Audit Report - A-02-96-61000

Benchmarking Private Sector Policies and Practices for Distributing Customer Notices - A-02-96-61000 - 9/22/97

TABLE OF CONTENTS

EXECUTIVE SUMMARY

INTRODUCTION

FINDINGS

MOST ORGANIZATIONS SOLICITED CUSTOMER INPUT ON THEIR NOTICES

KEY COMMON PRACTICES WERE IDENTIFIED

• Limiting Notices to One Page
• Using Attachments
• Avoiding Confusing Jargon
• Using Specialists
• Identifying a Contact Person
• Using Graphics
• Using Bulleted Lists
• Testing Reading Level

CONCLUSION AND RECOMMENDATIONS

APPENDICES

Appendix B - Major Contributors to This Report

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EXECUTIVE SUMMARY 

OBJECTIVE

The objective of this evaluation was to determine how the private sector and other public organizations distribute complex information to their customers and compare that to the Social Security Administration’s (SSA) current practices.

BACKGROUND

SSA annually mails over 240 million notices to its customers. These notices are the primary source of information customers receive, even though SSA has 25 million visitors to its field offices (FO) and 70 million callers to its 800 number annually. SSA issues hundreds of different types of notices, including entitlement decisions and changes, earnings statements, news of legislative or policy changes, and statements of beneficiary rights.

In the Twelfth Annual Social Security Customer Satisfaction Survey, the Office of the Inspector General (OIG) found that customers place a great deal of importance on mail that is easy to understand. When asked to select the 5 services (from a list of 17) that were most important to them, customers most often selected clear and easy-to-understand mail as the most important service. Sixty-two percent of respondents mentioned clear mail as the most important service.

The survey also found that some customers have problems understanding the mail they received from SSA. Eighty-five percent reported receiving mail other than a benefit check from SSA in the 12-month period covered by the survey. Of these, 15 percent were dissatisfied with the clarity and helpfulness of the mail.

We identified 10 public and private organizations whose services or customer relationships are comparable to those of SSA. We gave special attention to those who are required to mail complex information to their customers. The organizations selected were known to provide superior customer service and included three insurance companies, two financial institutions, two other Federal agencies, two State agencies, and one telecommunications provider. We conducted telephone interviews with representatives from these organizations to identify their methods for developing, designing, and mailing complex information, and to solicit suggestions of best practices and lessons learned.

FINDINGS

Most Organizations Solicited Customer Input on Their Notices

Seven of the 10 respondents received feedback from customers concerning their notices.

Most Organizations Were Legally Required to Include Certain Statements in Their Notices

Eight respondents reported being legally required to include certain information in their notices.

Key Common Practices Were Identified

Respondents offered many suggestions for simplifying and improving customer notices. The common practices included, among others, limiting the notice to one page, using attachments, and avoiding confusing jargon.

RECOMMENDATIONS

In order to improve the overall presentation of complex information to its customers, we recommend that SSA:

Use more of the practices reported by the study respondents, and do so on a consistent basis. This would include testing a notice which presents personal information on one page, and all other information, including legally required information, on an attachment.

Establish a process which generates continuous customer input on notices.

AGENCY COMMENTS

In its written comments to the draft report, SSA agreed with our findings and the thrust of the recommendations. The Agency found the information to be a helpful contribution to its continuing effort to improve notices to the public. SSA further noted that it already uses many of the suggestions mentioned in this report and will consider other recommended practices as new notices are developed and the Agency’s ongoing notice improvement work continues.

OIG RESPONSE

OIG believes that the practices used by the organizations we contacted helped customers better understand complex information presented through notices. Further, we recognize SSA’s continuing efforts to improve its notices to the public by already implementing many practices highlighted in this report. We believe that the implementation of the remaining recommended practices, where appropriate, will further support SSA’s ongoing notice improvement and future notice development.

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INTRODUCTION 

OBJECTIVE

The objective of this evaluation was to determine how the private sector and other public organizations distribute complex information to their customers and compare that to SSA’s current practices.

BACKGROUND

SSA annually mails over 240 million notices to its customers. These notices are the primary source of information customers receive, even though SSA has 25 million visitors to its FOs and 70 million callers to its 800 number annually. SSA issues hundreds of different types of notices, including entitlement decisions and changes, earnings statements, news of legislative or policy changes, and statements of beneficiary rights.

SSA’s Office of Program Support (OPS) within the Office of Programs and Policy, Office of General Counsel, and many other components work together to ensure that SSA notices are both clear and accurate. This is done in support of the SSA Customer Service Pledge which states, "We will clearly explain our decisions so you can understand why and how we made them and what to do if you disagree."

Due to its vast customer population, SSA strives to write these notices as consistently and simply as possible, and has developed Notice Standards to facilitate this practice. SSA’s Notice Standards set criteria for reading levels, length of sentences, salutations, translations, etc. For example, the standards require that notices should be written at a sixth- to eighth-grade reading level, which is the level currently used in most newspapers. The standards also require that the content of each notice should be clear, logical, pertinent, and sufficient to allow the reader to decide if he/she disagrees with a decision.

