Under the Dutch system, coverage is based not only on work, but also on residence. Most persons who reside in the Netherlands will have residence-based coverage up to age 65 which is the Dutch retirement age. Thus, when issuing a coverage record for a person younger than 65, the Dutch often assume that the claimant will continue to have residence-based coverage up to the 65th birthday. Since it is obviously impossible for the Dutch to establish a full and exact coverage record prior to age 65, the Dutch refer to these as “provisional” records. The Dutch will follow up with a non-provisional record only if the provisional record is later found to be in error.

SSA will not give credit for periods of Dutch coverage that are based on assumed residence, i.e. periods that are later than the month prior to the month the coverage record was certified.

Follow these procedures when crediting periods of Dutch coverage from a provisional record.

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  Credit coverage only for months through the month prior to the date of certification.

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  Do not credit coverage for any months from the date of certification through the month of attainment of age 65 (or later).

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  Do not credit coverage for the period from the person's 15th birthday through December 31, 1956 even if it is certified by SVB.

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  Route any disallowances resulting from the above instructions to DTPS before processing the disallowance. Cite this reference in your referral.