Disability Insurance:

SSA Can Improve Efforts to Detect, Prevent, and Recover Overpayments

GAO-11-724: Published: Jul 27, 2011. Publicly Released: Jul 27, 2011.

Additional Materials:

Contact:

Daniel Bertoni
(202) 512-5988
contact@gao.gov

 

Office of Public Affairs
(202) 512-4800
youngc1@gao.gov

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).

Disability Insurance overpayments detected by SSA increased from about $860 million in fiscal year 2001 to about $1.4 billion in fiscal year 2010. SSA estimates about 72 percent of all projected DI overpayments were work-related during fiscal years 2005 through 2009. While the agency collected, or recovered, $839 million in overpayments in fiscal year 2010, monies still owed by beneficiaries grew by $225 million that same year, and cumulative DI overpayment debt reached $5.4 billion. SSA does not have agencywide performance goals for debt collection-- for example, the percent of outstanding debt collected annually. And while SSA has a policy for full repayment within 3 years, 19 of the 60 work CDR cases GAO reviewed had repayment plans exceeding 3 years. SSA officials said that lengthy repayment plans are often the result of an individual's limited income, but SSA does not review or approve repayment plans which exceed agency policy. During the course of the review, GAO also found a limitation in SSA's Recovery of Overpayments, Accounting and Reporting (ROAR) system. Used to track overpayments and collections, ROAR does not reflect debt due SSA past year 2049, so the total balance due the program is unknown and likely larger than the agency is reporting. SSA officials acknowledged this issue, but are unable to determine the extent of the problem at this time. They told GAO they have a work group which will recommend action to correct the problem. But until this issue is addressed, SSA officials said that the agency can only track and report on overpayments scheduled to be repaid through 2049. The amount owed after that year is unreflected in current totals even as it annually increases. SSA officials reported that the agency has ongoing initiatives to enhance debt collection. SSA has numerous policies and processes in place to perform work CDRs, though two key weaknesses have hindered SSA's ability to identify and review beneficiary earnings which affect eligibility for DI benefits. First, SSA lacks timely earnings data on beneficiaries who return to work. In 49 of the 60 CDR cases GAO reviewed, there was no evidence in the file that the beneficiary reported his or her earnings, as required by program guidelines. To identify unreported work and earnings, SSA primarily relies on data matching with the Internal Revenue Service (IRS), then sends these matches to staff for a work CDR. However, the IRS data may be more than a year old when received by SSA, and SSA says it is not cost-effective to gain access to and use other sources of earnings information, such as the National Directory of New Hires database. In addition, GAO found that cases may wait up to 15 additional months before SSA staff begin work on the CDRs. Second, SSA lacks formal, agencywide performance goals for work CDRs. While it targets 270 days to complete a case, actual processing time ranged from 82 to 992 days (with a median of 396 days) in the 60 cases GAO reviewed, and overpayments which accrued as a result topped $1 million total. SSA officials reported several initiatives to more effectively prioritize work CDR cases--for example, those with the largest potential overpayment amounts--but these efforts are in the early stages, and GAO could not yet assess their effectiveness as part of this review. GAO recommends that SSA develop and adopt agencywide performance goals for recovering DI overpayments and processing work CDRs, require supervisory review of certain repayment plans, address a system limitation which precludes an accurate record of debt owed SSA, and explore options for obtaining more timely earnings information. SSA agreed with four of five recommendations. It disagreed with the need for supervisory review of repayment plans while acknowledging the need for more related guidance to its staff.

Recommendations for Executive Action

  1. Status: Open

    Comments: Based on discussions with the Office of Management and Budget, 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. To date, it has notified over 200,000 affected debtors. The agency's target to complete the required due process notification is February 2014. In FY 2013, SSA will implement the required systems enhancements to collect delinquent debt through the TOP/State Reciprocal program. In October 2013, the agency will begin notifying debtors of SSA's ability to offset State payments to collect their delinquent debt. We will close this recommendation when these efforts are complete.

    Recommendation: 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.

    Agency Affected: Social Security Administration

  2. Status: Closed - Implemented

    Comments: While SSA disagreed with this recommendation, the agency reminded employees to follow the agency's policy to collect overpayments within 36 months.

    Recommendation: 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.

    Agency Affected: Social Security Administration

  3. Status: Closed - Implemented

    Comments: 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).

    Recommendation: 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.

    Agency Affected: Social Security Administration

  4. Status: Open

    Comments: 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. Currently, SSA is analyzing NDNH and eWork data to develop the CBA. SSA anticipates completion of the CBA by the end of FY 2013. GAO awaits the completion of this effort, as well as additional efforts to obtain more timely earnings information.

    Recommendation: 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).

    Agency Affected: Social Security Administration

  5. Status: Closed - Implemented

    Comments: 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.

    Recommendation: 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.

    Agency Affected: Social Security Administration

 

Explore the full database of GAO's Open Recommendations »

Jul 9, 2014

May 14, 2014

Apr 30, 2014

Mar 26, 2014

Jan 13, 2014

Dec 9, 2013

Dec 6, 2013

Nov 20, 2013

Oct 29, 2013

Sep 25, 2013

Looking for more? Browse all our products here