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Audit Report - A-06-95-00076


Office of Audit

Review of Entitlement Determination Procedures for Unlocated Title II Disability Beneficiaries - A-06-95-00076 - 7/29/97

We evaluated policies and procedures that the Social Security Administration (SSA) uses for suspending and terminating benefits to title II disability beneficiaries whom SSA cannot locate. Except for actions involving Continuing Disability Reviews (CDR), SSA`s practice is to maintain the entitlement of unlocated beneficiaries by suspending, rather than terminating, benefits. This practice is inconsistent with section 223(f) of the Social Security Act (the Act) and SSA’s implementing regulations regarding unlocated title II disability beneficiaries. The relevant regulation at 20 Code of Federal Regulations (CFR) 404.1594(e)(3) states:

If there is a question about whether you continue to be disabled and we are unable to find you to resolve the question, we will determine that your disability has ended.

When SSA terminates benefits, the beneficiary’s entitlement to title II benefits ends. When SSA suspends benefits, however, the beneficiary’s entitlement to title II benefits continues.

During our review, we identified beneficiaries who incorrectly remained entitled to title II benefits because SSA suspended, rather than terminated, benefits when it could not locate the beneficiaries. Although SSA was not paying benefits to these unlocated beneficiaries, the value of the unpaid benefits continued to accrue pending resolution of the suspension issue. SSA would be obligated to pay these unpaid benefits if the beneficiaries or their representatives provided new addresses. However, if SSA had terminated the benefits as the relevant regulation requires, it would not be obligated to pay these benefits. In addition, SSA’s actions unnecessarily overstate SSA’s accrued benefit liability and program expenses in the Agency`s financial statements.

Based on a statistical sample of unlocated title II disability beneficiaries in suspended pay status, we identified an estimated $79.5 million in unpaid benefits as of September 30, 1995. We also identified $1.4 million in benefits SSA paid to related individuals (i.e., the spouse and children of the unlocated beneficiary) because the beneficiary incorrectly remained entitled to benefits. Therefore, we are recommending that SSA place an individual in terminated status after SSA has made reasonable attempts to locate the beneficiary and has provided the beneficiary with all appropriate due process rights.

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BACKGROUND

Legal Authority

The Social Security Disability Benefits Reform Act of 1984 (Disability Reform Act), codified at section 223(f) of the Act, establishes the basis for SSA to terminate disability benefits for beneficiaries SSA cannot locate. The accompanying congressional conference report states that benefits should be terminated either as a result of medical improvement or other exceptions. The specific exceptions which permit termination of title II benefits are set out in the conference report and include, among other things, failure to cooperate, failure to follow prescribed treatment, and cases where an individual cannot be located. Relevant SSA regulations at 20 CFR 404.1594(e)(3) reflect this legal requirement:

If there is a question about whether you continue to be disabled and we are unable to find you to resolve the question, we will determine that your disability has ended. The month your disability ends will be the first month in which the question arose and we could not find you.

Therefore, according to section 223(f) of the Act and implementing regulations, SSA’s inability to locate a beneficiary after several returned disability checks raises a question of continuing disability. If SSA is still unable to locate a beneficiary after reasonable attempts and due process has been provided, the Act requires that entitlement should end (i.e., benefit termination). Suspension of benefits should only be a means of stopping payments temporarily while SSA maintains entitlement and attempts to locate missing beneficiaries.

SSA Procedures

When a beneficiary is scheduled for a CDR and cannot be located, SSA sends a due process notice to the last known address informing the beneficiary that it will terminate benefits unless the beneficiary cooperates. If the beneficiary does not respond within 10 days, SSA terminates benefits.

In situations other than a CDR, SSA suspends, rather than terminates, benefits if it cannot locate the beneficiary. If an unlocated beneficiary in suspended pay status is subsequently found, and meets the entitlement criteria, SSA will pay the benefits accrued during suspension. Moreover, the suspension does not apply to related individuals, (i.e., the spouse and children of the beneficiary). If these individuals are entitled to benefits under the beneficiary’s record, they will remain entitled and continue to receive benefits as long as the beneficiary is entitled (i.e., while the beneficiary is in current or suspended pay status, but not in terminated status).

