Recommendation: The Administrator of FNS should develop and implement a process, documented in policies and procedures, to analyze SNAP state-level root causes to identify potential similarities among the states and develop and implement SNAP agency-level corrective actions, if appropriate, to help address them. (Recommendation 1)

Agency: Department of Agriculture: Office of the Secretary: Food, Nutrition and Consumer Services: Food and Nutrition Service
Status: Open

Comments: In commenting on our draft report, USDA stated that the Food and Nutrition Service should formalize its existing processes into a standard operating procedure to analyze the Supplemental Nutrition Assistance Programs (SNAP) state-level root causes to identify potential similarities among states, in order to improve development and implementation of SNAP agency-level corrective actions, if appropriate.

Recommendation: The Secretary of Agriculture should revise USDA's procedures to include processes for monitoring the progress and measuring the effectiveness of improper payment corrective actions. The process for measuring the effectiveness of corrective actions should clearly demonstrate the effect USDA's corrective actions have on reducing improper payments. (Recommendation 2)

Agency: Department of Agriculture
Status: Open

Comments: In commenting on our draft report, USDA stated that a proposed action plan will be developed to revise USDA's procedures for monitoring the progress and measuring the effectiveness of improper payment corrective actions. Processes will focus on the impact corrective actions have on the root causes of improper payments.

Recommendation: The Secretary of Education should revise and document Education's process for measuring the effectiveness of its corrective actions based on its new statistical estimation methodology for Direct Loan and Pell Grant improper payments. This process should clearly demonstrate the effect Education's corrective actions have on reducing improper payments. (Recommendation 3)

Agency: Department of Education: Office of the Secretary
Status: Open

Comments: In commenting on our draft report, Education stated that Federal Student Aid (FSA) will continue to evaluate and refine its processes to measure corrective actions and the effectiveness of these actions. Further, Education stated that FSA's measurement of corrective action effectiveness and root cause identification will gain additional precision as FSA collects annual improper payment data and builds upon the new baseline of statistically valid improper payment estimates. Education stated that FSA annually measures the overall effectiveness of its corrective action plans collectively against the improper payment reduction targets, rather than measuring the effectiveness of each individual corrective action. However, OMB guidance directs agencies to measure the effectiveness of each individual corrective action annually.

Recommendation: The Secretary of Health and Human Services should document in policies and procedures HHS's improper payment corrective action plan process. As part of these procedures, HHS should include processes for (1) establishing planned completion dates, (2) monitoring the progress of implementing corrective actions, and (3) measuring the effectiveness of improper payment corrective actions. The process for measuring the effectiveness of corrective actions should clearly demonstrate the effect HHS's corrective actions have on reducing improper payments. (Recommendation 4)

Agency: Department of Health and Human Services: Office of the Secretary
Status: Open

Comments: In commenting on our draft report, HHS elaborated on the improper payment corrective action plan process that is called for in OMB guidance. HHS stated that OMB guidance provides agencies the flexibility to measure the effectiveness of corrective actions and believes that this flexibility is vital to its oversight processes to reduce improper payments.

Recommendation: The Secretary of the Treasury should determine whether Treasury's current improper payment root cause analysis provides sufficiently relevant information that can be used as a basis for proposed corrective actions in reducing EITC improper payments and, if not, update the analysis using more timely data to ensure their reliability for identifying root causes of EITC improper payments. (Recommendation 5)

Agency: Department of the Treasury: Office of the Secretary
Status: Open

Comments: In commenting on our draft report, Treasury stated that each year it indicates in its corrective action plan that IRS will continue to work with Treasury to develop legislative proposals that will improve refundable credit compliance and reduce erroneous payments.

