Social Security Administration: Longstanding Problems in SSA's Letters to
the Public Need to Be Fixed (Letter Report, 09/26/2000, GAO/HEHS-00-179).

Pursuant to a congressional request, GAO assessed the equality of the
Social Security Administration's (SSA) letters to the public, focusing
on the: (1) problems that make SSA's letters difficult to understand;
and (2) status of SSA's actions to fix the problems.

GAO noted that: (1) the majority of letters in each of the four
categories GAO reviewed did not clearly communicate at least one of the
following key points: (a) SSA's decision (that is, the action SSA was
taking on a claim that prompted the agency to send the letter); (b) the
basis for SSA's decision; (c) the financial effect of SSA's decision on
the person addressed in the letter; or (d) the recourse the person could
take in response to SSA's decision; (2) the lack of clarity was caused
by one or more problems, such as illogically sequenced information,
incomplete or missing explanations, contradictory information, and
confusing numerical information; (3) an unclear explanation of the basis
for SSA's decision was the most widespread problem among the four
categories of letters; (4) for example, it was difficult to understand
the basis for SSA's decision in Supplemental Security Income (SSI) award
letters because the letters did not explain the relationship between
program rules and the amount of the SSI benefit; (5) a subgroup of SSI
award letters--those sent to about 13 to 15 percent of SSI awardees who
are eligible for previous but not a future month's benefits--were
unclear in communication all four key points; (6) SSA acknowledges that
these letters contain the problems GAO identified; however, for many of
the problems, the agency has not taken any corrective action; (7) many
of the problems GAO identified are not amenable to quick fixes but,
rather, will require a comprehensive revision of the language used in
the letters and rewriting the agency's software applications that
generate them; (8) the agency has repeatedly rescheduled plans to make
comprehensive changes for its Social Security benefit adjustment letters
because of competing demands of computer systems resources; the agency
allocated resources to other priorities, such as making computer system
changes that resulted from legislation; (9) however, the agency
announced plans to make significant changes to this category of letter,
but few details are yet available; (10) major improvements to SSI
letters were also delayed, but in this case SSA was waiting for
resolution of a nationwide court case involving these letters; (11) in
September 1999, a federal court ordered SSA to develop and implement a
plan to improve its SSI letters, prompting SSA to begin a major,
multiyear initiative to improve its SSI letters, prompting SSA to begin
a major, multiyear initiative to improve its SSI award and benefit
adjustment letters; (12) this initiative is still in the early phase;
and (13) SSA has not placed a high priority on improving its letters to
the public.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  HEHS-00-179
     TITLE:  Social Security Administration: Longstanding Problems in
	     SSA's Letters to the Public Need to Be Fixed
      DATE:  09/26/2000
   SUBJECT:  Customer service
	     Social security benefits
	     Income maintenance programs
	     Written communication
IDENTIFIER:  SSI
	     Supplemental Security Income Program

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GAO/HEHS-00-179

Appendix I: Scope and Methodology

30

Appendix II: Comments From the Social Security Administration

33

Appendix III: GAO Contacts and Staff Acknowledgments

36

Table 1: The Most Significant Problems in Four Categories of
SSA Letters and Their Estimated Frequency 9

Table 2: Comprehensive Improvements Needed for Selected
SSA Letters 23

Figure 1: A Social Security Benefit Adjustment Letter in Which
SSA's Decision Is Unclear 11

Figure 2: An SSI Award Letter in Which the Basis for SSA's
Decision Is Unclear 14

Figure 3: A Social Security Benefit Adjustment Letter in Which
the Financial Effect of SSA's Decision Is Unclear 16

Figure 4: An Unclear SSI Award Letter 19

HHS Department of Health and Human Services

SSA Social Security Administration

SSI Supplemental Security Income

Health, Education, and
Human Services Division

B-284086

September 26, 2000

The Honorable E. Clay Shaw
Chairman, Subcommittee on Social Security
Committee on Ways and Means
House of Representatives

Dear Mr. Chairman:

The Old Age and Survivors Insurance and Disability Insurance programs,
commonly referred to as Social Security, and the Supplemental Security
Income (SSI) program provide monthly cash benefits to about 50 million
beneficiaries. The Social Security Administration (SSA), which administers
both programs, mails millions of letters each year to notify Social Security
and SSI applicants and recipients about its decisions regarding their
eligibility to receive benefits or changes in the amount of their
benefits--important issues that have a bearing on their everyday lives.
Because these letters serve as SSA's official means of communicating this
information to the public, it is important that they be clearly written and
easy to understand. If they are not clear, the public may miss important
information about their eligibility, the continuation of their payments, or
the recourse available to them if they disagree with SSA's decisions.

We have long been critical of SSA's letters. For example, in 1994, we
reported that many SSA letters, particularly those dealing with Social
Security overpayments, were difficult to understand.1 Specifically, we found
that SSA's letters excluded essential details needed to understand its
decisions, presented information in an illogical order, and required complex
analyses to reconstruct how SSA had made adjustments to benefit payments. To
help you assess SSA's progress in improving its letters, you asked us to
provide updated information on their quality. This report addresses (1) the
problems that make SSA's letters difficult to understand and (2) the status
of SSA's actions to fix the problems.

To address these issues, we interviewed SSA officials responsible for
improving SSA's letters and reviewed documents on past and current
evaluations of the agency's letters and its initiatives to improve them. We
focused our review on four categories of automated letters--Social Security
award letters, SSI award letters, Social Security benefit adjustment
letters, and SSI benefit adjustment letters--because these letters reach a
large number of people and convey important information on their eligibility
for benefits or changes in their benefit amounts that can significantly
affect their lives.2 SSA mails about 14.2 million of these letters each
year. We used writing consultants to help us develop criteria to assess
whether the letters communicated clearly and to verify our assessment of the
types of problems that occur. To quantify the frequency of the problems we
found in Social Security and SSI benefit adjustment letters, we reviewed a
statistical sample of 1 day's production of letters. For Social Security and
SSI award letters, we identified specific problems with the letters and
obtained information from SSA about the number or percentage of letters that
included problems we identified. We conducted our work between June 1999 and
July 2000 in accordance with generally accepted government auditing
standards. For more details about our scope and methodology, see appendix I.

