INFORMING SOCIAL SECURITY’S PROCESS FOR
Committee to Evaluate the Social Security Administration’s
Paul S. Appelbaum, Carol Mason Spicer, Frank R. Valliere, Editors
Board on the Health of Select Populations
Institute of Medicine
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This activity was supported by Contract No. SS00-13-60048-0005 with the U.S. Social Security Administration. Any opinions, findings, conclusions, or recommendations expressed in this publication do not necessarily reflect the views of any organization or agency that provided support for the project.
International Standard Book Number-13: 978-0-309-39257-0
International Standard Book Number-10: 0-309-39257-8
Digital Object Identifier: 10.17226/21922
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Suggested citation: National Academies of Sciences, Engineering, and Medicine. 2016. Informing Social Security’s process for financial capability determination. Washington, DC: The National Academies Press. doi: 10.17226/21922.
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COMMITTEE TO EVALUATE THE SOCIAL SECURITY ADMINISTRATION’S CAPABILITY DETERMINATION PROCESS FOR ADULT BENEFICIARIES
PAUL S. APPELBAUM (Chair), Elizabeth Dollard Professor of Psychiatry, Medicine and Law, and Director, Division of Law, Ethics and Psychiatry, Department of Psychiatry, Columbia University
KAREN E. ANDERSON, Director, Huntington Disease Care, Education and Research Center, and Associate Professor of Psychiatry and Neurology, Georgetown University Medical Center and MedStar Georgetown University Hospital
MARÍA P. ARANDA, Associate Professor, University of Southern California School of Social Work
NANCY BAGATELL, Associate Professor, Division of Occupational Science and Occupational Therapy, University of North Carolina at Chapel Hill
JULIE BIRKENMAIER, Professor, Saint Louis University School of Social Work
NANCY N. DUBLER, Professor Emerita, Albert Einstein College of Medicine; Consultant for Ethics, New York City Health and Hospital Corporation; and Adjunct Professor, Division of Medical Ethics, New York University Langone Medical Center
LAURA B. DUNN, Director, Geriatric Psychiatry Fellowship Training Program and Professor, Department of Psychiatry and Behavioral Sciences, Stanford University
ALAN M. JETTE, Professor of Health Policy & Management, Boston University School of Public Health
DAVID A. LOEWENSTEIN, Director and Professor of Neuropsychology, Department of Psychiatry and Behavioral Sciences, University of Miami Miller School of Medicine
MARC A. NORMAN, Professor, Medical Neuropsychology, and Director, Neuropsychiatry/Epilepsy Clinical Evaluation Program, University of California, San Diego
ELDAR SHAFIR, William Stewart Tod Professor of Psychology and Public Affairs, Department of Psychology and the Woodrow Wilson School of Public and International Affairs, Princeton University
KELLY A. THOMPSON, Thompson Wildhack PLC, Arlington, Virginia
ALLEN W. HEINEMANN, Director, Center for Rehabilitation Outcomes Research, Rehabilitation Institute of Chicago
KENDALL M. CAMPBELL, Co-Director, Center for Underrepresented Minorities in Academic Medicine, and Associate Professor, Family Medicine and Rural Health, Florida State University College of Medicine
IOM Project Staff
CAROL MASON SPICER, Study Director
FRANK R. VALLIERE, Associate Program Officer
JENNIFER FLAUBERT, Associate Program Officer (since December 2015)
NICOLE GORMLEY, Senior Program Assistant
PAMELA RAMEY-McCRAY, Administrative Assistant
FREDERICK ERDTMANN, Director, Board on the Health of Select Populations
This report has been reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise. The purpose of this independent review is to provide candid and critical comments that will assist the institution in making its published report as sound as possible and to ensure that the report meets institutional standards for objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process. We wish to thank the following individuals for their review of this report:
Henry Aaron, The Brookings Institution
Sara S. Bachman, Boston University School of Social Work
Denise Burnette, Columbia University School of Social Work
Lisa Dixon, Columbia University Medical Center
Kathryn Edin, Johns Hopkins University
Eric B. Elbogen, University of North Carolina at Chapel Hill School of Medicine
Jason Karlawish, University of Pennsylvania
Kristi L. Kirschner, University of Illinois at Chicago
Daniel C. Marson, The University of Alabama at Birmingham
Barton W. Palmer, University of California, San Diego
Elizabeth K. Rasch, National Institutes of Health
Marc I. Rosen, Yale University School of Medicine
Elyn Saks, University of Southern California Gould School of Law
Although the reviewers listed above provided many constructive comments and suggestions, they were not asked to endorse the report’s conclusions or recommendations, nor did they see the final draft of the report before its release. The review of this report was overseen by Georges Benjamin, American Public Health Association, and Bradford H. Gray, The Urban Institute. They were responsible for making certain that an independent examination of this report was carried out in accordance with institutional procedures and that all review comments were carefully considered. Responsibility for the final content of this report rests entirely with the authoring committee and the institution.
The U.S. Social Security Administration (SSA) provides benefits to disabled adults and children, offering vital financial support to more than 17 million disabled Americans. Of that group, approximately 5 million have been deemed—by virtue of youth or mental or physical impairment—incapable of managing or directing the management of their benefits.1 Hence, a representative payee has been appointed to receive and disburse SSA payments for these beneficiaries to ensure that their basic needs for shelter, food, and clothing are met. Periodically, however, concerns have been expressed about the accuracy of the process by which SSA determines whether beneficiaries are capable of managing their benefits, with some evidence suggesting that underdetection of incapable recipients may be a particular problem.
