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    Subject Term: "Disability insurance"

    8 publications with a total of 34 open recommendations including 6 priority recommendations
    Director: Seto Bagdoyan
    Phone: (202) 512-6722

    4 open recommendations
    Recommendation: The Commissioner (or Acting Commissioner) of SSA should direct the OAFP to lead a comprehensive fraud risk assessment that is consistent with leading practices, and develop a plan for regularly updating the assessment.

    Agency: Social Security Administration
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: The Commissioner (or Acting Commissioner) of SSA should direct the OAFP to develop, document, and implement an antifraud strategy that is aligned to its assessed fraud risks.

    Agency: Social Security Administration
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: The Commissioner (or Acting Commissioner) of SSA should direct the OAFP to work with components responsible for implementing antifraud initiatives to develop outcome-oriented metrics, including baselines and goals, where appropriate for antifraud activities.

    Agency: Social Security Administration
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: The Commissioner (or Acting Commissioner) of SSA should direct the OAFP to review progress toward meeting goals on a regular basis, and recommend that the NAFC make changes to control activities or take other corrective actions on any initiatives that are not meeting goals.

    Agency: Social Security Administration
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Director: Kay E. Brown
    Phone: (202) 512-7215

    2 open recommendations
    including 1 priority recommendation
    Recommendation: The Secretary of Agriculture should take additional steps to collect and disseminate information on promising practices that could help improve data matching processes among state SNAP agencies, including broad and timely dissemination of information on results of recent relevant pilots or demonstrations.

    Agency: Department of Agriculture
    Status: Open
    Priority recommendation

    Comments: The U.S. Department of Agriculture's (USDA) Food and Nutrition Service (FNS) agreed with this recommendation. The agency noted it is moving in this direction and would build on current efforts to address them. GAO will monitor these efforts and consider closing the recommendation when these efforts have been completed.
    Recommendation: The Secretary of Agriculture should work with the Department of Health and Human Services (as appropriate) to analyze spending and understand data needs for SNAP across federal and state contracts and in relation to other programs as FNS explores ways to potentially reduce the costs of using commercial data services.

    Agency: Department of Agriculture
    Status: Open

    Comments: The U.S. Department of Agriculture's (USDA) Food and Nutrition Service (FNS) agreed with this recommendation. The agency noted it has been moving in this general direction and would build on current efforts to address it. GAO will monitor these efforts and consider closing the recommendation when these efforts have been completed.
    Director: bertonid@gao.gov
    Phone: (202) 512-7215

    8 open recommendations
    including 1 priority recommendation
    Recommendation: To ensure effective and appropriate recovery of DI overpayments and administration of penalties and sanctions, the Acting Commissioner of the Social Security Administration should clarify its policy for assessing the reasonableness of expenses used in determining beneficiaries' repayment amounts to help ensure that withholding plans are consistently established across the agency and accurately reflect individuals' ability to pay.

    Agency: Social Security Administration
    Status: Open

    Comments: As a result of the Bipartisan Budget Act of 2015, SSA gained the ability to use the Access to Financial Information (AFI) system to verify information about the assets of beneficiaries. In February 2017, the agency reported it is continuing to work on clarifying its policy for assessing the reasonableness of expenses used in determining repayment amounts, including guidance on using the new AFI process. As part of this effort, SSA is also reviewing the Internal Revenue Service's (IRS) Collection Financial Standards and determining whether it can incorporate these or similar standards in its policies for determining reasonable repayment amounts. We will continue to track SSA's efforts to clarify its policies, including efforts to incorporate IRS standards.
    Recommendation: To ensure effective and appropriate recovery of DI overpayments and administration of penalties and sanctions, the Acting Commissioner of the Social Security Administration should improve oversight of DI benefit withholding agreements to ensure that they are completed appropriately. This could include requiring supervisory review of repayment plans or sampling plans as part of a quality control process, and requiring that supporting documentation for all withholding plans be retained to enable the agency to perform such oversight.