The majority of letters in each of the four categories we reviewed did not
clearly communicate at least one of the following key points: (1) SSA's
decision (that is, the action SSA was taking on a claim that prompted the
agency to send the letter), (2) the basis for SSA's decision, (3) the
financial effect of SSA's decision on the person addressed in the letter, or
(4) the recourse the person could take in response to SSA's decision. The
lack of clarity was caused by one or more problems, such as illogically
sequenced information, incomplete or missing explanations, contradictory
information, and confusing numerical information. An unclear explanation of
the basis for SSA's decision was the most widespread problem among the four
categories of letters. For example, it was difficult to understand the basis
for SSA's decision in SSI award letters because the letters did not explain
the relationship between program rules and the amount of the SSI benefit.
Finally, a subgroup of SSI award letters--those sent to about 13 to 15
percent of SSI awardees who are eligible for previous but not a future
month's benefits--were unclear in communicating all four key points.

SSA acknowledges that these letters contain the problems we identified;
however, for many of the problems, the agency has not taken any corrective
action. Many of the problems we identified are not amenable to quick fixes
but, rather, will require a comprehensive revision of the language used in
the letters and rewriting the agency's software applications that generate
them. The agency has repeatedly rescheduled plans to make comprehensive
changes to its Social Security benefit adjustment letters because of
competing demands for computer systems resources; the agency allocated
resources to other priorities, such as making computer system changes that
resulted from legislation. Recently, however, the agency announced plans to
make significant changes to this category of letter, but few details are yet
available. Major improvements to SSI letters were also delayed, but in this
case SSA was waiting for resolution of a nationwide court case involving
these letters. In September 1999, a federal court ordered SSA to develop and
implement a plan to improve its SSI letters, prompting SSA to begin a major,
multiyear initiative to improve its SSI award and benefit adjustment
letters. This initiative is still in the early phase.

Overall, SSA has not placed a high priority on improving its letters to the
public, and it will be years before the improvements are completed to most
of these letters, even if there are no more delays and SSA adheres to its
current plans. Because of past delays to letter improvement initiatives, we
are recommending that SSA develop performance measures to monitor the
agency's progress in making the necessary comprehensive improvements to
these letters.

The Social Security program and the SSI program provide monthly cash
benefits to persons who meet the programs' eligibility requirements. In
fiscal year 1999, 38 million persons received a total of $332.4 billion in
Old Age and Survivors Insurance benefits, 6.5 million persons received $50.4
billion in Disability Insurance benefits, and 6.6 million persons received
$28.1 billion in SSI benefits. The rules affecting eligibility and benefit
amounts in these programs can be complex. Once individuals are determined to
be eligible for Social Security or SSI benefits, changes in their
circumstances, such as changes in the amount of their income, disability, or
marital status, can affect their continuing eligibility for

benefits or the amount of their benefits.3 When SSA learns of these
changes--either through its own review processes or from individuals
reporting changes in their circumstances to the agency--SSA adjusts
individuals' eligibility status or benefit amounts accordingly.

The Social Security programs provide protection to insured workers and their
dependents against the loss of earnings because of workers' retirement,
disability, and death. The monthly cash benefits, which are intended to
replace a portion of lost earnings, are financed through payroll taxes. The
monthly benefit amount to which workers (and their dependents) are entitled
is based on workers' lifetime earnings covered by Social Security.
Individuals can begin receiving partial retirement benefits due them at age
62, or they can receive full benefits beginning at full retirement age,
which is currently age 65. In addition, some individuals continue to work
after they start receiving benefits. SSA continues to credit these earnings
to the individuals' Social Security accounts, and their monthly benefits may
increase as a result. However, once individuals receive retirement benefits,
an earnings limit applies to persons who have retired and are younger than
full retirement age. If earnings exceed established limits, SSA reduces the
benefit amount. To determine whether and by how much to reduce benefit
amounts, SSA requests individuals to provide estimates of their annual
earnings. If their actual earnings are less than they estimated, SSA will
have underpaid them and will need to adjust their payments. Monthly benefits
paid to workers who retired before reaching full retirement age and their
dependents are reduced by $1 for every $2 earned over the $10,080 annual
limit for 2000.4 For individuals receiving Social Security benefits based on
disability, different rules govern subsequent earnings. During a trial work
period, no earnings limit applies to disabled workers. But disabled workers
who have completed the trial work period generally stop receiving benefits
if their monthly earnings continue to exceed $700 as of 1999. For all these
reasons, a person's earnings after he or she becomes disabled or retires
before the full retirement age can result in overpayments, underpayments, or
both.

SSI, in contrast, is a means-tested program funded from general tax revenues
designed to provide a minimum level of income to individuals with limited
income and resources who are 65 or older or blind or disabled, including
children. To qualify for benefits, individuals must have income and
resources below the SSI program's limits. Qualified recipients receive
monthly cash payments sufficient to raise their income to the level
guaranteed by the federal SSI program. The amount of the SSI benefit varies
according to income. Persons who have no income receive the maximum federal
SSI benefit--currently $512 per month for an individual and $769 for a
couple.5 SSI recipients with income, including those receiving Social
Security benefits, receive less.

Letters are one of SSA's primary means of communicating with the public. SSA
estimates that each year it issues approximately 250 million letters and
forms to the public, including claimants, workers, employers, and government
agencies. These letters deal with a wide range of issues. SSA sends letters
to Social Security and SSI applicants and recipients notifying them about
their eligibility for benefits or changes in their eligibility or benefit
amounts. SSA sends annual statements to Social Security beneficiaries
documenting, for tax purposes, the amount of Social Security benefits
received; annual estimates to current workers of future Social Security
benefits; letters to employers about workers' Social Security numbers;
letters to SSI recipients verifying, for other means-tested programs, the
amount of their SSI benefits; and many other types of letters.6 SSA has
pledged to the public that its letters will clearly explain the agency's
decisions so that the public can understand how and why SSA made them and
what to do if it disagrees.

