Office of the Inspector General
Larry G. Massanari
Acting Commissioner of Social Security

Inspector General

Audit of Enumeration at Birth Program (A-08-00-10047)

The attached final report presents the results of our audit. Our objectives were to determine whether (1) participating hospitals and Bureaus of Vital Statistics provide the Social Security Administration (SSA) accurate and reliable information under the Enumeration at Birth program and (2) SSA’s internal controls adequately protect the integrity of the process.

Please comment within 60 days from the date of this memorandum on corrective action taken or planned on each recommendation. If you wish to discuss the final report, please call me or have your staff contact Steven L. Schaeffer, Assistant Inspector General for Audit, at (410) 965-9700.

James G. Huse, Jr.

SOCIAL SECURITY ADMINISTRATION

Executive Summary

The objectives of the audit were to determine whether (1) participating hospitals and Bureaus of Vital Statistics (BVS) provide the Social Security Administration (SSA) accurate and reliable information under the Enumeration at Birth (EAB) program and (2) SSA’s internal controls adequately protect the integrity of the process.

Implemented in 1990, the EAB program assigns Social Security numbers (SSN) to newborns, with parental approval, as part of States’ and certain jurisdictions’ birth registration processes. SSA developed the EAB process in response to increased demand for SSNs for children at earlier ages, especially for tax and other financial requirements. SSA recognized that all the information needed to process an SSN application for a newborn was captured during the hospital birth registration process. Therefore, SSA contracted with State and certain jurisdiction BVSs to obtain birth registration data. The birth registration data serve as evidence of age, identity, and citizenship for purposes of assigning an SSN to a child. SSA designed EAB as a convenient service option, saving parents the trouble of gathering necessary proof, completing an SSN application, and visiting or mailing original documents to an SSA field office (FO) for processing.

About 69 percent of the original SSNs SSA assigns annually are processed through the EAB program. SSA estimates approximately 75 percent of newborns receive SSNs via EAB. During Fiscal Year (FY) 2000, SSA assigned about 4 million original SSNs to newborns through the EAB process. As of September 1997, all 50 States, as well as certain jurisdictions (Puerto Rico, New York City, and the District of Columbia), participated in EAB.

Because the EAB program provides SSNs through the birth registration process, SSA’s enumeration workload has significantly decreased since its implementation. The FY 2000 unit cost of processing SSN applications submitted at FOs was $18.70. Accordingly, the EAB program could save SSA about $60 million in administrative costs, annually.

We commend SSA for its innovation in implementing the EAB program. The 24 hospitals and 4 BVSs we reviewed generally provided accurate and reliable enumeration data through EAB. However, because the SSN is so heavily relied upon in today’s society and the potential for its misuse is so great, we believe SSA should establish additional controls in the program. Although these measures may require SSA to reinvest some of the savings realized through EAB in the program, we believe these controls are essential to reduce the Agency’s vulnerability to SSN misuse and enhance program efficiency.

The hospital birth registration units we visited lacked adequate segregation of duties to ensure the proper collection of birth registration data. Clerks working within these units were generally involved in all phases of the process. The clerks gathered information needed to prepare the certificates of live birth, entered information into personal computers, printed certificates, obtained parents’ and hospital certifiers’ signatures, and forwarded the electronic and paper versions of the certificates to the BVSs. Hence, if motivated to do so, these clerks could generate a certificate of live birth for a nonexistent child.

To identify any additional controls that might be in place to compensate for the lack of segregation of duties, we asked hospital personnel whether anyone periodically reconciled birth statistics with the total number of hospital birth registrations. Representatives from 20 of the hospitals reported they did not perform this type of reconciliation. Representatives from the other four hospitals indicated they compared statistics for birth registrations with other hospital data. However, we determined the individuals who made the comparisons at three of these hospitals were not independent of the birth registration process.

While our audit did not disclose any instances of suspected impropriety, we believe some type of additional compensating controls, such as the periodic reconciliations mentioned above, are needed to reduce the program’s vulnerability to potential error and misuse.

Our review of SSA’s Modernized Enumeration System (MES) Transaction History File data for SSN cards issued to children age 1 year and under during Calendar Year (CY) 1999 disclosed 178 instances where SSA assigned a child 2 different SSNs that were not cross-referenced. We believe SSA assigned multiple SSNs to these children for the following reasons:

• system edits did not detect when duplicate SSN applications for a child were processed on the same day (for example, when there were minor differences in the names provided on the two applications);

• system edits did not recognize SSNs previously assigned to children, usually because of minor differences in the names provided on the second applications; and

• FO personnel failed to appropriately resolve system edit exceptions.

