I found an interesting report online which was sent to a congressman about how Social Security made errors in calculating additional military wage credits for Social Security. Congress added the following additional military wage credits for veterans who served in the following eras:
Service after September 15, 1940 and before 1957: $160 per month.
Service after 1956 and before 1978: $300 per quarter.
Service before 1977 and before 2002: $100 per month.
Service after 2001 credits eliminated. I am posting this report below but for some reason the footnotes are missing. Perhaps someone else here to post a link to this document.
October 27, 2003
The Honorable E. Clay Shaw, Jr.
Chairman, Subcommittee on Social Security
Committee on Ways and Means
House of Representatives
Washington, D.C. 20515
Dear Mr. Shaw:
I am pleased to provide you with the enclosed report addressing your August 11, 2003
letter, asking our Office to determine whether the Social Security Administration (SSA)
is properly including military wage credits when calculating benefits. This report
contains information related to:
• the number of military veterans receiving SSA benefits,
• the complexities of the legal and regulatory environment,
• potential SSA systems limitations that need to be considered in correcting
underpayments/overpayments,
• the status of any open Office of the Inspector General recommendations from
previous reviews of military earnings, and
• SSA’s planned approach to resolve any underpayments/overpayments.
If you have any questions or would like to be briefed on this issue, please call me or
have your staff contact Douglas Cunningham, Executive Assistant, at (202) 358-6319.
Sincerely,
James G. Huse, Jr.
Enclosure
cc:
Jo Anne B. Barnhart
CONGRESSIONAL RESPONSE
REPORT
TITLE II BENEFICIARIES WITH
MILITARY EARNINGS
A-03-04-24049
OCTOBER 2003
Mission
We improve SSA programs and operations and protect them against fraud, waste,
and abuse by conducting independent and objective audits, evaluations, and
investigations. We provide timely, useful, and reliable information and advice to
Administration officials, the Congress, and the public.
Authority
The Inspector General Act created independent audit and investigative units,
called the Office of Inspector General (OIG). The mission of the OIG, as spelled
out in the Act, is to:
Conduct and supervise independent and objective audits and
investigations relating to agency programs and operations.
Promote economy, effectiveness, and efficiency within the agency.
Prevent and detect fraud, waste, and abuse in agency programs and
operations.
Review and make recommendations regarding existing and proposed
legislation and regulations relating to agency programs and operations.
Keep the agency head and the Congress fully and currently informed of
problems in agency programs and operations.
To ensure objectivity, the IG Act empowers the IG with:
Independence to determine what reviews to perform.
Access to all information necessary for the reviews.
Authority to publish findings and recommendations based on the reviews.
Vision
By conducting independent and objective audits, investigations, and evaluations,
we are agents of positive change striving for continuous improvement in the
Social Security Administration's programs, operations, and management and in
our own office.
Title II Beneficiaries with Military Earnings (A-03-04-24049) 1
Background
On August 11, 2003, the Chairman of the Subcommittee on Social Security requested
the Office of the Inspector General (OIG) review the following:
1. The status of ongoing efforts in the Social Security Administration (SSA) to ensure
members of the military and their families receive proper accounting of their
military wage credits toward benefits;
2. The estimated number of members of the military and their eligible family
members who may be affected by failure to properly use military wage credits as
well as the potential impact on their benefits; and
3. The potential amount of under- and overpaid benefits related to inappropriate
application of military wage credits.
This report contains information related to our initial survey of this area. We anticipate
additional military earnings work in the future to fully address all of the above questions.
This particular report will address:
• the number of military veterans receiving SSA benefits,
• the complexities of the legal and regulatory environment,
• potential SSA systems limitations that need to be considered in correcting
underpayments/overpayments,
• the status of any open OIG recommendations from previous reviews of military
earnings, and
• SSA’s planned approach to resolve any underpayments/overpayments.
MILITARY SERVICE AND SOCIAL SECURITY
Military personnel have been covered under Social Security since 1957.1 Although
Social Security benefits are based on average lifetime earnings, members of the military
receive special credits that augment their earnings for the purpose of computing Social
Security benefits. The Congress enacted special credits because it believed that the
military earnings reported to SSA were too low, and that, without the credits, Social
Security benefits for veterans and their dependents would also be too low. Congress
has also provided special credits for veterans who served before the military was
brought under the Social Security system.
1 Servicemen’s and Veterans’ Survivor Benefits Act, Public Law No. 84-881, August 1, 1956; Amended
the Social Security Act by extending regular contributory coverage under the old-age and survivors
insurance program to members of the uniformed services on active duty after 1956.
Title II Beneficiaries with Military Earnings (A-03-04-24049) 2
The OIG has released two reports in recent years on military earnings. In September
1997, we released a report entitled Payment Accuracy Task Force: Earnings Record
Issue Team2 that made 18 recommendations to improve the earnings process, 13 of
which related directly to problems with military earnings. The report noted that military
service earnings errors accounted for the largest dollar amount, about 60 percent, of all
earnings record errors caused by field offices. In Fiscal Year 1995, military service
errors accounted for $52.6 million (30 percent) of the $166.1 million in projected
earnings errors related to the Title II retirement program. These type of errors could
impact SSA’s dollar accuracy of Title II payments—one of the Agency’s performance
indicators.3
The 1997 report highlighted problems in the following areas:
• Ensuring that military wages are posted properly;
• Allowing claimants to verify military service dates;
• Obtaining evidence of military service;
• Preventing the exclusion of post-1956 military service;
• Identifying reserve and National Guard service;
• Identifying military service using SSA’s records; and
• Establishing clear military service policies for use by field offices.
In October 2002, we released a Congressional Response Report entitled Status of
Corrective Actions Taken in Response to Recommendations in Fiscal Years 1997
Through 2000 Payment Accuracy Task Force Reports.4 In this report we noted that
10 of the 13 recommendations provided in the prior report had been implemented, and
the remaining 3 were in the process of implementation, which we will discuss later in
this report.
2 Payment Accuracy Task Force: Earnings Record Issue Team Final Report, (A-13-97-52003),
September 1997. The Payment Accuracy Task Force was created through the cooperative efforts of SSA
and the OIG to improve the accuracy of payments for SSA’s Old-Age Survivors and Disability Insurance
and Supplemental Security Income programs. To guide and support this effort, an Associate
Commissioner level Steering Committee was formed.