    Agency: Social Security Administration
    Status: Open

    Comments: SSA agreed with this recommendation, but does not believe that it is necessary to conduct supervisory reviews. As of February 2017, SSA reported that it is exploring system, policy, and training opportunities to better ensure staff appropriately complete benefit withholding agreements. We will continue to track SSA's efforts to improve oversight in this area.
    Recommendation: To ensure effective and appropriate recovery of DI overpayments and administration of penalties and sanctions, the Acting Commissioner of the Social Security Administration should explore the feasibility of using additional methods to independently verify financial information provided by beneficiaries to ensure that complete and reliable information is used when determining repayment amounts. These additional tools could include those already being used by the agency for other purposes.

    Agency: Social Security Administration
    Status: Open

    Comments: According to SSA, Section 834 of the Bipartisan Budget Act of 2015 gave the agency the authority to use the Access to Financial Information system as part of the agency's waiver determination process. SSA reported that, as of February 2017, it also considered using the National Directory of New Hires Query for verifying an overpaid beneficiary's financial information, but preliminarily determined that the information in this system would be of limited value since it is a quarterly report of past earnings. SSA states that it continues to explore other options to verify financial information such as The Work Number and the Interstate Benefit Inquiry. We will monitor SSA's efforts to explore additional options for verifying financial information.
    Recommendation: To ensure effective and appropriate recovery of DI overpayments and administration of penalties and sanctions, the Acting Commissioner of the Social Security Administration should adjust the minimum withholding rate to 10 percent of monthly DI benefits to allow quicker recovery of debt.

    Agency: Social Security Administration
    Status: Open
    Priority recommendation

    Comments: SSA agreed with this recommendation and as of April 2017, it estimated that this would result in an additional $213 million in collections over a 5-year period. The fiscal year 2017 President's budget submission contained a legislative proposal to make this change, but has not yet been enacted. In April 2017, the agency reported that, in the third quarter of fiscal year 2017, it intends to resubmit a regulatory change to establish the minimum withholding rate to 10 percent in the event that its legislative proposal is not included in the fiscal year 2017 budget.
    Recommendation: To ensure effective and appropriate recovery of DI overpayments and administration of penalties and sanctions, the Acting Commissioner of the Social Security Administration should consider adjusting monthly withholding amounts according to cost of living adjustments or charging interest on debts being collected by withholding benefits. Should SSA determine that it is necessary to do so, it could pursue legislative authority to use recovery tools that it is currently unable to use.

    Agency: Social Security Administration
    Status: Open

    Comments: As of February 2017, SSA continued to disagree with this recommendation. For debt subject to benefit withholding, which is not considered delinquent debt, SSA asserted that these measures would not have a significant effect on the amount of debt recovered, especially compared to the option of changing the minimum withholding rate to 10 percent of monthly benefits. For delinquent debt, SSA stated charging interest on debts would require substantial changes to multiple systems that affect its overpayment businesses processes, and would require extensive training to its employees. We continue to believe there is merit in further consideration of these measures. While SSA reported it has studied the potential changes needed to charge interest on debt, without further consideration of, for example, the costs and benefits of charging interest or adjusting withholding amounts according to cost of living adjustments, SSA cannot know the extent to which these options would improve debt recovery efforts or help protect the value of debts against the effects of inflation, which can be substantial given that withholding plans can take decades to complete.
    Recommendation: To ensure effective and appropriate recovery of DI overpayments and administration of penalties and sanctions, the Acting Commissioner of the Social Security Administration should pursue additional debt collection tools for collecting delinquent penalties. This includes taking steps to implement tools within its existing authority and exploring the use of those not within its authority, and seeking legislative authority if necessary.

