms are being maintained in each claimant’s file, providing a potentially

valuable body of information. SSA officials said that these files may

eventually be incorporated into the database.

Another task force effort has resulted in SSA plans to review possibly

fraudulent cases involving middlemen for which benefits are already being

paid. In California, SSA identified many potentially fraudulent cases as a

result of an ad hoc cooperative venture between the state and SSA. (See

following section on state initiatives.) SSA plans to conduct 600 CDRs in

California. As of April 26, 1995, 386 CDRs had been completed in California,

resulting in 207 initial benefit terminations. These terminations are subject

to appeal, and thus far about 60 percent have been appealed. In

Washington, potentially fraudulent cases were identified as a result of an

intergovernmental task force effort. (See following section on state

initiatives.) SSA has begun to do 460 reviews in Washington, but none have

been completed yet.

SSA also reported that its ultimate goal is to dramatically reduce reliance

on middlemen in developing the claims of non-English-speaking

applicants. SSA is trying several approaches to reduce the use of

middlemen as interpreters. First, SSA continues to encourage bilingual

hiring in its field offices to improve service delivery to the

non-English-speaking public. SSA reported that in fiscal year 1993, 266 of

533 permanent field office hires (50 percent) were bilingual; in fiscal year

1994, 481 of 1,099 such hires (44 percent) were bilingual.

In addition, in February 1995, SSA officials reported that a statement of

work was being prepared for a pilot contract to test the feasibility of using

contract interpreter services to supplement SSA’s own interpreter staff. But

the funding for the pilot has been reduced to $100,000, so only a limited

number of SSA offices will receive contract services under the pilot. SSA

officials doubt that a national contract for interpreter services is feasible,

given anticipated costs.

21On February 24, 1994, the Subcommittee on Oversight and the Subcommittee on Human Resources,

House Committee on Ways and Means, held a joint hearing to review the problem of middleman fraud

in the SSI program and to consider possible legislative and administrative solutions.

Page 16 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

Furthermore, in 1994, SSA expanded upon efforts of at least 2 regional

offices by asking all 10 regional offices to establish directories of bilingual

employees who were available to help other field offices by interpreting

during telephone interviews. Many of the 13 SSA field offices we visited

expressed a need for more bilingual staff; only 1 reported having used a

bilingual SSA employee from another field office to interpret by telephone.

Finally, individual field offices have also looked to external sources, such

as local advocacy groups, professional translation and interpreter services,

and community service centers, for interpreting assistance. At least two

field offices have made arrangements with universities and institutes for

students to earn credits or serve internships for performing interpreter

services.

State Initiatives Several states have been active in seeking more effective fraud prevention

and detection approaches. Again, many of these initiatives are in the early

stages of implementation, so it is too soon to evaluate their success.

One initiative involves the use of independent or state-certified

interpreters at CEs, a practice currently employed in Pennsylvania and

Minnesota. In California, if fraud is suspected or if there is reason to

believe that the claimant’s interpreter is not objective or qualified, the

state DDS pays for an independent interpreter for the CE or uses someone

from a community assistance group or other reliable source.

Massachusetts and Connecticut DDS offices use paid interpreters as much

as possible and encourage CE providers to require positive identification

from the person being examined.

In addition, California has initiated a pilot project to establish a fraud

investigation unit in one of its DDS offices. With SSA approval and

assistance, the state plans to hire and train investigators to pursue

fraudulent SSI disability claims. Investigations will be based on suspected

fraud referrals from DDS staff.

Also in California, an ad hoc cooperative venture between the state

Medicaid agency and SSA yielded useful information. When the state

requested assistance from the HHS OIG on some of their Medicaid fraud

investigations, SSA had the opportunity to obtain the names of patients of

providers who had been arrested or convicted of Medicaid fraud, as well

as the names of clients of middlemen who used these medical providers.

SSA then compared these names to those in their database of current SSI

Page 17 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

claimants, to flag claimants who might have been collecting benefits

fraudulently. Since July 1992, 6,062 potentially fraudulent claimants have

been identified in California, many as a result of the cooperation between

the state, the HHS OIG, and SSA. Furthermore, during 1993 and 1994,

California reported 22 arrests or convictions of providers, middlemen, and

their assistants.

