SOCIAL SECURITY ADMINISTRATION

IMPACT OF STATUTORY BENEFIT
CONTINUATION ON
SUPPLEMENTAL SECURITY INCOME
PAYMENTS MADE DURING
THE APPEALS PROCESS

May 2006

A-07-05-15095

AUDIT REPORT

Mission

We improve SSA programs and operations and protect them against fraud, waste, and abuse by conducting independent and objective audits, evaluations, and investigations. We provide timely, useful, and reliable information and advice to Administration officials, the 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

By conducting independent and objective audits, investigations, and evaluations, we are agents of positive change striving for continuous improvement in the Social Security Administration's programs, operations, and management and in our own office.

MEMORANDUM

Date: May 10, 2006

To: The Commissioner

From: Inspector General

Subject: Impact of Statutory Benefit Continuation on Supplemental Security Income Payments Made During the Appeals Process (A-07-05-15095)

OBJECTIVE

Our objective was to evaluate the financial impact on the general fund when recipients continue to receive Supplemental Security Income (SSI) payments while appealing a medical cessation decision.

BACKGROUND

In 1972, Title XVI of the Social Security Act established the SSI program. SSI is a nationwide Federal cash assistance program administered by the Social Security Administration (SSA) that guarantees a minimum level of income to financially needy individuals who are aged, blind or disabled. SSI benefits are financed from the general fund of the United States Treasury.

Once SSA establishes an individual is eligible for disability benefits under the SSI program, SSA turns its efforts toward ensuring only those who remain disabled continue to receive benefits. Continuing disability reviews (CDR) are performed on SSI recipients to assess whether individuals remain medically eligible for SSI payments. A decision to discontinue benefits is made when a CDR reveals the recipient no longer meets the medical requirements for disability benefits; these are referred to as medical cessation decisions. Medical cessation decisions are made by disability examiners in the Office of Central Operations and State Disability Determination Services (DDS), as well as disability specialists in the program service centers. See Appendix B for additional background information on CDRs.

Once a decision has been made that an individual is no longer eligible for disability benefits, SSA informs the recipient of its decision. Provided the individual continues to meet the non-disability requirements for SSI, payments continue for 2 months after cessation. The recipient may appeal the decision within 60 days of the date he or she receives notice that SSA has determined that the individual’s disability has ceased, or any time thereafter if good cause is shown for late filing.

The current appeals process has three administrative levels of review. First, the recipient can request that the DDS reconsider the cessation decision. Second, if the recipient is dissatisfied with the DDS decision at the reconsideration level, the recipient may request a hearing before an Administrative Law Judge (ALJ) in the Office of Disability Adjudication and Review (ODAR). , Third, the recipient may appeal the ALJ’s decision to the Appeals Council (AC). The AC may deny, dismiss, or grant the request for review. If the AC grants the request for review, the AC either issues a decision or remands the case back to an ALJ.

Public Law 98-460 § 7 provides the recipient the option for benefit continuation through the reconsideration and ALJ levels of appeal in medical cessation decisions. Benefit payments made during the appeals process are considered overpayments if the cessation decision is upheld. See Appendix C for the Scope and Methodology of our review.

RESULTS OF REVIEW

We estimate that SSA paid approximately $199.5 million in SSI payments to recipients who received an appeal decision from an ALJ between October 1, 2002 and September 30, 2004. Of this amount, we project that about $146.1 million became overpayments when an ALJ affirmed the decision that the recipient was no longer eligible to receive SSI benefits. These large overpayments were incurred because SSA’s process for making decisions on medical cessation appeals is not as efficient as it could be.

PUBLIC LAW 98-460

Twenty-seven percent of the recipients in our population whose benefits were continued as a result of Public Law 98-460 § 7 received a continuance by an ALJ (see Chart 1 and Appendix D, Table 1). For these recipients, the intent of the law—to help prevent financial hardship to recipients who appeal a medical cessation decision —was achieved. However, for the remaining 73 percent of the recipients who received a cessation decision on their appeal, we project the application of the law resulted in the recipients being overpaid $146.1 million (see Chart 1).

