TN 9 (07-00)
SI 00870.055 Monitoring PASS Progress
A. Policy -- types of monitoring
1. Progress Check by PASS Expert
Use the progress check to quickly see how things are going. Help the individual as appropriate to avoid or quickly remedy a potential problem and improve the individual's chances for success. Document the contact for the record. Conduct additional progress checks as you believe are warranted by the circumstances of the PASS.
2. Progress Review by PASS Expert
Use a progress review to determine whether the PASS should continue as is, be amended, suspended or terminated. Take into account:
changes in income or other circumstances that have occurred that might affect the PASS;
whether the individual has met plan milestones on schedule and, if not, why not; and
whether funds excluded under the PASS have been set aside and/or spent as agreed and, if not, why not.
Create and control a schedule of progress reviews based on the relevant circumstances of each PASS, including:
key milestones. Revise the schedule as circumstances dictate (e.g., a change in income, work activity, resources, living arrangements, etc., or when a PASS is otherwise amended); and
periods of 6 months or more during which funds are being set aside but not spent.
Although a progress review need not follow every milestone, conduct one at least annually.
NOTE: No longer use the “SU” diary as the means to schedule a redetermination and PASS review. If a SU diary exists for a PASS case, delete it by transmitting DASU000000 in the diary code and date fields (SM 01301.230).
B. Policy -- conducting the review—PASS experts
Follow the procedures below:
Ask the individual to submit evidence of savings and spending under the PASS, e.g., bank account records, bills, receipt, cancelled checks--and to organize the evidence before submitting it.
Ask the individual to obtain any missing required evidence from the appropriate third party, or obtain a signed authorization and contact the third party directly.
Reconcile, as of the most recent full month, the amount of funds excluded under the PASS with the amount of funds saved and spent under the PASS. Verify that savings are accruing as planned and not being used for other purposes.
Obtain the individual's signed explanation if the individual is not following the savings/spending schedule of the PASS.
Confirm with the individual that services (e.g., case management services in conjunction with a PASS preparation fee) were actually received. If not, document the file as to why the services were not received.
Determine whether the individual received reimbursement for expenses related to items and services obtained under the PASS, or whether any such items or services were provided free of cost or paid for by someone else. If so, adjust the savings/spending schedule accordingly.
Obtain either evidence that scheduled milestones have been reached, or a signed statement as to why the milestones were not reached.
C. Procedure -- PASS expert actions based on the review
1. Pre 4/96 PASS Not Previously Reviewed by Specialist
a. Individual Following Plan
If the person is following a PASS that was approved prior to 4/96, but does not meet one or more of the requirements in effect since 4/96, explain the requirement(s) to the individual and amend the PASS accordingly. Apply the requirement(s) prospectively. See SI 00870.055C.1.c. Schedule a progress check to see that the person is following the amended PASS.
If the PASS can't be amended, suspend the PASS prospectively. Conduct a final accounting only if the PASS file is readily available at the PASS expert cadre site or from the FO. Suggest the possibility of a new PASS with a more suitable work goal. Consider whether alternate exclusions (e.g., IRWE) are appropriate.
b. Individual Not Following Plan
If the person is not following a PASS that was approved prior to 4/96, explain to the person that not following the plan will cause the PASS to be suspended. A suspension may derail the person's work effort as well as lead to the loss of PASS goods being purchased (e.g., repossession of a vehicle for non-payment of a loan) and SSI monies and/or eligibility. Make every effort to work with the person to amend the PASS, particularly if failure to follow the PASS is due to circumstances beyond the person's control. Be sure that any amendment meets the current requirements in effect. Schedule a progress check to see that the person is following the amended PASS.
If, after your efforts, the PASS can't be amended, or the individual is no longer interested in pursuing the work goal, suspend the PASS prospectively. Conduct a final accounting only if the PASS file is readily available at the cadre site or the FO. Suggest the possibility of a new PASS with a more suitable work goal. Consider whether alternate exclusions (e.g., IRWE) are appropriate.
c. Expense No Longer Allowed
Help the individual to amend the PASS to remove any expense approved prior to 4/96 and to make any corresponding changes prospectively in the amount of excluded income or resources provided the expense is not:
2. All Other PASSES
a. Individual Working in Goal
If the person is working in the occupational goal and the PASS expenses are paid, suspend the PASS per SI 00870.070. Consider the appropriateness of alternate exclusions, such as an IRWE.
If the individual is working in the occupational goal but the expenses are not all paid, extend the PASS to pay for unpaid items and services per SI 00870.055D.1. if the person is unable to pay for the remaining PASS expenses as well as his/her living, unpaid medical, and other work expenses per SI 00870.006A.1. If the person can afford to pay for all of the expenses, suspend the PASS per SI 00870.070. Consider the appropriateness of alternate exclusions, such as an IRWE.
b. VR Evaluation Completed
If an amendment has been submitted, process the request per SI 00870.050.
If the evaluation does not identify any feasible work goals, but the individual submits an amendment, process the request per SI 00870.050. Evaluate the feasibility of the amended work goal and the viability of the amended plan using the criteria in SI 00870.025B.3. The VR evaluation carries considerable weight, but is not controlling.
If the individual declines to submit an amendment, document the record and suspend the PASS per SI 00870.070. Consider the appropriateness of alternate exclusions, such as IRWE.
c. Individual Not Working in Goal As Scheduled
If the individual is actively pursuing the occupational goal and additional time and/or the exclusion of additional income and/or resources are justified, work with the individual to amend the PASS to reflect the additional time or expenses required. Extend the PASS per SI 00870.055D.1.
If the person is not following the plan, explain that the PASS may be suspended which may derail the person's work effort and lead to the loss of PASS goods being purchased (e.g., repossession of a vehicle for non-payment of a loan) and SSI monies and/or eligibility. Make every effort to work with the person to amend the PASS, particularly if failure to follow the PASS is due to circumstances beyond the person's control. Schedule a progress check to see that the person is following the amended PASS.
If, after your efforts, the PASS can't be amended, or the individual has abandoned pursuit of the PASS, suspend the PASS per SI 00870.070. Suggest the possibility of a new PASS with a more suitable work goal. Consider whether alternate exclusions (e.g., IRWE) are appropriate.
D. Procedure -- related actions when PASS extended
1. Duration of Extension
You may extend the PASS up to an additional 12 months provided disbursements are being made and the PASS has been in existence for less than 36 months (or 48 months if a lengthy educational or training program is involved).
If no disbursement for items and services has been made, or the PASS has been active longer than 36/48 months, you may extend the PASS up to 6 months before conducting another progress review and deciding whether the PASS should be extended for another 6-month period.
2. Adjustment of Exclusion Needed
Follow the instructions in SI 00870.050B.3.
3. Progress Review Notice
Follow the instructions in SI 00870.060.
4. Future Progress Checks and Review
Schedule your future progress review when a milestone should be reached or the extension ends. Conduct progress checks in the future as warranted.