In most cases, you must use the e4641 (electronic Authorization for the Social Security Administration to Obtain Account Records From A Financial Institution and Request) or eAFI (electronic Access to Financial Institutions) systems to verify financial account balances for the current month and the preceding 25 months. For additional instructions, see procedures in SI 01140.206D.

For initial claims, you must verify the financial account balances for up to 25-months prior to the filing date. Therefore, we routinely receive financial account data that precedes the filing date in initial claims. When we examine financial account records from 2 years prior to the Supplemental Security Income (SSI) application, we would expect to see the spend-down of cash from existing accounts to meet ordinary monthly expenses.

Use the following procedures to determine whether you can abbreviate development when we identify a spend-down of cash via e4641 or eAFI.

In order to determine whether the spend-down was a transfer of resources and fair market value was received in return, use the following procedures when:

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  the procedures for abbreviated development do not apply; or,

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  an individual alleges spend-down of cash not held in a financial institution.

If you determine that, a spend-down of cash may result in a period of ineligibility:

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  Obtain the individual's statement either signed or recorded on a Report of Contact page (an application derived report of contact) to document how the individual spent the cash.

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  Obtain available evidence to support the allegation if the allegation is questionable (e.g., sales receipts for purchases, bank statements showing withdrawals, etc.)

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  Document your determination on the Property/Cash Given or Sold page, the Report of Contact page, or an SSA-5002 as appropriate.

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  Document if an eligible individual is over the resource limit in any month(s) of the review period and alleges spending sufficient cash to fall below the resource limit. You must obtain evidence to support their allegation.

NOTE: An individual may not be able to provide an exact “to the penny” accounting for purchases. Therefore, the claims representative (CR) should accept any reasonable accounting. In addition, an individual may allege an expenditure that they cannot corroborate. Exercise great care in resolving the issue of transfer by spend-down before determining that the individual is ineligible due to excess resources or is subject to a period of ineligibility due to a transfer for less than fair market value.

Example 1- Allegation acceptable

During their redetermination, Barrett submitted bank records showing resources over the $2,000 limit for 03/10 and 04/10 followed by a $750 withdrawal in 05/10 that brought their total resources below the limit. Barrett provides a statement that they used $150 for utility bills, $170 for a dentist bill, $300 for car repairs, and $130 for plumbing repairs. Assuming there is no conflicting information in the file, there is no need to request receipts to verify these allegations.

Example 2 - Allegation questionable

Jones filed for SSI on 06/05/09 and they alleged liquid resources of $1,800 on 06/01/09. Jones alleged that they spent about $3,000 from savings in 05/09 just prior to filing for SSI. They said that they spent $2000 for a new furnace and spent the rest on a series of small purchases. Prior to spending this money, Jones was over the SSI resource limit. At the time of the interview, Jones could not explain how and when they spent the additional $1,000. Since they could not provide a reasonable accounting of how they spent the funds, their allegation is questionable. The CR requests additional evidence to support Jones' allegation of spend-down before making a determination.

Example 3 - Abbreviated development in AFI based determination

Fox filed for SSI on 10/01/11 and alleged the only resource they had was a checking account with a balance of $1400. The financial account information received via eAFI revealed that they had $6,000 in that account 7 months prior to their application and their monthly bank balances show a steady decline. The CR considers the information on the application, which shows a mortgage of $1000 a month, the spouse reports no income, and two minor children in the household who have no income. Based on these factors derived from the application and the financial account information, the CR determines that Fox spent the money to pay the family’s monthly bills. The CR has no cause to question the spend-down and curtails any development. The CR documents their decision on a Report of Contact page. Fox received FMV for their cash spend-down, and therefore, no transfer of resource penalty exists.

SI 01150.005 Determining Fair Market Value

SI 01150.110 Period of Ineligibility for Transfers on or After 12-14-99