PUBLIC LAW 97-455

Public Law 97-455 was enacted in 1983 to protect Disability Insurance beneficiaries from being financially disadvantaged while problems in the disability decision and appeals process were addressed—specifically, problems in the lack of uniformity of DDS and ALJ decisions. At that time, approximately 65 percent of DDS medical cessation decisions were reversed by an ALJ, which placed an undue financial burden on the majority of claimants whose benefits were terminated as a result of a CDR. This concern remained in 1984 when the law was extended by Public Law 98-460 to encompass SSI recipients. During the period of our review, the ALJ reversal rate for SSI medical cessation appeals was 27 percent. Therefore, it appears SSA’s enhancements to the disability determination process, such as process unification, have improved the uniformity of DDS and ALJ decisions.

OVERPAYMENTS RESULTING FROM CESSATION DECISIONS

Of the projected $146.1 million in overpayments identified for our cessation population, we project that only $5.2 million (3.5 percent) was collected, and approximately $49.7 million (34 percent) is in the process of being collected through installment payments (see Chart 2). Furthermore, we project that SSA has not yet determined what action to take on approximately $26.8 million (18.3 percent) of the overpayments. We project that the remaining $64.5 million (44.1 percent) in overpayments were waived, deemed uncollectible by SSA, or collection of the overpayment was suspended.

Waived

We project that SSA waived approximately $30.4 million (20.8 percent) of the overpayments identified in our population (see Chart 2 and Appendix D, Table 2). When overpayments are waived, the recipient is relieved from ever having to repay the funds to SSA. Accordingly, the funds will never be returned to the general fund. SSA grants SSI overpayment waivers when the recipient is not at fault for the overpayment and recovery would:

be against equity and good conscience;
impede effective and efficient administration because of the small amount involved; or
defeat the purpose of SSI.

Collection Suspended

We project that collection was suspended for approximately $24.5 million (16.7 percent) of the overpayments identified in our population (see Chart 2 and Appendix D, Table 2). Debt in which collection is suspended is eligible for future benefit offset should the individual return to SSA’s benefit rolls.

Uncollectible

We project that approximately $9.6 million (6.6 percent) of the overpayments identified in our population were deemed uncollectible (see Chart 2 and Appendix D, Table 2). When an overpayment is deemed uncollectible, the recipient is relieved from ever having to repay the funds to SSA. Accordingly, the funds will never be returned to the general fund.

LENGTH OF APPEAL

SSA’s process for making decisions on medical cessation appeals could be more efficient to help reduce the amount of overpayments recipients incur during the appeals process. Specifically, SSA does not require medical cessation appeals to be given processing priority at the reconsideration level, even though they involve benefit outlays. Furthermore, although ALJs have instructions for medical cessation appeals to be given priority processing, the results of our review show that these cases need to be expedited more than the instructions currently require. Since reconsideration and ALJ appeals are not being processed timely and they involve benefit outlays, large overpayments are incurred. Given that medical cessation appeals often result in large overpayments, they should not be processed in the same manner as those cases that are not receiving payments. Therefore, appeals that involve benefit payments should be processed separately from those that do not involve payments to avoid or minimize overpayments.

Of the projected $146.1 million in overpayments incurred by individuals that were determined to be no longer eligible for SSI payments, we project:

$43.9 million occurred at the reconsideration level of appeal;
$88.3 million occurred at the ALJ level of appeal; and
$13.9 million occurred between levels of appeal.

Reconsideration

We project that SSA paid approximately $43.9 million in SSI payments during the reconsideration level of appeal to recipients in our cessation population. The median processing time for the reconsiderations was 195 days. A reconsideration appeals process with a median processing time of 195 days is not financially efficient because it results in larger than necessary overpayments to SSI recipients. To minimize overpayments, SSA needs a process that results in timely decisions on medical cessation reconsiderations. If SSA would have completed the reconsiderations in our population within 30 to 60 days, we project that overpayments of between $37.5 and $42.1 million could have been avoided (see Chart 3 and Appendix D, Table 4).

