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Audit Report - A-09-96-64208


Office of Audit

Monitoring Representative Payee Performance: Non-Responding Payees - A-09-96-64208 - 12/16/96

TABLE OF CONTENTS

EXECUTIVE SUMMARY

INTRODUCTION

FINDINGS

SSA Does Not Receive An Accounting For Approximately $1.2 Billion In Annual Benefits

SSA Does Not Maintain Systematic Information About Nonresponding Payees

Nonresponding Payees Are Usually Relatives With Custody

Agencies And Institutions Are The Most Common High-Volume Nonresponding Payees

RECOMMENDATIONS

APPENDICES

A - Locations And Characteristics Of Nonresponding Payees

D - Major Contributors To This Report

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EXECUTIVE SUMMARY 

PURPOSE

This report identifies how many representative payees did not respond to requests for an annual accounting of benefits for the report period October 1993 through September 1994.

BACKGROUND

The Social Security Administration (SSA) administers two programs under The Social Security Act--title II (Retirement, Survivors, and Disability Insurance (RSDI)) and title XVI (Supplemental Security Income (SSI)). These programs provide monthly benefits to approximately 49.2 million beneficiaries. For the 6.6 million beneficiaries who cannot manage their own finances, Congress has authorized SSA to pay the benefits to other individuals or organizations. The SSA calls them representative payees or payees.

A major payee responsibility is to submit an annual report to SSA accounting for benefits received, used, and conserved. If payees have not returned forms within 6 months of mailing, SSA generates a list of nonresponding payees for further contact by staff. Staff attempt to contact payees until an accounting is completed.

The SSA has undertaken initiatives to strengthen the entire annual accounting process. To assist in this effort, SSA requested that the Office of the Inspector General conduct a series of inspections to review and recommend improvements to the annual accounting process. This report is one in the series of reports that assess the risk of misuse of benefits associated with various categories of payees. Other reports will present data concerning demographics of payees, misuse or questionable use of benefits by payees, poor performance by payees, effectiveness and efficiency of the payee accounting review process, and problems with completion of the accounting forms. A roll-up report will provide overall recommendations for improving the accounting process.

In September 1994, SSA prepared a computerized file of titles II and XVI beneficiaries with payees who received benefits for the report period October 1993 through September 1994. In October 1995, we obtained a copy of the file to determine how many nonresponding payees (payees who did not respond to SSA's attempts at contact) remained after 1 year. We analyzed this information to identify the amount of benefits controlled by and any possible trends among these nonresponding payees.

FINDINGS

SSA Does Not Receive an Accounting for Approximately $1.2 Billion in Annual Benefits

We found that SSA had not received approximately 316,000 accounting forms from 248,000 payees between October 1994 and October 1995. These payees receive approximately $1.2 billion in benefits on behalf of beneficiaries. Annual benefits for nonresponding payees averaged $3,934, with almost 74 percent managing between $1,200 and $7,200 during the report period. Although SSA policy is to continue efforts to obtain an accounting until it is secured, the low priority typically assigned to this workload makes it unlikely that these cases are aggressively pursued.

SSA Does Not Maintain Systematic Information About Nonresponding Payees

The SSA's present computerized file does not retain any history of payees' return of accounting forms. Payees who fail to respond to the accounting process are not systematically tracked after 1 year has elapsed. The SSA overwrites the computerized file of nonresponding payees when it mails accounting forms for the following year.

Nonresponding Payees are Usually Relatives With Custody

Approximately 76 percent of nonresponding payees are parents and other relatives with custody of the beneficiaries. We found that the greatest number of nonresponding payees live in States with large general populations (California, New York, Texas, and Florida), while Puerto Rico, with a relatively small general population, also has a large number of unreturned accounting forms.

Agencies and Institutions are the Most Common High-Volume Nonresponding Payees

We found 12 instances in which agency or institutional payees did not return 10 or more accounting forms. The number of unreturned forms for each payee ranged from 10 to 56, with an average of 18.2 forms. Approximately 74 percent of all nonresponding agency or institutional payees have custody of beneficiaries.

RECOMMENDATIONS

The SSA should:

1. Determine why selected payees (e.g., high-volume agency or institutional payees and payees in Puerto Rico) fail to complete accountings.

