[Senate Hearing 117-421]
[From the U.S. Government Publishing Office]
S. Hrg. 117-421
SOCIAL SECURITY DURING COVID:
HOW THE PANDEMIC HAMPERED ACCESS
TO BENEFITS AND STRATEGIES FOR
IMPROVING SERVICE DELIVERY
=======================================================================
HEARING
before the
COMMITTEE ON FINANCE
UNITED STATES SENATE
ONE HUNDRED SEVENTEENTH CONGRESS
FIRST SESSION
__________
APRIL 29, 2021
__________
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Printed for the use of the Committee on Finance
______
U.S. GOVERNMENT PUBLISHING OFFICE
48-991-PDF WASHINGTON : 2022
COMMITTEE ON FINANCE
RON WYDEN, Oregon, Chairman
DEBBIE STABENOW, Michigan MIKE CRAPO, Idaho
MARIA CANTWELL, Washington CHUCK GRASSLEY, Iowa
ROBERT MENENDEZ, New Jersey JOHN CORNYN, Texas
THOMAS R. CARPER, Delaware JOHN THUNE, South Dakota
BENJAMIN L. CARDIN, Maryland RICHARD BURR, North Carolina
SHERROD BROWN, Ohio ROB PORTMAN, Ohio
MICHAEL F. BENNET, Colorado PATRICK J. TOOMEY, Pennsylvania
ROBERT P. CASEY, Jr., Pennsylvania TIM SCOTT, South Carolina
MARK R. WARNER, Virginia BILL CASSIDY, Louisiana
SHELDON WHITEHOUSE, Rhode Island JAMES LANKFORD, Oklahoma
MAGGIE HASSAN, New Hampshire STEVE DAINES, Montana
CATHERINE CORTEZ MASTO, Nevada TODD YOUNG, Indiana
ELIZABETH WARREN, Massachusetts BEN SASSE, Nebraska
JOHN BARRASSO, Wyoming
Joshua Sheinkman, Staff Director
Gregg Richard, Republican Staff Director
(ii)
C O N T E N T S
----------
OPENING STATEMENTS
Page
Wyden, Hon. Ron, a U.S. Senator from Oregon, chairman, Committee
on Finance..................................................... 1
Crapo, Hon. Mike, a U.S. Senator from Idaho...................... 2
ADMINISTRATION WITNESS
Kim, Grace, Deputy Commissioner for Operations, Social Security
Administration, Baltimore, MD.................................. 4
ADDITIONAL WITNESSES
Causeya, Kascadare, program manager, Central City Concern,
Portland, OR................................................... 6
Murphy, Peggy, immediate past president, National Council of
Social Security Management Associations, Great Falls, MT....... 7
McGuinness, Tara Dawson, fellow and senior adviser, New Practice
Lab, New America, Washington, DC............................... 9
ALPHABETICAL LISTING AND APPENDIX MATERIAL
Causeya, Kascadare:
Testimony.................................................... 6
Prepared statement........................................... 39
Responses to questions from committee members................ 42
Crapo, Hon. Mike:
Opening statement............................................ 2
Prepared statement........................................... 44
Kim, Grace:
Testimony.................................................... 4
Prepared statement........................................... 45
Responses to questions from committee members................ 50
McGuinness, Tara Dawson:
Testimony.................................................... 9
Prepared statement........................................... 95
Responses to questions from committee members................ 99
Murphy, Peggy:
Testimony.................................................... 7
Prepared statement........................................... 104
Responses to questions from committee members................ 110
Wyden, Hon. Ron:
Opening statement............................................ 1
Prepared statement........................................... 114
Communications
AARP............................................................. 117
American Federation of Government Employees, AFL-CIO............. 119
American Federation of Government Employees, Council 220 New York
Region......................................................... 123
Center for Fiscal Equity......................................... 127
Consortium for Citizens with Disabilities........................ 128
Inner City Law Center............................................ 132
International Association of Rehabilitation Professionals........ 140
Justice in Aging................................................. 141
National Disability Rights Network............................... 144
National Organization of Social Security Claimants'
Representatives................................................ 148
National Treasury Employees Union................................ 152
SOCIAL SECURITY DURING COVID:
HOW THE PANDEMIC HAMPERED ACCESS
TO BENEFITS AND STRATEGIES FOR
IMPROVING SERVICE DELIVERY
----------
THURSDAY, APRIL 29, 2021
U.S. Senate,
Committee on Finance,
Washington, DC.
The hearing was convened, pursuant to notice, at 10:07
a.m., via Webex, in the Dirksen Senate Office Building, Hon.
Ron Wyden (chairman of the committee) presiding.
Present: Senators Stabenow, Menendez, Cardin, Brown,
Bennet, Warner, Whitehouse, Hassan, Cortez Masto, Warren,
Crapo, Thune, Portman, Cassidy, Lankford, Daines, and Young.
Also present: Democratic staff: Tom Klouda, Senior Domestic
Policy Adviser; and Joshua Sheinkman, Staff Director.
Republican staff: Gregg Richard, Staff Director; and Jeffrey
Wrase, Deputy Staff Director and Chief Economist.
OPENING STATEMENT OF HON. RON WYDEN, A U.S. SENATOR FROM
OREGON, CHAIRMAN, COMMITTEE ON FINANCE
The Chairman. This morning, the Finance Committee meets to
discuss ways to improve Social Security after a difficult
pandemic year.
The employees at Social Security have worked hard to get
payments out on time, while undergoing big changes to the way
the agency operates. Despite that, the reality is, social
distancing and Social Security go together like water and oil.
The Social Security Administration has tens of thousands of
employees and 1,500 field offices around the country. Sixteen
of those offices, and more than 500 employees, serve Oregon
alone. It takes a lot of hard work to uphold the promise of
Social Security, and that work often looks awfully old-school:
face-to-face interaction and lots of paper documents.
Social Security closed their field offices when the country
went into lockdown. That is because gathering seniors and those
with disabilities in confined offices would have been the worst
imaginable idea 12 months ago. Social Security also needed to
protect their own employees. But the fact is, the level of
service dipped when Social Security's old-school approach no
longer worked during the pandemic.
Being cut off from face-to-face service is hardest on
seniors and folks who rely the most on Social Security. They
often have very modest incomes and may not even have Internet
access. The number of new applications for certain types of
Social Security benefits plummeted during the pandemic. There
is an extra layer of difficulty coming between a lot of
Americans and Social Security benefits they are eligible to
receive.
With fewer employees working in person, work that cannot be
handled remotely, such as handling mail or verifying documents,
has piled up. Social Security's ability to process applications
and other important data has slowed. Some Americans have been
asked to put their most sensitive personal documents in the
mail--not a copy, the original, including driver's licenses and
birth certificates.
That would have been an unattractive prospect to a lot of
people even before Louis DeJoy arrived at the Postal Service.
These days, particularly because of the pandemic, the big
challenge facing Social Security is reaching people who are
unable or prefer not to deal with the government online. In the
future, Social Security could face the opposite challenge. More
people will want to interact with Social Security through a
smartphone or a computer, and the face-to-face approach may be
less common.
When you are talking about changing business as usual at
Social Security, it is not just a question of responding to the
pandemic. There are big challenges ahead. This committee and
the Social Security Administration need to explore new ways of
meeting the needs of Americans to provide the benefits they
have earned, need, and deserve. Making smart improvements to
Social Security based on the experience of COVID-19 can pay off
big in the future.
All of these areas fall under the far-out, revolutionary
agenda I describe as ``making government actually work
better.'' There has never been a more important time, as far as
I am concerned, for Social Security. For me, this hard work
goes back to the days when I was co-director of the Oregon Gray
Panthers and ran the legal aid service for the elderly.
In the course of that job, I visited with a lot of seniors
who were walking an economic tightrope, barely able to cover
their bills. Social Security was a lifesaver for them. With too
many of today's seniors, we still find them going through that
kind of hardship that is made even more difficult by a global
pandemic and a year of isolation.
So this committee, on our watch, is going to uphold the
promise of Social Security. I am glad we are going to be able
to have this opportunity to discuss improving access to the
benefits and services.
We have excellent witnesses today. We will have their
introductions shortly.
[The prepared statement of Chairman Wyden appears in the
appendix.]
The Chairman. Senator Crapo?
OPENING STATEMENT OF HON. MIKE CRAPO,
A U.S. SENATOR FROM IDAHO
Senator Crapo. Thank you, Mr. Chairman, for holding today's
hearing on Social Security service delivery during the
pandemic. Social Security employees were informed in March of
last year that they would be teleworking indefinitely, and that
field offices would be closed to the public because of the
COVID-19 pandemic.
Within days of announcing a shutdown, the majority of field
office employees and a large number of teleservice center
employees were teleworking. Initial challenges included lack of
equipment, software licensing, and data capacity. The
leadership, management, and the workforce at the Social
Security Administration responded rapidly to increased data
capacity and stabilized networks after only a few weeks.
During the pandemic, conducting office and processing
center work in person was not possible because of lockdowns and
worker safety concerns. With those constraints, SSA has had to
innovate, relax some procedural rules, and perform in many
previously untested ways.
Thus far, the agency has performed admirably and rapidly to
ensure that beneficiaries, including at-risk populations,
obtain the services they need.
I have been impressed by the dedication and diligence of
SSA's workforce, the field office and processing center
managers, and the leadership all the way to the top. Customer
service and service delivery have been at the forefront of
their efforts during the pandemic.
We are fortunate to have SSA's head of operations, Ms.
Grace Kim, with us today. I am interested in her assessment of
where SSA has been during the pandemic, where things stand
currently, and lessons learned thus far to help us inform the
future.
From the beginning of the pandemic, field office management
staff have continued to physically go into the offices to
handle incoming and outgoing mail, scan documents and support
those working from home, provide in-person service for
critical-need cases, and handle facilities-related duties.
Ms. Peggy Murphy is also with us today, and I look forward
to hearing about her experience and insight as a representative
of field office management.
I am also interested in the experiences and service-
delivery perspectives of our other two witnesses, Ms.
McGuinness and Mr. Causeya--I hope I pronounced that right.
During the pandemic, it has been important to focus on at-
risk populations, including many on Supplemental Security
Income, Disability Insurance beneficiaries, and homeless
beneficiaries. I am interested in hearing today about service
delivery to at-risk beneficiaries and outreach.
My understanding is that the Social Security Administration
has engaged in an unprecedented amount of outreach to community
organizations, beneficiary advocate organizations, and directly
to at-risk beneficiaries themselves. I commend the Social
Security Administration's commitment and dedication to ensure
that beneficiaries receive their service and benefits.
Commissioner Saul has stayed true to the focus on
beneficiary service that we all expected when he was confirmed
on a bipartisan basis by this committee and the full Senate.
Solid leadership and a dedicated workforce have been key to
enabling the agency to confront the service-delivery shock of
the pandemic.
Thus far, the SSA has risen to that challenge.
Thank you, Mr. Chairman.
[The prepared statement of Senator Crapo appears in the
appendix]
The Chairman. Thank you, Senator Crapo.
Now I would like to introduce our four witnesses. Our first
witness will be Ms. Grace Kim, Deputy Commissioner of
Operations for Social Security. She is headquartered in
Baltimore. She is joining us today from San Francisco.
Our next witness, Kascadare Causeya, is up early in my home
town of Portland, OR. He is program manager at Central City
Concern. Central City helps those with life's biggest
challenges to end or avoid homelessness and build healthy
housing resilience and an engaged life. Kasc, as he is known by
his friends, heads up BEST--Benefits and Entitlement Specialist
Team--and works with the homeless to assist them in applying
for benefits.
Our third witness will be Peggy Murphy, immediate past
president of the National Council of Social Security Management
Associations. Ms. Murphy is the District Manager of the Social
Security office in Great Falls, MT.
And our final witness is Tara Dawson McGuinness, the
founder of the New Practice Lab and a senior adviser to New
America in Washington, DC.
We will begin with you, Ms. Kim.
STATEMENT OF GRACE KIM, DEPUTY COMMISSIONER FOR OPERATIONS,
SOCIAL SECURITY ADMINISTRATION, BALTIMORE, MD
Ms. Kim. Chairman Wyden, Ranking Member Crapo, and members
of the committee, I am Grace Kim, Deputy Commissioner for
Operations at the Social Security Administration. In my current
position, as a former regional commissioner, and as a career
SSA employee for over 30 years, I understand how vital SSA's
programs and services are to the public.
Thank you for inviting me to discuss our service delivery
during the coronavirus pandemic. I appreciate the opportunity
to share some of our accomplishments and challenges as we
prioritize health and safety, while delivering vital services.
I am so proud of the agency's employees who have worked to
serve our customers, despite their own personal challenges,
during the pandemic. It is my honor to lead over 44,000
employees in more than 1,200 local field offices, 24
teleservice centers, and eight processing centers.
I am also pleased to oversee the work of the 15,000
employees in the Disability Determination Services, the State
agencies that make our medical determinations.
Since the beginning of this crisis, Commissioner Andrew
Saul's priority has been safety for our employees and the
public. Many of the people we serve, older individuals and
those with serious health conditions, are at a higher risk for
the effects of COVID-19. To allow for physical distancing and
to limit close contact, in March 2020 we made the unprecedented
decision to have our employees work from home and to limit in-
person services to appointment only.
No one anticipated the length of the pandemic, but we have
been working hard throughout the last year to implement
policies that support the public and focus on delivering
mission-critical services.
We published our local field office phone numbers. We
extended time frames to submit documents. During the critical
period in the pandemic, we deferred certain workloads to
preserve beneficiaries' income and health care. Due to the
uncertain course of the pandemic and our stewardship
obligations, we resumed most workloads late last year and
provided flexibilities to help the public.
We are implementing new ideas to expand access to our
programs and reduce paper workloads, like creating electronic
signature options and an online process for Medicare Part B
Supplemental Medical Coverage.
For customers who must visit a field office, we developed
service options that limit time spent in the office, like the
option to submit evidence in secure drop boxes, and shortened
interview times.
We are testing an online video process that allows certain
U.S. citizens to apply for replacement Social Security cards.
We are also using video to hold certain consultative
examinations and hearings to make disability decisions.
Helping our most vulnerable population--individuals with
low income, limited English proficiency, homelessness, or
mental illness--access our services is our priority. To reach
them, we expanded outreach to these groups through close
partnerships with community-based advocates and ongoing robust,
targeted outreach efforts.
The pandemic has also created workload challenges. Some
work can only be handled in the office, like issuing certain
Social Security cards, and processing and scanning mail. We
depend on nearly 3,000 field office employees each day, mostly
managers and volunteers, to process these nonportable workloads
on site.
These workloads have increased dramatically since the
beginning of the pandemic. Our field offices are handling three
times as many phone calls compared to pre-pandemic, and on-site
employees are scanning over a million and a half documents per
week, ten times the volume before the pandemic.
Scanning these documents into our system is a workaround we
put in place to allow our employees to work remotely, but this
process also reduces our productivity. Like much of the world,
we have been affected by the challenges caused by the pandemic.
The fiscal year 2022 SSA discretionary budget request of
nearly $14.2 billion, which is $1.3 billion more than what we
received this year, will strengthen our service to the public.
We hope you will support this request.
I want to thank the public for their continued cooperation,
and especially our extraordinary employees who care so much for
the people we serve, and you for being patient and supportive
of our mission during this national health emergency.
I look forward to answering any questions you may have.
[The prepared statement of Ms. Kim appears in the
appendix.]
The Chairman. Thank you very much, Ms. Kim. And now, up
early in my hometown, Kascadare Causeya. Welcome.
STATEMENT OF KASCADARE CAUSEYA, PROGRAM MANAGER, CENTRAL CITY
CONCERN, PORTLAND, OR
Mr. Causeya. Thank you, Chairman Wyden, Ranking Member
Crapo, and members of the committee. My name is Kascadare
Causeya. I am a program manager for the Benefits and
Entitlements Specialist Team, BEST, for Central City Concern in
Portland, OR. I am on the board of directors for New
Narrative--formerly LukeDorf--and a member on SOAR's National
Experts Panel, all organizations serving people experiencing
poverty and homelessness. My team has been using the SOAR model
for developing and filing our claims since 2008.
SOAR, a national project funded by the Substance Abuse and
Mental Health Services Administration, was designed to help
increase access to SSI/SSDI for people with severe conditions
that could not go through the SSA disability process on their
own.
Since March of 2020, the barriers for those needing Social
Security benefits have increased in various ways. Applicants
just cannot walk into the field office, and prearranged
appointments are hard to get. This means people have trouble
getting help understanding the nuances of going through the
disability process; for example, a woman new to homelessness
listening to the myths about SSA and disability, suffering from
the residual effects of a severe bipolar decompensation, being
so disorganized and afraid that she slept on the sidewalks
during the day and began using meth at night to stay awake for
fear of being harmed. She is going to struggle until she finds
help.
Two, people might not always have a working phone number, a
mailing address, a printer, or a way to check mail if Social
Security tries to get in touch with them. For those without
necessary technology and understanding to begin and complete
the process, there is limited or no access to SSA staff and
information that could help them complete applications and the
various other tasks requested of them. We helped a person with
an intellectual disability who was estranged from his family
and choosing to live on the streets rather than to admit to his
family that he just could not understand things.
Three, increased hopelessness and feelings of apathy for
those attempting to become more self-sufficient, like an older
gentleman suffering from a multitude of conditions who had been
falling through the social service cracks for decades, losing
trust in the system, that his life will ever have any meaning,
and even losing trust in those who attempted to help him.
Fortunately, the people I have described here were the
lucky ones, because they were able to get help from BEST, but
there are so many more who cannot get assess to my program and
are just as ill and vulnerable.
Although these issues exist in all homeless communities, it
is particularly true for blacks, Native Americans, and Latin
communities who disproportionately experience homelessness at
higher rates compared to their white counterparts.
Here are a few statistics from my program related to years
prior to the pandemic compared to during the pandemic.
For the 3 years prior to March 2020, we averaged 806
referrals a year, and average time to an SSA decision was 79
days. Since March of 2020, we received 673 referrals, and time
to an SSA decision is 110 days. National numbers reflect this
local trend.
Many people suffering from severe and persistent conditions
have nothing in the way of resources to help them survive. A
maximum of $794 a month they get from SSI is still below the
Federal poverty level, but it can open housing doors, offer the
ability to get from place to place using public transportation
for things like primary care appointments and counseling, can
offer some hope for the future, and allow them to set their own
level of self-sufficiency and quality of life that previously
was not available to them.
So here are some possible solutions.
Safely re-open the SSA field offices for drop-in
appointments. Make the SSA application available online, and
simplify the questions.
The current My Social Security electronic access is too
complicated for most people, and requires an email address that
not everyone has or can remember passwords to. People should be
able to access SSA services with their Social Security number,
even if all they can do is schedule a phone call. People also
do not have phone minutes to wait on hold for 40 minutes or
more.
More funding for nonprofit organizations to help vulnerable
people apply for SSI and SSDI. More flexible scheduled call-in
times for the public.
The COVID pandemic has caused us to rethink how we do what
needs to be done, and what the new normal will look like. Let's
consider making things a little bit easier for those whose
abilities are a little more challenged than ours.
Thank you for listening to my testimony, and I look forward
to answering your questions.
[The prepared statement of Mr. Causeya appears in the
appendix.]
The Chairman. Mr. Causeya, thank you. And Central City
Concern in Portland has been there for vulnerable folks since
my days with the Gray Panthers, and I just want everybody there
to know how much we appreciate the incredible leadership.
Our next witness is going to be Peggy Murphy, past
president of the National Council of Social Security Management
Associations.
STATEMENT OF PEGGY MURPHY, IMMEDIATE PAST PRESIDENT, NATIONAL
COUNCIL OF SOCIAL SECURITY MANAGEMENT ASSOCIATIONS, GREAT
FALLS, MT
Ms. Murphy. Hello, Chairman Wyden, Ranking Member Crapo,
and members of the committee. My name is Peggy Murphy. In
addition to being the immediate past president of NCSSMA, I am
the District Manager of the Great Falls, MT Social Security
office. On behalf of the National Council, thank you for the
opportunity to be here today to provide our front-line
perspective of SSA service during the pandemic.
On Friday, March 17, 2020, the majority of Social Security
employees were informed that effective Monday, March 20th, they
would be teleworking indefinitely, and that field offices would
be closed to the public because of the pandemic.
This was a colossal undertaking, given that most employees
had never teleworked, and our telework pilot had just ended a
few months before. We rose to the occasion, and within a couple
of weeks the majority of field office employees, and a large
number of teleservice center employees, were up and running
taking care of customers from home.
I manage four offices that had not been part of the
telework pilot, and my employees were not so interested in
teleworking. We met the challenge, though, and my employees
went home on Friday and were successfully serving customers on
Monday.
My employees were anxious about working from home and, like
the rest of the world, we did not expect this to go on as long
as it has. Thirteen months into it, I can say that my
employees, my management team, and I are very proud of the way
we were able to mobilize and continue to serve the public.
I am confident that customers in my service area are being
served, regardless of how they contact us. However, there have
been many challenges. I have four Indian reservations in my
service area that, prior to the pandemic, had access to us via
video service delivery. Through existing partnerships, we
continue to serve those customers via phone and online
services, and look forward to expanding those services again.
Due to our current policies and the nature of SSA's work,
dedicated field office management staff have continued to come
into the office every day to handle incoming and outgoing mail,
nonportable work, and to provide in-person service to critical
cases such as immediate payment.
This current model is not sustainable because it leaves
managers with very little time to perform their duties, which
include facility and personnel responsibilities. Most of our
employees remain at home, while managers are in the office.
Each office is managing their own unique service area
challenges the best they possibly can, and some face additional
obstacles depending on size, location, demographics, and
available resources.
We have realized the advantages of telework, and so have
our employees. However, we need to reopen our offices with the
right mix of office workers and teleworkers to ensure customers
are getting the service they need. And in some cases, that is
definitely face to face.
It was not until the fall of 2020 that a very small number
of non-management employees began returning to field offices on
a voluntary and rotational basis to assist with the substantial
volume of incoming and outgoing mail. In most cases, there are
between one and three employees coming into the office to
assist.
Besides increasing on-site personnel, SSA has made efforts
to improve public access to facilities. These efforts include
field office drop boxes and the use of Microsoft Teams to
conduct certain enumeration interviews.
Overall, the agency's response to serving the public during
COVID-19 has shown our commitment to serving the public.
However, in order to overcome our preexisting inefficiencies
and apply the lessons learned, SSA needs resources. We need
front-line staff. And even with the recent investments in IT
modernization, SSA's computer system continues to have many
challenges. We continue to rely on 40-year-old COBOL systems.
SSA must continue to modernize.
We must expand existing services and implement technologies
that will assist our more vulnerable population, including the
deaf and hard-of-hearing community, non-English-speaking
customers, the homeless, and those who live in rural and tribal
locations.
It is critically important that Congress and SSA address
the need to improve upon outdated program policy that makes
administering SSA's programs inefficient and ultimately does
not provide the level of service the public expects and
deserves.
The pandemic caused us to reevaluate some of our existing
policies and make changes quickly to gain efficiencies that we
need to build on post-pandemic. Agency leadership has placed
customer service at the forefront and has made efforts to
provide the full range of services to the American public.
The pandemic has changed the agency and the way we serve
the public. We must take this opportunity to reassess the
customer experience and what it means to provide world-class
service. Our agency's limitations with IT, policy, and
resources became more apparent once the pandemic hit. Closing
offices and relying on management to serve and support our
staff, working from home, made matters even worse.
This is the moment where SSA must redefine itself and move
into the 21st century. Thank you for the opportunity to be here
today and to provide our front-line perspective. We are
committed to the mission of the agency and giving the American
public the best customer service, which they deserve.
[The prepared statement of Ms. Murphy appears in the
appendix.]
The Chairman. Thank you very much, Ms. Murphy.
Our final witness will be Tara Dawson McGuinness, founder
of the New Practice Lab and an adviser at New America.
STATEMENT OF TARA DAWSON McGUINNESS, FELLOW AND SENIOR ADVISER,
NEW PRACTICE LAB, NEW AMERICA, WASHINGTON, DC
Ms. McGuinness. Thank you very much, Chairman Wyden,
Ranking Member Crapo, and members of the committee. I am so
grateful to join you and these tremendous public servants this
morning to talk about really making the Federal Government work
for the public.
President Lincoln was perhaps the first President to truly
drill down on this question of how are we delivering benefit to
those who elected us. In my new book, I talk about how he
reopened the doors to the White House after breakfast and heard
not only from government officials but from citizens, welcoming
their petitions and concerns.
But as the U.S. has grown to ten times the size of the
populace of Lincoln's time, the practicality of this exercise
has changed, not to mention the dynamics of the global
pandemic.
The challenge, however, remains for today's agency leaders:
how can government adapt to reach people in this digital age?
Just because government structures were built for a different
time does not mean they cannot adapt. This is very hard.
Massive digitization has come to the private sector, and very
few of the Fortune 500 companies around at the turn of the
century actually survived this disruption.
While companies can be replaced by startups, the government
is not going to be replaced. It needs to adapt to meet the
times. Millions of Americans depend on it.
And there are new tools to do this, the modern equivalent
of Lincoln's one-man effort to understand what citizens need.
There are new units in the U.S. Digital Services and 18F, and
there are growing capacities that are happening at the State
level.
There are nonprofits like mine that work to serve and help
people make this adaptation. And we are seeing in the Federal
Government new possibilities. Another agency inside the Food
and Nutrition Service moved to remote validation for food
assistance to serve millions more people during the pandemic.
This process takes work, but it is not impossible. I want
to highlight one example in the State of Michigan, which once
had America's longest public benefits application, 40 pages
long. This form was an inhumane barrier between the people
desperately in need of emergency services and the State of
Michigan.
One resident described it as being left up to fate as to
whether you make it through. This is borne out in the data of
how many people got stuck in the process. A team of remarkable
agency leaders and one nonprofit tackled this form. The results
were stunning. The form can now be completed in 20 minutes, and
it is processed by the State in half the time.
Michigan is not alone. Similar transformations have
happened across the country, from California's work on SNAP to
Vermont's edit processing.
I want to share four key lessons from existing efforts
across the country to improve benefit delivery. They apply to
Social Security and other agencies, and they come from a book
of serving needs across the country called ``Power to the
Public.''
First, increasing outreach does not help if the front door
is locked. You heard this in earlier testimony. Agency leaders
need to think of their forms and applications as the front
door. They are often the equivalent of either a welcome mat or
a locked gate that says ``need not apply.''
Agency leaders--and I am very sympathetic to the role of
public servants in these times; I have often been in the seats
of other witnesses--but we need to test our forms with typical
beneficiaries. Grab a group of beneficiaries and see where
people get stuck before you subject millions of people to these
forms.
You can collect data about what questions are not working.
Many times, backlogs are the result of a single confusing
question that requires requests for more information and more
processors to process it.
Second, we need to map the user experience of the client
journey end to end. Very often, there is no single person in
charge of an application process end to end. One part of an
agency runs a call center, another part runs a website. We need
to trace the journey and what it feels like to someone on it,
from the beginning to the end, to really understand where the
bottlenecks are.
Third, we need to measure what matters in real time. Agency
administrators need real-time data to see who they are serving,
to be able to understand where there are decreases in certain
populations, without doing retroactive analysis.
Finally, one word of caution about modernizing, and I think
you could hear this. There are some client populations that may
never be served through an online process. But many government
agencies have taken to digitizing the broken process. And when
you digitize a broken process, you get a digitized broken
process. In more than one instance, governments have tried to
turn an existing process digital only to make things worse.
Making service delivery work is about understanding truly
who we serve, really engaging the front-line office leaders and
adjudicators who work with them. Some of the best innovations
come from front-line agency offices and being able to monitor
and see the applications, and to make changes. This cannot
happen if call centers are short-staffed or agency budgets are
crunched.
In closing, I am so grateful for the attention this
committee has paid to how these benefits really reach people.
While policy matters a great deal, it matters very little if it
does not reach those who need it most, when they need it most,
in crisis.
Thank you, very much.
[The prepared statement of Ms. McGuinness appears in the
appendix.]
The Chairman. Thank you very much, Ms. McGuinness.
Colleagues, we are going to have a number of votes at
11:30, and so we are going to keep this to 5-minute rounds.
Ms. Kim, if I could begin with you. Can you hear me? Great.
As I mentioned in my statement, one of the problems in
delivering first-rate service is the requirement that some
people have to put their most sensitive, important documents in
the U.S. mail.
Now I think we all understand why some people are reluctant
to do that. And they just cannot get by without their driver's
license. If they do mail their documents, it can take weeks to
get the documents back.
So why don't you begin by telling us what Social Security
is doing to fix this clearly unacceptable issue?
Ms. Kim. So thank you, Senator Wyden, for that question. We
share your concern, and the concern of the members of the
public who have had to mail in those types of original
documents for proof of their various transactions. Usually, it
is enumeration transactions.
We have put a number of things in place to mitigate the
need for our public to have to mail in their primary forms of
evidence such as driver's licenses, State IDs, and those sort
of identity proofs.
For States that have our online replacement card in place,
we have a data exchange with the driver's license, the DMV. And
in those States, we are able to conduct no-change replacement
card applications entirely online and by video. So that is one
way that we have been able to prevent members of the public
from having to part with their primary forms of identification.
We have also had secure drop boxes. So in every field
office where it is appropriate and we are able to place one, we
have put in these secure drop boxes where members of the public
can drop off their proofs of identity instead of relying on the
mail, which in the beginning of the pandemic was causing a
delay. They can drop those identity proofs in those drop boxes
instead of mailing them, and then we can process those
documents there.
Currently during the pandemic, we are also being very
flexible with our policies. So now, in appropriate situations,
we are allowing members of the public to provide secondary
types of proofs of identity instead of driver's licenses,
passports, and things of that nature. So certified medical
records might be an appropriate form of verifying someone's
identity. There are other types of documents other than
driver's licenses that we will accept as verification of
someone's identity.
The Chairman. Ms. Kim, because time is short, we have to
get this straightened out. There are too many people for whom
this is a huge burden, because they need their driver's
licenses if they go for other government services. There are
various other places they visit, businesses and elsewhere. So
we are going to follow this up with you, and I recognize there
may be a bit of politics associated with this as well.
But I want you to know, as chairman of this committee, I am
committed to getting this corrected. We cannot have people's
original documents flying around in the mail and putting it in
a drop box, and wondering when it is going to get returned, and
the like. We just absolutely have to do better, because these
are some of the most vulnerable people.
One other question for you, if I might. Members of Congress
wrote the agency asking about the decline in applications in
November, and what the agency was doing to reach at-risk
populations. The agency said that you all were doing targeted
mailings to a number of people, that you sent 200,000 letters.
What are the results so far? And what has been done as a
result of those responses?
Ms. Kim. So, Senator Wyden, we initially identified about 2
million title II beneficiaries who might be eligible for SSI.
And so what we did was, we sent notices to the first 200,000 of
those individuals to let them know that they might be eligible
for SSI and invited them to apply if they believed that they
were eligible.
After that 200,000 mailing, which concluded in March, we
analyzed the results of that mailing, further refined the
universe of the individuals who might be eligible for SSI, and
now we have identified a remaining universe of approximately
1.2 million individuals who we will begin to reach out to in
June.
So we will be sending out notices to 1.2 million
individuals, again notifying them that they might be eligible
for SSI and inviting them to contact us if they think so.
The Chairman. I am over my time, Ms. Kim. I would like a
written answer to that question within 10 days. Specifically,
what you all have heard in those mailings, and when, with dates
and times, those reforms are going to be put in place. Thank
you, very much.
Senator Crapo?
Senator Crapo. Thank you very much, Mr. Chairman. And you
actually took a couple of my questions. You are focused on the
same kind of things that I wanted to focus on, so I will go
beyond that.
Let me start also with you, Ms. Kim. You know, one of the
lessons that I think we have learned in terms of our health-
care system is that the telehealth that we resorted to during
the pandemic has become a really significant improvement in our
health-care system and--I think Senator Wyden and I agree on
this--we need to try to figure out how to make permanent the
adjustments and improvements that we made to telehealth as we
go past the pandemic.
The question I have for you is kind of a broad one here. Do
you believe that the experience that Social Security has gone
through during the pandemic has given an increased and
appropriate focus on digital service, on tele-Social Security
service, if you will?
Ms. Kim. Senator Crapo, I believe that during the pandemic
we have definitely focused on where we can use digital services
to enable us to overcome some of the challenges that we have
faced during the pandemic.
So in terms of processing our disability applications, the
DDSs, the State agencies that adjudicate disability claims,
they were successfully using telehealth consultative
examinations for psychiatric and psychological cases in order
to get evidence to support those claims. So our experience in
using telehealth in that arena has been very, very successful.
I would like to be able to see us broaden the ability to
use video in that manner to be able to enhance and help our
disability process.
Senator Crapo. All right; thank you very much.
And Ms. McGuinness raised the question, she kind of made, I
think, a very significant analogy. She said the front door, if
I understood her right, may be too restrictive, meaning--and
she referred there to the forms and applications that people
need to provide in order to gain access to Social Security to
get in that front door.
Do you agree with that? And how can--I mean, I think that
most Americans can immediately identify with the notion that
the government's forms and applications are a real problem. Do
you agree that there is a way we can significantly improve
access by addressing the complexity and sort of the
restrictiveness of the forms and applications that we currently
use?
Ms. Kim. I do, Senator. And in fact what we are looking at
right now is our SSI application. That is a lengthy
application, more than 20 pages long. And the detail of
information that is required in that application has been a
barrier in the past for the agency in putting that application
online.
So the agency, during the pandemic, has been working across
components within the agency, and with community-based
advocates. This is an initiative that we are working on with
advocate groups around the country. And what we are looking to
do is to simplify the SSI application so that it is much easier
and much more approachable for individuals who are applying for
that benefit. And then eventually, once we are able to
streamline that, we will put it online for those individuals
who would be able to access it online.
But I do agree that there are some of our applications that
are very, very difficult for the members of the public who need
them.
Senator Crapo. Well, thank you. And for my last minute I
would like to go to Ms. McGuinness in this area to elaborate a
little more about what you were referring to when you talked
about the problem we have with forms and applications and
getting in the front door.
Ms. McGuinness. Certainly, Senator. I think, having been a
person at a Federal agency overseeing forms, I know how much I
do not know about how the average person views the forms. And
so the best way to improve them is to allow the people for whom
you are designing the program to try them out. It is unexpected
what acronyms they get caught on, and you can dramatically
reduce the front-load work of the offices by understanding that
nobody knows where to find their EIN number.
So when it comes to forms, I think the first piece is to
test them out on the actual humans. Collect oral data. Forty
people filling out a form will tell you what percentage of
people really get stuck on number 2. Try to improve it. Test
the forms again on 40 humans before you send the forms to 2
million humans.
There are excellent best practices. I cannot say enough
about the tremendous work in the State of Michigan. The same
thing has happened in California. Communities are studying more
models of what forms look like. There are teams inside the
program and outside that are experts on this. If we can improve
and make it easier to purchase a pair of shoes on the Internet,
we can also make it easier for seniors to get their benefits.
Senator Crapo. Thank you. I appreciate that, Mr. Chairman.
The Chairman. Thank you, Senator Crapo.
You are being way too logical, Ms. McGuinness, to actually
test some of these forms on people. That is far too logical
[laughing].
Senator Stabenow?
Senator Stabenow. Well, good morning. And thank you, Mr.
Chairman, and our great ranking member, for this really
important discussion.
I just have to start out and join all of us in echoing a
``thank you'' to the staff, the people who have remained during
this pandemic and kept things going when the whole world and
the workplace was turned upside down because of COVID-19. And
so, it is important to learn those lessons. I think there are a
lot of things that we can learn going forward, and that we need
to learn. But first, a big ``thank you.''
I have been sitting here this morning also with a smile on
my face as, Ms. McGuinness, you were talking about Michigan. I
know that--and I appreciate your citing our reform of the
application process for a number of benefits, especially the
form used to apply for benefits, which was one of the longest
and most Byzantine in America, I think.
You described the tangible relief that the people who need
these benefits felt after the reform; that they could
successfully apply, get answers from the State much faster, and
they really focus on the problems of people who are getting
through the application process. And so it was hard work, but I
am very proud of what Michigan did.
But I wonder if you might just talk a little bit more about
applying what Michigan did to the Social Security
Administration. And can you talk more about mapping the user
experience for accessing benefits, especially for beneficiaries
who may be older or not have access to technology to apply?
Ms. McGuinness. Certainly, Senator. I think many agencies
at the State and Federal level have found the mapping of the
experience of a journey--this needs to be done. We have talked
this morning about a couple of different types of benefits.
Social Security users are not the same for SSDI as they may be
for other benefits. Really understanding who is the average
user--are 70 percent of people in communities that do not have
Internet access--and this is done by front-line staff as well
as community partners like we have heard from this morning. You
take the steps step by step, and you literally map it out.
What happens first? We fill out a 20-page application.
Then, who receives it? What is the average wait time for the
reception? What does it take to pass ``Go''? What share of the
forms need to go back to their original beneficiary for more
information? How many forms are 100-percent correct on the
first go? They are very quickly processed. But in many
agencies, you have upwards of 40 percent--and this is true for
everything from your EITC at IRS, or your Child Tax Credit, or
your unemployment insurance. Very frequently Federal agencies
spend a ton of effort going back to people and asking them for
more information.
This is expensive. This is costly. People miss the letter
in the mail. And so, thinking step to step from when a form is
filled out, to what share of forms get stuck, to how they get
adjudicated, to how a person knows where they are on the
journey, sometimes taking pressure off of call centers--this
has been the case in unemployment insurance; 90 percent of
people are calling for one thing. If you could make it clearer
that they could check on their own on a website, you could make
it easier to get through.
So it is literally making a map of what the experience is.
And this type of map needs to be made with beneficiaries, but
also with front-line workers who have done tremendous work
through COVID to try to make this work.
Senator Stabenow. Great. Thank you very much.
And then, Mr. Causeya, thank you so much for all of your
great work, and for talking about the reality for folks you are
working with trying to work through this system.
I wonder if there is anything else you would want to share
with us about the human toll that delays and difficulties in
applying for benefits take on people in need as you are working
with them.
Mr. Causeya. Can you hear me?
Senator Stabenow. Yes.
Mr. Causeya. Okay. People who are living outside, or who
are close to being outside, who have severe mental health
conditions, these questions that are asked on the application
are just overwhelming for them. You have many people who suffer
from a variety of disorders, and they just cannot focus long
enough, or they cannot get over the fear inside them when it
comes to dealing with having to trust the government.
A lot of our people, they really have a problem with
trusting the government. And I am not sure where it comes from.
But it is very difficult for those people. It is also difficult
for the people who are housebound because of their physical
condition to actually get to a place where they can get access
to a computer, or to have a phone, or someone who can assist
them. Office closures are very difficult on these groups of
people.
Senator Stabenow. Thank you.
Thank you very much, Mr. Chairman. I look forward to
working with you to make this system better.
The Chairman. We will be working together.
Kasc, thanks so much for that really thoughtful answer.
Our next Senator in line of appearance is Senator Menendez.
Are you there?
[No response.]
The Chairman. Senator Thune--there is Senator Menendez.
Yes, Senator Menendez.
Senator Menendez. Thank you, Mr. Chairman.
Ms. Kim, I have a constituent who was on SSI and was laid
off during the pandemic. They followed Social Security rules
and filed for emergency unemployment that Congress authorized
last spring. However, because of their unemployment benefits,
they now have a large amount of unearned income, and their SSI
benefits were suspended. They run through the 12 months of
suspension. They will have to reapply for SSI.
So my question is, why has the agency not used their
regulatory authority to exclude disaster relief UI from being
counted against beneficiaries?
Ms. Kim. So, Senator Menendez, this is an issue that we are
currently looking at right now. I do not--because we are in the
middle of analyzing how to proceed, looking at the EIP payment
as disaster relief assistance, I would like to provide
additional information for the record. This is an issue that we
are currently talking about right now.
Senator Menendez. Well, I hope we do more than talk about
it, because I do not think that Congress intended to provide
individuals the type of relief that we did during the pandemic
only to have them lose their SSI. That could never have been
Congress's intent at the end of the day.
Let me ask you this. Do you support automatic renewal of
SSI for people who lost their benefits due to the pandemic,
with issues with unemployment insurance income, when the time
comes?
Ms. Kim. That is another issue that we are looking at. The
bottom line is, in appropriate circumstances, I fully support
that.
Senator Menendez. All right. I look forward to hearing what
your ultimate decisions are on this question.
Mr. Causeya, for the work your organization and other
similar ones do in helping people with severe disabilities,
applying for SSI, do you have sufficient resources to help your
clients?
Mr. Causeya. No, we do not. We try and make it work with
what we get, but it is difficult because each case is
different. And so each case requires a different amount of
effort and resources. But we most certainly could use more
resources.
Senator Menendez. How difficult is the process for people
with disabilities who may need some assistance to fill out
their applications, but do not have access to organizations
like yours?
Mr. Causeya. It is almost prohibitive. I mean, I think of
Ms. McGuinness, who was talking about the difficulties with
understanding the acronyms, and the use of the information, or
terminology that Social Security uses. The majority of people
who are homeless do not really understand the terminology or
understand the questions. Whereas people who have been trained
and who are working in that field, when they look at it, they
think it is a simple question. But for someone who is not
familiar with it, they get stuck. And so, if they answer it the
wrong way, then of course, you know, that could result in a
denial of their claim or prolong the process by having SSA send
them more requests for information from them.
Senator Menendez. Thank you.
Ms. Kim, beneficiaries encounter numerous challenges when
going through their application process for SSI, and they
require assistance from the field offices. But with the field
offices closed, many people have been running into challenges
accessing this needed help.
What is SSA's timeline for reopening offices safely so that
older adults and people with disabilities can access the help
they need?
Ms. Kim. So currently, Senator, SSA is operating under its
current workplace safety plan, which aligns with the
President's executive order and OMB guidance. And that right
now permits SSA workplaces to operate up to 25 percent of
normal occupancy.
So we are working within the parameters of our workplace
safety plan, and that plan does limit our ability to bring in
additional staff on site. We have been open throughout the
pandemic--I want to make that very clear. But we have only been
open to the public if they have an appointment.
And we are currently, within the parameters of the plan,
incrementally increasing staff on site to handle workloads such
as critical workloads that serve vulnerable populations. But we
are doing that in a way to ensure the safety of our employees,
as well as the public that has to come into our field offices.
But one way that we are also trying to reach the SSI
population and help them with their applications as part of the
vulnerable population outreach efforts that we have done with
community-based advocates--that I mentioned in my opening, that
I discuss in my hearing testimony--is that we have established
SSA points of contact in every area where we have a field
office.
And those points of contact are working directly with
community organizations and advocates, and working with them to
facilitate the SSI claims-taking and referrals of SSI claims to
SSA. And in those instances, we are processing----
The Chairman. We are going to have to move on. Senator
Menendez, did you need to say anything else?
Senator Menendez. Yes, just briefly, Mr. Chair. I
appreciate the answer, but it is not working for people, I can
tell you that. And one of the things we could do is streamline
this application. It is a 23-page application for SSI. I mean,
I think in the 21st century, we can do a lot better than that.
So I look forward to working with the chair to try to make it
better.
The Chairman. Great. Thank you, Senator Menendez.
Senator Thune will be coming later, and that means Senator
Cardin is up for questions.
Senator Cardin. Well, thank you, Mr. Chairman. And let me
thank you for conducting this hearing on COVID-19 and SSA. And
I want to thank all of our witnesses.
I want to start by just acknowledging the extraordinary
work being done by the SSA workforce. I am honored to represent
the State of Maryland, the principal location for SSA in
Woodlawn. The workforce there are dedicated public servants
working under very difficult circumstances before COVID-19,
which have been made even more complicated because of COVID-19.
So, Ms. Kim, I want to start and ask you a question as it
relates to the workforce issues in two respects. First, we have
learned from COVID-19 that telework is a much more efficient
way, where appropriate, to use the workforce, and that moving
forward, we would hope that there would be a progressive
telework policy for workers to be able to be more efficient in
carrying out their mission at SSA.
On the other hand, you are now bringing more of the
workforce back in person, and there is concern that that be
done in a way for safety for the workforce. So we had both
issues of safety for those who are going to be physically
present and interacting with constituents, and those who
believe they can do their work more efficiently and safely from
their home environment.
My question to you is, how are you engaging the workforce?
How are you working with the unions for the workers at SSA, and
the workers themselves? How are they engaged in the discussion
moving forward on the policies of telework and safely returning
to their work stations?
Ms. Kim. So, thank you for that question. Currently we are
engaging with the union on a number of fronts. So the workplace
safety plan that I mentioned, the plan that is kind of the
blueprint for how SSA is operating right now, we implemented
that safety plan in accordance with the President's executive
order, and we implemented that plan in the middle of March.
And when we did so, we notified the union and gave them the
opportunity to bargain, which we are doing in good faith right
now. So we are engaging with the union, bargaining our
workplace safety plan, and that negotiation is ongoing.
We are also----
Senator Cardin. I would just say, on that issue, just so I
can point out, it is always best if you work together in a
nonconfrontational way, to work with the same set of facts. And
the way you sort of presented that, it looks like you presented
the plan, and now you are negotiating.
It seems to me that the union should have been involved in
the initial aspects of developing the plan. But I take it they
were not?
Ms. Kim. They were not. This was--we were entering into
post-implementation bargaining for the workplace safety plan.
But President Biden's executive order and the OMB guidance that
followed did permit agencies to move forward with their
workplace safety plans because of the health and safety
concerns--and the necessity of agencies having such a plan in
place--and then entering into post-implementation bargaining at
that point.
So that is what we have done in our agency, and we have met
our labor obligations by engaging in negotiations with them.
Going forward, however, we are actively engaging with the
union about issues, not just post-implementation, but looking
for their input on a variety of other issues. Right now, the
issue of telework is still in the future. That is an area
where, when we have further guidance from the White House about
our ability to reopen beyond the 25 percent that is currently
in our workplace safety plan, we will certainly, and I will
certainly, engage with the union about any telework program
that we put forward in Operations, because I want to make sure
that that program reflects the interests of our employees.
Senator Cardin. I thank you for that. Clearly, we had
challenges under the previous administration, and I was pretty
vocal about that. We expect you to follow up on what you just
said. And if you could keep my office informed, I would
certainly appreciate that.
We have regular contacts with the workers at SSA, and I
think engaging them early in the process will make it best for
all. So thank you very much for that commitment.
The Chairman. Thank you, Senator Cardin, not just for this
but for your long years of advocacy for Social Security and
your constituents.
Senator Portman?
Senator Portman. Thank you, Mr. Chairman. And it sounds
like the COVID-19 experience at Social Security has taught us a
lot of lessons, and those have been discussed today. And I hope
we have learned from them, including in the remote work
environment.
I want to talk for a moment about program integrity, not
just good public policy but also about being good stewards of
hard-earned taxpayer money.
In your written testimony, Ms. Murphy, you addressed the
importance of fully funding your program integrity activities.
For Fiscal Year 2022, I see the President has requested $1.9
billion, which is a big increase, a $283-million increase over
2021.
Would you please elaborate on how program integrity
activities ensure beneficiaries are well served, while
safeguarding taxpayer resources?
Ms. Murphy. Thank you for that question, Senator. And yes,
the integrity workload is definitely what we want to be
investing in, and we want to be making sure that we are paying
the right folks at the right time, and that we are reassessing
benefits, whether they are medical CDRs, whether they are
redeterminations of SSI benefits. Not because we want to get
people off the rolls, but we want to make sure that we are
paying people correctly, and that if they are due benefits,
that we are actually increasing their benefits.
So, having those integrity workloads is very, very vitally
important to the work that we do in making sure that, once we
get somebody on benefits, and as they continue and they are due
those benefits, we can review and, if their living arrangements
have changed, or anything has changed in regard to their
entitlement, they are getting relooked at regularly and we are
making sure that we are paying people correctly the benefits
that they are due.
Senator Portman. Can you talk a little about the return on
the investment, essentially the $283-million increase in 2022
compared to 2021, as an example? If we were to do that, what
would you expect the return to be on that to the Treasury, to
the taxpayer?
Ms. Murphy. I would--the return would be that we would be
able to increase the number of medical CDRs, of work CDRs, and
redeterminations that we are able to complete. You know, those
take a lot of time. They are one of our biggest workloads. They
take a couple of hours for each one of our customers--a lot of
man-hours to do those redeterminations. But I do not have the
number that I could actually put forward for the agency, but I
know that if we have the resources, then we can deliver more
redeterminations, more integrity workload, and we can make sure
that, again, we are paying people correctly.
Senator Portman. Okay. We will follow up on that, if it is
all right, and see if we can come up with some numbers to be
able to support this increase. Because I think it is a good
idea to make sure that the program integrity is working
properly, including the CDRs being more available, and that you
have the resources to do it.
And if you have any other ideas on program integrity, let
us know. On this committee, the chair and ranking member and
others have worked a lot on unemployment insurance, and that is
another area where we want to work on program integrity. And I
think we have some common ground there to try to figure that
out so that the benefits are going to the right people. We have
had a lot of issues in Ohio, and I know other States as well,
with regard to fraud in that program.
So, Mr. Chairman, I look forward to working with you on
that.
On solvency, just quickly, the big issue is, Social
Security is facing insolvency, as we know. According to the
latest report, the Old-Age and Survivors Insurance could pay
benefits only through 2034, and then we see substantial
reductions under current law.
I know you are not responsible for these actions, Ms.
Murphy, or others before us today, but what sort of impact
would this have on the many clients whom your members serve,
Ms. Murphy and others as well, if we were not to address this
looming insolvency?
Ms. Kim. So, Senator Cardin, I will respond. I would have
to get you more information on that for the record, because I
do not have that information off the top of my head.
Senator Portman. Senator Cardin would not have asked such
an open-ended question. This is Senator Portman.
Ms. Kim. Oh, I apologize, Senator Portman.
Senator Portman. Well, thank you. I mean the bottom line
is, all of us want to be sure the Social Security benefits are
there. And today we are talking about the Administration more,
but the looming insolvency obviously will be a huge dislocation
for beneficiaries and for the program.
Thank you, Mr. Chairman.
The Chairman. Thank you, Senator Portman.
And now the chair of the Social Security Subcommittee,
Senator Brown.
Senator Brown. Thank you, Mr. Chairman, for holding this. I
have committed, as you and I have talked about many times, to
working together to protect and expand Social Security.
Sadly, based on their track record, it appears that
Commissioner Andrew Saul and Deputy Commissioner David Black do
not share that commitment that Chairman Wyden and I do. Senator
Casey has spoken up. We need leadership that believes in the
promise of Social Security, not leadership that has actively
worked to dismantle it.
Commissioner Saul and Deputy Commissioner Black should
resign.
Ms. Kim, as a means-tested program in a period of economic
downturn, SSI should be helping more people than ever. Instead,
we find SSI applications and awards at historic lows. Field
office closures during a global pandemic--Senator Menendez
mentioned that--explain part of the decline, but at the heart
of this we must acknowledge how difficult an SSI application
is. You basically need to have a law degree to successfully
apply.
Here is what I have observed. The Social Security
Administration under Commissioner Saul spent a lot of time and
regulatory energy making it harder for people to qualify for
and retain these benefits. And he has continued that effort
even after the switch-over in the White House.
The President and I want to see a different agenda. Instead
of finding ways to deny disability benefits, I want to see you
helping people successfully get the benefits they are eligible
for.
If you would, answer this ``yes'' or ``no.'' Will you help
shift the focus from denial to assistance, Ms. Kim?
Ms. Kim. Thank you, Senator Brown. I do not know that I can
give you a ``yes'' or a ``no'' answer. What I would say is that
I am committed to ensuring that, for the individuals who apply
for benefits, it is easier for them to understand the benefit
for which they are applying, and the entitlement criteria as
well.
I want to make sure that whoever receives benefits from us
is entitled to them. And we are looking at ways right now to
simplify and clarify our programs so that people who are in
need of these benefits can access them.
Senator Brown. Ms. Kim, I get that. And I do not put this
on you entirely, by a long shot; I put it much more on Mr. Saul
and Mr. Black, but you need to do better on this too.
Mr. Causeya, if you can answer this quickly, from your
experience with the SOAR program--which helps the hardest-to-
reach individuals gain access to benefits--do you think we
would benefit from a broader nationwide navigator program that
would help individuals complete the SSI application process? Be
as brief as you can answering that question.
Mr. Causeya. Yes, I do. Right now, for the most part, if a
person goes through Social Security and files for an
application, the Social Security Administration will gather
records, medical records. And medical records do not tell the
whole story of a person's life. And so I think that
organizations like mine that can take the time to develop the
case and tell the person's whole story will give the applicant
a much better chance at being successful.
Senator Brown. Thank you, Mr. Causeya.
I want to turn to the Social Security workforce. As one of
his first acts, President Biden signed an executive order
directing agencies to return to the bargaining table with
unions after years of union-busting practices. At the Social
Security Administration under Commissioner Saul, this took many
forms, including eliminating the option of remote work.
According to AFGE, SSA leadership has not returned to the
bargaining table yet and has not reopened the 2019 agency
employee contract.
Ms. Kim, why has SSA delayed this process after a clear
directive to return to the table?
Ms. Kim. So, Senator Brown, we have actually returned to
the table. We are bargaining currently over the workplace
safety plan, which right now limits our ability to bring
employees in beyond 25 percent. Under the workplace safety
plan, we are still utilizing maximum telework.
So at the point where we get further White House guidance
on our ability to reopen, and we are at a point where we can
revisit instituting a telework program, at that point we will
be engaging with the union in good-faith negotiations about
that.
And I look forward to that. I look forward to that,
actually.
Senator Brown. Thank you for that, Ms. Kim. I expect you to
double down on efforts to improve relationships with your
employee unions. It is something--throughout the Trump
administration, they were dismissive of unions generally. Their
politics was that, their behavior was that, their treatment of
workers was that.
Another question, though, about the workforce and the time
the telework pilot ended months before the pandemic began. Was
Mr. Saul working out of Social Security's Woodlawn office
personally?
Ms. Kim. Yes, he was.
Senator Brown. He was working out of the office itself;
okay.
Ms. Kim. I'm sorry? At the time the pilot ended? Is that
what you are asking, Senator Brown?
Senator Brown. Yes.
Ms. Kim. Yes, he was.
Senator Brown. Okay. Thank you, Mr. Chairman.
The Chairman. Thank you, Senator Brown. We will be working
closely with the subcommittee.
Senator Cassidy?
[No response.]
The Chairman. Senator Bennet?
[No response.]
The Chairman. Senator Lankford is next.
Senator Lankford. Thank you, Mr. Chairman. I appreciate
everyone's testimony; obviously an incredibly difficult season
for everyone as we actually walk through the time of the
pandemic. No one saw this coming, obviously, and you had a
rapid response, as everyone else said, as several of you have
testified.
Everyone went home for a couple of weeks and thought this
would be a couple of weeks, and now we are a year into it. But
there are some lessons learned in this, and I want to make sure
I drill down on a couple of these.
Ms. Kim, in your testimony you noted that express
interviews were offered at 81 offices. Some of those offices
were actually in Oklahoma. What have you learned from that
pilot? What will remain that you have learned from that pilot?
Ms. Kim. So, Senator Lankford, the express interviews are
one of the things that we instituted during the pandemic to
shorten the time that members of the public are in our field
offices. And that is to protect their safety as well as our
employees'.
And we have learned the response to that pilot has been
overwhelmingly favorable. And we are rolling out express
interviews nationwide because of the effectiveness that that
process has had in enabling us to process certain transactions
more quickly, and to be able to serve our customers in a better
way.
Senator Lankford. So obviously, people do not want to spend
a long time in the office, pandemic or no pandemic. At this
point, when we talk about this, this is something you are going
to continue to expand on one way or the other, and what is your
anticipated timeline for that expansion?
Ms. Kim. We are in the process of expanding now. I would
have to add some additional information for the record, if you
want a specific timeline, but we are in the process of
expanding express interviews to all 1,200 of our field offices.
Senator Lankford. If I can just get a follow-up on that
from you; I do not need an exact date, but give me generalities
on times in a follow-up for the record, that would be helpful.
Just so we will know if it is going to take 10 years to
implement, or is this going to take 10 months to implement, so
we can get a good feel for that.
Ms. Kim. I would be happy to do that.
[The information appears in the appendix on p. 77.]
Senator Lankford. So the disability case processing system
has had a few questions, as you know well, and the Inspector
General has raised some issues. There are some outside third-
party groups that have done some audits and have raised some
issues.
My State has not fully implemented that yet, based on some
of those questions and issues on security. Tell me the status
on that, because, obviously, that is a lot of private
information that is out there. We want to have a more efficient
system that is helpful, but we've got to make sure it actually
works, and that it is actually secure. So give me an update on
it.
Ms. Kim. So in July of last year, Andrew--Commissioner
Saul--made the decision to have DCPS as the national case
processing system. So since that time, we have been working
with each State to transition DCPS to all States.
Currently we have 47 States that are now rolled onto DCPS,
and we are continuing to work with those remaining States that
are not yet on DCPS. And what we are doing is, we are deploying
staff to States like Oklahoma to ensure that they have the
support that they need to address the unique questions and
concerns and issues arising for those States.
And so I am confident that we are going to be able to
transition all States to DCPS in the next year or so.
Senator Lankford. Are you confident in the security of the
system as well?