Finally, Washington State formed an intergovernmental task force in 1992

in one county to investigate middlemen and others suspected of fraud.22

Under the direction of the U.S. Attorney, the task force has identified 460

suspected fraudulent claims involving middlemen. In 1994, three

middlemen, three SSI recipients, and several others were arrested or

convicted.

Conclusions SSA has awarded SSI benefits to unknown numbers of non-English-speaking

immigrants who are actually ineligible for SSI benefits. These awards are

very costly to the government, accounting in each case for thousands of

dollars in improper payments over the years. Although individual SSA field

offices have been creative in developing their own approaches to dealing

with the problem, SSA’s programwide efforts to ensure that only people

who are eligible for SSI benefits receive them have been limited. SSA’s

responses to SSI fraud have included publishing guidance for SSA

interviews. If the interviewer believes that the interpreter may be

providing inaccurate information, the interview should be terminated until

an interpreter who meets SSA criteria for a qualified interpreter can be

provided. SSA also plans to improve communication with and outreach

efforts to the non-English-speaking community, and it plans to develop a

quality assurance program for interpretations.

A more effective programwide strategy for ensuring that only eligible

people obtain SSI benefits would require consistent, programwide

practices for obtaining more accurate applicant information, maintaining

and sharing information on interpreters and middlemen among field

offices, and using the work of other government agencies to help identify

potentially fraudulent cases. A comprehensive strategy should consider

cost-benefit analyses of SSA’s alternatives for addressing the problem, SSA’s

limited resources, and applicants’ need for timely service. Such a strategy

could involve, for example, SSA requiring that its own bilingual staff or

22The task force has included investigators or staff from the Federal Bureau of Investigation, Internal

Revenue Service, Customs Service, Postal Inspection Service, Department of Agriculture’s OIG, INS,

Washington State Patrol, Pierce County Prosecutor’s Office, Tacoma Police Department, Pierce

County Sheriff’s Office, then-HHS OIG, and SSA.

Page 18 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

contractors conduct interviews with non-English-speaking applicants and

exploring the use of videoconferencing technology, which, as mentioned

earlier, could take best advantage of SSA bilingual staff. These components

of a programwide strategy would further prevent claimants from using

middlemen to manipulate the system.

Recommendations We recommend that the Commissioner of Social Security develop a more

aggressive, programwide strategy for improving the quality of information

obtained from applicants, maintaining and sharing data collected on

interpreters and middlemen among field offices, and using information

that results from the work of other government agencies—local, state, and

federal—to pursue cases in which fraud is suspected.

Such a strategy should include developing improved ways to more

effectively manage SSA’s resources to further facilitate communications

with applicants, possibly by requiring that SSA bilingual staff or SSA

contracted staff conduct the interviews and by exploring

videoconferencing technology.

This strategy should also include

• instituting procedures for sharing, among field offices, the information SSA

has already collected about interpreters and middlemen from its required

forms and other sources, until the automated interpreter database is

established, and

• establishing a mechanism to facilitate regular sharing of all state Medicaid

agencies’ investigative results with SSA.

Agency Comments

and Our Evaluation

SSA agreed with the intent of our recommendations and stated that it is

exploring these recommendations as it continues its efforts to minimize

fraud in cases involving middlemen. For example, SSA cited a pilot

currently under way in California wherein state investigators are reviewing

cases referred from DDS for possible prosecution under state and local

laws.

SSA also suggested the following change to our report concerning whether

SSA’s practices permit non-English-speaking applicants to use middlemen:

“SSA officials explained that SSA is attempting to address the fraud problem

within the framework of its efforts to provide all non-English-speaking

claimants convenient, accessible, and timely service in an environment of

Page 19 GAO/HEHS-95-116 Disability Fraud Program
B-257888 

limited bilingual staff and funding. Experience suggests that the vast

majority of non-English-speaking claimants are not involved in fraudulent

activity. Therefore, to meet customer service needs and save resources,

SSA does allow the non-English-speaking claimant the option of providing

his or her own interpreter as long as the interpreter agrees to provide an

exact interpretation of the claimant’s response and can function as a

capable interpreter. However, if, during the course of the interview, the

interviewer believes that the interpreter is not acting in the claimant’s best

interest or is not providing accurate information, the interview is

terminated. The interview is then rescheduled for a later date when

another interpreter can be provided by SSA.”

