# SSR 92-7c: SSR 92-7c: SECTIONS 202(a), 204(a), 204(a)(1), 204(a)(1)(A) AND (B), 204(b), 205(a), 1611(c)(1), 1631(b)(1)(A) AND (B) OF THE SOCIAL SECURITY ACT (42 U.S.C. 402(a), 404(a), 404(a)(1), 404(a)(1)(A) AND (B), 404(b), 1382(c)(1), 1383(b)(1)(A) AND (B)) OVERPAYMENTS AND UNDERPAYMENTS -- PAYMENT ERRORS CALCULATED (NETTED) FROM THE FIRST PAYMENT ERROR TO THE MONTH THE INITIAL DETERMINATION OF OVERPAYMENT OR UNDERPAYMENT IS MADE

> Federal · Rulings · In force

URL: https://www.frixlaw.com/law-library/statutes/SSA_SSR_OASI_SSR_92_7c

## Section

- **Citation:** SSR 92-7c
- **Heading:** SSR 92-7c: SECTIONS 202(a), 204(a), 204(a)(1), 204(a)(1)(A) AND (B), 204(b), 205(a), 1611(c)(1), 1631(b)(1)(A) AND (B) OF THE SOCIAL SECURITY ACT (42 U.S.C. 402(a), 404(a), 404(a)(1), 404(a)(1)(A) AND (B), 404(b), 1382(c)(1), 1383(b)(1)(A) AND (B)) OVERPAYMENTS AND UNDERPAYMENTS -- PAYMENT ERRORS CALCULATED (NETTED) FROM THE FIRST PAYMENT ERROR TO THE MONTH THE INITIAL DETERMINATION OF OVERPAYMENT OR UNDERPAYMENT IS MADE
- **Jurisdiction:** Federal
- **Kind:** Rulings
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** Social Security Rulings / OASI / Overpayments and Underpayments / SSR 92-7c

## Text

SSR 92-7c

EFFECTIVE/PUBLICATION DATE: 06/29/92

20 CFR 404.502-404.504, 404.902, 416.538, 416.558(a), and
416.1402

Sullivan v. Everhart, 494 U.S. 83 (1990)

SCALIA, Supreme Court Justice:

If the Secretary of Health and Human Services determines that a
beneficiary has received "more or less than the correct amount of
payment," the Social Security Act requires him to effect "proper
adjustment or recovery," subject to certain restrictions in the case of
overpayments. This case requires us to decide whether the Secretary's
so-called "netting" regulations, under which he calculates the difference
between past underpayments and past overpayments, are merely a permissible
method of determining whether, "more or less than the correct amount of
payment" was made, or are instead, as to netted-out overpayments, an
"adjustment or recovery" that must comply with procedures for recovery of
overpayments imposed by the Act.

I

Two statutory benefit programs established by the Social Security Act
(Act) are involved: the Old-Age, Survivors, and Disability Insurance
program (OASDI), 53 Stat. 1362, as amended, 42 U.S.C. § 401 et seq. (1982
ed. and Supp. IV), and the Supplemental Security Income program (SSI), 86
Stat. 1465, 42 U.S.C. § 1381 et seq. (1982 ed. and Supp. IV). Millions of
Americans receive benefits under these programs; inevitably, some
beneficiaries occasionally receive more than their entitlement, and others
less. The OASDI program provides the following procedure for correcting
such errors:

As to overpayments, the Act provides:

The provisions regulating payment errors in the SSI program are
substantially similar. [1] Califano v. Yamasaki , 442 U.S. 682, 697, 99 S.Ct. 2545,
2555, 61 L.Ed.2d 176 (1979), held that the limitation on adjustment or
recovery of overpayments imposed by § 204(b) of the Act gives recipients
the right to an oral hearing in which they may attempt to convince the
Secretary to waive recoupment.
provisions regulating payment errors in the SSI program are
substantially similar. [1] Califano v. Yamasaki , 442 U.S. 682, 697, 99 S.Ct. 2545,
2555, 61 L.Ed.2d 176 (1979), held that the limitation on adjustment or
recovery of overpayments imposed by § 204(b) of the Act gives recipients
the right to an oral hearing in which they may attempt to convince the
Secretary to waive recoupment.

