SSA - POMS: RS 00205.400 - Processing Claims and Conversion Cases for Student Benefits

A. Background

To limit interruptions in benefit payments and to improve payment accuracy to student beneficiaries, SSA obtains verification of the student's school attendance before paying student benefits.

B. Policy

The student must have a school official certify the student's attendance using Form SSA-1372-BK before we adjudicate an initial claim or convert the child beneficiary to student benefits.

Obtain verification of full-time attendance (FTA) for all periods of attendance, whether current or retroactive, in which the child has attained age 18 prior to adjudication or conversion in every case. This policy applies to all educational institutions as defined in RS 00205.200.

For more information on Form SSA-1372-BK, including student responsibilities, refer to RS 00205.735.

C. Taking initial claim for student benefits

The field office (FO) completes the child's application in the Modernized Claims System (MCS) or Form SSA-4-BK, Application for Child's Insurance Benefits, if an MCS exclusion exists. For more information on MCS exclusions, refer to MS 03504.001.

NOTE: For instructions on processing Form SSA-1372-BK, refer to RS 00205.400E in this section.

1. Month of entitlement (MOET)

A child who qualifies for student benefits as the child of a living number holder (NH) must be in FTA “throughout the month” for the first MOET. A student is deemed to meet this requirement if they meet the definition of FTA in RS 00205.300. The “throughout the month” requirement does not apply in death cases.

2. Child who is at least 17 years and 6 months (or will be as of the adjudication date) will be a student in the month of attainment of age 18

a. Automated process

If the child is at least 17 years and 6 months old (or will be as of the adjudication date) and will be a student in the month they attain 18:

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SSA automatically generates and mails Form SSA-1372-BK to the student.
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This process occurs when the child becomes entitled more than 90 days before the child’s 18th birthday.

b. Manual process

If SSA takes the initial claim within 90 days of the child attaining age 18:

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SSA does not automatically mail Form SSA-1372 to the student.
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The 1372 Issue appears on the MCS DW01 screen.
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The FO technician must manually create the SSA-1372-BK using the Document Processing System (DPS), complete SSA’s portion, print the form in the FO, and give or mail the form to the child.

c. Student responsibilities

In both scenarios (C2.a and b above), the child must:

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Complete their portion of the SSA-1372-BK.
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Obtain certification from a school official.

For more information, refer to RS 00205.400D.2 in this section.

d. Returning the form

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If SSA is adjudicating the claim within 90 days of the child attaining 18 and the child will be in actual or deemed FTA in the age 18 attainment month, the child must return the completed form to the FO before adjudication.
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If SSA has already adjudicated the claim, the child must return the completed form to the FO to establish student benefits.

3. Child who is at least 17 years and 6 months (or will be as of the date the claim is adjudicated) alleges a disability

If the child is at least 17 years and 6 months (or will be as of the adjudication date) and alleges being disabled, to develop a Childhood Disability Benefit (CDB) claim follow the instructions in RS 00203.080 – RS 00203.090.

4. Fugitive status

For instructions about determining fugitive status, refer to GN 02613.050 and GN 02613.860.

D. Notices mailed before a child beneficiary attains age 18

When the child is entitled to benefits more than 90 days before the child's 18th birthday, SSA automatically generates and mails the following notices:

1. Form SSA-1387 to payee

Central Office (CO) mails Form SSA-1387, Advance Notice of Termination of Child's Benefits, to the payee when a child beneficiary attains age 17 years and 9 months. This notice informs the payee that the child's benefits will terminate at age 18 unless the child is a full-time elementary or secondary-school student or qualifies for childhood disability benefits. The notice further explains what actions to take if the child is disabled or a full-time student. If the child is disabled, the payee should call or visit any Social Security office or call SSA's toll-free number.

If the payee visits an FO, they should bring:

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The SSA-1387;
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A history of the child's disabling condition;
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Names and addresses of the child's medical record sources;
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Names and addresses of the schools the child attended;
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The child's employment history;
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The child's Social Security number; and
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A copy of a check or bank statement, if the child's name is on the account, for direct deposit.

The notice tells the payee that, if the child will be a student after age 18, the child must complete the SSA-1372-BK and return it to a local Social Security office before age 18.

2. Form SSA-1372-BK to child

At the same time CO mails the SSA-1387 to the payee, it mails the SSA-1372-BK to the child.

