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Audit Report - A-03-96-31001


Office of Audit

Activity Related to the Suspense File - A-03-96-31001 and A-03-96-31002 - 9/15/97

This management advisory report presents the results of work performed to date by the Office of the Inspector General (OIG) on Suspense File related activities and the efforts of the Deputy Commissioner for Operations to reduce the size of the Suspense File. It also provides OIG’s observations on the value of certain procedures available for use in reinstating suspended wage items and allegations made about the earnings system.

The OIG informed the Social Security Administration (SSA) that it would conduct two reviews concerning Suspense File activities. These reviews were entitled "Use of Internal Data to Post Wage Items from the Suspense File" (A-03-96-31001) and "Review of Computerized Methods for Identifying Postable Suspense Items" (A-03-96-31002). During the testing phase of these reviews, SSA informed us it was conducting pilot studies on ways to reduce the Suspense File. SSA’s studies evolved from a task force project sponsored by the Deputy Commissioner for Operations. Our reviews are being deferred pending completion of SSA’s studies. We will review the results of SSA’s pilot studies and progress toward implementing the results of those studies later this month. From our preliminary work, however, we have made some observations which you may wish to consider.

We determined that procedures utilized by the San Bernardino District Office (SBDO) have value in reinstating suspended wage items and that the pilot studies should experiment with SBDO procedures. However, SSA pilot studies indicate that the operation could provide a better internal control and quality assurance environment if conducted and controlled in a single location.

Further, in conducting our preliminary work, we considered the allegations that SSA failed to reinstate suspended wage items when ownership of the earnings was apparent from its own records and that many workers were disadvantaged, especially women and minorities. This is because name and Social Security number (SSN) matches are required for wages to be posted to an individual’s Master Earnings File (MEF). We found that SSA does not routinely cross match wage items against other information files, other than the Numident file and a file of previously reinstated wages, to identify ownership prior to discontinuing the reviews. We do not believe, however, that the system discriminates against women and minorities. The Numident validation system includes several processes which increase the likelihood that wages for women and individuals with compound surnames will be posted. Our review of the earnings system also found that it has special validation rules for both women and wage earners with compound surnames which increase the chances that their wages will be posted.

BACKGROUND

Employers and self-employed individuals are required to submit wage and self-employed data to SSA on an annual basis. This information includes the amount of wages paid or self-employment income earned and the amount of taxes withheld on wages and self-employment income; the names and SSNs of wage earners; and the employers’ identification numbers. All wage items and self-employed data are subject to SSA’s overnight validation procedures. The purpose of the procedures is to identify ownership of wage items using a 3-step process to allow posting to an individual’s MEF record. The MEF contains a detailed record of an individual’s earnings (Detailed Earnings Record) and also a summary record of earnings for each individual for each year worked (Summary Earnings Record). Through Calendar Year  (CY) 1995, there were 375.2 million MEF records containing wages of $42.6 trillion.

The first step of validation compares the SSN and name to the Numident file. The Numident file is SSA’s primary identification record and contains information such as the first and last name of the number holder, SSN, and other identifying data. Each name can be processed against as many as 16 validation rules. The first rule requires that the first seven positions of the last name contained in the Numident file be identical to the first seven positions of the last name contained on the wage report submitted by an employer; about 90 percent of the data pass this rule. If the name does not pass the first rule, the data is then processed against up to 15 other rules which manipulate the name in an attempt to reach a match. Good matches are posted and nonmatches are passed to the second validation step. In the second validation step, the SSN and name are run against prior year files that were reinstated to determine if the same combination was previously reported and reinstated. In the third step, the SSN is assumed to be wrong and is run against a program which rearranges the SSN in 89 different combinations seeking a match.

SSA’s Suspense File is the alternate repository for annual and quarterly wage items which are processed through SSA’s earnings system but fail to match SSA name and SSN records. SSA places mismatched wages in an electronic Suspense File. The electronic Suspense File offers orderly accounting, methodical and systematic reference abilities, and a means to apply both electronic and manual efforts toward movement of wage items from the Suspense File to the MEF. The Suspense File contains over 203 million wage items and represents over $217 billion in covered wages accumulated from the inception of the program through February 1997.

