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National Council
on Independent Living
 
 
Not Just Responding To
Change, But Leading It!
 
   
 

Ticket to Work and Centers for Independent Living

 

2008 Ticket Partners Summit Highlights the New Ticket to Work

The Social Security Administration began its exciting campaign to unveil the NEW Ticket to Work Program by hosting a Ticket Partners Summit in Louisville, Kentucky on March 10-13.  CESSI, SSA’s Program Manager for Recruitment and Outreach, managed the Summit which brought together 450 partners, including public and private service providers [both Employment Networks (ENs) and potential ENs], State Vocational Rehabilitation agencies, Work Incentives Planning and Assistance Programs (WIPAs), State Protection and Advocacy Programs, federal agencies, and key SSA staff, as well as advocates and beneficiaries. The focus of the Summit was the proposed changes to the Ticket to Work regulations, but the sessions covered a wide range of related topics including the WIPA Program and Work Incentives Seminar initiatives, Federal and State partner models and examples of new opportunities for public and private-sector partnerships under the new Ticket Program. 

While Social Security representatives opened and closed the Summit, the plenary sessions and 36 different workshops brought together panels of individuals from all over the country representing diverse programs and interests.  The presenters spoke from their own perspectives and shared their knowledge on various hot topics.  In his opening remarks, Deputy Commissioner David A. Rust said, “The truth is … that expectations can only be met by putting in the hard work to achieve them.  And to achieve SSA’s agenda for the new Ticket to Work Program, we will need your co-operation and unity of purpose.  That is why the theme of this conference – Working Together for Success—is so appropriate.” 

 

J. Randolph Lewis, a key executive at Walgreens Company, gave the keynote address and spoke from his perspective as both an employer and a parent of a child with a disability.  He talked about the company’s distribution center in South Carolina where the idea of accommodating people with all types of disabilities was built into the original plans for the building.  Today, almost half of the employees at the center are people with disabilities, occupying the same positions and being paid the same wages as their non-disabled peers.  Quoting Sean Heaney from The Cure at Troy, Mr. Lewis said:

New Ticket to Work 2008 Ticket Partners Summit: Working Together for Success

 

“History tells us not to hope on this side of the grave, but then once in a lifetime, a longed for tidal wave of justice can rise up and hope and history rhyme.  So hope for a great sea change and believe that a further shore is reachable from here.”

The idea of making hope and history rhyme became a major theme of the Summit.

The Summit’s mix of sessions, presenters and facilitated discussions was aimed at strengthening linkages and creating partnerships among the people and programs that constitute the different partners of the Ticket to Work Program.  The breakout sessions covered a wide range of topics including “New Financial Opportunities for ENs,”  “25 Essential Tools for EN Success,” “Finding Start-up Funding for ENs,” “VR and ENs: The New Partnership,” “Outreach and Service to Veterans,” “WIPA Quality Service,” “Building Relationships with Youth,” “Supporting Beneficiaries with Career Building,” and “Work Incentives Analysis and Business Resources to Support Self-Employment.”  Two “Ask the Experts” sessions provided an opportunity for people to ask questions and seek clarification on things they had heard or learned about during the Summit. 

Networking and partnership development were taken to another level during the final ten breakout sessions where Summit participants were asked to meet with the other participants from their geographic regions.  These facilitated discussions identified the regional needs and resources to help the various Ticket partners thrive and support the efforts of beneficiaries with disabilities who want to work.    

In her final remarks, Sue Suter, SSA’s Associate Commissioner for Employment Support Programs, reminded everyone of the importance of partnerships (both old and new).  She said, “The closing of this Summit represents just the beginning of the work that needs to be done to launch the NEW Ticket to Work Program.”

Visit CESSI’s Summit web site at http://www.cessi.net/ticketpartnerssummit/ and click on materials to view power point presentations from the Summit, materials handed out, and background information and resource materials from this important meeting.