During the period of suspension, SSA records the unpaid amounts as a program expense in its accounting records. SSA also accrues a liability for the suspended payments. Both the program expense and liability are presented in SSA`s annual financial statements.

Efforts Required to Locate Missing Beneficiaries

The field office (FO) is required to take reasonable steps to find unlocated beneficiaries. First, the FO requests address information from the postmaster. Second, it contacts family members who receive benefits. When the FO contacts family members, it urges the family members to cooperate fully and reminds them that their benefits may be terminated if the FO cannot locate the beneficiary. If the FO had previously received a busy signal when attempting to telephone family members, it must attempt a telephone call at a different time and different day. Finally, the FO attempts to contact other sources based on leads in the beneficiary’s file. Other sources may include representative payees, relatives, friends, landlord, neighbors, merchants, employers, homeless shelters, financial institutions, city or State welfare agencies, and any medical sources and institutions to which the beneficiary has been admitted (Program Operations Manual System, section DI E13015.001 C.1.b.).

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SCOPE

This audit was performed in accordance with generally accepted government auditing standards. The objective was to evaluate SSA’s polices and procedures for suspending and terminating benefits to title II disability beneficiaries whom SSA cannot locate. We also assessed SSA’s compliance with legal requirements and, accordingly, obtained a legal opinion from the Inspector General Division (IG Division) of SSA’s Office of the General Counsel (OGC) in January 1996. The opinion is attached to this report as Appendix A. We limited our review of internal controls to those necessary to achieve the audit objective. We interviewed SSA personnel in the Dallas regional office, Southeastern Program Service Center in Birmingham, Alabama, and headquarters in Baltimore, Maryland. We conducted field work between August 1995 and January 1996.

We conducted a case folder review of a sample of unlocated title II disability beneficiaries selected from a 10 percent sample of the Master Beneficiary Record as of April 1995. The sample consisted of 537 title II disability beneficiary records in suspended pay status pending development of a correct address. We then selected a stratified random sample of 195 of those records. For each sampled record, we calculated the length of time that the benefits had been in suspended pay status and the dollar amount of those suspended benefits, as well as the amount of benefits paid to family members while the beneficiary was in suspended pay status.

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RESULTS OF AUDIT

We determined that SSA has a statutory obligation to terminate benefits for title II disability beneficiaries whom it cannot locate. The IG Division`s interpretation of the pertinent implementing regulation notes that returned checks and mailings raise a question regarding an unlocated beneficiary`s continuing disability. Thus, the fact that SSA cannot locate the beneficiary is grounds for termination after SSA has made reasonable efforts to locate the individual and has provided all appropriate due process rights.

Nearly $80 Million in Benefits are Payable to Beneficiaries Whom SSA Cannot Locate

At the time of our audit, we found that 115 of the 195 sampled beneficiary records remained suspended--many of them incorrectly. SSA should have terminated benefits for beneficiaries that it had attempted to locate and provided all appropriate due process rights. We found that the status of the 80 remaining sampled beneficiary records had changed at the time of our audit. For these sampled beneficiaries:

  • 50 were in current pay status;
  • 15 were in suspense status for reasons other than SSA’s inability to locate them (e.g., need for representative payee, prison-related problem);
  • 14 were in terminated status--mostly due to death; and
  • 1 was in deferred pay status.

The results of our review are shown in Appendix B.

Length of Suspension

We found that the length of benefit suspension for the 115 beneficiaries ranged from 1 month to 24 years. We noted that SSA made a determination to terminate benefits for one of the cases in our sample, but the benefits continued in suspense status at the time of our audit. For 35 of the unlocated beneficiaries (30 percent), the length of suspension was more than 4 years.

