TN 14 (10-19)

GN 02230.035 Overview of the Non-Entitled Debtor (NED) Initiative

A. Definition of a non-entitled debtor

A Non-Entitled Debtor (NED) is a person or entity that owes a debt to the Social Security Administration (SSA) but is not entitled to Social Security benefits or Supplemental Security Income (SSI) payments. Generally, the NED does not have a Master Beneficiary Record (MBR) or a Supplemental Security Record (SSR) of his or her own.

B. Scope

Currently, NED captures legally defined overpayments (LDOs) consisting of payments made to representative payees after the death of a title II beneficiary, and other LDOs made to representative payees prior to the death of the title II beneficiary for which the payee is responsible. For more detailed information about this population of NED, see GN 02230.040.

Note: NED captures and controls only the LDOs described above. For example, a debt owed by an individual who fraudulently appropriates payments issued after the death of a beneficiary is not an LDO, even if the individual agrees to repay the debt or is convicted and ordered to make restitution. Such a debt is not controlled by NED.

C. Purpose

In order to take appropriate actions, SSA’s automated debt collection systems have always interfaced with an master beneficiary record (MBR) or a supplemental security record (SSR) for the debtor. In cases where the debtor did not have a MBR, debt collection required manual control and efforts.

The purpose of the NED initiative is to create an automated system for controlling debts (both overpayments and incorrect payments) owed by people who do not have MBR. Therefore, SSA developed the capability within the Debt Management System (DMS) to identify, record, collect, and otherwise resolve debts owed by NEDs.

The NED database will record overpayments and other debts in a series of releases to be determined in the future. Ultimately, the plans are to enable SSA to record and control debts owed by all types of NEDs. SSA intends to use all available, authorized debt collection methods to recover the debts:

  • Billing and follow-up via the Recovery and Collection of Overpayments (RECOOP) system;

  • Benefit withholding if available;

  • Treasury Offset Program/External Collection Operation (TOP/ECO) process to collect NED debts by means of tax refund offset (TRO), administrative offset, administrative wage garnishment (AWG), Federal Salary Offset (FSO) and any collection method subsequently added to TOP/ECO.

See Details

GN 02201.030 Collection of Title II Overpayments by Tax Refund Offset (TRO)

GN 02201.040 Collection of Title II/Title XVI Overpayments by Administrative Wage Garnishment (AWG)

GN 02201.043 Collection of Title II/Title XVI Overpayments by Federal Salary Offset (FSO)

In addition, SSA plans to report all NEDs to consumer reporting agencies.

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GN 02230.035 - Overview of the Non-Entitled Debtor (NED) Initiative - 10/31/2017
Batch run: 10/21/2019