2. Determine whether field office or processing center staff are properly processing the nonresponder alerts.

3. Develop a more immediate and appropriate method (e.g., suspension of benefits, immediate change of payee with final accounting by former payee) to be used in conjunction with the tracking system to obtain accountings. Additionally, SSA should annotate the Master Representative Payee File to indicate that the payee failed to respond to a request for accounting and should not be considered as a representative payee for other beneficiaries.

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INTRODUCTION

PURPOSE

This report identifies how many representative payees did not respond to requests for an annual accounting of benefits for the report period October 1993 through September 1994.

BACKGROUND

Overview of the Representative Payee Program and the Jordan Court

The SSA administers two programs under The Social Security Act--title II (RSDI) and title XVI (SSI). These two programs provide monthly benefit payments of about $25 billion to approximately 49.2 million beneficiaries and recipients who are aged, disabled, or survivors.[Workpapers 4S-33]

The SSA collects and maintains data on all beneficiaries in two computerized data bases--title II data are maintained in the Master Beneficiary Record (MBR), and title XVI data are maintained in the Supplemental Security Record (SSR). The data bases contain descriptive information about the beneficiary, such as date of birth and amount of benefits.

Approximately 6.6 million beneficiaries, or slightly more than 13 percent, cannot manage their own finances.[Workpapers 4S-33] If beneficiaries cannot manage their own finances, Congress has authorized SSA to pay the benefits to other individuals or organizations on their behalf. The SSA calls these individuals and organizations representative payees (hereinafter called payees).

Using medical and Agency guidelines, SSA determines if beneficiaries need payees. Such beneficiaries may include the mentally or physically impaired, disabled adult children, and persons incapable of exercising good financial judgment. In addition, SSA requires a payee for some individuals, including:

1. minor children under age 18, (2)
2. legally incompetent adults, and (3)
3. persons who receive benefits because they are disabled due to alcohol and/or drugs.

Public Law 104-121 passed on March 28, 1996 prohibits eligibility to individuals whose drug addiction and/or alcoholism is a contributing factor material to the finding of disability. This legislation affects the status of current drug addicts and/or alcoholics who must request new medical determinations by July 28, 1996. These individuals may be found disabled due to other conditions and may continue to receive benefits. The new law requires payees for current and future beneficiaries who have a drug addiction and/or alcoholism condition and who are also determined to be incapable of managing their benefits.

The Social Security Act authorizes the Commissioner of SSA to appoint payees. Payees may include, but are not limited to, parents with or without custody of children, spouses, other relatives, legal guardians, friends who show strong concern for the beneficiary's welfare, and institutions with or without custody of the beneficiary.

When SSA appoints payees, it updates beneficiaries' MBR and/or SSR files with information about the payees. This information includes, but is not limited to, the payee's name and address, the type of payee code, and the custody arrangement.

Prior to 1983, SSA did not have a mandate to conduct accountings of funds that payees received on behalf of beneficiaries. The Agency relied on its own initiative to create an accounting system. In 1979, Ms. Jeanne Jordan brought a certified class action suit against SSA challenging how it monitored payees. (Ms. Jordan alleged that her payee was not using her SSA benefits properly to meet her needs.) In its 1983 decision, the Jordan Court decided that payees should be required to give a full accounting of how they spend and save title II and title XVI benefits on behalf of beneficiaries. Subsequently, Congress amended The Social Security Act to require annual accounting of all payees except State mental institutions participating in the onsite review program.

The SSA designed an annual accounting process to gather data from the payee about various situations involving the beneficiary. The data helps SSA determine:

1. the continuing suitability of the payee;

2. the continuing need for representative payment; and

3. whether the payee used benefits properly during the 12-month report period.

Payee Responsibilities

Responsibilities include (1) frequently monitoring the beneficiary's well-being, (2) notifying SSA of situations that affect the beneficiary's entitlement to or amount of benefits (e.g., work), and (3) informing SSA of changes in the payee's own circumstances that would affect the payee's performance. A major payee responsibility is to submit an annual report to SSA accounting for benefits received, used, and conserved. Payees receive the booklet, A Guide For Representative Payees, during the SSA interview which describes a payee's responsibilities and the appropriate use of benefits. The booklet includes a worksheet to record the use of benefits and a sample accounting form.

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The Accounting Review Process

Each month, SSA uses its computerized data bases (the MBR and the SSR) to identify payees who are to receive annual accounting forms. The SSA usually schedules payees to receive forms on the anniversary of the month they were selected to be the payee, although SSA and/or payees may designate an alternate report period. As a result of this selection process, SSA sends initial accounting forms to approximately one-twelfth of all payees each month. The SSA uses a contractor to mail accounting forms to payees.

