OFFICE OF
THE INSPECTOR GENERAL

SOCIAL SECURITY ADMINISTRATION

Reinstatement of the Reconsideration Step in the Michigan Disability Determination Services

April 2010

A-01-10-20153

CONGRESSIONAL RESPONSE
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.

Background
OBJECTIVE

The objective of our review was to assess the impact of reinstating the reconsideration step in the Michigan Disability Determination Services (DDS) under four scenarios.

BACKGROUND

SSA provides Disability Insurance (DI) and Supplemental Security Income (SSI) to eligible individuals under Titles II and XVI of the Social Security Act. The Social Security Administration (SSA) generally refers claims for disability benefits to the State DDS for disability determinations. If the claimant disagrees with an initial disability determination, he or she can file an appeal within 60 days from the date he or she receives notice of the determination. In most States, the first level of appeal is reconsideration by the DDS.

In 1999, SSA began testing several modifications to the disability determination procedures, including the elimination of the reconsideration step in 10 Prototype States: Alabama, Alaska, California (Los Angeles North and Los Angeles West Branches), Colorado, Louisiana, Michigan, Missouri, New Hampshire, New York, and Pennsylvania. The Agency has decided to assess the effect of reinstating the reconsideration step as part of the disability claims process in Prototype States because allowing claims at the reconsideration level provides benefits earlier to some claimants who would otherwise wait for a hearing. Michigan was selected as the first Prototype State to reinstate the reconsideration step and will resume reconsiderations in Fiscal Year (FY) 2011. Decisions about other Prototype States are still pending.

On April 5, 2010, we received a request from the Subcommittee on Social Security, Committee on Ways and Means, U.S. House of Representatives, to review the impact of reinstating reconsiderations in the Michigan DDS. Specifically, the Subcommittee

requested an analysis of the cumulative average processing time for Michigan claimants under the four scenarios below for each of the following FYs: 2011, 2012, and 2013.

1. SSA implements its plan to reinstate reconsideration and fully funds the new reconsideration process.
2. SSA retains current policy in Michigan: It remains a Prototype State, and no additional funds are allocated to the Michigan DDS to process reconsiderations.
3. Michigan remains a Prototype State, and the funds SSA would have used for the reinstatement of reconsideration are provided to the Michigan DDS for processing initial claims. (This should include the impact on the level of pending initial claims at the end of each FY and the impact on average processing time at the initial claims level.)
4. Michigan remains a Prototype State, and the funds SSA would have used for the reinstatement of reconsideration are provided to Michigan hearing offices for processing ALJ hearings. (This should include the impact on the level of pending hearings at the end of each FY and the impact on average processing time at the hearings level.)

To perform this review, we gathered and reviewed data related to claims processing times and allowance rates in FYs 2008 through 2010; contacted SSA officials and staff to obtain information on how reinstatement of reconsiderations will affect SSA’s budget and operations; and researched the impact reinstatement of reconsiderations will have on DI beneficiaries and SSI recipients. Our review was an assessment of processing time changes due solely to whether or not the reconsideration step is reinstated in Michigan. We did not consider the relationship between budgeted workload receipt and pending levels on processing times. (See Appendix B for additional information on our scope and methodology.)

Results of Review

Based on available information, we assessed the impact of reinstating the reconsideration step in the Michigan DDS under four different scenarios—summarized in Table 1 below. SSA was able to provide the assumptions—specific to reinstating reconsiderations in Michigan—it used in preparing the FY 2011 budget request; however, it was not able to provide the assumptions for FYs 2012 and 2013.

Table 1: Summary of Analysis and Estimates
Scenario DDS ODAR
1 Average cumulative processing time for initial claims in FY 2011: 123 days. Processing times would not change significantly in future FYs. Average cumulative processing time in FY 2011: 915 days. Processing times may decrease in future FYs.
2 Average cumulative processing time for initial claims in FY 2011: 123 days. Processing times would not change significantly in future FYs. Average cumulative processing time in FY 2011: 762 days. Processing times would not change significantly in future FYs.
3 DDS could adjudicate about 25,300 more initial claims in FY 2011. Processing times would not change significantly in future FYs. ODAR could receive about 6,780 more hearing requests per year. Processing times would probably increase in future FYs.
4 Average cumulative processing time for initial claims in FY 2011: 123 days. Processing times would not change significantly in future FYs. ODAR could process about 17,600 additional hearings per year. Processing times would probably decrease in future FYs.