In the provisions set forth above, the Act contemplates that the
Secretary will "fin[d] [whether] more or less than the correct amount" of
payment has been made. Elsewhere, it confers upon the Secretary general
authority to "make rules and regulations and to establish procedures, not
inconsistent with the provisions of this subchapter, which are necessary
or appropriate to carry out such provisions," Act § 205(a), 42 U.S.C. §
405(a) (1982 ed.); see also Act § 1631(d)(1), 42 U.S.C. § 1383(d)(1) (1982
ed., Supp. IV) (SSI). Pursuant to that authority, the Secretary
promulgated the regulations at issue here. The SSI regulation provides:

The OASDI regulation unhelpfully provides that "[t]he amount of an
overpayment or underpayment is the difference between the amount paid to
the beneficiary and the amount of the payment to which the beneficiary was
actually entitled," 20 CFR § 404.504 (1989), but the Secretary has
interpreted this as embodying the methodology set forth in the SSI
regulation. Dept. of Health and Human Services, Social Security Ruling
81-19a (cum.ed. 1981).
amount of an
overpayment or underpayment is the difference between the amount paid to
the beneficiary and the amount of the payment to which the beneficiary was
actually entitled," 20 CFR § 404.504 (1989), but the Secretary has
interpreted this as embodying the methodology set forth in the SSI
regulation. Dept. of Health and Human Services, Social Security Ruling
81-19a (cum.ed. 1981).

Two hypotheticals will illustrate the operation of the netting
regulations. Mr. A, entitled to $100 per month, is erroneously paid $80 in
January and erroneously paid $150 in February. In March the Secretary
determines that these payments were incorrect, nets the errors (i.e.,
calculates the difference between the underpayment and the overpayment),
and seeks to recover the net overpayment of $30. Mrs. B, also entitled to
$100 per month, receives $50 in April and $110 in May. In June, the
Secretary makes the incorrect payment determination, nets the errors, and
pays out $40. In neither case may the beneficiaries seek to have the
underpayment and the overpayment treated separately: Mr. A could not
demand $20 for January and seek a waiver of the recoupment of $50 for
February, and Mrs. B could not demand $50 for April and seek a waiver for
the $10 in May.

In the present case, the Secretary made both underpayments and
overpayments to each of the respondents, and netted those errors pursuant
to the regulations. He determined that three respondents (the original
plaintiffs) received net underpayments, and paid that net amount. The
other respondents (intervenors below) received net overpayments, and the
Secretary offered them hearings to determine whether recoupment should be
waived as to the net overpayment. The plaintiffs (later joined by the
intervenors) filed this suit under §§ 205(g) and 1631(c)(3) of the Act, 42
U.S.C. §§ 405(g), 1383(c)(3) (1982 ed.), in the United States District
Court for the District of Colorado
espondents (intervenors below) received net overpayments, and the
Secretary offered them hearings to determine whether recoupment should be
waived as to the net overpayment. The plaintiffs (later joined by the
intervenors) filed this suit under §§ 205(g) and 1631(c)(3) of the Act, 42
U.S.C. §§ 405(g), 1383(c)(3) (1982 ed.), in the United States District
Court for the District of Colorado. They claimed that the netting
regulations were facially invalid because (1) they were contrary to the
Act and (2) they violated beneficiaries' rights to procedural due process.
The District Court granted respondents' motion for summary judgment on the
former ground, and the Court of Appeals for the Tenth Circuit affirmed in
all relevant respects. 853 F.2d 1532 (1988). The Court noted that two
other Courts of Appeals had upheld the netting regulations against similar
attacks. Id., at 1536-1537 (citing Lugo v. Schweicker , 776
F.2d 1143 (CA3 1985), and Webb v. Bowen , 851 F.2d 190 (CA8
1988)).

We granted certiorari, 490 U.S. _____, 109 S.Ct. 2098, 104 L.Ed.2d
660.