    Agency: Social Security Administration
    Status: Open

    Comments: In June 2016, SSA reported that: it had drafted regulations to use existing external debt collection tools for penalties, was developing a legislative proposal to allow the use of additional debt collection tools such as Federal salary offset and credit bureau reporting, and had started planning for a multi-activity, multi-year administrative sanctions project. In February 2017, SSA reported that, as part of its administrative sanctions project, the agency revised policy guidance on factors significant to OCIG's civil monetary penalty determinations. We will track SSA's progress in applying new tools to collecting penalties.
    Recommendation: To ensure effective and appropriate recovery of DI overpayments and administration of penalties and sanctions, the Acting Commissioner of the Social Security Administration should take steps to collect complete, accurate, and timely data on, and thereby improve its ability to track civil monetary penalties and their disposition.

    Agency: Social Security Administration
    Status: Open

    Comments: As of February 2017, SSA reported that it is developing a workload tracking tool for penalties to provide accurate management information on cases. SSA expects to implement this tool by September 2017, and have the first full year of management information available in fiscal year 2018. We will close this recommendation once SSA implements and begins using this tool.
    Recommendation: To ensure effective and appropriate recovery of DI overpayments and administration of penalties and sanctions, the Acting Commissioner of the Social Security Administration should take steps to collect complete, accurate, and timely data on, and thereby improve its ability to track administrative sanctions and their disposition.

    Agency: Social Security Administration
    Status: Open

    Comments: As of February 2017, SSA reported that it has been developing a new workload tracking tool for administrative sanctions. The first phase of this tool was implemented in December 2016 and allows SSA to track administrative sanction cases throughout the development process. The second phase, expected to be implemented by September 2017, will provide SSA with management information on sanctions cases. We will continue to monitor SSA's process in developing this tool. We will close this recommendation once the tool is implemented.
    Director: Daniel Bertoni
    Phone: (202) 512-7215

    6 open recommendations
    Recommendation: The Acting Commissioner of Social Security should direct the Deputy Commissioner of Operations to further consider cost savings as part of its prioritization of full medical reviews. Such options could include considering the feasibility of prioritizing different types of beneficiaries on the basis of their estimated average savings and, as appropriate, integrating case-specific indicators of potential cost savings, such as beneficiary age and benefit amount, into its modeling or prioritization process.

    Agency: Social Security Administration
    Status: Open

    Comments: In July 2017, SSA stated that there is no accepted way to accurately predict future benefit payments at the individual level and that any improvement from implementing this recommendation would be minimal - and would be reduced over time as the continuing disability review (CDR) backlog diminishes - because SSA already considers expected return on investment by cohort in its overall approach to releasing CDRs. It is unclear whether SSA will be able to achieve and sustain currency in its CDR workloads. Even if SSA were to eliminate the backlog of full medical reviews, refining its prioritization process would enable the agency to more efficiently use its resources with any future backlogs. SSA could use actuarial considerations to prioritize refined cohorts of beneficiaries (e.g., types of DI beneficiaries) on the basis of their estimated average savings. SSA Operations could collaborate with SSA's Office of the Actuary on this work as needed. SSA previously agreed that it could look for ways to improve its return on conducting CDRs, but also stated that its statistical models and prioritization process already do much of what we recommend. For example, SSA stated that age is already a strong variable in its statistical models. However, these models predict medical improvement and are not designed to take expected cost savings into account. We continue to believe that to maximize expected cost savings SSA could refine its prioritization process by factoring in additional actuarial considerations.
    Recommendation: The Acting Commissioner of Social Security should direct the Deputy Commissioner of Budget, Finance, Quality, and Management to complete a re-estimation of the statistical models that are used to prioritize CDRs and determine a plan for re-estimating these models on a regular basis to ensure that they reflect current conditions.

    Agency: Social Security Administration
    Status: Open

    Comments: In July 2016, SSA re-estimated the statistical models that it uses to prioritize CDRs. However, as of October 2017, SSA has not yet produced a plan for re-estimating the models on a regular basis to ensure that they continually reflect current conditions.
    Recommendation: The Acting Commissioner of Social Security should direct the Deputy Commissioner of Budget, Finance, Quality, and Management to monitor the characteristics of CDR errors to identify potential root causes and report results to the Disability Determination Services. For example, SSA could analyze CDRs with and without errors to identify trends by impairment, beneficiary type, or other characteristics.

