The Social Security Administration's Challenges and Successes in

MEMORANDUM

Date:

September 23, 2022

Refer To:

A-01-21-51029

To:

Kilolo Kijakazi

Acting Commissioner

From:

Gail S. Ennis,

Inspector General

Subject:

The Social Security Administration’s Challenges and Successes in Obtaining Data to Determine

Eligibility and Payment Amounts

CONTAINS REDACTED INFORMATION

The attached final report presents the results of the Office of Audit’s review. The objective was

to review the Social Security Administration’s efforts to implement new incoming data

exchanges to reduce its reliance on beneficiaries’ self-reporting information that could affect

their eligibility and payment amounts.

Please provide within 60 days a corrective action plan that addresses each recommendation. If

you wish to discuss the final report, please contact Michelle L. Anderson,

Assistant Inspector General for Audit.

Attachment

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The Social Security Administration’s Challenges and

Successes in Obtaining Data to Determine Eligibility and

Payment Amounts

A-01-21-51

029

September 2022 Office of Audit Report Summary

Objective

To review the Social Security

Administration’s (SSA) efforts to

implement new incoming data

exchanges to reduce its reliance on

beneficiaries’ self-reporting information

that could affect their eligibility and

and living arrangements, to determine

eligibility and payment amounts. As

beneficiaries do not always fully

comply with the requirement to report

to SSA any change in circumstances,

obtaining data from external sources,

agencies and financial institutions, is

critical to preventing and detecting

data-exchange agreements. Its Office

of Data Exchange and International

Agreements provides coordination,

oversight, strategic decision-making,

policy, and procedures on

We reviewed SSA’s policies,

procedures, and processes for

entering into incoming data

exchanges. We also reviewed

information the Agency provided

concerning data exchanges it

attempted to enter into from 2019

through August 2021, including

approved, pending, abandoned, and

denied requests.

payment amounts.

Results

While SSA has made progress implementing data exchanges to

reduce its reliance on beneficiaries self-reporting information, it still

has work to do. SSA encountered various challenges when

entering into data exchanges, such as:

 legal authority to obtain data or require that others provide data

to SSA,

 not having a centralized system for administering data

exchanges,

 the need for an SSA component sponsor,

 budget limitations, and

 technical issues.

The Agency successfully:

 developed policies and procedures for entering into data

exchanges, and the Agency regularly reviews and updates the

policies and procedures to improve the process and

 participated in activities to learn about best practices in

obtaining data from other agencies.

Recommendations

We recommend SSA:

Implement a centralized, interactive, and user-friendly system

for administering data exchanges.

Submit legislative proposals in Fiscal Year 2024 for data the

Agency does not have the authority to obtain.

SSA agreed with Recommendation 1 but disagreed with

Recommendation 2. SSA disagreed because, in most cases, the

decision to pursue data-exchange-related legislation is driven by

factors other than a need for legal authority. However, SSA should

continue seeking legislative changes to obtain data it cannot obtain

through other means. For example, the Agency should seek

legislative changes to obtain information it requested from the

Federal Bureau of Investigation.

such factors as income, resources,

SSA must obtain beneficiaries’ data on

Background

such as other Federal and State

improper payments.

SSA has more than 3,000

data-exchange activities.

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TABLE OF CONTENTS

Objective.....................................................................................................................................1

Background.................................................................................................................................1

Methodology .........................................................................................................................4

Results of Review .......................................................................................................................4

Challenges Entering into Data Exchanges ............................................................................4

Legal Authority ................................................................................................................4

No Centralized System for Administering Data Exchanges..............................................6

Need for Sponsor and Budget Limitations .......................................................................7

Other Challenges ............................................................................................................7

Best Practices for Entering into Data Exchanges ..................................................................8

Successful Data Exchanges..................................................................................................9

Conclusions ..............................................................................................................................10

Recommendations ....................................................................................................................11

Agency Response.....................................................................................................................11

OIG Response ..........................................................................................................................11

–Self-reported Information ..................................................................................A-1

–Scope and Methodology ...................................................................................B-1

–Data Exchanges ...............................................................................................C-1

– Agency Comments...........................................................................................D-1

SSA’s Challenges and Successes in Obtaining Data (A-01-21-51029)

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ABBREVIATIONS

ABLE Achieving a Better Life Experience Act

C.F.