II

Our mode of reviewing challenges to an agency's interpretation of its
governing statute is well established: We first ask "whether Congress has
directly spoken to the precise question at issue. If the intent of
Congress is clear, that is the end of the matter, for the court, as well
as the agency, must give effect to the unambiguously expressed intent of
Congress." Chevron U.S.A. Inc. v. Natural Resources Defense
Council , Inc., 467 U.S. 837, 842-843, 104 S.Ct. 2778, 2781, 81 L.Ed.2d
694 (1984). "In ascertaining the plain meaning of the statute, the court
must look to the particular statutory language at issue, as well as the
language and design of the statute as a whole." K Mart Corp. v. Cartier, Inc. , 486 U.S. 281, 291, 108 S.Ct. 1811, 1817, 100 L.Ed.2d
313 (1988); see also Mead Corp. v. Tilley , 490 U.S. _____,
_____, 109 S. Ct. 2156, _____, 104 L.Ed.2d 796 (1989)
694 (1984). "In ascertaining the plain meaning of the statute, the court
must look to the particular statutory language at issue, as well as the
language and design of the statute as a whole." K Mart Corp. v. Cartier, Inc. , 486 U.S. 281, 291, 108 S.Ct. 1811, 1817, 100 L.Ed.2d
313 (1988); see also Mead Corp. v. Tilley , 490 U.S. _____,
_____, 109 S. Ct. 2156, _____, 104 L.Ed.2d 796 (1989). But "if the statute
is silent or ambiguous with respect to the specific issue, the question
for the court is whether the agency's answer is based on a permissible
construction of the statute," Chevron, supra, 467 U.S. at 843, 104
S.Ct., at 2781, that is, whether the agency's construction is "rational
and consistent with the statute." NLRB v. United Food &
Commercial Workers, 484 U.S. 112, 123, 108 S.Ct. 413, 420, 98 L.Ed.2d
429 (1987). These principles apply fully to the Secretary's administration
of the Act. See Schweiker v. Gray Panthers , 453 U.S. 34, 43,
101 S.Ct. 2633, 2639, 69 L.Ed.2d 460 (1981); Batterton v. Francis , 432 U.S. 416, 425, 97 S.Ct. 2399, 2405, 53 L.Ed.2d 448
(1977).

A

We first consider whether the Act speaks directly to the validity of the
netting regulations. Two provisions are relevant: a general authorization,
and a specific limitation. First, the Act authorizes the Secretary to
determine whether "more or less than the correct amount" has been paid. 42
U.S.C. §§ 404(a), 1383(b)(1)(A) (1982 ed., Supp. IV). The Act does not
define the term "correct amount." It assuredly could be construed to refer
to the amount properly owing for a given month. If that were the only
possible interpretation, respondents would prevail, since the netting
regulations ascertain the correct amount for a longer time period. But the
Act does not foreclose a more expansive interpretation of "correct
amount," viz., the amount properly owing as of the date of the
determination
y could be construed to refer
to the amount properly owing for a given month. If that were the only
possible interpretation, respondents would prevail, since the netting
regulations ascertain the correct amount for a longer time period. But the
Act does not foreclose a more expansive interpretation of "correct
amount," viz., the amount properly owing as of the date of the
determination. Although the Act elsewhere describes OASDI and SSI as
monthly benefit programs, e.g., Act § 202(a), 42 U.S.C. § 402(a) (1982
ed., Supp. IV); Act § 1611(c)(1), 42 U.S.C. § 1382(c)(1) (1982 ed., Supp.
IV), it nowhere specifies that the correctness of payments must be
determined on a month-by-month basis.

