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Audit Report - A-01-96-61083


Office of Audit

Effectiveness of the Social Security Administration’s Procedures to Process Prisoner Information, Suspend Payments and Collect Overpayments - A-01-96-61083 - 6/24/97

TABLE OF CONTENTS

EXECUTIVE SUMMARY

INTRODUCTION

SCOPE OF AUDIT

RESULTS OF REVIEW

Prisoner Record Matching Procedures

-- Prison Match Design

-- Prisoner Records Processing

-- Paper Prison Record Submissions

Controls Over the Processing of Alerts

-- Alerts Not Processed

-- Timeliness of Alert Actions

-- Review of FO Procedures

-- Review of PSC Procedures

Prisoner Overpayment Collection Procedures

-- RSDI Collections

-- SSI Collections

-- SSA`s Collection Practices

RECOMMENDATIONS

APPENDICES

Appendix A -- Computer Match Sampling Methodology

Appendix B -- Paper Records Sampling Methodology

Appendix C -- Alerts Sampling Methodology

Appendix D -- Field Office Procedure Survey

Appendix E -- Supplemental Security Income Overpayment Sampling Methodology

Appendix F -- Overpayment Collection Sampling Methodology

Appendix H -- OIG`s Response to SSA`s Comments

Appendix I -- Major Contributors to the Report 

EXECUTIVE SUMMARY

OBJECTIVE

Our objective for this review was to determine whether the Social Security Administration (SSA) had adequate procedures for matching Federal, State, county, and local prisoner data to SSA`s records and suspending payments to prisoners identified. We also assessed whether SSA was effective in collecting overpayments from prisoners. 

BACKGROUND 

The Social Security Act (The Act) prohibits the payment of benefits to prisoners under the Retirement, Survivors, and Disability Insurance (RSDI) and the Supplemental Security Income (SSI) programs. This prohibition applies to individuals receiving RSDI benefits who are convicted of an offense punishable by imprisonment for more than 1 year and confined in a penal institution, and to individuals who are receiving SSI payments and confined in a public institution throughout any month.

Our previous audit entitled, "Effectiveness in Obtaining Records to Identify Prisoners" dated May 10, 1996, reported that prisoners were receiving RSDI and SSI program benefits. Our recommendations were intended to improve the timeliness of prisoner information. Also, improvements could be achieved by exempting prisoner agreements from the Computer Matching and Privacy Protection Act of 1988 and by searching other sources to obtain timely prisoner data. Most of our recommendations were included in the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, Public Law (P.L.) 104-193, which was signed on August 22, 1996.

To perform our review, we sampled prisoner records submitted to SSA and alerts that were produced when prisoner records matched SSA`s records. We also reviewed SSA`s collection efforts for RSDI and SSI prisoner overpayment cases. 

RESULTS OF REVIEW

Our previous audit focused on SSA`s effectiveness in obtaining prisoner information from Federal, State, and local correctional agencies on a timely basis in order to identify incarcerated beneficiaries and recipients. The current audit focused on SSA`s effectiveness in matching the prisoner information received with SSA`s payment records and suspending payments where appropriate. We found that payments to prisoners were not always detected nor stopped because of control weaknesses in SSA`s prisoner record matching procedures and in SSA`s processing of prisoner alerts. In addition, SSA has had limited success in attempting to recover overpayments made to prisoners.

Matching Prisoner Records

SSA`s procedures for matching prisoner data to its records do not provide reasonable assurance that prisoners who receive benefits are identified. We found that:

SSA`s Comments

In the Acting Commissioner`s letter transmitting SSA`s comments to the recommendations contained in our draft report, the Acting Commissioner expressed disappointment with the report and noted that he expected the report to reflect the remarkable improvements in the prisoner suspension process at SSA. He also noted that the data used to make recommendations was outdated and that we did not reference the changes SSA has implemented since 1993 and 1994. Also, the Acting Commissioner shared his confidence that SSA is on top of the prisoner suspension problem and has implemented almost all of the recommendations made in the report. Further, the Acting Commissioner urged the OIG to reconsider issuing the report in final or asked that we review the process from SSA`s perspective today. In addition to the comments summarized above, SSA provided an appendix containing specific comments addressing each of our 12 recommendations.

