An initial notice of overpayment should generally propose full withholding of the benefit due (excluding SMI premiums) as an alternative to full refund.

Proposing full withholding in the initial notice applies even if partial withholding (or repayment by installments) is in effect for a prior overpayment. In such case, propose full withholding for the total outstanding amount (new overpayment plus prior one). If eligibility to benefits is reestablished and there is a prior overpayment for which waiver (including personal conference) rights were offered, full (and immediate) withholding is appropriate regardless of any existing repayment schedule.

There are three exceptions to proposing full withholding:

1. a. 

   The overpayment can be recovered from a single month's benefit. The notice should propose a withholding equal to the amount outstanding and not request refund.

2. b. 

   An immediate full withholding of current monthly benefits is appropriate (see GN 02210.010A.1.). The notice should explain the current withholding and not request refund.

3. c. 

   Adjustment is proposed against a dually entitled beneficiary who is not the overpaid person. Withholding is limitedto the amount of the benefit being received on the record on which the overpayment occurred.