Interpreting BPQYs Presentation 2015

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Work Incentives Planning and Assistance
National Training and Data Center
Interpreting BPQYs
Training Objectives
After this training, participants should be able to:
• Describe why BPQYs are necessary and identify which
beneficiaries require a BPQY.
• Identify specific strategies for procuring BPQYs from Social
Security.
• Describe what information is contained in each section of the
BPQY.
• Identify the limits of the BPQY and what information is not
contained in this report.
• Identity three situations in which BPQYs may contain
confusing information and describe strategies for making
correct interpretations.
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What is a BPQY?
• BPQY (SSA-2459) stands for Benefits Planning Query. It is a
specialized report from Social Security computer files that
provides information needed to conduct work incentives
counseling.
• The BPQY report is updated periodically. The most current
BPQY report is version 5.3.2 which was released on July 15,
2015.
• The BPQY has an associated handbook which can be found at:
http://www.ssa.gov/disabilityresearch/documents/BPQY_Han
dbook_Version%205.2_7.19.2012.pdf
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Why is a BPQY necessary?
The BPQY is a tool used to facilitate accurate and comprehensive
work incentives counseling. It will verify:
1. The type and amount of Social Security disability benefit(s)
received;
2. Some Medicare/Medicaid information; and
3. Information Social Security has about past work and work
incentive usage.
WARNING: The BPQY does NOT provide all the information a
CWIC needs to provide individualized benefits analysis!
4
Who needs a BPQY?
• Quite simply, ANY Social Security beneficiary who is going to
receive individualized work incentives counseling should have
a BPQY report generated before counseling begins.
• Some beneficiaries will require MORE information from Social
Security than is provided on the BPQY. The BPQY is the
starting point for verification – not the end.
• Additional verification will be needed if other benefits are
received (SNAP, HUD housing subsidies, etc.)
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Requesting a BPQY
• Social Security strongly encourages beneficiaries to request
their own BPQY. WIPA staff should provide guidance and
support to beneficiaries as to how to request using the Social
Security toll free line at 1-800-772-1213 or going to the local
Social Security office.
• If the beneficiary is unable to do this, or if there is undue
delay, CWICs may request the BPQY (on behalf of the
beneficiary) directly from the Field Office serving the
beneficiary or through the 800 # per current
instructions. WIPA projects should not batch the requests.
6
Requesting a BPQY
• Two signed Consent for Release of Information forms
(SSA-3288) must be submitted to Social Security if the
BPQY will be sent to anyone other than the beneficiary
and/or representative payee.
• The SSA-3288s should be pre-filled with recommended
language for release of Social Security and Internal
Revenue Service records (see pp.12-13 of BPQY
Handbook)
7
Important Tips for Obtaining BPQYs
• If the beneficiary requests the BPQY, make sure he/she knows
what to request. Referencing the Red Book is highly
recommended. No releases are necessary in these cases.
• CWICs should ask local Social Security offices how they prefer
to process BPQY requests in advance. Discuss this with local
Field Office managers, WILs and/or AWICs and follow
instructions.
• In general, Social Security offices will want faxed 3288s and
will respond by fax or mail. BPQYs are not sent by email due
to security concerns.
• Social Security should not charge a fee for producing BPQYs
when requested by WIPAs or beneficiaries.
• Work with the AWIC to resolve problems.
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Let’s review the current BPQY format
section by section.
Please have the BPQY Handbook open
as a reference.
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Cash Section – Benefit Type
This block details type and status of benefits and payment amounts.
Type of Benefit: Shows the type of benefit received.
• Possible SSDI entries:
Disabled Worker, Disabled Adult Child, Disabled Widow,
Disabled Widower, Disallowed Claim, Denied Claim-Medical Denial
• Possible SSI entries:
Disabled Individual, Disabled Spouse, Disabled Child, Blind
Individual, Blind Spouse, Blind Child, Disabled Student, Blind
Student
Current Status: A beneficiary may be in a “current pay” status (getting a
check), suspended, or terminated entitlement.
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Cash Section – Payment Amount
Full Amount: The full amount of the monthly cash benefit before any
deductions or reductions for Medicare premiums, overpayment collections,
etc.
Possible entries are: Monthly cash benefit amount, suspended, deferred, or
terminated.