The following comments were made in response to our specific recommendations on making matching procedures for identifying prisoners receiving benefits more effective:

  • SSA implemented a new system on March 8, 1997 to process prisoner data which will produce alerts in cases where payments are currently suspended but could potentially be resumed and paid retroactively for a period of incarceration;
  • SSA modified the match to prevent duplicate tape processing and unnecessary alerts;
  • SSA encouraged sources to report electronically and has required that sources report electronically within 12 months of executing incentive payment agreements; and
  • SSA is studying ways to improve the EVS system in order to find ways to enhance prisoner matches and ways to make the SSN verification process more effective.

The following comments were made in response to our recommendations on making procedures for processing alerts of prisoners receiving benefits more effective:

  • with the implementation of the Prisoner Update Processing System (PUPS) in March 1997, alerts are sent to follow up on pending prisoner match alert cases;
  • with the implementation of PUPS, alerts will be sent to the regional office for investigation if the case is still pending after 120 days;
  • with the implementation of PUPS, SSA will ensure that all prisoner alerts are processed in a timely manner; and
  • as of March 1997, alerts are transmitted to FOs electronically.

The following comments were made in response to our recommendations making procedures for collecting overpayments from prisoners more effective:

  • SSA is developing data elements on the SSR that will enable better identification and monitoring of SSI prisoner overpayments;
  • SSA is assessing its policies and procedures regarding collection efforts for prisoner overpayments;
  • SSA is in the process of expanding the use of the tax refund offset to SSI delinquent debts for recipients whose benefits have been terminated; and
  • SSA will exercise its full statutory authority to recover overpayments where it is cost-effective to do so. 

OIG`s Response

We disagree with the Acting Commissioner`s characterization of the report and his conclusions and feel it necessary to address the issues he raises. The full text of our reply to the Acting Commissioner`s transmittal memorandum is contained in Appendix H.

With regard to pursuit of overpayments, SSA commented that it does not have the authority to use tax refund offset to recover debt from suspended beneficiaries, that it is limited by statute to a recovery rate of 10 percent of the SSI payment and that SSA has no authority to collect SSI overpayments from RSDI benefits without the voluntary consent of the individual. In response to SSA`s comment, we recommend that SSA seek a legislative change to allow more aggressive pursuit of overpayments if the current legislation does not allow SSA to perform all collection activities deemed effective.

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Appendix A 

Computer Match Sampling Methodology

To determine the effect of delays in processing prisoner records, we reviewed 2 separate samples from prisoner information received by the Social Security Administration (SSA) from 35 State correctional departments. To determine whether individuals identified in the information submitted by prisons were SSA beneficiaries, we traced the sampled prisoner records through SSA`s electronic matching program. For each of our sampled cases, we determined whether the individual was receiving Retirement, Survivors and Disability Insurance and/or Supplemental Security Income payments during their period of incarceration.

From prisoner information submitted by State correctional departments, we obtained access to 85 magnetic tapes containing 303,976 records submitted to SSA from July 1993 to February 1994. The 85 tapes contain records submitted by 33 different States. Information for two States (Montana and Oregon) was received by SSA during our audit period but not archived in time to be included in our sample.

We selected for review 12 of the 85 tapes using the Rao-Hartley-Cochran sampling method that uses approximate probability proportional to size selection techniques. We used the number of records on each of the 85 tapes as the size factor. In other words, a tape with more records had a greater chance of being selected than a tape with fewer records.

From each of the 12 tapes, we used simple random sampling to select 100, 125, 150 or 200 prisoner records. Prior to selecting our sample of prisoner records from the 12 tapes, we analyzed the tapes to remove multiple records for the same Social Security number. Our sample size was 1,525 from a possible 137,658 records contained on the 12 tapes.

Of the 1,525 prisoners` records selected, 91 were receiving benefits after their period of incarceration began. Our review of each case consisted of obtaining the Master Beneficiary Record and the Supplemental Security Record and comparing it to the prisoner information to determine whether SSA had identified that the beneficiary or recipient had been overpaid because he was a prisoner. We traced sample prisoner records through the prisoner matching process, from receipt to payment suspension. We identified control weaknesses and, using sample cases, tested their effect on the results of the computer match. Case folders were reviewed and field offices contacted to reconstruct how SSA learned of incarceration in each sample case.