Wage items that remain in the Suspense File are not available for use in computing an individual’s benefit amount, unless a number holder questions or disputes earnings when applying for benefits. Thus, reinstatement of wages contained in the Suspense File is essential. After other clerical, electronic, and correspondence attempts to reinstate Suspense File wage items fail, they are reviewed in Operation 30. At the Wilkes-Barre Data Operations Center (WBDOC), key operators compare Suspense File items with corresponding Numident records which are system-generated on a computer screen. The system generates up to five name options for use in the comparisons. A match identifies the wage item for posting.

Since March 1996, there has been much attention paid to the subject of SSA’s earnings Suspense File by the Congress, SSA management, and OIG. The genesis for the interest was a number of allegations made by the Manager of SBDO that SSA had been remiss in correcting workers’ earnings records. In response, the Deputy Commissioner for Operations formed a task force in March 1996 to develop recommendations aimed at both preventing wage and self-employment items from entering the Suspense File and reducing the number already in suspense. Also, in July 1996, OIG initiated two reviews related to the Suspense File. Our objectives were to evaluate the procedures used by SBDO in posting open suspense items to the MEF using internal records and to evaluate the effectiveness of SSA’s computerized methods for identifying postable wage items with incorrect names and/or SSNs.

Specifically, the SBDO Manager alleged that: SSA failed to reinstate earnings from the Suspense File when ownership of the earnings was apparent from its own records; and the failure to reinstate earnings due to the requirement of matching name and SSN was especially disadvantageous to women and minorities. Women often marry without notifying SSA of their name changes and employers often mishandle ethnic surnames of minority groups. SBDO based these allegations on its study of the Suspense File and experience in performing 117,000 wage corrections over a 15-month period. The allegations surfaced in March 1996, and in April 1996 were widely circulated in the form of a white paper prepared by SBDO.

SBDO had, for some time, been conducting a self-initiated pilot test it called the "earnings repair study." Instead of waiting for number holders to come into the office inquiring about their earnings, SBDO researched the Suspense File looking for employers with a high number of open wage items that SBDO determined had high potential for matches and subsequent postings of earnings. The research efforts were not always successful. When a candidate was found, SBDO would then utilize various SSA records to match enough data related to suspended wage items to make a reasonable inference about the identity of the wage earners. When satisfied that an identity had been determined, SBDO then posted the suspended wages to the account holder’s earnings record. The SBDO Manager had actively recommended that the procedure utilized in the study be adopted by Headquarters as a nationwide methodology for correcting workers’ earnings records. The SBDO procedures for correcting earnings records were not in accordance with SSA’s current policy, which requires reviewing the earnings record with the number holder or his/her survivor to be sure that the earnings posted are accurate and consistent with the individual’s work history. This policy applies to pre-claims, claims, and post adjudicative claims situations.

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METHODOLOGY

Our initial proposal was to conduct two reviews. Both reviews were to utilize data extracts from SSA’s files to assist us in our determination of whether wages contained in the Suspense File could be posted to the MEF. The objective of the first review was to examine the effectiveness and accuracy of procedures utilized by SBDO and determine the proper point in the process for implementing SBDO validation procedures. This review was to test the accuracy of a sample of the corrections made by SBDO. The objective of the second review was to identify additional profiles for incorporation into the validation rules. This review was to analyze an extract of the Suspense File to identify additional, acceptable profiles for use as validation rules.

The testing phase for both reviews was not accomplished. However, while waiting for SSA to extract the requested data, we asked SBDO to perform a study for our review and understanding. The employer chosen for the review was selected from a pre-screened list of employers that SBDO had determined had a large number of open wage items with a high potential for matches in its Suspense File. This employer’s 1980 Suspense File contained 131 wage items which were not posted because of incorrect names or SSNs. The amount of the suspended wages was $1.8 million. We reviewed the 131 wage items.