R. C

ode of Federal Regulations

IRS Internal Revenue Service

OASDI Old-Age, Survivors and Disability Insurance

ODEPPIN Office of Data Exchange, Policy Publications, and International Negotiations

ODXIA Office of Data Exchange and International Agreements

OIG Office of the Inspector General

POMS Program Operations Manual System

Pub. L. No. Public Law Number

SSA Social Security Administration

SSI Supplemental Security Income

U.S.C. United States Code

SSA’s Challenges and Successes in Obtaining Data (A-01-21-51029)

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OBJECTIVE

Our objective was to review the Social Security Administration’s (SSA) efforts to implement new

incoming data exchanges to reduce its reliance on beneficiaries’

self-reporting information that

could affect their eligibility and payment amounts.

BACKGROUND

The Old-Age, Survivors and Disability Insurance (OASDI) program provides monthly benefits to

retired and disabled workers and their dependents as well as the survivors of deceased

workers.

The Supplemental Security Income (SSI) program provides a minimum level of

income security to financially needy individuals who are aged, blind, or disabled.

SSA must

obtain data on a number of factors to determine eligibility and payment amounts, such as

income, resources, and living arrangements.

SSA obtains these data from beneficiaries and

third parties. The Agency must collect information to the greatest extent practicable directly

from the individual when the information may result in a reduction of benefits.

Further, the

Agency must independently verify the information obtained through data exchanges unless they

are for benefits paid by a Federal benefit program and there is a high degree of confidence the

information provided are accurate.

While beneficiaries are required to report to SSA any change in circumstances that may affect

their benefits; they do not always fully comply with this requirement. Obtaining data from

external sources, such as other Federal and state agencies and financial institutions, is critical

to preventing and detecting improper payments.

A significant management challenge the Agency faces is to improve the prevention, detection,

and recovery of improper payments. Preventing improper payments is more advantageous than

recovering them since the Agency must expend additional resources to recover overpayments

or process additional payments to rectify underpayments. The Agency needs to use available

data to better identify changes that affect beneficiaries’ benefit payments and expand efforts to

collect data from reliable third-party sources that would aid SSA in mitigating discrepancies that

can occur when they rely on beneficiaries to self-report information.

We use the term “beneficiary” generically for both OASDI beneficiaries and SSI recipients.

Social Security Act, 42 U.S.C. §§ 402(a-h) and 423(a) (1-2).

Social Security Act, 42 U.S.C. § 1381(a).

See Appendix A for a list of factors that OASDI and SSI beneficiaries must report to SSA.

5 U.S.C. § 552a(e)(2).

5 U.S.C. § 552a(p).

SSA’s Challenges and Successes in Obtaining Data (A-01-21-51029) 1

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Methodology

We reviewed SSA’s policies, procedures, and processes for entering into incoming data

exchanges. Additionally, we reviewed information the Agency provided concerning data

exchanges it attempted to enter into from 2019 through August 2021, including approved,

pending, abandoned, and denied requests. We also interviewed SSA subject-matter experts.

See Appendix B for more information.

RESULTS OF REVIEW

While SSA has made progress implementing data exchanges to reduce its reliance on

beneficiaries self-reporting information, it still has work to do. While some of the challenges the

Agency encounters when entering into data exchanges are beyond its control, the Agency could

improve its process by implementing a centralized system for administering data exchanges and

consider pursuing legislative changes to obtain the data it needs.

Challenges Entering into Data Exchanges

SSA encounters various challenges when it enters into data exchanges. These challenges

include determining and/or obtaining legal authority, not having a centralized system for

administering data exchanges, the need for an SSA sponsor, and budget limitations.

Legal Authority

SSA’s Office of the General Counsel determines whether SSA has legal authority to obtain data.

In some instances, the agency from which SSA requests data will determine there is no legal

authority for that agency to provide the data. If there is not, SSA may seek to change the law.

SSA’s Office of Legislation and Congressional Affairs coordinates the development of legislative

proposals designed to improve Agency programs.

The first step in the legislative process introducing a bill to Congress. It is then considered in a

subcommittee, where it may be accepted, amended, or rejected. If the members of the

subcommittee agree to move a bill forward, it is reported to the full committee, where it may be

accepted, amended, or rejected. The committees and subcommittees may call hearings to

investigate the bill. If the full committee approves the bill, it is reported to the House or Senate,

and the majority party leadership decides when to place the bill on the calendar for

consideration. To pass legislation and send it to the President for signature, both the House

and Senate must pass the same bill with a majority vote. There is no guarantee a proposed bill

will be passed.

