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6118 Federal Register / Vol. 62, No. 28 / Tuesday, February 11, 1997 / Rules and RegulationsThis will make it more difficult for SSAto get caught up with its work.Response: In cycling benefitpayments, SSA’s objective is to improvepublic service by reducing theinordinate workload peak that nowoccurs when all payments are deliveredat the beginning of the month. Byleveling SSA’s workload, the public willbe able to get a consistent level ofquality service at any time of the month.It is true that eventually paymentcycling will have an effect upon SSA’sworkforce. Employees may receive moretelephone inquiries and field officecontacts in the last 2 weeks of themonth than occur today. Again, this isthe purpose of payment cycling. Byleveling workloads, the public is betterserved because it consistently has betteraccess to SSA services. At the sametime, SSA is in a position to make betteruse of its available resources.Comment: The same commenter wasconcerned that there will be additionalwork and expense for SSA becausesomeone who now receives two types ofbenefits (one on his/her own record andone on a spouse’s record) will nowreceive two checks. Receiving one checklater in the month will cause morepeople to call with inquiries aboutreceipt of the second check. This willalso cost SSA more (i.e., the costsassociated with disbursing two checks).Response: SSA’s intent is to pay eachentitled beneficiary all monies due onone day regardless of whether they aredually entitled on their own workrecord and that of a spouse. Forexample, a woman who receivesbenefits on her husband’s record, but isalso entitled on her own work record,would receive benefits on the paymentdate assigned based on her birth date.On that date, she would receive apayment reflecting the combinedamount of her own benefits and theexcess due for the ‘‘wife’s benefit.’’Comment: This same commenter wasconcerned that payment cycling is morefavorable to someone whose birthday isearlier in the month. Some people willnot receive their payment until 3 or 4weeks after the month for which theyare due, whereas someone whosepayment is not cycled receives it only3 days after the month for which it isdue.Response: There are two issuesmentioned. First, it is true that in usingthe method of cycling based on birthdates, individuals born early in themonth receive their benefits earlier eachmonth. But any formula designed toevenly distribute future beneficiaries’payments throughout the month (e.g.,using the last 2 digits of a person’ssocial security number) will produce thesame result. The birth date formula wasunanimously favored by members of thepublic who participated in SSA’s focusgroups in that it was the easiest for themto relate to and understand.Second, this raises an issue ofperception. Beneficiaries who are paidon the second, third and fourthWednesdays of the month for theprevious month’s entitlement mayperceive that they are not receiving thesame level of service as someone who ispaid on the 3rd of the month. This wasnot an issue that concerned participantsin SSA’s focus groups. Theseindividuals indicated that because theyhad not yet begun receiving SocialSecurity benefits, it was not of concernwhether their future benefits were paidon the 3rd of the month or on thesecond, third or fourth Wednesdaysbecause once their payments start, theywould be paid consistently at the samemonthly interval. Further, these samefocus group participants recognized thatunless SSA did something to levelworkloads that now occur at thebeginning of the month, their ability tofile a claim, have a question answeredor otherwise receive prompt service wasbeing jeopardized as the Agency’sworkloads increased.Comment: The above commenter alsobelieved it is unfair to pay SSIrecipients and OASDI beneficiaries whoqualify for Qualified MedicareBeneficiary (QMB) payments early inthe month while paying all other OASDIbeneficiaries later in the month,particularly since some of these OASDIbeneficiaries miss qualifying for SSI bya small amount. In a similar vein,another commenter recommended thattwo additional groups of individuals beexcluded from payment cycling: thoseliving below 200% of the poverty leveland those who would face ‘‘unduehardship’’ if they received their benefitsafter the 3rd of the month.Response: SSA can readily identifySSI recipients as those individuals oflimited means. Accordingly, we willexempt anyone who receives SSI fromhaving their payment cycled. However,we have no information relating to theeconomic circumstances of anyonereceiving OASDI benefits to enable us todetermine who is of limited means.Even if we did, we would have toestablish a benchmark at some level.Whatever benchmark SSA established,there would be individuals who fall justbelow the mark and those who fall justabove the mark. Therefore, we continueto believe that the use of the SSI meanstest is appropriate from both a policyand operational perspective.We do not believe that creatingadditional criteria for an ‘‘unduehardship’’ test is necessary. Indeed,people who otherwise would have beenpaid on the 3rd of the month will nowbe paid later in the month as a result ofpayment cycling. However, we believethe improved access to SSA’s servicesfor all beneficiaries and customers, aswell as the benefits to the banking andbusiness community which will enablethem to provide better customer service,and the reduction of the risk involvedin processing large once-a-month filesoutweigh the effects of being paid laterin the month. Moreover, as mentionedby many of the focus group participants,individuals paid consistently on thesecond Wednesday of the month fromthe inception of their entitlement arereceiving the same level of service asindividuals paid on the 3rd of themonth from the inception of theirentitlement. In addition, already limitedSSA staff and resources would have tobe assigned to administer an ‘‘unduehardship’’ test.Comment: One commenter thoughtSSA should assign the payment day forcycled payments based on somethingother than the date of birth. Thecommenter believed using the date ofbirth means banks would need to knowthe customer’s date of birth in order toprocess customer inquiries. Thecommenter also indicated the bankingindustry does not know a customer’sdate of birth and some customers willnot give out that information or do notknow it. A suggestion was to use thefirst initial of the customer’s last nameto assign the payment day. However,another commenter said that usingbirthdays to determine distribution‘‘makes a great deal of sense in eveningout the workload.’’ And still anothercommenter suggested givingbeneficiaries a sticker showing thepayment day which they could place ina prominent place in their house so thedate would be easily available.Response: SSA considered a numberof options in developing a means ofevenly distributing paymentsthroughout the month. In addition to thealpha formula suggested in thiscomment, SSA considered using the last2 digits of the individual’s SocialSecurity number. Any of these methodswould result in a random distribution ofpayments. However, the fact thatpeople’s surnames often change makesusing the alpha formula more complex.SSA selected the birth date formulabased on the unanimous endorsement ofthis method by those members of thepublic who participated in the Agency’sfocus groups. All participants expressedtheir belief that the public would relatebest to a formula based on a person’sdate of birth.