TN 130 (05-25)

SI 01130.623 Developing and Documenting Pandemic-Related Assistance Exclusions - Resources

Citations: Social Security Act sections 1612(b)(11) and 1613(a)(6), Disaster Assistance and Emergency Assistance Act, as amended, section 312(d), 20 CFR 416.1124(a), 416.1124(c)(5), 416.1150(c), and 416.1237

 

A. Introduction to developing and documenting resource exclusions from COVID-19 pandemic-related disaster assistance

The Coronavirus Disease 2019 (COVID-19) pandemic resulted in federal, state, and tribal governments' issuing a wide variety of assistance payments or other relief to affected individuals. Most Supplemental Security Income (SSI) claimants and recipients and their families received some form of assistance. Many forms of relief have been determined to qualify as disaster assistance. Special development and documentation procedures may apply to disaster assistance paid to SSI claimants, recipients, deemors, and ineligible children on account of the COVID-19 pandemic.

Use the special procedures in this section for resource determinations involving any assistance classified as disaster assistance in one of the charts found at SI 00830.622B.1.a. and SI 00830.622B.1.b.

B. Policy for COVID-19 pandemic-related disaster assistance received from March 2020 through May 11, 2023

Many types of assistance received from March 2020 through May 11, 2023, and retained are excluded indefinitely from resources in accordance with disaster assistance policies.

Because the disaster assistance resource exclusion is not time-limited, take extra care in applying appropriate exclusions when evaluating retained pandemic-related assistance or when processing excess resource determinations in which retained disaster assistance is documented or may be a factor. Only unspent disaster assistance is permanently excluded from resources under this policy.

See also:

  • SI 01130.700 Identifying Excluded Funds That Have Been Commingled With Nonexcluded Funds

C. Procedures for developing resource exclusions for retained pandemic-related disaster assistance

1. Overview of pandemic-related disaster assistance procedures

Special processing instructions apply to resource determinations involving this assistance. Developing these cases for resource purposes involves:

Action

Reference

Identifying the assistance and determining whether special processing applies.

SI 01130.623C.2. in this section;

SI 00830.623;

SI 00830.622B.1.a.; and

SI 00830.622B.1.b.

Recording the individual’s allegation regarding receipt and retention of disaster assistance.

SI 01130.623C.3. in this section.

Documenting and applying applicable resource exclusions for as long as the assistance is retained.

SI 01130.623C.4. in this section.

2. Procedure for identifying COVID-19 pandemic-related disaster assistance

See SI 00830.622 for information on sources of pandemic-related disaster assistance and the policy treatment for identified assistance types. When any pandemic relief is classified as pandemic-related disaster assistance according to one of the charts found at SI 00830.622B.1.a. and SI 00830.622B.1.b, follow special processing procedures in SI 00830.623 to document the income. Document retained pandemic-related disaster assistance according to SI 01130.623C.3 and C.4 in this section.

NOTE: Contact your Regional Office for help with alleged pandemic-related disaster assistance not classified as disaster assistance in either of the charts in SI 00830.622.

For resource development of disaster assistance that is not pandemic-related assistance, see SI 01130.620.

3. Procedure for collecting resource allegations about pandemic-related disaster assistance

a. Assistance received from March 2020 through May 11, 2023

Follow these steps when collecting and documenting allegations about pandemic-related disaster assistance received by SSI claimants, recipients, deemors, and ineligible children from March 2020 through May 11, 2023. Refer to the chart found at SI 00830.623.B.4 for the relevant period for each state, territory, or tribal area when documenting retained unemployment benefits, since the end dates for pandemic unemployment varied.

When and How to Document an Allegation of Retained Pandemic-Related Disaster Assistance

Step

Action

1

During all initial claims, redeterminations, resource-related limited issues, and post-eligibility events (PE) involving disaster assistance:

  • Ask about receipt and retention of disaster assistance; or

  • Ensure that we have collected the individual's allegation about pandemic assistance and that it is up-to-date.

When an applicant, recipient, or deemor alleges receiving pandemic-related assistance, ask them if any of the disaster assistance was retained.

Proceed to Step 2.

2

Document the yes or no response on a Report of Contact page or SSA-5002.

Important: The Toolbar Remarks Tool has been updated to save time and ensure consistency in documenting pandemic-related disaster assistance allegations. Technicians should use the Remarks Tool when completing the Report of Contact in CCE. Copy and paste the macro language from the Remarks Tool.

Record the resource retention allegation for each type of disaster assistance that was received by the SSI individual and that is listed in one of the charts found at SI 00830.622B.1.a and SI 00830.622B.1.b.

If the individual answered yes, document how much was retained, how long it was retained, and where it was retained (identify any financial accounts involved).

Important: Given the indefinite resource exclusion for disaster assistance and the potential for commingling, you must document the negative response to the retention question.

If an SSA-5002 is used to record the allegation, upload the SSA-5002 into the electronic folder or Evidence Portal (EP).

For no responses, stop.

