PROGRAM OPERATIONS MANUAL SYSTEMPart GN – GeneralChapter 006 – Use and Accountability of BenefitsSubchapter 03 – Conservation of BenefitsTransmittal No. 10, 06/02/2021
We updated our instructions on collective accounts to align with recent changes to the instructions on master sub accounts in GN 02402.050. We also updated information related to collective account information in eRPS, revised the language on site reviews to reflect the current monitoring process, and added clarifications to several examples.
Summary of Changes
GN 00603.020 Collective Checking and Savings Accounts Managed by Representative Payees
Subsection C.2 -We added master-sub accounts to what is an acceptable collective account and added language to align with changes in GN 02402.050 related to master-sub accounts involving representative payees.
Subsection C.3 -We moved "What is not a collective account" from Subsection C.2 to Subsection C.3. We also updated the alphabetical in this section and added information on when a payee receives benefits for multiple beneficiaries on one Direct Express card.
Subsection C.4-We moved "Third-party vendors and collective accounts" from Subsection C.3 to Subsection C.4.
Subsection C.4-We added "Corporate offices"to Third-party vendors.
Subsection D.1-We added language to show that the payee’s name on the collective account title must match the payee’s name in eRPS
SubsectionD.2.a-We added language to show that a state's fiduciary sub account can be an individual or SSA approved collective account.
Subsection D.3-We revised the language in this subsection related to local presence to more clearly distinguish it from the community-based requirement for non-governmental fee-for-service payees. We also changed the citation GN 00603.020C.2.b to GN
00603.020C.1. We also added language to the chart in D.3.c to clarify the reasons for why each example is acceptable or unacceptable.
Subsection E.1.c -We clarified that nursing facilities may establish accounts for use by both beneficiaries and non-beneficiaries clients.
Subsection G.1 -We updated the MS INTRANETERPS link and we replaced the reference to the use of the "precedent file" to store collective account information. This information will now be stored in eRPS. We updated the dates in the example, We also added a “NOTE” on how to handle if a payee has more than one approved collective account.
Subsection G.2-We updated the dates in the example.
Subsection G.3-We updated information on alerts in eRPS when a collective account is expiring. We replaced the reference of the use of the "precedent file" to store collective account information and updated the dates in the example.
Subsection G.3-We added a "NOTE" to show how and where to view terminated collective accounts.
Subsection G.4 -We changed the title of this subsection from "Expanded Monitoring and collective account" to "Monitoring and collective account." We also updated the language on periodic site reviews and updated the dates in the example.
Subsection G.5-We changed the title of this subsection from "Deleting the collective account" to"Terminating the collective account." We replaced the reference to the use of the "precedent file" with eRPS.
We may allow representative payees to “collect” Social Security or Supplemental Security Income (SSI) benefit payments for any number of beneficiaries and recipients in one deposit account. We call this a collective account. Institutions, agencies, and individual payees establish and use this “collective” checking or savings account to minimize costs and streamline maintenance. Some payees may have more than one collective account. All collective accounts must comply with SSA policy.
Field Office (FO) management reviews, approves, and monitors collective accounts. The payee must contact the FO before establishing and using a collective account. The FO management:
reviews the collective account requirements with the payee before the collective account is established;
receives the collective account documents from the payee;
determines if the accounts and documentation comply with our policy;
approves the account if the collective account and ledger meet our requirements as described in GN 00603.020B in this section; and
documents the approved collective account information in the Electronic Representative Payee System (eRPS).
A collective account is one checking or savings account that a payee uses to collect and manage the Social Security or SSI funds entrusted to the payee for each beneficiary they represent. The payee must use the collective account to pay the beneficiary's expenses.
A collective account must have a correct fiduciary title. The term “fiduciary” means the payee may not seek personal benefit from managing the money of those they represent. A fiduciary title shows the payee manages the account but does not own the account. The beneficiaries own the account, but do not have access to the account. In the account title “payee’s name for Social Security/SSI Beneficiaries,” payee’s name designates who is responsible for managing the account, and for Social Security/SSI Beneficiaries designates who owns the account.
A collective account normally contains only Social Security or SSI funds, for beneficiaries or recipients who are served by the representative payee that manages the collective account. However, some nursing facilities use resident trust fund (RTF) accounts as a collective account. These accounts can contain funds for beneficiaries and recipients who do not have a payee, and for residents who receive other federal benefits. These accounts are acceptable as a collective account, as described in GN 00603.020C in this section.
