SSA Disability
Enhanced Procedures and Guidance Could Improve Service and Reduce Overpayments to Concurrent Beneficiaries Gao ID: GAO-02-802 September 5, 2002In calendar year 2001, the Social Security Administration (SSA) paid cash benefits of $60 billion to more than six million working-age adults with disabilities and eligible family members under its Social Security Disability Insurance (DI) program, and $20 billion to more than 3.5 million working-age adults with disabilities under the Supplemental Security Income (SSI) program. Some beneficiaries, known as concurrent beneficiaries, receive cash and medical benefits from both programs. Concurrent beneficiaries comprised about 14 percent of SSA's disability population; 58 percent have mental impairments, and about 53 percent are female. Eleven percent of concurrent beneficiaries worked and earned a median income of approximately $250 per month. 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. 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 decrease in overall income, depending on the amount of earnings. Concurrent beneficiaries may not receive adequate explanations from SSA staff or 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.
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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 Beneficiaries‘
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 beneficiaries‘ decisions to
work and on their benefits.
To address these issues, we analyzed data from SSA‘s 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 SSA‘s 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
beneficiaries‘ 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 worker‘s 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 beneficiary‘s 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 beneficiary‘s 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 program‘s 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 beneficiary‘s 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 SSA‘s
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 Beneficiaries‘
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 beneficiaries‘ 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:
SSA‘s 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. SSA‘s 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 person‘s
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:
SSA‘s 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 programs‘ 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 beneficiaries‘ benefit payments. In
addition, without a monitoring system to ensure information about
concurrent beneficiaries‘ 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 employees‘ 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 Administration‘s
(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 beneficiaries‘ 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, ’Social Security Administration Disability: Enhanced
Procedures and Guidance Could Improve Service and Reduce Overpayments
to Concurrent Beneficiaries“ (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, ’SOCIAL SECURITY ADMINISTRATION
DISABILITY: ENHANCED PROCEDURES AND GUIDANCE COULD IMPROVE SERVICE AND
REDUCE OVERPAYMENTS TO CONCURRENT BENEFICIARIES“ (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 Agency‘s 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 employees‘ 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 SSA‘s
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 beneficiaries‘ 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 years‘ benefits.
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