    Agency: Social Security Administration
    Status: Open

    Comments: SSA agreed with this recommendation and stated that it reports all errors to the relevant DDS for corrective action. SSA further stated that its identification of root causes is limited by the relatively few reviewed CDRs that have errors. However, in fiscal year 2014 as an example, SSA identified over 600 CDRs with errors. Although these CDRs make up a small percentage of the CDRs reviewed by SSA that year, the agency could analyze the characteristics of CDRs with errors by comparing relevant percentages without modeling. In addition, SSA could combine data from multiple years if it determined that considering more CDRs with errors would be helpful. There is no change in the status of this recommendation for 2017.
    Recommendation: The Acting Commissioner of Social Security should direct the Deputy Commissioner of Budget, Finance, Quality, and Management to regularly track the number and rate of date errors, which can affect benefit payments (e.g., incorrect cessation dates), and consider including those errors in its reported CDR accuracy rates.

    Agency: Social Security Administration
    Status: Open

    Comments: SSA disagreed with this recommendation and stated that, per SSA regulation, the agency does not consider date errors when calculating accuracy rates because date errors do not affect the decision to cease or continue benefits. SSA also stated its stewardship reviews examine the non-medical quality of benefit payment decisions. However, these reviews are not focused on CDRs, and SSA does not report results from them for CDRs specifically. SSA also explained that it does not track the number and rate of date errors because they are infrequent. However, SSA's regulations do not prevent the agency from tracking date errors, and until it does, SSA cannot definitively determine the frequency of these errors. In addition, we found that considering date errors substantially reduced some states' estimated CDR accuracy rates. Without tracking these errors, SSA cannot assess their effect and consider whether including them in its reported CDR accuracy rates has merit. There is no change in the status of this recommendation for 2017.
    Recommendation: The Acting Commissioner of Social Security should direct the Deputy Commissioner of Budget, Finance, Quality, and Management to adjust its approach to sampling CDRs to efficiently produce reliable accuracy rate estimates for continuances and cessations separately in each state.

    Agency: Social Security Administration
    Status: Open

    Comments: SSA disagreed with this recommendation and stated that some states do not generate enough CDR decisions, particularly cessations, to generate statistically valid samples. However, for states with CDR samples that are consistently too small to produce reliable results, SSA could, for example, pool decisions from more months than it currently does to generate statistically valid samples by state. Conversely, for states with CDR samples that are consistently larger than necessary to efficiently achieve reliable results, SSA could, for example, reduce sample sizes. Because CDR accuracy rates vary by state and cessations are consistently less accurate than continuances, we maintain that SSA should adjust its approach to sampling CDRs. There is no change in the status of this recommendation for 2017.
    Recommendation: The Acting Commissioner of Social Security should direct the Chief Actuary to better document the methods including data sources, assumptions, and limitations that factor into its estimates of CDR cost savings.

    Agency: Social Security Administration
    Status: Open

    Comments: SSA agreed with this recommendation and stated that it will improve and expand its existing documentation as time and resources permit. As of July 2017, SSA had begun to improve documentation of its OASDI estimates and plans further enhancements including documenting the methods of its SSI estimates.
    Director: Daniel Bertoni
    Phone: (202) 512-7215

    7 open recommendations
    including 1 priority recommendation
    Recommendation: To improve transparency in reporting processing errors, SSA should provide additional information on the margins of error or confidence intervals, and clearly identify any limitations in its findings on overpayment information provided to Congress and the public.

    Agency: Social Security Administration
    Status: Open

    Comments: SSA agreed with this recommendation and reported in January 2016 that it would include a discussion about the limitations of error deficiencies data in future reports. To help close this recommendation, SSA will need to report any limitations, such as small sample sizes, that would affect the reliability of its estimates of DI improper payments due to specific types and causes of errors. Although SSA provided recommendation updates on this report in April 2017, it did not comment on this particular recommendation.
    Recommendation: To minimize the potential effect of vulnerabilities in the work reporting process, SSA should take steps to help ensure that work information is entered directly into eWork, the system of record for work information, and issue required receipts. Such steps could include: (a) Improving and issuing guidance and training to field and 800- number staff to help ensure they log information into eWork and issue required receipts. (b) Establishing policies to monitor alerts to help ensure that work information for concurrent beneficiaries is reflected in SSI and DI systems, and take steps to monitor and make enhancements to systems or guidance, as needed.

