In many cases, German agencies do not establish a coverage record until a claim for German benefits is filed or the record is requested by another agency, such as SSA. The effort to establish such a record can be very extensive and time consuming particularly when the alleged covered employment took place many years ago. Obviously, U.S. claims processing is delayed, in these cases, while repeated but often unproductive follow up requests are sent.

In many of these cases, only a few QCs are needed and coverage sufficient to yield those QCs may have been earned in later years. This could eliminate the need for a search for the earlier coverage resulting in faster delivery by the German agencies, fewer follow up requests and subsequently faster processing of U.S. totalization claims. Since German coverage generally begins at age 16, coverage prior to 1951 would probably not exist for anyone born in 1935 or later.

Before instructing the BET to obtain a German coverage record, the CA should ascertain the number of months of German coverage that is needed to yield the QCs required for totalization insured status. The CA should also determine whether German coverage prior to 1951 is needed.

As part of the CA's determination that a German coverage record is needed, multiply the number of missing QCs by three to determine the number of months of German coverage that is required to yield those QCs. Advise the BET accordingly.

Also examine the first column of item G of the claimant's form D/USA 1 or D /USA 2 or other material submitted with the claim to see if there is an allegation of coverage under the German sysem prior to 1951. Unless there is such an allegation, advise the BET to request a German coverage record from 1951 to date.

If there is alleged German coverage in the 1937 - 1950 period instruct the BET to request German coverage from 1937 to date unless, in your judgement, the claimant's allegation of coverage after 1950 would be easily sufficient to provide insured status. If doubtful, err on the side of requesting the pre 1951 coverage.