2024-30593. Use of Electronic Payroll Data To Improve Program Administration

	SSI	OASDI disability	Concurrent SSI and OASDI disability
Point at Which We Send Notice to Individuals 60	• We send a NOPA when an individual's earnings increase and their SSI payments will be reduced in an upcoming month • We send a Notice of Change in Payment when an individual's earnings decrease and their SSI payments will be increased	• We send a due process notice when an individual is performing SGA in the Extended Period of Eligibility • We send a final SGA notice explaining our decision and documenting which months the individual is over SGA	• Individuals would receive both the SSI and OASDI disability notifications.
Reason We Send Notice	• The NOPA explains the change to the payment and what information we used to determine the new amount. It provides appeal rights and other important information • The Notice of Change in Payment explains the new payment amount and how we computed it. It provides appeal rights and other important information	• The due process notice explains our proposed decision and presents an opportunity to provide additional evidence. It provides contact information and other important information • The final SGA notice will explain our decision. It provides appeal rights and other important information	• The reason is issue specific and applies to whichever notice they receive, since they may receive more than one notice depending on their circumstances as they relate to the specific program.

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Comment: One commenter stated the use of payroll provider data to automatically generate NOPAs reflecting even small changes in payment amounts could result in many SSI recipients receiving a new NOPA every month due to a fluctuating number of hours worked from month to month. The commenter expressed concern that, rather than increasing the efficiency of program administration, this “flood of notices” would result in more calls to our national 800 number and field offices with questions and concerns. Some commenters said that our proposed rule may result in very frequent (even monthly) NOPAs for some. They stated that these frequent notices may cause “confusion and distress.” Another commenter said we should examine the potential for an increase in calls to our national 800 number and an increase in visits to our field offices due to the new rule, and we should plan accordingly. The commenter stated that individuals will “undoubtedly reach out” to us if they have questions about the “many new notices” that will be mailed out under the final rule, such as those to dispute an error in payroll data or to appeal a benefit reduction. According to the commenter, individuals may also contact us if they are confused about their wage reporting obligations. The commenter asserted, that if calls and office visits increase significantly due to PIE, it could become more difficult for all of our customers to get help from us. Some commenters expressed concerns about our staffing levels and the effect staffing levels may have on the ability to get help with PIE-related concerns or questions.

Response: We anticipate that the PIE implementation may result in more notices. However, this is mostly because, with PIE in place, we will be able to capture and process more accurate and timely wage and employment information than before. Timely receipt of this information through PIE allows us to send correct and appropriate notices more quickly to ensure payment accuracy. Under PIE, the only additional notices are those that would generate when we receive wages from a new employer or stop receiving wages from an employer. While this may result in an increase in notice frequency, as well as related calls to our 800 number, we expect that PIE will also bring about decreased burdens in the form of reduced of routine reporting for hundreds of thousands of beneficiaries and recipients—if someone allows us to access their wage and employment information from a payroll data provider, and we receive that information, the individual will not have to report information about that employer for as long as we continue to receive it. And while some additional notices will go out, we anticipate that, because of the efficiencies gained from PIE, our staff will spend less time on wage reporting workloads because they will spend less time investigating wage information. Thus, staff would have more time to assist beneficiaries and recipients should questions arise from receipt of these notices. We expect to gather preliminary data on these issues as we implement PIE in phases and study its effects. As always, we remain committed to assisting individuals with any potential issues as soon as possible.

Comment: One commenter said we should reevaluate the information we provide to individuals who do not opt into PIE. Specifically, they asked us to examine the information we provide about reporting requirements, including the literacy level, accessibility, timing, and frequency. The commenter asserted that some individuals are unaware of the importance of reporting earnings and we should ensure they understand the projected amount of their monthly payments. According to the commenter, we should emphasize the importance of regularly checking their payment amounts to prevent overpayments.

Response: We appreciate the commenter's suggestion to improve our current notices. While we commit to continually improving our communication, including the notices relating to PIE, this rulemaking seeks to address factors specific to PIE.

Comment: A commenter asserted that we are subject to Executive Order (E.O.) 13166, Improving Access to Services for Persons With Limited English Proficiency,^[61] and that we have obligations to individuals with limited English proficiency (LEP) to provide meaningful language access. Specifically, the commenter said we should provide a translated NOPA whenever an individual requested language translation services in the past. According to the commenter, we should translate our NOPAs into additional languages commonly spoken by individuals with LEP in the United States and add more languages over time. Some commenters said that these notices should be fully accessible, in multiple formats including braille, large print and audio.

Another commenter alleged that field offices often fail to provide timely, accurate language services to people who primarily speak a language other than English, and the introduction of automated wage reporting will add a new element. The commenter stated that it is imperative that all related information—written or oral—be provided in the recipient's preferred language. The commenter said we should consider improving language service capabilities, especially the availability of interpreters and adoption of standardized scripts for explaining the automated wage reporting system.

Response: PIE notices are supported in English and Spanish and are made available based on the selected Special Notice Option, which are: standard print notice by certified mail, standard print notice by first class mail and a follow-up phone call to read the notice within five business days, braille notice and standard print notice by first-class mail, data compact disc (CD) in Microsoft Word format and a standard print notice by first-class mail, large print notice (18 point font) and a standard print notice by first-class mail, or audio CD and a standard print notice by first-class mail. Individuals with LEP may also bring a speaker of a given language into the office to translate for them.

Comment: One commenter asserted that we should clarify that, because TWN is receiving Federal funds as a Federal contractor, it is subject to E.O. 13166 and should provide language access for LEP individuals. According to the commenter, we should assess, under our contract, whether TWN is providing quality LEP services and has sufficient resources for translation and interpreter services. The commenter asserted, to meet its obligations, TWN should provide meaningful access for LEP individuals to their wage and employment information reports by translating them into the top languages spoken by LEP SSI recipients.

Response:E.O. 13166 places an obligation on the agency, not third parties. As we state on ssa.gov , “we provide free interpretive services to help you conduct your Social Security business. These interpreter services are available whether you talk to us by phone or in the Social Security office.” ^[62] TWN is a database belonging ( print page 107249) to Equifax, who is a third-party contractor.

Consistent with the above, our contract with Equifax does not put any LEP obligations on Equifax, a third-party contractor.

