A-09-05-15025 - Alternate Format

MEMORANDUM

Date: July 7, 2005

To: Carl L. Rabun
Regional Commissioner Seattle

From: Inspector General

Subject: Administrative Costs Claimed by the Alaska Disability Determination Services (A-09-05-15025)

The attached final report presents the results of our audit. Our objectives were to evaluate the Alaska Disability Determination Services' (AK DDS) internal controls over the accounting and reporting of administrative costs, determine whether costs claimed by the AK DDS were allowable and funds were properly drawn, and assess limited areas of the general security controls environment.

Please provide within 60 days a corrective action plan that addresses 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.

Patrick P. O'Carroll, Jr.

OFFICE OF
THE INSPECTOR GENERAL

SOCIAL SECURITY ADMINISTRATION

ADMINISTRATIVE COSTS CLAIMED
BY THE ALASKA DISABILITY
DETERMINATION SERVICES

July 2005

A-09-05-15025

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.

Executive Summary

OBJECTIVE

The objectives of our audit were to (1) evaluate the Alaska Disability Determination Services' (AK DDS) internal controls over the accounting and reporting of administrative costs, (2) determine whether costs claimed by the AK DDS were allowable and funds were properly drawn, and (3) assess limited areas of the general security controls environment.

BACKGROUND

Disability determinations under the Social Security Administration's (SSA) Disability Insurance and Supplemental Security Income programs are performed by disability determination services (DDS) in each State or other responsible jurisdiction, in accordance with Federal regulations. Each DDS is responsible for determining claimants' disabilities and ensuring adequate evidence is available to support its determinations. To assist in making proper disability determinations, each DDS is authorized to purchase medical examinations, x rays, and laboratory tests on a consultative basis to supplement evidence obtained from the claimants' physicians or other treating sources. SSA reimburses the DDS for 100 percent of allowable expenditures.

RESULTS OF REVIEW

Generally, AK DDS had adequate controls over the accounting and reporting of administrative costs. Also, AK DDS had adequate controls over its general security controls environment. However, we estimate that AK DDS could have saved up to about $1.3 million in medical costs for Fiscal Years (FY) 2001 through 2003 had a fee schedule been established. In addition, AK DDS claimed $177,092 of unallowable costs for FYs 2001 through 2003. This occurred because AK DDS improperly paid for missed consultative examinations and Medicaid expenditures that did not benefit SSA's programs. Furthermore, AK DDS charged $21,821 in medical and all other nonpersonnel costs to the incorrect FY.

RECOMMENDATIONS

We recommend that SSA (1) ensure AK DDS establishes a fee schedule for medical services, (2) work with AK DDS to evaluate the reasonableness of its payment rates, (3) determine whether it was necessary for AK DDS to pay medical providers for $120,920 in missed consultative examinations, (4) instruct the Alaska Division of Vocational Rehabilitation (AK DVR) to refund $56,172 in unallowable costs for the Medicaid program, and (5) instruct AK DVR to implement procedures to ensure that expenditures are reported in the proper FY.

SSA COMMENTS

SSA agreed with four of our five recommendations. SSA disagreed with our recommendation to recover $56,172 in unallowable costs for disability determinations performed on behalf of the Medicaid program. SSA believed it generally benefited from the reimbursement arrangement and should not request a refund because (1) under the reimbursable services agreement (RSA), AK DVR used a $75,000 salary when the actual average adjudicator salary was $64,000 and (2) the non Federal workload did not require the services of a full time adjudicator. SSA believed these factors would offset any potential finding of unallowable costs. Finally, SSA noted that since AK-DVR only showed personnel costs on its quarterly reports, it would instruct AK DVR to provide a breakdown of the Medicaid costs to reflect personnel, indirect, medical, and other costs. See Appendix D for the text of SSA's comments.

STATE AGENCY COMMENTS

The Alaska Department of Labor and Workforce Development (AK DOLWD) agreed with four of our five recommendations. AK DOLWD disagreed with our recommendation to recover $56,172 in unallowable costs for disability determinations performed on behalf of the Medicaid program. AK DOLWD stated that it should have used an average salary of $64,000 for an adjudicator rather than the highest salary of $75,000. In addition, AK DOLWD stated that it had incorrectly included nonpersonnel costs with the Medicaid billings for personnel costs and did not charge the full amount of State and departmental indirect costs during our audit period. See Appendix E for the text of AK DOLWD's comments.