    Agency: Social Security Administration
    Status: Open

    Comments: In April 2017, SSA reported that it updated training to Field and Processing Center staff and issued an administrative message to staff to remind them about issues related to overpayments and waivers. SSA also reported that, as part of its implementation of Section 826 of the Bipartisan Budget Act of 2015 (P.L.114-74), it is creating a business process and building an internet work reporting system that will allow both SSDI beneficiaries and SSI recipients to report work and earnings electronically. According to SSA, this system will determine the individual's entitlement and automatically forward the work report to the appropriate staff for processing CDR decisions. To close this recommendation, SSA will need to provide documentation that shows the agency provided training and reminders to staff, and that the agency implemented a mechanism that ensures work information for concurrent beneficiaries is reflected in both SSI and DI systems.
    Recommendation: To further ensure the effective screening of work reports, SSA should monitor its process for handling work reports to determine whether staff are taking action on work reports in accordance with proper procedures, and provide feedback to staff as needed.

    Agency: Social Security Administration
    Status: Open

    Comments: In its April 2017 update, SSA continued to disagree with this recommendation. SSA stated that the outcome of a work continuing disability review (CDR) is not dependent on the accuracy of the work report. However, as we noted in our report, inaccurate work reports may result in overpayments or work receipts (which are required by law) to not be issued. Further, pending work reports may be closed inappropriately without resulting in a work CDR. To help close this recommendation, SSA will need to show how it plans to monitor its process for handling work reports to determine compliance with agency procedures, and how feedback, if any, will be provided to staff.
    Recommendation: To enhance the ease and integrity of the work reporting process, SSA should study the costs and benefits of automated reporting options, including options similar to those currently available for SSI recipients, but that do not go as far as automating the continuing disability review process.

    Agency: Social Security Administration
    Status: Open

    Comments: In April 2017, SSA reported that the agency has made progress on two fronts, which could enhance the ease and integrity of its work reporting process, both pursuant to the Bipartisan Budget Act of 2015 (BBA). In response to Section 826 of BBA, which requires SSA to permit Disability Insurance (DI) beneficiaries to report their earnings via electronic means similar to what is available for SSI recipients, SSA reported that it has drafted a business process to build an Internet and wage reporting system for SSDI beneficiaries. SSA also noted that this business process contains plans for an Internet work reporting system that will allow both SSDI and SSI recipients to report work and earnings electronically and will automatically forward the work report to either SSI or eWork (for DI beneficiaries), and will automatically generate a receipt to the beneficiary. SSA has also completed a business process for Section 824 of the BBA, which allows SSA to contract with third party payroll providers to receive earnings in a monthly file. SSA reported that these data will allow SSI to automate benefit adjustments based on the monthly earnings report, and for DI, the information will be incorporated into the agency's Work Smart process--a new technique that combines several business processes into one unified approach to identify cases in need of a work continuing disability review. To help close this recommendation, SSA will need to provide documentation of its proposed business process for building Internet and telephone wage reporting systems for DI beneficiaries.
    Recommendation: To enhance beneficiary understanding of work reporting requirements, SSA should: (a) Clarify work reporting requirements provided to beneficiaries. (b) Explore options for increasing the frequency of reporting reminders to DI beneficiaries, similar to those currently available to SSI recipients.

