The POMS - Program
Operations Manual System
- are Social Security’s regulations by which the agency operates its
many programs. Before they were called the Program Operations Manual
System (POMS),SSA's internal operating instructions were called the
Claims Manual. The first version of the Claims manual appeared in
January 1937
These are the POMS on PASS. The PASS provision ispart of the
original legislation that created the SSI program,which was signed
into law by President Nixon in 1972.
Statutes are usually broad and brief. The regulations are then
written by the programs and entities affected by the statute, and it
is the regulations that spell out exactly how the program will
implement the statute. Regulations are lengthy and detailed, and
the devil is in the details.
There have been at
least 4 versions of the POMS
on PASS, all technically consistent with the statute. The original
regulations, in force for 20+ years, set limits on the length of a
PASS. These limits were challenged in court (Heckler v. Panzerino),
resulting in an act of Congress that eliminated the time limits in
1995. Since its inception, PASS’s were reviewed by local SSA
offices. In early 1997, in a knee-jerk reaction to a negative GAO
(General Accountability Office) report to Congress about PASS, new
Draconian POMS were hastily (in 2 months) written, forbidding using
instalment loans to purchase vehicles, and narrowly defining
business start-up costs. All PASS’s went to a central group of PASS
reviewers in Baltimore fr review. Advocates protested, resulting in
a policy statement by then Asst. Commissioner Colvin rescinding
these strict regulations, and review of PASS’s was established in
the ten federal regions. Due to the problems with the earlier
versions of the POMS on PASS, SSA conducted a long, open process to
write them, and published the current POMS in Sept. 2001.
The POMS are not
intended to inform beneficiaries.
They are directions to Social Security personnel telling them what
to do in implementing the PASS provision. Whether the POMS are cut
in stone or “just guidelines” can depend on the employee
interpreting them - and also on whether the POMS supports your side
of an argument or theirs. But usually, if you can back up what you
want done with your PASS by referencing the POMS, you will prevail.
It is useful to be
familiar with the POMS.
Local offices are often poorly informed about PASS, and insist that
their incorrect ionformation is correct, for example, stating that a
PASS can’t be used to buy a car, or that an SSDI check can’t go into
a PASS. But they can’t argue if you show them the citation in the
POMS that backs you up.
It is the POMS,
more than common sense or
human decency, that makes the argument with SSA.