OIG RESPONSE

The RSA, as applied during our audit period, stated the annual salary for one adjudicator would be allocated to the Medicaid program. During FYs 2001 through 2003, AK DVR charged Medicaid costs based on an estimated salary of $75,000 per year. In addition, we found no evidence that nonpersonnel costs were included with personnel costs or had otherwise been charged to the Medicaid program. Finally, the information supporting AK DOLWD's comment that it did not charge the full amount of State and departmental indirect costs was not made available to us during our audit. Therefore, we believe SSA should evaluate the sufficiency of this information to determine whether it should request a refund of any unallowable costs for the Medicaid program. We are pleased that SSA is taking corrective action to ensure AK DVR provides a breakdown of all Medicaid costs in the future.

Table of Contents
Page
INTRODUCTION 1
RESULTS OF REVIEW 3
Medical Fee Schedule 3
Missed Consultative Examinations 4
Expenditures for Medicaid Program 5
Incorrect Fiscal Year Payments 6
CONCLUSIONS AND RECOMMENDATIONS 8

APPENDICES
APPENDIX A - Acronyms
APPENDIX B - Scope and Sampling Methodology
APPENDIX C - Alaska Disability Determination Services Reported and Allowed Costs
APPENDIX D - SSA Comments
APPENDIX E - State Agency Comments
APPENDIX F - OIG Contacts and Staff Acknowledgments

Introduction

OBJECTIVE

BACKGROUND

The Disability Insurance program was established in 1954 under Title II of the Social Security Act (Act). The Disability Insurance program provides benefits to wage earners and their families in the event the wage earner becomes disabled. In 1972, Congress enacted the Supplemental Security Income program under Title XVI of the Act. The Supplemental Security Income program provides benefits to financially needy individuals who are aged, blind, or disabled.

The Social Security Administration (SSA) is responsible for implementing policies for the development of disability claims under the Disability Insurance and Supplemental Security Income programs. Disability determinations under both Disability Insurance and Supplemental Security Income are performed by disability determination services (DDS) in each State or other responsible jurisdiction, in accordance with Federal regulations. In carrying out its obligation, each DDS is responsible for determining claimants' disabilities and ensuring adequate evidence is available to support its determinations. To assist in making proper disability determinations, each DDS is authorized to purchase medical examinations, x rays, and laboratory tests on a consultative basis to supplement evidence obtained from the claimants' physicians or other treating sources.

SSA reimburses the DDS for 100 percent of allowable expenditures up to its approved funding authorization. The DDS withdraws Federal funds through the Department of the Treasury's (Treasury) Automated Standard Application for Payments system to pay for program expenditures. Funds drawn down must comply with Federal regulations and intergovernmental agreements entered into by Treasury and States under the Cash Management Improvement Act of 1990. An advance or reimbursement for costs under the program must comply with Office of Management and Budget Circular A 87, Cost Principles for State, Local, and Indian Tribal Governments. At the end of each quarter of the fiscal year (FY), each DDS submits a Form SSA 4513, State Agency Report of Obligations for SSA Disability Programs, to account for program disbursements and unliquidated obligations.

AK DDS is a component within the Alaska Division of Vocational Rehabilitation (AK DVR). AK DVR is a division within the Alaska Department of Labor and Workforce Development (AK DOLWD). For FYs 2001 through 2003, AK DDS employed about 29 employees and claimed total disbursements of $11.95 million. The following chart provides an overview of the organizational structure of AK DDS.

Results of Review

Generally, AK DDS had adequate controls over the accounting and reporting of administrative costs. Also, AK DDS had adequate controls over its general security controls environment. However, we estimate that AK DDS could have saved up to about $1.3 million in medical costs for FYs 2001 through 2003 had a fee schedule been established. In addition, AK DDS claimed $177,092 of unallowable costs for FYs 2001 through 2003. This occurred because AK DDS improperly paid for missed consultative examinations (CE) and Medicaid expenditures that did not benefit SSA's programs. Furthermore, AK DDS charged $21,821 in medical and all other nonpersonnel costs to the incorrect FY.

