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1580 Management of a Lump Sum Award (Supplemental Security Income (SSI) or Non-SSI)

1581 Managing a Supplemental Security Income (SSI) Lump Sum

CPS December 2011

The SSI coordinator works with the CPS caseworker and the foster care eligibility specialist to manage the child’s SSI lump sum award so that it will not affect the child’s current SSI eligibility. The lump sum procedure differs based on whether the child is in DFPS conservatorship and if the child is in a DFPS paid placement at the time the lump sum is received.

SSI Lump Sum Awards

Some children in DFPS conservatorship receive Supplemental Security Income (SSI) benefits based on their disabilities. An approved SSI application may generate a lump sum payment covering the monthly payments due between the original application date and the date eligibility is established, which is generally three to six months. The Social Security Administration (SSA) calls the lump sum an “underpayment” owed to the beneficiary. SSI lump sum awards are deposited into the regional Children’s Income Account for proper handling as described in section 1581 Managing a Supplemental Security Income (SSI) Lump Sum, unless they are designated by SSA as requiring a dedicated savings account for deposit. See section 1577 "Establishing a Dedicated Account Using a Supplemental Security Income (SSI) Lump Sum".

Non-SSI Lump Sum Awards

Children in conservatorship may receive lump sum awards from a parental entitlement if they meet the eligibility requirements. These may include Veteran Administration (VA) benefits; Retirement, Survivors, and Disability Insurance (RSDI); Railroad Retirement; Teacher Retirement; and other benefits available to children based on the employment earnings or military service of a parent who is disabled, retired, or deceased. These non-SSI lump sum awards are deposited into the regional Children’s Income Account for proper handling as described in section 1582 Managing a Non-SSI (Supplemental Security Income) Lump Sum.

Other types of non-SSI lump sums from a non-parental entitlement include inheritances, gift money, and insurance settlements. The handling of these lump sums is described in section 1582 Managing a Non-SSI (Supplemental Security Income) Lump Sum.

Approvals for Lump Sum Expenditures

Expenditures from the lump sum are permitted under certain conditions and with regional management review and approval, as described in the items below:

  •  1581 Managing a Supplemental Security Income (SSI) Lump Sum

  •  Appendix 1581.1: Appropriate Needs

  •  Appendix 1581: Examples of Appropriate and Inappropriate Items and Services to Purchase With Lump Sum Benefits

At a minimum, approvals are given by the regional SSI coordinator, the CPS supervisor, and the CPS program director. Each region establishes procedures for the lump sum expenditure review and approval process.

Once the funds have been placed into a savings account for the child, items or services may be purchased at a later time if the need arises. Staff should be cognizant of the child’s ongoing needs when making expenditure requests and approvals.

For more information about the approval process see Appendix 1581.1: Appropriate Needs.

Nine-Month Exclusion Period for Resources

Lump Sum Payments

According to SSA, resources are cash and any other personal property owned by an individual. This includes money in a regional Children’s Income checking or savings account. To be eligible for SSI an individual’s total countable resources must not exceed $2,000.

SSA excludes the unspent portion of the SSI lump sum payment from being a countable resource for nine months following the month it is received by DFPS. The nine-month exclusion period begins the month after the payment is received and ends at the end of the ninth month. If the lump sum payment is made by SSA in installments each installment is subject to the nine-month exclusion period as well.

For information on how staff are to properly dispose of SSI and non-SSI lump sum payments within nine months of receipt, see:

  •  1581 Managing a Supplemental Security Income (SSI) Lump Sum

  •  1582 Managing a Non-SSI (Supplemental Security Income) Lump Sum

Conserved Funds

Conserved funds are funds left after spending the child’s monthly benefit. If conserved funds were returned to SSA by a prior representative payee, SSA may reissue these funds to DFPS when becoming the new representative payee. SSA does not consider reissued conserved funds to be an underpayment and are therefore not given the nine-month exclusion period. SSA considers these funds to be a countable resource beginning the month after the month of receipt. Staff handle these funds in accordance with sections 1581 and 1582 but only have one month to properly dispose of the funds.

Returning Funds to SSA or Other Sources

When a child’s SSA benefits are returned to SSA or to the source of the parental entitlement, the regional SSI coordinator is responsible for ensuring the funds are returned to appropriate office. Conserved funds are always returned to SSA or the source of the parental entitlement directly and never forwarded to the beneficiary or a subsequent representative payee. The SSI coordinator works with the regional Children’s Income Accounting (CIA) unit to begin this process. The coordinator:

  •   approves all funds and amounts to be returned for a child;

  •   requests that the CIA accountant creates a check payable to SSA or to the source of the parental entitlement for each child with funds to be returned; and for the CIA accountant to send the funds to the coordinator;

  •   creates a letter explaining why the funds are being returned; and

  •   takes or mails the funds with the letter to the local SSA office or to the source of the parental entitlement.