3 SSA has a strategic objective, beginning in 2002 and through 2005, to maintain at 99.8 percent the
overpayment and underpayment accuracy based on non-medical factors of eligibility of Old Age Survivors
and Disability Insurance payment outlays.
4Status of Corrective Actions Taken in Response to Recommendations in Fiscal Years 1997 Through
2000 Payment Accuracy Task Force Reports, (A-13-01-21046), October 2002.
Title II Beneficiaries with Military Earnings (A-03-04-24049) 3
Results of Review
Military veterans represent approximately one out of every four Social Security
beneficiaries. A number of changes in legislation have attempted to provide these
veterans with equitable benefits when compared to the rest of the population. However,
these changes have also made the claims process more complex. Furthermore, SSA’s
own systems have limitations which complicate the benefit calculation process. While
the OIG has recommended improvements in Agency procedures for determining military
earnings and credits, these recommendations did not address previous errors. As a
result, SSA is attempting to locate beneficiaries who may have errors in their previous
benefit calculation and resolve these problems.
MILITARY VETERAN RECEIVING SSA BENEFITS
According to SSA’s Office of Policy, approximately 9.3 million military veterans were
receiving SSA benefits in 2000.5 These veterans represented about 25 percent of the
adult Social Security beneficiary population at that time. Furthermore, approximately
42 percent of all Social Security beneficiaries were either veterans or resided with family
members who were veterans. The SSA study also noted that between 1968 and 2000,
while the overall Social Security population almost doubled, the number of veterans
receiving Social Security more than quadrupled.
About 4.7 million of the veterans who receive Social Security benefits are World War II
veterans, most of whom were 75 years or older at the time of the SSA study. In
Figure 1 we provide information on military veterans receiving Social Security benefits
by the war in which they served. Figure 2 shows military veterans receiving Social
Security benefits by age.
5Military Veterans and Social Security, Research and Statistics Note, Note No. 2001-01, Office of
Research, Evaluation, and Statistics, SSA, February 2001.
Title II Beneficiaries with Military Earnings (A-03-04-24049) 4
Figure 1: Military Veterans Receiving
Social Security Benefits by Wartime Service
(As of March 2000)
World War II
51%
Korean War
31%
Vietnam
6%
Other
12%
0 1,000 2,000 3,000 4,000 5,000 6,000
Number of Veterans Receiving SSA Benefits
(shown in thousands)
Under 50
Age 50-61
Age 62-74
Age 75-84
Over 84
Age of Veterans
Figure 2: Military Veterans Receiving
Social Security Benefits by Age
(As of March 2000)
Title II Beneficiaries with Military Earnings (A-03-04-24049) 5
COMPLEXITIES OF LEGAL AND REGULATORY ENVIRONMENT
Title II of the Social Security Act requires that SSA maintain records of wage amounts
employers pay to individuals as well as each individual’s self-reported income.
Members of the U.S. military were not added to the Social Security program until 1957.6
Although this allowed U.S. veterans to benefit from the program, it also raised concerns
about whether their benefits were adequate since the veterans (1) lacked military
earnings credit history prior to 1957 and (2) had lower recorded wages than other
workers in the economy.7
As a result, Congress passed a number of laws to provide military veterans with
gratuitous wage credits8 and deemed wages,9 and thereby higher retirement benefits.
For example, under the new provisions the amount added to a veteran’s earnings
records would depend on when they served in the military.
• Service after September 15, 1940 and before 1957: $160 per month.
• Service after 1956 and before 1978: $300 per quarter.
• Service after 1977 and before 2002: $100 per month.
• Service after 2001: credits eliminated.
We further describe some of these provisions in Appendix C.
Whether or not to apply a credit or deemed wages as part of the benefit calculation can
be complicated by other factors as well. For example, SSA claims representatives (CR)
processing claims may need to determine whether (1) a veteran was honorably
discharged from the military,10 (2) the service lasted at least 90 days,11 (3) the earnings
were used towards any other Federal pension,12 and/or (4) the veteran was on active
duty or annual training.13 Each of these elements can impact the benefit calculations.
6 See Footnote 1.
7 The recorded wages were lower, in part, because military service basic pay was very low and did not
reflect the value of food, shelter, and other benefits.
8 Veterans are eligible for "gratuitous military wage credits" of $160 for each month of active duty if they
were on active duty in the uniformed services after September 15, 1940, and before January 1, 1957.
9 Deemed wages are noncontributory wages added to veterans wage records who served in the military
after 1957 and had covered military earnings reported.
10 Program Operations Manual System (POMS) reference RS 01701.060 “Pre-1957 Wage Credits –
Types of Discharge or Release.”
11 POMS reference RS 01701.055 “Pre-1957 Wage Credits – Length of Service Requirements.”
12 POMS reference RS 01701.080 “Bars to SSA Wage Credits.”
13 POMS reference RS 01701.140 “[Deemed Military Wage] Requirements After 1956 But Before 2002.”
Title II Beneficiaries with Military Earnings (A-03-04-24049) 6
An additional issue that must be considered is whether the military earnings were
properly posted to SSA’s earnings records. The Master Earnings File (MEF) contains
all earnings data reported by employers and self-employed individuals. However, as we
have noted, military veterans were not covered under SSA’s program until 1957, and
earnings between 1957 and 1967 do not always show sufficient detail to determine
whether the earnings relate to military service. Furthermore, sometimes military service
wages are missing from SSA’s earnings records if the name and Social Security
number combination on the reported wages does not match SSA’s records. In such
cases, the wages are posted to SSA’s Earnings Suspense File (ESF) until the earnings
can be resolved.14
In each case where military service is being developed, the military veterans or their
dependents may be required to provide evidence of military service. SSA attempts to
obtain evidence of military service from the claimant first,15 which may eliminate the
need to contact other sources. This verification may slow down the claims process if
the information is not readily available. Fortunately, SSA now has a variety of ways to
obtain the necessary military evidence. For example, SSA can query Department of
Veterans Affairs military service information via an online system.16 Furthermore, a
request for evidence can be sent to the Department of Defense.17 And, if necessary, a
local courthouse may even be able to provide the evidence. Nonetheless, this
additional work may complicate and delay the claims process.
