A-01-10-11007 - Alternate Format

OFFICE OF
THE INSPECTOR GENERAL

SOCIAL SECURITY ADMINISTRATION

Disability Determination Services
Medical Consultant Assessments

May 2010

A-01-10-11007

CONGRESSIONAL RESPONSE
REPORT

May 28, 2010

The Honorable Max Baucus
Chairman
Committee on Finance
United States Senate
Washington, D.C. 20510

Dear Senator Baucus:

On March 25, 2009, your staff asked that we review allegations by the American Association of Social Security Disability Consultants (AASSDC) that (1) medical consultant (MC) assessments were altered and/or destroyed in the disability determination services, (2) MCs were pressured to produce specific assessments, and (3) disability examiners were seeking certain MCs to obtain specific assessments.

In February 2010, the House Committee on Ways and Means received additional information from the AASSDC expressing concerns about information obtained for this review.

Thank you for the opportunity to provide the Committee with the requested information. To ensure the Social Security Administration is aware of the information provided to your office, we are forwarding a copy of this report to the Agency. I have also sent similar responses to Ranking Member Charles E. Grassley of the Senate Committee on Finance, as well as, Acting Chairman Earl Pomeroy and Ranking Member Sam Johnson of the House Committee on Ways and Means, Subcommittee on Social Security.

If you have any questions, please call me, or have your staff contact Misha Kelly, Congressional and Intra-governmental Liaison at (202) 358-6319.

Sincerely,

/s/
Patrick P. O’Carroll, Jr.
Inspector General
Enclosure

cc:
Michael J. Astrue
Charles E. Grassley
Sam Johnson
Earl Pomeroy

May 28, 2010

The Honorable Charles E. Grassley
Ranking Member
Committee on Finance
United States Senate
Washington, D.C. 20510

Dear Senator Grassley:

Thank you for the opportunity to provide the Committee with the requested information. To ensure the Social Security Administration is aware of the information provided to your office, we are forwarding a copy of this report to the Agency. I have also sent similar responses to Chairman Max Baucus of the Senate Committee on Finance, as well as, Acting Chairman Earl Pomeroy and Ranking Member Sam Johnson of the House Committee on Ways and Means, Subcommittee on Social Security.

If you have any questions, please call me, or have your staff contact Misha Kelly, Congressional and Intra-governmental Liaison at (202) 358-6319.

Sincerely,

/s/
Patrick P. O’Carroll, Jr.
Inspector General

Enclosure

cc:
Michael J. Astrue
Max Baucus
Sam Johnson
Earl Pomeroy

May 28, 2010

The Honorable Earl Pomeroy
Chairman
Subcommittee on Social Security
Committee on Ways and Means
House of Representatives
Washington, D.C. 20515

Dear Mr. Pomeroy:

On March 25, 2009, staff from the Senate Committee on Finance asked that we review allegations by the American Association of Social Security Disability Consultants (AASSDC) that (1) medical consultant (MC) assessments were altered and/or destroyed in the disability determination services, (2) MCs were pressured to produce specific assessments, and (3) disability examiners were seeking certain MCs to obtain specific assessments.

In February 2010, your staff received additional information from the AASSDC expressing concerns about information obtained for this review.

Thank you for the opportunity to provide the Committee with the requested information. To ensure the Social Security Administration is aware of the information provided to your office, we are forwarding a copy of this report to the Agency. I have also sent similar responses to Ranking Member Sam Johnson of the House Committee on Ways and Means, Subcommittee Social Security, as well as, Chairman Max Baucus and Ranking Member Charles E. Grassley of the Senate Committee on Finance.

If you have any questions, please call me, or have your staff contact Misha Kelly, Congressional and Intra-governmental Liaison at (202) 358-6319.

Sincerely,

/s/
Patrick P. O’Carroll, Jr.
Inspector General
Enclosure

cc:
Michael J. Astrue
Max Baucus
Charles E. Grassley
Sam Johnson

May 28, 2010

The Honorable Sam Johnson
Ranking Member
Subcommittee on Social Security
Committee on Ways and Means
House of Representatives
Washington, D.C. 20515

Dear Mr. Johnson:

Thank you for the opportunity to provide the Committee with the requested information. To ensure the Social Security Administration is aware of the information provided to your office, we are forwarding a copy of this report to the Agency. I have also sent similar responses to Acting Chairman Earl Pomeroy of the House Committee on Ways and Means, Subcommittee on Social Security, as well as, Chairman Max Baucus and Ranking Member Charles E. Grassley of the Senate Committee on Finance.

If you have any questions, please call me, or have your staff contact Misha Kelly, Congressional and Intra-governmental Liaison at (202) 358-6319.

Sincerely,

/s/
Patrick P. O’Carroll, Jr.
Inspector General
Enclosure

cc:
Michael J. Astrue
Max Baucus
Charles E. Grassley
Earl Pomeroy

May 2010

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.

Background
OBJECTIVE

Our objective was to review allegations by the American Association of Social Security Disability Consultants (AASSDC) that (1) medical consultant (MC) assessments were altered and/or destroyed in the Disability Determination Services (DDS), (2) MCs were pressured to produce specific assessments, and (3) disability examiners (DE) were seeking certain MCs to obtain specific assessments.

BACKGROUND

The Social Security Administration (SSA) provides Disability Insurance (DI) and Supplemental Security Income (SSI) disability payments to eligible individuals under Titles II and XVI of the Social Security Act. To receive either benefit, an individual must first file an application with SSA.

Disability determinations under SSA’s DI and SSI programs are performed by a DDS in each State or other responsible jurisdiction, according to Federal regulations. A claimant is required to prove that he or she is disabled by providing medical and other evidence of disability. However, the DDS is responsible for making every reasonable effort to help the claimant get medical reports from medical sources. All evidence in the claimant's case record will be considered in making any determination.

An adult is considered disabled under the Social Security Act if he or she is unable to engage in any substantial gainful activity because of a medically determinable impairment that (1) can be expected to result in death or (2) has lasted (or can be expected to last) for a continuous period of at least 12 months.

ROLES OF THE DISABILITY EXAMINER AND THE MEDICAL CONSULTANT

Generally, the DE and the MC work as a team—following SSA’s processes for developing and evaluating claims—to determine whether a claimant is disabled under the Social Security Act. See Appendix B for details. The DE gathers medical and non medical evidence related to the claimant’s impairment(s), functioning, and work history.