We believe that despite its staffing and funding constraints, concerns with

claim processing times, and current efforts to address fraud, SSA can do

more to reduce the SSI program’s vulnerability to fraudulent applications

involving middlemen. Given that each person collecting illegal SSI benefits

costs the program thousands of dollars a year, SSA must aggressively

pursue any available opportunity such as those we have recommended to

further minimize unwarranted outlays of federal monies so that it can

increase the public’s confidence in this important program.

The agency also made other technical comments that we incorporated

throughout the report as appropriate. (See app. II.)

As agreed with your office, unless you publicly announce its contents

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

date of this letter. At that time, we will send copies to the appropriate

congressional committees and federal agencies. Copies also will be

available to others on request.

If you or your staff have any questions concerning this report, please call

me on (202) 512-7215. Other GAO contacts and staff acknowledgments are

listed in appendix III.

Sincerely yours,

Jane L. Ross

Director, Income Security Issues

Page 20 GAO/HEHS-95-116 Disability Fraud Program
Page 21 GAO/HEHS-95-116 Disability Fraud Program
Contents

Letter 1

Appendix I 

Initiatives for

Addressing

Middleman Fraud

24

Appendix II 

Comments From the

Social Security

Administration

26

Appendix III 

GAO Contacts and

Acknowledgments

30

Related GAO Products 32

Abbreviations

CDR continuing disability review

CE consultative examination

DDS disability determination service

HCFA Health Care Financing Administration

HHS Department of Health and Human Services

INS Immigration and Naturalization Service

MFCU Medicaid Fraud Control Unit

OIG Office of Inspector General

PRUCOL permanently residing under color of law

SSA Social Security Administration

SSI Supplemental Security Income

Page 22 GAO/HEHS-95-116 Disability Fraud Program
Page 23 GAO/HEHS-95-116 Disability Fraud Program
Appendix I 

Initiatives for Addressing Middleman Fraud

Initiatives by the

Congress

(P.L. 103-296)

The federal crime of SSI fraud has been elevated from a misdemeanor to a

felony.

SSA now has the authority to impose civil penalties against any person or

organization determined to have knowingly caused a false statement to be

made in connection with an SSI claim.

Third-party translators are now required to certify under oath the accuracy

of the translation provided and the relationship between the translator and

the SSI applicant or recipient.

SSA now has enhanced authority to redetermine eligibility and give less

weight to evidence of disability in those cases where SSA has a reason to

believe that fraud was involved and to expeditiously terminate benefits in

those cases where there is insufficient reliable evidence of disability or

other basis for eligibility.

SSA now has the authority to request medical data and other information

from the Immigration and Naturalization Service and the Centers for

Disease Control for use in disability determination.

The cognizant Office of Inspector General (OIG) is required to make SSI

recipient identifying information available to SSA as soon as OIG has reason

to believe that fraud is involved and an active investigation will not be

compromised.

SSA is required to report annually to the House Committee on Ways and

Means and the Senate Committee on Finance the extent to which it has

used its authority to conduct reviews of SSI cases, including the extent to

which these cases involved probable fraud.

Initiatives by the

Social Security

Administration

SSA plans to develop a nationwide database to help SSA and disability

determination services (DDS) offices monitor middlemen.

SSA now requires that all non-SSA interpreters provide their name, address,

and relationship to the claimant and certify that they are providing an

accurate translation.

SSA has implemented plans to conduct reviews of suspected fraudulent

claims of identified SSI recipients. About 400 continuing disability reviews

Page 24 GAO/HEHS-95-116 Disability Fraud Program
Appendix I 

Initiatives for Addressing Middleman Fraud

have been completed in California, and 460 reviews are being started in

Washington. Additional reviews will be started as resources permit.

Efforts to improve the availability of reliable interpreters include

encouraging the field offices to hire more bilingual staff, testing the

feasibility of contract interpreter services, developing alternative sources

of community interpreters, and establishing regional directories of

bilingual staff.

SSA has published new guidance that includes criteria for identifying

qualified or reliable interpreters and terminating interviews with suspect

middlemen.

SSA plans to develop a quality assurance program for interpretations, to

develop a better procedure for processing fraud referrals, and to improve

communication with and outreach efforts to the non-English-speaking

community.