While we did not find evidence that these childrens’ SSNs had been used for unauthorized purposes, we are still concerned about SSA’s vulnerability in cases of this nature. In fact, SSA considers such cases "critical errors" when calculating its annual SSN accuracy rate.

Some BVSs did not transmit birth records to SSA within the time frame specified in contracts executed by both SSA and the States/jurisdictions. In fact, during CYs 1999 and 2000, 21 (40 percent) of the 53 participating BVSs did not transmit birth records to SSA within an average of 30 days of the child’s date of birth, as required by their contracts. As a result, some parents became impatient and applied for SSNs again at SSA FOs.

Our analysis of the MES data extract we obtained for CY 1999 disclosed 67,206 instances, nationwide, in which parents submitted a second SSN application when they did not receive the card through EAB within 30 days of the child’s date of birth. Based on unit cost data obtained from SSA, we estimate it cost the Agency approximately $1.26 million to process these second SSN requests through its FOs. If the timeliness of EAB application submissions does not improve, and all variables remain constant, SSA may reduce the savings otherwise realized from the EAB program by approximately $12.6 million between CYs 2000 and 2009. Because the trend in issuance of SSN cards via the EAB program during the last 3 years indicates a slight increase from year to year (3.59 million in FY 1998, 3.65 million in FY 1999, and 3.82 million in FY 2000), we believe the use of CY 1999 data in calculating the 10-year estimate results in a conservative amount.

The EAB Project Officer informed us that he continually monitors BVS processing times and, in September 2000, an SSA Contract Specialist contacted 10 of the BVSs with slower submission averages to encourage more timely submissions. As of December 31, 2000, the average processing times for these 10 BVSs still ranged from 40 to 111 days. At the exit conference, the EAB Project Officer provided us additional data for the 3-month period ended July 27, 2001 that indicated 7 of the 10 BVSs still had not complied with their contracts at that time. The average processing times for the seven BVSs still ranged from 32 days to 148 days, with the average being 63 days. Accordingly, we believe SSA should continue to work with these BVSs to reduce their processing times.

The birth registration data provided to SSA by the test hospitals and BVSs was generally accurate and reliable. However, weaknesses exist in controls and operations that we believe SSA needs to address to reduce the EAB program’s vulnerability to potential error and misuse and to enhance program efficiency.

We recommend that SSA:

• Re-invest some of the savings realized by the EAB program and provide necessary funding, during future contract modifications, for the BVSs to perform periodic, independent reconciliations of registered births with statistics obtained from hospitals’ labor and delivery units and periodically verify the legitimacy of sample birth records obtained from hospitals.

• Enhance its duplicate record detection and prior SSN detection routines to provide greater protection against the assignment of multiple SSNs.

• Instruct FO personnel to exercise greater care when resolving enumeration feedback messages generated by the system.

• Cross-reference multiple SSNs SSA assigned to the 178 children within our sample. We will provide further details regarding these individuals under separate cover.

• Continue to monitor the timeliness of BVS submissions and work with those BVSs having difficulty complying with the time frames specified in the contracts.

AGENCY COMMENTS

SSA agreed with all of our recommendations. The Agency also provided technical comments that we considered and incorporated, where appropriate. The full text of SSA’s comments is included in Appendix B.

Table of Contents

Appendix A – Summary of Multiple SSN Cases Identified in Four Test States

Appendix B – Agency Comments

Appendix C – OIG Contacts and Staff Acknowledgements

Acronyms

Introduction

The objectives of the audit were to determine whether (1) participating hospitals and Bureaus of Vital Statistics (BVS) provide the Social Security Administration (SSA) accurate and reliable information under the Enumeration at Birth (EAB) program and (2) SSA’s internal controls adequately protect the integrity of the process.

Implemented in 1990, the EAB program assigns Social Security numbers (SSN) to newborns, with parental approval, as part of States’ and certain jurisdictions’ birth registration processes. SSA developed EAB in response to increased demand for SSNs for children at earlier ages, especially for tax and other financial requirements. SSA recognized that all the information needed to process an SSN application for a newborn was captured during the hospital birth registration process. Therefore, SSA contracted with State and certain jurisdiction BVSs to obtain birth registration data. The birth registration data serve as evidence of age, identity, and citizenship for purposes of assigning an SSN to a child.