The MC does not have sole authority to determine whether a claimant is disabled under Social Security’s criteria. The MC provides expertise in evaluating impairments, documenting findings, and preparing or reviewing assessments. The assessment does not include an opinion on whether the claimant is disabled but does include the following:
• evaluation of the medical evidence to determine its adequacy for making disability decisions;
• determination whether the claimant’s impairment(s) is severe;
• determination of whether the claimant’s impairment(s) meets or equals a listing in SSA’s Listing of Impairments; and
• determination of the claimant’s residual functional capacity (RFC) if a listing is not met or equaled.

The RFC is an individualized assessment of the claimant’s impairments and abilities based on all available evidence. SSA does not provide guidance on assessing an RFC for specific impairments on a case-by-case basis. However, SSA’s policies and procedures give the MC and DE guidance on how to address specific issues within an RFC, such as the effects of treatment and symptoms (including pain and fatigue) and medical source statements about what the claimant can still do.

With the exception of single decision maker (SDM) States, the DE determines whether a claimant is disabled under Social Security’s criteria and must consult with the MC to resolve medical issues and medical evidence interpretations. The disability determination is based on medical and non-medical criteria, such as requirements in the Social Security Act; Agency rulings, policies, and procedures; court rulings; and vocational factors, including the claimant’s age, education, and past work experience.

In some States, a DE can make the disability determination alone if he or she is a SDM. SSA provides SDMs the authority to complete all disability determination forms and to make initial disability determinations without MC approval or review on all fully favorable adult cases, with noted exceptions.

The disability folder contains all documentation supporting the disability decision. This includes case development worksheets and DDS actions, such as establishing a medically determinable impairment(s), assessing the severity of impairment, determining the duration of impairment, and establishing the onset date of impairment.

The DE (not the MC) decides what information reflects the final disability determination and what to retain in the disability folder. When multiple assessments or forms are in a disability folder, the DE removes any assessments or forms that do not support the disability determination.

ROLES OF SSA AND DDS

SSA funds 100 percent of necessary DDS costs but is not involved in the ongoing management of the disability program at the DDS except as necessary and in accordance with regulations. SSA provides operational standards, instructions, procedural advice, technical support, and management direction to DDSs in support of the Agency’s disability programs. DDSs are required to establish and maintain adequate and responsive internal management controls and reporting mechanisms. Each DDS is also responsible for establishing a quality assurance system, with both in-line and end-of-line reviews, designed to detect and correct errors or problems and to promote quality in all aspects of DDS claims processing. See Appendix C for details of SSA and DDS responsibilities.

SSA’s Office of Quality Performance measures the accuracy of DDS determinations through two different reviews. The Quality Assurance Reviews—including both allowances and denials—found the net accuracy rates of initial disability determinations ranged from 96.3 to 96.8 percent in Fiscal Years (FY) 2005 through 2009. The Pre-Effectuation Reviews—including at least half of all initial and reconsideration level allowances—found the accuracy rates ranged from 97.9 to 98.7 percent in FYs 2005 through 2008. See Appendix D.

In March 2009, the Committee on Finance requested we review allegations from the AASSDC regarding the alteration and/or destruction of MC assessments in the DDS. See Appendix E for details regarding the allegations.

To perform our review, we researched SSA’s policies regarding the processing and documenting of MC assessments. We also reviewed SSA system controls for the disability folder. Additionally, we contacted 468 DDS employees nationwide about the processing and documenting of MC assessments. Specifically, we contacted
• 52 DDS Administrators (which included each of the 50 States plus Washington, D.C. and Puerto Rico),
• 208 DDS DEs (4 randomly selected from each DDS), and
• 208 DDS MCs (4 randomly selected from each DDS).

We also contacted SSA’s Regional Offices and Office of Disability Determinations and other disability insurance providers for information for our review. Additionally, we reviewed examples of claims with a MC assessment deleted from the disability folder. See Appendix F for the questions we asked DDS employees and see Appendix G for details of our scope, methodology, and sample results.

Results of Review
Based on feedback from DDS and SSA employees, our examination of controls over the documentation of disability determinations, and our review of some actual cases, we found that generally (1) MC assessments were not altered and/or inappropriately deleted in the DDS, and (2) MCs were not pressured to produce specific assessments. We also found that the majority of DEs responding to our survey did not seek certain MCs to obtain specific assessments.

Table 1 shows the number of DDS employees sampled and who participated in our review.

Table 1: Number of DDS Staff Who Participated in Our Review
DDS Position Population Sampled Participants
Medical Consultant 2,240 208 189 (91%)
Disability Examiner 8,172 208 197 (95%)
Administrator 52 52 52 (100%)
TOTAL 10,464 468 438 (94%)

ALLEGATIONS
Allegation 1: Medical Consultant Assessments Were Altered and/or Deleted in the Disability Determination Services
When asked, MCs generally indicated that assessments were not altered.

Of the 189 MCs who participated in
our review,
• 187 indicated assessments were not altered, and
• 2 indicated assessments were altered.

Of the two MCs who indicated an assessment was altered, each described one-time occurrences. In one of these cases, the MC prepared a complex assessment not taken into consideration when making the final disability determination. This occurred in a DDS with SDM authority and a supervisor noted that they did not consider the MC’s assessment. In the other instance, the MC did not give details other than it occurred over 2 years ago.

When asked, MCs generally indicated that assessments were not deleted.

Of the 189 MCs who participated in
our review,
• 182 indicated assessments were not deleted, and
• 7 indicated assessments were deleted.

Of the seven MCs who indicated an assessment was deleted, six reported
it was a one time occurrence. For example, an MC indicated an assessment was deleted because a more experienced consultant provided another assessment. The MC was notified and made aware of why the DE removed his assessment from the disability folder.

In another example, an MC indicated assessments were removed from the disability folder in certain instances such as a second MC assessment, the disability determination was made by the regional office, or the disability folder contained contradictory forms or narratives. Each of these instances was in accordance with SSA’s policies and procedures.

Additionally, of the seven MCs who indicated altered or deleted assessments, three brought these instances to the attention of management. When asked, 7 of the 52 DDS administrators indicated an MC had brought to their attention an altered or deleted assessment. For example, an MC notified the DDS administrator of an assessment that had a written comment deleted. In this instance, DDS supervisors removed the MC’s comment because it contained inappropriate language.