Under the Commissioner’s New Approach to improve the Social Security disability claims process, the reconsideration level of appeal will eventually be eliminated. It is our understanding that the reconsideration stage will be replaced by a Federal reviewing official who would review initial State agency denials if a claimant appeals. However, the new process, as it was presented in the Notice of Proposed Rule Making, is not clear as to what impact it will have on medical cessation appeals.

Administrative Law Judge Appeals

We project that SSA paid approximately $88.3 million in SSI payments to recipients in our population during the ALJ level of appeal. While ALJs are instructed to assign disability cessation cases immediately to avoid or minimize overpayments, the results of our review show that the instructions are not effective because large overpayments are being incurred.

The median processing time for ALJ appeals in our sample was 366 days. A process, with such a lengthy median processing time, is not financially efficient for claims that are receiving benefit payments. SSA needs to develop a process to make ALJ decisions on medical cessation appeals more timely.
If SSA would have completed the ALJ appeal on cases in our population within 60 to 120 days, we project that overpayments of between $61.7 and $75 million could have been avoided (see Chart 4 and Appendix D, Table 5).

Payments Stopped Untimely

We project that SSA paid approximately $13.9 million to SSI recipients in our cessation population between levels of appeal (see Appendix D, Table 6). This entire amount was avoidable because benefits were not terminated timely when a CDR, reconsideration, or ALJ decision was made to discontinue benefits and the recipient had not yet appealed to the next level. After a recipient has been notified of SSA’s initial or reconsideration decision, and a timely request for appeal has not been made, payments should be ceased. However, payments can be reinstated when a request for appeal to the reconsideration or ALJ level is filed. Payments may not be timely stopped following a medical cessation decision, or an upheld appeal decision, if the proper coding is not entered in the computer system.

CONCLUSION AND RECOMMENDATIONS

We found that 73 percent of individuals in our population who appealed a CDR decision, and continued to receive payments throughout the appeals process, were overpaid. The overpayments were increased because SSA’s process for deciding medical cessation appeals is financially inefficient. Medical cessation appeals should not be processed in the same manner as cases not receiving payments. Therefore, appeals that involve benefit payments should be processed separately from those that do not involve payments to avoid or minimize overpayments.

The President’s Management Agenda introduced the initiative of improved financial performance throughout Government agencies. By making SSA’s process for medical cessation determinations more efficient it would be better aligned with the President’s vision. If SSA would develop a process for making decisions on medical cessation appeals in a timely manner, financial performance of the SSI program could be greatly increased. For example, if SSA decreased the processing time on the reconsideration and ALJ medical cessation appeals to 60 and 90 days, respectively, we project overpayments of $105.8 million could have been avoided for Fiscal Years (FY) 2003 and 2004. Based on the average of these 2 years, we estimate SSA could have avoided an additional $52.9 million in overpayments in FY 2005. Furthermore, we project SSA could have avoided overpayments of approximately $13.9 million if payments were timely stopped between levels of appeal.

The President’s Management Agenda also emphasizes the Government’s need to reform its operations in how it conducts business and how it defines business. SSA owes it to the American people to ensure that the resources entrusted to the Federal Government are well managed and wisely used. It is not only beneficial, but necessary for SSA to increase performance and citizen satisfaction by expediting cases that receive payments during the appeals process. To operate more efficiently, SSA needs to develop a new business process for cases in which benefits are being continued throughout the appeals process. Therefore, we recommend that SSA:

1. Enhance the business process to allow more timely decisions on medical cessation appeals.

2. Remind SSA components of the proper procedures for terminating SSI benefits following medical cessation decisions.

AGENCY COMMENTS

SSA agreed with all of our recommendations. The full text of SSA’s comments is included in Appendix E.

Patrick P. O’Carroll, Jr.