Reasons for Suspension of Payments

Pie Graph of Reasons for Suspending Payments

Returned benefit checks and SSA mailings were the primary reasons that SSA documented in case folders as to why it suspended benefits. These reasons applied to 62 of the 115 cases (see Figure 2). We were not able to determine why SSA suspended benefits for 51 cases because of a lack of case folder documentation. SSA suspended the remaining two cases due to: (1) a representative payee notification; and (2) a death alert.

SSA Potentially Obligated for Suspended Benefits to Unlocated Beneficiaries

SSA is potentially obligated for payments totaling $2.7 million for sampled beneficiaries whose benefits should have been terminated. This point bears repeating. Although SSA was not paying the benefits to these unlocated beneficiaries, the value of the unpaid benefits continued to accrue. SSA will pay, retroactively, the unpaid benefits if the beneficiaries or their representatives provide new addresses. Had SSA followed its own regulations and terminated the benefits, it would not be obligated to pay these benefits. Another ultimate effect of SSA’s actions is to overstate unnecessarily SSA’s accrued benefit liability and program expenses in the Agency`s financial statements. When projected to the 3,340 estimated unlocated beneficiaries in suspended pay status, we estimated this liability at $79.5 million as of September 30, 1995.

Our sample identified an estimated 250 records under which related individuals continued to receive benefits because SSA incorrectly suspended, rather than terminated, benefits. We projected that, from the date of suspension until September 30, 1995, SSA improperly paid $1.4 million in benefit payments to related individuals.

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RECOMMENDATIONS

We recommend that SSA:

1. examine the entitlement status of all disability beneficiaries who are in suspended pay status because they cannot be located; and

2. terminate benefits in cases where: (a) a reasonable time period lapses (e.g., 90 days from the date of suspension) to locate the beneficiary; and (b) due process has been provided (e.g., notification letter to last known address).

SSA COMMENTS

We appreciate the efforts of the Office of the Inspector General (OIG) in reviewing the Social Security Administration`s (SSA) policies and procedures that apply to suspending and terminating benefits to title II disability beneficiaries whom SSA cannot locate. Resolving cases that are in suspense continues to be a major initiative for the agency. Although we find we are unable to agree with the report recommendation, we value OIG`s input in our efforts to improve this process.

Recommendation

That SSA:

  • determine the entitlement status of all disability beneficiaries who are in suspended pay status because they cannot be located; and
  • terminate benefits after: (a) a reasonable time period lapses (e.g., 90 days from the date of suspension) to locate the beneficiary; and (b) due process is given (i.e., sending a notification letter to last known address).

Comment

As stated in the report, the Social Security Disability Benefits Reform Act of 1984, (codified at section 223(f) of the Social Security Act), established the basis for SSA to terminate disability benefits for beneficiaries SSA cannot locate when these cases are being reviewed to determine if the impairments have ceased, no longer exist, or are no longer disabling. The accompanying conference report provides for terminating benefits without full medical development, either as a result of medical improvement or other exceptions, such as failure to cooperate, failure to follow prescribed treatment, and cases where the beneficiary cannot be located.

With respect to cases where the beneficiary cannot be located, the relevant SSA regulation at 20 CFR 404.1594(e)(3) states that, if there is a question about whether the beneficiary continues to be disabled and SSA is unable to find the individual, it will be determined that the disability has ended. The OIG report cites this regulation, along with an SSA Office of the General Counsel (OGC) staff attorney opinion, to support its conclusion that suspended title II beneficiaries for whom checks and mailings have been returned should be terminated because such returns raise the question of continuing disability.

After further review of the pertinent regulation, OGC does not believe that it provides the authority to terminate disability beneficiaries outside of the continuing disability review (CDR) process. Instead, OGC believes that the regulation clearly provides that as a threshold matter there must be a question about whether the claimant continues to be disabled before the inability to locate the claimant can result in a termination (20 CFR 404.1594(e)(3)). This regulation was promulgated to implement section 223(f) of the Act, which sets forth the criteria for CDRs and, accordingly, should be applied in the context of a CDR. Under OGC`s analysis, the intent of the law is that there must first be a question of continuing disability resulting in the case being selected for review, before termination can take place because of inability to locate. A copy of OGC`s revised opinion is attached (Appendix D).