Responsibility for improving letters is shared among various SSA offices,
including the office responsible for customer service, which helps identify
problems, and the program offices, which are responsible for further
analyzing problems and drafting revised language. The Office of Systems,
however, plays a key role because implementing changes often requires
systems programmers to rewrite one of the multiple software applications
that SSA uses to generate letters. SSA's Social Security program is
currently supported by a new, redesigned system and about 25 separate
systems applications, each dedicated to processing a specific type of
transaction. SSA has one application that, among other transactions,
processes claims for benefits and generates automated eligibility award or
denial letters; another application processes transactions such as reports
of work-related earnings and generates automated benefit adjustment letters.
For the SSI program, the agency has one major system to process transactions
for the program and produce automated SSI letters. Each software application
has its own programmed logic to generate letters and its own language
database. Depending on the particulars of the transaction, each application
is programmed to select appropriate paragraphs from among the numerous
paragraphs in its language database, many of which were written to be used
in multiple situations. Once the paragraphs are selected, the software is
programmed to complete paragraphs by filling in case-specific information
from SSA's master records and sequence paragraphs to assemble letters. These
master records contain account data for every beneficiary.

Many of the letters in our review do not meet the agency's own communication
standard or generally accepted principles of good communication. Social
Security award letters, Social Security benefit adjustment letters, SSI
award letters, and SSI benefit adjustment letters do not clearly communicate
one or more of the following key points: SSA's decision (that is, the action
SSA is taking on a claim that necessitated the letter), the basis for its
decision (that is, the program rules and facts on which SSA based its
decision), the financial effect of its decision on payments to the
individual, and the recourse the individual has in response to SSA's
decision. In addition, a subgroup of SSI award letters--those sent to about
13 to 15 percent of awardees who were found eligible for benefits for
previous but not future months--were especially difficult to understand.
These letters had problems that made it difficult to understand each of the
four key points. The unclear communication in the four categories of letters
we reviewed was caused by many of the same problems we identified in SSA's
letters in 1994, such as illogically sequenced information, incomplete or
missing explanations, contradictory information, and confusing numerical
information.

Table 1 presents what we consider to be the most significant problems
because of their frequency or their potential to adversely affect the
individuals receiving the letters.

 Key point  Social Security letter     SSI letter

            Award    Benefit           Award             Benefit adjustment
                     adjustment
                     80% of cover
                     sheets do not
 Decision            include all
                     decisions that
                     affect payments
                                       100% do not       86% do not clearly
                     100% illogically  explain           explain
 Basis for           sequence          relationship      relationship
 decision            explanations of   between program   between program
                     SSA's decisions   rules and benefit rules and changes
                                       amounts           in benefit amounts
                                                         55% lack clear
                                                         statement of
 Financial           86% lack clear                      timing or amount
 effect              explanations of                     of change in
                     adjustments
                                                         benefits or other
                                                         problems
            95% do   24% do not fully
            not      state options for
 Recourse   state    repaying
            how to   overpayments or
            appeal   how to appeal

Note: The percentages for the Social Security and SSI award letters are
based on information that SSA provided to quantify the frequency of the
problems we found with these letters. The percentages for the Social
Security and SSI benefit adjustment letters are based on the sample of
letters we reviewed.

Incomplete Information

SSA's decision to award benefits or to adjust the amount of individuals'
benefits was generally stated clearly in three of the four categories of
letters. However, letters sent to inform Social Security beneficiaries of
adjustments in their benefit amounts were not clear. In most of these
letters, information necessary to understand SSA's decisions was buried in
the letters' attachments or was not mentioned at all.

Most letters adjusting Social Security benefits consist of a cover sheet
acknowledging earnings that individuals recently reported to SSA and
sometimes a lengthy attachment. Information about possible changes in
payments are detailed in the attachment and in worksheets that are often a
part of the attachment. SSA's decision was unclear in 80 percent of the
letters we sampled, most often because the cover sheets did not disclose all
decisions discussed in the attachments. In these situations, the attachment
may have also discussed other decisions SSA made about (1) amounts it had
overpaid or underpaid individuals or (2) its plans to withhold payments to
recover amounts overpaid or both. For example, one cover sheet informed a
beneficiary that she had been overpaid $607 but requested that she repay
$2,213 (see fig. 1). This could confuse the reader until she read the
attachment, which explained SSA's plans to also recover a prior overpayment.
The explanation of the difference between the $607 overpayment and the
$2,213 to be repaid was not given until later in the attachment.

Is Unclear

In some cases, however, the attachment did not explain the decision stated
in the cover letter. We found a case in which the cover sheet informed an
individual that (1) on the basis of his work report, SSA had determined that
he had been overpaid $2,083.00 but that (2) after all adjustments, he had
been overpaid $2,055.00, and (3) he should refund the $2,009.50 overpayment
within 30 days. In this case, the attachment did not explain these
differences.

Our finding is similar to one included in a 1992 study done under contract
for SSA that cited cover sheets as not disclosing all essential actions
addressed in attachments.7 Such letters could conceivably cause the persons
receiving them to call or visit SSA offices for explanations. This creates
additional work for SSA employees that would not have been necessary had the
letters completely and clearly stated all decisions up front.

of Multiple Problems

The basis for SSA's decisions--that is, the program rules and facts on which
SSA based its decisions--was usually clear in the Social Security award
letters but unclear in the three other categories of letters. In some cases,
the basis for SSA's decisions was not clear because the rules were explained
in complex language that was difficult to follow, or the rules were
presented in an illogical order scattered throughout the letters. In other
cases, the program rules or facts on which the decisions were based were not
fully explained, and the relationship between an individual's income and
adjustments to benefits could not be easily understood. SSA officials
acknowledged that the latter situation occurs in all SSI award letters. In
our review of SSI award letters, we found that these letters do not clearly
show how income affects the amount of the SSI benefit, and the information
provided on an individual's benefit amount and income is not organized in a
way that enables the reader to easily understand the connection between the
two. Given this limitation, the basis for SSA's decisions can be difficult
to understand, even in a relatively simple award letter.