In another example, an MC notified a DDS administrator of an assessment that was deleted from the disability folder. According to the DDS administrator, “…this is not an accepted practice...” The administrator instructed staff not to remove any signed forms from the disability folder without discussing with the MC and/or their supervisor. The administrator stated “…this is not a common occurrence.”
When asked, DEs generally indicated that they did not alter or delete MC assessments. Of the 197 DEs who participated in our review, 66 indicated removal of assessments from the disability folder for the following reasons:

• MC second assessment that better supported the disability determination,
• receipt of new medical evidence,
• adherence to SSA policy,
• assessment did not apply to the disability determination, or
• MC was not available to change an assessment he or she had prepared.

These instances generally occurred to support the disability determination or process the case. For example, one DE removed an assessment from the disability folder because of new evidence. In this situation, a new assessment was required, and the original assessment was no longer valid. Therefore, the DE removed the original assessment from the disability folder as only documentation supporting the disability determination should be retained in the disability folder.

One of SSA’s regional offices commented that the AASSDC may perceive that assessments were being altered or destroyed, but may have been unaware there were business and policy reasons that required changing an assessment. For example, an assessment prepared may have to be changed while training a new MC or during a quality review.

When asked how much weight was placed on MC assessments when deciding a case, 167 of the 197 DEs responding to our review answered. As shown in Table 2, 161 of the 167 DEs (96 percent) indicated placing high to medium weight on MC assessments.

Table 2: Amount of Weight Disability Examiners Place on MC Assessments in Deciding a Case
Weight of Assessment Participants Portion
High 139 83%
Medium 22 13%
Low 3 2%
Little to None 3 2%
Total 167 100%

SYSTEM CONTROLS

When multiple MCs or SDMs are involved in assessing a case, one of them certifies the case as the overall case reviewer. DDS systems do not allow an MC to be removed, or another MC assigned to a case, when the current MC has already certified the case. The system also retains a history of MC status changes and the reasons for those changes.

When an MC has prepared an assessment, it can be unsigned and changed by the MC or the DE. However, DDS systems require the assessment be re-signed by the assigned MC or an SDM before the case can be closed.

Once a form is in the disability folder it cannot be altered or modified. Therefore, when an assessment needs to be changed or updated, a new assessment form must be created and placed in the folder.

SSA’s systems indicate whether documents were deleted from the disability folder. Assessments can be deleted from the disability folder, however, they remain in SSA’s central repository. Also, SSA maintains an audit trail of all user actions, including deleting documents from the disability folder. Authorized SSA personnel may retrieve an assessment no longer associated with the disability folder. Therefore, no assessments are actually deleted from SSA’s records. See Appendix H for more details on SSA and DDS case processing systems.

In FY 2009, DDSs adjudicated almost 3.9 million disability claims, and SSA processed more than 660,000 hearings. During the same period, about 152,000 assessments were deleted from disability folders.

In March 2010, we asked SSA for examples of deleted assessments and the Agency provided a list of 25 claims where the MC assessment was deleted from the electronic disability folder. We reviewed these claims and determined these assessments were all deleted in accordance with SSA’s policies and procedures. Specifically,
• 18 were duplicate copies of assessments;
• 4 were returns from a quality assurance component, and the prior assessments were deleted because they did not reflect the final determination on the claim;
• 2 were deleted by mistake, but the deletion did not impact the outcome of the claim; and
• 1 was the same MC who updated the assessment and deleted 2 prior versions when new evidence was received.
Allegation 2: Medical Consultants Were Pressured to Produce Specific Assessments at the Disability Determination Services

When asked, MCs generally indicated they were not pressured to produce specific assessments.

Of the 189 MCs who participated in our review,

• 174 indicated they were not pressured to prepare a specific assessment,

• 10 indicated they were not pressured, however, they had been asked to sign or prepare a specific assessment which conflicted with their opinion, and

• 5 indicated they were pressured to sign or prepare a specific assessment that conflicted with their opinion.

Of the 5 MCs who indicated they were pressured to produce specific assessments, a few provided details of such instances. For example, one MC indicated being pressured when management became involved in case assessment disagreements with a DE. If the MC continued to disagree with the case assessment requested by management, he would sign off on the case noting “Signed as requested by the Chief Medical Consultant.”

If an MC indicated that he or she was asked or pressured to produce specific assessments, we then asked whether DDS management explained any consequences for not producing an assessment as instructed. Of the 15 MCs who indicated being asked or pressured to produce specific assessments, 4 responded that DDS management explained the consequences of not producing an assessment as instructed.

For example, an MC refused to sign a specified assessment, and the supervisor requested that the MC’s time, attendance, and production be monitored. The MC described the situation as intimidating and reported it to the Regional Administrator who ordered corrective action and resolved the issue. The MC stated this occurred about 3 years ago and the situation was completely resolved and was no longer an issue.

MC ASSESSMENT DISAGREEMENTS

MC assessments in the disability folder must support the disability determination. At times, DDS management or the DE may disagree with an MC’s assessment. When this happens, some DDSs indicated they have procedures to resolve such disagreements.

One DDS administrator outlined the following procedures to resolve disagreements between the MC and DE regarding assessments.

Step 1 If the DE disagrees with the MC’s assessment, the DE should discuss the case with the MC and come to an agreement.
Step 2 If not resolved by Step 1, the DE should discuss the matter with his/her Supervisor and/or the Chief Medical Consultant to reach an agreement.
Step 3 If not resolved by Step 2, a group consisting of an MC, Chief Medical Consultant, and 2 to 3 other staff members reviews the case to reach an agreement regarding the case.
Step 4 If not resolved by Step 3, the DDS refers the case to the regional medical staff for consultation.

MCs generally indicated the process to resolve disagreements was good. Of the 189 MCs who participated in our review, 78 did not provide an opinion of the process to resolve disagreements.

Of the 111 MCs who responded:

• 10 said the process was very good,
• 98 said the process was good,
• 2 said the process was poor, and
• 1 said the process was very poor.

For example, an MC responded that,
“…the disability evaluation process generally is effective and that matters of differences in case evaluation are generally resolved adequately given the situation that many of the cases are difficult and subject to varying interpretations.”

Another MC responded that, “…the process can be improved by continuing to support an environment of open communication between consultants and examiners, recognizing the medical expertise of consultants and programmatic expertise of examiners and the common goal of well-reasoned decisions for claimants.”