MEDICAL FEE SCHEDULE

AK DDS did not establish a fee schedule to determine the maximum payment rates for medical services. Because of the limited number of medical providers in the State, AK DVR believed a fee schedule was not necessary. In addition, AK DDS believed a fee schedule could reduce the availability of medical providers. Without a fee schedule, SSA and AK DDS may be unable to ensure the payment rates for medical services are consistently applied. If payment rates were limited to the highest rate paid by Federal or other agencies in the State for the same or similar types of service, we estimate that AK DDS could have saved up to about $1.3 million in medical costs for FYs 2001 through 2003.

SSA's procedures state that the DDS will use a fee schedule to reimburse medical providers for their services. Authorized payments represent the lower of (1) the provider's usual and customary charge or (2) the maximum allowable charge under the fee schedule. The DDS must submit to the SSA Regional Office a copy of the fee schedule or any changes to an existing fee schedule. The DDS must also review its records annually with the SSA Regional Office to determine whether the fee schedule is adequate and cost effective.

Federal regulations require that each State determine the payment rates for medical or other services necessary to make disability determinations. The rates may not exceed the highest rate paid by Federal or other agencies in the State for the same or similar types of service. The State must maintain documentation to support the payment rates used.

Although AK DDS paid the usual and customary rates to its medical providers, this did not alleviate the need to establish a fee schedule to determine the maximum payment rates and ensure they were reasonable. In May 2004, the SSA Regional Office conducted an on site review of DDS operations in Alaska. Based on the results of its review, the Regional Office recommended that AK DDS consider establishing a fee schedule and rely on other agencies, such as AK DVR and Medicare, for payment caps.

During our review, we were unable to obtain medical fee schedules from other State agencies because these schedules were classified as proprietary information. For comparison purposes, we matched the rates Medicare paid with the fees AK DDS paid for its medical services. As depicted in the table below, AK DDS paid $2,831,304 for 12,469 medical services during FYs 2001 through 2003. However, using the applicable Medicare rates, the maximum payments for these medical services were limited to $1,511,765. Therefore, if a fee schedule had been established and payment rates were limited to the highest allowable rates, we estimate that AK DDS could have saved up to $1,319,539 in medical costs for FYs 2001 through 2003.

FY Medical Services Actual Payments Maximum Payments Potential Cost Savings
2001 4,866 $1,021,831 $578,793 $443,038
2002 4,594 1,045,800 550,077 495,723
2003 3,009 763,673 382,895 380,778
Total 12,469 $2,831,304 $1,511,765 $1,319,539

MISSED CONSULTATIVE EXAMINATIONS

AK DDS incorrectly paid fees for missed CE appointments. Although such fees are ineligible for reimbursement, SSA's Office of Disability Determinations may authorize an exemption to its no pay policy for missed CEs. However, we found the SSA Regional Office did not obtain the exemption as required. As a result, SSA reimbursed AK DVR for $120,920 of unallowable costs for FYs 2001 through 2003.

In response to a prior audit, SSA adopted a no pay policy for missed CE appointments. In April 2000, SSA clarified its no pay policy and stated that, on a case by case basis, the DDS may request an exemption to recruit or retain medical providers. To obtain an exemption, the DDS should work with the SSA Regional Office to determine the payments for missed CE appointments. After an agreement is reached, the Regional Office should submit the request, along with supporting documentation, to the Office of Disability Determinations for consideration.

In December 2002, AK DDS requested an exemption to the no pay policy for missed CE appointments. Nevertheless, we found no evidence to indicate that (1) the SSA Regional Office had submitted a request for exemption to its no pay policy or (2) the Office of Disability Determinations had approved such an exemption for AK DDS. For FYs 2001 through 2003, we identified 778 payments representing $120,920 for missed CE appointments. The following table provides a breakdown of these payments.

