-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-02-802					        					        
  TITLE:     SSA Disability: Enhanced Procedures and Guidance Could
Improve Service and Reduce Overpayments to Concurrent Beneficiaries  
     DATE:   09/05/2002

		 
This is the accessible text file for GAO report number GAO-02-802 
entitled 'SSA Disability: Enhanced Procedures and Guidance Could 
Improve Service and Reduce Overpayments to Concurrent Beneficiaries' 
which was released on September 05, 2002.



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Report to Congressional Committees:



United States General Accounting Office:



GAO:



September 2002:



SSA Disability:



Enhanced Procedures and Guidance Could Improve Service and Reduce 

Overpayments to Concurrent Beneficiaries:



GAO-02-802:



Contents:



Letter:



Results in Brief:



There Are Over 1 Million Concurrent Beneficiaries and Few Work:



Little Coordination of DI and SSI Programs Exists for Concurrent 

Beneficiaries Who Work:



The Application of Both DI and SSI Rules Makes It Difficult for 

Concurrent Beneficiaries to Make Informed Decisions about Work 

Activity:



Conclusions:



Recommendations for Executive Action:



Agency Comments and Our Evaluation:



Appendix I: Scope and Methodology:



Appendix II: Comments from the Social Security Administration:



Tables:



Table 1: DI and SSI Work Incentive Programs:



Table 2: Percentage of Working Concurrent and SSI Beneficiariesï¿½ 

Monthly Earnings at Various Levels:



Figures:



Figure 1: Primary Impairments of All Concurrent Beneficiaries and 

Concurrent Beneficiaries Who Worked:



Figure 2: Effect of Earnings on the DI and SSI Benefits of a 

Concurrent Beneficiary:



Abbreviations:



DI: Disability Insurance:



PSC: program service centers:



SSA: Social Security Administration:



SSI: Supplemental Security Income:



Letter:



September 5, 2002:



The Honorable Max Baucus

Chairman

The Honorable Charles E. Grassley

Ranking Minority Member

Committee on Finance

United States Senate:



The Honorable Bill Thomas

Chairman

The Honorable Charles B. Rangel

Ranking Minority Member

Committee on Ways and Means

House of Representatives:



In calendar year 2001, the Social Security Administration (SSA) paid 

cash benefits of nearly $60 billion to more than 6 million working-age 

adults with disabilities and eligible family members under its Social 

Security Disability Insurance (DI) program,[Footnote 1] and nearly $20 

billion to more than 3.5 million working-age adults with disabilities 

under the Supplemental Security Income (SSI) program. In addition to 

cash benefits, the DI program provides access to Medicare and for most 

beneficiaries the SSI program provides access to Medicaid. Some 

beneficiaries, known as concurrent beneficiaries, receive cash and 
medical 

benefits from both programs. To encourage beneficiaries to return to 
work, 

the DI and SSI programs offer work incentives that are designed to 
lessen 

the effect of earnings on benefits, by allowing beneficiaries to test 
their 

ability to work without losing all benefits. However, many of the work 

incentives in the two programs differ. These differences can create 

challenges for SSA in administering these programs for concurrent 

beneficiaries.



The Ticket to Work and Work Incentives Improvement Act of 1999 

(P.L. 106-170) requires us to assess the coordination of the DI and SSI 

programs for individuals who are concurrently entitled to benefits. 

This report discusses (1) the characteristics of concurrent 

beneficiaries, (2) the extent to which SSA coordinates the DI and SSI 

program rules when individuals are working and concurrently receiving 

benefits from both programs, and (3) the potential effect of applying 

both DI and SSI program rules on concurrent beneficiariesï¿½ decisions to 

work and on their benefits.



To address these issues, we analyzed data from SSAï¿½s Characteristic 

Extract Record for September 2001 and February 2002. This record 

contains information used to determine the eligibility for SSI 

benefits. We interviewed SSA officials at their headquarters in 

Baltimore, Maryland, and at seven field offices. We also interviewed 

academic researchers, advocates for people with disabilities, and a 

small number of disability beneficiaries. In addition, we reviewed SSA 

laws, regulations, and policies on the work incentive provisions of the 

two programs. We performed our work in accordance with generally 

accepted government auditing standards from September 2001 through 

August 2002. (See app. I for a detailed description of our scope and 

methodology.):



Results in Brief:



Concurrent beneficiaries comprised about 14 percent of SSAï¿½s disability 

population; 58 percent have mental impairments and about 53 percent are 

female. About 11 percent of concurrent beneficiaries worked and earned 

a median income of approximately $250 per month. More than three-

quarters of those who worked received benefits on the basis of mental 

illness or mental retardation. The proportion of individuals with 

mental retardation who worked was twice the proportion of concurrent 

beneficiaries with mental illness. However, working concurrent 

beneficiaries with mental retardation earned much less that those with 

mental illness.



There is little coordination between SSI and DI program rules for 

individuals who work and receive benefits from both programs 

concurrently. Because most field office staff specialize in one 

program, they may not be sufficiently knowledgeable of the procedures 

for the other program to ensure that concurrent beneficiaries who work 

are paid the appropriate benefit amount under both programs. The 

guidance SSA provides to assist staff in this task is not well-

integrated or sufficiently cross-referenced to help busy field office 

staff determine what actions to take when current beneficiaries work. 

In addition, SSA has not established procedures to ensure that both DI 

and SSI program staff receive information related to concurrent 

beneficiariesï¿½ work activity. Moreover, SSA does not monitor the 

overall processing of work activity and may not always take timely 

action, especially for DI benefits, which can result in overpayment of 

DI benefits for concurrent beneficiaries even when beneficiaries report 

their work in a timely manner. SSA recently took steps to improve 

service to concurrent beneficiaries, including testing the use of a 

field office employee specially trained in work issues and developing a 

new computer system to collect information about work. However, it is 

too early to know whether these initiatives will have the intended 

effect.



Applying both SSI and DI program rules to concurrent beneficiaries may 

make it difficult for them to make informed decisions about attempting 

work and could result in an increase or decease in overall income, 

depending on the amount of earnings. Concurrent beneficiaries may not 

receive adequate explanations from SSA staff or from published 

materials about the complete effect work has on their disability 

benefits. However, because the rules are complex and may be difficult 

to understand even with a detailed explanation, beneficiaries who do 

not understand them could possibly make decisions about work that would 

not meet their needs or improve their situation.



We make recommendations in this report that SSA develop methods for 

collecting information and sharing it across the DI and SSI programs 

and improve management information systems for tracking work activities 

of concurrent beneficiaries. We also recommend that SSA improve its 

guidance to employees regarding concurrent beneficiaries as well as 

develop new public information materials specifically for concurrent 

beneficiaries.



SSA provided comments on a draft of this report. SSA agreed with our 

conclusions and highlighted initiatives either planned or underway that 

it believes will address our recommendations.