RESULTS OF REVIEW ACTIVITY

About the time the testing for our audits was to begin, we were briefed by the Director of Earnings and Adjustments of the Office of Central Records Operations (OCRO) on the intended directions of the pilot studies. We believed the objectives of these studies would produce similar results as those planned in our audit. As a result, we deferred our review to allow SSA the opportunity to implement its pilot studies. We will review the results and progress in implementing the pilot studies later this month. Sufficient work has been done, however, to provide some insight into SBDO procedures and assertions and the accuracy of the SBDO Manager’s allegations.

Task Force Results

In September 1996, the Office of Operations’ sponsored task force report recommended action in eight aspects of Suspense File management which should aid in reducing the size of the Suspense File and materially reduce the number of wage items going into suspense. The recommended actions utilized a variety of approaches to the problem and would:

  • complete already established, scheduled Suspense File reduction functions (such as Operation 30) on a tighter, more regular time schedule and investigate and pilot other Suspense File reduction methods and business changes;
  • improve systems software to make the Suspense File easier to reference and assist searchers with their efforts to find items in suspense;
  • lower the rate of error acceptability in the magnetic media annual wage reporting process (currently, if 70 percent of the items on a wage report are in error, the system accepts the report for processing) and offer specific examples of the most common causes of suspense in the instructions provided to employers;
  • conduct outreach efforts with "problem" industries (in 1990, three industries accounted for 46.5 percent of all suspense items; agriculture, services, and bars/restaurants) and States (over a 6-year period, nine States account for 70 percent of all suspense items; California alone accounts for 35 percent);
  • institute a graduated approach of informing employers of suspense problems, offering help, and where not successful, work with the Internal Revenue Service to facilitate invoking penalties for repeat offenders;
  • support verification of name/SSN information with employers, aggressively, systematically, and through modern methods and techniques;
  • measure the acceptability of changing suspense software to include mother’s maiden name as part of validation, eliminating sex code as a validation consideration, and programming given name derivatives as an expansion of current matching criteria; and
  • develop, staff, and conduct a proactive, continuing SSA designed suspense evaluation program.

SSA Pilot Studies

Two pilot studies deal with expanding Operation 30 procedures and the SSN/name validation procedures. The first pilot study involving Operation 30 is to consist of experimentation with additional procedures in an attempt to post wages which failed to validate. The study initially will use suspended wage items for Tax Year 1980. Operation 30, as now designed, is performed periodically by WBDOC staff. It utilizes system-generated Numident records (up to five when wage earner has multiple surnames) for suspended wage items. If the name for a suspended wage item agrees with a name option, the name is corrected to the matched name and posted to MEF. When there is no agreement, the wage item remains in the Suspense File. The pilot study will create a third category of action in addition to "corrected" and "not corrected." The third category will apply to wage items where some doubt exists about whether there is a match. These items would not be acted on at the time, but set aside for further review by skilled technicians in OCRO.

As described to us by Office of Operations’ personnel, some of the additional procedures will be similar to those used by SBDO and will utilize SSA records other than the Numident file to identify ownership of suspended wage items. If the efficacy of these test procedures is proven, we would endorse their placement in a central location rather than in SSA’s 1,300 field offices. Placement in a single location with qualified technicians offers a more desirable internal control and quality assurance environment.

The objective of the second pilot study, involving the SSN/name validation process, is to identify additional profiles for incorporation into the Numident validation rules. This pilot study includes testing of expanded criteria for the Numident validation rules, which could prevent more wage items from going into suspense. Presently, the Numident validation rules require a matching relationship with the surname, the exception being when the wage earner is identified as a female. Then the rules will allow wages to be posted to the MEF based on a match of the first name and the middle initial only. The pilot study would consider applying the more liberal female rules to males. Other tests would expand the matching criteria to include given name derivatives, and incorporating the mother’s and father’s surname.

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OIG Observations

As part of our review, we intended to test the accuracy of the postings performed by SBDO during its "earnings repair study" and to evaluate the merits of SBDO’s allegations. We developed some preliminary observations in these two areas prior to discontinuing the audits.

