a= CENTER for

RETIREMENT
RESEARCH

at BOSTON COLLEGE

WORK OVERPAYMENTS AMONG NEW SOCIAL SECURITY
DISABILITY INSURANCE BENEFICIARIES

Denise Hoffman, Monica Farid, Serge Lukashanets, Michael T. Anderson, and John T. Jones

CRR WP 2022-6
July 2022

Center for Retirement Research at Boston College
Hovey House
140 Commonwealth Avenue
Chestnut Hill, MA 02467
Tel: 617-552-1762 Fax: 617-552-0191
https://crr.bc.edu

Denise Hoffman is a senior researcher at Mathematica. Monica Farid is a researcher at
Mathematica. Serge Lukashanets is a data analytics developer at Mathematica. Michael T.
Anderson is senior researcher at Mathematica. John T. Jones is an economist with the

U.S. Social Security Administration's Office of Research, Demonstration, and Employment
Support, Office of Retirement and Disability Policy. The research reported herein was pursuant
to a grant from the U.S. Social Security Administration (SSA) funded as part of the Retirement
and Disability Research Consortium. The findings and conclusions expressed are solely those of
the authors and do not represent the views of SSA, any agency of the federal government,
Mathematica, or Boston College. Neither the United States Government nor any agency thereof,
nor any of their employees, makes any warranty, express or implied, or assumes any legal
liability or responsibility for the accuracy, completeness, or usefulness of the contents of this
report. Reference herein to any specific commercial product, process or service by trade name,
trademark, manufacturer, or otherwise does not necessarily constitute or imply endorsement,
recommendation or favoring by the United States Government or any agency thereof. The
authors appreciate the helpful feedback of Yonatan Ben-Shalom of Mathematica on an early
draft.

© 2022, Denise Hoffman, Monica Farid, Serge Lukashanets, Michael T. Anderson, and John T.
Jones. All rights reserved. Short sections of text, not to exceed two paragraphs, may be quoted
without explicit permission provided that full credit, including © notice, is given to the source.
About the Center for Retirement Research

The Center for Retirement Research at Boston College, part of a consortium that includes
parallel centers at the National Bureau of Economic Research, the University of Michigan, and
the University of Wisconsin-Madison, was established in 1998 through a grant from the U.S.
Social Security Administration. The Center's mission is to produce first-class research and forge
a strong link between the academic community and decision-makers in the public and private
sectors around an issue of critical importance to the nation's future. To achieve this mission, the
Center conducts a wide variety of research projects, transmits new findings to a broad audience,
trains new scholars, and broadens access to valuable data sources.

Center for Retirement Research at Boston College
Hovey House
140 Commonwealth Ave
Chestnut Hill, MA 02467
Tel: 617-552-1762 Fax: 617-552-0191
https://crr.bc.edu/

Affiliated Institutions:

The Brookings Institution
Mathematica - Center for Studying Disability Policy
Syracuse University
Urban Institute
Abstract

This paper studies the experiences of the 2008 cohort of first-time Social Security
Disability Insurance beneficiaries who were at risk of overpayment because they engaged in
substantial gainful activity (SGA) after completing the trial work period and grace period (work
incentives allowing beneficiaries to test work). It uses data from the December 2020 Disabled
Beneficiaries and Dependents extract from the Social Security Administration's Master
Beneficiary Record to describe overpayment rates, amounts, and temporal characteristics of
overpayments. Drawing on the 2019 Disability Analysis File and Master Earnings File, it also
documents the sequence of program milestones overpaid beneficiaries experienced and compares
the experiences of overpaid beneficiaries with those whose benefits were concurrently suspended
or terminated for work and not overpaid. This analysis focuses on the first occurrence of
program milestones. Understanding beneficiary pathways to overpayments might help
policymakers design policies that minimize overpayments or, if they occur, help beneficiaries

maintain their connection to employment.

The paper found the following:

e Among a sample of 31,520 2008 first-time Social Security Disability Insurance awardees
at risk of a work-related overpayment, 82 percent (25,846) were overpaid in the first 10
years after award.

e Among those overpaid within 10 years of award, half of all overpayments began in the
first four years after award.

e Nearly all overpayments (89 percent) began in the first month of SGA after exhausting
trial work period and grace period months.

e Most overpaid beneficiaries (79 percent) followed a direct route to overpayment,
experiencing award, earnings, trial work period completion, and then engaging in SGA
(after the grace period). About 16 percent received employment network or vocational
rehabilitation services before their first month of post-grace period SGA.

e Overpaid beneficiaries are 7.5 percentage points less likely to experience work
termination in the first 10 years after Social Security Disability Insurance award

compared with at-risk beneficiaries who are not overpaid.
The policy implications of the findings are:

Earnings reporting reminders sent in the four years after award could help encourage
reporting and reduce the likelihood or amount of overpayment.

Engaging employment network or vocational rehabilitation providers in issuing earning
reporting reminders or directly assisting with earnings reporting to SSA could help avoid
overpayments.

Because overpaid beneficiaries experience lower rates of work termination relative to at-
risk beneficiaries who are not overpaid, supports to overpaid beneficiaries might help

them maintain employment at higher rates.
Introduction

Social Security Disability Insurance (DI) is an important safety net for people with
disabilities who meet the program eligibility rules. In 2019, almost 10 million people received
DI benefits, and the average monthly benefit was $1,258 (Social Security Administration 2020a).
For more than 80 percent of beneficiaries, DI benefits account for more than half of their income
(Bailey & Hemmeter, 2015). Yet even with DI support, about 20 percent live in poverty (Messel
& Trenkamp, 2022). Earned income could help these beneficiaries maintain their connection to
the labor force and improve their financial stability.

Work-related overpayments occur when the Social Security Administration (SSA), which
administers the DI program, issues a monthly DI benefit to which the individual is not entitled
because SSA determined that the person engaged in substantial gainful activity (SGA). SGA is
measured by earnings above a monthly threshold set annually. In 2022, the SGA level is $1,350
per month for non-blind applicants and $2,260 per month for blind applicants. The DI eligibility
criteria require a medical impairment that prevents a person from engaging in SGA. After
applying program rules that allow beneficiaries to test their ability to work, beneficiaries are
generally not entitled to a payment in months in which they have earnings above the SGA
threshold. Even so, SSA often issues a payment for months in which benefits should have been
withheld for work. This could occur if beneficiaries fail to report earnings timely to SSA or
because of SSA processing delays. Although there are other types of overpayments to DI
beneficiaries, this manuscript focuses on work-related overpayments and refers to these as
overpayments for brevity.

