October 31 – Expedited Reinstatement and the Initial Reinstatement Period
Question: A Title II beneficiary recently qualified for a new period of disability through Expedited Reinstatement. After receiving 7 payments during the Initial Reinstatement Period, he returned to work at the SGA level. How will this work affect his cash benefit status and Medicare?
Answer: The beneficiary is still in his Initial Reinstatement Period (IRP). This is a period of 24 qualifying months, or months during which the individual receives a payment. IRP months are not necessarily consecutive.
A qualifying month is one in which the benefits are paid. Benefits are not paid for any month the beneficiary performs SGA during the IRP. In making the SGA decision during this time, Social Security can use IRWEs and Subsidy/Special Condition, but no Averaging or Unsuccessful Work Attempt.
The IRP is completed when the individual has received a total of 24 months of paid benefits. There is no time limit for completion of the IRP, so if the beneficiary continues to perform SGA he will remain in the IRP until he reaches full retirement age and transitions to retirement benefit status. Medicare coverage continues during the IRP even when the individual does not receive a cash benefit due to SGA. If the individual is in the IRP when they reach age 65, it converts to Aged Medicare.
Example: Ben qualified for reinstatement of SSDI through EXR effective August 2015. In March 2016 he returns to work and Social Security determines that he is engaging in SGA. Prior to returning to work he had 7 IRP qualifying months. Effective March 2016 his SSDI is suspended because he is performing SGA. If his countable earnings fall below SGA, he will still have 17 months remaining in the IRP. Ben is 61 years old. He continues to perform SGA until he turns 66. At age 65 Medicare entitlement changes to Medicare based on age. At age 66, his SSDI converts to retirement benefits. His IRP never ended.
Would you like to find out more about WIPA and your benefits? Contact your statewide WIPA Program-Project 20/20 if you have questions like our Daily Tips or want to learn more about working while receiving social security disability benefits. Call our North Augusta office at 803-279-9611 or the Ticket to Work Helpline at 1-866-968-7842. You can also complete a Contact Us or Self-referral Form.