For yes responses or to document changes to allegations, proceed to Step 3.

3

If the individual alleges retaining any pandemic-related disaster assistance amounts after the month of receipt, go to SI 01130.623C.4, in this section, for instructions on how to apply resource exclusions for pandemic-related disaster assistance.

If the individual’s allegation has changed from the last time we documented pandemic assistance (e.g., they spent the money down), obtain an updated statement on a Report of Contact or SSA-5002.

Important: Resource exclusions for retained disaster assistance are indefinite. Continue to develop retained disaster assistance and apply appropriate exclusions during all initial claim, RZ, LI, and PE events involving disaster assistance when the individual alleges retaining disaster assistance.

b. Assistance received after May 11, 2023

Follow instructions in SI 00830.623C.3 to determine whether assistance received after the pandemic period is classified as pandemic-related disaster assistance subject to special processing.

For pandemic-related disaster assistance, document resource allegations and apply resource exclusions according to SI 01130.623C.3 and C.4 in this section.

4. Procedure for applying pandemic-related disaster assistance exclusions

As noted, special processing applies to resource determinations involving pandemic-related disaster assistance.

a. When to develop pandemic-related disaster assistance resource exclusions

Ask about and consider any pandemic-related disaster assistance exclusions during all:

  • Initial claims;

  • Redeterminations;

  • Resource-related limited issues in which an Access to Financial Institutions (AFI) request is required; and

  • PE events involving disaster assistance.

Important: When retained assistance is present, AFI verifications REQUIRE additional scrutiny in months when excess resources (N04) are involved. Manual actions are required to apply pandemic-related resource exclusions.

b. How to develop and apply pandemic-related resource exclusions held outside financial accounts

Accept the individual's reasonable allegation regarding:

  • How much assistance was retained;

  • For how long; and

  • How the funds were held.

Document the exclusion on the appropriate resource page in CCE. Continue to redevelop allegations at each review or resource-related post-eligibility event until the assistance has been spent down. For example, an individual may withdraw $500 of disaster assistance from their bank account and spend $350 of it while retaining the remaining $150 in their safe. The retained cash would continue to meet the resource exclusion under this policy; however, the spent cash or converted resource would no longer be excluded under this policy.

c. How to develop and apply pandemic-related resource exclusions held in financial accounts or involving commingling

AFI responses may include:

  • Retained Economic Impact payments (EIP);

  • Unemployment benefit amounts; and

  • Other disaster assistance in the first of the month balances.

 

NOTE: The resource exclusion for pandemic unemployment only applies to unemployment paid during the timeframe outlined in the chart found at SI 00830.623B.4. Regular unemployment benefits paid outside of the period, retained in the month after the month of receipt, are countable resources unless a separate exclusion applies.

When an individual alleges retaining any excludable funds, check ALL financial account balances in any month the individual has excess resources (N04). When account balances contribute to an excess resource determination, do the following for each month:

When and How to Document and Exclude Retained Pandemic-Related Disaster Assistance Held in Financial Accounts

Step

Action

1

For all months during the period of review in which the individual alleged retaining pandemic-related disaster assistance and commingling of funds or excess resources are involved:

Compare the account balances to the alleged pandemic assistance received. Check for allegations on the:

  • Report of Contact page or SSA-5002 used in section C.3 in this section; and

  • Unemployment Income page.

2

When fact patterns and bank balances align with the initial allegation:

  • Apply resource exclusions to the appropriate months based on the individual's allegation.

  • If excluded amounts are commingled with countable funds in an account, assume countable funds are spent first. See SI 001130.700 for more information on commingled funds.

When fact patterns and bank balances do not align with the initial allegation:

  • Contact the person and verify whether any excess resource balances are attributable to saved pandemic assistance;

  • Exclude only those amounts attributable to retained pandemic assistance (unless another exclusion applies, e.g., early deposits or Federal tax returns). If excluded amounts are commingled with countable funds, assume countable funds are spent first per SI 01130.700;

  • On a Report of Contact page in the Consolidated Claims Experience (CCE):

    • Record discrepancies;

    • Update disaster assistance allegations; and

    • Document any other information material to the resource determination.

    For changes to unemployment allegations, update the Unemployment Income page in CCE.

  • If you discover other income during the investigation, develop according to normal policies.

  • Use your best judgment when assessing the reasonableness of an individual's allegation and obtain detailed explanations when needed. If you have reason to question the individual's allegation or if you suspect fraud, follow normal disaster assistance policies in SI 00830.620 and SI 01130.620 to request evidence in support of the individual's allegation.

  • Do not routinely request evidence of assistance payments unless there is reason to question the individual's allegation and the issue cannot be resolved without additional evidence (e.g., resource allegations do not align with the fact pattern of the case or bank balance information and the individual does not change their allegation when questioned).

  • If requesting evidence to support continued resource exclusions is required, obtain records that show:

    • The source of the pandemic assistance;

    • Dates of payments; and

    • Bank records with transaction details showing how the pandemic assistance was retained if the money is retained in a financial account.

