TN 8 (08-06)
RS 01404.105 Examining the E/R for Accuracy
This policy applies to both claims and pre-claims situations and for SE income, as well as wages and tips. The following provides definitions and a general overview for reviewing an earnings record. See RS 01404.110 – RS 01404.260 for specific development and documentation guidelines of potential earnings record errors.
To avoid underpayments, SSA examines the E/R for gaps and incomplete postings.
To avoid overpayments, SSA examines the E/R for duplicate and erroneous postings.
3. Goal for Resolving E/R Inaccuracies
SSA's goal is to resolve E/R inaccuracies within 6 months of the date the inaccuracy was brought to SSA's attention.
4. Legal Limit for Resolving E/R Inaccuracies
SSA has a legal limit of 3 years, from the date the inaccuracy was brought to SSA's attention, to resolve the issue. An extension of 3 months, 15 days is permissible only if additional evidence is being developed; therefore, SSA is required to resolve the earnings issue not later than 3 years, 3 months and 15 days from the date SSA first became aware or was notified of the E/R problem.
The following definitions apply both to wages and tips:
1. Prelag Period
The prelag period is the period prior to the lag period. See RS 01404.005A.1. for definition of the lag period.
A gap is the total absence of a posting for a reporting period (quarter, except for agricultural wages, before 1978; annual after 1977 (1978 and later) within an individual's work history. A gap may be a single absence between postings or multiple successive absences between postings.
NOTE: Annual reporting began for Puerto Rico, American Samoa, Guam and the Virgin Islands in 1979; for State and local employers in 1981.
3. Incomplete Posting
An incomplete posting is a posting that does not reflect the total wages paid to the employee by an employer for a reporting period, i.e., the earnings posted from an employer are less than what the employee earned.
EXAMPLE: The NH’s E/R for 1999 shows earnings of $17,000 from his employer. The NH stated that he earned $22,500, not $17,000. He states he only worked for that employer that year. The NH presented his 1999 W-2 as evidence and contact with the employer verified that the NH’s 1999 earnings were $22,500.
NOTE: If the NH stated he worked for two employers in 1999 and earned $17,000 from one employer and $5500 from a second employer, this is not considered an incomplete posting. The missing $5500 is considered an employer gap for the second employer and if the NH worked for the second employer in the years adjacent to 1999, an EARQ will alert as Employer Gap for the second employer.
4. Duplicate Posting
A duplicate posting is a posting that matches exactly another posting (i.e., same amount of Social Security wages, same employer, same EIN, same reporting period, etc.).
5. Erroneous Posting
An erroneous posting is a posting:
To a particular time period that is for wages paid in another time period; or
For wages paid to another employee but incorrectly posted to the E/R being reviewed; or
For wages which are greater than were actually paid to the employee; or
In which the amount matches exactly the amount posted with another posting, but does not match exactly another characteristic(s), e.g., DEQY shows different EINs or employer name.