Representative Payee Criminal Bar Policy
Our objective was to assess the Social Security Administration’s (SSA) compliance with its criminal bar policy as implemented, and to determine whether individual representative payees with a criminal history were convicted of any of the felonies identified in the criminal bar policy.
In February 2014, SSA implemented a policy that bars individuals from serving as payees if they have been convicted of one of 12 felonies—such as fraud, homicide, or forgery—unless they meet certain exclusions.
On April 13, 2018, the Strengthening Protections for Social Security Beneficiaries Act of 2018 became law. It prohibits individuals convicted of certain crimes from serving as payees (including existing payees), unless they meet an exemption determined by SSA.
We identified 28,497 individuals who had a prior criminal record and were serving as representative payees as of April 2017. From this population, we sampled 180 payees for review.