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 applicant has an outstanding SSI overpayment, retroactivity may not be possible
because any underpayment created by PASS will net against the pending overpayment.
The PASS Cadre will consider retroactivity for a PASS applicant with an SSI overpayment
only if the individual was working towards the goal and paying for PASS expenses in
the months prior to submitting the plan. In this instance, approving the PASS retroactively
reduces the amount of overpayment.
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.