When DI beneficiaries engage in SGA, they run the risk of being overpaid. Among
beneficiaries who engaged in SGA after using available work incentives and were at risk of a
work-related overpayment, 71 percent were overpaid in a three-year period, with a median
overpayment amount of more than $9,000 (Hoffman et al., 2019). Beneficiaries can appeal
overpayments, but if the appeal is unsuccessful, they are required to repay the overpayment debt.
SSA-funded resources are available to help beneficiaries navigate overpayments, including the
Work Incentives Assistance Program, which provides benefits counseling, and Protection and
Advocacy for Beneficiaries of Social Security, which provides legal support, advocacy, and

information to help beneficiaries resolve employment-related issues.
Overpayments can cause financial and other challenges for overpaid DI beneficiaries and
SSA. Repaying overpayments can create economic hardship and stress for beneficiaries (O' Day
et al., 2016, Hoffman et al., 2017). Overpayments can also cause a decline in the proportion of
beneficiaries who continue to work and earn above the SGA threshold (Hoffman et al., 2020). In
addition, overpayments create fiscal and administrative challenges for SSA. Of all overpayment
debt SSA identified in 2004, nearly half was waived, cancelled, or outstanding 10 years later
(SSA, 2015). SSA considers minimizing overpayments a program integrity goal (SSA, 2020a).

Despite the adverse implications of overpayments to DI beneficiaries and SSA, little is
known about the program and service milestones leading up to overpayment. Previous literature
tracked work-related milestones and longitudinal work outcomes for the broader population of
beneficiaries without distinguishing overpaid beneficiaries from correctly paid beneficiaries.
Hennessey & Muller (1994) used survey data developed by SSA to document return to work, use
of vocational rehabilitation (VR), and use of SSA work incentives over a 10-year period among
DI awardees in 1982. More recently, several papers documented work milestones in a 5- or 10-
year period among DI awardee cohorts ranging from 1996 to 2004 (Liu & Stapleton, 2011; Ben-
Shalom & Mamun, 2015; Anand & Ben-Shalom, 2018). These papers found that, within 10
years of award, more than 4 percent of recent awardee cohorts engaged in SGA after using
available work incentives; these workers are at risk of work-related overpayments.

In this paper, we build on past research of work-related milestones to document
beneficiaries' experiences preceding and related to overpayments among those who first received
a new DI award in 2008. We document temporal aspects of overpayments, including the time
between DI award and first overpayment, duration of overpayment, and number of overpayment
spells. We also describe the attainment and timing of work-related milestones that occur before
overpayment, including employment service receipt, any earnings, completion of the trial work
period (TWP), and suspension of benefits because of work, and we compare overpaid and
correctly paid beneficiaries. Finally, we show the most prevalent set of pathways overpaid
beneficiaries experience and describe the characteristics of overpaid beneficiaries who completed

the most common paths.
Background

To qualify for DI, a person must have a medically determinable impairment that has
lasted or is expected to last for at least 12 months or result in death and be unable to engage in
SGA (SSA, 2021). Disabled worker beneficiaries, who account for 86 percent of all disabled DI
beneficiaries (SSA, 2020b), must also have a sufficient work history. Some children, widows,
and widowers of SSA beneficiaries qualify for benefits based on their own medical impairment
even if they have limited or no work experience. Although these beneficiaries qualify under
another SSA program, we follow common practice and refer to this group as DI beneficiaries.

DI award conveys both cash benefits and health insurance coverage, both after waiting
periods. There is generally a five-month wait between disability onset and the date DI payment
can begin. After a 24-month period of DI entitlement, beneficiaries are eligible for Medicare
coverage. Because the process for adjudicating DI applications can be complex and beneficiaries
may appeal their decision, at the time of award, some beneficiaries are eligible for both cash
benefits (including retroactive payments) and Medicare. For all DI beneficiaries, ongoing cash
benefit receipt depends on an inability to engage in SGA. DI eligibility continues until a
beneficiary has their benefit terminated for SGA or medical improvement, dies, or transitions to
the Social Security retirement program.

Although inability to engage in SGA is an eligibility criterion for DI, many DI
beneficiaries have work goals, and some are employed. A recent study found that 45 percent of
DI beneficiaries were work-oriented and considered employment a personal goal or a near-term
expectation (Livermore et al., 2020). Among beneficiaries awarded DI from 1996 to 2006, 28
percent returned to work, earning more than $1,000 in at least 1 of 10 years after award (Liu &
Stapleton, 2011). Among 2001 DI awardees, 4 percent engaged in SGA-after using other work
incentives-for at least one month in the 10 years after award (Anand & Ben-Shalom, 2018).

The DI program offers supports to help beneficiaries achieve work-related goals through
a program called Ticket to Work. Ticket to Work allows DI beneficiaries to receive services
from two types of organizations, and SSA pays those organizations if a beneficiary achieves
certain employment outcomes (or VR agencies may provide services under cost reimbursement).
First, DI beneficiaries can receive employment services through state VR agencies available in
every state. VR provides customized services in line with an individual's employment goals,

interests, and abilities. Services can include career counseling, work-based learning experiences,
financial support for vocational training and postsecondary education, rehabilitation technology,
transportation, and other services and supports (U.S. Department of Education, 2020). In
addition, employment networks (ENs) can help beneficiaries with work-related goals. ENs can
be an individual or organization that provides or coordinates employment-related services.

In addition, SSA work incentives allow beneficiaries to test work while in the DI
program. During the TWP, DI beneficiaries can work and earn at any level with no change to
their DI benefits. The TWP consists of 9 months (which do not need to be consecutive) in which
earnings exceed an annually adjusted monthly threshold ($940 in 2021) in a 60-month rolling
window. The extended period of eligibility comes after the TWP and lasts at least 36
consecutive months. During the first 36 months of this period, beneficiaries are ineligible for DI
benefits in any month in which they engage in SGA except for a grace period comprising the
first month of SGA and the following two months. After the grace period, SSA should suspend
benefits for months in which the beneficiary engages in SGA. We refer to SGA after the grace
period as meeting the criteria for suspension because of work. Beneficiaries are eligible for
benefits in months in which earnings are below the SGA threshold during the first 36 months of
the extended period of eligibility. Starting with the 37th month, DI benefits terminate
immediately or, if available, after the grace period if the beneficiary engages in SGA (the
termination phase). We refer to SGA after the 37th month and after the grace period as meeting
the criteria for termination because of work. A summary of employment supports for SSDI
beneficiaries is available in the SSA Red Book (SSA, 2020c).