Recommendation: The Secretary of the Treasury should update Treasury's strategy for addressing the root causes of EITC improper payments to include (1) coordinating with other agencies to identify potential strategies and data sources that may help in determining EITC eligibility and (2) determining whether legislative changes are needed, and developing proposals as appropriate, to help reduce EITC improper payments, such as those related to the inability to authenticate taxpayer eligibility. (Recommendation 6)

Agency: Department of the Treasury: Office of the Secretary
Status: Open

Comments: In commenting on our draft report, Treasury stated that each year it indicates in its corrective action plan that IRS will continue to work with Treasury to develop legislative proposals that will improve refundable credit compliance and reduce erroneous payments. Although Treasury has made certain legislative proposals, it has not made proposals to specifically help address EITC eligibility criteria issues. Additionally, Treasury's strategy does not include identifying and proposing additional legislative changes needed to help reduce EITC improper payments.

Recommendation: The Commissioner of SSA should develop and implement a process, documented in policies and procedures, to measure the effectiveness of SSA's corrective actions for OASDI and SSI improper payments. This process should clearly demonstrate the effect SSA's corrective actions have on reducing improper payments. (Recommendation 7)

Agency: Social Security Administration
Status: Open

Comments: In commenting on our draft report, SSA stated that it will determine the most cost-effective strategies to remediate the underlying causes of payment errors and monitor, measure, and revise the strategies as needed.

Recommendation: The Commissioner of the Social Security Administration should clarify policies and procedures to remind staff that a diagnosis of a substance use disorder is not necessary to conduct a Drug Addiction and Alcoholism evaluation. (Recommendation 1)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation. The agency stated that it had revised related policies in February 2020, and had planned to issue guidance and video-on-demand training to further clarify policies and procedures in this area. However, SSA said its efforts to maintain mission critical activities amid the COVID-19 pandemic have delayed further implementation of this recommendation and a specific implementation date could not be provided at this time.

Recommendation: The Commissioner of the Social Security Administration should ensure that staff document their rationale for decisions involving the Drug Addiction and Alcoholism evaluation process. (Recommendation 2)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation. The agency said it had planned to issue guidance reinforcing its policy on properly documenting decisions involving the Drug Addiction and Alcoholism evaluation process. However, SSA said its efforts to maintain mission critical activities amid the COVID-19 pandemic have delayed implementation of this recommendation and a specific implementation date could not be provided at this time.

Recommendation: The Commissioner of SSA should develop a set of public performance measures, to include accuracy and consistency, as well as timeliness, of administrative law judges' (ALJ) disability decisions. SSA could consider whether existing quality review or monitoring efforts could provide suitable data for such measures. (Recommendation 1)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation and stated that it would address it as part of a comprehensive assessment and refinement of its oversight roles and processes. As of February 2020, SSA officials reported that the agency developed a new review of hearing decisions to assess decisional quality on a national level. Officials said they implemented the review throughout fiscal year 2019 and will draft a report on the findings in fiscal year 2020. As they review results from this review, SSA officials said that they will assess whether existing quality review measures will provide suitable data for performance measures related to timeliness, consistency, and accuracy. Officials said they do not have a timeline for implementing this recommendation.

Recommendation: The Commissioner of SSA should systematically evaluate the efficiency and effectiveness of its quality assurance reviews and take steps to reduce or better manage any unnecessary overlap among them to ensure strategic use of resources. Such steps could include enhancing collaboration where reviews overlap or only conducting the reviews that are most efficient and effective in achieving agency goals for improving accuracy and consistency of ALJ disability decisions. (Recommendation 2)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation and stated that it would address this recommendation as part of a comprehensive assessment and refinement of its oversight roles and processes. In March 2018, SSA noted that the Offices of Quality Review and Appellate Operations are now consolidated under the Office of Analytics, Review, and Oversight (OARO). According to SSA, OARO was created with the purposes of enhancing collaboration, eliminating unnecessary overlap, and enhancing the efficiency of reviews. As of February 2020, SSA officials said that they developed a new review of favorable and unfavorable hearing decisions to provide statistically valid results on the quality of decisions on appealed disability claims at the national level. Officials said they will use the results of this one-time review to help assess the utility of their other quality reviews. Successful completion of these efforts should help to ensure effective use of resources in overseeing the quality of decisions on appealed disability claims.