Allegation 3: Disability Determination Services Disability Examiners are Seeking Specific Consultants to Obtain Specific Assessments

When asked, 108 of the 197 DEs participating in our review indicated they did not select specific MCs to review a case. The 89 DEs who indicated they had chosen specific MCs to prepare assessments did so for the following reasons:

• MC medical expertise,
• prior case discussion with MC,
• MC processing speed, or
• to obtain a certain case result.

Of the 89 DEs who indicated choosing specific MCs to prepare assessments, 65 chose an MC based on their medical expertise. For example, one DE indicated selecting an MC not for a specific result but for the MC’s medical expertise, such as knowledge regarding cancer, pediatric, or cardiac cases.

In another example, one DE recommended a particular MC to review a case but not to get a certain result. The DE thought the MC’s clinical background or medical expertise was “…more suited to the characteristics of the case, hence, they would be more likely to render an appropriate conclusion.”

Of the 89 DEs who indicated choosing specific MCs to prepare assessments, 5 chose a specific MC to obtain a certain case result. For example, a DE assigned a case to a specific MC because in the past, they reached an agreement when reviewing a similar case.

When asked how case assessments were assigned to MCs, 37 DDS administrators (71 percent) indicated case assessments were assigned by a general queue or by medical expertise. Additionally, several DDS administrators responded that their DDS’s case processing system does not allow for DEs to choose a specific MC.

When asked, 5 of the 189 MCs responded they were aware of instances when a case was or was not assigned to them because a certain result was desired.

Conclusions
Based on feedback from DDS and SSA employees, our examination of controls over the documentation of disability determinations, and our review of some actual cases, we found that generally (1) MC assessments were not altered and/or inappropriately deleted in the DDS, and (2) MCs were not pressured to produce specific assessments. We also found that the majority of DEs who responded to our survey did not seek certain MCs to obtain specific assessments.

Appendices
APPENDIX A – Acronyms

APPENDIX B – The Social Security Administration’s Process for Evaluating Disability in Adults and Children

APPENDIX C – Social Security Administration and Disability Determination Services Responsibilities

APPENDIX D – Quality Reviews at Disability Determinations

APPENDIX E – Details of American Association of Social Security Disability Consultants Allegation

APPENDIX F – Disability Determination Services Employee Questions

APPENDIX G – Scope, Methodology, and Sample Results

APPENDIX H – Case Processing Systems

Appendix A
Acronyms
AASSDC American Association of Social Security Disability Consultants
Act Social Security Act
AHIP America’s Health Insurance Plans
C.F.R. Code of Federal Regulations
DDS Disability Determination Services
DE Disability Examiner
DI Disability Insurance
DQB Disability Quality Branch
eCAT Electronic Case Analysis Tool
EF Electronic Folder
FY Fiscal Year
MC Medical Consultant
POMS Program Operations Manual System
RFC Residual Functional Capacity
SDM Single Decision Maker
SGA Substantial Gainful Activity
SSA Social Security Administration
SSI Supplemental Security Income
SSN Social Security Number
U.S.C. United States Code

Appendix B
The Social Security Administration’s Processes for Evaluating Disability in Adults and Children

Under the Social Security Act (the Act), an adult is considered to be disabled if he or she is unable to engage in substantial gainful activity (SGA) by reason of a medically determinable physical or mental impairment that can be expected to result in death or that has lasted or can be expected to last for a continuous period of not less than 12 months.

The Social Security Administration (SSA) has a five-step sequential process for evaluating disability for adults, which generally follows the definition of disability in the Act (Chart B 1). The steps are followed in order. If a decision about disability can be made at a step, the analysis stops and a decision is made. If a decision about disability cannot be made, the adjudicator proceeds to the next step.

At Step 1 in the process, SSA generally considers whether the claimant is performing SGA. If the claimant is performing SGA, SSA finds that he or she is not disabled, regardless of the severity of his or her impairments. If the claimant is not performing SGA, the claim is sent for a determination of disability at a later step of the process. When the claim is initially developed, the adjudicator generally requests all the evidence needed for consideration at Steps 2 through 5 of the sequential evaluation process. The adjudication process stops when a decision regarding disability can be made at any step.

At Step 2, SSA determines whether the claimant’s impairment—or combination of impairments—is severe. If the claimant does not have a medically determinable impairment(s) that is severe, the claim is denied. If the claimant has a medically determinable severe impairment(s), the Agency goes to Step 3 and looks to the Listing of Impairments. If the severity of the impairment meets or medically equals a specific listing and meets the duration requirement, the individual is determined to be disabled.

If the individual’s impairment does not meet or medically equal a listing, the Agency goes to Step 4, and, if necessary, Step 5. At Step 4, the Agency determines whether the claimant can perform any past relevant work, considering his or her residual functional capacity (RFC) and the physical and mental demands of the work he or she did. If the claimant can perform past relevant work, the claim is denied. If the claimant cannot perform past relevant work, SSA goes to Step 5 and determines whether the claimant can perform any other work that exists in the national economy, considering his or her RFC, age, education, and past work experience. If the claimant can perform any other work, then SSA finds him or her not disabled; if the claimant cannot perform any other work, SSA finds him or her disabled.

Under the Act, an individual under the age of 18 is considered disabled for the purposes of Supplemental Security Income (SSI) if he or she has a medically determinable physical or mental impairment, which results in marked and severe functional limitations, and which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months.

As shown in Chart B-2, SSA has a similar sequential process with three steps for evaluating disability in children under SSI. Steps 1 and 2 are the same as for adults, with “severe” defined in terms of age-appropriate childhood functioning instead of basic work-related activities. At Step 3, SSA determines whether the impairment(s) meets or medically equals a listing or functionally equals the listings.

Appendix C
Social Security Administration and Disability Determination Services Responsibilities

Disability determinations under the Social Security Administration’s (SSA) Disability Insurance (DI) and Supplemental Security Income (SSI) programs are performed by disability determination services (DDS) in each State or other responsible jurisdiction. Such determinations are required to be performed in accordance with Federal law and underlying regulations.

Federal/State Relationship

SSA will not become involved in the States' (that is, DDS) ongoing management of the disability program except as necessary and in accordance with regulations. Therefore, to comply with regulations, the DDS needs workload controls so disability determinations are accurate and prompt. Management controls also are needed to ensure the DDS has a responsive organizational structure, adequate facilities, qualified personnel, medical consultant (MC) services, and a quality assurance function.