Overpayments are possible after beneficiaries complete the TWP and grace period (when
they meet the criteria for suspension or termination because of work). During the extended
period of eligibility, work-related overpayments can occur when a beneficiary engages in SGA
and meets the conditions for which benefits should be suspended according to program rules. If
SSA does not revise the beneficiary's records to change their eligibility status and issues a benefit
payment, the beneficiary is overpaid. Similarly, overpayments can accrue from the month that
benefit eligibility terminates through the month in which SSA takes corrective administrative
action to discontinue benefit payments.

Overpayments generally occur for two reasons. First, some beneficiaries do not report

earings in a timely manner and, for those beneficiaries, SSA must wait to receive earnings
information from other sources.! In 2012, an estimated 65 percent of work-related overpayment
dollars occurred because of beneficiary reporting failures (SSA, 2018). Second, SSA might be
delayed in processing earnings information. Earnings processing involves confirming alleged
work incentives, verifying wages, gathering additional evidence as needed, and applying the
complex rules to individual cases. Overpayments may continue to accrue during both

beneficiary reporting and SSA processing delays.

Data and Methods
Here, we describe the data sources and sample selection criteria used in this analysis. We
then describe how we identified beneficiaries at risk of overpayments and those overpaid.

Finally, we describe our approach to identifying program milestones and pathways.

Data

For this analysis, we used the 2019 version of the Disability Analysis File (DAF)
Restricted Access File, which combines data from multiple SSA administrative data sources and
is SSA's largest longitudinal database of DI beneficiaries.? We identified the cohort of
beneficiaries who were first awarded DI benefits in 2008. As described below, we focus on
beneficiaries awarded benefits in 2008, meaning that beneficiaries first received DI benefits and
first engaged with the DI program in 2008. Because the data are longitudinal, we can follow the
milestones that the 2008 award cohort achieved over a 10-year period. The DAF contains
comprehensive information on beneficiary characteristics, monthly earnings, and the program
milestones we study, including TWP completion, use of EN or VR services, benefit suspension
because of work, work and medical terminations, reaching full retirement age, and death.

To identify overpayments, we use data from the December 2020 Disabled Beneficiaries
and Dependents (DBAD) file, which is a monthly extract of the Master Beneficiary Record
(MBR), the primary repository of data used to administer the DI program. When SSA learns of
beneficiary work activity, agency staff update the MBR to reflect the revised status. Each MBR

 

1 DI beneficiaries are expected to report earnings right away when they start or stop work or experience a change in
their work or earnings (SSA, 2021b). For beneficiaries who have not yet used the grace period, the three grace-
period months could allow for timely benefit adjustment and proper payment.

2 Documentation for the DAF Restricted Access File is available here:
https://www.ssa.gov/disabilityresearch/daf.html.
update supersedes previous iterations and the DBAD preserves concurrent monthly snapshots of
the MBR, elements of which may otherwise be overwritten. The DBAD's preservation of
historical records allows us to identify overpayments by comparing what the beneficiary
experienced at the time they worked with what should have happened.

We supplemented the DAF and DBAD data with information from the Master Earnings
File (MEF). The MEF contains annual earnings data derived from IRS Form W-2 and tax
submissions for self-employed workers. The DAF also includes monthly earnings information
derived from SSA's Disability Control File. The Disability Control File, however, only includes
earnings identified through formal SSA work reviews (known as work continuing disability

reviews) and is not as comprehensive a source of earnings data as the MEF.

Analysis Sample

We began by identifying the cohort of beneficiaries first awarded DI benefits in 2008
(also referred to as 2008 DI awardees). Our analysis centered on the DI award date, the date
SSA first sent a payment to the beneficiary, following previous literature tracking work-related
milestones (Liu & Stapleton, 2011; Ben-Shalom & Mamun, 2015; Anand & Ben-Shalom, 2018).
We focused on the award date (the date a beneficiary is notified that their application was
approved and receive their first payment) rather than the entitlement date (the date a beneficiary
first met the eligibility criteria for DI, which might occur before award) because beneficiaries
have not engaged with the program until they are notified of award and received their first
payment.

We imposed additional selection criteria to the sample of 830,271 beneficiaries awarded
DI benefits in 2008 (Table 1). We dropped beneficiaries who were enrolled in a benefit offset
demonstration that changes the benefit payment formula (namely the Benefit Offset National
Demonstration, or BOND) during the analysis period (n = 780); did not merge to the December
2020 DBAD file or for whom the DBAD did not record information for the full analysis period
from the DBAD (n = 909);? or were missing key analysis variables (n = 768).4 We retained

 

3 We dropped records that merged to the DBAD but for which the most recent updates (captured by "effective date")
occurred after the start of our analysis period in 2008. This would occur if SSA processed 35 or more actions after
award, overriding information about award and any other actions that occurred before the most recent 35 actions.

4 We dropped beneficiaries who had benefits suspended or terminated for work (concurrently or retroactively)
according to the December 2020 DBAD and for whom both the suspension and termination date were unavailable in
the DAF or were missing earnings information from both the DAF and MEF.
beneficiaries regardless of age at award because overpayments can occur among DI beneficiaries
nearing the retirement age, and a notable portion of our analysis sample (38 percent) reached full
retirement age within our 10-year analysis period. As a sensitivity check, we produced some
statistics excluding those who reached full retirement age within 10 years of award.

Next, we identified beneficiaries at risk of overpayments (that is, those who met the
criteria for suspension or termination because of work) and those overpaid using an algorithm
originally developed and used in the evaluation of BOND (Hoffman et al., 2017). The same
algorithm has since been used to produce overpayment statistics for beneficiaries subject to
current DI law outside of the BOND evaluation (Hoffman et al., 2019). Specifically, we
identified months in which beneficiaries were at risk of a work-related overpayment. A
beneficiary is at risk of overpayment in any month after the TWP and grace period in which they
engaged in SGA. Over the 10-year analysis period, 31,520 beneficiaries engaged in SGA after

the grace period and were at risk of an overpayment; this is our final analysis sample.

