Introduction

Some children in DFPS conservatorship may be eligible to receive SSI benefits based on their disabilities. Regional SSI coordinators are responsible for applying for these benefits from the Social Security Administration (SSA) on behalf of these children.

To ensure that children receive SSI benefits, DFPS uses a tracking system to provide the names of all potentially eligible children who meet the necessary criteria and to track the status of the children’s SSI applications.

SSI Tracking Report

The regional SSI coordinator manages the regional SSI tracking report and makes updates continually. Quarterly, the state office SSI program specialist sends the regional SSI coordinators an electronic list of potentially eligible state-paid and Title IV-E foster care recipients targeted for SSI benefits. The SSI coordinator screens the children on the list and applies on behalf of those who may qualify.

The SSI Tracking Report is an Excel spreadsheet with three sections:

• Client Information/Characteristics (CIC)
• Status - Application Status (APP)
• Award Status (AWD)

See Appendix 1583.1 Guide to the SSI Tracking Report.

Receiving and Processing the SSI Tracking Report

1. The state office SSI program specialist sends a quarterly memo prompting the SSI coordinators to email their current SSI tracking reports to state office. SSI coordinators do not update their regional SSI tracking report until the program specialist returns the tracking report updated with the new names.
2. Within five working days after receipt of each quarterly regional tracking report, the SSI program specialist updates the regional tracking reports with the names (color-coded in red) of children potentially eligible for SSI and returns the updated SSI tracking reports to the regional SSI coordinators.
3. After the SSI coordinator receives the updated tracking report, the SSI coordinator screens the list to eliminate children who meet any of the following criteria:
   • Whose SSI applications are pending.
   • Who have recently been denied SSI benefits.
   • Who have left DFPS conservatorship.
   • Who have too much income.
   • Who are Title IV-E eligible with a higher than Basic service level.
   • Who are Title IV-E eligible and are in a Community-Based Care (CBC) catchment area.
   • Who are current SSI recipients.
4. The SSI coordinator submits a cover letter to SSA with the list of children who are potentially eligible for benefits and for whom the SSI coordinator will submit an application. In the letter, the SSI coordinator requests a protective filing date that allows DFPS to receive children’s SSI benefits retroactive to the filing date instead of from the time the application is actually submitted.

SSI and Emergency Assistance (EA) and Title IV-E Eligibility

A child cannot simultaneously receive SSI benefits and EA or Title IV-E foster care assistance. Before submitting the request to SSA for a protective filing date for a child, the SSI coordinator ensures that the child is not eligible for EA and Title IV-E. The quarterly listing of potentially eligible children produced by state office indicates whether the child is eligible for EA or Title IV-E. The state office SSI program specialist gives this information to the SSI coordinators when the SSI program specialist updates the region's SSI Tracking Report. The SSI coordinators ensure that the child’s EA and Title IV-E eligibilities are ended in IMPACT using the following method.

Title IV-E Eligibility

The decision to deny a child’s Title IV-E eligibility has a fiscal impact on DFPS by preventing the agency’s ability to offset a child’s cost of care with federal funds. The SSI coordinator reviews these cases carefully to ensure that the child qualifies for SSI. Though the best interest of the child remains the overriding concern, the SSI coordinator does not pursue application of SSI benefits for Title IV-E eligible children when it is clear that the child will not qualify for SSI benefits. In addition, SSI coordinators do not pursue SSI benefits for a child who meets both of the following criteria because it is better for the child and the agency to claim Title IV-E funds than receive the SSI benefit:

• The child is eligible for Title IV-E.
• The child has higher than a Basic service level or is in a CBC catchment area.

For an exception to this policy see:

1574 SSI Applications for Youth Aging Out of Care

1583.2 1Child Resides with a Kinship Caregiver or Other Unpaid Caregiver

If the SSI coordinator decides to pursue SSI eligibility for a child who is eligible for Title IV-E, the child’s Title IV-E eligibility must end on the first date of the month that the SSI coordinator requests a protective filing date with SSA. The SSI coordinator contacts the child’s foster care eligibility specialist to change the child’s Selected Eligibility from Title IV-E to state-paid.