SSA designed EAB as a convenient service option for parents to complete an SSN application. About 69 percent of the original SSNs assigned by SSA annually are processed through the EAB program. SSA estimates approximately 75 percent of newborns receive SSNs via EAB. During Fiscal Year (FY) 2000, SSA assigned about 4 million original SSNs to newborns via EAB. As of September 1997, all 50 States, as well as certain jurisdictions (Puerto Rico, New York City, and the District of Columbia), participated in EAB.

Because the EAB program provides SSNs through the birth registration process, SSA’s enumeration workload has significantly decreased since its implementation. The FY 2000 unit cost of processing SSN applications submitted at field offices (FO) was $18.70. Accordingly, the EAB program could save SSA about $60 million in administrative costs, annually.

To accomplish our objectives, we reviewed applicable laws, regulations, and SSA procedures. In addition, we held discussions with SSA Headquarters personnel and made site visits to BVSs and 24 hospitals located in California, Florida, Texas, and Virginia. We selected these States for review based on the number of EAB submissions, timeliness of submissions to SSA, and geographic location. Factors we considered in selecting the hospitals included the number of EAB submissions, type of facility (that is, public or private), and geographic location.

We interviewed personnel at each of the four BVSs to obtain an understanding of the procedures they followed in processing both paper and electronic versions of birth certificates received from the hospitals and transmitting the EAB records to SSA’s National Computer Center. In addition, we interviewed hospital personnel to obtain an understanding of the processes they followed to collect birth registration information on newborns, prepare birth certificates, and transmit both paper and electronic versions of the certificates to the BVSs. During the site visits, we also verified birth registration data obtained from the BVSs against the hospitals’ records for 890 newborns whose parents elected to use the EAB process. We randomly selected these records from 29,943 EAB applications processed by the 4 BVSs during the quarter ended December 31, 1999. At each location, we inquired about controls in place to ensure the integrity of the birth registration data.

In conjunction with the audit, we obtained SSA’s Modernized Enumeration System (MES) Transaction History File data for children age 1 year and under whom SSA issued original and/or replacement SSN cards during Calendar Year (CY) 1999. After standardizing the mailing addresses, we identified addresses in our test States (California, Florida, Texas, and Virginia) that received multiple SSN cards. We then reviewed these matches to identify situations where SSA assigned a child more than one SSN and situations indicative of possible SSN misuse.

We also assessed the participating States’ and other jurisdictions’ timeliness in submitting birth registration data to SSA. Using the data extracted from MES for CY 1999, we calculated an estimate of the savings SSA may not realize between CYs 2000 and 2009 if States and other jurisdictions do not reduce their processing times.

The SSA entities audited were the Office of Public Service and Operations Support under the Deputy Commissioner for Operations and the Office of Systems Analysis under the Deputy Commissioner for Systems. We performed our audit field work from January 2000 through April 2001. We conducted our audit in accordance with generally accepted government auditing standards.

Results of Review

The procedures followed by the 24 hospitals and 4 BVSs we visited were generally adequate to ensure the accuracy of birth registration data provided to SSA for the enumeration of newborn children. However, we identified weaknesses in existing controls and operations we believe SSA needs to address to reduce the EAB program’s vulnerability to potential error and/or misuse and to enhance program efficiency.

In all of the hospitals we visited, we noted there was a lack of segregation of duties within the hospitals’ birth registration units. Generally, the clerks in these units were involved in all aspects of the process. The lack of separation of duties increases the likelihood that errors or irregularities could occur within the EAB program without being detected in a timely manner. Additionally, it is possible that a clerk could generate a certificate of live birth for a nonexistent child.

Personnel working in the hospitals’ birth registration units gathered information needed to prepare certificates of live birth from hospital records (for example, labor and delivery logs) and from the childrens’ parents. After keying the information into the personal computers and printing the certificates, they asked the parents to verify the accuracy of the data and sign the certificates. They then obtained the signatures of the attending physicians or other hospital certifiers and forwarded the electronic and paper versions of the certificates to the BVS.

Internal controls serve as a first-line defense in safeguarding assets and preventing and detecting errors and fraud. One commonly used control activity is the segregation of duties. Under this concept, no one individual should control all key aspects of a process, transaction or event. Staff size limitations may obstruct efforts to properly segregate duties. However, compensating controls should be implemented in such instances.

