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. 2 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 3 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.) 5 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. 8 Let’s review the current BPQY format section by section. Please have the BPQY Handbook open as a reference. 9 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. 10 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. 12 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. 13 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+) 14 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. 15 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. 16 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. 17 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. 18 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. 20 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. 21 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. 22 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. 23 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. 24 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. 26 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. 27 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! 28 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. 29 Let’s Review Some BPQYs Abigail Benjamin Carlos Donovan 30 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. 31 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. 32