Accessing Report Used To Make Adverse Action

Comment: Commenters stated that we must ensure that individuals can easily obtain file disclosures from TWN or we must provide recipients with the copy that we obtained to make an adverse action. According to one commenter, FCRA provides that consumers can obtain a copy of their own consumer report, and they are entitled to free file disclosure annually and when an adverse action has been taken against them.^[63] Commenters asserted that these free disclosures are “critical” because they enable consumers to identify and dispute errors in their reports. Other commenters stated that access to their own information is a “basic principle of fair information practices.” Some commenters alleged payroll data providers do not always meet their file disclosure requirements under FCRA. For example, one commenter said, “TWN's systems appear to impose barriers or an outright inability for consumers to obtain a copy of their own TWN report.” The commenter expressed that we should mandate performance standards for accessing reports in 20 CFR 422.150, our guidelines, or our contract with TWN. The commenter cited an example of a consumer who had significant difficulty accessing these reports. Another commenter stated that “consumers have a right to review their wage and employment information contained within TWN by requesting their Employment Data Report at any time.”

Response: Under the Privacy Act of 1974, individuals have a right to access records about themselves that are retrievable by a personal identifier from our (SSA) non-exempt systems of records. Accordingly, individuals would have a right to access the wage reporting records stored in our files and used to make a determination, including any adverse action.^[64] For wages we receive from our current payroll data provider, when sending an adverse action notice, we will provide individuals notice of their right to a free copy of their consumer report and how to contact our current payroll data provider.

Reporting

Comment: One commenter said we should clarify why we will require individuals to report a new employer and explain the consequences of reporting or not reporting a new employer. In addition, the commenter asked several questions: (1) If an individual does not report a new employer, will we still be able to match payroll data? (2) Is the affirmative report of a new employer necessary to allow us to manually input the new employer information in the system so that any later payroll data has a “place” to go? (3) When an individual reports their new employer, what happens to payroll data provided by PIE for the new employer? (4) Will we tell an individual whether the new employer's data is accessible via matching or manual reporting is needed? If so, how and when will this information be provided?

Response: We will continue to require individuals to report new employers to us because, as noted, our payroll data provider will not be able to provide us with wage information from every employer. We will inform the individual of their reporting obligations each time we receive a report that they began work with a new employer. Thus, if we receive wage information from the payroll data provider for the new employer, we will notify the individual they no longer are required to report wage information for that employer to us. If an individual begins to work for a new employer and we have not notified them that we are receiving wage and employment information through our payroll data provider, the individual will still need to report wages to us for that employer.

Regarding the commenter's questions, we clarify that even if an individual does not tell us about the new employer, we will generally be able to match payroll data if an individual has provided us with authorization to obtain their wage and employment information through PIE and the new employer reports their wages to our payroll data provider. We nonetheless require individuals to report new employers because there is no way for us to know whether a new employer's wage information will be available through PIE or not. Thus, reporting the new employer will help us make more accurate and timely payments.

Finally, as mentioned earlier, we instruct individuals to continue reporting their wages until they receive notice from us to stop. We will send a notice to individuals whenever their wage reporting responsibilities change, as discussed in the NPRM.

Comment: Several commenters asked how we will clearly communicate when individuals need to continue reporting wages to us. One commenter said that individuals may misunderstand the new rules to mean that they no longer need to track their wage information. According to the commenter, this could lead to significantly delayed or inaccurate wage reporting and the “mixed messages” we will send to individuals will confuse them, particularly those with cognitive difficulties, and potentially lead to noncompliance with our rules, frustration, and overpayment or a loss of benefits.

One commenter stated that, when we learn that an individual's employer does not use TWN, we should inform them to continue wage reporting using the existing methods. According to the commenter, this communication would prevent individuals from incorrectly assuming that they no longer need to report because they authorized us to use PIE. Another commenter said that individuals often work multiple jobs for short periods and their disabilities may hinder their ability to maintain consistent employment. According to the commenter, if wage reporting responsibilities change from one employer to the next, some recipients will be unable to keep up with their reporting obligations. The commenter said recipients should be clearly and promptly advised that payroll data providers may not receive information from every employer, so the individual may need to report earnings from some employers, even if we automatically receive payroll data from other employers.

An additional commenter asked how the individual will know, once they've opted in, that the data has or has not been received from the payroll data provider, and, if the payroll data provider fails to transmit data to us, transmits incorrect data, or delays transmitting data—if the individual will continue to be exempt from certain penalties.

Response: We will tell individuals to continue reporting their wages using existing methods until they receive notice from us telling them otherwise, and our notices will communicate any other changes to reporting requirements. This information is provided through a receipt they receive after providing authorization. We understand that individuals may work for multiple employers, change employers frequently, or not be aware initially whether their employer reports wages to us. Accordingly, as explained in the NPRM, we will notify individuals in ( print page 107250) writing of changes to their reporting responsibilities, including whenever we start or stop receiving their wage and employment information from an employer through a payroll data provider. The notices for changes in reporting responsibilities will list the employer(s) we receive wages from and the employer(s) we stop receiving wages from. Since the notices list specific employer(s), and also explain the need to continue reporting for any other employer(s), we expect to minimize confusion. Finally, as noted in the NPRM, individuals who authorize us to obtain wage and employment information from a payroll data provider will not be subject to penalties under section 1129A of the Act for omissions or errors in the data we receive from a participating payroll data provider. We will provide notice of this penalty relief, including the identity of the relevant employer(s).^[65]

Comment: One commenter asserted that starting or stopping a job is a major event that can disrupt people's lives and offering an extended grace period, especially for those who experience unexpected job losses, would benefit people who are likely in the process of applying for other programs to take care of their immediate needs.^[66] The commenter asked if there are exceptions to the reporting timeline for major life event experiences and, if an individual knows a change in their earnings is coming ( e.g., a raise), how far in advance are they able to notify us of these changes.

Response: While we appreciate that starting or stopping a job may be a big change, the suggestion to offer an “extended grace period” is not within the scope of this current rulemaking. Further, we cannot consider changing the time periods allowed for making required reports. We anticipate that the changes we are making with these new rules will significantly reduce reporting responsibilities for most individuals. Timely reporting, however, is still necessary to ensure we have enough time to adjust benefits, so we pay individuals the correct amount at the correct time. In the SSI program, individuals should continue to report to us as soon as an event listed in § 416.708 happens.^[67] If they do not report within 10 days after the close of the month in which the event happens, the report will be late.^[68] For disability, individuals should report changes “promptly.” ^[69]

When an individual knows that a change in their earnings will happen in the future (such as a raise), they can report the future event to us in advance and we will use that report to estimate their future wages.