1581.1 Child Is in a DFPS Paid Foster Care Placement

CPS December 2011

Receipt and Deposit of SSI Lump Sum

Most SSI lump sum awards are electronically deposited into the regional Children's Income Account, at the financial institution holding the accounts, by the Social Security Administration (SSA). SSA notifies the regional SSI coordinator of the lump sum award through an award letter.

  •   When the regional Children’s Income Accountant becomes aware of an SSI lump sum award, the accountant notifies the child’s caseworker, the SSI coordinator, and the foster care eligibility worker within three business days.

  •   If SSA issues the award in the form of a paper warrant, the regional Children’s Income Accountant deposits the warrant into the Children’s Income Account and notifies the child’s caseworker, the SSI coordinator, and the foster care eligibility worker within three business days of receipt of the funds.

Use and Conservation of Lump Sums

Staff follow the four steps below regarding the use and conservation of lump sums in the order listed. Staff proceed to the next step until the entire lump sum payment has been spent, conserved or allocated for expenditure.

The staff involved with processing a lump sum include the regional SSI coordinator, the CPS caseworker, the CPS supervisor, the CPS program director and the regional Children’s Income Accounting (CIA) unit. Once the decision about the utilization of funds has been decided, the regional foster care eligibility specialist is notified (Step 3 below). SSI coordinators are ultimately responsible for ensuring the lump sum is handled according to policy.

Step 1: Consider Appropriate Needs of Child

Within 30 days of the receipt of notice of the SSI or non-SSI lump sum award, the SSI coordinator works with appropriate regional staff to:

  •   identify any appropriate needs the child might have. Expenditures may be, but do not need to be, disability related but must meet the definition of “appropriate needs” as found in Appendix 1581.1: Appropriate Needs. Items that can be purchased by the child’s Medicaid benefit or that are included in the child’s foster care maintenance payment should not be considered for purchase with the lump sum award;

  •   obtain a cost estimate (invoice or purchase order) of all appropriate needs identified; and

  •   obtain approval of the expenditure as authorized by the SSI coordinator, CPS supervisor, and the regional program director.

After approval is obtained, the child’s worker has 30 days in which to purchase the approved items or services. The regional CIA unit issues a check, made payable to the vendor, to the caseworker for the amount of the approved items or services. The caseworker sends receipts for purchases to the regional CIA unit. The CIA unit holds these receipts in accordance with 1567 Records Retention Requirements for Transactions Involving Children’s Funds. The SSI coordinator is responsible for ensuring expenditures are made in a timely manner.

Step 2: Create a Savings Account

Within 30 days after the lump sum expenditure is made, or if no appropriate needs are identified and approved, the SSI coordinator requests that the CIA unit establish a savings account for the child with any remaining funds. For children receiving SSI benefits, including those who also receive RSDI, the amount of the lump sum placed into the savings account cannot exceed $1,150 and the child's total countable resources cannot exceed $2,000. For children who receive RSDI only, there is no limit to the amount of funds placed into a savings account.   

Funds in a savings account can be spent as additional appropriate needs are identified. In addition, if at any time the account balance exceeds the allowable limit at the end of a month, the excess can be spent down for any appropriate need as described in Step 1. If no appropriate needs are identified, the excess is used on cost of care until the balance is below the allowable limits.

Step 3: Apply Balance to Nine Month's Cost of Care

If the child is in a DFPS paid placement at the time the lump sum is received, remaining lump sum funds may be applied up to nine future months cost of care. Any lump sum funds may not be applied to the cost of care for months previously paid to a DFPS paid foster care provider. Within 30 days of creating a savings account, if additional funds exist, regional billing staff:

  •   calculates the amount of foster care to be paid in nine months and determines whether any lump sum amount would remain, using the instructions below;  

  •   applies the lump sum funds to the state’s portion of the child's cost of care for up to the next nine months;

  •   completes Form 8107 Lump Sum Distribution Checklist documenting the use of the lump sum award, placing a copy in the child’s folder maintained by the Children's Income Accounting unit; and

  •   sends a copy of Form 8107 to the regional eligibility specialist and the SSI coordinator, informing them how many months of care will be paid with the lump sum award and if any funds remain after paying nine month's cost of care.