    Agency: Social Security Administration
    Status: Open

    Comments: SSA agreed with this recommendation and noted in January 2016 that it plans to assess its method of communication and explore options to strengthen its message to Disability Insurance (DI) beneficiaries regarding the importance of consistent wage reporting. The agency also plans to consider whether direct phone outreach, currently being piloted to improve wage reporting for SSI recipients, would be appropriate for the DI program. In its April 2017 update, SSA indicated progress toward: updating policies and procedures related to "treatment of earnings derived from services," implementing a commercial payroll data exchange pursuant to section 824 of the BBA, and implementing electronic reporting of earnings pursuant to section 826 of the BBA. While the agency's actions to implement BBA requirements may improve program administration, SSA did not explain how these actions or its efforts to update to policies and procedures related to "treatment of earnings derived from services" would clarify work reporting requirements for or increase the frequency of reporting reminders to DI beneficiaries. SSA also did not provide an update on its plans to assess communication and explore options, as it reported in January 2016. To help close this recommendation, SSA will need to show how these or other actions taken clarify work reporting requirements for and increase reporting reminders for DI beneficiaries.
    Recommendation: improve compliance with waiver policies, SSA should develop a timetable for implementing updates to its Debt Management System to: (a) Align system controls with SSA policy, so that waivers over $1,000 cannot be administratively waived. (b) Ensure that evidence supporting waiver decisions is sufficiently maintained to allow for subsequent monitoring and oversight.

    Agency: Social Security Administration
    Status: Open
    Priority recommendation

    Comments: According to SSA, in February 2016, the agency implemented an edit to the Debt Management System remarks that amended a deficiency in the system that prevented system remarks from being deleted after a case is closed. The edit locks Debt Management System remarks to prevent technicians from overwriting existing remarks in closed cases. With respect to ensuring that overpayments over $1,000 cannot be administratively waived, SSA reported in November 2016 that it will provide a timeline for and take steps to update the Debt Management System when the agency obtains resources to fund the update. SSA reported in April 2017 that its ability to update system controls to align with SSA policy was dependent on resources. To help close this recommendation, SSA will need to show its plans and time frames for updating system controls to align them with SSA policy.
    Recommendation: To improve compliance with waiver policies, SSA should take steps to regularly assess the accuracy of DI waiver decisions, particularly for administrative waivers and for some waivers under $2,000. This could include periodically reviewing approved and denied DI waivers through its continuous quality initiative.

    Agency: Social Security Administration
    Status: Open

    Comments: In August 2016, the agency reported that it had taken several actions, including producing a comprehensive training series on overpayment and waiver policy and procedures, building a policy cluster to serve as a "one-stop resource shop" of policy references and tools for technicians, and clarifying agency policies including the Administrative Tolerance Decision Tree to assist technicians with making appropriate low-dollar overpayment waiver decisions. The agency also reported that its Continuous Quality work group continues to review the accuracy of waivers under Title II of the Social Security Act. Based on these efforts, in November 2016, SSA reported that it has closed this recommendation. However, as of April 2017, SSA did not specifically report that its review of Title II waivers will target DI waivers, including administrative waivers and waivers less than $2,000, or that such review will be an ongoing effort. To close this recommendation, SSA will need to show its plans for periodically assessing the accuracy of DI waiver decisions--particularly for administrative waivers and waivers under $2,000--through its continuous quality initiative or other means.
    Director: Seto Bagdoyan
    Phone: (202) 512-6722

    4 open recommendations
    including 2 priority recommendations
    Recommendation: To improve SSA's ability to detect, prevent, and recover potential DI benefit overpayments due to the concurrent receipt of FECA benefits, the Commissioner of Social Security should review the potential DI overpayments resulting from FECA benefits identified in our case studies, as well as any indicators of fraudulent activity related to FECA benefits that were not self-reported by DI beneficiaries, and establish debt-collection efforts and fraud-related penalties, as appropriate.