SSA’s Challenges and Successes in Obtaining Data (A-01-21-51029) 4

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SSA components maintained 20 different databases and paper repositories of data exchanges

making it difficult for the Agency to obtain complete information for the Agency’s data exchange

activities such as volumes, counts, lists of partners, and copies of agreements.

The Agency determined it needed to develop a better workflow, management information tool,

and repository for its data exchanges and proposed the Integrated Data Exchange Application.

SSA expected this Application to standardize the data-exchange business process, streamline

the data-exchange documentation, and automate data-exchange management information.

We recommended the Agency (1) continue developing and implementing a comprehensive

data-exchange inventory, workload process, and management information system with

available resources and (2) establish milestones that help ensure the system’s implementation

by 2017. The Agency did not move forward with the project because it was not funded.

In 2019, the Agency began working on a Data Exchange Product, which would provide a

centralized, interactive, and user-friendly experience for administering data exchanges. This

Product was also meant to contain an inventory of all data exchanges. SSA’s Office of

Retirement and Disability Policy initially received multiple year funding for this project, but the

funding was then moved for other priorities; and, as of February 2022, SSA did not have funding

for this initiative. Without an inventory of all data exchanges, SSA does not have overall

information on data exchange activities.

Need for Sponsor and Budget Limitations

Each incoming data exchange request must have an SSA component sponsor it. Without a

sponsor, the Agency will not pursue a data exchange. The sponsor (a) provides the budget

needed for the data exchange, (b) determines the use of the data and justification,

completed. SSA component sponsors must also request and obtain SSA information

technology resources to support the incoming data exchange, which is done through SSA’s

Information Technology Investment Process. ODXIA acts as the liaison between the

sponsoring component and the agency providing the data.

Congress decides funding for SSA’s administrative budget, which provides resources to the

Agency’s programs. It includes funding for information technology costs. Each year, SSA must

submit budget requests to Congress that justify its funding needs for the following year. Once

SSA receives its budget for the year, it allocates certain amounts to its components (for

example, ODXIA, Office of Operations, Office of Systems). The SSA component that sponsors

the data exchange needs to obtain approval to use its budgeted funds for the data exchange,

which are not always approved.

Other Challenges

SSA encounters other challenges that are out of its control when it tries to enter into data

exchanges. For example, the Agency encountered technical issues when it tested state foster

care data exchanges. This included States sending files that included missing or duplicate data

or data that were not properly updated. Staff noted these issues sometimes occurred even after

testing was completed and a state was regularly exchanging data.

In another example, the Agency noted that entering into a state foster care data exchange

agreement does not guarantee a project start date. State foster care production timelines

SSA’s Challenges and Successes in Obtaining Data (A-01-21-51029) 7

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depend on their capabilities. Some States are not ready to develop or test because of such

internal challenges as lack of funding, shortage of staff or technical resources, data collection

issues, state privacy laws, other priority projects, and delays caused by COVID-19.

Best Practices for Entering into Data Exchanges

SSA has policies and procedures for entering into data exchanges and regularly reviews and

updates them to improve the process. For example, SSA followed its policies and procedures

to have relevant stakeholders evaluate the data exchanges we reviewed.

In another example, the Agency developed a standard set of Guiding Principles (as shown in

Figure 2) SSA applies to all data-exchange requests to standardize decision making and

analysis. SSA adhered to the Guiding Principles when it entered into data exchanges. For

instance, when entering into the state foster care data exchange, SSA:

 Analyzed, developed, and finalized a model information exchange agreement to legally

support the data exchange.

 Determined state foster care agencies are not legally mandated to participate in the data

exchange.

 Considered SSA resources, even though the Agency was legally required to implement the

data exchange.

 Conducted a standard technical feasibility analysis and determined SSA could develop a

data exchange that would process data files sent from willing state foster care agencies.

 Determined the data exchange would help ensure representative payees are managing

benefit payments in the best interest of the beneficiaries or recipients they are serving in the

state foster care agencies.

 Determined the files would be transferred through secure existing software connections.

SSA also participated in activities to learn about best practices in obtaining data from other

benefit-paying agencies. In 2013, SSA established a Data Exchange Community of Practice,

which has over 50 members from various Federal agencies,

to strengthen the Agency’s

relationships, find collective solutions, and create data opportunities. During the bi-monthly

meetings, the Community gathers best practices for data sharing among the partners to

increase administrative efficiencies and reduce improper payments.

