RESULTS
OF REVIEW
MULTIPLE RECIPIENT ADDRESS LISTINGS
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.
Ø CHULA VISTA INN, 171 FOURTH AVE, CHULA VISTA, CA
92010
Ø 171 4 AVE CHULA VISTA, CA 92010
Ø CHULA VISTA INN, 171 4TH AVE, CHULA VISTA, CA 91910
Ø CHULA VISTA INN 171 FOURTH AVE CHULA VISTA, CA
91910
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.
EFFECTIVENESS OF HOME VISIT RESIDENCE VERIFICATIONS
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.
|
57 |
24.5 |
Recipients did not live at address of record
but actual address unknown; payment suspended pending
further development.
|
53 |
22.7 |
Payments stopped or denied for reasons
other than residency.
|
13 |
5.6 |
Recipients not at home and scheduled for
follow-up visits.
|
32 |
13.7 |
Recipients verified as living at residence
of record.
|
78 |
33.5 |
|
Total Number of Recipients Contacted |
233 |
100.0 |
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.
ADEQUACY OF PROGRAM OPERATIONS PROCEDURES FOR RESIDENCY
DEVELOPMENT
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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