It is even more difficult to understand the basis for SSA's decisions when
an individual is to be awarded several months' past due benefits and the
benefit amount changes during the months covered by the award letter. An
award letter to a disabled individual illustrates this point. In October
1999, SSA notified an SSI applicant that she had been eligible for monthly
benefits of $175.92 for July through September 1999 and $130.92 for October
and November 1999. This information was presented on the first page of the
letter. The facts on which SSA based the benefit amount--including the
amount of her income--are described separately on the letter's second page
(see fig. 2). It was not clear from the facts as presented on that
page--which was the only explanation SSA gave for its decision in this
letter--why this individual's benefits were reduced. No explanation was
given for the change in the benefit amount for October and November 1999.

SSA has long been aware that its SSI award letters do not clearly show the
relationship between program rules and the amount of an SSI benefit. For
example, an SSA document cites participants in a 1992 focus group as
criticizing SSI award notices for not clearly explaining how SSA calculates
benefit amounts and, in particular, for not explaining variations in the
amount of monthly benefits. Also in 1992, the Office of Inspector General in
the Department of Health and Human Services (HHS) recommended that SSA
revise its SSI award letters to include a worksheet to show how SSA
determined the benefit amount.8 More recently, in January 2000, the U.S.
District Court for the Eastern District of New York similarly instructed SSA
to revise its SSI award letters to provide information necessary to permit a
reasonable person to understand the basis for the agency's action on a
number of subjects, including worksheets to show how benefits were
computed.9

Understand Because of Confusing Time Periods and Numerical Information

The financial effect of SSA's decision was generally clear in the letters
awarding Social Security and SSI benefits but not clear in letters adjusting
them. In some cases, the letters contained conflicting information about
when adjustments would occur and, additionally, in some cases it was not
clear whether benefits were increasing or decreasing. Letters also contained
confusing numerical information involving the computation of payment
adjustments. For example, the financial effect of SSA's decision on amounts
payable to or owed by individuals was unclear in 86 percent of the letters
we sampled that involved adjustments of Social Security benefits. We found
that worksheets, which were intended to show how SSA computed amounts
overpaid or underpaid to individuals, used unexplained amounts. As shown in
figure 3, one worksheet showed SSA's computations to support the fact that
the agency should have withheld $2,714 of an individual's benefits because
his yearly earnings were $8,142 over the limit. However, on the next line,
the worksheet shows the amount that should have been withheld as
$1981.50--an amount that the attachment did not explain. No explanation is
given of the difference in the two amounts cited as "should be withheld."

Effect of SSA's Decision Is Unclear

In some cases, a worksheet adequately explained SSA's computations for
amounts it underpaid individuals; however, the worksheet then listed an
adjustment to the underpayment by an amount that it did not explain. In one
particular example, a worksheet explained how SSA computed that it had
underpaid an individual $17 by stating that the individual had an earnings
limit of $17,000 for 2000. It then stated, "because of other adjustments,
you are due an additional $17.00."

Information

SSA's explanations of the recourse available to individuals who disagree
with SSA's decisions on their claims were generally clear in SSI award and
benefit adjustment letters but, to varying degrees, were unclear in the
Social Security award and benefit adjustment letters because of incomplete
information. Most Social Security award letters did not clearly explain how
to appeal SSA's decisions, and almost a quarter of the letters adjusting
Social Security benefits did not fully inform individuals of all options for
repaying overpayments or how to appeal SSA's decisions.

Data on the frequency of the use of certain paragraphs in Social Security
award letters showed that 95 percent of these letters sent during a recent
3-month period did not inform individuals that if they chose to appeal SSA's
decision, they had to do so in writing. SSA officials were unaware that
letters omitted this information and said that under the discussion of
appeal rights, letters should have instructed individuals to request a
specific form for making their appeals.

Twenty-four percent of the Social Security benefit adjustment letters in our
sample did not fully inform individuals at the beginning of the letter of
the recourse available to them. The cover sheet for some letters instructed
individuals to immediately repay the full overpayment amount without also
informing them of the other repayment options discussed in the attachment.
The attachment informs them that they can either have SSA withhold benefits
until the amount is fully repaid or, if they cannot afford this, request SSA
to withhold smaller amounts over a longer period of time. Focus group
participants in SSA's 1992 study indicated a preference for placing such
information in the cover sheet. It was thought that when people largely
depend on Social Security payments, it would be helpful to let them know
immediately that they have other options for making repayment. In other
cases, the cover sheets referred individuals to the attachment for an
explanation of their appeal rights; however, no language addressing appeal
rights could be found in the attachment.

One particular group of SSI award letters--those sent to notify SSI
applicants that they have been awarded benefits for previous but not future
months--proved particularly confusing, because they contained numerous
contradictions, illogically sequenced explanations, and incorrect
statements.10 As a result, none of the four key points--SSA's decision, the
basis for the decision, the financial effect on the individual, and the
recourse available to the claimant--are clear. Key excerpts from a typical
letter that awarded benefits only for previous months illustrate these
letters' many problems, as seen in figure 4 (in which we have highlighted
passages with bold type). This letter was sent on October 13, 1999, to a
disabled adult. In 1998 and 1999, more than 100,000 individuals, or about 13
to 15 percent of all SSI awardees, received benefits only for previous
months and thus would have gotten a similar letter.

SSA's decision is unclear, because the letter shown in figure 4 goes back
and forth as to whether the applicant is eligible or ineligible for SSI. For
example, the first sentence in the letter ("A") informs the applicant that
she is eligible for SSI benefits, as does the first sentence on the second
page of the letter ("E"). She is also told on a subsequent page that her
benefits will continue if she is still disabled in the future ("H"). But
elsewhere in the letter, she is told that she is not eligible for SSI ("F"
and "G") and that she will not be receiving any more payments ("C," "D," and
"E").