Background:



SSA administers two programs that provide benefits for individuals who 

are unable to work because of disability. Although they differ with 

respect to program purpose and requirements for entitlement, both DI 

and SSI use the same definition of disability for initial entitlement. 

Specifically, in order to be found disabled, an individual must have a 

medically determinable physical or mental impairment that (1) has 

lasted or is expected to last at least one year or result in death and 

(2) prevents an individual from engaging in substantial gainful 

activity.[Footnote 2]



DI was established in 1956 as an insurance program to help replace 

earnings lost because of disability. To be eligible for benefits, 

individuals with disabilities must have a specified number of recent 

work credits under Social Security based on age as of onset of 

disability. Individuals may also be able to qualify on the work record 

of a deceased, retired, or disabled parent or a deceased spouse. 

Benefits are financed by payroll taxes paid by covered workers and 

their employers, and are linked to the workerï¿½s earnings history. In 

most cases, individuals who have been entitled to DI benefits for 24 

months qualify for Medicare.



The SSI program was established in 1972 to provide a standard minimum 

level of income for individuals with disabilities, as well as aged 

individuals, who have limited income and assets. Eligibility does not 

require a past work history. Benefits are paid from general revenues 

and, in general, most beneficiaries are eligible for the same benefit 

amount. However, other income counts against this benefit amount, 

usually resulting in a reduction in that amount. In most states, 

entitlement to SSI means automatic entitlement to Medicaid.



Most beneficiaries qualify for either one program or the other; 

however, receipt of benefits under one program does not necessarily 

preclude entitlement under the other program. Beneficiaries who are 

receiving one benefit may transition to the other benefit or they may 

receive both benefits concurrently. Receiving an SSI benefit has no 

bearing on continuing entitlement to DI benefits. However, because SSI 

is a means-tested program, the amount of the DI benefit must be 

considered in determining whether an individual with a disability also 

qualifies for SSI. If the amount of the DI benefit is low and all other 

income and resource factors are met, a DI beneficiary may also receive 

an SSI benefit. Concurrent beneficiaries who are covered by Medicaid 

and who have been entitled to DI long enough to qualify for Medicare 

may also be eligible for payment of their Medicare premiums and co-

payments by their state. The minimum value of these payments would be 

$54.00 a month.



Both programs feature work incentive provisions that are intended to 

encourage beneficiaries to return to work. However, the provisions of 

the two programs differ significantly, providing different levels of 

safeguards for continuing eligibility, income, and medical coverage for 

DI and SSI beneficiaries. For example, earnings, regardless of the 

amount, do not affect a DI beneficiaryï¿½s cash benefit for a period of 

time known as the trial work period. However, benefits will eventually 

stop completely after this period if earnings exceed a specified level. 

In contrast, earnings can affect an SSI beneficiaryï¿½s cash benefit 

immediately but the reduction in benefits is gradual with a reduction 

in benefits of $1 for every $2 earned over the first $65. Table 1 

highlights each programï¿½s work incentive provisions in effect at the 

time the Ticket to Work and Work Incentives Improvement Act of 

1999[Footnote 3] called for this study. Even with the work incentive 

provisions in the two programs, relatively few disability beneficiaries 

work and no more than 1 percent leave the DI and SSI beneficiary rolls 

each year because of their work.



Table 1: DI and SSI Work Incentive Provisions:



Type of safeguard: Income; Provisions by program[A]: DI: Impairment-

related work expenses: Allows the costs of certain impairment-related 

items and services needed to work and paid for by the beneficiary to be 

deducted from gross earnings in determining whether earnings indicate 

that the individual has performed substantial gainful activity.; 

Subsidies: Allows the value of the support a person receives on the job 

to be deducted from earnings to determine whether earnings indicate 

that disability has ended.; Trial work period: Allows beneficiaries 

to work for 9 months (not necessarily consecutively) within a 60-month 

rolling period during which they may earn any amount without affecting 

benefits. To qualify as one of the 9 months, earnings must exceed a 

specified amount (currently $560 a month). After the trial work period, 

cash benefits continue for 3 months and then stop if countable earnings 

exceed a specified amount (currently $780 a month; $1,300 a month for 

legally blind beneficiaries).; Unsuccessful work attempt: Allows for 

the exclusion of brief periods of work activity that stopped because of 

the beneficiaryï¿½s impairment from the consideration of benefit 

cessation following completion of the trial work period.; Extended 

period of eligibility: Allows for a consecutive 

36 month period after the trial work period in which cash benefits are 

reinstated for any month countable earnings fall below a specified 

level (currently $780 a month; $1,300 a month for legally blind 

beneficiaries). This period begins the month following the end of the 

trial work period.; Provisions by program[A]: SSI: Impairment-related 

work expenses: Same as DI, except that these expenses are also deducted 

from gross earnings in computing the monthly SSI benefit amount.; ; 

; Subsidies: Same as DI.; Earned income exclusion: Allows 

beneficiaries to exclude half of all earned income in excess of $65 

when determining the SSI payment amount. (In addition, beneficiaries 

may exclude from earned income any portion of the $20 general income 

exclusion that was not applied to unearned income.); Section 1619(a): 

Allows beneficiaries to continue to receive SSI cash payments even when 

monthly earnings exceed a specified amount (currently $780 a month). 

However, as earnings increase the payment decreases.; Plan for 

achieving self-support: Allows beneficiaries to exclude from their SSI 

eligibility and benefit calculation any income and resources used to 

achieve a work goal.; Student earned income exclusion: Allows student 

beneficiaries under age 22 to exclude higher levels of earned income 

than with the regular earned income exclusion, with both monthly and 

annual limits on the exclusion. Eligible students must not be married 

or the head of the household.; Blind work expenses: Allows 

beneficiaries receiving SSI on the basis of blindness to deduct from 

gross earnings the cost of all expenses associated with work activity 

in figuring the cash benefit.



Type of safeguard: Medical coverage; Provisions by program[A]: DI: 

Continued Medicare coverage: Allows for continued Medicare coverage for 

at least 39 months following a trial work period as long as medical 

disability continues.; Medicare buy-in: Allows beneficiaries to 

purchase Medicare coverage after the 39 month premium-free coverage 

ends. Beneficiaries pay the same monthly cost as uninsured retired 

beneficiaries pay, but individuals may be eligible for a reduction in 

the premium if they or their spouse or former spouse have a significant 

work history.; Provisions by program[A]: SSI: Impairment-related work 

expenses: Same as DI, except that these expenses are also deducted from 

gross earnings in computing the monthly SSI benefit amount.: Section 

1619 (b): Allows beneficiaries to continue receiving Medicaid coverage 

needed to continue working even when earnings become too high to allow 

a cash benefit. Coverage continues until earnings reach a threshold 

amount, which varies in every state.