A representative payee is responsible for managing, documenting, and reporting the use of all funds they receive as a payee. The payee must keep accurate accounting records clearly showing the deposits, withdrawals, expenditures, and interest for Social Security or SSI funds for each Social Security or SSI beneficiary for whom they are payee. The payee must maintain a separate account ledger for each collective account, and maintain separate records in the ledger for each beneficiary and recipient associated with the collective account. The payee must have an accounting system that regularly reconciles all withdrawals and expenditures paid from a collective account, using the beneficiaries' funds, with the associated accounting ledger for each beneficiary. The payee can pay expenses individually or collectively, but must keep accurate records clearly documenting each beneficiary’s individual expenses and each beneficiary’s individual dollar amount of any total collectively paid from the collective account. The collective account must also be reconciled with its bank statements on a monthly basis. All documentation must be available to us at any time. A payee may have more than one collective account. Each collective account must be approved by SSA.
The funds deposited in a collective account are for the beneficiaries' needs. Payments and transactions from the collective accounts are only for the beneficiaries’ expenditures. Each collective account managed by a payee must be separate and distinct from all operating, business, and facility accounts. The payee cannot commingle beneficiaries’ funds with the payee’s money, the organization’s money, or any money belonging to the organization’s officers. The payee cannot lend a beneficiary’s money to anyone.
FO management or staff designated by management may approve a collective checking or savings account established to hold monies belonging to more than one beneficiary. The payee must understand and comply with the policies and procedures in this section when establishing and maintaining a collective account.
IMPORTANT: A collective account cannot be the payee’s operating account. Federal Deposit Insurance Corporation (FDIC) insurance will cover the beneficiary's funds that are in a properly titled collective account showing the beneficiary's ownership of the account. Additionally, beneficiaries' funds deposited into an improperly titled bank account often cannot be easily returned back to SSA in cases of misuse.
The payee must establish the collective checking or savings account at an acceptable financial institution. Information on financial institutions is located in GN 00603.020E.1.d in this section.
The representative payee must:
contact us before establishing a new collective account;
correctly establish the collective account by:
setting up the collective account as a separate account;
titling the account in a fiduciary capacity on behalf of the beneficiaries, as described in GN 00603.020A.1. in this section. (For specific titling examples, refer to GN 00603.020D in this section);
providing documentation showing the account title such as a bank statement; and
obtaining SSA approval of the documentation and the collective account prior to using it;
use the collective account to pay the beneficiaries’ expenses;
deposit and manage the Social Security and SSI funds in the approved collective account, not in the operating account, business account, or any other account that SSA did not approve, as described in GN
00603.020C.3 in this section. The payee can deposit non-SSA funds into the collective account, as described in GN 00603.020E.1.c. in this section;
account for all funds entrusted to the payee for each beneficiary by establishing and maintaining an accounting system that:
ensures a complete and separate accounting of each beneficiary’s funds deposited to the collective account; and
reconciles all checks and transactions paid from the collective account with the accounting ledger for each beneficiary.
not allow a beneficiary direct access to his or her own funds;
not commingle beneficiaries' funds with the payee’s money, the organization’s money or any money belonging to the organization’s officers, directors or employees;
not loan beneficiary funds in the collective account to another beneficiary or to the organization’s officers, directors or employees; and
not give the beneficiary’s funds to someone else to manage, unless the employee represents the payee. EXAMPLE: Manor Corporation is a payee and receives benefits for Lily, who resides at Manor Corp’s facility: Gentle Manor Nursing Home. After Manor Corp. pays Lily’s expenses for this month, $50 remains for Lily’s Personal Needs Allowance (PNA). It is acceptable for Manor Corp. to transfer the PNA to Gentle Manor for Lily’s use. However, Manor Corp. must document the transfer, and Gentle Manor must keep its own ledger and maintain documentation for Lily’s expenses. Manor Corp. must have access to Gentle Manor's ledgers to present to SSA when requested.
Each beneficiary associated with the collective account must have his or her deposits, expenditures, and transfers documented in the related account ledger.
For each beneficiary, the payee must:
account for all deposits received as payee by maintaining records that document each individual beneficiary’s funds. This includes:
listing a beneficiary’s Social Security and SSI deposits;
posting any interest due the beneficiary; and
reconciling a beneficiary’s deposits and interest on the monthly collective account statement to each beneficiary’s account in the account ledger.
account for all expenditures from a beneficiary’s funds by showing whom they paid, the amount paid, and the date paid. This includes documenting a beneficiary’s individual dollar amount of any total collectively paid from the collective account;
document the PNA, if applicable. A payee must list the PNA as one entry in that month if the payee transfers the PNA to the payee’s employee to manage, as explained in GN 00603.020B.1.i. in this section. However, the employee or facility who receives the PNA must maintain a ledger documenting receipt of the PNA for the beneficiary, and document the beneficiary’s expenditures, as described in GN 00603.020F.3 in this section; and
account for all transfers of a beneficiary’s funds by documenting any funds moved to another account or financial vehicle. EXAMPLE: The collective account balance is $502.00 and $500.00 of it belongs to James. The payee moves the $500.00 from the collective account to a correctly titled Certificate of Deposit (CD) for James. The account ledger must reflect this CD as conserved funds.