The Agency also participated in the State Data Exchange Community of Excellence. This open

forum allowed all interested stakeholders to share their unique insights on electronic data needs

with SSA and collaborate directly with SSA and other Federal officials. This group gave

stakeholders the opportunity to share information and learn best practices. This inclusive and

collaborative approach helped the forum develop responsive, effective, and efficient electronic

data exchanges to streamline State health and human service business processes and

A representative payee is an individual or organization that receives and manages a beneficiary’s payments when

SSA determines the beneficiary is incapable of managing or directing the management of his/her own benefits, or

when direct payment is prohibited.

SSA’s Challenges and Successes in Obtaining Data (A-01-21-51029) 8

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minimize public burden. These meetings ended after the Affordable Care Act

was

implemented. SSA tried to revitalize the group, but there was no sustained interest.

Successful Data Exchanges

The Agency has successfully entered into data exchanges with Federal and state partners. See

Appendix C for the data exchanges the Agency reported it attempted to enter into from 2019

through August 2021.

SSA entered into two data exchanges with states to comply with

applicable laws.

1. The Stephen Beck, Jr., Achieving a Better Life Experience Act of 2014 (ABLE)

aims to

ease financial strains faced by individuals with disabilities by making tax-free saving

accounts available to cover qualified disability expenses. While following its policies and

procedures, including the Guiding Principles, SSA created an information exchange

agreement to allow States to disclose account statements on distributions and account

balances of all ABLE accounts to the Agency. As of June 2022, SSA had secured

agreements and was receiving data from 47 states.

2. Section 103(a) of the Strengthening Protections for Social Security Beneficiaries Act of

2018

requires that SSA enter into a data exchange with State foster care agencies to

obtain monthly information about “represented minor beneficiaries”

that have entered,

exited, or changed placement in foster care. While following its policies and procedures,

including the Guiding Principles, SSA created an inter-agency agreement to obtain foster

care data. As of June 2022, SSA had obtained signed data exchange agreements with

36 states and was receiving data from 20 of these states.

Additionally, in August 2020, the Agency entered into a data exchange with the Department of

Health and Human Services to obtain the List of Excluded Individuals and Entities. This data

exchange allows greater accuracy in identifying excluded medical sources to ensure compliance

Patient Protection and Affordable Care Act, Pub. L. No. 111-148, 124 Stat. 119 (2010), as amended by the Health

Care and Education Reconciliation Act, Pub. L. No.111-152, 124 Stat. 1029 (2010), collectively referred to as the

Affordable Care Act.

We could not verify this was a complete list because the Agency does not have a comprehensive system to track

data exchanges.

Pub. L. No. 113-295, § 128 Stat. 4056, p. 4056 (2014).

Less than 1 percent of the approximately 3 million SSI recipients eligible to open an ABLE account had one listed

as a resource in SSA’s records. Also, the Agency did not always verify recipients’ monthly ABLE account balances,

as required. SSA, OIG, Achieving a Better Life Experience Accounts, A-02-18-50357 (March 2021).

Strengthening Protections for Social Security Beneficiaries Act of 2018, Pub. L. No. 115-165, 132 Stat. 1261

(2018).

A represented minor beneficiary is a child entitled to Social Security funds and whose benefits are certified for

payment to a representative payee.

SSA’s Challenges and Successes in Obtaining Data (A-01-21-51029) 9

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with the Bipartisan Budget Act.

SSA followed its policies and procedures, including the

Guiding Principles. The Agency began receiving data in September 2020.

As a result of a recommendation in our February 2013 report,

SSA entered into a data

exchange agreement with the Department of Homeland Security to access data from its Arrival

and Departure Information system. We estimated 35,068 SSI recipients had approximately

$152 million in overpayments because of unreported absences from the United States. SSA

began accessing the data in June 2019. However, SSA only obtains this information when it

does a redetermination

for non-U.S. citizens if they answer no to being outside the United

States for longer than 30 days. A 2021 SSA Office of Quality Review report recommended that

SSA use these data for all SSI recipients (including U.S. citizens) when it performs

redeterminations,

which is the same recommendation we made in 2013.

CONCLUSIONS

Data exchanges help SSA detect or prevent improper payments and reduce the Agency’s

reliance on self-reporting. The Agency should continue seeking new data exchanges to better

identify changes that affect beneficiaries’ benefit payments and expand efforts to collect data

from reliable third-party sources that would aid SSA in mitigating discrepancies that can occur

when beneficiaries self-report information.

