SOCIAL SECURITY ADMINISTRATION
SUPPLEMENTAL SECURITY INCOME
RECIPIENTS WHOSE MEDICARE
BENEFITS WERE TERMINATED
DUE TO DEATH
November 2006 A-01-06-26105
AUDIT REPORT
Mission
By conducting independent and objective audits, evaluations and investigations, we inspire public confidence in the integrity and security of SSA’s programs and operations and protect them against fraud, waste and abuse. We provide timely, useful and reliable information and advice to Administration officials, Congress and the public.
Authority
The Inspector General Act created independent audit and investigative units, called the Office of Inspector General (OIG). The mission of the OIG, as spelled out in the Act, is to:
Conduct and supervise independent and objective audits and investigations relating to agency programs and operations.
Promote economy, effectiveness, and efficiency within the agency.
Prevent and detect fraud, waste, and abuse in agency programs and operations.
Review and make recommendations regarding existing and proposed legislation and regulations relating to agency programs and operations.
Keep the agency head and the Congress fully and currently informed of problems in agency programs and operations.
To ensure objectivity, the IG Act empowers the IG with:
Independence to determine what reviews to perform.
Access to all information necessary for the reviews.
Authority to publish findings and recommendations based on the reviews.
Vision
We strive for continual improvement in SSA’s programs, operations and management by proactively seeking new ways to prevent and deter fraud, waste and abuse. We commit to integrity and excellence by supporting an environment that provides a valuable public service while encouraging employee development and retention and fostering diversity and innovation.
Date: November 14, 2006 Refer To:
To: The Commissioner
From: Inspector General
Subject: Supplemental Security Income Recipients Whose Medicare Benefits Were Terminated Due to Death (A-01-06-26105)
OBJECTIVE
Our objective was to determine whether Supplemental Security Income (SSI) payments should be terminated for recipients whose Medicare benefit records indicated they were deceased.
BACKGROUND
SSI is a nationwide Federal cash assistance program administered by the Social Security Administration (SSA) that provides a minimum level of income to financially needy individuals who are aged, blind or disabled. Medicare is a health insurance program administered primarily by the Centers for Medicare and Medicaid Services (CMS) within the Department of Health and Human Services that provides health insurance benefits to the aged and disabled. Although CMS has primary responsibility for the Medicare program, SSA is responsible for making Medicare entitlement determinations and maintaining the benefit records.
In October 2005, we were asked to evaluate an idea submitted to SSA’s Employee Suggestion Program. The employee suggested we conduct an audit after finding several cases where SSI payments continued for recipients even though their Medicare benefits were terminated due to death.
To perform our review, we obtained a file from SSA of all Medicare records
terminated for death. Through data analysis, we found 251 individuals
whose SSI payments continued even though their Medicare records indicated they
were deceased. In April 2006, we referred all 251 cases to SSA for
review and corrective action. (See Appendix A for more information
about our scope and methodology.)
RESULTS OF REVIEW
Of the 251 individuals in our population, 86 are deceased and their SSI payments should be terminated. The remaining 165 beneficiaries were actually alive and their Medicare benefits—and, in some cases, their SSI payments—were incorrectly terminated.
PAYMENTS ISSUED AFTER DEATH
In 86 cases, the individuals’ Medicare records were properly terminated because they died. Although the Agency stopped the SSI payments timely for 19 of these individuals, SSA could have avoided issuing $490,288 in the remaining 67 cases had the Agency stopped the SSI payments when the deaths were first discovered. Additionally, we estimate SSA could save $237,103 over the next 12 months by stopping payments to the deceased recipients. The table below summarizes these 67 cases by the number of monthly payments issued after the deaths were reported.
Months Paid After |
Number of |
1 to 6 months |
11 |
7 to 12 months |
23 |
13 to 18 months |
11 |
19 to 24 months |
7 |
25 to 30 months |
7 |
31 to 36 months |
5 |
Over 36 months |
3 |
Total |
67 |
As of November 2006:
For example, one individual in our sample—who received both Medicare benefits and SSI payments—died in June 2004. The Medicare record was properly terminated. However, because there was no information on the Medicare record to indicate that the person also received SSI payments, these payments continued. Based on our audit, SSA field office staff reviewed the case and discovered that the deceased recipient's daughter had cashed SSI checks that were issued after the recipient's death. The case was referred to the Inspector General’s Office of Investigations. SSA could have avoided issuing $11,745—and the potential fraud that resulted—if the SSI payments had been stopped when the death was reported to the Agency. By taking action to stop the incorrect payments effective 2006, we estimate SSA avoided issuing an additional $6,876 over the next 12 months.