NOTE: The resource exclusion for pandemic unemployment only applies to unemployment paid during the timeframe outlined in the chart found at SI 00830.623B.4. Regular unemployment benefits paid outside of that period, retained in the month after the month of receipt, are countable resources unless a separate exclusion applies.

3

Exclude from resources, based on the individual’s reasonable allegation, all retained pandemic-related disaster assistance subject to special processing.

  • Document the exclusion on the appropriate resource page(s) (e.g., the Financial Institution Account page or Cash page) and enter “disaster assistance” as the exclusion reason.

  • Document the reason in the file documentation notes if there are multiple exclusions involved (e.g., we also excluded an early SSI payment or some of the account funds were from a Federal tax return).

4

For subsequent reviews (i.e., new RZs and LIs), continue to ask about receipt and retention of disaster assistance payments for the current review period and update allegations about previously documented assistance until no retained assistance remains.

NOTE: For disaster assistance that was not previously documented, you may have to document it going back to March 2020. Ensure all pandemic-related assistance subject to special processing, according to SI 00830.622B.1.a. and SI 00830.622B.1.b., is documented according to SI 00830.623.

D. Examples of applying resource exclusions for pandemic-related disaster assistance from March 2020 through May 11, 2023

Example 1:

At the August 2021 redetermination, the technician documents the following on a Report of Contact page in CCE:

“Recipient and spouse received all three EIPs, each in a single deposit to their checking account ($2,400 in May 2020, $1,200 in January 2021, and $2,800 in April 2021). Recipient alleges saving some of the money in their joint checking account in the months after they received the EIPs but eventually spending all the EIP money. The retained EIP payments were completely spent down by July 2020, April 2021, and July 2021, respectively.”

Since the person alleged having more than $400 in liquid assets during the period of review, the technician requests an AFI verification. When the response is received, the technician notes a pattern of lower balances, usually between $900 and $1,300, then spikes in resource values that would result in N04 ineligibility in the months of June 2020, February 2021, May 2021, and June 2021. The technician also notes a higher than normal balance in March 2021, but it was not high enough to potentially cause an N04 ineligibility month.

Since the bank balance patterns and allegation from the Report of Contact page align, the technician applies the pandemic assistance exclusion on the Financial Institution Account page to the months that would otherwise calculate to N04 ineligibility (June 2020, February 2021, May 2021, and June 2021). Because the recipient alleged and the technician documented a complete spend down of excluded funds, the technician would not have to continue monitoring the resource exclusion for the EIPs during future reviews.

Example 2:

In December 2023, an individual applies for an Aged SSI claim at their local FO. The individual alleges receiving all three EIPs, each in a single deposit to their checking account ($1,200 in May 2020, $600 in January 2021, and $1,400 in April 2021). The applicant also alleges saving some of the money in their savings account in the months after they received the EIPs. When the single individual alleges having $2,500, the technician asks about the source of the funds in the alleged balance. The applicant alleges the funds were saved from EIPs they received in 2020 and 2021.

However, upon return of an AFI request, the technician discovers that the applicant’s bank balance dropped to $5 for multiple consecutive months from November 2022 through May 2023. Suddenly, as of June of 2023, the bank balance showed balances that fluctuated from $2,700 - $3,000 depending on the month. When asked about the period of a $5 balance and about the source of the funds currently present in the account, the applicant says they do not remember what happened.

After further development, the applicant remembers that they used the entire $3,100 of the EIP funds they had saved to purchase shares in a mutual fund in October of 2022. After the mutual fund value fell sharply in 2023, they sold all their shares in May 2023 and deposited the funds back into their savings account. The technician documents a Report of Contact with the applicant’s allegations about how the EIP funds were saved and spent and counts the balance in the bank account as a resource effective with the December 2023 application month. Per SI 01130.620, only unspent assistance is permanently excluded from resources; the use of the funds to purchase the mutual fund(s) constitutes expenditure. Purchasing shares in a mutual fund entails buying an ownership stake in the investments held by the mutual fund (see SI 01140.230).

E. References

SI 00830.622 Effect of COVID-19 Pandemic-Related Disaster Assistance on SSI Income and Resources

SI 00830.623 Developing and Documenting Income Exclusions from Pandemic-Related Assistance

SI 00830.620 Disaster Assistance - Presidentially-Declared Disaster

SI 01110.600 First-of-the-Month (FOM) Rule for Making Resource Determinations

SI 01130.620 Disaster Assistance

SI 01130.700 Identifying Excluded Funds That Have Been Commingled With Nonexcluded Funds

SI 01140.010 Resource Verification

SI 01140.200 Checking and Savings Accounts


To Link to this section - Use this URL:
http://policy.ssa.gov/poms.nsf/lnx/0501130623
SI 01130.623 - Developing and Documenting Pandemic-Related Assistance Exclusions - Resources - 05/28/2025
Batch run: 05/28/2025
Rev:05/28/2025