The fuller context of the OASDI provisions suggests that Congress,. in
authorizing the Secretary to determine whether the "correct amount" was
paid, did not prohibit him from making that determination for more than a
monthly time period. The Act authorizes a determination of whether "the
correct amount of payment has been made," 42 U.S.C. § 404(a)(1), and
mandates adjustments "[w]ith respect to payment to a person of more than
the correct amount," § 404(a)(1)(A), and "[w]ith respect to payment to a
person of less than the correct amount," § 404(a)(1)(B). If Congress had
in mind only shortfalls or excesses in individual monthly payments, rather
than in the overall payment balance, it would have been more natural to
refer to "the correct amount of any payment," and to require adjustment
"with respect to any payment . . . of less [or more] than the correct
amount." This terminology is used elsewhere in § 204(a)(1)(A), whenever
individual monthly payments are at issue ("the Secretary shall decrease
any payment under this subchapter to which such overpaid person is
entitled"; "shall decrease any payment under this subchapter payable to
his estate"). 42 U.S.C. § 404(a)(1)(A) (emphases added)
ny payment . . . of less [or more] than the correct
amount." This terminology is used elsewhere in § 204(a)(1)(A), whenever
individual monthly payments are at issue ("the Secretary shall decrease
any payment under this subchapter to which such overpaid person is
entitled"; "shall decrease any payment under this subchapter payable to
his estate"). 42 U.S.C. § 404(a)(1)(A) (emphases added). Moreover, the
provision governing adjustment of overpayments to a deceased beneficiary
seems to contemplate computation on a multi-payment basis ("the Secretary
. . . shall decrease any payment under this subchapter payable to his
estate or to any other person on the basis of the wages and
self-employment income which were the basis of the payments to such
overpaid person") Ibid. (emphasis added).

The Act's provisions governing SSI are slightly different, but in no way
contradict the Secretary's position. They authorize the Secretary to
determine whether "more or less than the correct amount of benefits has
been paid," 42 U.S.C. § 1383(b)(1)(A) (1982 ed., Supp. IV) (emphasis
added). Had this read "more or less than the correct amount of any
benefit" it might support respondents' position, but as written it at
least bears (if it does not indeed favor) the interpretation that more
than a single monthly benefit is at issue.

Respondents nevertheless maintain, as did the Court of Appeals, that
another provision of the Act directly precludes the Secretary from netting
underpayments and overpayments. They point to § 404(b) (1982 ed.), which
provides: "In any case in which more than the correct amount of payment
has been made, there shall be no adjustment of payments to, or recovery by
the United States from, any person who is without fault if such adjustment
or recovery would defeat the purpose of this subchapter or would be
against equity and good conscience." See also Act § 1383(b)(1)(B) (1982
ed., Supp. IV) (SSI)
which
provides: "In any case in which more than the correct amount of payment
has been made, there shall be no adjustment of payments to, or recovery by
the United States from, any person who is without fault if such adjustment
or recovery would defeat the purpose of this subchapter or would be
against equity and good conscience." See also Act § 1383(b)(1)(B) (1982
ed., Supp. IV) (SSI). Respondents argue that by using the phrase
"adjustment or recovery," Congress intended to subject to this requirement
all collection methods, including the set off effected by netting. They
claim this broad meaning is given to the words "adjustment" and "recovery"
by other Social Security regulations (e.g., 20 CFR §§ 404.502-404.503
(1989)), common usage (e.g., Webster's Third New International Dictionary
27, 1898 (1981) (hereinafter Webster's)), and general legal usage (e.g., United States v. Burchard, 125 U.S. 176, 8 S.Ct. 832, 31
L.Ed. 662 (1888)). Under this interpretation, when the agency calculates
the difference between, or nets, Mr. A's $20 underpayment and his $50
overpayment, see supra , at 963, it has engaged in "adjustment or
recovery," but without complying with the restrictions on "adjustment or
recovery" that the Act imposes.