    Agency: Social Security Administration
    Status: Open

    Comments: As of January 2017, SSA stated that it will continue reviewing the potential DI overpayments resulting from FECA benefits identified in GAO's case studies, as GAO recommended in July 2015, and that actions are due to be completed by the end of April 2017. GAO will continue to monitor SSA's efforts in this area.
    Recommendation: To improve SSA's ability to detect, prevent, and recover potential DI benefit overpayments due to the concurrent receipt of FECA benefits, the Commissioner of Social Security should review the instances described in our report in which SSA staff did not obtain proof of FECA benefits that were reported by DI beneficiaries and (1) determine the reasons for these occurrences and whether this is a pervasive problem; and (2) if necessary, design appropriate controls or make other efforts, such as staff training, to help ensure SSA staff obtain proof of workers' compensation payments, as required by SSA policy.

    Agency: Social Security Administration
    Status: Open

    Comments: As of February 2017, SSA stated that it will continue reviewing the instances described in GAO's report in which SSA staff did not obtain proof of FECA benefits that DI beneficiaries reported nor took follow-up actions as needed, as GAO recommended in July 2015. SSA expected to complete its analysis by the end of April 2017. SSA also stated that it has published an administrative message to remind staff of correct development and processing procedures for FECA claims. GAO will continue to monitor SSA's efforts in this area.
    Recommendation: To improve SSA's ability to detect, prevent, and recover potential DI benefit overpayments due to the concurrent receipt of FECA benefits, the Commissioner of Social Security should, in accordance with OMB guidance, compare the costs and benefits of alternatives to SSA's current approach for reducing the potential for overpayments that result from the concurrent receipt of FECA benefits, which relies on beneficiaries to self-report any FECA benefits they receive. These alternatives could include, among others, routinely matching DOL's FECA program data with DI program data to detect potential DI overpayments.

    Agency: Social Security Administration
    Status: Open
    Priority recommendation

    Comments: SSA has taken steps to address this recommendation, but it has not completed its efforts. Specifically, in February 2017, SSA told GAO that the agency continues to discuss with DOL a data-matching agreement to obtain FECA payment data for offsetting DI benefits in accordance with federal law, as GAO recommended in July 2015. SSA also stated that it has reviewed its internal controls, policies, and workflow processes related to DI beneficiaries who receive concurrent FECA payments. Because SSA has not completed its work in this area, it is too early to determine whether these actions will address the problems GAO identified. GAO will continue to monitor SSA's work in this area.
    Recommendation: To improve SSA's ability to detect, prevent, and recover potential DI benefit overpayments due to the concurrent receipt of FECA benefits, the Commissioner of Social Security should strengthen internal controls designed to prevent DI overpayments due to the concurrent receipt of FECA benefits by implementing the alternative that provides the greatest net benefits.

    Agency: Social Security Administration
    Status: Open
    Priority recommendation

    Comments: SSA has taken steps to address this recommendation, but it has not completed its efforts. Specifically, in February 2017, SSA told GAO that the agency was negotiating with DOL to enter into a data matching agreement to obtain FECA payment data for offsetting DI benefits in accordance with federal law, as GAO recommended in July 2015. SSA also stated that it was reviewing its internal controls related to DI beneficiaries who receive concurrent FECA payments and is in the process of considering the best options for strengthening these internal controls. SSA further stated that in August 2016, it issued reminders to technicians regarding developing and processing DI cases when an individual is concurrently receiving FECA benefits. Because SSA has not completed its work in this area, it is too early to determine whether these actions will address the problems GAO identified. GAO will continue to monitor SSA's work in this area.
    Director: Daniel Bertoni
    Phone: (202) 512-7215

    2 open recommendations
    Recommendation: As part of initiatives currently under way to improve agency information on claims with appointed representatives and detect potential fraud associated with representatives, the Commissioner of the Social Security Administration should consider actions to provide more timely access to data on representatives and enhance mechanisms for identifying and monitoring trends and patterns related to representation, particularly trends that may present risks to program integrity. Specifically, SSA could (1) Identify additional data elements, or amendments to current data collection efforts, to improve information on all appointed representatives, including those under contract with states and other third parties; (2) Implement necessary policy changes to ensure these data are collected. This could include enhancing technical systems needed to finalize SSA's 2008 proposed rules that would recognize organizations as representatives; and (3) Establish mechanisms for routine data extracts and reports on claims with representatives.