WhAM! Article: Ticket to Work Summit Energizes Advocates and Beneficiaries

In preparation for the implementation of the Ticket to Work and Work Incentives Improvement Act of 1999, final regulations are due to be released this month.  NCIL is working with the Social Security Administration (SSA) to “relaunch” the Ticket Program, which provides Social Security Disability Insurance (SSDI) and Supplemental Security Insurance (SSI) beneficiaries with an opportunity to enter or reenter the workforce.

March 10-13th, NCIL policy staff joined SSA officials and other partners working to implement the program at a Ticket Partners Summit in Louisville, KY to strategize about fully implementing the forthcoming final Ticket regulations. Although some individuals with disabilities have successfully left the Social Security disability programs for work by taking advantage of TTW, the Ticket program has been more limited than disability advocates had expected. At last week’s Summit, SSA met with representatives of state Vocational Rehabilitation, other rehabilitation service providers and employment networks, businesses, Work Incentives Planning and Assistance Programs, Protection and Advocacy Systems, beneficiaries, and NCIL.  The goal was to stimulate more interest and to share opportunities for improved cooperation. NCIL continues to help implement the program by encouraging Centers for Independent Living (CILs) and Statewide Independent Living Councils (SILCs) to consider becoming Employment Networks, which enter into contracts with SSA to assume responsibility for the coordination and delivery of appropriate employment, employment activities, and other support services under the Ticket to Work Program. Final regulations are expected to further improve the mechanics of the Ticket program.  Ticket to Work has created an “Employment Network Revenue Estimator” that CILs and SILC can use to calculate the advantages in becoming an Employment Network!

For more information, including the benefits of becoming an Employment Network, please visit: www.ssa.gov/work. NCIL Policy Analyst Deb Cotter can put you in touch with the appropriate Ticket to Work staff to discuss the application process, and address specific questions. Please feel free to contact Deb by phone at (202) 207- 0334, ext. 1008 or email, deb@ncil.org.

 

Testimony Before the Ticket to Work & Work Incentives Advisory Panel
October 31st, 2007

John A. Lancaster, Executive Director, National Council on Independent Living

Thank you for inviting me to speak on behalf of the National Council on Independent Living (NCIL) before this Advisory Panel to respond to your final Report to Congress. NCIL appreciates the work of the Panel members over the past several years.

NCIL is proud to have been one of the leading organizations helping to shape the Ticket to Work and Work Incentives Improvement Act of 1999. We remain committed to ensuring the full and proactive implementation of this landmark legislation in a manner that empowers individuals with disabilities to get the information they need and leverage available incentives so that they can realize their full potential and find desirable jobs consistent with their goals and abilities.

As the oldest cross-disability, national grassroots organization run by and for people with disabilities, NCIL has long worked to garner the supports and services that people with disabilities need to achieve community integration and economic self-sufficiency. In 2006, the NCIL Board of Directors adopted the proposal, Being American: the Way out of Poverty as our employment policy.  We continue to work with the World Institute on Disability in seeking consumer and stakeholder input on the NCIL-WID proposal.

Our membership includes centers for independent living, state independent living councils, people with disabilities and other disability rights organizations. As a membership organization, NCIL advances independent living and the rights of people with disabilities through consumer-driven advocacy.  NCIL envisions a world in which people with disabilities are valued equally and participate fully.

NCIL’s perspectives on transformation are post integrationist (Lipman) and not just post entitlement. In other words, we are not focused just on current Social Security disability program beneficiaries, but also on the broader pool of workers with disabilities both in and out of the workforce. While the devil is in the details, the report makes a solid attempt to integrate worker’s compensation and state disability systems, prerequisites for real cultural and systemic change.

Transformation and Social Security Administration (SSA) risk management has to include from the beginning Worker’s Compensation and state and private disability insurance systems. The Advisory Panel draft report could do more to sufficiently address these matters. Additionally, NCIL believes that the Social Security Administration, the Centers for Medicare and Medicaid Services, Congress, and the Bush Administration have lost their focus and their drive to implement the Ticket Act, policy work that many consider the first phase of transformational reform.   