The State is responsible for furnishing reports and records relating to the administration of the disability program for budget submittals, and for cooperating in the conduct of audits. Consequently, appropriate reporting and fiscal controls must be used to achieve these objectives. The State also must provide adequate controls to assure that all applicants for, and recipients of, benefits are treated equally and courteously. In accounting for all property used for disability program purposes an appropriate inventory and control mechanism is required. Likewise, security controls and measures must be established that will provide for safeguarding the records created by the State in performing the disability determination function. Management must establish and maintain controls needed to assure compliance with those provisions of Federal law, regulations, and other written guidelines that apply to the States in performing the disability determination function.

SSA’s Role

SSA funds 100 percent of necessary DDS costs but is not involved in the DDS’s ongoing management of the disability program except as necessary and in accordance with regulations. SSA provides operational standards, instructions, and advice, as well as technical support and management direction to DDSs in support of SSA’s disability programs.
Specifically, SSA

• works with the DDS to provide and maintain an effective system for processing claims;
• provides program standards, leadership, liaison, and oversight;
• reviews regulations and other written guidelines periodically to ensure effective and uniform administration of the disability program;
• provides training materials—and in some instances conducts or specifies training as required by regulations;
• provides DDSs with funds for necessary costs in making disability determinations based on submitted estimates and available funding;
• monitors and evaluates DDS performance;
• maintains liaison with the medical profession nationally and with national organizations and agencies whose interests or activities may affect the disability program;
• establishes acceptable DDS performance standards for initial accuracy and initial processing time.

DDS’s Role

The DDS is a State-run agency that makes disability determinations for SSA. At most DDSs, a disability examiner (DE)—using SSA’s regulations, policies, and procedures—obtains the relevant medical evidence and then, working with an MC evaluates the case and determines whether the claimant is disabled under the Social Security Act.

Specifically, the DDS

• makes timely and accurate disability determinations;
• complies with regulations, rulings and other written guidelines, including standards established by SSA, and other provisions of Federal law and regulations that apply to the State in performing the disability determination function;
• provides management needed to carry out the disability determination function;
• provides organizational structure, facilities, qualified personnel, MC services, and a quality assurance function;
• furnishes timely reports and records;
• submits reports of expenditures as required;
• cooperates with audits;
• ensures that all applicants for and recipients of disability benefits are treated equally and courteously;
• maintains property and equipment used for disability program purposes;
• safeguards records created in making disability determinations;
• takes part in research and demonstration projects;
• maintains liaison with the medical profession and organizations that may facilitate performing the disability determination function;
• assists SSA in other ways the Agency determines may promote the objectives of effective and uniform administration; and
• establishes cooperative working relationships with other agencies concerned with servicing the disabled.

Each State is also responsible for establishing a quality assurance system, with both in-line and end-of-line reviews, designed to detect and correct errors or problems and to promote quality in all aspects of DDS claims processing.

Table C-1 shows DDS Fiscal Year 2009 workload statistics by DDS.

Table C-1: Fiscal Year 2009 DDS Workload Statistics
DDS Initial Receipts Initial Dispositions Total Dispositions Employees Processing Time (days)
DI SSI
Alabama 74,197 72,384 91,103 360 66 66
Alaska 4,585 4,374 5,286 21 95 94
Arizona 46,546 43,508 71,921 235 82 84
Arkansas 47,353 44,624 68,175 261 60 63
California 286,652 273,068 368,971 1322 78 82
Colorado 33,242 27,662 33,185 135 93 93
Connecticut 26,347 24,695 36,007 109 88 99
Delaware 6,179 6,138 9,453 41 106 105
District of Columbia 8,736 8,323 12,126 43 71 76
Florida 197,960 190,282 276,494 908 73 78
Georgia 104,251 89,377 123,164 480 97 100
Hawaii 8,421 8,090 10,430 43 83 89
Idaho 15,617 15,021 21,698 62 65 65
Illinois 105,672 96,050 140,396 474 73 77
Indiana 68,603 63,552 92,707 278 77 82
Iowa 23,431 22,956 34,076 129 74 80
Kansas 24,018 21,923 33,373 115 77 77
Kentucky 66,140 62,290 97,035 407 86 87
Louisiana 64,036 60,790 72,848 298 65 65
Maine 14,448 13,705 19,774 64 82 84
Maryland 50,751 43,938 63,116 231 86 90
Massachusetts 58,385 52,496 74,062 274 87 94
Michigan 115,664 107,181 126,332 536 98 101
Minnesota 37,917 35,579 52,069 164 71 75
Mississippi 52,463 50,331 82,814 271 75 71
Missouri 71,564 65,796 80,302 294 62 62
Montana 8,186 7,606 11,011 47 80 82
Nebraska 13,030 12,097 17,974 80 68 67
Nevada 21,816 18,874 26,712 105 86 97
New Hampshire 10,951 9,919 11,384 46 87 94
New Jersey 57,213 55,297 77,724 286 98 103
New Mexico 21,457 19,367 26,829 84 80 82
New York 162,391 156,742 206,019 822 71 76
North Carolina 99,531 100,416 147,413 472 103 105
North Dakota 3,756 3,361 5,058 24 72 84
Ohio 135,587 120,609 183,918 614 89 92
Oklahoma 42,946 39,163 58,590 227 74 79
Oregon 32,746 29,438 45,635 177 77 79
Pennsylvania 134,190 123,351 148,065 599 94 95
Puerto Rico 20,632 20,109 27,399 147 122 ***
Rhode Island 11,417 10,008 14,506 43 121 134
South Carolina 56,146 51,272 71,055 298 93 93
South Dakota 5,739 5,318 7,377 30 85 97
Tennessee 83,016 72,421 114,249 458 92 94
Texas 227,117 209,817 302,393 998 59 61
Utah 13,802 11,765 17,481 72 93 98
Vermont 5,685 5,256 7,428 33 90 88
Virginia 63,518 55,783 78,301 338 84 90
Washington 51,130 48,951 74,631 255 68 72
West Virginia 28,135 26,401 44,833 177 79 81
Wisconsin 48,651 45,951 67,627 220 109 116
Wyoming 3,463 3,186 4,079 17 72 74
Total 2,975,429 2,766,611 3,894,608 14,224 81 83
*** SSI is limited to residents of the 50 States, the District of Columbia, or the Northern Mariana Islands.
Appendix D
Quality Reviews at Disability Determinations
To ensure a high level of accuracy, the Social Security Administration’s (SSA) Office of Quality Performance conducts two types of Federal quality reviews of disability claims—the Quality Assurance Review and the Pre-Effectuation review. According to the Social Security Act (the Act), the Quality Assurance Review is designed to assess the disability determination services’ (DDS) performance and provide a statistically valid measure of individual DDS performance in terms of decision accuracy and documentation requirements for Disability Insurance claims. The review includes an equal number of both DDS allowances and denials. The purpose of the Pre-Effectuation review is to detect and correct erroneous favorable determinations before they are effectuated. As shown in Table D-1, in Fiscal Years (FY) 2005-2009, the net accuracy of DDS initial determinations, as determined by the Quality Assurance Review, ranged from 96.2 to 96.8 percent.
Table D-1: Net Accuracy Rates: Federal Quality Assurance Reviews of DDS Initial Disability Determinations
Fiscal Year Disability Determinations Cases Reviewed Changed Decisions Net Accuracy
2009 Allowances 987,793 15,553 144 99.1%
Denials 1,691,045 15,623 696 95.5%
All 2,678,838 31,176 840 96.8%