Internal Quality Review

Comment: One commenter said we should conduct rigorous evaluations of our implementation to ensure that the PIE authority is operating as intended by Congress. In addition, the commenter stated that we should publish annual reports so that the public and Congress can understand the impact. For example, according to the commenter, we should publish information on the number of individuals: (1) who have authorized us to access their commercial payroll data; (2) whose benefits have been reduced or stopped due to PIE wage reports; (3) who have reported errors in their PIE wage data and the outcomes of those reports; and (4) who have appealed and the outcome of those appeals. Further the commenter said we should report: (1) our actions to prevent, identify, and correct wage report errors; (2) the impact of the PIE on overpayments; and (3) the impact of the PIE on our customer service. Another commenter asked what the quality control process for PIE entails.

Response: We understand and share the commenter's desire for public transparency. We intend to conduct PIE rollout in phases, so that we can study its effects before full implementation and ensure our program complies with all applicable authorities. We will continue to evaluate these questions and information as we implement PIE. We currently publish a number of reports. However, we do not anticipate that a new, dedicated PIE report will be necessary. The most salient information is contained in reports that we already issue. For example, we include information related to wage and earnings overpayments in the Agency Financial Report.^[70] We anticipate that the reports we issue will be sufficient to publicly track the most important issues.

Overpayments

Comment: Many commenters said that the agency should revise overpayment waiver policies and recommended options like finding individuals “without fault” for overpayments created by inaccurate or incomplete reporting from employers or the payroll data provider, and that these “without fault” overpayments should always be waived. One commenter stated policy changes such as these ensure that the efficiency gained from PIE does not result in “harm” to individuals who rely on our programs for their basic needs.

Several commenters said we should take waivers a step further. One commenter said if, at the time the overpayment is posted, the individual meets the “deemed to defeat the purpose” provision, then we should consider waiving the overpayment without requiring any action by the beneficiary. According to the commenter, this would “lower the burden on individuals, promote equity and fairness, and improve administrative efficiency.” Another commenter said we should incorporate into the final rule a provision allowing for automatic waiver of any overpayments caused by third-party reporting errors to eliminate the burden on the individual to request a waiver of the overpayment and staff time to process the waiver. Similarly, other commenters also said we should adopt a “liberal interpretation” of both “defeat the purpose of the act” and the “against equity and good conscious” provisions, and asserted that if an individual is overpaid because of reliance on the data exchange program, even after we advised them that reporting is no longer required, then “equity is not served and some aspects of the purpose of the act are defeated.” Another commenter said that any time an individual questions an overpayment caused by inaccurate reporting from a third party, we should initiate an administrative waiver review, without requiring the individual to complete SSA Form 632 (Request for Waiver of Overpayment Recovery) or to undergo any similar administrative burden.

In contrast, a separate commenter stated that, because a “without fault” determination results in “writing off of ( print page 107251) the beneficiary's obligation to repay mistakenly received funds,” it is contrary to our stewardship responsibilities. The commenter also stated that it is an unnecessary incentive considering the high authorization rates that we are experiencing without that rule. The commenter asserted that it might be “fair” to presume “without fault” if the overpayment is discovered after a long period, for example, five or seven years.

Response: We appreciate the feedback from commenters on the “without fault” provisions in our overpayment recovery waiver policy. As stated previously, we take our program stewardship responsibilities seriously, and we strive to pay the right person the right amount at the right time. As explained in the NPRM, we sought these comments to help inform our consideration of possible clarifications to this aspect of our overpayment policy for individuals who participate in PIE. We agree with the commenter who stated that, if inaccurate data from the payroll data provider results in an overpayment and the overpaid individual asks us to waive recovery of their overpayment, we should usually find the individual to be “without fault” in causing the overpayment under our existing regulations, and would therefore assess whether we can waive the overpayment based on our existing overpayment procedures.^[71] However, there is no legal basis for simply dismissing repayment of the overpayment in all circumstances as the commenter further suggests. We are also considering the commenters' other suggested changes as part of a comprehensive review of overpayment policies.

Earnings Considerations, Including Work Incentives and Sick, Vacation, and Bonus Compensation

Comment: Some commenters questioned how payroll data will distinguish between paid hours that count toward SGA and those that do not. Specifically, commenters asked if the payroll data system will distinguish pay that represents bonus, sick, vacation, and holiday pay. They said that, without this differentiation, it is not clear how we will accurately determine SGA.

Multiple commenters stated concerns about addressing work incentives in the context of PIE and asked how we will integrate work incentives into the process. Commenters said individuals will continue to be burdened with reporting work incentives and our staff will continue to be burdened with processing them. Some commenters suggested potential improvements, such as using mySocialSecurity as a platform for reporting both wages and work incentives. Another commenter stated that we should provide easy-to-understand information about impairment-related work expenses and subsidized work and this rulemaking could allow us to increase outreach to large employers about what subsidized work is and how it impacts individuals with disabilities who receive benefits from us. One commenter said, for SSI, we should analyze how to best integrate third-party payroll data reporting and individual reporting of work incentives, prior to making determinations resulting in an adverse action. For OASDI disability, the commenter stated that we should consider notifying individuals about trial work period (TWP) progress and when they enter the extended period of eligibility.

Response: We do not expect PIE to meaningfully improve our access to the type of detailed information sometimes needed to make accurate SGA determinations (such as distinguishing pay for actual work versus holiday or sick pay or providing details about subsidized work, accommodations, or impairment related work expenses). Prior to making an SGA decision, we will continue to request information about special pay (sick, vacation, etc.) and any work incentives (including subsidy) from the beneficiary on form SSA-821 (Work Activity Report).^[72] If the information impacts the SGA decision, we will request proof of the information before effectuating a decision. In addition, we send the beneficiary a Notice of Proposed Decision, which includes a chart of the monthly earnings amounts that we used in our review and offers the individual a chance to supply any additional evidence before we finalize the decision.

Likewise, PIE will not affect how individuals report impairment-related work expenses that we exclude from earned income under SSI. Individuals should still report to us if their earnings are used for impairment-related work expenses, or if the amount of impairment-related work expenses changes. If an individual has reported impairment-related work expenses that occur on a regular and continuing basis, the appropriate deduction from earnings will be included in payment calculations when we receive wage information through PIE.

We will continue to explore ways for individuals to report work incentive information to us, potentially through mySocialSecurity or other channels.