The Advisory Panel’s report is constructive and thought provoking; it should serve the deep debate well. However, NCIL thinks there are serious omissions. There are omissions about how to pay for it, which we think should be based in large part with payroll-taxed social insurance methods, and omission about the evolving Ticket to Work program and how it could be fixed.  The Panel recommendation to extend state Medicaid Infrastructure Grants another five years should be extended to ten years to provide the stability and universality they need.

These programs are insurance programs with a dedicated payroll tax to fund the trust funds that make them work. Worker’s Compensation and Social Security Disability Insurance are the beginnings of the net/maze/web that end with “I Can’t Work programs” as we know them today, and the providers of these programs are stuck in that world. They are foreigners to the vision of people with disabilities working, and this is why we need them at the table, as do you all.  A transformational approach exclusively internal to SSA disability programs is late in the game, as I also know you know. Worker’s Compensation needs to be People’s Compensation and Employment Supports Insurance that is not limited to workplace injury.

NCIL also wants to see aspects of the Veterans’ Administration (VA) model of employment supports studied and used in transformation. We did not see reference to VA promising practices or VA benefits and employment supports integration that may prove helpful for all.

For more information on the NCIL-WID proposal, Being American, visit the NCIL Website at www.ncil.org.
Again, thank you for the opportunity to discuss ways to improve the employment outcomes for SSDI beneficiaries with disabilities. We look forward to continuing to work with Social Security Administration on this and other return-to-work and employment policy programs.

 

Barriers to Work for Individuals Receiving Social Security Disability Benefits Committee on Finance Hearing

June 21, 2007
The Honorable Max Baucus, The Honorable Chuck Grassley
Committee on Finance, U.S. Senate
219 Dirksen Senate Office Building
Washington, DC 20510-6200

Dear Senators Baucus, Grassley and Committee Members:

We present written testimony on behalf of the National Council on Independent Living. We thank you for holding this important Hearing. We outline our grave concerns about the delayed and uneven implementation of the Ticket to Work and Work Incentives Improvement Act of 1999 (the Ticket Act) and present new frameworks for solutions. The correlation between poverty and disability in the U.S. is unacceptable from both a moral and economic standpoint. The time has come to reassess employment and disability and poverty in the U.S. and better serve the needs of Americans with disabilities.

Ten years ago, after considerable input from key stakeholder groups, including NCIL, the National Council on Disability provided Congress with its seminal Report on Social Security and employment, entitled: “Removing Barriers to Work: Action Proposal for the 105th Congress and Beyond.” These recommendations, along with those from the National Academy on Social Insurance, NCIL, the Return to Work Group, and others, motivated hundreds of people nationwide to spend the next two years focused on health care, benefits and employment reform. They worked with the bipartisan Congress members who crafted the Ticket Act, the hopeful follow-up to the Americans with Disabilities Act promise with respect to health care, benefits and their connections to employment outcomes.

The National Council on Disability Report found that:

“Social Security programs can be transformed from a lifelong entitlement into an investment in employment potential for thousands of individuals.”

Senator Grassley and Senator Bunning, you in particular with other bipartisan leaders put forth great effort over two years to move the Ticket Act through the Congress. NCIL urges Committee members to reevaluate employment, disability, and poverty by supporting oversight hearings that question Ticket Act implementation procedures to date.

NCIL believes that Social Security, the Centers for Medicare and Medicaid Services, the Congress, and the Bush Administration have lost their focus and their drive to implement the Ticket Act, policy work that many consider the first phase of transformational reform.

NCIL is the oldest cross-disability, national grassroots organization run by and for people with disabilities. Our membership includes centers for independent living, state independent living councils, people with disabilities and other disability rights organizations. As a membership organization, NCIL advances independent living and the rights of people with disabilities through consumer-driven advocacy. NCIL envisions a world in which people with disabilities are valued equally and participate fully.

