**Ticket to Work**

**and Work Incentives Advisory Panel**

**UPDATE, SIMPLIFY, AND EDUCATE:**

**A National Call to**

**Optimize Incentives to Work**

**Table of Contents**

[EXECUTIVE SUMMARY 1](#executive-summary)

[Introduction\.... 7](#introduction)

[Historical Context \-- Background
11](#historical-context----background)

[SSI Efforts to Support Work 15](#ssi-efforts-to-support-work)

[Overview of the SSI Program and Existing Work Incentives
15](#overview-of-the-ssi-program-and-existing-work-incentives)

[Current Beneficiary Efforts to Work and Use SSI Work Incentives
18](#current-beneficiary-efforts-to-work-and-use-ssi-work-incentives)

[SSDI Efforts to Support Work 23](#ssdi-efforts-to-support-work)

[Overview of the SSDI Program and Existing Work Incentives
23](#overview-of-the-ssdi-program-and-existing-work-incentives)

[Current Beneficiary Efforts to Work and Use SSDI Work Incentives
25](#current-beneficiary-efforts-to-work-and-use-ssdi-work-incentives)

[The Integration of Work Incentives: Complexity of Rules
27](#the-integration-of-work-incentives-complexity-of-rules)

[Concurrent Beneficiary Efforts to Work and Use SSI and SSDI Work
Incentives Simultaneously
29](#concurrent-beneficiary-efforts-to-work-and-use-ssi-and-ssdi-work-incentives-simultaneously)

[Discussion of Issues and Recommendations
31](#discussion-of-issues-and-recommendations)

[UPDATE Existing Work Incentives 31](#update-existing-work-incentives)

[Update IRWE 31](#update-irwe)

[Update Income Exclusions 33](#update-income-exclusions)

[Update PASS and the Ticket to Work Program
34](#update-pass-and-the-ticket-to-work-program)

[Update the Traditional Cost Reimbursement Program
34](#update-the-traditional-cost-reimbursement-program)

[SIMPLIFY Existing Work Incentives
35](#simplify-existing-work-incentives)

[Align Existing Work Incentives 35](#align-existing-work-incentives)

[Address Post-Entitlement Issues 37](#address-post-entitlement-issues)

[Simplify Wage Reporting 39](#simplify-wage-reporting)

[EDUCATE Beneficiaries and their Supporters Regarding Work and Use of
Work Incentives
40](#educate-beneficiaries-and-their-supporters-regarding-work-and-use-of-work-incentives)

[Expand Current Work Incentives Marketing and Outreach
40](#expand-current-work-incentives-marketing-and-outreach)

[Work Incentives Planning and Assistance
42](#work-incentives-planning-and-assistance)

[Protection and Advocacy for Beneficiaries of Social Security
44](#protection-and-advocacy-for-beneficiaries-of-social-security)

[SSA Internal Corps of Work Incentive Specialists
45](#ssa-internal-corps-of-work-incentive-specialists)

[SSA's Cadre of PASS Specialists 46](#ssas-cadre-of-pass-specialists)

[Improve Management by Data Practices
49](#improve-management-by-data-practices)

[Improve Beneficiary Communication
50](#improve-beneficiary-communication)

[Conclusion...... 52](#conclusion)

[References...... 56](#references)

[Appendix A \-- The Panel 60](#appendix-a----the-panel)

[Appendix B \-- Detailed Data on Specified Work Incentives, by State and
Selected Characteristics
61](#appendix-b----detailed-data-on-specified-work-incentives-by-state-and-selected-characteristics)

[Appendix C \-- Acknowledgements 61](#appendix-c----acknowledgements)

# EXECUTIVE SUMMARY

Section 101(f) of Public Law 106--170, the Ticket to Work and Work
Incentives Improvement Act of 1999 establishes the Ticket to Work and
Work Incentives Advisory Panel (the Panel) within the Social Security
Administration (SSA). The purpose of the Panel is to provide insight,
advice, and recommendations to the President, Congress, and the
Commissioner of the Social Security Administration that will lead to
increased employment and greater economic self-sufficiency for people
with disabilities.

The Panel's strategic plan supports the implementation of the Ticket to
Work and Work Incentives Improvement Act (the Ticket Act) and the
continuous improvement of SSA's return-to-work efforts.[^1] This report
is the result of a review of utilization of existing work incentives
associated with the Supplemental Security Income (SSI) and Social
Security Disability Insurance (SSDI) programs administered by SSA, as
well as related Medicaid and Medicare provisions, and their interaction
with other federal benefit programs. It provides background information
and recommendations. The report is based on a literature review and
careful consideration of the beneficiary summit recommendations and past
recommendations made by other federal entities and advisory groups
focused on the increased utilization and improvement of existing work
incentive programs. The short-term, incremental recommendations in this
report form the foundation for the transformational recommendations that
will be included in the Panel's Final Report.

The Panel strongly believes that there is no "one size fits all"
solution to the under-performance and under-utilization of existing work
incentives. We were guided in the development of this report by four
historic and current realities related to work incentive utilization.
These are:

-   SSDI and SSI are programs of last resort. They are an essential part
    of the nation\'s safety net, providing both cash and health
    insurance benefits.  The strict and frugal legislative design of the
    programs does not provide strong induced entry incentives for people
    with significant disabilities to apply for benefits instead of
    working. 

-   Beneficiaries want to work. Beneficiaries may be able to work on a
    full time, part time, or intermittent basis, under certain
    circumstances and depending on a myriad of complex and interrelated
    factors.

-   Work incentives are complicated, poorly understood and
    underutilized. However, they can serve as a safety net to transition
    from benefits to work and self-sufficiency.   

-   Work incentives are labor-intensive to administer. SSA\'s
    post-entitlement workload, which includes processing earnings
    reports and handling other work related issues, has been a low
    priority for many years due to increased initial claims, limited
    administrative resources and new legislative mandates. 

Keeping these realities in mind, there is a series of actions that could
be taken to create the conditions and policy environment that would
better support work beyond the outcomes currently being achieved by some
beneficiaries with disabilities. This series of actions under
consideration fall into three primary categories:

1\. **UPDATING** existing work incentives to make them more applicable
to the realities and employment support needs of beneficiaries in 2007
and beyond.

***RECOMMENDATIONS***

**Recommendation 1:** SSA should change the order in which impairment
related work expenses (IRWE) are deducted when calculating the SSI cash
payment to allow for up to a 100 percent cost recovery.

**Recommendation 2:** SSA should allow health insurance premiums to be
used as IRWE, when the beneficiary can document that the coverage is
disability-related and supports work.

**Recommendation 3:** SSA should eliminate the condition that family
members must suffer financial loss for their compensation by the
beneficiary to count as IRWE if they provide attendant care and/or
transportation to/from work to a person with a disability.

**Recommendation 4:** Congress should increase and index the key income
exclusion amounts and the resource limits under the SSI program.

**Recommendation 5:** SSA should approve proposed rule changes to the
Ticket to Work Program to enable Employment Networks (ENs) to receive
ticket outcome-only payments while a beneficiary is receiving a SSI cash
payment resulting from an active Plan for Achieving Self-Support (PASS).

**Recommendation 6:** SSA should allow state vocational rehabilitation
agencies to receive traditional cost reimbursement if and when an
individual is receiving a SSI cash payment resulting from an active PASS
or claim of Blind Work Expenses (BWE).

2\. **SIMPLIFYING** the maze of work incentives programs that exist not
only within SSA but other federal benefit programs so that those
programs mutually support a common work agenda and make work pay while
at the same time reducing the risk of overpayments for beneficiaries and
other unintended adverse program interactions.

***RECOMMENDATIONS***

**Recommendation 7:** SSA should reduce the complexity and improve the
consistency of work incentives across the SSI and SSDI programs and
other federal entitlements so that they universally support work.

**Recommendation 8:** SSA should establish mechanisms to monitor
post-entitlement workloads, develop performance standards (similar to
those established for initial claims in terms of processing time and
decisional accuracy), and Congress should allocate sufficient resources
to address post-entitlement workloads.

**Recommendation 9:** SSA should establish a cross-component internal
SSA Task Force on post-entitlement workload issues to identify resources
needed to perform critical program integrity activities that address
post-entitlement workloads such as processing work reports and
preventing and detecting overpayments. Publish these findings annually.

**Recommendation 10:** SSA should continue to expand systems for
reporting wages electronically, ensuring that concurrent beneficiaries
have a single point of earnings reporting and that timely receipts are
sent to all beneficiaries.

3\. **EDUCATING** and equipping the array of stakeholders that intersect
the return-to-work process is multi-pronged, focused on ensuring that
beneficiaries interested in going to work have access to customized,
responsive, timely, relevant and accurate information and services to
support their efforts.

***RECOMMENDATIONS***

**Recommendation 11:** SSA and Congress should strengthen both the Work
Incentives Planning and Assistance (WIPA) and Protection and Advocacy
for Beneficiaries of Social Security (PABSS) networks by establishing
performance standards, adjusting funding levels and resources to levels
necessary to achieve the desired results, and invest in ongoing training
and technical assistance that improves the accuracy of information and
quality of services provided with particular attention to underserved
populations and valued employment outcomes.

**Recommendation 12:** SSA should identify clear, objective performance
standards and indicators to evaluate the activities and impact of Area
Work Incentives Coordinators (AWICs) and Work Incentive Liaisons (WILs),
and collect, analyze, document, and publish evidence annually (by SSA
region and system-wide) of customer satisfaction, improved employment
outcomes, and advanced self-sufficiency.

**Recommendation 13:** SSA should collect workload information on the
number of PASS applications submitted and approved, including the
processing (wait) time by state, and publish this information annually
in SSA's *SSI Disabled Recipients Who Work* report. Provide high quality
training and support, and fiscal resources for the effective
administration and outreach of the PASS program. Recruit, develop, and
support PASS specialists (travel, technology, et al).

**Recommendation 14:** SSA should improve reporting of data and analysis
pertaining to SSDI (including Disabled Adult Children and concurrent
SSDI/SSI beneficiaries) and issue an annual report comparable to SSA's
*SSI Disabled Recipients Who Work* report*.*

**Recommendation 15:** SSA should establish a performance management and
return to work tracking system, providing benchmarks for each state, and
track utilization over time as part of a continuous quality improvement
plan.

**Recommendation 16:** SSA should empower beneficiaries by making SSA
policies and procedures easier to understand and accessible, e.g.
minimize "SSA Speak" and use plain language all can understand.

**Recommendation 17:** SSA should ensure that the availability and
relevance of work incentives are frequently included in communications
received by beneficiaries from SSA and the information is available in
alternative formats, and languages (e.g. Braille, large print, video
foreign/sign languages, etc).

[]{.mark}

**Recommendation 18:** SSA should increase beneficiary awareness of
earnings reporting requirements including the waiver process for
overpayments, and promote greater self-efficacy.

# Introduction

Section 101(f) of Public Law 106--170, the Ticket to Work and Work
Incentives Improvement Act of 1999 (the Ticket Act) establishes the
Ticket to Work and Work Incentives Advisory Panel (the Panel) within the
Social Security Administration (SSA). The purpose of the Panel is to
provide insight, advice, and recommendations to the President, Congress,
and the Commissioner of SSA that will lead to increased employment and
greater economic self-sufficiency for people with disabilities. A list
of current Panel members is provided in Appendix A.

The Panel's strategic plan supports the implementation of the Ticket to
Work and Work Incentives Improvement Act and the continuous improvement
of SSA's return-to-work efforts. This report is the result of a review
of utilization of existing work incentives associated with the
Supplemental Security Income (SSI) and Social Security Disability
Insurance (SSDI) programs administered by SSA, as well as related
Medicaid and Medicare provisions, and their interaction with other
federal benefit programs. It provides background information and
recommendations. The report is based on a literature review and careful
consideration of the beneficiary summit recommendations and past
recommendations made by other federal entities and advisory groups
focused on the increased utilization and improvement of existing work
incentive programs. The short-term, incremental recommendations in this
report form the foundation for the transformational recommendations that
will be included in the Panel's Final Report.

SSI and SSDI beneficiaries[^2] with disabilities, in fact, all people
with significant disabilities have historically been, and remain,
largely unemployed or significantly underemployed. Beneficiaries with
disabilities clearly want gainful employment, yet SSA's work incentives
remain significantly underused.

In their March 1988 report to the Congress, the 1986 Disability Advisory
Council reported that, in any given year, \"fewer than 15 percent of
beneficiaries are referred for VR services, and only a small portion of
these individuals received services.\" Historically, SSA's published
statistics have also shown that less than one-half of one percent of
disabled individuals approved for SSDI or SSI are removed from the
disability rolls due to their return to work. The Government
Accountability Office (GAO) published a report in 1994 that reported
that rehabilitation alone contributed little to benefit terminations in
the SSA system. These outcomes remained unchanged over the next decade.
The National Academy of Social Insurance's Disability Policy Panel's
final report in 1996, "Balancing Security and Opportunity: The Challenge
of Disability Income Policy," clearly stated that disability policies
can improve work outcomes by addressing any of the factors that together
produce work disability.