Appendices
APPENDIX A – Acronyms

APPENDIX B – Background on Continuing Disability Reviews

APPENDIX C – Scope and Methodology

APPENDIX D – Population and Sample Results

APPENDIX E – Agency Comments

APPENDIX F – OIG Contacts and Staff Acknowledgments

Appendix A
Acronyms

AC Appeals Council
ALJ Administrative Law Judge
CDR Continuing Disability Review
C.F.R. Code of Federal Regulations
DDS Disability Determination Services
FY Fiscal Year
HALLEX Hearings, Appeals, and Litigation Law Manual
ODAR Office of Disability Adjudication and Review
POMS Program Operations Manual System
SSA Social Security Administration
SSI Supplemental Security Income
SSR Supplemental Security Record
U.S.C. United States Code

Appendix B
Background on Continuing Disability Reviews

The Social Security Administration (SSA) is required to conduct periodic continuing disability reviews (CDR) on individuals who receive Supplemental Security Income (SSI) payments. The purpose of CDRs is to assess whether individuals remain medically eligible for SSI payments. CDRs are conducted at various intervals. Specifically:

Individuals with a significant potential for medical improvement are selected for review within the first 6 to 18 months of eligibility;
Individuals with a lower probability of medical improvement are reviewed every 3 years; and
Individuals with no expectation of medical improvement are scheduled for review every 7 years.

In addition, SSA is required to perform:

disability redeterminations for 18-year-old recipients using adult eligibility criteria for initial claims;
CDRs not later than 12 months after birth for children where low birth weight is a contributing factor material to the determination of disability; and
CDRs at least once every 3 years for children under age 18 with impairment(s) that are likely to improve (or, at the option of the Commissioner, recipients whose impairments are unlikely to improve).

SSA is required to report to Congress the number of CDRs performed each year to meet legislative or regulatory requirements:

Title II of the Social Security Act requires SSA to report to Congress annually on the results of periodic CDRs under the Social Security Disability Insurance program.
Title XVI of the Social Security Act requires SSA to report on the number of SSI CDRs and redeterminations in an annual report on the SSI program.

Processing CDRs

SSA conducts CDRs using one of two methods: full medical reviews or questionnaires (mailers).

Full Medical Reviews

Full medical reviews are primarily conducted by Disability Determination Services (DDS) located in each State and the District of Columbia in accordance with Federal regulations. SSA’s field offices send CDR cases to the DDSs throughout the year for processing. SSA initiates these CDRs for various reasons, including:

routine scheduling of a medical review (this is sent out as a “direct release”);
responses to a CDR mailer indicating that the individual’s medical condition may have improved;
receipt of information that an individual’s condition has improved and/or the individual has been working (this is sent out as a “work CDR”); or
testing the reliability of SSA’s systems and/or verifying assumptions through a full medical review.

SSA’s folder processing centers send the case folder (which contains background and medical information on the individual) selected for a full medical CDR to the appropriate SSA field office for development. Field office personnel review the information in the case folder, interview the individual, and update pertinent facts in the folder prior to sending the case to the DDS for a full medical review. DDS medical examiners, using information in the case folder, determine if additional tests are necessary. Based on this information, a decision is made as to whether the individual is still disabled.
CDR Mailer Questionnaires

CDR mailers are questionnaires sent to disabled individuals asking whether the recipient has been employed, attended school or training, been told by a doctor whether he or she can work, has gone to a doctor or clinic for treatment, or has been hospitalized or had surgery. If the answers to the questions indicate the individual’s condition may have improved, the case is referred to a DDS office for a full medical review to determine whether the individual is still disabled.
Appendix C
Scope and Methodology

To accomplish our objective we:

Reviewed -
Program Operations Manual System DI 12027, DI 28080, GN 02201,
SI 02201, SI 02260, SI 04005, SI 04030, SM 00614, and SM 01601
Hearings, Appeals, and Litigation Law Manual I-2-1-55
20 Code of Federal Regulations Sections 416.101, 416.110, 416.990, 416.996, 416.1001, and 416.1417
Public Law 98-460 § 7
Sections 221, 1601, 1614, 1631, and 1637 of The Social Security Act
42 United States Code Sections 421, 1381, 1382, and 1383

Reviewed prior Office of the Inspector General audit reports related to overpayments and continuing disability reviews (CDR).