Table 1. Sample Selection

 

Number Remaining
dropped sample

 

2008 DI awardees -- 830,271
Enrolled in benefit offset demonstration 780 829,491
Did not merge to DBAD or missing information for analysis period 909 828,582
Missing key analysis variables 768 827,814

Final analysis sample: No SGA after the TWP and grace period

(not at risk of an overpayment) 796,294 31,520

 

Source: 2019 Disability Analysis File, December 2020 DBAD extract from the MBR.

Finally, among months after the grace period in which beneficiaries engaged in SGA, we
identified overpayments in months for which SSA paid benefits (and later retroactively
suspended or terminated benefits).° We identified 25,846 beneficiaries (about 3.2 percent of the

 

>It is possible that beneficiaries engaged in SGA after the TWP and grace period and SSA paid beneficiaries for
those months, but SSA had not identified those benefits as having been overpaid. Indeed, in a recent report, auditors
identified 97 beneficiaries with earnings above SGA after the TWP and grace period, 77 of whom SSA identified as
having been overpaid for work, and 1 person whom SSA had not identified as overpaid, but the auditors determined
they should not have received benefits (SSA 2018). Such beneficiaries are not classified as having been overpaid in
this analysis.
award cohort) with overpayments in the 10-year period following award. The algorithm detects
the overwhelming majority of overpayments, but does not include all overpayments. For
example, if SSA was withholding monthly benefits to repay a prior overpayment debt, a
beneficiary who engaged in SGA could accrue additional overpayment debt in such a month that
our algorithm would not capture. However, SSA case reviews suggest close alignment with our
algorithm in aggregate (Hoffman et al., 2019).

We produced descriptive statistics on the overpayment rate, amount, timing, and
duration. We report the nominal dollar amount of the overpayment because SSA reports, tracks,
and collects overpayments in nominal dollars. That is, if SSA overpaid a beneficiary $1,000 in
2010, in future years, the overpayment debt will be $1,000 minus any amount repaid and is not

adjusted for inflation.

Identifying Program Milestones and Pathways

We used administrative data to document program milestones that occur along the
pathway to overpayment. Two milestones must have occurred within our sample of beneficiaries
who were at risk of an overpayment: positive earnings and TWP completion. When needed, we
imputed milestone dates. We identified the first instance of positive earnings after award using
monthly earnings information from the DAF when available. If the MEF reported positive
earnings in a particular year and the DAF did not, we used earnings information from the MEF
and imputed the earnings date (because the MEF records annual earnings). To impute the date of
first earnings, we first assigned the midpoint of the calendar year (in 2008, the midpoint between
award and December 2008, and June for all years thereafter) as the first month of earnings for
the year reported in the MEF. Second, if a beneficiary received EN or VR services in the same
calendar year as first earnings reported in the MEF only, we revised the earnings imputation to
occur at the end of the first month of employment service receipt. Third, we observed some
cases with first earnings after the TWP completion date, which is illogical because earnings must
occur before TWP completion. In such cases, we imputed the first earnings date to occur nine
months before the TWP completion date. In total, 14.6 percent of our sample had an imputed

value for the first month of positive earnings: 8.6 percent received the first imputation, 0.3
percent received the second, and 5.7 percent received the third.© In addition, some observations
in our analysis sample did not have a TWP completion date. For these beneficiaries (0.9 percent
of the sample), we imputed a TWP completion month, set as the month before the suspension
date (including those with retroactive suspension dates).

We used the DAF to identify remaining milestones occurring within the 10-year period
after award, including use of employment services, suspension or termination because of work,
medical terminations, retirement, or death. We define suspension and termination dates as the
dates in which beneficiaries met the programmatic criteria for benefit suspension or termination
because of work, even if the determination was made retrospectively. Following recent
literature, we used data derived from the SSA Waterfall file to identify medical terminations
(Hemmeter & Bailey 2016).' This file includes information on full medical reviews (the process
by which SSA determines medical terminations) reviewed by the state Disability Determination
Service and was newly added to the 2019 DAF.

We produced statistics on the prevalence of each milestone and time from award to
milestone among overpaid beneficiaries and compared these outcomes with those of
beneficiaries at risk of an overpayment who were not overpaid. We then created a visual
depiction of the milestone paths of overpaid beneficiaries to provide more detail about the
sequencing of milestones. For the visual pathways depiction, we documented the first
occurrence of work- and program-related milestones. We followed beneficiaries from award
until work termination or program exit for a non-work reason (medical termination, retirement,
or death). We excluded 5.8 percent of overpaid beneficiaries from the visual pathways depiction
for whom a first milestone occurred before award (but after eligibility). We also excluded 3.8
percent of beneficiaries in our sample from the visual depiction with pathways that represented
an impossible sequence of events. This comprised of 2.6 percent with program milestones in an
illogical order such as having a termination for work that preceded the first suspension for work

date and 1.2 percent with a first month of overpayment that occurs before a first suspension or

 

6 The overall rate of earnings imputations was similar among those overpaid (14.7 percent) and not overpaid (14.3
percent). The first earnings imputation relying only on MEF earnings, however, was more prevalent among those
not overpaid (12.2 percent versus 7.9 percent), and the reverse was true for the third imputation for first earnings
occurring after TWP completion (1.9 percent versus 6.6 percent).

7 Using the Waterfall file, we defined the date of medical termination based on the corresponding date for the CDR
final action type (for example, date of the initial decision, the decision at the reconsideration level, decision at the
admin law judge level, or the decision at the appeals council level).
termination for work.' Finally, we described the characteristics of overpaid beneficiaries who
follow the most frequent milestone paths to understand the characteristics of beneficiaries who

are represented in certain pathways.

Results
Overpayment Characteristics During the 10 Years After DI Award

A relatively small portion of beneficiaries awarded DI benefits in 2008 in our sample
engaged in SGA after the grace period and were at risk of an overpayment: less than 4 percent.
Among that group, 82 percent were overpaid within 10 years of DI award (Table 2, first
column). Nearly all first overpayment spells (98.7 percent) began when beneficiaries met the
criteria for suspension because of work (with the remainder, 1.3 percent, beginning when they
met the criteria for termination because of work). Most overpayments (89.0 percent) occurred
during their first month beneficiaries met the criteria for benefit suspension because of work;
some beneficiaries (11.0 percent) were correctly paid for their first SGA month after the grace
period and overpaid for a later SGA month.° The first month of overpayment occurred a median
of 49 months after award.