The SSI full amount includes any federally administered state supplement, but
does not include any state administered state supplement payment.
Net Amount: The amount of cash benefits paid by check or electronic funds
transfer to the beneficiary’s financial institution. This is the cash amount
received after deducting any Medicare premium, overpayment recovery,
garnishment, etc. from the “Full Amount.”
11
Cash Section – Others Paid on
Record
Others Paid On This Record: Indicates if other people are entitled
to benefits on this record. Other beneficiary’s cash or medical
benefits may be affected when the disabled individual’s work
activity results in termination of cash benefits.
Total Family Cash Benefit: The full amount of cash benefits paid
to the disability beneficiary and other entitled family members
on this record for SSDI. “Not Applicable” will print under the SSI
column since SSI is an individual entitlement.
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Cash Section - Overpayments
Overpayment Balance: The current balance of any
outstanding monies owed to Social Security for
incorrect cash payments.
Monthly Amount Withheld: The amount of cash
benefits that Social Security is withholding to apply
towards a past overpayment of benefits.
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Medical Reviews
Next Medical Review: The date scheduled to review the
beneficiary’s medical condition. If “Unknown” is displayed,
no medical review is scheduled.
Medical Re-Exam Cycle: There are three types of medical
review diaries. The letter codes represent the reason for
establishing a periodic review diary of less than 3 years (AU+), while the numeric codes represent periodic review
diaries of 3 years or longer (3+, 5+, 7+)
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Representation
Representative Payee: A “No” indicates that the disabled
beneficiary receives cash benefits directly; a “Yes” means that
he/she has a Representative Payee. There are separate lines for
SSDI and SSI and it’s possible to see a discrepancy between the
programs. This discrepancy is something to point out to Social
Security so it can be fixed.
Authorized Representative: A “No” indicates that the disabled
beneficiary does not have an authorized representative; a “Yes”
means that he/she has appointed an Authorized Representative.
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Health Insurance
Type: Shows the type of Medicare and/or Medicaid health
insurance entitlement and/or eligibility on Social Security’s
records. It includes Medicare Part A (hospital) and Part B
(medical) and Medicaid eligibility status under SSI.
CAUTION: There are many sources of Medicaid eligibility that are
unknown to Social Security!
Buy-In: Shows “Yes” or “No” for Parts A & B. A “Yes” means
the state of residency pays the premium for this beneficiary.
“No” means the premium is either deducted from his or her
monthly check or paid by premium billing.
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SSI Work Exclusions
•
•
•
•
Blind Work Expenses
Impairment-Related Work Expenses
Student Earned Income Exclusions
PASS Exclusion
If a work exclusion does not apply, the entry will be blank.
If a work exclusion applies, the dollar amount of the
exclusion and the month when it was excluded will be
provided.
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SSDI Work Activity
Trial Work Months: Shows start, end and number of months
used.
Month of Cessation: A month/year will show if Social Security
has determined that the beneficiary engaged in SGA.
Current SGA Level: Sometimes the BPQY will show an outdated
figure here.
Last Work Action Review: The last work action review represents
either the last work review decision date or the date Social
Security started a current review.
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Demonstration Project Info
Provides information about any applicable
demonstration project such as a Benefit Offset National
Demonstration (BOND).
Don’t ignore this section! BOND participants cannot
be served by WIPA projects!
19
Earnings Records
This section provides a breakdown of annual and monthly
earnings. The source of the annual earnings is from the IRS
based on employer reports to the IRS and reported to Social
Security.
The right columns display monthly earnings for the most recent 2
years posted on the SSI record. Verified earnings have a “V” code
and estimated earnings have an “E” code.
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Posted SSDI Monthly Earnings
Provides a listing of the last five years of monthly SSDI earnings.
Gross Wages: The monthly earnings for the five most recent
years as posted on the SSDI record.
Gross Verification: “Y” indicates earnings are verified. If gross
earnings are unverified, they are coded with an “N.”
Total Countable Earnings: The total amount of earnings after
deductions for subsidies, special conditions, unincurred business
expenses, and impairment-related work expenses.
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Limits of the BPQY
• BPQYs only provide SOME information CWICs need. You still
need to conduct a thorough information gathering interview
and verify using other sources.
• Social Security can only verify information they are aware of –
unreported or undeveloped employment or work incentives
information will be missing.