We believe a periodic reconciliation of birth statistics with the total number of hospital birth registrations could serve as a compensating control. Accordingly, we asked hospital personnel if anyone performed such reconciliations. Hospital representatives at 20 of the hospitals reported they did not perform such reconciliations. Representatives of the other four hospitals indicated they compared statistics for birth registrations with other hospital data. However, we determined the individuals who made the comparisons at three of these hospitals were not independent of the birth registration process.

Although we did not identify any apparent instances of impropriety, we believe additional controls are needed to compensate for the lack of segregation of duties within the hospitals’ birth registration units. We further believe that periodic, independent reconciliations similar to those described above would satisfy this need. In addition, we believe it would be most desirable for an independent party within the BVSs to perform the reconciliations. To do so would necessitate the BVSs obtaining statistical information from the hospitals’ labor and delivery units, but it would provide protection against internal error and/or misuse at both the hospital and BVS levels.

Our audit also showed that neither SSA nor the BVSs verified the legitimacy of birth registration data the hospitals submitted. SSA accepts the birth registration data received from the BVSs as evidence of a child’s age, citizenship, and identity.

SSA’s policy requires applicants for SSNs to provide evidence of age, citizenship, and identity. A birth certificate is considered acceptable evidence of age and citizenship, but not identity. This policy is true for newborns as well as other children and adults who are enumerated through field office input. Such applicants are required to provide other forms of evidence to prove identity. Examples of acceptable identity documents for newborns are vaccination and medical records.

Accordingly, we believe there is also a need for some form of verification of birth information provided by the hospitals. Such verification could be accomplished by requesting that the hospital’s labor and delivery units verify a sample of births when providing statistical information needed to perform the reconciliation mentioned above. We believe such verifications, coupled with a reconciliation, would greatly enhance protection against possible error and misuse.

Our analysis of records contained in SSA’s MES Transaction History File for children age 1 and under who received SSN cards during CY 1999, disclosed 178 instances where the Agency assigned a child 2 unique SSNs that were not cross-referenced to each other. We believe SSA erroneously assigned these children more than one SSN for the following reasons:

• system edits did not detect when duplicate SSN applications for a child were processed on the same day (for example, when there were minor differences in the names provided on the two applications);

• system edits did not recognize SSNs previously assigned to children, usually because of minor differences in the names provided on the second applications; and

• FO personnel failed to appropriately resolve system edit exceptions.

Assignment of more than one SSN to an individual causes concern because of the opportunity it creates for program abuse and/or identity fraud. In fact, SSA considers such cases "critical errors" when calculating its annual SSN accuracy rate. Each of the three causes for the assignment of the multiple SSNs is discussed in greater detail in the following sections. Appendix A also contains additional information about the 178 cases (such as the sources of the SSN requests).

When SSA’s MES processes each SSN application, the system runs an "edit routine" to determine whether any duplicate applications were submitted on the same date. In doing so, MES compares certain positions of the applicants’ first and last names and dates of birth with other applications processed that day. Additionally, the edit routine compares birth certificate numbers for records submitted via the EAB process. However, the duplicate record detection routine does not consider two SSN applications to be duplicates unless these data fields match exactly. For example, if the birth certificate numbers for two EAB records are different, the records are not treated as possible duplicates even if the other data fields are identical.

In 17 cases we identified, where both records were entered into MES on the same date, the matched records contained identical applicant names and dates of birth but different birth certificate numbers. Therefore, MES did not recognize them as duplicates. In six other cases, MES failed to recognize the records as possible duplicates because of a variance of one or two characters in the applicants’ names.

We believe SSA needs to enhance its duplicate record detection routine to provide greater assurance of identifying duplicate requests submitted on the same day.

Once a record passes the duplicate record detection routine, MES searches its SSN master file for SSNs the Agency may have previously assigned the applicant. During the search, the system compares numerous fields of data on the incoming record with the master file.

Our audit disclosed 93 instances where system edits failed to identify an SSN previously assigned to a child. In each of these cases, there was a variance of only one or two characters in the applicants’ first names as shown on the matched records. We believe SSA needs to enhance its search routine to provide greater assurance of identifying previously assigned SSNs.

In 62 of the 178 cases, the system generated an Enumeration Feedback Message (EFM) on 1 or both of the matched records. In 8 of the 62 cases, the EFMs were generated because the applicants alleged having previously applied for or received SSN cards. In the other 54 cases, the EFMs were generated because the system found a record on the SSN master file containing applicant information similar to that shown on the incoming record.