SSA SYSTEMS LIMITATIONS
SSA has a number of systems limitations that impact the calculation of benefits for
military veterans, including (1) lack of a military identifier on earnings prior to 1968;
(2) lack of earnings detail on the Agency’s earnings system prior to 1978; and
(3) reporting problems related to military-related Employer Identification Numbers
(EIN).18
14 For more on the ESF, see our Congressional Response Report: Status of SSA’s Earnings Suspense
File (A-03-03-23038), November 2002.
15 To determine whether the earlier wages are military-related, the claimant may provide documentation
such as a Report of Transfer or Discharge (DD-214).
16 This system—the Veterans Benefits Administration Query—was first introduced in May 2002.
17 This may not be possible for some Army or Air force veterans whose records were destroyed in a fire.
The fire at the National Personnel Records Center in St. Louis, Missouri destroyed 75 to 80 percent of the
records for: Army veterans discharged before 1960 and Air Force veterans surnamed “Hubbard” through
“Z” who were discharged between September 25, 1947 and December 31, 1963.
18 The EIN is a 9-digit number assigned by the Internal Revenue Service to sole proprietors, corporations,
partnerships, estates, trusts, and other entities for tax filing and reporting purposes.
Title II Beneficiaries with Military Earnings (A-03-04-24049) 7
Identifying Military Earnings Prior to 1968
Prior to 1968, military earnings were shown in SSA’s systems as regular wages rather
than military wages. As a result, military wages reported from 1957 through 1967 have
not always been properly identified and used to provide appropriate credits. Beginning
in 1968, SSA modified its systems to specifically identify military earnings to ensure
appropriate credits were automatically added to an individual’s earnings record. SSA
staff informed us that the U.S. military places an identifier on their wage reports before
sending them to SSA so that the wages can be recognized by SSA as military wages.
To resolve the issue of unidentified military wages from 1957 to 1967, SSA created the
Disability, Railroad, Alien and Military Service (DRAMS)19 file—a separate database
used to identify proven military service during this period. During the benefit claims
process, the CR requests information about military service and places beginning and
ending dates of service into DRAMS. As part of the automated benefit calculation
process, wage credits related to the periods of service shown in DRAMS, if material, are
added to the veteran’s earnings record and treated as regular covered wages for
insured status purposes. However, unlike military wages posted after 1968, military
wage credits are not automatically noted in SSA’s system when a CR performs a
manual benefit calculation. As a result, errors are more likely to occur in calculations
using this pre-1968 military wage data.
Earnings Record Details Prior To 1978
The MEF does not provide details on military earnings, or any earnings, prior to 1978.
The wages are bundled together by year earned, but details such as employer name or
EIN are not posted to each individual’s earnings history. This makes it difficult for the
CR—who may be using the earnings information to understand a worker’s earnings
history—to determine whether an individual has been credited for each year of military
service.20 If the documentation is not available, SSA may request the Office of Central
Operations (OCO) begin a process called “Feedback,”21 which is used to identify and
post the quarterly earnings detail from each employer for the requested years to SSA's
MEF.22
19 DRAMS is an SSA file that contains information from other government agencies and prior SSA claims.
DRAMS provides information, by Social Security number, about (1) alien deportation actions from the
Immigration and Naturalization Service (now the Department of Homeland Security); (2) Japanese
internment from 1941 through 1946; (3) military service from 1940 through 1967; (4) prior periods of
disability from 1957 to present (excluding FREEZE only periods after 1977); and (5) Railroad Retirement
Board Jurisdiction information.
20 In our 1997 report, we noted that SSA should modify policy to require review of pre-1978 military
wages.
21 Feedback is a process used where OCO checks its microfilm files for an earnings detail of a number
holder between 1937 and 1977.
22 If the missing earnings are not posted as the result of Feedback, SSA’s ESF can be queried. Military
wages located in the ESF can be reinstated to the earnings record.
Title II Beneficiaries with Military Earnings (A-03-04-24049) 8
Military Employer Identification Numbers
SSA personnel told us that hundreds of EINs have been used by the Federal
Government over the years when reporting military wages. However, SSA staff noted
that not all of the military-related EINs were properly identified in SSA’s systems nor
recognized by SSA staff. For example, some of the military wages have been reported
as regular wages under the EIN of a private company. In a recent case, SSA
discovered that a private employer’s EIN was incorrectly used by the Department of the
Army for active military reservists for the years 1958 through 1966—impacting as many
as 11,000 wage earners. As a result, appropriate credits may be missing from the
veterans’ earnings records.
SSA advised us that 1972 amendments to the Social Security Act,23 which extended
deemed wage credits to military service personnel from 1957 to 1967, introduced
several factors which have contributed to the issues faced by the Agency, including:
• SSA did not have a systematic way to identify military earnings already reported
and posted for years 1957 through 1967. As a result, the Agency determined
that the only way to administer the provision was to require claims
representatives to obtain proof of military service and credit military service as
part of the claims process.
• Until the 1972 legislation, there was no legal requirement to maintain a record of
military earnings for the years 1957 through 1967. As a result, the systems
limitations related to a lack of a military identifier on the earnings records prior to
1968 and the EIN reporting issues, resulted from the retroactive application of the
deemed military wage provision.
• The 1972 legislation expanded the universe of beneficiaries covered by the
deemed military wages provisions, which contributed to the overall size of the
problem.
STATUS OF OPEN RECOMMENDATIONS
As stated earlier, our September 1997 report24 stated that Fiscal Year 1995 military
service errors accounted for $52.6 million (30 percent) of the $166.1 million in projected
Title II retirement earnings errors. About $19.7 million in deficiencies, or 37 percent,
were caused by a lack of clear military service policies for use by the field offices.
Another $12.7 million in deficiencies, or 24 percent, related to the need for field office
staff to ensure that military wages were posted properly to the earnings record.
23 Public Law No. 92-603, §120(a)(2).
24 Payment Accuracy Task Force: Earnings Record Issue Team Final Report, (A-13-97-52003),
September 1997.
Title II Beneficiaries with Military Earnings (A-03-04-24049) 9
At the time of our October 2002 report,25 SSA had implemented 10 of the
13 recommendations we made related to military earnings. In September 2003, SSA
provided an update on the remaining three recommendations:26
• Automate the feedback procedure used to prove alleged military service during
1957-1967 – SSA said resource limitations have not allowed the Agency to
implement the change;
• Generate a systems alert when the claimant alleges no military service, and the
system can identify possible military service – SSA said they will be able to
implement this recommendation in April 2004; and
• Establish an intercomponent team to improve military service procedures – SSA
said it hopes to issue revised procedures in the summer of 2004.
