Organizational Structure of the Social Security Administration

SSA Organizational Manual: Chapter S9 - The Office of the General Counsel

  1. Mission
    1. The Office of the General Counsel advises the Commissioner on legal matters, is responsible for providing all legal advice to the Commissioner, Deputy Commissioner, and all subordinate organizational components (except OIG) of SSA in connection with the operation and administration of SSA. The Office also develops and implements SSA’s privacy and disclosure policies under the Freedom of Information Act, the Privacy Act of 1974, and other privacy and disclosure laws and guidelines.
  2. Organization
    1. The General Counsel (S9).
    2. The Deputy General Counsel (S9).
    3. The Immediate Office of the General Counsel (S9A)
      1. The Executive Operations Staff ( S9A-3).
      2. The IT Resource Management Staff (S9A-4).
    4. The Office of General Law (S9B).
    5. The Office of Program Law (S9E).
    6. The Office of Privacy and Disclosure (S9H).
    7. The Offices of the Regional Chief Counsels (S9G-F1-S9G- FX).
  3. Functions
    1. The General Counsel (S9) is directly responsible to the Commissioner for carrying out the OGC mission and providing general supervision to the major components of OGC. The General Counsel serves as the Senior Agency Official for Privacy and the Chief Freedom of Information Act Officer.
    2. The Deputy General Counsel (S9) assists the General Counsel in carrying out his/her responsibilities and performs other duties as the General Counsel may prescribe. The Deputy General Counsel with oversight and responsibility for general law matters directly oversees the Office of General Law, the Office of Privacy and Disclosure, and general law issues and litigation across the Offices of the Regional Chief Counsels. The Deputy General Counsel with oversight and responsibility for program law matters directly oversees the Office of Program Law and program law and litigation issues across the Offices of the Regional Chief Counsels. The Deputy General Counsel with oversight and responsibility over program law matters also serves as the Designated Agency Ethics Official (DAEO) with responsibility for coordinating and managing the Social Security Administration's (SSA’s) ethics program. In addition, the Designated Agency Ethics Official (DAEO) and the Alternate DAEO serves on all ethics issues with an emphasis on the education and enforcement of the Standards of Ethical Conduct for Employees of the Executive Branch, the Hatch Act, and related ethics regulations. In the event of the General Counsel's absence or disability, or in the event of a vacancy in the position of General Counsel, the Deputy General Counsel with oversight and responsibility for program law matters acts for him/her unless the Commissioner directs otherwise.
    3. The Immediate Office of the General Counsel (S9A) includes the Executive Operations Staff (S9A-3).
      1. The Executive Operations Staff (S9A-3) provides internal organizational planning, management analysis and review, staff support and assistance to the General Counsel, Deputy General Counsel, OGC Executive Staff, OGC Executive Officer, and other OGC managers. Plans, develops, and coordinates OGC's financial, personnel, and administrative management regional offices. Plans, directs and provides day-to-day operational support services on all areas of administrative, budget, space and facilities, communications, and systems management. Identifies, coordinates, and implements OGC's training program. Formulates, justifies, and presents annual and multi- year budget submissions. Controls the collection, recording, and reporting of all financial, personnel, and administrative data in connection with budget and staffing formulation and executive functions.
      2. The IT Resource Management Staff (S9A-4) designs, develops, manages, supports, plans, maintains, and executes all aspects of systems planning and operations for the OGC. This includes the full range of hardware, software, and IT service initiatives and issues impacting OGC operations nationwide. Conducting research and analysis of Title II and title XVI disability issues, focusing on the susceptibility of SSA policies and processes to disability fraud
    4. The Office of General Law (S9B) provides all legal services to the Commissioner and every Headquarters component of the Agency on all non-program legal issues affecting the Agency’s operations and employees, with an emphasis on labor and employment law advice and litigation, other complex litigation with potential broad implications, contract formation, administration and litigation, E-Discovery, as well as appropriations and property management. OGL also provides legal advice on the provision of legal services incident to the agency’s duties and responsibilities under the Privacy Act, the Freedom of Information Act and related statutes. OGL acts as the agency’s Claims and Touhy officer.
    5. The Office of Program Law (OPL) (S9E) is responsible for providing a full range of legal services and advice (including administrative and court litigation) to the Social Security Administration (SSA) related to the operation and administration of its various programs under the Social Security Act. OPL is responsible for drafting and reviewing SSA regulations, Federal Register materials, and legal instruments within OPL’s areas of jurisdiction; proposals for legislation and specifications for such proposed legislation; reports and letters to congressional committees, the Office of Management and Budget, and others on proposed legislation and legislative matters and proposed testimony of SSA officials before Congress. OPL also coordinates program litigation strategy nationwide and is responsible for comprehensive analyses of litigation trends. OPL represents SSA, in concert with the Department of Justice, in litigation challenging its policies and procedures, the constitutionality of provisions of the Social Security Act, and benefit claim determinations.
    6. The Office of Privacy and Disclosure (S9H). The Office of Privacy and Disclosure (S9H) develops and interprets SSA policy related to the agency’s collection, use, maintenance and disclosure of information, to ensure compliance with: section 1106 of the Social Security Act, the Privacy Act of 1974; the Freedom of Information Act (FOIA); section 6103 of the Internal Revenue Code; the privacy provisions of the E-Government Act of 2002 and the Federal Information Security Management Act; and other applicable privacy and disclosure statutes and regulations and administration policies. To further its mission, OPD develops national guidelines and oversees the agency’s responses to FOIA requests; provides guidance and advice regarding the appropriate disclosure of agency information under the agency’s policies; and ensures necessary privacy protections are built into new systems and processes developed to deliver more efficient service to agency customers. OPD also drafts and manages Computer Matching and Privacy Protection Act (CMPPA) agreements and other agreements governing information sharing.
    7. The Offices of Regional Chief Counsels (S9G-F1 - S9G-FX) provide the Commissioner and the various regional components of SSA with legal services and support as follows:
      1. Provide professional legal and managerial expertise for the OGC in their respective geographic locations.
      2. Provide litigation support and legal services and advice to the SSA Regional Commissioners in the various areas set out above regarding OGC offices.