FY Number of Claimants Missed CE Appointments Unallowable Costs
2001 108 119 $15,306
2002 364 426 65,850
2003 199 233 39,764
Total 671 778 $120,920

We encourage SSA to determine whether it was necessary for AK DDS to pay medical providers for missed CE appointments. If it was not necessary to pay these fees, SSA should instruct AK DVR to refund $120,920 in unallowable costs. Otherwise, SSA should obtain approval from the Office of Disability Determinations to pay fees for missed CE appointments.

EXPENDITURES FOR MEDICAID PROGRAM

AK DVR incorrectly charged expenditures for the Medicaid program to SSA's programs. This occurred because AK DVR did not properly allocate all other nonpersonnel costs to the benefiting programs. Since these costs benefited the Medicaid program, they should not have been charged to SSA's programs. As a result, SSA reimbursed AK DVR for $56,172 in unallowable costs for FYs 2001 through 2003.

SSA's procedures authorize the Agency to provide States with funding for all expenditures, direct or indirect, necessary to make disability determinations. Generally, any expenditures incurred for SSA's disability determination process are deemed essential and may be charged to the Agency.

AK DDS performs a number of disability determinations for the Medicaid program. Under a reimbursable services agreement (RSA), AK DVR allocates costs incurred in making disability determinations from AK DDS to the Medicaid program. Our review of RSAs disclosed that personnel, medical, and indirect costs were properly allocated to the Medicaid program. However, except for applicant travel costs, all other nonpersonnel costs were not allocated to the Medicaid program.

For FYs 2001 through 2003, AK DDS performed 18,404 disability determinations, of which 17,232 were SSA disability claims and 1,172 were Medicaid claims. During this period, AK DVR charged $851,643 in all other nonpersonnel costs (excluding applicant travel costs) to SSA's programs. As depicted in the table below, we determined that $56,172 of all other nonpersonnel costs benefited the Medicaid program. Therefore, AK DVR should refund these costs to SSA.

FY Medicaid Claims Percentage of Total Claims Nonpersonnel Costs Unallowable Costs
2001 381 7.368% $386,641 $28,488
2002 377 5.631% 251,123 14,141
2003 414 6.332% 213,879 13,543
Total 1,172 $851,643 $56,172

INCORRECT FISCAL YEAR PAYMENTS

AK DDS charged payments to the incorrect FYs, although the costs were otherwise acceptable for reimbursement by SSA. Because of clerical errors, AK DVR and AK DDS did not ensure the purchase orders for goods and services were properly billed to the correct FY. As a result, AK DVR incorrectly reported $21,821 in administrative costs for FYs 2001 through 2003.

Federal law states that "The balance of an appropriation or fund limited for obligation to a definite period is available only for expenditures properly incurred during that period . . . The appropriation or fund is not available for expenditure for a period beyond the period otherwise authorized by law."

AK DDS generates purchase orders to establish valid obligations for goods and services ordered. For FYs 2001 through 2003, we reviewed 150 invoices for medical costs (50 items from each FY) and 150 invoices for all other nonpersonnel costs (50 items from each FY). Of this amount, we found that AK DDS had charged 20 invoices (6.7 percent) to the incorrect FY, resulting in $21,821 of misreported costs. The following table provides a breakdown of these payments.

FY Medical Costs Nonpersonnel Costs Unallowable Costs Number Amount Number Amount Number Amount
2001 3 $1,240 6 $16,083 9 $17,323
2002 5 3,001 4 1,089 9 4,090
2003 0 0 2 408 2 408
Total 8 $4,241 12 $17,580 20 $21,821

Improper reporting of funds between FYs prevents SSA from accurately monitoring the status of AK DDS' expenditures and unexpended appropriations. Therefore, for FYs 2001 through 2003, AK DVR should review the expenditures claimed on the Form SSA 4513 and reclassify expenditures as appropriate. AK DVR should also implement procedures to prevent future occurrences of similar problems.