We provide the full text of SSA’s responses to all 13 recommendations in Appendix D.
While the recommendations we made in the 1997 report should assist SSA as it
processes future benefit claims involving military earnings, past errors are not likely to
be resolved as a result of these improvements. As a result, the military service of
veterans who applied for Social Security retirement benefits in the past may need to be
revisited to ensure benefit calculations fully considered the impact of noncontributory
wage credits and/or deemed wages.
As noted earlier, about 4.7 million of the veterans who receive Social Security benefits
are World War II veterans, most of whom were 75 years or older at the time of the
March 2000 SSA study. Furthermore, according to the Center for Disease Control and
Prevention’s National Vital Statistics Reports,27 males who had reached age 75 in the
year 2000 had an average life expectancy of approximately 10 years. Hence, the
Agency has a narrow window to correct past Social Security retirement benefits for this
elderly group of veterans.
SSA advised that most World War II veterans are not adversely affected by missing
military service wage credits. The reason is that most benefit calculations for
beneficiaries in this age group consider only earnings after 1950. Therefore, military
wage credits for the World War II era are seldom used in benefit calculations. For the
most part, only those World War II veterans who had active military service after 1950
are potentially affected by missing military credits. SSA noted that this group would
include veterans who also served in the Korean Conflict or had an extended military
career, which is a fraction of the 4.7 million World War II veterans receiving benefits.
25 Congressional Response Report: Status of Corrective Actions Taken in Response to
Recommendations in Fiscal Years 1997 Through 2000 Payment Accuracy Task Force Reports,
(A-13-01-21046), October 2002.
26 These were recommendations 7, 12, and 13, respectively.
27 Deaths: Preliminary Data for 2001, National Vital Statistics Reports, Center for Disease Control and
Prevention, Department of Health and Human Services, Volume 51, Number 5, March 14, 2003.
Title II Beneficiaries with Military Earnings (A-03-04-24049) 10
SSA’s APPROACH TO RESOLVING MILITARY WAGE ERRORS
SSA’s Office of Quality Assurance and Performance Assessment (OQA) has a number
of ongoing efforts to identify missing noncontributory and contributory military wage
credits and determine their potential impact on current and future Title II beneficiaries.
OQA is attempting to locate military earnings errors by analyzing employer wage
reporting trends, reviewing areas known to be problematic in the past, and validating the
information in SSA’s records. As noted earlier, adjusting benefits for military earnings is
particularly difficult due to the complex statutory requirements as well as limitations
within SSA's systems.
In one of its reviews, OQA has profiled a 1 percent sample of individuals currently
receiving Title II payments on SSA’s Master Beneficiary Record (MBR) 28 to identify
those individuals most likely to have served in the U.S. military.29 For example, if an
individual’s MEF record showed 3 years of military service, from 1968 to 1970, and
detail on the earnings before 1968 was never added to the MEF, the record might be
selected for further review to ensure the early earnings did not also relate to military
service.
Once it identified this group with military service, OQA recalculated benefits for those
cases where it appeared relevant military wages and/or qualifying credits were not
taken into account as part of their initial benefit computation. Changes due to these
recalculations were immediately posted to the beneficiary’s account. This military
service profiling will be used to extract all potential records from SSA's MBR for further
investigation and possible benefit recalculation.
In the months to come, OQA will expand this review to more cases to properly quantify
the full impact on retired and disabled beneficiaries, as well as any auxiliary
beneficiaries on their record. Such a review will entail additional resources to (1) obtain
feedback on wages prior to 1978 and (2) recalculate benefits where wages and/or
credits were not properly included.
Additional efforts by OQA may involve reviewing the military EINs used in SSA’s MEF,
verifying SSA’s military information against other government databases, and/or
determining additional profiling techniques to find earnings errors. We asked SSA for
both an early estimate of underpayments and/or overpayments related to current and
planned projects, but were told by Agency staff that this information was not yet
available. However, based on early indications, OQA expects underpayments related to
military earnings to be considerably larger than overpayments.
28 The MBR is an electronic file containing information related to SSA beneficiaries’ retirement, survivors,
or disability benefits.
29 Some military service performed in foreign militaries might also qualify for military credits. For example,
service in the Philippines military may make an individual eligible for credits. See 20 C.F.R. §§
404.1312(d)-(e) and 404.1322(d).
Title II Beneficiaries with Military Earnings (A-03-04-24049) 11
Conclusions
Military veterans represent a large number of Social Security beneficiaries. The
complexity of the credits and deemed wages, as well as system limitations, also make
determining benefits for this group difficult at times. While past OIG recommendations
can help with future calculations, past errors will need to be resolved through OQA’s
efforts to identify beneficiaries with errors in their previous benefit calculations.
SSA should be commended for its proactive approach in this area. Regardless of the
complexities involved in implementing legislative mandates, military veterans are
entitled to full credit for the service they provided to the United States. Based on
projections in the 1997 review, military earnings errors in Fiscal Year 1995 caused
approximately $52 million in payment errors. If similar errors have occurred over the
years, the impact of these errors could have a significant impact on benefit
computations. Furthermore, since many of the veterans who may be impacted by these
recalculations are among the Agency’s older beneficiaries, SSA management will need
to ensure sufficient resources are made available to expedite OQA’s work.
We will continue to monitor the Agency’s progress in this area to ensure military service
is properly credited to past and future Title II beneficiaries.
Title II Beneficiaries with Military Earnings (A-03-04-24049)
Appendices
Appendix A – Acronyms
Appendix B – Scope and Methodology
Appendix C – Selected Legal Provisions Related to Military Earnings
Appendix D – Status of Previous Payment Accuracy Task Force
Recommendations
Title II Beneficiaries with Military Earnings (A-03-04-24049)
Appendix A
Acronyms
C.F.R. Code of Federal Regulations
CR Claims Representative
DMW Deemed Military Wages
DRAMS Disability, Railroad, Alien and Military Service
EIN Employer Identification Number
EMS Earnings Modernization System
ESF Earnings Suspense File
MBR Master Beneficiary Record
MCS Modernized Claims System
MEF Master Earnings File
OCO Office of Central Operations
OIG Office of the Inspector General
OQA Office of Quality Assurance and Performance Assessment
Question
deltaj
I found an interesting report online which was sent to a congressman about how Social Security made errors in calculating additional military wage credits for Social Security. Congress added the following additional military wage credits for veterans who served in the following eras:
Service after September 15, 1940 and before 1957: $160 per month.