To determine how many months of care can be used to pay for the state’s cost of care from a child's remaining lump sum balance after Steps 1 and 2 have been completed, regional billing staff:

  •   multiplies the number of days in the month by the child’s service level daily rate to get the Total Monthly Cost of Care;

  •   subtracts the monthly benefit amount from the Total Monthly Cost of Care to get the State's Monthly Portion of the child's cost of care; and

  •   divides the remaining lump sum balance by the State's Monthly Portion amount to get the number of months that could be paid.

To determine the remaining balance after the cost of nine months of care, regional billing staff:

  •   multiplies the State's Monthly Portion amount by nine to get the State's Nine-Month Cost of Care projection; and

  •   subtracts the remaining lump sum amount from the State's Nine-Month Cost of Care projection.

Step 4: Determine If the Funds Need to Be Added to the Statewide Trust for Children

If lump sum funds under $1,000 remain after Step 3, the funds are used on the child's cost of care. If $1,000 or more remains, the SSI coordinator contacts the regional attorney to begin a court proceeding to create a separate trust share for the child in the Statewide Trust for Children.

For children who receive SSI, the SSI coordinator notifies the regional attorney to initiate the court action, as it must be completed within nine months of receipt of the lump sum award to prevent the remainder from being considered a countable resource which could affect the child's SSI eligibility.

1581.2 Child Is Not in DFPS Paid Placement

CPS December 2011

When a child moves to a non-DFPS paid placement, the SSI coordinator reports the change in placement to SSA within 10 days after receipt of notice of the placement change.

Child Resides With a Kinship Caregiver or Other Unpaid Caretaker

When a child resides with a kinship caregiver or other unpaid caretaker, other than the parent, and DFPS retains conservatorship, the lump sum award is handled according to the steps described in this section. CIA staff forward the current monthly SSI or RSDI (Retirement, Survivors and Disability Insurance) benefit or another monthly benefit from a parental entitlement to the child’s caregiver. If the lump sum payment consists of payments for past months' benefits, none of the lump sum is issued to the caregiver even when the child resided with that caregiver for those specific months.

Child in an Adoptive Placement

The handling of the child's benefits from SSA or another entity based on a parental entitlement, as described in section 1582 Managing a Non-SSI Lump Sum, while in an adoptive placement depends on the type of benefit the child receives and if the child is eligible for an Adoption Assistance (AA) payment. Before issuing any SSA or other monthly benefits to prospective adoptive parents, Children's Income Accounting staff contact the Adoption Assistance Eligibility Specialist to verify the child's AA eligibility and whether a deferred AA agreement was negotiated for the child.  Benefits are handled as describes below.

Child is Eligible for AA Payments and Receives SSI Only or Both SSI, RSDI, and Other Parental Entitlement Benefits

When a child who receives SSI benefits only or both SSI, RSDI, and the child is eligible for adoption assistance payments, the Adoption Assistance negotiator generally negotiates a deferred Adoption Assistance Agreement with the prospective adoptive parents. The deferred agreement delays payment of the Adoption Assistance benefit until the adoption is consummated. CIA staff forward the monthly benefit to the prospective adoptive parents. DFPS remains representative payee of the child's benefits until the adoption is consummated and keeps the child's conserved funds in the child's savings account.

If a deferred agreement was not negotiated, SSI Coordinators or Children's Income Accounting staff consult with the state office Federal and State Support division for guidance before issuing any SSA benefits.

After consummation, the SSI coordinator resigns as the representative payee for the benefits and ensures all conserved funds, including those in a Dedicated Savings account, and any monthly benefits received by DFPS after the adoption has been consummated are returned to SSA or the entity issuing the parental entitlement benefits for handling.

See policy at 1714.4 SSI Payments and Adoption Assistance Payments for additional information on Adoption Assistance and SSI benefits and 1577 Establishing a Dedicated Account Using a Supplemental Security Income (SSI) Lump Sum.

Child is Eligible for AA Payments and Receives RSDI or Other Parental Entitlement Benefits

When a child who receives RSDI benefits or benefits from another parental entitlement and the child is eligible for adoption assistance payments, Children's Income Accounting (CIA) staff forward the monthly benefit to the prospective adoptive parents. DFPS remains representative payee of the child's benefits until the adoption is consummated and keeps the child's conserved funds in the child's savings account.

After consummation, the SSI coordinator resigns as the representative payee for the benefits and ensures all conserved funds, including those in a Dedicated Savings account, and any monthly benefits received by DFPS after the adoption has been consummated are returned to SSA or the entity issuing the parental entitlement benefits for handling.