Ms. Kim. I am.
Senator Lankford. Okay. We will be able to follow up from
there, but I appreciate that very much.
There is a lot, again, that we have learned from this time
in the pandemic. One thing is how much we have done by remote
that we never thought we could do remote. So, as we look
forward in the future, are there opportunities, or an
examination at least, to be able to look at hiring Social
Security employees who may never come into the office, who
could work in more remote areas a long way from the office, but
could still fulfill those job opportunities?
I am thinking especially of people who work, who are
spouses of those who are active duty, who may be transferred
every 2 or 3 years to very remote areas of the country on bases
and posts. They would like to be able to have a stable job and
a place to be able to work.
Are there job listings that you have seen now that say, we
have not had this as a permanent remote work task, but we could
do this as a remote work task in the future? And so, are you
open to listing it that way on USA Jobs and opening it up?
Ms. Kim. So, we have not made any decisions about precisely
that type of job listing, but I am open to considering it,
because we have learned many lessons during this pandemic,
particularly what is truly portable work that could be
performed at a location away from the office, as if the person
is in the office themselves.
And so I think we have opportunities, as we have identified
those workloads that are truly portable, to think about hiring
future staff who may not ever set foot in an SSA facility.
Senator Lankford. That would be very helpful to be able to
have the search capability in any office, because they could
work from anywhere, or to be able to increase the number of
highly qualified people that you could actually recruit to be
able to work with SSA, because you could recruit them from
anywhere. So I appreciate that very much.
Thank you.
The Chairman. Thank you, Senator Lankford.
Senator Cassidy?
Senator Cassidy. Thank you, Mr. Chairman. And to tag along
with that which Senator Lankford just asked, I know from
passports, the material being used was so sensitive it could
not leave the office. It had to be processed in the office.
But when the pandemic hit and the office was shut down,
there was not an agreement with the unions for people to wear
PPE in order to continue to work. And the only people actually
processing passports were management. Did that same situation
occur in SSA? Because it seems you, as well, would have
sensitive information which could not leave the premises.
First, let me start with that.
Ms. Kim. So, I am sorry, Senator Cassidy. Are you asking
whether we have protections in place for employees----
Senator Cassidy. No, whether there was a period of time in
which the majority of the employees were unable to come to work
because of the pandemic saying that you could not come in, and
the union placing restrictions upon the use of PPE to allow
these employees to show up, and so therefore there being kind
of the pause, if you will, in the processing.
Ms. Kim. We did not encounter that, Senator. At the
beginning of the pandemic, and for the first part of the
pandemic, the majority, the vast majority of people who were on
site, were managers. So they were nonbargaining employees who
were on site.
Those were the individuals who were processing the work
that came on site, scanning appropriate materials into our
system so that our teleworkers could process those workloads.
So we did not encounter, I think, the situation that you have
described.
And since that time, we have added about 1,000
nonbargaining staff on site to assist with only those workloads
that can be performed on site, and we have not encountered that
situation.
Senator Cassidy. So I guess what I am interested in--the
1,000 nonbargaining staff and the managers were presumably
safe. You would not endanger them. But nonetheless, those
represented by the union, their union would not allow them to
come onboard.
First, is that a fair statement? And if so, for how long
did the union not allow them to come in?
Ms. Kim. So, even though the union has filed ULPs, unfair
labor practices, with the FLRB, and has challenged the agency's
decision to allow nonbargaining unit staff on site, we are
currently bargaining that post-implementation right now.
So because it is a necessity, the----
Senator Cassidy. I'm sorry, just a second. Am I to
understand that the bargaining employees are still not on site?
Ms. Kim. No. The bargaining employees are on site, Senator.
So we have about 1,000----
Senator Cassidy. For how long did the bargaining employees
not show up on site for work?
Ms. Kim. Oh, I see what you are saying. For probably the
first 4 months or so of the pandemic, 4 or 5 months.
Senator Cassidy. And were they able to be fully employed
from home? Because I presume you gave them computers, if they
did not have them, but some of the material I am sure would be
very sensitive. So how many were actually doing work related to
processing? And how many were just being paid but not working?
Ms. Kim. So we had some employees who were unable to work
from home because they lacked Internet, or they had other
issues which prevented them from working. But for the most
part, Senator, all of the employees, bargaining unit and
nonbargaining, were working successfully from home.
Senator Cassidy. And ``some'' is an elastic number. Would
``some'' be 5 percent, or 45 percent?
Ms. Kim. That changed over the course of the pandemic. We
had to work through issues because, initially, there were some
employees who just did not have appropriate Internet at home,
or no connectivity----
Senator Cassidy. But do you have any sense of the percent
at the outset? And for how long did that percent remain
constant and then begin to fall?
Ms. Kim. Yes. We do have percentages, and I can share that
for the record.
Senator Cassidy. But you cannot tell me now?
Ms. Kim. Not off the top of my head, no, Senator.
Senator Cassidy. I would appreciate that.
With that, I yield back.
The Chairman. Thank you, Senator Cassidy.
Senator Thune?
Senator Thune. Thank you, Mr. Chairman.
Ms. Kim, thanks for the work that you and the agency
leadership have been doing to ensure that Social Security
continues to provide critical customer service during the
pandemic. I know that the chairman covered the issue of mailing
in sensitive documents at the top of the hearing. I want to
echo that I have heard from a number of women in my State who
got married during the pandemic and had to mail in multiple
documents to change their name.
I am not sure what the chairman was suggesting. He
mentioned earlier that this is political. I think it is
probably just inconvenient. So I hope the agency will continue
to work to expand options, as in-person services are still
limited.
On that note, as we have all adapted to this virtual world,
I expect there are things about it we can keep in place moving
forward. And I also expect that there are folks who are hopeful
to be able to resume their business with Social Security in
person as things begin to return to normal.
I understand that Social Security's workplace safety plan
for field offices provides that the occupancy rate should be no
more than 25 percent, and that field offices have been
operating well below that rate.
Is that correct?
Ms. Kim. That is correct.
Senator Thune. So, as vaccines are becoming more widely
available, what plans does the agency have to bring employees
back safely and increase that capacity to serve customers in
person?
Ms. Kim. So, as we have seen the nonportable workloads
grow--and by ``nonportable'' I refer to the number of in-office
appointments that we are handling right now--and the volume of
mail that we are seeing in our field offices, both have grown
significantly over the course of the pandemic.
I am going to start incrementally increasing staff on site
well within the workplace safety plan, but we have to increase
on-site staffing in order to meet the demands of the public and
in order to ensure that we are processing the 1\1/2\ million
pieces of mail that need to be scanned in, in a timely manner,
so that our employees who are working from home can process
them.
So, so long as I can do so safely, I plan to incrementally
increase staff on site to meet the demand.
Senator Thune. Thank you, Ms. Kim. I lost you there. I do
not know if the cut-out was on my end or your end, but I will
try and get that full answer for the record. But I would hope
that, as everybody gets vaccinated, you can start getting folks
operating again in a normal work environment. Because I just
think the customers that you serve are really anxious to be
able to get back to where they can contact you in a direct way,
as opposed to through all these virtual technologies, which
served their purpose during the course of the pandemic, but
certainly are not as effective when it comes to taking care of
your customers out there as the one-on-one personal experience
I think that everybody who comes in to the Federal Government
is looking for.
So I encourage you to, as quickly as you can, given the
fact, I mean assuming people are vaccinated, begin to get
people back into the workplace.
So thank you, Mr. Chairman.
The Chairman. Thank you, Senator Thune.
Senator Warner?
Senator Warner. Thank you, Mr. Chairman. I appreciate you
holding this hearing.
I want to build upon what my friend, John Thune, was just
talking about on how we make sure, Ms. Kim, that we get these
offices reopened. And again, I want to thank you for your 30-
plus years of public service.
I know you have this OMB rule that says you cannot put more
than 25 percent of your personnel back in the office at this
point, but I still do not understand why that would preclude at
least some level of in-person appointments.
And again, I know this has been a hard, hard time for you
and your workforce, but I am getting inundated with
constituents who have really heart-breaking stories. I had a
constituent named Marie who had a young son, literally a 1-
year-old son, who had his Social Security number stolen, and
she did not know his Social Security number. Obviously, if they
are an adult, they can rememer it. So she was told she had to
send in all this paperwork, including the original copy of her
driver's license, which is just baffling to me. Because she
knew if she sent her driver's license in, she had to still
drive to work, and if she did not have her driver's license,
she was going to get fined.
And when she finally tried to get some response, they said,
``Well, you can file an extension on your taxes,'' but it is
causing some real consternation. And I really do hope you will,
even working with the OMB restrictions, be willing to get more
of these in-person sessions scheduled.
I also want to talk to you about outreach to vulnerable
communities. I know the number of SSI applicants during the
pandemic went down, but I am really afraid about where we are
going to go from here.
What kind of outreach are you going to be able to do?
Because my understanding is that of the couple of million
people eligible, you only sent out 200,000 notices of this
eligibility. It feels like, even with the COVID restrictions,
you have a lot of vulnerable populations that are not being
told about what they can benefit from.
Can you talk about this outreach to vulnerable populations?
Ms. Kim. Absolutely, Senator Warner. So this is one area
that I have been very, very proud of, considering our
limitation in the number of people that we can see in our field
offices.
So, over the course of the pandemic, and as I laid out in
my testimony, we have engaged in unprecedented partnerships
with national and community-based advocacy organizations. And
these organizations and advocates represent and serve the most
vulnerable populations.
And I characterize our effort as unprecedented because of
the breadth and the number of groups with which we have
partnered, and the scope and number of initiatives that we are
currently working on with these partners. And these initiatives
encompass a number of areas of broad-based national and local
campaigns to educate the public about how to reach us, the
kinds of benefits that are available. As I mentioned earlier,
we are establishing SSA points of contact in every area where
we have a field office. And those points of contacts are
working directly with organizations to help those organizations
file SSI claims on behalf of those they serve and get those
claims to SSA, or to help those organizations access other
types of services for their clients and customers.
We are also developing training tools and videos for these
organizations, as well as for the public, and anyone who might
be able to assist another person in filing an SSI application
or any other kind of claim. And the 200,000 mailers that you
mentioned, we are about ready to start that mailer for an
additional 1.2 million individuals in June.
So we are going to be reaching out to an additional 1.2
million individuals who might be eligible for SSI, and invite
them to apply for SSI if they think they meet the requirements.
And then as I also mentioned----
Senator Warner. Ms. Kim, I think the chairman wants to move
to the next, but I will follow up with you, because I
appreciate that 200,000 have been sent out, but 2 million are
eligible. But I will follow up.
Thank you, Mr. Chairman.
The Chairman. Thank you. An important point, Senator
Warner.
Next is Senator Daines.
Senator Daines. Mr. Chairman, thank you. In particular I
want to thank Ms. Murphy for taking the time to join us from
Great Falls, MT. My mom saw her first rodeo when she was 4
years old in Great Falls, so, a lot of family members in that
part of our State.
I want to start by commending the leadership and the
workforce of the Social Security Administration for their hard
work over the past difficult 14 months. They were tough times,
and I think the SSA really did step up to the plate.
Social Security is really relevant, it is truly relevant
and important to Montanans, and that is why I care deeply to
ensure that benefits are accessible and service delivery is
smooth. In fact, when we look at the State of Montana, we are
actually one of the oldest States west of the Mississippi. In
fact, we are among the top 10 oldest in the country. So this is
a very important issue in many ways for the people of Montana.
One thing I have heard from my constituents is that they
would prefer to have the ability to sit down in person with a
Social Security staff member. They tell me it is just not the
same to talk to somebody over the phone.
Coincidentally in fact, I heard this exact concern just
last week from a constituent in Great Falls, MT, and I think it
does make sense from a service delivery perspective to have
Social Security's workforce safely returned to the workplace as
soon as possible.
Ms. Murphy, again, thanks for joining us from Montana. Have
you heard any similar stories from Social Security
beneficiaries in Great Falls? And would you say that Social
Security Administration employees would like to be back in the
office as well?
Ms. Murphy. Thank you, Senator Daines. I am happy to be
here, and happy to be in the State of Montana. And I would like
to tell you, in Montana and in my service area, I have four
offices. And our customers are probably a good representation
of customers all across the United States.
They like service delivery options. And so I have some
folks who say, ``Yes, I want to sit down and have a face-to-
face.'' I have others who are very happy and say, ``Oh, I do
not have to come in? Great. I am happy to do this over the
phone.''
So I think the key in Montana and every other State is that
we have options for customers. And that is face-to-face
service. That is on the phones. That is online. And it is also
video service delivery. And in my oral testimony, I said that
we have video service delivery, especially in rural areas. The
four reservations are in my service area. We have video service
delivery at every IHS clinic there.
And so, that means folks do not have to travel. They love
having that video service delivery option, because a customer
in the IHS clinic can directly see one of my employees in my
office. The problem with that is, the IHS clinics have also
been closed, so customers cannot come in there to have that
service delivery channel.
So I would say the most important thing is having all of
the options. And that is what we want to advocate for. However
people want to do business with us, should be the option that
they have to do business with us. And that includes face-to-
face.
And as far as employees coming back, I think that is a
mixed bag. We were very, very nimble in being able to go to
telework, more than we actually expected. My employees,
particularly in Great Falls, MT, Havre, and Glasgow, were not
excited to be teleworkers. Now they love it. So we have to
balance that as well.
The work that makes sense to do teleworking, great. The
work that makes sense to do in the office, we want our
employees back in the office as well.
Senator Daines. Ms. Murphy, thank you. It is refreshing to
hear your focus on the customer in terms of their needs and the
multi-channel approach you apply towards customer service.
Thank you.
Ms. Kim, I know you have touched multiple times on Social
Security's plan to return to normal operations, but could you
talk about the back-to-work plan that takes into account the
regional--the regional--differences?
Ms. Kim. So currently, as I mentioned, we are still
operating under our current workplace safety plan. So we are
limited in the numbers of individuals that we can bring on
site, and I want to make sure that anyone we do bring on site
will be safe.
So those plans to bring additional employees on within the
parameters of our current workplace safety plan are really
going to be dependent on where the workload need is. So the way
we are--the way I am handling how we will be staffing up is
really looking to my regional Commissioners. They are the
primary executives in every region, and they are working with
their area directors----
Senator Daines. I am running out of time. Thank you. You
answered my question.
Squeezing in one last question, we hear a lot about scams
targeting seniors. We hear news reports from Great Falls and
elsewhere in Montana of scammers using local numbers to target
the elderly. These scammers are pretending to be Social
Security employees in an attempt to get seniors to hand over
their Social Security numbers.
Ms. Murphy, have you seen an uptick in Great Falls and
other parts of Montana, during the pandemic, of these kind of
scams?
Ms. Murphy. Yes, Senator, we definitely have. And how we
have been combating that is just basically by communication.
Any person who calls us, we routinely are letting folks know,
do not give your Social Security number out to anybody who
calls. We will not ask you for your Social Security number.
They have gotten more and more clever. They are using actual,
it looks like a local phone number, and saying that they are
the Social Security Administration.
In my particular area in Montana, we also go the extra step
to say the best way to spread the news is to tell somebody
else. So tell your neighbors, tell your friends, tell your
relatives: do not take any calls from these scammers. Do not
give out your Social Security number. And if Social Security
calls you, it is because you asked us to call you.
So sometimes it is just spreading that message.
Senator Daines. Thanks, Ms. Murphy. You just made a public
service announcement for us. Thank you.
Thanks, Mr. Chairman.
The Chairman. That is very important. Thank you.
Senator Whitehouse is next.
[No response.]
The Chairman. And then Senator Young.
[No response.]
The Chairman. And then Senator Hassan.
[Pause.]
The Chairman. Senator Hassan?
Senator Hassan. Thank you very much, Mr. Chair, and thank
you, Ranking Member Crapo, for holding this hearing. And thanks
to the witnesses for being here to discuss this important
topic. Social Security programs certainly serve as a lifeline
to our most vulnerable citizens, and we have to ensure that
these programs are accessible.
I want to start with a question to you, Deputy Commissioner
Kim. A year ago, I helped lead efforts to ensure that Social
Security recipients automatically received Economic Impact
Payments. Unfortunately, Social Security beneficiaries did not
receive their latest automatic payment until more than a month
after the American Rescue Plan was signed. I have also heard
from constituents who have still not received their automatic
payment.
Deputy Commissioner Kim, how is the Social Security
Administration working with the IRS to ensure that Economic
Impact Payments reach beneficiaries who should have
automatically received their payments but have not?
Ms. Kim. So, Senator, the Commissioner is working directly
with the IRS to ensure that SSI beneficiaries and recipients
are automatically receiving their Economic Impact Payments. And
it is something that the Commissioner has done with every
Economic Impact Payment. We have shared information with the
IRS to enable them to send the payments to our beneficiaries
and SSI recipients.
And, as we have done with the other Economic Impact
Payments, we are providing information to our beneficiaries and
recipients on our website. We are working through our advocate
groups to share information about how they can get their
questions answered about these Economic Impact Payments. And
so, we are doing everything that we can to ensure that our
beneficiaries and recipients will receive those payments
automatically.
Senator Hassan. Thank you. I appreciate that. I will urge
you to keep trying to be as creative as you can be, and
innovate there, because people really do need these Economic
Impact Payments, and they are still having difficulty getting
them automatically. So I look forward to continuing working
with you and your agency on it.
I want to turn to Ms. Murphy, to an issue that the chairman
talked about at the top of this hearing with the Deputy
Commissioner. Ms. Murphy, New Hampshire is one of five States
where residents cannot request a replacement Social Security
card online.
Over the last year, with Social Security field offices
closed for in-person services, my office heard from a number of
constituents who sought to replace their Social Security cards
and were directed to complete the process through the mail. It
included mailing in driver's licenses, leaving individuals
without their IDs for long periods of time.
In March 2021, the Social Security Administration permitted
individuals to use other forms of identification to meet this
requirement, but they still required identification documents
to be mailed.
Ms. Murphy, how do you think the Social Security
Administration can streamline this process, as field offices
remain closed for most appointments, and make this process more
accessible going forward?
Ms. Murphy. Thank you for that question, Senator.
Definitely, that has been one of our biggest challenges
during the pandemic, is folks who would normally come into the
office to take care of a simple transaction not having that
opportunity. And moving forward, I would like to see that we do
streamline that process, be it data exchange, so that we have
opportunities to verify people's documents.
Sometimes--this has caused us to really re-look at our
policies and say, ``Why do we have to have this document?'' So
I think we have done a good job of being flexible during this
pandemic. And what I am really hoping--and I know Grace is
too--is that we will be able to realize some of these things
that we have had to put in place temporarily that really make
sense, so that we can serve our customers in the way that is
easiest for them.
And the change in the policy for secondary evidence has
really made a huge difference for the constituents in my area,
and across the Nation, because it is easier to get one of those
documents and part with it than is a driver's license.
Senator Hassan. Well, thank you for that. And I thank you
for your service and your work, and we really should just be
focusing on our customers, our citizens.
So I have one more question for the Deputy Commissioner. On
Tuesday, I led an oversight hearing where we discussed the
Federal Government's use of outdated legacy IT systems. The
Social Security Administration's reliance on legacy IT and
paper-based systems hurts the American people's ability to
access benefits, increases security threats to the agency, and
creates more opportunities for waste, fraud, and abuse, costing
taxpayers money.
So, Ms. Kim, how will you work with the Chief Information
Officer at the Social Security Administration to execute the
agency's modernization plans to these systems? And when can we
expect the agency to fully dispose of its legacy IT platform?
Ms. Kim. So that is an excellent question, Senator. And
Operations is working hand-in-glove with Systems, as well as
other components that all have a stake in the IT modernization
effort underway with SSA. It is why it is so important that
there continues to be investment in SSA's IT modernization,
because for my employees especially--and this is something that
we have learned and that was highlighted during the pandemic--
we do not have end-to-end systems that allow a customer to seek
to do business with us, and that let our employees be able to,
from end to end, process that transaction seamlessly.
Instead, the pandemic highlighted the number of workarounds
and stops and starts that we have because of the use of our
legacy system. I do not have an end date yet for when all
legacy systems will be eliminated, but we are making headway
every day on our IT modernization plan. And I am very, very
excited for the opportunity that modernizing our systems will
bring Operations and all front-line employees.
Senator Hassan. Well, thank you very much. And thank you,
Mr. Chair, for your indulgence in letting us go over time.
The Chairman. A very important question.
Senator Hassan. It is very important. Thank you.
The Chairman. Thank you, Senator Hassan, and for your good
work.
We are now waiting for several Senators who would like to
ask questions. There is Senator Whitehouse. Very good. And I am
going to run and go vote, and we have several other Senators
who are going to ask questions, and then I want to make sure we
wrap up with clear instructions about what needs to be done
going forward.
Senator Whitehouse? And thank you, Senator Crapo; we will
go back and forth and keep this going.
Senator Whitehouse?
Senator Whitehouse. Thank you.
I share the concerns of many of my colleagues who have
heard from our constituents about a variety of problems that
have followed from the transition to pandemic-safe remote work
by Social Security. I appreciate the effort that you all have
gone through to keep your employees safe, but it has had these
effects. And the quicker they can be resolved, the better.
Two questions. One is, where are we on finding other ways
to have access to people's personal documentation, like
passports, for identity verification? Because people get
spooked when they have to put their passport physically in the
mail. Have we solved that?
Ms. Kim. Senator, I'm sorry, I needed to get off mute.
Senator, what we are doing during the pandemic is allowing for
individuals to use secondary evidence to verify their identity.
The fact of the matter is, there are certain types of
transactions, Social Security number transactions, that require
us to look at primary forms of identity, and to meet with
individuals in person. That is a regulatory requirement.
Senator Whitehouse. Have you adapted that for Zoom? I mean,
we are adapting everything for Zoom. This hearing is being done
for Zoom. If you have somebody in front of you and they can
show you, wave their passport at you, it seems to me that there
are ways to make that work.
Ms. Kim. There are. There are certain types of Social
Security cards where we are able to successfully use video to
verify someone's identity that way. But those are really no-
change replacement cards.
But for original cards and other types of Social Security
cards, the law does require us to verify primary forms of
identity proofs, and also to interview the person in person.
So----
Senator Whitehouse. Can we change that legislatively? Or is
the clock going to run out as you come back to work, so that
this is a problem whose horizon is close enough that we do not
need to take action?
Ms. Kim. So we are currently looking at that very issue
internally, Senator. And I hope that we will have an
opportunity to revisit the legal requirements for what we need
to do to process the Social Security card.
But for purposes of the pandemic, we have tried to
alleviate the burden on the public by allowing for secondary
forms of evidence, or identity proofs, that do not require
someone giving up their passport or their driver's license.
So, in appropriate circumstances, individuals can use
certified medical records or other forms of proof to verify
their identity.
Senator Whitehouse. Well, I would encourage you to try to
get an answer to us within the window that the chairman is
going to provide for questions for the record as to what you
are going to need. Because we do not want to be in a situation
where, because we are not getting a timely answer from Social
Security, we end up not taking action that we could probably do
with a huge bipartisan, instantaneous, almost unanimous consent
on the Senate floor, and then we find out in fact this is a
problem that is going to endure for several months and continue
to bedevil our constituents.
So I think, if Ranking Member Crapo and Chairman Wyden
could get a clear signal from you within the QFR time about
what is needed, we can then respond appropriately and not have
people caught in this quagmire of indecision.
A separate question for Ms. McGuinness. Just over half of
Social Security Disability applications have been submitted
online in 2020. Is there a way--what do you recommend--is there
anything we should do to be able to make electronic submission
of Social Security Disability applications more prevalent?
Ms. McGuinness. I think it is really important to try to
understand the beneficiaries' needs. There may be some
beneficiaries for whom you will never move them online. There
may be some beneficiaries for whom if the process were more
straightforward, it would be easier to move online. And I think
a close look at the trends in the pandemic would be the first
step in trying to up the number of folks.
Second is, we found in other benefit delivery experiments
that complex online processing can be beaten by paper. So you
may be driving people to in-person assistance because of the
complexity of some online systems. So I think a closer look,
really testing with folks you are serving, understanding what
the feeling is of people to be able to move online--I suspect
some of the Social Security population, as we have heard,
really does need to go into the office. But trying to maximize
the efficiency of folks who do not is going to be the first
step.
Senator Whitehouse. Well, you could, I think, help us if
you could make a recommendation, again in the QFR window of
this hearing. Treat it as a question for the record from me, if
you must, and see if you can make a recommendation that is
simple and clear and obvious enough that it would be amenable
to unanimous consent by the Senate to work our way through this
problem.
I know there are going to be some complexities and some
difficulties, but to the extent you can follow the KISS--keep
it simple, you-know-what--rule and give us a recommendation, I
think we would be in a position to act on it.
Thank you all very much.
Senator Crapo. Thank you, Senator Whitehouse.
Next is Senator Warren.
Senator Warren. Thank you very much.
When the pandemic hit and Social Security offices across
the country had to close their doors, millions of Americans
faced delay in receiving their benefits, or they were unable to
apply for benefits at all. And this is particularly the case
for some of our most vulnerable Americans who depend on the
Supplemental Security Income program, or SSI. SSI is the part
of Social Security that serves as a lifeline for low-income
seniors and people with severe disabilities, people who
otherwise would have little or no income to live on.
So SSI is really about survival. And it helps keep more
than 8 million people, including a million children, afloat.
But the program has been neglected for decades now. And it is
not providing beneficiaries with the economic security they
need.
Mr. Causeya, you have helped hundreds of people in your
community access SSI. Let me just get your opinion on this. Is
the program doing enough to provide adequate support for people
with disabilities, and seniors with very low incomes?
Mr. Causeya. They are doing, I guess, what they can under
the circumstances, but it is not--I would not say it is
adequate. There are hundreds of people who need basic
assistance that they are not able to get right now through SSI
benefits.
Senator Warren. Well, thank you. You know, we need to
improve SSI so that Americans who are most in need have access
to this support. And that is why I have called for increasing
SSI benefits to at least the Federal poverty line, eliminating
the asset limits that prevent beneficiaries from saving for the
future, and ending the rules that force people to choose
between their benefits and marrying the person they love.
Now, President Biden also supports many of these reforms,
and I joined several of my colleagues, including Senator Brown
and Chair Wyden, in urging him to include them in the American
Families Plan. Congress should make good on the President's
promises and strengthen SSI now.
Mr. Causeya, let me just ask you, would these SSI reforms--
increasing benefits, eliminating asset limits, ending outdated
rules--would they meaningfully change the lives of the
vulnerable Americans that you work with every day?
Mr. Causeya. Absolutely. Absolutely. We have clients who
comment about how being on benefits has changed their lives,
has increased their hope in their lives.
We have counselors who work with these people with severe
and persistent mental illness all day, every day, and one of
them wrote to us to say that they cannot tell us enough about
how much of a change is made in people's lives when they have a
stable income. They go from being very stuck and really
struggling, to quickly making immense progress. Not only that,
you know, it opens doors for people who are living on the
street or who are at risk of being put out on the street, who
are in shelters and transitional housing units, that are
probably on a short-term grant for housing.
So SSI is immense when it comes to improving the quality of
lives.
Senator Warren. Well, thank you. Thank you for the work you
do, and thank you for your up-close and personal testimony
about this.
We need to strengthen SSI, but we also need to make sure
that people have the help they need to access SSI and other
benefits. SSI applications and awards have been at historic
lows during the pandemic, a time when the program should have
been helping more people, not fewer.
Field office closings are one of the reasons, but another
is decades of disinvestment in the Social Security
Administration. Congress has starved the agency of funding for
years. And its operating budget is now 12 percent smaller than
it was a decade ago, even though the number of beneficiaries is
up by 21 percent.
Ms. McGuinness, I am running out of time, but can you just
say very quickly what have been the consequences of this
disinvestment in SSA on low-income seniors, people with
disabilities, and other people who rely on benefits?
Ms. McGuinness. Senator Warren, the consequences of
disinvestment are real and formidable. Low-income families go
without food. They are forced to move, and they scrimp on life-
saving medications. It is really clear that improving the
process is necessary, but funding the fundamentals is
essential. And State and Federal agencies must have the basics.
It does not matter if the form is useful if there is no one
there to pick up the phone.
Senator Warren. Thank you. And thank you for your work.
You know, for people with disabilities who rely on SSI to
get by, these investments in our safety net are long overdue.
We need to make it easier for people to access the benefits
they desperately need, and we need to rewrite the rules of SSI
so that recipients have a fighting chance at building some real
economic security for themselves.
President Biden should do this today.
So thank you, Mr. Chairman. Thank you for having this
hearing.
Senator Crapo. Thank you, Senator Warren. And I am waiting
right now for Senator Wyden to return. We have a number of
Senators still on the list, but we are also in a vote.
Actually, we are in the process of four consecutive votes, and
we expect that that may cause a number of our Senators to be
unable to return.
Are there any Senators who have not had an opportunity to
ask their questions who are with us?
[No response.]
Senator Crapo. All right; seeing that there are none, I am
going to recess the hearing. I apologize for the delay to each
of our witnesses, but I am going to recess our hearing
temporarily while we wait for either one of our Senators to get
back, or for the chairman to return and make the determination
as to whether we should wrap the hearing up.
So at this point in time, we will be in recess.
[A brief recess is taken.]
Senator Crapo. Mr. Chairman, this is Senator Crapo. I see
that you have returned. I have put the hearing into recess
awaiting your return, and so I think that if you are ready to
begin again, you will just need to bring us back into order.
The Chairman. You are ever gracious, Senator Crapo, and I
thank you. I have one additional question, and then a short
closer, and we will wrap up.
Senator Crapo, do you have any additional questions you
would like to ask?
Senator Crapo. No, I do not.
The Chairman. Okay.
Mr. Causeya, thank you again for your good work and all you
do to help the vulnerable in Portland. We have met so many
times with Central City over the years. We are very
appreciative.
I would be interested in hearing what would be the major
changes you would like to see at Social Security that could be
helpful to your folks who come to Central City. I know that you
really made the point about the acronyms and all the government
lingo and the like that is just kind of a blizzard of verbiage
for people. Are there other things that you think would be
particularly helpful for the folks you see at Central City?
Mr. Causeya. Yes; thanks for asking. I think that if the
field offices could dedicate more time or more access for their
claims reps with community partners, or people who are helping
others, the non-attorney or attorney reps who are helping
people file for Social Security, that would go a long way.
Because like my organization, for example, we do our best to
maintain contact with our clients. We go out in the streets and
find them. We gather all the information that we need if Social
Security has a request of them, and we do our best to ensure
that that information gets to Social Security. That is one
thing.
I think there could possibly be kiosks in places where
homeless populations frequent. That would be very helpful too.
I mean, maybe there is a lot that might not be able to be done,
but at the very least it could be a phone-in time for a
scheduled phone call with the rep at Social Security to get
your question answered, rather than having to wait on the phone
for 40 minutes to an hour, or even longer, and then take the
risk of, after you have been waiting for a while, getting hung
up on because of technical issues.
I think that making the Social Security application
different, making it easier, would be a great help. We have a
lot of people whom we serve who start the application process
on their own because of the time it takes for us to get to
them. So it would be great if they did not make so many errors
in filing the application by not understanding what SSA is
asking of them. And really a more flexible call-in time, more
time for the public to actually reach out to Social Security.
And I am not sure--I know that there are a lot of
organizations that have been working face to face with people,
like our clinics, or most clinics. They use plexiglass when
they are having face-to-face interactions with clients. That is
possibly something that Social Security could look into.
So I just think that during this time--and we are looking
at new ways to move forward during the pandemic, and possibly
after the pandemic. I guess my major point would be that Social
Security could engage more with community organizations that
are helping people file for Social Security Disability.
The Chairman. Thank you very much. And we just appreciate
all your good work, and getting up early to make this important
testimony.
Ms. Kim, what kind of wrap-up do we have, kind of a game
plan here going forward? Because we know that you are here
testifying on behalf of the agency, but there are many parts of
the agency that are involved in these issues.
First, I believe that it is critically important to end
this requirement that some people have to produce the original
documents like driver's licenses in the mail to start this
process of securing their benefits. And I will tell you,
listening to my colleagues today, one Senator after another
brought this up.
This requirement is just a prescription for bedlam and
making lives increasingly difficult, when I know that is not
your intent. You have been a professional there in the field
for a long time, and I know you care deeply about people.
So my first request is, I would like a detailed plan,
whether it is a tech fix--and it occurred to me, and I do a lot
of privacy work, that you have to be scrupulous about
protecting people's privacy. But it would seem to me that there
are some questions with respect to whether you could get this
data from the DMV in a way that protects people's privacy. But
you know, the point is, we need a detailed plan with respect to
how this is going to get done.
Is it tech? Is it appropriations? Is it legislation? But
this just is not right, period, full stop. So I would like to
set a 2-week deadline to get from you what your plan is to not
force vulnerable people to be sending hither and yon their
driver's licenses and these original documents, because this is
just unacceptable to me.
Can we agree that we will get a plan within 2 weeks on how
this is going to end?
Ms. Kim. Yes; we will get you something, Senator.
The Chairman. Very good. Thank you.
Second, I think we already talked about the targeted
outreach letters, and you indicated that you would get us the
results of the letters and what you all are doing on that as
well. Is that still acceptable to you?
Ms. Kim. Yes. And I just want to reiterate we are going to
start reaching out to the 1.2 million. We are sending out
letters to them.
The Chairman. Very good. Well, why don't you get us in
writing what we discussed earlier: you know, the plan for using
the data. And you touched on a number of things. I was trying
to keep track of them, and I did not get them all. And so it
would be helpful to do that as well.
And then the third area that Senators were talking about is
this 23-page application process where you have to get people
through all of this verbiage and the like. And I think it was
you, Ms. McGuinness, who was touching on some of the forms and
trying them out on people before you went ahead, and the like.
It would seem to me possibly there is a Kim-McGuinness
alliance here that could figure out how we could get the
process simplified there as well. Why don't we say, for
purposes of that, Ms. Kim, how about over the next month you
put together for the Finance Committee a plan on how we can
reduce the size of all that. And I suspect Ms. McGuinness could
be conscripted into working with you on all that. But again, it
just seems that it cries out for simplification. Okay? All
right.
Those are the three follow-up requests, Ms. Kim, and we
thank you for being here.
And let me again note my respect for--I believe you have
been at the agency for 30 years?
Ms. Kim. That is correct; 33 to be exact.
The Chairman. That is a long run of public service. And we
say to you and to the many employees at Social Security, this
has been obviously a year like none other. Back in the days
before I was an elected official, I was co-director of the Gray
Panthers. I ran the senior citizens law service. And I saw so
many dedicated people who work at Social Security, and I think
our challenge is that the kinds of issues we need follow-up on
are not necessarily going to involve decisions that they make
every single day. But we want their input. We want their ideas,
and we want to get results for people who are walking an
economic tightrope every day in America.
So I want to thank our witnesses for their patience. And
the information and questions for the record need to be
submitted by the close of business on the 6th of May, a week
from today.
We thank our witnesses and all the Senators for their
helpful questions. And with that, the Finance Committee is
adjourned.
[Whereupon, at 12:24 p.m., the hearing was concluded.]
A P P E N D I X
Additional Material Submitted for the Record
----------
Prepared Statement of Kascadare Causeya, Program Manager,
Central City Concern
Chairman Wyden, Ranking Member Crapo, and members of the committee,
hello, my name is Kascadare Causeya. I am the program manager for the
Benefits and Entitlements Specialist Team (BEST) for Central City
Concern, on the board of directors for New Narrative (formerly
LukeDorf), and a member on SOAR's National Experts Panel; all
organizations serving people experiencing poverty and homelessness. I
have been working for Central City Concern and those suffering from
severe medical and/or mental health conditions since 2008.
I want to thank Chairman Wyden and this committee for the
invitation to present here today, on this topic which impacts many
people struggling with homelessness, and those at risk of homelessness,
who suffer from severe and persistent conditions. I want to also say
that although I will be addressing some of the issues caused by the
closure of SSA offices, I have the utmost respect for those within SSA.
They are tasked every day, for much of the day, with reading about,
listening to and witnessing the pain and suffering that their fellow
Americans endure; and so you know, that can, and does take a toll on
you, many times in ways you don't even realize. However, for all of us
serving that population, it is our passion to help others that gets us
out of bed each morning and takes us to the place where we can assist
those needing our help. In the work that my team does, we have been
using the SOAR model for developing and filing our claims to SSA since
BEST (Benefits and Entitlements Specialist Team) began in 2008. SOAR, a
national project funded by the Substance Abuse and Mental Health
Services Administration, was designed to help increase access for SSI/
SSDI for people with severe conditions that could not go through the
SSA disability process on their own. It teaches social service and
mental health providers how to help their clients submit a completed
SSA applications, complete with records, testimonies and other
supporting documents that show the claimant's difficulties functioning.
Since March of 2020, the barriers for those needing Social Security
benefits have increased in various ways.
(1) Applicants can't just walk in to the field offices, and a pre-
arranged appointment is hard to get. This means people have trouble
getting help understanding the nuances of going through the disability
process: for example, a woman new to homelessness listening to the
myths about SSA and disability, suffering from the residual effects of
a serve bipolar decompensation, being so disorganized and afraid that
she slept on the sidewalks during the day and began using meth to stay
wake at night for fear of getting harmed. She is going to struggle
until she finds help.
(2) That even for those who have access to the various forms of
technology needed to complete the application process, there has been
an increase in the time demands on the claimant for completing the
process, such as technical issues and dropped calls. This is hard for
people: an example is a young woman who graduated cum laude from one of
the major universities in the land, but suffered from severe depression
since her teen years, and underwent over 30 electroconvulsive therapy
(ECT) treatments, resulting in a significant loss of IQ points and
extreme labile moods, and no longer has the ability to be patient or
struggle to complete tasks.
(3) For those without the necessary technology and understanding to
begin and complete the process, there is limited or no access to SSA
staff and information that could help them complete applications and
the various other tasks requested of them: we helped a person with an
intellectual disability who was estranged from his family and choosing
to live on the streets rather than admit to his family he just couldn't
understand things, which was a lifelong embarrassment for him.
Also it should be recognized that many in these categories will be
applying for SSI, and there is only a PDF application for SSI (which
requires printing it out to complete) this creates another barrier
because most people are not familiar with the SSA disability process
and don't know the difference between SSI and SSDI. And people might
not always have a working phone number, a mailing address, a printer or
a way to check mail if Social Security tries to get in touch. Also if a
person doesn't have enough earned income credits the online SSDI
application will be denied, and for many without the knowledge of the
disability process, believe that denial is for SSI as well.
(4) For those whose conditions prevent them from being mentally and
physically capable to respond to SSA requests, the closures of the
field offices can cause many to fall through the cracks, such as a man
in advanced years suffering from metastasized cancer and having one leg
amputated, but continuing to work albeit in a supported employment
role, not knowing the option of claiming early retirement benefits
while applying for disability.
(5) Increased hopelessness and feelings of apathy for those
attempting to become more self-sufficient, like an older gentleman
suffering from a multitude of conditions, who had been falling through
social service cracks for decades, losing trust in systems, that his
life will ever have meaning and even losing trust in those who attempt
to help him.
Fortunately, the people I have described here were the lucky ones
because they were able to get help from BEST, but there are so many
more that can't get access to my program, and are just as ill and
vulnerable. Unfortunately our capacity is limited and we can only
accept referrals from approved sources within our community. People
referred are screened by the referral source, then screened by us to
see if they meet our criteria for acceptance into the program.
Although these issues exist in all homeless communities, it is
particularly true for blacks, Native Americans, and Latinx communities,
who disproportionately experience homelessness at higher rates,
compared to their white counterparts.
A few statistics from my program related to years prior to the
pandemic, compared to during the pandemic:
For the 3 years prior to March 2020 (2017-2019).
We averaged 806 referrals a year.
Time to an SSA decision was 79 days.
Since March 2020.
We received 673 referrals.
Time to an SSA decision is 110 days.
I know that a small program serving some of the community doesn't
compare with all of those being served by SSA, but I share these
numbers to show the impact office closures to walk-in clients has had.
SSA closures can be expected to result in a significant impact to the
wider community as well. National numbers reflect this local trend--
applications are down approximately 15 percent and awards for people
with disabilities are at their lowest rate in 20 years. In Oregon, the
average number of initial disability claims from 2017-2019 was 2202 a
month; in 2020 it was 1907. That's a 13.4-percent drop. And even as
applications went down, the number of people waiting for an initial
decision went up 48.4 percent in Oregon comparing 2020 to the 3 years
before it. SSI-only claims dropped even faster and the backlog rose an
even greater percentage. When you consider the initial and
reconsideration levels together, 139 more low-income, low-asset
Oregonians received favorable disability determinations for SSI each
month in 2017-2019 than in 2020. That's 139 children and adults every
single month of 2020--we don't have the 2021 data yet. And Oregon is
just one State.
National numbers reflect this local trend.
Many people suffering from severe and persistent conditions have
nothing in the way of resources to help them survive. Many have a work
history but their conditions have persisted for years and in some cases
decades, so by the time they can qualify for disability benefits, they
are completely dependent on these funds. The $794 a month they get from
SSI is still below the Federal poverty level, but can open housing
doors, offer the ability to get from place to place using public
transportation for things like primary care appointments and
counseling, can offer them some hope for the future, and allow them to
set their own level of self-sufficiency and quality of life, that
previously wasn't available to them. These benefits are needed,
appreciated, and life-changing. We often have people comment how this
has changed their lives, saved their lives, and we get to see them with
a new sense of hope. A counselor at Central City Concern, who works
daily with those with severe and persistent mental illness wrote to us:
``I cannot tell you enough how much of a change it makes for people to
have secure income, it is often the thing that gets people from being
very stuck and really struggling to really quickly making immense
progress and improvement.''
So here are some possible solutions:
Safely re-open field offices for drop-in appointments. Many
clinics are and have been doing this for many months now.
Simplify the SSI application and make it more accessible. Many
people struggle with SSA terminology and understanding what to the
trained person seems a simple question.
The current My Social Security electronic access is too
complicated for most people, and requires an email address that not
everyone has or can remember passwords to. People should be able to
access SSA services with their SSN, even if all they can do is schedule
a phone call. Please remember that wait times can be very difficult on
a person with severe mental health issues. A remedy for this might be
kiosks that are located in places like grocery stores, libraries,
homeless resource centers, etc., kiosks located in places where people
in poverty and without homes frequent, these would provide a viable
option to walking into the local branch. For those with phones,
symptoms of mental illness are barriers to having the ability to sit on
hold and be hung up on multiple times when calling the general line.
People also don't have phone minutes to wait on a 40-minute hold
period. People need something between the My Social Security site and
the option of walking in the office. This could also be a resource for
SSA communicating with people for things like replacement SS cards,
reporting additional income, benefit verification letters (often needed
for housing), and other services the field offices provide.
Communication between SSA and the public is an absolute necessity; it
was time consuming before the pandemic, and now it's become prohibitive
for many.
More funding for nonprofit organizations to help vulnerable
people to apply for SSI/SSDI through SOAR. Many people who need SSI
will not be able to get through the complex form on their own. There is
and will be a backlog of cases this year, due to the delays resulting
from the pandemic.
More flexible and scheduled call in times for the public.
More access to reliable community based mailing addresses so
people have a place that will receive and hold their mail for them.
In the Portland area, SSA has established the Auburn/WSU (Work
Support Unit). Many of the disability claims that go to that unit are
for people over age 62 and eligible for early retirement benefits,
which they could receive while a decision on their disability claim was
pending, but because of not being able to communicate directly with
staff there, claimants are not able to make an informed decision based
on the details of their claim. It would be very helpful if this and
other SSA offices were to commit resources to increasing claimants' and
their representatives' accessibility to SSA staff; especially since the
representatives are doing the work to maintain contact as well as walk
these very vulnerable people through the complicated process of
applying for disability and other needed resources they may be entitled
to.
Another challenge is SSA's tendency now to move away from checks,
encouraging claimants to choose direct deposit or Direct Express, or a
third-party debit card. Unfortunately, many don't have bank accounts
for various reasons, and it's difficult to communicate with customer
service staff if they have Direct Express or a third party debit card.
Many people suffering from severe mental health issues often do not
have the best memories and need help figuring out what they need to do:
like a homeless gentleman we had as a client, so disorganized that he
couldn't keep track of his important documents, wallet, phone or keys.
Remembering his current and past addresses was also a problem which
resulted in the inability to prove his identity to the staff at Direct
Express so they would help him. It's understood that many of these
measures are in place to protect the claimant, but they rely on the
person having adequate memory and a certain level of organization.
The COVID pandemic has caused us to rethink how we can do what
needs to be done, and what the new normal will look like. Let's
consider making things a little easier for those whose abilities are a
little more challenged than ours.
Thank you for listening to my testimony today. I look forward to
answering any questions you may have.
______
Questions Submitted for the Record to Kascadare Causeya
Questions Submitted by Hon. Ron Wyden
Question. What is the BEST program, Central City Concern and the
community doing to address the barriers faced by SSA field office
closures?
Answer. We remind community partners and clients that the SSA
disability process is slow during the best of times, and to expect an
even longer process now that we are in a pandemic.
We have created interview rooms complete with phones, computers,
and webcams so that clients who can get to our office can have privacy
for their appointments with SSA and treating sources. We have also gone
to three party calls with SSA for those with cell phones and who can
find a private place to talk. Many programs are handing out cell
phones, unfortunately our benefits programs doesn't have the budget for
this.
We have tried to increase involving community partners in the
process for getting documents signed, helping their clients with a
private place with a phone for interviews with BEST and SSA. Many
outreach workers are considered essential during the pandemic and in
more and more instances we are relying on them to help us maintain
contact with clients who are living on the streets without a means to
be contacted.
We are asking primary care clinics to put flags in patient's files
for them to reach out to us when we or SSA need additional information.
We have relied heavily on using the US postal system for getting
documents signed by clients and to SSA.
We are keeping clients files open longer than we should once their
benefits have been awarded and are flowing, in case there are payment
or payee issues post eligibility.
Question. Two practical ideas stand out from your testimony. You
mentioned the struggle people have contacting SSA by phone and suggest
``people should be able to access SSA services with their SSN, even if
all they can do is schedule a phone call,'' and later you state,
``people need something between the My Social Security website and the
option of walking in the office.''
Can you tell the committee more about what you have in mind for
this new communication option?
Answer. When a person walks into a field office, they have to sign
in using a kiosk which notifies claims representative they are in the
office and ready to be seen. Our idea is that if we could place kiosks
in various places throughout the community, people needing help from
SSA could use them to schedule phone calls at a specific time with a
specific representative; they could use them to check the status of
claims or requested information; use them to document income; and use
them to get the SSA address, email address or fax number to submit
documents. This would cut down on call wait times as well as in some
rudimentary way could let the person know that SSA needs something from
them, as well as let SSA know what the person needs something from it
(we would hope that these kiosks would be a little more interactive
than those if the field offices). They could be used much like ``chat
with an operator'' features when visiting various sites for information
and technical help.
Simplify the SSI application and put it online just as the SSDI
application is. Also use common language instead of SSA terminology, or
offer a help screen where people can look-up the terms.
Simplify My SSA log-in and navigation. Consider that many of the
people using it will have mental health issues as well as limited
computer skills. Many will have intellectual barriers, and struggle
with normal activities in life. Understanding and going through the SSA
process is beyond their ability to understand it.
Have SSA and DDS develop more work flows and grant more access to
certain non-profit community partners and to programs like BEST, who
are committed to making SSA's jobs easier by doing all they can to make
sure the claimant understands and is getting SSA the needed information
in a timely manner.
Safely reopen field offices for limited walk-in clients. It can be
done safely by using screening before entry, masks, sanitizer, cleaning
and plexiglas stations for face to face interactions. Kiosks in the
community could be helpful in scheduling these walk-in appointments.
Question. The committee was informed that a SOAR program found it
useful to provide clients with a smartphone. When asked about this, a
program official remarked, ``We absolutely believe that smartphone
access would improve access to SSA benefits and help beneficiaries with
managing and maintaining their benefits. It's also key to their ongoing
communication and support with case management, housing providers, etc.
and so it leads to greater stability in the community.'' Do you agree
that smartphone would help SOAR clients? Does Central City Concern have
a similar program?
Answer. Yes, I absolutely believe smartphones would be helpful to
people in poverty manage and maintain their benefits or in the
application process. CCC does have several programs that are able to
offer their clients smart phones. Unfortunately my program is not one
of them, due to limited and restricted funding. One of the regrettable
things we have had to do is put potential clients on a waitlist,
because we we're not able to make or maintain contact with them. After
COVID closures there have been many who couldn't get in to see
providers face to face, case managers and in many cases addiction
service providers. Phones would allow those people to be reached and
have virtual or phone visits, whereas without them they have none; and
when their condition or symptoms become to problematic to cope, they
resort to using emergency rooms or are picked up by police for causing
disturbances. Smart phones for those living in poverty with severe
medical and or mental health issues would be a great help in
maintaining their connection to the people and programs in place to
help them, as well as with SSA.
Question. Regarding smartphones, I recently learned that Treasury's
Direct Express card cannot be used by Apple Pay or Google Wallet. I
contacted Treasury about this and Treasury reported that they are
working with Comerica Bank on a potential solution. Similar to having
transit benefits on a smart phone, it seems it would be useful for
smart phones to be set up to pay with Direct Express. Do you agree or
do you see any concerns with allowing phones to pay with Direct
Express?
Answer. My concern would be for those who have a tendency to lose
track of documents and possessions or have them stolen (which happens
frequently with some people experiencing homelessness). However the
ability to access all ones needed information and pay for goods or
services all with the phone, would be a great convenience for many. The
new normal after and during COVID is going rely more and more on phones
and computers. People with severe limitations will need all the help
they can get to make their lives more manageable. The use of the phone
will go a long way in helping many to recognize and reach their own
level of self-sufficiency and independence. There are many people with
medical issues, like heart, respiratory and mobility issues that this
will add a chance for more independence in their lives. And I have to
add, reduce the risk of a vulnerable person being taken advantage of
for carrying cash and needing to pull it out for routine purchases.
______
Question Submitted by Hon. Rob Portman
Question. During my questioning, I discussed how critical it is to
ensure that the Social Security trust funds remain solvent. Can you
discuss the human costs that would occur if we run into a situation
where we reached insolvency and the Social Security Administration were
forced to trim benefits?
Answer. If Social Security benefits were to decrease or further
limit eligibility we would see an increase in homelessness, housing
insecurity, food insecurity, and disrupted access to health care. It
would become difficult or impossible for people to purchase basic
household supplies, transportation, clothing, pay rent, or any other
obligations that require income. People would become even more reliant
on things like SNAP, food banks, emergency room care, and increase the
likelihood that someone will lose their housing and end up sleeping in
shelters or on the street. All of these things cause stress, trauma and
social instability that can and will exacerbate underlying mental
illness, substance use disorders and chronic health conditions that
lead people to apply for and obtain social security benefits.
______
Prepared Statement of Hon. Mike Crapo,
a U.S. Senator From Idaho
Thank you, Mr. Chairman, for holding today's hearing on Social
Security service delivery during the pandemic.
Social Security employees were informed in March of last year that
they would be teleworking indefinitely and that field offices would be
closed to the public because of the COVID-19 pandemic. Within days of
announcing a shutdown, the majority of field office employees and a
large number of teleservice center employees were teleworking.
Initial challenges included lack of equipment, software licensing,
and data capacity. The leadership, management, and the workforce at the
Social Security Administration--or SSA--responded rapidly to increase
data capacity and stabilize networks after only a few weeks.
During the pandemic, conducting office and processing-center work
in-person was not possible because of lockdowns and worker-safety
concerns. With those constraints, SSA has had to innovate, relax some
procedural rules, and perform in many previously untested ways. Thus
far, the agency has performed admirably and rapidly to ensure that
beneficiaries, including at-risk populations, obtain the services they
need.
I have been impressed by the dedication and diligence of SSA's
workforce, field office and processing center managers, and leadership,
all the way to the top. Customer service and service delivery have been
at the forefront of their efforts during the pandemic.
We are fortunate to have SSA's head of operations, Ms. Grace Kim,
with us today. I am interested in her assessment of where SSA has been
during the pandemic, where things stand currently, and lessons learned
thus far to help inform the future.
From the beginning of the pandemic, field office management staff
have continued to physically go into offices to handle incoming and
outgoing mail, scan documents to support those working from home,
provide in-person service for critical need cases, and handle facility-
related duties. Ms. Peggy Murphy is also with us today, and I look
forward to hearing about her experiences and insights as a
representative of field office management.
I am also interested in the experiences and service-delivery
perspectives of our other two witnesses, Ms. McGuinness and Mr.
Causeya.
During the pandemic, it has been important to focus on at-risk
populations, including many on Supplemental Security Income, Disability
Insurance beneficiaries, and homeless beneficiaries.
I am interested in hearing today about service delivery to at-risk
beneficiaries and outreach. My understanding is that the Social
Security Administration has engaged in an unprecedented amount of
outreach to community organizations, beneficiary-advocate
organizations, and directly to at-risk beneficiaries themselves. I
commend the Social Security Administration's commitment and dedication
to ensure that beneficiaries receive service and benefits.
Commissioner Saul has stayed true to the focus on beneficiary
service that we all expected when he was confirmed, on a bipartisan
basis, by this committee and the full Senate. Solid leadership and a
dedicated workforce have been key to enabling the agency to confront
the service-delivery shock of the pandemic. Thus far, SSA has risen to
the challenge.
Thank you, Mr. Chairman.
______
Prepared Statement of Grace Kim, Deputy Commissioner
for Operations, Social Security Administration
Chairman Wyden, Ranking Member Crapo, and members of this
committee, I am Grace Kim, Deputy Commissioner for Operations. In my
current position, as a former Regional Commissioner, and as a career
employee with more than 30 years of service with the Social Security
Administration (SSA), I understand how vital SSA's programs and
services are to the public. Thank you for the opportunity to discuss
service delivery at SSA. Today, I will share some of our
accomplishments and challenges as we work to keep our employees and the
public safe while delivering vital services during the Coronavirus
(COVID-19) pandemic.
I am honored to lead a team of over 44,000 Federal employees
providing critical services across our vast network of over 1,200
community-based field offices, 24 teleservice centers (TSC), 8 regional
processing centers and our support offices across the country. I am
equally proud to oversee the work of the nearly 15,000 employees in the
State offices responsible for making medical determinations for Social
Security's disability programs. Our employees help millions of people,
often at significant and stressful points of their lives, like the
birth of a child, onset of a disability, retirement, or death of a
loved one. During this unprecedented time, I am inspired by their
resilience and dedication as we adapt our business processes to
continue to meet the needs of the people we serve, especially the most
vulnerable and those directly affected by the pandemic.
our agency
For more than 85 years, SSA has provided income protection for
retirees, individuals with disabilities, or for families that lose a
wage-earner. Almost 90 percent of seniors over the age of 65 receive
Social Security benefits. To provide context for our services during
the pandemic, I would like to highlight some of our pre-
pandemic service delivery measures. In fiscal year (FY) 2019, we paid
more than $1 trillion in benefits to over 70 million Social Security
beneficiaries and Supplemental Security Income (SSI) recipients;
assisted 43 million individuals in our
community-based field offices; processed 18 million applications for
SSN cards, 10 million of those in our field offices; handled 33 million
calls on our 800 number; processed 288 million annual earnings reports
in our processing centers; and conducted nearly 2.7 million non-medical
reviews (redeterminations and limited issues) and 713,000 full medical
continuing disability reviews (CDR) to ensure program stewardship.
Our field offices serve a critical role for individuals
experiencing homelessness, those with mental illness, people
transitioning between incarceration and temporary living arrangements,
and those in need of Federal, State, and local benefits, such as
housing support and temporary assistance for needy families. Our
programs are also a critical gateway to health care, including Medicare
and Medicaid.
overview: response to the pandemic
Since the beginning of this public health crisis, Commissioner
Saul's priority has been keeping our employees and the public we serve
safe. The people we serve--older individuals and people who have
serious health conditions--are also often vulnerable to the most
serious effects of COVID-19.
For this reason, in March 2020, we made the unprecedented decision
to direct employees to work from home and limit in-person services to
limited critical situations by appointment only, which allows us to
implement physical distancing and limit close contact. This decision
presented a significant change -- to quickly shift nearly all
operations to a remote work environment.
While prior to the pandemic less than 25 percent of our front-line
employees had experience teleworking, all employees had laptops that
enabled a rapid shift to remote work. We deployed hardware such as
headsets to answer calls on agency laptops, cell phones and Internet
hotspots, training, and technology support to our employees. Within a
few weeks, by early April 2020, we successfully redeployed over 90
percent of our Operations' employees to remote work. During this
period, all SSA offices continued to provide ongoing service to the
public by phone, with a small number of employees, most of them
managers, on site to handle non-portable work and critical in-office
interviews.
We worked as a team to overcome challenges. For example, our 800
number platform requires specialized equipment to enable agents to work
remotely. We had approximately 1,300 of these remote answering kits for
the 4,500 agents who serve the public in our TSCs, so we engineered a
solution that allowed 800 number calls to transfer to softphone
technology installed on the laptops of another 2,000 agents within 10
days and the remaining 1,200 agents within 30 days. As a result, we
were quickly able to reestablish our 800 number service and provide
millions of callers who need our services critical access to our
telephone agents. This softphone technology also allows employees in
our local offices to answer calls from the public as if they were in
the office.