Various notices and publications contain information about our work incentives such as Working While Disabled: How We Can Help ^[73] and The Redbook.^[74] In addition, we are currently revising forms SSA-821 (Work Activity Report) and SSA-3033 (Work Activity Questionnaire) ^[75] for clarity about our work incentives. The planned revisions to form SSA-821 include descriptions of the various work incentives (like Impairment-Related Work Expenses), explain that we can deduct these items when making the SGA decisions, and provide examples of the work incentives. Form SSA-3033, The Employee Work Activity Questionnaire (OMB No. 0960-0483) collects information from the employer about subsidized work and special conditions given to the employee. We are updating this form so it explains how providing the information is beneficial to the employee, gives clear examples, and provides easier ways to calculate the information.

For OASDI, the Notice of Proposed Decision explains where an individual is in their TWP ^[76] and Extended Period of Eligibility (EPE).^[77] It includes a chart and labels the earnings as month one through nine of the TWP and indicates which earnings are SGA in the EPE.

Comment: One commenter expressed concerns about the “complexity and variance of data application.” A few commenters noted that, there are two different earnings considerations in using payroll data: (1) title II entitlement (OASDI disability), based on when wages are earned, and (2) title XVI payment amount (SSI), based on when wages are paid. The commenter said we should clearly explain how the two separate computations will be approached and asked if the data we receive will show both the date earned and the date paid.

Response: How we consider earnings depends on which program a person receives benefits from. For SSI determinations, we consider when wages are paid. The exchange will always provide the pay date and gross earnings for this determination. For OASDI disability, we consider when wages are earned. Section 825 of the BBA ^[78] simplifies post-entitlement SGA ( print page 107252) determinations by allowing us to presume earnings were earned in the month they were paid if more precise information is not available. Prior to applying this paid-versus-earned assumption, we evaluate any readily available evidence to determine when earnings were earned. Thus, we primarily use the pay period end date, and sometimes the pay period start date, to determine when wages were earned. The exchange will always provide a pay period end date; when the exchange does not include a pay period start date, our systems have incorporated logic to calculate one.

Comment: One commenter noted that the proposal states that the “pay period start date would have no discernible impact on benefit determinations” and will not be collected. The commenter stated that it is unclear if this statement includes post-entitlement determinations, and if it does, it is in direct conflict with POMS DI 10505.005, which states, “The Bipartisan Budget Act of 2015 simplifies post entitlement SGA determinations by allowing us to presume earnings were earned in the month they were paid. However, prior to applying this paid versus earned assumption, evaluate any readily available earnings verification sources and determine when earnings were earned.” ^[79] The commenter expressed concerns about the impact on title II beneficiaries if pay period start dates are ignored. Further, the commenter stated that documenting exactly when work is performed, along with any utilization of work incentives, is crucial for title II beneficiaries to accurately demonstrate whether they are engaging in SGA.

Response: For OASDI disability, we have the ability to use the pay period end date or start date to determine when wages were earned. However, we primarily use the pay period end date because we generally expect to receive more information about the end date. As a clarification, we collect the pay period start date when the payroll data provider supplies that information. When the exchange does not include the pay period start date, our systems have incorporated logic to calculate one. In addition, we will send form SSA-821 to the individual to develop more detailed information about the individual's work, including information relevant to work incentives. Also, we will send the individual a Notice of Proposed Decision which includes a monthly table of earnings that were used in making the decision and allows the individual to provide any additional information.

Internally Inconsistent Information

Comment: One commenter said that we made an error because our transfer estimates for implementation begin on October 7, 2023, but we published the NPRM on February 15, 2024.

Response: The actuarial estimates provided in the NPRM projected reductions in program costs as if PIE would have been implemented in October 2023. Actuarial estimates must make assumptions based on current facts to develop reasonable projections. While the effective date, as the commenter noted, could not actually occur in 2023, the estimates still provided a reasonable reference for individuals interested in the effects of PIE on our future costs and savings. We updated the projected effective date of the estimates in this final rule.

Comment: One commenter pointed to sections of the NPRM where we reported: (1) that SGA-related overpayments in the OASDI disability program, occurring predominately because individuals fail to report earnings in a timely manner, averaged $500 million a year; and (2) that individuals in this category were overpaid $1,163 million a year. The commenter asked which is correct and, in particular, which we used to estimate the savings to taxpayers. The commenter requested a more complete explanation and documentation of the savings estimate.

Response: The average of $500 million per year came from the FY2023 Agency Financial Report and relates to OASDI SGA errors.^[80] The average of $1,163 million per year comes from an internal study of SSI wage errors. We inadvertently mischaracterized this figure in the NPRM, and the NPRM should have referred to this as SSI wage-related overpayments. We regret any confusion.

Reconsideration Requests

Comment: Many commenters said we should allow individuals to request reconsideration orally. Commenters stated that obstacles such as insufficient internet access, field office delays, telephone delays, travel challenges, and communication barriers are reasons to accept reconsideration orally. Commenters asserted that language challenges further complicate the burden of making written requests, and accepting oral requests would allow us to comply with Federal laws requiring language access and disability accommodations.

Some commenters said we should ensure “adequate staffing” if we accept reconsiderations by phone and that our staff would need training to ensure that they would easily recognize stated requests for reconsideration. Other commenters suggested that we could find ways to automate the process. Commenters also expressed concerns about the documentation and processing of oral appeals. Some proposed that we provide a confirmation number (or similar proof) any time an individual requests an oral reconsideration request. Several commenters said that, if we allow such requests orally, we should accept a later attestation by the individual that they made an oral reconsideration request, without requiring further proof.

In contrast, one commenter asserted that, to ensure individuals' rights are protected, we should continue to require reconsideration requests in writing.

Response: We appreciate the feedback from commenters on accepting oral reconsideration requests. Commenters noted they find our current requirement for a written reconsideration request to be burdensome for some claimants and their representatives. As an agency that values customer experience and considers administrative burden reduction on the public to be an important priority, we appreciate the feedback and plan to seriously consider this proposal. Our ultimate goal is to achieve a balance between reducing burden to the extent possible, while ensuring the consistency and integrity of our processes. Further exploration of this proposal requires a review of multiple agency processes in which an appeal is involved, and would also entail seeking more fulsome feedback from the public on this issue specifically. At the present time as noted in the NPRM, we are not making any changes to the appeals filing process. Our regulations for both title II and title XVI require that the party seeking reconsideration file a written request.^[81] Whether we should amend these regulations to accept oral reconsideration requests requires consideration of all the contexts in which they arise, not just the sub-set of reconsideration requests that appeal an initial determination of income based ( print page 107253) on PIE data. Accordingly, we did not intend this rulemaking to decide the complex issue of accepting oral reconsideration requests.^[82]

Comment: Several commenters said we should eliminate the reconsideration step for initial disability cases. One commenter said we never published an analysis of the efficacy of the reconsideration step, “despite a promise years ago to do so when evaluating the ten-state disability adjudication prototype experiment.”

