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Audit Report - A-13-96-51142


Office of Audit

Audit of the Office of Program and Integrity Reviews` Special Studies - A-13-96-51142 - 2/19/97

TABLE OF CONTENTS

EXECUTIVE SUMMARY

BACKGROUND

SCOPE

FINDINGS

ESTABLISHING MANAGEMENT CONTROLS

ESTABLISHING SPECIAL STUDY STANDARDS

ESTABLISHING STATISTICAL POLICIES

CONCLUSION AND RECOMMENDATIONS

APPENDICES

A - SPECIAL STUDIES SELECTED FOR REVIEW

D - MAJOR CONTRIBUTORS TO THIS REPORT

EXECUTIVE SUMMARY

INTRODUCTION

The Social Security Administration (SSA) established the Office of Program and Integrity Reviews (OPIR) to perform quality assessment reviews of SSA programs and operations. OPIR is headed by the Associate Commissioner for Program and Integrity Reviews who reports directly to the Deputy Commissioner for Finance, Assessment, and Management and Chief Financial Officer. OPIR has 4 headquarters offices and 10 regional offices. These offices are responsible for conducting quality assurance reviews and special studies of SSA programs. These special studies and reviews generally contain recommendations for corrective changes in programs, policies, procedures, or legislation aimed at quality and productivity improvement and/or program simplification. Between October 1, 1992 and September 30, 1994, OPIR had approximately 1,500 staff and an operating budget of $90 million. We estimate that 25 percent of OPIR’s resources were dedicated to special studies with the remainder primarily dedicated to quality review initiatives.

The objectives of our audit were to determine whether OPIR`s special studies were: (1) used by management to improve SSA programs; (2) cost-effective and efficient; and (3) performed in accordance with established standards.

SUMMARY OF FINDINGS

We were not able to meet our intended objectives because OPIR has not implemented appropriate management controls necessary for assuring accountability for special studies. OPIR has not developed a system for tracking special studies and proposed recommendations, established standards for conducting its special studies, or established policies for assuring the statistical validity of its studies. As a result, we were unable to ascertain either the cost-effectiveness or efficiency of OPIR’s special studies or their usefulness to Agency managers. Therefore, we are reporting on the conditions that we found relating to weaknesses in management controls and the need for OPIR to establish management controls, special study standards, and statistical policies.

First, our attempt to determine the cost-effectiveness and efficiency of OPIR’s special studies, required us to identify an inventory of all special studies conducted during our audit period of Fiscal Years (FYs) 1993 and 1994. We found that OPIR has not implemented effective management controls that maintain an inventory of its special studies and the resulting recommendations and their current implementation status. The Office of Management and Budget (OMB) issued Circular A-123 to implement the requirements set forth by the Federal Managers’ Financial Integrity Act of 1982 (FMFIA), Public Law (P.L.) 97-255. The Circular requires that management controls be implemented to ensure that managers are accountable for their operations and for the proper stewardship of Federal resources. Management has not committed to these principles and as a result, we were unable to evaluate OPIR’s special study performance or the value of its studies to the Agency.

Second, we extended our procedures to determine whether standards were employed over the conduct of individual special studies. We originally intended to review a statistical sample of special studies that were conducted during FYs 1993 and 1994. However, due to the lack of management controls, we were unable to identify the universe of OPIR’s special studies. As an alternative, we selected a judgmental sample of 10 special studies and found that the standards for performing OPIR’s special studies are informally established by the staff who conduct the review and are not documented to assure compliance. Management has not implemented professionally accepted or recognized study standards or established policies or procedures for conducting OPIR’s special studies.

Third, in reviewing OPIR’s special studies, we found that two of the studies selected for review did not comply with minimal OMB statistical sampling requirements. These two studies involved the collection of information from the public to evaluate SSA’s effectiveness in making referrals to other government services. During the conduct of these studies, OPIR used inappropriate sample selection and data collection methods which resulted in a response rate well below OMB’s minimum response rate requirements. As a result, these two studies did not comply with OMB’s minimal statistical standards that are required under section 1320.9 of Title 5 of the Code of Federal Regulations (CFR). These deficiencies occurred because OPIR has not implemented adequate statistical policies and procedures for conducting special studies.