In the State Disability Determination Services (DDS), the component
responsible for making medical determinations on our behalf, only two
sites initially possessed the experience and equipment to telework when
we moved to a remote work environment. However, within 10 days, we
established a virtual private network (VPN) solution to provide a
secure option for State DDS employees to work from home using their
desktop computers.
To communicate with the public, we have continued to update our
website, social media, and our Social Security Matters blog, featuring
posts about how to reach us, online services, and benefit programs. We
marketed our field office telephone lines, so the public could directly
reach employees in local offices by telephone. We posted signs in our
offices, messaging the availability of services online, by mail,
telephone, and limited in-office appointments. We are also working with
the White House Office of Faith-Based and Neighborhood Partnerships and
have entered into an unprecedented partnership with claimant advocates
and other organizations to promote our services and ensure they are
accessible to our most vulnerable populations.
supporting the public: emergency policies and actions
We understand the challenges that the public has faced during the
pandemic and we have been working hard to implement policies and engage
in activities that support the public during this difficult time. In
our field offices, we implemented emergency policy flexibilities and
initially limited services to concentrate on delivering mission-
critical workloads. For example, we expanded telephone attestation
procedures in place of requiring wet signatures; enhanced telephone
authentication procedures in place of in-person identity proofing;
extended time frames for the submission of evidence and appeals due to
mail delays or limited access to our offices; suspended policies that
adversely impacted beneficiaries, such as failure to cooperate and
failure to provide information; expanded our evidence policy to accept
secondary proof of identity for replacement SSN cards instead of
requiring primary evidence such as an original driver's license or U.S.
passport; promoted existing policies that enabled benefit continuation
throughout the administrative appeals process and expanded the ability
to sign and submit certain forms online; focused on key workloads
during the initial weeks of the pandemic, including disability claims
intake, payment for priority disability claims such as terminal
illness, Presumptive Disability, Quick Disability, Compassionate
Allowances, and Veterans Affairs permanent and total disability claims,
and other payments and reinstatement of benefits, such as adjudicating
claims allowances, reinstatements, and appeal awards; prioritized
Medicare enrollments and adjustments and SSI claims for those in need
of Medicaid to ensure ongoing access to health care for seniors,
individuals who have limited income and resources, and children with
disabilities; and limited in-person SSN replacement card services,
which can be completed by mail and online in most States using our
Internet SSN Replacement Card application.
At the same time, we temporarily deferred specific workloads to
protect beneficiaries' income and health care during a critical time in
the pandemic, including certain program integrity workloads and actions
that rely on evidence from the claimant, third parties, and medical
service providers. Given the uncertain duration of the pandemic and our
stewardship obligations, we resumed processing adverse actions in
September and October of 2020. We continue to apply maximum flexibility
when deciding whether to extend good cause provisions related to the
timely filing of applications as well as the submission of evidence,
appeals, hearings, redeterminations, and continuing disability reviews.
In addition, we continue to work with our Treasury partners to
ensure our beneficiaries get their economic impact payments (EIPs)
quickly. From the first round of EIPs, Commissioner Saul has pushed to
ensure our beneficiaries receive their payments automatically, and he
continues to reach out to vulnerable populations to ensure those who
qualify for payments for themselves or their dependents receive them.
To further help the public, we published an interim final rule to
streamline the overpayment waiver process for beneficiaries who
incurred overpayment debts between March and September 2020 due to our
deferral of certain workloads. Under the streamlined waiver process, we
can more quickly waive recovery upon receiving a verbal request for
qualified debts.
We also minimally increased the number of employees on site in our
field offices to support non-portable work and critical in-office
interviews that cannot be handled online, through the mail, or over the
phone. For the small number of employees and public in our offices, we
implemented health and safety protocols based on Centers for Disease
Control and Prevention (CDC) guidance and model safety principles.
Employees and visitors perform a self-screening for COVID-19 symptoms,
and masks and physical distancing have been, and continue to be,
mandatory. We provide masks and hand sanitizer for anyone entering our
facilities (employees, public, and contractors), provide gloves for
employees to use as desired such as for mail handling, and installed
protective barriers between the public and our employees in our field
offices.
online and virtual service delivery expansion
The pandemic has presented challenges for many organizations
including ours; however, it has also driven service delivery
innovation. Our workforce is strongly committed to serving the public,
as is evidenced by the employees who have volunteered to work on site
during the pandemic and by other employees working behind the scenes to
adapt business processes and push service improvements through. We are
a large organization with a nationwide footprint; yet, we have learned
that we are more nimble than we realized.
We are using external online video platforms to access our
customers virtually, expanding access to my Social Security online
services, and adding options for individuals to complete, sign and
submit certain forms online. We are also testing new business models
for handling in-person workloads and engaging in broad and targeted
outreach campaigns to reach vulnerable customers who are seeking our
services, such as elderly beneficiaries, children with disabilities,
and those with limited English proficiency. For example:
In April 2020, as unemployment nationwide spiked, we quickly
implemented an online process for handling Medicare Part B Supplemental
Medical Coverage (Form CMS-40B) applications for seniors suddenly
unemployed and without employer-sponsored health-care coverage. To
date, more than 350,000 seniors at risk of losing their employer-
sponsored health care have used our online and fax applications to
apply for Medicare Part B Supplemental Medical Insurance coverage.
We have continued to work with the States to expand the
availability of our Internet SSN replacement card application, and we
are testing an online video process that allows certain U.S. citizens
to apply for replacement cards remotely.
We launched an online video solution for hearings conducted in
our Office of Hearings Operations and for State Protection and Advocacy
grantees conducting payee-monitoring reviews.
We now accept electronic signatures on notices of Appointment
of Representative (Form SSA-1696), allowing claimants and their
representatives to submit the form electronically. We implemented an
online application for representatives and their clients to complete
the entire representative appointment process online.
We implemented an electronic transfer of non-medical paper
appeals from our field offices to the Office of Hearings Operations for
processing.
new in-person service delivery initiatives
Some workloads continue to require in-person appointments and the
inspection of original evidence. For these workloads, and for customers
who may not have access or would prefer not to use technology, we are
exploring several solutions. For example, we tested an evidence drop-
box option in 100 high-traffic enumeration offices, offering customers
a secure drop-off location for applications and original evidence
documents and will continue to use this service based on local office
needs. We tested an express interview process in 81 offices to limit
in-person transaction time to reduce the risk of exposure to COVID-19,
and are expanding this service option.
outreach to vulnerable populations
The pandemic continues to impose hardships on our country's most
vulnerable citizens, many of whom are elderly, have low incomes,
limited English proficiency, face homelessness, or suffer from mental
illness. We realize that these populations may rely on in-person
service, so we have made outreach to this population a priority during
the pandemic. We are monitoring our progress as we continue these
efforts.
To ensure awareness of and access to our benefit programs, we have
worked extremely closely with the advocate community for many months.
In fact, our collaboration with advocacy groups has been
unprecedented--both in scope of outreach and in our commitment to
ongoing dialogue. For example, we conducted a national outreach
campaign blanketing thousands of organizations with information. Many
of these organizations committed to broadcast our message, reaching
millions of people across the Nation. Likewise, we established two
advocate-executive workgroups, the Workgroup on COVID-19 Emergency
Response and Service Delivery Outreach and the Workgroup on SSI/SSDI
Administrative Simplifications and Evidence-Based Outreach, to address
outreach to vulnerable populations. Participants in these workgroups
include SSA executives and a diverse group of advocates with varying
missions and from numerous geographic locations who assist our
applicants and beneficiaries. It has been an honor to work together
with our partners in the advocacy community to reach the people we are
here to serve.
We have also enhanced our communications and online content
targeted to people who can help others file for benefits, resolve an
overpayment debt, or appeal a decision. We added online tools and
information pages to our website including a national advertising
campaign to support all outreach efforts on TV, radio, and social
media, with special emphasis on children with disabilities; a dedicated
webpage with resources for people helping others; outreach materials
for partner groups; and information for Faith-Based and Community
Groups including a new toolkit in collaboration with White House Office
of Faith-Based and Neighborhood Partnerships.
In March 2021, we hosted a national conference call with more than
1,500 attendees interested in learning more about how they can partner
with SSA to share information about our programs, assist in taking SSI
claims, or actively refer individuals potentially eligible for SSI to
our field offices. Participants included representatives of the non-
profit community, health-care organizations, private industry, Federal,
State, and local government, and Congress.
We are also conducting mailed outreach to individuals who may be
eligible for SSI. Between December 2020 and March 2021, we released
approximately 200,000 notices to current Social Security beneficiaries
who may be eligible for SSI, encouraging them to contact us to apply.
While this first effort focused on elderly and limited English
proficiency populations, we are planning to continue this type of
mailed outreach, by reaching out to other targeted groups in the
future.
workload challenges
While we have implemented flexibilities and workarounds, not all of
our work is portable. The ability for our employees to work virtually
rests on a small number of mostly managers and volunteers handling non-
portable workloads and in-person appointments. In the early days of the
pandemic, out of more than 27,000 field office employees, only 2,000
were on site daily. Over this past year, we have slowly increased on-
site staff to about 3,000 employees--most of whom are managers--which
represent about 10 percent of all field office employees. These
employees handle an ever-increasing volume of in-person appointments
each month in addition to all other non-portable workloads and their
managerial responsibilities.
Limiting visitors has also resulted in an influx of incoming mail
and phone calls. To illustrate the magnitude of this increase, before
the pandemic, field offices scanned and uploaded about 150,000 paper
documents weekly for processing. Offices are currently scanning and
uploading approximately one and a half million paper documents weekly.
In FY 2020, the unit time for the 47 million field office actions
increased by 20 percent in part due to scanning, copying, indexing, and
returning mailed documents, which significantly reduced our
productivity. Throughout the pandemic we have worked hard to reduce the
volume of mailed documents we receive by establishing paperless
workarounds, like accepting electronic signatures, creating electronic
forms, and marketing and expanding our online services, but we continue
to see increases in these non-portable workloads due to the nature of
our services.
Similarly, field offices are now handling three times as many phone
calls as they did pre-pandemic. We are on track to answer over 60
million calls in our field offices in FY 2021--up from 20 million calls
handled in FY 2019.
Further, many of the workarounds we had to put in place to enable
employees to work remotely are inefficient and erode productivity. For
example, when an individual mails to us inaccurate or unacceptable
evidence or incomplete forms, employees must make additional contacts
with the individual through mail or phone calls, requiring the employee
and individual to handle documents and evidence multiple times. It is
also harder to reach people when we need to re-contact them,
particularly more vulnerable populations, such as those people who may
have been forced to move during the pandemic and no longer receive mail
at their address of record. The pervasive nature of phone scams also
makes customers hesitant to take our phone calls. By comparison, before
the pandemic, our employees could frequently complete all or most of a
customer's business at the first point of contact, with minimal need
for additional re-contacts, and the ability to quickly obtain needed
documentation in our offices.
Obtaining evidence needed to adjudicate claims in both initial and
post-entitlement situations has also been challenging throughout the
pandemic. For example, at least 30 percent of all disability
applications require a consultative examination (CE) to determine
disability. The pandemic has made it more difficult for our customers
to schedule medical providers for routine appointments and access
public transportation to attend scheduled meetings. Some may also have
limited phone access for telehealth appointments. In addition, only
about 72 percent of our CE service providers nationwide are scheduling
in-person CEs. Scheduling CE appointments and obtaining evidence is
taking almost twice as long now, up from 21 days before the pandemic to
37 days during the pandemic. When the Department of Health and Human
Services temporarily modified the enforcement of the Privacy, Security,
and Breach Notification rules under the Health Insurance Portability
and Accountability Act (HIPAA), we expanded plans to use video
communication technology to offer CEs via telehealth appointment, but
we were constrained to only psychiatric and psychological examinations.
Additionally, organizations we depend on for other types of evidence,
such as schools, community and State advocates, and social service
agencies, are also experiencing their own challenges adapting to the
current environment.
All these challenges have strained our resources, particularly
given significant increases in costs that we do not control, such as
government-wide pay increases. Moreover, due to the pandemic, some
program integrity work, such as CDRs and SSI redeterminations, has
slowed, which also affects our funding. We deferred these workloads in
the early part of the pandemic to protect beneficiaries' income and
health care, and to reduce the burden on the medical community, which
had stopped most elective services. While we restarted these workloads
at the end of FY 2020, we are handling them through the mail and over
the phone. During the pandemic, these complex workloads often require
multiple contacts with a beneficiary, which slows our ability to
complete this work. In addition, over 30 percent of CDRs require a CE.
We have focused our limited CE capacity on initial disability claims to
ensure that we can provide benefits to people who qualify. As a result
of these pandemic-related challenges, including the need to prioritize
processing of initial disability claims in FY 2021, we reduced our
planned full medical CDRs by almost 30 percent, the lowest level since
FY 2013.
conclusion
Like much of the world, we have not escaped the challenges caused
by the pandemic.While we have made tremendous strides in quickly
enabling a remote work posture to keep everyone safe and continue
service during the pandemic, the last year has made clear that we have
more work to do. We have some workloads that are not portable or are
not as efficient to handle remotely, and we are working on solutions,
including getting input from our unions, employees, and managers.
Technology has proven vital and reminded us again that we must continue
to press forward on modernization even after the pandemic.
We are doing everything we can within our available resources, but
our current budget will challenge our recovery. The FY 2022 SSA
discretionary request of $14.2 billion, which is $1.3 billion more than
what we received this year to operate our agency, will strengthen our
service to the public. No one anticipated the duration of the pandemic
and the ongoing challenges it presents. We hope you will consider these
challenges and support this request to help us improve service.
I want to thank the public, our extraordinary employees, and you
for being patient and supportive of our mission during this national
emergency.
I look forward to answering any questions you may have.
______
Questions Submitted for the Record to Grace Kim
Questions Submitted by Hon. Ron Wyden
Question. As I mentioned in my statement, one of the problems
delivering first rate service is the requirement that people put their
most sensitive and important documents in the U.S. mail. I understand
some people are reluctant to do that and I understand why. Some people
just cannot go without their driver's license. If they do mail their
documents--it can take weeks to get the documents back. Tell me more
about what Social Security is doing to fix this clearly unacceptable
issue?
Answer. Please see our COVID-19 Pandemic SSN Service Delivery
Improvement Plan provided to the committee on May 13th.
Question. Do you agree with Ms. Murphy's testimony that a
``comprehensive remote printing initiative'' should be developed? If
so, what is the status of that initiative?
Answer. We agree that a remote printing capacity could improve our
efficiency and ability to operate during unforeseen events. The
pandemic has clearly highlighted this issue. We are currently pursuing
offsite vendor printing options through the Government Publishing
Office, and will keep you updated on our progress.
Question. What is the status of the on-line application for SSI?
Answer. We are converting the current SSI application into a
fillable PDF document that our third-party partners can use to help
individuals complete their applications.
We have a number of initiatives underway to expand service delivery
to individuals interested in applying for SSI.
In the near term, we are working on an online service to allow the
public to indicate their interest in filing for SSI benefits. This
service will establish a protective filing date \1\ and will provide a
lead to one of our technicians to schedule an appointment to complete
the SSI application. We are hoping to have this service live this
summer.
---------------------------------------------------------------------------
\1\ In general, SSA establishes a ``protective filing date'' on the
date SSA receives a written statement of intent to file for title II,
title VIII, or title XVI benefits or an oral inquiry about title XVI
benefits, https://secure.ssa.gov/apps10/poms.nsf/lnx/0200204010.
We are also expanding our telephone services so that an individual
interested in filing for SSI can use the automated interactive voice
response system to protect their intent to file for SSI at the earliest
possible date. We will give the individual the option to have us call
them back so they do not need to wait on hold. Our technicians can
---------------------------------------------------------------------------
assist in scheduling an appointment.
For more information on the SSI filing experience and our efforts
to improve the process, please see the attached Plan for Simplifying
the Supplemental Security Income Application (as requested by this
committee) that we sent under separate cover on May 27th.
Question. SSA has a work group to redesign the application process
for SSI, which I think everyone would agree is needed. Mr. Causeya
mentioned printing out the PDF for SSI--the form is 23 pages long!
That's pretty daunting, especially for someone who may be in a
challenging situation health and income wise. I want to highlight work
done by the State of Michigan that Ms. McGuinness referred to about
improving a 40-page application form: ``After an intensive user-
centered redesign that spanned almost 2 years, the process resulted in
a beautiful, streamlined application that was 80-percent shorter and
could be processed in nearly half the time.'' It seems to me the
Michigan case is one model SSA should study. Do you agree?
Answer. We are interested in studying successful efforts to
streamline applications for government benefits, and we agree to look
at the revamped Michigan application.
We would note that our application seeks a lot of information from
SSI applicants given the statutory requirements of the complex SSI
program. That said, as noted above, we have begun a number of
initiatives to make it easier for individuals to apply for SSI.
Question. In the Agency Financial Report for 2016 (Table 2.3--page
190), SSA ``developed a process for addressing all 80 items on the
original Potential Entitlement workload list and have defined
deliverables for each stage of that process.'' Please provide the
committee with the list of 80 items that were identified by the
dedicated Potential Entitlements workgroup.
Answer. The 2016 AFR referenced the attached list of potential
entitlements, which SSA created in 2013. Creating the list is part of
an ongoing effort to consider a range of input--including internal
quality review findings, audit findings, and recommendations from
external sources--to explore groups of people who might be eligible for
a new type of benefit or who might be due a higher benefit on a current
record. These situations of potential entitlement might be due to
changed circumstances over time or needed improvements in agency
processes.
Since that time, we have completed numerous Potential Entitlement
projects to date that have resulted in approximately 768,000 notices
released; 221,000 claims filed as a result of the notices; and $529.5
million in retroactive and total monthly benefit increases paid.
Question. In the most recent Agency Financial Report, SSA indicates
it will conduct outreach this year to 20,000 disabled workers whose
children were not awarded benefits because SSA did not properly close
out applications for the children. What is the status of this year's
outreach to these families? What were the errors that led to the
children missing benefits and what corrective action has been taken
since the error was discovered? What evidence is available to establish
that the corrective action has solved the problem?
Answer. We are in the process of data mining to identify the
universe of specific cases that meet the selected criteria.
There are numerous reasons why these claims may not have been
filed. In some cases, the agency may not have done sufficient follow-up
outreach to beneficiaries. In other cases, beneficiaries may not know
the whereabouts of the children, and SSA may not be able to locate
them. We must evaluate each case individually.
In 2016, we implemented enhancements to address this issue,
including:
Reminding technicians to address potential entitlement for
each listed child on the application.
Enhancing the diary function to control this workload.
Improving notice language on the beneficiary's award letter to
provide information regarding potential entitlement for the children
listed on the application.
Once we identify these cases, we will conduct outreach and take
claims as appropriate. We will also track outcomes and ensure that the
problem is no longer recurring based on the enhancements we have made.
Question. The 20,000 cases of missed child benefits appears to be
for 1 year's worth of applications. How many children in total does the
agency estimate have been affected prior to SSA's discovery of the
error? Does the agency have any plans to contact other disabled
families who did not receive benefits?
Answer. The 20,000 cases cover May 2011 through May 2016, when we
implemented improvements to prevent this situation from recurring.
Question. In the most recent Agency Financial Report, SSA indicates
it has postponed analysis to identify potential entitlements due
competing coronavirus (COVID-19) pandemic-related workload priorities.
Given that potential entitlements mean children, widows, veterans, low-
income Americans, and others may not be receiving benefits, this work
seems like it should be one of SSA's top priorities. Why was this work
postponed? What is needed to get this work done and to prevent any
future postponements?
Answer. We agree these initiatives are of great importance. We
temporarily postponed two potential entitlement initiatives in 2020 as
we focused on ensuring continuity of service during the COVID-19
pandemic. The two initiatives include outreach to approximately 3,000
retirement beneficiaries and 500 SSI recipients who may be due
additional benefits. In March 2021, we resumed work on these two
initiatives.
Additionally, recognizing the importance of reaching people facing
barriers, between December 2020 and March 2021, SSA mailed 200,000
notices to potential Social Security beneficiaries--individuals
receiving benefits less than the Federal benefit rate for SSI--to
encourage SSI filing. Because of this outreach, since December, SSA has
received 5,162 applications, approved 2,271 SSI applications, and paid
over $451,000 in underpayments. As noted in our attached May 7th
Supplemental Security Income Targeted Mailers Progress Report to the
committee on this initiative, we continue to review the results of this
mailing, and will begin mailing notices to the remaining population of
about 1.2 million Social Security beneficiaries potentially eligible
for SSI benefits.
Four additional potential entitlement projects are scheduled to
begin over the remainder of this Fiscal Year.
------------------------------------------------------------------------
Project Description
------------------------------------------------------------------------
Unreduced Aged Widow Claims with This project identifies claimants
Retroactive Aged Wife Entitlement who could be eligible for
retroactive benefits as a spouse
based on a current entitlement as
a survivor.
------------------------------------------------------------------------
Cases that have been awarded Social This project is to determine
Security/SSI benefits but have not whether claimants were determined
been paid to be eligible for benefits but
not yet paid.
------------------------------------------------------------------------
Individuals with Lawfully Admitted This project investigates claimants
Permanent Residence completed in who have Lawfully Admitted
our records yet payments withheld Permanent Residence status issue
pending citizen status completed on the MBR yet payments
are missing or not being paid.
------------------------------------------------------------------------
Child named on parent's application This project identifies if a child
was named on a parent's
application and no claims were
taken.
------------------------------------------------------------------------
The pandemic drove us to make hard choices. Going forward, we will
continue to balance our post-entitlement work with our other priority
workloads. The FY 2022 SSA discretionary request of $14.2 billion, an
$1.3 billion increase over FY 2021, will strengthen our service to the
public, including performing important potential entitlement work.
Question. SSA has policies to provide benefits quickly--such as
presumptive disability (PD) and compassionate allowance (CAL)--that
should be especially helpful during a pandemic.
Has there been an increase in the use of these policies?
Answer. Use of our expedited processes to adjudicate claims for
disability or SSI benefits has remained consistent.
Question. How does SSA measure the effectiveness of these policies?
Answer. We measure the effectiveness of our presumptive disability
(PD) policies by comparing the level of PD usage with the denial rate
of cases that received PD status. The effectiveness of the CAL policy
is measured by the overall processing time for cases identified as CAL.
Question. Are there plans to expand these policies, such as
presumptive disability for title II or CAL for applicants in hospice
care or the homeless with chronic mental disorders?
Answer. We continually evaluate new conditions to add to our CAL
process. From 2017 to 2020, SSA added 17 new CAL conditions, and are
evaluating additional potential conditions in FY21.
Presumptive disability (PD) benefits are authorized by statute only
for SSI benefits (42 U.S.C. 1383(a)(4)(B); we do not have authority to
offer PD benefits under Social Security Disability Insurance.
We are reviewing whether additional impairments should be
considered under our PD policy. However, hospice claims are generally
identified as terminal illness claims and, on average, processed faster
than presumptive disability findings.
Claims involving homelessness and chronic mental impairment do not
have a higher allowance rate; therefore, we do not make presumptive
disability findings for mental impairments, other than intellectual
disability or neurodevelopmental impairments meeting certain criteria.
Question. I'm very interested in Targeted Denial Reviews. I--
working with Senator Grassley--amended the FY 2020 Budget Resolution
during Budget Committee consideration to potentially allow SSA to use
program integrity funds to conduct Targeted Denial Reviews. Ideally,
SSA would review denied applications at a similar level to the
statutory requirements to review allowances. What are SSA's plans to
increase the use of Targeted Denial Reviews?
Answer. The Targeted Denial Review (TDR) is a discretionary
workload that uses a predictive model to identify disability
determination services (DDS) denials most likely to be reversed to
allowances. In the developing the predictive model, we considered
variables with a statistically significant correlation to decision
reversal. The current predictive model uses age of the applicant, the
type of application (title II or title XVI), the primary impairment
code, the secondary impairment code, and the regulation basis code of
the denial determination. The model scores each case on the likelihood
the initial denial would be reversed if that case were selected for
TDR. The highest scoring cases are selected for review, up to a
threshold set to meet the annual workload target.
We determine the volume of TDR cases we conduct in light of our
mandatory workloads (such as quality assurance and pre-effectuation
reviews), our available resources, and our other priorities. In FY
2020, we reviewed 36,786 TDR cases, with a reversal rate of
approximately 10 percent. We plan to review 25,000 cases in FY 2021 and
increase the review of TDRs to 75,000 cases in FY 2022.
Question. Overpayments often occur because earning reports from
beneficiaries are not processed timely. Many have described the
agency's overpayment waiver process as cumbersome and time-consuming.
What steps is SSA taking to improve the over payment waiver process?
Answer. To help the public during the pandemic, we published an
interim final rule to streamline the overpayment debt waiver process
for beneficiaries who incurred overpayment debts between March and
September 2020 due to our deferral of certain workloads. Under the
streamlined waiver process, we can more quickly waive recovery upon
receiving a verbal request for qualified debts.
Beyond the pandemic, we have been looking at ways to streamline and
improve the waiver process more broadly. Our focus has been on
modernizing the systems we use to manage debts, including how we
recover overpayment debt and the ways the public can request that we
waive recovery of debt. In addition to enhancing our systems, we are
evaluating ways to reduce administrative burdens for individuals who
request a waiver such as by exploring how we might improve our form.
Question. SSA strives to pay the right person, the right amount at
the right time to reduce improper payments. Both under payments and
over payments are improper payments. What policies are in place to
prevent or remedy underpayments and ensure that claimants and
beneficiaries receive all benefits to which they are eligible? How much
of SSA's program integrity spending is used to reduce underpayments and
ensure claimants and beneficiaries are receiving all eligible benefits?
Answer. We conduct annual stewardship reviews that identify and
quantify the amount of improper payments, both overpayments and
underpayments, in our programs, as well as the leading causes of error.
In addition, we conduct other targeted reviews of complex and therefore
error-prone workloads that may lead to the identification of improper
payments. We take corrective action whenever we identify an improper
payment.
We have policies in place to ensure that claimants and
beneficiaries receive all benefits to which they are eligible.
Post-adjudication, our systems detect most underpayments. For SSI,
during redeterminations, policy instructs technicians to consider
recipients' potential eligibility to other benefits. Employees are
required to explore any allegations or statements made by recipients or
their representative payees during the redetermination interview that
indicate potential entitlement to other benefits. We explore potential
eligibility for title II benefits and other benefits such as Federal
employment, military service, railroad, State or local government,
private employer, or foreign government.
We use dedicated program integrity (PI) funding to conduct
continuing disability reviews, SSI non-medical redeterminations, work
CDRs, and in support of our Cooperative Disability Investigation units
and Special Assistant U.S. Attorneys. The funding is used to ensure
beneficiaries and recipients continue to qualify for benefits and meet
program requirements. We do not capture the amount of PI funding spent
on cases with identified underpayments.
Question. I have heard reports that ALJ hearings involving paper
documents (in contrast to cases involving electronic files) have been
subject to great delay. Is this accurate? What steps has SSA taken to
ensure that claimants appealing ``paper cases'' get due process and
timely decisions on their case?
Answer. When hearing offices closed in March 2020 due to the COVID-
19 pandemic, SSA temporarily paused processing paper-based cases while
we worked through options to address this non-portable work. Since
then, we have implemented information technology enhancements that
improve our business processes for paper cases, which allowed us to
resume processing both disability and non-
disability paper cases in September 2020.
Question. As you know, Economic Impact Payments (EIP) are excluded
as a countable resource for SSI for 12 months after receipt. Yet the
committee has been informed by advocates that SSA has suspended SSI
benefits and assessed overpayments due to excess resources for months
when EIP have not been properly excluded for 12 months after receipt.
What steps has SSA taken to prevent these overpayments and suspensions
from occurring? Will SSA require each individual negatively impacted to
file an appeal?
Answer. In April 2020, we instructed technicians that EIPs are
excluded from income, and that any retained balances the month after
the month of receipt are excluded from resources for 12 months, as
these payments are considered advanced tax credits. Before the end of
the 12-month exclusion period, we issued guidance to hold any resource
decisions on EIPs until we issue new guidance, and we recently issued
our updated guidance about excluding payments from resources.
Question. I'm concerned about time between when a disability case
is approved and when the claimant receives monthly benefits. What data
does SSA collect and what goals does SSA have for the timeliness and
accuracy of effectuating disability benefits once a favorable decision
has been issued?
Answer. We have goals for overall processing time for initial
claims and for effectuating hearing level decisions. Our goal is to
process 95 percent of favorable hearing decisions within 60 days, with
most processed within 30 days. We are meeting our goals for
effectuating favorable decisions.
Question. How does the time to effectuation differ depending on if
the claim is SSI only, title II only, or concurrent?
Answer. The agency's FY 2021 goal for overall average processing
time for all initial disability claims (SSI, Social Security
Disability, and concurrent) is 171 days. Our overall average processing
time for initial claims through March 2021 is 166 days. Average overall
processing time to adjudicate initial SSI Blind and Disabled claims is
174 days through March 2021; average overall processing time to
adjudicate initial Social Security Disability claims is 157 days
through March 2021.
Question. Does SSA track payment of retroactive benefits separately
from starting ongoing benefits?
Answer. Yes, we do.
Question. Does SSA track whether benefits are properly withheld for
a representative fee?
Answer. Yes. As part of an every 3-year review of initial claim
awards and disallowances, we review claimant representative fees to
determine whether they were correctly withheld or not withheld, based
on the information in file at the time of claim adjudication.
Question. Does SSA track whether the authorized fee is paid to the
representative?
Answer. Yes. Our automated programs generate alerts in our
processing centers (PCs) to track payments to representatives. When we
withhold to pay fees from beneficiaries' retroactive benefits,
technicians receive alerts until corresponding representative fee
payments are resolved.
Question. Does SSA track cases separately depending on what stage
of the application process (initial, reconsideration, ALJ hearing,
Appeals Council) the award was made?
Answer. Yes, we track awards for each stage of the application
process. We are providing below two charts with data for each stage of
the application process. The first chart contains the average
processing time for FYTD through March 31, 2021 for initial claims and
reconsiderations. The second chart contains the average processing time
for FYTD through March 31, 2021 for ALJ hearings and Appeals Council
cases.
FYTD Through March 31, 2021
------------------------------------------------------------------------
Stage of Application Average Processing Time
------------------------------------------------------------------------
Initial Claims 166 days
------------------------------------------------------------------------
Reconsiderations 141 days
------------------------------------------------------------------------
ALJ Hearings 314 days
------------------------------------------------------------------------
Appeals Council 163 days
------------------------------------------------------------------------
Question. Are there specific types of cases that take especially
long to effectuate or where SSA's accuracy is especially low? What
steps is SSA taking to improve those cases?
Answer. We are not aware of specific types of disability claims
meeting that description.
Question. How does SSA's statistics on these issues during the
pandemic compare to the year before the pandemic? Looking back over the
last 10 years, what trends stand out?
Answer. Below are SSA's statistics on these issues with comparison
points from FY 2019, FY 2020, and FY 2021. We are compiling the data
over the last 10 years for trend analysis.
The overall average time for processing claims has steadily
increased throughout the pandemic. We ended FY 2019 at 120 days and at
the start of the pandemic, we were around 127 days. For FY 2019, the
overall average processing time was 126 days for SSI Blind and Disabled
claims and 115 days for Social Security Disability claims.
When the pandemic began in March 2020, the overall average
processing time was 134 days for SSI Blind and Disabled claims and 121
days for Social Security Disability claims.
FY 2019 to FYTD 2021 Through March 31, 2021
------------------------------------------------------------------------
Overall Average Overall Average
Overall Average Social Security SSI Blind/
Processing Time Disability Disabled
Fiscal Year for Initial Insurance Processing Time
Claims Processing Time for Initial
for Initial Claims Claims
------------------------------------------------------------------------
FYTD 2021 166 days 157 days 174 days
------------------------------------------------------------------------
FY 2020 132 days 126 days 139 days
------------------------------------------------------------------------
FY 2019 120 days 115 days 126 days
------------------------------------------------------------------------
Question. In preparing for this hearing, my staff attempted to find
an SSI application on the SSA website. My staff was not able to use the
website to find the application. It was only when my staff Googled
``SSI application PDF'' that this link was discovered--https://
www.ssa.gov/legislation/Attachment%20for%20SSA%20Testimo
ny%207_25_12%20Human%20Resources%20Sub%20Hearing.pdf--and from the
looks of that link, it looks like the document is related to a
congressional hearing. My staff asked advocates if this is a common
situation. Here are the replies that were received:
The advocates I know who work on applications know to Google
``SSA Form 8000'' in order to get a copy. When we complained
about the lack of access to the form, SSA said they have
declined to do it because it is not designed for the public--it
is too complex for the general public! . . . when completed and
submitted by third parties, SSA staff have to key in all the
information all over again anyway. SSA IT staff said this would
be the case even with a fillable PDF version. When a person
starts an SSDI application and indicates interest in SSI, there
is an instruction to file the SSI app separately but no actual
information, link, instruction, etc.
I have an SSI application in PDF form from years ago that I
still use. Or if we do an SSDI claim, in the remarks I say to
treat it also as an SSI claim.
Our sub-workgroup on the SSI application has repeatedly asked
SSA to make the PDF of an application form (there are two--Form
8000 and 8001) available on their website, and they say no. SSA
states that it is not a ``self-help'' form, i.e., not a form
that a member of the public can complete successfully on their
own . . . [advocates] know the number of the forms, and if you
google it, you can find a PDF of the form online and print it
off (the 8000 is 23 pages long), complete it with your client,
and mail or fax in that hard copy. Even though it is not
publicly available on their website, they still receive lots of
hard copies this way. . . .
. . . some people can file the SSI application online but only
if they are age 18-64, never married, never made another SSI or
title II claim, and not blind. So you can imagine that leaves
out a lot of claimants. . . .
What is going on here? Why is the SSI application form not easily
available on the SSA website?
Answer. For information on the SSI filing experience and our
efforts to improve the process, please see the Plan for Simplifying the
Supplemental Security Income Application provided to the committee on
May 27th.
______
Question Submitted by Hon. Maria Cantwell
broadband
Question. The COVID-19 pandemic has forced us to rethink
longstanding systems, including the delivery of Social Security
benefits. Over the past year, the Social Security Administration (SSA)
has worked to transition services to their online platform. While
accessing services online instead of in-person may be more convenient
for some, it is important to remember that millions of Americans around
the country still do not have access to reliable Internet and millions
more find it difficult to pay the monthly cost of broadband service.
Beneficiaries have been left to navigate the complex system of
applying for benefits and submitting appeals online, reduced assistance
from SSA due to the closure of field offices, and long wait times for
phone calls. I have heard from constituents who waited on hold for 5
hours to verify a document scanned and sent to SSA. We must work to
ensure that the SSA has the adequate technology to handle online
services and that more people in rural and underserved areas have
access to reliable, affordable broadband connections.
Moving forward beyond the pandemic, how will SSA determine which
components will remain online and which will be in-person? How could
expanded broadband help support SSA?
Answer. We provide multiple service channels for people to reach
us. Our goal is to provide effective online services because many
people prefer to do business that way. These self-service options then
free up resources for us to help people who cannot use them. During the
pandemic, we have further strengthened our outreach and partnership
with advocacy groups to improve access to our programs and services.
This partnership will inform future improvements to our service model.
Expanded broadband is an important tool that helps customers in rural
areas reach us.
______
Questions Submitted by Hon. Benjamin L. Cardin
Question. Will SSA commit to reestablishing meaningful labor-
management forums and actively participating in them?
Answer. We are fully committed to maintaining and fostering a
culture of compliance, civility, and compromise in all of our labor
relations. In 2021, we increased official union time for two of our
unions by thousands of hours, offered to renegotiate all collective
bargaining agreement articles with one of our unions, successfully
bargained mid-term agreements with all three unions, and engaged on a
variety of other workplace matters. These efforts will continue even as
we deal with the many challenges and pressures related to our pandemic
response.
Question. SSA has indicated it will follow Executive Order 14003
and reopen the collective bargaining agreement with AFGE, which was
bargained under directives from previous executive orders issued by the
last administration. When does SSA anticipate that process beginning
with the union?
Answer. We are in full compliance with Executive Order (EO) 14003,
``Protecting the Federal Workforce.'' EO 14003 does not require an
automatic reopening/
renegotiation of entire collective bargaining agreements (CBAs).
Rather, EO 14003 required agencies to identify select actions related
to the three rescinded EOs issued by President Trump in May 2018 and,
``as soon as practicable, suspend, revise, or rescind'' those actions.
We promptly conducted a review from January 25-28, 2021, identified
relevant actions taken pursuant to the three rescinded EOs from May
2018, and reviewed personnel policies as required.
On March 18, 2021, we expanded our review of the CBAs, in
accordance with OPM guidance issued on March 5, 2021. On April 23,
2021, we informed AFGE that we had completed the review required by EO
14003, and invited AFGE to meet to discuss the preliminary findings of
the review and to receive any additional input the union may have
before finalizing the results. On April 29, 2021, AFGE declined to meet
and requested that we provide preliminary findings in writing. We
provided these preliminary findings in a written format on May 19. We
will continue to engage AFGE on this topic in good faith and as
required by EO 14003. Once the findings of the review are finalized, we
will engage AFGE to suspend, revise, or rescind the actions covered in
identified CBA provisions.
Question. Will SSA commit to including bargaining for telework in
the bargaining for a new CBA?
Answer. We have offered to renegotiate all articles in the
collective bargaining agreement with the Association of Administrative
Law Judges (AALJ), including the telework article. We have not yet
determined whether we will seek to renegotiate either the SSA-AFGE
National Agreement or the SSA-NTEU National Agreement when the two
current agreements expire in 2025. We are currently assessing changes
to pre-pandemic telework plans. We will comply with all contractual and
statutory obligations related to any renegotiation when that time
comes.
Question. Legal services advocates in my State have raised concerns
over an uptick in the number of SSI applications denied due to failure
to cooperate, or FTC, since the start of the COVID-19 pandemic.
What is the process for contacting an applicant before denying a
case for this reason?
Answer. We work to prevent denying claims based on ``failure to
cooperate.'' For initial claims, our employees assist applicants and
pursue all leads before considering denying the claim. In some
situations, we may also provide a good cause exception to extend the
time requirement to provide us with the evidence. We instruct our
employees to contact the claimant directly (or third parties) to
provide assistance. We:
1. Issue a written request providing 30 days to respond and
provide the necessary information.
2. Send a reminder after 15 days to ensure the claimant knows we
have not received the information.
3. Contact the claimant by telephone making several attempts at
different times on different days. We also contact other sources, such
as relatives, friends, medical professionals, or community
organizations, to try to reach claimants and provide assistance.
4. Document our attempts before denying the claim.
Question. Do you agree that there has been an increase in the
number of cases denied for this reason nationwide in the last year? If
so, what factors do you believe drive this increase?
Answer. We agree there has been an increase in the raw number of
cases denied for failure to cooperate during 2021 as compared to 2020,
given that we are now processing adverse actions that we had deferred
processing during 2020. We have not, however, seen a significant change
in the rate of FTC denials during 2021 as compared to pre-pandemic
levels.
We recently conducted a quality review study to assess whether
State Disability Determination Service (DDS) employees were incorrectly
denying applicants for insufficient evidence or failure to cooperate
(FTC). A cadre of experts reviewed 450 randomly sampled cases and found
that DDSs generally followed emergency procedures. The cadre also
offered recommendations for improving outreach to identify and involve
third parties in cases that require special handling.
Question. What policy changes have you considered or are you
considering to ensure that field offices are taking every possible step
to avoid denying cases for this reason?
Answer. We have extended several policy flexibilities, including
allowing
pandemic-related issues to be good cause for late filing and providing
leniency with our failure to cooperate policies.
Question. The issuance of expedited disability allowance policies
for clearly eligible disabled individuals, like the presumptive
disability and compassionate allowance policies, has declined in recent
years.
Why does the agency believe that this decline has occurred?
Answer. Use of our expedited processes is consistent over the past
3 fiscal years (FY). For FYs 2018, 2019, and 2020 the CAL percentages
are 3.4 percent, 3.5 percent, and 3.5 percent respectively; and the PD
percentages are 3.7 percent, 3.6 percent, and 3.3 percent respectively.
Question. What programmatic responses has the agency considered or
is the agency considering to respond to this decline and to reduce
administrative burdens to accessing benefits for clearly eligible
disabled individuals?
Answer. We have not seen a meaningful decline in PD or CAL cases.
Question. Will SSA consider expanding the criteria for such
allowances, for example, to include those in hospice care and/or
homeless individuals with chronic mental health disorders?
Answer. SSA continually evaluates new conditions potentially to add
to our CAL process. From 2017 to 2020, we added 17 new CAL conditions.
PD benefits are authorized by statute only for SSI benefits (42
U.S.C. 1383(a)(4)(B); therefore, there are no plans at this time to
offer PD benefits under Social Security.
We are reviewing whether additional impairments should be
considered under our presumptive disability policy. However, hospice
claims are generally identified as terminal illness claims and on
average, processed faster than presumptive disability findings.
Claims involving homelessness and chronic mental impairment have
neither a medical denial rate that is well outside the national average
nor a higher allowance rate; therefore, we do not make presumptive
disability findings for mental impairments, other than intellectual
disability or neurodevelopmental impairments meeting certain criteria.
Question. The current system of reviewing disability eligibility
decisions places significant focus on reviewing allowances, while
denials do not receive the same level of scrutiny. As you know, the
system of Targeted Denial Reviews is discretionary and results in a
very small percentage of denials reviewed. A much higher percentage of
allowances are reviewed. This imbalance may improperly influence
adjudicators' decision making.
How does SSA plan to ensure greater parity between reviews of
denials and terminations of benefits and allowance reviews?
Answer. The Targeted Denial Review (TDR) is a discretionary
workload that uses a predictive model to identify disability
determination services (DDS) denials most likely to be reversed to
allowances. Our current target for FY 2022 is 75,000 cases.
Question. Reducing fraud and overpayments is important work. Just
as critical to program integrity is the prevention of wrongful denials
and erroneous terminations of benefits.
How does SSA plan to expand the scope of current program integrity
work to include not just improper overpayments, but improper
underpayments?
Answer. We conduct an annual stewardship review that identifies and
quantifies the amount of improper payments (overpayments and
underpayments) in our programs, as well as the leading causes of error.
In addition, we conduct other targeted reviews of error-prone workloads
that may lead to the identification of improper payments. We take
corrective action whenever we discover an improper payment.
Redeterminations of eligibility are an effective way to identify
changes that result in improper payments, as they can uncover
underpayment errors as well as overpayment errors. These
redeterminations are periodic reviews of non-medical eligibility
factors, such as income and resources, for the means-tested SSI program
and can result in a revision of the individual's benefit level. Also,
SSI recipients are more likely to initiate a redetermination of
eligibility if they believe there are underpayments. We anticipate
completing approximately 2.4 million redeterminations in FY 2021, and
2.9 million in FY 2022.
Question. As you know, Economic Impact Payments (EIPs) are supposed
to be excluded as a countable resource for SSI for 12 months after
receipt. We understand from advocates that SSA has already begun
suspending SSI benefits and charging recipients with overpayments due
to excess resources for months during which EIP payments have not been
properly excluded. SSA could obtain EIP data from the IRS that would
allow the agency to avoid generating these improper actions in the
first place without placing the onus on elderly and disabled
individuals to appeal suspensions during a pandemic. During the
hearing, you commented that SSA is currently considering how to handle
such cases and that you would be supportive of automatic re-instatement
of benefits ``in appropriate circumstances.''
Will you commit to effectively implementing this EIP resource
exclusion protection, as well as automatically reinstating benefits for
those who have been suspended improperly?
Answer. In April 2020, we instructed technicians that EIPs are
excluded from income and that any retained balances the month after the
month of receipt are excluded from resources for 12 months, as these
payments are considered advanced tax credits. Before the end of the 12-
month exclusion period, we issued guidance to hold any resource
decisions on EIPs until we issue new guidance. We recently issued new
guidance about excluding these payments from resources beyond 12
months.
______
Questions Submitted by Hon. Sherrod Brown
Question. Legal services advocates are reporting that their clients
are receiving Notice SSA-L8155-U2. Is the Social Security
Administration reducing, suspending, or terminating SSI benefits for
otherwise eligible beneficiaries as a result of them receiving any
Economic Impact Payment?
How many reductions, suspensions, or terminations have occurred as
a result of otherwise eligible beneficiaries receiving any Economic
Impact Payment?
How is the Social Security Administration determining whether
otherwise eligible beneficiaries who have resources in excess of the
statutory limit are over the resource limit due to the second and third
Economic Impact Payments, issued to SSI recipients in January 2021 and
April 2021?
If otherwise eligible beneficiaries who have resources in excess of
the statutory limit are over the resource limit due to the second and/
or third Economic Impact Payments, does the Social Security
Administration agree that eligible beneficiaries are facing SSI
reduction, suspension, or termination in error?
How do you plan to rectify this urgent problem, given that SSI
beneficiaries losing critical economic support is clearly contrary to
Congress's intent when authorizing relief through the EIPs?
Answer. We agree that ensuring SSI recipients have access to
economic support is critical and have worked make sure that SSI
recipients received their EIP payments automatically.
Under the Social Security Act, EIPs should be excluded from
resources for 12 months. We published additional policy guidance,
released supplemental training, and provided verbal reminders on
national, regional, and all manager calls about the need for employees
to carefully adjudicate all types of pandemic-related assistance
excludable under our rules, and in particular, the receipt of EIPs. We
recently released new guidance about excluding these payments from
resources beyond 12 months.
We do not have a specific count of reductions, suspensions, or
terminations that occurred as a result of EIPs received by SSI
recipients. However, we are reviewing SSI reductions, suspensions, and
terminations resulting from receipt of EIPs that individuals may have
held in their financial accounts. For these cases, we will determine
whether employees properly applied policy that excludes the EIP from
counting as a resource for 12 months. We will correct any errors, such
as by reinstating suspended benefits.
Question. In 2019, SSA's telework pilot ended. Before the COVID-19
pandemic, this meant the 12,000 affected workers were required to
return to their duty stations. After the end of telework pilot, and
before the beginning of the COVID-19 pandemic, what was Commissioner
Saul's official duty station and how often was he physically present
there?
Answer. The Commissioner's official duty station was SSA's
Washington, DC office. He also reported to the agency's headquarters in
Baltimore, MD.
______
Questions Submitted by Hon. Sheldon Whitehouse
Question. As you know, field office closures have disrupted how the
SSA delivers its services to beneficiaries.
Given the increasing number of Americans who have received COVID-19
vaccinations, does SSA have a timeline for when they expect to have
field offices open to the public?
Answer. We want to emphasize that throughout the pandemic, we have
been and remain open for business. Most SSA services are available
online and by telephone. We also provide in-person appointments for
limited, critical situations such as individuals without shelter who
have the need to apply for or reinstate benefits, or individuals who
need to update SSN information to obtain income, resources, or medical
care. Social Security continues to operate under our Workplace Safety
Plan (WSP),\2\ consistent with the President's executive order \3\ and
government-wide guidance.\4\ This WSP is currently being updated in
accordance with more recent government-wide instructions.\5\ We are in
the process of increasing on-site staffing, which should result in
service improvement. We are also engaged in post-implementation
bargaining of the WSP.
---------------------------------------------------------------------------
\2\ https://www.ssa.gov/coronavirus/assets/materials/ssa-covid-19-
workplace-safety-plan.pdf.
\3\ https://www.whitehouse.gov/briefing-room/presidential-actions/
2021/01/20/executive-order-protecting-the-federal-workforce-and-
requiring-mask-wearing/.
\4\ https://www.whitehouse.gov/wp-content/uploads/2021/01/M-21-
15.pdf.
\5\ https://www.whitehouse.gov/wp-content/uploads/2021/06/M-21-
25.pdf.
Question. What does the SSA need in order to ensure a safe and
---------------------------------------------------------------------------
productive environment for workers and the public?
Answer. We are following government-wide health guidance, our
workplace safety plan, and planning and preparing for a safe increased
return to physical workplaces as appropriate . We are also encouraging
employees to get vaccinated and allowing administrative time to do so.
Question. What are the metrics that you will use to determine when
a field office should be opened back up to the public? Would it be
based on COVID-19 infection and vaccination rates?
Answer. We will continue to follow government-wide guidance,
include health and safety guidance informed by science. In the interim,
we are increasing on-site staffing within our WSP, as noted in our
previous answer above.
Question. Social Security offices also provide the essential
service of assisting seniors with enrolling in Medicare and helping
individuals to decide which coverage is right for them. In addition, if
an individual doesn't enroll in Medicare when they first become
eligible, they can face financial penalties for the duration of the
time they are enrolled in the program. What affect has the closure of
Social Security offices had on your ability to help seniors enroll in
Medicare?
Answer. We are aware that because of pandemic-related job losses,
beneficiaries may have lost their employment-related medical coverage
and needed Medicare Part B Supplementary Medical Insurance coverage
through a special enrollment period (SEP).
Working in collaboration with the Centers for Medicare and Medicaid
Services (CMS), we initiated two new service delivery channels: fax and
online application options. Both of these options expedite the handling
of beneficiaries requesting enrollment in Medicare Part B under the SEP
provisions. The new service channels offer the beneficiaries the
ability to fax or submit online the forms CMS-40B, Application for
Enrollment in Medicare--Part B (Medical Insurance) and the CMS-L564,
Request for Employment Information applications for enrollment in
Medicare Part B.
As of May 3, 2021, we received and cleared 105,770 Medicare
enrollment requests from the fax option and processed 238,002
applications through the online application.
In addition, working with CMS during the onset of the pandemic, we
extended certain time frames for beneficiaries requesting enrollment in
Medicare. We also offered an extended equitable relief period to those
eligible individuals who could not submit a timely Medicare enrollment
due to the impact COVID pandemic-related national emergency had on
SSA's processing.
Question. Due to office closures, some applicants have had to
physically send in their personal documentation, like a driver's
license or passport, to verify their identity. I have heard from Rhode
Islanders concerned about this process, which is inefficient and opens
up applicants to a host of potential security issues if they are
without their identification.
Answer. Please see our COVID-19 Pandemic SSN Service Delivery
Improvement Plan, which outlines the steps we are taking now to reduce
or eliminate the need to mail original important documents.
Question. How can the SSA better coordinate with other Federal,
State, and local government agencies to improve security and
application processing?
Answer. Please see our COVID-19 Pandemic SSN Service Delivery
Improvement Plan for descriptions of our decades-long partnerships with
Federal and State governments to automate SSN service delivery and more
recently to provide an online application for certain replacement card
requests.
We continue to work to increase the scope of these service delivery
options. For example, we are working with the Department of Homeland
Security (DHS) to expand Enumeration Beyond Entry (EBE) to noncitizens
who DHS approves for lawful permanent residence (LPR) and naturalized
U.S. citizenship. Through EBE, DHS collects and verifies the
information we need to assign an SSN when approving the request for
work authorization. DHS then sends the information to us. We assign an
SSN and issue the card automatically. If the noncitizen already has an
SSN, we issue a replacement card. EBE is currently limited to
noncitizens whose work authorization DHS approves. Expanding it to
those granted LPR and naturalized status would automate the processing
of an estimated 1.3 million SSN requests a year.
We are also working to expand our online replacement card
application, known as Internet Social Security Number Replacement Cards
(iSSNRC). iSSNRC is available in all but six States--Minnesota, Nevada,
New Hampshire, Oklahoma, West Virginia, and Alaska.\6\ Expanding iSSNRC
to these States would affect approximately 5 percent of the population.
---------------------------------------------------------------------------
\6\ As of May 28, 2021, the State of Alaska decided to no longer
participate in the American Association of Motor Vehicle Administrators
(AAMVA) Driver's License Data Verification (DLDV) service. Therefore,
Alaska residents can no longer request a replacement card online. SSA
is working with AAMVA and the State of Alaska to identify a solution
for resuming their participation in iSSNRC.
Question. What recommendations do you have for Congress to address
---------------------------------------------------------------------------
this issue legislatively?
Answer. We appreciate the offer of support and will advise Congress
should we identify a need for legislative change.
______
Questions Submitted by Hon. Catherine Cortez Masto
Question. In your testimony you mentioned various flexibilities
that have been implemented to address the challenges brought on by the
pandemic and field office closures. Nevadans, like many others, are
experiencing long wait times on the phone or getting disconnected with
SSA representatives, drop boxes are only offered for a couple of hours
once a week or a couple of days, field offices are not offering in-
person appointments, and there's a lack of Spanish-speaking services
for them to assist with appeals. All of these limitations have further
delayed constituents getting their needs met. My office has also
received inquiries regarding foster youth facing issues requesting a
replacement card, as Nevada is one of five states that is not currently
participating in the program that allows for Social Security card
replacements to be done online. I appreciate SSA's work with the State
and DMV in Nevada in getting this program up and running, until this is
active, Nevadan's are still faced with mailing sensitive documents to
SSA. While my office was able to coordinate a temporary solution for
our foster youth facing this issue in Clark County, many Nevadans have
had to endure this procedure.
What has the Administration done to raise awareness of these
flexibilities among entities like legal aid organizations that help
clients navigate SSA benefits?
Answer. SSA is actively engaging external stakeholders to raise
awareness of service flexibilities during the COVID-19 pandemic.
Beginning over a year ago, agency leadership began holding recurring
meetings with national advocacy groups to share updates on service
changes and receive feedback on service challenges. Those meetings
evolved into two advocate-executive workgroups--one focused on solving
short-term challenges caused by the pandemic and another focused on
solving long-term challenges that pre-dated the pandemic.
Representatives of legal aid and other legal professional organizations
nationwide participate in both work groups.
In addition to providing suggestions for short- and long-term
service improvements, the advocate workgroup members have advised on,
and assisted with, disseminating emergency communications to the
public. For example, they suggested new topics for questions and
answers on the agency's COVID-19 website,\7\ including using certified
secondary identity documents, rather than primary identity documents,
for a replacement Social Security card. Advocate workgroup members also
provided critical input on new outreach resources that we launched for
anyone assisting a person with accessing our services and benefits,
such as our new Information for People Helping Others website.\8\
---------------------------------------------------------------------------
\7\ https://www.ssa.gov/coronavirus/.
\8\ https://www.ssa.gov/thirdparty/.
Other agency communications to the public on service flexibilities
during the COVID-19 pandemic have included: press releases; article
placements online and in print; email blasts; social media and blog
posts; search engine marketing; radio and television public service
announcements; mailers; and national conference calls on serving the
---------------------------------------------------------------------------
public during the COVID-19 pandemic.
Additionally, SSA has established the Interventional Cooperative
Agreement Program (ICAP) to provide a process through which we can
systematically review proposals from outside organizations and enter
into cooperative agreements with them for data sharing, funding, and
waivers. ICAP will prioritize research that examines the structural
barriers in the labor market, including for racial, ethnic, or other
underserved communities. We envision ICAP will help us leverage local,
external knowledge about potential interventions relevant to SSA
beneficiaries, especially those in underserved communities, so that we
can better serve our recipients.
Question. My office has heard that Nevada is working closely with
the Administration and is expected to start participating in the online
replacement card application. If this issue is addressed how will SSA
work with beneficiaries that were unable to submit their identification
to waive any potential delays or penalties?
Answer. We look forward to providing Nevadans with replacement
cards via our online iSSNRC process.
Question. If greater changes are to be implemented after the public
health emergency to streamline the process and delivery of services in
the administration, how do you plan to work with states to reduce the
potential for any delay in the use of a new process?
Answer. Working well with our State partners is integral to the
success of many service delivery enhancements we deploy. Providing
time, support, and clear communication has proven a useful model for
successful deployment of improvements in our processes and equipment.
Question. Does the Administration have a timeline as to when
District offices will reopen to the public once again?
Answer. We want to emphasize that throughout the pandemic, we have
been and remain open for business. Most SSA services are available
online and by telephone. We also provide in-person appointments for
limited, critical situations such as individuals without shelter who
have the need to apply for or reinstate benefits, or individuals who
need to update SSN information to obtain income, resources, or medical
care. Social Security continues to operate under our Workplace Safety
Plan (WSP),\9\ consistent with the President's executive order \10\ and
government-wide guidance.\11\ This WSP is currently being updated in
accordance with more recent government-wide instructions.\12\ We are in
the process of increasing on-site staffing, which should result in
service improvement. We are also engaged in post-implementation
bargaining of the WSP.
---------------------------------------------------------------------------
\9\ https://www.ssa.gov/coronavirus/assets/materials/ssa-covid-19-
workplace-safety-plan.pdf.
\10\ https://www.whitehouse.gov/briefing-room/presidential-actions/
2021/01/20/executive-order-protecting-the-federal-workforce-and-
requiring-mask-wearing/.
\11\ https://www.whitehouse.gov/wp-content/uploads/2021/01/M-21-
15.pdf.
\12\ https://www.whitehouse.gov/wp-content/uploads/2021/06/M-21-
25.pdf.
Question. Is it the intention of Social Security Administration to
resume in-person appeals hearings or offer both virtual and in person
---------------------------------------------------------------------------
at the beneficiaries' preference?
Answer. We do intend to resume in-person hearings, focusing first
on critical and aged cases for individuals who have declined telephone
or online video hearings during the COVID-19 pandemic. We plan to
continue offering telephone and online video hearings as voluntary
hearing options.