In our view, however, with this provision as with those discussed
earlier, respondents have established at most that the language may bear
the interpretation they desire -- not that it cannot bear the
interpretation adopted by the Secretary. "Adjustment" can have the more
limited meaning (which the Secretary favors) of "an increase or decrease"
of payments (Webster's 27), and "recovery" can have the more limited
meaning of "get[ting] back" payments already made (see id., at 1989
("recover")). Moreover, other provisions of the Act support this limited
meaning. It is at least reasonable, if not necessary, to read the phrase
"adjustment or recovery" in § 204(b) in pari materia with the
identical phrase in § 204(a)(1)
r decrease"
of payments (Webster's 27), and "recovery" can have the more limited
meaning of "get[ting] back" payments already made (see id., at 1989
("recover")). Moreover, other provisions of the Act support this limited
meaning. It is at least reasonable, if not necessary, to read the phrase
"adjustment or recovery" in § 204(b) in pari materia with the
identical phrase in § 204(a)(1). The latter section directs the Secretary,
if he finds that incorrect payment has been made, to make "proper
adjustment of recovery . . . as follows." In the case of overpayment, he
shall "decrease any payment under this subchapter to which such overpaid
person is entitled, or shall require such overpaid person or his estate to
refund the amount in excess of the correct amount. . . ." 42 U.S.C. §
404(a)(1)(A) (1982 ed., Supp. IV). As to SSI, "adjustment or recovery
shall . . . be made by appropriate adjustments in future payments to such
individual or by recovery from . . . or by payment to such individual or
his eligible spouse. . . ." 42 U.S.C. § 1383(b)(1)(A) (1982 ed., Supp.
IV). Giving the terms their more limited meaning does not produce absurd
policy consequences. Reducing future benefits, or requiring the
beneficiary to pay over cash, will ordinarily produce more hardship than
merely setting off past under payments and overpayments. It is not at all
unreasonable to think that waiver hearings were established only for the
former.
(1)(A) (1982 ed., Supp.
IV). Giving the terms their more limited meaning does not produce absurd
policy consequences. Reducing future benefits, or requiring the
beneficiary to pay over cash, will ordinarily produce more hardship than
merely setting off past under payments and overpayments. It is not at all
unreasonable to think that waiver hearings were established only for the
former.

As used in the Act, therefore, adjustment can be read to mean decreasing
future payments, and recovery to mean obtaining a refund from the
beneficiary. Under this interpretation, when the agency nets Mr. A's
underpayment against his overpayment, it is not engaged in "adjustment or
recovery," but only in the calculation of whether "more or less than the
correct amount of payment has been made." Only after making that
calculation does the Secretary take the additional step to rectifying any
error by "adjustment" (increasing or decreasing future payments) or
"recovery" (obtaining a refund from the beneficiary). And it is only this
latter step that is governed by § 204(b) of the Act. We do not say this is
an inevitable interpretation of the statute; but it is assuredly a
permissible one.

B

Since the Act reasonably bears the Secretary's interpretation that
netting is permitted, only one issue remains: Respondents contend that the
manner in which the regulations provide for netting to be conducted is
arbitrary and capricious, because of their definition of the netting
period. Overpayments are netted with underpayments up to the "month [of]
the initial determination" of error. 20 CFR § 416.538 (1989). "Initial
determination" is a term of art meaning the Secretary's formal
determination that an error was committed. See 20 CFR §§ 404.902, 416.1402
rovide for netting to be conducted is
arbitrary and capricious, because of their definition of the netting
period. Overpayments are netted with underpayments up to the "month [of]
the initial determination" of error. 20 CFR § 416.538 (1989). "Initial
determination" is a term of art meaning the Secretary's formal
determination that an error was committed. See 20 CFR §§ 404.902, 416.1402
(1989). Needless to say, that formal determination will not be
simultaneous with the Secretary's first discovery that something is amiss;
delay is inevitable. Respondents contend that this delay is fatal. At
best, they say, the period over which netting is conducted will turn on
the fortuity of the time period between discovery and formal
determination. At worst, the Secretary will manipulate the netting period
by delaying formal determination, thus including more underpayments in the
netting period and reducing the net overpayment subject to the
recoupment-waiver procedures.

It seems to us not arbitrary or capricious to establish a grace period
within which these determinations can be considered and formally made;
they should not be spur-of-the-moment decisions. That delay will extend
the netting period, and may result in the inclusion of more underpayments
to be netted. But we cannot say that the alternatives -- immediate
determinations, or determinations within a fixed period -- would not
produce errors that make beneficiaries worse off on the whole.

Moreover, although the Secretary's regulations do not establish a fixed
time period for the formal determination, they do establish a time limit
upon the principal adverse consequence of delay; the netting-in of
additional underpayments. The regulations provide:
erminations, or determinations within a fixed period -- would not
produce errors that make beneficiaries worse off on the whole.