RECOMMENDATIONS

As a result of our review, we are making several recommendations. To establish effective management controls in OPIR’s operations, we are recommending that OPIR improve its management control program and establish special study and statistical policies and procedures. Specifically, we are recommending that OPIR:

1. develop and maintain a workload tracking system which includes monitoring prior and current assignments and resources expended;

2. develop and maintain a system for tracking the current status of OPIR recommendations incorporating any prior recommendations that have not been implemented;

3. establish OPIR as a management control area in SSA’s FMFIA program;

4. develop and implement policies and procedures for conducting OPIR studies, including requirements for maintaining adequate study documentation for examination; and

5. implement statistical policies and procedures, such as those published in the General Accounting Office’s (GAO) Using Statistical Sampling publication (GAO/PEMD-10.1.6) and modify reporting formats to include detailed statistical information, such as response rates and confidence intervals, in all reports where statistical sampling is used.

AGENCY COMMENT

SSA decided not to comment on the draft report. The Agency has engaged a consultant to review a number of issues related to OPIR’s operations. The Agency believes that it would be beneficial for the consultant to consider our findings and recommendations before providing specific comments.

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BACKGROUND

OPIR’s mission is to evaluate and assess the integrity and quality of SSA programs with emphasis on the prevention of program and systems abuse, the elimination of waste, and the increase of efficiency. To accomplish its mission, OPIR conducts quality assurance reviews and special studies. These reviews and studies generally contain recommendations for corrective changes in programs, policies, procedures, or legislation aimed at quality and productivity improvement and/or program simplification.

OPIR is headed by the Associate Commissioner for Program and Integrity Reviews who reports directly to the Deputy Commissioner for Finance, Assessment, and Management and Chief Financial Officer. OPIR has 4 headquarters offices and 10 regional offices that conduct its quality assurance reviews and special studies. The 10 Offices of Regional Program and Integrity Reviews support quality assurance and special study activities that are formulated by OPIR’s headquarters offices. OPIR is organized as follows:

(CHART UNAVAILABLE AT THIS TIME)

During FYs 1993 and 1994, OPIR, on average, had approximately 426 headquarters staff and 1,125 field staff in its 10 regional offices and an operating budget of $90 million. Between October 1, 1992 and September 30, 1994, we estimate that 25 percent of OPIR’s resources were dedicated to special studies with the remainder primarily dedicated to quality review initiatives.

Special studies are conducted within each of OPIR’s major offices. Special studies generally refer to one-time studies that focus on a particular area or issue of SSA’s programs. These special studies cover the full range of legal requirements, policies, procedures, systems, and operations for the Retirement and Survivors Insurance (RSI), Disability Insurance, and Supplemental Security Income (SSI) programs. They also cover service delivery issues that relate to SSA’s field and teleservice offices including customer satisfaction surveys of its customers. These special studies sometimes result in formal reports that contain recommendations or informational reports that summarize the data gathered during the study.

Examples of OPIR’s quality review initiatives include the annual quality reviews of the accuracy of disability decisions in addition to the Index of Dollar Accuracy and Stewardship reviews that provide payment accuracy measures for the RSI and SSI programs. Another initiative involves OPIR staff visits to SSA’s field offices for the purpose of improving operational issues.

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SCOPE

Our audit was conducted in accordance with generally accepted government auditing standards. The objectives of our audit were to determine whether OPIR`s reviews were: (1) used by management to improve SSA programs; (2) cost-effective and efficient; and (3) performed in accordance with established standards.

To determine whether OPIR special studies were cost-effective and used by management, we designed audit steps to review management and operational controls and special study workloads. We also designed steps to review the policies and procedures used to perform reviews and report on study results and recommendations. Our audit procedures included a review of:

  • applicable SSA and OPIR policies and procedures;
  • OPIR’s systems for measuring, reporting, and monitoring program performance relating to special studies;
  • OPIR work plans and other available management information;
  • OMB, GAO, and other standards for implementing and maintaining management controls; and
  • OMB statistical standards and other guidelines for statistical sampling.

We could not achieve our objectives because OPIR records were not complete. Therefore, we performed alternative audit procedures to identify the universe of OPIR’s FYs 1993 and 1994 workloads, that included reviewing work plans, OPIR’s correspondence records, management’s report files, and other available information. Because of the limitations in this data, we were unable to:

  • identify the total inventory of special studies conducted during the audit period;
  • determine the status of recommendations that resulted from special studies conducted during the audit period; and
  • determine the resource and operational costs attributable to special studies to measure the cost-effectiveness and efficiency of OPIR’s special study operations.