Child is Not Eligible for AA Payments and Receives SSI, RSDI or Other Parental Entitlement Benefits

When a child who receives SSI or RSDI benefits, or benefits from a parental entitlement, is not eligible for adoption assistance payments, CIA staff forward the monthly benefit to the prospective adoptive parents. DFPS remains representative payee of the child's benefits until the adoption is consummated and keeps the child's conserved funds in the child's savings account.

After consummation, the SSI coordinator resigns as the representative payee for the benefits and ensures all conserved funds, including those in a Dedicated Savings account, and any monthly benefits received by DFPS after the adoption has been consummated are returned to SSA or the entity issuing the parental entitlement benefits for handling.

Child Returns to Parents

When a child is placed with his or her parents, DFPS may not serve as representative payee even though DFPS may retain conservatorship. SSA eligibility rules require that the income and resources of the parents be used to determine the child’s eligibility.

The SSI coordinator:

  •   contacts SSA to inform them of the placement and resigns as representative payee;

  •   follows the procedures in 1580 Management of a Lump Sum Award (Supplemental Security Income (SSI) or Non-SSI), regarding returning funds to SSA or other sources;

  •   follows the procedures in 1577 Establishing a Dedicated Account Using a Supplemental Security Income (SSI) Lump Sum, if the child has a dedicated savings account;

  •   notifies the child’s caseworker to inform the child’s parents that their child was receiving SSI benefits while in care and that the parents should contact their local SSA office to inquire about possible benefits for the child; and

  •   ensures that any monthly benefits received after the child’s return home are subsequently returned to SSA.

1581.3 Child Is No Longer in DFPS Conservatorship

CPS December 2011

When a child is no longer in DFPS conservatorship, DFPS may not serve as representative payee for the child’s benefits. The exception is for youth in the Extended Foster Care program where SSA allows DFPS to remain the representative payee for the youth's benefits.

When conservatorship is dismissed, the SSI coordinator:

  •   notifies SSA that DFPS is no longer the managing conservator of the child and can no longer serve as representative payee;

  •   follows the procedures in 1580 Management of a Lump Sum Award (Supplemental Security Income (SSI) or Non-SSI), regarding returning funds to SSA or other sources;

  •   follows the procedures in 1577 Establishing a Dedicated Account Using a Supplemental Security Income (SSI) Lump Sum, if the child has a dedicated savings account;

  •   notifies the child’s caseworker to inform the child’s parents that their child was receiving SSI benefits while in care, and that the parents should contact their local SSA office to inquire about possible benefits for the child; and

  •   ensures that any monthly benefits received after DFPS’s conservatorship was dismissed and any conserved funds are returned to SSA.

Unless directed by SSA to return the conserved funds, DFPS may continue to manage the conserved funds of youth in the Extended Foster Care program even when SSA has appointed the youth to be their own representative payee. When the youth leaves extended foster care the youth's conserved funds are returned to SSA.

1581.4 Child Dies While DFPS Is Managing Conservator

CPS December 2011

When a child dies while DFPS is his or her managing conservator, the SSI coordinator follows policy in 1562.4 Handling Deceased Children’s Income.

1581.5 Overpayments

CPS December 2011

SSA may notify DFPS that SSA has issued overpayments to the child. If an overpayment situation exists, the money must be reimbursed to SSA from any remaining portion of the lump sum. SSA reimbursement takes priority over appropriate needs, current cost of care, or a savings account.

1582 Managing a Non-SSI (Supplemental Security Income) Lump Sum

CPS December 2011

Handling Lump Sum Awards from Parental Entitlement

A lump sum from parental entitlement may include:

  •   Veteran Administration (VA) benefits;

  •   Retirement, Survivors, and Disability Insurance (RSDI);

  •   Railroad Retirement;

  •   Teacher Retirement; and

  •   other benefits available to children based on the employment earnings or military service of a parent who is disabled, retired, or deceased.

Upon receipt of a lump sum award from parental entitlement, the SSI coordinator coordinates with the foster care eligibility specialist and other appropriate regional staff to ensure that these funds are handled according to the steps outlined in 1581 Managing a Supplemental Security Income (SSI) Lump Sum. For a definition of a non-SSI lump sums and approvals for lump sum expenditures see 1580 Management of a Lump Sum Award (Supplemental Security Income (SSI) or Non-SSI).

Handling Lump Sum Awards from Non-Governmental Sources

A lump sum from nongovernmental sources may include:

  •   inheritances;

  •   gifts of money;

  •   lawsuits or legal settlements; and

  •   insurance settlements.