As we recommended in 2015, the Agency should continue developing and implementing a

comprehensive data exchange inventory, workload process, and management information

system with available resources.

Additionally, while changing a law can be a long process with no guarantee that a proposed bill

will become a law, in situations where the Agency does not have legal authority to obtain data, it

should consider pursuing legislative changes.

Bipartisan Budget Act of 2015, Pub. L. No. 114-74 (2015).

Disability determination services’ employees query the List of Excluded Individuals and Entities in the Systems for

Award Management to determine whether consultative examiners are properly licensed and credentialed. SSA,

POMS, DI 39569.300 (October 20, 2015).

SSA, OIG, Usefulness of Department of Homeland Security Travel Data to Identify Supplemental Security Income

Recipients Who Are Outside the United States, A-01-11-01142 (February 2013).

A redetermination is a review of an SSI recipient’s non-medical eligibility factors, that is, income, resources, and

living arrangements) to determine whether the beneficiary is still eligible for and receiving the correct SSI payment.

SSA, POMS, SI 02305.001 (September 5, 2019).

SSA, Office of Analytics, Review, and Oversight, Review of Title XVI Foreign Travel Data for U.S. Citizens

(August 2021).

SSA’s Challenges and Successes in Obtaining Data (A-01-21-51029) 10

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RECOMMENDATIONS

We recommend SSA:

Implement a centralized, interactive, and user-friendly system for administering data

exchanges.

Submit legislative proposals in Fiscal Year 2024 for data the Agency does not have the

authority to obtain.

AGENCY RESPONSE

SSA agreed with Recommendation 1 but disagreed with Recommendation 2. SSA disagreed

because, in most cases, the decision to pursue data-exchange-related legislation is driven by

factors other than a need for legal authority. These factors include, but are not limited to, data

quality, technological and logistical challenges, anticipated program savings, and estimated

costs to establish a data exchange. If the feasibility of a given data exchange is questionable

because of other factors, there is little benefit to pursuing new legal authority. See Appendix D.

OIG RESPONSE

As described in the report, we recognize the decision to pursue data-exchange-related

legislation may be driven by other factors besides a need for legal authority. However, SSA

should continue to seek legislative changes to obtain data that it cannot obtain through other

means.

While beneficiaries are required to report to SSA any change in circumstances that may affect

their benefits; they do not always fully comply with this requirement. Obtaining data from

external sources, such as other Federal and state agencies and financial institutions, is critical

to preventing and detecting improper payments. Furthermore, preventing improper payments is

more advantageous than recovering them since SSA must expend additional resources to

recover overpayments or process additional payments to rectify underpayments. Therefore, if

SSA determines the data exchange meets all of its guiding principles (as described in Figure 2)

except for legal issues, the Agency should pursue legislative changes to obtain the data it

cannot obtain through other channels to mitigate discrepancies that can occur when SSA relies

on beneficiaries to self-report information.

Additionally, as described on page 5, the Agency should seek a legislative change to obtain

information it requested from the Federal Bureau of Investigation so it can conduct background

checks to prohibit persons convicted of certain crimes from serving as representative payees for

SSA beneficiaries. When beneficiaries are not capable of managing or directing the

management of their benefits, it is important that SSA appoint a representative payee who will

ensure the funds are being used to meet the beneficiaries’ needs, such as food, clothing,

shelter, and medical care.

Michelle L. Anderson

Assistant Inspector General for Audit

SSA’s Challenges and Successes in Obtaining Data (A-01-21-51029) 11

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APPENDICES

SSA’s Challenges and Successes in Obtaining Data (A-01-21-51029)

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–SELF-REPORTED INFORMATION

The following factors must be reported to the Social Security Administration and may impact

eligibility or payment amounts.

Retirement and Survivor beneficiaries must report if the beneficiary:

has an estimated earnings change

 moves,

 changes direct deposit accounts,

 is not able to manage his/her funds,

 receives a pension from non-covered work,

 becomes married or divorced,

 changes his/her name,

 receives benefits because he/she is caring for a child,

 adopts a child who is receiving benefits,

 becomes a parent after he/she begins to receive benefits,

 has an outstanding felony or arrest warrant,

 is convicted of a criminal offense,

 committed a crime and is confined to an institution,

 leaves the United States,

 has a citizen status change, or

 is receiving Social Security and Railroad Retirement Benefits.

