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(This post originally published on 47 Watch)

Recent administrative changes at the Social Security Administration (SSA) reveal a concerning pattern of decisions that disproportionately impact vulnerable populations while being implemented in ways that limit public awareness and oversight. Two specific policy reversals highlight this trend: the reinstatement of 100% benefit withholding for overpayments and the termination of “Enumeration at Birth” contracts in several states.

The Overpayment Recovery Rate Reversal

On March 7, 2025, the SSA quietly announced it would revert to withholding 100% of monthly benefits from recipients with overpayments, effective March 27, 2025. This reverses a significant reform implemented just one year prior, in March 2024, when the agency reduced the default withholding rate from 100% to 10% of monthly benefits.

The 2024 reform had been implemented specifically to prevent vulnerable beneficiaries from facing homelessness or inability to pay for basic necessities when their entire benefit was withheld. As former Commissioner Martin O’Malley stated, the previous practice was “unconscionable” when it left people “facing homelessness or unable to pay bills, because Social Security withheld their entire payment for recovery of an overpayment.”

Data from the SSA showed the 2024 policy change had measurable positive impacts:

• The number of people newly placed in full withholding plummeted from 6,771 in February to just 51 in September 2024
• Approximately 200,000 beneficiaries were able to maintain 90% of their benefits during repayment

While beneficiaries can still appeal for hardship waivers to reduce the withholding rate, the appeals process now faces significant delays — reportedly up to 200 days due to staffing shortages at SSA offices. This administrative bottleneck creates a de facto policy of 100% withholding for extended periods, even for those who would qualify for reduced rates.

Acting Commissioner Lee Dudek has framed the reversal as fulfilling the agency’s “significant responsibility to be good stewards of the trust funds for the American people,” estimating the change would increase overpayment recoveries by approximately $7 billion over the next decade.

The Enumeration at Birth Contract Terminations

In a separate but similarly concerning move, the SSA terminated “Enumeration at Birth” contracts with several states, including Maine, in February 2025. These contracts, which had been operating efficiently since 1980, allowed parents to register newborns for Social Security numbers through a simple automated hospital process.

The termination means parents must now physically visit Social Security offices with their newborns and documentation to apply for numbers — a significant burden in rural states like Maine with sparse populations and limited SSA offices. After public backlash and pressure from congressional representatives, Acting Commissioner Dudek issued an apology and claimed he would “reinstate” the contracts.

However, as numerous administrative experts have pointed out, federal contracts cannot simply be “reinstated” after termination. The entire contracting process must start over, which is:

1. More expensive than maintaining the original contracts
2. Time-consuming, especially with reduced SSA staff
3. Creates unnecessary burdens for new parents in the meantime

Notably, the contracts were terminated in six states, all of which have Democratic representatives in Congress, suggesting potential political targeting. Maine’s governer — Janet Mills — is also embroiled in a fight with Trump and his administration over rights of transgender citizens.

The terminations were supposedly conducted to save money (approximately $77,000 for a five-year contract base), but will likely result in higher administrative costs, less efficient service delivery, and more work for already-strained Social Security offices.

The Pattern of Administrative Weaponization

Both policy changes share several concerning characteristics:

1. Quiet implementation: Both were announced with minimal publicity, with the overpayment policy change released late on a Friday, a classic tactic to minimize media coverage.

2. Disproportionate impact on vulnerable populations: Both changes primarily affect those least equipped to navigate bureaucratic hurdles — elderly and disabled beneficiaries in the case of overpayments, and new parents in rural areas for the Enumeration at Birth terminations.

3. Administrative roadblocks to relief: While both policies theoretically offer pathways for relief (appeals for overpayment withholding, visiting SSA offices for birth enumeration), administrative realities like extended processing times and limited office locations create de facto barriers.

4. Questionable fiscal justifications: Both changes are justified as fiscal responsibility measures, yet both may ultimately cost more in administrative overhead and downstream social costs than they save.

5. Appearance of political targeting: The pattern of states affected by the Enumeration at Birth terminations, along with reports of partisan “hotlines” to expedite certain cases, suggests potentially politically motivated implementation.

These administrative changes highlight how consequential policy shifts can occur not through legislative action but through bureaucratic decisions that receive little public attention or congressional oversight. As these policies take effect in the coming weeks, their impact on vulnerable Social Security beneficiaries and new parents will become increasingly apparent.