TN 4 (07-10)

HI 01120.040 Life Changing Event (LCE) – Reduction or Loss of Pension Income

A. Policy

B. What Evidence is Needed to Support the Change

C. How to Process the Request

D. How to Record Evidence Provided on EVID Screens

A. Policy

A significant loss of income due to the reduction or cessation of certain types of pension income may cause a beneficiary to request a new initial determination and may qualify as a life-changing event. In order to qualify as an LCE based on a reduction or cessation of pension income, the pension must be

  1. A traditional defined benefit pension plan or a Cash Balance plan, and

  2. The loss of income is the result of:

    1. A plan failure or termination (e.g. through bankruptcy restructuring), or

    2. A scheduled cessation that the beneficiary made a decision about some time in the past. For example, the beneficiary chose to take a 20 year annuity rather than a lifetime pension when he retired in 1986.

B. What Evidence is Needed to Support the Change

If

Then

The beneficiary reports a loss or reduction in MAGI due to a pension plan failure.

Tell the beneficiary to provide:

  • A letter advising the beneficiary of the change in the annuity amount or cessation of annuity. (The letter may be from a pension fund administrator); and

  • A signed copy of the filed Federal income tax return for a more recent year or an estimate of what MAGI will be for a more recent year for which a tax return has not yet been filed.

You cannot determine from the letter if the type of plan qualifies (e.g the plan administrator letter is not clear about the type of plan).

Tell the beneficiary to provide a copy of the plan description. Review the plan description to find

  • A statement of the type of plan

    You may accept either a statement that it is a defined benefit or cash balance plan as evidence that the loss of pension income is considered to be an LCE.

The beneficiary says that the loss of MAGI is due to a cessation or reduction of the pension benefit caused by the choice of distribution (lump sum or time-limited annuity).

Tell the beneficiary to provide:

  • A letter from the pension plan administrator

    OR

  • Original documents recording retirement distribution choices. These documents may show a date when the distributions will stop, or the fact that the payment was a lump sum distribution.

C. How to Process the Request

If

Then

The beneficiary states that there has been a loss of income from a pension plan.

  • Evaluate whether the loss is due to:

    • plan failure;

    • a scheduled cessation of annuity payments; or

    • death of spouse who was receiving a pension, with no or reduced survivor benefits.

      NOTE: Two separate premium year inputs are necessary with all LCEs.

  • Access the IRMAA screens (See MSOM T2PE 008.001 through MSOM T2PE 008.019)

  • On the IRMN screen

    • Enter the Beneficiary's Own SSN.

    • In the “Select the Desired Option” field select “1” Establish

    • Input the premium year that the new initial determination request is for.

    • In the “Select the Desired Function” field select “1” Life Changing Event

    • Input the Tax Year the beneficiary requests we use to determine the IRMAA.

    • Press Enter

  • The PYTY screen appears when there is data on file for the tax year requested and it is displayed under the Highest Probative Value Data Field. (For an explanation of Highest Probative see MSOM T2PE 008.019.)

    • If you select “1” Use Highest Probative Data, the system will process the determination using that data on file. The data will be propagated to the IRMA screen.

    • If you select “2” New Tax Data, the system will process the determination using the new information provided as long as the value of the data is of higher value than the information on file.

  • Press Enter.

  • On the IRLC screen

    • In the Select LCE Field select “6” Pension Income Loss.

    • In the “Date of LCE” field enter the date of pension loss (Month and Year)

  • Show Proof as “1” Proven

  • Press Enter

    • On the IRMA screen

  • Input the beneficiary's alleged adjusted gross income and tax exempt income for the tax year the beneficiary is requesting to use. NOTE: If selection “1” Use Highest Probative Data on the PYTY was selected, the information will be propagated and cannot be changed.

  • On the “Select Type” field select the appropriate tax source based on the information provided by the beneficiary. See MSOM T2PE 008.005.

  • On the “Select Filing Status” field enter the appropriate filing status for the beneficiary.

  • Show Proof as “1” Proven

  • Press Enter.

The IRRE Screen will display the current and recalculated IRMAA data. The “New Determination Results” field will provide the determination based on the information entered.

  • The IRMN Screen will display an alert to go to the EVID screen to document proofs submitted for the event reported. Pressing any “PF” key or the “Enter” key from the IRMN screen, will take you to the Shared Processes Menu.

  • Record the evidence provided on the EVID screen in Shared Processes (See GN 00301.286 through GN 00301.300 and MSOM EVID 001.003).

Beneficiary reports that the pension plan failed and the income has been or will be reduced.

  • Determine if a loss has or will occur. Ask the beneficiary to provide a letter from the pension fund administrator advising of the change.

    NOTE : Two separate premium year inputs are necessary with all LCEs.

  • Access the IRMAA screens (See MSOM T2PE 008.001 through MSOM T2PE 008.019)

  • On the IRMN screen

    • Enter the Beneficiary's Own SSN.