The cover sheet tells the child that to receive student benefits after age 18, they must:

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Complete pages 2 and 3, "Student's Statement Regarding School Attendance";
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Take or mail the form to an official of their school to certify the student's attendance on page 4, "Certification By School Official";
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Leave pages 5 and 6 “Notice of Cessation of Full-Time Attendance," with a school official so the school will be able to report the date and reason the student’s full-time attendance ended; and
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Take or mail the completed pages 2 through 4, "Student’s Statement Regarding School Attendance" and the "Certification by School Official," to a Social Security office.

The cover sheet also tells the child that to receive childhood disability benefits, they must contact a Social Security office and provide:

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A history of the disabling condition,
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Names and addresses of medical record sources,
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Names of schools attended,
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Their work history, and
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Their Social Security number.

E. Processing the Form SSA-1372-BK

NOTE: If SSA receives a completed SSA-1372-BK after a beneficiary has been terminated (T4 A18TRM or T6 CNLFTS), refer to RS 00205.400F.2 and RS 00205.400F.3 in this section, as appropriate.

To process the SSA-1372-BK for an initial claim or conversion from benefits as a minor child to student benefits, follow these steps:

STEP	ACTION
1	Review the SSA-1372-BK to: • ensure all questions have responses; • resolve any discrepancies; and • determine whether there are factors that preclude student entitlement, e.g., incarceration (RS 00205.130), being paid by an employer to attend school (RS 00205.125), marriage (RS 00203.001A.1.d and RS 00203.035A.3), or change in relationship to the number holder (GN 00306.000). NOTE: If the child alleges disability, develop a CDB claim following the instructions in RS 00203.080 – RS 00203.090. An allegation of disability on the SSA-1372-BK is not clear intent to file and is not protective filing unless the individual indicates they want to file for benefits. For more information on protective filing, refer to GN 00204.010. Does it appear the child may qualify for student benefits? If yes, go to step 2. If no, and initial claim for student benefits, go to step 7. If no, and conversion from benefits as a minor child to student benefits, go to step 8.
2	Determine if the school the child is attending is an educational institution (EI) as discussed in RS 00205.250. Does the development indicate the school is an EI? If yes, go to step 3. If no, and initial claim for student benefits, go to step 7. If no, and conversion from benefits as a minor child to student benefits, go to step 8.
3	Determine if the child is in FTA as discussed in the following sections: • RS 00205.300 What is Full-Time Attendance • RS 00205.310 Scheduled School Attendance • RS 00205.315 Duration of Course of Study • RS 00205.320 Deemed Full-time Attendance During a Period of Nonattendance • RS 00205.325 When Student Benefits Terminate Does the school certification establish child is in FTA? If yes, go to step 4. If no, and initial claim for student benefits, go to step 7. If no, and conversion from benefits as a minor child to student benefits, go to step 8.
4	Code the STUD screen (MS 00705.029) based on the student's expected graduation date from a secondary school and considering age 19 attainment (RS 00205.325). IMPORTANT: Enter the school’s operating basis as certified by the school official in question 3 on page 4 (Certification by School Official) of the SSA-1372-BK. If an initial claim, go to step 5. If a conversion from benefits as a minor child to student benefits, go to step 6.
5	Take action to award student benefits. Absent evidence to the contrary, consider the student to be a capable adult and pay benefits directly to them. Appoint a representative payee (payee) only if the student is incapable of managing benefits. Continue entitlement while developing a payee. NOTE: Be aware that the beneficiary may be receiving another benefit, such as SSI, through a payee. The same payee must be appointed for all benefits to which the beneficiary is entitled (GN 00502.183.B.3). If the beneficiary is already receiving benefits through a payee, complete a new capability determination prior to paying the beneficiary directly (GN 00502.055.C). NOTE: The Department of the Treasury’s Fiscal Service (Treasury) mandates that all Federal payments be made through electronic funds transfer (EFT), either by direct deposit or Direct Express, unless the beneficiary meets one of the limited exemptions for a Treasury waiver (GN 02402.001). During the initial claim interview, obtain the student's payment information and establish EFT payment. After entitlement and conversion to direct payment, a student may establish and use an eligible my Social Security (mySSA) account to manage direct deposit information. For My Direct Deposit (myDD) functionality, refer to TC 24530.015. The student may also enroll in EFT payment through their financial institution, by calling Social Security's National 800 Number (1-800-772-1213), or by contacting a Social Security office. For Direct Express enrollment instructions, refer to GN 02402.025. Give or mail the following forms to the student: • SSA-1383, Student Reporting Form; and • SSA-453, How Your Earnings Affect Your Benefits. Fax the SSA-1372-BK into the Non-Disability Repository for Evidentiary Documents (NDRed) using the Evidence Portal (EP), or the electronic disability (eDIB) folder using eView or the EP. Once the form is stored and viewed for content in either the EP or eView, destroy the paper copy.