The SSA does not select payees to receive accounting forms if payments have been received for less than 1 year, if on-site reviews apply, if payments are made to an address in a foreign country, and if payments were suspended for the entire accounting period. The SSA also does not select all payees to receive accounting forms if the beneficiary is concurrently entitled to receive title II and title XVI benefits. In such cases, only the payee for title XVI benefits is selected.

To handle a high volume of annual accounting, SSA developed standardized accounting forms--the SSA-623 and the SSA-6230. The SSA-623 asks how payees used the funds for: (1) food and shelter; (2) other items such as clothing, education, personal items, and medical and dental expenses; and (3) savings. The form also asks payees about: (1) changes in the beneficiary's custody; (2) whether the payee or another person controlled the SSA benefits; and (3) their own felony convictions during the previous 12 months. In July 1990, SSA introduced the SSA-6230 accounting form for parents and, later, stepparents and grandparents with custody of minor children who receive title II benefits.See Workpaper file for the Process/Work-flow report (OEI-09-92-00858), #2P-11, p. 1. Relatives acting as payees may report their use of benefits for up to four children on the same form. Since parents, stepparents, and grandparents represent the largest type of payee category, most title II payees now receive the SSA-6230.

The SSA-6230 differs from the SSA-623 primarily in: (1) the payees' ability to account for up to four children on the same form; and (2) the wording of the questions on custody and use of benefits. Also, questions about funds on the SSA-6230 are more general. Payees report: (1) the expenses for care and support of the children and (2) savings.

When the contractor mails accounting forms to payees, SSA establishes a centralized computer systems diary to control the forms’ return. When payees return their form, SSA clears the systems diary to acknowledge receipt, thereby eliminating the systematic record of responses from the payees. The SSA's Wilkes-Barre Data Operations Center in Pennsylvania completes the initial screening, data verification, and review of all returned forms. The staff use a computer program to review the accounting forms and decide whether the responses are acceptable or need further explanation. If all responses are acceptable, no further action is necessary and the record is deleted from the data base. If payees do not return the accounting form to Wilkes-Barre within 3 months, the contractor mails a second copy of the accounting form. If payees return the form as a result of the second request, SSA clears the systems diary.

If payees have not returned either form within 6 months of first mailing, SSA, through the National Computer Center in Baltimore, produces lists of payees from the systems diary who have not returned the forms. The lists (called "nonresponder alerts" or "listings") are sent to SSA field offices and processing centers for follow-up by telephone or mail. The field offices contact nonresponding payees for title XVI beneficiaries. The processing centers attempt to contact nonresponding payees for title II beneficiaries. If they are unsuccessful, they send development requests to the appropriate field offices. The processing centers retain control of development requests for nonresponding payees and follow up with field offices for status reports.

The Increasing Costs of Annual Accounting

The cost of annual accounting has almost doubled over the last 5 years as indicated in the graph below. In Fiscal Year (FY) 1991, SSA spent approximately $33.2 million to administer annual accounting. For FY 1996, SSA estimated that it would spend $66.0 million for annual accounting.

chart of Increasing SSA Costs for Annual Accounting

SSA Initiatives and Changes in Annual Accounting

To combat rising costs, SSA initiated several activities to improve the annual accounting process. First, SSA introduced the SSA-6230 accounting form tailored for parents, stepparents, and grandparents with custody of minor children who receive title II benefits. Second, SSA asked the Office of the Inspector General (OIG) to conduct a series of inspections that would review and recommend improvements to the annual accounting process. This report is one in the series of reports that assess the risk of misuse of benefits associated with various categories of payees. Other reports will present data concerning demographics of payees, misuse or questionable use of benefits by payees, poor performance by payees, effectiveness and efficiency of the payee accounting review process, and problems with completion of the accounting forms. A roll-up report will provide overall recommendations for improving the accounting process. And third, independent of the OIG's work, SSA appointed an external Representative Payee Advisory Committee in June 1995 to study all aspects of the accounting process from payee selection through monitoring payee performance. The Committee reported its findings and recommendations to the Commissioner of SSA in November 1996.

