TN 9 (10-17)
GN 02230.035 Overview of the Non-Entitled Debtor Initiative
A. Definition of a non-entitled debtor
A Non-Entitled Debtor (NED) is a person or entity that owes a debt to the Social Security Administration (SSA) but is not entitled to Social Security benefits or Supplemental Security Income payments. Consequently, the NED does not have a Master Beneficiary Record (MBR) or a Supplemental Security Record (SSR) of his or her own.
Currently, NED captures payments made to representative payees after the death of a title II beneficiary, and overpayments to representative payees prior to the death of the title II beneficiary for which the payee is responsible. For more detailed information about this population of NED, see Representative payee of deceased title II beneficiary GN 02230.040.
Representative payee of deceased title XVI recipient
Representative payee who has not relinquished conserved funds
Representative payee who has misused title II or title XVI funds)
Representative payee who has misapplied title XVI funds
Person who owes civil monetary penalties and assessments
Person who owes a court ordered penalty or restitution
Attorney and non-attorney representatives who receive excess fees
Person who fraudulently or erroneously obtains benefits
In order to take appropriate actions, SSA’s automated debt collection systems have always interfaced with an MBR or SSR for the debtor. In cases where the debtor did not have a master beneficiary record, debt collection required manual control and efforts.
The purpose of the NED initiative is to create an automated system for controlling debts (both overpayments and incorrect payments) owed by people who do not have master beneficiary records. Therefore, SSA developed the capability within the Debt Management System (DMS) to identify, record, collect, and otherwise resolve debts owed by NEDs.
The NED database will record Overpayments and other debts in a series of releases to be determined in the future. Ultimately, the plans are to enable SSA to record and control debts owed by all types of NEDs. SSA intends to use all available, authorized debt collection methods to recover the debts:
Billing and follow-up via the Recovery and Collection of Overpayments (RECOOP) system;
Benefit withholding if available;
Treasury Offset Program/External Collection Operation (TOP/ECO) process to collect NED debts by means of tax refund offset (TRO), administrative offset, administrative wage garnishment (AWG), Federal Salary Offset (FSO) and any collection method subsequently added to TOP/ECO.
GN 02201.030 Collection of Title II Overpayments by Tax Refund Offset (TRO)
GN 02201.040 Collection of Title II/Title XVI Overpayments by Administrative Wage Garnishment (AWG)
GN 02201.043 Collection of Title II/Title XVI Overpayments by Federal Salary Offset (FSO)
In addition, SSA plans to report all NEDs to consumer reporting agencies.