CHILD WELFARE MANUAL

Section 4, Chapter 12 (Financial Considerations), Subsection 6 – Social Security and Federal Benefit Application and Information

Effective Date:  August 28, 2025

 

Overview

A child may receive federal benefits or may be eligible to receive federal benefits, while in the custody or under the supervision of Children’s Division (CD). It is important to determine if the child is eligible for, or is receiving federal benefits, to help support and provide future security.

Social Security is a federal anti-poverty program which administers retirement, disability, survivor, and family benefits and enrolls individuals in Medicare. Social Security benefits are payments made under a social insurance program administered by the Social Security Administration (SSA). Benefits are paid monthly to the beneficiary or representative payee to use on behalf of the beneficiary.

Social Security programs are complex; therefore, CD should always first consult a Department of Finance and Administrative Services (DFAS) Social Security Specialist when assistance is needed.

U.S. Railroad benefits are administered by an independent federal agency charged with providing benefits to eligible employees of the railroad industry and their families. It is closely tied with the Social Security program but has key differences such as funding and benefit structure.

Children of veterans or service members may qualify for certain benefits, such as health care related benefits, life insurance, or money while enrolled in higher education through the Veteran’s Administration (VA). 

Federal funds received by a child in the custody of CD shall not be used for the child’s cost of care. CD should recommend the appointment of a representative payee to manage the child’s federal benefits.  Only when there is no suitable representative payee available, should CD apply to become the representative payee. When CD is appointed the payee, the funds must be used to provide for any unmet needs and should otherwise be conserved for the child’s future benefit.

 

Policy and Procedure

Eligibility Determination and Application for benefits

Initial Eligibility Determination

Within 60 calendar days of a child entering CD custody, the CD worker should complete the CD-340 Federal Benefits Eligibility Assessment to determine whether the child is receiving or is presumed eligible to receive federal benefits from the Social Security Administration, U.S. Railroad Retirement Board (RRB) or Veterans Administration.  

The CD worker must inquire with the family if the child receives or is eligible for federal benefits. DFAS Eligibility Specialists should identify if a child is currently receiving a Social Security benefit once the Title IV-E eligibility determination for the child is completed.

If the child is already receiving benefits:

  1. The CD worker will email the completed CD-340 Federal Benefits Eligibility Assessment to the DFAS Social Security Specialist for notification the child already receives benefits.
  1. Complete the required actions in the “Representative Payee Information” section below.

If the child may be eligible for benefits and an application should be made:

  1. The CD worker will email the completed CD-340 Federal Benefits Eligibility Assessment to the DFAS Social Security Specialist for notification of the child’s potential to receive benefits.
  2. The DFAS Social Security Specialist will provide benefit application forms and instructions to the CD worker.
  3. The CD worker will complete and return the forms to the DFAS Social Security Specialist who submits all necessary forms to the applicable federal agency.

Note: The CD worker should never be listed as the child’s guardian on any Social Security forms as CD is not the child’s guardian. This is a common error which will delay benefit applications. Instead, the CD worker should be listed as the legal custodian.  

Annual Eligibility Determination  

After the initial assessment, CD shall annually review children in CD custody to determine whether a child may have become eligible since the last eligibility review for federal benefits.

The CD worker should use the CD-340 Federal Benefits Eligibility Assessment to complete the annual review.

Representative Payee Information

A representative payee is a person, or an organization, appointed to receive the federal benefits on behalf of an individual who cannot manage or direct their own benefits. Representative payees assume all responsibilities of managing benefits and reporting to the federal agency.

The federal agency providing the benefit has the responsibility to appoint a representative payee.  As an example, the preferred payee order of selection for Social Security benefits is described in 20 CFR 404.2021 and 20 CFR 416.621.

