GN 02401.910:
Handwriting Analysis and Checks Older than 12 Months
Effective Dates: 02/03/2016 - Present- Effective Dates: 06/15/2018 - Present
TN 25 (04-14)- TN 35 (06-18)
GN 02401.910 Handwriting Analysis Needed on a Limited Payability Case- GN 02401.910 Handwriting Analysis and Checks Older than 12 Months
A. Field Office (FO) and Processing Center (PC) policy for handwriting analysis- The Department of the Treasury (Treasury) performs a handwriting analysis to provide an indication about whether the beneficiary, representative payee, or intended recipient may have authored the endorsement on a questioned check.
Occasionally, we request a handwriting analysis on limited payability (LP) cases that the beneficiary or recipient either filed timely but the input was not correct, or did not file timely but the check in question is part of an overpayment on the beneficiary or recipient’s record.- This POMS section applies only to checks that are older than 12 months, where the nonreceipt allegation was not timely. When the beneficiary, representative payee, or intended recipient files a timely nonreceipt request, this is not a handwriting analysis situation. Process the timely nonreceipt request per GN 02406.120 and GN 02406.125.
When we need a handwriting analysis on an LP case, the technician forwards the check information and payee signature letter along with the handwriting analysis cover letter to the Department of the Treasury (Treasury) Questioned Documents Staff (QDS).- A. When to request a handwriting analysis
The cover letter consists of five sections:* Agency Case Contact Information,* Payee Name and Account or ID Number,* Questioned Items,* Standard, and* Any other instructions to assist Treasury with their determination.- The Social Security Administration (SSA) will only request a handwriting analysis from the Treasury Questioned Documents Branch (QDB) when the check in question is older than 12 months and:
- * The beneficiary, recipient or representative payee fails to file a timely nonreceipt request, and
- * The check in question is part of an overpayment on the record.
NOTE: Technicians must manually prepare the letters for each LP case requiring a handwriting analysis.- Example of a check that is older than 12 months, the check payee did not file a timely nonreceipt, and the check in question is part of an overpayment:
Example of Nonreceipt filed timely, but not input correctly- Mark Coleman received an overpayment notice dated June 2015 stating that he is overpaid $1200.00 for April 2014. Mr. Coleman contacted SSA and stated that he did not receive the payment in question. A review of the record indicates Mr. Coleman never filed a nonreceipt for the payment.
The beneficiary alleged nonreceipt in a timely manner. However, the technician input the nonreceipt as a photocopy request (K-stop) in error instead of a permanent stop (such as a B-stop or C-stop). Treasury sent an FMS-3858 (Claims Document) and a photocopy, but no FMS-1133 (Claim Against the United States for the Proceeds of a Government Check). The check is now over 12 months old, in limited payability status. At this point, the technician should prepare the letters for a Treasury handwriting analysis.- Because the check that is part of an overpayment is now older than 12 months, and the nonreceipt was not filed timely; the technician will submit this case for a handwriting analysis.
B. Assembling a package- Upon receipt of the handwriting analysis, follow processing procedures found in GN 02401.913.
1. Retrieve photocopies- For additional information on preparing and sending the handwriting analysis package, see GN 02401.911 and GN 02401.912.
a. Title II process- B. When not to request a handwriting analysis
The FO should:* Access the Treasury Check Information System (TCIS) to obtain check copies, if available.* Send a modernized development worksheet (MDW) to the PC, if TCIS is not available, instructing the technician to search eView to see if the check photocopy is available. The PC should forward the photocopy to the FO only if requested.* Contact Treasury at (855) 868-0151 to request an original photocopy of the check if the photocopies of the check(s) are missing or not available on TCIS.* Set a control for return in 30 days. NOTE: If not received, re-contact Treasury at (855) 868-0151.- Do not request a handwriting analysis for a check older than 12 months when:
- * A beneficiary, recipient or representative payee timely alleged nonreceipt per GN 02401.902A, and
- * SSA did not submit the nonreceipt allegation to Treasury within 12 months.