The standard definition of a collective account and related accounts is in GN
00603.020A.1. in this section.
The following relates to other types of acceptable collective accounts:
As of September 2011, the U.S. Department of the Treasury allows the delivery of federal payments to RTFs held by nursing facilities. These accounts are also known as patient fund accounts and are limited to Nursing Facility usage only. These accounts pool federal benefits for residents:
who receive Social Security and/or SSI benefits and the nursing facility is their representative payee;
who directly receive Social Security and/or SSI benefits (beneficiaries without a representative payee); and
who authorize the deposit of other funds, such as pensions and VA payments.
NOTE: We use RTF in the rest of this section to refer to RTFs and RTAs.
As of March 1, 2013, all federal benefits must comply with Treasury’s Electronic Initiative, which eliminates paper checks. Nursing facilities use the RTF to comply with the initiative. If a financial institution allows a facility to use an RTF account, you can approve the account as a collective account, using the following requirements. The account must:
show the payee’s name in the RTF title (payee’s name Resident Trust Fund);
be managed by the named payee; and
receive the full deposit of each beneficiary’s Social Security and SSI benefits.
IMPORTANT: If a beneficiary has a representative payee, the facility must be that representative payee in order to receive a beneficiary’s benefits. The facility cannot receive a beneficiary’s benefits that SSA has designated to another payee.
We do not consider some RTFs collective accounts. This often occurs when a corporation has established an RTF for their residents, but they are not the payee that SSA selected to receive and manage funds. For examples of when an RTF is and is not considered an acceptable collective account, see GN 00603.020H.3 and GN
00603.020C.1 in this section
For RTF titling examples, refer to GN 00603.020D in this section.
For RTF titling scenarios, refer to GN 00603.020H.3 and GN 00603.020H.4 in this section.
For other RTF policy, refer to GN 00603.020E.1.c in this section.
Financial institutions use master-sub account configurations for various business purposes. Master-sub accounts involving representative payees require that the payee establish a separate checking or savings account, as a sub account, for each beneficiary or recipient. The title of the master and sub account must show that the payee holds the account in a fiduciary capacity on behalf of the beneficiaries or recipients and that the beneficiaries or recipients own the account without having access to it.
Master-sub accounts involving representative payees are required to follow the same rules and requirements as a collective account covered in this section. The payee must:
contact SSA for guidance on how to set up the master-sub account before it is established;
maintain a system of ledgers for the master and sub accounts that show all transaction activities including deposits, withdrawals, and each sub-accounts remaining balance for each beneficiary; and
establish a separate, properly titled, checking or savings account, as a sub account, for each beneficiary or recipient.
Payees using SSA-approved master-sub accounts must have funds deposited into the master account, not the sub account, except in the situation described in GN 02402.050B.2.c.
Field office management or staff designated by management must adhere to the collective account responsibilities outlined in GN 00603.020G to ensure that the payee establishes the master-sub account properly.
NOTE: In some cases, the representative payee and the master account holder are not the same entity (e.g. the beneficiary lives in a nursing home and the spouse is the representative payee). In this situation, the representative payee of the beneficiary may not relinquish control of the beneficiary’s Title II or Title XVI payments to the master-sub account holder. Refer to GN 02402.050B.2.c.
For specific master-sub account policy, refer to GN 02402.050 and GN
The following situations are often confused with collective accounts, but they are not collective accounts.
The payee may transfer funds from a collective account to a separate, correctly titled individual account or financial investment account, as shown in the example in GN 00603.020B.2d in this section. However, the individual account is not part of the collective account.
An operating account is not a collective account. A payee cannot use an operating account, business account, or any other improperly titled account to receive the direct deposit of beneficiaries' funds.
A payee may transfer a beneficiary’s cost-of-care, fee-for-service fee, or other reasonable expenses from a correctly titled collective account to another account, such as the payee’s operating account, to pay themselves or others. These funds must not accumulate in this account. For an explanation of reasonable expenses, refer to Use of Benefits, GN 00602.000. The payee must maintain accurate records as explained in GN 00603.020B.1 in this section. For government exceptions, see GN 00603.020D.2 in this section.
According to the Direct Express Debit Card Program policy, individual payees can request one Direct Express card to contain the benefits for multiple beneficiaries. Although the Direct Express card is not a collective account, the payee must establish and maintain an account ledger system, as described in GN
00603.020B.2 in this section to ensure a full and separate accounting of each beneficiary’s funds entrusted to the payee. Direct Express cards are not available to organizational payees. For complete information about Direct Express cards, refer to GN 02402.007.