The 1986 Disability Advisory Council made several primary
recommendations, including increasing access to health care; improving
existing work incentives by updating them and making them more work
friendly; implementing the existing work incentive programs effectively;
and ensuring that beneficiaries have access to assistance in
understanding how to use work incentives effectively. Some of the health
care and work incentive recommendations were implemented with the
passage of the Ticket Act, specifically adding the Medicaid Buy-In,
updating some incentives, and establishing a national network of
benefits and work incentives specialists. Still, the changes do not
appear to have gone far enough to enhance work incentive utilization or
the employment outlook for SSA beneficiaries.

Using existing SSA administrative data, this report documents that
little improvement has occurred in the use of work incentives and
ultimately on the return of beneficiaries with disabilities to the
workplace. Building on the prior work of past federal commissions,
advisory councils, and panels, as well as the recurring experiences of
beneficiaries, the Panel presents a framework for how the President,
Congress, SSA and other federal partners can work together to update and
simplify existing work incentives and to educate beneficiaries and other
stakeholders in the return-to-work (employment) process.

The Panel strongly believes that there is no "one size fits all"
solution to the under-performance and under-utilization of existing work
incentives and was guided in the development of this report by four
historic and current realities related to work incentive utilization.
These are:

-   SSDI and SSI are programs of last resort. They are an essential part
    of the nation\'s safety net, providing both cash and health
    insurance benefits.  The strict and frugal legislative design of the
    programs does not provide strong induced entry incentives for people
    with significant disabilities to apply for benefits instead of
    working. 

-   Beneficiaries want to work. Beneficiaries may be able to work on a
    full time, part time, or intermittent basis, under certain
    circumstances and depending on a myriad of complex and interrelated
    factors.

-   Work incentives are complicated, poorly understood and
    underutilized. However, they can serve as a safety net to transition
    from benefits to work and self-sufficiency.   

-   Work incentives are labor-intensive to administer. SSA\'s
    post-entitlement workload, which includes processing earnings
    reports and handling other work related issues, has been a low
    priority for many years due to increased initial claims, limited
    administrative resources and new legislative mandates.  Keeping
    these realities in mind, there is a series of actions that could be
    taken to create the conditions and policy environment that would
    better support work beyond the outcomes currently achieved by some
    beneficiaries with disabilities. The actions under consideration
    fall into three primary categories:

1\. **UPDATING** existing work incentives to make them more applicable
to the realities and employment support needs of beneficiaries in 2007
and beyond. This would include improving existing work incentives and
ensuring that they accommodate the dynamic nature of disability while
assuring access to health care as work incentives are utilized.

2\. **SIMPLIFYING** the maze of work incentives programs that exist not
only within SSA but other federal benefit programs so that those
programs mutually support a common work agenda and make work pay while
at the same time reducing the risk of overpayments for beneficiaries and
other unintended adverse program interactions.

3\. **EDUCATING** and equipping the array of stakeholders that intersect
the return-to-work process is multi-pronged, focused on ensuring that
beneficiaries interested in going to work have access to customized,
responsive, timely, relevant and accurate information and services to
support their efforts. The stakeholders that need to be included in
order for work incentive provisions to be effective include: SSA field
personnel, employment networks and other community providers, educators,
and beneficiaries. Education would include increasing the awareness of
beneficiaries regarding work incentives through information
dissemination, expanded outreach, and increased numbers of work
incentive practitioners available and providing ongoing training of SSA
personnel. It would also include putting in place systems to inform SSA
regarding return-to-work efforts by improving the collection,
organization and use of data about work incentive utilization for
decision-making.

The recommendations included in this report are intended to support the
Panel belief that, if existing work incentives are updated and
simplified, and stakeholders are educated regarding their availability,
expanded opportunities and conditions for supporting work will be
created. In addition, these recommendations are intended to be
incremental and achievable in the short term.

While the Panel believes that the current Medicaid Buy-In and Medicare
programs for beneficiaries with disabilities need to be reformed, the
Panel has not included recommendations for these programs in this advice
report. Instead, the Panel will consider including these recommendations
in its Final Report, which will be delivered later this year to the
President, Congress, and the Commissioner of Social Security.

# Historical Context \-- Background

In 1956, Congress expanded the Social Security program (which was
created in 1935) by creating SSDI, which provided disability insurance
benefits to workers over age 50 who had disabilities that met the
requirement of inability to engage in any substantial gainful activity
(SGA) by reason of a medically determinable physical or mental
impairment which could be expected to result in death or to be of
long-continued and indefinite duration[^3].

This legislation was the result of Congress' struggle to reconcile the
creation of a program to help people who were totally and permanently
unable to work with efforts to return people to work. The program was
essentially a disability insurance program rather than a return-to-work
program. However, the legislation expressed the intent to rehabilitate
as many applicants as possible. In 1956, the SSDI legislation combined
cash benefits with referral to State Vocational Rehabilitation Services
(VR), resulting in the SSDI program.[^4] Eligibility determinations were
to be made by State agencies on SSA's behalf to speed referrals.

By June 1958, more than 800,000 had been referred to State VR agencies,
but only about 550 beneficiaries (.02% of the beneficiary population)
had been successfully rehabilitated.[^5] Subsequent amendments added
benefits for younger workers, disabled widows, individuals who became
disabled prior to age 22, and those whose working parent died or became
eligible for Social Security retirement benefits. The original
requirement of a disability of indefinite duration was reduced to
include disabilities lasting as little as a year, and health insurance
under Medicare was added for beneficiaries who had passed a 24-month
waiting period.

As the program evolved to include younger workers and shorter periods of
disability, work incentive provisions were added, to facilitate
returning beneficiaries to work. In 1960, the first SSDI work incentive
provision was enacted, which provided a nine-month Trial Work Period
(TWP) during which a beneficiary could test his or her ability to work
without suffering a loss of benefits. If the beneficiary continued to
work above SGA following completion of the TWP, benefits would be
terminated. Still, few SSDI beneficiaries returned to work. In 1967,
14,500 were rehabilitated, which was 1.2% of the beneficiary
population.[^6]

In 1972, Title XVI of the Social Security Act was signed into law,
creating the needs-based program of SSI. The program is a federally
administered income assistance program restricted to qualified
individuals who have countable resources not exceeding \$2,000 for an
individual and \$3,000 for married couples. The SSI program includes
cash assistance for children and adults with disabilities. SSI
recipients who work and have earnings have their SSI benefits partially
offset to adjust for this additional source of income. Earnings
exclusions that are applied before the offset is made result in the
beneficiary losing less than one dollar in benefits for each two dollars
of earnings. These exclusions recognize the additional costs associated
with employment and assure that a recipient will always have higher
gross income when he or she works than if he or she does not.

Since the beginning of the SSI program in 1974, Congress has included
work incentive provisions to provide beneficiaries with support to move
from benefit dependency to independence through work. During the 1970s,
the number of disability beneficiaries doubled. Ongoing beneficiary
payments increased by a factor of five.[^7] In response to rising
disability rolls, Congress provided additional incentives to support
work for SSI and SSDI disability beneficiaries through the 1980
amendments to the Social Security Act. These incentives included the
ability to deduct Impairment-Related Work Expenses (IRWE) in determining
whether earnings demonstrate SGA, an EPE within which to test ability to
work while retaining disability status after completion of the TWP,
provisions for SSI recipients to continue to receive SSI payments beyond
SGA under certain conditions, and extension of Medicare coverage for
SSDI beneficiaries. The Section 1619 SSI/Medicaid work incentives began
in 1981 and were made permanent effective July 1, 1987.

Even with these changes, few SSI or SSDI beneficiaries were leaving the
rolls for work. Barriers to health care and other supports needed for
work were viewed as being a primary reason. A 1992 study found that
about 10% of beneficiaries entitled in 1980-1981 performed some work
over a period of approximately 10 years, but only about 2% left the
rolls.[^8] Additional research showed that over 80% of beneficiaries
were unaware of the work incentives and few used them.[^9] Vocational
rehabilitation "seemed to have a positive effect on work resumption",
but only about 2% of beneficiaries received VR services. Physical
therapy, vocational training, general education, and job placement
efforts all seemed to increase the tendency to go back to work.[^10]

To further encourage beneficiaries to work, Congress enacted the 1999
Ticket to Work and Work Incentives Improvement Act which addressed the
threat of losing health benefits by extending Medicare coverage to 102
months from 36 months, and established a state option to offer a
Medicaid buy-in program for workers with disabilities. The Ticket Act
expanded work incentives providing SSDI and SSI beneficiaries with the
option to receive a ticket to secure vocational rehabilitation services,
training and employment, and other supports from employment networks
(ENs) of their choice---a market-driven approach to expanding employment
service options for beneficiaries.

The Ticket Act also eliminated work-triggered continuing disability
reviews (CDRs); provided a work incentives outreach program to provide
information, planning, and guidance to SSI and SSDI beneficiaries; and
provided the expedited reinstatement (EXR) provision for both SSDI and
SSI. The Ticket Act was viewed as greatly expanding both opportunities
and incentives for people with disabilities to go to work. The Ticket
program was outcome-based, authorizing payments to ENs based upon
employment outcomes. Despite the outcome-based payments, EN
participation was low. Revised SSA regulations are pending to improve
payment schedules and encourage greater EN participation.

# SSI Efforts to Support Work

Since the program began in 1974, the needs-based SSI program has
provided a \$1 for \$2 gradual reduction in earnings after an initial
\$85 income exclusion. The monthly Federal benefit rate (\$623 for an
individual and \$934 for couples in 2007) is reduced by the amount of
the individual\'s \"countable\" income, increased by a State supplement
if applicable. Since the beginning of the SSI program, incentives have
been provided to support work.

### Overview of the SSI Program and Existing Work Incentives 

The SSI program has attempted to support efforts to work by providing
work incentives that exclude earnings and resources. When determining an
individual\'s countable income, there is a general \$20 income
exclusion, which is applied to an individual\'s unearned income. Then
there is an earned income exclusion of the first \$65 and one-half of
the remainder of earned income. This greater exclusion for earned income
acts as a work incentive for all SSI recipients. In addition, the
Student Earned Income Exclusion (SEIE) allows an individual with a
disability who is under age 22 and regularly attending school to exclude
up to \$1,510 of earned income per month (up to an annual exclusion of
\$6,100) before applying the earned-income exclusion. The SSI program
also includes the Infrequent/Irregular Income Exclusion. Its purpose is
to simplify program administration by permitting SSA to overlook small
amounts of earnings received from sporadic employment. Specifically, the
first \$30 of earned or \$60 of unearned infrequent or irregular income
received in the calendar quarter is excluded.[^11]

In addition, IRWE allows a beneficiary to deduct from earned income work
expenses directly related to the individual\'s disability. The IRWE is
deducted from monthly earnings prior to the \$1 for \$2 reduction
equating to a maximum of up to 50% of the actual cost of expenses paid
out of the beneficiary's own pocket. Subsequently, Blind Work Expenses
(BWE) allows the deduction of certain work-related expenses for
individuals who are blind from their earned income when determining SSI
eligibility and cash benefit amount; however the expense is deducted
following the \$1 for \$2 reduction, allowing up to a 100% recoup of
expenses paid for out of pocket. The BWE is more advantageous than the
IRWE for two reasons. First, BWE only needs to be an expense related to
the cost of going to work paid by the beneficiary as opposed to an
impairment-related work expense. Second, because of the way it is
calculated, BWE provides a greater financial incentive to the blind and
recognizes that the costs attributed to going to work for a beneficiary
are greater than just the expenses that are impairment-related.

Under SSI, income set aside under a Plan for Achieving Self-Support
(PASS) may also be excluded. A PASS is established to help beneficiaries
who are blind or disabled become self-supporting over time. A PASS
allows a beneficiary to self-direct his or her plan for employment,
although it must be approved by SSA and the conditions of the plan must
be fulfilled. The PASS allows a beneficiary to exclude income and
resources that are set aside to help the individual reach a specific
occupational goal. Funds can be set aside for education, vocational
training, the purchase of a vehicle or equipment, etc. related to the
work goal. The income and resources set aside are excluded under the SSI
income and resources tests.[^12]

Effective March 1, 2006, the PASS qualified as an appropriate program of
employment services for benefit continuation purposes.[^13] This means
that SSI recipients who have medically recovered from a disability are
potentially eligible for continued monthly payments if they comply with
the self-sufficiency goals of their PASS. As with vocational
rehabilitation and other employment service programs, SSA encourages the
completion of a PASS as a means by which beneficiaries can be
permanently removed from the SSI rolls.

Property Essential to Self-Support (PESS) was one of the original SSI
work incentives and applies to unincorporated for-profit businesses such
as sole proprietorships, partnerships, and limited liability companies.
PESS allows a person to build unlimited funds in a small business
operating account, and to exclude from counted assets tools or equipment
used for work, or inventory needed for a business, inventory, equipment,
land, vehicles, commercial buildings. SSA counts the owner\'s share of a
corporation as a resource, which cannot be excluded for PESS. For
beneficiaries who are employees, PESS may be used to exclude tools or
equipment used for work.

The 1619 provisions of the Social Security Act provide additional
substantial incentives supporting work for SSI recipients. Section
1619(a) provides continued eligibility for SSI when earnings exceed SGA
levels until the amount of earnings would cause the beneficiary to
become ineligible for cash benefits under SSI income counting rules.
Section 1619(b) provides for continued Medicaid when SSI recipients lose
their benefits because of earnings and provides continued attachment to
SSI after earnings reduce benefits to zero. This continuation of
Medicaid under Section 1619(b) also applies to those who are dually
eligible for SSI and SSDI and who lose their SSI cash benefits before
they exceed the SGA earnings level because they have countable income
from SSDI.

