TN 15 (12-98)

A. INTRODUCTION

This section explains how to evaluate the payee's response about deposits in the dedicated account as an indicator that funds are improperly commingled and should be counted as resources.

B. POLICY

1. Types of Dedicated Accounts

A dedicated account can be a savings, checking, or money market account established in a financial institution.

2. Past-Due Benefits - Definition

Past-due benefits, for purposes of deposits into dedicated accounts, are:

1. benefits due but unpaid which accrued prior to the month payment was effectuated;

2. benefits due but unpaid which accrued during a period of suspension for which the recipient was subsequently determined to have been eligible; and

3. any adjustment to benefits which results in an accrual of unpaid benefits.

3. Subsequent Past-Due Benefits - Optional Deposit

Any subsequent past-due benefit (including any federally administered State supplement) that equals or exceeds 1 times the Federal Benefit Rate (FBR) plus any federally administered State supplement, but is less than or equal to 6 times the FBR plus any federally administered State supplement (OSS) may be deposited in the dedicated account at the option of the payee.

4. Resources and Income Exclusions

Past-due benefits deposited by SSA, and subsequent past-due benefits as described in B.3. above, are excluded from resources and any accrued interest is excluded from income and resources. No other funds may be deposited in the account. For any month that funds other than authorized past-due benefits and accrued interest are commingled in the account as of the first moment-of-the-month, none of the funds are excluded from resources in that month.

EXCEPTION: Funds, other than past-due benefits, required by a financial institution to open the dedicated account may be commingled in the account, but only until the end of the month following the month that the past-due benefits are direct deposited into the account. The funds required to open the account are not excluded from resources. (See SI 01130.601C.)

C. DESCRIPTION OF SSA-6233-BK - Question 6

D. PROCEDURE

1. Determine Whether Deposit Is Allowed

Review the PMTH segment of the SSR to determine if and when a subsequent past-due benefit was released, and in what amount. Compare this information with the amount and date of deposit provided by the payee. Follow SI 01130.600 for determining application of 6-month exclusion from resources for underpayments.

DECISION FACTOR: Subsequent past-due benefits deposited in the account must equal or exceed 1 times the FBR plus any federally administered State supplement.

2. Deposit Not Allowed - Commingled Funds

• Conduct a face-to-face interview with the payee whenever practical.

• Review the payee's financial records.

• Correct the dedicated account balance (question 8 on the SSA-6233-BK).

• Correct the conserved funds balance (question 3D on the SSA-6233-BK) as appropriate.

• If your review of the dedicated account reveals that a deposit is not allowed, all of the funds in the account are countable resources for any month that funds are commingled as of the first moment-of-the-month.

E. REFERENCES

• Acceptable Titling of Dedicated Accounts, GN 00603.025

• Subsequent Underpayments Which Must, or May, Be Deposited in Dedicated Account, SI 02101.010.C.3.

• Excluding Funds in Dedicated Account From Resources,
  SI 01130.601