NOTE: If a payee receives benefits for multiple
beneficiaries on one card and one of the beneficiaries dies, the bank
may freeze the card, which makes all funds on the card
A prepaid debit or credit card, or a gift card cannot replace a collective account. These cards titles do not include the fiduciary requirement. However, a payee can give a beneficiary his or her PNA using one of these cards, if the beneficiary agrees and if there are no fees associated with the card. The payee must document the transfer of the PNA to a card as described in GN
00603.020B.2.d in this section. For additional information about prepaid cards, refer to GN 02402.030D.
Payees may enter into contracts with third-party vendors or may use its own parent corporate office to handle client/resident fund accounts and to provide accounting services. However, we hold the payee responsible for establishing the accounts and providing us with the complete accounting of each beneficiary’s funds, as described in GN 00603.020B in this section. The payee is also responsible for determining the beneficiary’s needs and managing the use of funds to meet those needs. The payee, not the third party or corporate office, must timely submit complete annual accounting reports and final accounting reports.
Although a vendor or corporate office handles the representative payee’s accounting, the payee cannot outsource its fiduciary responsibilities. Our relationship is with the representative payee.
Bank accounts must include the representative payee’s name in the fiduciary title, not the vendor’s or corporate office's name.
Our records (Form SSA-11-BK Request to be Selected as Payee), and eRPS, must have the representative payee’s name on them, not the vendor’s or corporate office's name.
For corporate or third-party vendor RTF titling scenarios, refer to GN
The collective account title must show that the payee holds the account in a fiduciary capacity on behalf of the beneficiaries. The payee’s name on the collective account title must match the payee’s name in eRPS.
The beneficiaries must own the account without having access to it. The payee manages the funds, but cannot have a personal interest in the account (incorrectly titled as a joint account). For parent and spouse exceptions, refer to GN
Some acceptable collective account titles are:
Payee’s name for Social Security/SSI Beneficiaries;
Payee’s name for (any similar term describing Social Security/SSI Beneficiaries, such as "SSA beneficiaries"); and
Payee’s name Resident Trust Fund.
If the collective account title is:
This is a general account, not a fiduciary one.
Jane Smith for Social Security Beneficiaries
This is an appropriate title for an individual payee.
Helping Hands Fund for Social Security Beneficiaries
This is an appropriate title for the organizational payee, Helping Hands.
Helping Hands Fund for Social Security/SSI Beneficiaries
Helping Hands Resident Trust Account. See GN 00603.020C.1 in this section.
Helping Hands Trust
(a traditional trust account)
A payee cannot use a traditional trust fund as a collective account.
There are account titling exceptions for state/local governments,
see GN 00603.020D.2 in this section.
For examples of proper accounts titles involving an organizational payee using a “doing business as” (DBA) name, see GN 00603.020D.3.c.
NOTE: Helping Hands’ name and address must be in eRPS as the org payee. Helping Hands can use the corporate employee identification number (EIN).
There are account-titling exceptions for State and local government organizational payees.
A State or local government may require a subordinate agency to deposit all receipts into the State/local government’s general depository account that routes the deposits to an agency specific sub account.
The agency payee may use a State/local general depository account provided:
The State/local government requires the use of the general depository account;
The State/local government promptly routes beneficiary’s funds from the general depository account to a payee’s fiduciary collective account set up for the beneficiaries. The payee’s fiduciary collective account can be an individual account or SSA-approved collective account;
The sub account protects beneficiaries funds from any State/local government use; and
The payee complies with the payee responsibilities set out in this section.
A State or local government may have a current childcare fund, foster care account, or similar account to receive funds and pay expenses. The agency payee may use this account provided:
The State/local government uses this fund to receive the Social Security and SSI benefits;
The State/local government uses this fund to pay routine cost-of-care expenses;
The State/local government maintains sub account ledgers detailing cost of care and the Social Security and SSI deposits for each child beneficiary;
The sub account protects beneficiary funds from any State/local government use; and
The following pertains to organizational payees.
A corporation can operate its business using a DBA name. The corporate name is the legal name. The DBA name is the business name of one of the entities of the corporation. A corporation can have multiple businesses and use different DBA names to identify them.
EXAMPLE: Manor Corporation owns two community-based nursing facilities. The corporation does business as:
Manor Corporation DBA Gentle Manor Nursing Facility; and
Manor Corporation DBA Daisy Manor Nursing Facility.
In this example, if Gentle Manor is the payee, Gentle Manor must manage the collective account.
When evaluating an organizational payee applicant, we consider whether the organization has custody of or is located in close proximity to the beneficiary. See GN 00502.130. If the payee organization is a subsidiary, local chapter, or branch office of a parent corporation, the payee’s name, not the parent corporation’s name, must be part of the collective account title and must be in eRPS. Do not use the parent corporation’s name unless the parent corporation is the payee.