The basis for SSA's decision is unclear as well because the letter
illogically tells the applicant that she cannot receive any more payments
because she is disabled and living in Massachusetts ("E"). Also, this
illogical reason for nonpayment is listed before the actual reason for
nonpayment--her income ("F").

The financial effect of SSA's decision is unclear, because the letter makes
contradictory statements about the months for which benefits are payable.
First, the letter informs the reader that she will receive $3,367.36 in
benefits for March through October 1999 ("B" and "D"), but later it
incorrectly states that SSA can pay benefits for only 1 month--March 1999
("E").11

Finally, the recourse available to the claimant is unclear, because the
letter incorrectly informs her that she must file a new application before
she can receive any more benefits ("I"). The letter does not explain that
under SSI program rules, monthly benefits can resume without the need to
file a new application if the individual becomes eligible again within 12
months. The letter is not clear about SSA's decision, the basis for the
decision, the financial effect of the decision, or the applicant's appeal
rights.

SSA has been aware for several years of the more serious problems we found
with three of the four categories of letters we reviewed--those adjusting
Social Security benefits, adjusting SSI benefits, and awarding SSI benefits.
The agency considers sending clear letters an important element of customer
service and specifically targeted these letters for improvement, yet the
actions it has taken to improve them have been limited. Its efforts have
primarily focused on the changes that are the easiest to complete. The more
serious problems we found require more comprehensive language revision and
rewriting software applications, and planned changes have been repeatedly
rescheduled because SSA did not have the computer systems resources
available to implement them because of other priorities. SSA has recently
announced plans to make the needed improvements to these three categories of
letters. However, SSA has not established meaningful performance measures to
monitor its progress in improving the letters.

Since at least the early 1990s, SSA has known about problems with the Social
Security benefit adjustment letters, the SSI award letters, and the SSI
benefit adjustment letters, which we identified as being the most
problematic, and the agency agrees that they are among the least
understandable and most sensitive of the agency's high-volume mailings.
Annually SSA sends out about 3.5 million Social Security benefit adjustment
letters, 0.6 million SSI award letters, and 3.3 million SSI benefit
adjustment letters.12 In various strategic and performance plans, SSA has
identified sending customers clear letters as an element of good service,
and beginning with its fiscal year 2000 performance plan, SSA specifically
targets improving these three letters as a strategy that would increase
customers' overall satisfaction with the agency. Improving its letters is
listed as one of the agency's key initiatives.

Despite acknowledging numerous problems with the three categories of
letters, SSA has completed only one minor improvement to one letter--the
Social Security benefit adjustment letter. In July 1999, SSA added a
worksheet to this letter to show how the agency computed amounts it
underpaid or overpaid individuals on the basis of their earnings. However,
SSA officials view the worksheet as an interim improvement because SSA did
not rewrite the master record to expand its capacity to hold additional data
so that it could provide the appropriate information to support the
worksheet. We drew our sample of Social Security benefit adjustment letters
after SSA began including worksheets with these letters. We found the
worksheets helpful to some extent in explaining how individuals' earnings
contributed to SSA's decision that it had underpaid or overpaid them.
However, as previously discussed, the worksheets sometimes did not
adequately explain some of the adjustments SSA made when computing
underpayments or overpayments, in part because doing so would require
rewriting the master records.

In addition to the completed change described above, SSA recently began to
address two of the problems we identified during the course of our present
work. First, the agency has taken steps to respond to the lack of language
in Social Security award letters to inform individuals of the form to use to
appeal the agency's decisions. After we brought this problem to SSA's
attention, SSA officials told us the responsible program office has
developed revised language and has requested the Office of Systems to
implement the language change as soon as reasonably possible. In commenting
on a draft of this report, SSA informed us that it plans to implement the
change in November 2000. SSA has also initiated action to correct the error
in SSI award letters sent to individuals eligible for benefits in previous
months but not current benefits that states that they need to make a new
application. SSA officials told us that when the agency releases its next
set of SSI systems changes in October 2000, they plan to add language to the
letters to correct this problem.

Systems officials told us that from a systems standpoint, these types of
problems are the easiest to correct because they involve a straight
substitution of language--one paragraph replaces another paragraph that had
been used for the same situation. This type of revision is relatively
straightforward because the software logic for selecting the paragraph for
insertion into a letter does not have to be revised. Therefore, SSA could
act relatively quickly to address these two problems.

SSA has made less progress in correcting some of the problems that are more
difficult to fix. As shown in table 2, the other problems we found would
require significant work to revise the language used in the letters and
rewrite the master records and software applications.

 Letter                 Needed improvement
                        Revise language, rewrite program's master record,
                        and rewrite software application so that

                        ⋅ Cover sheet discloses all decisions
                        discussed in attachment
 Social Security
                        ⋅ Work-related earnings rules are co-located
 benefit adjustment     and logically sequenced
                        ⋅ Letter clearly explains decision's effect on
                        payment to individual, and

                        ⋅ Letter completely explains available
                        recourse
                        Revise language, rewrite program's master record,
                        and rewrite software application so that

 SSI award              ⋅ Letter adequately explains the basis for the
                        decision and

                        ⋅ Letter explains the relationship between
                        program rules and benefit amount
                        Revise language, rewrite program's master record,
                        and rewrite software application so that

 SSI benefit adjustment ⋅ Letter adequately explains a decision's
                        effect on payment, particularly how and when
                        adjustments will be made for overpayments or
                        underpayments in the past months

Systems officials told us that the actions the agency would need to take to
make the comprehensive changes the three letters need are the most
complicated from a systems perspective because they involve extensive
revision or development of new paragraph language; rewriting the software
application, including the selection and sequencing criteria for using the
language; and rewriting the programs' master records to hold additional data
that may be necessary to support proposed language changes.

