BPAO Client Records


All clients served by the BPAO project who meet the project eligibility criteria should have a written record or file.   Clients who only receive information and referral services would have very little in the file, while individuals receiving intensive services such as benefits management would have a longer case record.  The basic components of a BPAO case record are listed below.  

BPAO case records are to be kept separate from all other agency records with access limited to BPAO staff only.  File cabinets must be kept locked at all time with access to the key limited to BPAO staff members.

1. Intake sheet with contact information.  This could be a printed copy of the BPAO Data System Beneficiary Form, or a different form used by the agency to collect this information.  

2. Case notes that describe services rendered, issues discussed and actions taken.  Notes should be made after every contact and should appear in chronological order.  Notes must be dated with service time indicated and signed with staff title listed.   Black or blue ink should be sued for all case notes with no information covered with marker or white out.  Mistakes should be struck thru with a single line.

3. Copies of any release of information forms used to access benefits information from SSA or other federal, state or local agencies.  Only the form SSA-3288 may be used to access information about a beneficiary from the Social Security Administration.   Other release of information forms used by the agency must specifically indicate what information is being sought, must be signed by the beneficiary and have an expiration date. 

4. Copies of Benefits Planning Queries (BPQYs), statements of benefits, or other correspondence that verifies public benefits received, current benefits status, payment amounts and work incentives used.  This is required for clients receiving intensive services.   A release of information should be on file for each item to verify that permission was provided to obtain it.     

5. Verification that the client has read and understands the BPAO project policies and procedures.  This would consist of a signature sheet signed by the client, or the legal guardian and the Benefits Specialist.  At a minimum, these policies should cover:

* Services to be provided and any limits to these services
* Client responsibilities with regard to BPAO services
* BPAO service eligibility criteria 
* Confidentiality policy
* Grievance/complaint procedure or appeals process including information on the PABSS program
* Any other client rights the agency wants to review
* Any disclaimers about benefits advisement 

6. Copies of any written Benefits Analyses, summaries of advisement provided or related correspondence.  This should include SSI calculation sheets and Title II disability benefit charts or time lines. 
 
7. Copies of any correspondence to or from other agencies regarding the client such as letters to Social Security or the state Medicaid department.   

8. Copies of any work incentives information such as PASS documentation, documentation on IRWEs, BWES, etc.  This may also include copies of pay stubs or any other correspondence or information related to the use of specific work incentives.  

BPAO case records would NOT contain diagnostic, medical or disability information unless there was a compelling need for such information related to the benefits counseling services rendered.  

Since BPAO case records may only be accessed by authorized BPAO staff, they should generally NOT contain forms or information related to other services the client has or is receiving from the provider agency.  A separate record should contain this information.