The 1619 provisions allow an individual to move from SSI cash benefit
status to Medicaid only status, and back again without the need for
either a new application or request for Expedited Reinstatement (EXR).
Thus, an individual in 1619(b) status can return to cash benefits when
wages decrease. EXR applies when an individual's eligibility for SSI is
terminated, and provides that SSI benefits may be reinstated without a
new application if the individual files for reinstatement within 60
months of entitlement with the same (or related) disability. The person
would have to satisfy the SSI income and resource limits and be
incapable of earning SGA. EXR permits up to six months of provisional
benefits while the reinstatement is processed.

Finally, under the Ticket Act, Congress enhanced the Medicaid Buy-In
program created two years earlier by the Balanced Budget Act of 1997.
The Buy-In, implemented in 38 states, allows beneficiaries to obtain or
retain Medicaid at higher earnings and resource levels by paying
income-based premiums if states choose to require them.

### Current Beneficiary Efforts to Work and Use SSI Work Incentives[^14]

The number of SSI recipients who work increased by 102% between 1987 and
2006, from 173,000 to 349,000; however this is discounted by the fact
that, during the same period, the number of SSI recipients aged 18 to 64
increased from 2,118,710 to 4,152,130---an increase of 96%. In December
2006, 349,420 individuals connected to the SSI program had earnings. Of
those, 16,537 were receiving SSI benefits under the provisions of
Section 1619(a) and 84,226 were not receiving SSI benefits but, under
the provisions of Section 1619(b), were considered to be SSI recipients
for purposes of Medicaid eligibility. An additional 228,838 SSI
recipients had earnings that reduced their SSI benefits.

Table 1 illustrates the number of SSI workers working below SGA, in
1619(a) status, and in 1619(b) status, by year. The total number of
working SSI recipients peaked in 2000 at 360,427 and in 2006 it was
349,420. The number of 1619(b) participants grew from 15,632 in 1987 to
89,350 in 2006. (Note that roughly 2/3 of 1619(b) beneficiaries may not
be earning above SGA but receive SSDI payments.)

In December 2006, 7.9 percent of all SSI recipients ages 18 -- 64 had
earnings, with a wide variation among the states in the percentage of
SSI recipients with earnings.[^15] It is not known for certain the
reasons for the variations. The list of tangible and intangible
variables set out in two December 2005 reports by Jensen and
Silverstein: \"Gradual Reduction Choice Option and Related Policy
Projects" and \"A Framework For Preparing Cost Estimates for SSDI \$1
for \$2 Gradual Reduction Demonstration Project\", provide some insight.

Among the tangible variables they identified are the variations among
the states in the availability and use of comprehensive
employment-related services and ongoing support services as well as the
age, type and severity of disability. In addition, the intangible
variables can include, but are not limited to, level of encouragement
and attitudes toward employment by both public and private service
providers in combination with the level of encouragement by agencies,
employers and family and other support.

**Table 1**

**SSI Federally-Administered Blind or Disabled Working Recipients**

**as of December, 1987-2006**

+--------------+-------+----------+--------+----------+--------------+
| Year         |       | In       |        |          |              |
|              |       | current  |        |          |              |
|              |       | -payment |        |          |              |
|              |       | status   |        |          |              |
+--------------+-------+----------+--------+----------+--------------+
|              | **SGA | [*       | [*     | 1619(b)  | Total        |
|              | Level | *1619(a) | *Other |          | Workers      |
|              | **^1^ | W        | Wor    | [**W     |              |
|              |       | orkers** | kers** | orkers** |              |
|              |       | ](http:/ | ](http | ](http:/ |              |
|              |       | /mwww.ba | ://mww | /mwww.ba |              |
|              |       | .ssa.gov | w.ba.s | .ssa.gov |              |
|              |       | /OACT/ss | sa.gov | /OACT/ss |              |
|              |       | ir/SSI07 | /OACT/ | ir/SSI07 |              |
|              |       | /WorkInc | ssir/S | /WorkInc |              |
|              |       | entives. | SI07/W | entives. |              |
|              |       | html#wp4 | orkInc | html#wp4 |              |
|              |       | 7824)^2^ | entive | 7813)^4^ |              |
|              |       |          | s.html |          |              |
|              |       |          | #wp478 |          |              |
|              |       |          | 26)^3^ |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 1987         | \$300 | 14,559   | 1      | 15,632   | 172,855      |
|              |       |          | 42,664 |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 1988         | 300   | 19,920   | 1      | 15,625   | 189,144      |
|              |       |          | 53,599 |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 1989         | 300   | 25,655   | 1      | 18,254   | 205,837      |
|              |       |          | 61,928 |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 1990         | 500   | 13,994   | 1      | 23,517   | 219,932      |
|              |       |          | 82,421 |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 1991         | 500   | 15,531   | 1      | 27,264   | 229,619      |
|              |       |          | 86,824 |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 1992         | 500   | 17,603   | 1      | 31,649   | 248,917      |
|              |       |          | 99,665 |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 1993         | 500   | 20,028   | 2      | 35,299   | 265,649      |
|              |       |          | 10,322 |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 1994         | 500   | 24,315   | 2      | 40,683   | 282,476      |
|              |       |          | 17,478 |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 1995         | 500   | 28,060   | 2      | 47,002   | 298,635      |
|              |       |          | 23,573 |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 1996         | 500   | 31,085   | 2      | 51,905   | 308,300      |
|              |       |          | 25,310 |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 1997         | 500   | 34,673   | 2      | 57,089   | 319,855      |
|              |       |          | 28,093 |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 1998         | 500   | 37,271   | 2      | 59,542   | 326,475      |
|              |       |          | 29,662 |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 1999         | [     | 25,528   | 2      | 69,265   | 340,618      |
|              | 700]( |          | 45,825 |          |              |
|              | http: |          |        |          |              |
|              | //mww |          |        |          |              |
|              | w.ba. |          |        |          |              |
|              | ssa.g |          |        |          |              |
|              | ov/OA |          |        |          |              |
|              | CT/ss |          |        |          |              |
|              | ir/SS |          |        |          |              |
|              | I07/W |          |        |          |              |
|              | orkIn |          |        |          |              |
|              | centi |          |        |          |              |
|              | ves.h |          |        |          |              |
|              | tml#w |          |        |          |              |
|              | p4784 |          |        |          |              |
|              | 2)^5^ |          |        |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 2000         | 700   | 27,542   | 2      | 83,572   | 360,427      |
|              |       |          | 49,313 |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 2001         | 740   | 22,100   | 2      | 76,455   | 346,110      |
|              |       |          | 47,555 |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 2002         | 780   | 17,271   | 2      | 82,177   | 340,910      |
|              |       |          | 41,462 |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 2003         | 800   | 17,132   | 2      | 71,097   | 323,682      |
|              |       |          | 35,453 |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 2004         | 810   | 17,114   | 2      | 73,681   | 328,204      |
|              |       |          | 37,409 |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 2005         | 830   | 17,621   | 2      | 78,205   | 336,570      |
|              |       |          | 40,744 |          |              |
+--------------+-------+----------+--------+----------+--------------+
| 2006         | 860   | 17,394   | 2      | 89,350   | 349,420      |
|              |       |          | 42,676 |          |              |
+--------------+-------+----------+--------+----------+--------------+

Source: 2007 Annual Report of the SSI Program, Social Security
Administration, Table V.E1.

^1^Increases in 2001 and subsequent years are based on increases in the
national average wage index.

^2^Workers\' earnings are above SGA level.

^3^Workers\' earnings are at or below SGA level.

^4^1619(b) recipients are not in current-payment status but retain SSI
recipient status for Medicaid purposes.

^5^Increased to \$700 in July 1999.

As shown in Table 2, the numbers of workers using IRWEs or BWEs have
declined over the past 15 years. In 2006, just 1.6% used IRWEs and 0.7%
used BWEs. That year, utilization of IRWEs and BWEs was at its lowest
level since 1990.

The usage of PASS plans is also exceedingly low. In December 2006, 0.5%
percent (1,583) of SSI recipients had PASS plans. Four hundred and nine
PASS participants had earnings, which averaged \$792 per month. However,
exclusions under a PASS are not limited to earnings. Of the 1,583
disabled recipients with a PASS, over 69% did not have any earnings
reported for December 2006. Out of all PASS participants, 435 had a PASS
that excluded only resources.[^16]

> **Table 2**.
>
> **SSI Federally-Administered Blind or Disabled Individuals with SSI
> Recipient Status Participating in Other Work Incentives**
>
> **as of December, 1990-2006**

  -------------------------------------------------------------------------------
               PASS                              IRWE    BWE         Total
                                                                     Workers
  ------------ ------------- ---------- -------- ------- ----------- ------------
  Year         Non-workers   Workers    Total                        

  1990         1,215         1,040      2,255    5,384   4,385       219,932

  1991         1,969         1,601      3,570    6,546   4,330       229,619

  1992         3,189         2,658      5,847    7,813   4,454       248,917

  1993         4,528         3,602      8,130    8,629   4,406       265,649

  1994         5,842         4,487      10,329   9,484   4,380       282,476

  1995         5,719         4,603      10,322   9,940   4,433       298,635

  1996         2,760         1,944      4,704    9,799   4,230       308,300

  1997         1,290         708        1,998    9,637   4,116       319,855

  1998         712           362        1,074    9,301   3,802       326,475

  1999         698           347        1,045    9,520   3,971       340,618

  2000         862           520        1,382    9,422   3,895       360,427

  2001         1,024         576        1,600    8,798   3,642       346,110

  2002         1,150         571        1,721    8,047   3,386       340,910

  2003         1,181         524        1,705    7,604   3,074       323,682

  2004         1,112         486        1,598    6,874   2,827       328,204

  2005         1,089         493        1,582    6,310   2,552       336,570

  2006         1,174         409        1,583    5,650   2,370       346,309
  -------------------------------------------------------------------------------

Source: SSI Recipients Who Work 2006, Social Security Administration.

In general, utilization of SSI work incentives (other than the Section
1619 provisions) is very low. In addition to low PASS utilization, the
utilization of IRWE and BWE by SSI recipients has continued to decline.
Participation under section 1619(b), now at 87,216 now exceeds
participation under section 1619(a) by more than five to one.[^17]
Utilization of PASS, IRWE, and BWE vary by state.[^18] The reasons for
state-to-state variation are not known.[^19] Medicaid Buy-In utilization
continues to increase but results vary significantly from state to
state.

# SSDI Efforts to Support Work

In the SSDI program, benefits are determined based upon the
beneficiary's work history and the amount the individual has contributed
under the Federal Insurance Contributions Act. Given that SSDI is an
insurance program and not means-tested, income and resources do not have
the same impact and effect. Incentives are provided to encourage work,
although those offered through SSDI are different from those of the SSI
program.

### Overview of the SSDI Program and Existing Work Incentives

The return-to-work process under the SSDI program is complicated and
guided by a series of time and earnings-sensitive benchmarks. The TWP
allows beneficiaries to test their ability to work for nine months
without losing benefits. The nine months do not have to be consecutive,
but they must occur within a 60-month rolling window. For 2007, a TWP
service month is a month in which the individual earns more than \$640
or works more than 80 self-employed hours. There is no limit to the
amount of money that may be earned during the TWP without losing the
SSDI cash benefit. An SSDI beneficiary is allowed one TWP during a
period of entitlement to benefits. Effective January 2001, the new EXR
rules allow for a new TWP after the person receives reinstatement of
benefits for 24 months.

Once a TWP has been completed, there is a 36-month EPE, or
re-entitlement period. The 36 months run consecutively, and the EPE
allows the person whose SSDI benefits payments have stopped because of
exceeding SGA to have their SSDI payments start again if earnings dip
below SGA. In the first month of the EPE in which a beneficiary earns
over SGA, that individual will receive their full cash benefit for that
month and the next two months. This three-month period is referred to as
the grace period. Following the grace period, any month in which a
person's earnings are over SGA, they will not receive a cash payment.

Under SSDI program rules, any earnings above SGA in a given month that
occur after completion of the TWP and the EPE result in a loss of all
cash benefits. This is a situation commonly called the "cash cliff."
This is widely believed to be the most significant barrier to work
efforts, as it provides a financial disincentive to earning above the
SGA level and leaving the SSDI benefit rolls. Over the years, there have
been numerous proposals to remove the cash cliff through a gradual
benefit offset similar to provisions in the SSI program. In fact,
Congress mandated a demonstration project in both the Social Security
Act Amendments of 1980 and the 1999 Ticket Act to test if a gradual
reduction of benefits after work above SGA would result in an induced
entry or to reduce exits from the SSDI rolls. SSA's benefit offset
demonstration project is currently under development.

Under the SSDI program, work incentives reduce the amount of income that
is counted in the determination of whether or not an individual has
earned above SGA, IRWEs include deductible disability-related work
expenses paid for by the beneficiary and may be subtracted from a SSDI
beneficiary's earned income to determine whether or not the SGA test has
been met. People who are blind must follow the rules for IRWE rather
than BWE, which is only an SSI work incentive.

