Recommendation: The Board should work with SSA to explore options for obtaining data electronically and limiting the reliance of the financial interchange process on manual data entry. (Recommendation 1)

Agency: Railroad Retirement Board
Status: Open

Comments: RRB reported taking steps to implement this recommendation. In January 2020, the agency received a cost estimate from SSA for a proposed data exchange. In May 2020, RRB and SSA held an inaugural conference call and reached an understanding of the technical requirements to move forward with a data exchange. As of June 2020, RRB reports that systems analysts at SSA are developing the procedures and systems necessary for an electronic data exchange. GAO will close this recommendation when the data system is implemented.

Recommendation: The Board should produce written documentation on the financial interchange process such that a knowledgeable third party could carry out and replicate its process consistently without further explanation. (Recommendation 2)

Agency: Railroad Retirement Board
Status: Open

Comments: As of June 2020, RRB reports that it has been working to draft documentation of the financial interchange calculation process, and sharing drafts of this documentation with SSA for its review. SSA has requested revisions in this documentation and RRB plans to hire additional staff to implement GAO's recommendation. GAO will close this recommendation once RRB finalizes its documentation of the financial interchange calculation process.

Recommendation: The Board should produce formal policies on how the work of staff performing the financial interchange is reviewed. (Recommendation 5)

Agency: Railroad Retirement Board
Status: Open

Comments: As of June 2020, RRB reports that it is in the process of developing formal review policies and plans to include them in its written documentation of the financial interchange process. GAO will close this recommendation once RRB's formal review policy is complete.

Recommendation: The Commissioner of SSA should work with RRB to explore options for electronically sharing data and limiting the reliance of the financial interchange process on manual data entry. (Recommendation 6)

Agency: Social Security Administration
Status: Open

Comments: SSA reported that it received a data exchange request from RRB in October 2018. RRB proposed to send SSA a file of beneficiary and earnings data, and receive calculations for sample financial interchange cases. RRB and SSA discussed options for exchanging information electronically. In early 2020, SSA reported that it is developing a Rough Order of Magnitude/Cost Estimate for electronically sharing data and limiting the reliance of the financial interchange process on manual data entry under its existing agreement. The agency has no timeline to complete this effort.

Recommendation: The Commissioner of SSA should take additional steps to provide oversight of financial interchange calculations at the individual-case level. This could include periodically reviewing a subset of these cases. (Recommendation 7)

Agency: Social Security Administration
Status: Open

Comments: In September 2020, SSA reported that it has developed plans to review of a subset of financial interchange calculations as the individual-case level. SSA anticipates that this review will take place following the completion of RRB's fiscal year 2021-2022 financial interchange calculations. We will close this recommendation once SSA's review successfully takes place.

Recommendation: The Secretary of HHS should, consistent with its existing statutory authority, take additional steps to provide oversight of financial interchange calculations at the individual-case level. If the Secretary concludes that there are limitations in its authority in this area, the Secretary should seek to obtain the necessary additional authority. (Recommendation 8)

Agency: Department of Health and Human Services
Status: Open

Comments: As of July 2020, HHS continues to disagree with this recommendation. HHS officials said that RRB is responsible for certifying its costs through the financial interchange, and that they believe the department lacks the authority to question RRB's calculations. We continue to believe that HHS would be better positioned to ensure that the transfers it makes and receives through the interchange are calculated correctly if it reviews case-level calculations. We will close this recommendation if HHS seeks the authority to review financial interchange calculations or takes other steps to ensure the accuracy of financial interchange calculations performed by RRB.

Recommendation: To improve RRB's ability to make accurate disability benefit eligibility determinations, including CDRs, and to decrease the potential for making improper payments, Congress should consider granting RRB access to the Department of Health and Human Services' quarterly earnings information from the National Directory of New Hires database. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: As of March 2020, no legislation has been enacted resulting from this matter to Congress. RRB's (the Board) fiscal year 2020 budget proposal included a legislative proposal to provide the Board access to the NDNH. Although the Board reported that the resulting proposed legislation drafted by HHS - the entity that maintains the NDNH - would, if enacted, provide access to the NDNH, the Board opposed the proposal in part because it would not waive associated fees to access the NDNH, and concluded access to the NDNH would not be cost-effective. In January 2020, the Board informed GAO it is not currently seeking legislation to gain access to the NDNH, resulting in the Board continuing to use earnings data that may be outdated in its continuing disability reviews, but that it may seek access in the future.

Recommendation: To enhance RRB's ability to manage and oversee its CDR program, RRB should routinely compile and analyze CDR program data, such as the number of cases selected for review, the number of beneficiaries in each medical improvement category, outcomes, and the costs and benefits of conducting CDRs, to improve program oversight. (Recommendation 3)

Agency: Railroad Retirement Board
Status: Open

Comments: RRB agreed with this recommendation. In June 2020, RRB reported that its Program Evaluation and Management Services (PEMS) section will compile and analyze all relevant CDR program case and cost data to better oversee CDRs. RRB said that its first analysis would cover CDR's adjudicated from April 2019 through September 2020; as of June 2020 they had adjudicated 107 CDR cases. In addition, RRB reported that its monthly reporting on CDRs to the Director of Disability includes information on the type of CDR completed, the medical improvement category for medical CDR, and the disposition of the CDR. In August 2018, the agency had reported that it began reporting in October 2017 weekly pending CDR type action cases to the Director of Programs, and that it had begun tracking CDR reason codes for each medical improvement category. To close this recommendation, RRB will need to include an analysis of the costs and benefits of conducting CDRs, including any overpayments or underpayments processed, and share its complete analysis of CDRs through September 2020 after it is completed. At that point GAO will review the analysis and decide if it provides a sufficient bases for program oversight.