Using the Manor Corporation example in GN 00603.020D.3.a in this section, we prefer the individual nursing facilities; Gentle Manor and Daisy Manor, to be the payees, not Manor Corporation. When using a collective account, each payee would have an account using that specific business’s DBA name. The payee must deposit Social Security and SSI funds into the payee’s collective account. In this example, Gentle Manor receives the deposits for Gentle Manor residents and Daisy Manor receives the deposits for Daisy Manor residents.
The following shows examples of acceptable and unacceptable collective account titles using Manor Corp. and Manor Corp. DBA Daisy Manor Nursing Facility:
No, neither can use this as a collective account.
This is a corporate account, not a fiduciary account. There is no indication SSA beneficiaries own the funds within the account.
Manor Corporation DBA Daisy Manor Nursing Facility
This is the nursing facility’s business account. There is no indication SSA beneficiaries own the funds within the account.
Manor Corporation DBA Daisy Manor Nursing Facility Resident Trust Fund
Yes, if the payee is Daisy Manor.
See GN 00603.020C.1 in this section. Trust as a legal term demonstrates a fiduciary role of the payee over assets belonging to the residents, aka beneficiaries.
Daisy Manor Nursing Facility Resident Trust Account
Manor Corporation Resident Trust Account
Yes, if the payee is Manor Corp.
No, if the payee is Daisy Manor.
See GN 00603.020C.1 in this section.
Daisy Manor Nursing Facility Fund for Social Security Beneficiaries
Yes, if Daisy Manor is the Payee.
NOTE: Whenever Daisy Manor is the payee, Daisy Manor’s name and address must be in eRPS as the org payee. Daisy Manor can use Manor Corp.’s EIN.
Manor Corp. Fund for Social Security Beneficiaries
Yes, if Manor Corp is the payee.
NOTE: Manor Corp.’s name, address, and EIN must be in eRPS as the org payee.
The following applies to collective account transactions:
IMPORTANT: Only the designated representative payee for a beneficiary can receive the beneficiary’s Social Security or SSI funds.
As a representative payee, the payee must receive the deposit of Social Security or SSI funds in a fiduciary account with the payee’s name in the title. The payee must title the collective account as described in GN 00603.020A.1 and GN 00603.020D in this section.
The payee cannot deposit SSA benefits into a payee’s operating account, business account, or any other account that does not have Social Security approval.
Refer to GN 00603.020D.2 in this section.
We prefer the collective account contain only Social Security or SSI funds the individual or organizational payee receives.
However, nursing facilities may establish an account, such as the Resident Trust Fund account, for the use of all their clients. For more information concerning RTF accounts, refer to GN 00603.020C.1 in this section.
For other accounts, the FO may approve an account containing both beneficiary and non-beneficiary money, if it has a correct title and the payee can adequately account for the funds owned by each beneficiary.
IMPORTANT: If a beneficiary has a representative payee, the individual or organization must be the designated representative payee for that beneficiary in order to receive the deposit of the beneficiary’s benefits. The individual or organization cannot receive a beneficiary’s benefits we have designated to another payee.
A properly titled collective account established at an FDIC-insured financial institution, usually a bank, provides each beneficiary in the collective account FDIC protection up to $250,000.
Other financial institutions offer similar deposit protection. For the acceptable types of financial institutions, see GN 02402.030. The FO must make sure an account established at any type of financial institution adheres to all collective account policy so that each beneficiary’s funds in the account are insured.
The FDIC limit applies per financial institution. The payee should ensure that a beneficiary’s funds in the account do not exceed the FDIC insurance limit at one financial institution.
Payees use collective accounts to eliminate or reduce the amount of service charges or other fees charged to beneficiaries by the financial institution. A payee may use an account that charges the beneficiary individual account fees or prorate the fees associated with the collective account. We strongly encourage payees to avoid or minimize such fees. If a payee is allowing the financial institution to assess excessive or unnecessary fees, this may be one indication that the payee is not serving the best interests of the beneficiaries.
Any interest earned by the collective account belongs to the beneficiaries. The payee should prorate and credit interest to each individual beneficiary, based on his or her share of funds in the account, as described in GN 00603.010.
NOTE: In situations where the total interest paid on the collective account is minimal ($10 or less per quarter), we do not need a strict allocation of the interest. Use a reasonable method to allocate the interest, such as equally dividing the interest among all beneficiaries having a share in the account.
The representative payee can transfer money for transactions such as cost-of-care, PNA, or to conserve a beneficiary’s funds.
The payee can make payments from the collective account using any method acceptable to the financial institution, such as electronic funds transfer (EFT) or a paper check. The payee can transfer a beneficiary’s PNA to a bankcard or prepaid card, as described in GN 00603.020C.3.d in this section.