We also designed procedures to review OPIR’s management controls over operations and controls that related to the conduct of its special studies. Our assessment showed that management controls were not properly designed and/or implemented, therefore, we could not rely on them.

We continued to perform additional audit steps to determine whether compensating procedures existed in the management of individual special studies and to identify standards that were used by OPIR when conducting special studies. We selected a judgmental sample of 10 studies that were either initiated, in progress, or completed during FYs 1993 and 1994. For the 10 studies, we:

  • reviewed draft and/or final reports;
  • reviewed project statements, highlight reports, monthly status reports, and other study documentation, where available, and
  • interviewed OPIR management and staff responsible for conducting the 10 selected studies.

Several of the 10 selected studies were conducted by regional staff. We requested interviews with regional staff who conducted the studies, but were informed that individuals who worked on these studies were no longer employed with OPIR. Therefore, we relied on headquarters’ managers and staff who were involved with these studies to assist us.

We conducted our audit between November 1995 and May 1996 at SSA headquarters in Baltimore, Maryland.

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FINDINGS

We were not able to meet our intended objectives because our assessment of OPIR’s policies and procedures showed that OPIR has not implemented appropriate management controls necessary for assuring accountability for special studies. OPIR has not developed a system for tracking special studies and proposed recommendations, established standards for conducting its special studies, or established policies for assuring the statistical validity of its studies. As a result, we were unable to ascertain either the cost-effectiveness or efficiency of OPIR’s special studies and their usefulness to Agency managers. Therefore, we are reporting on the conditions that we found relating to weaknesses in management controls and the need for OPIR to establish management controls, special study standards, and statistical policies.

ESTABLISHING MANAGEMENT CONTROLS

OPIR has not implemented effective management controls to ensure accountability for its special study operations. OPIR does not have systems that maintain an inventory of its special studies, the recommendations resulting from studies, or the status of the recommendations within the Agency. OMB Circular A-123 requires that management controls be implemented to ensure that managers are accountable for their operations and for the proper stewardship of Federal resources. Since management has not committed to these principles, we were unable to evaluate OPIR’s special study performance or the value of its special studies to the Agency.

We requested a complete inventory of OPIR’s workload to identify special studies conducted during FYs 1993 and 1994. However, OPIR was unable to readily produce a comprehensive accounting of its special study workload for studies that were initiated, ongoing, or completed during the audit period. We extended our audit steps and attempted to quantify OPIR’s study workload by reviewing other available information such as management’s report files, correspondence files, available status reports, and work plan documents. Despite these efforts, we were still unable to reasonably reconstruct OPIR’s workload because the available information was incomplete and inconsistent.

We also found that OPIR does not have a mechanism that provides an inventory of OPIR’s study recommendations or a method for following up to assure that study recommendations are implemented within the Agency. OPIR also does not accumulate information that allows management to determine the costs or resources invested when conducting these special studies. Therefore, we could not evaluate the usefulness of these studies to the Agency, the resulting impact of study recommendations, or whether budgetary resources were used in the most efficient and effective manner. As a result, we cannot attest to the value of OPIR’s special study efforts to the Agency or to the impact that its study efforts have on improving SSA’s operations because OPIR does not have management controls to track this information.

OPIR’s primary controls for managing studies and monitoring performance are through the use of project statements, highlight reports, and monthly status reports. The project statements are prepared at the beginning of a study and summarize the study’s purpose and review methodology. The highlight reports serve as an informal, internal mechanism to promote staff communication and awareness of current OPIR activities, while the monthly status reports provide management with the current status of studies. These documents are used to manage studies only while the studies are in progress and are not intended to be used as historical documents. Each manager has the discretion to retain or dispose of this information. These documents could not be utilized by management to construct an inventory of studies and recommendations or be used to monitor the implementation or status of study recommendations. Therefore, these documents are insufficient for the purposes of evaluating OPIR’s performance.

FMFIA requires agencies to establish internal accounting and administrative controls in accordance with standards prescribed by the Comptroller General. It also requires agencies to evaluate their controls and annually report on the status of compliance with the requirements of FMFIA. To implement FMFIA, OMB issued Circular A-123 to provide guidance to Federal managers on improving accountability and effectiveness of Federal operations by establishing, assessing, correcting, and reporting on management controls.