SSA implements its plan to reinstate reconsiderations and fully funds the new reconsideration process.

SSA has committed to reinstating the reconsideration step in the Michigan DDS. The Agency planned for the additional reconsideration workload in the FY 2011 budget request, estimating the Michigan DDS would receive 33,750 reconsideration claims

during the year, and 114 staff resources will be needed to process the anticipated workload. Currently, the DDS is hiring additional staff—fully funded and supported by SSA.

These additional staff and resources would allow the Michigan DDS to maintain the current level of service to claimants at the initial level. In FY 2010 (as of March 26, 2010), the DDS had processed initial DI claims in about 123 days and SSI claims in about 119 days from date of application to determination. (See Appendix C for statistics by DDS for FYs 2008, 2009, and 2010.) During the same time period at the national level, DDSs had processed DI reconsideration claims in about 276 days cumulatively from date of application through reconsideration. We assume that Michigan would process reconsideration claims in line with the national average. Historically, about 44 percent of claimants appealed initial determinations, and about 14 percent of reconsideration claims were allowed. We estimate that about 4,700 claimants would be allowed at the reconsideration level and thus receive benefits sooner than if they were to go through the entire hearing process.

The Agency does not report cumulative processing time for claims at the hearing level. However, in our December 2008 report, Disability Claims Overall Processing Times (A 01 08 18011), we determined it took SSA an average 811 days to process a disability claim from date of application through the hearing level in Calendar Year 2006, with 482 of those days spent at ODAR. In FY 2010, the five ODAR offices in Michigan have processed hearings in an average 559 days. (See Appendix D for ODAR statistics for FYs 2008 through 2010.) Historically, about 73 percent of claimants appeal reconsideration determinations. Since the hearing offices nationwide have a backlog of cases to process, reinstating the reconsideration step in the DDS would not necessarily result in decreased processing time at ODAR in FY 2011. However, as ODAR works through the backlog, processing times may decrease in future FYs.

Assuming that all appeals of initial determinations in FY 2011—which begins October 1, 2010—would be reconsiderations, there would be about a 2-month period in which ODAR would not receive new requests for hearings while the reconsiderations are being processed. Additionally, claimants allowed at the reconsideration step would not be likely to appeal to ODAR. Because of these 2 factors, SSA expects about 11,250 fewer appeals to ODAR in FY 2011.

Based on these data and assumptions, we estimate in FY 2011:

1. The Michigan DDS would process initial claims in 123 days from the date of application and reconsiderations in about 276 days from the date of initial application. Based on available information, we have no reason to believe processing times would change significantly in FYs 2012 and 2013.

2. ODAR would process appeals of reconsideration denials from the Michigan DDS in about 915 days from the date of initial application. However, the reduced number of appeals would allow ODAR to focus on processing older claims and decreasing the number of pending hearings. This could result in decreased processing times and the number of pending hearings in FYs 2012 and 2013.

Michigan remains a Prototype State, and no additional funds are allocated to the Michigan DDS to process reconsiderations.

The Michigan DDS is hiring new staff in anticipation of reinstating reconsiderations in FY 2011. SSA has already committed to supporting the DDS and funding these new hires. However, if the new staff to process reconsiderations were not hired, we assume, in FY 2011, the DDS would continue to process initial claims in 123 days from the date of application, and hearing offices in Michigan would continue to process hearings in

559 days from the date of the request for hearing—or 762 days from the date of application. Based on available information, we have no reason to believe processing times would change significantly in FYs 2012 and 2013.

Michigan remains a Prototype State, and the funds SSA would have used for the reinstatement of reconsiderations are provided to the Michigan DDS for processing initial claims.

As of March 2010, the Michigan DDS had almost 32,000 initial claims pending. SSA estimates the DDS will process about 222 initial claims per employee per year in FY 2011. The DDS is hiring new staff to process the anticipated reconsideration workload. We assume all disability examiners in Michigan, including the new staff, would continue to process initial claims, rather than reconsiderations, at the current rate. Based on these assumptions, we estimate:

1. The Michigan DDS could adjudicate about 25,300 more initial claims in FY 2011. This would result in a significant decrease in initial claims pending, approximately 9,000 additional allowances, and about 6,780 additional appeals to ODAR. Based on available information, we have no reason to believe processing times and the number of claims processed would change significantly in FYs 2012 and 2013.