Service after 1956 and before 1978: $300 per quarter.
Service before 1977 and before 2002: $100 per month.
Service after 2001 credits eliminated. I am posting this report below but for some reason the footnotes are missing. Perhaps someone else here to post a link to this document.
October 27, 2003
The Honorable E. Clay Shaw, Jr.
Chairman, Subcommittee on Social Security
Committee on Ways and Means
House of Representatives
Washington, D.C. 20515
Dear Mr. Shaw:
I am pleased to provide you with the enclosed report addressing your August 11, 2003
letter, asking our Office to determine whether the Social Security Administration (SSA)
is properly including military wage credits when calculating benefits. This report
contains information related to:
• the number of military veterans receiving SSA benefits,
• the complexities of the legal and regulatory environment,
• potential SSA systems limitations that need to be considered in correcting
underpayments/overpayments,
• the status of any open Office of the Inspector General recommendations from
previous reviews of military earnings, and
• SSA’s planned approach to resolve any underpayments/overpayments.
If you have any questions or would like to be briefed on this issue, please call me or
have your staff contact Douglas Cunningham, Executive Assistant, at (202) 358-6319.
Sincerely,
James G. Huse, Jr.
Enclosure
cc:
Jo Anne B. Barnhart
CONGRESSIONAL RESPONSE
REPORT
TITLE II BENEFICIARIES WITH
MILITARY EARNINGS
A-03-04-24049
OCTOBER 2003
Mission
We improve SSA programs and operations and protect them against fraud, waste,
and abuse by conducting independent and objective audits, evaluations, and
investigations. We provide timely, useful, and reliable information and advice to
Administration officials, the Congress, and the public.
Authority
The Inspector General Act created independent audit and investigative units,
called the Office of Inspector General (OIG). The mission of the OIG, as spelled
out in the Act, is to:
Conduct and supervise independent and objective audits and
investigations relating to agency programs and operations.
Promote economy, effectiveness, and efficiency within the agency.
Prevent and detect fraud, waste, and abuse in agency programs and
operations.
Review and make recommendations regarding existing and proposed
legislation and regulations relating to agency programs and operations.
Keep the agency head and the Congress fully and currently informed of
problems in agency programs and operations.
To ensure objectivity, the IG Act empowers the IG with:
Independence to determine what reviews to perform.
Access to all information necessary for the reviews.
Authority to publish findings and recommendations based on the reviews.
Vision
By conducting independent and objective audits, investigations, and evaluations,
we are agents of positive change striving for continuous improvement in the
Social Security Administration's programs, operations, and management and in
our own office.
Title II Beneficiaries with Military Earnings (A-03-04-24049) 1
Background
On August 11, 2003, the Chairman of the Subcommittee on Social Security requested
the Office of the Inspector General (OIG) review the following:
1. The status of ongoing efforts in the Social Security Administration (SSA) to ensure
members of the military and their families receive proper accounting of their
military wage credits toward benefits;
2. The estimated number of members of the military and their eligible family
members who may be affected by failure to properly use military wage credits as
well as the potential impact on their benefits; and
3. The potential amount of under- and overpaid benefits related to inappropriate
application of military wage credits.
This report contains information related to our initial survey of this area. We anticipate
additional military earnings work in the future to fully address all of the above questions.
This particular report will address:
• the number of military veterans receiving SSA benefits,
• the complexities of the legal and regulatory environment,
• potential SSA systems limitations that need to be considered in correcting
underpayments/overpayments,
• the status of any open OIG recommendations from previous reviews of military
earnings, and
• SSA’s planned approach to resolve any underpayments/overpayments.
MILITARY SERVICE AND SOCIAL SECURITY
Military personnel have been covered under Social Security since 1957.1 Although
Social Security benefits are based on average lifetime earnings, members of the military
receive special credits that augment their earnings for the purpose of computing Social
Security benefits. The Congress enacted special credits because it believed that the
military earnings reported to SSA were too low, and that, without the credits, Social
Security benefits for veterans and their dependents would also be too low. Congress
has also provided special credits for veterans who served before the military was
brought under the Social Security system.
1 Servicemen’s and Veterans’ Survivor Benefits Act, Public Law No. 84-881, August 1, 1956; Amended
the Social Security Act by extending regular contributory coverage under the old-age and survivors
insurance program to members of the uniformed services on active duty after 1956.
Title II Beneficiaries with Military Earnings (A-03-04-24049) 2
The OIG has released two reports in recent years on military earnings. In September
1997, we released a report entitled Payment Accuracy Task Force: Earnings Record
Issue Team2 that made 18 recommendations to improve the earnings process, 13 of
which related directly to problems with military earnings. The report noted that military
service earnings errors accounted for the largest dollar amount, about 60 percent, of all
earnings record errors caused by field offices. In Fiscal Year 1995, military service
errors accounted for $52.6 million (30 percent) of the $166.1 million in projected
earnings errors related to the Title II retirement program. These type of errors could
impact SSA’s dollar accuracy of Title II payments—one of the Agency’s performance
indicators.3
The 1997 report highlighted problems in the following areas:
• Ensuring that military wages are posted properly;
• Allowing claimants to verify military service dates;
• Obtaining evidence of military service;
• Preventing the exclusion of post-1956 military service;
• Identifying reserve and National Guard service;
• Identifying military service using SSA’s records; and
• Establishing clear military service policies for use by field offices.
In October 2002, we released a Congressional Response Report entitled Status of
Corrective Actions Taken in Response to Recommendations in Fiscal Years 1997
Through 2000 Payment Accuracy Task Force Reports.4 In this report we noted that
10 of the 13 recommendations provided in the prior report had been implemented, and
the remaining 3 were in the process of implementation, which we will discuss later in
this report.
2 Payment Accuracy Task Force: Earnings Record Issue Team Final Report, (A-13-97-52003),
September 1997. The Payment Accuracy Task Force was created through the cooperative efforts of SSA
and the OIG to improve the accuracy of payments for SSA’s Old-Age Survivors and Disability Insurance
and Supplemental Security Income programs. To guide and support this effort, an Associate
Commissioner level Steering Committee was formed.
