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Audit Report - A-06-97-22009


Office of Audit

Southwest Tactical Operations Plan: Impact on Field Office Operations (A-06-97-22009) 1/8/98

EXECUTIVE SUMMARY

OBJECTIVE

The objective of this evaluation was to provide information on the impact of the Southwest Tactical Operations Plan (STOP) on the operations of the Social Security Administration (SSA) field office (FO) in El Paso, Texas, and staff concerns regarding the need for stronger measures to deter residency fraud.

BACKGROUND

Supplemental Security Income (SSI) is a needs-based program that provides income support to aged, blind, or disabled adults, and blind or disabled children. One of the primary eligibility requirements for SSI is that individuals be United States (U.S.) residents and must maintain a continued presence in the U.S.

SSA staff in FOs in border States have alleged that some individuals obtain SSI benefits while in the U.S. and subsequently leave to live in a foreign country. If not detected, these recipients will continue receiving payments for which they are not entitled. Obtaining SSI generally results in eligibility for Medicaid, Food Stamps, and other Federal and State assistance programs. Since SSI is an entry point for receiving other assistance, the impact of individuals receiving SSI fraudulently is far-reaching.

SSA’s Office of the Inspector General (OIG) conducted the STOP pilot project to determine if individuals were receiving SSI payments based on fraudulent statements regarding residence. During the course of the field work, SSA FO staff discussed with STOP project personnel their impressions and ways to improve the overall operation of STOP. This report provides the insights of the El Paso FO staff.

In order to determine the impact of STOP on the FO, we conducted a focus group meeting with claims representatives (CR) and service representatives (SR).  Additionally, we held meetings with managers, supervisory staff, and security guards. (Unless otherwise noted, we will refer to CRs, SRs, managers, and supervisors collectively as staff.)

FINDINGS

Our findings include information on STOP’s impact on FO operations and staff concerns.

  • STAFF WAS SUPPORTIVE OF STOP AND WOULD PARTICIPATE IN SIMILAR OPERATIONS
  • STOP IMPACTED ON FO OPERATIONS
  • STAFF EXPRESSED FRUSTRATION WITH THE LIMITED PENALTIES FOR RECIPIENTS WHO BREAK THE RULES
  • STAFF PROVIDED SUGGESTIONS FOR IMPROVEMENT TO THE SSI PROGRAM AND THE STOP PILOT PROJECT

CONCLUSIONS

Staff supported project STOP. Despite the significant impact on operations, the project helped increase awareness of SSI residency requirements in the community. Staff want to send a message to SSI recipients and the surrounding community that SSA does not tolerate fraud. They want increased penalties and additional investigative resources invested to deter and detect fraud in the SSI program. The staff would be willing to work on similar projects in the future.

TABLE OF CONTENTS

EXECUTIVE SUMMARY

INTRODUCTION

FINDINGS

STAFF WAS SUPPORTIVE OF STOP AND WOULD PARTICIPATE IN SIMILAR OPERATIONS

STOP IMPACTED ON FIELD OFFICE OPERATIONS

Security Guards and Receptionists Hardest Hit

CRs and SRs Faced Additional Workloads

STAFF EXPRESSED FRUSTRATION WITH THE LIMITED PENALTIES FOR RECIPIENTS WHO BREAK THE RULES

STAFF PROVIDED SUGGESTIONS FOR IMPROVEMENT TO THE SSI PROGRAM AND THE STOP PILOT PROJECT

Staff Suggestions to Improve SSI Fraud Detection and Prevention

STOP Suggestions

CONCLUSIONS

APPENDICES

Appendix A - Major Report Contributors 

INTRODUCTION

OBJECTIVE

The objective of this evaluation was to provide information on the impact of STOP on the operations of the SSA FO in El Paso, Texas, and staff concerns regarding the need for stronger measures to deter residency fraud.

BACKGROUND

STOP was developed as a pilot project to test methods for identifying potential residency fraud. During the course of the field work, FO staff discussed with project STOP personnel their impressions of STOP and ways to improve the overall operation. This report provides the opportunity for FO staff to provide their insights.

Field Office Allegations

The catalyst for STOP was allegations that some individuals obtain SSI benefits while in the U.S. and subsequently leave to live in a foreign country. If not detected, these recipients will continue receiving payments for which they are not entitled. Obtaining SSI generally results in eligibility for Medicaid, Food Stamps, and other Federal and State assistance programs. Since SSI is an entry point for receiving other assistance, the impact of individuals receiving SSI fraudulently is far-reaching.

SSI is a needs-based program that provides income support to aged, blind, or disabled adults, and blind or disabled children. One of the primary eligibility requirements for SSI is that individuals be U.S. residents and must maintain a continued presence in the U.S.