In another case, SSA terminated the Medicare record of an individual who died in October 2003 but did not stop the ongoing SSI payments. The Agency could have avoided issuing $15,525 if the SSI payments had been stopped when the death was reported to SSA. In addition, we estimate the Agency could save an additional $7,236 over the next 12 months if the individual’s SSI payments are stopped.
We discussed these cases with staff in SSA’s Office of Systems. They identified limitations in the Agency’s automated systems that caused these cases to go undetected. The Agency implemented systems enhancements on September 30, 2006 which are expected to resolve these issues.
BENEFITS TERMINATED FOR LIVING INDIVIDUALS
In our review, we found that SSA terminated the Medicare benefits to 165 individuals
who were actually alive. In
addition, the Agency incorrectly terminated the SSI payments to 85 of these individuals. Erroneous
death terminations “…can cause undue hardship for the individual[s]
and create public relations problems” for SSA. They
also create additional workloads for Agency staff, who must take action to correct
the benefit records and resume payments. According to SSA, these cases
are “…very time sensitive and require immediate action.”
Medicare Benefits Terminated
Erroneous Medicare terminations could lead to unpaid medical bills. Even though the Agency considers these cases to be a high priority workload, we found that erroneous Medicare terminations were not always corrected timely. Information on SSA’s systems indicated that 36 individuals contacted the Agency previously to report the problems and request that their Medicare benefits be reinstated. As of November 2006:
For example, in November 2005, an 81-year old beneficiary contacted SSA to report that her Medicare claims were being denied. After recontacting the Agency several times to resolve the error, SSA reinstated her Medicare benefits in July 2006—8 months after the error was first discovered.
In another case, the Agency terminated the Medicare benefits of a 79-year old individual in December 2004. The beneficiary reported the error to SSA in September 2005. The individual followed up with the Agency several times, but her Medicare benefits had not been reinstated as of November 2006.
SSI Payments Terminated
We found that deaths were not always verified before SSI payments were stopped. As a result, the SSI payments to 85 recipients were terminated for death even though they were alive. For example, in April 2005, CMS reported that a beneficiary died and, as a result, SSA terminated the Medicare benefits. Although the death was not confirmed by SSA, the Agency’s computer system automatically terminated the SSI payments to the individual. In June 2005, SSA discovered that the beneficiary was actually alive and took action to correct his SSI record and issue the payments that were previously withheld. (Although SSA resumed his SSI payments in June 2005, the Agency did not correct his Medicare benefit record until October 2006.)
According to SSA, first party reports of death are those the Agency receives by mail, telephone or in person from acceptable reporters. Third party reports are those received via computer matching with other agencies, including CMS. The Agency does not require verification of death reports received from first party sources before stopping benefit payments. However, because the Privacy Act requires that SSA confirm information resulting from computer matches before taking action to stop benefit payments, it is the Agency’s policy to verify death reports received from third parties—including CMS—before stopping SSI payments.
The SSI payments to these 85 individuals were stopped without verification of the deaths because of limitations in SSA’s computer systems. Agency staff informed us that, although the death reports were the result of computer matching with CMS, SSA’s system treated them as first party reports instead of third party reports. As a result, the system automatically terminated the payments to the individuals without first requiring that Agency staff verify the deaths.
CONCLUSION AND RECOMMENDATIONS
About 34 percent of the 251 individuals whose Medicare benefits were terminated for death were actually deceased and should no longer be issued SSI payments. For the remaining 66 percent, the beneficiaries were actually alive and their Medicare benefits—and, in some cases, their SSI payments—were incorrectly terminated. Although these 251 cases represent a very small portion of the individuals receiving Medicare benefits and SSI payments, we believe the sensitive nature of these cases requires that immediate action be taken. Therefore, we recommend that SSA:
AGENCY COMMENTS
SSA agreed with our recommendations. (See Appendix C.)
Patrick P. O’Carroll, Jr.