\"Subsidy\" and \"special conditions\" are supports received on the job
that result in an individual receiving more pay than the actual value of
the work performed. If the individual is not fully earning the wages
paid because the work is performed under special conditions (e.g., close
and continuous supervision, on-the-job coaching and substitution during
which the job coach performs part or all of the job duties), then SSA
must deduct that part of the wages that are not \"earned\" by the worker
from his or her average gross wages. This is true whether or not the
employer or someone else provides the special (on-the-job) conditions.

Before the EXR provisions became effective in 2001, if an SSDI
beneficiary went off benefits and later lost a job or had wages reduced
below SGA, he or she would have to reapply for benefits. The Ticket Act
provided that a recipient who loses benefits due to wages can apply for
reinstatement and have benefits reinstated (without a new application)
if they apply within 60 months of the last month of eligibility, and
they meet all eligibility requirements. EXR permits up to 6 months of
provisional benefits while the request is processed. The EXR work
incentive protects those who work above SGA after the EPE and later are
not able to continue to work above SGA.

When an SSDI beneficiary goes to work, Medicare continues for the
nine-month trial work period and at least 93 additional months. After
premium-free Medicare coverage ends due to work, some individuals who
have returned to work may buy continued Medicare coverage, as long as
they remain medically disabled. Some individuals with low incomes and
limited resources may be eligible for state assistance with this cost.
In contrast to SSI, a Medicaid Buy-In appears to be the only work
incentive that enables SSDI-only beneficiaries to go to work and
maintain Medicaid coverage of disability-related expenses needed to work
(i.e., attendant care).

### Current Beneficiary Efforts to Work and Use SSDI Work Incentives

From 1990 to 2006, the number of disabled workers receiving SSDI
benefits more than doubled, increasing from about three million to 6.8
million. The termination rate (terminations per 1000 beneficiaries) due
to recovery (which includes both return to work and medical recovery)
has declined, and is less than one-half of one percent of disabled
worker beneficiaries.[^20]

Little or no data was found on utilization of TWP, EPE, IRWEs for SSDI
beneficiaries, subsidy and special conditions, EXR, or extended
Medicare. This lack of information prevents SSA analysis of the success
or failure of these work incentives in returning SSDI beneficiaries to
work.

Until a few years ago, SSA did not track monthly earnings of SSDI worker
beneficiaries, or their utilization of these work incentives. SSA has
not published any analysis of SSDI work incentive utilization.
Particularly given the low rate of SSDI worker beneficiaries returning
to work, SSA should provide regular reporting of data and analysis
pertaining to SSDI work incentive utilization. This could provide SSA
with better insight into how to support local Area Work Incentive
Coordinators (AWICs) in encouraging other SSA staff, Community Work
Incentive Coordinators (CWICs), community agencies and
beneficiaries/recipients to more fully utilize work incentives.

# The Integration of Work Incentives: Complexity of Rules

SSI and SSDI beneficiaries have to deal with the complexities of an
array of work incentives. It is not a matter of being informed about and
using a single work incentive, but rather understanding all the
applicable work incentives and managing them to avoid pitfalls.

In 2000, SSA produced an internal report to Commissioner Kenneth S.
Apfel that discussed the evolution of the SSI program, issues of benefit
adequacy, and the challenge of simplifying the program.[^21]

The report notes that, by definition, complexity is unavoidable in any
means-tested program. SSI is no different. In the SSI program, the
complexity extends beyond an earnings test to include an extensive set
of initial and continuing eligibility rules that govern not only all
types of income but also resources, living arrangements, and
documentation of any changes. SSA must take account of all income and
resources that an individual has or can obtain. The amount of an
individual\'s income and resources are the measure of that individual's
need for assistance.

The report describes the tension that exists between:

-   reducing the complexity of program rules to make them easier for
    beneficiaries to understand and for SSA to administer, and

-   the objectives of the SSI program to (1) ensure a minimum level of
    income to meet the basic necessities of living (2) ensure by
    objective criteria that people with like income and resource levels
    are treated in the same way and (3) ensure that benefits are paid
    accurately, efficiently, and with no tolerance of fraud.

The Panel has heard from many beneficiaries about their fear of losing
benefits and access to health care. In addition, many have told us that
they are reluctant to risk losing their benefits after undergoing a
lengthy and rigorous eligibility process. Further, incentives often do
not go far enough in offsetting not only the impairment-related but also
other expenses associated with going to work. It may not be reasonable
to expect beneficiaries to deal with confusing and seemingly arbitrary
time frames and dollar amounts as they try to understand the impact of
earnings on their benefits.

For SSDI, the complexity includes:

-   A 24-month waiting period before Medicare benefits begin;

-   A nine-month (not necessarily consecutive) TWP within a rolling 60
    month timeframe, which allows unlimited earnings but requires a
    \"work\" continuing disability review (CDR). (Note that rules
    governing whether or not a month of work counts as a TWP month
    include both hours worked and earnings thresholds unrelated to SGA);

-   A 36-consecutive month EPE, during which earnings are limited to
    less than SGA, with no questions about why earnings dropped;

-   A three-month grace period before payments are stopped if the
    beneficiary has earned SGA;

-   A five-month waiting period before payments can be started;

-   A five-year period during which benefits can be reinstated if
    earnings are less than SGA but unlike the EPE it applies only if
    benefits ended because of work;

-   A time limit that the 37th month after the end of the nine-month
    (not necessarily consecutive)TWP is latest that benefits can be
    restarted; and,

-   A maximum of 93 consecutive months of Medicare after cash benefits
    stop, starting with the last month of 9 month (not necessarily
    consecutive) TWP.

For SSI recipients, the complexities due to timing are not as great. The
\$1 for \$2 reduction avoids the all-or-nothing situation with regard to
benefits and health insurance, and the 1619 provisions provide for a
smoother transition.

Table 3 identifies the work incentives and indicates whether they apply
to SSI, SSDI, or both programs.

> **Table 3**
>
> **Work Incentive Application to SSI and SSDI**

  ------------------------------------ -------------- -------------------
  Work Incentive                       Applies to SSI Applies to SSDI

  Earned Income Exclusion              Yes            

  Student Earned Income Exclusion      Yes            
  (SEIE)                                              

  Impairment-related work expenses     Yes            Yes
  (IRWE)                                              

  Blind Work Expenses (BWE)            Yes            Yes

  Plan for Achieving Self-Support      Yes            
  (PASS)                                              

  Property Essential to Self-Support   Yes            
  (PESS)                                              

  1619(a), Working above Substantial   Yes            
  Gainful Activity (SGA)                              

  1619(b), Medicaid While Working      Yes            

  Expedited Reinstatement (EXR)        Yes            Yes

  Medicaid Buy-In                      Yes            In some states

  Trial Work Period (TWP)                             Yes

  Extended period of eligibility for                  Yes
  reinstatement of benefits (EPE)                     

  Subsidy and Special Conditions       Yes (initial   Yes
                                       eligibility)   

  Extended Medicare                                   Yes
  ------------------------------------ -------------- -------------------

### Concurrent Beneficiary Efforts to Work and Use SSI and SSDI Work Incentives Simultaneously

## 

As outlined above, work incentives and eligibility for both the SSI and
the SSDI programs are complex. This complexity is compounded for
concurrent beneficiaries (individuals receiving both SSI and SSDI
benefits) who must navigate two sets of work incentives and eligibility
provisions, which are often at odds.

According to a recent GAO report,[^22] concurrent beneficiaries account
for about 14 percent of SSA's disability population, and about 11
percent of concurrent beneficiaries worked, compared to eight percent of
SSI-only recipients. While a greater percentage of concurrent
beneficiaries worked than that of SSI-only recipients, the average
median monthly earnings of concurrent beneficiaries was less: \$250
compared to \$400 for SSI-only recipients. This GAO report explored the
implications that uncoordinated program rules have on overpayments and
underpayments.

Findings include:

-   Information affecting benefits or eligibility is not reported timely
    and/or reported information affecting benefits or eligibility is not
    processed timely;

-   Field office staff generally specialize in only one of the programs,
    so they may not be fully aware of rules for both programs, making it
    difficult for them to offer guidance; and,

-   Reliable public information materials clearly explaining the complex
    interaction of the two programs are not available, so it is
    difficult for beneficiaries to make informed decisions about
    working.[^23]

# Discussion of Issues and Recommendations

The Panel feels strongly that the President, Congress and SSA can take
additional steps, beyond those incorporated into the initial Ticket Act,
to create an enhanced policy environment that supports work and creates
conditions needed by some beneficiaries to work. Prior to outlining
these issues and recommendations, it is important to state that the
Panel recognizes that beneficiaries invest great resources and effort
into their attempts to work in the current return-to-work policy
environment and that current policy does not equitably distribute risk.
The recommendations highlighted below attempt to balance this risk,
encouraging the government to make a greater investment in the work
efforts of all beneficiaries. The Panel calls for continued investment
in the lives and efforts of beneficiaries.

## UPDATE Existing Work Incentives 

The Disability Advisory Panel in 1996 clearly stated the need for
Congress and SSA to update existing work incentives to make them more
applicable to the realities and employment supports needed in 2007 and
beyond. This would include improving existing work incentives and
ensuring that they accommodate the dynamic nature of disability while
assuring access to health care as work incentives are utilized.

### Update IRWE

IRWE applies to both SSDI and SSI. However, under the SSI program, the
reimbursement for expenses paid for by the beneficiary only allows for
up to a 50% cost recovery -- not dollar for dollar as is true of BWE or
PASS. This poses a considerable barrier to work for those beneficiaries
starting out in positions that do not provide adequate earnings to
offset the loss of income associated with paying for these expenses and
the potential loss of SSI cash benefits. This is important to
beneficiaries trying to survive on limited income. For example, a
working SSI beneficiary with \$100 of IRWE would get an extra \$50 of
SSI, which is 100% recovery of some the costs involved in working. This
would be significant for an SSI beneficiary who has under a thousand
dollars a month to spend on food and shelter, and would likely encourage
more beneficiaries to go to work.

**Recommendation 1:** SSA should change the order in which impairment
related work expenses (IRWE) are deducted when calculating the SSI cash
payment to allow for up to a 100 percent cost recovery.[^24]

While the definition of IRWE is the same regardless of the program, as
are the conditions necessary for approval by SSA, items and/or services
can be allowed as IRWE even if they are also needed for normal daily
activities. However, the cost of *routine* drugs and medical services,
such as a yearly physical, are not deductible *unless* they are needed
to control the impairment and enable the person to work. The cost of
health insurance premiums is listed in the Program Operations Manual
System as a "non-deductible" item.[^25] One could argue that because
Medicare is *only* available to individuals who have a disability (or
are retired), the premium cost should be recognized as an
impairment-related expense and necessary for work. Certain individuals
will purchase supplemental coverage due to co-insurance or deductibles.
For example, a disability beneficiary with degenerative joint disease
can only continue working if he or she has systematic joint replacement,
which is costly surgery only partially covered by Medicare Hospital
Insurance. The supplemental policy covers the deductible portion of the
costs, but cannot be used as an IRWE. This problem became more evident
when Medicare Part D was implemented. Prior to Part D, a disability
beneficiary without drug coverage could use the out-of-pocket medication
costs as IRWE. Now, if a beneficiary enrolls in Medicare Part D to get
the drug coverage, the IRWE deduction is lost because the Part D premium
cost is not allowed. For this reason, individuals who could benefit from
Medicare Part D coverage may not be enrolling in the program.

**Recommendation 2:** SSA should allow health insurance premiums to be
used as IRWE, when the beneficiary can document that the coverage is
disability-related and supports work.

The assistance of family members in providing transportation to and from
work and attendant care services is essential. Delegates to the Panel's
2007 Beneficiary Summit selected "Support family caregivers who provide
personal assistant and other services" as one of their key
recommendations. Many beneficiaries rely on family members to drive them
to and from work because they are unable to drive themselves, cannot
afford a car, public transportation is not available and/or accessible.
They also rely on family members to provide attendant care services
because other providers are difficult to find and often are unreliable.
If a person with a disability pays a family member to perform attendant
care services, the payment will generally not be deductible as an IRWE
*unless* it is established that the family member has been "otherwise
employed and suffers economic loss by reducing the number of work hours
or terminating his or her own employment in order to perform such
service".[^26] This is the case even though, at age 18, parents no
longer have a legal responsibility to care for their son or daughter
unless there is a court decision requiring it.

**Recommendation 3:** SSA should eliminate the condition that family
members must suffer financial loss for their compensation by the
beneficiary to count as IRWE if they provide attendant care and/or
transportation to/from work to a person with a disability.

### Update Income Exclusions

The four key income exclusions are: \$65 earned income exclusion; \$20
general income exclusion; \$30 infrequent/irregular earned income
exclusion; \$60 infrequent/irregular unearned income exclusion; and
\$2000/\$3000 resource limit. These amounts were not indexed when the
SSI was enacted in 1972 and have not changed despite the 1996 Disability
Advisory Panel's call to action regarding annually indexing of all work
incentives. "Raise the SSI resource limit to today's dollars" was a key
recommendation of the delegates to the Panel's Beneficiary Summit.