Previous Evaluations of SSA Notices

In the Twelfth Annual Social Security Customer Satisfaction Survey, OIG found that customers place a great deal of importance on mail that is easy to understand. When asked to select the 5 services (from a list of 17) that are most important to them, 62 percent of the respondents mentioned clear and easy-to-understand mail as the most important service.

This same survey found that some customers have problems understanding the mail they received from SSA. Eighty-five percent reported receiving mail, other than a benefit check, from SSA in the past 12 months. Of these, 15 percent were dissatisfied with the clarity and helpfulness of that mail.

OIG also conducted a number of studies specifically examining SSA notices. In 1992, the Department of Health and Human Services, Office of Inspector General (HHS/OIG), evaluated the extent to which SSA notices were clear, appropriate to the audience, and met SSA’s Notice Standards. The reports issued as a result of that study, "Clarity of Supplemental Security Income Notices" (OEI-07-90-02410) and "Examples of Revised Supplemental Security Income Notices" (OEI-07-90-02461), found that although the notices reviewed met the standards for reading level and sentence length, some other aspects of the notices continued to be difficult to understand. While most of the respondents to that study understood the main message of the notice, they did not understand other important notice information. Specifically, Supplemental Security Income respondents found the Notice of Award and explanations regarding payment changes particularly difficult to understand. The study also found that SSA had no systematic process for monitoring the effectiveness of its notices.

In another HHS/OIG study, "Employee Opinions of Social Security Notices" (OEI-05-92-00042), dealing with employee comments and concerns about SSA notices, employees noted the public’s dissatisfaction with notices. The employees believed that many notices were unclear, especially to those unfamiliar with SSA programs. This, in turn, may cause the public to contact FOs or the 800 number for explanations. The employees thought the notices contained too much jargon, were too long and rambling, had reading levels that were too high, contained inconsequential information, and/or lacked a sequential presentation of the facts.

PRE-EVALUATION SUMMARY

We met with SSA’s OPS staff to obtain their input and understanding as to the issues and focus for this survey. Additionally, we reviewed the Program Operations Manual System, specifically the area dealing with notices, letters, and paragraphs (NL 0700.000) to gain a better understanding of the regulations guiding the issuance of notices. Further, we made some preliminary telephone calls to public and private organizations to determine if they had notice-writing policies.

METHODOLOGY

We identified 10 public and private organizations whose services or customer relationships are comparable to those of SSA. We gave special attention to those that are required to mail complex information to their customers. The organizations selected were known to provide superior customer service and included three insurance companies, two financial institutions, two other Federal agencies, two State agencies, and one telecommunications provider. We conducted telephone interviews with representatives from these organizations to identify their methods for developing, designing, and mailing complex information, and to solicit suggestions of best practices and lessons learned. We then held additional discussions with SSA staff to identify their methods for designing and mailing notices.

Our review was conducted from August 1996 to February 1997. This evaluation was performed in accordance with the Quality Standards for Inspections issued by the President’s Council on Integrity and Efficiency.

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FINDINGS 

MOST ORGANIZATIONS SOLICITED CUSTOMER INPUT ON THEIR NOTICES

Seven of the 10 organizations we contacted received customer feedback concerning their notices. Some mentioned working hand-in-hand with local advocacy groups to obtain customer input. The feedback ranged from focus groups, the most frequently mentioned, to satisfaction surveys and comment cards. One respondent established an 800 number specifically for questions or problems concerning letters customers had received from the company.

Customer input varied and included such suggestions as using simpler language, avoiding the use of patronizing language, increasing the use of bullets and lists, and using fewer words and more graphics in the notices. Respondents stressed that obtaining customer input before sending out notices enabled them to identify and clarify confusing material before incurring the expense of mailing notices to customers.

MOST ORGANIZATIONS WERE LEGALLY REQUIRED TO INCLUDE CERTAIN STATEMENTS IN THEIR NOTICES

SSA is legally required to include certain information in its notices (e.g., appeal rights must be included.) Eight respondents also reported being legally required to include certain information in their notices. These requirements included any and all changes in account history, pricing and rate changes, credit sources, and appeal rights. One respondent reported that 99 percent of its notice is made up of language to satisfy legal requirements. Other respondents explained that legal requirements varied from case to case.

Some respondents reported meeting legal requirements through the use of separate fact sheets or attachments. They explained that this fulfilled all legal requirements while making the notice somewhat easier to read.

KEY COMMON PRACTICES WERE IDENTIFIED

Respondents offered many suggestions for simplifying and improving customer notices. They included:

Limiting Notices to One Page

Seven of the 10 respondents said they kept their notices to one page or less. They used various methods to do this (e.g., using both sides of the page, attachments, graphics, etc.). The three respondents whose notices exceeded one page in length reported that the complexity of their notices precluded limiting them to one page.