Question. With a lot of conversation around digitizing the process,
do you believe SSA will move to accepting e-signatures for the
appointment of personal representatives? Why has the agency expended
the resources to litigate this issue rather than move the agency to an
electronic format?
Answer. We currently accept electronic signatures for the
appointment of personal representatives. On March 8, 2021, we released
an electronic version of the Claimant's Appointment of Representative
form (e1696), which allows users to complete the form to appoint a
representative electronically, including electronic signing, via Adobe
Sign technology. The e1696 is the third release in a series, and is
located on our website, on the representative webpage at www.ssa.gov/
representation.
To complete the e1696, representatives can begin an electronic
password-protected submission of the form, and they and their clients
(claimants) can complete, sign, and submit the form to the agency
entirely electronically.
Question. What specific actions will SSA take to address the
serious backlog of cases and the drop in awards for people that are
disabled? How long does SSA anticipate this work will take?
Answer. Disruptions due to the pandemic caused a backlog of initial
disability cases. Between September 2019 and April 2021, the backlog
grew by approximately 115,000 cases. While applications for benefits
were lower than we projected prior to the pandemic, our pending level
of cases rose significantly because we were not able to complete as
many cases. It was difficult to complete disability cases due to a
reduced number of medical providers to conduct Consultative Exams, an
inability to reach individuals by phone, and a lag in receiving mailed
documents. These factors, along with the operating adjustments made to
safely serve the public, reduced our ability to complete our workloads
and contributed to increased backlogs and wait times.
We must work down this backlog while also handling an increase in
disability applications that we project to see in the second half of FY
2021 and in FY 2022. We received nearly 190,000 fewer applications in
FY 2020 than we expected. We expect many of these individuals to apply
for benefits as we emerge from the pandemic. During the pandemic, some
people may have been isolated from the community groups who would
normally assist them and provide them with information about our
programs. We are conducting outreach to reach these communities.
In FY 2021, we are replacing DDS staff losses and providing an
additional 1,300 hires to position the DDSs to address the disability
claims backlog and a potential spike in claims.
With the President's FY 2022 budget, we plan to maintain these new
hires in FY 2022 and fund increased overtime for a total FY 2022
increase of nearly 1,400 work years, or 10 percent, allowing us to
significantly increase our capacity to process disability claims.
Compared to FY 2020, we plan to complete nearly 300,000 more claims in
FY 2021 and over 700,000 more claims in FY 2022.
In FY 2016, we began implementing our Compassionate and Responsive
Service plan to reduce the backlog of hearings. With Congress's support
and the hard work of our employees, we have dramatically improved
service. From September 2017 through April 2021, we have reduced the
average monthly wait time for a hearing by 310 days. We expect to
eliminate the hearings backlog and reduce the average annual wait time
to 270 days by the end of FY 2022.
Question. What can Congress do to support SSA in addressing the
issues around service delivery that have been amplified by the
pandemic?
Answer. Congress can continue to assist us through your support of
the President's budget. Over the past year, technology has proven vital
and reminded us again that we must continue to press forward on IT
modernization even after the pandemic. The FY 2022 SSA discretionary
request of $14.2 billion, which is a $1.3 billion increase over FY 2021
enacted, will strengthen our service to the public.
______
Questions Submitted by Hon. Mike Crapo
Question. Some constituents have expressed concerns about providing
original documents, such as a driver's license, to SSA in order to gain
certain beneficiary services. For example, understandably, people are
apprehensive about sending a driver's license through the mail. I
understand, however, that SSA has responded to concerns in a number of
ways, including installation of more drop boxes. I wonder if you could
discuss how SSA is handling original or sensitive document processing.
Answer. Please see our COVID-19 Pandemic SSN Service Delivery
Improvement Plan, which outlines the steps we are taking now to reduce
or eliminate the need to mail important documents.
Question. Please briefly discuss telephone responsiveness at SSA
prior to the pandemic, during the pandemic, and where you think SSA
will be working to improve responsiveness.
Answer. Before the pandemic, we were improving telephone service on
SSA's national 800 number network. The average length of time it took a
caller to reach an agent was almost 24 minutes in fiscal year 2018 and
just over 20 minutes in fiscal year 2019. By February of 2020, the
average wait time had improved to 15 minutes. In addition, the
percentage of calls that could not reach an agent went from nearly 15
percent in fiscal year 2018 to 14 percent in fiscal year 2019 to 11
percent in February of 2020.
During the initial stage of the pandemic, the agency worked quickly
to enable 800 number agents to work remotely. Although the months of
March and April were challenging, by the end of 2020, the average time
it took callers to reach an agent was just over 16 minutes and the
percentage of calls unable to reach an agent due to all agents being
busy was 7.4 percent.
The average wait time through April 2021 is 16.9 minutes and the
agent busy rate is down to 0.3 percent. Moving forward post-pandemic,
we will focus on process efficiencies and more self-service
opportunities to reduce the wait time and keep the percentage of
unanswered calls low.
Question. Under the leadership of Commissioner Saul and Deputy
Commissioner Black, SSA has been remarkably transparent with Congress
about its responses to challenges generally, and those presented by the
pandemic in particular. SSA has provided briefings from senior
officials to staff of the Senate Finance Committee and House Ways and
Means Social Security Subcommittee on at least a weekly basis, and on a
daily basis during the onset of the pandemic. Between mid-March and the
date of our hearing, SSA officials have spent an estimated 2,600 hours
of SSA staff time to preparing for and executing 160 conference calls
with congressional staff of the Finance Committee and Ways and Mean
Social Security subcommittee, lasting roughly 105 hours in total. SSA
has also engaged in unprecedented outreach to community, faith-based,
and advocacy organizations with attention paid to service deliver for
``at risk'' populations. Please provide data and information on SSA's
outreach efforts to those populations during the pandemic.
Answer. We have prioritized ongoing communications with all our
external stakeholders during the COVID-19 pandemic, with a focus on at-
risk populations and those assisting them.
As we have discussed with you, during the pandemic we experienced a
reduction in applications for benefits, particularly Supplemental
Security Income (SSI) and Disability benefits, and we are concerned
that there may be a significant number of Americans facing barriers who
needed our help but were unable to reach us. Since the start of the
pandemic, we conducted more than 46,000 outreach activities.
In response, we are conducting community outreach to ensure that
people facing barriers and the most under-resourced communities,
including homeless individuals, children with disabilities, and those
with mental and intellectual disabilities can access our programs. We
are implementing strategies to address the complex challenges facing
underserved communities. We are working with the White House Office of
Faith-Based and Neighborhood Partnerships, claimant advocates, and
other organizations to ensure our services are accessible to those most
in need. We created a liaison position in our field offices to
complement the work of other regional employees in reaching out to
community based groups, asking them to help their constituents apply
for benefits. In March 2021, we enhanced our outreach to focus on
partnerships with groups that could help us reach at-risk populations.
Many of these organizations agreed to assist us by referring applicants
for SSI benefits and completing applications.
We created new public information products and implemented
additional outreach activities. For example, we launched our COVID-19
website with answers to common service questions; created a new
Information for People Helping Others website to assist anyone helping
another person access our services and benefits; published new outreach
toolkits for partners, including faith and community leaders; expanded
communication through print and social media, mailers, radio and
television advertising; established advocate-executive workgroups to
receive continuous feedback on short- and long-term service challenges;
and continued other agency communications to the public on service
flexibilities during the COVID-19 pandemic, including press releases,
article placements online and in print, email blasts, social media and
blog posts, search engine marketing, radio and television public
service announcements, mailers, and national conference calls on
serving the public during the COVID-19 pandemic.
We will continue to prioritize external engagement with all our
external stakeholders to ensure continuous service to the public, with
a particular focus on at-risk populations and the people serving them.
Please refer to the 2022 Congressional Justifications for
additional details regarding FY 2021 outreach efforts and planned
actions for FY 2022.
Question. It was asserted in the hearing that SSA's operating
budget is 12 percent smaller than it was a decade ago. Similar
assertions about double-digit declines in SSA's budget have been put
forward repeatedly in the past by groups outside of SSA, and are
typically subject to numerous qualifiers, such as: some notion of a
``core operating budget;'' crude ``inflation adjustments,'' and the
like. SSA identifies in its FY 2021 Congressional Justification that
its ``main administrative budget'' is the Limitation on Administrative
Expense (LAE) account. Please provide a time series of enacted LAE
amounts over the period 2000 through the most recently available
enacted data.
Answer. Below is a table with our Limitation on Administrative
Expenses history from 2000-2021.
------------------------------------------------------------------------
Limitation on Administrative Program Integrity
Year Expenses Appropriations \1\ Funding (dollars in
(dollars in millions) millions) \2\, \3\
------------------------------------------------------------------------
2000 $6,572.00 $605
------------------------------------------------------------------------
2001 $7,124.00 $650
------------------------------------------------------------------------
2002 $7,562.10 $633
------------------------------------------------------------------------
2003 $7,885.10 -
------------------------------------------------------------------------
2004 $8,313.20 -
------------------------------------------------------------------------
2005 $8,732.50 -
------------------------------------------------------------------------
2006 $9,108.60 -
------------------------------------------------------------------------
2007 $9,297.60 -
------------------------------------------------------------------------
2008 $9,744.60 -
------------------------------------------------------------------------
2009 $10,453.50 $504
------------------------------------------------------------------------
2010 $11,446.50 $758
------------------------------------------------------------------------
2011 $11,423.60 $756
------------------------------------------------------------------------
2012 $11,446.20 $756
------------------------------------------------------------------------
2013 $11,045.60 $743
------------------------------------------------------------------------
2014 $11,697.00 $1,197
------------------------------------------------------------------------
2015 $11,806.00 $1,396
------------------------------------------------------------------------
2016 $12,161.90 $1,426
------------------------------------------------------------------------
2017 $12,481.90 $1,819
------------------------------------------------------------------------
2018 $12,872.90 $1,735
------------------------------------------------------------------------
2019 $12,876.90 $1,683
------------------------------------------------------------------------
2020 $12,870.90 $1,582
------------------------------------------------------------------------
2021 $12,930.90 $1,575
------------------------------------------------------------------------
\1\ Total LAE includes funding for program integrity and user fees.
\2\ Program integrity is a subset of total LAE.
\3\ Congress did not authorize or appropriate dedicated funding for
program integrity workloads from FY 2003-2008.
Question. There were assertions made in late March that nearly 30
million Social Security and Supplemental Security Income beneficiaries
were awaiting economic impact payments because SSA had not sent payment
files to the IRS. Indications from SSA's Office of Inspector General
are that such an assertion, at best, ignores constraints, protocols,
legal and funding restrictions, and that attributing delays to SSA or
any of its officials is inaccurate. Please identify whether SSA
followed all requirements--legal, budgetary, and otherwise--in sharing
data to facilitate economic impact payments with IRS and/or the
Treasury Department generally, and whether any unnecessary delays were
introduced.
Answer. We followed all requirements--legal, budgetary, and
otherwise--to assist the IRS in its issuance of the third round of
Economic Impact Payments (EIP 3). The American Rescue Plan Act of 2021,
enacted March 11, 2021, authorized EIP 3, but did not provide direct
funding to SSA. We worked quickly with IRS to sign a Memorandum of
Understanding and Reimbursable Agreement (RA) by March 17, 2021, and
released the necessary files to support IRS on March 24 and 25.
The SSA Press Release,\13\ Statement from Andrew Saul, Commissioner
of Social Security About Economic Impact Payments, dated March 25, 2021
describes our work to assist IRS.
---------------------------------------------------------------------------
\13\ https://www.ssa.gov/news/press/releases/2021/#3-2021-4.
Question. It currently appears that the overwhelming majority of
SSA staff in the office presently are volunteers. Please identify how
SSA is able to find an adequate number of volunteers, and how the
agency has communicated with and safely brought in the very small
---------------------------------------------------------------------------
number of non-volunteers that have been needed.
Answer. We have had volunteers coming into our field offices since
the beginning of the pandemic. This small number of employees has
continued to be the backbone of our service, working on site to upload
paper documents so that their co-workers can work safely from home. In
July 2020, the agency instituted several health and safety policies in
compliance with CDC guidance. These policies included, but are not
limited to, mandatory face coverings, temporary barriers, physical
distancing restrictions, screening protocols for both employees and the
public, and cleaning protocols. We have shared and enforced these
policies down to the employee level, and remind on-site staff of safety
protocols. When we identify a workload need, local on-site managers
discuss with local union officials and solicit volunteers.
In the minority of instances where there are not sufficient
volunteers, we direct employees without underlying conditions or
dependent care responsibilities to rotate in office responsibilities.
This rotation could be 1-5 days per week, depending on the workload
need.
Question. Testimony for the hearing has addressed the importance of
fully funding SSA's program integrity activities. For FY 2022, the
President has requested $1.9 billion for these activities, marking a
$283 million increase over the FY 2021 enacted level. Please elaborate
on how program integrity activities ensure beneficiaries are well-
served and while safeguarding taxpayer resources.
Answer. We take seriously our responsibilities to ensure eligible
individuals receive the benefits to which they are entitled, and to
safeguard the integrity of benefit programs to better serve recipients.
We have a number of strategies in place to serve the public while also
protecting the public's tax dollars. Program integrity funding helps
ensure eligible individuals receive the benefits to which they are
entitled, and it safeguards the integrity of benefit programs to better
serve recipients by confirming eligibility and preventing fraud.
Dedicated program integrity funding helped us to eliminate the backlog
of CDRs in FY 2018. In addition, program integrity funding allows us to
conduct SSI redeterminations, expand the anti-fraud CDI program, and
support special attorneys for fraud prosecutions.
Due to the COVID-19 pandemic, we completed fewer full medical CDRs
and SSI redeterminations in FY 2020 than we have in recent years
because we temporarily deferred certain workloads during a critical
time in the pandemic, such as medical CDRs, so that we could prioritize
service to the public and maintain beneficiaries' payments and
healthcare. In addition, we initially implemented a moratorium on
scheduling in-person CEs to protect the safety of claimants and reduce
the burden on the medical community. We are working to restore our
program integrity workloads to our pre-pandemic levels and anticipate
eliminating the CDR backlog in 2023.
The budget includes $1.7 billion in dedicated funding for PI
activities, including a $1.4-billion allocation adjustment. This is a
$150-million decrease from the discretionary request for PI released on
April 9, 2021, and a $133-million increase over FY 2021. Our LAE
topline remains unchanged, and using PI carryover allows us to devote
more resources to improve frontline services while maintaining our
commitment to completing PI work. We are using $150 million of
unanticipated carryover from FY 2021 resulting from COVID-related
impacts to support the same level of PI activities in the discretionary
request.
The proposed funding is essential in providing the resources needed
to carry out associated activities that provide effective stewardship
of program dollars. Access to approximately $20 billion in
discretionary funding over 10 years, including approximately $17
billion in allocation adjustments, would produce $73 billion in gross
Federal savings ($54 billion from allocation adjustments), with net
deficit savings of approximately $37 billion in the 10-year window and
additional savings in the outyears (the budget excludes funding for the
now withdrawn proposed rule regarding increasing the number and
frequency of CDRs).
Full funding of CDRs and redeterminations will save billions of
taxpayer dollars. We estimate that CDRs conducted in FY 2022 will yield
net Federal program savings over the next 10 years of roughly $9 on
average per $1 budgeted for dedicated program integrity funding,
including OASDI, SSI, Medicare, and Medicaid effects. Our estimates
indicate that non-medical redeterminations conducted in FY 2020 will
yield a return on investment of about $3 on average of net Federal
program savings over 10 years per $1 budgeted for dedicated program
integrity funding, including SSI and Medicaid program effects.
______
Questions Submitted by Hon. Chuck Grassley
Question. Scam artists often use an emergency that disrupts normal
practices and procedures to their advantage. I've received a number of
reports from my constituents that they have received fraudulent phone
calls and letters claiming their benefits were in danger due to the
closure of Social Security offices. Could you speak to what types of
scams you have seen using the pandemic and recent changes in procedures
to prey on vulnerable seniors? Also, please, address what SSA is doing
to alert seniors of potential scams and how to avoid being defrauded.
Answer. We take reports of Social Security-related and government
imposter scams seriously, and we have continued to work closely with
our Office of Inspector General (OIG) to educate the public about the
potential scams during the pandemic.
On March 20, 2020, during the pandemic's initial stage, the OIG
issued a fraud advisory \14\ warning to alert the public that SSA will
not suspend or discontinue Social Security payments, or offer a benefit
increase, as a result of us suspending in-person service during the
pandemic. The advisory urged the public to be cautious of any
unsolicited calls, letters, emails, or texts offering a benefit
increase. To help spread the word, we posted the advisory to our
website and blog. We also worked with OIG to update its online scam
reporting form in May 2020. This update enabled OIG to begin monitoring
COVID-19 related scams. For the first half of this FY, OIG reports that
these scams represent only about 1 percent of the allegations they
receive.
---------------------------------------------------------------------------
\14\ https://oig.ssa.gov/newsroom/news-releases/march20-advisory.
We also keep our COVID-19 web page up-to-date with the latest scam
information, help publicize additional OIG fraud advisories, and
---------------------------------------------------------------------------
continue to increase our outreach efforts. A few examples include:
Publishing information on our COVID-19 web page \15\ alerting
the public to fraud and scam schemes and how to report them.
---------------------------------------------------------------------------
\15\ https://www.ssa.gov/coronavirus/.
---------------------------------------------------------------------------
Blogging frequently about scam awareness, new scam trends, and
OIG fraud advisories.
Adding ``scam alert'' messages to routine correspondence with
the public--to date that is over 274 million mailed envelopes.
The United States Postal Service displaying scam awareness
posters in over 30,000 Post Offices.
Collaborating with OIG to hold our second annual ``Slam the
Scam'' Day, which included a series of social media events and
partnerships with Walmart and CVS to help spread the word.
We appreciate the interest in this topic. Scammers create fear and
wreak havoc on their victims. They also potentially damage trust in
government programs. We would appreciate help in educating the public
and below are links to two fact sheets to share with your constituents:
Slam The Scam--Beware of Phone Scams (https://oig.ssa.gov/sites/
default/files/Beware%20of%20Phone%20Scams%20Infographic_0.pdf)
Protecting Personal Information (https://oig.ssa.gov/sites/default/
files/Protecting%20Personal%20Information_2.pdf)
Question. As life starts to return to normal, how are you going
about serving more people in your field offices? What is the strategy
for a full return to in-person services?
Answer. We want to emphasize that throughout the pandemic, we have
been and remain open for business. Most SSA services are available
online and by telephone. We also provide in-person appointments for
limited, critical situations such as individuals without shelter who
have the need to apply for or reinstate benefits, or individuals who
need to update SSN information to obtain income, resources, or medical
care. Social Security continues to operate under our Workplace Safety
Plan (WSP),\16\ consistent with the President's executive order \17\
and government-wide guidance.\18\ This WSP is currently being updated
in accordance with more recent government-wide instructions.\19\ We are
in the process of increasing on-site staffing, which should result in
service improvement. We are also engaged in post-implementation
bargaining of the WSP.
---------------------------------------------------------------------------
\16\ https://www.ssa.gov/coronavirus/assets/materials/ssa-covid-19-
workplace-safety-plan.pdf.
\17\ https://www.whitehouse.gov/briefing-room/presidential-actions/
2021/01/20/executive-order-protecting-the-federal-workforce-and-
requiring-mask-wearing/.
\18\ https://www.whitehouse.gov/wp-content/uploads/2021/01/M-21-
15.pdf.
\19\ https://www.whitehouse.gov/wp-content/uploads/2021/06/M-21-
25.pdf.
Question. During my time in the Senate, I have worked to combat
fraud in our Federal benefit programs, including Social Security.
Agencies play a crucial role in reducing the risk of fraud within their
own programs. In Fiscal Year 2019, the Social Security Administration
developed the disability fraud risk profile and completed two
additional fraud risk assessments focused on key electronic services
and administrative areas, such as payroll, contracts, and travel
purchase cards. You also finalized your Enterprise Fraud Risk
Management strategy. What were the key takeaways from these
assessments? What policies have you implemented or plan to implement as
---------------------------------------------------------------------------
a result of these assessments?
Answer. Our Enterprise Fraud Risk Management (EFRM) Program has
provided us with valuable insights into our major fraud risk areas and
created a thorough and strategic process to evaluate and address our
fraud risks. Some of our key takeaways from these assessments include:
1. We have already put many controls in place to prevent and
detect fraud, making the residual risk for the vast majority of our
risks either low or very low.
2. Developing a comprehensive and enterprise wide fraud risk
assessment process has helped enhance awareness and knowledge of fraud
risk management strategies across SSA, resulting in more proactive
consideration of fraud risks when program changes are considered.
3. Effective fraud risk assessments and management requires
collaboration and buy-in from all parts of the agency, and our EFRM
Program has done an excellent job in ensuring all key stakeholders
(Operations, Policy, Systems, etc.) are at the table in the development
of fraud risk assessments and in the planning of new mitigation
strategies to further reduce our fraud risks.
After we complete a fraud risk assessment, our senior leadership
reviews each risk identified and determines whether the current
controls reduce the residual risk to an acceptable level, or whether
certain risks need additional mitigation strategies. In response to our
Disability Fraud Risk Assessment, we identified 18 new mitigation
strategies to help further reduce specific risks, to include training,
expansion of our Cooperative Disability Investigation Units, and
enhancements to our OIG referral process. We have implemented 8 of
those 18 mitigations thus far and the remaining mitigations are on
track to be implemented by the established implementation dates.
We are also in the process of implementing mitigations to our
eServices Fraud Risk Assessment and are developing a mitigation plan in
response to our Representative Payee Fraud Risk Assessment. Our
mitigation strategies are both preventive and detective in nature, and
encompass a wide range of strategies to include strengthening our
digital identity procedures for online services, training for front
line staff, and conducting studies to determine the extent of potential
fraud in certain areas.
Question. A common concern I've heard from Iowans during the
pandemic is the requirement to mail in certain original documents,
including driver's licenses and certificates of citizenship, to apply
for benefits. One of my constituents has reported that when SSA mailed
her documents back, her daughter's certificate of citizenship was
missing. My staff is currently working with SSA to try and locate the
document for the constituent. Could you discuss how SSA is handling
original or sensitive document processing?
Answer. We take our duty to protect personally identifiable
information seriously and do our best to carefully handle evidence we
receive. Unfortunately, we know that errors happen, and we are working
to reduce and even eliminate the need to mail important documents. For
more information about our plans, please see our COVID-19 SSN Service
Delivery Improvement Plan.
When we become aware of missing or lost documents, we provide
reimbursement for the cost of the document and offer credit monitoring.
______
Question Submitted by Hon. Rob Portman
Question. During my questioning, I discussed how critical it is to
ensure that the Social Security trust funds remain solvent. Can you
discuss the human costs that would occur if we run into a situation
where we reached insolvency and the Social Security Administration were
forced to trim benefits?
Answer. The administration is committed to protecting and
strengthening Social Security. We understand how vital SSA's programs
and services are to the public. For more than 80 years, SSA has
provided income protection for retirees, individuals with disabilities,
or for families that lose a wage-earner. Almost 90 percent of seniors
over the age of 65 receive Social Security benefits. Our programs are
also a critical gateway to healthcare, including Medicare and Medicaid.
Under current law, the 2020 Social Security Trustees report
predicts that the combined trust funds will deplete their reserves in
2035, after which time Social Security will only be able pay
approximately 79 percent of scheduled benefits. While this does not
present near-term risks to either beneficiaries or the Nation's
finances, the President is committed to working with Congress to
address this important long-term challenge and ensure that this country
will always meet its commitments to seniors and people with
disabilities.
______
Questions Submitted by Hon. Todd Young
Question. Over the course of the pandemic, men and women of the
Social Security Administration (SSA) have worked tirelessly to serve
Hoosiers. Over the past year, my office has worked to secure over a
million dollars in benefits owed to Hoosiers. This was made possible in
no small part thanks to the tireless efforts of SSA employees.
Amid great uncertainty, the SSA rapidly adapted to a new mode of
work, going from an in-person service model to one almost entirely
telework-based within a matter of weeks. Of course, challenges still
persist, and I would like to explore further your thoughts on the past
year and the SSA's ability to adapt and meet future challenges.
Can you please briefly share one or two of the SSA's greatest
successes over the past year?
transitioning to work at home
Answer. In March 2020, to keep the public and our employees safe
and continue key services, we made the unprecedented decision to direct
employees to work from home and limit in-person services. This decision
presented a significant change--to quickly shift nearly all of
Operations 44,000 employees to a remote work environment. Before the
pandemic less than 25 percent of our front-line employees had
experience teleworking. We adapted procedures, provided training,
deployed hardware and software that enabled a rapid shift to remote
work. Within a few weeks, by early April 2020, we successfully
redeployed over 90 percent of our Operations' employees to remote work
and currently serve more than 90,000 in-office visitors each month. In
a normal year we answer around 20 million phone calls in our field
offices. A key shift was to channel the public online and to our
phones, including having the same employees who would have seen the
public in person in the office handle that work by phone. In FY 2020,
we answered 33 million phone calls in our field offices and we are on
track to answer 60 million phone calls in FY 2021. We also relied on
mail to accomplish some work, which increased our mail volume ten-fold
to 1.5 million items received each week. Finally, in April 2020, our
customers successfully completed 18.5 million online transactions with
us. One year later, in April 2021, our customers successfully completed
31.5 million online transactions, which is approximately 13 million
more than 2020.
reconstituting the national 800 number
We worked as a team to overcome challenges on our national 800
number. Our 800 number platform requires specialized equipment to
enable agents to work remotely. We had approximately 1,300 of these
remote answering kits for the 4,500 agents who serve the public in our
Teleservice Centers (TSCs), so we engineered a solution that allowed
800 number calls to transfer to softphone technology installed on the
laptops of another 2,000 agents within 10 days and the remaining 1,200
agents within 30 days. As a result, we were quickly able to reestablish
our 800 number service and provide millions of callers who need our
services critical access to our telephone agents.
Question. What are the SSA's most significant ongoing challenges,
and what is the SSA doing to address them?
Answer. Our most significant and ongoing challenges are handling
non-portable workloads and in-person appointments with a small number
of staff on site ranging from 7 to 9.5 percent of our overall field
office staff, which we are currently increasing to the maximum allowed
per our WSP. This cadre of on-site staff handles an ever-increasing
demand and must use systems not designed for that purpose to make non-
portable work like mail actionable for remote workers.
Workarounds including telephone appointments and mailed evidence in
lieu of in-person options have resulted in an influx of incoming mail
and phone calls. Before the pandemic, field offices scanned and
uploaded about 150,000 paper documents weekly for processing. Offices
are currently scanning and uploading 1.5 million paper documents
weekly.
Some of how we have operated during the pandemic is intended as
temporary workarounds to allow us to better serve our recipients.
However, these challenges are also opportunities to rethink the status
quo. We are breaking our processes down to better understand the
customer experience. For example, we realize that many office visits
happen because we need something (evidence) from someone but we do not
need to interview the person. Thus, we are considering how we can
safely and efficiently get the evidence we need without requiring a
person to come to or wait in an office. We have been expanding the use
of the appointment only process we have used during the pandemic, which
allows us to predict who is coming in for what reason and to staff
accordingly and to quickly serve the customer. We can also reduce the
time a customer must spend in our office for a SSN card by asking the
person to complete the application in advance of the appointment,
reducing time spent in the office. While we initially took this step to
limit close contact during the pandemic, it is an efficiency for us and
better service for the public.
Other steps we have taken include: in April 2020, as unemployment
nationwide spiked to unprecedented levels, we quickly implemented an
online process for handling Medicare Part B Supplemental Medical
Coverage (Form CMS-40B) applications for seniors suddenly unemployed
without employer-sponsored health-care coverage. To date, more than
300,000 seniors at risk of losing their employer-sponsored health care
have used our online and fax applications to apply for Medicare Part B
Supplemental Medical Insurance coverage.
We launched a video solution for hearings conducted in our Office
of Hearings Operations, and for use by State Protection and Advocacy
grantees conducting payee- monitoring reviews. In November 2020, we
tested the use of video to 100 of our high-volume SSN card sites to
process simple replacement cards for U.S. citizens using the same data
exchange we use to verify identity evidence for the online replacement
SSN card. We are interested in exploring how video might be a part of
our service delivery in the future.
We have also continued to work with the States to expand the
availability of our online SSN replacement card application during the
pandemic. This service, which is located behind our secure my Social
Security portal, allows adult U.S. citizens to apply for a no-change
replacement card using a data exchange with the American Association of
Motor Vehicle Administrators that electronically verifies the
individual's State ID or driver's license in real-time.
In our disability program, the greatest ongoing challenge involves
reducing pending workloads relates to scheduling and conducting
consultative examinations (CE). Some of the common CE challenges
reported by the State DDSs include the following: lack of available CE
providers within the State--nationally, 73.9-percent availability as of
April 23, 2021; and CE provider safety protocols in place due to COVID
concerns, and claimant reluctance to attend in-person CEs, and those
who opt out of telehealth appointments.
Question. As we all know, this pandemic has presented unique
hardships for Americans and has had a disproportionate impact on those
who were medically and economically vulnerable. From the onset,
Commissioner Andrew Saul and Deputy Commissioner David Black have shown
great leadership in their outreach to at-risk beneficiaries,
particularly homeless individuals and those that depend on Supplemental
Security Income, to ensure they have access to the resources they
desperately need.
In your opening testimony you outlined several steps the SSA has
taken to address this issue. Can you please speak to the impact you
have seen on these at-risk beneficiaries as a result of those efforts?
Answer. We have engaged with our partners in the advocate community
and are working to find new ways to reach people facing barriers. Since
June 2020, we have been engaging in a vast community-based outreach
campaign, blanketing communities with our message. That grassroots
campaign yielded thousands of organizations committing to broadcast our
message that our offices are reachable by phone to help people. This
campaign has reached millions of people across the Nation.
We have also enhanced our online resources dedicated to people
helping others to assist with inquiries like filing for benefits,
resolving an overpayment, or appealing a decision. In March, we
circulated a new toolkit we created for faith-based organizations, and
recently hosted a national session with more than 2,000 registered
attendees interested in learning more about how they can partner with
SSA to share information about our programs, assist in taking SSI
claims, or actively refer individuals potentially eligible for SSI to
our field offices.
We are also conducting mailed outreach to individuals who may be
eligible for SSI. Between December 2020 and March 2021, we released
approximately 200,000 notices to beneficiaries potentially eligible for
SSI benefits, encouraging them to contact us to apply. This effort,
which is the first of many, focused on elderly and limited English
proficiency populations. We are planning on continuing mailed outreach
later this summer and in FY 2022. For more information about this
effort, please see the report provided to the committee on May 7th.
More recently, we began a new initiative seeking the help of
organizations to assist people in their community access SSI benefits.
We continue to work with our partners to ensure we find and serve those
facing barriers during this challenging time.
Please refer to the 2022 Congressional Justifications for
additional details regarding FY 2021 outreach efforts and planned
actions for FY 2022.
Question. What metrics does the SSA use to track success in its
outreach efforts and, ultimately, service delivery?
Answer. We rely on feedback through a variety of sources to help us
gauge our success in outreach and service delivery. Our longstanding
relationship with advocacy groups continues to inform opportunities to
improve our services through valuable feedback. We also use other
mechanisms to solicit feedback from the public. For example, we use the
Foresee survey to inform level of satisfaction of our online services
and occasionally hire private contractors to conduct surveys directly
with the public for their opinions on our service.
Additionally, we strengthened our outreach communication to raise
awareness of our programs and how to access them. Since the beginning
of the pandemic, we have reached out to thousands of organizations to
help reach underserved individuals. We continue to monitor application
trends to help measure the success of our outreach efforts.
Question. How has the delivery of services to at-risk populations
shifted amid the pandemic protocols?
Answer. As discussed, reaching at-risk populations has been one of
the greatest challenges we currently face.
We are serving the majority of customers today by telephone,
online, and via mail. We continue to limit our in-person services to
certain critical situations by appointment only. The appointment-only
model is the best way to balance the safety of our staff and your
constituents with our mission of public service.
For individuals able to access the Internet, online services will
often be the easiest way to conduct business with us during this time.
Those people who cannot use our online services should call their local
office or use our national 800 number for assistance. For needs that we
cannot handle by phone, the local office can determine whether an in-
person appointment is needed or another option may be available.
Our office locator is available at https://secure.ssa.gov/ICON/
main.jsp. Constituents who are unable to use our online office locator
may call our national 800 number at 1-800-772-1213 and use the
automated prompts to obtain the phone number for their local office.
Question. What unique challenges have been presented when trying to
access vulnerable populations in urban areas as opposed to rural?
Answer. Based on our outreach efforts, it is clear that
homelessness and transiency pose significant barriers to being able to
reach and maintain contact with people. We also identified challenges
through some of the demonstration programs, such as travel time, lack
of local resources, and lack of high-speed Internet access.
Another of the greatest challenges we face accessing people with
barriers--whether in rural or urban areas--is identifying third-party
partners who can assist. Some organizations report they are interested
in working with us but have resource constraints, including staffing
and technology limitations. Other organizations interested in working
with us report their facilities are closed due to the COVID-19 pandemic
and they do not currently have access or contacts with those who are in
the greatest need. We appreciate how helpful our third-party partners
have been and understand how crucial they are to helping individuals.
Question. While the adaptations made to accommodate remote work in
the SSA have been impressive, we have all come to understand over the
last year the limitations of remote work. For example, I have heard
from a number of constituents who have been told by the SSA to send
original documents such as birth certificates or passports by mail.
While I understand that SSA policy has recently shifted to allow
secondary documentation to be used in place of a driver's license,
there is still concern about parting with these items for an indefinite
period of time.
Answer. To keep our visitors and employees safe during the
pandemic, we implemented temporary workarounds for some workloads. For
example, we agree that people need their important documents. As you
note, in February 2021, we instituted a temporary policy flexibility to
accept alternative forms of evidence of identity for replacement cards;
however, while this flexibility provides some relief, we are also
increasing service options to address SSN card requests, including
additional in-person express appointments. For more information about
our plans, please see our COVID-19 SSN Service Delivery Improvement
Plan, which balances safely improving service during the pandemic with
our obligation to protect the integrity of the SSN issuance
process.Through our plan, we will reduce or eliminate the need to mail
important documents.
Question. Is there an SSA policy in place regarding the maximum
amount of time these documents can be held?
Answer. No, although we strive to review and return documents as
quickly as possible. We are adding additional staffing to our offices
consistent with our Workplace Safety Plan to be able to expedite
handling mail. At the same time, we are expanding express appointments,
which do not rely on mailed evidence.
Question. How quickly are these documents being processed and
returned to the owner?
Answer. We have a goal of processing all mail within a 2-week
period. However, the amount of time to return documents varies based on
mail time and limited on-site staffing and may range from 4-8 weeks,
which we agree is too long. We are increasing staffing in our offices
consistent with the Workplace Safety Plan to respond timelier to mail
and reduce reliance on mail by expanding express appointments.
Question. Given the concern of documents getting lost or damaged in
the mail, does the SSA provide tracking information to the recipients
when returning the documents?
Answer. We generally return documents via USPS certified mail or
UPS. We receive tracking information that reduces the likelihood of
lost documents, but unfortunately, occasionally some documents are
lost. When we become aware of missing or lost documents, we provide
reimbursement for the cost of the document and offer credit monitoring.
Question. In addition to the concern about not having access to
these original documents, there is also a risk that documents could be
lost or damaged during the mailing process. I understand that field
offices have begun to set up secure drop boxes for members of the
public to safely submit this documentation.
Could you please share some information about the implementation of
these drop boxes, including a list of locations where operational drop
boxes can be found?
Answer. Our COVID-19 SSN Service Delivery Improvement Plan focuses
on adding express interview options so that individuals can keep their
important documents with them at all times. Moving forward, we expect
to reserve the drop box option for customers dropping off information
for initial claims, reconsiderations, hearings, and other workloads.
We tested drop boxes in 100 offices with the highest number of
critical, in-person appointments. After successful testing, we began
national implementation of drop boxes in mid-March 2021. We currently
have 376 offices providing this service and expect to have about 875
drop boxes in use in the near future.
We have submitted an attachment which contains the list of
locations where operational drop boxes can be found.
Question. How exactly do these secure systems work? Are individuals
able to submit as well as retrieve their original documents through
them?
Answer. Drop boxes are located securely within SSA offices, either
in a vestibule or reception area and within sight of security guards
and SSA management. Customers can drop off their documents during
office hours, and we return them via mail or UPS.
Question. As the Nation returns to normal and the SSA moves to
reopen its field offices and operation centers, it is worth examining
the investments and modifications made by the SSA in response to the
pandemic.
As Americans are vaccinated and the immediate threat of the
pandemic subsides, how is the SSA planning to reopen field offices for
in-person services?
Answer. We want to emphasize that throughout the pandemic, we have
been and remain open for business. Most SSA services are available
online and by telephone. We also provide in-person appointments for
limited, critical situations such as individuals without shelter who
have the need to apply for or reinstate benefits, or individuals who
need to update SSN information to obtain income, resources, or medical
care. Social Security continues to operate under our Workplace Safety
Plan (WSP),\20\ consistent with the President's executive order \21\
and government-wide guidance.\22\ This WSP is currently being updated
in accordance with more recent government-wide instructions.\23\ We are
in the process of increasing on-site staffing, which should result in
service improvement. We are also engaged in post-implementation
bargaining of the WSP.
---------------------------------------------------------------------------
\20\ https://www.ssa.gov/coronavirus/assets/materials/ssa-covid-19-
workplace-safety-plan.pdf.
\21\ https://www.whitehouse.gov/briefing-room/presidential-actions/
2021/01/20/executive-order-protecting-the-federal-workforce-and-
requiring-mask-wearing/.
\22\ https://www.whitehouse.gov/wp-content/uploads/2021/01/M-21-
15.pdf.
\23\ https://www.whitehouse.gov/wp-content/uploads/2021/06/M-21-
25.pdf.
Question. How do you envision the experiences of the past year
shaping the long-term management at the SSA? Are there any
modifications resulting from the pandemic that improved the SSA's
ability to fulfill its mission and should be adopted on a permanent
---------------------------------------------------------------------------
basis?
Answer. Much of the public has embraced phone, online, and video
services, which frees resources to focus on people facing barriers and
those who cannot use alternate service options.
We also plan to continue the use of drop boxes and express
interviews for customers.
______
COVID-19 Pandemic Social Security Number (SSN)
Service Delivery Improvement Plan
May 2021
Background
On April 29, 2021, the Senate Committee on Finance held a hearing
titled, ``Social Security During COVID: How the Pandemic Hampered
Access to Benefits and Strategies for Improving Service Delivery.''
During the hearing, Committee Members discussed concerns that
constituents who seek replacement Social Security cards need to mail
their evidence, including driver's licenses or passports. Chairman
Wyden asked us to submit a plan within two weeks for how we can improve
service by not requiring people, especially vulnerable populations, who
apply for Social Security Numbers (SSNs) and replacement cards to mail
important original documents to us.
Pre-Pandemic SSN Service Delivery
In Fiscal Year (FY) 2019, we processed about 17.5 million SSN requests,
including assigning about 5.5 million new SSNs (we refer to these as
``original SSNs'') and issuing about 12 million replacement SSN cards.
We have a number of decades-long partnerships with Federal and State
governments to automate the issuance of certain original and
replacement cards. Because we obtain the information we need directly
from government entities--the custodians of record for the physical
evidence we require--these partnerships ensure the security and
integrity of our SSN issuance processes, and eliminate the need for an
in-person visit to present original documentary evidence. The
individual simply asks the government agency to share their information
with us so that we can issue the number or card.
In 2015, we implemented a new online service, known as the Internet
Social Security Number Replacement Card (iSSNRC), to allow adult United
States (U.S.) citizens seeking certain replacement cards to apply
online through our my Social Security portal. Through iSSRNC, we
establish the identity of the applicant using information from
applicants' evidence--a State-issued driver's license (DL) or
identification (ID) card--and directly verifying the information with
the State's Department of Motor Vehicles. iSSNRC is available in 45
States.
In FY 2019, we issued about one-third of SSN cards through these
automated and online options.\1\ We processed the remaining 11.87
million in our field offices and card centers. Our COVID-19 Pandemic
SSN Service Delivery Improvement Plan focuses on SSN cards issued by
field offices.
---------------------------------------------------------------------------
\1\ To learn more about these automated and online services, as
well as our evidentiary requirements, please see the Appendix.
SSNs Processed in Field Offices and Card Centers in FY 2019
(in millions)
------------------------------------------------------------------------
Grand Total In-Office SSN Actions 11.87
------------------------------------------------------------------------
Original SSNs
------------------------------------------------------------------------
U.S. Citizens .16
Noncitizens .95
------------------------------------------------------------------------
Total 1.11
------------------------------------------------------------------------
Replacement SSNs
------------------------------------------------------------------------
U.S. Citizens 10.05
------------------------------------------------------------------------
No Change 5.95
Change 4.11
------------------------------------------------------------------------
Noncitizens .7
------------------------------------------------------------------------
No Change .42
Change .28
------------------------------------------------------------------------
Total 10.76
------------------------------------------------------------------------
Current SSN Service Delivery
To protect those we serve and our employees during the COVID-19
pandemic, we provide in-person service by appointment only for critical
services that we cannot handle online or over the phone. Accordingly,
we prioritized requests for in-person SSN services for individuals:
Age 12 or older applying for their first SSN card,\2\ or
---------------------------------------------------------------------------
\2\ Our longstanding regulations at 20 CFR Sec. 422.107 require in-
person interviews for these individuals.
---------------------------------------------------------------------------
Who need to update or correct their SSN information (such as
their name, date of birth, or citizenship) to obtain income, resources,
or medical care or coverage, or other services or benefits (for
example, filing a tax return, applying for housing, or seeking an
Economic Impact Payment).
U.S. citizens not eligible for in-person services may request
replacement cards online through iSSNRC, or mail the SSN card
application with original evidence.
We recognize people need their important documents, and in February
2021, we instituted a temporary policy flexibility to accept
alternative forms of evidence of identity for replacement cards.
Temporarily, U.S. citizens who mail a replacement card application are
not required to submit primary evidence of identity (i.e., State-issued
DL or ID card, or U.S. passport). Instead, applicants may mail
unexpired and valid secondary evidence (e.g., U.S. military dependent
identification card, Certificate of Naturalization, etc.), or other
evidence when secondary evidence is not available.\3\
---------------------------------------------------------------------------
\3\ https://secure.ssa.gov/poms.nsf/lnx/0110210420.
While this flexibility provides some relief, we are increasing service
options to address requests for SSN cards.
Service Delivery Moving Forward During the COVID-19 Pandemic
We will improve SSN service delivery during the pandemic for original
SSNs and replacement cards by ending the need to mail SSN applications
and evidence. Specifically, we will:
Direct eligible individuals to use iSSNRC because it is the
easiest and fastest option to obtain a replacement SSN card if the
individual is not seeking a change to our records.\4\
---------------------------------------------------------------------------
\4\ ``No change'' replacement cards are duplicate SSN card
requests. ``Change'' replacement cards are those where the applicant
requests a change to their SSN record, including a name, date of birth,
or citizenship status change.
Expand video service delivery to U.S. citizens and noncitizens
---------------------------------------------------------------------------
for replacement SSN cards if they are unable to use iSSNRC.
Expand in-person service delivery by appointment for original
and replacement SSN cards for individuals who we are unable to serve
online or via video.
We are starting to implement these service improvements now, within the
framework of our Workplace Safety Plan (WSP), which was approved in
accordance with Executive Order (EO) 13991, Protecting the Federal
Workforce, and M-21-15 COVID-19 Safe Federal Workplace: Agency Model
Safety Principles. To ensure we have capacity in our field offices and
card centers to help those who must visit us, we will direct customers
to online and video options first. Video options afford us flexibility
in meeting fluctuating demands for service across the country, provide
a convenient and secure option for the public, and allow an employee to
process an SSN application without geographic limitations.
We will incrementally increase our in-office staff within the WSP
guidelines to handle additional in-office appointments. We will monitor
the effect of our plan on reducing the need to mail applications and
evidence, evaluate customer feedback, and make adjustments as needed.
Details regarding in-person and video service delivery follow.
Microsoft (MS) Teams--U.S. Citizen ``No Change'' Replacement Cards
We will expand the use of MS Teams video interviews for replacement SSN
cards nationwide.\5\ MS Teams will be available to U.S. citizens
requesting ``no change'' replacement cards if they are unable to use
iSSNRC.
---------------------------------------------------------------------------
\5\ MS Teams requires a verification with the State DMV, just like
iSSNRC. Accordingly, MS Teams will not be available in the five States
that do not yet participate in iSSNRC.
Through MS Teams, individuals can securely apply from any location
using a computer, tablet, or smartphone with Internet service, and our
employees will conduct a remote video interview.\6\ We will send the
applicant a link to the MS Teams application; the applicant does not
need to download any software to participate in the interview. During
the interview, our employee asks knowledge-based questions, views the
individual's evidence--either a State-issued DL or ID card--and
verifies the information from the evidence directly with the State
Department of Motor Vehicles (DMV).
---------------------------------------------------------------------------
\6\ These devices must have a working camera capable of interacting
with MS Teams.
We will continue to engage with the union on these changes.
Video Service Delivery (VSD) Expansion--U.S. Citizen ``Change''
Replacement Cards; All Noncitizen Replacement Cards
We will expand our use of VSD to provide replacement card services to
U.S. citizens and test it for noncitizens. We will direct U.S. citizens
requesting ``no change'' replacement cards to iSSNRC or MS Teams first,
reserving VSD for U.S. citizens who do not have a State-issued DL or ID
card or who need to change information in our records, and for
noncitizen replacement SSN card requests.
Through VSD, an employee visually inspects the authenticity of evidence
of identity or immigration status, as well as evidence to support
requests for changes (e.g., marriage record for name changes, birth
certificates for date of birth changes). VSD offers high-resolution
magnification--1920 1080P, the resolution available on most High
Definition Televisions--and black light capability, allowing for in-
depth review of the security features and authenticity of the evidence
presented.
Applicants must visit one of our offices or a participating third-party
partner site to use VSD. We are adding software to our employees'
laptops so they can connect to the in-office VSD equipment from their
remote workstations.\7\ We currently have VSD units in approximately
half of our field offices, and in 97 third-party sites. We have begun
shipping an additional 170 VSD units to field offices with high volumes
of noncitizen SSN requests, with a focus on States that do not
currently have iSSNRC.
---------------------------------------------------------------------------
\7\ VSD is currently available to U.S. citizens requesting no-
change replacement SSN cards. However, the current capability requires
employees and applicants to be in our offices. Thus, this expansion
allows more applicants to use VSD and our employees to assist the
public remotely.
We will continue to engage with the union on these changes.
In-Person Express Appointments--Original SSN Requests and More, As
Needed
We will expand capacity at field offices and card centers to increase
the number of express in-person appointments we offer for individuals
we are unable to serve through iSSNRC and video appointments. When
scheduling these interviews, we ask the applicant to complete the paper
SSN application prior to their visit, and advise them of the evidence
documents they will need to bring. We have found that this model
minimizes the time spent in office to 5-7 minutes.
We will expand these appointments in accordance with the safety
measures in our WSP. We are iteratively increasing staff over the
coming weeks subject to WSP limits, as explained to Congressional staff
in a briefing on April 22, 2021.
Appendix:
SSN Eligibility Requirements
Section 205(c)(2)(B)(ii) of the Social Security Act requires that we
obtain evidence of age, identity, and citizenship or current work-
authorized immigration status from applicants for original SSNs.
Generally, newborns receive an original SSN through our automated
Enumeration at Birth program. Individuals (other than newborns) must
come into a field office or Social Security Card Center to apply for an
original SSN. We require an in-person interview for all original SSN
applicants age 12 or older. During the interview, we attempt to locate
a prior SSN to help ensure that we do not assign an SSN to an
individual assuming a false identity.
For replacement SSN cards, we require proof of identity from U.S.
citizens. For noncitizens, we require evidence of current immigration/
work authorization status as well. Individuals needing to update their
SSN record must present evidence to support the update--a marriage
certificate, divorce decree, or birth certificate, etc.
For noncitizen original SSN and replacement card requests, we verify
work authorization and immigration status directly with Department of
Homeland Security (DHS) via an electronic process called the Systematic
Alien Verification for Entitlements (SAVE) Program. If DHS does not
verify the applicant's status, we will not assign an SSN. Per our SAVE
agreement with DHS, we must visually inspect the original immigration/
work authorization document presented by the applicant.
These stringent policies comply with requirements enacted by Congress
in the Intelligence Reform and Terrorism Prevention Act of 2004 (Pub.
L. 108-485), which include:
Rigorous minimum standards for verification of documents
submitted in connection with an SSN;
Adding death and fraud indicators to SSN verification routines
for employers and for State agencies issuing driver's licenses and
identity cards; and,
Limiting individuals to 3 replacement SSN cards per year and 10
per lifetime (with limited exceptions).
Automated SSN Services
Enumeration at Birth
The Enumeration at Birth (EAB) program--established in 1987--allows
parents to obtain SSNs for their newborns as part of the birth
registration process. The evidence required to process an SSN
application is the same evidence gathered by hospitals and birthing
facilities and verified by bureaus of vital statistics (BVS) during the
birth registration process. Through EAB, BVSs electronically send us
the information we need; we assign the number and issue an original
card. Today, all 50 States plus Puerto Rico, New York City and the
District of Columbia participate. The vast majority of parents choose
to use EAB. In FY 2019, we assigned 3.8 million original SSNs through
EAB, which represents nearly 99 percent of original SSN cards for
children under the age of one.
Enumeration at Entry
The Enumeration at Entry (EAE) program--established in 2002--allows
lawful permanent residents to obtain SSNs as part of the immigrant visa
process. Once Department of State approves the visa, it transmits
identifying information from the visa application to DHS; DHS then
transmits to us the data we need when the person enters the country. We
assign the number and issue an original card. If the permanent resident
already has an SSN, we issue a replacement card. In FY 2019, we
assigned almost 213,000 SSNs and issued almost 17,000 replacement cards
through EAE.
Enumeration Beyond Entry
The Enumeration Beyond Entry (EBE) program--our newest automated
program, implemented in 2017--allows lawfully present noncitizens to
obtain an SSN when DHS provides them temporary work authorization. DHS
sends us the information it collected and verified when approving the
request for work authorization. We assign the number and issue an
original card. If the noncitizen already has an SSN, we issue a
replacement card. In FY 2019, we assigned about 350,000 SSNs and issued
almost 63,000 replacement cards through EBE.
Online Replacement SSN Card Service
Internet Social Security Number Replacement Cards (iSSNRC)--implemented
in 2015--allows U.S. citizens requesting ``no change'' replacement
cards to apply online through our partnerships with States' Departments
of Motor Vehicles. To mitigate the potential risk of eliminating face-
to-face interviews and in-person visual document inspections, iSSNRC
has built-in controls. For example, iSSNRC is behind the my Social
Security portal to take advantage of the portal's authentication
protocols. It also includes a verification of the DL and ID card
information submitted as proof of identity with the States' DMVs
through the American Association of Motor Vehicle Administrators.
iSSNRC is available in all but five States: Minnesota, Nevada, New
Hampshire, Oklahoma, and West Virginia. In FY 2019, we issued about 1.3
million replacement cards through iSSNRC.
______
Plan for Simplifying the Supplemental
Security Income Application
May 2021
Background
On April 29, 2021, the Senate Committee on Finance held a hearing
titled, ``Social Security During COVID: How the Pandemic Hampered
Access to Benefits and Strategies for Improving Service Delivery.''
During the hearing, Chairman Wyden asked us to submit within a month a
plan for how we can simplify the application for Supplemental Security
Income (SSI) benefits.
The Supplemental Security Income Program
Congress enacted the SSI program in 1972 to replace the varied Federal-
State programs of Old-Age Assistance, Aid to the Blind, and Aid to the
Permanently and Totally Disabled in the 50 States and the District of
Columbia. In 1974, the SSI program began paying benefits.
The program provides monthly benefits to people who are blind,
disabled, or at least age 65. The maximum monthly benefit amount in
2021 is $794 for individuals (about 75 percent of the Federal,
individual poverty line) and $1,191 for couples where both members are
eligible and either married or ``holding themselves out'' to their
community as being married.
About 8 million people currently receive monthly Federal SSI benefits.
The States can--and in some cases must--provide supplemental benefits
to residents who are eligible for SSI. In 12 States, we determine on
behalf of the State whether SSI beneficiaries are eligible and pay the
appropriate amount of the State supplement, using the criteria set
forth in an agreement we reach with that State.
The law requires us to determine a person's eligibility for SSI
benefits every month, using information verified from independent and
collateral sources. This includes not only accounting for all of the
income and resources that the beneficiary or applicant has or can
access, but also accounting for the income and resources of spouses
(from either a legal marriage or holding-out relationship, as mentioned
above), parents (of child beneficiaries under 18), and sponsors (of
certain noncitizen beneficiaries) who live in the household.\1\
---------------------------------------------------------------------------
\1\ We are also required to consider the income and resources of a
sponsor even if the sponsor doesn't live with the beneficiary.
Eligibility for and the amount of SSI benefits depend on a person's
countable income. The Social Security Act defines income broadly and
requires us to count more than 20 types of income, such as wages, self-
employment, and pensions, as well as support and maintenance provided
``in-kind,'' which can include the provision of food or payment of all
---------------------------------------------------------------------------
or some of a person's household expenses.
The law distinguishes between income that is ``earned'' and income that
is ``unearned,'' and applies different basic exclusions to each type;
we exclude up to $20 of a person's unearned income. If a person has
less than $20 in unearned income, we apply the remainder of this
exclusion to their earned income. We then exclude $65 plus one-half of
the remainder of earned income.
The Social Security Act and other Federal laws further exclude from
counting some or all of over 86 other types of income, including
assistance based on need, advance refundable tax credits, disaster
assistance, earned income of students of a certain age, certain
payments for participation in clinical trials, various payments Tribes
provide their members, and payments in reparation for Nazi genocide or
certain eugenics programs. Please see the Appendix for a list of these
exclusions.
Eligibility also depends on a person's countable resources. The Social
Security Act allows someone to own up to $2,000 in resources and a
couple to own up to $3,000 in resources; when resources equal or exceed
these limits, the person or couple are ineligible for SSI.
The Social Security Act also provides specific procedures for
evaluating certain resources, such as a home, burial expenses, the cash
surrender value of life insurance, and trusts. The Social Security Act
and Federal law further exclude some or all of the value of dozens of
other types of resources, some indefinitely and others for only a
certain period. Finally, the law requires us to consider a person's
resources for the 3-year period before he or she filed for SSI in order
to determine whether the applicant sold or disposed of any assets for
less than fair market value, which can result in a period of
ineligibility for SSI. The Appendix also has a list of the SSI resource
exclusions.
In addition to income and resources, the law requires us to consider a
host of other factors in determining whether a person is eligible and
the amount of benefits he or she will receive. People who reside in a
hospital operated by a State are not eligible, whereas those who reside
in a private hospital are eligible, although their monthly benefit may
be capped at $30 per month if Medical Assistance is paying a
substantial portion of their care. Individuals are not eligible for SSI
benefits if they fail to apply for other benefits for which they may be
eligible, are fleeing to avoid prosecution or confinement for a felony,
or are violating a condition of probation or parole. Individuals who
reside outside the United States are not eligible,\2\ but students or
the children of American service members temporarily abroad remain
eligible.
---------------------------------------------------------------------------
\2\ Residents of the Commonwealth of the Northern Mariana Islands
are eligible for SSI. However, residents of Guam, American Samoa, the
Commonwealth of Puerto Rico, or the U.S. Virgin Islands are not
eligible.
The rules concerning eligibility for people who are noncitizens are
particularly complex, requiring us to, for example, evaluate a person's
current immigration status and prior statuses and when they were
attained, as well as the person's work history and in some cases the
work history of a parent or spouse. The additional factors that apply
only to people who are noncitizens determine whether the person must
serve a waiting period before receiving SSI, whether the person can be
eligible for SSI immediately and indefinitely, and whether the person's
eligibility will be limited to seven years from first obtaining a
qualifying immigration status.
Plan for Simplifying the SSI Application
Commissioner Saul has made improving the administration of the SSI
program a top priority for SSA. We appreciate the Committee's interest
in this topic. Paper applications are long and detailed, which make
them challenging for many people to complete on their own. Although the
applications are used to gather the information needed to decide
whether someone is eligible for this complex program,\3\ we generally
do not expect people to complete the applications on their own. When
someone applies for SSI, we do not require them to complete the paper
forms. Rather, we interview the applicant, and that conversation allows
us to explain the questions and the program rules and answer any
questions.
---------------------------------------------------------------------------
\3\ When we refer to ``applications'' in this plan, we mean the
SSA-8000, the ``full'' SSI application that includes all questions, and
the SSA-8001, a shorter application we use when we defer asking some
questions and development until after we've decided whether the
applicant is disabled.
The COVID-19 pandemic has underscored the need for more simple SSI
applications. Simpler applications would make it easier for
organizations to help us reach people who have been unable to
participate in the traditional interview. In the longer term, simpler
applications will facilitate the development of an online application
---------------------------------------------------------------------------
for SSI.
Outlined below is our plan to simplify the SSI applications, as well as
other efforts to improve the overall application process, including
plans to use our existing authority to administratively simplify the
program rules.