APPENDICES
APPENDIX A – Scope and Methodology
APPENDIX B – Medicare Benefits Terminated for Living Individuals
APPENDIX C – Agency Comments
APPENDIX D – OIG Contacts and Staff Acknowledgments
Appendix A -- Scope and Methodology
To accomplish our objective, we:
We performed our audit in Boston, Massachusetts between April and November
2006. We tested the data obtained for our audit and determined it to
be sufficiently reliable to meet our audit objective. The entities audited
were the Office of Applications and Supplemental Security Income Systems under
the Deputy Commissioner for Systems and SSA’s field offices under the
Deputy Commissioner of Operations. We conducted our audit in accordance
with generally accepted government auditing standards.
Appendix B -- Medicare Benefits Terminated for Living Individuals
In total, 165 cases in our population were alive and their Medicare benefits were incorrectly terminated. The tables below summarize these 165 cases by State and by responsible Program Service Center.
Table 1: 165 Cases in which Medicare benefits were incorrectly terminated, by State |
|||
State |
Count |
State |
Count |
Alabama |
4 |
Mississippi |
2 |
Arkansas |
1 |
New Jersey |
10 |
California |
32 |
New Mexico |
3 |
Connecticut |
1 |
New York |
22 |
District of Columbia |
4 |
North Carolina |
3 |
Florida |
6 |
Ohio |
4 |
Georgia |
9 |
Oklahoma |
2 |
Illinois |
6 |
Oregon |
1 |
Indiana |
2 |
Pennsylvania |
6 |
Kentucky |
4 |
Rhode Island |
1 |
Louisiana |
3 |
South Carolina |
5 |
Maine |
1 |
Tennessee |
1 |
Maryland |
5 |
Texas |
13 |
Massachusetts |
5 |
Washington |
3 |
Michigan |
3 |
Wisconsin |
2 |
Minnesota |
1 |
|
|
Table 2: 165 Cases in which Medicare benefits were incorrectly terminated, by responsible Program Service Center |
||
Program Service Center |
Count |
Percent |
Northeastern |
28 |
17% |
Mid-Atlantic |
20 |
12% |
Southeastern |
26 |
16% |
Great Lakes |
18 |
11% |
Western |
37 |
22% |
Mid-America |
18 |
11% |
Office of Disability Operations |
18 |
11% |
Total |
165 |
100% |
Appendix C -- Agency Comments
MEMORANDUM |
Date: |
November 01, 2006 |
Refer To: S1J-3 |
To: |
Patrick P. O'Carroll, Jr. |
From: |
Larry W. Dye /s/ |
Subject: |
Office of the Inspector General (OIG) Draft Report, "Supplemental Security Income Recipients Whose Medicare Benefits Were Terminated Due to Death" (A-01-06-26105)--INFORMATION |
We appreciate OIG’s efforts in conducting this review. Our comments on the draft report’s recommendations are attached.
Please let me know if you have any questions. Staff inquiries may be
directed to
Ms. Candace Skurnik, Director, Audit Management and Liaison Staff, at extension
54636.
Attachment:
SSA Response
COMMENTS ON THE OFFICE OF THE INSPECTOR GENERAL’S (OIG) DRAFT
REPORT, “SUPPLEMENTAL SECURITY INCOME RECIPIENTS WHOSE MEDICARE BENEFITS
WERE TERMINATED DUE TO DEATH”
(A-01-06-26105)
Thank you for the opportunity to review and provide comments on this draft report. Since June 2006, various Agency components have continued working to ensure that our process for death terminations on all records is valid and effective. We have reviewed not only the death inputs from data received in person, by telephone or via returned checks, but also those reports of death received from external agencies, such as the Center for Medicare and Medicaid Services (CMS). Our review process is complicated by the fact that each system of record treats data differently and so each must be analyzed to determine the most effective and efficient method of establishing interfaces between the records. Therefore, starting with a clear understanding of how each separate system works and interfaces with other systems is essential. Our goal is to make the death input process and the interfaces between the various systems as error-free and effective as possible.
Recommendation 1
Review the cases in our audit population and take appropriate action to terminate the Supplemental Security Income (SSI) payments for the deceased individuals and remove the erroneous death information for those individuals who are alive and reinstate their Medicare benefits.
