GN 02408: Stop Payments and Reclamations
TN 18 (11-08)
IMPORTANT: This section does not apply to International Direct Deposit (IDD) payments (RTN begins with 5, 6, or 7).
A. Overview of manual EFT reclamation requests
The field office (FO) or payment center (PC) must input a manual reclamation request (E-stop) when:
The system has failed to send an automated reclamation request 20 days after a DNE has gone out for Title II, or 30 days after a DNE has gone out for Title XVI;
The FO/PC receives a reject message that the system's attempt to send an automated reclamation request rejected;
An automated or manual E-stop has been sent with an incorrect date of death, and not all of the incorrect payments were requested;
More than 50 Title II payments need to be reclaimed; or
A Title II PMA payment sent after death needs to be reclaimed because the beneficiary was not due the payment. (A manual reclamation request is not needed if the payment was due.)
B. Policy
1. 120-day rule
It is important to input the manual reclamation as soon as the responsible component learns of the need for a manual input. SSA is required by the Code of Federal Regulations to send the reclamation request within 120 days of the date the agency learned of the death.
2. Manual reclamation exclusions
Do not input a manual reclamation request (E-stop) for a case listed in GN 02408.620E in this section.
3. Three-year rule
Effective January 2, 2008, the Department of the Treasury (DT) imposed a three (3) year time limit for federal agencies to submit final debits (i.e., ACH reclaims) of a Financial Institution's (FI) Federal Reserve account via the FMS-135, Request for Debit. An ACH reclaim represents a debit against an FI for certain liability on payments disbursed after the death of a beneficiary. Agencies have three years from the date the FMS-133, Notice of Reclamation, is dated to submit ACH reclaims via the FMS-135 to DT's Philadelphia, Kansas City and San Francisco Regional Financial Centers. Items older than three years are rejected and not processed.
4. Six-year rule
Generally, the FI is not liable for any money received more than six years before the most recent payment. However, if the account contains more than that amount, the FI is responsible for the total amount of all payments made after death, up to the amount in the account when the FI receives the notice of reclamation.
The responsible SSA component must assist the FI by doing a manual reclamation input or providing a reclamation request letter when an FI asks for documentation. (See FI Notifies SSA of Possible Escheat GN 02408.750.)
C. Process for Title II
1. When to do a manual reclamation input
a. Situations when the PC manually inputs an E-Stop
The PC manually inputs an E-stop in the following situations:
A death termination has been on the MBR for more than 20 days, and the PHUS query does not show E-stops (EVENT 070 -1184 SP) on payments issued after death.
The PC has corrected an incorrect month or year of death on the MBR, and not all of the incorrect payments after death were included in the original reclamation request.
SSA does not learn of the death until more than 50 payments have been sent out after death. Because of a systems limitation, the most that can be input on the same day (by either an automated or a manual reclamation request) for one Title II beneficiary is 50 payments. If more than 50 payments need to be reclaimed, the system does not process automated reclamations for any of the payments. It generates an exception to the PC, and the PC must do manual reclamation requests for all of the payments (up to 50 payments per day). SSA notifies the Regional Finance Center in this case, to alert them to combine the requests into one Reclamation Notice to the FI via the Non-Entitlement Due to Death (NED) Report (see NED Report, GN 02408.660 ).
The FI notifies SSA of a death that occurred in the past and requests a reclamation. Many years of payments may be involved, and the FI wants documentation of the reason for returning the large sum of money.
A PMA payment was sent after death, and the beneficiary was not due the payment.
Manually input PMA amounts that are not due AND are reclaimable in the SPA O/P field on the Master Beneficiary Record (MBR).
b. Examples
On September 16, 2007, the FO received a letter saying that Ms. Jones, a Title II beneficiary, had died on August 12, 2006. The FO mistakenly input the date of death as August 12, 2007. A DNE with this information was sent to the FI, followed by a reclamation request to DT for the payment dated August 31, 2007. Upon receipt of the DNE, the FI notified the beneficiary's estate that it had returned the August 31, 2007 payment to SSA because SSA had notified the FI of the beneficiary's death. Ms. Jones' executor called SSA to correct this information. At the request of the FO, the PC then input E-stops for the remaining EFT payments from August 13, 2006 through September 16, 2007.
Mr. Beneficiary died on October 6, 2003, but SSA did not learn of his death until his divorced spouse filed for benefits on December 4, 2008. Title II payments sent to Mr. Beneficiary after his death included his regular payments through December 3, 2008; a PMA for a cost-of-living adjustment in August 2006; and a PMA for a recomputation in February 2004, a total of 64 payments. The PC first input a manual E-stop request for 50 payments, starting with the most recent. The next day, the PC did a manual request for the remaining incorrect payments, including the PMAs since they were not due.
2. Notifying the Regional Financial Center (RFC) when more payments must be reclaimed:
When a manual reclamation request is needed for more months after an automated or manual reclamation request has already been sent, SSA notifies the RFC to put the requests together and send a reclamation notice to the FI for all incorrect payments at the same time using the NED Report. See NED Report, GN 02408.660.