Worker Responsibilities Regarding Representative Payees

When the child is already receiving benefits prior to being placed in CD’s legal custody, or once the child is approved to receive benefits from the federal agency, these steps should be followed:

  1. The CD worker shall consult with the child and the child’s GAL to identify a suitable representative payee. The CD-341 Federal Benefit Representative Payee form will be utilized during the consultation to determine prospective, suitable representative payees, and to document the recommended payee. In the event there is disagreement as to the recommended payee, the CD worker should contact the Division of Legal Services (DLS) to determine appropriate next steps.
  2. The CD worker will contact the recommended payee to determine if the individual is interested in becoming the representative payee.
  3. If the recommended payee intends to apply to be the representative payee for the child, the CD worker should request a Representative Payee Recommendation Letter from the DFAS Social Security Specialist. The CD worker should provide the letter to the recommended payee who submits the letter to the appropriate federal agency.
    • The federal agency providing the benefit (SSA, VA, RRB) is responsible for selecting the appropriate representative payee. The recommended payee should apply to become the representative payee directly by contacting the appropriate agency.
  4. If the recommended payee is the placement provider for the child, the CD worker will direct the recommended payee to disclose to the federal agency any maintenance payments they are receiving from CD. This is important because some federal benefits programs, such as Social Security Income (SSI) program, are income based and therefore the SSA may reduce the SSI benefit if the CD maintenance is also federally funded.
  1. If a recommended payee does not wish to become the representative payee, the CD worker will contact subsequent individuals as identified on the CD-341 Federal Benefit Representative Payee form.  

Children’s Division as Representative Payee

The division shall not apply to be the representative payee, unless no other suitable candidate is available. The CD-341 Federal Benefit Representative Payee form is designed to assist the CD worker, the child, and the child’s GAL in identifying a suitable payee. If it becomes known that no other suitable payee can be identified, the CD worker will notify the DFAS Social Security Specialists who will then apply for CD to become the representative payee.

When CD is the payee, the CD worker will report the following to the DFAS Social Security Specialist:

  • Change in placement including run status, hospitalization, detention and jail;
  • Income earned;
  • Information regarding other banking (checking and/or savings) accounts or resources;
  • Hospitalizations;
  • Incarcerations;
  • Marriage; or
  • Death

Annual Reviews – CD as Representative Payee

The CD worker, in consultation with the child and the child’s GAL, shall annually review if someone other than CD is available and willing to serve as representative payee, and is in the best interests of the child to serve, to apply to assume the role of representative payee.  The CD-341 Federal Benefit Representative Payee form is utilized to document the annual review.  If a suitable payee is identified follow the steps outlined above.

A review of CD as the representative payee may occur at any time due to a change in circumstance (e.g. change of placement) or at the request of a member of the Family Support Team or Court.

Request to Change the Representative Payee

To request a change in representative payee, the CD worker should email the following information to the DFAS Social Security Specialist and the Title IV-E Benefit Program Specialist:

  • Child’s Name
  • Child’s DCN
  • Current representative payee name
  • New recommended payee name, address, phone number and relationship to the child
  • Explanation for the change request

Representative Payee – Trial Home Placement, Case Closure or Youth nearing age 18

Trial Home Placement and Case closure

As soon as a CD worker becomes aware that a trial home placement will begin or that the AC case will close, the CD worker should:

  • Email the CD-341 Federal Benefit Representative Payee form to the DFAS Social Security Specialist and the Title IV-E Benefit Specialist notifying them of any requested changes to the payee no later than 90 calendar days of the anticipated closure of the alternative care case.

Youth approaching age 18

When a youth is approaching age eighteen (18), the CD worker should:

Representative Payee – Benefits Received in Error

In the event an individual receives a check or deposit in error, or for a child that they are not representative payee for, the CD worker should:

  1. Inform the individual that it is their responsibility to return those funds to the appropriate federal agency providing the benefit who will then distribute the funds to the new representative payee, if applicable; and
  2. Follow the steps outlined in the “Worker Responsibilities Regarding Representative Payees” section of this policy.

In the event the county office receives a check made payable to the youth, and the youth is their own payee, the CD worker:

  1. Will give the check to the youth and provide guidance and support to access and use the funds.
  2. Will assist the youth in contacting the federal agency to ensure the youth’s correct address is on file, as receiving a check at the CD office indicates that the youth’s address is incorrectly recorded.

Federal Benefit Conservation

CD shall not use the child’s federal benefits for the cost of the child’s obligatory care and services. CD may only use the federal benefits for the child’s unmet needs beyond what the division is obligated, required, or agrees to pay.

When CD is the representative payee, CD is responsible for conserving the child’s federal benefits in specified accounts including:

  • Special needs trusts;
  • Pooled special needs trusts;
  • Achieving A Better Life Experience (ABLE) accounts;
  • Other trust accounts that do not interfere with asset limitations for state or federal benefits programs; or
  • KIDS account for youth who do not qualify for other types of accounts.

