Disability Insurance: SSA Can Improve Efforts to Detect, Prevent, and Recover Overpayments
GAO-11-724
Published: Jul 27, 2011. Publicly Released: Jul 27, 2011.
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Highlights
The Social Security Administration's (SSA) Disability Insurance (DI) program paid almost $123 billion in benefits in fiscal year 2010 to more than 10 million workers and dependents. The program is poised to grow further as the baby boom generation ages. GAO examined (1) what is known about the extent to which SSA makes overpayments to, and recovers overpayments from, DI beneficiaries who exceed program earnings guidelines, and (2) potential DI program vulnerabilities that may contribute to overpayments to beneficiaries who have returned to work. To answer these questions, GAO reviewed work continuing disability review (work CDR) policies and procedures, interviewed SSA headquarters and processing center officials, visited 4 of 8 processing centers, and reviewed a random nongeneralizable sample of 60 CDR case files across those 4 centers (15 from each).
Recommendations
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Social Security Administration | To enhance SSA's ability to recover debt and to improve the detection and, where possible, prevention of overpayments in the DI program, the Commissioner of Social Security should develop and adopt agencywide performance goals, for the recovery of DI overpayment debt, such as the percent of outstanding debt collected annually. |
Based on discussions with OMB, SSA agreed to develop a performance-based recovery target to comply with the requirements of Executive Order 13520. Since SSA's payments are a subset of its overall total payments, the agency is unable to set a numeric target specifically for the recovery of improper payments. For the future, SSA is exploring other systems enhancements and policy improvements that will increase its debt recoveries. SSA's performance-based recovery target was included in its March 15, 2013 Accountable Official's Report. Since the publication of that report SSA has made additional progress on the project, notifying over 200,000 affected debtors. In FY13, SSA implemented the required systems enhancements to collect delinquent debt through the TOP/State Reciprocal program and reported that it began notifying debtors in early FY14 and collected $2.8 million through the state reciprocal program. In FY14, SSA reported that in April 2014, SSA's Acting Commissioner decided to halt recovery of debts 10 years or more delinquent via the Treasury Offset Program pending a thorough review of the agency's policies and discretion under the law. As a result, SSA has not yet completed its notifications, and cannot provide a timeframe for resuming notification to affected debtors.
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| Social Security Administration | To enhance SSA's ability to recover debt and to improve the detection and, where possible, prevention of overpayments in the DI program, the Commissioner of Social Security should require supervisory review and approval of repayment plans which exceed SSA's target of 36 months. |
While SSA disagreed with this recommendation, the agency reminded employees to follow the agency's policy to collect overpayments within 36 months.
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| Social Security Administration | To enhance SSA's ability to recover debt and to improve the detection and, where possible, prevention of overpayments in the DI program, the Commissioner of Social Security should correct the ROAR 2049 system limitation so that debt scheduled for collection after 2049 is included in the system and available for SSA management, analysis, and reporting. |
To address the ROAR 2049 system limitation, SSA took the necessary action to submit a request for systems resources for the FY 2014 Strategic Information Technology Assessment and Review (SITAR).
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| Social Security Administration | To enhance SSA's ability to recover debt and to improve the detection and, where possible, prevention of overpayments in the DI program, the Commissioner of Social Security should explore options for obtaining more timely earnings information for DI program beneficiaries who may be working, and thus are more likely to incur overpayments. This would include developing data sharing agreements to access pertinent earnings-related databases, such as the National Directory of New Hires (NDNH). |
In September 2012, SSA awarded a task order to a vendor to conduct an independent cost benefit analysis (CBA) of a wage data match between Title II disability insurance beneficiaries and the Office of Child Support Enforcement's National Directory of New Hires (NDNH) database. SSA analyzed NDNH and eWork data to develop the CBA. In 2014, SSA implemented a pilot utilizing knowledge of work above SGA due to quarterly earnings targeted for the Ticket to Work program. A sample of SSDI beneficiaries are participating in this small-scale pilot simultaneously replacing unproductive work CDRs with prioritized work CDRs identified using quarterly wages. The pilot was designed to address two issues to reduce improper payments (overpayments): 1) to test new screening protocols to suppress work CDRs that are 100% unproductive (do not represent wages); and 2) to test the ability to release quarterly earnings enforcement work CDRs as part of the existing business process for releasing CDREO alerts based on yearly earnings. In 2015, SSA reviewed data from the first year of the pilot and found that the pilot saved about $700,000, uncovered approximately $3 million in overpayments, and helped SSA process 278 cases about 10 months earlier using the NDNH file than they presumably would have if CDREO selected the case for a CDR using annual earnings. They expanded the pilot to two additional northern Program Service Centers. Additionally, they negotiated a new Computer Matching Agreement (CMA) to provide a quarterly batch match of quarterly wage, new hire, and unemployment insurance against Social Security Disability Insurance (SSDI) beneficiaries, similar to current Supplemental Security Income CMA. The agency believes the new CMA would help to reduce improper payments by enhancing the effectiveness of our current work CDR process to identify cases with work-related overpayments. The agreement is expected to take effect on November 13, 2015.
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| Social Security Administration | To enhance SSA's ability to recover debt and to improve the detection and, where possible, prevention of overpayments in the DI program, the Commissioner of Social Security should develop and adopt additional formal agencywide performance goals for work CDRs to measure the time that cases are pending development, and the number of days taken to process a work CDR. |
SSA's Office of Public Service and Operations Support developed formal performance goals for work CDRs that measure both the time that cases are pending and the number of days taken to process a work CDR. For fiscal year (FY) 2013, SSA Operations adopted new processing time goals for work CDRs, in addition to the age of pending goals that have already been in place for two years. SSA's Office of Systems is also working with Operations to improve the integrity of the Disability Control File, which is the source of the agency's management information (MI) in this area. As the MI source for work CDRs is improved and expanded, the goals will likely change, and additional goals may be added.
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BeneficiariesCollection proceduresDebt collectionDisability benefitsDisability insuranceEligibility determinationsFederal social security programsInternal controlsOverpayment collection waiversOverpaymentsPeople with disabilitiesProgram evaluationPolicies and proceduresFinancial reporting