2. ODAR would process appeals of initial denials from the Michigan DDS in about 762 days from the date of application. In FY 2011, the additional appeals to ODAR would not significantly impact processing time. However, without additional resources, the increased ODAR workloads would increase processing times and the number of pending hearings in FYs 2012 and 2013.

Michigan remains a Prototype State, and the funds SSA would have used for the reinstatement of
reconsiderations are provided to Michigan hearing offices for processing ALJ hearings.

The Michigan DDS is hiring new staff in anticipation of reinstating reconsiderations. SSA has already committed to supporting the DDS and funding these new hires. However, if the new staff to process reconsiderations were not hired, we assume the DDS would continue to process initial claims in 123 days from the date of filing. The funds SSA would have used to reinstate reconsiderations, totaling almost $20.6 million, could be moved to ODAR. If ODAR were able to immediately use these funds to processing hearings in FY 2011, it could process about 17,600 additional hearings.

However, according to SSA, all hearing offices nationwide are operating at full capacity, and the Agency has implemented its Plan to Eliminate the Hearing Backlog and Prevent Its Recurrence. Any funding transferred from the DDS to ODAR could be used for additional overtime for support staff to prepare more claims for hearings. Otherwise, these funds would not result in additional hearings being processed in FY 2011 because the Agency would need to acquire additional office space and hire more ALJs and support staff—which could not be fully implemented quickly. If ODAR did use these funds to acquire additional office space and hire more ALJs and support staff, we would expect the number of hearings held to increase and processing times to decrease in FYs 2012 and 2013.

BENEFITS OF REINSTATING THE RECONSIDERATION STEP

According to SSA, reinstatement of the reconsideration step in the Prototype States offers several potential benefits.

• The Agency would return to a uniform national disability determination process with the same appeal rights for all claimants. Currently, disability applications in Prototype States do not have a reconsideration step, while applicants in non-Prototype States do. Further, applicants living in one part of California have a reconsideration process while applicants in other parts of California do not.
• The reconsideration process would provide a faster first-level appeal—currently 84 days in the DDS, rather than 559 days at ODAR. Although the reconsideration allowance rate would be lower than at the initial or hearings levels, the claimants who are allowed would get positive results much sooner than if they were to go through the entire hearing process.
• The reconsideration process would moderate the volume of hearing requests. The national reconsideration allowance rate is about 14 percent, and 27 percent of those denied at the reconsideration level do not request a hearing—resulting in many new cases per year that would not proceed to hearing.
• For reconsideration denials, a well documented claim will go forward to ODAR, with less documentation needed at the hearing level for an overall more efficient process.

Conclusions
Based on the available information, we assessed the impact of reinstating the reconsideration step in the Michigan DDS under four different scenarios.

1. If SSA reinstates the reconsideration step in the Michigan DDS and fully funds the process, we estimate, in FY 2011, (a) the Michigan DDS would process initial claims in 123 days from the date of filing and reconsideration claims in 276 days from the date of filing, and (b) ODAR would process appeals of reconsideration determinations in the Michigan DDS in about 915 days from the date of initial application. Based on available information, we have no reason to believe DDS processing times would change significantly in FYs 2012 and 2013. However, as ODAR works through the backlog, processing times may decrease in FYs 2012 and 2013.

2. If the Michigan DDS continues to be a Prototype State without additional funding, we estimate, in FY 2011, (a) the DDS would continue to process initial claims in 123 days from the date of filing, and (b) ODAR would continue processing appeals of initial determinations from the Michigan DDS in 559 days from the date of the request for hearing—or 762 days from the date of initial application. Based on available information, we have no reason to believe processing times would change significantly in FYs 2012 and 2013.

3. If Michigan remains a Prototype State and funds for reinstating reconsiderations are used to process initial claims, we estimate, in FY 2011, (a) the Michigan DDS could adjudicate about 25,300 more initial claims—resulting in approximately 9,000 additional allowances and about 6,780 additional appeals to ODAR, and (b) ODAR would process appeals of initial determinations from the Michigan DDS in about 762 days from the date of application. Based on available information, we have no reason to believe DDS processing times would change significantly in FYs 2012 and 2013. However, without additional resources for ODAR, the increased workloads would increase processing times and the number of pending hearings in FYs 2012 and 2013.