Recommendation: The Acting Commissioner of the Social Security Administration should analyze the SEIE data to determine why a large proportion of transition-age youth on SSI with reported earnings did not benefit from the SEIE and, if warranted, take actions to ensure that those eligible for the incentive benefit from it.

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation. In August 2018, the agency reported that it was evaluating the accuracy of its SEIE data and once completed, the agency would analyze these data to determine whether there are significant numbers of students with earnings who are not benefiting from the SEIE. In February 2020, SSA reported that it was still working to resolve the issues with SEIE data identified during GAO's audit. SSA does not currently have a timeline for completing its analysis of its SEIE data. SSA also reported that it has submitted legislative proposals in several Presidential Budgets, most recently in fiscal year 2021, that would eliminate earnings reporting for youth, which would prevent similar concerns in the future. GAO will close this recommendation when SSA analyzes SEIE data and, if warranted, takes actions needed to ensure those eligible for SEIE benefit from it, or when all students with earnings receive SEIE because SSA's legislative proposal was enacted.

Recommendation: The Acting Commissioner of the Social Security Administration should analyze options to improve communication about SSA-administered work incentives and the implications of work on SSI benefits, with a goal of increasing understanding of SSI program rules and work incentives among transition-age youth and their families. This should include, but not necessarily be limited to, updating SSAs procedures for staff meeting with SSI applicants, recipients, and their families to regularly and consistently discuss - when applicable--how work incentives can prevent reductions in benefit levels and how work history is considered during eligibility redeterminations.

Agency: Social Security Administration
Status: Open

Comments: SSA disagreed with this recommendation. In August 2018, SSA noted it already requires staff to meet with SSI recipients regularly and instructs staff to discuss relevant work incentives, and that there is no indication that staff are not providing youth with appropriate work incentive information. However, SSA did not explain how it knows or ensures that staff are providing this information and SSA policies do not instruct staff to consistently convey information to youth and families on how work may or may not affect age 18 redetermination. SSA also reported that Work Incentives Planning and Assistance (WIPA) projects must prioritize working with youth who are referred to them. While we recognize the important role that WIPA projects play in providing work incentives counseling to SSI youth, as we previously reported, WIPA projects have limited capacity for serving youth along with other SSI recipients and disability insurance beneficiaries. In June 2019, SSA reported it had updated a brochure-containing information in English or Spanish on age-18 redeterminations, impact of earnings on benefits, work incentives and contact information to include information on SSA work incentives that may allow recipients who work to keep their Medicaid benefits. As of February 2020, the agency reported that it began sending this brochure to approximately 358,000 youth between the ages of 14 and 17 who receive SSI, and made this brochure available on its website. SSA also reported that it has begun exploring ways to better utilize social media to reach youth. While these are positive steps, we previously reported that written information may not be sufficient for conveying complex information. GAO continues to believe that SSA field office staff are both obliged and best-positioned to explain these rules. Moreover, in response to an SSA request for information in January 2018, SSA received public feedback on how it might improve transition outcomes for youth on SSI through better communication, suggesting that SSA's current communication strategies may not be sufficiently effective. We will consider closing this recommendation when SSA has taken further steps to ensure field staff are providing consistent and accurate information.

Recommendation: The Acting Commissioner of the Social Security Administration should work with the Secretary of Education to determine the extent to which youth on SSI are not receiving transition services through schools that can connect them to VR agencies and services.

Agency: Social Security Administration
Status: Open

Comments: SSA partially agreed with this recommendation, but after discussing it with the Department of Education, reported that significant challenges exist to pursuing certain implementation approaches. In December 2019, SSA reported that it continues to support research to identify the connection between youth on SSI and the receipt of VR services through its Retirement and Disability Research Consortia and its Analyzing Relationships Between Disability, Rehabilitation, and Work programs. SSA also reported that until very recently, data on open VR cases were unavailable at the national level; thus, it has not been possible to actively monitor SSI and VR participation in a timely manner. However, SSA reported that the agency will explore the possibility of using newly available data on open VR cases as resources allow. Determining the extent to which SSI youth are receiving or have access to services may help youth on SSI achieve employment and, potentially, self-sufficiency.