Conclusions and Recommendations

Our review of administrative costs disclosed that AK DDS could have saved up to about $1.3 million in medical costs for FYs 2001 through 2003 had a fee schedule been established. In addition, we found that AK DDS claimed $177,092 of unallowable costs for FYs 2001 through 2003. This occurred because AK DDS improperly paid for missed CEs and Medicaid expenditures that did not benefit SSA's programs. We also found that AK DDS charged $21,821 in medical and all other nonpersonnel costs to the incorrect FY.

We recommend that SSA:

1. Ensure AK DDS establishes a medical fee schedule and submits a copy to the SSA Regional Office.

2. Work with AK DDS to evaluate the reasonableness of its fee schedule and ensure the payment rates are adequate to obtain medical or other services necessary for disability determinations.

3. Determine whether it was necessary for AK DDS to pay medical providers for missed CE appointments. If such expenditures were not necessary, instruct AK DVR to refund $120,920 in unallowable costs for FYs 2001 through 2003. Otherwise, obtain approval from the Office of Disability Determinations to pay fees for missed CE appointments.

4. Instruct AK DVR to refund $56,172 in unallowable costs for disability determinations performed on behalf of the Medicaid program during FYs 2001 through 2003.

5. Instruct AK DVR to (1) implement procedures to ensure that expenditures are reported in the proper FY and (2) review the Form SSA 4513 for FYs 2001 through 2003 and reclassify expenditures as appropriate.

SSA COMMENTS

SSA agreed with four of our five recommendations. SSA disagreed with our recommendation to recover $56,172 in unallowable costs for disability determinations performed on behalf of the Medicaid program. SSA believed it generally benefited from the reimbursement arrangement and should not request a refund because (1) under the RSA, AK DVR used a $75,000 salary when the actual average adjudicator salary was $64,000 and (2) the non Federal workload did not require the services of a full time adjudicator. SSA believed these factors would offset any potential finding of unallowable costs. Finally, SSA noted that since AK-DVR only showed personnel costs on its quarterly reports, it would instruct AK DVR to provide a breakdown of the Medicaid costs to reflect personnel, indirect, medical, and other costs. See Appendix D for the text of SSA's comments.

STATE AGENCY COMMENTS

AK DOLWD agreed with four of our five recommendations. AK DOLWD disagreed with our recommendation to recover $56,172 in unallowable costs for disability determinations performed on behalf of the Medicaid program. AK DOLWD stated that it should have used an average salary of $64,000 for an adjudicator rather than the highest salary of $75,000. In addition, AK DOLWD stated that it had incorrectly included nonpersonnel costs with the Medicaid billings for personnel costs and did not charge the full amount of State and departmental indirect costs during our audit period. See Appendix E for the text of AK DOLWD's comments.

OIG RESPONSE

Appendices

Appendix A
Acronyms
Act Social Security Act
AK DDS Alaska Disability Determination Services
AK DOLWD Alaska Department of Labor and Workforce Development
AK DVR Alaska Division of Vocational Rehabilitation
CE Consultative Examination
C.F.R. Code of Federal Regulations
DDS Disability Determination Services
Form SSA 4513 State Agency Report of Obligations for SSA Disability Programs
FY Fiscal Year
POMS Program Operations Manual System
RSA Reimbursable Services Agreement
SSA Social Security Administration
Treasury Department of the Treasury
U.S.C. United States Code

Appendix B
Scope and Sampling Methodology
SCOPE

We reviewed the administrative costs reported by the Alaska Disability Determination Services (AK DDS) on its Form SSA 4513, State Agency Report of Obligations for SSA Disability Programs, for Fiscal Years (FY) 2001 through 2003. For the items tested, we reviewed AK DDS' compliance with applicable laws and regulations, as well as the Social Security Administration's (SSA) policies and procedures, over the allowability of administrative costs and draw down of Federal funds.

To accomplish our objectives, we:

Reviewed Office of Management and Budget Circular A 87, Code of Federal Regulations, United States Code, SSA's Program Operations Manual System, and AK DDS' Indirect Cost Proposal;

Reviewed AK DDS' policies and procedures related to personnel, medical, indirect, and all other nonpersonnel costs;

Interviewed employees from SSA, AK DDS, Alaska Division of Vocational Rehabilitation (AK DVR), and Alaska Department of Labor and Workforce Development (AK DOLWD);

Reconciled the amount of Federal funds drawn for support of program operations to the allowable expenditures;

Examined the administrative costs incurred and claimed by AK DDS for personnel, medical, indirect, and all other nonpersonnel costs during FYs 2001 through 2003;

Selected a random sample of personnel, medical, and all other nonpersonnel costs; and

Reconciled the accounting records to the administrative costs reported by AK DDS on its Form SSA 4513 for FYs 2001 through 2003.