4. If Michigan remains a Prototype State and funds for reinstating reconsiderations are used to process hearings, we estimate ODAR could process almost 17,600 additional hearings, if the Agency were able to immediately use these funds for processing hearings in FY 2011. However, since hearing offices nationwide are operating at full capacity, any funds transferred from DDS to ODAR would not result in additional hearings being processed in FY 2011. If these funds were used to acquire additional office space and hire more ALJs and support staff, we would expect the number of hearings held to increase and processing times to decrease in FYs 2012 and 2013.

Appendices
APPENDIX A – Acronyms
APPENDIX B – Scope and Methodology
APPENDIX C – Disability Statistics by Jurisdiction
APPENDIX D – Office of Disability Adjudication and Review Statistics

Appendix A
Acronyms

ALJ Administrative Law Judge
C.F.R. Code of Federal Regulations
DDS Disability Determination Services
DI Disability Insurance
FY Fiscal Year
ODAR Office of Disability Adjudication and Review
SSA Social Security Administration
SSI Supplemental Security Income
U.S.C. United State Code

Appendix B
Scope and Methodology

To achieve our objective, we:

• Reviewed the Social Security Act and Social Security Administration (SSA) regulations, rules, policies, and procedures on disability case processing.

• Reviewed prior Office of the Inspector General reports.

• Reviewed disability claims processing data from SSA for Fiscal Years 2008 through 2010.

• Contacted SSA officials and staff to obtain information on SSA’s budget costs, processing times, and workload information relative to reinstating reconsiderations in the Michigan Disability Determination Services. Because of time constraints, we did not independently verify the data the Agency provided.

• Estimated cumulative processing times for disability hearing decisions in Fiscal Year 2011, using results from our December 2008 report, Disability Claims Overall Processing Times (A-01-08-18011) and updating them with available Fiscal Year 2010 data. Our review was an assessment of processing time changes due solely to whether or not the reconsideration step is reinstated in Michigan. We did not consider the relationship between budgeted workload receipt and pending levels on processing times.

We conducted our review during April 2010 in Boston, Massachusetts. The principle entity reviewed was the Office of Disability Determinations under the Deputy Commissioner of Operations. We conducted our review in accordance with the Council of the Inspectors General on Integrity and Efficiency’s Quality Standards for Inspections.

Appendix C
Disability Statistics by Jurisdiction

Table C-1 shows non-Prototype State disability determination services’ (DDS) average overall processing times for Disability Insurance (DI) claims in Fiscal Years (FY) 2008 through 2010 (as of March 26, 2010).

C-1: Non-Prototype Overall Processing Times for DI Claims Sent to a DDS
DDS FY 2008 FY 2009 FY 2010
Initial Recon Initial Recon Initial Recon