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Appendix B 

Paper Records Sampling Methodology

To determine how many prisoners continued to receive Retirement, Survivors and Disability Insurance (RSDI) and/or Supplemental Security Income (SSI) benefits during the period that paper correctional agency records awaited processing, we used simple random sampling to select 200 of 6,646 prisoner records received between February 2 and November 21, 1995. Before eliminating duplicate records, there were 10,869 records. To determine whether the delay in processing the paper records resulted in additional overpayments, we reviewed each of the sample cases to determine whether any of the prisoners received RSDI and/or SSI benefits between February 1994 and February 1995.

Based on our review, seven of the prisoners were paid RSDI and/or SSI benefits during the period in which the Social Security Administration delayed processing the records. Projecting our results to the population of prisoner records submitted on paper and not processed immediately, we estimate that 233 prisoners continued to receive a total of approximately $558,000 in benefit payments while the paper records waited to be processed. At the 90 percent confidence level, the precision of this estimate is plus or minus 73.77 percent.

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Appendix C 

Alerts Sampling Methodology

We obtained 5,341 Retirement, Survivors and Disability Insurance (RSDI) prisoner alerts generated during the 6-month period of July 1 through December 31, 1994 from the Southeast Program Service Center in Birmingham (PSC 3) and the Office of Disability and International Operations Program Service Center in Baltimore (PSC 7). To determine whether the Social Security Administration (SSA) had adequate procedures to suspend RSDI benefit payments, we used simple random sampling to select 150 of the 5,341 RSDI prisoner alerts. Also, from SSA`s central office, we obtained 13,950 Supplemental Security Income (SSI) prisoner alerts generated during the 6-month period of July 1 through December 31, 1994. To determine whether SSA had adequate procedures to suspend SSI benefit payments, we used simple random sampling to select 150 of the 13,950 SSI prisoner alerts. For each sampled case, we obtained and reviewed case folders, prison confirmations, Master Beneficiary Records, and Supplemental Security Records.

Based on this sampling methodology, it was possible that more than one alert could be included in our population for the same beneficiary. To account for this in our sample, we did not include a beneficiary in our overpayment calculation and projection more than once. For example, two beneficiaries were randomly selected twice in our sample of 150 RSDI alerts. The first time we reviewed an alert for a beneficiary, we treated the alert as any sample item and calculated the related overpayment. However, the second time the same beneficiary was selected, we treated the case as if it were properly handled by SSA and did not calculate an overpayment.

For each case, we determined whether RSDI and/or SSI benefits should have been suspended. In this regard, we confirmed with the correctional facility the identity of the beneficiary as well as the dates of incarceration and whether the conviction was for a felony. To confirm the identity of the beneficiary, we requested that the correctional facility confirm the name, date of birth, and Social Security number of the prisoner against those of the beneficiary. In cases where we could not confirm the identity of the beneficiary as that of the prisoner, we did not calculate an overpayment.

Next, we reviewed the dates of incarceration. For cases where the identity of the prisoner was confirmed, we determined the length of incarceration. At the time of our review, RSDI benefits were to be suspended for a month any part of which the beneficiary was confined and convicted of a felony. Consequently, we only calculated overpayments for months in which the prisoner was confined for at least 1 day for a felony conviction.

Under SSI provisions, benefits are to be suspended for any month throughout which the recipient resides in a public institution. Hence, we only calculated overpayments for months in which the prisoner was confined for every day in that month. For example, if the recipient was incarcerated July 15 through August 15, 1994, benefits would be payable for the period of incarceration under the Social Security Act since the recipient was not confined for all of either month. In such a case, we did not calculate an overpayment.

In completing our review of cases and calculating the related overpayments, we calculated the overpayment from the date on which the alert was created. In this regard, we only included payments which were made more than 30 days after the alert was created. For example, if a beneficiary was incarcerated from January 1994 through January 1995, but the alert was created on August 15, 1994, we did not calculate the overpayment from January (the date of incarceration). Instead, we calculated the overpayment including any payments made after September 15, 1994 (30 days after alert issuance). Our overpayment period ended when one of the following events occurred: (1) the prisoner was released; (2) SSA terminated benefits for any reason; or (3) our audit started. In cases where the prisoner was released before the alert was created, we did not calculate an overpayment. For RSDI alerts, our overpayment period ended May 31, 1995, which was the start of our RSDI sample review. For SSI alerts, our overpayment period ended April 30, 1995, which was the start of our SSI sample review. 

