When the FO makes a decision to impose an administrative sanction, and the person
is not currently entitled/eligible for either Title II or Title XVI benefits, we must
defer the sanction period. The sanction period cannot begin until the person is entitled
or eligible to some payment under either Title II or Title XVI. There is no limit
on how long we wait to impose the sanction. The sanction period begins with the first
month that we schedule a payment under either Title II or Title XVI. Entitlement or
eligibility for a payment of even a partial or intermittent benefit will cause the
sanction period to start (see GN 02604.447J.9.). The administrative sanction is all inclusive of any type of payment made under
either title.
If we decide to defer a sanction because we denied the claim or no payment is due
for any reason, enter the following as a Special Message on the MBR for Title II or
a Remark on the SSID for Title XVI:
“Admin Sanc apply when entitled/eligible under Title II or Title XVI Refer to Administrative
Sanctions Tool”.
In addition, enter the sanction information Administrative Sanctions (SPAS) screen
in the Client database (see GN 02604.440).
When entitlement or eligibility under either title begins, follow the procedure in
GN 02604.440.
If a potential sanction applies to a person who filed a false claim using another
person’s SSN, establish an MBR (or SSID) on the SSN belonging to the person we sanction.
Process a denial using the same denial code used on the first record. Do not send
a notice on the second denial. Enter the above remark on the MBR or SSID to ensure
we impose the sanction in the future.