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May 9, 2008 The Honorable Dear Representative: Proposals, such as those in H.R. 4088, to require employers to authenticate employment eligibility through the Employment Eligibility Verification System (EEVS, sometimes called “e-verify”), would have tragic unintended consequences for people with severe disabilities. Mandatory use of the EEVS system would overwhelm the Social Security Administration (SSA) and threaten its ability to fulfill its core duties of serving retirees, survivors, dependents, and people with disabilities under the Title II and Title XVI programs. The cash benefits provided under Title II and Title XVI, along with the related Medicaid and Medicare benefits, are the means of survival for millions of individuals with severe disabilities. The Consortium for Citizens with Disabilities (CCD) is a working coalition of national consumer, advocacy, provider, and professional organizations working together with and on behalf of the 54 million children and adults with disabilities and their families living in the United States. The CCD Social Security Task Force focuses on disability policy issues in the Title II and Title XVI disability programs. Even now, people with disabilities are already paying a terrible price for the persistent and cumulative under-funding of SSA’s administrative expenses. Processing times for disability applications have increased dramatically, with over 750,000 people with severe disabilities now waiting an average of over 550 days (much more in some offices) for a hearing decision on their applications. Lives of applicants have unraveled while waiting for decisions – families are torn apart; homes are lost; medical conditions deteriorate; once stable financial security crumbles; and many individuals die. Social Security Commissioner Michael Astrue has called it “a moral imperative” to reduce these backlogs. If this EEVS mandate were imposed, the disability application backlog – and the impact on claimants with disabilities – would become much worse. In addition, SSA workloads have increased in recent years as new duties were imposed (e.g., Medicare Part D) without adequate appropriations to fully implement the changes. To make matters worse, staffing has decreased to the lowest level in more than 30 years. Even without a new EEVS mandate, SSA estimates that in FY 2009, it will have a deficit of at least 8,100 full time staff just to return to FY 2007 service staffing levels. Given the current SSA workload situation, matters can be expected to worsen dramatically if the EEVS mandate is imposed. For example, it is estimated that over 6 million employers will be required to use it to check on eligibility of employees, compared to the 53,000 employers who currently use the existing EEVS pilot program jointly run by SSA and the Department of Homeland Security. In addition to administering these additional screenings, SSA would be required to deal with the fallout of mismatches and other problems flagged by these screenings. Under the current system, which deals with less than 10 percent of the number of employers compared to an EEVS mandate, there are many mismatches resulting from errors in the SSA database. According to the SSA Inspector General, the database has a 4.1% inaccuracy rate which would be approximately 17.8 million records. The vast majority of workers affected would be United States citizens. As a result of being wrongly flagged, they would need to document their legal status or risk losing their jobs. SSA testified last year that under a national EEVS system, 6 of every 100 workers would need to visit an SSA office in person to correct their records or lose their jobs – which would result in an estimated 3.6 million extra visits per year to SSA offices. In addition, if H.R. 4088 is enacted, over 45 million people who hold more than one job in a year will need to visit an SSA field office every year in order prove they earned the income reported on their W-2 forms. Otherwise, they will lose credit for their earnings and their future benefits will be reduced. The cost for SSA to implement a mandatory EEVS program is enormous, and it comes at a time when SSA is attempting to handle increased workloads (such as retirement of the baby boomers) and decreased staffing. For H.R. 4088, the Congressional Budget Office (CBO) has estimated the cost to SSA alone at over $12 billion over 10 years. This cost would be in addition to $11 billion to other federal agencies and $17 billion in lost revenues to the Social Security trust funds. In the unlikely event that Congress were to fully fund this cost, it would still take SSA years to hire and train at least hundreds of new staff, procure additional office and storage space, and develop systems to handle this burden. On behalf of the undersigned members of the Consortium for Citizens with Disabilities, we urge you to oppose an EEVS mandate in any legislation that would result in an avalanche of additional administrative burdens on SSA. If such a mandate were imposed, the delays for decisions on disability applications would increase dramatically and SSA’s ability to provide other critical services would be greatly diminished, with tragic consequences for people with serious disabilities. Sincerely, Marty Ford Peggy Hathaway United Spinal Association Susan Prokop Paul Seifert Ethel Zelenske National Organization of Social Security Claimants' Representatives Co-Chairs, Social Security Task Force ON BEHALF OF: ADAP Advocacy Association
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