We generally agree, as is stated in the earlier OGC opinion, that when a case is already being reviewed because of some evidence regarding continued disability, or because it was scheduled for a CDR, returned mailings can be the basis for termination. We do not believe, however, that outside the CDR process, returned checks or mailings, are, in and of themselves, an indication of whether disability is continuing, or that the inability to locate a beneficiary raises the question of continuing disability. When there is no other evidence that raises this question, returned mailings are more likely to be an indication of a deterioration of medical condition requiring a change in care, a family emergency, or a change in living arrangement for other reasons. Therefore, we continue to believe that the appropriate action to take in these kinds of cases is suspension of disability benefits.

While we are unable to implement the report`s recommendation, we believe the information it provides offers helpful insight as SSA continually seeks ways to resolve cases in suspense. As stated in SSA`s recent response to an OIG report, "Follow-Up Report on a Department of Health and Human Services` OIG Audit Entitled "Suspended Payments Need to be Resolved Timely" (A-13-93-00421) the agency has several initiatives, planned and underway, to ensure more timely resolution of current and future suspensions. In addition, we will explore the possibility of initiating CDRs for unlocated disability beneficiaries whose benefits have been suspended for an extended period, and we will ask our Office of Program and Integrity Reviews to conduct a brief study of unlocated disability beneficiary records. We believe that these efforts will greatly enhance our ability to resolve more suspense cases.

Other Comments

The last sentence of the second paragraph on page 1, as well as the section on page 5, "SSA Still Obligated for Suspended Benefits to Unlocated Beneficiaries," conclude that SSA`s actions in suspending, rather than terminating, these beneficiaries has the effect of overstating SSA`s accrued benefit liability on the financial statement and related benefit expense. This conclusion is factually inaccurate and both references should be deleted.

As recognized in the report, beneficiaries in suspense continue to have a right to unpaid benefits. The amount of these benefits is a liability and it is SSA`s responsibility to show the amount as an accrued liability on its financial statements. Under existing policy, this amount cannot be characterized as an overstatement.

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OIG RESPONSE TO SSA COMMENTS

Issue

Whether the Agency is legally precluded from terminating a beneficiary’s title II disability benefits when the Agency: (a) cannot locate the beneficiary; and (b) the beneficiary is not scheduled for a CDR.

OIG Position

The Agency is not legally precluded from terminating title II benefits in whereabouts unknown cases where the Agency has received several returned disability checks. However, the Agency must ensure that the beneficiary is provided with all relevant due process rights prior to termination of benefits.

Background

In January 1996, our office received a legal opinion from the OGC, Inspector General Division (IG Division Opinion) on the above-noted issue. The legal opinion concluded that the plain meaning of section 223(f) of the Social Security Act (Act) and relevant regulations did not preclude the Agency from terminating title II disability benefits in cases of whereabouts unknown, if the Agency had received several returned checks and due process rights were provided.

The IG Division Opinion also noted concurrence from the Policy and Legislation Division of OGC, pursuant to the Interim Memorandum of Understanding (MOU) between the Inspector General and the General Counsel in effect at that time. The opinion was widely circulated throughout the Agency and went unchallenged for nearly 15 months. The Agency questioned the validity of the legal opinion only after the Office of Audit issued its draft audit recommendations in March 1997. In April 1997, the General Counsel issued his own legal opinion on this issue (General Counsel`s Opinion) (Appendix C). The General Counsel issued a memorandum to the Inspector General on this issue in June 1997 (Appendix D).

We have concluded that the IG Division Opinion, which had the concurrence of OGC`s Policy and Legislation Division, in compliance with the relevant MOU, provides the sounder legal analysis. Our reasoning follows.

