TN 23 (05-13)
GN 02610.022 The Windfall Offset Period
A. How to determine the windfall offset begin and end dates
The windfall offset period is the period that retroactive title II benefits could affect the title XVI payment.
1. Definitions of windfall offset begin and end dates
The windfall offset begin date (WOBD) is the month after the month of entitlement (MOE) to title II benefits or the title XVI date of entitlement, whichever is later. The WOBD may change to an earlier or later date as explained in GN 02610.050B.
The windfall offset end date (WOED) is either:
one month after the first title II current monthly accrual (CMA) payment; or
if no title II CMA was paid, the WOED is the month equal to 2 months after the last month in which the retroactive title II benefits would have been paid if paid when regularly due; or
the month of death if the person died before receiving title II benefits. For examples of how to process an offset when a recipient dies, see GN 02610.050C.1.
EXAMPLE: The recipient’s title II CMA was due for 4/11 and paid in 5/11. A full account (FACT) query shows title II funds withheld since the MOE of 9/10. The title XVI DOE is 7/10. The offset period was 10/10 - 6/11. Remember that we paid the first month's benefit for 9/10 in 10/10.
2. Windfall offset end date when no CMA paid
If no title II benefits are payable because of an entitlement or eligibility factor; e.g., disability (DIB) cessation, workers’ compensation (WC), or work issues, the offset period ends in the month equal to the month we process the title II award plus two months. See the case example in GN 02610.022C. in this section.
If no CMA is payable because of a temporary development issue, e.g., suspension of benefits due to whereabouts unknown, or development of a payee, the offset period does not end until we pay the title II benefits. For procedures to process these claims, see GN 02610.022B in this section.
3. Windfall offset period for dual entitlement and couples cases
In dual entitlement (D/E) and couples cases, the windfall offset period is continuous beginning with the first month that title II benefits could affect title XVI payment and ending as described in GN 02610.022A.1., in this section. The windfall offset period is continuous, unless there is a break in title II entitlement of two months or more between the last month of the prior month accrual (PMA) for one title II benefit and the first month of PMA for the other title II benefit. When a break of two months or more exists, there are two separate offset periods.
4. Windfall offset period for Railroad Board (RRB) certification cases
In Railroad (RR) Certification cases, we determine the offset period using the rules in GN 02610.022A.1, in this section, regardless of when the RRB actually makes payment.
B. No CMA payable due to temporary development
1. Claims representatives or authorizers
The Manual Adjustment, Credit, and Award Process (MADCAP) and Modernized Claims System (MCS) can process initial award cases with no CMA payable due to temporary development. Post the Windfall (WF) code to the Benefit Continuity Factors (BECF) screen. MCS will identify the situation based on other data and post WIN ‘Z’ when required. For a list of WIN codes posted to the MBR, see SM 03005.330A and SM 00510.150C. For a description of WIN codes posted to the Supplemental Security Income Data (SSID), see SM 00815.430.
2. Benefit Authorizers (BA)
For instructions on processing windfall offset when no CMA is payable due to temporary development, see SM 00815.000.
C. Windfall offset period examples
The following are examples of how to determine the windfall offset period:
Mr. Riley became disabled and eligible for both title II and title XVI benefits. He is entitled to title XVI benefits beginning 04/11, and to title II benefits beginning 06/11. His offset period begins 07/11, the month after the month of title II entitlement, which is later than the title XVI DOE (04/11).
Mr. Riley’s first month title II CMA payment was for 09/11, received in 10/11. His offset period ends 11/11, one month after the first CMA payment.
Cheryl is a disabled child receiving title XVI benefits. Her father files for retirement insurance benefits (RIB) in 12/10 and we award child’s benefits. The field office (FO) processes the title II award in 01/11. Cheryl is eligible for title II benefits for 09/10 through 12/10, but we do not pay the CMA because of her father's work. Since, the title II award processed in 01/11, the WOED is two months after the award was processed, or, 03/11.