Moreover, although the Secretary's regulations do not establish a fixed
time period for the formal determination, they do establish a time limit
upon the principal adverse consequence of delay; the netting-in of
additional underpayments. The regulations provide:

See also HHS, Program Operation Manual System, GN 02201.002 (1989)
(Social Security Administration policy to resolve overpayments as quickly
as possible). Respondents' fear of intentional manipulation of the netting
period can be entirely dismissed if this provision is observed in good
faith -- as we must presume, in this facial challenge, it will be. See,
e.g., FCC v. Schreiber, 381 U.S. 279, 296, 85 S.Ct. 1459,
1470, 14 L.Ed.2d 393 (1965). The intentional manipulation hypothesis is in
any event implausible. Deliberately protracting the netting period may
indeed draw in future underpayments; but it may just as likely draw in
future overpayment, which will be uncollectible until the Secretary's
determination is made. The Secretary might conceivably ensure that delay
works to the Government's financial advantage by deliberately underpaying
while keeping the netting period open, but since that is an obvious
violation of the Act it is again not the stuff of which a facial challenge
can be constructed.
draw in
future overpayment, which will be uncollectible until the Secretary's
determination is made. The Secretary might conceivably ensure that delay
works to the Government's financial advantage by deliberately underpaying
while keeping the netting period open, but since that is an obvious
violation of the Act it is again not the stuff of which a facial challenge
can be constructed.

In addition to the fact that the disadvantages of the Secretary's
approach are less than respondents assert, the disadvantages of
respondents' approach are more. The Secretary points out that a separate
accounting for each month would cause the agency great expense, in the
cost of a greatly increased volume of complex recoupment-waiver
proceedings, in the cost of overpayments that are simply written off
because the cost of the proceedings would exceed the recovery, and in the
cost of overpayments whose return will be subject to lengthy delays. These
expenses "in the end come out of the pockets of the deserving since
resources available for any particular program of social welfare are not
unlimited." Matthews v. Eldridge, 424 U.S. 391, 348, 96
S.Ct. 893, 909, 47 L.Ed.2d 18 (1976).

Respondents seek to minimize the administrative burden by proposing a
scheme under which the Secretary would notify the beneficiary of under
payments and overpayments, withhold reimbursement of the underpayments for
a brief period during which the beneficiary may seek waiver of recoupment
of overpayments, and then net the underpayments and that portion of the
overpayments as to which waiver has not been sought. This scheme, however,
does not at all address the problem of delay in netting that is the
asserted basis for finding the regulations arbitrary and capricious.
Substituting, "notification" of underpayments and overpayments for
"determination" of underpayments and overpayments merely gives the
occasion for the delay another name
of the
overpayments as to which waiver has not been sought. This scheme, however,
does not at all address the problem of delay in netting that is the
asserted basis for finding the regulations arbitrary and capricious.
Substituting, "notification" of underpayments and overpayments for
"determination" of underpayments and overpayments merely gives the
occasion for the delay another name. What this alternative proposal of
respondents really puts forward is an alternative means of assuring that
overpayments cannot be "netted out" without an opportunity for waiver
hearing. As we discussed at length earlier, the statute does not require
such assurance. In sum, we find no basis for holding the regulations
arbitrary and capricious.

* * *

The Court of Appeals did not reach respondents' contention that the
regulations violate due process, and we will not address that claim in the
first instance. See, e.g., United States v. Sperry Corp., 493 U.S. _____, _____ 110 S.Ct. 387, _____, 107 L.Ed.2d 290 (1989).
Accordingly, the judgment is reversed and the case remanded for further
proceedings consistent with this opinion.

It is so ordered.

Justice Scalia delivered the opinion of the Court, in which Chief Justice
Rehnquist and Justices White, Blackmun, and O'Connor joined. Justice
Stevens filed a dissenting opinion, in which Justices Brennan, Marshall,
and Kennedy joined.