Site Selection

We selected El Paso, Texas, as the site of the pilot project because of its proximity to the U.S.-Mexican border. El Paso, a city of approximately 652,000 inhabitants, shares its city border with the Mexico border. Directly across the Rio Grande and connected by a variety of foot and automobile bridges is Ciudad Juarez, Mexico, a city of approximately 1.2 million inhabitants. The relative ease of travel between the two cities has resulted in many people looking at El Paso and Ciudad Juarez as one large city. SSA staff and El Paso residents with whom we spoke believed residency choices are often based on costs and proximity to family and friends rather than the desire to live in a specific country. SSA staff allege that some SSI recipients in El Paso do not meet the residency requirements.

OIG Pilot Project

SSA’s OIG conducted the STOP pilot project to determine if individuals were receiving SSI payments based on fraudulent statements regarding residence. OIG used a mailer and office interviews as the primary means of obtaining information from SSI recipients. We sent letters to 2,107 SSI recipients residing in the 79901 and 79912 ZIP codes. We requested that individuals provide, by mail, proof of U.S. residency. The project STOP personnel were located in the El Paso FO.

OIG’s Offices of Investigations (OI) and Audit (OA) worked as a team to conduct STOP. OI and OA, with assistance from SSA’s Office of Program and Integrity Reviews staff (Region VI), reviewed recipients’ documentation and, when recipients or their representatives came into the FO, conducted interviews to verify residency. Additionally, OI investigated potential nonresidency cases that arose as a result of the document reviews and/or interviews. OA analyzed the outcomes of the pilot project and its impact on the El Paso FO. Based on these efforts, the OIG will determine the usefulness and transferability of such an effort to other locations.

METHODOLOGY

In order to determine the impact of STOP on the FO, we conducted a focus group meeting with CRs and SRs. Additionally, we held meetings with managers, supervisory staff, and guards.

This report is one in a series of reports related to the STOP project. Additional reports will contain information on demographic characteristics of recipients, results of the matching efforts with the Texas Bureau of Vital Statistics and the Immigration and Naturalization Service, characteristics of nonresidents, results of STOP investigations, and a follow-up review to determine the payment status of SSI recipients whose benefits were suspended as a result of STOP.

Our evaluation was performed in accordance with the Quality Standards for Inspections issued by the President’s Council on Integrity and Efficiency. 

FINDINGS 

STAFF WAS SUPPORTIVE OF STOP AND WOULD PARTICIPATE IN SIMILAR OPERATIONS

Staff believe "there is a lot of [residency] abuse" and, therefore, were supportive of STOP. They are concerned about potential residency abuses and the deception that individuals use to become entitled to and receive SSI benefits. The following are two accounts of CR’s and SR’s experiences with recipients who provided false information about residency.

A woman owned her home in El Paso and gave that address to SSA as her residence. Property is important as it solidifies an individual as being part of a community. Additionally, the assumption is that if an individual owns a house and land in a city the individual is a resident of that city. However, the recipient rented her house to others. A STOP investigator found that the woman had not lived in her house in 1 years and was residing in Mexico. She was willing to go through the extreme of lying.

A claimant admitted he comes to pick up his check, stays 3 days [in El Paso] then goes back to [Ciudad Juarez].

Because of the potential for residency abuse, CRs and SRs volunteered to assist with STOP-related tasks. They believe projects like STOP are needed on a regular basis. One worker summed up the feelings of others when he asked,

Is there consideration for this type of review to continue? I have been with the Agency many years. From what I see, we need more activities like STOP. We don’t have a sufficient number of staff to constantly scrutinize individuals’ residency status.

Initially, managers were "apprehensive" about participating in STOP. However, after assisting in STOP, they stated that they would "participate in another study of this type because it sends a message to the public that we are not lenient on individuals committing SSI fraud."

STOP IMPACTED ON FO OPERATIONS

STOP generated extra work for the FO. Staff said recipients’ office visits had a significant impact on their operations. Although recipients were told to mail documents needed to verify their residency in the U.S., the majority brought the documents into the office or had relatives or friends deliver the documents. The FO manager summed up the volume of office visits by saying:

As many as 83 recipients came in the office in a day. The office was usually jam packed with people. Only one-tenth were coming to see CRs or SRs.

Even before STOP started, CRs and SRs believed that recipients would come into the office as a result of the mailer. They provided the following comments about recipients’ reactions to mailed correspondence.

The letter says mail [the documents]. People are not going to mail them. They are going to come in.

Recipients’ responses to the letter will be ‘The tone of the letter doesn’t sound like something that I want to just put in an envelope. I want to know what’s happening. I want to go in person.’

