Hi,

I am performing my ACH Audit and when reviewing my DNE's for timely return I found one where the Govertment payment was made on the same day as the beneficiary died. We have not returned the payment. Are we compliant?

I have been looking in the Green Book 2004, Ch 5 and see nothing relating to specifics such as this. Can anyone tell me where I can find that info?

Let me reword this. Do any of you return your reclaimations immediately when you get the first notice or do you wait for the paper request?

Once you are notified, aren't you required to return it? We go off the DNE report???? They are only eligible for Soc Sec in most cases, if they were around for the entire month and so if they pass away on 10/3 and are paid for October on 10/1, October's should go back.

Our person passed away on the 25th of the month with the payment coming in on the same day. Someone told me that if the person passes away after the 15th of the month the beneficiaries are allowed to keep the payment. I have not been able to substantiate that with anything I have found so far.

Also, as far as responding to DNE notifications in the Green Book 2004, Chapter 5, page 5-9 it states,

"When an RDFI receives actual or constructive knowledge of the death, it may decide to await a Notice of Reclamation before returning the already credited post-death payment(s). However, the RDFI must immediately return all subsequent (i.e. subsequent to receiving notice of death) post-death benefit payments to the Government Disbursing Office."

It sounds to me like you need to decide on what your policy will be regarding the current month.

I believe different benefit payments are handled differently. I know my parents were on basic social security/disability, my Dad passed away on the 31st (disability payments) and that month's payment had to be returned. My mom passed away on the 18th and that month had to be returned. So what I know is in part from personal experience and in part from work related experience.