3 SSA has a strategic objective, beginning in 2002 and through 2005, to maintain at 99.8 percent the
overpayment and underpayment accuracy based on non-medical factors of eligibility of Old Age Survivors
and Disability Insurance payment outlays.
4Status of Corrective Actions Taken in Response to Recommendations in Fiscal Years 1997 Through
2000 Payment Accuracy Task Force Reports, (A-13-01-21046), October 2002.
Title II Beneficiaries with Military Earnings (A-03-04-24049) 3
Results of Review
Military veterans represent approximately one out of every four Social Security
beneficiaries. A number of changes in legislation have attempted to provide these
veterans with equitable benefits when compared to the rest of the population. However,
these changes have also made the claims process more complex. Furthermore, SSA’s
own systems have limitations which complicate the benefit calculation process. While
the OIG has recommended improvements in Agency procedures for determining military
earnings and credits, these recommendations did not address previous errors. As a
result, SSA is attempting to locate beneficiaries who may have errors in their previous
benefit calculation and resolve these problems.
MILITARY VETERAN RECEIVING SSA BENEFITS
According to SSA’s Office of Policy, approximately 9.3 million military veterans were
receiving SSA benefits in 2000.5 These veterans represented about 25 percent of the
adult Social Security beneficiary population at that time. Furthermore, approximately
42 percent of all Social Security beneficiaries were either veterans or resided with family
members who were veterans. The SSA study also noted that between 1968 and 2000,
while the overall Social Security population almost doubled, the number of veterans
receiving Social Security more than quadrupled.
About 4.7 million of the veterans who receive Social Security benefits are World War II
veterans, most of whom were 75 years or older at the time of the SSA study. In
Figure 1 we provide information on military veterans receiving Social Security benefits
by the war in which they served. Figure 2 shows military veterans receiving Social
Security benefits by age.
5Military Veterans and Social Security, Research and Statistics Note, Note No. 2001-01, Office of
Research, Evaluation, and Statistics, SSA, February 2001.
Title II Beneficiaries with Military Earnings (A-03-04-24049) 4
Figure 1: Military Veterans Receiving
Social Security Benefits by Wartime Service
(As of March 2000)
World War II
51%
Korean War
31%
Vietnam
6%
Other
12%
0 1,000 2,000 3,000 4,000 5,000 6,000
Number of Veterans Receiving SSA Benefits
(shown in thousands)
Under 50
Age 50-61
Age 62-74
Age 75-84
Over 84
Age of Veterans
Figure 2: Military Veterans Receiving
Social Security Benefits by Age
(As of March 2000)
Title II Beneficiaries with Military Earnings (A-03-04-24049) 5
COMPLEXITIES OF LEGAL AND REGULATORY ENVIRONMENT
Title II of the Social Security Act requires that SSA maintain records of wage amounts
employers pay to individuals as well as each individual’s self-reported income.
Members of the U.S. military were not added to the Social Security program until 1957.6
Although this allowed U.S. veterans to benefit from the program, it also raised concerns
about whether their benefits were adequate since the veterans (1) lacked military
earnings credit history prior to 1957 and (2) had lower recorded wages than other
workers in the economy.7
As a result, Congress passed a number of laws to provide military veterans with
gratuitous wage credits8 and deemed wages,9 and thereby higher retirement benefits.
For example, under the new provisions the amount added to a veteran’s earnings
records would depend on when they served in the military.
• Service after September 15, 1940 and before 1957: $160 per month.
• Service after 1956 and before 1978: $300 per quarter.
• Service after 1977 and before 2002: $100 per month.
• Service after 2001: credits eliminated.
We further describe some of these provisions in Appendix C.
Whether or not to apply a credit or deemed wages as part of the benefit calculation can
be complicated by other factors as well. For example, SSA claims representatives (CR)
processing claims may need to determine whether (1) a veteran was honorably
discharged from the military,10 (2) the service lasted at least 90 days,11 (3) the earnings
were used towards any other Federal pension,12 and/or (4) the veteran was on active
duty or annual training.13 Each of these elements can impact the benefit calculations.
6 See Footnote 1.
7 The recorded wages were lower, in part, because military service basic pay was very low and did not
reflect the value of food, shelter, and other benefits.
8 Veterans are eligible for "gratuitous military wage credits" of $160 for each month of active duty if they
were on active duty in the uniformed services after September 15, 1940, and before January 1, 1957.
9 Deemed wages are noncontributory wages added to veterans wage records who served in the military
after 1957 and had covered military earnings reported.
10 Program Operations Manual System (POMS) reference RS 01701.060 “Pre-1957 Wage Credits –
Types of Discharge or Release.”
11 POMS reference RS 01701.055 “Pre-1957 Wage Credits – Length of Service Requirements.”
12 POMS reference RS 01701.080 “Bars to SSA Wage Credits.”
13 POMS reference RS 01701.140 “[Deemed Military Wage] Requirements After 1956 But Before 2002.”
Title II Beneficiaries with Military Earnings (A-03-04-24049) 6
An additional issue that must be considered is whether the military earnings were
properly posted to SSA’s earnings records. The Master Earnings File (MEF) contains
all earnings data reported by employers and self-employed individuals. However, as we
have noted, military veterans were not covered under SSA’s program until 1957, and
earnings between 1957 and 1967 do not always show sufficient detail to determine
whether the earnings relate to military service. Furthermore, sometimes military service
wages are missing from SSA’s earnings records if the name and Social Security
number combination on the reported wages does not match SSA’s records. In such
cases, the wages are posted to SSA’s Earnings Suspense File (ESF) until the earnings
can be resolved.14
In each case where military service is being developed, the military veterans or their
dependents may be required to provide evidence of military service. SSA attempts to
obtain evidence of military service from the claimant first,15 which may eliminate the
need to contact other sources. This verification may slow down the claims process if
the information is not readily available. Fortunately, SSA now has a variety of ways to
obtain the necessary military evidence. For example, SSA can query Department of
Veterans Affairs military service information via an online system.16 Furthermore, a
request for evidence can be sent to the Department of Defense.17 And, if necessary, a
local courthouse may even be able to provide the evidence. Nonetheless, this
additional work may complicate and delay the claims process.