2008 Allowances 909,223 16,087 183 98.9%
Denials 1,615,624 16,551 801 95.4%
All 2,524,847 32,638 984 96.6%

2007 Allowances 854,372 16,835 242 98.4%
Denials 1,612,180 16,842 753 95.6%
All 2,466,552 33,677 995 96.6%

2006 Allowances 870,027 17,492 281 98.1%
Denials 1,604,441 20,698 946 95.1%
All 2,474,468 38,190 1,227 96.2%

2005 Allowances 914,062 16,979 292 98.0%
Denials 1,646,402 20,726 895 95.3%
All 2,560,464 37,705 1,187 96.3%

The Act requires SSA to report to the Committee on Ways and Means of the House of Representatives and to the Committee on Finance of the Senate on the pre-effectuation reviews conducted during the previous fiscal year. The Act requires that SSA review at least 50 percent of all State DDS initial and reconsideration allowances and a sufficient number of continuing disability review continuances to ensure a high level of accuracy in such determinations. Additionally, the Act requires that SSA select and review those determinations deemed most likely to be incorrect. As shown in Table D 2, in FYs 2005-2008, the accuracy of DDS initial and reconsideration allowance decisions, as determined in SSA's Pre-Effectuation reviews, ranged from 97.9 to 98.7 percent.

Table D-2: Net Accuracy Rates: Federal Pre-effectuation Reviews of DDS Initial and Reconsideration Disability Determination Allowances
Fiscal Year Claims Allowed Cases Reviewed Changed to Denials Accuracy Rate
2008 805,756 434,847 (54.0%) 5,487 98.7%

2007 756,637 380,844 (50.3%) 6,694 98.2%

2006 571,272 295,336 (51.7%) 5,889 98.0%

2005 606,199 319,525 (52.7%) 6,659 97.9%

Appendix E
Details of American Association of Social Security Disability Consultants Allegation

Below is a summary of the allegation received from the American Association of Social Security Disability Consultants (AASSDC).

For many years, disability consultants have been aware of the occasional destruction of their opinions (case assessments) by persons who disagreed with their conclusions. Related problems have been the altering of opinions without the consultant’s knowledge or consent, the pressuring of consultants to produce opinions having specific conclusions, and the seeking of the opinions of specific consultants for the purpose of obtaining specific results (“doctor shopping”). We believe that these practices are inconsistent with the Social Security Administration’s (SSA) interest in a fair and honest adjudicatory process and should be curtailed. Because, prior to the creation of our Association, consultants had no effective representation with Congress or SSA, these concerns had not been raised.

The national standard for the creation and preservation of records, used in almost all financial, medical and governmental entities, requires that anything placed in records remain in those records permanently without alteration. Changes in facts or opinions are noted by amending the records, not by destroying or altering prior records. Financial, medical and governmental institutions are expected to establish policies for the preservation of records prior to opening their doors. For example, a financial institution is expected to guarantee the preservation of depositors records and assets from the outset. Depositors are not asked to demonstrate losses in order to obtain those guarantees. Similarly, SSA should have guaranteed the integrity of claimants' records at all levels from the first days of the disability program and long ago have effectuated that guarantee through policy statements, regulations and employee training.

In February 2010, the AASSDC followed up on the allegation above and stated concerns regarding this review as follows:

that because parts of the survey were carried out using State disability determination service computer systems, many consultants, fearing reprisals, did not feel free to answer the Inspector General’s questions fully and honestly.

that because consultants have no way of tracking the fate of their opinions, they probably have not been aware of most instances of the destruction or alteration of their opinions,

that a finding a “low” frequency of these problems not be seen as acceptable, and

that in most states, consultants are forced to sign contracts which allow their termination with little or no notice. In no case is a reason required for termination. As long as consultants have so few rights under these contracts, various forms of pressure, such as requiring the pre-approval of opinions prior to placing them in a file, can be expected even if policies prohibiting the destruction and surreptitious alteration of consultant opinions are established.

Appendix F
Disability Determination Services Employee Questions

Our review included position specific questions for sampled disability determination services (DDS) employees as listed below.

Table F-1 shows questions for our sample population of DDS medical consultants (MC).

Table F-1 : DDS Medical Consultant Questions
1. How long have you been with the DDS?
2. How are cases assigned to you for review?
3. If an examiner, DDS management or Disability Quality Branch reaches a different conclusion than your assessment what generally happens?
4. What is your opinion of the process used to resolve differences relating to assessments? How can it be improved?
5. Have you ever been asked to prepare or revise an assessment to allow a case when you believe it should be denied (or vice versa)? Or have you been pressured to produce assessments having certain conclusions?
6. If above was answered “yes” – did DDS management explain any consequences if you failed to comply?
7. Are you aware of any instances where a case was or was not assigned to you to review because a certain result was desired? If yes, please explain.
8. Do you know of any instance regarding an assessment you prepared that was not included or was removed from claim folder?
9. Have any of your assessments been altered without your knowledge or consent? If yes, explain and provide Social Security Number (SSN) of claim if possible.
10. If you answered “Yes” to questions #8 or #9 did you bring this matter to DDS management and what did they say and/or do? Can you provide us the SSNs of the claim involved?
11. Do you have any additional thoughts you would like to share with us?