NCIL is proud to have been one of the leading organizations helping to shape the Ticket Act of 1999. We remain committed to ensuring the full and proactive implementation of this landmark legislation in a manner that empowers individuals with disabilities to get the information they need and leverage available incentives so that they can realize their full potential and find desirable jobs consistent with their goals. This commitment is reflected in recent discussions at NCIL’s Board meeting in Boston 2006 that drilled down and focused on the current lack of predictability in incentives and employment supports for persons with disabilities, and new policy proposals and frameworks to remedy these untenable situations. NCIL’s commitment is reflected by the more than 55 centers for independent living (CIL) that initially served as Social Security Benefits Planning, Advocacy and Outreach (BPAO) grantees, in the historic first round of these federal grants to explain federal rules so people can use them without penalty. Currently 37 CILs serve as Work Incentives Planning and Assistance (WIPA) Project grantees, the successor program to BPAO. The recent lack of predictability in incentives and employment supports for job seekers with disabilities and the uneven implementation of the newer WIPA grants have dissuaded CILs and other interested parties from participating.

Baseline Principle and Goal
Earnings Replacement and Employment Support Insurance Enhance Employment Outcomes

NCIL believes strongly that receipt of cash benefits and health coverage when work is not an option are not competing priorities with the employment supports needed for beneficiaries and people with disabilities when we are ready to work, at any point in our lives. These are equally important supports that must not be pitted against each other, as we hear often from some Social Security senior management, and some advocates, largely due to stated, chronic funding constraints from Congress.


NCIL calls for Employment Support Insurance along with Earnings Replacement Insurance. These are new frameworks to improve the performance of the current Social Security Disability Insurance (SSDI) and Supplemental Security Income (SSI) programs and their connections to employment supports and outcomes. A Summary of NCIL’s employment framework is available at www.ncil.org under the Employment and Social Security section. The NCIL framework runs parallel to and in some ways complements:

  1. Similar national proposals being discussed under the commonly used term “two-plan model,” including a report last fall on employment from the Social Security Advisory Board (www.ssab.gov);
  2. Informal reports from the Social Security Beneficiary Summit in February of this year that describe a recommendation from Social Security beneficiaries for a similar Work Supports Program. We look forward to reading the Beneficiary Summit Report to be public this coming July; and,
  3. Social Security’s Ticket to Work and Work Incentives Advisory Panel current goal to develop a national employment investment strategy to transform approaches to assets, income, health care, and supports for people with disabilities.

It is right, proper, legal and necessary that the Ticket to Work program not rob Social Security Trust Funds of resources mandated by Congress to pay benefits when people cannot work. Congress frontloaded the funding for Welfare to Work reform legislation in 1996. It is long past due that Congress fund employment services, health coverage and personal assistance services in ways that serve as the employment supports they are for so many thousands of American beneficiaries with a disability.

Your hearing is timely, given the increasing number of SSI recipients, and the lower rate of SSI recipients with earnings. In 2000 there were 5.4 million SSI recipients; 360,427 of them had earnings from paid work. In 2006, there were over 600,000 added new SSI recipients; 349,420 of them had earnings from work.   More SSI recipients and less of them with earnings eight years after enactment of the Ticket Act. We do not have a lot of time left to get this right. Current demographics and the aging of the workforce require your immediate attention and leadership on the issues of this Hearing. Getting this right will take the Congress and all of us working with you.

NCIL calls on Congress, as we did in a letter last fall to the U.S. House of Representatives Committee on Ways and Means, Subcommittee on Social Security, to mobilize a renewed focus and initiative on employment in the face of what is now an arrested Social Security Ticket to Work program.

NCIL presents four key recommendations for your Committee’s review:

Recommendation One: Immediate Suspension of All Social Security Funded Evaluations of the Ticket to Work Program until Full Program Implementation

NCIL recommends that all formal evaluation proceedings prescribed and focused on the Ticket to Work Program, funded and commissioned by Social Security, be suspended immediately, and until such time as a national Ticket to Work Program is implemented and operationally in place, with diverse choice in providers in 50 states and the territories. Congress should exercise its oversight authority with the Bush Administration and the Social Security Administration to suspend these wasteful exercises using millions of tax payer dollars to evaluate a program that is not up and running as prescribed in the law.

Since early 2004 the Commissioner of Social Security, the Committee on Ways and Means of the House of Representatives and the Committee on Finance of the Senate have received ample reports and letters that the Ticket to Work Program is in crisis, is not working and is not attracting Employment Networks to the program in enough numbers and diversity to effectively evaluate the program.