For youth age 16 years and older, up to $999.00 can be saved in their KIDS account with additional federal benefits being deposited using a financial institution as required by law, except in situations where the youth is in a MO Medicaid Waiver placement via an Interdivisional Agreement.

Benefit Specific Details

Supplemental Security Income (SSI)

Supplemental Security Income (SSI) is an income-based program and is established based on the child’s own qualifying disability. Factors such as income and wages of the child, as well as alternative bank accounts, stock, bonds, and some trust accounts in the child’s name can affect the SSI benefit amount.

Additionally, if a child runs away, becomes hospitalized, goes into detention, or a youth is in jail, the SSI benefit amount could be affected. If a child receives SSI benefits and their placement changes to any of the above, this information must be reported to a DFAS Social Security Specialist immediately to prevent benefits from being overpaid.

The SSA requires that an individual claiming to be a child’s guardian supply the accompanying court order naming that individual as the child’s legal guardian.  Workers are not considered the child’s guardian according to the SSA. Pursuant to MO law, CD is the legal and/or physical custodian, not the legal guardian. When completing SSA forms, CD workers must check “other personal representative” and in the text field add “legal custodian.”

Qualifications for SSI

The SSA defines a child as a person who has not attained age 18. The SSA considers a child disabled for SSI purposes if the child has a medically determinable physical or mental impairment (or combination of impairments); and the impairment(s) results in marked and severe functional limitations; and the impairment(s) has lasted or is expected to last for at least one year or to result in death. 

The SSA’s Listing of Impairments describes physical and mental conditions that are considered severe enough to prevent a person from doing any gainful activity. The listing is intended to be used as a tool to assist CD workers in determining if a child may be eligible for SSI benefits. If a child does not have a listed impairment, the SSA will evaluate if a child’s condition(s) would equate to a “listed impairment” or would cause marked and severe functional limitations.

The SSA also utilizes Compassionate Allowances when making disability determinations. The Compassionate Allowances program identifies claims where the applicant’s disease or condition clearly meets the SSA’s definition and statutory standards for disability, to reduce wait time to reach a disability determination for individuals with the most serious disabilities.

Referral/Request for New SSI Application

To determine if a child receives SSI, or to request an application for SSI be made:

  1. The CD worker will email the child’s name and DCN to the DFAS Social Security Specialist.
  2. The DFAS Social Security Specialist will provide the CD worker with the appropriate forms and instructions.
  3. The CD worker will return the completed forms to the DFAS Social Security Specialist who then submits the forms to the SSA. Forms are not to be submitted to the SSA by anyone other than the DFAS Social Security Specialist.

It may take six (6) months or more for the SSA and/or Disability Determination Services (DDS) to process the application and determine if a benefit should be awarded. The DFAS Social Security Specialist will scan and email a copy of the determination letter to the child’s worker.

It is imperative the CD worker follows the instructions of the DFAS Social Security Specialists throughout the SSI application process as DFAS and the SSA have established internal processes to best serve children in CD custody.

SSI Application Process – Medical Verification & Documentation 

Disability Determination Services (DDS) works with the SSA on disability determinations. DDS may require and schedule a medical appointment or consulting exam to aid in the disability determination.

Once a new application for SSI benefits has been submitted, it is crucial that all placement changes be updated in FACES as soon as possible, but no later than 24 hours after the placement change occurs, so appointments or exams can be scheduled within proximity to the child’s current location.

It is the CD worker’s responsibility to ensure the child attends appointments, including arranging the transportation or taking the child to the appointments. If the scheduled appointment cannot be kept or is not within proximity to the child’s location, it is the responsibility of the CD worker to reschedule the appointment directly with the DDS worker named on the appointment letter.

There may be instances in which DDS requests documentation of a child’s disability. It is imperative that the CD worker provides the information to the DFAS Social Security Specialist in a timely manner so that DFAS may submit the information to DDS.

SSI Application Process – Financial Requirements

In addition to determining disability, a child also must meet non-medical criteria related to their resources and income.

Resources

A child may qualify for SSI if personal resources do not exceed $2,000.00. Resources are things the child has ownership rights or access to, such as cash, or bank accounts, property and stocks and bonds in their name.

