SSA - POMS: RS 02801.010 - Immediate Payment (IP) Criteria and Process

A. Background

Immediate Payments (IPs) were established in 1985 to allow SSA to make expedited payments to beneficiaries in dire need faster than the 5-7 day period required to deliver Treasury-prepared payments via the Title II Critical Payment System (CPS).

Once an IP is made, action should be taken to resolve the original processing problem as soon as possible to avoid any need to make a second IP. IPs are made only in the FOs.

B. Policy

If the requirements below are met, the FO may make an IP through the third party payment system (TPPS) and record the payment in CPS. (See RS 02801.010D.)

NOTE: TSCs and PCs may not make IPs.

1. Requirements for payment

A payment is due because of a stop payment action taken, nonpayment, or a newly processed claim.

The critical case criteria in RS 02801.001 (for Title II) and/or SI 02004.100 (for Title XVI) must be met.

The beneficiary must have an immediate financial need for payment (i.e., a need for food, shelter, medical treatment, etc.) that cannot reasonably be met through other resources available in the community. (See GN 00903.010 regarding referrals to other social service agencies/programs.)

2. Limitations on payment

Each beneficiary who meets the requirements may receive an IP, but payment must be made to that person (or the person's representative payee) directly, (e.g., a a beneficiary may not receive an IP for their entitled children unless they are their payee). Each child’s payment requires a separate IP.

The IP may not exceed the lesser of $5,000.00, or the amount of benefits due the beneficiary.

IPs must not be mailed.

3. Exception to one immediate payment

Generally, the issuance of the IP removes the financial emergency, and the person is then paid under normal processes or CPS. In some situations, a second IP may be needed.

NOTE: Because of concerns about improper use of the IP procedure, initially more than one IP in a 30-day period was prohibited. However, an audit showed that SSA FOs follow the strict criteria for issuance of IPs and this concern was not justified. Therefore, the limit of one IP in a 30-day period has been eliminated.

When another IP is needed within a 30-day period, ALLrequirements must be met for each IP paid. Therefore, situations where a second IP (meeting all the requirements) would be issued within 30 days will be rare. Examples of possible situations when more than one IP may be issued in less than 30 days include:

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A natural disaster, where mail is disrupted for more than one month, or
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When a recipient is given an IP for the initial payment because of dire need, their next month’s check does not arrive timely, and they are still in dire need.

Each IP is limited to the lesser of $5,000.00 or the amount due. Because of the TPPS/CPS interface, CPS edits the amount and will not allow an IP greater than $5,000.00.

NOTE: If there is concurrent Title II/XVI entitlement or dual entitlement on two SSNs, the $5,000.00 limitation applies against the total benefits due under both Title II/XVI or SSNs (i.e., payment may be made under both Titles or SSNs), but the total IP cannot exceed $5,000.00.

4. Program responsibility in concurrent Title II/XVI critical cases

If the beneficiary is concurrently eligible for Title II and Title XVI benefits, an IP may be paid under one Title or both, according to the following rules.

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The IP can be paid under only one Title, pay the IP from that Title.
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If the Title II benefits due equal or exceed the IP, pay the IP from the Title II benefits due.
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If the Title II benefits due are less than the IP but the Title XVI benefits due are equal to or greater than the IP, pay the IP from the Title XVI benefit due.
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If both the Title II and Title XVI benefits due are each less than the IP, pay the IP from the Title II benefits due and the remainder from the Title XVI benefits due.

In concurrent cases where the immediate payment is being made from Title II benefits, solicit all retroactive Title II data from the PC. (This can be accomplished by MDW, phone, or fax.) Provide the PC with the resultant windfall noncountable income (WNC) amount. This will prevent a delay in the release of the retroactive Title II benefits.

See RS 02803.330 for PC handling of inquiries of immediate payment cases.

C. Procedure - verifying entitlement

Before the payment of an immediate payment, an individual must qualify for the payment. If the individual qualifies, the CPS system is used as the quickest way to get funds to someone in dire need. Obtain an MBR and/or PHUS query to verify that payment is due.