Legal Standard - IG Division Opinion

The Disability Reform Act, Public Law 98-460, establishes a standard of review for Agency determinations of continuing entitlement to disability benefits, and all other determinations that disability benefits should be terminated. The conference report accompanying the Disability Reform Act explains that, under the revised standard, disability benefits should be terminated only for beneficiaries who can perform substantial gainful activity due to medical improvement in their medical conditions, and beneficiaries to whom certain exceptions apply. The Disability Reform Act standard of review for termination of disability benefits, and relevant exceptions language, is codified at section 223(f) of the Act. Additionally, the Agency has promulgated implementing regulations which further develop the exceptions to the medical improvement standard (e.g., whereabouts unknown). See 20 C.F.R. 404.1594 et. seq.

According to the IG Division Opinion, section 223(f) expressly excepts the Agency from the mandatory entitlement determination requirement (e.g., CDR) in cases of whereabouts unknown. The relevant exceptions language in section 223(f) reads as follows:

Nothing in this subsection shall be construed to require a determination that a [title II beneficiary based on disability] ... is entitled to such benefits ... if the individual ... cannot be located. (emphasis added).

In other words, the express statutory exceptions language prohibits SSA from construing section 223(f) to require a disability entitlement "determination" or CDR, in cases of whereabouts unknown. This makes enormous practical sense, inasmuch as there is no reason to require a CDR, employing a medical improvement standard, when the beneficiary

cannot even be located. Moreover, we find such an interpretation to be consistent with the conference report language on exceptions to the medical improvement standard. Thus, we feel that the answer to the above-noted issue can be gleaned from the plain statutory language of section 223(f).

The implementing regulations also recognize this express statutory exception to the medical improvement or CDR requirement. See 20 C.F.R. 404.1594(e)(3). The regulations specifically list whereabouts unknown as an exception to the blanket rule requiring a CDR prior to terminating title II disability benefits:

If there is a question about whether you continue to be disabled and we are unable to find you to resolve the question, we will determine that your disability has ended. The month your disability ends will be the first month in which the question arose and we could not find you. (emphasis added).

We feel that a series of returned, uncashed benefit checks certainly raise "a question about whether . . . [a title II beneficiary] continue[s] to be disabled" under 20 C.F.R. 404.1594(e)(3). The whereabouts unknown beneficiary may be deceased, working "off-the-books," or otherwise not entitled. Further, we find that our interpretation of the regulatory phrase "a question about whether you continue to be disabled" harmonizes SSA’s implementing regulations with the express statutory prohibition against conducting a CDR for whereabouts unknown.

As noted in the IG Division Opinion, due process matters must be resolved prior to termination. As a temporary stop-gap measure, benefits should be suspended upon the discovery of the returned checks. During this suspension period, SSA should contact the beneficiary’s auxiliaries in an attempt to locate the beneficiary under 20 C.F.R 404.1595. Proper notice and appeal rights should be provided to all relevant parties as specified in 20 C.F.R. 404.1595, 404.1597. However, if such efforts are unsuccessful, the Act requires that benefits be terminated.

Disagreement with General Counsel’s Opinion

In numerous places, the General Counsel’s Opinion states that the Agency must have some reason for selecting a case for a CDR before returned mailings could provide a basis for termination of disability benefits. In reaching this conclusion, the General Counsel sidesteps the relevant statutory provision, and instead relies on SSA’s implementing regulation. We find such heavy reliance on this regulation to be misplaced. Additionally, we feel that the General Counsel’s interpretation of the relevant regulatory provision puts the regulation in direct conflict with section 223(f) of the Act.

The disputed clause can be found in SSA’s implementing regulation for section 223(f). See 20 C.F.R. 404.1594(e)(3). Specifically, it states that "[i]f there is a question about whether you continue to be disabled and we are unable to find you to resolve the question, we will determine that your disability has ended." (emphasis added). As noted above, we read this clause to mean that a series of returned checks would logically raise a question as to whether a title II beneficiary is still disabled. We base our reading on the IG Division Opinion. In contrast, the General Counsel’s April 1997 Opinion interprets this clause as a "threshold requirement that there be some question regarding a beneficiary’s continuing disability before the inability to locate a beneficiary can result in a termination." The General Counsel’s Opinion also states that "[s]ome evidence, information, or scheduling regarding a CDR must first exist that would cause the Agency to contact the beneficiary for purposes of a CDR." (emphasis added).