Subchapter S9B - Office of General Law

  1. Mission
    1. As a component of the Office of the General Counsel, the Office of General Law (OGL) provides all legal services to the Commissioner and every Headquarters component of the Agency on all non-program legal issues affecting the Agency’s operations and employees, except for matters involving personnel and employment law.
  2. Organization
    1. The Associate General Counsel for General Law (S9B)
    2. The Deputy Associate General Counsel for General Law (S9B)
    3. The Immediate Office of the Associate General Counsel for General Law (S9B)
    4. The Contracts and Fiscal Law Division (S9BA)
    5. The Disclosure Law Division (S9BB)
    6. The Employment Law Division (S9BC)
    7. The Strategic Litigation Division (S9BG)
  3. Functions
    1. The Associate General Counsel for General Law (S9B) leads OGL in executing its mission, Claims Officer and Touhy Officer, and performs other duties as the General Counsel or Deputy General Counsel may prescribe.
    2. The Deputy Associate General Counsel for General Law (S9B) assists the Associate General Counsel in carrying out his/her responsibilities and performs other duties as the Associate General Counsel may prescribe.
    3. The Immediate Office of the Associate General Counsel for General Law (S9B) provides the Associate General Counsel and Deputy Associate General Counsel with staff and technical assistance on the full range of his/her responsibilities.
    4. The Contracts and Fiscal Law Division (S9BA) is responsible for providing legal advice on all non-program legal issues affecting the Agency’s operations and employees with an emphasis on contract formation, administration and litigation as well as appropriations and property management matters.
    5. The Disclosure Law Division (S9BB) is responsible for providing legal advice on all non-program legal issues affecting the Agency’s operations and employees with an emphasis on the provision of legal services incident to the Agency’s duties and responsibilities under the Privacy Act, the Freedom of Information Act and related statutes.
    6. The Employment Law Division (S9BC) is responsible for providing all non-program legal issues affecting the Agency’s operations and employees with an emphasis on advising Agency components on labor law matters and providing appropriate related representation.
    7. The Strategic Litigation Division (S9BG) is responsible for providing advice and litigating legal matters that require a centralized approach, including employment law and other class actions, eDiscovery, and labor relations matters. This includes handling such cases before the Merit Systems Protection Board (MSPB), the Federal Labor Relations Authority, the Equal Employment Opportunity Commission (EEOC), and arbitrators. It also will develop best practices on issues that have a national scope, such as those involving the EEOC and MSPB.