Another commenter stated that requiring reconsideration after an initial denial “depletes SSA resources and significantly burdens claimants without improving the accuracy of disability determinations.” The commenter said the agency could expand existing sub-regulatory guidance on informal remands, which already permits additional review from Disability Determination Services staff in cases where new evidence or certain other circumstances warrant an additional level of review before a hearing.

Response: We appreciate the comments received but they are outside the scope of this final rule.

Systems Questions

Comment: One commenter asked what system would support the data exchange to upload the monthly verification.

Response: We first verify that the data are complete and in the right format. The data are then stored in a centralized repository before they are moved to the appropriate title II and title XVI systems where the data are automated to beneficiary and recipient records or flagged for technician review.

Comment: A commenter asked how employees will handle the new workload for exceptions and failed submissions.

Response: Our OASDI work review system will send wage alerts when incoming PIE data is incomplete, due to such issues as missing pay period start date information. When this happens, the alert will guide our technicians to manually query sources of earnings (including PIE) to determine if the individual has substantial earnings. All work reviews require manual review of earnings prior to effectuating a determination. Similarly, our SSI systems will create a diary to be worked by a technician when we do not have an Employer Identification Number (EIN) match for an individual who has already reported an employer/EIN to us. Once the technician confirms the incoming employment, future PIE wages will automate to the recipient's record for that employer. Any name mismatch cases (where the name and SSN do not match) will not go downstream to any application.

Comment: A commenter asked what percentage of liability the representative payee, deemor, essential person, and claimant have regarding wages.

Response: When the representative payee, beneficiary, recipient, or claimant receives a PIE reporting responsibilities notice, they would not have to report wages monthly, and they would not be considered “at fault” for any inaccuracies. All SSI recipients (or their representative payees) are responsible for reporting their wages as well as the wages of any deemors or essential persons.^[83] In any event, we are not changing who is responsible for making required reports.

Comment: A commenter asked if individuals have to report initial work to update the Consolidated Claims Experience (CCE).^[84]

Response: Yes, we continue to require individuals to report a change in employment, including new employment.

Comment: A commenter asked if the Retrospective Monthly Accounting (RMA) cycle will remain in effect.^[85]

Response: Yes, normal RMA accounting rules will still apply.

Comment: A commenter asked if employers report wages monthly or quarterly.

Response: We will receive wages that are readily available to the payroll data provider at the time of our monthly information exchange regardless of how often the employer provides that data to them.

Comment: A commenter asked if the report will be delayed.

Response: We are not certain what the commenter means by “the report.” We expect to receive the information through PIE prior to the GK payment continuation cutoff date in a given month to ensure we receive the data in time to determine an individual's eligibility or payment amount.

Comment: A commenter asked if there will be an overpayment if this program works.

Response: While we anticipate PIE will lead to more accurate and timely payments, it cannot eliminate overpayments and underpayments altogether for a variety of reasons, some of which may be that not everyone will opt in, not all employers are covered, and there will still be cases where manual actions are necessary.

Comment: A commenter asked if the system will understand pre-tax deductions.

Response: PIE data only includes employer wage data. Calculations are based on gross wages, not on net pay.

Comment: A commenter asked if counting the net and removing the wage exclusion provision would “change the game” as more individuals become eligible for benefits.

Response: Laws and regulations govern how we count earned income and what we can exclude from income counting. Changes to income counting are outside of the scope of this rule.

Comment: One commenter asked how we will rectify duplicate reporting, particularly with the EIN or corporate name reported in the data exchange and the “doing business as” (DBA) name on paystubs with an individual continuing to manually report.

Response: We will receive the DBA name on the incoming wage and employment information from the payroll data provider through PIE and will prioritize PIE information over other reporting methods, unless manually adjusted by one of our technicians.

Comment: A commenter asked if there is a plan to address benefits received under a cross referenced number ( e.g., a parent).

Response: Yes, PIE data is based on the individual's own SSN, so their wages for SSI or OASDI disability will be posted to their record with any cross-referenced SSNs.

Other Public Comments

Comment: One commenter requested information about how PIE implementation will increase efficiency. The commenter asked: (1) Is there data showing how much time is saved or how much greater accuracy is achieved by this process? (2) If time is saved, how much and in which components? (3) What benefits might be realized by redirecting this saved time toward other workloads? (4) Are there any critical workloads that would be addressed because of such savings? and (5) How might this benefit individuals in general?

Response: PIE will increase efficiency by allowing our systems to receive and automate wage and employment information timely. Timely receipt of this information allows us to administer ( print page 107254) the OASDI disability and SSI programs more efficiently, as well as reduce improper payments, because we will receive the information sooner and will process it quicker when the information automates for SSI and when the information alerts us to wages sooner for OASDI disability. This also creates administrative efficiencies because it reduces the time our technicians would otherwise use to verify wages.^[86] In our NPRM, we anticipated some administrative savings from a shorter wage development process in affected cases during SSI pre-effectuation reviews, redeterminations, post-eligibility actions, and overpayments, as well as during OASDI disability work continuing disability reviews. However, we do not attempt to quantify these time savings. As we explained in the NPRM, under our current process, we sometimes conduct a manual query to request records from payroll data providers or employers. We estimate we would save approximately 20 minutes of our staff's time each time we no longer need to complete this query.^[87]

We expect that our Operations components would realize these time savings and could redirect this time toward other critical workloads. In addition to the benefits identified elsewhere in this rule ( e.g., reduced burden on individuals), we anticipate others may benefit if we are able to initiate work on their cases sooner because of the time savings PIE will afford staff.

Comment: One commenter said the public must have the “maximal ability” to understand the technology we will use to implement PIE before we implement it, including how it works, potential problem points, plans to work through such problem points, plans to identify and fix unanticipated and anticipated problems, and ways to revert to “non-automated” means in the event that the system produces widespread inaccuracies or other problems. The commenter said this information should be posted publicly, and we should consider engaging individuals and their advocates in system design, and we should support individuals to enable them to meaningfully participate.