We find the General Counsel’s regulatory interpretation to be in direct conflict with the plain meaning of section 223(f) of the Act. The section 223(f) exceptions language prohibits the Agency from construing section 223(f) to require the application of the medical improvement standard in certain instances (e.g., whereabouts unknown). Indeed, the implementation of such a medical improvement standard for whereabouts unknown leads to somewhat bizarre results. First, the Agency would be required to perform a medical improvement CDR, even when it cannot locate somebody to start such a CDR. Second, such an interpretation would make the length of title II entitlement, for an individual whom SSA cannot find, a function of when a computer selects the person for a medical improvement determination (e.g., CDR). This makes length of entitlement for whereabouts unknown a function of a computer’s randomization selection criteria for CDRs.

In practical terms, the Agency’s adoption of this legal position has resulted in whereabouts unknown cases, where length of entitlement ranges from several months to 24 years, depending on CDR selection date. Meanwhile, the auxiliaries of many title II beneficiaries maintain their entitlement to benefits throughout the entire period. Such auxiliaries would have received benefit checks throughout the entire period, even though there would have been no way to determine whether the entitled individual was still entitled to benefits (e.g., alive or deceased). Such a rule could be perceived as unfair to the whereabouts unknown individual with auxiliaries whose benefits are terminated within a matter of months due to a CDR, and overly generous to the whereabouts unknown individual whose auxiliaries maintain entitlement status for many years because no CDR has been scheduled.

Thus, we find that the IG Division Opinion provides sounder legal reasoning and more consistent results. The IG Division Opinion would allow all title II whereabouts unknown cases to be handled in an identical fashion. Specifically, SSA would make an attempt to locate the beneficiary, contact any auxiliaries, provide due process, and then terminate entitlement. Moreover, the Agency would not be paying auxiliaries for many years, when the entitled wage earner may no longer be alive.

Disagreement with Agency Response - Policy Issues

We strongly disagree with the Agency’s position that several returned disability checks do not raise a question regarding continuing disability. Specifically, the Agency states:

We do not believe, however, that outside the CDR process, returned checks or mailings, are, in and of themselves, an indication of whether disability is continuing, or that the inability to locate a beneficiary raises the question of continuing disability. When there is no other evidence that raises this question, returned mailings are more likely to be an indication of a deterioration of medical condition requiring a change in care, a family emergency, or a change in living arrangement for other reasons.

After we received the Agency’s response, we reviewed our audit working papers to definitively determine whether returned mailings and/or unknown addresses, in and of themselves, ever directly correlate with the death of a title II disability beneficiary. We examined this parameter, because we thought it would provide a definitive answer as to whether returned checks and/or address unknown ever raise the "ultimate question" as to continuing disability status--death. Moreover, we thought that all parties would agree that leaving deceased individuals in entitlement status creates an unnecessary liability, and opens the door to erroneous payments to auxiliaries.

Our brief review uncovered 13 such cases in our sample alone. In these 13 cases, deceased individuals were inappropriately placed in suspense status due to returned mailings and/or unknown address. We find this to be compelling evidence that returned mailings raise a legitimate issue as to continuing entitlement to disability benefits.

Other Matters

SSA stated that it would explore initiating CDRs for all beneficiaries who have been in suspense status for an extended period of time. Even if SSA instituted such a CDR policy, it would not be responsive to our audit findings. As noted at length above, unlocated title II beneficiary cases should not be subject to the CDR process.

Finally, SSA feels that our statements related to overstatement of accrued liability on the financial statements are factually inaccurate. SSA is correct in stating that beneficiaries in suspense status continue to have the right to unpaid benefits and, therefore, this information should be included in the financial statements. However, we believe that these beneficiaries are incorrectly in suspense status, thus making it unnecessary to present this information in the financial statements. We have revised the report to reflect this point.