The SSI coordinator refers these cases to the state office SSI program specialist. The award is reviewed with the Office of the General Counsel and is handled on a case-by-case basis.

As a general rule, these funds are not used for cost of care.

Overpayments

Non-SSI lump sum awards may not be used to pay back the SSA for any outstanding SSI overpayment claims.

Handling Lump Sum Awards for a Child Who Dies While in DFPS Conservatorship

When a child dies while DFPS is his or her managing conservator, the SSI coordinator follows policy in 1562.4 Handling Deceased Children’s Income.

1583 Supplemental Security Income (SSI) Reports

1583.1 SSI Tracking Report

CPS December 2011

Introduction

Some children in DFPS conservatorship may be eligible to receive SSI benefits based on their disabling conditions. Regional SSI coordinators are responsible for applying for these benefits from the Social Security Administration (SSA) on behalf of these children.

To ensure that children receive SSI benefits, the agency utilizes a tracking system to provide the names of all potentially eligible children who meet the necessary criteria and to track the status of the children’s SSI applications.

SSI Tracking Report

The regional SSI coordinator manages the regional SSI tracking report and makes updates continually. Quarterly, the state office SSI program specialist sends the regional SSI coordinators an electronic list of potentially eligible state-paid and IV-E foster care recipients targeted for SSI benefits. The SSI coordinator screens the children on the list and applies on behalf of those who may qualify.

The SSI Tracking Report is an Excel-based report with three sections entitled:

  •   Client Information/Characteristics (CIC);

  •   Status - Application Status (APP); and

  •   Award Status (AWD).

See also:

Appendix 1583.1: Guide to the SSI Tracking Report

Receiving and Processing the SSI Tracking Report

1.   The state office SSI program specialist sends a PSA (Protective Services Action memo) each quarter prompting the SSI coordinators to electronically mail their current SSI tracking reports to state office. Coordinators do not update their regional SSI tracking report until the program specialist returns the tracking report updated with the new names.

2.   Within three to five working days after receipt of each quarterly regional tracking report, the SSI program specialist updates the regional tracking reports with the names (color-coded in red) of children potentially eligible for SSI and returns the updated SSI tracking reports to the regional SSI coordinators.

3.   After the SSI coordinator receives the updated tracking report, the SSI coordinator screens the list to eliminate children:

  •   whose SSI applications are pending;

  •   who have recently been denied SSI benefits;

  •   who have left DFPS conservatorship;

  •   who have too much income; or

  •   who are current SSI recipients.

4.   The SSI coordinator submits a cover letter to SSA with the list of children who are potentially eligible for benefits and for whom the SSI coordinator will submit an application. In the letter, the SSI coordinator requests a protective filing date that allows DFPS to receive children’s SSI benefits retroactive to the filing date instead of from the time the application is actually submitted.

SSI and Emergency Assistance (EA) and Title IV-E Eligibility

A child cannot simultaneously receive SSI benefits and EA or Title IV-E foster care assistance. Before submitting the request to SSA for a protective filing date for a child, the SSI coordinator ensures that the child’s EA and Title IV-E eligibilities have ended. The quarterly listing of potentially eligible children produced by state office indicates whether the child is EA or Title IV-E eligible. This information is given to the SSI coordinators when the SSI program specialist updates their region's SSI Tracking Report. The SSI coordinators ensure that the child’s EA and Title IV-E eligibilities are ended in IMPACT using the following method.

Title IV-E Eligibility

The decision to deny a child’s Title IV-E eligibility has a fiscal impact on the agency by preventing the agency’s ability to offset a child’s cost of care with federal funds. The SSI coordinator reviews these cases carefully to ensure that the child qualifies for SSI. Though the best interest of the child remains the overriding concern, the SSI coordinator does not pursue application of SSI benefits for Title IV-E eligible children when it is clear that the child will not qualify for SSI benefits. In addition, SSI coordinators do not pursue application of SSI benefits for Title IV-E eligible children with higher then a Basic service level as it is more advantageous to the child and the agency to claim Title IV-E funds than receive the SSI benefit. For an exception to this policy see:

1574 SSI Applications for Youth Aging Out of Care

1583.2 17-Year-Old SSI Report (related to applying for SSI benefits for 17-year-old youths)

If the SSI coordinator decides to pursue SSI eligibility for a Title IV-E eligible child, the child’s Title IV-E eligibility must end on the first date of the month that the SSI coordinator requests a protective filing date with SSA. The SSI coordinator contacts the child’s foster care eligibility specialist to change the child’s Selected Eligibility from Title IV-E to state-paid.