Income

The amount of income the child can have each month and still qualify for SSI benefits is determined January 1st of each year. The SSA does not count all types of income in determining eligibility for SSI.

Examples of income the SSA does not count:

  • SNAP benefits;
  • Food, shelter, or clothing received from private or non-profit organizations;
  • The first $20.00 of most earned income received in a month; and
  • Assistance based on need funded by state or local governments.

To learn more about types of income for SSI purposes and for a complete list of income that does not count for SSI see Understanding SSI Income (ssa.gov).

SSI Approval or Denial Process

The DFAS Social Security Specialist communicates the child’s social security eligibility determination when it is received, as well as the amount of benefit if approved, to the CD worker.

If the application is denied, the DFAS Social Security Specialist will provide the CD worker with the denial letter. The denial letter includes information and documentation that was used to make the determination.  If there is information or documents, not listed on the denial letter which could be valuable in the determination process, the CD worker will provide those items to the DFAS Social Security Specialist who can file a reconsideration, or an appeal within the 60-calendar day deadline.

Continuing Disability Reviews (CDRs)

Once SSI eligibility is established, the SSA is required to complete periodic disability reviews to verify whether the child continues to meet disability criteria. Disability reviews occur approximately every three (3) years and when a youth’s 18th birthday is approaching.

When CD is the representative payee, the DFAS Social Security Specialist e-mails the CDR forms to the worker. The CD worker will complete the forms timely and thoroughly using the instructions provided in the notification from the DFAS Social Security Specialist. Failure to complete the CDR process accurately and timely could result in a loss of benefits. 

The CD worker will return the forms and required documentation to the DFAS Social Security Specialist who provides them to the SSA. The CD worker should not send information directly to the SSA.

Important reminders when completing the CDR process:

  • CD workers do not need to request or provide medical records to the SSA. The SSA will obtain the records directly from the sources indicated on the forms.
  • If medical information is not readily known, consider seeking information from FACES medical screen or contact screen, OnBase, or Cyber Access. The Health Information Unit may also be utilized to locate information.
  • Workers may consult with placement providers and/or parents for assistance in completing the forms.
  • Forms are to be completed by the CD worker, even when consulting with others for informational purposes.
  • The CD worker is considered a legal custodian of the child. Do not mark or indicate that CD is the guardian on any of the forms.
  • If the individual has an Individualized Educational Plan (IEP) at school, a copy should be provided to the DFAS Social Security Specialist when the forms are returned.
  • The most recent court order indicating the child is in CD custody must be included.
  • To ensure all mail is centralized for tracking purposes, any section asking for a mailing address for the child or worker should be PO Box 1082, Jefferson City, MO 65102.

Continuing Disability Reviews Youth Age 18+

The SSA will initiate another CDR when the youth’s 18th birthday is approaching to determine if the youth may continue to be eligible for SSI under adult disability criteria, which differs from criteria for children. When CD is the representative payee, the DFAS Social Security Specialist will email the required forms and instructions to the CD worker. The above bulleted considerations would still apply.

When it is determined a youth meets adult disability criteria, the SSA will evaluate and determine if having a representative payee is an ongoing need or if the youth can manage their own benefits.

To ensure access to those funds, it may be necessary to assist the youth by providing guidance on how to cash a check or open and manage a checking account. Should the youth be determined incapable of managing their funds, it is important to begin transition planning with the Division of Legal Services at least one year in advance of the youth exiting care to assure the youth will have a plan for financial management (conservatorship) and/or support (adult guardianship). For additional information on establishing a conservatorship and/or adult guardianship refer to Section 4.5.9.2 Guardianship and Conservatorship.

Retirement, Survivors, and Disability Insurance (RSDI)

Old Age, Survivors and Disability Insurance (OASDI) is a Social Security entitlement program which administers Retirement, Survivors, and Disability Insurance (RSDI) benefits based on a parent’s Social Security record. This is established when a child’s parent is deceased or becomes disabled.  RSDI Fact Sheet

Referral to Establish RSDI Benefits

If a child’s parent has been determined disabled or is deceased, the worker should email the DFAS Social Security Specialist to determine if benefits are payable to the child(ren). The Title IV-E Benefit Program Specialist should be included on the email for awareness. The referral email to the DFAS Social Security Specialist should include the following information:

  • Child’s name, DCN, Social Security number (SSN) and date of birth (DOB);
  • Parent’s name, SSN and DOB (for all parents disabled and/or deceased);
  • Date of death of parent, if applicable;
  • Death certificate of parent, if applicable;
  • Proof of relationship such as birth certificate, court order establishing child support or documented proof of paternity; and
  • Court order documenting CD is the legal custodian of the child.