Our observations on the accuracy of SBDO postings are based on a review of a demonstration performed by SBDO at our request. Initially, we intended to obtain a data extract to review a random sample of the approximately 117,000 wage items that SBDO posted to MEF records during its "earnings repair study." The purpose of the demonstration was to provide an understanding of the procedures pending receipt of an extract of SBDO posted items. However, we did not perform a random review because our audit was suspended. Although the results of the demonstration cannot be projected, we believe they provide insight into the value of SBDO procedures.

SBDO selected an employer previously identified through its research efforts from the Suspense File for CY 1980. This employer had 131 open wage items which were not posted because of incorrect names or SSNs. The amount of the suspended wages was $1.8 million. SBDO determined that this particular suspense list had the potential for a high percentage of matches and subsequent postings. The list showed many unreadable surnames that contained ampersands and double letters in combination, e.g., 0@GG0. Many showed high wages in the $20,000 range. To perform its matches, SBDO relied on first name and middle initial matches to SSA files other than the Numident, such as the Detailed Earnings Query Report (DEQR), the Summary Earnings Query Report, and the Master Beneficiary Record (MBR). When matches were established that identified the owner of the wages, SBDO posted the wages to MEF records.

SBDO concluded that 105, or 80 percent, of the 131 wage items in the demonstration had sufficient matching data to other SSA files to warrant posting. The 105 postings for this employer reduced the Suspense File by $1.62 million. The average wage posted was $15,470.

We reviewed SBDO’s determinations in the 131 demonstration items for accuracy. Our verification procedures were similar to SBDO’s procedures. We considered matches as valid only when a clear and obvious relationship existed between the reported first name and middle initial and the data on SSA’s Numident files and DEQR files. For example, the Numident first name and middle initial matched with Suspense File data. After the Numident match was established, we reviewed DEQR for additional evidence of identity.

Our results differed from SBDO’s. Of the 131 wage items, we believe that 107, or 81.7 percent, contained sufficient matching data to Numident and DEQR files to warrant posting to MEF records. We differed with SBDO’s determination on 16 cases (see Appendix A for the details of the 16 cases.) Neither our review nor SBDO’s review could find any relationship for 24 items (including 10 items that did not have SSNs). Based on our results, we believe there is merit to SBDO’s procedures and that these procedures should be incorporated into SSA’s pilot studies.

SBDO provided us with its comments on the 16 cases. Of the seven SBDO matches that we determined to be nonmatches, SBDO agreed with our determination for three accounts and stated that the three earnings records have been corrected and no incorrect benefits have been paid on these accounts. On the other four accounts with which we disagreed, SBDO believes the matches are correct because the open wages formed an exact match to the individuals’ earnings pattern. We noted that one of the four wage earners was just 11 years old in our review year of 1980, based on date of birth data in the Numident file.

Of the nine SBDO "no matches" that we determined to be matches, SBDO agreed that all nine should have been posted as matches. SBDO stated that five accounts were posted at the time the pilot demonstration was performed for us and one account was posted prior to the demonstration. For the remaining three errors, SBDO had made the proper determination, but posted the wages to the wrong account. However, the Suspense File used in our review, dated several months after the SBDO demonstration, showed these six accounts as open items. The SBDO Manager has stated that he is in the process of performing a follow-up review and correction of the nine accounts.

We noted that in five of the cases, SBDO made the proper determination to post wages from the Suspense File to the individual’s earnings record; however, the wages were posted to the wrong account. Three of these errors were also included in SBDO’s nine "no matches" discussed above. The errors caused an overstatement of earnings for five individuals and an understatement of earnings for five other individuals. These clerical errors were brought to the attention of the SBDO Manager who concurred with our observations and initiated the process of correcting the earnings records.

For the seven OIG "no matches," SBDO has corrected the three accounts with which we are in agreement and has not corrected the four with which we disagree. For those nine OIG matches and the accounts involving clerical errors, only three of the records have been corrected to date. We were informed that the remainder are in the process of being corrected.

The SBDO white paper alleged deplorable conditions of neglect in the correction of suspended wage items for women and minorities. It strongly implied that the system discriminated against them. We do not believe, however, that the system discriminates against women and minorities. The earnings system has special validation rules for both women and minorities which increase the chances of posting wage items for females with surname changes and minorities with compound names.