Response: While we are unable to share sensitive information for security reasons, we will publish procedures describing the process for requesting and receiving wage and employment information from a payroll data provider through an information exchange. In the unlikely event the system produces “unanticipated problems,” we can, as always, accept alternative wage evidence ( e.g., pay stubs) from the wage reporter.

Comment: One commenter asserted that adding the penalty of ineligibility will create a potentially “insurmountable barrier to employment” for individuals. The commenter said that individuals consistently report that “fear of prematurely losing their benefits is a primary reason they are reluctant to try working,” and work incentives planners spend “countless hours” reassuring them that they will not lose their benefits just because they return to work. The commenter stated we must remove the language about the penalty of ineligibility related to wage reporting mistakes because these rules create “new and extreme penalties.”

Response: Neither the BBA nor the NPRM propose new penalties of any kind. Nor does this final rule. Rather, the BBA and this final rule create protections from some existing penalties for individuals. As we explained in the NPRM, we may not subject individuals to certain penalties related to reporting if they authorize us to obtain information from a payroll data provider.^[88] For example, when an individual is reporting wages to us currently, and they omit material facts related to the wage data they report, we can, under 1129A of the Act, stop their benefits. However, if we are receiving wage data from a payroll data provider under the PIE program, we will not stop the individual's benefits because of any errors made in reporting by the payroll data provider. This will alleviate some of the “fear” the commentator described currently associated with having to report wage data to us directly.

However, in reviewing the CFR text we understand that as written in the NPRM it might not clearly reflect the explanation provided in the preamble. Accordingly, we have rewritten the CFR text.

Comment: One commenter asserted that our proposal would impose a financial burden on payroll companies, particularly small businesses. The commenter said that payroll reporting to us and IRS is already “more difficult and time-consuming than it needs to be.” According to the commenter, small businesses are “drowning in federal, state and local government regulations,” and if we require reporting, we should reimburse payroll companies for the cost.

Response: This rule and the implementation of PIE will not impose burdens on payroll companies, including small businesses, because we are not requiring, nor requesting, they change reporting or any other aspects of their business processes. Rather, we are working with a payroll data provider that already receives information from employers, and that payroll data provider (that is under a contract with us) will provide that information to us directly.

Comment: One commenter said we should not obtain information without working with the employer to request information. They stated this proposal is an overreach that should not be pursued. According to the commenter, irregularities can present an “opportunity to interact with an employer to request additional information.” Further, the commenter said every employer has the right to oversee their own payroll service, without having them “work for the government.”

Response: We are not mandating any employers to “work for the government,” nor do we have the authority to do so. Rather, we have exercised the authority in the BBA to enter into an information exchange arrangement with a payroll data provider. We will work directly with our contracted payroll data provider who has willingly entered into an information exchange with us.

To the extent this comment applies to individual employees, anyone who does not want us to obtain their information from our payroll data provider may decide not to provide authorization or may revoke their authorization at any time. We will not obtain payroll data provider information without authorization and the individual can continue to submit their information to us directly.

Comment: One commenter referred to our policy that extends the time period for individuals to request benefit continuation from 10 to 60 days pursuant to the settlement agreement in Amin v. Kijakazi.^[89] The commenter ( print page 107255) stated that we should formalize this policy through rulemaking, updating POMS, and communicating the modified policy to our staff prior to finalizing the payroll data rule.

Response: We would like to emphasize that, in accordance with the settlement agreement in the referenced litigation, we already use this policy in practice. Codifying the policy into regulations is out of the scope of this final rule.

Comment: One commenter said SSI or SSDI “navigators” or case managers could help streamline the current wage reporting process and reduce the administrative burden on individuals. According to the commenter, the use of navigators can also improve the accessibility of current reporting options. Further, the commenter said, if multiple individuals request assistance for a recurring accessibility issue, navigators or case managers can review these reporting methods and bring accessibility concerns to the appropriate person or team at the SSA.

Response: While we are unsure precisely who the commenter intended when referencing “navigators” and “case managers” in the SSA context, we clarify that our technicians will be available to help individuals with their PIE-related questions and we will publish policy describing the process for requesting and receiving wage and employment information from a payroll data provider through an information exchange. For any concerns or questions about accessibility, please visit https://www.ssa.gov/​accessibility/​504_​overview.html. Our notices also advise members of the public that they can contact us through our 800 number with additional questions or requests for guidance.

Comment: One commenter expressed that individuals would benefit from “well-considered policy and implementation choices that guarantee full access and do not discriminate.” The commenter said, among other ideas, we can consider implementing a “clear process that informs people that reasonable accommodations are available, recognizes requests, and acts on them quickly and appropriately.”

Response: We comply with relevant and applicable anti-discrimination policies and laws, including section 504 of the Rehabilitation Act and its reasonable accommodation requirements. As part of this final rule, we are not revising our obligations under section 504, including our reasonable accommodation process, or our language support for the public. For more information about those policies, please visit https://www.ssa.gov/​accessibility/​504_​overview.html and https://www.ssa.gov/​site/​languages/​en/​.

Comment: One commenter said, to ensure that the “automated wage reporting does not simply replace monthly income reports required of recipients with monthly notices that prompt them to call,” we could consider building in “tolerances” for income fluctuations so small changes in benefit amounts do not trigger notices for a certain period of time. The commenter suggested that we could consider couching these as small overpayments and use existing waiver authority to waive them.

Relatedly, the commenter also suggested that we could average wage income over a set span of time ( e.g., three or six months), make one determination about benefit amounts for the next span, send one notice for that span, and allow recipients to present evidence if they believe we should adjust their benefit amount. The commenter asserted that recipients would benefit most from simplified benefit calculations and fewer notices.

Response: This suggestion is not within the scope of this final rule. Nevertheless, we will continue to evaluate our processes on an ongoing basis, looking for opportunities to provide enhancements and improvements that reduce burdens for our customers or increase agency efficiency and that provide effective program stewardship.

Comment: One commenter proposed that we eliminate the complex rules and make the program simpler for recipients to navigate.

Response: We appreciate this comment and always look for ways to simplify our programs. We anticipate that implementation of PIE will make one part of the SSI and OASDI disability process (wage reporting) simpler for most individuals who provide authorization for us to receive their wages through PIE.