Interviewed Social Security Administration (SSA) staff from the Office of Disability and the Office of Disability Adjudication and Review (ODAR) to obtain an understanding of (1) the CDR process, (2) appeals process for disability cessations, and (3) the treatment of overpayments.

Obtained a file from the Office of Disability and Income Security Programs of all 25,786 individuals who received an Administrative Law Judge (ALJ) decision for medical cessation between October 1, 2002, and September 30, 2004. From this file, we identified a population of 23,198 individuals who continued receiving Supplemental Security Income payments while appealing SSA’s CDR decision that they were no longer disabled.

Separated the population of 23,198 into two groups:
6,261 recipients (27 percent) who received a continuation at the ALJ level of appeal and
16,937 recipients (73 percent) whose cessation was affirmed at the ALJ level of appeal.

Selected a random sample of 250 cases from each of the two groups for a total sample size of 500 cases.

Analyzed recipient information available on SSA’s electronic systems—including the Supplemental Security Record (SSR) and the ODAR query—and projected our results to the population.

We conducted our audit in Kansas City, Missouri between February and December 2005. We determined that the data used for this audit was sufficiently reliable to meet our audit objective. The entity audited was SSA field offices and program service centers under the Office of Central Operations and ODAR. We conducted our audit in accordance with generally accepted government auditing standards.

Appendix D
Population and Sample Results

Of the 25,786 recipients who received an Administrative Law Judge (ALJ) decision for medical cessation between October 1, 2002 and September 30, 2004, we identified a population of 23,198 recipients who continued to receive Supplemental Security Income payments during the appeals process. An ALJ affirmed the cessation decision for 16,937 recipients and continued benefits for 6,261 recipients.

Our analysis of 250 cases where benefits were ceased identified 234 recipients who received payments during the appeals process totaling over $2.1 million that were subsequently considered overpayments. In addition, we conducted analysis on the overpayments to determine what the Social Security Administration’s (SSA) recovery activities were for each individual. Our analysis of 250 cases allowed to continue to receive benefits identified 242 recipients who received payments during the appeals process totaling over $2.1 million. The following tables reflect the sample results and projections based on our audit.

Table 1: Population and Sample Size
Continuance Cessation Total
Population size 6,261 16,937 23,198
Percent of total population 27% 73% 100%
Sample size 250 250 500
Number of Cases
Cases Identified in Sample 242 234 476
Point Estimate 6,061 15,853 21,914
Lower Limit – Quantity 5,908 15,322
Upper Limit – Quantity 6,159 16,247
Associated Dollar Amount
Payments Identified in Sample $2,130,675 $2,156,4802,
$4,287,155
Point Estimate $53,360,614 $146,097,190 $199,457,804
Projection Lower Limit $49,673,526 $136,617,822
Projection Upper Limit $57,047,702 $155,576,558

Table 2: Overpayment Recovery Activities
Collected Collection In Process Waived Collection Suspended Uncollectible Undetermined
Identified in Sample $76,226 $733,390 $448,661 $360,966 $141,811 $395,426
Percent of Sample 3.5% 34% 20.8% 16.7% 6.6% 18.3%
Point Estimate $5,164,186 $49,685,691 $30,395,907 $24,454,694 $9,607,401 $26,789,310
Projection Lower Limit $3,325,007 $40,420,941 $23,164,063 $18,133,447 $5,192,779 $19,793,023
Projection Upper Limit $7,003,365 $58,950,442 $37,627,751 $30,775,941 $14,022,024 $33,785,596

