Implementation will be ineffective --- no organized structure or implementation and retirements gut effectiveness

(Dawn Nuschler, Specialist in Income Security, Congressional Research Service, “International Social Security Agreements,” pg online @ https://www.everycrsreport.com/files/20100111_R41009_f1dc12843e82d3913aa00854a71db03a76c1ee57.html#_Toc251315428 //um-ef)

Despite these initiatives, GAO cautioned in 2005:

While these tools appear to be a positive first step for helping SSA identify potential risks associated with future totalization agreements, SSA has only recently begun implementing them and has not developed plans to integrate these initiatives into formal procedures. The lack of a formal protocol, coupled with the expected retirement of key management and staff over the next few years, may result in the loss of important institutional knowledge relating to totalization agreements, which may hinder the agency's ability to effectively assess risks associated with future agreements.127