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Audit Report - A-06-96-62001

Office of Audit

The Adequacy of the Residency Verification Process for the Supplemental Security Income Program - A-06-96-62001 - 5/29/97

This final report provides you with the results of our review of the residency verification process for the Supplemental Security Income (SSI) program (A-06-96-62001). The objective was to determine if: (1) listings of addresses with multiple recipients could be useful to field offices (FO) in identifying nonresident recipients, (2) home visits are effective for verifying residency, and (3) program operations instructions provide adequate guidance to FOs for verifying that recipients are United States (U.S.) residents.

Although address listings can be useful to FOs in identifying SSI recipients whose residency is questionable, such information is not readily accessible to FOs because of system limitations. The FOs cannot query recipient addresses through their computerized system, and recipient address listings that the Social Security Administration (SSA) has developed contain unstructured address information. SSA should consider establishing a process that FOs can use to identify SSI recipients based on either names or addresses.

The results of the home visit residency verifications conducted by the Chula Vista FO in California demonstrate that home visit verifications are effective in verifying U.S. residence for SSI recipients. From a targeted population of 233 recipients, 47.2 percent did not live at the residence of record. The FO identified 63 recipients who were overpaid $385,443 because SSA was unaware that they were not U.S. residents and were, therefore, ineligible for SSI benefits. SSA should increase resources for conducting home visits by using private contractors or making staff available.

Program operations instructions do not require adequate development in cases where a question persists as to the individual`s eligibility due to residency. Current procedures allow SSA to make SSI benefit awards to individuals based on testimonial information without obtaining documentary evidence to support their U.S. residency. The instructions can be improved by providing for additional actions such as home visit residency verifications for

SSI cases that FO staff believe need further development. Additional resources are needed to implement such actions.

SSA agreed with our recommendations. The full text of the Agency comments is in Appendix B of the report.

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The Social Security Act (Act) (Section 1614(a)(1)(B)(i)) requires that an individual must be a resident of the U.S. to be eligible for SSI payments. The Act also stipulates that no individual will be eligible for SSI payments for any month during all of which the individual is outside of the U.S. (section 1611(f)). Further, after an individual has been outside the U.S. for a period of 30 consecutive days, that person shall be treated as remaining outside of the U.S. until he or she has returned and been in the U.S. for a period of 30 consecutive days (Section 1611(f)). Except for section 1611(f), the Act is silent regarding minimum requirements for length of residency in the U.S.

SSA has taken some action to address the need to verify U.S. residency for SSI recipients who live near the U.S.-Mexico border. Significant actions taken by SSA include: (1) contracting with a private vendor to conduct a pilot of home visit residency verifications for selected cases, (2) holding a combined Dallas and San Francisco FO conference to address problems that border FOs encounter in verifying residency of SSI recipients, (3) revising procedures to strengthen the residency development process used by FOs, and (4) working with the Office of the Inspector General on the Southwest Tactical Operations Plan to determine the nature and extent of residency issues in El Paso, Texas.

The contract to perform home visit residency verifications was a pilot project for the Chula Vista, California FO. The original contract covered the period February 27, 1996 through August 26, 1996. SSA has extended the contract period to a full year and is in the process of extending the contract for an additional period. The Chula Vista FO selected the recipients for home visit residency verifications based on various sources, including: (1) Office of the Inspector General generated address listings containing multiple recipients at the same address, (2) FO staff referrals of suspicious SSI cases identified during the initial application or redetermination process, and (3) State agency or third party referrals of other suspicious cases.


Our review was conducted in accordance with generally accepted government auditing standards. The objective was to assess the potential effectiveness of address listings and home visits, as well as the adequacy of current procedures used by FOs for verifying the residency status of SSI recipients living near the U.S.-Mexico border.

Our review consisted primarily of monitoring progress reports from the Chula Vista FO and its contractor regarding the results of home visit residency verifications and reviewing SSA`s program operations procedures concerning the development of residency determinations. We also visited the Chula Vista FO and attended the SSA border conference in San Diego, California. A test of the Chula Vista FO’s compliance with program operations procedures for residency development was not required to satisfy the objectives of this review. Our review was conducted primarily at our office in Dallas, Texas. Field work was conducted from April 1996 through November 1996.