It should be noted that in 44 of the 62 cases, the applicant names on the matched records were identical. In five of the cases, the applicants’ names were identical except for the suffixes. Furthermore, while there were some differences in the applicants’ middle names in the other cases, the first and last names were identical. For example, in some cases, one record contained a middle name while the other record either contained a middle initial or no middle name at all.

In conclusion, we believe FO personnel need to exercise greater care when resolving EFMs. In addition, we believe FO personnel need to establish the practice of querying the SSN master file when resolving EFMs to ensure the applicants have not already been assigned an SSN.

Some BVSs did not transmit birth records to SSA within the time frame specified in the contracts executed by SSA and the States/jurisdictions. As a result of the slow transmissions, some parents became impatient and applied for their childrens’ SSNs through SSA’s FOs even though the SSNs were previously requested using the EAB process.

Our analysis of the MES data extract we obtained for CY 1999 disclosed 67,206 instances, nationwide, in which parents submitted a second SSN application at an SSA FO when they did not receive the card through EAB within 30 days of the child’s date of birth. Based on unit cost data obtained from SSA, we estimate it costs the Agency approximately $1.26 million to process these second SSN requests. If the timeliness of EAB application submissions does not improve, and all variables remain constant, SSA may reduce the savings otherwise realized from the EAB program by approximately $12.6 million between CYs 2000 and 2009. Because the trend in issuance of SSN cards via the EAB program during the last 3 years indicates a slight increase from year to year (3.59 million in FY 1998, 3.65 million in FY 1999, and 3.82 million in FY 2000), we believe the use of CY 1999 data in calculating the 10-year estimate results in a conservative amount.

Section F.2. of SSA’s standard contract with each of the participating States and jurisdictions requires the BVSs to transmit files containing birth certificate data to SSA with sufficient frequency to ensure the data are received within an average of 30 calendar days from the date of birth of the individuals for whom enumeration has been requested. Review of statistical data provided by the EAB Project Officer showed that 21 BVSs failed to comply with this contract provision during CYs 1999 and 2000. Two of our 4 test states, Virginia and Florida, were included in the 21 BVSs for each year.

Average processing times for the 21 BVSs ranged from 31 to 85 days during CY 2000 and 31 to 108 days during CY 1999. The average processing time for the 21 BVSs during CY 2000 was 50.2 days as compared to 47.3 for CY 1999, an increase of 6 percent over the previous year.

We believe the untimely transmissions by the BVSs could diminish the effectiveness of the EAB process. The additional SSN requests parents made at the FOs increase the FOs’ workloads. Duplication of costs also occurs because SSA is contractually obligated to reimburse the BVSs for the birth data even though they are no longer needed to assign the childrens’ SSNs. In addition to cost, untimely submissions result in reduced customer program satisfaction because the parents don’t receive the SSN cards as soon as they want or need them.

The EAB Project Officer informed us he continually monitors the BVS processing times, and, in September 2000, an SSA Contract Specialist contacted 10 of the BVSs with slower submission averages to encourage more timely submissions. As of December 31, 2000, the average processing times for these 10 BVSs ranged from 40 to 111 days. At the exit conference, the EAB Project Officer provided us additional data for the 3-month period ended July 27, 2001 that indicated 7 of the 10 BVSs still had not complied with their contracts at that time. The average processing times for the 7 BVSs ranged from 32 days to 148 days, with the average being 63 days. Accordingly, we believe SSA should continue to work with these BVSs to reduce their processing times.

Conclusions and Recommendations

The birth registration data provided by the hospitals and BVSs we visited were generally accurate and reliable. However, review of the procedures and related controls employed by the hospitals, cognizant BVSs, and SSA disclosed the need for SSA to establish additional controls to reduce the EAB program’s vulnerability to potential error and misuse and to enhance program efficiency.

We recommend that SSA:

1. Re-invest some of the savings realized by the EAB program and provide necessary funding, during future contract modifications, for the BVSs to perform periodic, independent reconciliations of registered births with statistics obtained from hospital’s labor and delivery units and to periodically verify the legitimacy of sample birth records obtained from the hospitals.
2. Enhance its duplicate record detection and prior SSN detection routines to provide greater protection against the assignment of multiple SSNs.
3. Instruct FO personnel to exercise greater care when resolving EFMs generated by the system.
4. Cross-reference multiple SSNs SSA assigned to the 178 children within our sample. We will provide further details regarding these individuals to SSA under separate cover.
5. Continue to monitor the timeliness of BVS submissions and work with those BVSs that are having difficulty complying with the time frames specified in the contracts.