There was notable variation in the time to first overpayment, with 7 to 16 percent
experiencing their first overpayment in each of the first 10 years after award (Figure 1). Half of
all overpayments observed in our 10-year analysis period occurred in the first four years after
award. Overpayments were most prevalent in the second and third years after award, when 16.2
and 12.4 percent of overpayments observed in our sample occurred. Thereafter, overpayments
were generally less common in each subsequent year. Notably, it is possible for beneficiaries to
be overpaid in the first year after award (the first year in which a beneficiary received a DI
benefit payment) if there was a gap between DI entitlement and DI award; beneficiaries can use
TWP months as soon as they are entitled and might have completed some or all their TWP

months upon award.

 

8 We also excluded 0.1 percent of beneficiaries who experienced program exit because of a non-work reason, such
as medical termination, before their first suspension. It is possible that these beneficiaries were re-awarded benefits
and then experienced a work suspension or termination.

° On average, overpaid beneficiaries had 1.8 spells in which they met the criteria for suspension or termination for
work relative to 1.1 spells among those who met the suspension or termination criteria and were not overpaid.
Beneficiaries can have multiple spells in which they meet the criteria for suspension or termination if they engage in
SGA, reduce earnings below the SGA threshold, and then engage in SGA once again (this example depicted two
spells).

10
Beneficiaries in our analysis sample were overpaid for a median of nine months, with
durations ranging from just one month to more than four years. For some, these months were
spread across multiple spells of overpayment: 39 percent experienced more than one
overpayment spell. The median length of a first or only overpayment spell was five months and,
among those with multiple spells, there was a median of four months between overpayment
spells. The median overpayment amount was $9,206 and, because some beneficiaries had very
high overpayment amounts, the average overpayment amount was even higher: $13,556.

The overpayment experiences of the sample excluding beneficiaries who reached full
retirement age within 10 years of award were broadly similar to those of the entire cohort of
beneficiaries awarded DI benefits in 2008 (Table 2, second column). The most notable
difference is the relatively higher rate of engagement in SGA after the grace period: 5.5 percent
were at risk of an overpayment relative to 3.8 percent among the full sample. Among those at
risk, the overpayment rates, duration of overpayment, and overpayment amounts were similar for
the full analysis sample and the non-retirement sample. Here, we present results for the full

analysis sample.

11
Table 2. Rate, Duration, and Amount of Overpayment

 

2008 DI
awardees,
2008 DI excluding those
awardees who reached full
retirement age in
analysis period

 

 

 

 

 

Number of beneficiaries 827,814 516,307
Beneficiaries at risk of overpayment (n) 31,520 28,164
At risk, among 2008 awardees (%) 3.8 5.5
Beneficiaries overpaid (n) 25,846 23,274
Overpaid, among 2008 awardees (%) 3.1 4.5
Overpaid, among those at risk (%) 82.0 82.6
Among overpaid beneficiaries
First overpaid when met criteria for suspension because of work (%) 98.7 98.6
Overpaid in first month of SGA after grace period (%) 89.0 88.8
Duration of overpayment (months)
Average 12.2 12.5
1st percentile 1 1
25th percentile 4 4
50th percentile 9 9
75th percentile 17 18
99th percentile 49 49
Time to first overpayment spell (months)
Average 53.2 55.2
50th percentile 49 52
Multiple overpayment spells ("%) 38.8 39.2
Duration of first overpayment spell (months)
Average 7.8 7.9
50th percentile 5 5
Duration between overpayment spells (months)
Average 8.7 9.0
50th percentile 4 4
Overpayment amount ($)
Average 13,556 13,614
1st percentile 660 660
25th percentile 3,934 3,943
50th percentile 9,206 9,258
75th percentile 18,337 18,486
99th percentile 64,205 64,428

 

Source: 2019 Disability Analysis File, December 2020 DBAD extract from the MBR.

12
Figure 1. Year of First Overpayment After Award

20%

 

16%

15%
12%

11% 11% 10%
1 0 4 99 0
0% 8% J7/0 O% 8%,

7%

0% Td T T T T T T T T T

Ist 2nd 3rd 4th Sth 6th 7th 8th 9th 10th

year year year year year year year year year year
Year of first overpayment after award

 

 

 

 

 

Note: Sample size = 25,846 overpaid beneficiaries.
Source: 2019 Disability Analysis File, December 2020 DBAD extract from the MBR.

Overpayment Pathways

Figure 2 presents the sequencing of program milestones overpaid beneficiaries
experienced. We include the first observance of each milestone. For example, although most
beneficiaries engaged in SGA in multiple months after the grace period, we only document the
first month in which a beneficiary met the criteria for suspension due to work. Also, the exhibit
does not indicate when overpayments occurred for ease of presentation. However, recall that
nearly 90 percent of overpaid beneficiaries were overpaid the first time they engaged in SGA
after the grace period.

The relative timing of observed milestones and proportion following each path are
documented in Figure 2. The percentages reflect the proportion that advanced to the upcoming
milestone along each segment of the branch. Percentages layered on top of a milestone indicate
the terminal milestone. Terminal milestones include meeting the criteria for termination for
work, non-work exit, and continued entitlement to DI. Note the terminal nodes of suspension
followed by a termination because of work means that beneficiaries met the criteria for both

suspension and termination for work.

13
Figure 2. Pathways to Overpayment

6.5%) (93.5% )

6.5%] (9.2% | 84.3%)

  
   

   

Btu a mlm ls BIG n mld

    

a =
| Non-work exit
0.9%

   
 
 

 

   

" Non-work exit |
(01%)

  
       
  

BE amma Bia Cee mel S

  

ia - ™
| Non-work exit |
oer

=--0.2%-

   
   

Termination for work

1.2% }

Notes: This figure represents the program milestones overpaid beneficiaries experienced and captures receipt of
employment services from an EN or VR provider (EN/VR), positive earnings (earnings), completion of the TWP
(TWP), meeting the criteria for suspension because of work (suspension), meeting the criteria for termination
because of work (termination for work), meeting the criteria for non-work exit (non-work exit), and continued
entitlement to DI (remain on DI). The percentages between milestones indicate the percentage of all overpaid
beneficiaries included in the figure who moved from one milestone to the next. The percentages layered on top of a
milestone indicate that was the last observed milestone. Sample size: 23,372 overpaid beneficiaries who had a first
milestone of award and had a logical sequence of milestones.