In March 2000, a SSA report on SSI exclusions mandated by the Ticket
legislation included a detailed range of options for updating the dollar
amounts and the estimated costs.[^27] In a recent statement, the Social
Security Advisory Board (SSAB) calculated that if the earned income and
the general income exclusions had kept pace with inflation, they would
exceed \$90 and \$290 per month, allowing disabled beneficiaries to earn
up to \$380 per month without reducing their benefits.[^28] The upcoming
increase in minimum wage means that beneficiaries will be able to work
even fewer hours before impacting their benefits. The Panel recognizes,
as did the SSAB, that changes could be expensive. It is impossible to
predict what the implications would be for other SSI provisions and
related programs such as Medicaid and State supplementation.
Nevertheless, the current exclusions are failing to meet congressional
intent because of their significantly reduced value.

For example:

-   \$65 earned income exclusion is worth less than \$15;\
    \$20 general income exclusion is worth less than \$5;

-   \$30 infrequent/irregular earned income exclusion;

-   \$60 infrequent/irregular unearned income exclusion;\
    \$3000 resource limit is worth less than \$400 value.

**Recommendation 4:** Congress should increase and index the key income
exclusion amounts and the resource limits under the SSI program.

### Update PASS and the Ticket to Work Program

Disincentives for use of PASS can be found in existing policies that
regulate the interaction of PASS and rehabilitation programs. PASS could
be used to supplement the Ticket to Work program by providing the
initial investment in employment supports, which the Ticket payments
could then maintain. Under current policies, an EN cannot receive a
Ticket outcome-only payment while the individual is receiving an SSI
cash payment resulting from an active PASS. This creates a disincentive
for ENs to support PASS use. Also, PASS funds cannot be used to pay an
EN for services.

**Recommendation 5:** SSA should approve proposed rule changes to the
Ticket to Work Program to enable Employment Networks (ENs) to receive
ticket outcome-only payments while a beneficiary is receiving a SSI cash
payment resulting from an active Plan for Achieving Self-Support (PASS).

### Update the Traditional Cost Reimbursement Program

The Traditional Cost Reimbursement Program administered by SSA with
State VR programs is based on sustained individual participant gross
earnings over SGA[^29]. While utilization of most work incentives do not
count against the agency seeking reimbursement, two specific incentives
can impact an agency receiving their reimbursement if the programs are
used by the beneficiary---BWE and PASS. These are incentives excluded by
SSA under current procedures because they are not impairment-related.
The use of either of these incentives negatively impacts the ability of
a State VR agency to claim reimbursement because earnings often fall
below SGA once BWE and PASS have been accounted for. The unintended
negative consequence is that the policy provides a disincentive to VR in
promoting the use of BWE and PASS because their claim for reimbursement
may be disallowed.

**Recommendation 6**: SSA should allow state vocational rehabilitation
agencies to receive traditional cost reimbursement if and when an
individual is receiving a SSI cash payment resulting from an active PASS
or claim of Blind Work Expenses (BWE).

## SIMPLIFY Existing Work Incentives

The maze of work incentives that exist, not only within SSA but other
federal benefit programs as well, are complex, difficult to understand,
challenging to manage and do not appear to support a common, universal
approach to work. In many cases they do not make work pay. Instead, they
increase the risk of overpayments for beneficiaries and unintended
adverse program interactions. Beneficiaries may understand how to use
the work incentives but other disincentives keep them from working.[^30]

### Align Existing Work Incentives

In general, the two types of federal government programs concerning
disability are employment support programs and income support programs.
When the term "benefits" is mentioned, many assume the reference is to
either the SSDI or SSI programs administered by SSA. Although both SSA
programs are the primary public disability-support programs in this
country, the scope and complexity of the broader benefits circumstances
for individuals with disabilities frequently extends beyond Social
Security. Other equally important income support and employment support
programs that provide benefits to individuals with disabilities include,
but are not limited to Housing and Urban Development, Temporary
Assistance for Needy Families, Veteran's Benefits and VR, Worker's
Compensation, Unemployment Insurance, Food Stamps, Energy Assistance,
and programs operating under the authority and funding connected with
the Workforce Investment Act. Adding to the complexity is the fact that,
while most programs are fully or partially funded with federal
resources, many are administered at the State and local levels.

The interplay between earnings and public benefits is unique to each
participant. Although information regarding programmatic constraints and
work incentives within public programs are consistently available to
participants, it is the diversity of program requirements that makes the
issue complex. Although the work incentive provisions in one program may
be generous, they may be limited in another, which unintentionally
negates the potential of the work incentives available in the first
program.

There are two primary ways that work incentives can be simplified.
First, SSA should conduct a careful review of their existing work
incentives and develop legislative proposals to remove the
complexity.[^31] As discussed earlier, the dollar amounts governing
specific incentives vary greatly. For example, the SGA and TWP amounts
are different. Simply adjusting and aligning existing work incentives
would go a long way toward simplifying and minimizing the amounts of
information beneficiaries need to learn and manage as they attempt to go
to work. Second, SSA and their federal partners who administer other
means-tested entitlements should evaluate their existing work incentives
and ensure they all mutually and universally support a common work
agenda. For example, a beneficiary who receives SSDI and is also
residing in HUD-sponsored housing has specific complexities to manage
when first attempting to work. When that individual decides to begin
working they are entitled to a nine-month TWP during which there are no
limits on their earning potential and impact on their cash benefit. In
comparison, for HUD, the first 12 months of earnings are subject to a
100 percent income exclusion and not counted against them in the
computation of their rent share. This requires the beneficiary to know
in great depth how earnings are treated by each public entitlement or
benefit they receive, and they must track using different time tables
the points at which their gross monthly income may be impacted. This is
one example across two programs where the work incentives provided do
not clearly align in support of a universal work agenda---there are many
more examples that could be provided, which would further illustrate the
magnitude of this problem.

SSA and their other federal partners should consider how to streamline
the work incentives and reduce program complexity. Making work
incentives easier to understand will make it easier for beneficiaries to
use them successfully in their path to work, as well as make them easier
to administer.

**Recommendation 7:** SSA should reduce the complexity and improve the
consistency of work incentives across the SSI and SSDI programs and
other federal entitlements so that they universally support work.

### Address Post-Entitlement Issues

Existing work incentive provisions demonstrate a commitment by SSA to
support the employment efforts of people with disabilities. The work
incentives, however, also illustrate how complicated the issue of
benefit levels and eligibility become when a disability beneficiary
pursues employment and experiences changes in earned income. SSA
recognizes that, while many individuals may want to return to work,
there are multiple barriers that may hinder employment; work related
overpayments are identified as one of these barriers.[^32]^,^ [^33]
Overpayments are benefits that a SSI and/or SSDI beneficiary receives
for which Social Security determines the beneficiary was not entitled.
There are two primary reasons why an overpayment situation would occur
in either program: Beneficiaries do not report information affecting
benefits or eligibility in a timely manner, and/or SSA does not process
the information affecting a beneficiary's benefits or eligibility in a
timely manner.[^34] Overpayments, or the risk of experiencing an
overpayment, can affect a beneficiary's decision to go to work, or the
decision to continue working.

SSI redeterminations and work continuing disability reviews (CDR)
represent two of SSA's main efforts towards processing the information
affecting a beneficiary's benefits or eligibility in a timely manner
helping to prevent and detect improper payments. SSI redeterminations
yield a savings of \$7 for every \$1 spent in administering them, and
work CDRs in the SSDI program save \$10 in program benefits for every
\$1 spent.[^35] SSI redeterminations assess whether a SSI recipient
continues to meet the financial eligibility requirements or has
experienced a change of circumstances that would affect his or her
monthly benefit amount.

SSA is implementing efforts to increase the number of SSI
redeterminations processed and to improve the profiles that are used to
select cases for review.[^36] In FY 2005, SSA completed 1,724,875
redeterminations, and it is estimated that this effort produced \$1.5
billion in overpayment benefits.[^37] CDRs conducted in 2005 are
estimated to yield more than \$5 billion in program savings.[^38] SSI
redeterminations and work CDRs have been identified as cost effective
efforts to detect and to help reduce overpayments in the SSI and SSDI
programs. However, due to budget cuts in FY 2006, Commissioner
Barnhart[^39] determined that workloads "such as processing retirement
and disability claims have priority over other workloads,
including...CDRs and SSI non-medical redeterminations." According to
testimony heard before the Subcommittee,[^40] the lack of resources to
conduct CDRs and SSI redeterminations will adversely impact SSA's
ability to significantly reduce overpayments.

**Recommendation 8:** SSA should establish mechanisms to monitor
post-entitlement workloads, develop performance standards (similar to
those established for initial claims in terms of processing time and
decisional accuracy), and Congress should allocate sufficient resources
to address post-entitlement workloads.

**Recommendation 9**: SSA should establish a cross-component internal
SSA Task Force on post-entitlement workload issues to identify resources
needed to perform critical program integrity activities that address
post-entitlement workloads such as processing work reports and
preventing and detecting overpayments. Publish these findings annually.

## Simplify Wage Reporting

SSI recipients are required to report changes in their income, resources
and living arrangements that may affect eligibility or payment amount.
SSA conducted wage reporting pilots for workers at risk for wage-related
overpayments to develop easier ways for recipients to report their wages
in a timely manner. Through a pilot conducted in 2003 and again in 2006,
SSA is using telephone voice recognition/touchtone technology as a means
to improve wage and income reporting by determining if, given an easily
accessible automated format, individuals will increase compliance with
reporting responsibilities. The initial SSI Monthly Wage Reporting
Pilot[^41] was conducted in 2003. Evaluation of the pilot[^42] [^43]
determined that the wage reports were much more accurate, and the use of
a system like this could prevent approximately \$200 in annual SSI
overpayments for every person who reported wages monthly. Further, it
was estimated that if 10,000 beneficiaries participated, \$2 million in
overpayments would be prevented per year. This pilot required a password
authentication process, which half of the participants found difficult
to use. As a result, SSA made software changes and, in January,
2006,[^44]^,^ [^45]^,^ [^46] began a new telephone wage reporting pilot
using a knowledge-based authentication process. No data on the impact of
the new pilot was found. In its FY 2008 budget,[^47] reference is made
to "expanded telephone wage reporting" as one way that SSA is developing
easier ways for SSI recipients to report their wages.

**Recommendation 10:** SSA should continue to expand systems for
reporting wages electronically, ensuring that concurrent beneficiaries
have a single point of earnings reporting and that timely receipts are
sent to all beneficiaries.[^48]

## EDUCATE Beneficiaries and their Supporters Regarding Work and Use of Work Incentives 

There are a myriad of stakeholders involved in the return-to-work
process, including the beneficiary, their family members, service
providers, and other entities. Going to work is a multi-pronged process
that should be focused on ensuring that beneficiaries interested in
going to work have access to customized, responsive, timely, relevant
and accurate information and services to support their efforts. These
efforts need to include SSA field personnel, employment networks and
other community providers, educators, and beneficiaries in order to
expand the use of work incentives. Not only should an emphasis be placed
on continuing to increase the awareness of beneficiaries regarding work
incentives, but efforts need to be focused on educating families,
service providers, and SSA as well. This is particularly important to
ensure that stakeholders stay informed regarding return-to-work efforts
of beneficiaries, that SSA effectively administers the programs, and
that the collection, organization and use of data about work incentive
utilization impacts decision-making.

### Expand Current Work Incentives Marketing and Outreach

SSA's Strategic Plan for 2006-2011 recognizes the importance of
increasing awareness of beneficiaries of opportunities to achieve
greater financial independence through employment. As part of the
Strategic Plan and in support of the President's New Freedom Initiative,
SSA details three specific objectives: 1. Provide improved marketing
materials to beneficiaries with disabilities to increase awareness of
the Ticket to Work Program; 2. Make beneficiary planning services more
available and useable for beneficiaries to increase their awareness of
return to work options; and 3. Focus on the improvement and expansion of
the Agency's partnerships with other public and private community-based
organizations.[^49] Title I, subtitle C of the Ticket Act authorizes
important strategies to inform, assist, and protect beneficiaries
interested in pursuing work by establishing the Benefits Planning,
Assistance and Outreach (BPAO) program (currently known as the Work
Incentives Planning and Assistance (WIPA) program), and the Protection
and Advocacy for Beneficiaries of Social Security (PABSS) program. The
Act also authorized that SSA create an internal corps of work incentive
specialists.

In the SSA Strategic Plan, there is no specific mention of the WIPA or
PABSS programs as a method to ensure that individuals with disabilities
who want to work have the opportunity to do so or even to increase
awareness of opportunities to achieved "greater financial independence
through employment." No measures are offered as to how SSA will track
their level of achievement of these proposed long-term outcomes through
internal staff capacity or external (WIPA and PABSS) program
relationships.

The challenges of marketing and outreach to beneficiaries to provide
accurate, consistent information and to attract a new level of interest
and use of available work incentives are formidable. Challenges
identified by diverse stakeholders include; inadequate resource
allocation to support either the internal AWIC infrastructure at SSA or
the external support systems of WIPA and PABSS programs, inadequate
quality assurance mechanisms to continue to evaluate and improve timely
and effective service delivery systems, and a continuing need to improve
coordination and clarify complimentary roles and responsibilities among
these specialists (AWICs, WILs, WIPA, and PABSS) and other relevant
community partner agencies and organizations.