The importance of creating as accurate a process as possible for incapability determinations is underscored by the consequences of incorrectly identifying recipients either as incapable when they can manage their benefits or as capable when they cannot. Given the importance of individual autonomy in decision making in a democratic society, deprivation of the right to manage one’s money—which ensues from a finding of incapability—represents a serious infringement on liberty that should occur only when absolutely necessary. Conversely, failure to identify beneficiaries who are incapable of managing their funds means abandoning a vulnerable population to potential homelessness, hunger, and disease. Needless to say, neither error is desirable.
1 The prepublication version of this report erroneously included a group of nondisabled beneficiaries in the numbers provided in the preceding sentences. These numbers were revised for accuracy.
With support from SSA, the Institute of Medicine (IOM) of the National Academies of Sciences, Engineering, and Medicine convened a committee to evaluate SSA’s capability determination process. In pursuit of that goal, the committee reviewed the relevant professional literatures in several languages, heard testimony from researchers who study the capability determination process and from persons directly involved with it, considered existing assessment tools and their applicability to this process, looked at comparable programs in the public and private sectors in Canada and the United States, and obtained background information and data from SSA on the operation of its system.
Drawing on all of these sources, the committee formulated a number of conclusions and recommendations that it believes can inform and guide efforts to improve the current capability determination process. Most notably, the committee concluded that basing capability determinations on evidence of beneficiaries’ actual performance in meeting their basic needs is superior to office-based assessment of individuals’ financial competence. In such a performance-based process, priority is given to information from persons who are in direct contact with beneficiaries and are in a position to know about their financial performance.
On behalf of the committee, I want to thank all of the individuals who shared their time and expertise during the committee’s information-gathering sessions. Special thanks go to Winthrop Cashdollar at America’s Health Insurance Plans for collecting and compiling information from a number of private companies that provide disability income protection coverage about their procedures for determining when a claimant is not competent to handle disability income benefits. I also extend thanks to the IOM staff members who played a key role in the production of this report, including Rick Erdtmann (board director), Carol Mason Spicer (study director), Frank Valliere (associate program officer), Nicole Gormley (senior program assistant), and Julie Wiltshire (financial associate). Research assistance was provided by Daniel Bearss and Rebecca Morgan. Rona Briere and Alisa Decatur are to be credited for the superb editorial assistance they provided in preparing the final report.
Finally, as committee chair, I want to express my appreciation for the hard work and collegial approaches of all the committee members. I know they share my hope that this report can have a positive impact on the lives of persons with disabilities who may need assistance in managing their benefits.
Paul S. Appelbaum, Chair
Committee to Evaluate the Social Security
Administration’s Capability Determination
Process for Adult Beneficiaries
Boxes, Figures, and Tables
1-2 Number and Percentage Distribution of Supplemental Security Income (SSI) Recipients with Representative Payees Receiving Federally Administered Payments, by Eligibility Category and Age, December 2014
2-1 Number and Percentage of Adult Social Security Disability Insurance (SSDI), Disabled Adult Children SSDI, and Supplemental Security Income (SSI) (Blind or Disabled) Recipients with Representative Payees, December 2014
|ACED||Assessment of Capacity for Everyday Decision-making|
|ADA||Americans with Disabilities Act|
|AHIP||America’s Health Insurance Plans|
|ASD||autism spectrum disorder|
|ATM||automated teller machine|
Clinician Assessment of Financial Incapability
|CDR||continuing disability review|
|CPP||Canada Pension Plan|
|CSRS||Civil Service Retirement System|
Disability Determination Services
|DEBT||Disability Examiner Basic Training Program|
|DSM-IV||Diagnostic and Statistical Manual of Mental Disorders, Fourth Edition|
Everyday Functioning Battery
|ESDC||Employment and Social Development Canada|
Financial Competence Assessment Instrument
|FCI||Financial Capacity Instrument|
|FCI-SF||Financial Capacity Instrument-Short Form|
|FEGLI||Federal Employees’ Group Life Insurance|
|FEHB||Federal Employee Health Benefits|
|FERS||Federal Employee Retirement System|
|FISCAL||Financial Incapability Structured Clinical Assessment done Longitudinally|
Health Resources and Services Administration
instrumental activity of daily living
|ICD||International Classification of Diseases|
|ICF||International Classification of Functioning, Disability and Health|
|ILS||Independent Living Scales|
|ILSS||Independent Living Skills Survey|
|IOM||Institute of Medicine|
Kohlman Evaluation of Living Skills
Money Mismanagement Measure
National Association of Disability Examiners
|NCE||National Counselor Examination|
|NICS||National Instant Criminal Background Check System|
|NPV||negative predictive value|
Old Age Security
|OASDI||Old-Age, Survivors, and Disability Insurance|
|OASI||Old-Age and Survivors Insurance|
|OIDAP||Occupational Information Development Advisory Panel (SSA)|
|OIG||Office of the Inspector General|
|OIG-SSA||Office of the Inspector General for the Social Security Administration|
|OPM||U.S. Office of Personnel Management|
power of attorney
|POMS||Program Operations Manual System|
|PPV||positive predictive value|
Rating Veterans Service Representative
|SGA||substantial gainful activity|
|SLOF||Specific Levels of Function|
|SSA||U.S. Social Security Administration|
|SSDI||Social Security Disability Insurance|
|SSI||Supplemental Security Income|
Timeline Historical Review of Income and Financial Transactions
U.S. Department of Veterans Affairs
|VBA||Veterans Benefits Administration|
|VSCM||Veterans Service Center Manager|
|VSR||Veterans Service Representative|
World Health Organization