The Circular states that Federal agency management has a fundamental responsibility for being accountable for the proper stewardship of Federal resources. It requires management to develop and implement appropriate, cost-effective management controls in their program and administrative functions. It also requires managers to assess and report on the adequacy of those controls in their operations. OMB Circular A-123 integrates management control activities into other management requirements and policies, such as the Government Performance and Results Act of 1993, P.L. 103-62. This integration emphasizes management’s responsibility to design and implement an appropriate management structure that helps ensure accountability for results, and includes appropriate, cost-effective controls.

Management controls are operational checks and balances which ensure that a task will be carried out as planned in the most efficient and effective way possible. The control environment represents the collective effect of various factors on establishing, enhancing, or mitigating the effectiveness of specific policies and procedures. One of these factors is management’s control methods for monitoring and following up on performance, including internal auditing. Management control activities are not considered to be stand-alone management practices, but rather are woven into the day-to-day operational responsibilities of agency managers.

The expectation that managers are responsible for implementing management controls is common to basic management practices that are recognized in the Federal community. For example, a Public Administration Review article explains the concept of management controls as follows:

"The concept of management control is quite simple. Management control encompasses all activities designed to assure that an organization accomplishes its objectives effectively and efficiently (1) within the planned time frame, (2) within approved cost limitations, and (3) with the planned quality and quantity of output. The control process spans the whole gamut of management activities from deciding what the organization should do or what it should emphasize, to allocating funds, monitoring activities, conducting reviews, making midcourse corrections, and evaluating organizational and individual performance. As such, it differs from internal accounting control because of its emphasis on results."

We believe that controls have not been established because management has not recognized the importance of management controls and made a commitment to implementing them to ensure accountability for its operations. This is evidenced by the exclusion of OPIR from SSA’s annual FMFIA program. As a result, SSA has not conducted a periodic management control review of OPIR’s operations to determine whether controls are adequate and working as intended, and whether new controls are needed. These reviews are required by OMB Circular A-123 to meet the requirements of FMFIA and should be reasonably comprehensive so that weaknesses in controls are identified and corrected. The FMFIA program seeks to ensure that strong management controls exist in Federal operations thereby decreasing the likelihood of fraud, waste, and mismanagement.

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ESTABLISHING SPECIAL STUDY STANDARDS

We originally intended to review a statistical sample of special studies that were conducted during FYs 1993 and 1994. However, due to the lack of management controls, we were unable to identify the universe of OPIR’s special studies. Alternatively, we selected a judgmental sample of 10 special studies from OPIR’s work plans and correspondence records that were conducted during the period under audit to assess whether standards were employed. Our review of these 10 studies showed that the standards for performing OPIR’s special studies are informally established by the staff who conduct the review and not documented to assure compliance. Management has not implemented professionally accepted or recognized study standards or established policies or procedures for conducting OPIR’s special studies.

For the 10 studies we reviewed, we asked OPIR to provide all study documentation or working papers in order to evaluate management`s involvement, the basis for decisions, and the support for statistical sampling and study methodologies used during the conduct of these studies. We were provided study documentation for three of the special studies because no documentation existed for the other seven studies. We found that the available study documentation for the three studies did not provide sufficient information for us to assess that standards were employed during the conduct of these studies.

We also requested statistical documentation, when applicable, from OPIR staff who conducted these studies and from OPIR’s statistical specialists. These specialists provide technical assistance and oversight for statistical sampling performed across the various OPIR components. OPIR did not provide sufficient supporting statistical documentation that would allow us to verify either the validity of the sampling methods used or the basis for conclusions drawn from the samples.

We interviewed OPIR’s management regarding the retention of study documents. They stated that they do not require staff to maintain documentation for historical purposes and if information is maintained, it is at the sole discretion of the staff conducting the study. Management relies on the latest version of the study report as the documentation of the results of the study and the statistical sampling methodology used to conduct the review.

OMB Circular A-123 requires that management controls be established consistent with the Comptroller General’s "Standards for Internal Controls in the Federal Government." Two specific management control standards address supervisory and documentary techniques that are essential to providing assurance that internal control objectives are achieved. The supervision standard requires supervisors to continuously review and approve the assigned work of their staff. This requires supervisors to clearly communicate the duties, responsibilities, and accountabilities assigned to each staff member, in addition to systematically reviewing and approving each member’s work.

