TN 3 (01-18)

Several SSA components are responsible for the Section 218 State and local coverage provisions. The following describe those components and their functions.

A. Regional Office (RO)

The RO provides leadership and technical direction in administering the State and local coverage program within the region, consistent with established policy. Within the RO, the Assistant Regional Commissioner (ARC) has responsibility for State and local coverage activities within the region. The RO:

• Conducts day-to-day negotiations with the State;

• Assists the State in drafting Section 218 Agreements and modifications;

• Interprets, reviews, processes and executes Section 218 Agreements and modifications;

• Reviews supporting documentation from States to remove legally dissolved entities from coverage under Section 218 Agreements;

• Makes coverage and wage determinations consistent with established policy;

• Provides guidance and advice to States on proposed legislation that may have impact on the State's Section 218 Agreement;

• Interprets and advises States on established SSA policies and procedures;

• Refers to Central Office issues for which no policy has been established or present policy may require a change;

• Maintains file of original agreements and modifications;

• Responds to inquiries concerning magnetic media reporting, electronic filing, and paper reporting of wages; and

• Advises State Social Security Administrators and the Internal Revenue Service regarding Social Security and Medicare issues.

• May send a letter, at its discretion, to a State Governor advocating for the State Social Security Administrator position and reinforcing the resources available to the State Administrators upon Regional Commissioner’s approval. In determining whether to send the letter, the RO should consider factors such as:

  1. The State Administrator has requested the letter.

  2. The RO has not heard from a State in several years.

  3. The RO has reason to believe there could be potential coverage issues in the State.

The RO may use the following sample template language for the letter and may insert information tailored to the State.

 View PDF Version

If the RO chooses to modify the template language, email a copy of the letter with the added language to ^OGC OPL Controls for review and authorization prior to release. The RO should retain a copy of all letters sent to governors.

B. Regional Chief Counsel

The Regional Chief Counsel’s office reviews Section 218 Agreements, modifications and legal dissolutions for legal form and substance and provides legal opinions, advice and legal clearance. This office also provides legal interpretations on Federal and State laws and advises SSA when to obtain an Attorney General opinion.

C. SSA Central Office

1. Office of Income Security Programs (OISP)

OISP is responsible for administering the State and local coverage program under the Act. OISP is overseen by the Deputy Commissioner for Disability and Income Security Programs. OISP plans, develops, evaluates, and issues operational policies and procedures concerning coverage and wage questions related to Sections 210 and 218 of the Social Security Act. As lead component for the State and local coverage program, OISP:

• Interprets laws and regulations relating to state and local coverage and wages;

• Coordinates national coverage and wage policy with the Internal Revenue Service and other Federal and state agencies;

• Coordinates coverage and wages issues for which no policy has been established or present policy may require a change that may have national impact;

• Issues policies and develops procedures and instructions on coverage, wages, and reporting;

• Administers the policy for decisions involving pre-1987 reporting and wage corrections; and

• Maintains the SSA website for State and Local Government Employers (SLGE); and

• Maintains the SLCH for SSA and the State Social Security Administrators.

2. Office of Central Operations (OCO)

OCO processes wage and correction reports and reconciles Annual Wage Reports with IRS Form 941 tax returns and corresponds with employers showing discrepancies.

3. Office of Communications (OCOMM)

OCOMM is the SSA component responsible for SSA’s national public information and public affairs (PI/PA) programs. Public affairs specialists in each region speak at seminars to discuss the Social Security and Medicare program and its benefits.

4. Office of Legislation and Congressional Affairs (OLCA)

OLCA monitors and advises SSA officials on legislation pending in Congress and on legislative activity including those related to State and local coverage issues. OLCA also prepares testimony and background material for use by SSA officials for congressional hearings and other contacts with the Congress.