Type of safeguard: Eligibility; Provisions by program[A]: DI: Continued 

benefit while in an approved vocational rehabilitation program: Allows 

a person actively participating in a vocational rehabilitation program 

to remain eligible for cash and medical benefits even if he or she 

medically improves and is no longer considered disabled by SSA.; Re-

entitlement to cash benefits and Medicare: After a period of disability 

ends, allows beneficiaries who become disabled again within 5 years to 

be re-entitled to cash and medical benefits without another 5 month 

waiting period. (Different rules apply to beneficiaries who qualify on 

the work record of a spouse or parent.); Provisions by program[A]: SSI: 

Impairment-related work expenses: Same as DI, except that these 

expenses are also deducted from gross earnings in computing the monthly 

SSI benefit amount.: Continued benefit while in an approved vocational 

rehabilitation program: Same as DI.; Property essential to self-

support: Allows beneficiaries to exclude from consideration in 

determining SSI eligibility the value of property that is used in a 

trade or business or for work. Examples include the value of tools or 

equipment.



[A] In effect as of December 17, 1999, the date the Ticket to Work and 

Work Incentives Improvement Act was signed into law.



Source: GAO Analysis of SSA law, regulations and policy guidance.



[End of table]



DI and SSI beneficiaries who do return to work are responsible for 

reporting their work activity to SSA as soon as it occurs. SSA has no 

specific provisions for adjusting benefits for concurrent beneficiaries 

who work and must apply the work incentive provisions of the two 

programs independently to determine whether an individual remains 

entitled to DI and SSI and, if so, the amount of each benefit. Most 

concurrent beneficiaries interact with SSA through its network of 

nearly 1,300 field offices. To cope with the complexity of its 

programs, most of these field offices use employees who specialize in 

either the Social Security programs, including the DI program, or the 

SSI program. The remaining offices use generalist employees who are 

trained in both programs. To supplement the information provided by its 

staff, SSA also publishes several pamphlets that explain the provisions 

of the DI and SSI programs. Two of these publications, Red Book on 

Employment Support and Working While Disabled--How We Can Help, provide 

information about the effect of work on DI and SSI benefits.



There Are Over 1 Million Concurrent Beneficiaries and Few Work:



Concurrent beneficiaries, who comprised about 14 percent of SSAï¿½s 

disability population, were likely to have mental impairments and be 

female. In addition, their average age was 45. About 11 percent of 

concurrent beneficiaries worked and had a median earned income of about 

$250 a month. More than three-quarters of those who worked have mental 

impairments--mental illness and mental retardation.[Footnote 4] 

Individuals with mental retardation worked at twice the rate of 

beneficiaries with mental illness, but earned much less. The median 

earnings of beneficiaries with mental retardation were nearly half 

those of beneficiaries with mental illness.



More than One-half of Concurrent Beneficiaries Have Mental Impairments:



Of the more than 6 million working-age adults receiving disability 

benefits under the DI program and the more than 3.5 million working-age 

adults receiving SSI, our analysis of the February 2002 SSA data 

indicates that, approximately 1.2 million[Footnote 5]--14 percent--

received benefits from both programs. These beneficiaries were an 

average age of 45, with fewer than 15 percent between the ages of 17 

and 30. In addition, 53 percent were female. Concurrent beneficiaries 

received an average DI payment of about $430 per month and an SSI 

payment of about $150 per month. The majority of concurrent 

beneficiaries qualified for DI benefits on the basis of their work 

record. The remainder received benefits on the basis of the work 

history of a deceased, disabled, or retired parent (25 percent); or 

their deceased spouse (3 percent).



Over half of concurrent beneficiaries had a mental impairment--a third 

had mental illness and about a quarter had mental retardation. 

Approximately one-ninth of concurrent beneficiaries had an impairment 

related to their muscular or skeletal system. The remaining 

beneficiaries had one of a wide range of impairments as their primary 

impairment.



About 11 Percent of Concurrent Beneficiaries Work but Earn Relatively 

Low Wages:



Of the approximately 142,000 concurrent beneficiaries who worked, 

almost 80 percent had a mental impairment. Concurrent beneficiaries who 

worked were more likely to have mental retardation, tended to be 

younger, and male. As shown in figure 1, while individuals with mental 

retardation made up only a quarter of the concurrent population, they 

accounted for over half of the concurrent beneficiaries who worked. 

Moreover, nearly half may not have had a significant work history. 

Instead, they qualified for benefits on the basis of the work history 

of a parent or spouse.



Figure 1: Primary Impairments of All Concurrent Beneficiaries and 

Concurrent Beneficiaries Who Worked:



[See PDF for image]



Source: GAO analysis of SSA data.



[End of Figure]



Most concurrent beneficiaries who worked earned low wages, but earnings 

levels varied by impairment categories. While the median earned income 

of all working concurrent beneficiaries was approximately $250 per 

month, more than one-quarter earned $65 per month or less.[Footnote 6] 

Workers with mental retardation had median monthly earnings of about 

$200, compared with about $400 for concurrent beneficiaries with mental 

illness. However, the median earned income for concurrent beneficiaries 

eligible for DI benefits on the basis of the work history of a 

deceased, disabled, or retired parent was only $85 per month.



A higher proportion of concurrent beneficiaries worked than SSI 

beneficiaries,[Footnote 7] but they earned much less. Fewer than 8 

percent of SSI beneficiaries worked, but they had median earnings of 

$400, compared with about $250 for concurrent beneficiaries. More than 

one-quarter of SSI beneficiaries earned $1,000 per month or more, 

greater than three times the percentage of concurrent beneficiaries 

with earnings at that level. Table 2 provides the percentage of 

concurrent and SSI beneficiaries that were earning at the levels 

listed. The difference in earnings may be explained, in part, by the 

higher proportion of working concurrent beneficiaries with mental 

retardation as compared with SSI beneficiaries. However, this higher 

incidence of beneficiaries with mental retardation does not completely 

explain the difference in earnings since the earnings for SSI 

beneficiaries with mental retardation were higher than those for 

concurrent beneficiaries with mental retardation. For example, median 

monthly earnings for SSI beneficiaries with mental retardation were 

$250 compared with $200 for concurrent beneficiaries with the same 

impairment.



Table 2: Percentage of Working Concurrent and SSI Beneficiariesï¿½ 

Monthly Earnings at Various Levels:



Earnings: $1-65; Percent of working concurrent beneficiaries: 26.2; 

Percent of working SSI beneficiaries[A]: 19.5.



Earnings: $66-99; Percent of working concurrent beneficiaries: 4.0; 

Percent of working SSI beneficiaries[A]: 3.8.



Earnings: $100-199; Percent of working concurrent beneficiaries: 13.1; 

Percent of working SSI beneficiaries[A]: 10.4.



Earnings: $200-299; Percent of working concurrent beneficiaries: 10.6; 

Percent of working SSI beneficiaries[A]: 8.0.



Earnings: $300-399; Percent of working concurrent beneficiaries: 9.2; 

Percent of working SSI beneficiaries[A]: 6.3.