Emergency Assistance (EA) Eligibility

An SSI application cannot be made for any child until the child’s EA eligibility is denied. When the SSI coordinator decides to pursue SSI or applies to be the representative payee, the coordinator contacts the DFPS Customer Service Center (CSC) at 1-877-642-4777 to request denial of the child’s EA eligibility. The coordinator informs the CSC representative that:

• The request is time-sensitive and needs to be expedited.
• The SSI coordinator is the “approving supervisor” on the data change.
• The reason for the EA denial is that the SSI coordinator is making an application for federal funding on behalf of the child from another source (SSI) and the continued EA eligibility creates a dual receipt of federal benefits that is not allowed under existing federal law and regulation.
• The child’s EA Deny date needs to be the last day of the month prior to the month the SSI coordinator submits the protective filing date letter to SSA.

The CSC assigns the EA denial request a ticket number. Each SSI coordinator tracks the requests. If more than two weeks pass before any action is reported, the coordinator reports the delay to the state office program specialist for the SSI.

Since EA eligibility might not have been determined at the time an application is filed, the SSI coordinator verifies the child’s EA status at the time a Notice of Award is received.

Submitting Applications to SSA for Benefits

Applications for SSI benefits must be accompanied by legal, psychological, and medical documents. The SSI coordinator requests these documents from the child’s caseworker. The SSI coordinator must follow up with the caseworker’s supervisor or program director if the caseworker does not provide the necessary documentation to support the SSI application. The SSI coordinator submits the application within 60 days after notifying SSA of DFPS’s intent to file an application for benefits. SSI coordinators must have a method for tracking the return of the required application information from field staff.

Updating the Regional Tracking Report

The SSI coordinator records the status of each child screened for eligibility for SSI on the APP Status worksheet on the regional SSI tracking report. The SSI coordinator enters one of the following:

• The date the application was submitted to SSA under the APP SUB column.
• The code indicating the reason the child was screened out in the STATUS column.

See Appendix 1583.1: Guide to the SSI Tracking Report for the entire list of codes and their descriptions. The coordinator updates the APP STATUS worksheet on an ongoing basis to reflect the dates the applications were submitted to SSA.

On an ongoing basis, the SSI coordinator updates information about SSI awards and current monthly benefits on the AWD (award) Status worksheet of the region’s SSI tracking report.

Regional Oversight

Supervisors of SSI coordinators verify that the coordinators have screened the potentially eligible children and updated the status on their SSI tracking reports. Supervisors check that the SSI coordinator did both of the following:

• Made an entry in the STATUS column in the APP STATUS worksheet.
• Included a date entry in the APP SUB (date application submitted) column for items marked with a P (current - pending approval) status in the same worksheet.

This date must be no later than 60 days after the screening deadline for the current listing included on the quarterly memo. By adhering to this 60-day time frame, the SSI coordinator ensures that, if the application is approved, the child’s eligibility will be retroactive to the protective filing date.

Preventing Overpayments

The SSI coordinator will receive an award letter indicating that a child will be eligible for SSI benefits. The award letter indicates the amount of the child’s monthly SSI payment and if the child will receive a lump sum payment.

Upon receipt of the award letter, the SSI coordinator:

• Reviews the child’s case to confirm that the child’s Title IV-E foster care eligibility was changed to State-paid effective the first date of the month that the SSI coordinator requests a protective filing date with SSA.
• Pulls the child’s Person Eligibility report in IMPACT to verify that that the child’s EA Eligibility has been Denied effective the last day of the month prior to the month the SSI coordinator submits the protective filing date with SSA.

If the SSI coordinator determines that eligibility for either Title IV-E or EA was mistakenly reinstated, the coordinator follows the procedures in the SSI and Emergency Assistance (EA) and Title IV-E Eligibility subheading earlier in this section to deny Title IV-E or EA eligibility.  The SSI coordinator determines if the child was therefore not eligible for part or all of the award and the amount that must be returned to SSA to prevent and overpayment based on dual receipt of SSI and Title IV-E or EA federal benefits.

The SSI coordinator receives the monthly SSI/RSDI Recipients With Eligibility Mismatches report to identify overpayment situations with children receiving SSI benefits and simultaneously having Title IV-E or EA eligibility. The report is described in 1585.3 SSA Change Reports.