The Ticket Act offers individual beneficiaries a new opportunity to
access a variety of supports and work incentives that will change
expectations about life-long dependence on cash benefits for
subsistence. Without a coordinated, comprehensive outreach strategy that
focuses not just on the Ticket to Work Program but also the range of
work incentive options, millions of beneficiaries will remain afraid to
attempt to work and increase income.

The Panel continues to recommend a broad marketing and outreach strategy
addressing these challenges. The following sections detail our
recommendations.

### Work Incentives Planning and Assistance

SSA established 116 BPAO[^50] programs in all 50 states and five
territories. The purpose of the BPAO was to provide SSI and/or SSDI
beneficiaries accurate information about work incentives and to help
make informed choices regarding work and potential impact of earnings on
their benefit status. BPAO programs nationwide were administered by
State VR agencies, centers for independent living and other
community-based organizations. Data were reported on activities from
over 500 benefit specialists in the 116 projects to a centralized data
management system at Virginia Commonwealth University. The BPAO program
operated from 2000-2006 and served over 252,000 beneficiaries
nationwide.[^51] The BPAO program served individuals across the full
range of age and disability type. Over 84 percent of individuals served
were between ages 22 and 59.[^52] One-third of the individuals served
identified psychiatric or emotional disability as their primary
disability.[^53] Of individuals provided services, there was equal
representation of women (50.2 percent) and men (49.8 percent).[^54] The
range of services provided included information and referral (90.9
percent), problem solving and advocacy (31.9 percent), benefits analysis
and advisement (43.4 percent), benefit support planning (13.9 percent),
and benefits management (5.3 percent).[^55] Work incentives recommended
most frequently for access and use included Ticket to Work Program (53.6
percent), extended period of eligibility (EPE) (49.9 percent), 1619(b)
(31.9 percent), extended Medicare coverage for SSDI beneficiaries (28.9
percent), and Medicaid Buy-In (19.9 percent).

According to a customer satisfaction survey of 1,764 beneficiaries who
received services from a BPAO provider, 89 percent of participants rated
the services provided as excellent, very good, or good.[^56] Before
receiving counseling, 28 percent of participants indicated that they
were working. Forty-seven percent indicated that they were working after
contact with the BPAO, an increase of 19 percent.[^57] However,
according to beneficiaries who brought concerns to the Panel's
attention, there were still not enough benefits planners, with some
people waiting weeks for appointments. Because of the size of some
geographic areas, some beneficiaries did not have any real access to
planners to address their documented needs. Others complained that
benefit specialists could not answer their questions or provided
inaccurate information.[^58] In response to concerns about the
presentation of inaccurate information by some BPAO providers, the Panel
sent a letter in February 2005 to the Commissioner of SSA that
recommended the development of minimum standards for effective service
delivery and minimum qualifications for benefit specialists.

The Panel also suggested to SSA that all BPAO programs have agreements
with ENs and Disability Program Navigators in their geographic catchment
area to better assist unserved and underserved populations. Increased
collaboration between SSA field offices and the BPAO programs would also
improve service to beneficiaries through joint problem solving.

In September 2006, SSA awarded 99 WIPA program cooperative agreements to
a variety of community-based organizations nationwide. Of the 99
awardees, 84 previously served as BPAO organizations.[^59] The change in
name from BPAO to WIPA, as explained by SSA, was to move beyond
providing high quality information to individuals with disabilities and
to begin connecting beneficiaries to the employment supports they need
so that the work incentives information they receive is put into action.
The staff members of the WIPA projects are termed Community Work
Incentive Coordinators (CWICs). The shift is from general information
dissemination and outreach to strategic and intentional outreach with
increased emphasis on practice and utilization that results in enhanced
employment outcomes.[^60] There are no performance standards for WIPA
projects.

In October 2006, SSA published in the Federal Register a request for
applications for WIPA projects in the geographic areas not covered by
the first set of awards. In July 2007, SSA awarded a contract for a
national training and technical assistance provider to WIPA projects.
Between October 2006 and July 2007, SSA held monthly teleconferences
with all WIPA projects and contracted for interim training and technical
assistance.

### Protection and Advocacy for Beneficiaries of Social Security

In April 2001, SSA established the national system of services for the
protection and advocacy of beneficiaries. The Ticket Act defined the
role of agencies providing PABSS as "providing information and advice
about obtaining vocational rehabilitation and employment services and
advocacy or other services that a disabled beneficiary may need to
secure or regain gainful employment." PABSS grants were made to 57
states, territories and Native American protection and advocacy
agencies. Since December 2001, PABSS programs provided information and
advocacy services to over 9,500 beneficiaries. Since 2003 through the
end of fiscal year 2006, PABSS programs had documented over 14,003
client concerns across 13 major categories requiring individual
assistance. The top four areas of concern requiring advocacy and
assistance were issues with Social Security overpayments (36 percent),
vocational rehabilitation (20 percent), benefits planning (12 percent)
and employment discrimination (10 percent). Services were provided to
individuals with disabilities across the full range of age and
disability type. PABSS program assistance resulted in outcomes such as
new beneficiary knowledge concerning rights, resolution of overpayment
situations, improved access to services from State VR agencies or ENs,
and employment for individuals.[^61] The Panel has heard from diverse
stakeholders that the funding level of seven million dollars nationwide
is inadequate to meet demand.[^62]

**Recommendation 11:** SSA and Congress should strengthen both the Work
Incentives Planning and Assistance (WIPA) and Protection and Advocacy
for Beneficiaries of Social Security (PABSS) networks by establishing
performance standards, adjusting funding levels and resources to levels
necessary to achieve the desired results, and invest in ongoing training
and technical assistance that improves the accuracy of information and
quality of services provided with particular attention to underserved
populations and valued employment outcomes.

### SSA Internal Corps of Work Incentive Specialists

Prior to the implementation of the Ticket Act, SSA recognized the
importance of marketing and outreach to beneficiaries regarding existing
work incentives. From July 2000 -- September 2001, SSA piloted new field
positions titled Employment Support Representatives (ESRs) to serve as
work incentive specialists to improve access to information for
beneficiaries with disabilities who wanted to work. Thirty-two ESRs were
assigned to serve 54 specific cities. ESRs were trained to be experts on
all Title II and Title XVI employment support programs.

An evaluation of the pilot program identified the importance of locating
ESRs on-site in SSA field offices to provide expert assistance to
beneficiaries in concert with other SSA field staff. In 2002, a
Strategic Partnerships and Outreach Team was created for the first time
at SSA as part of SSA's Office of Employment Support Programs Division
of Employment Policy. The purpose of the team was to develop a more
comprehensive approach to outreach and public information focused on
interdepartmental (federal, state, and local partners), employers, and
advocacy group relationships.

In 2004, SSA established the position of AWICs that replaced the ESR
pilot with permanent full time positions. AWICs were placed in 54 SSA
field offices nationwide to outreach to beneficiaries and provide timely
and accurate information on work incentives. In addition to AWIC's other
responsibilities, each AWIC was responsible for training WILs in each
field office. There were 1,335 individuals designated and trained as
WILs to provide enhanced services to beneficiaries in all SSA field
offices nationwide. The WILs' responsibilities were to complement the
role of AWICs with focused attention on assistance to other personnel in
SSA's field offices regarding SSA's employment support programs and
being directly involved with high profile individual cases that were the
most complex and challenging. However, the WILs' responsibilities were
in addition to other regular duties in the field office. On a quarterly
basis, SSA has reported to the Panel on the training and outreach
activities of AWICs and WILs nationwide. Despite the presentation of
meetings attended and trainings offered within and outside SSA field
offices to different target audiences, there has not been made public
any type of performance-based indicators to try to objectively evaluate
either the individual performance of an AWIC or a WIL in a specific
geographic area or to collectively gauge the impact of the positions
nationwide on improved customer satisfaction or change in employment
status of beneficiaries with the use of specific work incentives.[^63]
Beneficiaries at Panel meetings as recently as November 2006 continue to
report having received inaccurate information from SSA staff in field
offices and that there are an inadequate number of AWICs able to access
timely and consistent information that supports informed beneficiary
decisions about work.

Because AWICS and WILS are under the jurisdiction of SSA's Office of
Operations, resources tend to be redirected to other operational
activity. SSA should clarify the results required to avoid long wait
times and to process post-entitlement actions in a timely manner. In
addition, SSA should ensure that adequate resources are devoted to
achieve those results. This includes setting clear standards for hiring,
continuing education, and skill and knowledge levels for AWICs and WILs,
and establishing standards for service delivery to underserved
populations. One way that this might be accomplished would be to require
collaborative agreements between WIPA programs and the workforce
development system. The SSAB has made repeated recommendations with the
regard to the need for adequate resources in these areas.

**Recommendation 12:** SSA should identify clear, objective performance
standards and indicators to evaluate the activities and impact of Area
Work Incentives Coordinators (AWICs) and Work Incentive Liaisons (WILs),
and collect, analyze, document, and publish evidence annually (by SSA
region and system-wide) of customer satisfaction, improved employment
outcomes, and advanced self-sufficiency.

### SSA's Cadre of PASS Specialists

Social Security's PASS was enacted by Congress as a part of the original
1972 SSI legislation. PASS is self-determined, and is one of very few
tools that can provide critical supports to assist individuals in
achieving self sufficiency. Despite the enormous potential of PASS, the
desire of many individuals with disabilities to work, and several policy
and legislative changes to the program, PASS is currently significantly
underutilized. Figure 1 below shows the number of PASS applications
nationally in December of each year, from 1990-2006.[^64]

Figure 1. PASS Utilization

![](media/image1.wmf)

Through the work of the Adequacy of Incentives Advisory Group, several
critical recommendations were provided in 2004[^65] to address
disincentives and barriers in using PASS. These included: allowing for
the use of PASS and Ticket payments at the same time; providing outreach
to targeted groups of beneficiaries who could benefit from the use of
PASS and Ticket; partnering with vocational providers to promote PASS as
an option; and, partnering with traditional financial institutions to
incorporate PASS as collateral or assist in financing return-to-work
efforts.

Enhancements needed for the PASS program were also identified as
critical by beneficiaries at the February 2007 beneficiary summit.
During the summit, beneficiaries drew from their own experiences to
provide recommendations to the PASS work incentive. Those
recommendations included: providing Federal or state matching funds,
allowing a successful PASS to continue after its scheduled end date in
order to promote greater self-sufficiency and to expand on a business
opportunity, better communication between the PASS cadre and recipients
during the application (appeal/denial) process, more trained PASS
specialists available, better communication with youth about work
incentives including PASS, and simplification and streamlining of the
PASS application forms and process.

Current active approved PASS applications total 1,583 (December
2006),[^66] averaging 30.44 PASS applications per state, and outlying
areas. Some PASS specialists and offices cover one state or one area of
one state. Other PASS specialists cover entire regions of the country.

***PASS Workloads***---There is currently no publicly available workload
information on the number of PASS applications submitted and approved or
on processing (wait) times. However, based on subjective experiences,
there appears to be a wide variance in PASS office work load. Based on
statistics presented earlier, PASS approvals vary widely.

***PASS Specialist Training/Outreach***---While SSA engaged in an active
national training campaign for PASS specialists in the spring of 1996,
it is not clear whether SSA continues with national training. The Panel
believes that PASS use would increase significantly with an enhanced
focus on PASS outreach.

**Recommendation 13:** SSA should collect workload information on the
number of PASS applications submitted and approved, including the
processing (wait) time by state, and publish this information annually
in SSA's *SSI Disabled Recipients Who Work* report. Provide high quality
training and support, and fiscal resources for the effective
administration and outreach of the PASS program. Recruit, develop, and
support PASS specialists (travel, technology, et al).

### Improve Management by Data Practices

In the same manner as its annual reporting for the SSI program, SSA
should provide annual data reporting and analysis on SSDI work incentive
utilization, including state-to-state variation. This report should also
include the experiences of Disabled Adult Children and concurrent
beneficiaries.  In general, SSA has reported SSI work incentive
utilization for many years. However, it has not reported the experiences
of concurrent beneficiaries. According to a December 2005 analysis by
Jensen and Silverstein, \"Gradual Reduction Choice Option and Related
Policy Projects", the percentage of the 1.2 million concurrent
beneficiaries with earnings is significantly higher than the percentage
of all SSI recipients who work.[^67]

 

As earnings of SSDI beneficiaries are reported using e-Work, the
Panel\'s understanding is that work incentive utilization information is
being collected.  As mentioned earlier in the report, analysis and
reporting of work incentive utilization data will provide insight into
the performance of the SSDI and SSI programs with regard to returning
beneficiaries to work. This could provide SSA with a better
understanding of how to support local AWICs in encouraging other SSA
staff, CWICs, community agencies and beneficiaries/recipients to more
fully utilize work incentives.

**Recommendation 14:** SSA should improve reporting of data and analysis
pertaining to SSDI (including Disabled Adult Children and concurrent
SSDI/SSI beneficiaries) and issue an annual report comparable to SSA's
*SSI Disabled Recipients Who Work* report*.*

**Recommendation 15**: SSA should establish a performance management and
return to work tracking system, providing benchmarks for each state, and
track utilization over time as part of a continuous quality improvement
plan. []{.mark}

### Improve Beneficiary Communication

Delegates to the Panel's 2007 beneficiary summit overwhelmingly
supported making SSA policies and procedures easier to find and
understand, as well as making them more accessible. This would include
using plain language (minimizing "SSA Speak"), explaining all acronyms,
and ensuring that all communication is correct and accurately
translated. All material should be reviewed by a diverse ethnic and
disability community, perhaps by these delegates or a similar group.
This would also include improving SSA's 1-800 \# service by updating it
to a 21^st^ century system that is easy to use and responsive, as well
as utilizing long-distance learning and training technology.