6	Absent evidence to the contrary, consider the student to be a capable adult and pay benefits directly to them. Appoint a payee only if the student is incapable of managing benefits. Continue entitlement while developing a payee. NOTE: Be aware that the beneficiary may be receiving another benefit, such as SSI, through a payee. The same payee must be appointed for all benefits to which the beneficiary is entitled (GN 00502.183.B.3). If the beneficiary is already receiving benefits through a payee, complete a new capability determination prior to paying the beneficiary directly (GN 00502.055.C). NOTE: The Department of the Treasury’s Fiscal Service (Treasury) mandates that all Federal payments be made through EFT unless the beneficiary meets one of the limited exemptions for a Treasury waiver (GN 02402.001). After entitlement and conversion to direct payment, a student may establish and use an eligible mySSA account to manage direct deposit information. For My Direct Deposit (myDD) functionality, refer to TC 24530.015. The student may also enroll in EFT payment through their financial institution, by calling Social Security's National 800 Number (1-800-772-1213), or by contacting a Social Security office (GN 02402.025). For Direct Express enrollment instructions, refer to GN 02402.025. If the student has not provided direct deposit information, follow these steps: • Attempt telephone contact to discuss electronic payment methods and, if necessary, Treasury waiver options. • If telephone contact is successful, discuss electronic payment options and either schedule an appointment or advise the student to visit their local field office with a valid ID, financial institution routing transit number (RTN), depositor account number (DAN), and account type (checking or savings) to arrange direct payment. • If telephone contact is unsuccessful, issue an SSA-2708 Field Office Call In/Come In request stating, “We need to talk to you about electronic payment.” Do not delay processing the SSA-1372-BK. Proceed with paying benefits directly to the student via paper check. • If the student subsequently contacts SSA, follow GN 02402.005F and GN 02402.005G to encourage conversion to direct deposit. NOTE: The student must be receiving their own benefits directly, without a representative payee, to provide their own EFT election. Give or mail the following forms to the student: • SSA-1383, Student Reporting Form; and • SSA-453, How Your Earnings Affect Your Benefits. Fax the SSA-1372-BK into NDRed using the EP, or eDIB using eView or the EP. Once the form is stored and viewed for content in either the EP or eView, destroy the paper copy. NOTE: If the initial POS action excepts, T2R will automate a Paperless ACR to the jurisdictional processing center (PC). In these situations, there is no requirement to fax the document directly into Paperless. The Regular Transcript Attainment and Selection pass (RETAP) system scans the MBR and sends the case to the Title II Redesign program (T2RD). T2RD evaluates the data on the MBR to determine whether a period of intended school attendance has been documented for the month of age 18 attainment. If the documentation exists, entitlement automatically continues. T2RD generates a notice informing the child they will receive benefits directly as a student beginning with the age 18 month.
7	Deny the initial claim for student’s benefits using disallowance code 38, student not attending an EI, or disallowance code 41, student not in FTA (SM 00380.040)). Fax the SSA-1372-BK into NDRed using the EP, or eDIB using eView or the EP. If the child is also applying for disability benefits: • leave the disability portion of the claim pending when denying student’s benefits by entering “N” in the field for “Process Disability Portion of Claim” on the Benefit Continuity Factors (BECF) screen (MS 03509.003); • annotate the SSA-1372-BK “Not full-time student” and fax it with the disability material; and • after storing and viewing the form for content in either the EP or eView, destroy the paper copy.
8	Fax the SSA-1372-BK into NDRed using the EP, or eDIB using eView or the EP. After storing and viewing the form for content in either the EP or eView, destroy the paper copy. The system automatically terminates benefits at age 18 if student data or disability data is not posted to the MBR. T2RD will automatically send the termination notice at age 18.

F. Special Considerations for form SSA-1372-BK

1. PC receives a misrouted SSA-1372-BK before benefits terminate

Review the student's statement and the school's certification (pages 2, 3, and 4) to determine whether student benefits are payable. Be sure the child has answered the disability question.

If the child alleges disability, develop a CDB claim following the instructions in RS 00203.080 – RS 00203.090.

Process the SSA-1372-BK following instructions in RS 00205.400E in this section.

