The FI protests to Treasury if it believes that SSA sent the reclamation request more
than 120 days after learning of the death. The 120-day period is usually counted from
the date the death notification entry (DNE) was sent to the FI. However, in some cases
the FI protests because it believes we had the death information before that time.
If the FI submits a protest of reclamation involving the 120-day rule, SSA will have
30 days to send a response to Treasury with documentation reflecting that SSA submitted
the reclamation timely.
Analysts who respond to 120-Protests should provide Treasury with:
Proof of when our agency received constructive knowledge of death; and a
Short narrative explaining why our agency had no knowledge of death prior to sending
the Notice of Reclamation.
The proof provided to Treasury could be a screenshot of an Modernized Development
Worksheet (MDW), Numident, Report of Contact, the archived Master Beneficiary Records
(MBR) section reflecting the suspension for address development, etc…. If SSA does
not provide proof to Treasury, our agency is presumed to have knowledge of death at
the time we stop certifying recurring payments.
NOTE: If a technician receives documentation reflecting that an FI is submitting protest
of reclamation involving the 120-day rule, please forward the documentation to your
Lead PSC Analyst for a Title II Reclamation. If the 120-day protest involves a reclamation
for a Title XVI benefit, please forward the documentation to OBASA.TOB@ssa.gov.
For Title II, if the Lead PSC Analyst receives a 120-day protest forwarded from a
technician or the mailroom, forward the document to Treasury and request Treasury
to determine if the 120-day protest has been addressed.