As we proceed, we must balance the need for simplification with our
obligations to be good stewards of taxpayer funds and to provide timely
and efficient service to everyone who needs our help. We must ensure
that the simplified applications continue to collect the level of
information needed for us to accurately determine eligibility for this
complex program. Furthermore, the simplified applications must continue
to allow us to determine early in the application process whether a
person is ineligible for benefits. This ensures that we provide good
service and a timely decision on such applications. It also conserves
the resources of the Disability Determination Services--which perform
the critical function of determining whether people meet the program's
disability standards--by reducing the likelihood that we forward to
them an application from someone who is ineligible for SSI based on
other factors.
Creating a Fillable, PDF Version of the Application for SSI (SSA-8000-
BK) (by May 2021)
We have enlisted the aid of national and community-based advocates and
organizations to help us ensure that vulnerable people across the
country can continue to access our programs during the pandemic. We
have trained these groups on how they can help someone complete an SSI
application. To help these organizations help people apply for SSI, we
are creating a fillable PDF application. This meaningful step will make
it easier for these trusted partners to complete the form. After the
applicant signs the application, our partners will fax it to us.
We plan to make this version available by the end of May 2021.
Streamlining the Applications for Supplemental Security Income
(Recommendations by the End of September 2021)
We are reviewing the applications and are developing recommendations on
ways to simplify them further while still ensuring we capture the
information needed. We expect to have these recommendations by the end
of September 2021.
After internal review and revision of the applications is complete, we
will request feedback from advocates and stakeholders on the draft,
revised applications. We will test the revised applications to ensure
that the public can understand and successfully complete them. And any
new applications will ultimately require approval by the Office of
Management and Budget. We will keep the Committee apprised of our
progress as we finalize the recommendations and determine
implementation dates.
Implementing Online and Automated Telephone Protective Filing Services
(by the End of September 2021)
We will also implement an online and automated telephone service to
allow the public to record their interest in filing for SSI. Although
this will not be an application, this service will provide the
important function of allowing a person to establish a ``protective
filing date,'' which ensures that benefits are not lost when an
application cannot be immediately filed (SSI benefits can be paid no
earlier than the month of filing). When someone uses this service, we
will contact them to obtain the actual application.
We plan to implement these services by the end of September 2021.
Updating Our Claims Systems and Implementing an Online, SSI-only
Application (by November 2023)
Once we have revised the SSI applications, we will make any necessary
corresponding updates to the software our technicians use to take
applications. We will also use the simplified forms as the basis for
developing and implementing an online, SSI-only application that can be
used by many people to apply for benefits. Since April 2017, we have
allowed people who meet certain criteria to file an SSI application
when they also file online for Social Security Disability Insurance
Benefits (DIB). However, that option is not available to everyone and
it collects only the bare minimum of information needed to start an SSI
application. By November 2023, we plan to implement a more robust
online application, for use when a person is only eligible for SSI or
for people who are 65 and older.
Administrative Simplifications (by the end of Fiscal Year 2022)
In addition to our efforts improve the applications, we intend to make
the following improvements to SSI policies under our existing
authority.
Rules Regarding In-Kind Support and Maintenance (ISM)
In 2005, we revised our rules to stop counting the value of clothing
given to SSI recipients as in- kind support and maintenance. We will
explore what other similar changes to our rules we might make.
Increase the $5 Sharing Tolerance to $20
When figuring whether a beneficiary pays for his or her pro rata share
of the household expenses (a step in determining whether a beneficiary
is receiving in-kind support and maintenance), we consider
beneficiaries to be paying their share when they contribute within $5
of the actual, pro rata amount. We intend to increase this tolerance to
$20.
Streamline Process for Temporarily Institutionalized (TI) Individuals
Beneficiaries can remain eligible for up to the full amount of SSI
benefits for the first 90 days in which they reside in an institution,
provided they request they need the benefits to pay the expenses of the
household they intend to return to and an attending physician certifies
that the person's stay is expected to be 90 days or less. We intend to
improve the process by creating a standard form to collect this
information from a physician. We also intend to develop a demonstration
project to assess the effect of automatically providing these temporary
benefits in the first 90 days without requiring the person to
demonstrate their need to maintain household expenses or provide the
physician's certification.
Appendix--Current Program Exclusions
Earned Income Exclusions
Any refund of Federal income taxes received under section 32 of
the Internal Revenue Code (relating to earned income tax credit (EITC))
and any payment received under section 3507 of the Internal Revenue
Code (relating to advance payment of EITC);
Amounts received pursuant to the Making Work Pay tax credit set
forth in the American Recovery and Reinvestment Act of 2009;
Any refundable child tax credit;
The first $30 of earned income in a quarter if it is infrequent
or irregular, that is: (1) if it is received only once in a calendar
quarter from a single source and is not also received in the month
immediately preceding or the month immediately following the month of
receipt regardless of whether or not these payments occur in different
calendar quarters; or (2) if its receipt cannot reasonably be expected;
Up to $1,930 per month but not more than $7,770 in a calendar
year received by a blind or disabled recipient who is a working student
under age 22 and regularly attending school;
Any portion of the monthly $20 exclusion not used to exclude
unearned income;
$65 of earned income in a month;
Amounts used to pay impairment-related work expenses if a
recipient is disabled (but not blind) and under age 65 or is disabled
(but not blind) and receiving SSI (or disability payments under a
former State plan) before age 65;
One-half of remaining earned income in a month;
Earned income used to meet any expenses reasonably attributable
to the earning of the income if the recipient is blind and under age 65
or if he or she received SSI as a blind person prior to age 65;
Any earned income received and used to fulfill an approved plan
to achieve self-support if the recipient is blind or disabled and under
age 65 or is blind or disabled and received SSI as a blind or disabled
individual in the month before he or she attained age 65;
Cash or in-kind income provided under an AmeriCorps program;
Any earned income deposited into either a Temporary Assistance
for Needy Families (TANF) or ``Assets for Independence Act'' Individual
Development Account (IDA); and
Unearned Income Exclusions
Any public agency's refund of taxes on real property or food;
Assistance based on need wholly funded by a State or one of its
political subdivisions. This exclusion includes State supplementation
of Federal SSI benefits but does not include payments under a Federal/
State grant program such as TANF;
Any portion of a grant, scholarship, fellowship, or gift to an
individual used for paying tuition, fees, or other necessary
educational expenses;
Food raised by a household if it is consumed by that household;
Assistance received under the Disaster Relief and Emergency
Assistance Act and assistance provided under any Federal statute
because of a catastrophe that the President of the United States
declares to be a major disaster;
Assistance received under a program for flood mitigation
activities;
The first $60 of unearned income in a quarter if it is
infrequent or irregular, that is: (1) if it is received only once in a
calendar quarter from a single source and is not also received in the
month immediately preceding or the month immediately following the
month of receipt regardless of whether or not these payments occur in
different calendar quarters; or (2) if its receipt cannot reasonably be
expected;
Any unearned income received and used to fulfill an approved
plan to achieve self-support if the recipient is blind or disabled and
under age 65, or if the recipient is blind or disabled and received SSI
as a blind or disabled individual in the month before he or she
attained age 65;
Periodic payments made by a State under a program established
before July 1, 1973 and based solely on the recipient's length of
residence and attainment of age 65;
Payments for providing foster care to an ineligible child placed
in the recipient's home by a public or private nonprofit child
placement or child care agency;
Any interest earned on excluded burial funds and any
appreciation in the value of an excluded burial arrangement left to
accumulate and become part of the separately identifiable burial fund;
Certain support and maintenance assistance provided in the form
of home energy assistance;
One-third of support payments made by an absent parent if the
recipient is a child;
The first $20 of unearned income in a month other than income in
the form of in-kind support and maintenance received in the household
of another and income based on need;
The value of any assistance paid with respect to a dwelling unit
under the United States Housing Act of 1937, the National Housing Act,
section 101 of the Housing and Urban Development Act of 1965, Title V
of the Housing Act of 1949, or section 202(h) of the Housing Act of
1959;
Any interest accrued on and left to accumulate as part of the
value of an excluded burial space purchase agreement (effective April
1, 1990) and any interest earned on the value of nonexcludable burial
funds and burial space purchase agreements is excluded from income
(effective July 1, 2004);
The value of any commercial transportation ticket for travel by
a recipient or his or her spouse among the 50 States, the District of
Columbia, Puerto Rico, the Virgin Islands, Guam, American Samoa, and
the Northern Mariana Islands that is received as a gift and is not
converted to cash;
Payments received from a fund established by a State to aid
victims of crime;
State-provided pensions to aged, blind, or disabled veterans (or
their spouses);
Relocation assistance provided by a State or local government
that is comparable to assistance provided under title II of the Uniform
Relocation Assistance and Real Property Acquisition Policies Act of
1970;
Hostile fire pay received from one of the uniformed services
pursuant to 37 U.S.C. 310 and other kinds of additional pay received by
military personnel in a combat zone;
Interest or other earnings on a dedicated account excluded from
resources;
In-kind gifts not converted to cash and the first $2,000
annually of cash gifts made by tax-exempt organizations, such as the
Make-A-Wish Foundation, to, or for the benefit of, individuals under
age 18 with life-threatening conditions;
Payments made under the Ricky Ray Hemophilia Relief Fund Act of
1998;
Up to $2,000 per calendar year in compensation for participating
in clinical trials researching treatment of rare diseases and
conditions;
TANF funds made available to an SSI recipient as part of an IDA;
Amounts received from the Filipino Veterans Equity Compensation
Fund set forth in the American Recovery and Reinvestment Act of 2009;
Amounts received by Medicaid recipients from the ``Incentives
for Prevention of Chronic Diseases in Medicaid'' program established by
the Affordable Care Act of 2010;
Payments to Indian landowners made in accordance with the Cobell
et al. v. Salazar et al. lawsuit settlement as ratified by the Claims
Resettlement Act of 2010;
Refundable tax credits (or advance payment of such credits);
Deposits made by a participating individual or a sponsoring
nonprofit organization or State or local government into an IDA under
the Assets for Independence Act IDA demonstration project and interest
earned on these deposits;
Unearned income excluded by other Federal laws. See Federal
Regulations Appendix to Subpart K 20 CFR 416;
Generally, all interest and dividend income earned on countable
resources;
Lump sum payments made under the Energy Employees Occupational
Illness Compensation Program Act of 2000 (the EEOCIP Act), including
reimbursement for medical expenses, are excluded from income for SSI
purposes;
Contributions to an Achieving a Better Life Experience (ABLE)
account are excluded for the account's beneficiary. In addition,
interest and dividends accrued by and retained within an ABLE account
are also excluded; and
Payments made by a State program intended to compensate
individuals who had been sterilized under the authority of a State.
Many Federal laws in addition to the Social Security Act provide
for the exclusion of assistance received in the form of food, housing
and utilities, educational and employment benefits, or benefits derived
from being a member of a Native American Tribe.
Resource Exclusions
The home in which an individual has ownership interest and that
serves as the individual's principal place of residence (including the
land appertaining thereto);
Household goods and personal effects;
One automobile if used for transportation for the recipient or a
member of the recipient's household;
Property used in a trade or business that is essential to self-
support;
Up to $6,000 of nonbusiness property that is essential to self-
support;
Resources of a blind or disabled individual that are necessary
to fulfill an approved plan to achieve self-support;
Stock in regional or village corporations held by natives of
Alaska during the 20-year period in which the stock is inalienable
pursuant to the Alaska Native Claims Settlement Act;
Life insurance owned by an individual (and spouse, if any)
provided that all life insurance on any person does not exceed a face
value of $1,500;
Restricted allotted Indian lands;
Disaster relief assistance;
Assistance received under a program for flood mitigation
activities;
Burial spaces and certain funds up to $1,500 for burial
expenses;
SSI or Old-Age, Survivors, and Disability Insurance retroactive
payments for 9 months following the month of receipt;
The value of any assistance paid with respect to a dwelling unit
under the United States Housing Act of 1937, the National Housing Act,
section 101 of the Housing and Urban Development Act of 1965, title V
of the Housing Act of 1949, or section 202(h) of the Housing Act of
1959;
Refunds of Federal income taxes and advances made by an employer
relating to an EITC for 12 months following the month of receipt;
One-time economic recovery payment received under the American
Recovery and Reinvestment Act of 2009, for the month of receipt and the
following 9 months;
Amounts received pursuant to the Making Work Pay tax credit set
forth in the American Recovery and Reinvestment Act of 2009 for the
month of receipt and the following 12 months;
Amounts received from the Filipino Veterans Equity Compensation
Fund set forth in the American Recovery and Reinvestment Act of 2009;
Refundable child tax credit for 12 months following the month of
receipt;
Refundable tax credits or advance payment of such credits for 12
months following the month of receipt;
Grants, scholarships, fellowships, or gifts to be used for
tuition or educational fees for 9 months following the month of
receipt;
Payments received as compensation for replacement or repair of
losses, damages, or theft for 9 months following the month of receipt;
Relocation assistance from a State or local government for 9
months following the month of receipt;
Payments made from State-provided pensions to aged, blind, or
disabled veterans or their spouses;
Dedicated financial institution accounts for disabled children;
In-kind gifts not converted to cash and the first $2,000
annually of cash gifts made by tax-exempt organizations, such as the
Make-A-Wish Foundation, to, or for the benefit of, individuals under
age 18 with life-threatening conditions;
Up to $2,000 per calendar year in compensation for participating
in clinical trials researching treatment of rare diseases and
conditions;
Amounts received by Medicaid recipients from the ``Incentives
for Prevention of Chronic Diseases in Medicaid'' program established by
the Affordable Care Act of 2010;
Payments to Indian landowners made in accordance with the Cobell
et al. v. Salazar et al. lawsuit settlement, as ratified by the Claims
Resettlement Act of 2010 (for 12 months following the month of
receipt);
Payments made under the Ricky Ray Hemophilia Relief Fund Act of
1998;
Amounts deposited into either a TANF or Assets for Independence
Act IDA, including matching funds and interest earned on such amounts;
Certain trusts (e.g., those established by will or certain
Medicaid trusts that will repay the State, upon the death of the
recipient, for the costs of medical assistance provided to that
individual);
Payments or benefits provided under a Federal statute other than
title XVI of the Social Security Act where exclusion is provided by
such statute;
Up to $100,000 held in a qualified ABLE account. Furthermore,
any distribution from an ABLE account for a qualified disability
expense that is not
housing-related is excluded from resources in the month it is used or
in a month for which it is intended to be used for such expenses; and
Payments made by a State program intended to compensate
individuals who had been sterilized under the authority of a State.
______
Potential Entitlements From 2013 Brainstorming
The list of Potential Entitlements was developed in May 2013, to
develop ideas and suggestions for further analysis or investigation.
Medicare Only Beneficiaries, who are fully insured but either
elect entitlement only to Medicare or have end stage renal disease, who
should convert to Retirement Benefits.
Medicare Only Beneficiaries who have at least 20-39 quarters of
coverage and are eligible for reduced Buy-in fees.
Spouse to Retirement Benefits.
Combined Family Maximum.
Title 2 (T2) Retroactivity--ensure retroactive benefits due are
paid.
Number holder (NH) is uninsured but names a spouse on their
application for benefits, who is insured.
Possible T2 Auxiliary Entitlement--Individual on Supplemental
Security Income (SSI) with ineligible spouse who receives T2.
Parisi Cases--Dually entitled individuals subject to deduction-
before reduction in order to maximize benefits to other auxiliaries/
survivors entitled on the social security number (SSN).
Possible T2 Auxiliary/Survivor Entitlement.
SSI Diary was set-case, not worked due to non-pay status.
SSI Diary was set-case, never worked due to non-pay status.
2049 Cases--systems limitation with the recovery of overpayment
accounting and reporting.
Deemed Military Wage credits were not considered in the insured
status computation.
12/68 Military Wage Report for Navy Reserve was not posted as
military wage.
Military Retirees who did not receive military service (MS)
credits for years prior to 1968.
Children in suspense pending a decision on a need for payee.
Underpayment is due the estate or family of deceased NH.
Underpayment is due to unnegotiated checks.
Master beneficiary record (MBR) in suspense with SSI
entitlement.
Medicare for Qualified Government Employee earnings involved-
eligible for cash and/or Medicare.
Individual eligible after consideration of Totalization
Agreement A.
NH alleges wages from totalization country.
Individual has lawfully admitted for permanent residency (LAPR)
issue on MBR and some payment has been withheld pending citizenship/
lawful presence.
Administrative Law Judge allowance and case was never
effectuated by the processing center.
T2/T16 allowance decision with Disability Determination Services
(DDS) allowance and not adjudicated after 180 days.
Cases that were awarded for T2/SSI and award was never
processed.
Military Service Annual Earning Reappraisal Operation--Annual
selection can reduce the incidence of occurrence by obtaining verified
military service credits and posting to record.
Individual filed T2 only claim-alleging visual impairment-denied
using incorrect computation.
Child named on application of a parent(s) and no claim taken.
The agency may be using a prior record to establish LAPR when in
fact it was never proven to SSA.
T2 did not correct the DDS or Disability Quality Branch (DQB)
date of onset change.
Possible problem with Primary Insurance Amount (PIA)--at Full
Retirement Age (FRA) new computations are not being considered in all
cases.
T2 Disability medical cessations are not being effectuated
timely.
NH filed for Medicare along with spouse or disabled child/
subsequent application for RIB, but spouse/child were overlooked.
Young widow-to-widow benefits terminated when youngest child
reached age 16-child was subsequently entitled as Disabled Adult Child
(DAC)--Need to determine if widow can be re-entitled.
Most advantageous election of Aged Widow with Disabled Number
holder entitlement.
Simultaneous Disabled Worker/Aged Widow(er) over age 60
entitlement overlooked.
T2 Adjustment of Reduction Factor.
Unreduced Aged Widow (D) claims with retroactive Aged Wife (B)
entitlement.
Conversions from Wife to Aged Wife at FRA.
Divorced Spouse terminated due to marriage and alerted spouse
over age 62, who remarried after age 60.
Possible disability insurance benefit (DIB) Entitlement -
Individual receiving T2 Disabled Adult Child (CDB ) benefits has worked
and/or gained insured status on own SSN and now has higher PIA on own
record.
T2 CDB denials with possible child entitlement prior to age 18
after retro consideration.
Possible T2 CDB Entitlement--SSI DI applicant was disabled prior
to age 22 but SSI was established after age 22, parents now in receipt
of T2 benefits or are deceased.
Possible T2 CDB Entitlement--Previous childhood disability
awarded on SSI.
T2 CDB was awarded in the past--the NH on the CDB account was
terminated or suspended and later reinstated. Upon reinstatement, the
CDB entitlement was missed.
Previous childhood disability awarded on SSI. Student benefits
previously awarded on T2 and no conversion to CDB on the record of the
entitled parent.
Possible T2 CDB entitlement Individuals without a payee in an
institution now potentially entitled on their parents SSN- Disability
began as a child. No current entitlement.
Individuals without a payee but NOT in an institution--now
potentially entitled on their parents SSN--Disability began as a child.
Previous childhood disability awarded on SSI--now converted to
adult and one parent or the other (or both) in receipt of T2.
Possible T2 CDB Entitlement.
Possible T2 CDB Entitlement. Individuals with a payee but
residing in an institution. Now eligible for auxiliary/survivors
benefits based on parents' SSN.
Individuals with a payee but NOT residing in an institution. Now
eligible for auxiliary/survivors benefits based on parents' SSN.
CDB charged with a 5 month waiting period.
In receipt of SSI payments and eligible for Retirement.
In receipt of SSI payments and eligible for Retirement; birthday
in last 9 months of the year. Individual receives disabled benefits.
In receipt of SSI payments and eligible for Retirement; birthday
in last 9 months of the year. Individual receives blind benefits.
Disabled child/adult is listed on another's SSI application.
In receipt of SSI/Type A income, diary not setting.
Individuals who are ceased on T2 DIB still show up on the annual
diary run-creates duplicate work.
Individual has a divorced spouse and spouse files for benefits.
NH is eligible if 10-year duration is met.
Part B Medicare in non-auto accrete States is not being filed
for.
SSI-Special Disability workload Fallout.
JR Diary SSI.
SSI Blind individual-filed for T2 and denied -did not use Blind
Fully insured computation.
Type of master record is Disabled Individual but the individual
is Statutorily Blind. SSA 831 information was not recorded in
Modernized SSI Claims System--creates incorrect payment if NH works
(10/1/09).
SSI Individual who is terminated due to work and earnings but
1619a is not being considered.
Wife to Widow approaching age 50 receiving SSI DIB.
SSI Diary-need to automate and identify.
T16 technical denial taken-but NH is insured for T2 and no T2
claim taken.
SSI diary was set/T2 not taken/T16 was technical denial/NH
insured for T2.
SSI diary was set/T16 claim taken/NH insured for T2.
SSI Veteran-Eligible for Veteran Administration pension.
Supplemental Security Record/MBR Interface Failures.
SSI diary sets annually. Current PIA on another record is always
higher.
SSI date of onset changed-and SSI did not properly pay the case
with new onset.
Veteran's Pension posting problems. Veteran's Pension is not
verified and attendance was posted to the Veteran rather than the
spouse, and/or other posting issues.
Individual was referred for T2 but no claim was taken.
T16 medical cessations are not timely effectuated.
______
SOCIAL SECURITY
The Commissioner
May 7, 2021
The Honorable Ron Wyden
Chair
U.S. Senate
Committee on Finance
Washington, DC 20510
Dear Committee Chair Wyden:
At the April 29, 2021 hearing titled ``Social Security During COVID:
How the Pandemic Hampered Access to Benefits and Strategies for
Improving Service Delivery,'' you asked us to provide information on
our efforts to encourage Old-Age, Survivors, and Disability Insurance
(OASDI) program beneficiaries who might also be eligible for
Supplemental Security Income (SSI) benefits to apply for them. Enclosed
please find a progress report on this initiative.
I hope this information is helpful. If you have questions or wish to
discuss this issue in more detail, please contact me, or have your
staff contact Dennis Foley, our Assistant Deputy Commissioner for
Legislation and Congressional Affairs, at (202) 358-6030.
Sincerely,
Andrew Saul
Commissioner
Enclosure
______
Supplemental Security Income Targeted Mailers
Progress Report
May 2021
Background
The Supplemental Security Income (SSI) program provides monthly cash
benefits to people with limited income and resources who are age 65 or
older, blind, or disabled. SSI also serves as a gateway program that
can provide beneficiaries with automatic eligibility for other
programs, including Medicaid and the Supplemental Nutrition Assistance
Program.
In addition to the SSI program, we also administer the Old-Age,
Survivors, and Disability Insurance program (OASDI; also often referred
to as ``Social Security''), which provides monthly benefits to retired
and disabled workers and their dependents and to survivors.
Our data analyses indicated that, during the pandemic, there has been a
disproportionate decrease in SSI applications among several groups,
including people who are age 65 or older, children with disabilities,
and people with limited English proficiency. Other impacted groups
include people diagnosed with mental illness, people experiencing
homelessness, veterans, and people recently released from
incarceration.
The goal of our SSI Targeted Mailer project is to increase SSI program
participation by encouraging certain OASDI beneficiaries who may also
qualify for benefits from the SSI program to contact us and apply.
Initial Mailing
For the initial mailing, we selected OASDI beneficiaries from three of
the groups that have experienced the most significant decrease in SSI
applications, specifically beneficiaries who are:
age 18-64 and receiving disability benefits;
age 65-84; or
age 65-84 and have limited English proficiency (LEP).
We excluded from this outreach OASDI beneficiaries whose income--based
on the Social Security benefits they receive as well as other income
information in our records--would preclude SSI eligibility because it
exceeds the maximum monthly Federal SSI benefit (the ``Federal Benefit
Rate'').
From late December through March, we mailed 200,000 notices in total to
the initial group selected for outreach. The notice encouraged these
OASDI beneficiaries to contact us and apply for SSI.
Interim Results
We expect to complete a full analysis of the initial mailing by
November 2021. This timeframe is because some people selected to
receive the initial mailing continue to contact us and apply for SSI,
and we continue to process some of the applications we have received.
Below are interim results for the initial mailing as of April 23rd:
5,162 SSI applications received (2.58% of total mailers sent);
2,271 SSI applications approved (1.14% of the total mailers
sent);
$198.70 per month--the average Federal SSI benefit for newly
eligible SSI beneficiaries in this group. This does not include
benefits from Medicaid, the supplements that certain States provide SSI
recipients, and other programs these people may now qualify for as a
result of SSI eligibility; and
$451,238.40--the total Federal SSI benefits paid.
Next Steps
In June 2021, we will begin mailing notices to the remaining population
of about 1.2 million OASDI beneficiaries potentially eligible for SSI
benefits who are in the three groups mentioned above,\1\ in addition to
those age 85 and older. We will send these notices over the course of a
year to ensure that we can provide high-quality service to the
beneficiaries who contact us and as well as to the rest of the public
we serve.
---------------------------------------------------------------------------
\1\ We had previously estimated sending this notice to about 2
million OASDI beneficiaries. After applying additional refining
criteria, the potentially eligible population is now about 1.2 million
beneficiaries.
In anticipation of this larger mailing we have improved the process
---------------------------------------------------------------------------
based on what we learned from the initial mailing:
We refined our data screening to better target the mailing to
people who are more likely to be eligible for SSI. For example, we
added additional screening criteria to more precisely identify and
exclude individuals who would not be eligible for SSI because our
records indicate they receive a pension in addition to their Social
Security benefits.
We shortened and simplified the notice and will now include with
it a one-page fact sheet about the SSI program.
We will send an email notification to OASDI beneficiaries who
have given us an email address. This email will be in addition to the
paper notice.
As in the initial mailing, the notice we send for the full
mailing will encourage OASDI beneficiaries to apply for SSI by calling
us at a toll-free number dedicated solely to this purpose and staffed
by bilingual employees in our national call center who are fluent in
Spanish and English. We have expanded capacity on this dedicated line,
and in June it will include new features made possible by an upgrade to
our telephone system, such as improved call routing capability and
giving the caller the option to have us call them back. Like our main
toll-free number (1-800-772-1213), the dedicated line will offer
telephone translation in 200 languages.
Estimated Costs
We estimate that we will spend about $3 million on this project in
fiscal year 2021 and about $5.5 million in fiscal year 2022. This
includes both printing and mailing costs and staff time to answer calls
and process the applications.
______
National Drop Box Status List
Office Code Office Region
620 GWINNETT GA ATL
00G ORLANDO SSCC ATL
723 MIAMI SOUTH FL ATL
322 RALEIGH NC ATL
260 SOUTH BROWARD FL ATL
262 HIALEAH FL ATL
328 DURHAM NC ATL
C29 LITTLE HAVANA FL ATL
C19 FT LAUDERDALE W ATL
320 CHARLOTTE NC ATL
949 CARROLLWOOD FL ATL
568 CHATTANOOGA TN ATL
661 WEST PALM BEACH FL ATL
261 PERRINE FL ATL
619 KENNESAW GA ATL
565 NASHVILLE TN ATL
663 GAINESVILLE FL ATL
344 CONCORD NC ATL
628 DOTHAN AL ATL
C27 FAIRHOPE AL ATL
631 FLORENCE AL ATL
632 HUNTSVILLE AL ATL
624 MOBILE AL ATL
264 ALLAPATTAH FL ATL
A57 BELLE GLADE FL ATL
265 BRADENTON FL ATL
257 CLEARWATER FL ATL
A98 DADE CITY FL ATL
266 EAST HILLSBOROUGH ATL
665 FT LAUDERDALE EAST ATL
672 KEY WEST FL ATL
C24 LITTLE RIVER FL ATL
671 MIAMI BEACH FL ATL
C18 NAPLES FL ATL
709 NEW PORT RICHEY FL ATL
722 NORTH BROWARD FL ATL
A06 PT CHARLOTTE FL ATL
667 SARASOTA FL ATL
C26 SOUTH PALM BEACH ATL
662 ST PETERSBURG FL ATL
656 TAMPA FL ATL
A14 VENICE FL ATL
A20 FT WALTON BEACH FL ATL
663 GAINESVILLE FL ATL
263 JACKSONVILLE NORTH ATL
255 LAKE CITY FL ATL
658 LAKELAND FL ATL
258 LEESBURG FL ATL
657 ORLANDO FL ATL
00G ORLANDO SSCC ATL
664 PORT ORANGE FL ATL
602 ALBANY GA ATL
604 ATHENS GA ATL
606 AUGUSTA GA ATL
614 BRUNSWICK GA ATL
605 COLUMBUS GA ATL
C96 COVINGTON GA ATL
615 DUBLIN GA ATL
612 GAINESVILLE GA ATL
616 GRIFFIN GA ATL
608 LAGRANGE GA ATL
603 MACON GA ATL
610 MILLEDGEVILLE GA ATL
I15 NEWNAN GA ATL
609 ROME GA ATL
601 SAVANNAH GA ATL
A44 STATESBORO GA ATL
611 THOMASVILLE GA ATL
C95 TIFTON GA ATL
B23 TOCCOA GA ATL
613 VALDOSTA GA ATL
E69 VIDALIA GA ATL
607 WAYCROSS GA ATL
C31 WINDER GA ATL
645 GREENWOOD MS ATL
B14 GRENADA MS ATL
642 HATTIESBURG MS ATL
B15 KOSCIUSKO MS ATL
652 LAUREL MS ATL
651 NATCHEZ MS ATL
481 ALBEMARLE NC ATL
323 ASHEVILLE NC ATL
325 GREENSBORO NC ATL
B10 HENDERSON NC ATL
331 HICKORY NC ATL
334 NEW BERN NC ATL
326 ROCKY MOUNT NC ATL
321 SALISBURY NC ATL
484 SMITHFIELD NC ATL
327 WILMINGTON NC ATL
324 WINSTON SALEM NC ATL
585 CHARLESTON SC ATL
587 FLORENCE SC ATL
588 ROCK HILL SC ATL
590 ANDERSON SC ATL
592 MYRTLE BEACH SC ATL
594 ORANGEBURG SC ATL
595 SUMTER SC ATL
C16 CLINTON SC ATL
C94 ATHENS TN ATL
574 CLARKSVILLE TN ATL
581 CLEVELAND TN ATL
569 COLUMBIA TN ATL
573 COOKEVILLE TN ATL
570 DYERSBURG TN ATL
558 GALLATIN TN ATL
575 GREENEVILLE TN ATL
580 JACKSBORO TN ATL
571 JACKSON TN ATL
572 JOHNSON CITY TN ATL
579 KINGSPORT TN ATL
567 KNOXVILLE TN ATL
B08 LAWRENCEBURG TN ATL
C37 MADISON TN ATL
B19 MCMINNVILLE TN ATL
C90 MEMPHIS NORTH TN ATL
556 MEMPHIS SOUTH TN ATL
566 MEMPHIS TN ATL
576 MORRISTOWN TN ATL
578 MURFREESBORO TN ATL
A51 OAK RIDGE TN ATL
582 PARIS TN ATL
D00 SELMER TN ATL
577 TULLAHOMA TN ATL
B03 UNION CITY TN ATL
450 CAMPBELLSVILLE KY ATL
452 DANVILLE KY ATL
442 FLORENCE KY ATL
441 FRANKFORT KY ATL
446 HAZARD KY ATL
439 LEXINGTON KY ATL
437 LOUISVILLE DOWNTO ATL
A45 LOUISVILLE EAST KY ATL
428 MAYSVILLE KY ATL
448 PIKEVILLE KY ATL
454 SOMERSET KY ATL
032 CAMBRIDGE MA BOS
030 BOSTON MA BOS
072 PROVIDENCE RI BOS
085 NEW HAVEN CT BOS
087 STAMFORD CT BOS
041 LAWRENCE BOS
003 AUGUSTA BOS
022 BURLINGTON BOS
A23 EAST HARTFORD BOS
011 PORTSMOUTH BOS
347 GRAND RAPIDS MI CHI
485 CHICAGO LOOP IL CHI
00L TWIN CITIES SSCC CHI
499 CHICAGO NORTH IL CHI
D63 COLUMBUS NORTH CHI
350 PONTIAC MI CHI
532 MOUNT PROSPECT IL CHI
399 HAMILTON OH CHI
857 HOUSTON SOUTHEAS DAL
A76 MCKINNEY TX DAL
A73 DENTON TX DAL
814 DALLAS NORTH TX DAL
873 MID CITIES TX DAL
A74 CONROE TX DAL
763 FAYETTEVILLE AR DAL
820 AMARILLO TX DAL
813 AUSTIN TX DAL
784 TULSA DAL
792 MOORE DAL
787 MUSKOGEE DAL
B45 OKMULGEE DAL
791 MIAMI DAL
785 CHICKASHA DAL
798 CLINTON DAL
765 FORREST CITY DAL
802 MONROE DAL
A71 KENNER DAL
D18 ST. TAMMANY DAL
E36 BATON ROUGE N DAL
810 OPELOUSAS DAL
809 NATCHITOCHES DAL
828 LEAGUE CITY DAL
841 MCALLEN DAL
E45 GEORGETOWN DAL
843 CORSICANA DAL
D20 WAXAHACHIE DAL
837 SHERMAN DAL
00K RIO RANCHO, NM DAL
B53 HOBBS, NM DAL
860 SANTA FE, NM DAL
862 CLOVIS, NM DAL
00Z MANHATTAN CARD C NY
00Q BRONX SOC SEC CARD NY
144 MELVILLE NY NY
00E QUEENS SOC SEC CAR NY
SSCC-Broo BROOKLYN SSCC NY
170 NEWARK NJ NY
173 PATERSON NJ NY
186 PARSIPPANY NJ NY
182 HACKENSACK NJ NY
171 TRENTON NJ NY
176 JERSEY CITY NJ NY
158 HUNTS POINT NY
113 YONKERS NY
118 NEWBURGH NY
154 MONTICELLO NY
B93 PEEKSKILL NY
148 WHITE PLAINS NY
B95 EAST VILLAGE NY
149 WEST NYACK NY
134 INWOOD HILL NY
D58 HYLAN BLVD NY
132 NORTH BRONX NY
133 POUGHKEEPSIE NY
128 NEW ROCHELLE NY
C01 LONG ISLAND CITY NY
150 FLUSHING NY
163 RIVERHEAD NY
160 BEDFORD HEIGHTS NY
151 FREEPORT NY
137 NEW UTRECHT NY
B97 WEST BABYLON NY
139 CYPRESS HILLS NY
138 MINEOLA NY
130 TROY NY
142 OLEAN NY
129 WATERTOWN NY
141 GENEVA NY
115 NIAGARA FALLS NY
116 OGDENSBURG NY
146 ONEONTA NY
B89 MANATI NY
A31 CAROLINA NY
271 SAN JUAN NY
380 SAN PATRICIO NY
272 PONCE NY
B00 HATO TEJAS NY
528 AGUADILLA NY
C71 FAJARDO NY
198 TOA ALTA NY
177 CLIFTON NY
B99 BRIDGEWATER NY
A26 TOMS RIVER NY
175 WOODBRIDGE NY
180 BRIDGETON NY
181 NEPTUNE NY
C73 MOUNT LAUREL NY
A25 GLASSBORO NY
174 UNION TWP NY
188 SPRINGFIELD AVE NY
178 EGG HARBOR TWP NY
184 EAST ORANGE NY
D24 AURORA CO DEN
900 SALT LAKE CITY UTAH DEN
887 COLORADO SPRINGS C DEN
902 PROVO UT DEN
771 DODGE CITY KS KC
779 JOHNSON COUNTY KS KC
692 SIOUX CITY IA KC
697 FORT DODGE KC
737 ST JOSEPH KC
693 WATERLOO KC
738 SPRINGFIELD KC
751 COLUMBIA KC
734 ST. PETERS KC
234 FAIRLESS PA PHI
294 ALEXANDRIA VA PHI
231 PITTS EAST LIBERTY P PHI
318 FAIRFAX VA PHI
C07 GREENBELT MD PHI
A33 ROCKVILLE MD PHI
282 SILVER SPRING MD PHI
270 DC DOWNTOWN PHI
227 NORRISTOWN PA PHI
B56 VIRGINIA BEACH PHI
B68 ACCOMAC VA PHI
96 ELKTON MD PHI
A35 CARLISLE PA PHI
235 CHAMBERSBURG PA PHI
205 ERIE PA PHI
7 MEADVILLE, PA PHI
216 YORK PA PHI
292 DANVILLE, VA PHI
301 FARMVILLE, VA PHI
299 WISE, VA PHI
298 WYTHEVILLE, VA PHI
A92 CULPEPPER, VA PHI
309 CLARKSBURG WV PHI
310 ELKINS WV PHI
312 MORGANTOWN WV PHI
D36 GARDEN GROVE CA SFN
972 SANTA ANA CA SFN
B58 MISSION VIEJO CA SFN
908 TUCSON AZ SFN
00I SACRAMENTO SSCC SFN
984 SALINAS CA SFN
960 SAN JOSE CA SFN
062 CHATSWORTH CA SFN
025 PAGO PAGO AM SAM SFN
987 OCEANSIDE CA SFN
066 HAYWARD CA SFN
D44 WILSHIRE CENTER SFN
068 SANTA MARIA CA SFN
385 SAN JOSE EAST CA SFN
946 LAS VEGAS NV SFN
945 RENO NV SFN
907 PHOENIX NORTH AZ SFN
B60 FREMONT CA SFN
976 BERKELEY CA SFN
950 SAN FRANCISCO DT C SFN
978 MODESTO CA SFN
E31 GLENDORA CA SFN
952 FRESNO CA SFN
250 EL CAJON CA SFN
253 UNIVERSITY VILLAGE C SFN
249 ANAHEIM SFN
D39 BREA SFN
A78 FOUNTAIN VALLEY SFN
168 GUAM SFN
D41 KEARNEY MESA SFN
B80 LA MESA SFN
435 NATIONAL CITY SFN
E02 SAIPAN SFN
954 SAN DIEGO SFN
931 SAN MARCOS SFN
914 GLENDALE SFN
939 MESA SFN
A53 MORONGO BASIN SFN
A15 NEEDLES SFN
913 PHOENIX DTN SFN
930 SOUTH TUCSON SFN
B63 ANTIOCH SFN
561 GILROY SFN
A83 MOUNTAIN VIEW SFN
383 RICHMOND SFN
781 SF MISSION SFN
E41 SOUTH SAN JOSE SFN
967 SAN MATEO SFN
988 SAN RAFAEL SFN
061 SANTA CRUZ SFN
248 WALNUT CREEK SFN
948 WATSONVILLE SFN
060 MERCED SFN
E27 OROVILLE SFN
E78 PLACERVILLE SFN
969 REDDING SFN
E77 ROSEVILLE SFN
955 SACRAMENTO SFN
E28 NORTH SACRAMENTO SFN
E29 WEST SACRAMENTO SFN
962 STOCKTON SFN
A01 SUSANVILLE SFN
A03 UKIAH SFN
989 YUBA CITY SFN
D35 AUBURN SFN
979 CHICO SFN
E08 FRESNO SOUTHEAST SFN
386 FRESNO WEST SFN
958 LONG BEACH SFN
I55 ELKO SFN
B69 FONTANA SFN
906 HEMET SFN
A00 HENDERSON SFN
B73 MORENO VALLEY SFN
D49 NORTH LAS VEGAS SFN
251 RIVERSIDE SFN
959 SAN BERNARDINO SFN
A87 VICTORVILLE SFN
943 WEST COVINA SFN
D46 ALHAMBRA SFN
434 COMPTON SFN
968 HOLLYWOOD SFN
966 HUNTINGTON PARK SFN
059 LANCASTER SFN
063 MONTEBELLO SFN
562 NORWALK SFN
957 PASADENA SFN
982 WHITTIER SFN
924 WENATCHEE WA SEA
191 KENT WA SEA
190 BELLEVUE WA SEA
919 YAKIMA WA SEA
______
Prepared Statement of Tara Dawson McGuinness,\1\
Fellow and Senior Adviser, New Practice Lab, New America
---------------------------------------------------------------------------
\1\ See McGuinness and Schank, Power to the Public: The Promise of
Public Interest Technology, Princeton, Princeton University Press,
April 2021.
---------------------------------------------------------------------------
Thank you, Chairman Wyden, Ranking Member Crapo, and members of the
committee. I am grateful to join you this morning to talk about making
the Federal Government really work for the public.
The effort to ensure that citizens and taxpayers are served by
their government goes back over 100 years.
When President Lincoln presided over a country of 31 million
residents he was perhaps the first President to focus on this
question--how are we delivering for those who elected us? He would open
the doors to the White House after breakfast to hear from not only
government officials, but citizens, welcoming their petitions and
concerns.\2\
---------------------------------------------------------------------------
\2\ Harold Holzer, ``Abraham Lincoln's White House,'' White House
History 25 (Spring 2009): https://www.whitehousehistory.org/abraham-
lincolns-white-house.
---------------------------------------------------------------------------
But as the U.S. grew to ten times the size of the populace of
Lincoln's time, the practicality of this exercise has changed. The
challenge however remains today for agency leaders: how do they bring
this spirit of citizen connection and government delivery into the
digital age?
If government is going to deliver for people, it needs to
constantly ask them what they need, and understand how they live their
lives. This requires:
Using data and technology to make the process as
seamless as possible, and understanding what data and technology can't
do.
A focus on the people an agency serves--really
understanding their needs.
A deep understanding of the approval process for
services and the role different State and Federal agencies play.
A culture of learning, re-tooling and adjusting
to make sure the services keep up with the times and respond to crises
like a pandemic.
I am grateful that you have called this hearing to understand
how responsive the Social Security Administration was to the COVID
crisis, what we can learn from it, and how we can take these lessons
forward to improve services into the future.
adapting structures and using new tools to serve the public
Just because government structures and systems were built for a
different time doesn't mean they can't adapt.
Massive digitization has come to the private sector and the
truth is--many of the Nation's leading companies didn't survive the
digital revolution.
Very few of the Fortune 500 companies at the turn
of the century survived this disruption.\3\ Failure is not an option
for the critical services like those administered by the Social
Security Administration.
---------------------------------------------------------------------------
\3\ Scott D. Anthony, S. Patrick Viguerie, Evan I. Schwartz, and
John Van Landeghem, 2018 Corporate Longevity Forecast: Creative
Destruction Is Accelerating (Lexington, MA: Innosight, 2018).
---------------------------------------------------------------------------
While companies can be replaced by startups
better adapted for the time, the government is not going to be replaced
by a startup--it needs to adapt to meet the moment.
Millions of Americans depend on it.
Transforming an organization, whether to meet the changes of a
digital age or a global pandemic, is difficult.
There are new tools to do this--the modern equivalent of
Lincoln's one man effort to understand what citizens need and serve
them.
While the new Millennium brought a ruthless focus on delivering
for customers in the private sector--testing messages, imagery, and
even tweaking the timing of emails to increase customer response--this
modern toolkit is not yet accessible to all government leaders trying
to bring critical benefits to citizens.
This isn't just about making paper applications digital.
Digitizing a broken process gets you a digitized broken process.
Many organizations make the mistake of just taking an existing
process and digitizing it without understanding who they are serving or
whether that process works.
Making services work for people requires: building a culture of
tracking the whole experience for consumers, de-siloing different lanes
traditionally done by different departments and finding new ways to
adapt processes to meet beneficiaries where they are.
There has been progress. There are now multiple government units
dedicated to the delivery of services from the US Digital Service which
hires top technologists into term-limited tours to work alongside civil
servants to build better tools for the people to 18F, an office within
the General Services Administration, to help governments fulfill their
mission, stay on budget and use leading technology practices.
We have seen adaptations to COVID-19 that model new
possibilities, and some of these models can be found in other Federal
agencies:
The Food and Nutrition Service out of the
Department of Agriculture moved to remote validation for SNAP (food
assistance) during the pandemic.\4\ More specifically, FNS allowed
State agencies to adjust in several ways including:
---------------------------------------------------------------------------
\4\ USDA Food and Nutrition Service, SNAP--Adjusting Interview
Requirements Due to Novel Coronavirus (COVID-19) (Washington, DC: GPO,
2021), https://www.fns.usda.gov/snap/adjusting-interview-requirements-
covid-19.
---------------------------------------------------------------------------
By not requiring a household to complete an
interview prior to approval, provided the applicant's identity has been
verified and all other mandatory verifications are complete.
By not requiring a face-to-face interview or
granting a request for a face-to-face interview to any household at
application or recertification.
This process takes work, but it isn't impossible. Here are a few
examples of bureaucracies seeing a delivery challenge and making a
change:
In the State of Michigan--the Michigan Department
of Health and Human Services and Civilla worked on project re:form--the
transformation of America's longest benefits application.\5\
---------------------------------------------------------------------------
\5\ ``Project Re:Form,'' Design Awards, Core 77, accessed April 26,
2021, https://designawards.core77.com/Service-Design/86102/Project-Re-
Form.
---------------------------------------------------------------------------
DHS-1171, the application was the longest of its
kind in America at over 40 pages.
The form was an inhumane barrier between people
desperately in need and the emergency services the State of Michigan
provides to over 2.5 million residents each year.
One resident described the system as ``a cosmic
force'' ``it feels like it is left up to fate whether you will make it
through.\6\''
---------------------------------------------------------------------------
\6\ Interviews with Lena Selzer about original Re:form research and
Zack Quaintance, Government Technology (e.Republic, June 2018), https:/
/www.govtech.com /civic/A-Blueprint-for-Human-Centered-Change.html.
---------------------------------------------------------------------------
After reviewing the stories of beneficiaries who
could not get through the system and data on how the application was a
maze for beneficiaries and State employees alike to navigate, a team of
State agency leaders and external organizations tackled the design of
the country's longest benefits application.
After a massive redesign the experience is
different, one resident said, ``I feel like I can breathe again, after
completing the process.''\7\ So is the efficiency of processing, the
form can be completed in under 20 minutes and processed by the State in
half the time it used to take.
---------------------------------------------------------------------------
\7\ McGuinness and Schank, Power to the Public: The Promise of
Public Interest Technology, Princeton, Princeton University Press,
April 2021.
---------------------------------------------------------------------------
Why does it matter? Paying attention to form design,
and ensuring it is accessible, could be the difference between a needy
family receiving the help they need, and going hungry.
Similar transformations have happened in
California's SNAP application, Vermont's process for accepting benefits
applications supporting documentation, and multiple States' application
process for accepting foster parents into the child welfare system. In
Vermont, a document uploader (allowing people to upload documents
without coming into the office), cut 9 days processing to 1 day.\8\
---------------------------------------------------------------------------
\8\ Domenic Fichera, ``Integrating Eligibility and Enrollment for
Health and Human Services,'' Nava, accessed April 26, 2021, https://
www.navapbc.com/case-studies/integrating-eligibility-and-enrollment-
for-health-and-human-services.html.
---------------------------------------------------------------------------
In the State of California, a collaboration of
State, county, and external partners transformed the process of
applying for SNAP (food assistance). The reach of Calfresh,
California's food and nutrition services for low-
income families was very low--only 67 percent of those eligible used
the program compared to many states where enrollment was 80 percent or
90 percent. A series of engagements, starting with fellows to the
nonprofit Code for America, has become a multi-year public-private
partnership for a statewide transformation to bring the SNAP enrollment
process into the digital age. The results: while once an online
application for CalFresh required access to a desktop computer and took
the better part of an hour to complete, after the GetCalFresh
transformation the application could be submitted from a smartphone and
completed in 10 minutes. Applicants can get multilingual live chat
support while applying, send necessary documents from their mobile
phone, receive text and email reminders to guide them through the
enrollment and reporting process, which saves countless hours of
anxiety and stress for applicants, and reduces operational
inefficiencies for the counties and State.
This didn't happen overnight. The team did
research with users, adjudicators, created a short minimum viable
product, and over 5 years, transformed the experience of digital SNAP
outreach and enrollment.\9\ Harvard has written a case study about this
work.\10\
---------------------------------------------------------------------------
\9\ Francesca Costa, ``Code for America Improves Access to Social
Services During COVID-19,'' Hunger and Health--Feeding America, June 3,
2020, https://hungerandhealth.feedingamerica.
org/2020/06/code-america-improves-access-social-services-covid-19/.
\10\ Laura Winig and David Eaves, Hacking Bureaucracy: Reimagining
California's Food Stamp Program in the Digital Age (Cambridge, MA:
President and Fellows of Harvard College, 2016).
Here are four key lessons for making this transformation to service
delivery in the digital age:
First, increasing outreach doesn't help if the front door is locked
(forms):
It is very important to make sure that the public knows and
understands the benefits they are eligible to receive. Communication
and outreach from trusted messengers is critically important, but it is
rarely enough to make the difference.\11\
---------------------------------------------------------------------------
\11\ Elizabeth Linos, Aparna Ramesh, Jesse Rothstein, and Matt
Unrath, ``Increasing Take-Up of the Earned Income Tax Credit''
(California Policy Lab, 2020).
---------------------------------------------------------------------------
Often forms or applications, online or on paper, and the
approval process beneath them are the equivalent of either a locked
gate or a welcome mat that says ``need not apply.''
Agencies should think hard about their forms for benefits:
Try them out on a few people before you subject
them to millions of people.
Talk to the beneficiaries who use the form in
order to better understand the pain points and the experience.
Understand who uses your form (paper and
online)--and how they differ. There may be some clients that will need
in person application processes.
Talk to the front-line workers who adjudicate and
process these forms, understanding their work and perspective on the
process. Often great innovations come from those on the front lines of
a broken process.
Collect data on where people get stuck. Many
times backlogs are the result of confusing questions that require
requests for more information that must be processed through the mail,
slowing down applications.
User research with beneficiaries shouldn't just
ask people what their experience was. Where possible, researchers
should watch the process of filling out forms--ask people to think
aloud, and see which questions are difficult and cause confusion.
Testing forms takes iteration. Try new forms, and
then test them again.\12\
---------------------------------------------------------------------------
\12\ Brigid Schulte, ``Want to design policies that really work?
Test them on the users who need them first,'' New America, March 31,
2021, https://www.newamerica.org/better-life-lab/blog/want-to-design-
policies-that-really-work-test-them-on-the-users-who-need-them-first/.
---------------------------------------------------------------------------
Second, map the user experience (client journey)--end to end:
Often there is no single person in charge of an application
process end to end. Without tracing the journey (and what it feels like
to someone on it) end to end, it is hard to know where the bottlenecks
are.
By moving step by step, you can come to understand the true
experience on the customer side--often, people get lost in the
transition from one part of the process to the next.
Time and again, in the California and the Michigan examples
above, and in countless others, this mapping of the user experience
helps us understand how a person gets approved.
Third, measure what matters, in real-time:
Understanding the universe of eligible populations and the
recipients a program currently serves is the first step in assessing
service delivery and identifying important gaps.
Correspondence with this committee revealed that the Social
Security Administration conducted a comparative analysis of pre- and
post-COVID Supplemental Security Income (SSI) applications to identify
any subgroups which showed a larger than average impact from the
pandemic by analyzing demographic factors, disabilities, and local
economic characteristics. This analysis identified two specific
subpopulations which showed larger than average declines: individuals
aged 65 and older and those with limited English proficiency. These
groups were under-enrolled during the pandemic compared to prior years.
This is an important insight. But a critical question is what
data instrumentation does SSA have to see beneficiaries and where they
are in the process in real-time?
The ideal for service delivery is to establish monitoring real-
time data for priority services. This will ensure that the policy is
achieving the help it intended, and that people aren't being left out.
The installation of real-time data monitoring was game-changing
for the ad hoc team of engineers, designers, data scientists and
contractors working to turnaround Healthcare.gov in its early days.
The team didn't know what was broken until they could see where
clients were stuck: the log-in, the identity verification, the part of
the site where you pick a plan. It was impossible to prioritize fixes
until you could see all parts of the system in one place and where
people were getting through and where they met barriers.
Often different services (log-in, identity verification,
application validation) are run by different offices, agencies or
contractors--many times agencies have a hard time creating a complete
picture of the data because it requires seeing across these lanes of
work.
The ability to see in real-time who you are serving and how
applications are being processed is a key part of modern benefit
delivery operation.
Finally, fourth a word of caution: digitizing a broken process gets
you . . . a digitized broken process.
In more than one instance, governments have tried to turn an
existing process digital only to make things worse and experience few
gains. In 2005, the U.S. Citizenship and Immigration Service (USCIS),
the successor to the Immigration and Naturalization Service and the
Federal agency responsible for green cards and citizenship
applications, began a project to digitize the Nation's immigration
system.\13\ USCIS undertook this digitization process over the course
of 10 years. Early work didn't account for how field offices actually
functioned, and digitizing the process at first made it a lot worse.
Leaders at the agency have since course corrected, and set USCIS on a
strong course but the example is a warning. To modernize or digitize a
process requires really understanding both the beneficiaries and the
barriers they face, and the work an agency does on the other side.\14\
---------------------------------------------------------------------------
\13\ Office of Inspector General, ``USCIS Automation of Immigration
Benefits Processing Remains Ineffective'' (Washington, DC: GPO, 2016),
https://www.oig.dhs.gov/reports/2016-03/uscis-automation-immigration-
benefits-processing-remains-ineffective/oig-16-48.
\14\ Hana Schank and Tara McGuinness, ``What Happened When the U.S.
Government Tried to Make the Immigration System Digital,'' Slate, April
16, 2021, https://slate.com/technology/2021/04/elis-uscis-digital-
immigration-system.html.
In closing, I am grateful for the attention this committee has paid
to how these benefits really reach people. There are models across the
---------------------------------------------------------------------------
Federal Government and across the country to build on.
While policy matters a great deal, it matters very little if it
doesn't reach those who need it most when they need it most: in a
crisis.
______
Questions Submitted for the Record to Tara Dawson McGuinness
Questions Submitted by Hon. Ron Wyden
Question. Your testimony is extremely useful as we think of the
challenge of ensuring all people have access to benefits. One key
statement goes to the heart of the issues discussed during the
hearing--this is all about making services work for people:
Making services work for people requires building a culture of
tracking the whole experience for consumers; de-siloing
different lanes traditionally done by different departments;
and finding new ways to adapt processes to meet beneficiaries
where they are.
From what you learned from testimony and heard at the hearing,
where do you recommend SSA and agencies like it put their focus on
meeting beneficiaries where they are? What particular considerations
should these agencies have for people experiencing disability,
homelessness, or other impacts on their access? Are there any near term
solutions that could be implemented during the next six months that you
recommend?
From what you learned from testimony and heard at the hearing,
where do you recommend SSA and agencies like it put their focus on
meeting beneficiaries where they are?
near-term ideas to meet beneficiaries where they are
Answer. There are near-term solutions that SSA and other government
agencies like it can undertake right away to start meeting their
beneficiaries where they are. SSA should pick a place to start to make
improvements in one area and move to the next. Three possible areas to
consider starting service delivery improvement are: improving access to
phone assistance, making applications mobile accessible; and reducing
the application burden of the SSI application.
Improving access to phone assistance. According to multiple
beneficiary advocates it has, even prior to the pandemic, been
difficult to get answers by phone from SSA's national line or field
offices due to wait times and failure of SSA personnel to return phone
calls. Improving this phone service is critically important as most
applications cannot be processed without engaging SSA technicians.
There are a number of performance measures SSA could focus on to
improve phone assistance including: looking at the average number of
calls per day, average call wait times, call abandonment (i.e., the
percentage of calls dropped before the customer speaks to an agent and
the call resolution rate). A closer examination of call center and
field office call data might reveal bottlenecks. By understanding which
issues are receiving high volume and SSA could offer other channels to
address these questions and reduce call volume, a successful tactic
that has been deployed by other State and Federal agencies. It is also
possible that SSA needs to extend the call center hours or adjust the
size of the team off of predicted call volume. While national centers
have flexible hours outside of the 9-4 window many field offices have
more limited schedules.
Focus on making applications mobile accessible. Among low-
income clients, a mobile phone is a more common way to access the SSDI/
SSI application, compared to other technology. Federal Government data
analytics services suggest nearly 45 percent of users on the SSA site
are using mobile phones to access information. Moving applications for
SSDI and SSI to
mobile-friendly could be a high impact way to improve access.\1\ But
first, SSA should estimate the number of the applications submitted
online and the percent of those submitted from mobile, tablet, and
desktop.
---------------------------------------------------------------------------
\1\ U.S. General Services Administration, ``Social Security
Administration,'' Washington, DC: GPO, 2021, https://analytics.usa.gov/
social-security-administration/ (accessed May 20, 2021).
Reducing the application burden of the SSI Application. The
statistics about how many eligible beneficiaries for SSI never apply
and how many applications are rejected on their first attempt are
astonishing. According to the Center for Budget and Policy Priorities
``of those who complete the 24-page application process for SSI
disability, only about 1 in 4 receive benefits after the initial
application. Another 1 in 10 receive benefits on appeal.\2\'' One place
to start is with the form 8000, the front door to SSI. SSA should run
an assessment of the form 8000 (bringing policy and legal review
together with designers) to understand what questions are mandated in
statute and which can be skipped. Ultimately, the goal should be to
create the leanest application possible, with only the most essential
and mandatory information on the form, as all applicants must undergo
further review regardless. Understanding that the questions that are
frequently left incomplete, answered incorrectly, or require agency
follow-up could provide clues as to where the form needs
simplifications. Advocates report the most challenging factors with the
paper form are the living arrangement section and the confusion that
emerges from having various claimant types (adult/child/couple and
disability/age) all using the same form. The current form is universal
and covers various types of claims, including individual adult, child,
or couple. It also covers claims for SSI based on age. SSA should
consider creating several forms for the different categories of
applicants/users who are likely to need to provide different
information. Currently there are dozens of prompts to skip certain
questions (if not relevant) these irrelevant questions confuse and
overwhelm beneficiaries. Ultimately, online form should allow e-
signatures (with verbal verification), and completion by third-
party.\3\
---------------------------------------------------------------------------
\2\ ``Policy Basics: Supplemental Security Income,'' Center on
Budget and Policy Priorities, updated February 8, 2021, https://
www.cbpp.org/research/social-security/supplemental-security-income.