Table 3: Breakdown of Overpayments Incurred By Level of Appeal
Reconsideration ALJ Between Levels of Appeal
Identified in Sample $647,472 $1,303,186 $204,722
Percent of Sample5
30% 60.4% 9.5%
Point Estimate $43,864,941 $88,288,261 $13,869,533
Projection Lower Limit $40,065,597 $81,039,956 $11,891,401
Projection Upper Limit $47,664,285 $95,536,565 $15,847,666

Table 4: Savings at Reconsideration
Reconsideration Appeal not Complete in:
30 Days 60 Days
Identified in Sample $621,433 $553,983
Percent of Sample 96% 85.6%
Point Estimate $42,100,858 $37,531,256
Projection Lower Limit $38,337,972 $33,836,936
Projection Upper Limit $45,863,745 $41,225,576

Table 5: Savings at ALJ Level
ALJ Appeal not Complete in:
60 Days 90 Days 120 Days
Identified in Sample $1,106,729 $1,008,464 $910,249
Percent of Sample 84.9% 77.4% 69.8%
Point Estimate $74,978,670 $68,321,399 $61,667,546
Projection Lower Limit $68,276,628 $61,845,670 $55,437,378
Projection Upper Limit $81,680,713 $74,797,129 $67,897,714

Table 6: Overpayments Incurred Between Levels of Appeal
Before Reconsideration Before ALJ Before Appeals Council Total
Identified in Sample $20,163 $178,422 $6,138 $204,723
Percent5
.9% 8.3% .3% 9.5%
Point Estimate $1,365,979 $12,087,745 $415,809 $13,869,533
Projection Lower Limit $782,482 $10,247,073 $179,186
Projection Upper Limit $1,949,475 $13,928,417 $652,433

Appendix E
Agency Comments

MEMORANDUM
Date: May 4, 2006

To: Patrick P. O'Carroll, Jr.
Inspector General

From: Larry W. Dye
Chief of Staff

Subject: Office of the Inspector General (OIG) Draft Report, "Impact of Statutory Benefit Continuation on Supplemental Security Income Payments Made During the Appeals Process"
(A-07-05-15095)--INFORMATION

We appreciate OIG’s efforts in conducting this review. Our comments on the draft report’s recommendations are attached.

Please let me know if you have any questions. Staff inquiries may be directed to
Ms. Candace Skurnik, Director, Audit Management and Liaison Staff, at extension 54636.

Attachment:
SSA Response

COMMENTS ON THE OFFICE OF THE INSPECTOR GENERAL’S (OIG) DRAFT REPORT, “IMPACT OF STATUTORY BENEFIT CONTINUATION ON SUPPLEMENTAL SECURITY INCOME PAYMENTS MADE DURING THE APPEALS PROCESS” (A-07-05-15095)

Thank you for the opportunity to review and provide comments on this draft report. Overall, the Agency supports the purpose of this audit but has several concerns regarding the results.

We disagree with the conclusion that appeals for which benefits are being paid should be processed completely separately from appeals where benefits are not being paid. Two of our top goals are to: (1) deliver high-quality, citizen-centered service in a timely and efficient manner; and (2) ensure superior stewardship of Social Security programs and resources. Financial efficiency is not the single goal of the Social Security programs, especially when it comes to needy disabled individuals. We have a duty to serve all citizens in a timely and efficient manner. We also have a duty to follow the requirements of law as set forth in Congressional statutes, Agency regulations and in Federal court decisions, which may dictate priorities that are at odds with financial efficiency considerations alone.

Furthermore, it is unrealistic to suggest that reconsiderations of medical cessations can be completed within 30 days on average or that hearing decisions by an Administrative Law Judge (ALJ) on such cases can be completed within 60 days on average. In this regard, it appears from footnote 18 (page 7) that the report has overlooked the fact that a recipient who requests reconsideration of a medical cessation must be offered the opportunity for a face-to-face evidentiary hearing with a disability hearing officer employed by an adjudicatory unit other than the one that made the decision being appealed (20 C.F.R. §416.1414ff). Scheduling, sending the required notice at least 20 days before the hearing, and holding an evidentiary hearing only adds time to a process where initial disability decisions currently average over 90 days to process. It is incorrect to say that reconsiderations and hearings merely consist of a reexamination of existing evidence. We do not believe that processing disability cessation reconsiderations in approximately twice that time is “untimely.” As for ALJ hearings, this report offers no basis for the assumption that such hearing decisions can be successfully completed within 60 days on average.