Arizona 124.9 353.3 108.5 301.4 116.5 279.2
Arkansas 85.9 205.2 83.3 186.0 98.6 209.1
Connecticut 97.7 232.9 111.4 261.9 116.2 259.6
Delaware 125.5 341.9 140.1 280.0 133.5 279.9
District of Columbia 117.3 351.8 103.7 299.3 136.3 279.4
Florida 108.6 284.9 99.5 257.5 101.4 252.4
Georgia 113.8 308.9 120.4 345.9 149.7 437.5
Hawaii 116.2 374.8 113.0 313.7 128.2 329.6
Idaho 88.6 214.7 89.7 205.3 95.6 212.2
Illinois 103.8 256.3 101.5 238.4 112.6 270.6
Indiana 108.1 225.2 100.9 213.2 109.4 228.0
Iowa 96.8 246.0 91.8 219.2 92.7 224.5
Kansas 93.8 234.9 96.9 255.6 109.0 279.8
Kentucky 100.9 215.8 103.7 214.0 109.7 215.8
Maine 94.6 244.8 107.7 280.5 108.7 323.3
Maryland 110.2 300.7 117.6 306.2 156.3 356.6
Massachusetts 109.5 265.3 123.2 284.3 141.2 337.4
Minnesota 103.9 252.7 101.4 243.0 107.6 239.4
Mississippi 93.1 191.9 95.8 186.0 102.3 197.3
Montana 104.3 269.4 100.3 248.9 109.8 263.9
Nebraska 83.9 212.3 85.3 206.2 100.1 224.6
Nevada 122.7 416.0 117.1 300.3 142.6 302.0
New Jersey 151.0 391.1 127.8 343.1 137.6 331.3
New Mexico 100.4 242.2 104.4 273.2 112.6 372.5
North Carolina 115.9 271.9 124.0 293.7 108.9 283.2
North Dakota 90.1 215.8 96.1 237.9 109.7 248.6
Ohio 118.3 299.6 113.5 286.9 144.8 334.8
Oklahoma 112.3 261.1 103.3 235.4 120.1 243.3
Oregon 111.1 278.5 104.1 266.6 121.5 276.9
Puerto Rico 167.2 557.6 153.4 360.3 144.0 310.3
Rhode Island 156.4 356.3 155.5 348.4 167.9 371.9
South Carolina 109.1 267.6 116.8 287.9 128.7 354.3
South Dakota 110.2 254.3 109.9 248.3 113.9 251.2
Tennessee 117.0 287.2 114.8 260.6 135.9 276.3
Texas 93.3 216.7 89.1 198.6 104.9 214.6
Utah 108.4 267.1 115.1 250.8 138.8 263.3
Vermont 131.5 292.2 129.1 294.5 134.1 313.3
Virginia 107.5 272.3 115.1 290.9 143.9 325.8
Washington 102.8 252.1 96.1 242.6 106.0 238.8
West Virginia 98.9 243.6 101.8 246.3 107.4 241.3
Wisconsin 108.2 280.2 137.0 315.6 114.8 278.1
Wyoming 111.5 232.6 95.7 207.2 108.1 201.5

Table C-2 shows Prototype State DDS average overall processing times for DI claims in FYs 2008 through 2010 (as of March 26, 2010).

C-2: Prototype Overall Processing Times for DI Claims Sent to a DDS
DDS FY 2008 FY 2009 FY 2010
Initial Recon Initial Recon Initial Recon
Alabama 88.7 432.7 88.2 446.0 95.3 500.3
Alaska 115.3 410.8 130.0 382.4 122.8 288.6
California 111.7 282.6 100.4 250.1 111.4 282.6
Colorado 103.5 401.4 115.6 381.2 156.6 575.1
Louisiana 92.8 478.3 86.9 430.1 99.0 707.8
Michigan 107.7 832.8 120.9 656.5 122.7 572.1
Missouri 79.9 436.6 80.6 506.1 97.4 776.1
New Hampshire 129.8 462.0 124.2 360.5 146.9 948.8
New York 115.4 401.9 105.6 367.2 107.6 419.8
Pennsylvania 120.1 538.4 119.3 461.9 135.2 413.9

Table C-3 shows non-Prototype State DDS claims dispositions in FYs 2008 through 2010 (as of March 26, 2010).