- David C. Williams

1   H.R. Rep. No. 98-1039, 2d Sess. at 25 (1984).
 
Id. at 25-26. See also section 223(f) of the Act.

3 The purpose of the MOU was to ensure that the Inspector General was provided with independent and authoritative legal advice. As such, the MOU created a mechanism for the Inspector General to receive legal advice from a separate unit of OGC, the IG Division, "provided in a manner consistent with the statutory independence" of the Inspector General. The MOU required that "where the OIG unit proposes to issue a legal opinion to the OIG which interprets or analyzes SSA program law, a draft of that opinion will be shared with appropriate OGC staff prior to issuance for OGC concurrence. The appropriate OGC staff shall review the draft and provide concurrence or comments as promptly as possible." As the IG Division component satisfied all of the relevant requirements in the MOU, including securing concurrence from OGC program attorneys, the legal opinion was a valid IG Division Opinion at the time, and continues to function as such to this day. In October 1996, staff attorneys in the IG Division were absorbed into the Office of the Counsel to the Inspector General. This new OIG unit provides legal advice solely to the Inspector General.

H.R. Rep. No. 98-1039, 2d Sess. at 25 (1984).

Relevant SSA regulations clearly define a CDR as a disability entitlement determination. For example, 20 C.F.R. 404.1589 states the following:

[W]e must evaluate your impairment(s) from time to time to determine if you are still eligible for disability cash benefits. We call this evaluation a continuing disability review. (emphasis added).

The Conference Report briefly touches on the relevant exceptions, and it essentially paraphrases the statutory language. H.R. Rep. No. 98-1039, 2d Sess. at 25 (1984).
 
See United States v. Ron Pair Enterprises, Inc., 109 S.Ct. 1026, 1031 (1989) (noting that "[t]he plain meaning of legislation should be conclusive, except in the ... rare cases [in which] the literal application of a statute will produce a result demonstrably at odds with the intentions of its drafters") (citations omitted).
 
 8  Our audit report noted that 30 percent of the whereabouts unknown cases involved beneficiaries who remained entitled for a period between 4 to 24 years.
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Appendix B

NUMBER OF DISABLED BENEFICIARIES NOT LOCATED

STRATA DESCRIPTION

SSA SAMPLE

OIG SAMPLE

OIG RESULTS - BENEFICIARIES NOT LOCATED

Family members in current payment status

35

35

15

Family members not in current payment status

99

50

28

No family members on the record

403

110

72

TOTAL

537

195

115

Projectable Number  

115

 
Projected Number of Beneficiaries Not Located  

3,340

 
Confidence Limits at 90 Percent:      
Lower Limit  

3,070

 
Upper Limit  

3,610

 

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NUMBER OF CASE RECORDS WITH FAMILY MEMBERS PAID DURING THE SUSPENSE PERIOD

STRATA DESCRIPTION

SSA SAMPLE

OIG SAMPLE

OIG RESULTS - NUMBER OF CASES RECORDS WITH FAMILY MEMBERS

Family members in current payment status

35

35

15

Family members not in current payment status

99

50

5

No family members on the record

403

110

0

TOTAL

537

195

20

Projectable Number  

20

 
Projected Number of Cases Records with Paid Family Members  

250

 
Confidence Limits at 90 Percent:      
Lower Limit  

200

 
Upper Limit  

300

 

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TOTAL SUSPENDED BENEFITS FOR DISABLED
BENEFICIARIES NOT LOCATED

STRATA DESCRIPTION

SSA SAMPLE

OIG SAMPLE

OIG RESULTS - AMOUNT

Family members in current payment status

35

35

$ 231,266.40

Family members not in current payment status

99

50

848,325.30

No family members on the record

403

110

1,649,552.90

TOTAL

537

195

$2,729,144.60

Projectable Amount    

$2,729,144.60

Projected Amount of Suspended Benefits    

$79,543,120

Confidence Limits at 90 Percent:      
Lower Limit    

$66,452,130

Upper Limit    

$92,634,120

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