We determined the electronic data used in our audit were sufficiently reliable to achieve our audit objectives. We assessed the reliability of the electronic data by reconciling them with the costs claimed on the Form SSA 4513. We also conducted detailed audit testing on selected data elements from the electronic files.

We performed audit work at AK DDS in Anchorage, Alaska; AK DVR and AK DOLWD in Juneau, Alaska; and SSA Regional Office in Seattle, Washington. Field work was conducted between July and November 2004. We conducted our audit in accordance with generally accepted government auditing standards.

SAMPLING METHODOLOGY

Our sampling methodology included the four general areas of costs as reported on Form SSA 4513: (1) personnel, (2) medical, (3) indirect, and (4) all other nonpersonnel costs. We obtained data extracts from AK DOLWD for FYs 2001 through 2003 to use in statistical sampling. After selecting and reviewing the randomly selected samples, we did not identify errors that we felt warranted statistical projection.

Personnel Costs

We reviewed 31 personnel transactions from 1 pay period in FY 2003. In addition, we reviewed the transactions from the same pay period for the seven medical consultants hired by AK DDS. We tested payroll records to ensure AK DDS accurately paid its employees and adequately supported these payments.

Medical Costs

We reviewed 150 medical cost items (50 items from each FY) using a stratified random sample. We distributed the sample items between medical evidence of records and consultative examinations based on the proportional distribution of the total medical costs for each year.

Indirect Costs

AK DDS indirect costs were computed by applying a Federally approved rate to a cost base. This methodology was approved by the Department of Labor, which is the Federal agency responsible for approving indirect costs for AK DOLWD. We reviewed the indirect cost calculations for FYs 2001 through 2003 to ensure the correct rate was applied.

All Other Nonpersonnel Costs

We reviewed 150 all other nonpersonnel costs items (50 items from each FY) using a stratified random sample. Before selecting our sample, we sorted the transactions into the following categories: (1) transportation, (2) per diem, (3) conference/training, (4) applicant travel, (5) other travel costs, (6) professional services, (7) communication, (8) service agreements, (9) postal charges, (10) freight and delivery, (11) advertising, (12) supplies, (13) office equipment, (14) machinery and equipment, (15) information technology equipment and software, (16) other current expenses, and (17) other building expenses. We then distributed the 50 sample items between these categories based on the proportional distribution of all other nonpersonnel costs for each year. We also judgmentally selected two transactions for rental/lease costs for each year.

Appendix C
Alaska Disability Determination Services Reported and Allowed Costs
Table 1 - Administrative Costs for Fiscal Year (FY) 2001
Category Reported
Costs Audit Adjustments Allowable
Costs
Personnel $1,537,101 $0 $1,537,101
Medical 1,290,558 (15,306) 1,275,252
Indirect 369,726 0 369,726
All Other Nonpersonnel 779,980 (28,488) 751,492
Total $3,977,365 ($43,794) $3,933,571

Table 2 - Administrative Costs for FY 2002
Category Reported
Costs Audit Adjustments1 Allowable
Costs
Personnel $1,760,764 $0 $1,760,764
Medical 1,486,634 (65,850) 1,420,784
Indirect 412,457 0 412,457
All Other Nonpersonnel 709,321 (14,141) 695,180
Total $4,369,176 ($79,991) $4,289,185

Table 3 - Administrative Costs for FY 2003
Category Reported
Costs Audit Adjustments1 Allowable
Costs
Personnel $1,696,120 $0 $1,696,120
Medical 1,061,384 (39,764) 1,021,620
Indirect 376,401 0 376,401
All Other Nonpersonnel 469,205 (13,543) 455,662
Total $3,603,110 ($53,307) $3,549,803