 

RSDI Cases
Overpaid

RSDI
Overpayments

SSI Cases
Overpaid

SSI
Overpayments

Not
Processed

32

$ 96,488

16

$ 29,539

Processed Untimely

45

$ 64,967

15

$ 11,052

TOTAL

77

$ 161,455

31

$ 40,591

Based on the above, 77 of the 150 RSDI cases involved $161,455 in overpayments because alerts were not processed or were not processed in a timely manner. Projecting the results of the sample to the population, we estimate that $5.7 million of improper payments could have been prevented if the alerts printed during the 6-month period ending December 1994 had been processed timely. At the 90 percent confidence level, the precision of this estimate is plus or minus 19.54 percent.

For the SSI cases, 31 of the 150 cases involved $40,591 in overpayments because alerts were not processed or were not processed in a timely manner. Projecting the results of the sample to the population, we estimate that $3.8 million of improper payments could have been prevented if the alerts printed during the 6-month period ending December 1994 had been processed in a timely manner. At the 90 percent confidence level, the precision of this estimate is plus or minus 35.40 percent.

With regard to the 73 RSDI cases and 119 SSI cases which did not result in overpayments, we found the following: 

  Reason the Sample Item Was Not
Considered to be an Overpayment

RSDI Cases

SSI Cases

Suspense Period Ended Before Alert Created

25

22

Beneficiary Not Incarcerated an Entire Month

--

48

Beneficiary Not Convicted of a Felony

13

--

Benefits Suspended Within 30 Days of Alert Issuance

11

26

Beneficiary Identification Not Confirmed

11

2

Prisoner Not Paid During Incarceration

5

16

Overpayment Recovered Prior to Review

4

0

Benefits Suspended for Other Reason

0

4

Alert in Sample Twice

2

1

Family Maximum Offset of Overpayment

2

--

Total

73

119

To ensure that our overpayment calculations and projection were as accurate as possible, we considered the family maximum in each RSDI case, in relation to the amount of the overpayment. In this regard, in cases where the prisoner was receiving benefits as an auxiliary beneficiary, we determined whether the family maximum was in effect at the time of incarceration. In two cases, the overpayment made to the prisoner was completely offset by an underpayment made to other auxiliary beneficiaries on the same record. In these two cases, we did not calculate overpayments since the total payment to the families would have remained the same even if SSA had suspended payments to the prisoners.

For 25 RSDI cases and 22 SSI cases, we did not calculate an overpayment for our review even though an overpayment had been paid to the prisoner. In these cases, the prisoner alert was created after the prisoner`s incarceration period ended. In such cases, we did not calculate an overpayment since our review only included the handling of the alerts created and overpayments were only calculated for the period subsequent to the alert issuance. However, these beneficiaries were incarcerated for a period of time during which they received benefits. These cases need to be resolved by SSA and the respective benefit hich they received benefits. overpayments collected even were not considered overpayments during the period covered by our though they review.

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Appendix D 

Field Office Procedure Survey

To determine the procedures the Social Security Administration`s field offices (FO) follow to identify incarcerated Retirement, Survivors and Disability Insurance (RSDI) and Supplemental Security Income beneficiaries, we conducted a survey of 70 FOs who had processed cases sampled in our review. The questions asked of each FO are as follows:

1. Do you have formal or informal agreements with local or county correctional or mental health facilities to receive information on prisoners or inmates? If so, are you in the process of renewing or extending the agreements?

2. Do you receive information on prisoners or other inmates from any correctional or mental health facilities?

3. Do your agreements with local or county correctional or mental health facilities take into account recent changes brought about by the passage of Public Law 103-387?

4. Have you received and read a March 1995 release of Program Operations Manual System DI E11505.001-006C, which provides new procedures for collecting and processing prisoner information?

  • Have you prepared a plan that will implement the new procedures?
  • Have you attempted to amend your agreements to integrate the new procedures?
  • Have you attempted to inventory correctional and mental health facilities in your service area?
  • If you have inventoried correctional and mental health facilities in your service area, have you reported the inventory results to your Regional Office?

5.For information that you receive from local and county correctional or mental health facilities:

  • How is it controlled when received in the office?
  • How is it distributed to be processed?
  • How is it tracked and followed up on?
  • Is it tracked and followed up on after a suspension request is made?
  • Do you report on the results of that work?
  • What is the final disposition of the files or listings that you receive?
  • Do you have documentation showing the effectiveness of the match (e.g., number of suspensions per prisoner records received)?

