The Government Accountability Office (GAO) provided a list of recommendations to Social Security in an effort to improve Social Security’s Representative Payee program.
Social Security utilizes the payee program when disabled and vulnerable beneficiaries are unable to manage their own benefits. Many times Social Security allows a relative or friend to manage a beneficiary’s benefits, but when that is not possible Social Security turns to non-profit organizations, or other types of care facilities to manage the benefits of these beneficiaries. There have been incidents where the benefits of one of these beneficiaries have been misused and the GAO’s report urges Social Security to redesign the program.
In a joint statement from U.S. Rep. John Larson, (D-CT) and U.S. Rep. Tom Reed, (R-NY), both legislators, who serve as the chair and ranking member of the U.S. House Ways and Means Social Security Subcommittee, said Social Security should adopt the recommendations in an effort to strengthen and monitor the reliance of organizations that are asked to manage the Social Security benefits of vulnerable beneficiaries. The nine recommendations the GAO presented to Social Security are below.
- The Commissioner of the Social Security Administration should ensure that (a) the agency’s policies and guidance are specific enough so field office staff know how to apply complex suitability criteria for assessing payee suitability, such as by providing a minimum set of specific questions; and (b) additional regional guidance that is made available to staff is centrally reviewed for compliance and completeness.
- The Commissioner of the Social Security Administration should create safeguards in the Electronic Representative Payee System (eRPS) to ensure that field office staff fully document all required information, such as the rationale for their decision, before approving an application.
- The Commissioner of the Social Security Administration should complete a plan, including timeframes, for comprehensively evaluating if and how to leverage external sources of information on organizations’ suitability, such as by conducting background checks or credit checks on organizations or key staff that handle beneficiaries’ funds or requiring organizations to conduct their own background checks on key staff.
- The Commissioner of the Social Security Administration should develop and implement mechanisms to systematically obtain and review feedback from organizational payees and communicate findings to SSA management.
- The Commissioner of the Social Security Administration should (a) establish a plan and time frame for periodically reviewing the predictive model’s design; (b) consider additional data sources that would allow for additional screening or modeling of potentially high-risk organizational payees; and (c) ensure that subsequent design decisions are documented in sufficient detail so the development process can be more fully understood and replicated, either by SSA or a knowledgeable third party, with minimal further explanation.
- The Commissioner of the Social Security Administration should require field offices to contact payees about missing or problematic annual accounting forms within a specific time frame.
- The Commissioner of the Social Security Administration should revise the annual accounting form to enhance its effectiveness. Such revisions could include (but not be limited to) more fully ascertaining the use of collective accounts, adopting stakeholders’ recommendations on using the form to collect more meaningful data, and reflecting best practices from behavioral science insights in the design of the form.
- The Commissioner of the Social Security Administration should enhance the eRPS system to ensure that field offices are (a) alerted when collective accounts are due to be reviewed; and (b) able to take action on expired collective account information and thereby avoid payees’ continued use of these accounts without oversight.
- The Commissioner of the Social Security Administration should, as it carries through with its plan to develop a risk assessment for the organizational payee program, ensure that that the plan reflects periodic consideration of findings from onsite reviews and audits.