2. Child terminated in age 18 attainment month due to delay in processing SSA-1372-BK

Sometimes SSA receives a completed SSA-1372-BK prior to the system’s automatic termination action, but a delay in processing the SSA-1372-BK causes the system to terminate benefits at age 18. In such cases, process the SSA-1372-BK following the conversion instructions in RS 00205.400E in this section.

NOTE: If the child does not qualify for student benefits, after storing the form as described in step 8 in RS 00205.400E in this section, send the child a notice informing them that the full-time attendance requirement is not met. Include paragraph number 209 (with appropriate fill-ins) from NL 00708.100.

3. Form SSA-1372-BK received after benefits terminated

a. Within 60-day appeal period of the date of the notice of the initial determination or late requests

If the child submits the completed form SSA-1372-BK timely, within the appeal period, and clearly implies disagreement with the termination determination, it can be treated as a request for reconsideration.

NOTE: A claimant or appointed representative who disagrees with an initial determination or decision may request further review under the administrative review process, also known as the appeal process, even if it is not timely. For more information on good cause for extending the appeal period, refer to GN 03101.020.

Process the request for reconsideration under normal procedures (GN 03102.000):

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If the child was not in actual or deemed FTA in the age 18 attainment month (RS 00205.320E), follow instructions in GN 03102.425A.1 to affirm the initial determination. Include paragraph number 209 (with appropriate fill-ins) from NL 00708.100 in the notice of reconsideration determination.

NOTE: If the child meets FTA in a subsequent month after the month the child attains age 18, consider the possibility of re-entitlement (refer to RS 00205.400F.5 in this section).
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If the child qualifies for student benefits, a conversion from benefits as a minor child to student benefits, follow instructions in GN 03102.425B.1 to reverse the initial determination. Code the STUD screen (MS 00705.029) and prepare a MACADE input. Be sure to verify representative payee and direct deposit information, as appropriate, as described in step 6 in RS 00205.400E in this section.

b. Within one year or four years of the date of the notice of the initial determination

SSA can reopen incorrect determinations. If a determination is incorrect, SSA can reopen that determination within a certain time period and for specific reasons, as explained in GN 04001.010. For more information on Title II reopening, refer to GN 04000.000.

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If the child’s entitlement terminated due to attainment of age 18, and within one year they submit a completed SSA-1372-BK showing the child was in FTA in the month they attained 18, we can reopen and revise our determination under the "any reason" standard.

NOTE: If the child meets FTA in a subsequent month after the month the child attains age 18, consider the possibility of re-entitlement (refer to RS 00205.F.5 in this section).
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If the child’s entitlement terminated due to attainment of age 18, and within four years they submit a completed SSA-1372-BK showing the child was in FTA in the month they attained 18, we can reopen and revise our determination on the basis of new and material evidence (GN 04010.030) under the "good cause" standard.

4. Student changes schools or does not graduate on schedule

If the student changes schools or does not graduate on schedule, they must complete another SSA-1372-BK, have their attendance certified by a school official, and return pages 2, 3, and 4 to the FO for processing.

5. Re-entitlement as a student

A child whose entitlement to child’s benefits ended with the month preceding the month the child attained age 18, or with a subsequent month, may be re-entitled on the same earnings record upon filing a new application if they are under age 19 and a full-time student in an elementary or secondary level school program. For more information on requirements for re-entitlement to child’s benefits, refer to RS 00203.015. For more information on taking the claim and processing the SSA-1372-BK, refer to RS 00205.400C and RS 00205.400E in this section.

IMPORTANT: Do not require a new application unless the student turned age 18 during a period of nonattendance that exceeded four consecutive months (RS 00205.320.D). If the PC receives a SSA-1372-BK that shows a break in FTA for more than 4 consecutive months but no new application has been taken, the PC should request the servicing FO to request a new application via the Processing Center Action Control System (PCACS).

G. Procedure for VA non-insured cases

In Veterans’ Administration (VA) non-insured cases (RS 01702.540), forward completed student development and supporting evidence to the PC for processing.

If the child qualifies as a student, the PC prepares the award and lists the case under code 166, Development of Non-Insured VA Payment (RS 01702.558 and RS 01702.562).

If the child does not qualify as a student, the PC prepares an amended award to terminate the child's benefits and adjusts rates to the remaining beneficiaries (RS 01702.572).

Social Security

Program Operations Manual System (POMS)

RS 00205.400 Processing Claims and Conversion Cases for Student Benefits