At the same time, the documentation standard requires documents to be complete and accurate to facilitate tracing the event and related information from before it occurs, while it is in process, to after it is completed. It goes on further to state that "documentation of internal controls systems and transactions and other significant events be purposeful and useful to managers in controlling their operations, and to auditors or others involved in analyzing operations." Other professionally recognized standards for conducting studies, audits, or inspections, such as the Internal Auditing Standards, generally require that documentation of the work performed be maintained so that an independent party can ascertain whether the evidence supports the studies’ significant conclusions and judgements.

As a result of OPIR having no documentary evidence that supports its work performed during these studies, senior management cannot attest to the quality and accuracy of its work. Since OPIR’s mission is to assist the Agency in making improvements in SSA programs and it can recommend significant program changes resulting from its work, OPIR should be in a position to defend the methodologies used to reach its conclusions both internally and externally to the Agency.

ESTABLISHING STATISTICAL POLICIES

In reviewing OPIR’s special studies, we found that two of the studies selected for review did not comply with minimal OMB statistical requirements. For the other eight studies, the reports and supporting documentation did not contain sufficient detail to determine the validity of the statistical methods used. The two studies were the "Evaluation of SSA Field Office Referral Services" (FO Referral) and the "Evaluation of Teleservice Center Referral Services" (TSC Referral), both of which involved collecting information from the public to evaluate SSA’s effectiveness in making referrals to other government services.

When Federal agencies perform studies that involve the collection of information from the public, they must comply with OMB regulations. Under the authority of 5 CFR  1320.9, OMB requires effective and efficient statistical survey methodology. These two studies did not comply with OMB standards because OPIR utilized inappropriate sample selection and data collection method which resulted in a response rate well below OMB’s minimum response rate requirements. These deficiencies occurred because OPIR has not implemented adequate statistical policies and procedures.

OMB requires that statistical surveys be conducted using appropriate statistical methods that will produce valid and reliable results that can be generalized to the universe. OMB also issued specific guidance in January 1979 regarding minimal response rates when using statistical sampling. OMB’s minimal requirements for response rates are stated as follows:

"Survey Response Rates and Sample Design. It is expected that data collections based on statistical methods will have a response rate of at least 75 percent. Proposed data collections having an expected response rate of less than 75 percent require a special justification. Data collection activities having a response rate of under 50 percent should be terminated."

Response rates lower than 75 percent put the statistical validity of the results at risk and may, ultimately, provide misleading results because the nonresponders may be unlike the sampled group that responded.

We reviewed the reports that were written for both studies. We were unable to review documentation that supported the statistical sampling methods used during the review because information was not maintained by OPIR. However, the reports contained enough information for us to conclude that minimal OMB standards were not followed.

Both studies used a preselection method for identifying the survey sample. In the field office study, the field offices distributed a form to each visitor asking whether the visitor would or would not be willing to participate in the survey. A similar method was used in the teleservice center study. The OPIR staff selected their sample from the individuals who agreed to participate. We concluded that this method of selection is not based on probability sampling because each item in the population does not have a known and specified (nonzero) probability of being selected. We contacted officials from OMB and confirmed that this method, referred to as a "self-selected" sampling method, would not meet OMB’s statistical sampling requirements. Most experts believe that results of customer surveys cannot be interpreted with confidence unless probability sampling is used.

Both of the studies resulted in response rates lower than OMB minimal requirements. The FO Referral study had a reported response rate of 28 percent, which is well below the 50 percent termination threshold. OPIR issued this report to the Agency and provided estimates on a national basis with a qualifying statement in the report methodology section stating that "Because only 28 percent of the sampled field office (FO) visitors either agreed to participate in this survey or were able to be contacted at a later date, we cannot be certain that the data in this report, that is based on 992 respondents, is representative of all FO-referred individuals." The FO Referral study reported an 81 percent referral accuracy rate to the Commissioner of Social Security. OPIR also reported that due to the small sample size (45 cases out of 992 respondents) of cases requiring a referral, it was unable to isolate any specific corrective actions.

The TSC Referral report was written in draft, but not issued outside of OPIR due to its poor response rate and internal disagreement over the validity of the statistical methods used during the study. We reviewed the draft report and calculated a 34 percent response rate, also well below OMB’s minimum requirements.