SSA's ability to make these comprehensive improvements to the three letters
depends on the agency's allocating significant systems resources. When
allocating systems resources, SSA appropriately gives highest priority to
projects that help the agency maintain operations essential to its mission
or that it needs to undertake in order to implement legislative changes to
the Social Security and SSI programs. Resources not committed to these
efforts are available for SSA to use for discretionary projects, such as key
initiatives that support one of its strategic goals. Improving letters is a
key initiative. SSA senior officials collectively determine which
discretionary projects the agency's systems staff will work on, based on
each project's ranking and expected contribution to SSA's strategic
objectives. However, the relative priority SSA gives projects can change.
For example, SSA may decide to shift priorities and discontinue, delay, or
deemphasize a specific project to undertake others in cases in which SSA
does not have systems staff available.

Social Security Benefit Adjustment Letters

SSA has long had plans to make comprehensive improvements to one of the
categories of letters--the Social Security benefit adjustment letter.
According to SSA documents, by 1996, SSA had developed and tested in focus
groups comprehensive language changes for this letter. However, SSA's
documents showed that since developing the language, the agency has
repeatedly rescheduled the systems work required to implement the new
language. SSA systems officials told us that their computer systems staff
did not work on projects at the scheduled times because the agency had to
divert computer programmers to other, more pressing projects, such as those
required to implement significant program changes resulting from legislation
and to ensure that SSA's computer systems were year 2000 compliant.13 They
told us that the agency, with the emergence of workloads arising from
legislative changes, had to shift priorities away from working on
improvements to letters.

Until recently, SSA's progress in changing the Social Security benefit
adjustment letter was further limited by the agency's decision to make
comprehensive changes to these letters a part of a broader multiyear
initiative to redesign its current systems for processing transactions for
Social Security programs. Under this redesign effort, SSA plans to develop a
single system that will use common code to process virtually all
transactions for the Social Security programs. SSA is taking a building
block approach to this significant change and is starting with the easier
applications in order to gain experience before merging other more complex
applications--such as the one that generates Social Security benefit
adjustment letters. SSA's plans for having a single computer system will
allow the agency to rewrite the software more quickly and efficiently and at
less cost. Systems officials told us that the agency had planned that as
existing software applications were brought into the new redesigned system,
it would make language improvements as needed, retire the respective
language databases, and move the revised language into a central language
database.

In July 2000, SSA program and systems officials told us that the agency had
recently decided to move forward on making comprehensive improvements to the
Social Security benefit adjustment letters without waiting to merge the
respective software application under the new redesigned system. An SSA
official told us that the office that drafted the proposed language changes
had recently requested SSA senior officials to designate the project to
improve Social Security benefit adjustment letters as Customer Targeted
Work. This is a relatively new category for the use of discretionary
resources that gives the project a higher priority than it has been given
before.14 Although SSA is in the early planning stage of this effort, the
Office of Systems has established a plan for completing the more
comprehensive improvements by July 2002. However, because SSA's decision is
recent, we did not evaluate the approach.

SSI Letters

SSA has not made comprehensive improvements to either type of SSI letter and
has only recently begun developing action plans for improving them. SSA
officials told us they postponed plans to improve SSI award and benefit
adjustment letters, pending the outcome of the recently decided court case,
a class action law suit that an SSI recipient initiated. In that case, the
court upheld the plaintiffs' claim that SSA's letters denied recipients due
process because the letters did not adequately explain the basis for SSA's
decisions. The court ordered SSA to revise its automated SSI financial
eligibility letters--including its SSI award and benefit adjustment
letters--to more clearly communicate essential information to their
readers.15 SSA established a workgroup to review its SSI letters and
determine what changes were needed to improve them. In December 1999, the
SSA Commissioner signed a decision paper in which he approved the
workgroup's recommendations to make comprehensive changes to SSI letters.

Improving SSI letters will take time. The workgroup recommended that SSA
implement the recommendations in phases, concentrating first on better
explaining how benefit amounts are determined. SSA has begun work on some of
these changes. In February 2000, SSA drafted and tested with some SSI
recipients a prototype worksheet to be added to SSI award and benefit
adjustment letters showing how SSI benefits are computed. The worksheet is
intended to show how SSI benefits are computed in the least complex
cases--that is, the 90 percent of cases in which SSI recipients have no
income or only unearned income, such as Social Security benefits. SSA plans
to add the worksheet to the SSI letters by July 2002. By September 2004, SSA
also plans to develop additional worksheets covering more complex
situations, such as when persons have a combination of earned and unearned
income or when children receive benefits based on parents' income. The
workgroup also recommended other improvements such as revising letters so
that the information in them is logically ordered and adequately explains
the factors that affect eligibility and benefit amounts. SSA officials
estimated that it could take 10 years to implement the full range of planned
improvements.

Despite acknowledging problems with its letters, SSA currently has no
performance measures for monitoring its progress toward improving them. In
the past, SSA surveyed customers about their overall satisfaction with the
agency's letters and monitored the percentage of customers rating the
clarity of SSA's notices as excellent, very good, or good. SSA found that
the information it collected, which was a measure of general satisfaction
with the letters, was not useful in identifying ways to improve letters, so
it discontinued these surveys. Instead, the agency now relies on a
relatively new Market Measurement Program to help it target a few specific
types of letters each year and develop action plans for improving them. This
program uses a variety of initiatives, such as special studies and focus
groups, to systematically gather information on the full range of services
SSA provides to help the agency improve customer service overall. According
to its fiscal year 2001 performance plan, the agency plans to establish a
new indicator to monitor improvements to its letters at a later point.

Although SSA has been aware for many years of some of the more serious
problems with its letters, it has not corrected them. The agency's recently
announced plans to improve the Social Security benefit adjustment letter and
its SSI award and benefit adjustment letters will take years to complete and
will require significant computer systems resources. In view of the agency's
past decisions to delay some planned changes to the letters because of
competing demands for its computer systems resources, we believe that SSA
needs to allocate the necessary systems resources for these improvements. To
do this, the agency will need to better anticipate and plan for the varied
demands on its computer systems' resources and place a higher priority on
improving its letters. The agency will also need to develop appropriate
performance measures with which to hold itself accountable to the public for
achieving these improvements. These measures should help SSA monitor its
progress in adhering to the proposed timetables to help the agency stay on
track. In addition, because past changes to letters have not always
significantly improved clarity, SSA should develop other measures to assess
whether changes to the letters have achieved the intended results. Failure
to implement the needed improvements will mean continued poor service to the
public in this area.

