SSI: retirement funds never count as resources, but POMS SI 01120.210 counts an owner's accessible lump sum #10446

PE-US counts only bank, stock and bond assets as SSI resources, and it has no input for a retirement-account balance. So a retirement fund never counts toward the SSI resource limit. SSA's POMS SI 01120.210 counts an eligible person's retirement fund as a resource when they can withdraw a lump sum. It makes exceptions for funds that pay nothing unless the owner stops working and for owners eligible for periodic payments, and it leaves funds owned by an ineligible spouse or parent out of deeming.

This came up while building the SSI interface in PolicyEngine/microcosm-dynamics#573. The files below are the same on main at fe615712 (2026-10-24) and in the 2.2.1 release.

Where

• parameters/gov/ssa/ssi/eligibility/resources/countable.yaml lists bank_account_assets, stock_assets and bond_assets. Its description says it excludes "home, one vehicle, household goods, burial plots, and retirement accounts."
• variables/gov/ssa/ssi/eligibility/resources/ssi_countable_resources.py adds that list, and its documentation says retirement accounts are excluded "per SSI rules".
• variables/household/assets/ has no retirement-account variable, so no input can reach the resource test.

What POMS says

POMS SI 01120.210, Retirement Funds, effective 12/04/2012 to present:

A.3. The value of a retirement fund is the amount of money that an individual can currently withdraw from the fund. If there is a penalty for early withdrawal, the fund's value is the amount available to an individual after penalty deduction. However, any taxes due are not deductible in determining the fund's value.

B. A retirement fund owned by an eligible individual is a resource if he/she has the option of withdrawing a lump sum even though he/she is not eligible for periodic payments. However, if the individual is eligible for periodic payments, the fund may not be a countable resource. See E.1. below if an individual is eligible for periodic payments.

A previously unavailable retirement fund is not income to its recipient when the fund becomes available. The fund is subject to resources counting rules in the month following the month in which it first becomes available.

C.1. A retirement fund is not a resource if an individual must terminate employment in order to obtain any payment.

C.2. A resources determination for the month following that in which a retirement fund becomes available for withdrawal must include the fund's value. A delay in payment for reasons beyond the individual's control (e.g., an organization's processing time) does not mean that the fund is not a resource since the individual is legally able to obtain the money. It is a nonliquid resource.

C.3. If an individual receives a denial on a claim for periodic retirement payments but can withdraw the funds in a lump sum,include the fund's lump sum value in the resources determination for the month following that in which the individual receives the denial notice.

E.1. If an individual is eligible for periodic retirement benefits, he/she must apply for those benefits to be eligible for SSI. If he/she has a choice between periodic benefits and a lump sum, he/she must choose the periodic benefits.

E.4. If an ineligible spouse, parent, or spouse of parent owns a retirement fund,we exclude it from the deeming process (SI 01330.120 and 01330.220). See SI 00830.500 regarding the treatment of interest income.

D.1 says to determine periodic-payment eligibility under SI 00510.001 ff. first, and D.2 that a fund is a resource in the amount currently available if any of it can be withdrawn.

What the model needs

Each account stays with its owner. Moving a household total onto one person gives wrong answers; PolicyEngine/microcosm#1215 shows what goes wrong when liquid assets sit on the wrong person. Per account:

• the amount the owner can withdraw now, the early-withdrawal penalty and the taxes due (A.3);
• whether any payment requires the owner to stop working (C.1);
• whether the owner is eligible for periodic payments, and whether a lump sum is offered instead (B, E.1);
• the month the fund first became available, and the month of any periodic-claim denial notice (B, C.2, C.3).

The rules:

• An eligible owner's accessible lump sum, with no periodic-payment eligibility, is a resource worth the withdrawable amount less the penalty. Taxes are not deducted (A.3, B, D.2).
• It counts from the month after it first becomes available, and becoming available is not income (B). A processing delay doesn't defer it (C.2).
• A fund that pays nothing unless the owner stops working is not a resource (C.1).
• After a periodic-claim denial, an accessible lump sum counts from the month after the notice (C.3).
• A fund owned by an ineligible spouse, parent or parent's spouse is left out of resource deeming (E.4). An applicant's own fund gets no such exclusion.
• When the owner is eligible for periodic payments, B says only that the fund "may not be" countable, and E.1 requires applying for and choosing the periodic benefits. That branch depends on SI 00510.001 ff., so it shouldn't default to a zero resource before those rules are modelled.

Test cases

Hand-computed from the POMS text above; none comes from an engine.

Properties: a fund's resource value never falls when the withdrawable amount rises with the penalty fixed; taxes due never change it; a deemor's retirement fund adds nothing to deemed resources.

Related

• Count retirement distributions as unearned income for SSI #4125 (closed) counts retirement distributions as unearned income. This issue is about the fund itself as a resource.
• SSI: deemed benefit is capped at the individual rate instead of the no-deeming amount, and couples are identified by tax roles #10138 covers the spousal-deeming benefit cap, a separate gap.
• The RuleSpec mirror is Encode SSI retirement-fund resources under POMS SI 01120.210 (PE-US #10446 parity) TheAxiomFoundation/rulespec-us#1910; resource deeming there is Encode SSI spouse and parent resource deeming under 20 CFR 416.1202 and the 416.1205 resource limits (PE-US #3557 parity) TheAxiomFoundation/rulespec-us#1626.

Until this is fixed, the microcosm-dynamics SSI interface refuses any case with a retirement-account balance or periodic-payment eligibility as a rules-engine gap.