SSA SYSTEMS LIMITATIONS
SSA has a number of systems limitations that impact the calculation of benefits for
military veterans, including (1) lack of a military identifier on earnings prior to 1968;
(2) lack of earnings detail on the Agency’s earnings system prior to 1978; and
(3) reporting problems related to military-related Employer Identification Numbers
(EIN).18
14 For more on the ESF, see our Congressional Response Report: Status of SSA’s Earnings Suspense
File (A-03-03-23038), November 2002.
15 To determine whether the earlier wages are military-related, the claimant may provide documentation
such as a Report of Transfer or Discharge (DD-214).
16 This system—the Veterans Benefits Administration Query—was first introduced in May 2002.
17 This may not be possible for some Army or Air force veterans whose records were destroyed in a fire.
The fire at the National Personnel Records Center in St. Louis, Missouri destroyed 75 to 80 percent of the
records for: Army veterans discharged before 1960 and Air Force veterans surnamed “Hubbard” through
“Z” who were discharged between September 25, 1947 and December 31, 1963.
18 The EIN is a 9-digit number assigned by the Internal Revenue Service to sole proprietors, corporations,
partnerships, estates, trusts, and other entities for tax filing and reporting purposes.
Title II Beneficiaries with Military Earnings (A-03-04-24049) 7
Identifying Military Earnings Prior to 1968
Prior to 1968, military earnings were shown in SSA’s systems as regular wages rather
than military wages. As a result, military wages reported from 1957 through 1967 have
not always been properly identified and used to provide appropriate credits. Beginning
in 1968, SSA modified its systems to specifically identify military earnings to ensure
appropriate credits were automatically added to an individual’s earnings record. SSA
staff informed us that the U.S. military places an identifier on their wage reports before
sending them to SSA so that the wages can be recognized by SSA as military wages.
To resolve the issue of unidentified military wages from 1957 to 1967, SSA created the
Disability, Railroad, Alien and Military Service (DRAMS)19 file—a separate database
used to identify proven military service during this period. During the benefit claims
process, the CR requests information about military service and places beginning and
ending dates of service into DRAMS. As part of the automated benefit calculation
process, wage credits related to the periods of service shown in DRAMS, if material, are
added to the veteran’s earnings record and treated as regular covered wages for
insured status purposes. However, unlike military wages posted after 1968, military
wage credits are not automatically noted in SSA’s system when a CR performs a
manual benefit calculation. As a result, errors are more likely to occur in calculations
using this pre-1968 military wage data.
Earnings Record Details Prior To 1978
The MEF does not provide details on military earnings, or any earnings, prior to 1978.
The wages are bundled together by year earned, but details such as employer name or
EIN are not posted to each individual’s earnings history. This makes it difficult for the
CR—who may be using the earnings information to understand a worker’s earnings
history—to determine whether an individual has been credited for each year of military
service.20 If the documentation is not available, SSA may request the Office of Central
Operations (OCO) begin a process called “Feedback,”21 which is used to identify and
post the quarterly earnings detail from each employer for the requested years to SSA's
MEF.22
19 DRAMS is an SSA file that contains information from other government agencies and prior SSA claims.
DRAMS provides information, by Social Security number, about (1) alien deportation actions from the
Immigration and Naturalization Service (now the Department of Homeland Security); (2) Japanese
internment from 1941 through 1946; (3) military service from 1940 through 1967; (4) prior periods of
disability from 1957 to present (excluding FREEZE only periods after 1977); and (5) Railroad Retirement
Board Jurisdiction information.
20 In our 1997 report, we noted that SSA should modify policy to require review of pre-1978 military
wages.
21 Feedback is a process used where OCO checks its microfilm files for an earnings detail of a number
holder between 1937 and 1977.
22 If the missing earnings are not posted as the result of Feedback, SSA’s ESF can be queried. Military
wages located in the ESF can be reinstated to the earnings record.
Title II Beneficiaries with Military Earnings (A-03-04-24049) 8
Military Employer Identification Numbers
SSA personnel told us that hundreds of EINs have been used by the Federal
Government over the years when reporting military wages. However, SSA staff noted
that not all of the military-related EINs were properly identified in SSA’s systems nor
recognized by SSA staff. For example, some of the military wages have been reported
as regular wages under the EIN of a private company. In a recent case, SSA
discovered that a private employer’s EIN was incorrectly used by the Department of the
Army for active military reservists for the years 1958 through 1966—impacting as many
as 11,000 wage earners. As a result, appropriate credits may be missing from the
veterans’ earnings records.
SSA advised us that 1972 amendments to the Social Security Act,23 which extended
deemed wage credits to military service personnel from 1957 to 1967, introduced
several factors which have contributed to the issues faced by the Agency, including:
• SSA did not have a systematic way to identify military earnings already reported
and posted for years 1957 through 1967. As a result, the Agency determined
that the only way to administer the provision was to require claims
representatives to obtain proof of military service and credit military service as
part of the claims process.
• Until the 1972 legislation, there was no legal requirement to maintain a record of
military earnings for the years 1957 through 1967. As a result, the systems
limitations related to a lack of a military identifier on the earnings records prior to
1968 and the EIN reporting issues, resulted from the retroactive application of the
deemed military wage provision.
• The 1972 legislation expanded the universe of beneficiaries covered by the
deemed military wages provisions, which contributed to the overall size of the
problem.
STATUS OF OPEN RECOMMENDATIONS
As stated earlier, our September 1997 report24 stated that Fiscal Year 1995 military
service errors accounted for $52.6 million (30 percent) of the $166.1 million in projected
Title II retirement earnings errors. About $19.7 million in deficiencies, or 37 percent,
were caused by a lack of clear military service policies for use by the field offices.
Another $12.7 million in deficiencies, or 24 percent, related to the need for field office
staff to ensure that military wages were posted properly to the earnings record.
23 Public Law No. 92-603, §120(a)(2).
24 Payment Accuracy Task Force: Earnings Record Issue Team Final Report, (A-13-97-52003),
September 1997.
Title II Beneficiaries with Military Earnings (A-03-04-24049) 9
At the time of our October 2002 report,25 SSA had implemented 10 of the
13 recommendations we made related to military earnings. In September 2003, SSA
provided an update on the remaining three recommendations:26
• Automate the feedback procedure used to prove alleged military service during
1957-1967 – SSA said resource limitations have not allowed the Agency to
implement the change;
• Generate a systems alert when the claimant alleges no military service, and the
system can identify possible military service – SSA said they will be able to
implement this recommendation in April 2004; and
• Establish an intercomponent team to improve military service procedures – SSA
said it hopes to issue revised procedures in the summer of 2004.