The worker should not contact the SSA directly as this is the responsibility of the DFAS Social Security Specialist as specific processes have been established with the SSA for completing these applications.

RSDI Youth 18+

RSDI benefits received by a child are based upon their parent’s disability or deceased status and will therefore automatically end with the payment for the month before the youth attains age 18, unless the youth is a full-time student (minimum 20 hours per week or the rate determined by the school if higher) at a secondary school, or the youth qualifies for childhood disability benefits.

For SSA purposes the youth attains age 18 on the day before their 18th birthday. This is important when the youth’s birthday is on the first day of the month.

For example, if the youth’s birthday is June 1st, they attain that age on May 31st. If the youth is neither a full-time student nor disabled in May, benefits would not be payable for May. The last check to which the youth would be entitled would be the one received in May, which represents the payment for April. 

RSDI Continuing Benefits Process

When a youth receives RSDI benefits and is approaching age 18, the SSA will send an Advance Notice of Termination of Child’s Benefits (SSA-1372) to the DFAS Social Security Specialist who will forward the form and instructions to the CD worker. The CD worker will assist the youth, in a developmentally appropriate manner, to ensure the form is completed correctly. Information provided via the SSA-1372 is used to determine eligibility beyond age 18.

If determined eligible, the youth will continue to receive these benefits through the month before turning age 19 (for those remaining full-time student status) or the month of high school graduation, whichever date comes first.

Once a youth receiving RSDI benefits turns 18 years old, SSA will automatically make the individual their own payee. However, if they receive both RSDI and SSI, the representative payee may manage both benefits. 

Additional benefits past age 19 may be possible if the youth remains in full-time attendance at an elementary or secondary school during the month of becoming age 19.  

  • If the school operates on a yearly basis, then payment may be continued after age 19 up through the earlier of:
    • the month the youth completes the course in which the youth is enrolled full-time, or
    • the second month after the month the youth becomes age 19.
  • If the school requires re-enrollment on a timeline other than a yearly basis, benefits may continue through the month ending the term that is in progress when the youth become age 19.
  • Payments cannot be made beyond age 19, if the youth becomes age 19 during a month of non-attendance (e.g. during summer vacation).

Completion of the SSA-1372

The DFAS Social Security Specialist will provide the CD worker with instructions for completing the SSA-1372. These instructions may differ from those printed on the form as the SSA and DFAS have developed unique processes related to youth in CD custody.

Tips for Completion:

  • The youth’s address should be their actual address, not a CD office address, unless the youth also receive SSI benefits for which CD is already representative payee.
    • In these scenarios, CD should be payee over both benefits; therefore, the youth’s address should be PO Box 1082, Jefferson City, MO 65102
  • The form requires the signatures of the youth and a school official.
    • Signatures do not have to be original; the form may be mailed or faxed to obtain signatures.
  • The youth should complete their portion of the form before it is sent to the school as the school verifies the accuracy of the information provided by the youth.

All questions related to the SSA-1372 process should be directed to the DFAS Social Security Specialist.

U.S. Railroad Benefits

The Railroad Retirement Act (RRA) is a federal law which provides benefits for qualified railroad employees and their spouses and survivor benefits for family members of deceased employees who were insured under the Act. The U.S. Railroad Retirement Board (RRB) administers these benefit programs, as well as the Railroad Unemployment Insurance Act (RUIA), and has administrative responsibilities under the Social Security Act for certain benefit payments.

If it is determined a child may be eligible for these benefits, the assigned DFAS Social Security Specialist should be contacted.

Veteran’s Administration Benefits

Children who have a parent who served in the military may be eligible for a variety of benefits. They may be eligible for educational benefits and scholarships to assist with furthering their education, survivor benefits, memorial benefits, and health or dependency benefits.

If it is determined a child may be eligible for these benefits, the worker will contact the assigned DFAS Social Security Specialist by sending an email with as much information as possible. Information provided includes which parent served, which branch of the military they served in, and the timeframe they served.