Research indicates that in-kind support and maintenance (ISM) computations significantly complicate SSI program administration and lead to over and underpayments. The Board suggests a thorough reexamination of how SSI is administered, including how benefits are adjusted for ISM.
Any simplifications of the SSI program should be undertaken with caution and well-designed analysis. A plan for data collection, research design, and selection of testing sites should be an integral part of any implementation plan. Given the financial vulnerability of the population served and the cost of the SSI program, it is crucial that SSA undertake any simplification testing with care. In addition, Congress needs to decide whether the agency time spent on case management and oversight is a job function that should rest with SSA field office staff. Collecting and verifying information to determine whether there is in-kind support at the application stage is time-consuming, and having to continue making that assessment is burdensome for both the agency and the SSI recipient, who must maintain constant communication with the agency. Finally, the agency needs to investigate the causes of a recent upward trend in improper underpayments while continuing to avoid overpayments.
The Statement is included in SSA’s 2015 Annual Report on the SSI Program. The Personal Responsibility and Work Opportunity Act of 1996 gives Board members the opportunity, individually or jointly, to include their views on SSI in SSA’s annual report to the President and Congress on the Supplemental Security Income (SSI) program. The Board or one of its members has submitted a statement every year since 1998, except for 2024 due to the lack of a quorum.