6. When title XVI prisoner alerts are received:

  • How are they controlled when received in the office?
  • How are they distributed to be worked?
  • How are they tracked and followed up on?
  • Are they worked on a priority basis or after other postentitlement work?
  • How long do you keep alerts and related documentation?

7. Are you able to determine when you receive program service center (PSC) action requests whether they were initiated by the PSC`s receipt of an RSDI prisoner alert?

8. How are action requests stemming from RSDI prisoner alerts controlled, distributed, tracked, followed up on, and accounted for?

9. Do prisoner alert-related PSC action requests receive a different processing priority than other PSC action requests?

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Appendix E 

Supplemental Security Income Overpayment Sampling Methodology

To estimate the amount of Supplemental Security Income overpayments made to prisoners in Calendar Year (CY) 1994, we requested a data extract from the Supplemental Security Record (SSR) of all beneficiaries with overpayments who were suspended for "N02" status. This status includes all prisoner suspensions, but is also used for other suspension reasons as well. Our extract identified 31,499 overpayments which were "N02" suspensions during a period for which an overpayment occurred. These overpayments were all identified by the Social Security Administration (SSA) during CY 1994 and totaled $48.3 million.

To estimate the amount of the overpayments made to prisoners, we randomly selected 100 of the 31,499 overpayments and determined whether they were prisoners or whether their payments were suspended for another reason. The 100 sample cases had total overpayments of $166,673. Based on our review, 64 of the overpayments were made to prisoners and the amount overpaid to those 64 prisoners was $130,219 (78 percent). Projecting the results of our sample to the population of 31,499 overpayments valued at $48.3 million, we estimate that during CY 1994, SSA identified and initiated collection activities on $37.7 million overpaid to prisoners. At the 90 percent confidence level, the precision of this estimate is plus or minus 11.71 percent.

To determine whether each of the 100 sample cases were suspended due to incarceration, we reviewed SSRs and/or Master Beneficiary Records of the beneficiaries and contacted field offices when reviews of the automated files were inconclusive. The 36 beneficiaries who were not prisoners were mostly suspended due to residency in another type of institution, such as a nursing home.

Appendix F 

Overpayment Collection Sampling Methodology

From our statistical samples of 150 Retirement, Survivors and Disability Insurance (RSDI) and 150 Supplemental Security Income (SSI) beneficiaries discussed in Appendix C, we identified 64 RSDI cases and 47 SSI cases where the Social Security Administration (SSA) had identified overpayments and initiated collection activities prior to the start of our review.

For each case, we determined the outstanding overpayment amount as of March 1996 and its collection status. To confirm the collection status, we contacted program service centers and reviewed RSDI case folders and contacted field offices responsible for the 47 SSI cases. Overall, SSA had collected $48,720 (16 percent) of the RSDI overpayments and $15,137 (11 percent) of the SSI overpayments as of March 1996. Specifically, we found: 

  RSDI Overpayment Sample Cases

Collection
Status

Number of
Cases

Overpayment
Amount

Amount Collected

Percent
Collected

Full Collection

9

$ 13,780

$13,780

100%

Partial Collection

33

$153,527

$34,940

23%

No Collection

22

$134,357

$ 0

0%

Total

64

$301,664

$48,720

16%

 

Of the 64 RSDI overpayments, 9 had been fully collected, 33 had been partially collected, and, for the remaining 22, SSA had not collected any of the prisoner overpayment amount. Projecting the results of our review to the population of 5,341 prisoner alerts issued during July through December 1994, we estimate that of the $10.7 million overpaid to these prisoners, $8.9 million remained uncollected as of March 31, 1996. At the 90 percent confidence level, the precision of this estimate is plus or minus 31.59 percent. 

  SSI Overpayment Sample Cases

Collection
Status

Number of
Cases

Overpayment
Amount

Amount
Projected

Percent
Collected

Full Collection

5

$ 4,753

$ 4,753

100%

Partial Collection

13

$49,818

$10,384

21%

No Collection

29

$83,887

$ 0

0%

Total

47

$138,458

$15,137

11%

 

Of the 47 SSI overpayments, 5 had been fully collected, 13 had been partially collected, and, for the remaining 29, SSA had not collected any of the prisoner overpayment amount. Projecting the results of our review to the population of 13,950 SSI prisoner alerts issued during July through December 1994, we estimate that of the $12.9 million overpaid to these prisoners, $11.5 million remained uncollected as of March 31, 1996. At the 90 percent confidence level, the precision of this estimate is plus or minus 30.93 percent.

