TN 1 (04-01)
VB 00501.036 Evaluation of Accounting Form Responses
A. Item 1 - Payee Address Change
Evaluate a change in the payee's address in conjunction with the responses to item 2 (and other information in file or the SVB record on the SSR) to determine if the appointed payee continues to be the preferred payee.
B. Item 2 - Beneficiary Custody Change
For accounting purposes, living with means having custody of the beneficiary. If the beneficiary lives alone or with someone other than the representative payee, then the payee does not have custody.
The responses in item 2 indicate whether the payee has custody of the beneficiary or whether there has been a change in the custody situation. A change in custody may indicate that the payee is no longer aware of the beneficiary's needs and/or may no longer be qualified to manage the benefits.
Develop any indication of a change in custody to determine if there is a need for a new payee or if direct payment would be in the beneficiary's best interests.
NOTE: There is no need to develop an indication of a change in custody if it is a short-term, temporary arrangement and the beneficiary has returned to the payee's custody.
C. Item 3 - Who Decided how the Benefits were Used
A conduit payee is a payee who turns the benefits over to the beneficiary or to another person without providing any guidance about the use of the benefits. A conduit payee does not exercise any control over the funds and cannot accurately account for the funds.
The existence of a conduit payee may indicate a lack of interest in the beneficiary or suggest that the beneficiary should be receiving benefits directly.
If the response in item 3 indicates that the payee turned over the benefits without deciding how they were spent or saved, develop to determine if a new payee is needed or if the beneficiary is capable of receiving direct payment.
EXCEPTION: Do not develop if the representative payee is a guardian who does not have custody and the benefits are turned over to the custodian, but the payee provides guidance about the use of the benefits.
D. Item 4 - Use of Benefits
In evaluating the use of benefits, it is important to note that foreign cases can present special situations. Due to unique family customs in some foreign countries, the term "proper use" may have a broader meaning than when applied in domestic cases. In foreign cases, it is not unusual for only one member of a large household to be entitled to benefits. In some cultures, these large households may encompass more than those individuals living in the same house. They may include people in the beneficiary's immediate family, as well as distant relations and even unrelated individuals. The benefits often represent a substantial part, if not all, of the income to the household.
In such cases, the benefits are often merged with any other income and used for all the members of the household. No attempt is made to segregate the beneficiary's funds for his or her use to meet any special expenses or to conserve funds. His or her current needs are met in the same proportion and manner as other members of the household. The degree to which the beneficiary derives social or psychological support from such an extended or kinship family structure is difficult to measure. It is unrealistic to attempt to establish the value of the benefits derived by the beneficiary as a member of a communal family household where all members customarily share and share alike. It is equally unrealistic to expect that the beneficiary's funds would be held separately to meet only his or her needs or to provide him or her with a standard of living significantly different from the household group.
If item 4 is answered "NO," and there is not an adequate explanation in "Remarks" to determine if the payee used and/or saved all the SVB payments, develop to resolve what the payee did with the benefits.
In cases such as described in VB 00501.036D.1., do not question the use of the payments for the entire household in a foreign country.
E. Item 5 - Savings Information
Benefits not required to meet the needs of the beneficiary must be conserved or invested for the beneficiary. Conserved or invested funds must be held in a form of account which shows that the payee holds the benefits in trust for the beneficiary and has only a fiduciary interest in the funds.
Resolve any indications that the payee is conserving funds for some vague, future purpose or to pay prior debts, or to reimburse himself or herself for the support of the beneficiary.
Foreign savings account legends do not always follow the formats that are common in the United States. Legends may differ in situations where the payee is a court-appointed guardian, conservator, friend or relative or may even vary from country to country. If the payments are conserved in an account outside the United States and the account legend does not correspond to those preferred in the United States, check to determine if the account legend is listed in GN 00603.015. If it is not listed, request the FSP to determine if the bank treats the funds as belonging to the beneficiary and not the payee.