\3\ SSA SSI Application Workgroup has compiled design improvements
from their experiences working through challenges with beneficiaries.
The best way for SSA to identify meaningful quick win opportunities
and to unblock bottlenecks is by establishing basic data monitoring of
existing benefit services. This is something that should be able to be
done rapidly (in a matter of days or just a few weeks) once SSA has an
end to end picture of how people are using their systems today, it will
be easy to identify high-impact opportunities to improve services.
There are multiple resources throughout the Federal Government that can
help SSA do this rapid review including the U.S. Digital Service, 18F,
and the Federal Consumer Experience Office inside the Office of
---------------------------------------------------------------------------
Management and Budget.
SSA also has tools at its disposal to assess how people use their
site. SSA participates in the Digital Analytics Program,\4\ this allows
agency leaders to see how many people visited each webpage, what device
(e.g., desktop or mobile) they are using, and the ``drop-off'' rate
across pages.\5\ In assessing the current beneficiary journey and
experience, SSA may want to go beyond the website and consider measures
that account for the accessibility of different routes including: call
center effectiveness and application burden. If agency leaders are
seeking key performance indicators to help size up quick areas for
improvement there is a new tool out ``A New Framework for Assessing
Safety Net Delivery.''\6\ This framework could guide a quick assessment
in one or more of these service delivery including:
---------------------------------------------------------------------------
\4\ U.S. General Services Administration, ``Social Security
Administration,'' Washington, DC: GPO, 2021, https://analytics.usa.gov/
social-security-administration/ (accessed May 20, 2021).
\5\ Ibid.
\6\ ``The National Safety Net Scorecard,'' Code for America,
accessed May 20, 2021, https://www.codeforamerica.org/programs/insight-
and-impact/scorecard/the-national-safety-net-scorecard/.
Online accessibility.
Mobile accessibility.
Call center accessibility.
In person.
Application burden.
Question. What particular considerations should these agencies have
for people experiencing disability, homelessness, or other impacts on
their access?
Answer. Agencies should build with these populations in front of
mind. In particular, the digital divide, inconsistent mailing
addresses, forms and processes should be reviewed to consider whether
there are structural barriers baked in preventing the unhoused or
disabled from even reading or accessing or completing the process. A
U.S. Interagency Council on Homelessness (USICH) Federal work group,
established in 2013, was created to analyze SSI/SSDI access among
adults experiencing homelessness and provide guidance to the field on
key strategies for linking eligible adults to benefits their assessment
identified the following barriers:\7\
---------------------------------------------------------------------------
\7\ Key Strategies for Connecting People Experiencing Homelessness
to Supplemental Security Income (SSI) and Social Security Disability
Insurance (SSDI) Benefits, https://www.ssa.gov/homelessness/docs/
Final_Key-Strategies-for-Connecting-People-Experiencing-
Homelessness.pdf.
They often lack required forms of identification and
documentation. Due to their limited access of ongoing health-
care services, people experiencing homelessness often do not
have current or quality medical records that document their
disabilities. The inability to document a disability can be a
major barrier to receiving the SSI or SSDI benefits to which
individuals are otherwise entitled. Individuals experiencing
homelessness may not have a way to receive correspondence by
mail, have limited experience working with computers, or have
limited access to Internet connections to take advantage of
electronic processes. Because of these challenges, many people
experiencing homelessness often do not complete the SSI/SSDI
application process, experience longer application and
processing times, or have their applications denied due to lack
---------------------------------------------------------------------------
of information.
A review of the form 8000 or any application processes should be
done with these populations in mind and be built to allow for service
providers to be the lead contact person or appointed representative.
This or any application or digital programs should conduct usability
testing with the disability community and the unhoused to identify and
address accessibility issues early.\8\
---------------------------------------------------------------------------
\8\ American Association of People with Disabilities, ``Lessons
from COVID-19,'' Medium, published February 26, 2021, https://
medium.com/disability-in-the-time-of-covid-19/lessons-from-covid-19-
1d80f164c539.
Finally, the first step is to make short term improvements in
delivering to those served by SSA today. It is critical that overtime
SSA work to make sure it is effectively serving not those who apply
today, but those who are eligible under the law. SSA must attempt to
answer the question, ``how are we doing reaching the population that is
eligible for SSI and SSDI? This could be through a quick data analysis
of the universe of potentially eligible beneficiaries for these two
programs (i.e., who is eligible to receive benefits under the law) and
who is receiving benefits today. Studies suggest only 8 million
families and individuals received SSI in 2020, a fraction of those
likely eligible. Research suggests that 40-60 percent \9\ of those
eligible for SSI do not apply for benefits. Other studies like that
conducted by the Institute of Medicine \10\ found substantial under-
enrollment among disabled children across a range of mental health
diagnoses. While SSA might want to first focus on improving service
delivery to the beneficiaries they are reaching, it is important to
improve the experience of today's beneficiaries in the context of who
is eligible to receive them.
---------------------------------------------------------------------------
\9\ https://www.jstor.org/stable/pdf/10.7758/
rsf.2018.4.2.04.pdf?refreqid=excelsior%3A1f62275
22f9f53baab2f63f7f2b997d0.
\10\ Committee to Evaluate the Supplemental Security Income
Disability Program for Children with Mental Disorders; Board on the
Health of Select Populations; Board on Children, Youth, and Families;
Institute of Medicine; Division of Behavioral and Social Sciences and
Education; The National Academies of Sciences, Engineering, and
Medicine; Boat TF, Wu JT, editors. Mental Disorders and Disabilities
Among Low-Income Children. (Washington, DC): National Academies Press
(U.S.); October 28, 2015. Available from: https://www.ncbi.nlm.nih.gov/
books/NBK332882/ doi: 10.17226/21780.
Question. It was brought to my attention by a constituent that the
MySSA website is only available from 5 a.m. to 1 a.m. weekdays.
Apparently, the limited hours relate to SSA's legacy systems. The
majority of SSA's production applications and services rely on
mainframe processing. SSA needs to take its systems offline so the
Agency can process the day's transactions (and address maintenance
issues). Your testimony spoke to the need to be able to monitor
applications in real time to see where people get stuck in the process.
It seems that batch processing needs to go in order to provide the
level of analysis you recommend, is that correct?
batch processing and reaching consumers in ``off hours''
Answer. It is not necessarily the case that batch processing needs
to go to serve SSA clients well. When a complex application process is
going to take weeks or months (SSI average wait time is 6-8 months),
overnight batch processing is generally not a big contributor to the
timeline of slowing down the application. It would be helpful if
applicants were still able to see and interact with their application
at all hours, but this can be implemented without eliminating batch
processing, which is much more difficult. There are multiple examples
across the Federal Government where agency systems are mainframe based
and include overnight batch processing but the customer facing
frontends run 24/7.
monitor applications in real time to see where
people get stuck in the process
You don't necessarily need to end batch processing to set up real-
time data monitoring. Instrumenting basic monitoring of existing
services is critical to understanding how people are using your systems
to access the benefit today. The best way for SSA to assess quick wins
and opportunities to unblock bottlenecks is to undertake basic data
monitoring of existing services to understand how people are using your
systems to access the benefit today. This is something that should be
able to be done rapidly (in a matter of days or just a few weeks) once
SSA has an end to end picture of how people are using their systems
today, it will be easy to identify high-impact opportunities to improve
services. There are multiple resources throughout the Federal
Government that can help SSA do this rapid review including the U.S.
Digital Service, 18F, and the Federal Consumer Experience Office inside
the Office of Management and Budget.
SSA also has tools at its disposal to assess how people use their
site. SSA participates in the Digital Analytics Program,\11\ this
allows agency leaders to see how many people visited each webpage, what
device (e.g., desktop or mobile) they are using, and the ``drop-off''
rate across pages.\12\ In assessing the current beneficiary journey and
experience, SSA may want to go beyond the website and consider measures
that account for the accessibility of different routes including: call
center effectiveness and application burden. If agency leaders are
seeking key performance indicators to help size up quick areas for
improvement there is a new tool out ``A New Framework for Assessing
Safety Net Delivery.''\13\ This framework could guide a quick
assessment in one or more of these service delivery including:
---------------------------------------------------------------------------
\11\ U.S. General Services Administration, ``Social Security
Administration,'' Washington, DC: GPO, 2021, https://analytics.usa.gov/
social-security-administration/ (accessed May 20, 2021).
\12\ Ibid.
\13\ ``The National Safety Net Scorecard,'' Code for America,
accessed May 20, 2021, https://www.codeforamerica.org/programs/insight-
and-impact/scorecard/the-national-safety-net-scorecard/.
Online accessibility.
Mobile accessibility.
Call center accessibility.
In person.
Application burden.
Question. Many of SSA systems still rely on COBOL. How does COBOL
hamper SSA's ability to make services work for people? Do you think
monitoring the number of lines of COBOL still in production would be a
useful metric to gage SSA's IT modernization progress?
Answer. COBOL is not the problem.\14\ The agency's use of COBOL
doesn't hamper SSA's ability to work for people. It is possible to
choose one piece of functionality and make it work better for users,
and as needed turn off that function in the mainframe and replace it.
This effort to migrate from a legacy system by gradually replacing
specific pieces of functionality with new applications and services has
worked effectively and has come to be known in IT software management
as ``the strangler pattern.'' This term refers to the strangling and
turning off of the old system's features part by part eventually
allowing it to be decommissioned.\15\
---------------------------------------------------------------------------
\14\ Ben Miller, ``An Apology to COBOL: Maybe Old Technology Isn't
the Real Problem,'' GovTech, published February 25, 2021, https://
www.govtech.com/opinion/an-apology-to-cobol-maybe-old-technology-isnt-
the-real-problem.html.
\15\ Chanaka Fernando, ``How to migrate your on-premise system to
cloud through strangler pattern,'' Solution Architecture Patterns,
published February 4, 2020, https://medium.com/solutions-architecture-
patterns/how-to-migrate-your-on-premise-system-to-cloud-through-
strangler-pattern-2c8ea69ba717.
One note of caution with COBOL is that it is not a functionality
issue as much as it is a human capital challenge. It is difficult to
recruit experts and staff who can program in COBOL. While agencies
build new functionality and turn off pieces of legacy systems, the
Federal Government will still need to rely on COBOL and therefore it is
of critical importance that government's talent and recruitment for use
of COBOL meets the demand. This is a critical interim step as newer
frameworks gradually replace old ones.\16\
---------------------------------------------------------------------------
\16\ Jennifer Pahlka, ``How the Government's Multibillion-Dollar
Plan to Modernize Its Tech Could Go Horribly Wrong,'' OneZero,
published April 19, 2021, https://onezero.medium.com/our-kill-it-with-
fire-moment-f900aaabd743.
Monitoring lines of COBOL would not be a useful metric to gage
SSA's IT modernization progress. The next generation of metrics should
focus on outcome for beneficiaries not on internal metrics about use of
---------------------------------------------------------------------------
certain technologies.
There are other ways beyond mainframe improvements to speed things
for beneficiaries. Beneficiaries aren't just stuck to do legacy
computer systems. Beneficiaries are delayed and stuck due to the
inability to simply call to ask questions about their applications
without wait times and dropped calls. They are stuck due to complex
forms and SSA's work load is such that it takes months for them to
assess disability claims--the application process takes 6 to 8 months
(on average). It is not just the mainframe system slowing things down.
The current system overall designed to make it harder for people to
apply and be approved for benefits.
______
Question Submitted by Hon. Sheldon Whitehouse
Question. According to the Congressional Research Service, in 2020
only 53.5 percent of Social Security disability applications were
submitted online. What recommendations do you have for Congress to help
the SSA increase the share of online applications versus other methods?
Answer. If SSA wants to improve its service it first needs to
understand the different pathways of getting access to SSI and SSDI.
Driving up applications online might not equate to improving processing
and access for beneficiaries. Keep in mind that some beneficiaries may
not be able to use an online service. So it is critical that any
service design contemplates the 10 percent who will not be able to
access this service either due to their circumstances or difficulties
accessing the Internet. The SSA needs to understand how people are
using these benefits today and what the blockers are before determining
whether increasing online applications is the best path forward.
The best way for SSA to assess quick wins and opportunities to
unblock bottlenecks is to undertake basic data monitoring of existing
services to understand how people are using your systems to access the
benefit today. This is something that should be able to be done rapidly
(in a matter of days or just a few weeks) once SSA has an end to end
picture of how people are using their systems today, it will be easy to
identify high-impact opportunities to improve services. There are
multiple resources throughout the Federal Government that can help SSA
do this rapid review including the US Digital Service, 18F, and the
Federal Consumer Experience Office inside the Office of Management and
Budget.
SSA also has tools at its disposal to assess how people use their
site. SSA participates in the Digital Analytics Program,\17\ this
allows agency leaders to see how many people visited each webpage, what
device (e.g., desktop or mobile) they are using, and the ``drop-off''
rate across pages.\18\ In assessing the current beneficiary journey and
experience, SSA may want to go beyond the website and consider measures
that account for the accessibility of different routes including: call
center effectiveness and application burden. If agency leaders are
seeking key performance indicators to help size up quick areas for
improvement there is a new tool out ``A New Framework for Assessing
Safety Net Delivery.''\19\ This framework could guide a quick
assessment in one or more of these service delivery including:
---------------------------------------------------------------------------
\17\ U.S. General Services Administration, ``Social Security
Administration,'' Washington, DC: GPO, 2021, https://analytics.usa.gov/
social-security-administration/ (accessed May 20, 2021).
\18\ Ibid.
\19\ ``The National Safety Net Scorecard,'' Code for America,
accessed May 20, 2021, https://www.codeforamerica.org/programs/insight-
and-impact/scorecard/the-national-safety-net-scorecard/.
Online accessibility.
Mobile accessibility.
Call center accessibility.
In person.
Application burden
______
Question Submitted by Hon. Rob Portman
Question. During my questioning, I discussed how critical it is to
ensure that the Social Security trust funds remain solvent. Can you
discuss the human costs that would occur if we run into a situation
where we reached insolvency and the Social Security Administration were
forced to trim benefits?
Answer. Sixty-five million Americans depend on Social Security, so
any issues of SSA insolvency could impact millions. However the latest
report ``The 2020 Annual Report of the Board of Trustees of the Federal
Old-Age and Survivors Insurance and Federal Disability Insurance Trust
Funds,'' suggests program solvency for many years depending on the
program including that OASO trust fund should be able to pay scheduled
benefits until 2034, the Disability Insurance (DI) trust fund, which
pays disability benefits, will be able to pay scheduled benefits until
2065. While trimming benefits could be devastating to millions of
families, the recent report from the Social Security trustees paints a
different picture.
______
Prepared Statement of Peggy Murphy, Immediate Past President,
National Council of Social Security Management Associations
Chairman Wyden, Ranking Member Crapo, and members of the committee,
my name is Peggy Murphy. In addition to being the immediate past
president of the National Council of Social Security Management
Associations (NCSSMA), I am the District Manager of the Great Falls, MT
Social Security office. On behalf of the National Council, thank you
for the opportunity to be here today to provide our front-line
perspective of the Social Security Administration's service delivery
during the coronavirus (COVID-19) pandemic.
NCSSMA is a professional association of almost 3,000 management
personnel in the field offices and teleservice centers of the Social
Security Administration (SSA). Each day, NCSSMA members directly serve
the American public in over 1,250 of SSA's public-facing offices. For
over 50 years, NCSSMA's mission has been to provide a clear, credible
and valuable perspective on public service from the front lines.
As our country continues to address the ongoing pandemic, we find
ourselves in uncharted territory facing ever-evolving challenges. The
pandemic and its ongoing threat to the health, economic security and
well-being of our Nation have had an unimaginable impact on not only
those seeking assistance from our agency, but also our own staff and
their loved ones. What remains unchanged during these unprecedented
times is that SSA has a critical mission of helping the American
public. The role of the Social Security Administration has never been
more important than it is today.
NCSSMA firmly believes that this is a time when we must not lose
sight of the core mission of the Social Security Administration and,
perhaps even more importantly, the many challenges that the agency
faces in fulfilling that mission.
On Friday, March 17, 2020, the majority of Social Security
employees were informed that effective Monday, March 20, 2020, they
would be teleworking indefinitely and that field offices would be
closed to the public because of the COVID-19 pandemic. The rest were
informed on March 20, 2020, and sent home. This was a colossal
undertaking for the agency given that the majority of employees had
never teleworked, and the agency's telework pilot had ended just a
handful of months before. Within days, the majority of field office
employees and a large number of teleservice center employees were
successfully teleworking. Initial challenges involved lack of equipment
and software licensing as well as data capacity. SSA was able to
increase data capacity and stabilize the network after a few weeks.
Unfortunately, securing the software licensing and headset equipment
for softphones to enable field office employees to answer incoming
public calls and make outgoing calls took longer. Limited quantities of
each were available from the previous telework pilot, but significant
effort was required to quickly acquire and deploy new equipment and
software.
Though field offices were closed to the public, given the nature of
the work SSA does, it was not entirely possible for every field office
employee to telework. Since the beginning, dedicated members of field
office management staff continued to physically come into the office to
handle incoming and outgoing mail, scan tens of thousands of documents
to support those working from home, provide in-person service for
critical cases such as immediate payments, and to handle facility-
related duties. Early on, this situation was manageable because so many
of our customers found themselves in lock-down and dealing with the
impact of COVID-19. In addition, many probably believed that at some
point in the near future, field offices would reopen, and therefore
delayed contacting field offices or calling the teleservice center.
Around 4 months into the pandemic, those customers who delayed
contacting us because they thought our lobbies would reopen, realized
they would not, so they began contacting us in increasing numbers. The
phone queue was our new lobby. While the majority of our services can
be accomplished online or via telephone, one of the ongoing challenges
facing customers has been the need for SSA to see original
documentation in many situations. Customers began mailing more original
documentation, placing an increasing amount of strain on management's
ability to stay current on incoming and outgoing mail. Management also
needed to address significantly delayed mail service which in many
cases resulted in customers searching for their documents. It was an
unsustainable situation that continued to deteriorate as demand
increased. At around the same time, the agency was making plans to
reinstate workloads that had been suspended at the start of the
pandemic and increase the types of services that could be performed in
the office. Yet, there were no plans to increase on-site staffing.
It was not until early fall of 2020 that a very small number of
nonmanagement employees began returning to field offices on a voluntary
and rotational basis to assist with the substantial volume of incoming
and outgoing mail. Staffing numbers did not increase to higher levels
in most locations until late January and early February 2021.
Though comments have been made that employees are more productive
working from home, this is far from accurate. No doubt, many employees
were more productive early on based on the way the agency measures
productivity, meaning that they were able to process more work.
However, they are only able to process more work, because of the
clerical assistance they receive from on-site personnel and the easing
of some programmatic requirements. Prior to the pandemic, individual
employees would have been responsible for printing, mailing and faxing
their own documents. With the time saved from these responsibilities
and the easing of some programmatic requirements, some employees are
able to be more productive, but it is not efficient, and it comes at
the expense of management not being able to manage the operations in
their respective offices.
SSA rarely takes a holistic approach in assessing how long it
actually takes to process work from beginning to end. SSA monitors
numerous workloads, including, but not limited to: claims,
redeterminations (RZs) and continuing disability reviews (CDRs). What
is not necessarily captured effectively is the amount of other work
that SSA staff complete. The agency's current work unit calculations do
not take into account the additional work associated with processing a
specific action. This has been exacerbated by the pandemic where many
workloads now require additional handling and processing time in order
to make the work or action portable for employees to process from home.
The additional handling and time necessary to receive, scan, profile,
assign, and mail documents associated with claims or post-
entitlement actions is not reflected in the overall processing time.
In addition to increasing on-site personnel, SSA has made efforts
to improve public access to facilities and lessen the clerical burden
on field offices. These efforts have included field office drop boxes
and the use of Microsoft Teams to conduct certain enumeration
interviews. The drop box pilot began in late October 2020 and as of
last month was expanded to every field office. If field offices have
available space and a separate vestibule, they can install a drop box
so that customers can drop off required proofs. This greatly reduces
the chances their documents will be lost in the mail. SSA is testing
using Microsoft Teams to conduct enumeration interviews with customers
where customers can use their smartphone or computer to conduct
business face to face. It is hoped that this can be expanded to other
workloads.
Perhaps the biggest challenge field offices faced and will continue
to face in providing service during the pandemic is policies that
mandate face-to-face interactions to process certain workloads and the
need for in-person service for some of our customers. During the
pandemic SSA has relaxed face-to-face requirements for certain
workloads and we recommend that these changes be made permanent. For
the workloads where face-to-face interactions are required, SSA must
find a way to satisfy policy requirements or indeed change such
policies when feasible. A good example is enumeration for non-citizens,
which requires the undue burden of a face-to- face interview. The
incidence of fraud would be low considering that we must verify
information with the Department of Homeland Security. If it is indeed a
significant concern, then all non-citizens should be enumerated at
entry by the U.S. Department of State or the Department of Homeland
Security. While eliminating the requirements for face-to-face service
can be achieved through changes in policy, procedures or legislation,
changing the need for in-person service for some of our customers will
be difficult to achieve. During the pandemic, those individuals who do
not have Internet service, a telephone or easy access to mail service
have not been able to access our services. Even during normal times,
these individuals find it difficult to conduct business with SSA, but
at least they could visit a field office. This is not a viable option
so long as our lobbies remain closed to walk-in service.
While NCSSMA fully supports automation, and the pandemic has
reinforced the need for technology upgrades, there is a compelling need
for ongoing support of SSA's community-based field offices to
adequately serve our most vulnerable customers and those without
technology that would otherwise connect them with SSA. Field offices
provide compassionate service to the most vulnerable members in our
communities including those living in rural and tribal locations.
Employees in local offices live and work in the community and, to SSA
field office visitors, they provide an invaluable lifeline to essential
services. Local field offices make a difference in their communities,
beyond the execution of SSA's mission. Although the agency has engaged
in an historically unprecedented amount of outreach to vulnerable
populations by partnering with advocacy and support groups during the
pandemic, the fact is that many community organizations and third-party
sites that SSA relies on to connect our underserved populations with us
have also been closed. This includes Indian Health Services, homeless
shelters and other community advocate centers. Field offices that
relied heavily on video service connections with third-party sites have
been dormant during the pandemic. Coupling limited staffing in field
offices with the closure of most third-party sites, connecting
customers in our rural and tribal locations has been difficult.
The Social Security Administration upholds a high standard of
superior customer service and maintains this through the employees who
work in field offices. The coronavirus pandemic has emphasized how
critical it is for SSA to continue to transition as an agency and
embrace automation, technology and self-help tools such as Internet
claims, online enumeration and telework for employees. SSA must provide
additional ways for the public to access our services. Even with the
shift to more online services, field offices and their employees are
necessary to process much of the backend work on complex online cases
including Supplemental Security Income (SSI), and to serve our
customers who do not have access to the telephone or Internet.
SSA's computer systems face fundamental challenges. Some of SSA's
core programs still rely on COBOL systems that are well over 40 years
old. Although some databases have been converted to a more modern and
flexible platform, SSA must continue to modernize its computer language
and database infrastructure, including moving its data to the cloud. It
is critical that we focus on these efforts to reduce the risk of
cyberattacks, service disruptions and reduced system performance and
production.
It is also critical that we continue to advance SSA's IT
modernization plan while maintaining an appropriate balance between the
service delivery options available to the public. NCSSMA members
nationwide are interested and willing to play an active role in
development, testing and deployment of enhancements to existing systems
in addition to new technology and programs. Our position on the front
lines provides us with the best vantage point to offer assistance. We
continue to encourage agency leadership to include managers and
employees on the front lines in all aspects of software development and
policy implementation. The challenges of the pandemic have only
emphasized the need to include front-line experience and perspective to
these efforts.
NCSSMA strongly supports SSA IT modernization. Dedicated funding is
needed for IT investments to modernize systems to the standards the
administration, Congress and the public expect. From our perspective,
SSA needs to address four specific areas: modernize core agency
applications; improve SSA's telephone system and associated management
information; implement national scanning and remote printing; and
implement technologies that will assist our more vulnerable
populations, including the deaf and hard-of-hearing community, non-
English-speaking customers, the homeless, and those who live in rural
and tribal locations.
Modernize Core Agency Applications
Improve SSA's appointment and check-in system to
allow for online appointment scheduling.
Modernize both the Supplemental Security Income
(TXVI), and the Retirement, Disability and Medicare (TII and TXVIII)
claims processing systems utilizing a single claims-taking platform.
Modernize the electronic Representative Payee
System (eRPS) to both process and oversee the administration of SSA
representative payees.
Modernize the Electronic Disability Collect System
(EDCS) to integrate the disability analysis process in the overall
claims process. This includes eliminating all exclusions to the
electronic file and the ability to file all appeals online.
Work with the Department of Interior to modernize
SSA's payroll system, Web Time and Attendance (WebTA).
Modernize and consolidate all management
information (MI) data into a single, user-friendly platform that
managers can use to control and measure work production.
In October 2020, the agency was able to make the
SSA-455 CDR mailer available online that Wilkes-Barre mails, but the
agency has not yet made the SSA-454 that field offices utilize
available for online access. All medical CDR forms should be available
online.
SSA's Telephone System
Ensure SSA moves forward expeditiously with a new
comprehensive telephone system in order to provide consistency among
the national 800 number, field offices and all other SSA components.
Improve management information for assessing call
volume, levels of customer service, and the overall customer
experience.
National Scanning and Remote Printing
Implement dedicated scanning facilities where
members of the public can send by mail, email, or facsimile, documents
to a central location for scanning, profiling, and assigning.
Implement a comprehensive remote printing
initiative to direct all field office print traffic to one or more
centralized locations for mailing.
Expand the use of electronic notices behind the my
Social Security portal.
Technology to Meet the Needs of Our Vulnerable Populations and
Reduce Field Office Contacts
Implement alternative service methods that may
include expanded video and video service delivery third-party contracts
in rural locations.
Make stand-alone, self-service kiosks available in
locations where the public is already conducting business with other
State and local government agencies.
Provide enumeration at entry for all immigrants.
This would eliminate the need for immigrants to visit SSA field
offices.
Expand the use of the American Association of Motor
Vehicle Administration (AAMVA) verification process to include all 50
States. Allow verification of driver's licenses and State-issued
identification via AAMVA for all enumeration activities that would
normally require the technician to view the original document. This
process is already in use with those States covered under Internet
Social Security Replacement Cards online (iSSNRC). This would allow the
agency to explore initiatives to provide replacement Social Security
cards over video and enhance the current MS Teams enumeration pilot.
Expand the use of verification methods through the
Department of Homeland Security (DHS) and U.S. Department of State in
order to further verify foreign documents and U.S. passports for
enumeration purposes. This would allow the agency to issue replacement
Social Security cards over video and enhance the current MS Teams
enumeration pilot.
Expand the use of the Social Security Electronic
Remittance System (SERS) to include processing of all remittance types.
This will reduce the time it takes to credit a remittance to a
customer's account and eliminate the need to involve the remittance
unit in the processing centers.
Require members of the public to report wages using
current electronic wage-reporting technology. This includes allowing
the public to submit wage stubs electronically through my Social
Security. This would provide a significant reduction in paper
processing in field offices and virtually eliminate the need to copy,
scan, profile, and mail pay stubs.
We understand modernizing SSA's computer systems is costly and will
take time. The path established by the Commissioner and his team
relative to IT modernization was making progress in this area, and
while the pandemic has resulted in some shifts to address current
needs, we must continue to address these challenges.
In addition to IT modernization, NCSSMA believes it is critically
important that changes be made to the Social Security and SSI programs
that have the potential to increase administrative efficiency, decrease
operational costs, and ultimately provide better service to our
customers. It is unfortunate that a pandemic has reinforced the need
for streamlined and updated policies that better serve the public and
make it easier for the agency to administer. The pandemic and the
service delivery challenges associated with current policies and
business practices in place certainly emphasize the need for change. We
suggest the following:
Eliminate the Need for the Social Security Number Card. This
would reduce Social Security number fraud, significantly reduce in-
office traffic and telephone calls and allow for the closure of Social
Security number card centers so that employees could be redeployed to
field offices, which would reduce SSA's real estate footprint and save
money. In addition, as stated above, expand enumeration at entry, DHS
interfaces, and AAMVA verification in order to enhance and support
initiatives to obtain original Social Security numbers without the need
to visit a field office. This would allow field offices to focus on
customers with more complex issues that do not lend themselves to
online or telephone service.
Simplify Disability Work Incentives and Pursue Early
Intervention Measures once a beneficiary is on the rolls. This would
reduce the number of disability beneficiaries, minimize time developing
complex issues, increase public understanding of work incentives, and
return more beneficiaries to work. Early invention measures, such as
supportive employment services and targeted incentives for employers to
help disabled workers remain on the job, have the potential to achieve
long-term gains in employment.
Supplemental Security Income (SSI) Program Simplification in
order to improve the efficiency of program administration and yield
savings to the American taxpayer. Continuous policy changes regarding
resources, income and living arrangements make it difficult to
administer the SSI program and ensure accuracy of payments. With
growing agency workloads and diminished resources, the following SSI
policy simplifications are recommended:
Revise SSI Living Arrangements (LA) and In-kind
Support and Maintenance (ISM) Rules to eliminate administrative
complexity and a source of payment errors. Reducing the myriad of
living arrangement situations would eliminate complex development and
save administrative costs, while still providing a support mechanism
for SSI recipients.
Change SSI Retrospective Monthly Accounting (RMA)
Rules Regarding Prisoners allowing a beneficiary recently released from
jail to collect SSI benefits until Social Security benefits are
reinstated. This is a labor-
intensive workload with little benefit. Changes would save
administrative costs.
Eliminate the Dedicated Account and Installment
Payment Provisions in SSI to reduce administrative complexity. The
first provision requires underpayments paid to SSI disabled children be
set aside in a dedicated account for use on only approved expenditures.
The second provision requires that underpayments in excess of three
times the Federal benefit rate be released in no more than three
installments. Eliminating these provisions will improve administration
and management of money for SSI recipients.
Eliminate SSI Holding Out Provisions for
individuals who hold themselves out to be husband and wife to be
considered a couple, the same as if legally married. The holding out
provision, which also applies to same sex couples, is a carry-over from
pre-1970 State welfare laws. It adds unnecessary complexity to SSI
cases, and leads to unequal treatment of applicants in similar
situations. Elimination would save administrative costs.
Simplify Workers' Compensation (WC) and Public Disability
Benefit (PDB) Offset through legislation to simplify WC and PDB offset
computation by providing a flat benefit reduction would simplify the
complex calculations now required to apply the offset and significantly
reduce SSA's need to continually monitor the worker's receipt of, and
fluctuations in, the number of WC/PDB payments. Replacing the existing
complicated offset calculation with a uniform offset, would realize
administrative savings without a significant impact on beneficiary
payments.
Much of what we have discussed can be accomplished, but it requires
resources. SSA must have consistent and adequate funding to ensure the
American public receives the services for which they have paid for,
expect and deserve. Our hope is that the Fiscal Year (FY) 2022
appropriations process will result in no less than the President's
budget request of $14.2 billion for SSA. Resource allocations in FY
2022 must be sufficient to improve the timely processing of disability
claims, expand outreach to vulnerable populations, and ensure that SSA
makes the correct payments to those who qualify while maintaining
program integrity work. Resources are also necessary to advance SSA's
ongoing IT modernization project that will significantly enhance the
agency's systems and improve productivity, while at the same time
increasing the accessibility of benefits for seniors and people with
disabilities.
Our customers deserve improved telephone and online services, while
still being able to request timely and safe in-person service. Our
offices must continue to have the resources and staff necessary to
address additional workloads and responsibilities. The President's FY
2022 budget request provides $895 million in additional funding to
provide better services at SSA's field offices, teleservice centers,
and State disability determination services. Perhaps consideration
should be given to multi-year funding for critical systems investments
and expenditures. This would ensure that adequate planning could be
completed for service delivery improvements.
SSA must also continue to address critical stewardship workloads
that save billions of dollars for taxpayers. It is imperative that the
workers and taxpayers who have paid trillions of dollars in FICA taxes
to the trust funds have access to all the necessary services that they
have paid for and receive timely benefit payments. The President's FY
2022 budget request includes $1.9 billion for dedicated program
integrity activities, including a $283 million increase above the FY
2021 enacted level. The definition of program integrity funding should
be expanded to include critical systems investments and expenditures
that facilitate completion of program integrity initiatives.
From the beginning of the pandemic, the Commissioner and agency
leadership have placed customer service at the forefront and every
effort has been made for SSA to provide a full range of services to the
American public. Management and employees have continued to provide the
highest quality of compassionate service possible during these
difficult times. Though the pandemic has changed this agency and the
customers we serve, we should take this opportunity to reassess the
customer experience and what it means to provide world class customer
service. This is a moment for SSA to redefine itself, its mission and
its place in the public sphere and finally move into the 21st century.
On behalf of the National Council of Social Security Management
Associations, thank you again for the opportunity to be here today to
provide our front-line perspective of the Social Security
Administration's service delivery during the coronavirus pandemic.
National Council members are not only dedicated Social Security
employees, but are also personally committed to the mission of the
agency, providing the best service possible to your constituents. We
want to ensure the American public benefits from the lessons learned
during these unprecedented times. We respectfully ask that you consider
our comments and appreciate any assistance you can provide in ensuring
the American public receives the critical and necessary service they
deserve from the Social Security Administration.
______
Questions Submitted for the Record to Peggy Murphy
Questions Submitted by Hon. Ron Wyden
Question. You stated in your testimony that a lot of the
``nonportable work'' involves the U.S. mail--both opening the mail and
printing documents then stuffing envelopes. You mentioned that a
``comprehensive remote printing initiative'' should be developed. That
seems like a good idea, especially when everyone is working remotely.
Can you tell us more about how that would speed up service and reduce
the need for people to be in the office?
Answer. While many of SSA's notices are automated and are mailed
from a centralized location, field offices are responsible for manual
notices, claims-related material such as receipts, numerous forms,
appointment letters, and letters requesting proofs. The majority of
these lend themselves to centralized printing, though the option to
print in the field office should remain for situations where proofs are
needed. In February 2021, NCSSMA was able to provide feedback to the
agency and propose a phased approach to centralized printing. One of
the difficulties in implementing centralized printing is that SSA has
numerous programs that can print, and these programs use different
methods to route print traffic. Unfortunately, there is no single
solution to address this issue. Prior to the pandemic, employees were
responsible for mailing or providing these documents directly to
customers. Mailing of these documents takes time away from other, often
higher priority, work. Managers and the limited number of bargaining
unit employees who are physically in the field offices now find
themselves mailing all documents that in many cases would have been
provided directly to the customer during an in-office visit. Field
office personnel must now balance the incoming mail with the outgoing
mail, both of which take up most of the workday. As a result, managers
are not able to dedicate time to manage other work and employees are
not able to process higher priority work. Reducing this burden would
decrease the number of on-site staff needed to process this workload.
Centralized printing capabilities and employees assigned to this
initiative would ensure that printed materials are mailed daily. This
is not always possible in the current field environment.
Question. In your testimony you recommended eliminating the Social
Security card. Times have changed. Employers can now use E-verify or
other systems to check names and numbers. Can you tell us more about
why NCSSMA recommends this change?
Answer. The purpose of the Social Security number (SSN) is to tie
earnings to the Social Security number holder. It was not intended for
any other purpose. However, over time the SSN and the Social Security
card have been used by numerous other entities, such as financial
institutions, medical providers and even States to identify an
individual for reasons at odds with the SSN's intent. This was done as
a matter of convenience, but this contributes greatly to identity theft
and serves no purpose as far as the Social Security Act is concerned.
Eliminating the Social Security card and its associated workload would
allow field offices to redirect resources to address other workloads.
Question. Do you feel field offices were adequately staffed pre-
pandemic?
Answer. No. Our field offices have been severely understaffed for
many years. Though technology improvements have helped mitigate some
staffing shortfalls, the fact remains that employees are needed to
process the work. The primary reason SSA cannot provide timely service
on most workloads is due to inadequate staffing.
Question. Do you feel field offices are adequately staffed now?
Answer. No. We have even fewer staff now than we did at the start
of the pandemic and though some of the workload numbers have decreased
such as claims, it now takes more time to process many of the workloads
we have because of the need to scan everything into an electronic
system to transfer to technicians to work from home.
Question. What resources do you need now to continue working under
your current posture with limited on-site personnel?
Answer. We need more centralized printing and mailing capabilities,
program simplification and the elimination of the paper Social Security
number (SSN) card. We also recommend the elimination of the SSN for any
purpose other than its original intent. If SSA had electronic
interfaces with every bank, insurance company and wage provider, we
could more easily verify eligibility for Supplemental Security Income
(SSI) and Social Security Disability. We also need enumeration at entry
for all non-citizens.
Question. Do you feel SSA has done all it can to ensure the safety
of the public? Safety of employees?
Answer. Regarding the safety of the public, yes. Regarding the
safety of employees, sending employees home was the best thing to do to
ensure their safety. Unfortunately, that option was not available to
field office managers. While the majority of SSA's bargaining unit
employees were teleworking, field office managers were physically in
the office every day. Some had concerns for their own health and safety
and that of their families, but came in daily to serve the public and
continue agency operations. This is not a sustainable model for
customer service.
Question. What IT enhancement do you need now to help alleviate the
stresses on applicants and field offices employees?
Answer. Adding more online options would provide the public with
greater flexibility in how they do business with the agency. The
following claims should be available online: Supplemental Security
Income (SSI), Disability for everyone, SSI Aged, Lump Sum Death
Payments (LSDP), children's claims, widow(er) claims, mother with child
in care claims, Medicare for those already drawing, retirement claims,
spouse's claims when filing after the number holder. The agency needs
one integrated claims-taking system on the employee side. SSA is
working towards that goal, but we needed it years ago. Dedicated self-
help PCs at third-party sites such as senior centers, State offices and
hospitals.
______
Question Submitted by Hon. Maria Cantwell
broadband
Question. The COVID-19 pandemic has forced us to rethink
longstanding systems, including the delivery of Social Security
benefits. Over the past year, the Social Security Administration (SSA)
has worked to transition services to their online platform. While
accessing services online instead of in-person may be more convenient
for some, it is important to remember that millions of Americans around
the country still do not have access to reliable Internet and millions
more find it difficult to pay the monthly cost of broadband service.
Beneficiaries have been left to navigate the complex system of
applying for benefits and submitting appeals online reduced assistance
from SSA due to the closure of field offices and long wait times for
phone calls. I have heard from constituents who waited on hold for 5
hours to verify a document scanned and sent to SSA. We must work to
ensure that the SSA has the adequate technology to handle online
services and that more people in rural and underserved areas have
access to reliable, affordable broadband connections.
What are the unique technological challenges that the regional
offices face when providing online services for people living in rural
or underserved areas? What considerations should SSA take to address
any gaps in technology and reliable broadband?
Answer. SSA should use available agency data and data from reliable
third-party sites such as broadbandnow.com to target areas with low my
Social Security participation rates, but widespread broadband
availability. Many rural areas have fiber broadband availability. SSA
should also consider locating self-help computers/kiosks in places
where our customers already frequent such as senior centers, State
government offices, libraries and hospitals. While some customers do
not have Internet or phone service, many of our customers without in-
home Internet service do have smart phones and therefore access to the
Internet through cellular data. SSA should ensure that all online
services are optimized for mobile phones. In addition, consideration
should be given to providing free Wi-Fi to customers in field offices.
The Wi-Fi should also be accessible in field office parking lots where
feasible.
______
Questions Submitted by Hon. Mike Crapo
Question. Your testimony identifies that:
[T]he Commissioner and agency leadership have placed customer
service at the forefront and every effort has been made for SSA
to provide a full range of services to the American public.
Management and employees have continued to provide the highest
quality of compassionate service possible during these
difficult times.
The Commissioner and agency leadership, by appearance and evidence,
have continued their focus on service delivery to beneficiaries, and
that focus has grown even sharper in response to the shock of the
pandemic, including attention to providing service to at-risk
populations. How has communication been with SSA's leadership during
the pandemic, including with your co-panelist Ms. Grace Kim and her
operations team?
Answer. SSA leadership has maintained open communication with
NCSSMA. In addition to ongoing communication, NCSSMA has had several
formal meetings with the Commissioner, Ms. Grace Kim, and components
within DCO.
Question. It currently appears that the overwhelming majority of
SSA staff in the office presently are volunteers. Please identify how
SSA is able to find an adequate number of volunteers, and how the
agency has communicated with and safely brought in the very small
number of non-volunteers that have been needed.
Answer. SSA employees are committed to customer service, and many
of them have volunteered to come into the office to assist management
with non-portable workloads.
Unfortunately, some offices have limited to no volunteers and have
been restricted from bringing in non-volunteer bargaining unit
employees. Some employees do not volunteer for various reasons, but one
primary reason is the time they spend in the office addressing mail, is
time they do not have to process their claims workloads. The same is
true for management as they are spending the majority of time on
clerical duties and are often unable to keep up with their own
management workloads. SSA should institute a measured and comprehensive
approach to adequately staff all field offices both during and after
the pandemic.
Question. Testimony for the hearing has addressed the importance of
fully funding SSA's program integrity activities. For FY 2022, the
President has requested $1.9 billion for these activities, marking a
$283-million increase over the FY 2021 enacted level. Please elaborate
on how program integrity activities ensure beneficiaries are well-
served and while safeguarding taxpayer resources.
Answer. Program integrity activities ensure that beneficiaries
receive the correct payment. Program integrity initiatives save
taxpayer dollars and contribute to reducing the Federal budget and
deficit. SSA's current estimates indicate that medical CDRs conducted
in FY 2020 yielded a return of investment (ROI) of about $8 on average
per $1 budgeted for program integrity funding, including Old-Age,
Survivors, and Disability Insurance (OASDI), SSI, Medicare and Medicaid
program effects. SSA estimates also indicate, in the same fiscal year,
that non-medical redeterminations will yield a ROI of about $3 on
average of net Federal program savings over 10 years per $1 budgeted
for dedicated program integrity funding, including SSI and Medicaid
program effects.
______
Questions Submitted by Hon. Chuck Grassley
Question. Scam artists often use an emergency that disrupts normal
practices and procedures to their advantage. I've received a number of
reports from my constituents that they have received fraudulent phone
calls and letters claiming their benefits were in danger due to the
closure of Social Security offices. Could you speak to what types of
scams you have seen using the pandemic and recent changes in procedures
to prey on vulnerable seniors?
Answer. The scams are constantly evolving. Some of the more common
telephone scams: your SSN has been used in a crime; there is a warrant
for your arrest because your SSN was misused; your Social Security
account has been frozen; your SSN is being retired; your SSN has been
stolen. Regarding what SSA is doing to alert seniors of potential scams
and how to avoid being defrauded: SSA has a banner with a link to more
information on the agency's home page concerning scams. There is also a
link to report scams to the Office of Inspector General (OIG).
Employees also have access to various materials concerning fraud that
can be mailed or emailed to customers.
Question. Your written testimony addressed the importance of fully
funding SSA's program integrity activities. Would you please elaborate
on how program integrity activities ensure beneficiaries are well-
served while safeguarding taxpayer resources?
Answer. SSA's current estimates indicate that medical CDRs
conducted in FY 2020 yielded a return of investment (ROI) of about $8
on average per $1 budgeted for program integrity funding, including
Old-Age, Survivors, and Disability Insurance (OASDI), SSI, Medicare,
and Medicaid program effects. SSA estimates also indicate, in the same
fiscal year, that non-medical redeterminations will yield a ROI of
about $3 on average of net Federal program savings over 10 years per $1
budgeted for dedicated program integrity funding, including SSI and
Medicaid program effects.
______
Questions Submitted by Hon Rob Portman
Question. During my questioning, we discussed the additional $283
million for FY 2021 over FY 2020 enacted levels for program integrity
activities. I said that I would follow up with you on the return on
investment that would be yielded from such an increase. Could you
clarify what the return on investment would be of this additional $283
million?
Answer. Our estimates are based on SSA's numbers. SSA's current
estimates indicate that medical CDRs conducted in FY 2020 yielded a
return of investment (ROI) of about $8 on average per $1 budgeted for
program integrity funding, including Old-Age, Survivors, and Disability
Insurance (OASDI), SSI, Medicare, and Medicaid program effects. SSA
estimates also indicate, in the same fiscal year, that non-
medical redeterminations will yield a ROI of about $3 on average of net
Federal program savings over 10 years per $1 budgeted for dedicated
program integrity funding, including SSI and Medicaid program effects.
Question. During my questioning, I discussed how critical it is to
ensure that the Social Security trust funds remain solvent. Can you
discuss the human costs that would occur if we run into a situation
where we reached insolvency and the Social Security Administration were
forced to trim benefits?
Answer. NCSSMA does not take a position or comment on program
solvency as it falls beyond the scope of our mission and ability to
enact any change.
______
Questions Submitted by Hon. Todd Young
Question. Over the course of the pandemic, thousands of SSA
employees across the Nation have voluntarily elected to return to the
office in order to assist in handling mail, processing key documents,
and the other duties that are vital to the delivery of SSA's services.
Could you please describe the overall morale of SSA staff?
Answer. Overall morale for field office managers is low. The
burdens and added responsibilities placed on managers are now at 15
months and counting. Managers have very little time to manage despite
the assistance many are receiving from volunteer bargaining unit
employees. For employees at home, many love teleworking, but just as
many want to return to the office. Some employees feel isolated at home
and are ready to see their customers and coworkers again.
Question. What ways have staff in offices across the Nation stepped
up to address these unique challenges in the past year?
Answer. Managers in field office have been responsible for
fulfilling management responsibilities in addition to serving as the
mail clerk and support staff for the majority of the offices'
administrative tasks. Processing the mail in an SSA office is very
cumbersome due to the volume and the agency did not have a precedent to
follow to establish a system that would work efficiently and be
sustainable. Because employees cannot print at home, every claim they
take must be printed in the office, management retrieves those claims
and mails every document to customers. This can take several hours each
day. In addition, every piece of mail that arrives must be opened,
stamped, and scanned into SSA's system, and is then distributed
electronically to the employees. All of the outgoing mail must be
placed in envelopes, weighed, and metered, another time-consuming task.
And finally, managers must take care of the dire need customers in the
field offices who require a face-to-face visit. Developing an internal
process in each of our offices to make this happen was a phenomenal
undertaking. The commitment to keeping operations moving has been
inspiring. Managers have made use of virtual staff meetings to stay in
touch with employees for performance reviews, conversations, and staff
meetings. While these efforts have been noteworthy and the unique
challenges associated with the pandemic were addressed, this model is
not sustainable.
______
Prepared Statement of Hon. Ron Wyden,
a U.S. Senator From Oregon
This morning the Finance Committee meets to discuss ways to improve
Social Security after a difficult pandemic year. The employees at SSA
have worked hard to get payments out on time while undergoing big
changes to the way the agency operates. Despite that, the reality is,
social distancing and Social Security go together like water and oil.
The Social Security Administration has tens of thousands of
employees and 1,500 field offices dotted around the country. Sixteen of
those offices and more than 500 employees serve Oregon alone. It takes
a lot of hard work to uphold the promise of Social Security, and that
work often looks awfully old-school: face-to-face interaction and a lot
of paper documents.
SSA closed its field offices when the country went into lock-down.
That's because gathering seniors and people with disabilities in
confined offices would have been the worst imaginable idea 12 months
ago. SSA also needed to protect its own employees. But the fact is, the
level of service dipped when SSA's old-school approach no longer worked
during the pandemic.
Being cut off from face-to-face service is hardest on the people
who rely the most on Social Security, including seniors and individuals
with very modest incomes who may not have Internet access. The number
of new applications for certain types of Social Security benefits
plummeted during the pandemic. There's an extra layer of difficulty
coming between a lot of Americans and Social Security benefits they're
eligible to receive.
With fewer employees working in person, work that cannot be handled
remotely, such as handling mail or verifying documents, has piled up.
SSA's ability to process applications and other important data has
slowed. Some Americans have been asked to put their most sensitive
personal documents in the mail, including drivers' licenses and birth
certificates. That would have been an unattractive prospect to a lot of
people even before Louis DeJoy arrived at the postal service.
These days, particularly because of the pandemic, the big challenge
facing SSA is reaching people who are unable or prefer not to deal with
the government online. In the future, SSA could face the opposite
challenge. More people will want to interact with Social Security
through a smartphone or a computer, and the face-to-face approach may
be less common.
When you talk about changing business as usual at Social Security,
it's not just a question of responding to the pandemic. There are big
challenges ahead. This committee and the Social Security Administration
need to explore new ways of meeting the needs of Americans to provide
the benefits they've earned, need, and deserve. Making smart
improvements to Social Security based on the experience of COVID-19
will pay off in the future in a big way.
All of these issues fall under the far-out, revolutionary agenda I
like to call ``making the government work better.'' That's never been
more important than when you're talking about Social Security. For me,
this hard work goes back to my days as the co-director of the Oregon
Gray Panthers, which was an advocacy organization for seniors in my
home State. In the course of that job, I visited with a lot of seniors
who were walking an economic tightrope every day, barely able to cover
the bills.
Social Security was a life-saver for them. Far too many of today's
seniors are still going through that kind of hardship, and it's made
even more difficult by a global pandemic and a year of isolation. So
this committee must maintain our commitment to upholding the promise of
Social Security.
I'm pleased the committee has this opportunity to discuss improving
access to the benefits and services provided by Social Security today.
We have an excellent witness panel, and I thank them all for their
thoughtful testimony.
______
Communications
----------
AARP
601 E Street, NW
Washington, DC 20049
(202) 434-2277
https://www.aarp.org
Introduction
On behalf of our 38 million members and all older Americans nationwide,
AARP would like to thank Chairman Wyden, Ranking Member Crapo and the
members of the Finance Committee for holding this important hearing on
``Social Security During COVID: How the Pandemic Hampered Access to
Benefits and Strategies for Improving Service Delivery.'' We appreciate
the committee's efforts to better understand the impact the pandemic
had on the Social Security Administration's (SSA) service delivery to
its customers. We also thank the committee for examining potential
reforms and additional resources that SSA may need in order to better
ensure millions of older Americans, those with disabilities and those
who are at-risk can effectively access vital benefits and services.
The Importance of Social Security Administered Benefits and Services
According to SSA, an estimated 178 million Americans paid into Social
Security in 2019, and in March 2021, Social Security provided critical
retirement, disability and survivor benefits to almost 65 million
individuals. This included over 49 million retirees, almost 10 million
Americans with disabilities, and their respective families.\1\ In 2019,
SSA administered over $1 trillion in Social Security benefits to the
American people. SSA also administers the Supplemental Security Income
(SSI) program, which provides monthly cash benefits to about 7.8
million older adults, individuals who are blind, or people with
disabilities, and who have very low incomes and resources.\2\
---------------------------------------------------------------------------
\1\ Social Security Administration, Monthly Statistical Snapshot,
March 2021, https://www.ssa.gov/policy/docs/quickfacts/stat_snapshot/.
\2\ Ibid.
For most Americans, Social Security is the only inflation-protected,
guaranteed source of retirement income they have or will have. Despite
its critical importance, Social Security's earned benefits are modest,
and in March 2021, averaged only about $1,550 per month for all retired
workers. Disability benefits are even more modest, averaging about
$1,280 per month.\3\ Nonetheless, Social Security keeps approximately
15 million older Americans out of poverty \4\ and allows millions more
to live their retirement years independently, without fear of outliving
their income. For those receiving SSI, their modest benefits are
crucial given their circumstances, averaging only $586 per month.\5\
---------------------------------------------------------------------------
\3\ Ibid.
\4\ Center on Budget and Policy Priorities, Kathleen Romig, Social
Security Lifts More Americans Above Poverty Than Any Other Program,
February 2020, Table 2, https://www.cbpp.org/research/social-security/
social-security-lifts-more-americans-above-poverty-then-any-other-
program.
\5\ Ibid.
In addition to administering benefits, SSA also provides a substantial
array of services to current and future beneficiaries, businesses, and
the general public, primarily to keep its programs running smoothly.
These services include, but are not limited to: helping individuals
apply for retirement, disability, and SSI benefits; administering the
disability appeals process; enrolling eligible individuals in Medicare;
paying death benefits; managing the Representative Payee program;
verifying names and Social Security Numbers; replacing lost Social
Security and Medicare cards; and managing reported wages from
employers.
The Impact of COVID-19 on SSA Service to the Public
SSA primarily provides services to individuals at their 1,230 field
offices throughout the country, via their online My Social Security
Account, and through a national 800 number. In March 2020, however, SSA
announced it would be suspending in-person, face-to-face services at
local field offices in order to prevent the spread of COVID-19 and
protect the health and well-being of their customers and staff.
In FY 2019, prior to the pandemic, an estimated 43 million people
visited a Social Security office.\6\ Without this option, SSA has
primarily leveraged its online and phone services, while providing
limited face-to-face interactions for those in dire need circumstances.
AARP supported SSA's decision to temporarily close its field offices,
which continues to this day, and we applaud SSA employees for their
commitment to serving the public as many transitioned to and remain
teleworking.
---------------------------------------------------------------------------
\6\ AARP.org, ``Closed Social Security Offices Hinder Applying for
Supplemental Security Income,'' Sharon Jayson, March 26, 2021, https://
www.aarp.org/retirement/social-security/info-2021/closed-offices-
impact-ssi-applicants.html.
The closure of SSA field offices has, however, assuredly hindered
service delivery for some individuals. The impact of these changes has
likely been most acute for at-risk populations who need assistance with
applications and other services. AARP remains especially concerned
about these populations who may typically require or benefit from face-
to-face interactions with SSA to receive critical services, including
---------------------------------------------------------------------------
SSI.
In addition, many older Americans, those who live in rural communities,
or those with low incomes may not have access to a computer or the
Internet, or lack comfort with navigating online platforms like My
Social Security in order to receive services. Some simply prefer
speaking with a real person, either face-to-face or on the phone,
especially when dealing with something as important as their Social
Security benefits. While these individuals may have turned to SSA's
phone lines during the pandemic, they likely experienced busy signals,
as well as increased call volumes and wait times that made it more
challenging to get the services they needed, especially when using
SSA's national 800 number. Finally, the lack of face-to-face service
availability has led to a troubling situation where some individuals
must mail or drop off sensitive original documents such as birth
certificates or drivers licenses. Many are understandably reluctant to
do so.
The Importance of Personal Interactions and Other Recommendations
Once again, AARP applauds the agency and its staff for their ability to
pivot to remote work, and we appreciate the dual challenge of both
serving the public and protecting the workforce during the pandemic. We
also appreciate that employees at field offices around the country
continued to go into work to process files, open, scan, and send mail,
attend the fax machines and provide valuable face-to-face services for
those in serious need.
We recognize that, over the first year-plus of the pandemic, limiting
face-to-face interactions was a necessary reality. As more people are
immunized against COVID-19 and more safety measures are implemented,
however, AARP looks forward to a time when these offices can be safely
reopened to the public. SSA should consider the need to prepare for a
possible surge in applications and other service requests when field
offices are reopened.
We also believe SSA should focus additional resources, which Congress
will need to provide, toward its phone services, both at local field
offices and the national 800 number. Even after field offices reopen,
SSA phone services provide the personal interaction that many customers
prefer and need. AARP appreciates that SSA provided teleworking
employees with the technology to answer phone calls during the
pandemic. We also appreciate that SSA made public local field office
numbers that were not previously available. In June 2020, ``SSA's field
offices and national 800 number received 30 percent more calls than
June 2019, with field offices receiving most of the additional
calls.''\7\ Despite this increase in volume, callers to field offices
received fewer busy messages and shorter wait times. Callers to the
national 800 number also experienced fewer busy signals, partly due to
reduced hours, but waited longer for service.\8\ SSA should seek to
build on the phone service improvements made thanks to local field
offices while improving performance at the national 800 number.
---------------------------------------------------------------------------
\7\ Social Security Administration, Office of the Inspector
General, Congressional Response Report, ``The Social Security
Administration's Telephone Services During June 2020,'' April 2021,
https://oig.ssa.gov/audit-reports/2021-04-08-audits-and-investigations-
audit-reports-A-05-20-
50998/.
\8\ Ibid.
AARP also appreciates the steps the agency has taken to reach
vulnerable populations through mailings--including plans to send an
additional 1.2 million letters to those who may be eligible for SSI--
and partnerships with other social services groups. SSA should continue
to place particular emphasis on this work. To the extent that SSA can
publicize these partner organizations to ease the burden on those
seeking services, we believe this would be a worthwhile step. We also
note that mailers alone will not be sufficient to reach all potential
SSI beneficiaries, and the process of applying for SSI is still a very
cumbersome endeavor. We encourage SSA to potentially expand its
national communications campaign designed to raise awareness of SSI and
disability programs and encourage people to apply. And we also
encourage SSA to work to streamline SSI and other application processes
---------------------------------------------------------------------------
and make them more user-friendly.