We recommend that the Commissioner of Social Security direct SSA officials
to develop performance measures to hold the agency accountable for making
the needed comprehensive changes to its Social Security benefit adjustment
letters and SSI award and benefit adjustment letters. These measures should
include indicators that clearly articulate the timetables and basis against
which progress to complete improvements can be tracked and, as further
progress is made, the effectiveness of the improvements.

In commenting on a draft of this report, SSA generally agreed with our
findings, conclusions, and recommendation (see app. II). SSA expressed its
commitment to making the needed improvements to the letters addressed by our
report as quickly as possible and outlined its plan for developing
performance measures for beneficiary understanding of the problematic
letters. In addition, SSA mentioned other initiatives to improve this aspect
of its service. The agency stated that its efforts to improve letters have
been focused on changes that could be made quickly and have resulted in the
agency's improving most of the other types of letters it sends to the
public. Indeed, as we mentioned previously, SSA improved the Social Security
Statement, which provides estimates of future Social Security benefits,
after we reported problems with it.16 However, we have not formally
evaluated the effectiveness of the other initiatives. Finally, SSA also made
several technical comments, which we incorporated in the report where
appropriate.

We are sending copies of this report to the Honorable Kenneth S. Apfel,
Commissioner of SSA, and others who are interested. Copies will also be made
available to others on request.

If you or your staff have any questions concerning this report, please call
me on (202) 512-7215. The major contributors to this report are listed in
appendix III.

Sincerely yours,

Barbara D. Bovbjerg
Associate Director, Education,
Workforce, and Income Security Issues

Scope and Methodology

We identified problems with letters for the Old Age and Survivor Insurance
and Disability Insurance programs, commonly known as Social Security, and
the Supplemental Security Income (SSI) program from our earlier work, by
interviewing Social Security Administration (SSA) headquarters and field
office officials and by reviewing other related studies. We also interviewed
and obtained guidance documents from National Partnership for Reinventing
Government officials responsible for the governmentwide initiative to have
federal agencies improve their written communications to the public. Before
deciding the categories of letters we would select for a detailed review, we
performed a cursory review of several thousand that had been generated by
more than 17 different automated programs. We also reviewed several types of
letters prepared manually by the SSA offices where we conducted our
fieldwork. The automated letters we reviewed represented the types of
letters that are produced across SSA. We decided to limit the focus of our
work to letters produced by automated means and exclude manually prepared
letters because SSA lacked management information that would allow us to
identify and quantify them for sampling.

Given the range of issues that SSA's letters address, we screened first for
letters that conveyed information on issues that in our view would more
likely affect recipients adversely if the letters were not understandable.
From among this group of letters, we selected categories that we believed
had the most serious problems. We chose four types of letters--an award
letter and a benefit adjustment letter for each of the two programs, Social
Security and SSI. On the basis of our preliminary screening, we judged these
letters to contain the most serious problems among all categories of letters
that convey SSA's decision on individuals' eligibility for benefits or
adjustments to their benefits.17

We used SSA's customer service pledge, which promises that letters the
agency sends customers will meet certain standards, and our professional
judgment as the basis for deciding the issues that letters need to clearly
convey to individuals.18 We based our detailed assessment of the letters on
our premise that letters should

1. Clearly state SSA's decision (that is, they should clearly communicate
the decision SSA made to award, deny, or adjust benefits or that it had
overpaid or underpaid individuals).

2. Sufficiently and clearly explain the basis for SSA's decision.

3. Clearly explain the financial effect SSA's decision will have on payments
to the individual and, if applicable, how SSA computed payments or change in
payments.

4. Clearly explain the actions the individual can take if he or she
disagrees with SSA's decision.

We used the assistance of two writing consultants to identify writing
deficiencies in cases in which letters were unclear in any of the four
areas. We tested our methodology for assessing letters by applying it to a
small number of letters that contained a range of problems, and we had the
consultants also apply it to the same letters. We resolved differences in
the way the consultants and we assessed the letters. We used the agreed-upon
methodology to identify problems in the statistical sample of benefit
adjustment letters discussed below.

Because SSA's electronic files for 1 day's production of automated letters
are multiple and voluminous, and because SSA did not have resources readily
available to provide us with a computer-generated sample, we consulted with
SSA officials to determine the best sampling method. We randomly sampled 1
day's production of Social Security benefit adjustment letters and 1 day's
production of similar SSI letters. Our sample of Social Security letters
consisted of 104 letters selected from among the first 933 (of a total of
3,910) that SSA produced on February 14, 2000. Our SSI sample included all
64 letters that SSA produced on March 2, 2000 (of a total of 9,448) for
which the beneficiaries' Social Security numbers ended in a predetermined
two-digit number. Our estimates of the frequency of problems we found with
the benefit adjustment letters in both samples can be generalized to the
universe of such letters that SSA produced on the days the samples were
drawn. On the basis of statements of SSA officials, we believe that our
sampling methodology produced a representative selection of the sampled
days' workloads that were typical of workloads throughout the year.

Because the estimates we report are based on a sample, a margin of error or
imprecision surrounds them. This imprecision is usually expressed as a
sampling error at a given confidence level. We calculated sampling errors
for our estimates of how frequently letters were unclear at the 95 percent
confidence level. The sampling error for percentage estimates we cite in
this report is plus or minus 12.1 percentage points at the 95 percent
confidence level.

We did not use random samples for our work on Social Security and SSI award
letters. After we reviewed a variety of these award letters and identified
specific problems with them, we were able to obtain information from SSA
officials to quantify the frequency of the problems without sampling. SSA
officials provided us information on how many of the Social Security award
letters were generated during a recent 3-month period--December 1999 through
February 2000--and how many of these letters contained certain appeals
language that we identified as problematic. We discussed with SSA officials
the problems we identified in the SSI award letters, and they confirmed that
these problems exist in all SSI award letters because of shortcomings in
their computer systems.