    • In the “Select the Desired Option” field select “1” Establish

    • Input the premium year that the new initial determination request is for.

    • In the “Select the Desired Function” field select “1” Life Changing Event

    • Input the Tax Year the beneficiary request we use to determine the IRMAA.

    • Press Enter

  • The PYTY screen appears when there is data on file for the tax year requested and it is displayed under the Highest Probative Value Data Field. (For an explanation of Highest Probative see MSOM T2PE 008.019.)

    • If you select “1” Use Highest Probative Data, the system will process the determination using that data on file. The data will be propagated to the IRMA screen.

    • If you select “2” New Tax Data, the system will process the determination using the new information provided as long as the value of the data is of higher value than the information on file.

    • Press Enter.

 
  • On the IRLC screen

    • In the “Select Life Changing Event” Field select “6” Pension Income Loss.

    • In the “Date of Life Changing Event” field enter the date of pension loss (Month and Year)

    • Show Proof as “1” Proven

    • On the remarks field annotate the reason for the loss. For example:

      1. Plan failure

      2. Scheduled cessation of benefits.

      3. Press Enter

  • On the IRMA screen

    • Input the beneficiary's alleged adjusted gross income and tax exempt income for the tax year the beneficiary is requesting to use. NOTE: If selection “1” Use Highest Probative Data on the PYTY was selected, the information will be propagated and cannot be changed.

    • On the “Select Type” field select the appropriate tax source based on the information provided by the beneficiary. See MSOM T2PE 008.005.

    • On the “Select Filing Status” field enter the appropriate filing status for the beneficiary.

    • Show Proof as “1” Proven

    • Press Enter.

  • The IRRE Screen will display the current and recalculated IRMAA data. The “New Determination Results” field will provide the determination based on the information entered.

  • Record the evidence provided on the EVID screen in Shared Processes (See GN 00301.286 through GN 00301.300 and MSOM EVID 001.003).

The letter the beneficiary provides is from a pension plan administrator and you cannot determine whether the type of pension plan qualifies.

  • Advise the beneficiary to provide a copy of the Plan description. See HI 01120.001F

The beneficiary says that a copy of plan description is not available and has no other evidence of the type of plan.

  • Advise the beneficiary to contact the plan administrator or the personnel office of the former employer to find out how to get one.

  • See HI 01120.001F

The beneficiary says the plan administrator will not provide a copy of his plan description

If the pension plan was insured, the beneficiary may send a request to:

Department of Labor, PWBA
Public Disclosure Room
Room N-5638
200 Constitution Avenue, NW Washington, DC 20210

If the pension plan was not insured, ask the beneficiary to provide any documentation about the plan or changes.

  • Input the information provided by the beneficiary on the IRMAA screens and show proof as “PENDING” on the IRLC screen. (See MSOM T2PE 008.001 through MSOM T2PE 008.013).

  • Explain that proof will be needed within 30 days or the request for a new initial determination will be dismissed. See HI 01120.001F

The beneficiary reports the death of his spouse, and the loss will occur due to the cessation of the spouse's pension and no survivor benefit.

Evaluate under the procedures for an LCE of “death of spouse.” See HI 01120.010.

The beneficiary reports that the reason for the reduction/loss is that distribution was in a lump sum, or time-limited annuity.

Tell the beneficiary to provide:

  • a letter from the pension plan administrator advising of the ending of payments; or

  • original documents recording retirement distribution choices.

    NOTE: These documents may show a date when the distributions will stop, or the fact that the payment was a lump sum distribution.

    • Access the IRMAA screens (See MSOM T2PE 008.001 through MSOM T2PE 008.013) and enter the information provided by the beneficiary. Show proof as “PENDING” on the IRLC screen.

    • Advise the beneficiary what proofs are required and inform him/her that proofs must be supplied within 30 days or the request for the new initial determination will be dismissed.

    • See HI 01120.001G

Adequate proof above not supplied.

D. How to Record Evidence Provided on EVID Screens

If

Then

The beneficiary provides a letter from a pension plan administrator.

  • Access the EVID screen in Shared Processes (See GN 00301.286 through GN 00301.300 and MSOM EVID 001.003).

  • Select “OTHER” as the document submitted as proof.

  • For “Issuance/Recordation Date” show “Y.”

  • For “Date Issued” show the date on the letter.

  • For “Document Type” enter: pension plan administrator letter.

  • In “Comments” enter – Administrator Letter, name of the administrator, name of pensioner.

EXAMPLE - Document
Type = pension plan administrator letter, Charles Aznevour, Juanita Public


To Link to this section - Use this URL:
http://policy.ssa.gov/poms.nsf/lnx/0601120040
HI 01120.040 - Life Changing Event (LCE) - Reduction or Loss of Pension Income - 07/20/2010
Batch run: 07/20/2010
Rev:07/20/2010