To assist the Chula Vista FO in identifying potential suspect cases, we provided a listing of 41 addresses which listed 3 or more SSI recipients at each address; this list included a total of 133 recipients. We developed the listing from computerized data that SSA provided during prior audit work. The FO referred 31 of the 133 recipients to the contractor for home visit residency verifications. Based on the results of the contractor’s home visit residency verifications and/or FO development, Chula Vista FO staff determined the recipients’ eligibility and calculated overpayments for ineligible recipients. We did not verify the information provided by SSA.

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Address listings can be useful to FOs in identifying questionable residence addresses for SSI recipients. In September 1995, we provided the Chula Vista FO with a list of 41 addresses in which 3 or more SSI recipients claimed residency at the same address. The FO included 31 of the 133 recipients from this list in its pilot project involving contracted home visit residency verifications. Of the 31 recipients, the contractor found that 18 (58.1 percent) did not live at the residence of record, including 7 who lived outside the U.S. Accordingly, the FO suspended payments to 11 recipients and placed the 7 recipients who lived outside the U.S. in nonpay status. Of the remaining 13 recipients, the contractor verified that 9 were living in the U.S. and 4 were unverified and scheduled for revisits.

Although address listings could be useful to FOs, such listings can only be obtained through special requests from SSA systems staff in Baltimore, Maryland. The border FOs did not have routine access to computerized address listings for verifying residency.

Supplemental Security Record Address Information

In obtaining an extracted computer file of SSI records, we noted that the address field in the Supplemental Security Record (SSR) was not standardized. Without defined data segments within the address field, the information was inconsistent in its location from record to record. For some records, the data information began with the payee`s name, while for others the information started with either the street address or with an establishment’s name. As a result, the addresses could not be readily compared or analyzed without the use of special processing techniques and manual screening.

For example, the following addresses for four different individuals (names excluded) appear to be the same, although they have two different zip codes. Note that the street name, 4th Avenue, was inconsistently recorded. Also, the name of the establishment was not included in the second listing, and the city and State appear in different locations in the record depending on the length of the preceding information. This layout prevents a particular address element, such as the street name, to be used to identify all SSI recipients claiming the same residence address.

The information is illustrated as it appeared in the SSR records.


171 4 AVE CHULA VISTA, CA 92010



An address search capability would be useful to border FOs as a means of cross-checking recipient addresses. With such a feature, claims representatives (CR) could determine if recipients were claiming the same residence address, or using questionable addresses such as that of a business or other establishment. However, to allow such cross-checking may require SSA to develop separate fields for each of the data elements presently contained in the single address field.


Based on the private contractor`s home visit residency verifications, the Chula Vista FO determined that 110 of the 233 suspect cases (47.2 percent) did not live at the residence recorded on the SSR. A total of 57 recipients did not live in the U.S. and were ineligible for continued payments. The FO suspended payments for an additional 53 individuals who could not be located, pending further residency development.

The results of the home visit residency verifications are summarized in the table below.

 Results of Contractor Home Visits to Selected SSI Recipients/Applicants

Number of Recipients

Percent of Total

Recipients did not live at address of record --lived outside the U.S.; payment stopped or denied.



Recipients did not live at address of record but actual address unknown; payment suspended pending further development.



Payments stopped or denied for reasons other than residency.



Recipients not at home and scheduled for follow-up visits.



Recipients verified as living at residence of record.



Total Number of Recipients Contacted



As of July 3, 1996, the Chula Vista FO had calculated overpayments to 63 SSI recipients totaling $385,443 due to nonresidency. These overpayments included 53 cases that the FO referred to the private contractor and 10 cases that the FO independently developed.

The improper overpayments were the result of recipients either providing inaccurate information to SSA when they initially applied for SSI or failing to report a move outside of the U.S. while receiving SSI benefits. These results indicate that stronger control procedures, such as the home visit residency verifications, are needed to determine the residency of recipients with questionable addresses.


The Program Operations Manual System (POMS) instructions do not discuss the use of home visits to verify addresses for suspect SSI cases. In general, the instructions specify that residency development is required when doubt exists concerning whether an individual lives in the U.S. (section GN 00303.740). The required development, however, consists of obtaining evidence categorized as convincing or secondary, including statements from disinterested third parties. Convincing evidence includes documentation such as property tax records, utility bills addressed to the claimant, U.S. driver’s license, record of volunteer activity or correspondence addressed to the claimant. Secondary evidence consists of satisfactory answers to open ended questions and statements from two reliable disinterested individuals who have first-hand knowledge of the claimant’s U.S. residence. There are no provisions for conducting home visit residency verifications, although some FOs may conduct them if they have staff available.