The 1999 Ticket Act authorizes an evaluation of the Ticket to Work Program as it is implemented nationally. The legislative text clearly intends the evaluation for a program being used, and populated by enough service providers to warrant the detailed methodology criteria in the Ticket Act.   It is cruel charade to pretend there is enough of a Ticket to Work Program to warrant the millions of dollars being spent evaluating it. It is not the case and everyone knows it. Your action on this one recommendation will signal to a wide community that a major national problem persists and that you plan to address it.

Recommendation Two: Funding and Statutory Reform for the Ticket Program and Employment Support Services

Many would agree that Congress did not intend Ticket Act implementation to become just an internal Social Security project. NCIL recommends that the Committee on Finance exercise its oversight responsibilities, convene added hearings, and initiate legislative amendments to Public Law 106-170 (the Ticket Act) to meet following minimum objectives:

  1. Appropriate immediate, upfront funding to 1) re-launch the Ticket to Work program as a social insurance benefit in Social Security, or other appropriate social insurance financed venue; 2) fund related marketing needs for the program and other work incentives in and outside of Social Security; and, 3) increase and diversify the funding and the information services menu for critically needed community-based benefits planning, outreach and training services;
  1. To support, to succeed at and to access funding sources for #1, require in law, not just encourage, that the Centers for Medicare and Medicaid Services, Social Security, the Department of Labor and the Department of Education, along with private health care and employment partners, coordinate programming, services and interactions to serve Americans as they might request employment support services related to the findings, the provisions and the outcomes sought in the Ticket Act.

Successful areas of Ticket Act implementation, such as supporting the growing field of community-based benefits planners, have been under funded since the beginning in 2000, and continue to be under funded. The Ticket Act made few if any benefit or health care rules easier to understand. Indeed the opposite has been the outcome, as there has been little to no substantive integration (that we are aware of) of Medicaid Infrastructure Grant, Medicaid buy-in and federal rule making initiatives related to benefit program interaction and employment outcomes. New and ever changing federal regulations related to the Ticket Act interact with a hodgepodge of different state rules on health coverage, Section 8, and vocational rehabilitation and other employment related rules (Goodman & Livermore, 2004). Social Security funded community-based benefits planner capacities to keep up with these complex rules has been fragile and strained at best since 2000, and weakened with delays in grants and training grants for benefits planners for the past 15 months. Community-based partner ties with Social Security have suffered across the country.

Recommendation Three: Synchronize all SSI and SSDI Work Rules and Procedures into One Set of Rules

NCIL recommends that Congress require Social Security to synchronize all of its SSI and SSDI work rules into one set of rules that can allow options (a NCIL position on these matters from the 1990s.) Improve SSI and SSDI work rules mindful of their important connections to accessing Medicaid buy-ins in the states and to employment services.

SSI recipients who work and remain disabled become dual eligible, concurrent beneficiaries, potentially eligible for SSDI and Medicare. SSI work rules and the separate SSDI work rules routinely confound those with a Ph.D., and can encourage some to suppress earnings or avoid employment advancement opportunity rather than risk seamless access to their health coverage. Available data across all state Medicaid buy-in enrollment numbers show that the majority enrolled are SSDI beneficiaries or concurrent (dual) eligible beneficiaries on SSI and SSDI. Another cruel Ticket Act implementation reality since 1999 is the much increased availability of Medicaid buy-ins for those still confronted with and affected by the SSDI “cash cliff” when they gradually increase their earnings from lower paid employment categories.

Synchronization: Methodology and Objectives

  1. Raise the earned income disregard in SSI to the indexed Social Security Substantial Gainful Activity level (or SGA), $900 and $1,500 for the blind in 2007, to make work pay for many thousands of SSI very low wage earners, and to  eliminate their fear and rampant confusion about SSI work rules amongst their service providers and natural supports;

  2. Raise the Trial Work Month earnings test dollar amount to SGA (with indexing) for those using current SSDI work rules;

  3. Introduce a 2 for 1 ($1 dollar reduction in cash benefits for every $2 in earnings) in the SSDI program for earnings above SGA. Implement regionally or state by state if finances and operational efficiencies warrant. Allow SSDI beneficiaries the choice of using current SSDI work rules, or the new benefit offset fully synchronized with SSI work rules as improved here in 1. and 2.