METHODOLOGY

In September 1994, SSA prepared a computerized file of titles II and XVI beneficiaries with payees scheduled to receive initial accounting forms in October 1994, who received benefits for the report period October 1993 through September 1994. The SSA used a contractor to mail accounting forms to these payees in October 1994. As payees returned their accounting forms, SSA deleted their names from this file. In October 1995, we obtained a copy of the file to determine how many nonresponding payees (payees who did not respond to SSA's attempts at contact) remained after 1 year. We analyzed these data to identify: (1) how many payees did not respond to the annual accounting; (2) the amount of benefits for which SSA did not receive an accounting; and (3) any possible trends among these nonresponding payees.

This inspection was conducted in accordance with the Quality Standards for Inspections issued by the President's Council on Integrity and Efficiency.

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FINDINGS

SSA DOES NOT RECEIVE AN ACCOUNTING FOR APPROXIMATELY $1.2 BILLION IN ANNUAL BENEFITS

In October 1994, SSA mailed 367,636 accounting forms asking payees to describe how they spent or saved benefits on behalf of the beneficiaries. One year later, we found that SSA had not received 26,331 accounting forms (from 20,681 payees), representing $104 million in benefits, from these payees. On an annual basis, this projects to approximately 316,000 unreturned accounting forms from 248,000 payees and $1.2 billion in benefits for which SSA did not receive an accounting.

chart showing Some Payees Do Not Return Forms

For the report period, annual benefits for nonresponding payees averaged $3,934. Almost 74 percent of these payees managed between $1,200 and $7,200 during the report period.

SSA DOES NOT MAINTAIN SYSTEMATIC INFORMATION ABOUT NONRESPONDING PAYEES

The SSA’s present tracking system is not designed to provide a historical overview of payees’ return of accounting forms. It does not even track when payees return forms. Rather, the system tracks which payees have not returned accounting forms so that SSA knows which payees require additional contact.

Under the current process, payees who fail to respond to the accounting process within 1 year receive no further centralized systematic scrutiny. After 1 year has elapsed, the nonresponder file is overwritten when SSA mails another accounting form. Since no computer data is maintained about the nonresponding payees, SSA has no way of knowing how often these payees fail to respond or if they have ever responded to a request for accounting.

NONRESPONDING PAYEES ARE USUALLY RELATIVES WITH CUSTODY

Approximately 76 percent of nonresponding payees are relatives with custody of beneficiaries. At 37.6 percent, mothers with custody of their children account for the single largest group of unreturned accounting forms. This is followed by:

  • payees coded "W" (assumed to be parents with custody) at 21.8 percent,
  • other relatives with custody at 8.3 percent, and
  • fathers with custody at 7.9 percent.

These results are not unexpected, however. Mothers with custody represent 38.2 percent of the payees who receive accounting forms, while payees coded "W" represent 19.9 percent, other relatives with custody represent 6.3 percent, and fathers with custody represent 7.8 percent.

Nonresponding payees are concentrated in a few States and Puerto Rico

The highest volume of unreturned accounting forms are concentrated in the States with the highest general populations. Overall, California has the greatest number of unreturned forms with 2,043 (7.8 percent of all unreturned accounting forms), followed by New York with 1,976 (7.5 percent), Texas with 1,870 (7.1 percent), and Florida with 1,605 (6.1 percent). Table 1 in Appendix A provides information on unreturned accounting forms for each State and SSA region.

Not so predictable, however, is the number of unreturned accounting forms from Puerto Rico. Puerto Rico had a total of 978 unreturned forms for title II beneficiaries. This accounts for 3.7 percent of all unreturned forms and projects to 11,736 for the year. We also found that Puerto Rico accounted for:

  • Eight of the 24 SSA field offices with 60 or more unreturned accounting forms from those that SSA originally mailed in October 1994. The number of unreturned forms from these 8 field offices ranged from 61 to 106, with an average of 76.0 per office. Table 2 in Appendix A lists all field offices with 60 or more unreturned accounting forms.
  • Six instances in which groups of individuals (mostly relatives) had not returned 10 or more accounting forms from the same small geographic location. In several instances, a single payee is responsible for more than one unreturned form. Table 3 in Appendix A provides information about these concentrations of nonresponding payees.