Subchapter S9E - Office of Program Law

  1. Mission
    1. The Office of Program Law (OPL) is responsible for providing a full range of legal services and advice (including administrative and court litigation) to the Social Security Administration (SSA) related to the operation and administration of its various programs under the Social Security Act.
    2. OPL is responsible for drafting and/or reviewing SSA regulations, Federal Register materials, and legal instruments within OPL’s areas of jurisdiction; proposals for legislation and specifications for such proposed legislation; reports and letters to congressional committees, the Office of Management and Budget, and others on proposed legislation and legislative matters; and proposed testimony of SSA officials before Congress.
    3. OPL also coordinates program litigation strategy nationwide and is responsible for comprehensive analyses of litigation trends. OPL represents SSA, in concert with the Department of Justice, in litigation challenging its policies and procedures, the constitutionality of provisions of the Social Security Act, and benefit claim determinations.
  2. Organization A.The Associate General Counsel for Program Law (S9E) B.The Deputy Associate General Counsel for Program Law (S9E) C.The Immediate Office of the Associate General Counsel for Program Law (S9E). 1. The Management Information and Process Analysis Staff (S9E-1) D.The Disability Program Division (S9EA) E.The Title II Program Division (S9EB) F.The Title VIII and XVI Programs Division (S9EC)
  3. Functions
    1. The Associate General Counsel for Program Law (S9E) is directly responsible to the General Counsel for carrying out OPL’s mission and provides general supervision to the components of OPL.
    2. The Deputy Associate General Counsel for Program Law (S9E) assists the Associate General Counsel in carrying out his/her responsibilities and performs other duties as the Associate General Counsel may prescribe.
    3. The Immediate Office of the Associate General Counsel (S9E) provides the Associate General Counsel with staff assistance on the full range of his/her responsibilities.
      1. The Management Information and Process Analysis Staff (S9E-1) is responsible for developing and analyzing a variety of management information related to litigation trends and outcomes. As part of this function, the Staff provides analysis and recommendations regarding litigation strategies and challenges to SSA’s policies and procedures.
    4. The Disability Program Division (S9EA) is responsible for providing legal advice to SSA’s components on disability issues in order to ensure the integration of Agency policies and coordinating disability program litigation strategy. This Division also represents SSA, in concert with the Department of Justice, in litigation challenges to the disability program.
    5. The Title II Program Division (S9EB) is responsible for providing legal advice to SSA’s components on non-disability issues arising under the Title II insurance program in order to ensure the integration of Agency policies and coordinating litigation strategies relative to non-disability issues. This Division also represents SSA, in concert with the Department of Justice, in litigation challenges to the Retirement and Survivors Insurance program, non-disability entitlement, coverage and administrative policies and procedures.
    6. The Title VIII and XVI Programs Division (S9EC) is responsible for providing legal advice to SSA’s components on non-disability issues arising under Titles VIII and XVI in order to ensure the integration of Agency policies and coordinating litigation strategies relative to the Special Benefits for certain World War II Veterans and Supplemental Security Income issues. This Division also represents SSA, in concert with the Department of Justice, in litigation challenges to Title VIII and Title XVI policies and procedures.