Payees may transfer money, such as cost-of-care, fee-for-service fees, or another reasonable expense, from the collective account to another account, such as their operating account, to pay themselves or others, as explained in GN 00603.020C.3.b in this section. The payee must thoroughly document transfers to an operating account or business account for Social Security review.
Payees must have policies in place to timely return outstanding funds to the collective account that originally received the funds and document voided transactions on the beneficiary’s sub account ledger, when warranted.
A beneficiary’s funds should not accumulate in a collective account. If the payee has met the beneficiary’s current needs, does not anticipate any foreseeable beneficiary needs, and the remaining beneficiary’s funds exceed $500, the payee should transfer the funds from the collective account to a separate, correctly titled, interest-bearing account, or other investment, that is relatively risk free. The payee must document the transfer on the beneficiary’s account ledger as noted in the example in GN 00603.020B.2.d in this section.
For more information about conserving benefits, see GN 00603.001.
If the payee is frequently transferring money between the collective account, an operating account, and other accounts, request documentation and an explanation. We do not allow a payee to borrow a beneficiary’s funds. We do not allow a payee to lend a beneficiary’s funds to anyone, as described in GN 00603.020B.1 in this section.
NOTE: Representative payees that have more than one
collective account may not transfer beneficiaries' funds from one collective
account to another collective account.
For information on transfers between an operating account and a collective account, see GN
00603.020C.3.d in this section.
A payee must:
understand and comply with our collective account policies and procedures, as summarized in GN 00603.020A in this section;
establish and maintain a collective account and its related ledger according to our policy in GN 00603.020B in this section;
title the collective account as described in GN 00603.020D in this section;
manage the account according to our policy in GN 00603.020E, GN 00603.020F.2 and GN
00603.020F.3 in this section; and
understand and comply with all other collective account policies and procedures, as described in this section.
A payee must accurately manage and maintain each beneficiary’s benefits by:
maintaining a system that ensures a complete and separate accounting of each beneficiary’s funds entrusted to the payee;
accounting for all funds deposited into the collective account, and all withdrawals and expenditures from the collective account, with the expenditures documented on each beneficiary’s account ledger. The accounting must include transfers to other accounts for cost-of-care, fees, PNA or any other expense; show any outstanding items; and show any funds moved to a conserved funds account.
reconciling monthly all bank accounts and their associated ledgers containing beneficiary’s funds with the payee’s use of these funds; and
keeping electronic or printed copies of the reconciliations.
A payee must document all accounts and transactions involving a beneficiary’s funds by:
having the account title show that the funds belong to the beneficiaries and not the payee; and that the payee manages the account;
ensuring clear and current records show the amount of each individual beneficiary's share in the account;
having access to any account statement or supporting record involving a beneficiary’s funds;
providing the account statements, supporting records, and a complete and separate accounting of each beneficiary’s funds entrusted to the payee, upon our request. Electronic documents, such as scanned receipts or bank statements are acceptable records, as long as they are available to us. For example, we cannot access a payee’s bank account online to review the payee’s bank statements, but the payee can download the files and give them to us.
In addition, care facilities should maintain a petty cash log or account ledger for a beneficiary’s personal spending funds, also known as the PNA. The payee must make the log available to us and should include the date and amount of funds received, the owner and beneficiary’s name, intended use of the funds, a beneficiary’s signature, and a staff signature.
Field Office (FO) management or staff designated by management is responsible for ensuring that the payee establishes the collective account in accordance with our policies and procedures as described in this section. The FO must review collective account documentation at least once every three years to ensure continued compliance with SSA policies and procedures. We use eRPS to establish and document approved collective accounts, as follows:
Use eRPS to document collective accounts. Enter and update approved collective accounts, as described in MS 07418.001 and MS 07418.002.
When entering a newly approved collective account, set the initial expiration date of the approval by adding three years to the date the collective account is established. eRPS allows the expiration date of not less than 6 months or more than 3 years from the current date.
NOTE: If the payee has more than one approved collective
account, use the Make Note screen in eRPS to document the account information of
all approved collective accounts.
EXAMPLE: Bruce Doe is a lawyer serving as an individual payee for 15 Social Security beneficiaries. His law firm is not the payee. You explain the collective account requirements to Mr. Doe, and he opens a collective checking account titled Bruce Doe for Social Security/SSI Beneficiaries. He provides you with a bank statement or other bank documentation showing this title and the account number. You approve the account on October 13, 2018, and use the account documentation to set up direct deposit into the collective checking account for all of the beneficiaries entrusted to Bruce Doe.
Finally, you establish, Bruce Doe in the collective account in eRPS as described above. Use the initial approval date (10/13/18) to determine the expiration date. In this case, set the expiration date to 10/13/2021.