  4. Require Social Security to craft one set of rules regarding when earnings were earned and when they were paid for use in both programs; require Social Security to implement and market one user friendly wage reporting procedure for both programs; promote, market and expand use of the Social Security Benefits Planning Query (BPQY) information sheet, available now to beneficiaries regarding their current benefits and prior use of work incentives.

Recommendation Four: Commission a Congressional Panel of Social Insurance and Employment Experts

NCIL urges the Committee to lead long-term transformational reform by commissioning a bipartisan experts panel to assist Congress with shaping solutions to decouple the two conflicting goals of the existing Social Security disability programs.

“National public policy on employment and benefits remains stuck in a morass of confusing program rules and conflicting advocacy positions.  Both the rule makers and the advocates are struggling with how to support employment while protecting health and income benefits for those who rely on them most.  To sum up: “There is a terrible tension between eligibility to get benefits versus getting employment help.” “

Within NCIL’s current policy framework on these matters, providing supports to help people prepare for, find and maintain a job would become a separate program of equal stature from providing income when people are physically or mentally unable to work.  An Employment Support Insurance (ESI) program would provide health coverage through a new model of Medicare, benefits planning for those looking for work, and referrals to Ticket to Work program services, vocational rehabilitation, One-Stop, and other employment services. Improved Social Security ‘work incentive’ rules would be administered in the ESI program. 

This Employment Support Insurance (ESI) program would operate under a social insurance model similar to the one that SSDI uses, with automatic FICA payroll deductions serving as premiums. ESI would provide better transitions between looking for work, employment, and having to go on SSI or SSDI. For those who are unable to work, the current SSDI program would maintain its successful earnings replacement components under the auspices of an Earnings Replacement Insurance (ERI) program. Current SSDI ‘cash cliff’ work rules would remain in the new ERI program for those whose transition back to full time work requires modest or little public support.

Closing Comment: We think it may be too convenient for some in government, and we know it is tragic for us on the outside to learn that the Office of Management and Budget and the Social Security Administration cannot come together in 2007 to resolve funding issues for crisis level problems they have been informed on since before 2004. In a word, the arrested Ticket to Work Program today is about failure, a lost commitment to Americans with disabilities.

Senator Bob Dole said, and President Clinton agreed with him in the late 1990s, the Ticket Act is the “right thing to do.” NCIL has learned a great deal since the late 1990s. These recommendations come to you after two years of NCIL discussion; we take these issues and our recommendations to you very seriously. Were the Committee on Finance to begin the action steps needed to implement them without another month of unconscionable delay, we are highly confidant that the talented and expert stakeholders focused on employment, health care and full equality throughout the disability community will rally to your leadership. Many of us can provide your Committee and Congress the technical assistance to get employment back on track in the U.S. for beneficiaries of Social Security disability programs and for other Americans with a disability at earlier risk of losing their attachments to the workforce.

This is a painful letter for NCIL members. NCIL members from 1996 to 1999 devoted thousands upon thousands of pro bono hours to the hopes and the promise Congress first extended to us with the work incentives initiative that became the Ticket Act. We come back to you now on these matters with benefit of fresh, new thinking. We have a framework for you to consider and move forward with.

We implore you to listen and seize the moment. NCIL is ready to provide any details requested on matters in this testimony. NCIL members nationwide are ready to work with you to refocus Congress on the employment potentials of Americans with disabilities.

Thank you for your time and review of our recommendations. We look forward to working with you and your colleagues to enhance the employment opportunities and outcomes for American with disabilities and Social Security disability beneficiaries. Please do not hesitate to contact Deb Cotter, NCIL policy staff, with any questions.