To determine SSA's actions and plans to correct problems with the categories
of letters that were the subject of our work, we reviewed SSA's 5-year plan
and annual plans to identify the agency's objectives and goals. We also
interviewed SSA officials and reviewed the agency's documents relating to
its initiatives to improve letters to determine what actions SSA has
proposed to address problems and its plans for implementing them. We
interviewed SSA officials to gain an understanding of the actions required
to correct the problems we identified and the SSA offices responsible for
initiating the actions, and we reviewed SSA's process for implementing
actions that would improve letters.

We performed our work at SSA headquarters in Baltimore, Maryland, and SSA
field locations in Chicago, Illinois; Reisterstown, Maryland; and Richmond,
Virginia. We conducted our work between June 1999 and July 2000 in
accordance with generally accepted government auditing standards.

Comments From the Social Security Administration

GAO Contacts and Staff Acknowledgments

Barbara Bovbjerg, Associate Director, (202) 512-7215
Kay Brown, Assistant Director, (202) 512-3674

In addition to the persons named above, others made important contributions
to this report: Jacquelyn Stewart, Evaluator-in-Charge; Ellen Habenicht,
Senior Evaluator; Valerie Melvin and James Wright, Assistant Directors;
Michael Alexander, Senior Information Systems Analyst; Patrick di Battista,
Communications Analyst; Jay Smale, Social Science Analyst; and Ann
McDermott, Visual Communications Analyst.

(207069)

Table 1: The Most Significant Problems in Four Categories of
SSA Letters and Their Estimated Frequency 9

Table 2: Comprehensive Improvements Needed for Selected
SSA Letters 23

Figure 1: A Social Security Benefit Adjustment Letter in Which
SSA's Decision Is Unclear 11

Figure 2: An SSI Award Letter in Which the Basis for SSA's
Decision Is Unclear 14

Figure 3: A Social Security Benefit Adjustment Letter in Which
the Financial Effect of SSA's Decision Is Unclear 16

Figure 4: An Unclear SSI Award Letter 19
  

1. Social Security Administration: Many Letters Difficult to Understand
(GAO/T-HEHS-94-126, Mar. 22, 1994).

2. SSA characterizes its letters as automated or manual. SSA considers a
letter automated if its personnel input transaction data, such as a death or
earnings report, and SSA's systems generate the letter without any other
human intervention. If SSA personnel were involved in selecting paragraphs
or providing individualized data, then SSA considers the letter to have been
manually prepared.

3. Our review did not include letters sent to persons whose benefits were
terminated because they had been determined to be no longer disabled.

4. In 1999, an earnings limit also applied to retired workers aged 65 to 69
and their dependents. Benefits were reduced by $1 for every $3 over $15,500.
On April 7, 2000, Public Law 106-182, the Senior Citizens' Freedom to Work
Act of 2000, eliminated the earnings limit for retired workers between full
retirement age and age 70, effective January 1, 2000.

5. States have the option of supplementing the federal SSI benefit with
state payments. Forty-four states provide such a supplement to at least some
SSI recipients.

6. In 1996, we reviewed SSA's statements estimating current workers' future
Social Security benefits based on their earnings. We identified problems
that made the statements difficult to understand and recommended that SSA
make several improvements to them. (See SSA Benefit Statements: Well
Received by the Public but Difficult to Comprehend (GAO/HEHS-97-19, Dec. 5,
1996 ).) SSA subsequently revised the statements, consistent with our
recommendations. We found the revised statements to be much improved. (See
Social Security: Providing Useful Information to the Public
(GAO/T-HEHS-00-01, Apr. 11, 2000) .)

7. QS & A Research & Strategy, Comprehension of Two Notices: Overpayment
Notice and Due Process Notice (Fairfax, Va.: Dec. 17, 1992).

8. HHS, Office of Inspector General, Examples of Revised Supplemental
Security Income Notices, OEI-07-9002461 (Sept. 1992).

9. Ford et al. v. Apfel, No. CV-94-2736 (E.D.N.Y., Jan. 13, 2000).

10. This situation occurs when individuals' cirsumstances change while they
are waiting for SSA's eligibility decision on their application for
benefits. Their change in circumstances makes them eligible to receive
benefits for one or more months after they applied for SSI but ineligible
for SSI benefits in the current month. A common scenario involves disabled
individuals who meet the SSI program's income limit only until they receive
Social Security Disability Insurance benefits. Their SSI payments stop once
their Social Security Disability Insurance payments cause them to exceed the
SSI program's income limit.

11. This incorrect statement occurs in these letters only when individuals
receive more than 1 month's past due benefits--a common scenario, according
to SSA.

12. Because of recently enacted legislation, Public Law 106-182, that
eliminated earnings-related reductions in benefits for beneficiaries who
have reached full retirement age, the volume of Social Security benefit
adjustment letters will decrease in the future, but SSA has not determined
by exactly how much.

13. For example, the Personal Responsibility and Work Opportunity
Reconciliation Act of 1996 (Public Law No. 104-193) made major changes to
the SSI program. Among other things, it revised the criteria under which
children and noncitizens are eligible for benefits and added restrictions
governing the payment and use of certain large retroactive benefit amounts.

14. Key initiatives requiring systems work and Customer Targeted Work must
provide a significant return on investment or help meet agency strategic
goals. However, to be given the higher priority of Customer Targeted Work, a
sponsoring component is required to substantiate the need for extra
attention and prioritization.

15. Ford et al. v. Apfel, No. CV-94-2736 (E.D.N.Y., Jan. 13, 2000).

16. GAO/T-HEHS-00-01, Apr. 11, 2000.

17. We excluded from detailed analysis (1) letters that SSA sent to
government agencies or businesses and (2) other types of letters that
conveyed eligibility and benefit adjustment decisions but appeared to have
less serious problems with clarity.

18. SSA pledges to customers that "We will clearly explain our decisions so
you can understand why and how we made them and what to do if you disagree."
*** End of document. ***