Emergency Assistance (EA) Eligibility

An SSI application cannot be made for any child until the child’s EA eligibility is suspended or terminated. When the SSI coordinator decides to pursue SSI, the coordinator contacts the DFPS Customer Service Center (CSC) at 1-877-642-4777 to request suspension of the child’s EA eligibility.

When the request is made, the coordinator informs the CSC representative that:

  •   the request is a time-sensitive request and needs to be expedited;

  •   the SSI coordinator is the “approving supervisor” on the data change;

  •   the reason for the EA suspension is that the SSI coordinator is making an application for federal funding on behalf of the child from another source (SSI) and the continued EA eligibility creates a dual receipt of federal benefits that is not allowed under existing federal law and regulation; and

  •   to change the child’s EA Deny date to the last day of the month prior to the month the SSI coordinator submits the protective filing date letter to SSA.

The CSC assigns the EA suspension request a ticket number. Each SSI coordinator tracks the requests. If more than a two-week period has elapsed before any action is reported, the coordinator reports the delay to the state office program specialist for the SSI Initiatives.

Since EA eligibility might not have been determined at the time an application is filed, the SSI coordinator verifies the child’s EA status at the time a Notice of Award is received.

Submitting Applications to SSA for Benefits

Applications for SSI benefits must be accompanied by legal, psychological, and medical documents requested by the SSI coordinator from the child’s caseworker. If the application material is not provided to the SSI coordinator on a timely basis, the region remedies this situation by taking whatever steps are necessary. The SSI coordinator submits the application within 60 days after notifying SSA of DFPS’s intent to file an application for benefits. SSI coordinators must have a method for tracking the return of the required application information from field staff.

Updating the Regional Tracking Report

SSI coordinators record the status of each child potentially eligible for SSI that they have screened on the APP Status worksheet on their region’s SSI tracking report. Either the date the application was submitted to SSA under the APP SUB column or the code indicating the reason the child was screened out is entered in the STATUS column. See Appendix 1583.1: Guide to the SSI Tracking Report for the entire list of codes and their descriptions. The coordinator updates the APP STATUS worksheet on an ongoing basis to reflect the dates the applications were submitted to SSA.

On an ongoing basis, the SSI coordinator updates information about SSI awards and current monthly benefits on the AWD (award) Status worksheet of the region’s SSI tracking report.

Regional Oversight

Supervisors of SSI coordinators verify that the coordinators have screened the potentially eligible children and updated the status on their SSI Tracking reports. Supervisors check that:

  •   an entry was made in the STATUS column in the APP STATUS worksheet; and

  •   items marked with a P (current - pending approval) status include a date entry in the APP SUB (date application submitted) column in the same worksheet.

This date must be no later than 60 days after the screening deadline for the current listing included on the quarterly PSA. By adhering to this 60-day time frame the SSI coordinator ensures that if the application is approved and that the child’s eligibility will be retroactive to the protective filing date.

Preventing Overpayments

SSI coordinators receive award letters indicating that a child will be eligible for:

  •   a monthly SSI award; or

  •   a lump sum payment.

Upon receipt of the award letter, the SSI coordinator reviews the child's case to verify that the child's Title IV-E and EA eligibilities continue to show a denied status in IMPACT. The child's Title IV-E and EA eligibilities should have been ended before submission of the request for a protective filing date from SSA. If the coordinator determines that either Title IV-E or EA eligibilities were reinstated they follow the procedures described in the above section SSI and Emergency Assistance (EA) and Title IV-E Eligibility to end the child's Title IV-E or EA eligibility. If the SSI coordinator determines that neither eligibilities were denied and as a result the child was not eligible for ongoing SSI benefits or was not eligible for a specific period of time, the coordinator determines if all or part or of the award must be returned to SSA to prevent an overpayment based on dual receipt of federal benefits. 

In addition the SSI coordinator receives the monthly "SSI/RSDI Recipients With Eligibility Mismatches" report to identify overpayment situations with children receiving SSI benefits and simultaneously having Title IV-E or EA eligibility. The report is described in section 1583.3 SSA Change Reports.

1583.2 17-Year-Old SSI Report

CPS December 2011

The agency has an ongoing interest in supporting youths who are transitioning from foster care to adulthood. The agency pursues Supplemental Security Income (SSI) eligibility for youths prior to their aging out of care at age 18 regardless of the youths' eligibility for Title IV-E assistance. By establishing SSI disability benefits for youth prior to their 18th birthday, DFPS ensures that youth will have monthly SSI benefits to support their transition out of foster care.