Select one beneficiary’s financial transactions for a one-year period. Review the transactions to determine if the payee is maintaining the account properly, the bank statements are reconciled, and the account title is correct. If the payee is complying with our collective account policy and procedures, approve the account and reset the expiration date for the next three-year period.
If the account is not in compliance, document facts and problems using the Make Note screen in eRPS under the Rep Payee Details. Review the issues with the payee and follow up with the payee in 90 days to verify the problems are resolved.
EXAMPLE: If the expiration date was 3/31/2019 and the payee's collective account remains compliant, set the expiration date to 03/31/2022.
When the collective account for a particular payee is expiring, eRPS creates a work issue “Collective Account Recertification” three months before the expiration date in the Workload Management screen. eRPS creates a second recertification alert during the expiration month. This recertification can be viewed in eRPS under the Workload Management screen. Follow GN 00603.020G.2 for instructions on how to review the account for compliance and approval.
If the FO fails to review and approve the account, eRPS automatically terminates the payee’s collective account information during the following month (30 days after expiration date).
This deletion causes two issues:
If the account is no longer active in eRPS, the payee’s collective account information on their next accounting report will not match our files, and the electronic Representative Payee Accounting (eRPA) system will generate an exception. Wilkes-Barre (WBDOC) will initially receive the exception, but WBDOC cannot update the account information. WBDOC and the Processing Centers (PC) can only query eRPS. You receive a pending annual accounting exception case and must resolve the exception; or
If the account is no longer valid as a collective account, you must request the account documentation from the payee to see if the account is still active and compliant with our collective account policies and procedures. You must review and approve the collective account again. EXAMPLE: ABC Mental Health, Inc., a representative payee, has an approved collective account with a 09/2019 expiration date. In June 2019, you receive an alert to review the account. In September 2019, you receive the second alert. You do not review the account and eRPS automatically deletes it in October 2019. In January 2020, the payee submits an accounting report designating they have a collective account. The report is now an exception in eRPA and refers the report to the field office to resolve. Since the status of this collective account is no longer available after four months, you must review the account documentation to see if it is still active and compliant. You must review, approve, and establish the collective account in eRPS again. Set the new expiration date based on your new approval date.
NOTE: To view terminated collective accounts, see MS
07418.004 and MS 07418.005 for information and guidance.
A payee that has an approved collective account may be subject to a payee site review. Some payees receive a site review every four years, but we must review collective accounts every three years. For an overview of monitoring, refer to GN
Before the site review, query the collective account in eRPS, to verify that the payee has an approved collective account and to determine the expiration date. After the site review, if the collective account is in compliance, reset the expiration date in eRPS. Use the review date as the basis for the next three-year interval. If the account is not in compliance, follow the instructions in GN 00603.020G.2 and G.3.
EXAMPLE: A site review is conducted at Sunnydale Nursing Facility in February 2019. A query of the collective account eRPS shows the approval expires in 14 months (04/2020). After the review, the FO determines if the payee maintained the collective account in compliance with our policies and procedures. Use the site review date (02/2019) to calculate the new expiration date and reset it to 02/2022.
Terminate the collective account in eRPS when the payee no longer serves as payee, or when they no longer maintain a collective account for beneficiaries.
The following organizational payee scenarios refer to the Manor Corporation and its nursing facilities, introduced in GN 00603.020D.3.a in this section. Manor Corporation owns two community-based nursing facilities, Daisy Manor and Gentle Manor.
The nursing facilities, Gentle Manor and Daisy Manor, are the organizational representative payees. Each facility must establish its own collective account to receive Social Security and SSI deposits for the beneficiaries they serve. Each nursing facility must maintain a separate account ledger for the collective account, and maintain separate records in the ledger for each beneficiary and recipient associated with the collective account. For PNA documentation information, refer to GN 00603.020F.3 in this section. Each nursing facility completes an annual accounting report for each of their beneficiaries.
The FO will enter each payee in eRPS with the payee’s own business name, even if the payees use the corporate EIN. Although Manor Corp. owns both nursing facilities, Gentle Manor and Daisy Manor cannot share a collective account because they are responsible for different beneficiaries. The corporation, Manor Corp., cannot set up one collective account, because the corporation is not the payee for any of the beneficiaries.
If Manor Corp. is the most suitable payee for its beneficiaries, you will enter Manor Corp. as the payee in eRPS.
Manor Corp. decides to have one collective account to receive all of the Social Security and SSI deposits for all residents of the facilities it owns. Manor Corp. must also establish a separate account ledger for the collective account, and maintain separate records in the ledger for each beneficiary and recipient associated with the collective account.
The payee cannot transfer beneficiaries’ money to its other businesses. The payee cannot allow their other businesses, such as the nursing facilities, to administer the funds. The only exception is the PNA.