AGENCIES AND INSTITUTIONS ARE THE MOST COMMON HIGH-VOLUME NONRESPONDING PAYEES

We found 12 instances in which agency or institutional payees (e.g., State departments of social services or county public guardian services) had not returned 10 or more accounting forms (Table 4 in Appendix A). The number of unreturned forms ranged from 10 to 56, with an average of 18.2 for each payee. We found that approximately 73.8 percent of the nonresponding agency or institutional payees have custody of beneficiaries. This group mirrors the universe of nonresponding payees--approximately 72.4 percent have custody of their beneficiaries.

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RECOMMENDATIONS

The SSA’s payee policies, the Jordan Court, and Federal law require that SSA obtain accounting forms from payees annually. Even so, more than 26,000 of the payees that SSA originally contacted in October 1994 failed to respond to the request for accounting. These payees failed to respond to two mailed requests, and, presumably, the field offices’ or processing centers’ attempts at contact.

The SSA’s present system does not provide sufficient information to determine why certain payees do not return accounting forms and if these payees have ever returned accounting forms. The SSA has no knowledge of how payees used these funds. Therefore, we recommend that SSA should:

1. Develop an improved system for tracking non-responding payees.

We recommend that, as a first step, SSA maintain data on nonresponding payees that it currently overwrites.

2. Determine why selected payees (e.g., high-volume agency or institutional payees and payees in Puerto Rico) fail to complete accountings.

3. Determine whether field office or processing center staff are properly processing the nonresponder alerts.

4. Develop a more immediate and appropriate method (e.g., suspension of benefits, immediate change of payee with final accounting by former payee) to be used in conjunction with the tracking system to obtain accountings. Additionally, SSA should annotate the Master Representative Payee File to indicate that the payee failed to respond to a request for accounting and should not be considered as a representative payee for other beneficiaries.

SSA Comments

The SSA agreed that it should maintain data on nonresponding payees. It also agreed with our recommended actions to determine why selected payees fail to account and whether field office personnel are properly processing nonresponder alerts. Additionally, SSA agrees with the proposal to annotate the Master Representative Payee File with information on nonresponders. Systems changes and procedural changes are being planned to implement these recommendations.

The SSA wishes to wait for the results of additional OIG work now in progress to determine what direction SSA will take concerning the recommendation to develop a more immediate and appropriate method to obtain accountings from nonresponding payees.

OIG Response to Agency Comments

We agree with the Agency's response to our recommendations and the approach it is taking to implement corrective action.

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APPENDIX A

LOCATIONS AND CHARACTERISTICS OF NONRESPONDING PAYEES

The following tables provide breakdowns on the locations of nonresponding payees, type of payee information for selected high-volume nonresponding payees, and geographic concentrations of unreturned accounting forms.

TABLE 1: UNRETURNED ACCOUNTING FORMS BY STATE AND REGION (OCTOBER 1994)

 STATE

TOTAL

PERCENTAGE

Connecticut

315

1.20%

Maine

70

0.27%

Massachusetts

706

2.68%

New Hampshire

80

0.30%

Rhode Island

64

0.24%

Vermont

62

0.24%

TOTAL REGION I

1,297

4.93%

New Jersey

892

3.39%

New York

1,976

7.50%

Puerto Rico

978

3.71%

Virgin Islands

23

0.09%

TOTAL REGION II

3,869

14.69%

Delaware

102

0.39%

District of Columbia

100

0.38%

Maryland

503

1.91%

Pennsylvania

1,128

4.28%

Virginia

507

1.93%

West Virginia

234

0.89%

TOTAL REGION III

2,574

9.78%

Alabama

596

2.26%

Florida

1,605

6.10%

Georgia

910

3.46%

Kentucky

436

1.66%

Mississippi

452

1.72%

North Carolina

665

2.53%

South Carolina

436

1.66%

Tennessee

686

2.61%

TOTAL REGION IV

5,786

21.97%


Indiana

492

1.87%

Illinois

1,157

4.39%

Michigan

989

3.76%

Minnesota

210

0.80%

Ohio

1,088

4.13%

Wisconsin

456

1.73%

TOTAL REGION V

4,392

16.68%

Arkansas

342

1.30%

Louisiana

707

2.69%

New Mexico

199

0.76%

Oklahoma

382

1.45%

Texas

1,870

7.10%

TOTAL REGION VI

3,500

13.29%

Iowa

137

0.52%

Kansas

149

0.57%

Missouri

446

1.69%

Nebraska

97

0.37%

TOTAL REGION VII

829

3.15%

Colorado

278

1.06%

Montana

78

0.30%

North Dakota

20

0.08%

South Dakota

42

0.16%

Utah

153

0.58%

Wyoming

30

0.11%

TOTAL REGION VIII

601

2.28%


Arizona

378

1.44%

California

2,043

7.76%

Guam

21

0.08%

Hawaii

104

0.39%

Nevada

99

0.38%

TOTAL REGION IX

2,645

10.05%

Alaska

34

0.13%

Idaho

123

0.47%

Oregon

228

0.87%

Washington

453

1.72%

TOTAL REGION X

838

3.18%

TOTAL

26,331

100.00%

 

