TN 13 (02-18)

A. Policy for selecting the month to start a PASS

The Social Security Administration (SSA) makes a PASS effective with any month of eligibility for SSI or any month of potential eligibility assuming approval of the PASS, subject to the rules of administrative finality in SI 04070.001.

B. Procedure for selecting the month to start a PASS

1. Starting month

The PASS Cadre uses the month that we receive the plan as the starting month for the PASS unless another month applies per SI 00870.007B.2 or SI 00870.007B.3. in this section.

If the individual is not receiving SSI benefits when they submit the SSA-545-BK, the SSA-545-BK serves as a protective filing. If an individual submits a SSA-545-BK to the field office, set up an appointment to file for SSI benefits. Add remarks to the appointment screens “DI submitted SSA-545-BK with protective filing date of mm/dd/yy. Take full application and contact your regional PASS Cadre.”

2. Retroactivity

Subject to the rules of administrative finality, start a PASS with the earliest month in which the individual was entitled to SSI and was incurring expenses or setting aside money for future expenses related to the work goal. Exclude previously counted income that the individual used or set aside (in a manner that clearly identifies its purpose) for allowable PASS expenses.

If the applicant has an outstanding SSI overpayment, retroactivity may not be possible because any underpayment created by PASS will net against the pending overpayment.

The PASS Cadre will consider retroactivity for a PASS applicant with an SSI overpayment only if the individual was working towards the goal and paying for PASS expenses in the months prior to submitting the plan. In this instance, approving the PASS retroactively reduces the amount of overpayment.

If the PASS applicant receives title II benefits only and has no title XVI entitlement prior to PASS, the date the Cadre receives the SSA-545-BK will be the protective filing date for the title XVI benefit. In this situation, the plan will begin the month after the month of SSI eligibility.

3. Future month

Start a PASS in a future month if:

• it is more advantageous to the individual (e.g., using the month we receive the plan as the starting month provides the individual with a lower SSI payment than expected due to proration); or the individual requests it; and

• the system is able to accept the future month.

NOTE: If the PASS application indicates there will be no expenditures until a date six months or more in the future, we will require a progress review every six months until spending begins.

4. Retrospective Monthly Accounting (RMA) adjustment

Use up to two months prior to the starting month to accommodate the RMA cycle for individuals already eligible for SSI, regardless of whether the individual has already saved money or incurred expenses, when:

• the exclusion of income under the PASS would not increase the SSI payment amount for 1 or 2 months due to RMA; and

• it appears that the individual may need this early exclusion to increase the SSI payment in order to provide a source of funds to set aside for the PASS.

EXAMPLE: Martha, a concurrent beneficiary, submits a PASS in July 2016. She has been working in a sheltered workshop but has an opportunity to begin working in a supported employment setting beginning in August 2016 if she has the additional funds to begin paying her job coach. She proposes to set aside funds from her title II benefit to do this. Recognizing that she needs the increased SSI before she can afford to pay the job coach, input the PASS exclusion as of June 2016 so she will receive an increased SSI payment in August.