State office issues a quarterly report to the regional SSI coordinators identifying youth in foster care who are age 17 and are potentially eligible for SSI. SSI coordinators screen the regional listing to determine whether an SSI application has already been submitted to SSA, an application needs to be submitted, or if SSI eligibility should not be pursued. The SSI coordinator updates the quarterly report with the decision and the status of the youth’s SSI application on the DFPS SharePoint site to which they have been given access.

Regional contacts have been designated to ensure that each quarterly list is researched and updated by the SSI coordinator on the SharePoint site and to assist the SSI coordinator if they are having difficulty obtaining the medical documentation from a child’s caseworker.

When an SSI Application Has Been Submitted to SSA

On the report, the SSI coordinator selects the status of the application from the drop-down box alternatives: Pending, Awarded, or Denied.

  •   If the application is “pending” (application has been submitted to SSA but a decision has not yet been made by SSA), the SSI coordinator enters the date that the application was submitted to SSA.

  •   If the application was “awarded” or approved by SSA (the SSI coordinator received an SSI award letter from SSA), the SSI coordinator notifies the caseworker of the child’s approval for SSI.

  •   If the application was “denied” by SSA more than two years previously, the SSI coordinator assesses if the child’s current disabling condition warrants the submission of another application.

When an SSI Application Has Not Been Submitted to SSA

If an SSI application has not been submitted for a youth on the list, the SSI coordinator has 30 days from date of issuance of the Regional Tracking Report by state office to complete the following tasks.

1.   Screen the listing to determine if an SSI application should be pursued. The SSI coordinator may consult the state office SSI program specialist for assistance in determining if an SSI application is appropriate for a youth.

2.   Contact the caseworker to request all medical documentation that will support an SSI application. The documentation should be sent to the SSI coordinator no later than two weeks from the date of the request. If the caseworker does not send the needed documentation to the SSI coordinator within two weeks, the SSI coordinator asks the designated regional contact for assistance in obtaining this documentation.

3.   Request a protective filing date from SSA upon receipt of the medical documentation from the caseworker.

4.   Coordinate with the foster care eligibility specialist to transition Title IV-E eligible youth from Title IV-E to state-paid. The end date of the Title IV-E eligibility should be the first day of the month in which the SSI coordinator requests a protective filing date with SSA. This ensures that Title IV-E funding ends on the last day of the preceding month and there is no dual federal funding.

On the report, the SSI coordinator indicates:

  •   the date the documentation was requested from the worker;

  •   the protective filing date or the reason why the application is not yet submitted; and

  •   the status of the submitted application.

The SSI coordinator submits the full SSI application to SSA by 60 days from the date of issuance of the Regional Tracking Report by state office. After the report is updated the SSI coordinator contacts the regional contact to let him or her know their regional listing has been updated and is ready for review.

1583.3 SSA Change Reports

CPS December 2011

The regional SSI coordinators are issued a set of reports called the SSA Change Reports on a monthly basis. The reports provide information from IMPACT for SSI/RSDI recipients that may affect the benefits of children receiving Supplemental Security Income (SSI) or Retirement, Survivors, and Disability Insurance (RSDI) benefits from the Social Security Administration (SSA). The three reports are the:

  •   SSI/RSDI Recipients with Conservatorship Dismissal Recorded;

  •   SSI/RSDI Recipients with Placement Changes; and

  •   SSI/RSDI Recipients with Eligibility Mismatches.

Each SSI coordinator is responsible for viewing and performing the duties outlined below on a monthly basis for the children listed under their region on the report. Duties may involve coordination with the CPS caseworker, the regional eligibility specialist, the Children’s Income Account (CIA) accountant or the local Social SSA office. If an SSI coordinator determines that a child appearing on the report under their region is from a different region, the SSI coordinator contacts the SSI coordinator from the child's region for handling.

SSI/RSDI Recipients With Conservatorship Dismissal Recorded Report

The report lists children receiving SSI or RSDI benefits that had a terminating legal status recorded in IMPACT during the prior month. The SSI coordinator uses this report to begin the process of returning conserved funds to SSA belonging to the children identified.

SSI coordinators review the children from their region and:

  •   notify the CIA accountants to prepare checks to return the child’s conserved funds to SSA; or

  •   if the child will be remaining in Extended Foster Care after age 18, contact the CPS caseworker to ensure the Voluntary Extended Foster Care Agreement and Financial Attachment have been signed.