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Appendix H 

Office of the Inspector General’s (OIG) Response to
Acting Commissioner’s Comments to OIG Draft Report,
"Effectiveness of the Social Security Administration`s
Procedures to Process Prisoner Information,
Suspend Payments, and Collect Overpayments"

In your transmittal memo containing the comments to our recommendations, you express disappointment with the report. On the basis of your concerns, you urge that we reconsider issuing the report in final or ask that we review the results from the perspective of the Agency today. We disagree with your characterization of the report and your conclusions.

The report does not reflect the remarkable improvements SSA has made in the Prisoner Suspension Process.

The actions taken by the Social Security Administration (SSA) cited in your memo may indeed be noteworthy but they were taken in response to an earlier audit. In May 1996, we issued a report entitled "SSA`s Effectiveness in Obtaining Records to Identify Prisoners." In that report, we discussed SSA`s process for obtaining information on prisoners receiving SSA benefits and payments. The list of corrective measures cited in your memo were prompted by the recommendations made in that report. The current audit did not examine the adequacy of these corrective actions. Consequently, we do not know if these actions are working nor are we able to comment on them. We plan to undertake a follow-up audit to assess those corrective actions taken in response to our earlier audit and will comment on the success of SSA`s efforts then.

The results of the audit rely on old data from 1993 and 1994.

Your memo indicated that our audit found problems that existed in 1993-1994. Actually, our audit identified problems that have continually existed since 1993-1994. We found it useful to track these same long-standing issues from SSA’s failure to identify the prisoners to our second audit that found that once identified, SSA did not promptly act to suspend the unauthorized payments. SSA is just now taking actions intended to correct these long-standing deficiencies. There is no dispute on this issue. SSA’s prompt corrective actions to implement our recommendations testify to the reliability and relevance of the data we examined.

Your letter has identified a related problem, however. SSA frequently does not respond to OIG information requests in a timely manner. For example, for this audit, it took SSA over 4 months to provide us with the requested data. This is a very common problem that needs to be addressed. Under separate cover, we will identify the problem in greater detail and would appreciate your action to support our audit efforts.

Your memo does not clearly convey that the corrective actions taken were in response to our audit. You indicate that, over the past 2 years, SSA has worked to correct this problem and has implemented almost all of the OIG’s report recommendations.

This audit examined deficiencies in SSA’s policies and practices for taking payment suspension action upon learning that prisoners were receiving benefits. You point out that SSA has taken action in response to these problems. Your letter would lead an independent reader to believe that SSA took corrective action on payment suspensions divorced from our audit recommendations. That is not the case.

We had originally planned to do a series of audits on this problem. At the request of the former Commissioner, we did a single, comprehensive audit. So that the problems could be dealt with in a timely fashion, we briefed SSA after each problem was identified. We encouraged SSA to take action before the conclusion of our work, which it agreed to do. We did not expect that this professional courtesy would cause you to suggest that we not issue our report. We intend to issue the report and will identify corrective actions that you have agreed to take. We will also revisit this area in the next audit cycle to ensure that the actions taken are effective.

In the conclusion of your memo, you characterize SSA as very much on top of the issue of processing prisoner information. We take exception to your assessment. Our report clearly describes several areas where SSA needs to improve its prisoner information management and responsiveness. We believe the report is clear on these matters. That $20 million of taxpayer monies was improperly paid to incarcerated individuals and, to date, remains uncollected, illustrates our continuing concerns.

SSA is committed to addressing the problem of unauthorized payments to prisoners. We acknowledge your efforts in this area and look forward to continuing to work together to overcome it. All the same, we recognize that more work is needed before this problem is under control.

Appendix I

MAJOR CONTRIBUTORS TO THE REPORT

Office of the Inspector General

Gary Kramer, Director, Program Audits
Scott Patterson, Director, Evaluations and Technical Services
Roger Normand, Director, Program Audits
Rona Rustigian, Deputy Director, Program Audits
Pat Kennedy, Auditor
David Mazzola, Auditor
Jodi Connor, Auditor

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