The PASS Cadre uses the month we receive the plan as the starting month for the PASS unless another month applies per instructions in this section.

If the individual is not receiving SSI benefits when they submit the SSA-545-BK, follow instructions in SI 00870.020D to establish the lead for the Title XVI application.

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 individual was working towards the goal and paying or saving for future PASS expenses, then the PASS Cadre will consider retroactivity for a PASS applicant with an outstanding overpayment. In this instance, approving the PASS retroactively reduces the amount of the outstanding overpayment.

EXAMPLE: In January 2020, Chue applied and was accepted to a vocational program for the fall term beginning in September 2020. Chue needed to pay a tuition fee of $2500 by September 2020 to attend the program. In February, Chue began saving a portion of their wages each month into a separate bank account to use for educational expenses. Chue continued to save the income through September 2020. Chue did not report their wages timely, resulting in an overpayment in March 2020, June 2020 and August 2020. When they meet with a Claims Specialist in July 2020 to discuss the overpayment, the Claims Specialist refers them to the PASS Cadre to submit a PASS application. The PASS Cadre approves the plan and the tuition for the vocational program. The PASS Specialist reviews the savings and pay stubs and determines that the income that caused the overpayment had been set aside for approved PASS expenses. The PASS Specialist applies a retroactive PASS exclusion beginning in February 2020, the month Chue began saving their wages, and the overpayment is reduced. Additionally, the PASS Specialist excludes the amount in the bank account that had been set aside for tuition.

If the applicant has an outstanding SSI overpayment, a PASS exclusion applied retroactively will net any resulting underpayment against the outstanding overpayment. When the prior overpayment is unrelated to the PASS, a PASS exclusion would not result in a payment that the applicant could use toward approved PASS expenses.

EXAMPLE: Using the example from above, Chue has been saving their wages to cover the cost of their tuition fees and has been reporting their wages timely. However, they have an overpayment on their record from when they were working in 2019, before they began saving for their vocational training. A PASS exclusion applied beginning February 2020 would cause an underpayment which would net against the existing overpayment. Since the prior overpayment is unrelated to the PASS, the PASS Specialist determines that even though Chue had been saving for their approved PASS expenses since February 2020, any resulting underpayment would not be available to pay for the approved tuition expense. The PASS Specialist, therefore, cannot approve the retroactive exclusion of wages.

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. To establish the lead for the Title XVI application, follow instructions in SI 00870.020.

Start a PASS in a future month if:

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  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

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  the individual requests it; and

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  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.

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:

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

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  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: Amaya, a concurrent beneficiary, submits a PASS in May 2019. To become certified in their work goal, they need to begin their coursework in fall 2019; otherwise, they will have to wait another year to begin as the courses only begin each fall. They need to save $1,000 to pay for their classes by August 15, 2019. Their Social Security benefits are $385 per month. If we begin their PASS exclusion in May 2019, the month of application, their SSI will increase in July due to RMA adjustment and they will not be able to save enough money to pay for their classes by August 15. Recognizing that they need the increased SSI before August 15, 2019, input the PASS exclusion as of March 2019. This action enables Amaya to receive an increased SSI payment in May 2019 so that they will be able to save the appropriate amount of money by August 15 in order to begin their coursework.