Recommendation 1

Enhance the business process to allow more timely decisions on medical cessation appeals.

Comment

We agree. Enhancing the business process may allow for improved stewardship and more timely decisions regarding Supplemental Security Income (SSI) cessation cases and benefit continuation during the appeal period. We intend to decrease processing time in all our disability appeals through the implementation of eDib and the new disability regulations.

Processing times reflected in the report indicate that we are following the regulations and ALJs are following HALLEX guidelines that include assignment of continuing benefit disability cessation cases as 7th of 11 categories of priority cases they may be processing. There are significant reasons for the categorization of these priorities and we cannot justify moving this category of cases ahead of the others. Although we recognize our responsibility to stewardship, we must at times balance that against service obligations. Therefore, at this time we are not in a position to support segregating cases that are receiving benefit continuation and processing those cases first.

Recommendation 2

Remind SSA components of the proper procedures for terminating SSI benefits following medical cessation decisions.

Comment

We agree. We will remind the appropriate components of the proper procedures for terminating SSI benefits following medical cessation decisions. Also, it should be noted that SSA implemented systems enhancements in January and April 2004 which automatically handle payment termination in Statutory Benefit Continuation cases with Office of Hearings and Appeals (OHA) or Disability Determination Service (DDS) involvement, respectively. When the termination decision is received from the DDS or ALJ, the SSI system automatically terminates the benefit continuation according to established guidelines. Manual intervention is not required. In addition, systems controls are in place to ensure that these cases can be tracked.

Appendix F
OIG Contacts and Staff Acknowledgments

OIG Contacts

Mark Bailey, Director, Kansas City Audit Division (816) 936-5591

Shannon Agee, Audit Manager (816) 936-5590

Acknowledgments

In addition to those named above:

Khristan Kaufman, Auditor

Kenneth Bennett, IT Specialist

N. Brennan Kraje, Statistician

Cheryl Robinson, Writer-Editor

For additional copies of this report, please visit our web site at www.ssa.gov/oig or contact the Office of the Inspector General’s Public Affairs Specialist at (410) 965-3218. Refer to Common Identification Number A-07-05-15095.

DISTRIBUTION SCHEDULE

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Social Security Advisory Board

Overview of the Office of the Inspector General

The Office of the Inspector General (OIG) is comprised of our Office of Investigations (OI), Office of Audit (OA), Office of the Chief Counsel to the Inspector General (OCCIG), and Office of Resource Management (ORM). To ensure compliance with policies and procedures, internal controls, and professional standards, we also have a comprehensive Professional Responsibility and Quality Assurance program.

Office of Audit
OA conducts and/or supervises 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 and program evaluations and projects on issues of concern to SSA, Congress, and the general public.

Office of Investigations
OI conducts and coordinates investigative activity 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 OIG liaison to the Department of Justice on all matters relating to the investigations of SSA programs and personnel. OI also conducts joint investigations with other Federal, State, and local law enforcement agencies.

Office of the Chief Counsel to the Inspector General
OCCIG provides independent legal advice and counsel to the IG on various matters, including statutes, regulations, legislation, and policy directives. OCCIG 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. Finally, OCCIG administers the Civil Monetary Penalty program.

Office of Resource Management
ORM supports OIG by providing information resource management and systems security. ORM also coordinates OIG’s budget, procurement, telecommunications, facilities, and human resources. In addition, ORM is the focal point for OIG’s strategic planning function and the development and implementation of performance measures required by the Government Performance and Results Act of 1993.