SSA revised the POMS instructions in May 1995 to enhance requirements for developing U.S. residency and documenting the development process. The revisions expanded the number of circumstances which raised doubt as to an individual`s U.S. residency and added a blanket statement that questionable situations were not limited to those specifically listed (see Appendix A for highlighted revisions). The revisions added requirements that CRs document the results of their residency determinations in cases where convincing evidence could not be provided. Another revision was that statements from individuals attesting to the claimant’s residency must be from individuals who were reliable disinterested individuals who had first hand knowledge of the claimant’s U.S. residence.

The revised instructions do not address situations where CRs, after developing evidence to the extent required, still have doubts about an individual`s residence. The instructions do not address cases where an individual, who previously failed to report a change in residency and was terminated for living outside of the U.S., reapplies for benefits. Such cases should require more verification of residency than initial claims because the individuals were terminated for nonresidency and are reporting a new address which will make them eligible once again for SSI benefits.

At some border FOs, CRs request home visit residency verifications if further development is needed. However, this option is not required by POMS and staff may not be available at all border offices to conduct home visits. Without an incentive or the resources to do home visit residency verifications, FOs may choose not to pursue development beyond that which is required. If the residency of SSI recipients is not adequately developed, SSA risks making payments to ineligible nonresidents.

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We recommend that SSA:

1. Implement a process that FOs can use to search for addresses of its SSI recipient population. The process could involve developing a capability for FOs to search SSA`s computer records directly or provide standard address listings that can be used on personal computers.

2. Continue the practice of conducting home visits by using private contractors or making staff available.

3. Revise POMS instructions to provide for expanded residency development to verify questionable addresses of SSI claimants and recipients (e.g., conducting home visits or researching third party information).


SSA agreed with our recommendations.


David C. Williams

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Comparison of POMS Requirements Before and After the May 1995 Revisions

POMS before May 1995

POMS Revisions Effective May 1995

A. Operating Policy - General

Determine U.S. residency if there is an indication that the individual is not residing in the U.S. Determine residency in the following situations:

- The situation raises doubt as to U.S. residency; e.g., the address is a rooming house that caters to a transient population or a post office box or general delivery address in a city or town near Mexico or Canada.

- The address is in care of another person; or

- The claimant presents a grommeted I-151 ; or

- The claimant presents a commuter I-551 (type 2).

3. Kinds of Doubtful Residency Situations

Question circumstances which raise doubt as to U.S. residency, including but not limited to situations such as:

a. The address is a rooming house that caters to a transient population or a post office box or general delivery address in a city or town near Mexico or Canada; or

b. The claimant presents a grommeted I-551 or a commuter I-551 (both documents indicate the bearer commutes to the U.S. to work); or

c. The address is in care of another person (refer to GN 00303.740C.5. for development when the in care of address is in a FO service area which borders Canada or Mexico); or d.The address is near Mexico or Canada and the claimant is filing out of service area.

e. The claimant declares that his/her spouse lives in another country.

f. The claimant explains that he/she lives with a "friend", but his/her family is in another country.

B. Operating Procedure


If there is an indication that the individual is outside the U.S., question him/her concerning residency.


If there is any doubt that the individual resides in the U.S., question him/her concerning residency; develop evidence to establish where the claimant lives; and prepare a special determination or report of contact to document your residency determination. Use the evidence in 1. Or 2. below to develop residency.


If the claimant does not have any of the types of evidence listed above (a. through I.), affirmative answers to the questions below, along with the statements of at least two reliable individuals who can state where the claimant lives and the basis for their knowledge, in conjunction with the SSA interviewer`s observations, will generally establish U.S. residency. (Examples not cited.)

2. Secondary Evidence

b. Statements from two reliable disinterested individuals who have first-hand knowledge of the claimant`s U.S. residence. (Examples cited including but not limited to: employer, official of religious organization, landlord or neighbor.)

Note: Underlining added to highlight significant changes.




Office of the Inspector General

Bill Fernandez, Director, Program Audits
Brian Pattison, Deputy Director
Paul Davila, Senior Auditor

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