D. Process for Title XVI
1. When to input a manual reclamation
The FO manually inputs an E-stop in the following situations:
A death termination has been on the SSI record for more than 30 days. The SSR shows that one or more incorrect payments were issued. However, the Treasury Status Query (UPTQ) does not show E-stops for one or more of these payments. (For information on the Treasury Status Query, see MSOM BUSSR 003.020)
An incorrect month or year of death has been discovered on the SSI record, and the actual date of death was earlier. An E-stop is required for any incorrect payment that was not included in the original reclamation request.
The date of death is earlier than the start date (SD) on the current record.
NOTE: Unlike Title II, there is no systems limitation on the number of payments that can be included in a Title XVI automated or manual reclamation request.
2. Examples
The recipient's date of death was August 9, 2008, but on September 10, 2008, a date of death (DOD) of September 8, 2008, is input. When the TSR discovers the error, he corrects the DOD and sends a request to the FO to input an E-stop for the September payment, which was dated September 3, 2008.
On September 30, 2008, a date of death for Ms. Day is input as July 10, 2008. When her daughter calls to correct the DOD to July 25, 2008, the CR corrects the date. However, the CR does not send a reclamation request, as the correct DOD did not change the months for which an automated reclamation had already been sent.
After the CR terminates Mr. Cheer's Title XVI record and establishes a new record with a start date of October 1, 2008, she learns that Mr. Cheer died on September 30, 2008. In addition to making the death input, the CR inputs an E-stop for the October 1, 2008, payment.
E. Process for exclusions from the manual reclamation process
In the following situations, do not input a manual E-stop:
1. Title II or Title XVI payment went to a representative payee
A payment that went to the representative payee after the beneficiary's death is a legally defined overpayment. We process the overpayment, giving due process.
2. A spouse or parent on the same Title II record had direct deposit to the same account
For manual reclamation inputs, this exclusion is valid even when the spouse or parent is only technically entitled on the record (in LAF-AD or LAF-SD). (Due to systems limitations, automated reclamations can’t take into account any situations in which the beneficiary is not being paid on the same record. Therefore, the system may send an automated reclamation for these cases.)
The PC sends an overpayment notice, with due process, to collect the incorrect payment(s) from the spouse or parent joint-account holder who was entitled on the same Title II record for the month before the month of death. The PC inputs the overpayment information into ROAR and the MBR BOUD field. If the spouse or parent does not return the funds, the PC takes the money out of benefit payments to the spouse or parent.
NOTE: No DNE is sent to the FI when a beneficiary and spouse share the same bank account. For more about DNE, see GN 02408.605.
3. Beneficiary/Recipient dies on or after an early delivery payment date
When the regular payment date falls on a Saturday, Sunday, or Federal holiday, the payment date becomes the last day before the regular payment date that is not a Saturday, Sunday, or Federal holiday. This is defined as an early delivery payment date. When a Title II or Title XVI beneficiary/recipient dies on an early delivery payment date or later, the payment is normally due the beneficiary/recipient.
EXCEPTION EXAMPLE: 09/03/07 was Labor Day (Monday). The early delivery date was 08/31/07 (Friday). If a Title II beneficiary died on 08/31/07, he or she is not entitled to the payment.
4. IDD payment
Treasury has no authority over foreign banks. Reclamation of Title II IDD payments (when the routing number begins with 5, 6, or 7) begins at GN 02408.900.
5. Direct deposit was involved for either or both members of a Title XVI couple’s case
The system does not send an automated reclamation for a deceased recipient on a Title XVI couple’s record when either or both members had direct deposit. This scenario is treated as an overpayment to the surviving spouse. Do not initiate a manual reclamation.
6. Examples
The Title XVI payment date for March 2008 was February 29, 2008, because March 1 was Saturday. Mr. Smith, who was receiving Title XVI payments, died on February 29, 2008. He was due the payment, and no reclamation was sent.
The Title II payment date for the January 2008 benefit was February 1, 2008. Mr. Johnson, a Title II beneficiary, died at 12:01 AM (just after midnight) on February 1, 2008. He was due the payment, and no reclamation was sent.
The Title XVI payment for February 2008 was February 1, 2008. Ms. Green died at 10:58 PM on January 31, 2008. She was not due the payment, and a reclamation was sent.
John Doe and his wife, Joan, both received Title II benefits on his record to a joint bank account. One payment went out for John after his death, but no reclamation request was sent to DT. Instead, the PC sent an overpayment notice to Joan for the amount of the payment that was not due to John.
Ms. Repp was the representative payee for Ms. Worker, a Title II beneficiary. Two payments went out after Ms. Worker's death. An overpayment notice was sent to Ms. Repp for the amount of the two payments. No reclamation request was sent to DT.
F. References
MSOM RSDHI 002.005 - Stop-Payment Request (PESP)
SM 01315.135 - How to Transmit a Stop-Payment Action
MSOM T2PE 007.016 - Standard Messages
GN 02408.900 - Recovery of Title II IDD Payments Improperly Issued After Death of Beneficiary
SM 00545.295 - Nonreceipt, Stop-Payment and Photocopy Events
SM 01315.134 - When to Initiate a Stop-Payment Action
SM 01315.136 - When the SSI System Automatically Generates Stop-Payment Requests
GN 02408.615 - Automated EFT Reclamation Requests