[1] "(A) Whenever the Secretary
finds that more or less than the correct amount of benefits has been paid
with respect to any individual, proper adjustment or recovery shall,
subject to the succeeding provisions of this subsection, be made by
appropriate adjustments in future payments to such individual or by
recovery from such individual or his eligible spouse (or from the estate
of either) or by payment to such individual or his eligible spouse (or
from the estate of either) or by payment to such individual or his
eligible spouse. . . .

* * * * *
shall,
subject to the succeeding provisions of this subsection, be made by
appropriate adjustments in future payments to such individual or by
recovery from such individual or his eligible spouse (or from the estate
of either) or by payment to such individual or his eligible spouse (or
from the estate of either) or by payment to such individual or his
eligible spouse. . . .

* * * * *

"(B) The Secretary (i) shall make such provision as he finds appropriate
in the case of payment of more than the correct amount of benefits with
respect to an individual with a view to avoiding penalizing such
individual or his eligible spouse who was without fault in connection with
the overpayment, if adjustment or recovery on account of such overpayment
in such case would defeat the purposes of this subchapter, or be against
equity and good conscience, or (because of the small amount involved)
impeded efficient or effective administration of this subchapter. . . ."
Act § 1631(b)(1)(A), (B); 42 U.S.C. § 1383(b)(1)(A), (B) (1982 ed., Supp.
IV).

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- [SSR 70-3 SSR 70-3: SECTIONS 204 and 216. -- UNDERPAYMENT -- PRIORITY OF PAYMENT TO STEPCHILDREN OF DECEDENT](https://www.frixlaw.com/law-library/statutes/SSA_SSR_OASI_SSR_70_3.md)
- [SSR 70-4 SSR 70-4: SECTION 204(d)(7). -- UNDERPAYMENT -- PAYMENT TO RESIDUARY LEGATEE OF DECEASED BENEFICIARY'S STATE AS "LEGAL REPRESENTATIVE"](https://www.frixlaw.com/law-library/statutes/SSA_SSR_OASI_SSR_70_4.md)
- [SSR 70-9 SSR 70-9: SECTION 204(d)(7). -- UNDERPAYMENT -- STATUS OF COUNTY WELFARE AGENCY UNDER INDIANA'S SMALL ESTATE STATUTE](https://www.frixlaw.com/law-library/statutes/SSA_SSR_OASI_SSR_70_9.md)
- [SSR 70-30 SSR 70-30: SECTION 204(d)(7). -- UNDERPAYMENT -- LEGAL REPRESENTATIVE -- ORDER GRANTED UNDER "SMALL ESTATE" STATUTE OF STATE OTHER THAN STATE OF DOMICILE OF DECEDENT AT TIME OF DEATH](https://www.frixlaw.com/law-library/statutes/SSA_SSR_OASI_SSR_70_30.md)
- [SSR 70-54 SSR 70-54: SECTION 204(a). -- OVERPAYMENT -- ADJUSTMENT OR RECOVERY -- LIMITED TO BENEFITS PAYABLE ON RECORD OF DECEASED OVERPAID INDIVIDUAL OR FROM HIS ESTATE](https://www.frixlaw.com/law-library/statutes/SSA_SSR_OASI_SSR_70_54.md)
- [SSR 72-28c SSR 72-28c: SECTIONS 204(a) and (b) -- (42 U.S.C. 404(a) and (b)). -- DISABILITY INSURANCE BENEFITS -- RECOVERY OF OVERPAYMENT -- FAILURE TO REPORT WORK ACTIVITY AS CONSTITUTING FAULT](https://www.frixlaw.com/law-library/statutes/SSA_SSR_OASI_SSR_72_28c.md)
- [SSR 73-4c SSR 73-4c: Rescinded 1986](https://www.frixlaw.com/law-library/statutes/SSA_SSR_OASI_SSR_73_4c.md)
- [SSR 73-5c SSR 73-5c: Rescinded 1986](https://www.frixlaw.com/law-library/statutes/SSA_SSR_OASI_SSR_73_5c.md)

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/SSA_SSR_OASI_SSR_92_7c. Check the current official text before relying on it. Not legal advice.