Recommendation: The Acting Commissioner of the Social Security Administration should explore various options for increasing connections to VR agencies and services, including their potential costs and benefits. One option, among others, could be to expand the Ticket to Work program to include youth.

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation and, in August 2018, SSA officials reported that they had taken several steps to explore and pursue options for increasing youths' connections to vocational rehabilitation agencies and services. Specifically, officials previously reported that they published a request for information (RFI) in the Federal Register in January 2018 that asks, among other things, for strategies to connect youth receiving Supplemental Security Income (SSI) with vocational rehabilitation agencies and about options for programs like a Ticket to Work for youth. In July 2019, SSA reported receiving and analyzing almost 200 responses to its RFI and indicated that it plans to discuss its findings with federal partners and other stakeholders. SSA officials also previously reported that the agency reviewed the Social Security Act and that the law precludes SSA from directly or indirectly referring youth on SSI to vocational rehabilitation agencies. Therefore, as of December 2019, the agency reported that it has submitted legislative proposals in several presidential budgets, including its fiscal year 2021 budget justification, that would allow SSA to refer youth to vocational rehabilitation agencies. SSA officials also reported that the agency has initiated demonstration projects to determine whether youth on SSI benefit from referrals to vocational rehabilitation agencies and commissioned reports related to services for youth.. According to information provided in July 2019, one of SSA's demonstration projects analyzes an experimental intervention to improve the outcomes of children receiving SSI by providing personalized information to families about the likelihood that a child will not continue on SSI as an adult, as well as resources to help these youth with the transition to employment. The resources offered will include: math tutoring, SAT/ACT test preparation, and help with applying for vocational rehabilitation services. In addition, according to information SSA provided in July and December 2019, the agency's second demonstration project will involve testing direct referrals to VR in one state for 19 year olds who are or may become SSI or Social Security Disability Insurance beneficiaries, and involves data sharing between SSA and the state on individuals eligible to participate in the project. This project is scheduled to begin recruiting participants in January 2020. SSA also reported that it has commissioned two reports on youth services that will help it identify implementable polices related to youth. Exploring the potential costs and benefits of employment support services for youth who receive or are at risk of being disability program beneficiaries as adults may help SSA develop programs to support the self-sufficiency of these youth. However, to date, SSA has not indicated that it has explored, or it may be too soon to explore, the costs and benefits of any of the options SSA has considered for increasing access to vocational rehabilitation agencies for youth on SSI.

Recommendation: To ensure that current vesting policies appropriately balance plans' needs and interests with the needs of workers to have employment mobility while also saving for retirement, Treasury should evaluate the appropriateness of existing maximum vesting policies for account-based plans, considering today's mobile labor force, and seek legislative action to revise vesting schedules, if deemed necessary. The Department of Labor could provide assistance with such an evaluation.

Agency: Department of the Treasury
Status: Open

Comments: As of August 2020, no action had been taken on this recommendation. Treasury did not report an evaluation of existing maximum vesting policies for account-based plans and reiterated its policy of not recommending any legislative change to Congress. Other priorities have delayed the agency's plan to work with IRS on guidance to update the regulations under Code section 411, which concern vesting schedules, as currently in effect. But those updates, even if they should occur in the future, cannot modify permitted vesting schedules because, as Treasury notes in its comments, the vesting rules were determined by Congress. Given that more than 84 million people hold 401(k) plan accounts and that median current tenure in the private-sector is about four years, the potential for these policies to significantly impact Americans' retirement security remains. We will close this recommendation when Treasury evaluates the appropriateness of current maximum vesting policies to help determine whether they unduly reduce the retirement savings of workers, regardless of whether the agency opts to seek legislative action.

Recommendation: To help participants better understand eligibility and vesting policies, the Department of Labor (DOL) should develop guidance for plan sponsors that identifies best practices for communicating information about eligibility and vesting policies in a clear manner in summary plan descriptions. For example, DOL could discourage plans from including in documents information about employer contributions or other provisions that are not actually being used by the plan sponsor.