Subchapter S9H - Office of Privacy and Disclosure

  1. Mission
    1. The Office of Privacy and Disclosure (OPD)(S9H) provides guidance to SSA and develops and interprets SSA policy related to the agency’s collection, use, maintenance and disclosure of information to ensure compliance with: section 1106 of the Social Security Act; the Privacy Act of 1974; the Freedom of Information Act (FOIA); section 6103 of the Internal Revenue Code; and other applicable privacy and disclosure statutes, regulations, and Administration policies. To further its mission, OPD develops national guidelines and oversees SSA’s FOIA activities; provides guidance and advice regarding the appropriate disclosure of agency information; and ensures that the necessary privacy protections are built into new systems and processes developed to deliver service that is more efficient to agency customers. OPD also drafts and manages Computer Matching and Privacy Protection Act (CMPPA) agreements and other agreements governing information sharing.
  2. Organization
    1. The Executive Director for Privacy and Disclosure (S9H)
    2. The Deputy Executive Director for Privacy and Disclosure (S9H)
    3. The Immediate Office of the Executive Director for Privacy and Disclosure (S9H)
    4. The Disclosure and Data Support Division (S9HA)
    5. The Privacy Implementation Division (S9HB)
    6. The FOIA and Transparancy Division (S9HC)
    7. The Electronic Interchange and LIaison Division (S9HE)
  3. Functions
    1. The Executive Director for Privacy and Disclosure (S9H) is directly responsible to the General Counsel for carrying out the OPD mission and providing general supervision to the components of OPD.
    2. The Deputy Executive Director for Privacy and Disclosure (S9H) assists the Executive Director in carrying out the other duties as the Executive Director may prescribe. The Deputy Executive Director for Public Disclosure also serves as SSA’s Freedom of Information Officer and Privacy Officer.
    3. The Immediate Office of the Executive Director for Privacy and Disclosure (S9H) provides the Executive Director and Deputy Executive Director with administrative staff assistance, technology leadership, planning, and customer relations support on the full range of their responsibilities.
    4. The Disclosure Data Support Division (S9HA)
      1. Provides guidance and services to SSA Regional and Headquarters components to resolve questions of whether Agency employees may disclose personal information from Agency records.
      2. Provides guidance on questions arising under other disclosure statutes.
      3. Responds to requests for personal information pursuant to a subpoena, court order or law enforcement request.
      4. Develops, manages, and tracks policy and emerging trends related to alldisclosure and data exchange issues throughout Headquarters and the Regions.
      5. Provides support on FOIA requests and appeals, and Privacy Act appeals.
    5. The Privacy Implementation Division (S9HB).
      1. Identifies and ensures that all programs and systems comply with privacy requirements contained in the FISMA certification and accreditation process and the OMB 300 budget submission.
      2. Develops privacy implementation documentation for Agency systems and programs, i.e., privacy threshold analyses, privacy impact assessments, and systems of records notices.
      3. Reviews Agency technology business process descriptions, project scope agreements and software development and procurement plans for privacy issues.
      4. Prepares notices, manages privacy incidents, and the agency’s non-cyber and cyber-related data breach reporting, and supports the agency’s response to cyber-related data breach incidents.
      5. Develops, manages, and tracks policy and emerging trends related to all privacyissues throughout Headquarters and the Regions.
      6. Provides support on FOIA requests and appeals, and Privacy Act appeals.
    6. The FOIA and Transparency Division (S9HC)
      1. Develops national guidelines related to FOIA and coordinates, directs, and provides guidance on FOIA policies and procedures throughout OPD, other Headquarters components, and the Regions.
      2. Responds to simple and complex FOIA requests and appeals, coordinates office-wide FOIA processes, and handles collection of responsive materials.
      3. Carries out FOIA-related Open Government initiatives.
      4. Coordinates and directs any internal or external FOIA reports.
      5. Plans, directs, and manages use of the eFOIA processing system.
      6. Supports the FOIA Officer in the coordination of FOIA-related litigation
      7. Develops, manages, and tracks policy and emerging trends related to FOIA throughout Headquarters and the Regions.
      8. Provides support on Privacy Act appeals.
    7. The Electronic Interchange and Liaison DivisionS9HE)
      1. Negotiates and manages matching agreements that are subject to the CMPPA and similar information exchange agreements.
      2. Provides leadership to the Agency’s Data Integrity Board (DIB) on CMPPA processes that include advising the DIB and supports AC-level committees on nationwide operating policies related to data exchange.
      3. Develops, manages and tracks policy and emerging trends related to all data exchanges, including the CMPPA throughout Headquarters and the Regions.
      4. Oversees the maintenance of the Electronic Data Exchange System Tracking System.
      5. Provides support on FOIA requests and appeals, and Privacy Act appeals.