**Recommendation 16**: SSA should empower beneficiaries by making SSA
policies and procedures easier to understand and accessible, e.g.
minimize "SSA Speak" and use plain language all can understand.

**Recommendation 17**: SSA should ensure that the availability and
relevance of work incentives are frequently included in communications
received by beneficiaries from SSA and the information is available in
alternative formats, and languages (e.g. Braille, large print, video
foreign/sign languages, etc).

With the addition of benefits and work incentive specialists, first
through the BPAO, now the WIPA, program,[^68] SSA has provided one way
for SSI and SSDI beneficiaries to become more aware of the impact of
work on their benefits. These projects represent a significant resource
available to beneficiaries for information and guidance on work and
disability benefit issues, which should include timely wage reporting
and dealing with the issues that lead to overpayment problems. This
network is limited, however, in their ability to provide the information
necessary to ensure that all beneficiaries are aware of earnings
reporting requirements, and SSA should explore other approaches to
expanding beneficiary understanding in this area.

**Recommendation 18**: SSA should increase beneficiary awareness of
earnings reporting requirements including the waiver process for
overpayments, and promote greater self-efficacy.

# Conclusion

These recommendations are intended to support the Panel's belief that,
if existing work incentives are updated and simplified, and stakeholders
are educated regarding work incentive availability and use, expanded
opportunities and conditions for supporting work will be created.

This report does not include recommendations on several key
return-to-work initiatives, which include, but are not limited to:* *

 

**Ticket Regulations**---SSA's implementation of the revised final
Ticket regulations are expected to revitalize the Ticket program by
recognizing the multi-step nature of returning to work and offering more
frequent and earlier payments for ENs. It is reasonable to assume the
final rules will generate significant beneficiary and EN participation
in the program. The new rules are expected to be published early next
year. The Panel looks forward to providing comments shortly on SSA's
Notice of Proposed Rulemaking, which is intended to simplify and improve
the definition of using a ticket and related requirements for measuring
timely progress toward self-supporting employment.

**WIPA Program**---Implementation of the new WIPA program is expected to
play a significant role in providing proactive pre-employment assistance
that supports beneficiaries in making an informed choice to work. As
mentioned earlier, SSA recently concluded that BPAO programs, which had
been operating for six years and were doing an excellent job providing
high quality information to beneficiaries regarding the impact of
earnings on their benefit status, but the BPAOs fell short of assisting
them in connecting to the employment they needed to use the work
incentives effectively.

**State Medicaid Buy-In Programs**---Implementation of Medicaid Buy-In
programs for working individuals with disabilities are still underway at
this time. As mentioned earlier, to date, there are 38 states that have
implemented a Buy-In program; however, only 22 of them have been
operating a program for five years or more. In addition, each state's
Medicaid Buy-In program is unique. There is very wide variation in the
eligibility criteria, premiums charged, and unearned income eligibility
limits, all of which impact the number of participants. According to
beneficiary testimony to the Panel, the lack of awareness and
understanding of eligibility criteria for a state's Buy-In program is
pervasive with rehabilitation counselors, SSA field office staff and
also local Medicaid service coordinators.[^69]

The Medicaid Infrastructure Grant (MIG) program is an eleven-year
program, which is expected to end in the next few years. Not later than
October 1, 2010, the Secretary of the Department of Health and Human
Services, in consultation with the Panel, is required to submit a
recommendation to the Congress regarding whether the MIG program should
be continued after FY 2011.[^70] The MIG funding (\$150 million for the
first 5 years, with no state or local matching required) is intended to
facilitate enhancements to State Medicaid programs, to promote linkages
between Medicaid and other employment-related service agencies, and to
develop a comprehensive system of employments supports for people with
disabilities.[^71]

**Demonstration to Maintain Independence and Employment**--- The
Demonstration to Maintain Independence and Employment is a grant program
authorized by the Ticket Act and administered by Centers for Medicare
and Medicaid Services (CMS). It provides funds to states for developing,
implementing, and evaluating interventions intended to improve health
care coverage and employment services for working adults with conditions
that are potentially disabling, such as diabetes. The goal is to
increase the likelihood of sustained employment. The program will be
continuing over the next two years, and the program's contractor will
begin completing annual interim reports and will submit a final report
to CMS in 2010 on the national findings.[^72]

All of these programs are critical to the success of work incentive
implementation, and we anticipate making recommendations that relate to
these programs in our final report.

The Panel believes that the Ticket legislation, other work incentives,
and ongoing programs continue to be a major challenge for SSA and CMS to
administer.

# References {#references .Closing}

Gallagher, Tanya M. Enhancing Earnings and Income Through
Self-Determination for AOI Targeted Groups, Adequacy of Incentives (AOI)
Advisory Group, September 2004. Report prepared for the Social Security
Administration. Disability Research Institute: University of Illinois at
Urbana-Champaign**.**
<http://www.dri.uiuc.edu/research/p03-08h/AOIFinal.pdf>

Golden, T.P., Zeitzer, I. and Bruyere, S.M. Evaluation and Future
Prospects of US Return to Work Policies for Social Security
Beneficiaries. Korean Journal on Disability and Employment. 2007, pp.
59, 53-90.

Jensen, Allen and Silverstein, Robert (2005). Gradual Reduction Choice
Option and Related Policy Proposals. The research was developed as part
of a research project funded through a sub-award from the Disability
Research Institute (DRI) at the University of Illinois at
Urbana-Champaign.
<http://www.dri.uiuc.edu/research/p05-12h/gradualreduction.pdf>

Livermore, G. A. (2003). Wage Reporting and Earnings-Related
Overpayments in the Social Security Disability Programs: Status,
Implications, and Suggestions for Improvements. Report prepared for the
Ticket to Work Advisory and Work Incentives Advisory Panel. Cornell
Center for Policy Research: Washington, DC.
<http://www.ssa.gov/work/panel/panel_documents/briefingpapers.html>

National Academy of Social Insurance. Balancing Security and
Opportunity: The Challenge of Disability Income Policy. 1996.
http://www.nasi.org/usr_doc/Balancing_Summary.pdf

National Disability Rights Network. Protection and Advocacy for
Beneficiaries of Social Security FY 2006 Final Report, March 2007.

Social Security Administration. Kearney, John R., 2007, Social Security
and the \"D\" in OASDI: The History of a Federal Program Insuring
Earners Against Disability, Social Security Bulletin, Vol. 66, No. 3,
August 2006. Washington, DC.
<http://www.ssa.gov/policy/docs/ssb/v66n3/v66n3p1.html>

Social Security Administration. Muller, L. Scott, 1992, Disability
Beneficiaries Who Work and Their Experience Under Program Work
Incentives, Social Security Bulletin Vol.55, No.2:2-19, April 1992.
Washington, DC.

Social Security Administration. Hennessey, John C. and L. Scott Muller
1994, Work Efforts of Disabled-Worker Beneficiaries: Preliminary
Findings from the New Beneficiary Follow-up Survey, Social Security
Bulletin Vol. 57, No.3:42-51, July 2004. Washington, DC.

Social Security Administration. Hennessey, John C. and L. Scott Muller
1995,The Effect of Vocational Rehabilitation and Work Incentives on
Helping the Disabled-Worker Beneficiary Back to Work, Social Security
Bulletin Vol. 58, No.1:15-28, January 1995. Washington, DC.
<http://www.ssa.gov/policy/docs/ssb/v58n1/v58n1p15.pdf>

Social Security Administration. Annual Report of the SSI Program. May
2006. Office of the Chief Actuary. Baltimore, MD.

Social Security Administration. SSI Disabled Recipients Who Work,
Reports from

1990 -- 2006. Washington, DC. <http://www.ssa.gov/policy/>

Social Security Administration. Simplifying the Supplemental Security
Income Program: Challenges and Opportunities, Office of Policy, December
2000. Washington, DC.
<http://www.ssa.gov/policy/programs/SSI/simplification/simplification.pdf>

Social Security Administration. Report on Supplemental Security Income:
Income and Resource Exclusions and Disability Insurance Earnings-Related
Provisions, March 2000. Office of Policy. Washington, DC.

Social Security Administration. Program Operations Manual System (POMS)
DI 10520.001 Impairment-Related Work Expenses (IRWE), DI 10520.010
Definitions. <http://www.ssa.gov/regulations>

Social Security Administration. Vocational Rehabilitation Provider's
Handbook, Baltimore, MD.
<http://www.ssa.gov/work/ServiceProviders/providers.html>

Social Security Administration. Strategic Plan FY 2006 -- FY 2011.
Baltimore, MD. <http://www.ssa.gov/strategicplan.html>.

Social Security Administration. Social Security Administration Budget,
Justification of Estimates for Appropriations Committees FY 2008.
Baltimore, MD.

<http://www.socialsecurity.gov/budget/2008cjapp508.pdf>

Social Security Administration. Social Security Administration Budget,
FY 2008 and Revised Final FY 2007 APP, Appendix A: Service -- Improve
Service Through Technology (1.3 a-g) Means/Strategies p.51. Baltimore,
MD. <http://www.socialsecurity.gov/budget/2008cjapp508.pdf>

Social Security Administration. Performance and Accountability Report
for Fiscal Year 2004. Baltimore, MD.
<http://www.ssa.gov/finance/fy04_accountability.html>

Social Security Administration. Social Security Quarterly Update,
November 2006. Report prepared for the Ticket to Work and Work
Incentives Advisory Panel.

Social Security Advisory Board. Statement on the Supplemental Security
Income Program, May 2005, p.8. Washington, DC.
<http://www.ssab.gov/documents/2005SSIReport.pdf>

Social Security Advisory Board. The Social Security Definition of
Disability, October 2003. Washington, DC.

<http://www.ssab.gov/documents/SocialSecurityDefinitionOfDisability_002.pdf>

Ticket to Work and Work Incentives Advisory Panel. Annual Report to the
President and Congress, Year Four, July 2004, p17. Washington, DC.
<http://www.ssa.gov/work/panel/panel_documents/reports.html>

Ticket to Work and Work Incentives Advisory Panel. Annual Report to the
President and Congress, Year Five. December 2005. Washington, DC.
<http://www.ssa.gov/work/panel/panel_documents/reports.html>

Ticket to Work and Work Incentives Advisory Panel. Annual Report to the
President and Congress, Year Seven. March 2007. Washington, DC.
<http://www.ssa.gov/work/panel/panel_documents/reports.html>

Ticket to Work and Work Incentives Advisory Panel.Quarterly Meetings.
Minutes: 2004, 2005, 2006. Public Comment. Washington, DC.
<http://www.ssa.gov/work/panel/meeting_information/minutes.html>

Ticket to Work and Work Incentives Improvement Act of 1999, Public Law
106-170; Sec. 203 (f).
<http://frwebgate.access.gpo.gov/cgiin/getdoc.cgi?dbname=106_cong_public_laws&docid=f:publ170.106>

U.S. Department of Health and Human Services, 1986 Disability Advisory
Council, "Final Report." 1988, Baltimore, MD.

U.S. Department of Health and Human Services. The Centers for Medicare
and Medicaid Services. Funding Opportunity Number HHS-2008-CMS-MIG-0001.
ww.cms.hhs.gov/TWWIA/downloads/2008_MIG_Solicitation.pdf

U.S. General Accounting Office. 2002. SSA Disability: Enhanced
Procedures and Guidance Could Improve Service and Reduce Overpayments to
Concurrent Beneficiaries. GAO-02-802. Washington, DC: September 2002.
<http://www.gao.gov/new.items/d02802.pdf>

U.S. Government Printing Office. Federal Register. Agency Information
Collection Activities: Proposed Request, Vol. 70 No. 172, September 7,
2005, p. 53266. <http://www.gpoaccess.gov/fr/index.html>

U.S. Government Printing Office. Federal Register. Continuation of
Benefit Payments to Certain Individuals Who Are Participating in a
Program of Vocational Rehabilitation Services, Employment Services, or
Other Support Services, Final Rule, vol. 70 No. 121, June 24, 2005.

<http://www.gpoaccess.gov/fr/index.html>

U.S. Government Printing Office. Federal Register. Cooperative
Agreements for Work Incentives Planning and Assistance Projects: Program
Announcement No. SSA-OESP-06-1, Vol. 71 No. 94, May 16, 2006, pp.
28401-28413. <http://www.gpoaccess.gov/fr/index.html>

U.S. Government Printing Office. U.S. House of Representatives.
Committee on Ways and Means. Social Security Service Delivery
Challenges: Hearing before the Subcommittee on Social Security of the
House of Representatives. 109th Congress, 2nd Session, May 2006.
Washington, DC. <http://www.gpoaccess.gov/chearings/index.html>

U.S. Office of Management and Budget. Budget of the United States
Government, FY 2007 and FY 2008. <http://www.whitehouse.gov/omb>

Virginia Commonwealth University. Rehabilitation Research & Training
Center on Workplace Supports. Benefits Assistance Resource Center. BPAO
National General Report.
<http://www.vcu-barc.org/NatReport/CurrentReport.html>

# Appendix A \-- The Panel {#appendix-a----the-panel .Closing}

**Members of the Panel**

Twelve individuals serve on the Panel: four appointed by the President,
four by the Senate and four by the House of Representatives. The
appointees represent a cross-section of experience and expert knowledge
as recipients, providers, veterans, employers and employees in the
fields of employment services, vocational rehabilitation and other
disability-related support services. Most are individuals with
disabilities or their representatives. Several have personal experience
as beneficiaries of Social Security.