With respect to women, the Numident validation rules include three rules specific to females. These rules are more liberal than the other rules in that matches are based on first names and middle initials only, thereby, allowing SSA to post wages for those women who fail to report their married name changes. In contrast, the other rules require some matching relationship with the last name.

As for minorities, the Numident validation rules include several that specifically address compound surnames that are common to certain cultures and minority groups, e.g., Hispanics, Orientals, Asians, and Arabs. The rules allow posting of wage items where parts of the reported surname match the Numident. For example, when a reported compound surname contains a hyphen or a blank, the Numident validation rules will allow a match if either the first part or the second part of the compound surname equals the Numident surname.

CONCLUSIONS

The task force report recommended actions which should reduce the size of the Suspense File and the number of wage items going into suspense. Two of the pilot studies emanating from the task force efforts have near identical objectives to the OIG reviews. Therefore, we deferred our reviews pending completion of the SSA pilot studies. We will review SSA’s progress in implementing actions being studied under the pilots at that time. Our preliminary work, however, indicates that the procedures used by SBDO in posting suspended wage items have value in identifying ownership of suspended wage items. From our perspective, the actions recommended by the task force should be implemented. The pilot tests now underway with Operation 30 and the validation procedures are especially appealing and should be completed. The pilot test should experiment with the procedures used by SBDO, i.e., establishing ownership of suspended wage items by matching them with identifying data and employment history contained on internal SSA records other than the Numident.

- David C. Williams

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APPENDIX A

SUMMARY
SBDO CASES

  SBDO OIG OIG  
TOTAL WAGE ITEMS

131

--

--

131
NO SSN

(10)

--

--

(10)
REVIEWED

121

--

--

121
POSTABLE TO MEF

105

- 7 a +9 b,c 107
NOT POSTABLE TO MEF

16

+7 a - 9 b,c 14
TOTAL WAGE ITEMS

121

    121

The evidence, such as names and/or initials, provided in the Suspense File for these seven wage items, in our opinion, is insufficient to warrant a match with the account number’s Numident file and Detailed Earnings Query Report.

a) For these nine wage items, we believe the evidence provided in the Suspense File, such as names and/or initials and an earnings history with this particular employer, is sufficient to warrant a match. In many cases, the work history included the years prior to and after the year of suspense.

b) SBDO made the right determination for 5 wage items but posted them to the wrong accounts, resulting in errors affecting 10 earnings records. Three of these erroneous accounts are also included in b) above. 

SUMMARY OF SBDO CASES REVIEWED

 

(a) Seven SBDO Postable to MEF/OIG Not Postable to MEF:

OIG CASE NO. COMMENT

#38 Suspense File showed two initials only. Only middle initial matched.

#42 Suspense File provided only a first name initial. No work history with this employer.

#49 Suspense File showed only a first name initial.

#80 Suspense File name did not show any relationship to Numident name. No work history.

#90 Due to age of wage earner, 11 years old, we believe this case should be classified as a no match pending further review.

#117 Suspense File provided only a first name initial.

#119 No name association with Numident and no work history with this employer.

(b) Nine SBDO Not Postable to MEF/OIG Postable to MEF:

OIG CASE NO. COMMENT

#55 First name: four of seven letters match; prior and post work history with this employer.

#58 First name: five of seven letters match; middle initial match; prior work history with this employer.

#63 First name initial and middle initial match; prior and post work history with this employer.

#74 First name: five of seven letters match; middle initial match; prior and post work history with this employer.

#95 First name and middle initial match. Prior and post work history with this employer.

#101 First name: five of seven letters match; middle initial match; prior work history with this employer.

#105 First name: four of five letters match; middle initial matches last name initial; prior work history with this employer.

#106 First name: five of six letters match; middle initial match; prior work history with this employer.

#110 First name initial and middle initial match; prior and post work history with this employer.

APPENDIX B

Office of the Inspector General

Roger Normand, Director, Program Audits (North)
Emil Mallek, Team Leader
Louis Faiola, Senior Auditor
Frank Cassidy, Auditor
Frank Trzaska, Auditor

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