Comment: Commenters brought up a variety of other issues not directly related to the proposal. For example, one commenter asserted that people cannot live on SSI alone and they deserve at least $2,500 a month to survive. Another commenter questioned whether the States should have a bigger role in managing Social Security. Other commenters raised issues about personal loans or changes in qualifying for disability. An additional commenter expressed that we may be able to use PIE data to establish insured status for applicants.

Response: While we appreciate these suggestions, they are outside the scope of this rulemaking.

Rulemaking Analyses and Notices

Regulatory Procedures

E.O. 12866 as Supplemented by E.O. 13563 and Amended by E.O. 14094

We consulted with the Office of Management and Budget (OMB) and OMB has determined that this final rule meets the criteria for a section 3(f)(1) significant regulatory action under E.O. 12866, as supplemented by E.O. 13563 and amended by E.O. 14094 and is subject to OMB review.

Assumptions

We estimate that, by 2034, 98 percent of SSI recipients will have provided an active authorization as of that time allowing us to obtain this information from payroll data providers through information exchanges, and about 87 percent of disabled OASDI beneficiaries will have also provided this authorization.^[90] We base this estimate on current rates of adoption as we have sought authorization from beneficiaries during both new enrollment and disability review processes since late 2017. Since 2017, about 98 percent of OASDI disability beneficiaries and SSI recipients who have been asked have provided authorization—this corresponds to about 35 percent of all current OASDI disability beneficiaries as of the end of fiscal year 2024. As of July 2024, 64 percent of all current SSI recipients and 72 percent of SSI deemors have provided an active authorization as of that time.^[91]

We estimate that there are about 1,100,000 OASDI disability beneficiaries, between 200,000 and 300,000 SSI recipients, and another 500,000 to 600,000 deemors of SSI recipients who work in a given year. Because employers representing approximately two-thirds of the non-farm workforce provide payroll data to Equifax, and we will be able to receive payroll data from Equifax for anyone who has authorized us to do so, we expect individuals will submit fewer wage reports to us.^[92]

( print page 107256)

Additionally, we estimate that there are about 100,000 OASDI disability beneficiaries who are overpaid due to working at or above the SGA level. Based on the most recent data available, over FYs 2019 through 2023, these individuals were overpaid an annual average of $729 million. We estimate that, through the information exchange, we will be able to identify both wages we otherwise would not have known about, as well as wages that will be identified timelier than under current processes. Additionally, we estimate that we will identify and assess approximately an additional 10 percent of overpayments due to working at or above SGA (OASDI) or having wages from employment (SSI) which we would likely not have assessed through our current processes.^[93]

Anticipated Costs to the Public

As discussed in the NPRM, there are minor costs to the public associated with this rulemaking.^[94] For example, individuals who apply for or are receiving OASDI disability, individuals who apply for or are receiving SSI, and SSI deemors, will need to spend a minimal amount of time to complete the authorization to allow us to obtain wage and employment information from payroll data providers through an information exchange. As another example, there is a potential burden on the public to correct any inaccurate data reported to us from a payroll data provider if an individual identifies an error in the information we receive through an information exchange. See the NPRM for more explanation.^[95]

Anticipated Benefit to the Public

As discussed in the NPRM,^[96] an information exchange has many benefits. For example, it will reduce wage reporting responsibilities for some individuals. PIE would also help us obtain timelier wage and employment information, which we anticipate will also help us reduce improper payments, which is a potential source of confusion for the public and may cause individuals to spend time addressing errors associated with improper payments or filing appeals or waiver requests. See the NPRM for more explanation.^[97]

Anticipated Transfers to Our Program

Our Office of the Chief Actuary estimates that implementation of this proposed rule would result in a total net reduction in OASDI benefit payments of $1.1 billion ^[98] and a total net reduction in Federal SSI payments of $1.8 billion over fiscal years 2025 through 2034. The estimates assume implementation of this rule on March 11, 2025, and that SSA will not, during the estimate period, contract with any other payroll data provider beyond Equifax. We note that the increase in the amount of overpayments identified or prevented in this period would be larger than the reduction in actual benefits paid in this period. First, regarding overpayments newly identified, as discussed in our Assumptions section, these estimates assume that 50 percent of work-related overpayments identified for OASDI beneficiaries and 80 percent of earned-income related overpayments for SSI recipients will be recovered within 10 years after they are identified. Thus, much of the overpayments newly identified, especially those identified late in this 10-year period, will be only partially recovered with subsequent reductions in payments through fiscal year 2034. Second, while potential overpayments that would be prevented due to implementation of this rule will immediately reduce benefit payments, such early identification of earnings will also avoid subsequent potential overpayments through fiscal year 2034 and beyond.

Anticipated Administrative Costs to the Social Security Administration

The Office of Budget, Finance, and Management estimates that this proposal will result in a net administrative cost of $846 million for the 10-year period from FY 2025 to FY 2034. The net administrative cost is mainly a result of the contract and IT costs to administer the information exchange. The total costs are offset by some administrative savings from a shorter wage development process in affected cases during Title XVI pre-effectuation reviews, redeterminations, post-eligibility actions, and overpayments, as well as during Title II work continuing disability reviews.

Congressional Review Act

Pursuant to the Congressional Review Act (5 U.S.C. 801 et seq.), the Office of Information and Regulatory Affairs designated this rule as meeting the criteria in 5 U.S.C. 804(2).

Executive Order 13132 (Federalism)

We analyzed this final rule in accordance with the principles and criteria established by Executive Order 13132 and determined that the final rule will not have sufficient Federalism implications to warrant the preparation of a Federalism assessment. We also determined that this final rule will not preempt any State law or State regulation or affect the States' abilities to discharge traditional State governmental functions.

Regulatory Flexibility Act

We certify that this final rule will not have a significant economic impact on a substantial number of small entities because it primarily affects individuals. In some instances, this final rule may reduce the burden on employers because we may need to contact employers for information less frequently when we receive wage and employment information from payroll data providers through an information exchange. Because our contact with employers for this reason is limited now, we do not expect a significant difference. Therefore, a regulatory flexibility analysis is not required under the Regulatory Flexibility Act, as amended. We discuss the time burden savings for employers stemming from this final rule in the Paperwork Reduction Act section of the preamble.