Security Guards and Receptionists Hardest Hit

The security guards and receptionists (rotating CRs and SRs) experienced the greatest impact from the office visits due to the volume of individuals coming into the FO. The security guards served as the initial receptionist. All individuals coming to the office were required to speak to the security guard before making contact with any other worker. He would explain that they needed to wait and that a STOP staff would be with them shortly. Some individuals chose not to tell the security guard that they were there regarding STOP and spoke with the receptionist.CRs and SRs Faced Additional Workloads

For staff, the STOP workload was more than anticipated. Additional work included:

  • conducting unscheduled office and telephone interviews with recipients who wished to discuss STOP;
  • making data entries in recipients’ automated folders (up to 2 hours per day);
  • responding to recipients’ inquiries about suspended cases;
  • assisting recipients whose benefits were suspended by setting up conferences and arranging for recipients to file appeals;
  • responding to calls from local service providers (SSI suspensions were negatively affecting recipients receiving hospice and homemaker services);
  • meeting with protesting recipients who believed they were penalized for visiting relatives in Mexico;
  • meeting with U.S. citizens who were upset and confused about their need to prove they are U.S. residents; and
  • explaining residency requirements to recipients–especially elderly recipients–who have misunderstandings of what residency means for SSI purposes.

STAFF EXPRESSED FRUSTRATION WITH THE LIMITED PENALTIES FOR RECIPIENTS WHO BREAK THE RULES

FO Staff expressed a variety of concerns related to the penalties recipients face when they willfully provided false information to obtain and/or receive SSI benefits. For example, they question the lack of a waiting period after an individual is found to have falsified residency information to reapply for benefits. Currently, individuals who have falsified residency information need only establish residency for 30 consecutive days and present the information to SSA to be placed back into payment status. They also question the handling of overpayments. One worker summed up the feelings regarding this issue.

In the end, most of [the suspended cases] are going to be put back into pay status. We will reduce the SSI payments to pay for the overpayment. So the effect is, the Government is paying its own self back.

In addition, the small amount that the recipient usually pays back each month will require years before the overpayment is recovered.

Staff believe that U.S. Attorneys are reluctant to prosecute some recipients, especially the elderly. They also believe that recipients are aware of the limited penalties. The recipients and the community believe "[SSA is] not willing to take harsh steps when [recipients] commit residence fraud." One worker reported,

The community should be advised of the penalties associated with SSI residency fraud.

STAFF PROVIDED SUGGESTIONS FOR IMPROVEMENT TO THE SSI PROGRAM AND THE STOP PILOT PROJECT

The staff provided suggestions for improving the SSI program–especially related to residency–and STOP.

Staff Suggestions to Improve SSI Fraud Detection and Prevention

If a recipient provides falsified information regarding residency, there should be an extended waiting period before the individual can be reinstated.

Recipients committing fraud should be punished. They should be given the message, "If you provide false information, you are likely to be fined or go to prison."

The FO should be able to routinely request assistance from OIG to verify residency when there is a suspicion that an individual has provided falsified information to obtain benefits.

STOP Suggestions

More publicity should be given to fraud detection and identification studies. The community and recipients need to receive the message, "If you do not live in the country, you are not going to get benefits."

FO staff should be more involved in the planning stage of a pilot project like STOP. They are able to: 1) direct the team to the areas in the city where fraud is most likely found; 2) provide insights into the culture of the individuals to be reviewed; and 3) determine which data collection methods are most likely to be successful.

Staff resources should be provided to handle the residual work that projects like STOP generate. The FO was left with the clean-up work resulting primarily from suspended cases. Two workers commented,

I have 34 requests for reconsiderations added to my workload. Some clients are requesting to see their folder [which also] adds to my workload.

After [STOP staff] did what they needed to do here, they closed up shop and left. They left the rest of us kind of [hanging]. There was no indication of what was going to be our next step.

CONCLUSIONS

Staff supported project STOP. Despite the significant impact on operations, the project helped increase awareness of SSI residency requirements in the community. Staff want to send a message to SSI recipients and the surrounding community that SSA does not tolerate fraud. They want increased penalties and additional investigative resources invested to deter and detect fraud in the SSI program. The staff would be willing to work on similar projects in the future.

APPENDICES

Appendix A

MAJOR REPORT CONTRIBUTORS

Office of the Inspector General

William Fernandez, Director, Program Audits (West)
Brian Pattison, Deputy Director
Elsie Chaisson, Senior Evaluator
George De Luna, Senior Evaluator
Johannah G. Evans, Staff Assistant

 Social Security Administration

El Paso Field Office Staff

For additional copies of this report, please contact the Office of the Inspector General’s Public Affairs Specialist at (410) 966-9135. Refer to Common Identification Number A-06-97-22009.

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