Earnings: $400-499; Percent of working concurrent beneficiaries: 7.7; 

Percent of working SSI beneficiaries[A]: 5.9.



Earnings: $500-599; Percent of working concurrent beneficiaries: 7.6; 

Percent of working SSI beneficiaries[A]: 5.1.



Earnings: $600-699; Percent of working concurrent beneficiaries: 6.0; 

Percent of working SSI beneficiaries[A]: 4.3.



Earnings: $700-799; Percent of working concurrent beneficiaries: 3.9; 

Percent of working SSI beneficiaries[A]: 3.7.



Earnings: $800-899; Percent of working concurrent beneficiaries: 2.7; 

Percent of working SSI beneficiaries[A]: 3.5.



Earnings: $900-999; Percent of working concurrent beneficiaries: 1.9; 

Percent of working SSI beneficiaries[A]: 2.9.



Earnings: $1000 or more; Percent of working concurrent beneficiaries: 
7.2; 

Percent of working SSI beneficiaries[A]: 26.5.



[A] Includes individuals who receive SSI benefits, but not DI benefits.



Source: GAO analysis of SSA data.



[End of table]



Our analysis of data available on the use of work incentives indicated 

that, while 11 percent of concurrent beneficiaries worked, they did not 

take advantage of most of the work incentives available to them under 

the SSI and/or DI programs. Most concurrent beneficiaries who worked 

used the earned income exclusion under the SSI program that reduces 

cash benefits by $1 for every $2 earned, but the other incentives were 

not widely used. The next most frequently used work incentive was the 

Impairment Related Work Expenses provision, which allows beneficiaries 

to exclude the costs of certain impairment-related items and services 

needed to work. It was used by fewer than 3 percent of concurrent 

beneficiaries who worked. Concurrent beneficiariesï¿½ use of work 

incentives was comparable to that of SSI beneficiaries. Because 

beneficiaries may not meet all the eligibility requirements for work 

incentives, it may be difficult to determine whether the low rates of 

use of work incentives were attributable to the inability to meet 

eligibility factors or lack of understanding of the provisions.



Little Coordination of DI and SSI Programs Exists for Concurrent 

Beneficiaries Who Work:



There is little coordination between SSI and DI program rules, 

especially for concurrent beneficiaries who work and, as a result, SSA 

must apply the complex provisions of the two programs independently. 

The specialization of most SSA field office staff in either the DI or 

SSI program makes it difficult to serve concurrent beneficiaries 

effectively. Specialists in one program lack integrated guidance to 

readily determine the effect of work on the benefits in the other 

program. Moreover, because the guidance does not adequately cross 

reference the DI and SSI rules that pertain to concurrent 

beneficiaries, these specialists may not recognize the need to 

communicate information about work to the other program as required by 

SSA guidance. In addition, SSA has not established formal operating 

procedures that ensure that this information is collected and 

communicated nor has it established a monitoring system to ensure that 

appropriate actions are taken. Because information on the work 

activities of concurrent beneficiaries may not be exchanged between the 

two programs or acted on in a timely manner, SSA may be overpaying 

benefits. SSA took steps recently that have the potential for improving 

service to concurrent beneficiaries and increasing the accuracy of 

their payments by better coordinating the administrative process 

related to work activity. For example, SSA officials have created a new 

position and new software to handle work-related issues for all 

beneficiaries, which could provide better integrated service to 

concurrent beneficiaries. Because these initiatives are still being 

tested and evaluated, it is too early to know whether they will have 

the intended effect if implemented nationwide.



Lack of Integrated Guidance and Operational Procedures Increases the 

Difficulty Specialized Staff Have in Effectively Serving Concurrent 

Beneficiaries:



SSAï¿½s guidance for administering the DI and SSI programs may contribute 

to the difficulty encountered by staff that specialize in one program 

but are required to collect information about both programs for 

concurrent beneficiaries. SSAï¿½s written guidance for both programs is 

contained in a voluminous document of about 35,000 pages divided into 

multiple parts.[Footnote 8] A DI specialist collecting work activity 

information from a concurrent beneficiary may find it challenging to 

use the multi-part guidance for DI benefits and even more challenging 

to use the guidance for SSI that would also be needed for a concurrent 

beneficiary.



SSA guidance does not provide integrated instructions for processing 

work information reported for concurrent beneficiaries or an integrated 

explanation of the effect of work on both DI and SSI benefits. 

Available guidance usually segregates information by program and 

provides little cross-referencing to issues that may be common to both 

programs. In addition, the cross-referencing that is provided does not 

always direct specialists to the specific procedures to follow for the 

other program. For example, the guidance for dealing with a DI 

beneficiary who returns to work contains a single cross-reference to an 

81 page section of SSI policy and procedural statements. However, this 

81 page section does not explain the basic effect of work on benefits. 

To determine the specific procedures and how work affects the personï¿½s 

SSI benefits, the DI specialist would need to go to yet another section 

of SSI guidance without the benefit of a cross-reference to find it. 

The need for efficient and accessible guidance is particularly 

important in field offices where heavy workloads and changing 

priorities often compete for employee attention.



The lack of integrated guidance may contribute to SSA not collecting 

all the required information on concurrent work beneficiaries. In some 

offices, concurrent beneficiaries report their work activity to either 

a DI or SSI specialist who collects the information he or she believes 

necessary to determine the amount of benefits that should be paid under 

both programs. Some specialists reported that they did not always know 

when an individual was a concurrent beneficiary and did not always know 

what information to collect about the other program. In other offices, 

a concurrent beneficiary reported to a specialist in each program. If 

the beneficiary is unable to meet with both specialists, SSA may not 

collect all the information needed to adjust benefits correctly.



Even if the information is collected, some field offices lack standard 

procedures for ensuring that information about the work activity is 

shared between programs. Some field offices have established local 

procedures for sharing this information, but these procedures may not 

always be adequate. For example, in one field office we visited, the 

SSI specialists who usually collected information about work activity 

from concurrent beneficiaries would copy and share the information with 

one designated supervisor who was responsible for taking the actions 

necessary to adjust DI benefits. Even with this procedure in place, the 

supervisor told us she was not confident that she was receiving all the 

information that was being reported by concurrent beneficiaries.