TABLE 2: FIELD OFFICES WITH 60 OR MORE NONRESPONDER CASES (OCTOBER 1994)

 DOC

CITY

STATE

TOTAL UNRETURNED ACCOUNTING FORMS*

198

Bayamon

PR

106

622

Birmingham

AL

90

281

Caguas

PR

90

363

Detroit

MI

87

657

Orlando

FL

83

280

Arecibo

PR

82

500

Evergreen Park

IL

79

279

Mayaguez

PR

78

172

Camden

NJ

73

783

Oklahoma City

OK

71

858

Albuquerque

NM

69

455

Indianapolis

IN

67

136

Patchogue

NY

66

655

Jacksonville

FL

65

272

Ponce

PR

65

816

Houston

TX

64

271

Rio Piedras

PR

64

617

East Point

GA

62

641

Jackson

MS

62

379

Hato Rey

PR

62

656

Tampa

FL

61

B00

Bayamon

PR

61

566

Memphis

TN

60

855

Houston

TX

60

*This information is intended to show geographic concentrations of unreturned forms and is not intended to demonstrate a failure by field offices or processing centers to obtain completed forms.

TABLE 3: CONCENTRATIONS OF NONRESPONDING PAYEES:

10 OR MORE FORMS FROM THE SAME SMALL GEOGRAPHIC LOCATION (OCTOBER 1994)

 TYPE OF
PAYEE CODE(S)*

CITY

STATE

DOC

NUM

Grandparent, Mother, Other Relative, Spouse, "W"

Ponce

PR

272

28

Child, Father, Mother, Other Relative, "W"

Mayaguez

PR

279

18

Child, Mother, Other Relative, Spouse, "W"

Caguas

PR

281

17

Child, Father, Mother, Other Relative, Spouse, "W"

Toa Baja

PR

B00

13

Father, Mother, Nonrelative Individual, Other Relative, Spouse, "W," Missing

Villas de Buena

PR

198

11

Grandparent, Mother, Other Relative, Stepfather, "W"

Vega Baja

PR

B89

10

*In each instance, at least one payee is responsible for more than one unreturned accounting form.

TABLE 4: HIGH-VOLUME NONRESPONDING PAYEES:

10 OR MORE FORMS FROM THE SAME AGENCY OR INSTITUTION (OCTOBER 1994)

 TYPE OF
PAYEE CODE(S)*

CITY

STATE

DOC

NUM

Agency or State Nonmental Institution

Olympia

WA

918

56

Public Official

Los Angeles

CA

951

21

Agency or State Mental or Nonmental Institution

Utica

NY

164

20

Nonprofit Mental or Private Nonmental Institution

Akron

OH

A66

20

Agency or State Nonmental Institution

Boston

MA

030

18

Agency

Phoenix

AZ

913

15

Agency or Nonprofit Nonmental or

State Nonmental Institution

Los Angeles

CA

D44

15

Agency or State Mental or Nonmental Institution

Jefferson City

MO

740

12

Agency

Trenton

NJ

171

11

Agency

New York

NY

159

11

Nonprofit Mental or Nonprofit Nonmental or

Private Nonmental Institution

Mid-Island

NY

144

10

State Nonmental Institution

Memphis

TN

C90

10

*Each row represents accounting forms mailed to a single nine-digit zip code. Although the Social Security Administration’s data bases frequently listed more than one type of payee code, each row represents a single agency or institution.

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APPENDIX D

MAJOR CONTRIBUTORS TO THIS REPORT

Office of the Inspector General

Scott Patterson, Director, Evaluations and Technical Services
Deborah Harvey, Senior Evaluator
Brian Pattison, Senior Evaluator
Alan Stubbs, Senior Evaluator
Robert Gibbons, Senior Evaluator (Department of Health and Human Services)
Pat Kennedy, Senior Auditor

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