Agency: Department of Labor
Status: Open

Comments: As of June 2020, the Department of Labor (DOL) was considering delaying regulatory action to improve disclosures, to direct its regulatory resources elsewhere. The agency noted however, that it may reopen for further comment a Request for Information posted in 2019, which sought public input on actions that could make retirement plan disclosures more understandable and useful for participants and beneficiaries, among other things. Such actions may include revising standards for the summary plan description, which our report found can contain obsolete and confusing information concerning eligibility and vesting. We continue to encourage the agency to include eligibility and vesting among topics considered for clarification in its future regulatory work and, in the meantime, to consider using sub-regulatory guidance to help plan sponsors better communicate these critical policies.

Recommendation: Congress should consider whether ERISA's provisions related to the timing of employer matching contributions need to be adjusted to reflect today's mobile workforce and workplace plans, which are predominantly 401(k) plans offering matching employer contributions.

Agency: Congress
Status: Open

Comments: As of February 2020, Congress has not taken action on this matter.

Recommendation: Congress should consider whether ERISA's provisions related to last day policies need to be adjusted to reflect today's mobile workforce and workplace plans, which are predominantly 401(k) plans offering matching employer contributions.

Agency: Congress
Status: Open

Comments: As of March 2020, Congress did not take action on this matter.

Recommendation: To ensure the agency has sufficient information about risks to SSI program integrity when making decisions about efforts to address them, the Commissioner of the Social Security Administration should conduct a risk assessment of the current manual process for connecting and adjusting claim records of SSI recipients who live in households with other SSI recipients, and, as appropriate, take steps to make cost-effective improvements to SSA's claims management system to address identified risks.

Agency: Social Security Administration
Status: Open

Comments: In September 2020, SSA stated that it will include its current manual process for connecting and adjusting claims records for SSI recipients who live in households with other SSI recipients as a potential risk in the agency's upcoming Fraud Risk Assessment of the SSI program. According to SSA officials, the Fraud Risk Assessment will assess the current manual process based on its inherent risks, existing controls to reduce the risks, and the residual effects if the agency implements a process to connect SSI recipients' records. In addition, officials said they will determine a risk response as part of this assessment. SSA anticipates conducting the Fraud Risk Assessment of the SSI program by the end of calendar year 2020.

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: SSA continues to disagree with this recommendation as of December 2019. As we reported, when SSA accepts a beneficiary's return to work allegation (work report), staff have 30 days to determine whether additional action is needed, such as a continuing disability review (CDR) to assess continued eligibility and determine whether benefits should be adjusted. However, not all work reports result in a CDR, and GAO reported that SSA lacks an oversight process to help determine whether work reports are not resulting in CDRs when they should. SSA continues to maintain that its staff carefully review work reports and make independent determinations on the need for a CDR. Absent an oversight process to ensure that work reports are properly screened, SSA may be missing opportunities to prevent overpayments for unreported work. SSA further reported that it may decide to complete a CDR through alternative approaches, such as its Continuing Disability Review Enforcement Operation process using Internal Revenue Service data, its Quarterly Earnings Project using Office of Child Support Enforcement data, or its analysis of electronically reported wages. However, SSA did not indicate whether these alternative avenues for conducting CDRs could identify errors made by its staff handling work reports and result in feedback. Implementing this recommendation will help ensure that SSA staff appropriately take action on work reports.

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: As of December 2019, SSA reported taking several steps to clarify work reporting requirements. For instance, SSA reported it has developed outreach materials to share information with beneficiaries and advocacy groups. However, SSA has not provided sufficient documentation for GAO to determine if it has clarified issues identified in GAO's 2015 report, such as how and when to report work, and that beneficiaries may have to repay overpayments that occur even when they report work. Finally, SSA has not indicated whether it has assessed options for increasing the frequency of reporting reminders to DI beneficiaries. Until SSA can demonstrate that it has improved the clarity of its work reporting requirements and frequency of its work reporting reminders, DI beneficiaries may continue to incur overpayments, or be required to repay overpayments that occurred even though they reported work.