Table F-2 shows questions for our sample population of DDS disability examiners (DE).

Table F-2 : DDS Disability Examiner Questions
1. How long have you been with the DDS?
2. What is your role in assigning cases to medical consultants?
3. How frequently do you and a medical consultant reach different conclusions on a case?
4. If you ever reached a different conclusion than a medical consultant’s assessment, how was it resolved (did you talk with the medical consultant about it, talk with DDS management, just let it go, etc.)?
5. How much weight do you put on a medical consultant’s assessment(s) when deciding whether to allow or deny a case?
6. How frequently do you remove a medical consultant’s assessment from a claim folder?
7. If you ever removed a medical consultant’s assessment from the claim folder, please explain why.
8. Do you ever select a specific medical consultant to review a case because a certain result is desired? If yes, please explain.
9. Do you have any additional thoughts you would like to share with us?

Table F-3 shows questions for our sample population of DDS administrators.

Table F-3 : DDS Administrator Questions
1. How long have you been with the DDS?
2. Do you provide written or verbal guidance to DDS staff regarding how individual cases are assigned to medical consultants for review? How long has this guidance been in place? Please provide a short summary of the guidance.
3. How frequently do you resolve differing opinions between an examiner and medical consultant?
4. If an examiner and a medical consultant have differing opinions regarding an assessment, how is it handled?
5. Do you ever direct an examiner or medical consultant to modify their initial assessment/conclusion?
6. If a medical consultant and DDS Management have differing opinions regarding an assessment, how is it handled?
7. If the Disability Quality Branch has a different opinion than a medical consultant’s assessment, how is it handled?
8. Has any doctor brought to your attention a assessment that was altered or
deleted from the claim folder without his/her knowledge or consent? If yes, explain and provide SSN of claim if possible.
9. Are you aware of any instance where a case was assigned to a specific medical consultant to review because a certain result was desired? If yes, please explain.
10. Do you have any additional thoughts you would like to share with us?

Appendix G
Scope, Methodology, and Sample Results

To achieve our objective, we:

• Reviewed applicable Federal laws and regulations, as well as, Social Security Administration (SSA) policies and procedures.
• Reviewed prior Office of the Inspector General reports.
• Contacted SSA’s regional offices and the Office of Disability Determinations for input on our review.
• Contacted other disability insurance providers for input on our review.
• Contacted disability determination services (DDS) administrators from each of the 52 DDSs (50 States plus the District of Columbia and Puerto Rico) about the processing and documenting of medical consultant (MC) assessments.
• Obtained listings of DDS disability examiners (DE) and MCs from each DDS Administrator. Using these lists, we contacted four DEs and four MCs randomly selected from each DDS and asked about the processing and documenting of MC assessments.
• For each DDS Administrator, DE, and MC sampled, we:
o Emailed background information regarding our review and asked position specific questions.
o Followed up twice with non-responsive individuals. For those who responded, we recorded and categorized information provided regarding the processing and documenting of MC assessments.
• Reviewed procedures and controls for altering and deleting documents from the (official disability) certified electronic folder contents.
• Reviewed examples of claims with a MC assessment deleted from the disability folder.

We conducted our review between November 2009 and April 2010 in Boston, Massachusetts and Baltimore, Maryland. The principal entity audited was the Office of Disability Determinations under the Deputy Commissioner for Operations. We conducted our review in accordance with the Council of the Inspectors General on Integrity and Efficiency’s Quality Standards for Inspections.

SAMPLE RESULTS

Table G-1: Audit Population and DDS Staff Participating in Our Review
DDS Position Population Sampled Participants
Medical Consultant 2,240 208 189 (91%)
Disability Examiner 8,172 208 197 (95%)
Administrator 52 52 52 (100%)
TOTAL 10,464 468 438 (94%)

Table G-2 shows the number of DEs and MCs obtained from each DDS Administrator. From each DDS population, we randomly sampled 4 MCs and 4 DEs and asked about the processing and documenting of MC assessments.

Table G-2: Audit Population-Medical Consultants and Disability Examiners by DDS
DDS Number of Medical Consultants Portion of Population Number of Disability Examiners Portion of Population
Alabama 56 2.50% 155 1.90%
Alaska 7 0.31% 12 0.15%
Arizona 58 2.59% 123 1.51%
Arkansas 22 0.98% 157 1.92%
California 180 8.04% 788 9.64%
Colorado 28 1.25% 64 0.78%
Connecticut 39 1.74% 80 0.98%
Delaware 13 0.58% 25 0.31%
District of Columbia 7 0.31% 26 0.32%
Florida 175 7.81% 361 4.42%
Georgia 85 3.79% 273 3.34%
Hawaii 15 0.67% 21 0.26%
Idaho 11 0.49% 33 0.40%
Illinois 87 3.88% 202 2.47%
Indiana 34 1.52% 168 2.06%
Iowa 33 1.47% 73 0.89%
Kansas 27 1.21% 68 0.83%
Kentucky 40 1.79% 283 3.46%
Louisiana 41 1.83% 120 1.47%
Maine 15 0.67% 44 0.54%
Maryland 33 1.47% 110 1.35%
Massachusetts 84 3.75% 182 2.23%
Michigan 82 3.66% 290 3.55%
Minnesota 32 1.43% 100 1.22%
Mississippi 34 1.52% 165 2.02%
Missouri 50 2.23% 145 1.77%
Montana 11 0.49% 20 0.24%
Nebraska 18 0.80% 41 0.50%
Nevada 18 0.80% 49 0.60%
New Hampshire 14 0.63% 24 0.29%
New Jersey 57 2.54% 166 2.03%
New Mexico 21 0.94% 52 0.64%
New York 90 4.02% 621 7.60%
North Carolina 58 2.59% 326 3.99%
North Dakota 9 0.40% 8 0.10%
Ohio 87 3.88% 640 7.83%
Oklahoma 34 1.52% 104 1.27%
Oregon 17 0.76% 106 1.30%
Pennsylvania 103 4.60% 267 3.27%
Puerto Rico 24 1.07% 86 1.05%
Rhode Island 19 0.85% 26 0.32%
South Carolina 36 1.61% 110 1.35%
South Dakota 14 0.63% 19 0.23%
Tennessee 69 3.08% 241 2.95%
Texas 59 2.63% 524 6.41%
Utah 23 1.03% 41 0.50%
Vermont 10 0.45% 15 0.18%
Virginia 43 1.92% 170 2.08%
Washington 64 2.86% 223 2.73%
West Virginia 20 0.89% 46 0.56%
Wisconsin 23 1.03% 170 2.08%
Wyoming 11 0.49% 9 0.11%
TOTAL 2,240 100.00% 8,172 100%

Appendix H
Case Processing Systems

In each Disability Determination Services (DDS), medical consultants (MC) and disability examiners (DE) prepare assessments electronically using the Electronic Case Analysis Tool (eCAT) or the DDS case processing system. Assessments and all evidence used in disability determinations are stored in SSA’s Electronic Folder (EF).