Source: 2019 Disability Analysis File, December 2020 DBAD extract from the MBR, and Master Earnings File.

More than three-quarters of overpaid beneficiaries in our sample followed one of the
three most prevalent overpayment paths. The most common overpayment pathway, experienced
by 38.8 percent of overpaid beneficiaries in our sample, was award, earnings, TWP completion,
meeting the criteria for benefit suspension because of work, and meeting the criteria for
termination because of work. An additional 24.1 percent followed that same pathway but
remained entitled to DI, and an additional 13.7 percent left the program for medical termination,

retirement, or death rather than work termination. The remaining pathways were much less

14
frequent. For example, the fourth most prevalent pathway was taken by 4.2 percent of the
sample: award, earnings, EN or VR, TWP, meeting the criteria for benefit suspension because of
work, and meeting the criteria for termination because of work.

Two trends emerge when looking at the complete set of pathways. First, when overpaid
beneficiaries engaged with EN or VR services varied: 6.5 percent of overpaid beneficiaries
received these employment services before earning, 9.2 percent received services after having
positive earnings but before completing the TWP, 1.6 percent engaged after completing the TWP
but before meeting the criteria for benefit suspension because of work, and 2.6 percent received
services after their meeting the criteria for their initial benefit suspension. Second, consistent
with Liu & Stapleton (2011), termination because of work was the most common final milestone
across all pathways and occurred more frequently than remaining on the DI rolls or exit because
of medical termination, retirement, or death.

The characteristics of beneficiaries awarded DI benefits in 2008 in our sample varied
across the three most prevalent pathways (Table 3). Beneficiaries in the most common pathway
ending in work termination were generally similar to all overpaid beneficiaries in our sample.
They were primarily male (53.3 percent) and younger than age 45 (66.3 percent), had 12 or
fewer years of education (50.0 percent), were most commonly diagnosed with mental disorders
(31.0 percent) and did not receive Medicare at first award (81.8 percent). Beneficiaries who
followed the earnings, TWP, suspension pathway (the second most common pathway) had the
lowest levels of education: 57.8 percent had 12 or fewer years of education. These beneficiaries
also had the highest rates of Medicare eligibility at first award (23.6 percent), it is possible that
Medicare receipt at award could help beneficiaries with their return to work . Those who exited
DI for a non-work reason (the third pathway) were the oldest: less than 40 percent were younger
than age 45 at award. This is perhaps not surprising considering that non-work terminations
include retirement (as well as death and medical termination). Mental disorders were relatively
less common among members of this path (21.7 percent), and neoplasms (that is, cancer) were
more common in members of this path compared with beneficiaries in other pathways (16.5

percent).

15
Table 3. Characteristics of Overpaid Beneficiaries in the Three Most Frequent Paths

 

Sequence of milestones following DI award

 

(1)

 

All ., Earnings-TWP- (2) . (3)
overpaid . . Earnings-TWP-
beneficiaries SUSPension- Earnings-TWP- Suspension-Non-
Work Suspension Work Exit

Characteristic Termination
n 25,846 9,151 5,686 3,236
Sex

Female 48.3 46.7 50.9 46.8

Male 51.7 53.3 49.1 53.2
Age at first award

18-24 17.7 18.7 13.0 9.5

25-34 22.4 22.2 23.1 15.5

35-44 24.9 25.5 29.1 14.5

45-54 22.6 23.8 30.8 11.6

55-64 12.5 9.8 4.0 48.9
Education in award year

0 to 11 years 14.9 14.0 17.4 17.4

12 years 37.7 36.0 40.4 37.1

13 to 15 years 21.9 22.5 20.3 23.2

16 years or more 12.2 14.1 9.8 14.2

Missing 13.3 13.4 12.2 8.2
Impairment type

Mental disorders 33.8 31.0 37.7 21.7

Intellectual disabilities 5.5 5.4 5.2 0.9

Nervous system and sense organs diseases 8.9 8.2 7.3 5.1

Musculoskeletal and connective tissue 19.9 18.5 44 243

diseases

Neoplasms 7.0 9.5 2.8 16.5

Other physical disorders 24.9 27.4 22.6 31.5
Medicare Eligibility at first award

Yes 21.8 17.7 23.6 13.5

No 77.1 81.8 75.8 86.4

Missing 1.1 0.5 0.6 0.2
First award includes both SSDI and SSI benefits 16.5 15.7 17.2 10.6

 

Note: We define suspension and termination because of work dates as the dates when beneficiaries met the
programmatic criteria for benefit suspension or termination because of work, even if the determination was made

retrospectively.

Source: 2019 Disability Analysis File, December 2020 DBAD extract from the MBR, and Master Earnings File.

16
Comparison of Program Experiences of At-Risk Beneficiaries Who Were Overpaid and Not
Overpaid

To contextualize the experiences of overpaid beneficiaries, we compared their
experiences with those of beneficiaries who engaged in SGA after the grace period and were not
overpaid (Table 4). Among beneficiaries awarded DI benefits in 2008 who met the criteria for
benefit suspension or termination for work within 10 years of award and were at risk of
overpayment, 82.0 percent were overpaid, and 18.0 percent were not overpaid. The latter group
comprised beneficiaries for whom SSA withheld benefits in real time. Compared with at-risk
beneficiaries who were not overpaid, those who were overpaid were more likely to be female
(48.3 versus 44.3 percent), be younger than age 45 (64.9 versus 56.5 percent), have 12 or fewer
years of education (52.6 versus 44.6 percent), have mental disorders (33.8 versus 28.4 percent)
or intellectual disabilities (5.5 versus 1.9 percent), have Medicare eligibility at first award (21.8
percent versus 15.0 percent), and receive SSI at the time of DI award (16.5 percent versus 9.5
percent). !°

At-risk beneficiaries who were overpaid experienced program milestones at different
rates than those who were not overpaid (Figure 3). We do not show earnings and TWP
completion in this figure because all beneficiaries in our sample had positive earnings and
completed the TWP. Overpaid beneficiaries were less likely to meet the criteria for benefit
suspension (94.1 versus 99.0 percent) than at-risk beneficiaries who were not overpaid; the
balance of both groups experienced a termination for work.!! Overpaid beneficiaries were less
likely to exit the DI program because of work termination (55.4 versus 63.0 percent). They were
also less likely to terminate for non-work reasons (23.7 percent versus 26.1 percent) relative to
those who were not overpaid. Specifically, overpaid beneficiaries were more likely to
experience medical termination than at-risk beneficiaries who were not overpaid (9.4 versus 6.2
percent) but less likely to retire (10.2 versus 14.0 percent) or die (5.8 versus 8.6 percent). !?