AARP is also hopeful to learn about the pending expansion of express
interview options for those who want in-person services. We would
encourage SSA to incorporate more identity verification options as part
of this process in lieu of requiring people to send or drop off
critical identifying documents. Given the importance of these documents
to individuals and the ongoing challenges with the postal service,
sending such sensitive information through the mail should be
discouraged.
The Importance of Administrative Funding for SSA
SSA continues to face significant administrative challenges, largely
due to demographics and chronic underfunding. AARP believes the
President's proposed FY 2022 administrative funding level of $14.2
billion, including $895 million to strengthen SSA customer service and
$75 million in additional funding for outreach, would help prevent
further erosion in service delivery to customers. However, several
important details have yet to be provided by the Administration.
In addition, and as AARP has previously communicated to the Office of
Management and Budget and the House and Senate Appropriations
Committees, the definition of ``program integrity'' should, by
regulation or legislation, specifically authorize cost-effective field
office infrastructure improvements. At present, many offices lack the
high speed connections necessary for real-time document and medical
image transfers and related-privacy protocols. Communications
infrastructure enhancements, among others, would also enable SSA to
conduct far more Continuing Disability Reviews, Redeterminations and
other customer services.
Finally, SSA Commissioner Saul recently advised House Social Security
Subcommittee Chairman Larson that it will be unable to spend about $200
million in FY 2020 program integrity funds, citing operating ``issues
receiving and verifying documents and medical evidence we need to make
decisions.'' AARP strongly encourages the Administration and Congress
to specifically authorize expenditure of the $200 million for this
purpose, prior to the end of the fiscal year.
Closing
Once again, AARP would like to thank Chairman Wyden and Ranking Member
Crapo for holding this important hearing. We look forward to working
with you and the members of the committee to ensure Americans can
continue to rely on the Social Security benefits and services they and
their families need. We also look forward to continuing to utilize our
communications channels to share information about Social Security and
its benefits and services with our members and the general public.
______
American Federation of Government Employees, AFL-CIO
80 F Street, NW
Washington, DC 20001
(202) 737-8700
www.afge.org
Chairman Wyden, Ranking Member Crapo and Members of the Committee, the
American Federation of Government Employees, AFL-CIO (AFGE) appreciates
the opportunity to provide this statement for the record of the
Committee's hearing on ``Social Security During COVID: How the Pandemic
Hampered Access to Benefits and Strategies for Improving Service
Delivery.'' We thank the Committee for exploring this important topic.
AFGE represents more than 700,000 federal and District of Columbia
employees in 70 agencies, including over 45,000 employees at the Social
Security Administration (SSA). It is essential that union
representatives be explicitly engaged in deliberations over decisions
that affect the safety, working conditions and morale of the workforce.
This is an even more urgent matter when employees and the public they
serve are threatened by both a deadly virus and potential challenges to
timely service delivery.
AFGE's members are proud of their success in maintaining operations
throughout the pandemic of all of SSA's components. They have continued
to serve the public and work down the backlog of cases in claims and
appeals. We commend the Committee for exploring how the challenges
presented by the COVID-19 pandemic and the management of the agency
could have made that service delivery better.
SSA Restriction of Telework in 2019 and Early 2020
The unionized workforce's first challenge to continued service delivery
during the pandemic was the abrupt migration to near-100 percent
telework. This shift was made far more chaotic than necessary by SSA's
earlier, ill-advised decision to revoke or severely limit telework for
much of its workforce.
On October 27, 2019, the Social Security Administration informed SSA's
Operations components (field offices, teleservice centers and data
operations center) that all telework would end by November 22, 2019.
Despite contractual and legal requirements, the agency did not provide
a business rationale for ending telework. It simply revoked permission
unilaterally.
On January 27, 2020, SSA informed non-Operations components, including
the Office of Hearing Operations, that telework would be reduced in
most components and that any employees currently using telework would
have to submit a new telework agreement by February 7, 2020.
These poor decisions left the vast majority of the SSA workforce much
less ready to shift to telework and virtual service delivery when the
pandemic hit. Employees lacked equipment, training and had little or no
input into the agency's continuation of operations plan.
Despite those poor management decisions, within a matter of weeks, SSA
reported that wait times for calls were down and the number of calls
answered per employee was up. The agency has also been able to reduce
the pre-pandemic backlog of both newly filed claims and appeals claims.
In the Office of Hearings Operations, the backlog of pending hearings
requests also dropped. At SSA's headquarters in Maryland, the migration
to telework was delayed for many who did not have a telework plan,
including many who did not have access to the Internet at home. Their
ability to work was delayed until equipment and connectivity to be
acquired. Overall, SSA has not only maintained vital services, but
performance has improved and wait times have decreased for many
services. In order to meet all of the public's needs, however, SSA will
need to address workloads that are not portable, or that have been
suspended or altered because of the pandemic. As described below, this
includes initial disability claims and continuing disability review
(CDR).
Most SSA Work Is Portable; Addressing Non-portable Work
As telework in most components has continued throughout the pandemic,
it is important to identify the non-portable workloads and consider how
more of this work can be portable in the future.
In SSA field offices, work that is non-portable includes:
Original Social Security number applications for applicants over
age 12
Dire need Social Security new or replacement card requests
Immediate payments for claimants in critical situations
Opening, sorting and scanning mail
Processing remittances
Interaction with members of the public who need to visit the
office to receive Social Security checks and notices--individuals who
do not have access to the Internet, telephone or have a fixed address
Updating an SSA account for those who have blocked ``mySSA'' for
fraud purposes (updates such as change of address)
In the Office of Hearings Operations, work has remained largely off-
site. Hearings are being conducted by telephone and video. By providing
these virtual service options, the backlog of immediate cases with
hearings pending has decreased.
However, it is essential to recognize that individuals have the right
to request an in-person hearing and may benefit from that personal
interaction. It is therefore crucial that SSA return to the in-person
hearing format as soon as it can do so safely and that SSA continue
community-based service for disability hearings. It would be a mistake
to centralize hearings and migrate to an all-video format that would
impersonalize services for some of America's most fragile and
vulnerable populations.
AFGE's Recommendations
Engage the Unionized Workforce and Replace Leadership
The past 4 years have seen a decline in employee satisfaction and a
drastic upheaval of the treatment of the unionized workforce by agency
management. It is essential to morale and efficient operations of SSA
to restore regular labor-management relations. SSA needs leaders who
view the unionized workforce as a partner and not an obstacle, and that
views employees as the knowledgeable, professional and dedicated public
servants that they are. SSA needs new leaders at the highest levels
that will cooperate and collaborate with the unions representing the
people who know best how to get the public's work done. A change in
leadership will improve both public service and employee engagement and
empowerment.
To make labor management engagement productive, meetings must include
decision-makers among all parties with expectations to achieve results
to build a better agency. SSA should engage with its unionized
workforce through regular meetings and bargaining to find ways to
further improve employee working conditions on issues such as
technology, workstations, work processes, position descriptions and
career development.
SSA must also work with AFGE to resolve as many outstanding disputes
and grievances as possible, to further reset our relationship, improve
morale and working conditions, and allow the parties to move forward
less weighed down by the past four years.
Plan for Expanded Telework in a Post-Pandemic Work Environment
We have described the work conducted in the telework environment
necessitated by the COVID-19 pandemic. Telework should continue into
the future and SSA should identify additional portable work and the
technologies needed make it possible.
Even before we envisioned the challenges of a pandemic, in a July 2017
Office of Inspector General report, employees utilizing telework in SSA
Operations positions indicated:
68 percent completed more work when teleworking,
78 percent feel more satisfied with their jobs since the
implementation of telework,
90 percent indicated no difference in communication with a
supervisor when needed, and
67 percent indicated no problems accessing SSA's systems.
Equally important, the report found that telework productivity and
customer service in Field Offices, Teleservice Centers and the Office
of Hearings Operations was not markedly different between those
employees performing telework and those in the office. Had the findings
of this report been considered, the agency would have been better
prepared for telework during the pandemic.
Making Expanded Telework Possible: Use Technologies to Deliver In-
Person Services in a Virtual Environment
Use of technologies such as electronic meeting platforms can enable SSA
employees to meet with members of the public remotely. Secure platforms
will allow for employees to verify documents through web cameras. This
will make currently non-portable workloads such as application for
Social Security cards and numbers available for video-meeting services.
This will need to be conducted securely to avoid privacy concerns of
both employees and beneficiaries.
Employees have identified as a service challenge the slow rate of
answered outgoing phone calls. Numbers typically appear in caller ID as
either random numbers or as blocked or anonymous callers. SSA should
change the caller ID on those outgoing calls to improve the connection
rate and deliver better public service.
Additionally, SSA must review its Personally Identifiable Information
(PII) policy, which is not reflective of current technologies. If
updated with appropriate guidance and safeguards, this has the
potential to continue to protect the public while increasing
productivity.
Provide In-Person Services in a Safe Manner
Mail: Limited staff will be needed to open, sort and scan mail. This
function involves only a small number of employees and is necessary to
maintain portable work.
Immediate Payments: Immediate payments are an ongoing need. This will
require that each field office have an authorized check signer in the
office each day and could require additional employees be accorded
check signing authority.
Public Visits: Our field offices must continue to interact with members
of the public who do not have access to telephone or internet. This
requires a small number of employees in the office wo can maintain safe
distances. This is an essential service, but demand is generally low.
Paper Files: Some files still exist only in paper format. Going
forward, active files could be digitized and closed files could be
destroyed in an appropriate manner.
Disability Claims, Reconsideration and Medical Continuing Disability
Review
Continuing Disability Reviews (CDR) are a necessary part of SSA's
function. Medical Continuing Disability Reviews were temporarily
suspended during the pandemic to avoid cessation of benefits, but they
have resumed. With this resumption comes a backlog of cases that must
be reviewed. The last administration pushed to require CDRs to be
conducted as frequently as every six months, a bad idea the current
administration wisely reversed.
Of greater concern right now is the decision by the agency to extend
Public Service Indicator measurements to complete disability claims,
reconsiderations and CDRs. Instead of changing the goals, SSA should
hire sufficient front line field office personnel to address this
delayed backlog to continue to deliver these vital services in a timely
manner.
Office of Hearings Operations
Maintaining Community Operations: As noted above, individuals filing
appeals have the right to an in-person hearing and may very well
benefit from that engagement. SSA should plan for the resources
necessary to address the influx of delayed live hearings and keep this
essential community-based service available to the public.
Staffing: The Office of Hearing Operations (OHO) provides the essential
service of an administrative appeals process for benefits decisions. At
the core of OHO's work is the position of Legal Assistant. These are
among the individuals whose telework was severely and restricted in
January 2020 without any business case for the decision.
In 2017, OHO consolidated the position descriptions of Legal
Assistants, capping their career ladders and specializations. Many
legal assistants were previously categorized as specialists in major
workloads, such as master docket and case pulling, and were highly
productive performing specialized work. OHO should review and revise
position descriptions and create new career ladders to allow legal
assistants to develop and build in their OHO careers, instead of being
capped at GS-8 with little chance to advance. Developing this career
ladder will realign hearing offices to maximize employee talents,
increase opportunity, and improve service as the post- pandemic demand
for service will only grow.
Conclusion
AFGE thanks the Committee for considering how essential a respected,
engaged and well-resourced workforce is to the effective function of
the Social Security Administration. We have outlined the need for
personnel management improvements, identified areas where additional
resources are needed, and recommended some simple, practical solutions
to overcome service delivery challenges. These should be viewed as
closely connected and not severable. As labor and management relations
come into balance and technology and staffing needs are addressed the
public's vital needs will be better served during this pandemic and in
its aftermath.
______
American Federation of Government Employees
Council 220 New York Region
38 Bertrand Street
Old Bridge, NJ 08857
Tel: 732-991-7853
Fax: 609-642-8607
[email protected]
When a flower doesn't bloom, you fix the environment in which
it grows, not the flower.
--Alexander den Heijer
Chairman Wyden, Ranking Member Crapo, and Members of the Committee:
The leadership of the five AFGE C220 New York Region locals, on behalf
of our bargaining unit, submit the following for the Committee's
consideration in exploring the topic of improving service delivery by
the Social Security Administration.
Introduction
As Federal employees we embody the ideal of the American dream. An
ideal whose origins date back to the Founding Fathers and their
courageous struggles in the name of life, liberty, and the pursuit of
happiness. Through the years, the American dream has encompassed the
honest labor of the people for the benefit of themselves and others.
Federal employees devote their careers to promoting and effectuating
the very programs that promise financial security to all Americans in
their years of retirement or failing health. As civil servants of the
American public and employees of the Social Security Administration, it
is with great respect that we administer the greatest anti-poverty
program ever conceived by the American people. It is our passion for
our country and our sense of duty that enables us to serve the public
day in and day out with great pride and distinction. This is an honor
that we cherish; although often proven to be challenging with
government cutbacks, attrition of civil servants, and the perils of
predisposed beliefs that often devalue the contributions of federal
employees. As discouraging as this may be at times, we do not allow
this to impede our duty to serve the American public. It is with this
enthusiasm that we bring to you our concerns over the mismanagement of
SSA that threatens the very mission we have sworn to uphold.
Staffing Shortage Challenges
The customer service delivery issues encountered by SSA during the
pandemic predate the current COVID-19 public health emergency. Our
organization offers a unique perspective on the issues being discussed
during hearings on this matter. The employees we represent are the
public face of Social Security and interact with members of the public
dealing with a wide range of their concerns. During the pandemic, the
workforce has proven their dedication to the public by continuing to
provide a high level of service, despite the limitations that the
pandemic presents. However, there is a considerable amount of room for
enhancing how SSA delivers service presently and in the future. This
could readily be achieved if the Agency expressed a willingness to
engage in a bona fide partnership with AFGE to provide the best
customer service experience while maximizing the contributions of the
employees without overburdening them.
Years of underfunding have left the Agency in desperate need of
additional resources. While the need for SSA's services has increased
exponentially over the years, staffing has been on a constant decline
over the past decade, to the tune of approximately 20,000 front end
employees. This failure to keep pace with public demand has caused an
inordinate amount of stress on SSA bargaining unit employees. Every
year, via retirement and lack of retention, the Agency loses decades of
institutional knowledge that is not being replaced. The type of work
that SSA does is complex and requires high level of commitment; and we
deal with members of the public from diversified backgrounds and
educational levels. SSA's computer infrastructure is mostly outdated,
and any computer system modernization plan should target improving how
work is processed and not be a substitute for direct customer service,
especially when it appears to be at the expense of hiring much needed
frontline employees. Whether service is being delivered by phone or in-
person, it is important that the public can speak with a live
individual in an efficient and timely manner. It should be noted that
most benefit applications that are completed at SSA are not paper
applications, rather most, if not all, benefit applications are
completed electronically by SSA employees.
Telework Is Effective
While SSA offices continue to struggle during the pandemic due to
reduced staffing levels. Telework has given SSA offices an alternative
option to provide quality customer service, process current workloads,
answer phone inquiries, and process backlogs. Restoring staffing to
levels commensurate with public demand in all field offices is critical
as we transition to a post-COVID environment; this is crucial to
restore SSA's full scope of services to the public. Merely returning
employees to offices is not going to solve the deficiencies in being
able to serve the public effectively. It will only revert the Social
Security Administration to ongoing pre-pandemic challenges which
include long in-office wait times and unmanageable backlogs.
Moving forward, SSA workers, during this pandemic, have proven that
telework is an essential component to effectively processing SSA
workloads and must be incorporated into any post-pandemic work model.
Of course, any future vision should include the public being able to
receive face to face service in a safe manner. Many SSA field offices
have been closed because staffing has been reduced to levels that have
prevented those offices from maintaining the level of service required.
In upstate New York alone, there have been 5 SSA office closures within
the past 15 years and over a dozen in the New York City area. In New
Jersey, there have been 2 field offices and 2 teleservice centers
closures. At the same time, retention of new hires has been anemic with
many recent hires leaving the Agency during their training period. The
COVID-19 emergency has only exacerbated working conditions for new
hires.
Labor/Management Relationship
There are many approaches that can be jointly identified by the Union
and SSA that would collaboratively motivate SSA to align itself with
Executive Order 14003; recognizing the Federal Government as a model
employer that should attract, as well as retain, the best and the
brightest employees. First, field offices need to be reimagined to
provide shared workspaces to accommodate teleworking on a sustained and
rotating basis. This approach would allow for permanent workspaces for
non-teleworkers who would continue to serve in-office visitors, and at
the same time allow for offices to hire additional staff without the
confines of a traditional office set up. Secondly, there needs to be
mechanisms in place to properly staff SSA field offices based on the
level of service being provided in a geographic area, accounting for
attrition and customer demand. Having the Agency always telework ready
will not only ease the transition to long-term telework, but it will
also allow the Agency to effectively deal with any service disruptions,
such as a pandemic or other hazardous condition.
Effective Training for Retention and Job Satisfaction
SSA's training methods have deteriorated precipitously over the years,
preventing new hire retention as well as causing journeyman employees
to either seek early retirement or employment outside of the Agency.
This severely impacts the delivery of quality customer service.
Traditionally, new hires attended in-person training classes for
anywhere from 12-16 weeks where they were immersed in policy and
systems training with an in-person mentor. Circa 2010, the Agency
abandoned this approach and initiated a virtual training model, where
trainees spend a couple of hours per day with a mentor in a remote
location. The rest of their day is spent at their assigned duty station
doing assigned production work for the Agency, under the guidance of
in-office mentors who often do not have the time to help the trainee
because they are normally engaged in assigned duties dealing with the
more complex issues of the office. While the Agency stated the shift to
virtual training was a cost-saving measure nevertheless, it has created
a training environment full of distractions and unacceptable
consequences. This has made it more challenging for new hires to be
proficient doing their job. In many understaffed offices, training is a
secondary concern as these offices will rely heavily on trainees to
interview the public and process workloads, severely impeding the
effective training of new hires. The Agency is critically hindering the
ability of new employees to become successful and in turn this has the
cumulative effect on the Agency's ability to provide quality service to
the public.
Initial training is only the first component of the training process.
The claims specialist position, the most common position at SSA, is a
journeyman position that is a three-year process involving increasing
responsibilities with accompanying training. When the pandemic ends,
the Agency needs to revert to traditional proven training methods for
all employees. To achieve this, the Agency needs to be provided with
dedicated funding to ensure that training can be dispensed in the most
effective manner. A short-term investment in training ensures that SSA
will have a productive workforce in the long term. Likewise, meaningful
improvements to the training process requires collaboration with the
Union, who have been traditionally excluded from discussions and plans
for new hire training and training in general.
Supplemental Security Income (SSI) Service Delivery Issues
The Agency has alleged that the number of SSI claims taken have
declined since the start of the pandemic. It is unclear what hard data
the Agency is using to support this claim. During the pandemic,
applications for all SSA programs has continued to be consistent with
pre-pandemic levels. SSI is a needs-based program and is only one type
of program that SSA administers. Individuals who file for Retirement,
Survivors, and Disability benefits are always screened for SSI
eligibility. It should be noted that SSA policy offers the option of a
closeout notice or the completion of an abbreviated application as a
formal notice of ineligibility to individuals who are screened and do
not qualify for SSI; with the latter process being much more time
consuming for both the member of the public and the employee completing
that abbreviated application. Most SSA field office management
officials mandate the completion of abbreviated applications in order
to inflate application statistics. The Agency needs to formulate a much
more efficient method to address SSI ineligibility that promotes
efficiency for employees and the public.
If there is truly a decline in the number of SSI applications taken
during the pandemic, it could very well be attributable to the fact
that a lot of potential SSI recipients supplement their monthly income
from part-time work. A lot of these same individuals have been eligible
for the enhanced unemployment benefits, which would preclude SSI
eligibility. Perhaps, this explains why the working disabled are filing
less SSI applications.
Processing SSI initial claims is only one workload component of the SSI
program. The additional adjudication of redeterminations and post-
entitlement actions involve more employee work hours than dealing with
initial claims. Acerbating the situation are the volumes of regulations
involved with administering the SSI program. Payments are determined on
a monthly versus a yearly basis; and requires each month to be analyzed
for income, resource, and living arrangement data. Likewise, the
software ``enhancements'' that the Agency has utilized to modernize and
speed up SSI claims processing instead, has slowed down the processing
time of initial applications and post entitlement actions. Numerous
software malfunctions are encountered by employees daily. This
reinforces the argument that automation cannot be a substitute for
adequate staffing in SSA field offices.
Another factor to keep in mind is that pre-pandemic, SSA field offices
had limited appointment availability due to staffing shortages, which
in turn contributed to reduced intake of SSI applications. An
individual may have waited up to sixty days to get the next available
appointment to file an application. This will continue to be a problem
post-pandemic if adequate staffing is not restored to the Agency.
Alternatives to Paper Documents
Attempting to provide improved customer service during the pandemic,
the Agency is piloting the use of document drop boxes. However, the use
of drop boxes is only putting a band-aid on the immediate need to offer
an alternative to mailing in documents and is not taking advantage of
the opportunity to make bold changes in the way the Social Security
Administration offers service delivery to the public. Moreover, while
the use of the drop box facilitates the public in providing SSA with
important documents, it still relies on the same undependable method of
returning these documents, the mail system. This gives the appearance
of being disingenuous; SSA shows great concern for the protection of
vital documents to process claims but abandons those concerns when it
comes to returning them. The Agency should explore alternative methods
of document verification that would eliminate the need for the public
to temporarily be separated from their documents. For example, the
Agency should explore interfacing with other federal, state, and local
government agencies to be able to verify information such as date of
birth, marriage, citizenship, legal immigration status, etc. While the
rest of the business world seems to have embraced technology, the
Social Security Administration seems to be not only reluctant to find
alternative methods, but also seems outright opposed to exploring these
options.
The Agency should update their computer systems to be able to update
records without the need to fill out and mail/drop off forms. In
particular, the use of an SS5 (Application for Social Security card)
should not be needed to update a claimant's citizenship on their
record. The Agency should have the ability to update the record with
appropriate verification of citizenship through an interface with U.S.
Citizenship and Immigration Services (USCIS). This simple example could
have a ripple effect on the processing of claims by SSA. Not only would
this eliminate the need for claimants to provide documentation, but
applications for benefits would also be processed faster as a result.
There are numerous other examples of how utilizing technology would
better serve the public. Once again, the Agency is not even receptive
to discussing or exploring any alternatives.
When the Union attempts to initiate any discussion concerning possible
technological changes within the SSA systems, the Agency continues to
disregard the Union's position as the exclusive representative of the
bargaining unit. This failure to communicate and consult with the Union
often results in vast amounts of taxpayer funded dollars being spent on
outdated technology that often proves more cumbersome and ultimately
creating an impediment to the efficiency of federal service. In the
face of longer interviews with the public because of ill-conceived
enhancements to the SSA systems, there are also less employees serving
the public, thus creating an inefficient method of delivering vital
public services at critical times. This is a failure by SSA to maintain
a position of trust demanded by the American people. What makes this
most egregious is that the solutions are not complex or unattainable.
The hiring of sufficient new employees with a commitment to retaining
them would enhance the Agency's ability to serve the public effectively
and timely. The Agency has chosen the road of isolation rather than
partnering with the Union to seek practical and pragmatic solutions.
While the Union will always applaud the willingness to pursue new
technologies, the application of new technology for its own sake with
no measurable improvements represents poor judgement that reflects on
the Agency's unwillingness to work with the Union.
SSA's Most Valuable Asset
SSA's most valuable commodity are the civil servants that are on the
front line assisting the public. It has been proven time and time again
that an employee that is motivated to be their best through an
encouraging and positive work environment is likely to produce at a
high level. Instead of providing a work setting that produces elevated
office morale, the Agency is often alienating employees, detaching them
from their sense of civic pride that is the driving force behind their
desire to serve the public. Most employees enter civil service with the
intent to make a difference in the lives of the average American. This
should be fostered by the Agency instead of sabotaged. In violation of
President Biden's Executive Order 14003, SSA has continued to operate
under a collective bargaining agreement that was the result of
President Trump's anti-federal employee executive orders that has
diminished employee rights and made them feel unappreciated and
dispirited. At the same time, the Agency continues its union animus
that began over 4 years ago and has created a mistrust between the
Union and the Agency that prevents SSA from fulfilling its mission
effectively. After years of indignity and mistrust endured by the Union
and the employees they represent, a complete reversal of course must be
undertaken by SSA to rebuild the trust that has been shattered. The
last four years have been traumatic for SSA employees and a once in a
lifetime pandemic has only added to the challenges facing SSA front
line employees. Employees need to feel appreciated and respected by
their employer. Once again, they must be permitted to be guided by
their love of their chosen vocation and their commitment to serving the
American public.
Conclusion
AFGE Council 220 New York Region representing the bargaining unit
employees at Field Offices and Teleservice Centers in New York, New
Jersey, Puerto Rico, and the U.S. Virgin Islands, thank you for your
time and consideration to our concerns regarding public service
provided by the Social Security Administration. We have offered for
your consideration the crisis of short staffing at the Agency, the
importance of telework in providing possibilities to easily increase
staffing while providing quality customer service, the need for
effective training, the use of technology in moving the Agency forward
effectively while not imposing hardship on the American public. We have
provided some insight into the SSI program and welcome the opportunity
to discuss potential improvement in the program and accessibility by
the most vulnerable of the American public. We have offered the
importance of a meaningful labor/management relationship for the
benefit of the employees and the American public that are served by the
Agency. Public service is at its best when the exclusive representative
of the bargaining unit is respected, and the ideas of the bargaining
unit brought forward on their behalf are valued by the Agency. It is in
the interest of the public that the Agency engage with the Union in
healing a broken relationship to move forward in a bold and effective
manner.
Respectfully Submitted,
Angela Digeronimo
Regional Vice President, AFGE Council 220 New York Region
President, AFGE Local 2369
Edwin Osorio
First Vice President, AFGE Council 220
President, AFGE Local 3369
Rafael Arroyo
President, AFGE Local 2608
Shawn Halloran
President, AFGE Local 3342
Chris Delaney
President, AFGE Local 3343
Joseph N Cooke
Executive Vice President, AFGE Local 2369
Roy Porter
Executive Vice President, AFGE Local 3342
Jennifer Ramirez-Seranno
Treasurer, AFGE Local 3369
______
Center for Fiscal Equity
14448 Parkvale Road, Suite 6
Rockville, MD 20853
[email protected]
Statement of Michael G. Bindner
Chairman Wyden and Ranking Member Crapo, thank you for the opportunity
to submit these comments for the record to the Committee on this topic.
I will allow the scheduled witnesses to deliver the problems and
success stories regarding service delivery, which I expect will greatly
resemble conditions which occurred at every Driver's License Renewal
office in the nation, although I will draw that parallel. There are
more urgent matters, aka, bigger fish to fry, on how Social Security is
responding to the Pandemic.
My Driver's License expired in November. It was disconcerting to need
an appointment to get one, but because of the pandemic it was no
problem with it expiring in the mean time (of course, I don't drive
anyway, so it was no big deal). Years before, a new license renewal
meant almost an hour waiting for my number to be called. When, pre-
pandemic I was applying for temporary disability and to get a new card
because of a new job, the lines were worse than at the DMV.
This time, there was very little waiting while my number was called to
get a license. I imagine that my local Social Security office has done
the same things to cope with COVID--at least I hope so. We need to
preserve these lessons and create a new normal.
Money will be an issue. We need more Social Security offices and maybe,
because they have similar functions, cooperation with the DMV might be
in order. It would require cross training citizen service workers, but
that just means we would have to pay them more and hire more of them.
Just a stray thought. More importantly, building more offices for both
DMV and Social Security will take money and it should not require
higher driver's license fees or take away from the pool of money used
for benefits.
Social Security has low administrative costs. It should not have any.
The general fund already owes trillions of dollars to the Social
Security Trust Fund. Preserve the trust fund a bit more and use general
revenues now to fund administration, improvements and more office
space. As the pandemic wanes, caution will still be necessary for a
while. It is time to build out some infrastructure in both government
and leased space.
Now for the bigger fish. In the last six months, I can no longer afford
big fish. My SSDI was inadequate for food, medicine, clothing and
cable. If I owned a vehicle, there is no way I could maintain it or
even buy gas. I have an above average benefit, high enough to be
ineligible for SNAP or Medicaid. Many are not so lucky, even on a good
day.
In the last few months, days have not been so good. Were it not for
stimulus payments, I would be running out of food as I write this and
would not have just bought new clothes, from socks and underwear to a
jacket I can wear when the Committee finally asks me to testify in
person. As it is, I will need to use the last $600 from my December
payment (which should have come through Social Security) to attend my
upcoming high school reunion. Whale I have wi-fi, I cannot afford cable
and a car is still out of reach.
Let me underline a point. In most months, new underwear is not an
option, I rely on free bus rides due to the pandemic and subsidies from
Ride On and there is never enough money in that last week before the
check comes. When it does arrive, the cupboard is bare.
Double underline: food prices are skyrocketing. Part of the problem may
be too much money chasing too few goods, but retirees and the disabled
find (our) selves between a rock and a hard place. We don't need
stimulus money, we need a COLA.
We don't need a COLA next year. We are thirsty now--or rather--hungry.
Please address this. Don't hold hearings, just pass a bill.
Thank you for the opportunity to address the committee. We are, of
course, available for direct testimony or to answer questions by
members and staff.
______
Consortium for Citizens with Disabilities
820 First Street, NE, Suite 740
Washington, DC 20002
Ph 202-567-3516
FAX 202-408-9520
[email protected]
www.c-c-d.org
May 12, 2021
Senator Ron Wyden Senator Mike Crapo
Chair Ranking Member
U.S. Senate U.S. Senate
Committee on Finance Committee on Finance
Dirksen Senate Office Bldg., Rm.
SD-219 Dirksen Senate Office Bldg., Rm.
SD-219
Washington, DC 20510-6200 Washington, DC 20510-6200
RE: April 29, 2021 Hearing on ``Social Security During COVID:
How the Pandemic Hampered Access to Benefits and Strategies for
Improving Service Delivery''
Dear Chairman Wyden and Ranking Member Crapo:
This statement is submitted by the cochairs of the Social Security Task
Force of the Consortium for Citizens with Disabilities, the nation's
largest coalition of national disability organizations. We thank you
for holding this hearing on the important topic of service delivery at
the Social Security Administration (SSA). Our comments focus on issues
related to SSA's Operations component because the Deputy Commissioner
of Operations was the agency's witness for this hearing.
SSA faced difficulties in customer service before COVID-19; the
pandemic worsened some challenges and introduced new ones. Many of
these issues, new and old, were highlighted by the hearing and we were
grateful for the substantial interest from members of both parties in
ensuring that SSA processes are straight forward and easy to navigate
and that beneficiaries can access the benefits to which they are
entitled. To inform Congressional work, we wish to highlight problems
that we as a coalition have also focused on or of which we have been
made aware. Some ways of improving or fixing the agency's problems
require changes to the law or increased administrative funding; others
could be done by SSA itself, but would benefit from Congressional
oversight.
We are grateful for SSA's communications with the public and with
advocates throughout the pandemic. SSA is providing better services now
than it was a year ago when we were only six weeks into stay-at-home
orders. There even are some aspects of SSA's workloads that are being
performed more efficiently than they were before the pandemic. But many
challenges remain, especially for the lowest income and most
disadvantaged beneficiaries.
(1) Pandemic Disaster Relief and Supplemental Security Income (SSI)
Beneficiaries
As Senator Menendez highlighted, many people with disabilities who rely
on SSI are encountering challenges when dealing with pandemic relief,
either related to unemployment insurance compensation or economic
stimulus. Last year, we highlighted some of these issues in our
statement for the record in response to the Finance Committee's hearing
on Unemployment Insurance During COVID-19.\1\ As Deputy Commissioner
Kim said, we know that SSA has been working to determine if the
disaster protections of 20 CFR Sec. 416.1150 apply in this context--
other agencies have applied disaster relief regulations since last year
and this seems to be a reasonable interpretation to us.\2\ It was
clearly not Congress' intent to deprive people of benefits by providing
relief.
---------------------------------------------------------------------------
\1\ http://c-c-d.org/fichiers/FINAL_CCD-Statement-for-the-Record-
re-UI-Disregards-_6-23-20.pdf.
\2\ We will note that the Department of Labor is applying the
Disaster Unemployment Assistance (DUA) regulations: https://
wisconsinexaminer.com/wp-content/uploads/2020/07/Wisconsin-Department-
of-Workforce-Development-SSDI-Inquiry.pdf.
We have received reports of children with disabilities receiving SSI
benefits having their benefits cut because of their parents' receipt of
unemployment benefits; SSI beneficiaries who do work having their
benefits suspended or terminated because of unemployment compensation;
and of SSI beneficiaries being inappropriately terminated for being
over the asset or resource limit, despite a clear statute prohibiting
the stimulus payments from being considered assets for the first 12
months. We know that these problems will continue in response to the
recent additional stimulus checks. We believe that this confusion is
actively harming beneficiaries. It is extremely frightening for
beneficiaries to receive termination or suspension notices, incorrect
or not, especially since eligibility for SSI benefits often conveys
eligibility for health care. We would urge Congress to both increase
asset limits (which have not been updated since 1984) and to work with
SSA to ensure that no one is terminated inappropriately. No one on SSI
should be have their benefits terminated due to pandemic relief
assistance.
(2) Redesign on the SSI Application
As mentioned by Mr. Causeya, the SSI application is only available
online to an incredibly narrow group of applicants: people age 18-64
who are not blind, never married, and never made a claim for any SSA-
administered benefit. With the field offices closed and the paper SSI
application form only available buried on the SSA website, thousands of
potential applicants have been unable to apply.\3\ The phone lines are
often too busy, leading to extended delays. A widely available online
SSI application would help ensure that those who are eligible for SSI
can apply, especially if accompanied by other reforms to ensure that
the SSI application is understandable for those with disabilities who
need to use it. During the working groups that SSA mentioned, we know
that the many issues with the current application have been brought to
SSA's attention. We would be glad to work with Congress and SSA to
ensure that the application is available online and in a more
understandable form.
---------------------------------------------------------------------------
\3\ https://www.aarp.org/retirement/social-security/info-2021/
closed-offices-impact-ssi-applicants.html.
---------------------------------------------------------------------------
(3) Assistance for Assisters
Many people unable to navigate SSA's current systems have turned to
legal services organizations, other community navigators such as the
program run by Mr. Causeya, the media, or their members of Congress for
assistance. Others simply are not receiving the benefits for which they
qualify. We know that applications and awards for disability benefits
have declined significantly \4\ during the pandemic: this is
detrimental to people who are going without financial supports and the
Medicare or Medicaid that can accompany them. It also means that SSA
must prepare now for a coming increase in people seeking the agency's
services. These same individuals will also seek help from legal
services organizations and other community navigators who assist with
applications, increasing a burden on already stressed assistance
system.
---------------------------------------------------------------------------
\4\ https://www.nytimes.com/2021/01/14/opinion/supplemental-
security-income-ssa-disability.html.
SSA's policies are complicated. People benefit from skilled assistance
interacting with SSA--and when the public has more information so
claimants can provide necessary documentation and complete forms
---------------------------------------------------------------------------
accurately, the agency benefits too.
Ensuring that appointment of representative forms (SSA-1696) are
processed quickly and accurately is critical: SSA should track this
workload more closely and make efforts to improve it. Paying approved
representative fees promptly is important too: it allows beneficiaries
to receive any portion of withheld past-due benefits that exceeds the
authorized fee and encourages skilled representatives to continue
practicing in this area. Congress should also increase funding for
legal services, SOAR, Protection and Advocacy for Beneficiaries of
Social Security, and Work Incentives Planning and Assistance programs.
These programs provide valuable services and help SSA work more
efficiency. A specific navigator program for people with disabilities
applying for SSI over the next several years would also help reverse
the dramatic drops in application and award rates, provide access to
needed benefits to COVID-19 long haulers, and reduce the burden on the
agency and newly opened field offices.
(4) Issues Stemming from Field Office Closures
In Fiscal Year 2019, SSA had more than 174,000 visits each day \5\ to
its network of over 1,200 field offices. Some of those visits were
successfully replaced during the pandemic with phone calls, faxes,
online services, and mailed communications; indeed, some people with
disabilities prefer to use such services when they are available and
accessible. But many people lack technology, mailing addresses, or
phone minutes. Some need services that SSA does not provide online,
like new (or, in some states, replacement) Social Security cards;
online SSI applications for most claimants; or reporting the death of a
loved one and applying for survivors' benefits. And others are unable
to verify their identities using SSA's system based on credit-
bureau data, and thus cannot set up the mySSA accounts needed to
receive many of the agency's electronic services. A disproportionate
number of low-income people rely on Social Security and SSI benefits
and are less likely to have access to regular Internet access, a
problem compounded in rural areas.
---------------------------------------------------------------------------
\5\ https://www.ssa.gov/open/data/field-office-visitors-average-
daily.html.
We also note there is considerable variation across and within field
offices as to how SSA's policies are applied and services are provided.
Some field office staff are quick to return phone calls and others are
not. Some offices scan mailed or faxed documents into the WorkTrack
system quickly and assign them to workers; in other offices, field
office staff are unable to review documents that have been submitted
and ask for them to be re-sent multiple times.Looking in from the
outside at such a massive agency with so many complex workloads, it is
hard to know precisely how SSA should improve efficiency and
consistency. Collecting and publishing management information, tracking
how field offices compare to each other on different metrics and
adopting best practices from high-performing offices, providing
adequate training and resources, and ensuring that productivity
measures do not reward inaccurate work or incentivize employees to
---------------------------------------------------------------------------
ignore challenging cases are all parts of the solution.
We have received reports of numerous issues resulting from the closure
of field offices and will discuss a few in detail.
A. Issues Related to Identity Verification Documents
One area where there is a lot of variation is getting in-person
appointments versus needing to mail in documents. This issue was
highlighted by many different Senators during the hearing. One of our
organizations was recently contacted by the relative of an elderly
person who was born in the former Yugoslavia. She was incredibly
nervous about mailing in her marriage certificate because if it were
lost, she would never be able to replace it when the issuing government
no longer existed. Yet she was told that her only option to obtain
widow's benefits was to mail it: numerous field office employees said
she could not have an in-person appointment. We helped her relative
connect with the District Manager and Area Director and the situation
was quickly resolved. SSA has issued guidance \6\ about when in-person
appointments are available, but it is quite vague and even when the
agency offers an appointment it might be weeks or months away. Although
SSA finally stated in late December that people should not mail their
lawful presence documents (green cards) to field offices, we are aware
of people who have still been asked to do so. SSA has also created a
``policy flexibility'' whereby people who would normally have to submit
their drivers' licenses can send other forms of identification instead,
and drivers' license information can be verified via data sharing. We
support these changes, because people generally cannot be without
drivers' licenses for over a month when they need the licenses for
identification and to drive legally. However, this plan will not work
for everyone, especially those who may not possess multiple forms of
identification. SSA needs to create a plan to ensure that people can
make in-person appointments to provide these forms of identification,
or to use data sharing to verify information without hands-on
examination of documents, and Congress should ensure that happens as
promptly as possible.
---------------------------------------------------------------------------
\6\ https://www.ssa.gov/coronavirus/.
---------------------------------------------------------------------------
B. The Intermediary Role of the Field Office
Field offices are also the intermediaries between the public and other
SSA offices like payment centers, the Office of Central Operations, and
Workload Support Units. Beneficiaries may not understand that their
case is being handled by one of these offices and when they call the
field office or 800 number the person who answers the phone may not
have access to, or know how to, review all the information that these
offices are reviewing. This causes a lot of confusion and inefficiency
that SSA should consider how to improve.
An example of problems between field offices and program service
centers is handling reports from beneficiaries who work. We know that
SSA's work incentives are important to the agency and to Congress, but
during the pandemic disability beneficiaries who returned to work are
having difficulties reporting that work activity and having their
benefits adjusted properly, causing both overpayments and
underpayments. Those whose benefits were suspended in the past for work
activity and then lost their jobs or saw earnings decrease are having
difficulty obtaining the expedited reinstatements they should be
receiving. Communications breakdowns within field offices and between
field offices and program service centers/payment centers often mean
that people are waiting months even for provisional benefits to start.
In many cases, the agency has not decided on whether benefits can be
reinstated by the time the six months of provisional benefits end.
SSA's neglect of this important work incentive is unacceptable. People
with disabilities who rely on SSI and other Social Security disability
benefits should be encouraged to work to the best of their ability, not
punished for doing so.
C. COVID Overpayments Caused by SSA
SSA has tried to simplify its process for waiving overpayments caused
by the agency's suspension of certain workloads during the pandemic.
Although we appreciate the agency's efforts, we made several
recommendations \7\ that have not been implemented. Furthermore, some
field office employees seem much more aware than others of this
temporary final rule.
---------------------------------------------------------------------------
\7\ http://c-c-d.org/fichiers/SSTF-Comments-on-SSA-Waiver-
Rule_final-for-signon.pdf.
Another area where we are beginning to see allegations of overpayments
is when SSI recipients received stimulus payments. By law, these
payments are considered tax refunds and exempted from SSI resource
limits for 12 months. However, some SSI recipients are receiving
notices stating that they were over resources during that time period,
and this is due to the agency's failure to apply these policies. SSI
recipients who are able to obtain legal services or other assistance
can likely successfully contest these alleged overpayments, but we are
concerned that some low-income, low-asset, people with disabilities and
senior citizens will have their benefits reduced from their already low
level (a maximum of $794 per month, well below the poverty line) in
order to recover overpayments that never should have been assessed.
D. DDS Difficulties and Delays
Every state has an agency funded by SSA (generally referred to as
Disability Determination Services or DDS, though some states use
different names) that decides if disability claimants meet medical
requirements. Some state agencies adjusted much faster than others to
the switch to remote work during the pandemic, and some states are
still much more communicative with claimants and representatives than
others.
There are major differences between different states in how DDS
backlogs have changed. For example, according to SSA's data, \8\
Alabama, New Hampshire, New Mexico, and Wyoming saw their initial level
backlogs more than double from April 2019 to December 2020. Other
states, such as Alaska, Hawaii, Rhode Island, and Vermont, reduced
their initial level backlogs during the same time period.
---------------------------------------------------------------------------
\8\ https://www.ssa.gov/disability/data/ssa-sa-mowl.htm.
Some cases take more time than others. We do not believe that DDSs
should be pushed to decide cases before evidence is received or the
appointment of representative form is processed. It is taking longer to
gather medical evidence during the pandemic and some delays are
therefore to be expected. But it seems from the representatives that we
have talked to that some cases are sitting for months after all
evidence has been submitted and DDS staff in many of those cases are
not responsive to attempts to contact them. We encourage Congress and
SSA to closely monitor this situation.
E. Paper and Non-Disability Appeals
Some of the most challenging cases for SSA to consider are about the
amount of benefits someone should receive or if they meet SSA's non-
medical requirements. Such cases often involve evidence provided by
SSA, financial documents like pay stubs and worker's compensation
settlements, and other documents like birth and death certificates.
They can touch on issues of tax law, immigration law, trusts and
estates, family law, and more. Further complicating matters is the fact
that these cases are often not electronic. They are paper files that
get mailed to different Social Security offices when the beneficiary
moves or appeals. Many of these paper files were stuck in field offices
or hearing offices for months during the pandemic. Although SSA has
recently begun tracking them, we know that there are some that the
agency acknowledges have been misplaced, have systems issues that
preclude processing them, or must be redeveloped. And we believe that
there could be paper files in SSA offices that the agency is not
tracking, if they are on someone's desk or in a file cabinet or another
place that nobody has looked recently.
These are important cases, whether they involve hundreds of thousands
of dollars--as did a recent survivors' benefits case, stalled for
years, of which we recently became aware--or a change in SSI benefits
of only a few dollars a month. SSA should institute better methods for
tracking these cases and converting them to electronic cases so they
can be more easily transferred across offices and more accessible to
beneficiaries and appointed representatives
Conclusion
Thank you for your efforts on behalf of disability claimants and
beneficiaries and the millions of others who interact with SSA. We
stand ready to work with you, other members of Congress, and SSA to
improve services to the public.
Sincerely,
Stacy Cloyd
National Organization of Social Security Claimants' Representatives
Tracey Gronniger
Justice in Aging
Bethany Lilly
The Arc of the United States
Jeanne Morin
National Association of Disability Representatives
______
Inner City Law Center
624 S. Grand Avenue, Suite 2510
Los Angeles, CA 90017
TEL: (213) 443-2355
FAX: (213) 891-2888
https://innercitylaw.org/
May 12, 2021
U.S. Senate
Committee on Finance
Dirksen Senate Office Bldg.
Washington, DC 20510-6200
Chairman Wyden, Ranking Member Crapo, and Members of this Committee:
Thank you for the opportunity to submit a statement for the record
regarding the important issues discussed during the hearing held April
29, 2021, on Social Security Administration services during the COVID-
19 pandemic. The COVID-19 pandemic has created an unprecedented
challenge in service delivery for SSA--the agency charged with
providing crucial income supports to individuals with disabilities and
seniors. Although SSA took steps during the pandemic to change
procedures to reflect the COVID reality and SSA front-line staff are
undoubtedly working very hard, the agency's service delivery to the
public is nonetheless in crisis.
Inner City Law Center (``ICLC'') is a non-profit legal services
provider based in the Skid Row neighborhood of Los Angeles, California.
For more than thirty years, ICLC has provided critical legal services
to low-income individuals who are either experiencing homelessness or
at risk of homelessness. This has included several decades of work
representing clients whose Supplemental Security Income (SSI) or Social
Security Disability Insurance (SSDI) benefits have been reduced,
denied, or terminated. Currently, we represent hundreds of clients in
appeals before the Social Security Administration, which necessitates
daily contact with SSA field offices across Los Angeles County. In
addition, we work closely with a Los Angeles County program based on
the SOAR model that has assisted thousands of low-income Angelenos who
are homeless or at risk of homelessness with applying for SSI and SSDI
benefits. This program is in constant contact with SSA field offices
and we advise them on how to resolve issues with SSA field offices
related to individual applications.
A. INTRODUCTION
This statement responds to and challenges assertions that were made by
SSA during the Senate Finance Committee hearing held April 29, 2021,
and provides additional information to the members of the Committee on
the crisis that we have witnessed unfolding on the ground. Failure to
take immediate steps to improve service delivery at SSA's field offices
will have the continued effect that thousands of our nation's most
vulnerable individuals will either lose their urgently needed benefits
or they will continue to be unable to even apply for benefits in the
first place.
The most critical issues we have witnessed at SSA's field offices
include the lack of in-person access to SSA personnel, limited ability
to make appointments, a phone system that is seriously overburdened,
failure to implement effective policies within SSA's discretion, SSA
personnel misstating rules or policies that create additional burdens
on the public, and SSA's failure to leverage the knowledge of community
organizations and advocates who have assisted the public with Social
Security issues for decades.
There are approximately thirty SSA field offices in Los Angeles County,
making it one of the largest, if not the largest, SSA service-delivery
regions in the country. Our office has clients spread across Los
Angeles County and so we interact regularly with many of these field
offices. We also collaborate with advocate networks throughout
California and nationwide. The problems noted below are not confined to
one or two offices, or just to Los Angeles County, but are systemic
problems that are occurring throughout the SSA system.
The impact of the field office closures has been immediate and
catastrophic. SSI applications and awards plummeted during the
pandemic. SSA statistics show that, from July to November 2020, ``the
Social Security Administration awarded benefits to about 100,000 fewer
individuals compared with the same period last year. In July 2020 the
agency distributed just 38,318 new awards--the fewest in 20 years of
available data.''\1\ Thus, the real-world consequence of field office
closures is that tens of thousands of people who are impoverished and/
or disabled will not receive the benefits to which they are entitled
under federal law. This is a permanent loss of benefits to these
individuals as the amount of money one is awarded is tied to when an
application is filed. In other words, even if these individuals file an
application for benefits in the future, they will never be able to get
money for the period of time when their applications were not filed.
---------------------------------------------------------------------------
\1\ Jonathan Stein, David Weaver, ``Disabled Americans Are Losing a
Lifeline,'' New York Times, January 14, 2021.
Moreover, SSA's focus during the pandemic has overwhelmingly been to
increase online and virtual service delivery. Although this is
understandable, it further marginalizes members of the public who
cannot access the Internet. Online access is far from universal in our
country and access has eroded during the pandemic. As one example, many
low-income individuals rely on public libraries to access Internet
resources but many libraries have been closed or had limited operating
hours since March 2020. Although the creation of online tools is
useful, these tools cannot substitute for in-person and telephone
access to SSA.
B. THERE ARE SERIOUS ISSUES WITH THE PUBLIC'S ACCESS TO FIELD OFFICES
SSA field offices play a critical role as the front-line of the
public's access to the Social Security Administration. In their written
testimony, SSA did not acknowledge that phone service is an imperfect
substitution for in-person service as some members of the public do not
have access to phones or are unable to effectively communicate by
phone. The promised in-person appointments for critical issues are
illusory as there is no system for making such appointments. Most
worrisome, the phone systems at SSA local offices are so overburdened
that in many cases it is not possible to even reach offices by phone.
SSA stated in their written testimony that their efforts to maintain
access to the public included that, ``[w]e marketed field office
telephone lines, so the public could directly reach employees in local
offices by telephone. We posted signs in our offices, messaging the
availability of services online, by mail, telephone, and limited in-
office appointments.'' (Deputy Commissioner Kim's Written Testimony, p.
4.)
The measures implemented by SSA have been wholly insufficient to meet
the needs of the public. As one example of this, Deputy Commissioner
Kim lauds SSA for listing the phone numbers of SSA field offices on
their website during the pandemic. She fails to explain that this was
necessary only because SSA had previously scrubbed the field office
phone numbers from the national website. Many advocates, including our
office, had to maintain independent lists of field office numbers that
we could provide to clients because this information was unavailable
otherwise. Members of the public who previously did not have access to
direct field office telephone numbers had to call the national 800
number, which typically has extended wait times, provides inconsistent
information, and is unable to effectively communicate with the field
office employees who are making the actual decisions in these cases.
Providing a list of field office phone numbers is a minimal level of
service to the public and not, as SSA implied, a dramatic improvement
in service delivery.
1. SSA Had Serious Pre-existing Customer Service Issues that Have
Been Exacerbated by the COVID-19 Pandemic.
It has always been difficult to get answers by phone from SSA field
offices due to wait times and failure of SSA personnel to return phone
calls. Individuals who lacked phones or were not able to communicate
effectively by phone frequently visited field offices in person in
order to get answers to their questions. Field office access thus
provided a safety valve that enabled members of the public to bring in
a written notice they did not understand, ask for the status of their
cases, or submit an appeal in person.
Even when field offices were open to the public, this was an imperfect
system because SSA has never had a system where the public or an
advocate can make an appointment at an SSA office. A visit to an SSA
field office typically meant getting to the office before it opened,
waiting in line 30 minutes to an hour to check-in, and then waiting
anywhere from one to two hours to speak to a representative at the
window. Many claimants, due to physical or mental disabilities, were
not able to access in-person services as their disabilities made it
impossible for them to wait the one to two hours required to speak with
an SSA employee. This already imperfect system is now in crisis.
2. SSA's Offices are very difficult to reach by telephone.
The only way to communicate with SSA in real time over the last year
has been by telephone but SSA's telephone access is unpredictable and
frustrating. SSA noted in their written testimony that the number of
phone calls SSA receives has tripled in the last year. (Deputy
Commissioner Kim's Written Testimony, p. 8.) We have found that it has
grown increasingly difficult to speak with both field office and
hearings office employees via telephone due to wait times of 30 minutes
or more, calls being dropped, phone lines not being operational, and
employees failing to respond to voicemails in a timely manner or at
all.
Below are two representative examples of what this actually looks like
on-the-ground:
We needed to confirm that the Lakewood, California field office
had processed a client's appeal after we submitted it on November 4,
2020. Our staff called the Lakewood Field Office more than fifteen
times between January 5, 2021 and March 16, 2021. Eleven of those phone
calls would not connect to an SSA representative either because the
line was busy, we received an error tone, or the call simply ended in
dead air. We were not able to confirm that the client's appeal was
processed until the end of March 2021 when we were given a particular
employee's extension. Even then, we had to call that employee
repeatedly until they confirmed the claimant's appeal was processed.
The average unrepresented claimant would likely not have the telephone
access, stamina, or understanding of the process to enable them to
follow up so extensively to ensure their case was moving forward.
In another example, we contacted the Huntington Park, California
Field Office after a client was awarded less money than he was due. We
received busy signals, error messages, and unreturned voicemail
messages on more than 10 occasions between December 2020 and April
2021.
These are only two examples, but we have found that calling SSA field
offices and hearing offices frequently results in error messages
(``your call could not be completed''), busy signals, dropped calls,
and very long wait times to reach a representative. In the cases
described above, we were ultimately only able to resolve the issues
because we had the names and extensions of specific employees, which is
not information that is available to the public. Even when armed with
employees' extensions, we still cannot reach them when the office's
phone line is busy or fails to connect.
Moreover, the average member of the public does not know how to access
a supervisor if their case is languishing or they are provided
contradictory information--and if by chance they are transferred to a
supervisor's voicemail from a frontline staff member, the supervisor
far too often fails to respond to voicemail messages at all.
There are additional problems with reaching DDS--the state agency
contracted by SSA to complete disability evaluations. Despite being a
year into the pandemic, the Disability Determination Services' notices
in California do not include the correct telephone number to reach the
person assigned to the case. Claimants call the telephone number listed
on notices only to reach a voicemail that states that the person cannot
accept calls at that number and a different telephone number must be
called. This could be easily remedied if DDS updated their notices to
reflect their employees' remote work telephone numbers.
These problems are not just occurring at one or two SSA offices in Los
Angeles, but across nearly all of the offices. We have heard similar
feedback from other non-profit agencies across California and
nationwide. For this reason, the SSA phone system needs to be
overhauled with more rigorous oversight to track numbers of dropped
calls, frequency and timeliness of returned voicemail messages, and
accuracy of information provided. Re-opening field offices in a limited
fashion with all Centers for Disease Control protocols rigorously
enforced would be another way to increase the public's meaningful
access to SSA.
3. SSA Field Offices and Hearing Offices fail to timely process
paperwork received by mail or by fax.
Prior to the pandemic, it was common knowledge among SSA advocates that
SSA would frequently fail to process submitted paperwork or would
process it only after a long delay and repeated telephone calls to
follow-up. As the pandemic has forced most documentation to be sent via
mail or fax, the processing has slowed down even further. As Deputy
Commissioner Kim stated, they continue to have very few staff members
in the office to process mail or faxes and they are receiving a massive
increase of documents to be scanned in. Although we certainly
appreciate the Administration's need to keep their staff safe by having
limited people on-site, they have to continue providing services to the
American public in a reasonable and competent way. Too often, we have
found that this is not the case, even more than a year after their
offices closed to the public.
These delays and failures to process paperwork are made worse by the
fact that the electronic systems of the different branches of SSA often
do not update each other. Thus, for example, we regularly need to
submit our Appointment of Representative forms more than three times in
order for them to be processed by a field office and even then, the
hearing office systems are not automatically updated to include the
representative's information.
SSA's repeated failure to process critical forms received by mail or
fax, including appeal forms, is a significant due process issue created
by the agency. SSA must have an effective and error-free system to
process forms and appeals. SSA has frequently lost appeals requests
sent by our office. These failures lead to claimants being incorrectly
told they missed an appeals deadline, claimant's representatives not
receiving timely notice of denials and approvals, and, most critically,
claimants being incorrectly terminated from benefits.
Moreover, we have found that field offices frequently fail to process
the Appointment of Representative (SSA-1696) forms we submit. When they
do not update their system to reflect that we are the representatives,
field offices refuse to provide us information on the status of cases
and do not send us notices in the case. This can lead to claimants
missing critical appeals or submission of evidence deadlines in their
cases. Offices have failed to send us notices about cases even after we
represented the claimant at a hearing. This has led to claims being
improperly closed. Further issues exist when organizations assisting
individuals call field offices for information on their claim. SSA
rules state that, if the claimant is on the phone, they may provide
verbal authorization for an advocate to receive information from SSA.
However, the countywide program we advise has found that this rule is
frequently ignored. SSA representatives have told advocates that verbal
authorization is not permitted, that there is no such rule, and will
even refuse to connect the advocate to a supervisor when requested.
The new process SSA has initiated in the last few months to allow for
electronic signing of the Appointment of Representative form is
unlikely to remedy the above problems.\2\ The process requires the
claimant to have an email address and to be able to e-sign the form
within five days after receiving the link from SSA in their email.
Given our clients lack of access to the Internet and the step-by-step
support they would need to follow the process, it is easier for our
clients to receive and sign a paper form.
---------------------------------------------------------------------------
\2\ As one obvious example, the e-1696 portal does not work in
Google Chrome as the link leads to a blank page that does not load.
This is nearly unbelievable given that nearly 50% of Internet users use
Chrome as their browser.
4. In-person appointments, even for critical issues, are an
---------------------------------------------------------------------------
illusory promise by SSA.
SSA has never had a system that enabled members of the public to make
their own appointments at a field office. An appointment could only be
made if a particular SSA field office representative chose to do so.
They frequently declined to do so prior to the pandemic and this has
not changed over the last year.