• BPQYs are a snapshot in time – as circumstances change, so
will the information on the BPQY.
• Like all computerized reports, errors will occur. Be prepared
to spot omissions and inconsistencies.
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What You Will NOT Find on the BPQY
• Reasons for reduction in SSI and differences in full amount &
net amount of benefits (mostly Title II), except overpayment
recovery.
• Medicare Part D enrollment or any information related to lowincome subsidy (LIS) eligibility.
• Specific information about Medicaid eligibility categories
beyond SSI conduit.
• Information about beneficiary’s spouse and dependents
(other than total amount of benefits).
• Verification of EXR status.
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Tips for Checking the Accuracy of BPQYs
1. Never assume all of the information is correct – actively look
for missing, confusing, or inaccurate data.
2. Review the BPQY with the beneficiary and/or representative
payee and ask questions about any inconsistencies.
3. Get help interpreting BPQYs from your VCU TA Liaison.
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Tips for Checking the Accuracy of BPQYs
4. The beneficiary should contact Social Security, with
assistance from WIPA staff as needed, to clarify any and all
inconsistencies. Check with local Social Security offices to
find out who should be contacted.
5. Work with your AWIC when needed.
25
Interpreting Confusing BPQYs:
Earned Income Problems
• Annualized earnings are listed in the past five years, but no
month-by-month break-down in pay is listed.
• Annualized earnings are listed and some month-by- month
break-downs are shown, but no TWP months are showing as
having been used when wages appear to exceed the
guideline.
• Annualized earnings are listed but beneficiary insists that no
work has been performed.
• IRWEs are showing on page two but the countable income
and the gross wages are the same under the month-by-month
breakdown.
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Interpreting Confusing BPQYs:
Beneficiaries Who Get Two Checks
• Concurrent beneficiaries should show both the SSI and the Title II
disability benefits on the same BPQY.
• Remember that SSI and Title II benefit programs do not always count
wages the same way. Monthly wage break-downs for concurrent
beneficiaries may not always match.
• Dually entitled Title II beneficiaries will need two separate BPQYs
requested – one under each SSN.
• The BPQY will only pull information from disability files. If the person gets
a Title II benefits unrelated to disability, it will not show up.
• Dually entitled Title II disability beneficiaries have two TWPs which may
not run exactly in tandem. Only one shows on a BPQY.
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Interpreting Confusing BPQYs:
Monthly Benefit is Reduced
•
•
•
SSI cash payments may be reduced by ISM, deeming, other
unearned income, earned income, eligible couple status,
overpayment recovery or a combination of reasons.
Title II disability payments may be reduced due to Medicare
premiums, child support/alimony, voluntary federal tax
withholding, IRS or other federal program levy, PDB offset,
overpayment recovery, or a combination of reasons.
Beneficiaries need to contact Social Security (or CWICs may
contact on their behalf) to research WHY benefits are being
reduced! Your VCU TA liaison will not always be able to
help!
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Other Strange Things
What do you think these things could mean?
–
–
–
–
–
–
–
–
The date of entitlement is after the dates listed for TWP usage.
SSI recipient shows “disallowed claim” on Title II side.
SSDI beneficiary showing “terminated” on SSI side.
The SGA amount shown on the BPQY isn’t current.
The BPQY format doesn’t match the one in the BPQY
Handbook.
CDB payment is really small, but no eligibility shows on the SSI
side.
Adult SSI recipient is listed as a disabled child.
Stat blind shows on the title II side for a concurrent
beneficiary, but not on the SSI side.
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Let’s Review Some BPQYs
Abigail
Benjamin
Carlos
Donovan
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Sharing BPQYs
• The beneficiary may share the BPQY with anyone
he/she chooses.
• WIPA staff should not share the BPQY report with
anyone except the beneficiary. ALWAYS give the
beneficiary a copy!
• If you send a BPQY to your VCU TA Liaison you must
remove all PII from the report.
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Final Words
• Some BPQYs tell you more by what is MISSING, than what is
included.
• Learning to interpret BPQYs is really a matter of knowing what
to look for and how to spot clues to potential problems or
inconsistencies.
• Never assume that information on the BPQY is correct!
• Getting a BPQY does not mean that you or the beneficiary will
never have to talk to Social Security.
• Getting a BPQY does not mean that you do not need to
perform full information gathering and verification.
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