SSI/RSDI Recipients With Placement Changes Report

The reportlists children receiving SSI/RSDI that had a placement change recorded in IMPACT during the previous month. The SSI coordinator uses the report to inform SSA of placement changes for children receiving SSA benefits.

SSI coordinators review the children from their region and:

  •   enter the claim number in the Claim# field for children receiving RSDI benefits;

  •   enter Yes or No for each child in the Remain Payee field depending on whether the agency will remain payee for the child’s benefits; and

  •   send a copy of the report with their region’s listing to their local SSA office or follows their local SSA office procedures for reporting the placement changes within 10 calendar days from receipt of the report.

SSI/RSDI Recipients With Eligibility Mismatches Report

The report lists children who have SSI eligibility and either Emergency Assistance (EA) eligibility or Title IV-E foster care eligibility recorded in IMPACT. The report excludes children placed in ‘Own Home’ or ‘Relative/Kinship home’ placements, and children without an EA eligibility end date and whose EA eligibility deny date for that record is before the earliest financial transaction date for the report.

The SSI coordinator uses the report to identify children whose EA benefits need to be denied and to determine whether it is more advantageous to leave the identified children on SSI or Title IV-E benefits.

To deny EA benefits, SSI coordinators follow the instructions in 1583.1 SSI Tracking Report under the Emergency Assistance (EA) Eligibility section.

To deny Title IV-E benefits, SSI coordinators follow the instructions in 1556.1 SSI Tracking Report under the Title IV-E Eligibility section.

1590 Audits

CPS January 2010

Routine audits are conducted by the Internal Audit section. The Internal Audit section conducts other audits as requested by regional directors.

Routine audits may cover, but are not limited to, the following:

  •  Eligibility status for Title IV-E or state-paid foster children as certified in IMPACT

  •  DFPS's Title IV-E or state-paid foster care reimbursements to individual foster homes, residential facilities, or child-placing agencies to ensure that the daily rate and number of days of care are correct

  •  The Title IV-E or state-paid foster care payments to individual foster homes, residential facilities or child-placing agencies to ensure that the daily rate and number of days of care are correct

  •  Payments made only to licensed or verified facilities

  •  Transactions of children's funds held in regional accounts

Audits are not limited to the preceding items.

1591 Audit Recommendations

CPS January 2010

Management Policy

After an audit, the auditors meet to review the audit findings with the regional administrator, other DFPS staff (including staff who work with the child welfare board), and a representative of the board or the county.

The auditor prepares an audit report and sends it to the assistant commissioner for protective services. The deputy commissioner for programs reviews the report and sends written recommendations for resolution of the audit exceptions to the regional director for families and children.

The regional director provides the recommendations to the local child protective services unit, county officials, and the child welfare board in counties with child welfare contracts. If the child welfare board agrees with the audit recommendation, the board must present written confirmation for use in processing any fiscal adjustments. If the board agrees to reimburse DFPS, the confirmation must include a payment plan. The local unit must report to the regional director the corrective actions taken or scheduled if the audit exception resulted from errors of fact or policy misinterpretations.

The CPS invoice dialog must be used for reimbursements from DFPS. DFPS claim forms must be used for reimbursement to DFPS.

If the child welfare board disagrees with the audit recommendations, the board representative meets with the regional director and regional staff. If an agreement is not reached at this meeting, the board has 10 days to request an appeal. The board sends a letter to the regional director stating the reasons it was not in violation of the contract provisions.

If the audit report recommends a fiscal or management adjustment, the board, region, and local child protective services unit must determine the actions needed to correct the causes of the errors. The child protective services unit must include the follow-up recommendations in the report to the regional director. Examples of recommendations are:

  •  requests for training or consultation to improve accounting procedures;

  •  recommendations for changes in accounting and management procedures; and

  •  changes in or clarification of policies which have caused errors.

The regional director must obtain the necessary consultation for the local units. The Child Protective Services division and the Internal Audit section are available upon request to consult with the region, local unit, or the child welfare board.

The regional director evaluates the recommendations of the local unit and the child welfare board and approves the recommendations. The regional director sends a report to the deputy commissioner for programs on the action taken or scheduled to correct the problems described in the audit report. After approving the report, the deputy commissioner for programs sends it to the chief financial officer.

The region has 60 calendar days after receiving the audit report to respond to the assistant commissioner. If this deadline cannot be met, the regional director may request an extension from the assistant commissioner. In the request, the regional director explains the reasons an extension is needed.

The regional director sends a final report to the deputy director for protective services for families and children after all corrective action is completed and the audit is resolved.

The regional director or designated staff must explain the policies governing audits and audit recommendations to child welfare boards.

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