Table C-3: Non-Prototype DDS Claims Dispositions
DDS FY 2008 FY 2009 FY 2010
Initial Recon Initial Recon Initial Recon
Arizona 35,247 10,558 43,508 13,024 22,126 6,935
Arkansas 43,285 13,696 44,624 13,242 22,304 7,200
Connecticut 23,536 2,186 24,695 7,444 14,083 4,515
Delaware 6,242 1,600 6,138 1,890 3,148 699
District of Columbia 5,509 1,676 8,323 1,936 4,905 829
Florida 162,414 45,510 190,282 56,727 106,892 31,857
Georgia 85,149 27,625 89,377 19,458 45,339 12,680
Hawaii 6,782 1,300 8,090 1,118 4,024 711
Idaho 11,372 2,780 15,021 3,770 7,875 2,489
Illinois 100,541 27,236 96,050 25,095 51,367 15,415
Indiana 58,842 18,213 63,552 19,063 37,765 11,514
Iowa 20,352 6,316 22,956 6,672 11,856 3,875
Kansas 20,679 6,332 21,923 5,855 11,776 3,928
Kentucky 58,899 22,468 62,290 21,925 33,387 12,387
Maine 12,062 1,149 13,705 3,922 7,135 3,311
Maryland 42,832 10,564 43,938 11,059 21,598 5,249
Massachusetts 51,021 3,912 52,496 11,525 27,213 8,343
Minnesota 34,556 11,266 35,579 10,925 19,965 6,244
Mississippi 48,289 15,869 50,331 16,816 26,976 9,626
Montana 6,674 1,940 7,606 1,905 3,758 1,081
Nebraska 11,549 3,326 12,097 3,237 6,505 1,741
Nevada 18,046 4,337 18,874 5,077 9,879 2,796
New Jersey 54,346 15,845 55,297 14,437 27,868 6,010
New Mexico 18,134 5,762 19,367 4,108 11,323 1,751
North Carolina 82,808 27,350 100,416 33,174 51,695 19,189
North Dakota 3,493 1,143 3,361 1,149 2,054 567
Ohio 123,373 34,547 120,609 42,110 63,603 17,395
Oklahoma 37,176 11,134 39,163 10,645 20,778 6,385
Oregon 26,183 7,617 29,438 9,571 16,800 4,458
Puerto Rico 16,960 9,626 20,109 5,355 10,729 2,456
Rhode Island 9,942 1,036 10,008 2,913 6,018 1,922
South Carolina 46,048 15,532 51,272 12,062 29,372 6,817
South Dakota 5,204 1,536 5,318 1,210 2,961 700
Tennessee 64,972 27,853 72,421 28,237 42,747 15,187
Texas 198,414 49,755 209,817 48,943 115,294 28,048
Utah 11,162 3,158 11,765 3,674 6,742 2,285
Vermont 4,931 414 5,256 1,231 2,884 702
Virginia 54,541 14,153 55,783 13,615 28,488 8,961
Washington 45,574 13,314 48,951 16,202 26,838 8,945
West Virginia 26,029 9,663 26,401 11,071 14,204 5,935
Wisconsin 40,903 11,405 45,951 10,903 29,646 7,092
Wyoming 2,981 565 3,186 451 1,870 426

Table C-4 shows Prototype State DDS claims dispositions in FYs 2008 through 2010 (as of March 26, 2010).

Table C-4: DDS Prototype Claims Dispositions
DDS FY 2008 FY 2009 FY 2010
Initial Recon Initial Recon Initial Recon
Alabama 62,546 342 72,384 455 39,927 361
Alaska 4,129 26 4,374 21 2,455 10
California 261,511 55,805 273,068 59,675 132,599 29,124
Colorado 27,799 165 27,662 112 14,319 63
Louisiana 54,510 345 60,790 348 32,634 178
Michigan 104,178 401 107,181 400 58,437 247
Missouri 61,737 322 65,796 267 36,432 192
New Hampshire 9,319 16 9,919 37 5,578 34
New York 150,299 1,330 156,742 1,334 86,901 546
Pennsylvania 121,703 346 123,351 372 65,951 204

Table C-5 shows non-Prototype State DDS allowance rates in FYs 2008 through2010 (as of March 26, 2010).
Table C-5: DDS Non-Prototype Allowance Rates
DDS FY 2008 FY 2009 FY 2010
Initial Recon Initial Recon Initial Recon
Arizona 36.9 20.0 34.3 17.1 31.8 15.2
Arkansas 36.1 11.1 37.1 11.7 34.3 10.1
Connecticut 33.1 14.7 31.9 14.2 31.2 11.4
Delaware 44.5 15.0 42.9 10.1 40.9 9.1
District of Columbia 44.6 22.1 40.5 17.0 47.4 19.6
Florida 33.6 14.0 34.7 14.7 33.4 13.8
Georgia 24.9 10.3 28.7 16.6 29.6 16.5
Hawaii 52.6 25.2 50.3 23.8 47.3 27.8
Idaho 39.2 10.4 38.6 10.9 34.4 10.9
Illinois 35.6 14.1 36.0 12.5 34.4 10.9
Indiana 36.2 6.8 35.1 6.6 34.0 6.6
Iowa 32.4 12.2 33.3 10.4 32.4 9.5
Kansas 36.0 16.2 38.3 18.3 39.0 18.0
Kentucky 28.8 7.7 32.3 8.8 30.4 8.3
Maine 35.7 15.5 32.4 13.3 33.0 15.5
Maryland 37.6 20.0 38.7 18.9 37.5 17.7
Massachusetts 45.7 29.0 46.2 27.4 44.6 26.4
Minnesota 37.4 12.4 39.6 11.0 37.7 9.7
Mississippi 24.5 6.9 26.6 6.9 25.2 6.2
Montana 41.6 14.6 41.5 15.0 40.5 14.4
Nebraska 37.3 12.0 38.6 12.9 39.6 14.9
Nevada 42.7 22.6 41.4 16.4 38.5 16.1
New Jersey 45.0 20.8 48.4 20.8 47.4 15.2
New Mexico 36.4 13.2 37.2 14.4 36.1 16.4
North Carolina 30.9 13.2 29.6 12.5 28.6 11.7
North Dakota 38.2 12.7 40.4 10.8 44.1 14.7
Ohio 27.1 10.5 28.6 10.4 31.1 12.8
Oklahoma 39.7 14.6 38.6 12.5 36.6 11.8
Oregon 37.4 13.2 39.9 13.1 40.3 12.8
Puerto Rico 43.7 28.1 59.8 35.5 61.7 30.2
Rhode Island 38.2 18.2 37.5 14.9 36.0 13.8
South Carolina 31.1 15.3 31.9 15.1 29.8 15.4
South Dakota 35.8 11.6 40.0 11.9 42.8 12.5
Tennessee 25.1 8.7 27.5 9.3 25.8 7.9
Texas 42.5 20.1 43.5 19.8 41.4 17.5
Utah 44.3 15.6 44.4 13.1 40.8 11.9
Vermont 48.1 15.9 48.3 15.7 44.2 21.4
Virginia 39.6 14.3 40.4 14.3 40.0 12.9
Washington 39.7 10.7 39.9 10.8 39.3 11.1
West Virginia 26.4 10.2 26.4 8.2 25.8 8.4
Wisconsin 40.3 17.8 44.1 18.2 38.9 16.2
Wyoming 48.0 10.4 51.8 7.0 49.1 4.5