Some of these differences might be related to the relatively younger age, advanced education,

 

10 An earlier paper found qualitatively similar findings when comparing characteristics among a representative 10
percent sample of DI beneficiaries who met the criteria for benefit suspension or termination for work between 2010
and 2012 (Hoffman et al., 2019).

11 This scenario can occur if a beneficiary completes the TWP, engages in SGA to initiate the extended period of
eligibility (during the grace period), and does not engage in SGA again until after the completion of the 36 month
extended period of eligibility, at which point benefits are terminated.

2 Note that some beneficiaries experienced several outcomes (for example, medical termination and death) during
our analysis period and are recorded in multiple categories.

17
and different medical conditions of overpaid beneficiaries. Relative to those not overpaid,
overpaid beneficiaries were more likely to have received EN or VR services (20.8 percent versus

18.3 percent).

Table 4. Comparison of Characteristics of At-Risk Beneficiaries Who Were Overpaid to Those
Not Overpaid

 

 

At-risk
Alloverpaid beneficiaries

Characteristic beneficiaries _ not overpaid Difference
n 25,846 5,674
Sex

Female 48.3 44.3 4.0***

Male 51.7 55.7 -4.0***
Age at first award

18-24 17.7 13.1 4.5***

25-34 22.4 20.3 2.1***

35-44 24.9 23.0 1.8***

45-54 22.6 26.8 -4,3***

55-64 12.5 16.7 -4.24**
Education at first award

0 to 11 years 14.9 9.2 5.7***

12 years 37.7 35.5 2.3***

13 to 15 years 21.9 24.6 -2,.8***

16 years or more 12.2 22.1 -9.8*¥*

Missing 13.3 8.7 4.6***
Impairment type

Mental disorders 33.8 28.4 5.4***

Intellectual disabilities 5.5 1.9 3.6***

Nervous system and sense organs diseases 8.9 8.1 0.8*

Musculoskeletal and connective tissue 19.9 18.6 3%

diseases

Neoplasms 7.0 16.6 -9,6***

Other physical disorders 24.9 26.5 -1.6**
Medicare Eligibility at first award

Yes 21.8 15.0 6.8*#*

No 77.1 84.1 -7.OF**

Missing 1.1 0.8 0.2
First award includes both SSDI and SSI benefits 16.5 9.5 7.O*#**

 

Notes: T-test significance is shown in the final column. * Indicates p < 0.10, ** indicates p < 0.05, and ***
indicates p < 0.01.
Source: 2019 Disability Analysis File, December 2020 DBAD extract from the MBR.

18
Figure 3. Share of At-Risk Beneficiaries Reaching Each Milestone among Overpaid and Not
Overpaid Beneficiaries

 

100% 22%

 
 
      
    

 

 

 

@ Ever Overpaid Not Overpaid

 

 

63%

  

 

24opex 267

Share of beneficiaries at risk of

 

0% -

% Suspended % Work % Non-work % EN/VR
termination program exit services

Notes: T-test significance is shown above each pair of columns. * Indicates p < 0.10, ** indicates p < 0.05, and ***
indicates p < 0.01. Sample sizes: 25,846 overpaid beneficiaries and 5,674 at-risk beneficiaries who were not
overpaid.

Source: 2019 Disability Analysis File, December 2020 DBAD extract from the MBR.

In addition to differences in the rates of milestone achievement, there were also
differences in the time from award to milestone among those who achieved given milestones by
overpayment receipt (Figure 4). Relative to beneficiaries who were at risk but not overpaid,
overpaid beneficiaries achieved almost all milestones except for earnings later. Notably,
overpaid beneficiaries first met the criteria for benefit suspension an average of six months after
non-overpaid beneficiaries and first recetved employment services three months later. On the
other hand, overpaid beneficiaries had their first month of positive earnings about one month
sooner than those who were not overpaid (17 versus 18 months after DI award). Although this
difference is statistically significant, 14 percent of earnings dates were imputed, and the type of
imputation differed across the two groups, so it is difficult to definitively state that this is a

meaningful difference.

19
Figure 4. Months from Award to Each Milestone for Overpaid and Not Overpaid Beneficiaries

 

96
84 -| WEver Overpaid @ Not Overpaid

72
60
48
36
24
12

0

 

 

 

 

 

 

 

 

 

 

Months since DI award

 

 

 

 

. a"
> we a e
s Sg ro Rs S
e 8 8 > em
Y os of & S
s NS
& ae &
os

Notes: T-test significance is shown above each pair of columns. * Indicates p < 0.10, ** indicates p < 0.05, and ***
indicates p < 0.01. Sample sizes: EN/VR: 1,548 overpaid, 312 not overpaid; earnings: 25,846 overpaid, 5,674 not
overpaid; TWP completion: 25,846 overpaid, 5,674 not overpaid; suspended: 24,321 overpaid, 5,617 not overpaid;
work termination: 14,329 overpaid, 3,753 not overpaid; non-work program exit: 6,131 overpaid, 1,481 not overpaid.
Source: 2019 Disability Analysis File, December 2020 DBAD extract from the MBR, and Master Earnings File.

Discussion and Conclusion

This analysis provides new details on the overpayment-related experiences of 2008 DI
awardees. We find that nearly 4 percent of beneficiaries were at risk of a work-related
overpayment because they engaged in SGA after the TWP and grace period and, among that
group, 82.0 percent of beneficiaries were overpaid in the first 10 years after award. These results
provide additional evidence that overpayments were the norm for beneficiaries who engaged in
SGA after the TWP and grace period. A previous study found that, among a representative
cross-section of beneficiaries, 71.0 percent of those at risk of overpayment were overpaid in the
three-year period from 2010 to 2012 (Hoffman et al., 2019). The higher prevalence noted in this
study likely reflects the longer analysis period (three versus ten year), among other differences.
Both the previous and current study estimated median overpayment duration of nine months and

total overpayment amounts of about $9,300.