SSA agreed with all of our recommendations. The Agency also provided technical comments that we considered and incorporated, where appropriate. The full text of SSA’s comments is included in Appendix B.

Other Matters

Analysis of MES Transaction History File data for CY 1999 for the 4 test States disclosed 74 instances where SSA assigned a child with the first name of "Infant" or "Baby" an SSN through the EAB program. While SSA’s contracts with the BVSs provides that a birth record for a newborn child shall not be transmitted to SSA where the parents have not named the child, SSA has not implemented edits to detect unacceptable names such as Baby Jones. Therefore, we believe SSA needs to implement automated edits to identify such records and prevent the assignment of SSNs to unnamed children.

Section C.2.A. of SSA’s contracts with the BVSs requires the BVSs to record the parent’s request for an SSN on either the birth registration document or another official record of the jurisdiction. Each of the four BVSs we visited had designed their birth certificates to capture the parent’s request. However, during our review of documentation for sample births, we noted 18 instances where the parents had not signed the birth certificates to authorize the request for the SSNs. Without the parents’ signatures, SSA does not have the proper authority to assign new SSNs to the children.

We believe the BVSs failed to detect the lack of signatures on the birth certificates due to clerical oversight. Therefore, we encourage SSA to instruct the BVSs to re-emphasize to their personnel the need to ensure that parents have signed the certificates.

Appendices

Appendix A

SUMMARY OF MULTIPLE SOCIAL SECURITY NUMBER CASES IDENTIFIED IN FOUR TEST STATES

The following table indicates whether (1) the two Social Security number (SSN) applications in each match originated solely from the enumeration at birth (EAB) process or from a combination of the EAB process and field office (FO) input; (2) the two applications in each match were entered into the Social Security Administration’s Modernized Enumeration System (MES) on the same or different dates; or (3) MES generated an enumeration feedback message (EFM) for these transactions.

Appendix B

Agency Comments

OIG Contacts and Staff Acknowledgements

OIG Contacts

Kimberly Byrd, Acting Director, Operations Audit Division, (205) 801-1605
Cliff McMillan, Senior Auditor, (205) 801-1602

Acknowledgments

In addition to those named above:

Theresa Roberts, Auditor
Kathy Youngblood, Senior Auditor
Jeff Pounds, Senior Program Analyst
Charles Lober, Senior Auditor
Reginia Grider, Senior Auditor
Kimberly Beauchamp, Writer/Editor

The Office of Audit (OA) conducts comprehensive financial and performance audits of the Social Security Administration’s (SSA) programs and makes recommendations to ensure that program objectives are achieved effectively and efficiently. Financial audits, required by the Chief Financial Officers Act of 1990, assess whether SSA’s financial statements fairly present the Agency’s financial position, results of operations, and cash flow. Performance audits review the economy, efficiency, and effectiveness of SSA’s programs. OA also conducts short-term management and program evaluations focused on issues of concern to SSA, Congress, and the general public. Evaluations often focus on identifying and recommending ways to prevent and minimize program fraud and inefficiency.

OEO supports the OIG by providing information resource management; systems security; and the coordination of budget, procurement, telecommunications, facilities and equipment, and human resources. In addition, this office is the focal point for the OIG’s strategic planning function and the development and implementation of performance measures required by the Government Performance and Results Act. OEO is also responsible for performing internal reviews to ensure that OIG offices nationwide hold themselves to the same rigorous standards that we expect from SSA, as well as conducting investigations of OIG employees, when necessary. Finally, OEO administers OIG’s public affairs, media, and interagency activities, coordinates responses to Congressional requests for information, and also communicates OIG’s planned and current activities and their results to the Commissioner and Congress.

The Office of Investigations (OI) conducts and coordinates investigative activity related to fraud, waste, abuse, and mismanagement of SSA programs and operations. This includes wrongdoing by applicants, beneficiaries, contractors, physicians, interpreters, representative payees, third parties, and by SSA employees in the performance of their duties. OI also conducts joint investigations with other Federal, State, and local law enforcement agencies.

The Counsel to the Inspector General provides legal advice and counsel to the Inspector General on various matters, including: 1) statutes, regulations, legislation, and policy directives governing the administration of SSA’s programs; 2) investigative procedures and techniques; and 3) legal implications and conclusions to be drawn from audit and investigative material produced by the OIG. The Counsel’s office also administers the civil monetary penalty program.