SSA Does Not Monitor Its Process for Accounting for Work Activity, 

Often Resulting in Untimely Actions That May Cause Overpayments:



SSAï¿½s procedures for determining the appropriate DI benefit amount when 

concurrent beneficiaries work make it difficult to adjust benefits in a 

timely manner. When a concurrent beneficiary reports work, the field 

office handling the case can adjust the SSI benefit, when warranted. In 

contrast, in most cases, field office employees cannot take immediate 

actions to adjust DI benefits because they cannot be adjusted until the 

beneficiary has completed a 9 month trial work period.[Footnote 9] At 

the beginning of the trial work period, SSA procedures direct the field 

office to transfer DI cases to one of seven program service centers 

(PSC) for documenting the start of this period. At the end of this 

period, the PSC is supposed to return the case to the field office, 

which then determines whether the beneficiary will continue to be 

entitled to benefits. However, SSA does not routinely monitor or have a 

comprehensive system that tracks actions on cases as they move between 

SSA components and automatically identifies the cases may be nearing 

the completion of the trial work period. As a result, the field offices 

may not be notified immediately upon the completion of a trial work 

period and, therefore, may not know whether or not to terminate DI 

benefits. Employees in several field offices told us that they often do 

not receive the cases back from the PSCs in a timely manner. Their 

estimates of the time it took the PSC to return these cases for further 

action ranged from 1 to 10 years. SSA officials could not verify these 

delays because they told us that they did not systematically collect 

information about these time frames. These problems occur not only when 

administering the trial work period for concurrent beneficiaries, but 

for all DI beneficiaries who return to work.



Untimely actions may also occur because the tasks related to adjusting 

benefits after the end of the trial work period are given a lower 

priority than other workloads. Several SSA officials told us that many 

tasks associated with adjusting benefits to account for work activity 

do not receive workload credits that help maintain or increase field 

office staffing levels. For this reason, field office managers 

generally give a higher priority to tasks that do, such as processing 

initial claims for benefits. However, an SSA headquarters official 

recently told us that SSA will focus greater attention on the post 

trial work period workload as it implements the Ticket to Work program.



Because SSA employees do not always evaluate and take action related to 

the work activity in a timely manner, some DI beneficiaries continue to 

receive benefits that they are no longer due. When DI beneficiaries 

earn more than a specified amount[Footnote 10] in any month after 

completing the trial work period, as of that month, SSA no longer 

considers the person disabled and should end their DI benefits 2 months 

later. However, several SSA officials told us about a one-time analysis 

of SSA disability overpayments based on cessation of disability in 

calendar year 2000 that revealed that about one-half of the overpayment 

dollars were made to people who should not have received benefits 

because of their earnings. Given this analysis, failure to take timely 

actions when DI beneficiaries work may account for about $350 million 

dollars in overpayments for calendar year 2001.[Footnote 11]



SSA established a temporary new position in July 2000, the employment 

support representative, which has the potential to address the 

challenges it faces in serving concurrent beneficiaries. SSA developed 

the position, in part, to concentrate on the needs of disability 

beneficiaries who work and tested it with 32 SSA employees who had 

responsibility for 54 field offices. These representatives received 

extensive training in the work incentive provisions of both the DI and 

SSI programs. This training prepared them to take the necessary actions 

for both programs without the need to rely on unfamiliar program 

guidance. Moreover, funneling all work activity cases through a single 

employee would allow this individual to develop a level of expertise 

that was not possible in the traditional field structure. Further, 

combining all duties related to disability beneficiaries who return to 

work into a single position could eliminate the problem of specialists 

in one program failing to share information with the other program. In 

addition, since these representatives do not share responsibility for 

handling the case with the PSC, they could take actions to adjust DI 

benefits in a timelier manner.



It is unclear whether SSA will make this position permanent, and to 

what degree. In a November 2001 report, an SSA workgroup recommended 

that the position be implemented permanently in as many of its 1,300 

service locations as feasible. While the 32 employment support 

representatives continue to perform the duties of this position, the 

agency has not announced decisions about the ultimate fate of this 

position. As of July 2002, SSA officials were still evaluating the 

resource implications of implementing this position in most of its 

field offices. Without additional resources, some field office managers 

told us they would have to divert existing staff from their current 

positions to assume the employment support representative role. SSA has 

not evaluated the timeliness of actions taken by the employment support 

representatives to adjust benefits. However, the employment support 

representatives with whom we spoke thought that the additional costs 

associated with the new position could be offset by the reduction in 

overpaid DI benefits from their more timely actions.



In addition to testing the employment support representative position, 

SSA is developing a new computer system that may potentially help to 

improve the timeliness of actions in response to the work activity of 

DI beneficiaries. Scheduled for release at the end of calendar year 

2002, the new program will allow SSA for the first time, to collect 

information about the monthly earnings of all DI beneficiaries who are 

working. This information should provide the basis for a systematic 

method for SSA to determine whether additional action is needed to 

determine continuing eligibility for of DI benefits. However, SSA is 

still deciding what additional information the new system should 

include and what reports it should produce to monitor all the actions 

needed to account for the work activity of DI beneficiaries and to 

adjust benefits in a timely way.



The Application of Both DI and SSI Rules Makes It Difficult for 

Concurrent Beneficiaries to Make Informed Decisions about Work 

Activity:



Just as SSA has no special procedures for administering the rules for 

concurrent beneficiaries, it does not provide concurrent beneficiaries 

with any integrated explanation of the effects of work on both DI and 

SSI benefits through its public information materials. The numerous 

publications that SSA has issued explain how work affects one benefit 

or the other. SSA extends this practice of not integrating their 

explanations of the effects on benefits by sending beneficiaries two 

separate letters, one to explain changes in DI benefits and another to 

explain SSI benefits. In addition, SSA field office specialist 

employees that lack expertise about both programs may provide 

incomplete or incorrect information about these effects.



While it may be difficult to communicate, it is important for 

concurrent beneficiaries to understand that work activity affects their 

benefits at different levels of earnings and at different times, 

depending on the program. For example, concurrent beneficiaries with 

relatively low earnings may be able to maintain both benefits while 

increasing their total income. However, as earnings increase, so does 

the probability that they will eventually lose one or both benefits. 

Figure 2 illustrates these effects of work activity at three earnings 

levels on the DI and SSI benefits. At low earnings, a beneficiary 

receiving the average DI benefit who starts working in February 2002 

retains DI and SSI benefits throughout the 13 month period shown. In 

contrast, a beneficiary with high earnings--higher than substantial 

gainful activity--will lose both benefits during the same period.



Figure 2: Effect of Earnings on the DI and SSI Benefits of a Concurrent 

Beneficiary:



[See PDF for image]



Note: Computations are based on the following assumptions: an 

individual (1) has the average monthly DI benefit of $430 for 

concurrent beneficiaries, (2) has an SSI benefit of $135 and no income 

other than earnings, (3) began work in February 2002, (4) lives in a 

state that does not supplement the federal SSI benefit and (5) has 

Medicare and does not need Medicaid to continue working. For the sake 

of simplicity, no cost-of-living adjustments have been estimated for 

2003.



Source: GAO Analysis of SSA law, regulations and policy guidance.