Currently, SSA is not able to limit all of its notices to one page; however, several SSA task groups are looking for ways to make this possible.

Using Attachments

In order to make the notices as brief as possible, all 10 respondents removed the required complex legal information from the body of the notices and placed it in attachments. Further, they suggested that attachments should be no more than one page and on the same size and type of paper as the notice itself. Many found through surveys that customers are more likely to read attachments of this type, rather than folded brochures or other types of fliers.

Some respondents reported using monthly newsletters to inform customers of legal issues or policy changes that might concern them. Therefore, it became unnecessary to repeat the policy changes in individual notices, making them shorter.

SSA is currently looking into a more widespread use of attachments.

Avoiding Confusing Jargon

Respondents repeatedly mentioned using simple, clear language as a way to clarify notices. Specifically, they recommended writing in plain English and avoiding the use of professional or agency jargon which may be foreign and confusing to the customer. Respondents also mentioned having selected customers test the notices to identify and clarify any confusing language.

Currently, SSA attempts to avoid confusing jargon while fulfilling its legal requirements.

Using Specialists

When asked to describe methods used to create notices, all respondents reported obtaining input from their legal departments first to ensure accuracy of the information being provided. However, more than half believed it was important to have specialists write the notices to avoid the technical terminology used by the legal department.

Specialists are those individuals actively involved in the subject or programmatic area covered by the notice, rather than experts in the area of writing notices. Specialists would, therefore, be better versed in any issues that might arise as a result of statements made in the notice.

Currently, SSA uses teams of notice writers, legal experts, and specialists to work on its notices.

Identifying a Contact Person

Another common suggestion was to identify a contact person and telephone number in each notice. "Customers like the idea of knowing exactly where to go if they have a problem," explained one respondent. Those who did not give a specific name and telephone number provided a general telephone number where customers could obtain assistance.

SSA currently includes its toll-free 800 number on every notice.

Using Graphics

Respondents mentioned the use of graphics as an effective tool for reducing the number of words in a notice without changing the message. One respondent reported, "Graphics rate very highly in our focus group testing. We’re sending the same exact message, but the approach is different and the customers prefer looking at the graphs to reading more words." Customers also preferred the use of illustrative charts and tables when possible, again with the result being a decrease in the number of words while maintaining the message.

SSA has not, to date, used graphics in its notices.

Using Bulleted Lists

Another repeated suggestion was the use of bulleted lists, bold print, and italics to emphasize important parts of the notice and to clarify the message. Respondents reported that customers find it easier to have the most important parts of the notice highlighted with bullets because it gives them a place to focus their attention. Respondents found that customers appreciate having ". . . everything boiled down to one clear little list."

SSA routinely uses bulleted lists when appropriate.

Testing Reading Level

Half of the respondents reported testing the reading level of a notice before it is sent. There are a number of tests available for this purpose, including the Flesch-Kincaid Index and Gunning Fog Index. Respondents suggested maintaining a reading level of eighth grade or lower, and fifth grade if at all possible.

SSA currently maintains a sixth- to eighth-grade reading level on most of its notices.

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CONCLUSION AND RECOMMENDATIONS 

SSA currently uses some of the same practices as those reported by the respondents to our survey in developing notices (e.g., testing reading levels, avoiding jargon, etc.). However, the use of the other reported practices is sporadic. Additionally, although SSA occasionally seeks customer input concerning notices, the process does not generate continuous input. To improve the overall presentation of complex information to its customers, we recommend that SSA:

Use more of the practices reported by the study respondents, and do so on a consistent basis. This would include testing a notice which presents personal information on one page, and all other information, including legally required information, on an attachment.

Establish a process which generates continuous customer input on notices.

AGENCY COMMENTS

SSA’s comments on our draft report are contained in their entirety in Appendix A. SSA agreed with our findings and the thrust of the recommendations. The Agency found the information to be a helpful contribution to its continuing effort to improve notices to the public. SSA further noted that it already uses many of the suggestions mentioned in this report and will consider other recommended practices as new notices are developed and the Agency’s ongoing notice improvement work continues.

OIG RESPONSE

OIG believes that the practices used by the organizations we contacted helped customers better understand complex information presented through notices. Further, we recognize SSA’s continuing efforts to improve its notices to the public by already implementing many practices highlighted in this report. We believe that the implementation of the remaining recommended practices, where appropriate, will further support SSA’s ongoing notice improvement and future notice development.

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APPENDIX B 

 MAJOR CONTRIBUTORS TO THIS REPORT

 Office of the Inspector General

E. Scott Patterson, Director, Evaluations and Technical Services
Timothy F. Nee, Acting Deputy Director
Tracey K. Rennie, Evaluator-in-Charge
Stephen L. Liebman, Auditor