We provide the full text of SSA’s responses to all 13 recommendations in Appendix D.
While the recommendations we made in the 1997 report should assist SSA as it
processes future benefit claims involving military earnings, past errors are not likely to
be resolved as a result of these improvements. As a result, the military service of
veterans who applied for Social Security retirement benefits in the past may need to be
revisited to ensure benefit calculations fully considered the impact of noncontributory
wage credits and/or deemed wages.
As noted earlier, about 4.7 million of the veterans who receive Social Security benefits
are World War II veterans, most of whom were 75 years or older at the time of the
March 2000 SSA study. Furthermore, according to the Center for Disease Control and
Prevention’s National Vital Statistics Reports,27 males who had reached age 75 in the
year 2000 had an average life expectancy of approximately 10 years. Hence, the
Agency has a narrow window to correct past Social Security retirement benefits for this
elderly group of veterans.
SSA advised that most World War II veterans are not adversely affected by missing
military service wage credits. The reason is that most benefit calculations for
beneficiaries in this age group consider only earnings after 1950. Therefore, military
wage credits for the World War II era are seldom used in benefit calculations. For the
most part, only those World War II veterans who had active military service after 1950
are potentially affected by missing military credits. SSA noted that this group would
include veterans who also served in the Korean Conflict or had an extended military
career, which is a fraction of the 4.7 million World War II veterans receiving benefits.
25 Congressional Response Report: Status of Corrective Actions Taken in Response to
Recommendations in Fiscal Years 1997 Through 2000 Payment Accuracy Task Force Reports,
(A-13-01-21046), October 2002.
26 These were recommendations 7, 12, and 13, respectively.
27 Deaths: Preliminary Data for 2001, National Vital Statistics Reports, Center for Disease Control and
Prevention, Department of Health and Human Services, Volume 51, Number 5, March 14, 2003.
Title II Beneficiaries with Military Earnings (A-03-04-24049) 10
SSA’s APPROACH TO RESOLVING MILITARY WAGE ERRORS
SSA’s Office of Quality Assurance and Performance Assessment (OQA) has a number
of ongoing efforts to identify missing noncontributory and contributory military wage
credits and determine their potential impact on current and future Title II beneficiaries.
OQA is attempting to locate military earnings errors by analyzing employer wage
reporting trends, reviewing areas known to be problematic in the past, and validating the
information in SSA’s records. As noted earlier, adjusting benefits for military earnings is
particularly difficult due to the complex statutory requirements as well as limitations
within SSA's systems.
In one of its reviews, OQA has profiled a 1 percent sample of individuals currently
receiving Title II payments on SSA’s Master Beneficiary Record (MBR) 28 to identify
those individuals most likely to have served in the U.S. military.29 For example, if an
individual’s MEF record showed 3 years of military service, from 1968 to 1970, and
detail on the earnings before 1968 was never added to the MEF, the record might be
selected for further review to ensure the early earnings did not also relate to military
service.
Once it identified this group with military service, OQA recalculated benefits for those
cases where it appeared relevant military wages and/or qualifying credits were not
taken into account as part of their initial benefit computation. Changes due to these
recalculations were immediately posted to the beneficiary’s account. This military
service profiling will be used to extract all potential records from SSA's MBR for further
investigation and possible benefit recalculation.
In the months to come, OQA will expand this review to more cases to properly quantify
the full impact on retired and disabled beneficiaries, as well as any auxiliary
beneficiaries on their record. Such a review will entail additional resources to (1) obtain
feedback on wages prior to 1978 and (2) recalculate benefits where wages and/or
credits were not properly included.
Additional efforts by OQA may involve reviewing the military EINs used in SSA’s MEF,
verifying SSA’s military information against other government databases, and/or
determining additional profiling techniques to find earnings errors. We asked SSA for
both an early estimate of underpayments and/or overpayments related to current and
planned projects, but were told by Agency staff that this information was not yet
available. However, based on early indications, OQA expects underpayments related to
military earnings to be considerably larger than overpayments.
28 The MBR is an electronic file containing information related to SSA beneficiaries’ retirement, survivors,
or disability benefits.
29 Some military service performed in foreign militaries might also qualify for military credits. For example,
service in the Philippines military may make an individual eligible for credits. See 20 C.F.R. §§
404.1312(d)-(e) and 404.1322(d).
Title II Beneficiaries with Military Earnings (A-03-04-24049) 11
Conclusions
Military veterans represent a large number of Social Security beneficiaries. The
complexity of the credits and deemed wages, as well as system limitations, also make
determining benefits for this group difficult at times. While past OIG recommendations
can help with future calculations, past errors will need to be resolved through OQA’s
efforts to identify beneficiaries with errors in their previous benefit calculations.
SSA should be commended for its proactive approach in this area. Regardless of the
complexities involved in implementing legislative mandates, military veterans are
entitled to full credit for the service they provided to the United States. Based on
projections in the 1997 review, military earnings errors in Fiscal Year 1995 caused
approximately $52 million in payment errors. If similar errors have occurred over the
years, the impact of these errors could have a significant impact on benefit
computations. Furthermore, since many of the veterans who may be impacted by these
recalculations are among the Agency’s older beneficiaries, SSA management will need
to ensure sufficient resources are made available to expedite OQA’s work.
We will continue to monitor the Agency’s progress in this area to ensure military service
is properly credited to past and future Title II beneficiaries.
Title II Beneficiaries with Military Earnings (A-03-04-24049)
Appendices
Appendix A – Acronyms
Appendix B – Scope and Methodology
Appendix C – Selected Legal Provisions Related to Military Earnings
Appendix D – Status of Previous Payment Accuracy Task Force
Recommendations
Title II Beneficiaries with Military Earnings (A-03-04-24049)
Appendix A
Acronyms
C.F.R. Code of Federal Regulations
CR Claims Representative
DMW Deemed Military Wages
DRAMS Disability, Railroad, Alien and Military Service
EIN Employer Identification Number
EMS Earnings Modernization System
ESF Earnings Suspense File
MBR Master Beneficiary Record
MCS Modernized Claims System
MEF Master Earnings File
OCO Office of Central Operations
OIG Office of the Inspector General
OQA Office of Quality Assurance and Performance Assessment
POMS Program Operations Manual System
SSA Social Security Administration
U.S.C. United States Code
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