[End of figure]



Because the work incentive provisions of the two programs are designed 

to encourage beneficiaries to test their ability to work without losing 

their benefits, concurrent beneficiaries who understand the rules of 

both programs can make decisions that best support their priorities for 

income, services, and self-sufficiency. Concurrent beneficiaries who 

wished to become self-sufficient would need to understand that, to 

maintain an equivalent of their level of benefits and services, they 

would need to earn enough to make up for the eventual loss of cash 

benefits and health insurance and benefits and services from other 

sources. Concurrent beneficiaries who are uncertain about their ability 

to sustain work can focus on working at a level that preserves enough 

benefits to support them while they test their ability to work. In 

determining what level of work they can pursue, these beneficiaries 

would have to weigh the value of non cash benefits that depend on 

income and assets such as housing or social services compared with the 

earnings from increased work activity. For example, a service provider 

told us about one concurrent beneficiary who was receiving in-home 

support services from his county that allowed him to live 

independently. However, he returned to work and was then earning too 

much to continue to qualify for these services. He determined that he 

could continue to qualify for the support services by working 1 hour 

less per week and he negotiated the change with his employer.



Concurrent beneficiaries who do not understand the programsï¿½ provisions 

may make decisions about work that will make them worse off 

financially. Some concurrent beneficiaries do not work at all because 

they are afraid of losing their benefits. For example, two social 

service providers with whom we spoke indicated that some of their 

clients with mental retardation and the family members who helped them 

make decisions would avoid any work activity. Even though some earnings 

would not significantly affect benefits, they feared the loss of any 

benefit and health insurance and decided to forego the additional 

income they could have earned. At the other extreme, beneficiaries may 

inadvertently lose the benefits and health insurance they need by 

earning more than the allowable limits under one or both of the 

programs.



Concurrent beneficiaries who do not understand the full range of work 

incentives may not pursue provisions that might ease their transitions 

to work. For example, one young concurrent beneficiary who was working 

part-time and attending college told us that SSA employees had never 

explained two SSI work incentive provisions that would have allowed her 

to exclude more of her earned income from the total used to determine 

her benefit. This would have allowed her to have more money for her 

tuition. Another concurrent beneficiary said that, even though she had 

expressed a strong desire to work and had returned to work for a short 

time, SSA had never explained that she could deduct from her countable 

earnings the cost of any items or services related to her impairments 

that were necessary for her to continue working.



To assist beneficiaries in making better decisions about work activity, 

as authorized by the Ticket to Work and Work Incentives Improvement Act 

of 1999, SSA has provided funding since 2000 to community-based 

organizations. These organizations are funded to provide work 

incentives planning and assistance to beneficiaries and conduct 

outreach to individuals who are potentially eligible to participate in 

work incentive programs. In fiscal year 2002, SSA awarded a total of 

about $20 million to more than 100 organizations for these activities. 

The 2001 annual report of this program indicates that, through the end 

of that calendar year, more than 100 organizations receiving funding 

provided intensive benefit support services to more than 4,500 

beneficiaries, most of whom were working or considering a return to 

work. In addition, more than 5,000 beneficiaries received less 

intensive services, such as information and referral.



Some disability advocates have recommended making the work incentive 

rules similar in both the DI and SSI programs to help beneficiaries 

better understand the effect of work on benefits. They frequently 

suggest eliminating the 9 month trial work period for DI and replacing 

it with a gradual reduction in benefits in response to increased 

earnings, similar to the SSI program. Such a change would require 

legislative action. The Ticket to Work and Work Incentives Improvement 

Act requires SSA to conduct a demonstration project to test whether a 

reduction of $1 in DI benefits for every $2 earned would remove 

disincentives to return to work. SSA is still in the planning stages 

for this demonstration, and it is unclear when data will be available.



Conclusions:



The DI and SSI programs were designed as two separate programs to serve 

two distinct categories of disability beneficiaries. However, a third 

category, concurrent beneficiaries--those who qualify for both DI and 

SSI benefits-has emerged as a sizable disability population. Failure to 

properly administer the program for this special population could 

result in benefit overpayments and underpayments and less-than-ideal 

beneficiary decisions about work.



Without taking additional steps, it will be more difficult for SSA to 

effectively administer the disability program and serve concurrent 

beneficiaries under the current program. Without improved guidance and 

procedures, staff that have knowledge only about SSI or DI program 

rules may not collect and share information needed to make accurate 

determinations about concurrent beneficiariesï¿½ benefit payments. In 

addition, without a monitoring system to ensure information about 

concurrent beneficiariesï¿½ work activity is shared across program 

components and acted upon within a timely manner, SSA faces an 

increased risk that concurrent beneficiaries, as well as all DI 

beneficiaries who return to work, will be overpaid. Moreover, without 

public information materials that clearly explain the complex 

interaction of the two programs, the possibility that beneficiaries 

would make decisions about working that are not in their best interest 

could increase. Further, a lack of understanding of the work incentive 

provisions could create a disincentive to work.



Recommendations for Executive Action:



SSA needs to undertake the necessary steps to ensure it adequately 

serves concurrent beneficiaries and exercises its stewardship over 

program funds by avoiding overpayments. We recommend that the 

Commissioner of SSA:



* Develop procedures and integrated guidance to ensure information 

about work activity is collected and shared between the DI and SSI 

programs. One option would be to improve the cross-references used in 

its program guidance to more specifically target needed information to 

take actions to adjust benefits for both programs. Another option would 

be to require that some staff are knowledgeable about both programs and 

that they collect and act on work activity information for both 

programs. Regardless of the option selected, SSA should also consider 

adding to its guidance explanations and examples of the effect of work 

activity for individuals receiving both DI and SSI benefits.



* Develop comprehensive systems to monitor the progress of DI cases as 

they move between SSA components and set timeliness goals for the 

entire process for each action and component. In addition, use this 

information to help ensure timely actions and minimize overpayments of 

DI benefits when individuals return to work.



* Develop public information materials targeted to concurrent 

beneficiaries that explain the complex interaction of the two programs 

in language that beneficiaries can understand. SSA may wish to consider 

revising its publication, Working While Disabled--How We Can Help, to 

include a basic explanation of the effects of work when an individual 

receives both DI and SSI benefits and examples that illustrate these 

effects. For more detailed explanations, SSA could direct beneficiaries 

to contact an SSA representative knowledgeable of both programs.



Agency Comments and Our Evaluation:



In its comments on a draft of this report, SSA agreed with our 

conclusions and highlighted the initiatives it has underway or planned 

that it believes will address our recommendations (see app. II). 

Concerning our first recommendation, SSA stated that it is developing 

training for fall 2002 to enhance field office employeesï¿½ technical 

proficiency in both the DI and SSI programs. It is also developing and 

refining its supportive software systems to print referral forms for 

use in routing program information. We believe additional training 

should help to improve the technical proficiency of field office 

employees in both programs. However, SSA may need to consider the time 

field employees will need to develop proficiency after completing the 

training. Reliable, user-friendly program guidance could help reinforce 

this training as well as be a reference to these and future employees. 