Comment
We agree. We will continue to investigate the cases to ensure that the appropriate actions are taken and to reinstate benefits, if appropriate. We expect to complete the review by the end of December 2006.
Recommendation 2
Confirm the deaths reported from CMS before terminating payments to SSI recipients.
Comment
We agree. It is the Agency’s policy to verify all third party reports of death received via computer matching with CMS and other agencies before terminating benefits to an SSI recipient. We will investigate the cost effectiveness of implementing the changes referenced in this report.
COMMENTS ON THE OFFICE OF THE INSPECTOR GENERAL’S (OIG) DRAFT
REPORT, “SUPPLEMENTAL SECURITY INCOME RECIPIENTS WHOSE MEDICARE BENEFITS
WERE TERMINATED DUE TO DEATH”
(A-01-06-26105)
Thank you for the opportunity to review and provide comments on this draft report. Since June 2006, various Agency components have continued working to ensure that our process for death terminations on all records is valid and effective. We have reviewed not only the death inputs from data received in person, by telephone or via returned checks, but also those reports of death received from external agencies, such as the Center for Medicare and Medicaid Services (CMS). Our review process is complicated by the fact that each system of record treats data differently and so each must be analyzed to determine the most effective and efficient method of establishing interfaces between the records. Therefore, starting with a clear understanding of how each separate system works and interfaces with other systems is essential. Our goal is to make the death input process and the interfaces between the various systems as error-free and effective as possible.
Recommendation 1
Review the cases in our audit population and take appropriate action to terminate the Supplemental Security Income (SSI) payments for the deceased individuals and remove the erroneous death information for those individuals who are alive and reinstate their Medicare benefits.
Comment
We agree. We will continue to investigate the cases to ensure that the appropriate actions are taken and to reinstate benefits, if appropriate. We expect to complete the review by the end of December 2006.
Recommendation 2
Confirm the deaths reported from CMS before terminating payments to SSI recipients.
Comment
We agree. It is the Agency’s policy to verify all third party
reports of death received via computer matching with CMS and other agencies
before terminating benefits to an SSI recipient. We will investigate
the cost effectiveness of implementing the changes referenced in this report.
Appendix D -- OIG Contacts and Staff Acknowledgments
Judith Oliveira, Director, Boston Audit Division (617) 565-1765
Jeffrey Brown, Audit Manager, (617) 565-1814
Acknowledgments
In addition to those named above:
Chad Burns, Auditor
Kevin Joyce, IT Specialist
Toni Paquette, Program Analyst
For additional copies of this report, please visit our web site at www.socialsecurity.gov/oig or
contact the Office of the Inspector General’s Public Affairs Specialist
at (410) 965-3218. Refer to Common Identification Number
A‑01-06-26105.
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Social Security Advisory Board
Overview of the Office of the Inspector General
The Office of the Inspector General (OIG) is comprised of our Office of Investigations
(OI), Office of Audit (OA), Office of the Chief Counsel to the Inspector
General (OCCIG), and Office of Resource Management (ORM). To ensure
compliance with policies and procedures, internal controls, and professional
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OA conducts and/or supervises financial and performance audits of the Social
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audits review the economy, efficiency, and effectiveness of SSA’s programs
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measures required by the Government Performance and Results Act of 1993.
-- FOOTNOTES FOLLOW --
SSA continues to review these cases. Our conclusions are based on our review of available electronic data on SSA’s systems through November 2006.
For purposes of our review, we considered an SSI payment that was issued after death to have been “avoidable” if it was issued more than 30 days after the Agency terminated the Medicare benefits.
SSA incorrectly terminated the Medicare benefits and SSI payments to these 85 individuals. As of December 2005 (when we obtained our data), the Agency had reinstated the monthly SSI payments but had not reinstated the Medicare benefits to these individuals. We did not quantify the number of individuals whose Medicare benefits and SSI payments were incorrectly terminated for death but were fully corrected by the Agency subsequent to December 2005.
In some cases, a deceased spouse’s date of death was incorrectly recorded on the living spouse’s Medicare record. The 165 cases in our audit represents 0.006 percent of the 2.7 million Medicare records that were terminated for death as of December 2005. Limited testing of the 2.7 million records did not uncover any additional instance of erroneous terminations.