Based on the information obtained:

IF	THEN
The disabled individual is 55 or older…	Obtain a PCACS (if MBR or PHUS not available) to verify the responsible PC (see RS 02803.045B).
No MBR or PHUS exists or entitlement cannot be determined from the MBR or FO records…	Do not issue an IP until entitlement has been verified. Fax, e-mail or call the Inquiries Staff in the PC (use DOORS for numbers).
The Inquiries Staff is unable to make an entitlement determination…	Explain the situation to the individual and, if necessary, have the individual return the next day for an IP or phone individual when entitlement is determined.
The Inquiries Staff determines the individual is not entitled…	Explain to the individual an IP cannot be paid.
The case is concurrent…	Determine that a Title XVI immediate payment has not been paid. Process according to RS 02803.130.
Additional benefits are due after IP is paid, but the FO cannot pay by CPS…	Send the PC a high priority MDW, according to GN 01070.228A.5, explaining an IP was processed and request PC to pay the remainder of the benefits due.

D. Procedure – issuing the payment

1. Step 1

Does the individual meet the criteria for an IP, RS 02801.010B.1.?

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If yes, go to Step 2.
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If no, explain that an IP cannot be made and offer other means for getting the individual's payment as quickly as possible.

2. Step 2

Effective 11/2006, the new CIPA screen in conjunction with the other required CPS screens, is used to send a record to the TPPS when a Title II IP is involved. TPPS will print the draft check and document the payment. The TPPS record provides a balance between what is recorded in CPS and what is paid.

Follow the instructions in MSOM INTRANETCPS 001.001 through .016 and SM 00635.070 for processing a CPS immediate payment using the 2-PIN process and the CPS screens. After the information has been entered in the CPAY, PAY2/PAY3 and CIPA screens, and approved on the CPAT screen, the necessary information is transmitted to the TPPS. Go to Step 3.

3. Step 3

From the TPPS system:

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The cashier will retrieve the information by entering the TPPS Main Menu.
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The cashier will prepare the draft. The draft should be made to the individual or representative payee.
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The cashier will give all copies of draft to SR/CR (or higher).

Go to step 4.

4. Step 4

Once the draft is prepared, the:

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SR/CR (or higher) will initial all copies of the third party draft (TPD) to indicate its receipt.
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SR/CR (or higher) will have individual or representative payee sign the Form SSA-795, Statement of Claimant or Other Person, with the language acknowledging receipt of the Title II immediate payment. Include the TPD# of IP on SSA-795 (See RS 02801.500 for required language needed for SSA-795.)
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SR/CR (or higher) will make 2 copies of the SSA-795-one for the cashier's file and one for the individual or representative payee.
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The SR/CR will give a one copy of the SSA-795 to the individual or representative payee as a receipt and notice.
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The SR/CR will give the original and one copy of the SSA-795 to the cashier.
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The cashier will review the SSA-795 for completeness, keep one copy and return the original with the CPS output to SR/CR.
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Use the Evidence Portal (EP) to put the completed SSA-795 in the Claims Folder (GN 00301.322).

NOTE: Management is no longer required to maintain a critical case log.

E. Procedure -- measures used when CPS cannot be used – systems malfunction

If the CPS cannot be used due to internal malfunctions, prepare a Form SSA-5002, Report of Contact, stating the need for the issuance of an immediate payment. Management must approve the immediate payment by countersigning the SSA-5002. Show the approved SSA-5002 to the cashier and obtain the TPD. At a later time, when the CPS system is available, the transaction must be entered into CPS. On the CPAT screen you must enter an “N” in the 3-C field which states you do not want to print a check, but you want to send an interface record to the TPPS documenting that an IP was made and providing the payment information. This entry generates an interface record to TPPS database. Do not send or fax the SSA-795 to the PC until the IP is entered into CPS. Annotate the SSA-5002 and send to the PC with the SSA-795 once the IP has been entered into CPS. See GN 00301.322, Retention of Paper Material After Faxing into Either the eDIB Folder or Claims Folder using EP.

F. References

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SI 02004.100 Payment and control of Title XVI IPs
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SM 00635.000 Critical Payment System
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GN 02201.030 Tax Refund Offset

Social Security

Program Operations Manual System (POMS)

RS 02801.010 Immediate Payment (IP) Criteria and Process