Ask Larry

Was There A Recent Social Security Change That I Missed?

Larry,

I’m a former customer, having subscribed twice over a 3+ year period and was very happy with your planning tool

Last week, both my spouse and our disabled adult child(DAC) each received a separate letter from SSA stating; ‘We reduced the monthly benefit amount beginning Dec 2022 because of a change in the way we compute benefits when someone is entitled on more than one SSA record.’

I’ve tried to be concise below, so hopefully you can opine. Was there a recent change by the SSA that I’ve missed? I was told they review payments twice a year manually and adjust when necessary. I realize our benefit scenario is complicated but was hopeful that once the data and claimant relationships were entered into the SSA system correctly, it would be locked in and only reviewed when necessary by claims specialists with an appropriate knowledge base and experience for more complex claims.

Background;
Feb, 2021 (age 64y11m) and a PIA of 2,732+-, I filed for reduced benefits of 2,501.50.
Though already receiving SSDI, I also filed for our DAC to receive auxiliary payments from my Family Benefits and to be associated with my record. (This took 16+ months)
Sept, 2022. After the DAC app was approved, my spouse was allowed to file for child-in-care benefits. This was approved and payments received.
Dec, 2022. (age 66y04m / FRA). Spouse files for their own retirement benefits with PIA of 524.60 to be augmented by auxiliary Family Benefits from my earnings record. Child-in-care benefit payments cease.
Dec, 2022 thru March, 2023. SSA payments received.
Self. 2,878.90 (reduced). *Note: My 2023 PIA is 3,179.80 / Family 5,564.20.
Spouse. 524.60 (PIA) + 1,064.30 (aux) = 1,588.90.
DAC. 718.20 (SSDI) + 870.80 (aux) = 1,589.00.
1,589.90 is half of my 2023 PIA.
Family 5,564.20 - 3,179.80 (PIA) = 2,384.40 available for family auxiliary.
Note: when adjusted for COLA increases, my spouse's payment was within .63 and the DAC payment within $4 of your software illustration. Awesome!
April, 2023. SSA Letter new payment breakdown for spouse and DAC. (25% reduction)
a) Spouse. 524.60 (PIA) + 667.60 (aux) = 1,192.20
b) DAC. 718.20 (SSDI) + 474.40 (aux) = 1,192.60.
I’ve tried to back end to their total number of 1,192.20 + 1,192.60 = 2,384.80. The closest I can come is in 2021, my reduced benefits of 2,501.50 - 148.50 (medicare) = 2,353. I know that isn’t correct, but the letter didn’t show their work or logic to arrive at this new amount. Only stating that they changed how they computed benefits.
We’ve gone to our local SSA office and have asked for an appeal and reconsideration.

Thank you for considering our submission.

Kind Regards

Hi. I answer general Social Security questions submitted to the 'Ask Larry' site, but I'm not involved in the software operations and I don't have access to software customer records. You may want to resubmit your question using an online contact form available in the help menu so that your question can be answered by one of our experts with access to your customer records.

I am, however, a retired Social Security technical expert, so I can give you my analysis based on what you've stated in your question. When your wife filed for her own benefits effective December 2022, that made her what Social Security refers to as dually entitled (i.e. entitled to two different benefits). In your wife's case, the dual benefits are retirement benefits on her account and spousal benefits on your account. Apparently, your child is also dually entitled to Social Security disability (SSDI) benefits on their own account and disabled adult child (DAC) benefits on your account.

The rules for calculating benefit distributions to dually entitled beneficiaries is explained in the following section of Social Security's operations manual: https://secure.ssa.gov/apps10/poms.nsf/lnx/0300615768. The bottom line is that because of their dual entitlement, your wife and child can't be paid a total monthly benefit rate in excess of their share of the difference between your PIA and the family maximum amount. You state that your PIA is 3,179.80 and your family maximum is 5,564.20, making the difference $2384.40. Split that evenly between your wife and child and you get $1192 each.

Therefore, Social Security's calculations appear to make sense to an extent, but what they apparently failed to do is combine your family maximum benefit (FMB) with your wife's FMB when she became entitled on her own account in December 2022. Assuming that your child meets the requirements for DAC benefits on your wife's account, Social Security should have solicited an application for DAC benefits for your child on your wife's account in order to establish technical entitlement on her record. That would make your child simultaneously entitled to DAC on both your account and your wife's account, which is a requirement for combining FMBs.

Once the FMBs are combined it should free up more total benefits to be payable to your wife and child, although the exact amount would depend on your wife's FMB. In any case, combining the FMBs appears to be the missing puzzle piece. What it sounds like you need to do is contact Social Security to have your child apply for technical entitlement to DAC benefits on your wife's account effective December 2022. If you're the representative payee for your child then you can file the application on your child's behalf. Once that claim is processed, Social Security should then combine the FMBs and recompute the monthly amount payable to your wife and child.

Best, Jerry

Posted: 
Apr 26 2023 - 10:52am
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