A recent study by the Social Security Administration’s Office of the Inspector General (OIG) found that the Administration failed to identify and properly resolve underpayments on prior Supplemental Security Income (SSI) records in a significant percentage of cases studied.  See OIG A-07-18-50676 – Underpayments on Prior Supplemental Security Income Records.

The OIG reviewed a sample of cases in which a prior Supplemental Security Record (SSR) had been terminated because, for example, the claimant had not been in pay for more than one year. In these situations, if the claimant becomes eligible again, SSA creates a new SSR. If an underpayment exits on the old SSR, SSA Field Office staff must take manual action to insure the underpayment is resolved, either by offsetting it against outstanding overpayments or refunding it.

Despite findings and recommendations by the OIG in 2007 and 2013, and new SSA software in 2014, the OIG found SSA did not identify or resolve outstanding underpayment in ninety percent of the 114 SSRs reviewed. According to the OIG, underpayments totaling $503,000 should have paid to recipients, offset against outstanding overpayments, or removed from prior records. Based on its sample, the OIG estimates that between May 2011 and April 2018, 70,000 prior SSRs were terminated, leaving outstanding underpayments of $173 million.

The OIG recommended that SSA correct the SSRs of the 103 claims it identified. It also recommended that SSA review and correct its software, and establish timeliness goals for employees to diary and process underpayments on prior SSRs.

Given the OIG findings, advocates should be on the outlook for outstanding underpayments based on prior SSRs. And of course, advocates should always be on the lookout for any prior claims or allowances where benefits were subsequently terminated for non-disability reasons. SSA often fails to obtain or consider the evidence in prior files on which the claimant was previously found disabled. See the December 2013 edition of this newsletter for more on this important issue of prior files.