Appendix D
SSA Comments

SOCIAL SECURITY

MEMORANDUM

Date: May 27, 2005

To: Inspector General Seattle Regional Office
Office of the Inspector General

From: Regional Commissioner Seattle Region

Subject: Administrative Costs Claimed by the Alaska Disability Determination Services (A 09 05 15025) REPLY

This responds to the draft audit report of administrative costs claimed by the Alaska Disability Determination Services (AK DDS) (A 09 05 15025). The Office of the Inspector General (OIG) had five recommendations for the Alaska DDS. Each recommendation, with our response, is shown below:

1. Ensure AK DDS establishes a medical fee schedule and submits a copy to the SSA Regional Office.

We agree with this recommendation and we are working with the AK DDS to establish a medical fee schedule. The expected completion date is August 30, 2005.

2. Work with AK DDS to evaluate the reasonableness of its fee schedule and ensure the payment rates are adequate to obtain medical or other services necessary for disability determinations.

We agree with this recommendation and, as stated above, we are working with the AK DDS to establish and evaluate a medical fee schedule to ensure payment rates are adequate.

We agree with this recommendation and we are working with the AK DDS and the Office of Disability, Division of Field Disability Operations, Resource Management Branch to obtain approval for the DDS's CE reimbursement guidelines and procedures for missed CE appointments. The expected completion date for this action is June 30, 2005.

4. Instruct AK Division of Vocational Rehabilitation (DVR) to refund $56,172 in unallowable costs for disability determinations performed on behalf of the Medicaid program during FYs 2001 through 2003.

We disagree with this recommendation. To cover the costs of a non federal workload processed by the AK DDS, the AK DVR was charged $75,000 plus costs for obtaining medical evidence and applicant travel. The $75,000 charge represented the estimated annual salary for one DDS adjudicator. While there appears to be a discrepancy, we believe that further analysis of information not considered during the audit would show that SSA generally benefited from the reimbursement arrangement for the years in question and should not request a refund. There are two primary reasons for this belief. First, the average salary for an adjudicator during fiscal years 2001 through 2003 was $64,000, but the reimbursement formula assumed a $75,000 salary. Second, the non federal workload did not necessitate the services of a full time adjudicator and consequently SSA received additional state funded adjudicator resources to process federal claims. We believe that these factors, which are both favorable to SSA, would offset any potential finding of unallowable costs.

In the past, the AK DDS only showed personnel costs on their quarterly reports. More recently, the AK DVR has changed the reimbursement formula to include reimbursement for a percentage of general expenses. We will instruct the AK DDS to provide a breakdown of the Medicaid costs to reflect Personnel Costs, Indirect Costs, Medical Costs and Other Costs on Form SSA 4513.

We agree with this recommendation and will instruct the AK DVR to implement procedures to report expenditures in the proper FY and review Form SSA 4513 for fiscal years 2001 through
2003 and reclassify expenditures as appropriate.

If you have any questions regarding this audit, please contact, Shelly Beach, Program Expert, in the Center for Disability at shelly.beach@ssa.gov , by telephone at 206-615-2137, or Robert Iseminger, Disability Program Administrator at robert.iseminger@ssa.gov , by telephone at 206-615-2680.

Appendix E
State Agency Comments

Appendix F
OIG Contacts and Staff Acknowledgments
OIG Contacts
James J. Klein, Director, San Francisco Audit Division, (510)-970-1739
Jack H. Trudel, Audit Manager, (510)-970-1733

Acknowledgments
In addition to those named above:
Wilfred P.K. Wong, Auditor
Stephen Flaherty, Auditor
Brennan Kraje, Statistician
Kimberly Beauchamp, Writer Editor

For additional copies of this report, please visit our web site at www.socialsecurity.gov/oig or contact the Office of the Inspector General's Public Affairs Specialist at (410) 965 3218. Refer to Common Identification Number A -09-05-15025.

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 Executive Operations (OEO). 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 Executive Operations

OEO supports OIG by providing information resource management and systems security. OEO also coordinates OIG's budget, procurement, telecommunications, facilities, and human resources. In addition, OEO 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.