The EF is a web-enabled application for storage and retrieval of data—including scanned documents, computer-generated images, audio-recorded tapes, and faxed documents. This information is accessed, viewed, and shared electronically by all disability processing components. Data in the EF is stored in SSA’s central repository, located at the Agency’s National Computing Center in Baltimore, Maryland and at several DDS sites throughout the United States.

ASSESSMENTS PREPARED USING eCAT

In DDSs using eCAT, assessment information is captured in the application, combined with all case data, and sent to the EF on a Disability Determination Explanation (DDE) at the time of adjudication.

To complete the assessment, the MC or SDM must have appropriate authority to sign the assessment. Any individual with access to the case can un-sign an assessment and make changes. However, the assessment must be re-signed by a MC or a SDM before the case is completed.

Both eCAT and the DDS case processing system require claims to be certified by a MC or SDM. Only one signature is needed to certify the case.

ASSESSMENTS PREPARED USING CASE PROCESSING SYSTEMS

In DDSs not currently using eCAT, assessment forms are added to the EF as individual documents as they are prepared in the case processing system.

In general, the DDS case processing system:

• provides a way for the user to specify and display the desired form,
• provides a way to track which assessments have been signed before a case can be closed,
• provides a way to track whether a signed assessment has been unsigned and ensures forms are re-signed before a case can be closed,
• ensures that new claims are assigned to the same MC already working a case,
• does not allow an MC to be removed and another MC assigned to a case when the current MC has already certified the case, and
• maintains a history of MC status changes.

Once an assessment is in the EF, it cannot be altered or modified. It can be unsigned, but the case processing system will ensure that it is re-signed by the assigned MC or a SDM before the claim is adjudicated.

To update an assessment already placed in the EF, a new document must be added to the EF. If a prior assessment is no longer applicable, the DE can keep it or delete it from the EF. However, SSA’s policy is to remove all assessments that do not reflect the final determination on the claim. All actions, such as deleting documents from the EF, are recorded by DDS and SSA systems and can be traced to the individual responsible.

DISTRIBUTION SCHEDULE

Commissioner of Social Security
Office of Management and Budget, Income Maintenance Branch
Chairman and Ranking Member, Committee on Ways and Means
Chief of Staff, Committee on Ways and Means
Chairman and Ranking Minority Member, Subcommittee on Social Security
Majority and Minority Staff Director, Subcommittee on Social Security
Chairman and Ranking Minority Member, Committee on the Budget, House of Representatives
Chairman and Ranking Minority Member, Committee on Oversight and Government Reform
Chairman and Ranking Minority Member, Committee on Appropriations, House of Representatives
Chairman and Ranking Minority, Subcommittee on Labor, Health and Human Services, Education and Related Agencies, Committee on Appropriations,
House of Representatives
Chairman and Ranking Minority Member, Committee on Appropriations, U.S. Senate
Chairman and Ranking Minority Member, Subcommittee on Labor, Health and Human Services, Education and Related Agencies, Committee on Appropriations, U.S. Senate
Chairman and Ranking Minority Member, Committee on Finance
Chairman and Ranking Minority Member, Subcommittee on Social Security Pensions and Family Policy
Chairman and Ranking Minority Member, Senate Special Committee on Aging
Social Security Advisory Board

Overview of the Office of the Inspector General
The Office of the Inspector General (OIG) is comprised of an Office of Audit (OA), Office of Investigations (OI), Office of the Counsel to the Inspector General (OCIG), Office of External Relations (OER), and Office of Technology and Resource Management (OTRM). To ensure compliance with policies and procedures, internal controls, and professional standards, the OIG also has a comprehensive Professional Responsibility and Quality Assurance program.
Office of Audit
OA conducts financial and performance audits of the Social Security Administration’s (SSA) programs and operations and makes recommendations to ensure program objectives are achieved effectively and efficiently. Financial audits assess whether SSA’s financial statements fairly present SSA’s financial position, results of operations, and cash flow. Performance audits review the economy, efficiency, and effectiveness of SSA’s programs and operations. OA also conducts short-term management reviews and program evaluations on issues of concern to SSA, Congress, and the general public.
Office of Investigations
OI conducts investigations related to fraud, waste, abuse, and mismanagement in SSA programs and operations. This includes wrongdoing by applicants, beneficiaries, contractors, third parties, or SSA employees performing their official duties. This office serves as liaison to the Department of Justice on all matters relating to the investigation of SSA programs and personnel. OI also conducts joint investigations with other Federal, State, and local law enforcement agencies.
Office of the Counsel to the Inspector General
OCIG provides independent legal advice and counsel to the IG on various matters, including statutes, regulations, legislation, and policy directives. OCIG also advises the IG on investigative procedures and techniques, as well as on legal implications and conclusions to be drawn from audit and investigative material. Also, OCIG administers the Civil Monetary Penalty program.
Office of External Relations
OER manages OIG’s external and public affairs programs, and serves as the principal advisor on news releases and in providing information to the various news reporting services. OER develops OIG’s media and public information policies, directs OIG’s external and public affairs programs, and serves as the primary contact for those seeking information about OIG. OER prepares OIG publications, speeches, and presentations to internal and external organizations, and responds to Congressional correspondence.
Office of Technology and Resource Management
OTRM supports OIG by providing information management and systems security. OTRM also coordinates OIG’s budget, procurement, telecommunications, facilities, and human resources. In addition, OTRM is the focal point for OIG’s strategic planning function, and the development and monitoring of performance measures. In addition, OTRM receives and assigns for action allegations of criminal and administrative violations of Social Security laws, identifies fugitives receiving benefit payments from SSA, and provides technological assistance to investigations.