b. Title XVI processThe FO should:* Access TCIS to obtain check copies, if available.* Contact Treasury at (855) 868-0151 to request an original photocopy of the check if TCIS is unavailable, or photocopies of checks are not available.* Set a control for return in 30 days. NOTE: If not received, re-contact Treasury at (855) 868-0151.2. Obtain completed Request for Check Information and Payee Signature Lettera. PC responsibilityForward a photocopy of the check(s), and the request for check information and payee signature letter to the beneficiary for examination and completion. To view the request for check information and payee signature letter, see NL 03001.055.NOTE: Use a separate request letter for each check(s) submitted.REMINDER: These are the only letters we will use to request a signature for a handwriting analysis.Include a self-addressed envelope for return of the documents to the PC and control for return in 60 days.After examining the check copy, if the beneficiary does not wish to pursue the nonreceipt allegation, e.g., he or she recognizes his or her own signature, prong-file the material in paperless. The responses to the questions on the signed form provide the necessary information to make the determination.If the PC:* did not receive a completed check information and payee signature request form after 60 days, document it in the file folder, eView, or MDW; or* received a completed request for check information and payee signature letter, review the letter to ensure the beneficiary completed and signed it. For additional information on reviewing the form prior to forwarding to Treasury for a handwriting analysis, see instructions in GN 02401.910C.1. through GN 02401.910C.4. in this section.Retain a copy of the completed form in the eView folder.b. FO responsibilityAfter obtaining photocopy(s) from the PC, mail a photocopy of the check(s), and the request for check information and payee signature letter to the beneficiary or recipient for examination and completion. To view the request for check information and payee signature letter, see NL 03001.055. Use a separate request for each check letter. Provide assistance when necessary if the recipient visits the FO directly.Include a self-addressed envelope for return of the documents to the FO and control for return in 60 days.If the FO:* did not receive a completed check information and payee signature letter after 60 days, document the file folder or MDW; or* received a completed check information and payee signature letter, review the letter to ensure that the recipient completed and signed it.* For additional information on reviewing the letter prior to forwarding documents to Treasury for a handwriting analysis, see instructions in GN 02401.910C.1. through GN 02401.910C.4. in this section* retain a copy of the check information and payee signature letter in the FO for 2 years.3. Check Information and Payee Signature Letter returned incompleteIf the beneficiary or recipient returns an incomplete check information and payee signature letter (i.e., questions left unanswered, signature examples are missing, etc.) take the following action.a. PC responsibility for title II cases* Re-mail the check information and payee signature letter to the check payee informing him or her to complete the incomplete items on the form to expedite processing.* Control for 30 days. If no response, attempt to contact the beneficiary or recipient via phone. If no response to phone contact, forward the material to the FO for follow-up.* If the beneficiary returns a completed check information and payee signature letter to SSA, see instructions for reviewing the letter prior to forwarding it to Treasury for a handwriting analysis in GN 02401.910C.1 through GN 02401.910C.4.* If the PC did not receive the completed check information and payee signature letter after 30 days, document the MDW, claims folder and file material.b. Division of Benefit Certification and Systems Analysis (DBCSA) responsibility for title XVI casesIf the DBCSA receives a title XVI letter, forward it with a transmittal, to the FO for completion.c. FO responsibility for title XVI cases* If the FO receives an incomplete letter, the technician will contact the recipient to complete cases originating in FO and those referred from PC or DBCSA.* For PC referrals forward completed materials back to PC.* For DBCSA referrals, the FO retains a copy of the completed materials in the FO for 2 years. The FO will process original documents per GN 02401.910B.2.