20
Our analysis focuses on beneficiaries awarded and 2008 and results may not generalize to
beneficiaries awarded benefits in other years. For example, it is possible that overpayment
experiences will differ for beneficiaries in more recent award cohorts because SSA has made
increasing efforts to prevent or minimize overpayments in recent years. In 2017, after an initial
pilot period, SSA began to draw on quarterly earnings data from the National Directory of New
Hires when reviewing earnings for all DI beneficiaries. As of 2020, SSA was in the process of
working with payroll data providers to access timely earnings data among beneficiaries paid
through those providers (SSA, 2020a).

This study also offers new insight into the timing of overpayments. First, nearly all
overpayment spells (89.0 percent) began in the first month beneficiaries meet the programmatic
criteria for benefit suspension because of work. Second, most overpaid beneficiaries (79
percent) followed a direct route to overpayment: experiencing award, earnings, TWP completion,
then meeting the criteria for suspension because of work. Third, although time to first
overpayment varied, half of all overpayments documented in this study occurred in the first four
years after award. Finally, about one in six overpaid beneficiaries (15.6 percent) received EN or
VR services before their first month of benefit suspension.

The timing and sequence of program experiences among overpaid beneficiaries suggests
two possible points of intervention to prevent or minimize overpayments. Because most
overpayment dollars result from beneficiary reporting failures (SSA, 2018), and a substantial
share occur in the first four years after award, well-formatted earnings reporting reminders sent
in the first four years after award might help encourage reporting and reduce the likelihood or
amount of overpayment. Zhang et al. (2020) found that earnings reporting reminders made to
Supplemental Security Income beneficiaries with disabilities helped reduce the incidence of
overpayments. Although the SSI and DI programs have different reporting requirements, it is
possible that the same practice reflecting SSI reporting standards would be effective for DI
beneficiaries. In addition, Hoffman et al. (2020) reviewed written SSA communications to DI
beneficiaries about earnings reporting and found that beneficiaries were infrequently notified of
the requirements, and content on earnings reporting was often located at the end of documents or
in dense text. Efforts to promote beneficiary reporting could supplement SSA initiatives to
identify earnings more quickly. However, there is not existing evidence about the overall

effectiveness or cost effectiveness of reporting reminders for DI beneficiaries.

21
A second possible intervention could occur in partnership with employment service
providers. Because about one in six overpaid beneficiaries received EN or VR services before
first suspension, engaging those providers in issuing earning reporting reminders or directly
assisting with earnings reporting could help avoid overpayments. Under Ticket to Work, ENs
and VRs not serving clients under cost reimbursement have an existing incentive to collect
earnings information from their clients to facilitate outcome-based payments. However, this
research highlights that, despite this incentive, EN and VR providers may sometimes be unable
to facilitate earnings reporting and if reported, may not result in timely SSA case reviews.!*
Highlighting the potential consequence of overpayments to clients or creating client incentives to
report could improve reporting rates in a way that benefits both clients and providers.

Finally, although work termination is the most common final milestone across all
pathways taken by overpaid beneficiaries, such beneficiaries are 7.5 percentage points less likely
to experience work termination in the first 10 years after DI award compared with at-risk
beneficiaries who are not overpaid. The two groups differ in other observable ways (for
example, those who are overpaid have lower levels of education) and likely in unobservable
ways which could help explain this difference. Relative to those not overpaid, overpaid
beneficiaries are younger, more likely to medically terminate, and less likely to die, suggesting
that they are in better health. Although alternate explanations are possible, this comparison and
the evidence shown in Figure 3 is consistent with the notion that overpayments might cause
beneficiaries to reduce employment. Other research has found a causal link between
overpayment and disengagement from SGA (Hoffman et al., 2020). Although the current study
is not meant to demonstrate a causal link between overpayments and subsequent SGA, when
considered with existing research, findings collectively suggest that reducing overpayments may
help more beneficiaries maintain SGA. When overpayments do occur, outreach efforts or
supports to overpaid beneficiaries might help them maintain employment and attain financial
self-reliance and independence from the DI program.

This analysis is subject to several limitations. First, the overpayment algorithm might not

capture all work-related overpayments. For example, our algorithm does not account for

 

13 SSA instituted the Monthly Earnings Project (MEP) in 2019. MEP established a systematic means of determine
whether reported earnings were potential overpayments cases and effectively transfers the cases to SSA's processing
center for immediate attention and case review on a monthly basis.

22
repayment plans for other overpayments or lump-sum transfers for underpayments. Yet SSA
case reviews of 20 beneficiary records with overpayments found that the algorithm estimated the
overpayment amount within 0.3 percent of SSA's calculation (Hoffman et al., 2019). Second,
this analysis focused on the first occurrence of work- and program-related milestones. For
example, we documented the first month beneficiaries met the criteria for benefit suspension
because of work rather than documenting all months beneficiaries met the criteria for benefit
suspension. We used this approach to streamline the analysis because of the sheer volume of all
milestones that might occur during a 10-year period. We describe some milestones that might
occur multiple times by documenting the number of overpayment spells and duration between
spells. This approach, however, overlooks some nuance in beneficiary experiences. Third, we
imputed earnings dates for nearly 15 percent of our analysis sample, which could have affected
the precision of earnings dates. Fourth, we documented the experiences of the 2008 cohort of
new awardees, and their experiences might not represent other awardee cohorts.

Despite these limitations, this study adds to the evidence on beneficiaries' experiences
with overpayments and yields some insight into approaches that might help reduce
overpayments. Future research could attempt to uncover more details about the mechanisms
behind why beneficiaries are overpaid and the extent to which certain entities-such as EN or
VR, SSA-funded benefits counselors, SSA field offices, or the centralized SSA toll-free
number- might have the ability to prevent or minimize overpayments. These pathways may
remain important even as SSA pursues initiatives to reduce overpayments, such as establishing
information exchange agreements with payroll data providers. Although there is reason to be
optimistic that timely information on wages from payroll providers will reduce overpayments,

these agreements do not cover all employers nor self-employed workers.

23
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24
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25
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26