Response rates below 50 percent do not produce valid results and ultimately waste valuable resources because the conclusions drawn from the information are not useful to the Agency. In line with OMB requirements, both of these studies should have been terminated earlier in the study process. We were unable to determine the amount of resources used to conduct these two studies, because this information was not maintained by OPIR. From the study reports, we estimate that at least 1,200 individuals were interviewed by OPIR staff during the course of these two studies.

We found that OPIR management has not implemented adequate statistical policies for addressing sampling design, selection, estimation, and reporting procedures. To assure that proper statistical methods are used, management needs to implement stringent policies and procedures, thereby ensuring the quality of OPIR studies.

Some time after these two studies were completed, we found that OPIR management was made aware of the improper statistical methods being used. As a result, on August 9, 1995, OPIR management issued a memorandum on reengineering OPIR’s statistical practices. In the memorandum, management states that OPIR’s current and future studies must be based on a probability sample and must have a high response rate. It also states that "OPIR must strive to achieve OMB’s minimal requirement or response rates." This memorandum was drafted in consultation with OMB officials. Despite management’s recognition of the statistical deficiencies, OPIR management has not developed specific procedures or supervisory controls, or followed up to ensure that OPIR’s studies use appropriate statistical methods.

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CONCLUSION AND RECOMMENDATIONS

Due to the lack of management controls, we were unable to ascertain either the cost-effectiveness or efficiency of OPIR’s special studies and their usefulness to the Agency. We found that OPIR’s management controls are not sufficient for management to adequately assess its performance and be accountable for its special study operations. We also found that standards for conducting studies and for performing statistical sampling have not been established. Management needs to make a commitment to implementing appropriate management controls and procedures to ensure that studies are: (1) conducted in accordance with management’s expectations; (2) cost-effective and efficient; (3) useful to the Agency; and (4) performed in accordance with standards.

To improve OPIR’s management controls to ensure that it is accountable for its special study operations, we recommend that OPIR:

1. develop and maintain a workload tracking system which includes monitoring prior and current assignments and resources expended;

2. develop and maintain a system for tracking the current status of OPIR recommendations incorporating any prior recommendations that have not been implemented; and

3. establish OPIR as a management control area in SSA’s FMFIA program.

To ensure that OPIR studies are carried out in accordance with management’s directives and to ensure that OPIR’s objectives are achieved, we recommend that OPIR:

4. develop and implement policies and procedures for conducting OPIR studies, including requirements for maintaining adequate study documentation for examination.

To assure that the statistical sampling OPIR performs when conducting studies is valid and defensible, we recommend that OPIR:

5. implement statistical policies and procedures, such as those published in the GAO’s Using Statistical Sampling publication (GAO/PEMD-10.1.6) and modify reporting formats to include detailed statistical information, such as response rates and confidence intervals, in all reports where statistical sampling is used.

AGENCY COMMENT

SSA decided not to comment on the draft report. The Agency has engaged a consultant to review a number of issues related to OPIR’s operations. The Agency believes that it would be beneficial for the consultant to consider our findings and recommendations before providing specific comments. The full text of SSA’s response is included in Appendix B.

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APPENDIX A

SPECIAL STUDIES SELECTED FOR REVIEW

1. Supplemental Security Income One-Time Payment Study

2. Probe of Insured Status and Critical Birthday Diaries

3. Evaluation of Primary Insurance Amounts

4. Study to Determine Reason for Increase in Supplemental Security Income Overpayment Detection

5. Evaluation of Regional Efforts to Improve Supplemental Security Income

6. Study of Terminated Age 18 Title II Beneficiaries Potentially Entitled to Supplemental Security Income.

7. Review of Representative Payees Who Receive Compensation for Services

8. Payment Service Center/Teleservice Center Analysis Assistance

9. Evaluation of Field Office Referrals

10. Evaluation of Teleservice Center Referrals

APPENDIX D

MAJOR CONTRIBUTORS TO THIS REPORT

Office of the Inspector General

Gary Kramer, Director, Program Audits
Carl Markowitz, Team Leader
Stephanie Palmer, Team Member/Auditor-In-Charge
Mary Ann Braycich, Team Member
George Richardson, Team Member
Tom Tennant, Team Member

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