Table C-6 shows Prototype State DDS allowance rates in FYs 2008 through 2010 (as of March 26, 2010).

Table C-6: DDS Prototype Allowance Rates
DDS FY 2008 FY 2009 FY 2010
Initial Recon Initial Recon Initial Recon
Alabama 31.8 22.3 31.6 17.3 30.8 20.7
Alaska 42.9 28.0 51.2 16.7 47.8 0.0
California 39.0 12.9 37.6 12.1 36.0 12.2
Colorado 34.9 21.5 39.4 20.4 38.5 31.6
Louisiana 36.6 25.7 36.2 24.9 35.4 27.3
Michigan 30.2 27.7 36.6 31.3 34.1 28.4
Missouri 33.6 28.3 33.6 27.7 32.5 22.8
New Hampshire 51.9 36.4 51.9 35.5 50.1 35.5
New York 44.3 51.2 45.0 44.2 42.1 38.2
Pennsylvania 36.7 27.9 35.3 25.9 34.0 23.5

Appendix D
Office of Disability Adjudication and Review Statistics

In April 2010, the Social Security Administration provided us data on hearing decisions. Table D-1 shows Office of Disability Adjudication and Review (ODAR) hearings processed in Michigan and nationally in Fiscal Years (FY) 2008 through 2010 (as of March 2010).
Table D-1: ODAR Hearings Processed
Michigan DDS FY 2008 FY 2009 FY 2010
Detroit 5,488 5,515 3,135
Flint 4,032 3,667 1,943
Grand Rapids 4,314 4,704 2,179
Lansing 3,818 3,719 1,807
Oak Park 4,991 6,058 2,976
Total 22,643 23,663 12,040
National Total 575,380 660,842 353,988
Table D-2 shows ODAR processing times in Michigan and nationally in FYs 2008 through 2010 (as of March 2010).
Table D-2: ODAR Processing Times
Michigan DDS FY 2008 FY 2009 FY 2010
Detroit 629 663 584
Flint 722 622 491
Grand Rapids 676 618 548
Lansing 726 636 584
Oak Park 731 674 590
Average 697 643 559
National Average 514 491 442
Table D-3 shows ODAR allowance rates in Michigan and nationally in FYs 2008 through 2010 (as of March 2010).
Table D-3: ODAR Allowance Rates
Michigan DDS FY 2008 FY 2009 FY 2010
Detroit 56% 56% 62%
Flint 61% 65% 75%
Grand Rapids 54% 53% 62%
Lansing 59% 62% 67%
Oak Park 56% 56% 64%
Average 57% 58% 66%
National Average 63% 63% N/A

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.