Therefore, we continue to believe that program guidance should be 

modified to more completely explain the interactions of the two 

programs when concurrent beneficiaries work. Further, while the 

enhancements to software should provide SSA with an additional tool for 

sharing information between programs, SSA may wish to consider 

developing procedures to ensure that such available tools are being 

used appropriately to share information.



Concerning our second recommendation, SSA said that the systems it now 

has under development and scheduled for release in November 2002 will 

provide the necessary management information capabilities needed to 

ensure actions related to beneficiaries working are taken on a timely 

basis. As acknowledged in our report, the new system under development 

has the potential for improving the timeliness of actions in concurrent 

cases. However, because the system is still under development, we are 

unable to determine how effective it will be in identifying and 

controlling work activity. For example, we cannot confirm at this time 

whether the databases being developed will contain information about 

all working beneficiaries nationwide that can be accessed by all field 

offices or local databases that can only be accessed by the employees 

in one office, similar to those being tested in a number of field 

offices.



Concerning our third recommendation, SSA stated that it would develop a 

fact sheet for concurrent beneficiaries that explains the interaction 

of the two programs in language they can understand. The agency will 

also modify another publication to make it clear that beneficiaries 

should contact the agency for an explanation because the interaction of 

work activity with the two programs is so complex that it requires 

individualized explanations. We believe a fact sheet that explains the 

interactions of the DI and SSI programs should be useful for concurrent 

beneficiaries. In addition, we agree that the interaction of work with 

DI and SSI benefits is complex and that individualized explanations may 

provide concurrent beneficiaries with the most complete information. In 

relying on individualized explanations provided by SSA employees, SSA 

may wish to consider developing methods to ensure that concurrent 

beneficiaries have access to employees who are knowledgeable in both 

programs regardless of the method of contact. For example, given that 

many beneficiaries may contact SSA through its 800 number teleservice 

centers, SSA could either deploy knowledgeable staff in the teleservice 

centers or establish procedures to ensure that these calls are referred 

to staff who are knowledgeable in both programs.



SSA also provided technical comments, which we have incorporated as 

appropriate.



We are sending copies of this report to the Commissioner of Social 

Security, appropriate congressional committees, and other interested 

parties. We will also make copies available to others on request. In 

addition, the report will be available at no charge on the GAO Web site 

at http://www.gao.gov.



If you or your staff have any questions about this report, please 

contact me on (202) 512-7215 or Shelia Drake at (202) 512-7172. Key 

contributors to this report were Beverly Crawford, Amy Bevan, Patrick 

DiBattista, and Vanessa Taylor.



Robert E. Robertson, Director

Education, Workforce, and

 Income Security Issues:



Signed by Robert E. Robertson:



[End of section]



Appendix I: Scope and Methodology:



To determine the number and characteristics of concurrent 

beneficiaries, we used data from the Social Security Administrationï¿½s 

(SSA) monthly 10 Percent Characteristic Extract Record file of the 

Supplemental Security Record, which contains data from a 10 percent 

simple random sample of the records of all Supplemental Security Income 

(SSI) applicants and beneficiaries. We used data from the September 

2001 extract to test our analysis and used the February 2002 extract 

for the final analysis.



We first determined the number of working age beneficiaries (both 

concurrent and SSI only). To do this, we deleted from the sample 

universe all records that:



* were not active (those that did not have a Record Identification 

Code of G);



* showed a date of death in a month prior to the month of the file;



* showed a master file type other than disabled or blind;



* showed that the beneficiary was under age 18 or over age 64 as of the 

month of the file;



* showed that the claim was denied and no payments had been made on 

that record;



* showed entitlement for a veteran under title VIII of the Social 

Security Act; and:



* showed that the beneficiary was not receiving SSI because of excess 

income, except for those beneficiaries who continued to be eligible for 

Medicaid under section 1619b of the Social Security Act and who would 

be eligible for SSI payments if it were not for their earnings.



We then determined which beneficiaries received Disability Insurance 

(DI) income as well as SSI income--concurrent beneficiaries. To do 

this, for the records that remained, we identified concurrent 

beneficiaries as individuals who were currently receiving type A 

unearned income. Type A unearned income is any Social Security benefit. 

The remaining records were identified as beneficiaries who received SSI 

but not DI. We did not eliminate the remaining records for which 

benefits were suspended, but were not terminated as of February 2002, 

because, in many cases, these suspensions are temporary and the 

beneficiary will return to payment status within a relatively short 

period of time. In addition, our methodology did not allow us to 

discern whether concurrent beneficiaries ages 62 through 64 were 

receiving Social Security benefits on the basis of disability or 

retirement. As a result, we may be slightly overstating the size of the 

concurrent beneficiary population.



All estimates have sampling errors of +/-5 percent or less of the value 

of the point estimates offered. We employed standard and widely 

accepted social science and statistical methods. We did not 

independently verify the accuracy or completeness of the data provided 

to us by the SSA.



To assess the extent to which SSA coordinates the DI and SSI program 

rules when individuals are working and receiving benefits from both 

programs, we reviewed the relevant sections of the Social Security Act, 

regulations, and SSA policy and procedural guidance to its employees. 

We also interviewed SSA officials at the headquarters in Baltimore, 

Maryland, and at several field offices. We visited two SSA field 

offices each in metropolitan Los Angeles, California; and Chicago, 

Illinois, and one each in Alexandria, Virginia; Wilmington, Delaware; 

and Towson, Maryland. We judgmentally selected the locations on the 

basis of geographic diversity, the presence or absence of an employment 

support representative pilot, and the use of generalist or specialist 

claims representatives.



To determine the potential effect of applying both DI and SSI program 

rules on concurrent beneficiariesï¿½ decisions to work and on their 

benefits, we relied on our review of SSA law, regulations, and policy 

and procedural guidance as well as our interviews with SSA officials at 

headquarters and in field offices. We also reviewed the public 

information materials that SSA developed and used to communicate 

information about its programs to beneficiaries and other interested 

parties. In addition, we interviewed academic researchers, advocates 

for people with disabilities, social service providers for individuals 

with disabilities, and a small number of concurrent beneficiaries.



[End of section]



Appendix II: Comments from the Social Security Administration:



SOCIAL SECURITY:



The Commissioner:



August 12, 2002:



Mr. Robert E. Robertson:



Director, Education, Workforce and Income Security Issues:



U.S. General Accounting Office Washington, D.C. 20548:



Dear Mr. Robertson:



Thank you for the opportunity to review and comment on the draft 

report, ï¿½Social Security Administration Disability: Enhanced 

Procedures and Guidance Could Improve Service and Reduce Overpayments 

to Concurrent Beneficiariesï¿½ (GAO-02-802). Our comments on the report 

are enclosed. If you have any questions, please have your staff 

contact Trudy Williams at (410) 965-0380.