Respectfully submitted:

John Lancaster                                              Kelly Buckland
Executive Director                                          President

 


Endnotes


A Disability System for the 21st Century, Social Security Advisory Board, 2006

SSI Disabled Recipients Who Work, 2006, Social Security Administration Office of Policy, Office of Research, Evaluation and Statistics, April 2007

Advice Report to Congress and The Commissioner of the Social Security Administration, The Crisis In En Participation—A Blueprint For Action, Ticket to Work and Work Incentives Advisory Panel, February 2004

Please refer to: Public Law 106-170: SEC. 101. [42 U.S.C. 1320b-19] ESTABLISHMENT OF THE TICKET TO WORK AND SELF-SUFFICIENCY PROGRAM. (d) Graduated Implementation of Program. (1) In general. (2) Requirements. (3) Full implementation. (4) Ongoing evaluation of program.— (A) In general. (B) Consultation. (C) Methodology.— (D) Periodic evaluation reports.

Appropriated funding levels for Medicaid Infrastructure Grants to the states in the Ticket Act speak clearly to Congressional intent. Integration of services and supports funded by MIG grants with Social Security efforts to implement the Ticket Act have been accidental, ad hoc, uneven and unevenly measured, if occurring at all. MIG grants are important supports to states, should continue and be extended with better integration with federal initiatives.

“Congress should develop statutory language that clearly articulates its original intent that the Ticket Program’s outcome and milestone payments should provide additional resources to assist beneficiaries in attaining and retaining employment.” Advice Report to Congress and The Commissioner of the Social Security Administration, The Crisis In EN Participation—A Blueprint For Action, Ticket to Work and Work Incentives Advisory Panel, February 2004

Facilitate Beneficiary Choice – “Congress should authorize and direct SSA, the Rehabilitation Services Administration (RSA), the Centers for Medicare and Medicaid Services (CMS), the Department of Housing and Urban Development (HUD), and the Department of Labor Employment and Training Administration (DOLETA) to develop and implement an integrated benefits planning and assistance program that coordinates resources and oversight across several agencies that enables beneficiaries to access benefit planning services within multiple federal systems.” The Social Security Administration's Efforts to Promote Employment for People with Disabilities, New Solutions for Old Problems, National Council on Disability, November 2005

For a full review of these complex program interactions, please see: The Effectiveness of Medicaid Buy-in Programs in Promoting the Employment of People with Disabilities, Goodman and Livermore, 2004, Briefing Paper Prepared for the Ticket to Work and Work Incentives Advisory Panel, Cornell University Institute for Policy Research, Washington, DC

An SSI recipient under the age of 24 can work part time a short 1.5 years with $900 in gross earnings per quarter of the year and become eligible for SSDI from that short a period of paid work, and in today’s world, may not know about this new eligibility until after it happens.

In the month of December 2006, 260,000 SSI recipients worked, reported earnings and received a lower partial SSI benefit check because of the earnings. These people worked at very low paying jobs with a significant disability. How many more would work if the work rules and the reporting rules were clear and easy to use for these workers? Data from SSI Disabled Recipients Who Work, 2006, Social Security Administration Office of Policy, Office of Research, Evaluation and Statistics, April 2007

The policy objective is one coherent set of work rules and reporting rules, with options as needed to suit variant employment objectives. The original NCIL objective from the 1990s was synchronization of two separate sets of arcane rules, not just a “2 for 1” sliding scale earnings plan for the SSDI program. Congress could look closely at current Social Security Ticket Act demonstration projects to assess if their directions suit such a policy objective.

Note well: the Committee on Finance should include in their oversight a review of the May 2007 recommendations found in the Social Security Inspector General Organizational Review of the Office of Disability and Income Security Program (A-12-07-27162). Careful analysis and steps should be taken to insure that the reports’ recommended changes support employment as the core Social Security social insurance goal that it has become, and support reduction and then elimination of its orphaned, bankrupt status when it becomes pitted against Office of Operations responsibilities in other social insurance areas.

William P. Molmen, General Counsel, Integrated Benefits Institute, San Francisco; quotes from Being American: the Way Out of Poverty, Poverty and Disability in the U.S., SUMMARY, Joshua Berezin, World Institute on Disability, an official NCIL Board policy position statement, available at www.ncil.org and www.wid.org, 2006

 
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