SSA, What You Need to Know When You Get Retirement or Survivors Benefits, Publication No. 05-10077, p. 4-11

(January 2021).

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In addition to the above items, disability beneficiaries must also report if the beneficiary:

 works while receiving disability payments,

 receives other disability benefits, or

 is offered services under the Ticket to Work program.

Supplemental Security Income recipients must report if the recipient:

 moves or changes his/her address,

 changes his/her direct deposit account,

 has someone moving into or out of the recipient’s household,

 starts or stops working,

 has a change in income or the income of certain family members,

 has a change in resources,

 receives help with living expenses,

 enters or leaves an institution (hospital, nursing home),

 becomes married, separated, or divorced,

 becomes a parent,

 leaves the United States,

 has an outstanding felony or arrest,

 is confined to a correctional facility,

 changes his/her name,

 is age 18 to 22 and starts or stops attending school, or

 has a change in immigration status

SSA, What You Need to Know When You Get Social Security Disability Benefits, Publication No. 05-10153, pp. 8

through 15 (April 2021).

Under the Ticket to Work program, SSA will issue tickets to eligible beneficiaries. Beneficiaries may use their

tickets to obtain employment, vocational rehabilitation, and other support services that will assist them in obtaining,

regaining, and maintaining self-supporting employment. SSA, POMS, DI 55002.001 (October 29, 2002).

SSA, What You Need to Know When You Get Supplemental Security Income, Publication No. 05-11011, p. 6

(August 2019).

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–SCOPE AND METHODOLOGY

To conduct our review, we:

 Researched and reviewed Social Security Administration’s (SSA) policies and procedures.

 Developed a flow chart of the Agency’s process for entering into new data exchanges and

obtained the Agency’s buy in.

 Reviewed information the Agency provided concerning data exchanges it attempted to enter

into from 2019 through August 2021 (this included approved, pending, abandoned, and

denied requests for data exchanges).

 Reviewed information the Agency provided concerning the State Data Exchange

Community of Excellence and Federal Data Exchange Community of Practice.

 Attended a Federal Data Exchange Community of Practice meeting.

 Interviewed SSA subject-matter experts to obtain information regarding challenges involved

in entering into new data exchanges and the Data Exchange Product.

 Obtained information from SSA to determine how it implemented certain prior Office of the

Inspector General recommendations related to data exchanges.

We assessed the significance of internal controls necessary to satisfy the audit objective. This

included an assessment of the five internal control components, including control environment,

risk assessment, control activities, information and communication, and monitoring. In addition,

we reviewed the principles of internal controls associated with the audit objective. We identified

the following component and principle as significant to the audit objective.

 Component 3: Control Activities

 Principle 10: Design Control Activities

 Principle 12: Implement Control Activities

We conducted our review between August 2021 and June 2022 in Boston, Massachusetts. We

conducted this performance audit in accordance with generally accepted government auditing

standards. Those standards require that we plan and perform the audit to obtain sufficient,

appropriate evidence to provide a reasonable basis for findings and conclusions based on our

audit objectives. We believe that the evidence obtained provides a reasonable basis for our

findings and conclusions based on our audit objectives.

SSA’s Challenges and Successes in Obtaining Data (A-01-21-51029) B-1

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– AGENCY COMMENTS

SOCIAL SECURITY

MEMORANDUM

Date:

September 2, 2022 Refer To: TQA-1

To:

Gail S. Ennis

Inspector General

From:

Scott Frey

Chief of Staff

Subject:

Office of the Inspector General Draft Report “The Social Security Administration’s Challenges

and Successes in Obtaining Data to Determine Eligibility and Payment Amounts” (A-01-21-

51029) — INFORMATION

Thank you for the opportunity to review the draft report. We agree with recommendation 1;

however, we disagree with recommendation 2.

In most cases, the decision to pursue data exchange-related legislation is driven by factors other

than a need for legal authority. These factors include, but are not limited to, data quality,

technological and logistical challenges, anticipated program savings, and estimated costs to

establish a data exchange. If the feasibility of a given data exchange is questionable due to other

factors, there is little benefit to pursuing new legal authority.

Please let me know if I can be of further assistance. You may direct staff inquiries to Trae

Sommer at (410) 965-9102.

SSA’s Challenges and Successes in Obtaining Data (A-01-21-51029) D-1

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