Paperwork Reduction Act Statement

SSA already has existing OMB approved information collection tools relating to this proposed rule: the Letter to Employer Requesting Information About Wages Earned by Beneficiary ( print page 107257) (SSA-L725, OMB Control No. 0960-0034); Letter to Employer Requesting Wage Information (SSA-L4201, OMB Control No. 0960-0138); Monthly SSI Wage Reporting (SSA's Mobile Wage Reporting, Telephone Wage Reporting, and internet myWage Report application, OMB Control No. 0960-0715); the Authorization for the Social Security Administration to Obtain Wage and Employment Information from Payroll Data Providers (Form SSA-8240, OMB Control No. 0960-0807); and the Notice to Electronic Information Exchange Partners to Provide Contractor List (SSA-731, OMB Control No. 0960-0820). While we previously obtained OMB approval for the new form (under OMB Control No. 0960-0807) to collect the authorization for the wage and employment information from payroll providers, SSA has not utilized this information through an automated exchange, because those exchanges have not, yet gone live. The final rule provides additional information on OASDI and SSI reduced reporting requirements, as well as the effects of beneficiaries, recipients, and deemors authorizing us to obtain records from payroll data providers. In addition, the final rule describes the establishment of the requirements to enter into an information exchange with payroll data providers. SSA established the information collection for the Authorization for the Social Security Administration to Obtain Wage and Employment Information from Payroll Data Providers (0960-0807) prior to the creation of this new rule. We will include the appropriate CFR citations under that OMB approved information collection upon publication of the final rule. In addition, we will obtain OMB approval for revisions to the collection instruments as needed 30 days after publication of the final rule. Finally, the implementation of this final rule will decrease the time burden for the public, as it removes the need for individuals or employers to submit wages to SSA when we receive them through payroll data providers through an information exchange instead. While we acknowledge that there is a burden on the public for 20 CFR 422.150(a)(3), we did not include it in the chart below because fewer than 10 providers submit this information to SSA. The following chart shows the anticipated burden reduction due to the other regulatory requirements from this rule:

OMB #; Form #; CFR citations	Number of respondents	Frequency of response	Current average burden per response (minutes)	Current estimated total burden (hours)	Anticipated new number of respondents under regulation	Anticipated new burden per response under regulation (minutes)	Anticipated estimated total burden under regulation (hours)	Estimated burden savings (hours)
0960-0034—SSA-L725	170,000	1	40	113,333	170,000	40	113,333	* 0
0960-0138—SSA-L4201	133,000	1	30	66,500	133,000	30	66,500	* 0
0960-0715—Mobile Wage reporting 404.703(a), 416.708(c), 416.709 (new)	88,382	12	6	106,058	36,237	6	43,484	62,574
0960-0715—Telephone Wage reporting 404.703(a), 416.708(c), 416.709 (new)	16,341	12	5	16,341	6,700	5	6,700	9,641
0960-0715—myWage Report 404.703(a), 416.708(c), 416.709 (new)	3,557	12	7	4,980	1,458	7	2,041	** 2,939
0960-0807—SSA-8240, 404.703(b), 404.1588(a), 404.1588(b)(3)(iii), 404.1588(b)(4), 416.988(a)	150,000	1	8	20,000	150,000	8	20,000	* 0
0960-0807—MCS/SSI Claim System 404.703(b), 404.1588(a), 404.1588(b)(3)(iii), 404.1588(b)(4), 416.988(a)	697,580	1	3	34,879	697,580	3	34,879	* 0
0960-0807—Internet 404.703(b), 404.1588(a), 404.1588(b)(3)(iii), 404.1588(b)(4), 416.988(a)	147,820	1	3	7,391	147,820	3	7,391	* 0
Totals	1,406,680			369,482	1,342,795		294,328	75,154
* This final rule will not significantly affect the burden for this information collection; therefore, we do not anticipate any burden reduction for this information collection due to the implementation of this rule.
** SSA is providing this figure as a current best estimate for burden reduction under this final rule. We will not have accurate data until we implement the rule.

The following chart shows the reduction in theoretical cost burdens associated with the rule:

OMB #; Form #; CFR citations	Anticipated new number of respondents	Estimated burden per response from chart above (minutes)	Anticipated estimated total burden under regulation (hours)	Average theoretical hourly cost amount (dollars) *	Average combined wait time in field office and/or teleservice centers (minutes) **	Anticipated annual opportunity cost (dollars) ***
0960-0034—SSA-L725	170,000	40	113,333	* $26.29	0	*** $2,979,525
0960-0138—SSA-L4201	133,000	30	66,500	* 26.29	0	*** 1,784,285
0960-0715—Mobile Wage reporting, 404.703(a), 416.708(c), 416.709 (new)	36,237	6	43,484	* 22.39	0	*** 973,607
0960-0715—Telephone Wage reporting, 404.703(a), 416.708(c), 416.709 (new)	6,700	5	6,700	* 22.39	0	*** 150,013
0960-0715—myWage Report, 404.703(a), 416.708(c), 416.709 (new)	1,458	7	2,041	* 22.39	0	*** 45,698
0960-0807—SSA-8240, 404.703(b), 404.1588(a), 404.1588(b)(3)(iii), 404.1588(b)(4), 416.988(a)	150,000	8	20,000	* 22.39	** 24	*** 1,791,200
0960-0807—MCS/SSI Claim System, 404.703(b), 404.1588(a), 404.1588(b)(3)(iii), 404.1588(b)(4), 416.988(a)	697,580	3	34,879	* 22.39	** 21	*** 6,247,526
( print page 107258)
0960-0807—Internet, 404.703(b), 404.1588(a), 404.1588(b)(3)(iii), 404.1588(b)(4), 416.988(a)	147,820	3	7,391	* 22.39	** 21	*** 1,323,876
Totals	1,342,795		294,328			*** 15,295,730
* We based this figure on the average Payroll and Timekeeping Clerks hourly salary, as reported by the Bureau of Labor Statistics data ( https://www.bls.gov/​oes/​current/​oes433051.htm); as well as the averaging of DI payments based on SSA's current FY 2024 data ( https://www.ssa.gov/​legislation/​2023factsheet.pdf) and the average U.S. citizen's hourly salary, as reported by Bureau of Labor Statistics data ( https://www.bls.gov/​oes/​current/​oes_​nat.htm).
** We based this figure on the average FY 2024 wait times for field offices and hearings office, as well as by averaging both the average FY 2024 wait times for field offices and teleservice centers, based on SSA's current management information data.
*** This figure does not represent actual costs that SSA is imposing on recipients of Social Security payments to complete this application; rather, these are theoretical opportunity costs for the additional time respondents will spend to complete the application. There is no actual charge to respondents to complete the application.