Initiatives by the

States

DDS in California, Washington, Pennsylvania, Minnesota, Massachusetts,

and Connecticut have begun to use independent or state-certified

interpreters at consultative exams (CE).

California has instituted a pilot project, funded by SSA, that established an

SSI fraud investigation unit in one of its DDS offices.

California shared information about some of its fraud investigations of

medical providers with SSA, which has used the information to identify

potentially fraudulent SSI claimants.

Washington has created an intergovernmental task force to investigate

middlemen suspected of fraud.

Massachusetts and Connecticut DDS offices encourage CE medical

providers to require positive identification from claimants.

The Texas DDS tries to use bilingual CE providers.

Page 25 GAO/HEHS-95-116 Disability Fraud Program
Appendix II 

Comments From the Social Security

Administration

Page 26 GAO/HEHS-95-116 Disability Fraud Program
Appendix II 

Comments From the Social Security

Administration

Page 27 GAO/HEHS-95-116 Disability Fraud Program
Appendix II 

Comments From the Social Security

Administration

See p. 19.

See pp. 19-20.

Page 28 GAO/HEHS-95-116 Disability Fraud Program
Appendix II 

Comments From the Social Security

Administration

Now on pp. 3 and 16.

Now on pp. 5 and 13-14.

Now on pp. 10 and 16.

Page 29 GAO/HEHS-95-116 Disability Fraud Program
Appendix III 

GAO Contacts and Acknowledgments

GAO Contacts Christopher C. Crissman, Assistant Director, (202) 512-7051

Ann Lee, Evaluator-in-Charge, (415) 904-2027

Acknowledgments In addition to those named above, the following individuals also made

important contributions to this report: Elizabeth A. Olivarez, Clarence Tull,

Zachary R. White, and Michael J. Ross, Evaluators; Eli Kuo, Intern; 

Nancy L. Crothers and Jonathan M. Silverman, Communications Analysts;

James P. Wright, Assistant Director (Study Design and Data Analysis); and

Stephen R. Myerson, Assistant Director (Investigations).

Page 30 GAO/HEHS-95-116 Disability Fraud Program
Appendix III 

GAO Contacts and Acknowledgments

Page 31 GAO/HEHS-95-116 Disability Fraud Program
Related GAO Products

Supplemental Security Income: Growth and Changes in Recipient

Population Call for Reexamining Program (GAO/HEHS-95-137, July 7, 1995).

SSI Disability Issues (GAO/HEHS-95-154R, May 11, 1995).

Social Security: Federal Disability Programs Face Major Issues

(GAO/T-HEHS-95-97, Mar. 2, 1995).

Welfare Reform: Implications of Proposals on Legal Immigrants’ Benefits

(GAO/HEHS-95-58, Feb. 2, 1995).

Supplemental Security Income: Recent Growth in the Rolls Raises

Fundamental Program Concerns (GAO/T-HEHS-95-67, Jan. 27, 1995).

(105672) Page 32 GAO/HEHS-95-116 Disability Fraud Program
Ordering Information

The first copy of each GAO report and testimony is free.

Additional copies are $2 each. Orders should be sent to the

following address, accompanied by a check or money order

made out to the Superintendent of Documents, when

necessary. Orders for 100 or more copies to be mailed to a

single address are discounted 25 percent.

Orders by mail:

U.S. General Accounting Office

P.O. Box 6015

Gaithersburg, MD 20884-6015

or visit:

Room 1100

700 4th St. NW (corner of 4th and G Sts. NW)

U.S. General Accounting Office

Washington, DC

Orders may also be placed by calling (202) 512-6000 

or by using fax number (301) 258-4066, or TDD (301) 413-0006.

Each day, GAO issues a list of newly available reports and

testimony. To receive facsimile copies of the daily list or any

list from the past 30 days, please call (301) 258-4097 using a

touchtone phone. A recorded menu will provide information on

how to obtain these lists.

For information on how to access GAO reports on the INTERNET,

send an e-mail message with "info" in the body to:

info@www.gao.gov

PRINTED ON RECYCLED PAPER
United States

General Accounting Office

Washington, D.C. 20548-0001

Official Business

Penalty for Private Use $300

Address Correction Requested

Bulk Mail

Postage & Fees Paid

GAO

Permit No. G100
GAO/HEHS-95-116 Disability Fraud Program