Sincerely, Jo Anne B. Barnhart:



Signed by Jo Anne B. Barnhart:



Enclosure:



SOCIAL SECURITY ADMINISTIRATION BALTIMORE MD 21235-0001:



COMMENTS OF THE SOCIAL SECURITY ADMINISTRATION (SSA) ON THE GENERAL 

ACCOUNTING OFFICE (GAO) DRAFT REPORT, ï¿½SOCIAL SECURITY ADMINISTRATION 

DISABILITY: ENHANCED PROCEDURES AND GUIDANCE COULD IMPROVE SERVICE AND 

REDUCE OVERPAYMENTS TO CONCURRENT BENEFICIARIESï¿½ (GAO-02-802):



General Comments:



We agree with GAO that concurrent beneficiaries who choose to work can 

face complex choices and confusion over the effects of work and 

earnings. As a result, SSA has underway a number of initiatives to 

increase the Agencyï¿½s ability to serve concurrent beneficiaries 

effectively in this area. We are continuing development of an extensive 

new systems capability to improve monitoring, notice capability, 

workload measurement, management information, and the ability of front-

line personnel to both query the system and make direct input. In 

addition, we have instituted new support structures such as the 

benefits planning, assistance and outreach program; protection and 

advocacy grants; and State partnership initiatives. SSA is also 

currently providing hundreds of hours of program training and is 

updating instructional materials on the changes brought on by the 

Ticket to Work and Work Incentives Improvement Act of 1999 and their 

interaction with existing work incentive programs.



Recommendation 1:



SSA should develop procedures and integrated guidance to ensure that 

information about work activity is collected and shared between the 

Disability Insurance (DI) and Supplemental Security Income (SSI) 

programs. One option would be to improve the cross-references used in 

its program guidance to more specifically target needed information to 

take actions to adjust benefits for both programs. Another option would 

be to require that some staff be knowledgeable about both programs and 

that they collect and act on work activity information for both 

programs. Regardless of the option selected, SSA should also consider 

adding to its guidance explanations and examples of the effect of work 

activity for individuals receiving both DI and SSI benefits.



Comment:



We agree it is advisable to have sufficient staff knowledgeable about 

both DI and SSI benefits. Training is being developed for Fall 2002 

implementation to enhance field office employeesï¿½ technical proficiency 

in both programs. Also, we are developing and refining our supportive 

Modernized Return to Work (MRTW) software to assist in improving cross-

references between the two programs. Some of the software developed in 

the MRTW system actually prints referral forms for SSI and Social 

Security Disability Insurance (SSDI) that can be routed to the 

appropriate person specializing in the other program. Completion of the 

referral screen does not require extensive knowledge of the other 

program.



Recommendation 2:



SSA should develop comprehensive systems to monitor the progress of DI 

cases as they move between SSA components and should set timeliness 

goals for the entire process for each action and component. In 

addition, SSA should use this information to help ensure timely actions 

and minimize overpayments of DI benefits when individuals return to 

work.



Comment:



We agree that a comprehensive system to monitor the progress of DI 

cases is necessary. We believe that the Disability Control File (DCF), 

being developed for release in November 2002, will provide a 

comprehensive system to monitor the progress of disability cases as 

they move among SSA components and programs.



We believe the systems that we currently have under development will 

greatly increase our abilities to identify and monitor concurrent 

cases. The databases that we are developing will provide the necessary 

information and systematic capabilities for employees to identify and 

control work activity in concurrent cases from the point of the work 

report to final action in both titles. Further, these systems will 

provide the management information capabilities we will need to insure 

actions are taken on a timely basis.



Recommendation 3:



SSA should develop public information materials, targeted to concurrent 

beneficiaries, that explain the complex interaction of the two programs 

in language that beneficiaries can understand. SSA may wish to consider 

revising its publication, Working While Disabled-How We Can Help, to 

include a basic explanation of the effects of work when an individual 

receives both DI and SSI benefits and examples that illustrate these 

effects. For more detailed explanations, SSA could direct beneficiaries 

to contact an SSA representative knowledgeable of both programs.



Comment:



We concur. SSA will develop a fact sheet for concurrent beneficiaries 

that explains the complex interaction of the two programs in language 

that beneficiaries can understand. We are also revising the 

publication, Working While Disabled-How We Can Help, to make clear that 

if a beneficiary is receiving benefits under one or both programs they 

should contact Social Security. We believe that the interaction of the 

way that work is treated under the two programs is so complex it 

requires individualized explanations.



[End of section]



FOOTNOTES:



[1] In addition to disability beneficiaries who qualified on the basis 

of their own work records, we are considering in the category of the DI 

program for purposes of this report, all disability benefits paid from 

the Old-Age, Survivors, and Disability Insurance trust funds to 

disability beneficiaries age 18-64 who qualified on the work record of 

a deceased, retired, or disabled parent; as well as disability 

beneficiaries age 50-64 who qualified on the work record of a deceased 

spouse.



[2] SSA considers individuals to engage in substantial gainful activity 

if they have countable earnings above a certain dollar level. For 2002, 

the dollar level was $780 a month ($1,300 a month for legally blind 

beneficiaries).



[3] This act provides for additional extensions of medical insurance 

and new options for reinstating eligibility if beneficiaries stopped 

working as well as demonstration projects providing for earned income 

exclusions under DI.



[4] The percentages shown are based on the proportion of those 

beneficiaries for which a primary impairment was shown in SSAï¿½s 

records. SSA records did not show the impairment for about 8 percent of 

concurrent beneficiaries. This analysis did not include additional 

impairments that may contribute to some beneficiariesï¿½ inability to 

work. 



[5] This figure includes individuals who do not receive cash benefits 

because of the amount of their earnings, but who remain eligible for 

Medicaid coverage under the provisions of section 1619(b).



[6] Monthly earnings of $65 or less do not affect the SSI benefit 

amount.



[7] For this report, we are using the term SSI beneficiaries to refer 

to individuals who receive SSI benefits only. DI beneficiaries were not 

considered in this analysis because SSA records do not allow them to 

readily distinguish between concurrent beneficiaries and those who 

receive only DI benefits.



[8] SSA guidance consists of multiple parts because of the need to 

adjust guidance over time, incorporate temporary updates, additional 

guidance from regional offices, and information about court decisions 

that affect how policies are applied in certain areas.



[9] See table 1 for an explanation of the trial work period. 



[10] Earnings above a specified monthly amount indicate the capacity to 

perform substantial gainful activity and would result in a finding that 

the beneficiary is no longer disabled. The monthly limit for 2002 is 

$780 for all beneficiaries, except for those with statutory blindness. 

For blind beneficiaries, the monthly limit is $1,300.



[11] In another situation, SSA has underpaid SSI beneficiaries who 

should have been concurrent beneficiaries. Because of a problem in the 

SSI benefit payment system, SSA was not alerted to all the cases in 

which SSI beneficiaries had worked a sufficient amount of time to 

become eligible for DI benefits. SSA estimates that more than 500,000 

SSI beneficiaries may be underpaid an average of 8 yearsï¿½ benefits. 



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