PNA information, and examples, are located in this section as follows:
for transfer example, refer to GN 00603.020B.1.i.
for documentation policy, refer to GN 00603.020B.2.d.
for prepaid card policy, refer to GN 00603.020C.3.d. and
for petty cash log example, refer to GN 00603.020F.3.
In addition, Manor Corp. must:
maintain a system that ensures a complete, and separate accounting of each beneficiary’s funds; and
complete an annual accounting report for each beneficiary.
Manor Corp. has an RTF account for residents at Gentle Manor and Daisy Manor, who do not have a representative payee. The account receives Social Security, SSI, and Veteran’s Administration (VA) deposits. The title of the account is Manor Corp. Resident Trust Fund.
serves as payee for 15 of its residents;
cannot use the Manor Corp RTF;
must establish its own collective account and account ledger for the 15 residents;
must include Daisy Manor’s name in the collective account title; and
can use a RTF account titled, “Daisy Manor Resident Trust Fund”, as described in GN 00603.020H.4 in this section.
Daisy Manor cannot use the Manor Corp. RTF account since:
Daisy Manor does not manage the account or have access to the account documentation;
Daisy Manor is the payee, not the Manor Corp; and
the payee must deposit the beneficiaries’ funds into an account that shows the payee is the manager of the fiduciary account (payee’s name for Social Security/SSI Beneficiaries).
Manor Corp. cannot receive the deposits for residents with Daisy Manor selected as the representative payee because Manor Corp. is not the payee for any of the beneficiaries. However, Manor Corp. can receive the deposits for beneficiaries Manor Corp. serves as payee.
Manor Corp. is the payee. It receives $950 for a beneficiary.
Example 1: We deposit the $950 into the account: Manor Corp. Resident Trust Fund. Manor Corp. transfers $900 from the RTF into its operating account to pay for the beneficiary’s cost of care; then documents the $50 remaining in their RTF, using their account ledger system. (Acceptable); or
Example 2: We deposit the $950 into the account: Manor Corp. Resident Trust Fund. Manor Corp. retains the cost-of-care for each beneficiary and sends the PNA to Daisy Manor. Manor Corp. deposits the $50 into the Daisy Manor Resident Trust Fund. Daisy Manor documents the $50 using their account ledger system. Manor Corp. reviews the ledgers maintained by Daisy Manor and can present them to SSA when requested. (Acceptable)
Daisy Manor has an RTF account for Social Security and SSI deposits of its residents who do not have a representative payee. The account also receives some of the resident’s VA deposits. The title of the account is “Daisy Manor Resident Trust Fund”.
Daisy Manor is the representative payee for 15 of its residents. Two other residents have representative payees other than Daisy Manor. Daisy Manor can use the Daisy Manor Resident Trust Fund for the 15 residents its serves as payee.
must maintain a system that ensures a complete and separate accounting of each beneficiary’s funds;
must complete an annual accounting report for each of its 15 beneficiaries; and
cannot accept SSA benefits for the two residents who have individual representative payees.
Example 1: Daisy Manor is the payee for a beneficiary who receives $1500 monthly in Social Security benefits. We deposit the $1500 into an account titled Daisy Manor Resident Trust Fund. Daisy Manor transfers $1450 to Manor Corp. for the beneficiary’s cost of care; then documents the remaining $50 using their account ledger system. (Acceptable); or
Example 2: A representative payee, other than Daisy Manor, receives $1200 for her mother who resides at Daisy Manor. Daisy Manor asks the payee to sign a Request for Direct Deposit (SF-1199A) to deposit the mother’s benefits into Daisy Manor Resident Trust Fund and the payee agrees. (Unacceptable).
You must inform the payee that she cannot deposit benefits entrusted to her to an account she cannot manage or access. You must inform Daisy Manor that they are not the representative payee and cannot receive the funds. Remind the payee that she will have to account for the benefits she receives when she gets the annual accounting form.
Atlas Funds Management Co. is a third-party vendor that handles accounting for Manor Corp. Atlas establishes a Resident Trust Fund (RTF) account, titled “Atlas Resident Trust Fund” to receive federal direct deposits for Gentle Manor Nursing Facility and Daisy Manor Nursing Facility. The residents at Gentle Manor and Daisy Manor, who do not have a representative payee, direct the facilities to manage their funds. However, Daisy Manor is also the payee for 15 residents who receive Social Security and SSI benefits. Two other residents have representative payees, other than Daisy Manor. Daisy Manor must establish a properly titled collective account and an account ledger for the 15 residents. Daisy Manor cannot accept the benefits for the 2 residents who have other representative payees. Atlas Funds cannot accept benefits for the 17 residents who have representative payees. See the examples in GN
00603.020H.4 in this section.