    Agency: Social Security Administration
    Status: Open

    Comments: In July 2017, SSA reported that it is approaching the conclusion of the first phase of a new initiative, called Registration, Appointment and Services for Representatives (RASR). This initiative aims to register all appointed representatives and improve relevant business processes and data collection. SSA reported that it had to postpone the first release of RASR, originally targeted for December 2016, due to some systems issues. SSA stated that it has not yet set a new target date for the first release. SSA stated that this new application will enhance data collection and management of representatives' information and that it will help make strides toward better oversight and improved data analysis and reporting. We will consider closing this recommendation when these efforts are completed.
    Recommendation: To address risks associated with potential overpayments to representatives and protect claimant benefits, the Commissioner of the Social Security Administration should take steps to enhance coordination with states, counties, and other third parties with the goal of improving oversight and preventing and identifying potential overpayments. This coordination could be conducted in a cost-effective manner, such as issuing guidance to states and other third parties on vulnerabilities for overpayment; sharing best practices on how to prevent overpayments; or considering the costs and benefits, including any privacy and security concerns, of providing third parties controlled access to portions of the eFolder to facilitate the detection of potential overpayments.

    Agency: Social Security Administration
    Status: Open

    Comments: In July 2017, SSA stated that it added a section to a new form--Form SSA-1698, Fee Agreement for Representation before the Social Security Administration--that claimants and representatives can use to enter into fee agreements. According to SSA, this form requires the disclosure of fees that the representative will receive from a third party and the amount of those fees. SSA expects this form to be in use upon OMB approval. Similar language already exists in another form--Form SSA-1560-U4, Petition to Obtain Approval of a Fee for Representing a Claimant before the Social Security Administration--that claimants and representatives can use for fee petitions. SSA stated that these forms are (and will be) included in the folder of evidence that adjudicators may review before determining whether and how much to authorize in fees. According to SSA, disclosure and approval of any third party fees, with potential adjustment of the fee, by both the claimant and SSA should help prevent excessive fees. While the proposed change to the form may help improve transparency of fee arrangements, the potential for a representative to receive a payment from SSA and also receive a payment from a state or other third party still exists. Unless SSA and the state or other third party share information on their payments or have policies and procedures in place to prevent such cases, representatives could still receive both SSA and state payments that total more than the SSA-authorized fee. In order to address this vulnerability, we continue to believe that SSA should enhance coordination or issue guidance to states and other third parties about this vulnerability, which could include SSA sharing best practices for preventing these types of overpayments. For example, one state requires contracted organizations to submit copies of their signed form 1696 (Appointment of Representative) so the state could verify the representative checked the appropriate box for payment.
    Director: Bagdoyan, Seto J
    Phone: (202) 512-4749

    1 open recommendations
    including 1 priority recommendation
    Recommendation: To improve SSA's ability to detect and prevent potential DI cash benefit overpayments due to work activity during the 5-month waiting period, the Commissioner of Social Security should assess the costs and feasibility of establishing a mechanism to detect potentially disqualifying earnings during all months of the waiting period, including those months of earnings that the agency's enforcement operation does not currently detect and implement this mechanism, to the extent that an analysis determines it is cost-effective and feasible.

    Agency: Social Security Administration
    Status: Open
    Priority recommendation

    Comments: While the Social Security Administration (SSA) initially concurred with our August 2013 recommendation, as of February 2017, SSA has not assessed costs and feasibility of establishing a mechanism to detect potentially disqualifying earnings during all months of the waiting period. Instead, SSA concluded that conducting a study at this time would yield unreliable information because the agency's ability to obtain and track earnings from alternative sources is changing due to several requirements of the Bipartisan Budget Act of 2016, which SSA believes will likely affect GAO's concerns. GAO continues to believe that undertaking an analysis to assess costs and feasibility could provide SSA with more comprehensive information with which to decide on potential revisions to its enforcement operation. We will continue to monitor SSA's efforts in this area.