SSA stated in their testimony that they have in-office staff available
to handle ``critical in-office interviews that cannot be handled
online, through the mail, or over the phone.'' (Deputy Commissioner
Kim's Written Testimony, p. 5.) The SSA website says that a ``critical
situation'' exists when an individual lacks food or shelter and needs
to apply for benefits or when an individual receives benefits and
cannot receive a payment electronically.\3\
---------------------------------------------------------------------------
\3\ https://www.ssa.gov/coronavirus/. ``I Need Help with
Benefits.'' Visited May 8, 2021.
We have not heard of any in-person appointments, even in the above
situations, being offered to claimants in our region. There is no
online portal or centralized phone number to request an appointment for
an individual in these critical situations. Calling a field office also
does not guarantee that an appointment will be made as this has been
left completely to the discretion of individual field offices. It is
not clear from SSA's testimony that SSA representatives are, in fact,
scheduling appointments for individuals on a consistent basis. SSA
should create an online and telephone system to request appointments
and provide data on the number of appointments made for and attended by
---------------------------------------------------------------------------
claimants at the field offices.
SSA's poor results thus far in making in-person appointments available
to the public stands in contrast to other public agencies. As an
example, the California Department of Motor Vehicles moved quickly
after the beginning of the pandemic to make limited in-person
appointments available for critical issues. These appointments were
available at limited offices in early May 2020, just two months after
the pandemic began, and expanded to include additional offices later
that month.\4\
---------------------------------------------------------------------------
\4\ https://www.dmv.ca.gov/portal/news-and-media/select-dmv-field-
offices-reopen-to-public-2/. Announcing reopening of 25 facilities for
critical appointments that must be done in person. Visited May 8, 2021.
5. SSA has not created a system that enables individuals to safely
provide original documentation of their identity without sending
---------------------------------------------------------------------------
original documents in the mail.
SSA lacks a secure system for individuals to provide original
documentation. Although SSA explained in their testimony that they have
begun to pilot using drop boxes at field offices, this is not a
substitute for in-person verification of documents because it still
requires individuals to give over their critical primary identification
documents to a government agency without knowing when or how they will
be returned. Early in the pandemic, our agency heard from a client who
had been asked to mail her original Lawful Permanent Resident card to a
field office so that they could issue benefits. We were very concerned
due to the risk of inadequate security measurements being taken with
these documents, as has been confirmed in North Carolina,\5\ and were
therefore relieved when SSA issued guidance to the field offices
stating that this practice should be discontinued. However, SSA has
failed to consistently allow for any alternate means of presenting
original documents for verification. Immigrant clients, and some
naturalized U.S. citizens, are often required to provide original
documentation of immigration status or citizenship to the field office
after medical approval of an SSI or SSDI claim so that benefits may be
issued. There is no nationwide system in place for clients to safely do
so without risking their documents being lost.
---------------------------------------------------------------------------
\5\ Nate Morabito, ``SSA Mistake Sends Confidential Documents to
Wrong People in Charlotte,'' WCNC Charlotte, February 5, 2021, https://
www.wcnc.com/article/news/investigations/ssa-mistake-sends-
confidential-documents-to-wrong-people-in-charlotte/275-98f18187-5466-
4f4e-a730-0e648fed775e.
C. SSA HAS FAILED TO IMPLEMENT POLICIES THAT WOULD ALLEVIATE PROBLEMS
CAUSED BY THE COVID PANDEMIC
Deputy Commissioner Kim's written testimony states that, ``we have been
working hard to implement policies and engage in activities that
support the public during this difficult time. In our field offices, we
implemented emergency policy flexibilities . . .'' (Deputy Commissioner
Kim's Written Testimony, p. 4.)
Contrary to their testimony, SSA has failed to effectively use their
policy discretion in a meaningful way to address the problems caused
for the public by the COVID pandemic and the shuttering of SSA field
offices for the past year.
1. SSA has refused to make accommodations for claimants who are
unable to effectively communicate via telephone.
Some claimants, including those with intellectual disabilities or
limited literacy, have historically relied on visiting local offices in
order to understand and respond to information in Social Security
notices. SSA has failed to provide any means for in-person services
with claimants with such needs. These individuals are not provided with
information on how to make an in-person appointment in critical
situations or any other specific accommodations. This is despite the
fact that SSA knows which clients were approved for disability benefits
due to intellectual disabilities or significant mental illness who may
therefore require such accommodations. Additionally, many of our most
vulnerable community members who lack regular and meaningful access to
telephones or the Internet are left without any means of communicating
with SSA because they cannot meet in person with SSA employees at field
offices. SSA could begin to allow for more in-person office visits,
with all Centers for Disease Control protocols rigorously enforced.
2. Although SSA has expanded electronic access during the
pandemic, there continue to be significant barriers to electronic
communication with SSA personnel.
Given the difficulty of reaching field offices by phone, SSA should
expand their ability to receive information electronically. SSA has no
system where claimants or claimants' advocates can email a specific SSA
representative or fax a submission directly to a specific SSA
representative. We think it would be tremendously useful if claimants
and their representatives could email SSA employees directly. This
could be done in a safe manner that would limit the risk that
personally identifiable information is sent to an incorrect party.
As one example of policy flexibilities they have initiated, SSA stated
that they have ``expanded telephone attestation procedures in place of
requiring wet signatures.'' (Deputy Commissioner Kim's Written
Testimony, p. 4.) Far from exhibiting flexibility in following SSA
policy in order to best serve the public, we have instead found that
some field offices create non-existent policies that are barriers to
clients.
As one example of this, we represent a client where the field office
refused to process a Request for Reconsideration (SSA-561) for eight
months on the stated basis that the signature from the client
``appeared to be `an electronic signature' '' despite the fact that the
Request for Reconsideration does not even require a claimant signature,
much less a wet signature. Despite our repeated calls to the field
office, it nonetheless took 8 months and intervention by a supervisor
for the appeal request to be filed.
3. SSA has refused to create a blanket rule allowing for late
submissions of appeals due to the COVID pandemic and the closure of
field offices.
SSA stated that they, ``[e]xtended timeframes for the submission of
evidence and appeals due to mail delays or limited access to our
offices.'' (Deputy Commissioner Kim's Written Testimony, p. 4.)
However, SSA fails to state that they have not implemented any blanket
rules that direct field offices to accept late appeals or late
submission of evidence. SSA has left it to the discretion of individual
field offices to determine whether an individual claimant had a COVID-
19 related reason for filing the appeal late.\6\ In our experience,
this has led to wide variation in interpretation of this rule by
different field offices to the detriment of claimants.
---------------------------------------------------------------------------
\6\ ``What Do I Do if I Have Missed the Deadline to File My Appeal
Request?'', https://www.ssa.gov/coronavirus/.
It is tremendously difficult for low-income individuals, especially
those experiencing homelessness, to file an appeal of a denial or
termination of benefits. SSA does not include the appeal form or a pre-
addressed return envelope with notices that deny, reduce, or terminate
benefits. So, an individual must then find the correct form on the SSA
website and possess the ability to print out the form. Then, the
individual must correctly fill it out and mail it to the correct field
office. In practice, our low-income community members typically visited
a field office in person for assistance with obtaining, completing, and
submitting appeals forms. With the field offices closed, many
---------------------------------------------------------------------------
individuals are not able to complete these steps in a timely manner.
SSA should implement a blanket rule that allows for late submission of
appeals in all cases due to the continued closures of field offices
without requiring claimants to state a specific good cause reason. It
seems likely that good cause for late filing exists in all cases
because there is a nationwide pandemic, all SSA offices serving the
public have been closed for more than a year, most other public
services (such as libraries) have also been closed, and simply riding
on public transportation or leaving home at all has been hazardous.
4. SSA continues to hold claimants responsible for overpayments of
benefits even when the overpayment is due to SSA's late processing of
income or other information.
SSA stated that they ``published an interim final rule to streamline
the overpayment waiver process for beneficiaries who incurred
overpayment debts between March and September 2020 due to our deferral
of certain workloads. Under the streamlined waiver process, we can more
quickly waive recovery upon receiving a verbal request for qualified
debts.'' (Deputy Commissioner Kim's Written Testimony, p. 5.)
Although streamlining the waiver process for overpayments caused by SSA
is a step forward, SSA should instead automatically waive any such
overpayments. These are overpayments caused by the temporary deferral
of processing of information by SSA due to the pandemic. SSA can
identify any such overpayments and waive them. Requiring a claimant to
verbally request a waiver is an unnecessary barrier that will cause
many claimants to pay back overpayments that should have been waived.
In order to verbally request a waiver, a claimant must be able to: (1)
understand the reason for the overpayment, (2) know that they can ask
for a waiver, and (3) have the ability to call the field office and
request a waiver. As described above, we have found that it has become
increasingly difficult to get through by phone to field offices. For
claimants with limited or unstable phone access, making a verbal
request for a waiver is an unnecessary barrier when these overpayments
could instead be administratively waived by SSA without the need for
such a request.
D. SSA'S PARTNERSHIP WITH CLAIMANT ADVOCATES WORKING WITH VULNERABLE
POPULATIONS NEEDS TO RESPOND TO THE NEEDS OF
CLAIMANTS' ADVOCATES
Deputy Commissioner Kim stated in her written testimony that SSA has,
``entered into an unprecedented partnership with claimant advocates and
other organizations to promote our services and ensure they are
accessible to our most vulnerable populations.'' (Deputy Commissioner
Kim's Written Testimony, p. 4.)
Given the drastic decline in SSI applications and awards in 2020, it is
a positive step that SSA is reaching out to community organizations for
assistance in serving claimants. However, SSA has not offered any
concrete changes in systems to these organizations such as enabling
their access to information or improving communication with field
offices. They also are not providing any funding for this work, instead
relying on non-profits to seek independent funding.
1. Claimants' advocates have well-established and effective
programs assisting individuals file applications for SSI and SSDI and
SSA should create an effective collaboration with programs like ours.
Our organization works with a county-wide program that is similar to
the program run by Central City Concern, whose representative testified
at the hearing. There are hundreds of such programs nationwide that
have demonstrated success in assisting individuals apply for SSI and/or
SSDI benefits based on disability. As one example, programs that use
the SOAR model have a cumulative success rate of 65% for initial
applications.\7\ This is in comparison to the 37% initial approval rate
\8\ reported by SSA nationwide. The Los Angeles County program we work
with has a comparable approval rate. We have trained hundreds of non-
attorney advocates in drafting and filing SSI and SSDI claims, have
reviewed thousands of applications for benefits, and have a thorough
understanding of how the application process could be improved.
Nonetheless, SSA's initiative has not created a mechanism by which
organizations like ours can effectively collaborate with SSA to improve
their system.
---------------------------------------------------------------------------
\7\ See https://soarworks.prainc.com/article/soar-outcomes-and-
impact#::text=Cumulative%20
Outcomes%20(2006%2D2020)&text=Of%20the%20applications%20assisted%20using
,approved%20
on%20reconsideration%20or%20appeal.
\8\ See https://empirejustice.org/resources_post/ssa-publishes-
annual-waterfall-chart/.
2. SSA should fix known problems with claimants' advocates' access
---------------------------------------------------------------------------
to information.
SSA's first step in collaborating with claimants' advocates should be
to create streamlined mechanisms that allow these organizations to send
and receive information to field offices and DDS. As explained above,
one of the most significant barriers to advocates' work is the
inability to communicate easily with field offices. SSA should
designate a liaison at each field office and DDS office for these
programs, share designated SSA staff email addresses with advocates,
and ensure that Appointment of Representative forms are processed
quickly and consistently in all cases.
Additionally, there are other steps SSA could take to improve
electronic access to information through ERE. Although SSA recently
took the positive step of expanding ERE access at the initial and
reconsideration levels, the system does not appear to be implemented
consistently and is not available to all claimants' representatives.
Although attorneys at our agency have Electronic Records Express (ERE)
access, they have found that they still cannot access information at
the initial or reconsideration levels on a consistent basis.
Additionally, this system is only available to claimants'
representatives who represent claimants at the hearing level. Many of
the most effective programs assisting claimants with initial
applications are non-
attorney advocates who do not represent claimants at the hearing level.
This system should be immediately expanded to all claimants' advocates
and improved so that access is consistently and easily granted once an
Appointment of Representative form has been filed.
3. Claimants' advocates should be consulted on ways to reform the
application process to fix known problems.
As Tara McGuinness testified so eloquently, ``[t]his isn't just about
making paper applications digital. Digitizing a broken process gets you
a digitized broken process.'' (McGuiness's Written Testimony, p. 2.) We
agree completely. The complexity of the application process for SSI and
SSDI means that a claimant is virtually guaranteed to fail to provide
important information or miss a critical step in the process. Even
trained non-attorney advocates require constant technical assistance
support from our office in order to submit accurate and complete
applications for disability benefits. There are numerous, concrete ways
that the process may be improved and made responsive to claimants'
needs. We strongly encourage SSA to be directed to collaborate with
offices like ours that are on the front-line of assisting claimants
apply for benefits and find ways to expeditiously implement fixes for
the challenges that are identified.
Thank you for holding a hearing to address these very important
concerns. We appreciate the opportunity to provide a statement on the
issues raised.
Sincerely,
Rebecca Watson, Directing Attorney
Jin Lee, Supervising Attorney
Eve Rutzick, Supervising Attorney
______
International Association of Rehabilitation Professionals
1000 Westgate Dr., Suite 252
St. Paul, MN 55114
612-290-6260
Chairman Wyden, Ranking Member Crapo and Members of the Committee, the
International Association of Rehabilitation Professionals' (IARP) SSVE
Section is pleased to submit these comments in response to the Senate
Finance Committee's hearing on the impact of the pandemic on SSA's
service delivery and suggestions for improvements. IARP is the only
organization focused on and committed to comprehensively serving the
professional private rehabilitation industry. IARP has five specialty
practice sections--Rehabilitation and Disability Case Management;
Forensic Rehabilitation; Life Care Planning; Social Security Vocational
Expert; and Vocational Rehabilitation Transition Services. SSVE Section
members provide vocational expert testimony during hearings held before
SSA Administrative Law Judges to determine whether a claimant meets the
agency's definition of disability and should be awarded benefits.
We want to thank you for holding this hearing. Our members are
extremely concerned that SSA office closings during the COVID-19
pandemic are making it impossible for millions of low-income people
with disabilities to access Supplemental Security Income (SSI) benefits
that they desperately need. The SSI program provides modest payments to
low-income seniors, disabled adults, and families with disabled
children. While the need for these benefits has likely intensified
during the pandemic, access to them has been severely restricted.
Vocational experts anticipated an increase in SSI applications during
the current pandemic, as has occurred during previous economic
downturns. However, our members have noticed just the opposite: a sharp
drop in the number of hearings held as well as the number of initial
applications filed. We are concerned that administrative hurdles are
preventing potentially qualified people from applying for and receiving
these benefits.
In July of this year, SSA awarded SSI benefits to just over 25,000
disabled adults ages 18 to 64. That is the lowest monthly award figure
in the last 20 years for this group. It is also 40 percent lower than
the figure for this group for the same month in the previous year. With
regard to disabled children, SSA awarded SSI benefits to 8,400
claimants in July of this year. That is the lowest number of awards for
any month in the last 20 years for this group. It is also 43 percent
lower than the award figure for this group for the same month of the
previous year. Declines in awards on the order of 40 percent or more
will, over time, lead to hundreds of thousands of disabled individuals
missing out on vital cash and health benefits.
One reason for these sharp declines is the lack of effective outreach
following the closure of SSA's 1,200 field offices due to the COVID-19
pandemic. Before the pandemic, potential SSI recipients learned about
the program during in-person visits to their local field office. They
were able to request an application, get answers to their questions,
and submit the application directly to that office. It is imperative
that SSA take immediate steps to remove the hurdles caused by office
closures and other impediments to communicating with these offices
during the pandemic.
Unlike with other types of benefits that SSA manages, there is no
electronic option to apply for child SSI benefits, and only some
disabled adults can apply online. With the field office closures, the
only option SSI applicants have is to call the agency's toll-free
number and face telephone wait times that can stretch to hours. For
those who pay by the minute for their cell phone usage, including many
potential SSI applicants, the cost of hours on hold alone is
prohibitive to obtaining the assistance they need and deserve.
Safely reopening SSA Field Offices to the public as quickly as possible
is the ultimate solution. In the process of reopening, SSA should
prioritize marginalized populations such as SSI applicants. In the
meantime, SSA must identify ways to reach those who have been
disenfranchised due to pandemic closures. For example, establishing a
centralized SSI intake unit with dedicated, direct phone lines for
potential SSI applicants would be a good first step. In order to be
effective, SSA would have to engage in targeted mailings and other
forms of communication to inform the public of this option while field
offices are closed. Setting up contactless kiosks where potential
claimants could safely speak face-to-face with a Field Office employee
also would help to address the unmet need for assistance in applying
for SSI. Congress, as well, has an obligation to provide effective
oversight in order to ensure individuals who are unable to work due to
disability receive the services they need and are due under the law.
Fully funding SSA's administrative expenses will be essential to
assuring that those who qualify for benefits are able to access them.
We look forward to working with Congress and the Administration to
assure that the most vulnerable among us are able to access the Social
Security benefits they are entitle to and so desperately need.
Thank you for considering these comments.
Sincerely,
Michelle Aliff, Ph.D., CRC, CVE
Chairperson, SSVE Section
______
Justice in Aging
1444 Eye Street, NW, Suite 1100
Washington, DC 20005
202-289-6976
May 12, 2021
Senator Ron Wyden
Chair
U.S. Senate
Committee on Finance
Dirksen Senate Office Bldg.
Washington, DC 20510-6200
RE: April 29, 2021 Hearing on ``Social Security During COVID: How the
Pandemic Hampered Access to Benefits and Strategies for Improving
Service Delivery''
Dear Chairman Wyden,
This statement is submitted on behalf of Justice in Aging, an advocacy
organization with the mission of improving the lives of low-income
older adults. We use the power of law to fight senior poverty by
securing access to affordable health care, economic security, and the
courts for older adults with limited resources. We have decades of
experience with Social Security and Supplemental Security Income (SSI)
benefits, with a focus on the needs of low-income beneficiaries and
populations that have traditionally lacked legal protections such as
women, people of color, LGBT individuals, and people with limited
English proficiency. Justice in Aging conducts training and advocacy
regarding Social Security and SSI benefits, provides technical
assistance to attorneys and others from across the country on how to
address problems that arise under these programs, engages with the
Social Security Administration (SSA) to address issues around agency
policies and procedures that affect claimants' or beneficiaries'
abilities to access Social Security and/or SSI benefits, and advocates
for strong protections to ensure that beneficiaries receive the
benefits to which they are entitled promptly and without arbitrary
denial or disruption.
We thank you for holding this hearing on the important topic of service
delivery at the Social Security Administration (SSA). Our comments
focus on the SSA's Operations component because the Deputy Commissioner
of Operations was the agency's witness for this hearing.
Even prior to the COVID-19 pandemic, SSA faced difficulties providing
appropriate customer service. The pandemic worsened some challenges
while also introducing new barriers to access, particularly for low-
income individuals, including low-income older adults, limited English
proficient individuals, and people of color. It is vital that we
address these problems to allow people who are desperately in need of
benefits to receive them quickly and without unnecessary roadblocks.
Some improvements will certainly require changes to the law or
increased administrative funding, but there are some solutions that SSA
can implement itself right now. Congressional oversight of the agency's
activities will speed up these fixes and are important to demonstrating
the importance of appropriate support, funding, and other resources to
ensure that SSA is able to fulfill its mission.
We are grateful for SSA's communications with the public and advocates
throughout the pandemic. SSA is providing better services now than at
the beginning of the pandemic, when many government agencies and
private companies shut their offices and, where possible, began to
engage in remote work. SSA is even performing some of its work more
efficiently than it had been before the pandemic. Yet many challenges
remain.
Field Office Closures
In Fiscal Year 2019, SSA had more than 174,000 visits each day to its
network of over 1,200 field offices. With the closure of SSA field
offices in March 2020, SSA forced customers to adapt to an almost all-
virtual mode of communication. Some of the services the agency provides
were successfully replaced with phone calls, faxes, online services,
and mailed communications. For some, including some people with
disabilities, these other methods are preferable when they are
available and accessible. However, there is a significant subset of the
population SSA serves that lack Internet access, mailing addresses, or
minutes on their mobile phone plans. Some need services that SSA does
not provide online, like new Social Security cards; applying for
survivors' benefits; and SSI applications (only people age 18-64 who
are not blind, never married, and never made a claim for any SSA-
administered benefit can use iSSI, the online SSI system). Others are
blocked due to an inability to verify their identities using SSA's
system based on credit-bureau data--this means they cannot set up the
mySSA accounts needed to receive many of the agency's electronic
services.
Some people unable to navigate SSA's current systems have turned to
legal aid organizations, the media, or their members of Congress for
assistance. Others simply are not receiving the benefits for which they
qualify. We know that applications and awards for disability benefits
have declined significantly during the pandemic. This hurts many people
who go without financial supports or the Medicare or Medicaid that can
accompany them. It also means that SSA must prepare now for a coming
increase in people seeking the agency's services.
Inconsistent Levels of Service
There is considerable variation across and within field offices as to
how SSA's policies are applied and services are provided. Some field
office staff are quick to return phone calls and others are not. Some
offices scan mailed documents into the WorkTrack system quickly and
assign them to workers; in other offices, field office staff are unable
to review documents that have been sent in and ask for them to be re-
sent multiple times. Looking in from the outside at such a massive
agency with so many complex workloads, it is hard to know precisely how
SSA should improve efficiency and consistency. Collecting and
publishing management information, tracking how field offices compare
to each other on different metrics and adopting best practices from
high-performing offices, providing adequate training and resources, and
ensuring that productivity measures do not reward inaccurate work or
incentivize employees to ignore challenging cases are all parts of the
solution.
There are a number of areas where the variation in services leads to
barriers to access critical benefits. SSA did create the opportunity
for ``dire need'' appointments that would allow individuals who needed
them to have an in-person person meeting with SSA for certain limited
types of services. We've found, however, that some SSA field offices
are extremely reluctant to schedule these dire need meetings, even when
they are entirely warranted. For example, in December 2020 we heard
from a social worker in Seattle, Washington helping homeless veterans
secure housing. These individuals needed to receive benefit
verification letters from SSA within a short period of time as proof of
income to qualify for subsidized housing, but were unable to print out
a copy from an online my SSA account or receive a letter through the
mail due to their homelessness. Despite making repeated requests on
behalf of several homeless veterans, the social worker continued to be
told by the manager of the local field office that this situation did
not qualify for a ``dire need'' in person appointment. We were able to
bring this gross injustice to the attention of our contact in
Operations at SSA headquarters who intervened with the management of
that field office so that these veterans could secure urgently needed
housing during the pandemic.
Overpayment Waivers
For a portion of this pandemic, due to the difficult transition to
remote work that occurred for SSA and many other agencies and
businesses throughout the country, SSA prioritized certain types of
work and suspended others. We greatly appreciated the agency's efforts
to ensure that people were able to keep their benefits in the early
months of this pandemic. However, SSA resumed all of its workloads in
September 2020 (despite the fact that their offices remain closed and
the pandemic continues to hinder many people's ability to engage with
the agency), and we are concerned about the effects on people who
received overpayments through no fault of their own, and are now being
asked to pay back money that they very likely already spent. SSA has
put a process in place to waive these overpayments, however it is
insufficient to adequately help all those affected.
Instead, we have recommended to the agency that it provide automatic
waivers, bypassing the complicated and confusing steps that people
would have to take to seek out a waiver they obviously need and are
eligible for. Despite our recommendations, SSA has chosen not to
implement them, to the detriment of low-income older adults and people
with disabilities who cannot navigate the waiver process, or the uneven
administration of the policy at various field offices that may turn
them away improperly.
We've also begun to hear reports that SSA is claiming that SSI
recipients have overpayments based on their receipt of stimulus
payments. By law, these payments are considered tax refunds and
exempted from SSI resource limits for 12 months. However, some SSI
recipients are receiving notices stating that they were over the
resource limit during that time period due to the agency's failure to
apply these policies. SSI recipients who are able to obtain legal
services or other assistance can likely successfully contest these
alleged overpayments, but we are concerned that low-income, low-asset
people with disabilities and senior citizens without representation
will have their benefits further reduced (from a maximum of $794 per
month that is well below the poverty line) in order to recover
overpayments that never should have been assessed.
Paper and Non-Disability Appeals
Some of the most challenging cases for SSA to consider are about the
amount of SSI benefits someone should receive or if they meet SSI's
non-medical requirements. Such cases often involve evidence already
held by SSA, as well as financial documents like pay stubs and bank
account statements, and other documents like birth, marriage, and death
certificates. They can touch on issues of employment law, immigration
law, trusts and estates, family law, and more. Further complicating
matters is the fact that these cases are often not electronic. They are
paper files that get mailed to different SSA offices when the
beneficiary moves or appeals. Many of these paper files were stuck in
field offices or hearing offices for months during the pandemic.
Although SSA has recently begun tracking them, we know that there are
some that the agency acknowledges have been misplaced, have systems
issues that preclude processing them, or must be redeveloped. We also
believe that there could be paper files in SSA offices that the agency
is not tracking if they are on someone's desk, in a file cabinet, or in
another place that nobody has looked recently.
These are important cases, whether they involve many thousands of
dollars or a smaller change in SSI benefits. SSA should institute
better methods for tracking these cases and converting them to
electronic cases so they can be more easily transferred across offices
and more accessible to beneficiaries and appointed representatives.
Assistance for Legal Services, Community Organizations, and Other
Assisters
SSA's policies are complicated. Legal services organizations; service
coordinators; SSI/SSDI Outreach, Access, and Recovery (SOAR);
Protection and Advocacy systems; and Work Incentives Planning and
Assistance programs all provide critical help to individuals attempting
to access SSI and Social Security benefits. Congress should increase
SSA's budget specifically to provide funding to these important
organizations. As SSA attempts to engage the community to help make up
for the work that it is unable to perform while its field offices are
closed, we must support those organizations, which are already
operating under limited budgets themselves.
Racial Equity and Justice
SSA and other federal agencies have been tasked by the Biden
Administration with reviewing their programs, policies, and procedures
to determine whether there are racial equity issues preventing full and
fair access to benefits for people of color and others who have been
historically underserved. SSA must perform this same equity analysis in
determining who has or lacks access to services because of the
pandemic. Some of SSA's own research has already indicated that people
with limited English proficiency, for example, have had trouble
applying for SSI due to the lack of in-person services that the agency
used to provide. There must be additional efforts by SSA to study
whether claimants and beneficiaries who are people of color or from
other underserved groups are being disproportionately impacted by SSA's
current pandemic policies. SSA must collect data on race and ethnicity
to identify gaps in service, barriers to access, and other systemic
problems.
Conclusion
Thank you for your efforts on behalf of older adults and people with
disabilities, and the millions of others who interact with SSA. We
stand ready to work with you, other members of Congress, and SSA to
improve services to the public.
Sincerely,
Tracey Gronniger
Directing Attorney
______
National Disability Rights Network
820 First Street, NE, Suite 740
Washington, DC 20002-4243
Tel: 202-408-9514
FAX: 202-408-9520
TTY: 202-408-9521
Website: www.ndrn.org
Email: [email protected]
The National Disability Rights Network (NDRN) thanks the committee for
holding this important hearing on the Social Security Administration's
actions on delivery of services during the COVID-19 pandemic. We
appreciate the opportunity to raise concerns with SSA's running of the
Protection and Advocacy for Beneficiaries with Representative Payees
(PABRP) program during the height of the pandemic of March 2020 to
March 2021. As will be demonstrated below, SSA has attempted to thwart
the intent of Congress in passing the PABRP program and made the lives
of some of our most vulnerable individuals in this country, Social
Security beneficiaries with representative payees, more dangerous and
open for abuse and neglect.
NDRN is the voluntary membership association for the nationwide network
of Protection and Advocacy (P&A) agencies. The P&A agencies are
congressionally mandated, cross disability organizations operating in
every state, the District of Columbia, Puerto Rico, and the U.S.
Territories (American Samoa, Guam, Northern Mariana Islands, and the US
Virgin Islands). There is also a P&A affiliated with the Native
American Consortium which includes the Hopi, Navajo, and San Juan
Southern Paiute Nations located in the Four Corners region of the
Southwest. NDRN is also the National Association Grant (NAG) holder for
the training and technical assistance provided to the P&As under PABRP
program.
The PABRP program was created by Congress in 2018 to take advantage of
the expertise and knowledge of the nationwide network of P&A agencies
to ensure the health and well-being of the over 5 million Social
Security beneficiaries with representative payees, along with an actual
accounting of the benefits received. This intent to ensure the health
and well-being of these beneficiaries was clearly laid out in both the
statute and committee statement that was released.
Congress through both the statute and the statement recognized that
this was the most vulnerable population in the country to abuse,
neglect and financial exploitation, and that the nationwide network of
P&A agencies was best positioned to address all aspects (health, well-
being, and finances) of these beneficiaries. The past work of the P&A
agencies to monitor representative payees was well demonstrated and
recognized in multiple hearings before passage of the legislation.
Additionally, the Congress relied on the more than 40 years of work of
the nationwide network of P&A agencies to monitor and prevent abuse,
neglect and financial exploitation in assigning the P&A network this
task.
In March of 2020 as the nation went into a temporary closure to slow
the spread of COVID, NDRN and the P&A Network gathered to figure out
ways to continue to do the important monitoring work of the PABRP
program in order to ensure the health and well-being of this vulnerable
population during the COVID pandemic. Unfortunately, SSA's initial
response was to temporarily halt any new casework under the program,
even in the virtual ways developed to at least maintain some measure of
connection with the beneficiaries. After more than two months of
discussion, SSA finally relented to allow virtual monitoring to
continue and the P&As immediately began to reach out to these
individuals to check on their health and well-being.
But even though limited, this work done by the P&As during this time
was critical to beneficiaries. From March 16, 2020 through March 15,
2021, P&As interviewed 2,559 payees and 10,067 beneficiaries. This
monitoring led to 1,174 referrals to a variety of agencies including
Children and Adult Protective Services, licensing agencies, health and
safety inspectors and others. All told, this work positively impacted
151,508 individuals.
Given the events in the nation, those interactions clearly contained
questions around COVID related issues to assess the health and well-
being of the beneficiaries. To do otherwise, would have been to ignore
the Congressional intent of the program. What follows is some examples
of the issues uncovered by the P&A agencies during the year starting
March 2020-March of 2021:
Georgia
A beneficiary moved into a nursing facility with no personal
belongings, literally in bare feet and only the clothes on their body.
A family member served as payee and did not issue payment for housing
(beyond the first month) or spending money for personal needs. The
facility maintained a locked closet with spare clothing and socks that
were shared between a few residents who were also in need of clothing.
At the time of review, the nursing facility had not received rent for
this individual for almost six months. The P&A issued referrals to
Adult Protective Services and the local Health Department.
During outreach calls to facilities and group homes regarding
COVID-19, the P&A, Georgia Advocacy Office, talked with a provider in a
rural part of the state. This provider reported concern with lack of
access to testing even though people receiving services had exhibited
symptoms and 2 people had died within the past few weeks. When she
tried to get testing for the people she supports and for her staff, she
was told that their symptoms were not severe enough. The P&A provided
resources and information regarding testing in that part of the state.
The provider has since reported that everyone was tested.
The P&A, Georgia Advocacy Office, is calling providers and
facilities to offer resources, ask about COVID-19 policies and
practices that they have in place, and to ensure that they have access
to PPE and have trained staff appropriately. They talked to a
developmental disability provider who manages several group homes and
learned that their PPE supply was very low and they had submitted a
request to the Department of Public Health which was denied. The P&A
followed up with the Department of Public Health and the state's
developmental disabilities agency and discovered there was a systemic
issue with the request for PPE from DD providers. The P&A's work
resulted in not only resolving the issue for that particular provider,
but for other DD providers in the state as well.
Michigan
A beneficiary experiencing homelessness was told by Payee that
their monthly SSI was only $400, but records show it was $771 a month.
The difference could not be found, and the payee had no information
about where the missing funds went. The P&A's review included the
following:
Several beneficiaries' landlords complained about
consistently late rent.
A beneficiary who rents out a storage unit
learned that the bill wasn't paid. Upon following up with the payee,
the beneficiary was neither given a response about whether the overdue
bill was paid, or if the contents were removed due to nonpayment.
Another beneficiary made several requests in
advance for cash to pay for medical visits and medication. These
requests were initially ignored, then denied because ``there isn't
enough money.''
Another beneficiary received threats of
cancellation from the electric company, then paid the overdue bills out
of pocket. The beneficiary requested that the payee reimburse the late
fee but was denied. This beneficiary was also put ``on probation'' for
allegedly calling the payee too often.
A beneficiary's family member serves as payee and legal
guardian. The family member stated that the first stimulus check went
to the county court to pay off child support in arrears without the
beneficiary's knowledge or consent. The beneficiary asked the P&A to
assist with finding a new payee and guardian.
Payee withheld Personal Needs Allowance (PNA) from beneficiaries
for several months and used stimulus funds to establish a burial
account for a beneficiary who specifically stated they want to be
cremated.
A staff person will only disburse PNA ``when they
feel like it,'' and refused a beneficiary access to their own TANF card
because it would be ``double-dipping'' since they already receive $25
for groceries each week.
Payee I payee maintained beneficiary bank accounts in the red;
some nearly -$1000. The payee also requires beneficiaries to purchase
their own toilet paper, paper towels, and other bathroom supplies
(including cleaning supplies). The P&A made a referral to the state
licensing bureau.
Payee rents their home to three beneficiaries. One beneficiary
hosted an overnight guest, to which the payee responded by physically
assaulting the beneficiary and evicting them immediately, claiming it
was against house rules to have overnight guests. The P&A's report
resulted in the beneficiary getting a new place to live and being
served by a new payee.
Maryland
When a beneficiary was being interviewed, they shared that their
roommate was beaten by a staff person with the remote control to their
adjustable bed. The P&A followed up with a referral to the state office
of Healthcare Quality.
New Jersey
Payee withheld Personal Needs Allowance (PNA) from a beneficiary
who was described by staff as ``confined to a bed,'' and ``having no
use for money.''
PNA was withheld from another beneficiary who was
told by a caseworker that they ``live on a locked unit and it would be
dangerous to give them money.''
Payee has issued a beneficiary's family over $7,000 total as
reimbursement for various purchases, none of which were made for the
beneficiary. They included gifts for other relatives and financial
assistance to their grandmother to purchase groceries. The family
believes these funds are an extension of their own financial resources.
Staff made complaints about this, resulting in a closed-door meeting
with the payee and the family. The P&A's review included referrals to
ABLE and SSA's Office of the Inspector General.
New York
During an interview with the P&A, a beneficiary reported having
been repeatedly physically assaulted by a housemate. The beneficiary
reported this to Payee, who did not intervene by helping the
beneficiary find a new place to live. At the time of the review, the
beneficiary's caseworker was still ``working on it.''
A beneficiary had a prepaid cell phone with two days left on it;
when they called the payee for additional funds, Payee hung up on them.
The same beneficiary said that requests for grocery money were denied
due to a history of substance abuse.
Another beneficiary asked for the status of their
stimulus funds and the person answering the phone said, ``We called SSA
and they said it was fine for us to go ahead and spend it.'' The same
beneficiary was threatened with institutionalization if they did not
use contraceptives.
A staff person was quoted to have called
beneficiaries ``fat,'' ``disabled,'' and ``incompetent'' to their
faces. They were also quoted as having said behind beneficiaries' backs
but within earshot, ``I can't stand working with these f'n people. I
hate them. All they do is smoke and drink off other people's money.''
The same staff person also made a false report to the police alleging
domestic violence against a beneficiary's husband, resulting in his
immediate arrest.
Payee lacked a plan to control a COVID outbreak, resulting in
the death of a beneficiary with complex medical needs. Staff did not
consistently provide the level of care they needed, resulting in
bedsores and falling out of bed.
Another beneficiary was covered in open sores and
was reported to have fallen out of bed at least five times. Their
clothing was shared throughout the floor because ``we share here,'' as
a staff person reported to the P&A.
On their birthday, a beneficiary was found by
their family wrapped in excrement-soaked bedsheets. The family took
photos and called the police and the local news to prevent the facility
from ``sweeping this under the rug.''
The P&A stated that the finance coordinator for
the facility claimed not to know how staff conduct themselves while on
the clock.
Ohio
A beneficiary was denied access to their own bank statements,
was refused money to repair or replace a broken vacuum, was denied
funds to have the exterior of the home repainted and had contact with
Payee maybe once a month. The beneficiary is now their own payee.
Payee rents a two-bedroom apartment that is shared by six other
people--five are beneficiaries they are responsible for, and one is a
family member who is in a relationship with one of the beneficiaries.
There are makeshift bedrooms in the kitchen and living room.
Mismanagement of funds caused one beneficiary to leave and become their
own payee.
The payee retained the stimulus checks for at
least two beneficiaries, as well as the unused funds of the beneficiary
who is now their own payee.
Virginia
A beneficiary was found to have been sexually assaulted while
living in a facility operated by Payee; tests concluded it was likely
done with a foreign object. The perpetrator was never identified. The
beneficiary passed away from COVID complications before alternative
housing could be secured.
Another beneficiary had bedsores so deep they
reached the bone and had both hips broken after being dropped by staff.
The head nurse was able to obtain Power of Attorney (POA) over the
beneficiary without the family's knowledge or consent, and subsequently
did not discuss with the family how their SSI was being used.
Currently, the beneficiary lives elsewhere and has family serving in
the roles of POA and payee.
Another beneficiary was denied access from using
the telephone on the floor they lived on, resulting in the family not
being able to call. The family expressed concern due to the pandemic,
especially while not being able to visit in person. The P&A made a
referral to the state licensing agency.
West Virginia
Payee has zero contact with beneficiaries. When the reviewer
asked why not, the payee appeared to disagree with the obligation
payees have to maintain regular contact with beneficiaries.
The payee was also found to have withheld grocery
money from a beneficiary.
Payee business office is inaccessible to people using
wheelchairs. The reviewer made a referral to the payee for the
accessible renovation of the office.
With guidance from a job coach, a beneficiary was
working at a hotel as a housekeeper but was not being paid. When the
beneficiary inquired about getting a paycheck, the job coach said,
``You're not getting paid right now.'' Not long after, the employee was
let go.
Personal Needs Allowance was withheld as a means
of deterring direct support staff from accessing cash in the house.
A beneficiary's landlord continually made unwanted sexual
advances. Payee did not assist with finding new housing, so the
beneficiary (independently) contacted a service coordinator for help.
Now, though, SSA is calling this work of the P&A agencies to monitor
around COVID-related issues as being outside the scope of the program.
This continues a long running trend of SSA throwing up barrier after
barrier to implementing this program, and fits into a pattern of
resistance to anything that is outside what SSA considers to be its
sole function, the issuance of retirement or disability benefit funds.
This is especially true for this program where P&A agencies find
unsuitable payees that by the sheer nature of their actions should
require removal as that individual's payees. SSA does not want to have
to address those issues by finding a suitable payee so they would
rather not know.
This long-running pattern of barriers also includes overly stringent
requirements on how reviews are done, which does not recognize that
flexibility is needed when interviewing people with different types of
disabilities, the requirements that all equipment be SSA authorized
equipment which creates delays and additional administrative headaches
in the obtaining of necessary equipment, and delays or lack of response
to reviews or simple questions.
Another issue that has been raised, which causes SSA pause in its
support of the program, is that the P&As are encountering the
inconsistencies within SSA. Some of those inconsistencies are between
headquarters and the regional offices (ROs) and field offices (FOs),
but more often are occurring between the individual ROs and FOs within
the same region. As a nationwide network of agencies we are seeing
these inconsistencies, but when alerted to them SSA tends to ignore
them and not correct these inconsistencies.
As demonstrated above, the PABRP program has been extraordinarily
effective, even with all the barriers SSA and the pandemic have thrown
in the way. But if SSA is continued to be allowed to subvert the intent
of Congress of the PABRP program to ensure the health and well-being of
Social Security beneficiaries with representative payees by insisting
that things like the examples above are outside the scope of the
program, people with disabilities who don't have control over their
finances and use a rep payee will not receive the intended benefits of
the PABRP program.
NDRN calls on the Congress to reinforce the clear legislative language
and intent of Congress that the P&A agencies are supposed to be
monitoring the health and well-being of the beneficiaries, not just
verifying that every penny is properly accounted for. NDRN also calls
on SSA to work collaboratively with NDRN as the NAG and the P&As as the
organizations doing the reviews to streamline the existing
administrative burdens to make the program more effective and efficient
and finally to ensure consistency between the national headquarters and
the ROs, between the ROs themselves, and the FOs within an individual
region on how the program is administered.
Congress took an important step in 2018 to ensure the health, well-
being, and financial security of beneficiaries by employing the P&A
network to do these important reviews. SSA should not be allowed to
undermine the effectiveness and efficiency of these programs through
their faulty interpretations.
______
National Organization of Social Security Claimants' Representatives
161 Airport Executive Park
Nanuet, NY 10954
Telephone: (845) 682-1880
email: [email protected]
April 28, 2021
Senator Ron Wyden
Chair
U.S. Senate
Committee on Finance
Dirksen Senate Office Bldg.
Washington, DC 20510-6200
RE: April 29, 2021 Hearing on ``Social Security During COVID: How the
Pandemic Hampered Access to Benefits and Strategies for Improving
Service Delivery''
Dear Chairman Wyden,
This statement is submitted on behalf of the National Organization of
Social Security Claimants' Representatives (NOSSCR), a specialized bar
association for attorneys and advocates who represent Social Security
Disability Insurance (SSDI) and Supplemental Security Income (SSI)
claimants throughout the adjudication process and in federal court.
Although NOSSCR members and staff engage with many components of the
Social Security Administration (SSA), these comments focus on the
services provided by the Office of Operations because Deputy
Commissioner of Operations Grace Kim is the agency's witness for this
hearing.
SSA's Operations component--which oversees field offices, program
service centers, state disability determination service agencies
(DDSs), international operations, and more--underwent major, rapid,
changes during the COVID-19 pandemic. This in turn required members of
the public, including disability claimants and beneficiaries, as well
as those who represent them, to adjust the ways they interact with SSA.
Some aspects of the changes were positive: for example, we commend SSA
for publishing the direct phone numbers for each field office on the
agency website so people could call them directly, instead of having to
go through the national 800 number. We appreciate that when we learned
that some field office staff were directing people to mail in their
green cards, Operations leadership issued a reminder that this was
against SSA and Department of Homeland Security policy and instructed
staff to offer in-person appointments when hands-on verification of
these documents were necessary. And NOSSCR had a helpful discussion
with the Office of Earnings and International Operations that led to
better communications and process improvements for claimants and
beneficiaries living abroad.
Unfortunately, the pandemic also made many aspects of interacting with
SSA more difficult and amplified many existing challenges. We will
highlight a few of these issues below.
Challenges for Applicants
Closing field offices to the public means that it is harder for
claimants, especially unrepresented claimants, to apply for benefits.
We see this in the steep declines in disabled worker and SSI disability
applications and awards over the past year. Research shows that when
one field office closes in an area, it reduces the number of disability
claims among people who would have been likely to be awarded benefits:
closing all field offices, unsurprisingly, had an even greater effect.
One area where we are especially concerned is for people over age 62
with disabilities, who may apply for early retirement without realizing
that they can also apply for SSDI. These claimants could have received
retirement benefits while their disability claims were pending and
received higher benefits and earlier eligibility for Medicare if they
were found to be disabled, but if they apply online without field
office staff to explain these complexities, many may just take the
reduced retirement benefit and have less financial stability for the
rest of their lives.
Field Office Interactions
When most field office employees began full-time telework at the start
of the pandemic, the effects varied widely. Some NOSSCR members
reported that it was easier than ever before to reach SSA staff by
phone and they could quickly resolve issues. But in other offices,
phones were rarely answered and voicemails were not returned. It is not
clear to us how SSA tracks productivity or compares field offices to
identify best practices and areas of concern.
A small number of field office employees have been working in person
throughout the pandemic to process mail and faxes. We appreciate their
service and realize that their jobs are extremely challenging. There
are often more documents that need to be opened, scanned, connected to
a specific claimant or beneficiary, and routed to teleworking employees
than the people working in person can handle. This creates serious
consequences for the public, who may be overpaid or underpaid until SSA
processes their communications, or who must go long periods without
important documents they mailed in for verification.
One example of document-processing challenges is the SSA-1696 form,
which claimants and beneficiaries use to appoint representatives.
Delays in processing the 1696 were a challenge before the pandemic, but
COVID made it worse. Whether the 1696 is mailed, faxed, attached to an
appeal, or submitted electronically with the online form SSA created
this year, an SSA employee must still type information about the
claimant and representative into several different computer systems and
take other manual steps. Until this is done properly, a representative
does not receive notices, cannot view the electronic file, and cannot
communicate with SSA or DDSs about their client's case.
State Agency Challenges
State agencies, also known as DDSs, make medical determinations on
disability claims at the initial and reconsideration levels and for
Continuing Disability Reviews. Before the pandemic, some DDSs did a lot
of telework and some did none. The pandemic led to much more telework
and some states adjusted much better and quicker than others. In some
states, mail piled up for weeks and months, fax machines were untended,
and it was not possible to communicate with DDS staff. Even today,
there are wide variations in how DDSs are operating--some state to
state and some employee to employee within a given state.
This is especially challenging because representatives' access to
electronic case files are more limited at the DDS level than when a
case is scheduled for an Administrative Law Judge (ALJ) hearing or
review by the Appeals Council (AC). Representatives for cases at the
DDS levels cannot view the A, B, or D sections of the claims file
online but need to be sent an encrypted CD. They do not have access to
a status report of all their cases, and cannot upload evidence in the
same way they can at the ALJ or AC levels. They are more reliant on
faxes, phone calls, and the mail. And as described above,
representatives can only communicate with DDSs about a case once the
field office has processed their 1696s.
DDS backlogs have grown tremendously during the pandemic, though there
is wide variation across states. DDSs nationwide received 11.5% fewer
initial claims and 13.3% fewer requests for reconsideration in the last
nine months of 2020 than they did in those same months of 2019.
Although fewer cases were coming in, there were 26.5% more pending
initial cases and 49.4% more pending reconsiderations in December 2020
than in April 2019. At the end of 2020, there were 887,829 initial and
reconsideration claims pending at DDSs. Each claim represents someone
waiting, often desperately, for SSI or SSDI.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Source: https://www.ssa.gov/disability/data/ssa-sa-mowl.htm.
There is no one correct amount of processing time. Some cases involve
more evidence, more barriers to communication, or more complicated
facts. It is possible for a case to be moved too quickly: if a decision
is issued before medical providers have the chance to submit evidence
or before the 1696 is processed and a representative can communicate
about the claim, then everyone is poorly served. But NOSSCR members
often report that they have submitted all evidence in clear-cut cases
that languish for months at DDSs--and that it is difficult or
impossible to contact anyone at the DDS to address these concerns.
Paper and Non-Disability Appeals
At times, SSA must adjudicate not whether a person meets the medical
standard for disability, but whether they qualify for SSI or Title II
benefits (and for what amount of benefits they qualify) based on age,
work history, marital status, citizenship, income, assets, living
situation, and a plethora of other criteria. These ``non-disability''
cases can be extremely complex. Adding to the complexity, many of these
cases are not electronic but rely on paper files that are mailed from
one SSA office to another. Some disability cases are also ``paper
cases.''
SSA has had extreme difficulty processing paper and/or non-disability
cases during the pandemic. SSA leadership has communicated to some
extent with advocates about these issues. The agency has made some
progress, but the number of cases pending in field offices that need to
be moved to the Office of Hearing Operations has actually increased in
the past few months. Cases awaiting effectuation of ALJ decisions,
cases pending due to systems issues, and cases that SSA misplaced or
needs to redevelop are also not decreasing. And we remain concerned
that SSA may have paper files that are not included in these statistics
because they have been lost in field offices or not properly tracked.
These situations can sometimes be resolved with the efforts of a
dedicated representative, but unrepresented claimants have an even
harder time. Proper adjudication of these cases is crucial if SSA is to
provide due process, comply with Congressional intent, and reach high
standards of payment accuracy.
Communicating with Program Service Centers and Workload Support Units
SSA has a variety of offices within the Operations component that even
before the pandemic were much more opaque to the public than field
offices or DDSs. These include the Office of Central Operations (OCO),
Program Service Centers (PSCs) and Workload Support Units (WSUs). The
pandemic has made it even harder for claimants, beneficiaries, and
representatives to get information from those offices, which play
critical roles in effectuating benefits, addressing over- and
underpayments, and processing claims. Notices can be confusing,
telephone messages are often not returned, and field office staff are
frequently unwilling or unable to inquire about cases being handled by
OCO, PSCs or WSUs.
For example, NOSSCR and other member organizations of the Consortium
for Citizens with Disabilities Social Security Task Force asked SSA to
establish ways for representatives to send documents to PSCs, as SSA
did with the Representative Call Center at OCO. SSA's written response
was, ``Representatives should continue to fax material to the PSCs
using the existing channels they have relied on for service in the
past.'' The problem is that SSA has not published any fax numbers for
the PSCs (there is a single fax number only for fee payment issues for
Title II claimants under age 54, whose claims are processed at OCO, not
the PSCs). The system of submitting documentation to field offices who
would then send them on to PSCs was barely serviceable before the
pandemic and has completely broken down now that there is limited staff
going to the field offices. Publicizing fax numbers and/or secure email
addresses for representatives to submit documentation directly to PSCs
would speed effectuation and reduce an unnecessary burden on field
office staff. When questioned again about this, SSA's response was
The Social Security Office Locator webpage now displays the fax
lines and phone numbers for each of our Field Offices (FOs).
While our employees continue to work remotely during the
pandemic, they are able to receive faxes electronically and
take all appropriate action on cases. The FO will route the
material to the Payment Center (PC) if the FO is unable to work
the case. We want to keep these existing communications
channels intact during the pandemic to ensure we handle the
flow of work into our FOs and PCs efficiently. If there is an
extended processing delay, please contact the local field
office via their general inquiry line.
This again misses the point that communicating through the field
offices is inefficient and extremely flawed. Expecting field office
managers to do ``manager to manager'' communications with the PSCs on
behalf of represented claimants, while they are also often the only
people physically in the office to process all mail and faxes and
handle in-person appointments, is not reasonable.
Similar issues exist with the WSUs that handle online claims. When a
representative files a claim on behalf of their client, the WSU (or
field office, if they are processing the claim) needs to send the
claimant an attestation to make sure the person really did want to
file. That is a good thing, but it seems to be working less well
recently, probably partially because of SSA and partly because of
declines in the US Postal Service's speed and accuracy. NOSSCR members
note that some WSUs seem to be working better than others and that some
but not all field offices can see what documents are in the WSU's
WorkTrack system of files scanned and waiting to be processed. This
means that in some cases, if the claimant submitted the attestation
packet but it hasn't been processed, field office staff could check the
WSU's WorkTrack and communicate with a representative. This is
especially helpful when a disability claimant qualifies for expedited
processing (for dire need, presumptive disability, compassionate
allowances, etc.), but this is not universal. It is not clear what data
Operations collects with regard to WSUs, what backlogs there are at
different WSUs, and how SSA plans to reduce them.
Effectuating Benefits and Representative Fees
When SSA does determine that a person qualifies for disability
benefits, there are a host of actions that must be taken to calculate
retroactive and ongoing benefits for the claimant and his or her
dependents (considering factors like the Windfall Elimination Provision
and Government Pension Offset; worker's compensation offsets; SSI rules
on income, assets, and living arrangements, etc.); determine where to
send the benefits (direct deposit or Direct Express card; to the
claimant or a representative payee); handle Medicare eligibility; pay
representative fees and state Interim Assistance reimbursements;
communicate with the Treasury Department for any offsets; and more.
This effectuation process is complicated and time-consuming, but it is
incredibly important to ensure that the proper benefits are paid.
Problems that predated the pandemic have only worsened over the past
year. Notices of Award (NOAs) are often delayed, sent to the claimant
and not the representative, or lost in the mail and SSA will not issue
a replacement. And sometimes the Notice is not accurate: it might have
math errors, inaccurately characterize a government pension or workers'
compensation, leave off auxiliary beneficiaries, etc. This causes
challenges for ensuring that benefits are effectuated properly, and
representative fees are accurately paid. And as described above, it can
be nearly impossible to talk with the people who are effectuating the
cases, either at field offices, OCO, or PSCs. It would be helpful to
know what management information SSA collects on if the NOA was sent
out in a timely fashion, whether it was also mailed to the
representative as the POMS directs, and if it is accurate. Does anyone
at SSA compare claims processed by OCO, the different district offices,
and various Program Service Centers to see how they are doing on this
workload, collect best practices, and provide additional training to
staff who are not sending NOAs or sending inaccurate ones?
Sometimes effectuating a decision requires reviewing documents like
birth, death, or marriage certificates or proofs of citizenship. With
field offices closed, effectuation is more difficult. SSA only allows
in-person appointments for benefit issues when the beneficiary is
without food, shelter, utilities, or medical care or coverage and
requires an in-person appointment to resolve it. This is interpreted in
very different ways by different hearing offices and individual
employees. When appointments are offered, they are often many weeks or
months away; people are sometimes told that their only option is to
mail the documents and they are understandably hesitant to do so.
There are also delays and inaccuracies in the representative fee
process. Again, this is not a new issue but it has become harder to
resolve during the pandemic. NOSSCR often hears from members who helped
their clients receive favorable disability determinations and have been
waiting over a year to be paid for their services. In some situations,
SSA withholds 25% of a claimant's past-due benefits, but takes months
or years to determine what portion goes to the claimant and what to the
representative. In other cases, SSA misapplies its own policies and
fails to properly withhold past-due benefits to pay the
representative's fee. SSA should collect and publish more data about
the timely and accurate processing of representative fees, and include
goals on this topic in the agency's Annual Performance Report and
Plans.
Conclusion
Thank you for your consideration of this statement and for your
valuable oversight of SSA in this hearing and many other ways. We would
be glad to provide additional information to the Committee if that
would be helpful.
Sincerely,
Barbara Silverstone
Executive Director
______
National Treasury Employees Union
800 K St., NW, Suite 1000
Washington, DC 20001
Statement of Anthony M. Reardon, National President
Chairman Wyden, Ranking Member Crapo and members of the Committee,
thank you for allowing NTEU to submit its thoughts on methods to
improve service delivery at the Social Security Administration. NTEU
represents approximately 150,000 federal employees in 34 agencies
including 1,900 attorneys and paralegals in the Social Security
Administration's Office of Hearings Operations (OHO). The Office of
Hearings Operations (OHO) handles appeals of disability claims. OHO
strives to issue legally sufficient decisions and award benefits to
disabled claimants as early in the process as possible. But in recent
years the hearing process has been encumbered by insufficient
resources, inadequate staffing, expanding case files, expansive changes
in regulations, conflicting operational messages, and escalating
internal tensions. There are many features of the process that could be
changed to improve service delivery, but NTEU would like to highlight
three areas that are important to the employees we represent.
Permanently expand telework. The pandemic has proven, once and for all,
the value of a robust telework program in the federal government.
Maximum telework policies have protected the health and safety of
federal workers around the country, and their families, without
sacrificing productivity. Prior to the pandemic, OHO attorneys
generally were allowed to telework three or four days per week. Due to
the pandemic, employees are currently on mandatory full time telework
whenever possible and have reported increase productivity and increased
employee satisfaction. NTEU believes telework should be expanded to the
maximum extent possible. Post-probationary employees should be required
to be in the office no more than one day per pay period and when needed
for training or other office activities. We also believe that OHO
should consider implementing a full time telework program like the
innovative program that has been so successful at the NTEU-represented
U.S. Trademark Office. Expanded telework would improve employee
productivity and retention as well as offering the potential savings
from the Social Security Disability Insurance Trust Fund by reducing
the leasing costs of OHO Offices. The pandemic has proven this program
works. The Agency should take advantage of that.
Support rural broadband. NTEU strongly supports the Administration's
proposal to expand rural broadband. When the mandatory telework orders
were issued due to the pandemic, there were at least fifty OHO
employees' with work that was perfectly portable who lacked
satisfactory broadband in the rural area in which they lived to
actually work remotely. Both workers and communities in rural America
would benefit from more federal and private sector employees being free
to work remotely in rural areas and we hope Congress will support the
rapid expansion of rural broadband to help make this a reality.
Public service student loan forgiveness. The Attorney-Advisors at OHO
are generally a young workforce and the unacceptable level of turnover
has negatively impacted the ability of the office to fully perform its
function. Our members believe an important tool for recruiting and
retaining the best employees would be to cancel the student loan debt
of employees who have completed a decade or more of public service. The
Public Service Loan Forgiveness (PSLF) program was created to ease the
burden of student loan debt for a generation of those who have chosen
careers in public service. But after years of scandal and allegations
of widespread mismanagement, it is clear to NTEU that the federal
government has fundamentally failed to deliver on this promise. Since
2017, when the first public service workers became eligible for debt
cancellation, 98 percent of those who applied for PSLF have been
rejected. And that is just the tip of the iceberg--for every borrower
who has served for a decade and been rejected for PSLF, tens of
thousands have been knocked off track or never had the opportunity to
apply for relief. Ensuring this program works for public servants is
vital to recruiting and retaining qualified employees at OHO and across
the federal government and we look forward to working with Congress and
the Administration to ensure this benefit is available for employees.
I appreciate this opportunity to present NTEU's views.