* If the recipient returns a completed check information and payee signature letter to SSA, see instructions on reviewing the letter prior to forwarding it to Treasury for a handwriting analysis in GN 02401.910C.1. through GN 02401.910C.4. in this section.NOTE: The beneficiary or recipient is not directly involved with Treasury.C. Treasury handwriting analysis process1. Review of the Check Information and Payee Signature LetterThe technician should review the responses to the questions on the check information and payee signature letter to make sure they are complete.2. When to forward for handwriting analysisForward the letter to Treasury for handwriting analysis if responses on the check information and payee signature letter indicate the beneficiary, recipient, or payee:* never received check,* did not endorse check,* did not cash check,* did not give permission for another person to cash the check,* did not benefit from proceeds of check, AND* did not have access to the account check was deposited.If the beneficiary, recipient or payee answers yes to any of these questions, do not forward the document to Treasury. No further action is necessary.3. What to forward to TreasuryInclude all information Treasury will need to make the determination; i.e.:* Check copy(ies).* Check information and payee signature letter (s) located in NL 03001.055.* Photocopy the Handwriting Analysis Request Cover Letter for Limited Payability Cases located in NL 03001.060 and forward to the following address: US Department of the Treasury Bureau of Fiscal Service Philadelphia Financial Center 13000 Townsend Rd Philadelphia, PA 19154NOTE: Please include the cover notice located in NL 03001.060. Treasury will return the entire package if the cover letter is not included.* Annotate envelope, “ATTN: Kevin McDaniels, DO NOT OPEN IN MAILROOM.”* Control for return in 60 days.4. No response received within 60 daysIf Treasury does not respond within 60 days, the technician will prepare the Handwriting Analysis Request Cover Letter for Limited Payability Cases found in NL 03001.060 and send the follow-up request to the above address. Write “Follow-up to Request Dated MM/DD/YYYY” in red across the top and control for return in 60 days.5. No response to first follow-upIf there is no response to the first follow-up:* PCs: Technicians should refer the case to the Operations Analysis staff (OAS) for assistance;* FOs: The Operations Supervisor should contact the RO Analyst in your region for assistance; and* OAS and RO Analysts: Contact the Philadelphia Financial Center at (855) 868-0151.6. PC or FO action when response received from TreasuryWhen the PC or FO receives the handwriting analysis letter (HAL) from Treasury, follow steps in GN 02401.910D.D. Procedure when SSA receives the HALTreasury sends a HAL to SSA based on the Agency Location Code (ALC). A title II document goes back to the PC of jurisdiction; title XVI documents go to DBCSA who then routes them to the servicing FO.If the HAL states any of the following, proceed as indicated.1. No signatures availableResubmit the package to QDS with signature samples from the beneficiary or recipient’s file or from previous checks that the beneficiary or recipient has endorsed.2. The author of the standard writing samples appears to be the author of the endorsement on the questioned check.This check does not appear to be forged. For additional information, see GN 02401.910F in this section.3. The author of the standard writing samples does not appear to be the author of the endorsement on the questioned check.This check appears to be forged. For additional information, see GN 02401.910E in this section.E. When the check appears to be forged1. Nonreceipt filed timelyAfter the technician determines that the beneficiary or recipient filed the nonreceipt timely, take the following actions:* reissue the check if the payment is still due;* annotate the special message (SPC MSG) or REMARKS field with “Limited Payability Case MM/DD/YYYY paid via SPS. NOTE: Use the original payment date of the check and the payment system used to repay the check; and* send a notice per NL 03001.025.2. Nonreceipt not filed timelyAfter the technician determined that the claimant did not file the nonreceipt timely, take the following actions:* If it is determined that the check was forged AND the check amount was included in an overpayment currently on the beneficiary’s or recipient's record, adjust the overpayment as described in GN 02210.006. Do not reissue another payment.* If the forged check is not part of an overpayment on the claimant’s record, do not issue another check. This check did not require a handwriting analysis from Treasury.Example of nonreceipt not filed timely:John Doe received a check dated 12/31/09. Someone stole John’s check from his mailbox and cashed it in a fraudulent manner. SSA suspends John's benefits from 12/01/2009 through 03/03/2011 and posts an overpayment to his record equal to the amount of the 12/31/09 check. John alleges nonreceipt of the 12/31/09 check on 03/03/11. Since John failed to file the nonreceipt timely, the technician will request a handwriting analysis ONLY because the check in question is part of an overpayment on the beneficiary's record.F. When check does not appear to be forgedDo not reissue the payment. Send the beneficiary or recipient the notice found in NL 03001.025 explaining Treasury’s findings and inform him or her that no replacement check is due.- The technician will follow the procedures outlined in GN 02401.902 for repaying the payment.
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