**Berthy de la Rosa Aponte -- Chair,** Berthy De La Rosa-Aponte has been
a disability advocate for over 20 years. She resides in Florida with her
husband Milton Aponte and Luz Elena (Lucy), the youngest of her three
children who has significant developmental disabilities. Mrs. De La
Rosa-Aponte holds a Masters of Arts Degree and is a naturalized US
citizen, born in Colombia, South America. Her professional experience
has been in the social service and educational fields. She has served on
numerous state and local boards. Currently, Mrs. De La Rosa-Aponte
serves as a member of the National Advisory Board on Improving
Healthcare Services for Seniors and People With Disabilities for the
AMERIGROUP Corporation. In addition, she serves as Vice Chair and for
the University of South Florida, University Center of Excellence For
People with Developmental Disabilities and as a member of the local
Memorial Hospital System Special Needs Advisory Board. Ms. De La Rosa
Aponte was appointed to serve on the Ticket to Work and Work Incentives
Advisory Panel by the House to serve a 4-year term ending in 2007 and
designated by the President to chair the Panel for a 4-year term ending
in 2008.

**Cheryl Bates-Harris --** Cheryl Bates-Harris, from Rising Sun,
Maryland, is a Senior Disability Advocacy Specialist for the National
Disability Rights Network, where she has over 20 years experience and
expertise working with people with disabilities. She has an in-depth
knowledge of cross disability issues and continues to focus on
employment issues of people with disabilities, including Vocational
Rehabilitation, Social Security and Return to Work, TANF, and other work
programs that impact people with disabilities, including DOL One-Stops.
Since the passage of Ticket to Work and Work Incentive Improvement Act
she has conducted national training on TWWIIA and Vocational
Rehabilitation Services and has conducted extensive training on the
intersection issues of the Ticket to Work with state vocational rehab
services. Cheryl currently co-chairs the CCD Work Incentives
Implementation task force and CCD Employment and Training task force and
is an active member of the CCD Social Security Task Force. The President
appointed her to serve on the Panel in 2004.

**Katie Beckett --** Katie Beckett is 29 years old and currently working
towards a graduate degree studying writing for children and young
adults. Katie has been an advocate all her life and has done several
presentations before various audiences and Congressional committees. She
is also a HUGE professional wrestling fan, as well as a fan of
basketball---especially the WNBA and college hoops and ALL football
teams. She has traveled quite a bit to Washington DC to speak before
policymakers about kids with special health care needs. She is a
co-founder of Kids as Self-Advocates (KASA) and former co-chair of the
KASA Board. Currently, Ms. Beckett is working as a volunteer Data Entry
Specialist with Senator Hillary Clinton's presidential campaign in the
Cedar Rapids office. The Senate appointed her to serve on the Panel
beginning in 2002.

**Libby Child --** Libby Child was Manager, Integrated Disability
Management Services for Steelcase, Inc for 25 years before resigning in
December 2002 to pursue consulting, writing endeavors and teaching
workers' compensation classes for Michigan State University. At
Steelcase, she was responsible for the fully integrated claims system
where workers\' compensation, short-term and long-term disability,
permanent and total disability and compliance with the Family Medical
Leave Act were fully coordinated and managed in one integrated unit.
Since 1990, Ms. Child has lectured extensively throughout the United
States on the topics of workers\' compensation and integrated disability
management and continues to serve on many disability related boards,
commissions and councils nationally and in the state of Michigan,
representing employers' interests. Ms. Child is also a member of the
National Academy of Social Insurance. She resides in Grand Rapids, MI.
She was appointed to the Panel by the President to serve a term starting
January 2003.

**J. Russell Doumas --** Russ Doumas has more than 34 years of
experience serving individuals with disabilities. He is the Chief
Executive Officer for TESH, a community-based non-profit rehabilitation
organization serving children and adults in Coeur d'Alene, Idaho. Prior
to July 2005, he was the President of Job Point in Columbia, Missouri --
a position he held since 1982. His responsibilities included operating a
comprehensive employment and training center serving persons with
disabilities and the economically disadvantaged. For ten years prior to
that he was the Director of Metro Industrial Services in Lexington,
Kentucky. Currently, he serves on the Idaho State Rehabilitation Council
and as Secretary/Treasurer of the Idaho Association of Community
Rehabilitation Programs. Mr. Doumas holds a MA in Rehabilitation
Administration from the University of San Francisco and a BA in
Political Science from the University of Kentucky. The House of
Representatives appointed him to the Panel in 2005.

**Loretta Goff --** Loretta Goff is a Registered Nurse with a BS in
Health Care Administration, a MS in Community Mental Health Counseling
and extensive experience with the New York State Office of Mental
Hygiene and Office of Mental Retardation and Developmental Disabilities.
In 2003, she retired form the New York State Commision on Quality of
Care for the Mentally Disabled after 25 years of service as a Protection
and Advocacy Specialist, where she provided oversight and advocacy for
individuals with disabilities in New York State. Since retirement, she
has served as a Compliance Evaluator in the Wyatt Settlement Agreement
in Alabama, a member of the New York State Protection and Advocacy for
Individuals with Mental Illness Advisory Council and has been recently
appointed to the New York State Commission on Quality Care and Advocacy
for Persons with Disabilities Advisory Council. She was appointed to the
Panel by the Senate in 2005. 

**Thomas Golden --** Thomas P. Golden is on faculty at Cornell
University and serves as the Associate Director of the Employment and
Disability Institute in the ILR School. Since joining faculty in 1991,
he has directed several state and national initiatives focusing on
training, technical assistance, and organizational development related
to work incentives, transition systems change and employment for people
with disabilities. Thomas is a founding member of the National
Association of Benefits and Work Incentive Specialists and a member of
the National Academy on Social Insurance. He currently serves on the
Board of the U.S. International Disabilities Council, is a Trustee at
Eastern Nazarene College in Boston, MA and is the incoming Chair of the
New York State Rehabilitation Council. Thomas was originally appointed
to the Ticket to Work Panel by President William Jefferson Clinton for a
two-year term and re-appointed twice by the U.S. Senate.

**Frances Gracechild** **--** When Frances Gracechild joined the
disability rights movement as Executive Director of Resources for
Independent Living in 1981; she came with a rich and diverse background
in civil rights advocacy. Frances is passionately interested in the root
causes of poverty. Both as an AFDC social worker and later as a teacher
in the barrio of San Bernardino she came to appreciate the day to day
struggle of those left out of the American dream. Through her own
struggle with the disabling effects of childhood polio, Frances
identifies with other people reaching beyond oppressive stereotypes to
live a life of dignity and purpose. Frances is a Congressional appointee
to the Panel and has served since 2000.

**Andrew J. Imparato --** President, CEO, American Association of People
With Disabilities (AAPD). Andy has extensive experience in public policy
work on behalf of people with disabilities. He has served as General
Counsel and Director of Policy with the National Council on Disability,
as attorney-advisor to Commissioner Paul Steven Miller at the U.S. Equal
Employment Opportunity Commission, and as Counsel to the U.S. Senate
Sub-committee on Disability Policy, chaired by Senator Tom Harkin of
Iowa. He graduated with distinction from Stanford Law School and
received his undergraduate degree summa cum laude from Yale. He is a
member of the Massachusetts Bar Association. He was appointed as
President and CEO of AAPD in November of 1999. He is nationally known as
a speaker and author on disability issues particularly for his work to
dispel myths about people with mental illness. The Senate re-appointed
him to serve a 4-year term ending in 2008.

**David Miller --** Mr. Miller is the Chief Compliance officer for
Communication Services for the Deaf (CSD) in Sioux Falls, SD. He is
responsible for goal setting, organizational accreditation, quality
assurance, performance management and policy compliance. CSD provides
telecommunication, interpreting, educational and community support
services for deaf and hard of hearing consumers in various locations
through out the United States. CSD is the nation largest provider of
telecommunication relay service for the Deaf. Mr. Miller was formally
the State Director of Rehabilitation Services in South Dakota and was
responsible for administering vocational rehabilitation, independent
living, personal attendant and disability determination services. Mr.
Miller holds a masters degree in rehabilitation counseling and has 30
plus years of leadership experience in the development and management of
large public and private disability programs. He has been a member of
the Panel since 2003.

**Dorothy Watson --** Dorothy Watson is an independent consultant who
recently retired from the Social Security Administration (SSA). During
her lengthy career she served in a series of operational, staff and
executive positions involving multi-programs. For over 15 years she
provided objective technical assistance on numerous disability reform
proposals originating in the Executive and in the Legislative branch of
the federal government. She served a stint on Capitol Hill as
Professional Staff to the Senate Special Committee on Aging during the
intense debate on SSA solvency and disability reforms. This experience
provided a unique view of the legislative and regulatory process.
Dorothy was an invited participant of the Disability Research
Institute's Adequacy of Incentives Advisory Group that made
recommendations for improvements in the Ticket to Work Program. She is a
member of the National Academy of Social Insurance. The President
appointed her to a four-year term ending in 2008.

**Torrey Westrom --** In 1987, Torrey Westrom lost his eyesight in a
farm related car accident. He graduated from Bemidji State University in
1995 with a B.A. in political science and a minor in business
administration. In 1996, at the age of 23, he was elected to the
Minnesota House of Representatives and became Minnesota\'s first elected
blind state representative. In 2003, he was appointed by the Speaker of
the House as the Chairman of the Regulated Industries Committee.  He
served as the committee\'s chairman until 2007.  As a representative, he
works on a wide-array of policy issues ranging from training/employment
opportunities for persons with disabilities, transportation, energy and
rural development issues. He has a J.D. degree from William Mitchell
College of Law, is a member of the Minnesota Bar and owns his own law
practice. He lives in Elbow Lake, MN with his wife and they have two
children.  The President appointed him to the Panel in 2002.

**Responsibilities of the Panel**

The Ticket to Work and Work Incentives Improvement Act of 1999, Public
Law 106-170 (the Act) established the Ticket to Work and Work Incentives
Advisory Panel (the Panel) within the Social Security Administration
(SSA) on December 17, 1999. The Panel is governed by the provisions of
the Act; Public Law 92-463, as amended, which sets forth standards for
the formation and use of advisory committees; and the General Services
Administration (GSA) regulations on the Federal Advisory Committee Act.
The original charter establishing the Panel was submitted to the GSA and
filed with the Committee on Ways and Means of the House of
Representatives and the Committee on Finance of the Senate on March 21,
2000; the charter was renewed in March 2004. The Commissioner of SSA
swore in the original members of the Panel on July 24, 2000.

Panel duties include advising the President, the Congress and the
Commissioner of Social Security on issues related to work incentives
programs, planning and assistance for individuals with disabilities and
the Ticket to Work and Self-Sufficiency Program. Operating procedures
governing the activities of the Panel have been developed and approved.
The Panel meets quarterly and transmits an annual interim report on the
implementation of the Act to the President and Congress. A final report
is due no later than December 17, 2007. The Panel terminates on January
16, 2008, 30 days after the submission of its final report.

# Appendix B \-- Detailed Data on Specified Work Incentives, by State and Selected Characteristics {#appendix-b----detailed-data-on-specified-work-incentives-by-state-and-selected-characteristics .Closing}

**Table B-1**

**Supplemental Security Income Disabled Recipients Using Various Work
Incentives, by State or Area, December 2006**

+-------------------+----------+----------+--------+--------+--------+
| State or area     |          |          |        | 1619   |        |
|                   |          |          |        |        |        |
|                   | Plans to | Imp      | Blind\ |        |        |
|                   | achieve\ | airment- | work   |        |        |
|                   | self-    | related\ | exp    |        |        |
|                   | support\ | work     | enses\ |        |        |
|                   | (PASS)   | e        | (BWE)  |        |        |
|                   | ^a^      | xpenses\ |        |        |        |
|                   |          | (IRWE)   |        |        |        |
+===================+==========+==========+========+========+========+
|                   |          |          |        | 1619   | 1619   |
|                   |          |          |        | (a)    | (b)    |
+-------------------+----------+----------+--------+--------+--------+
| All areas         | 1,583    | 5,650    | 2,370  | 17,394 | 89,350 |
+-------------------+----------+----------+--------+--------+--------+
| Alabama           | 23       | 143      | 28     | 284    | 1,195  |
+-------------------+----------+----------+--------+--------+--------+
| Alaska            | 4        | ^b^      | ^b^    | ^b^    | ^b^    |
+-------------------+----------+----------+--------+--------+--------+
| Arizona           | 7        | 59       | 27     | 281    | 1,424  |
+-------------------+----------+----------+--------+--------+--------+
| Arkansas          | 16       | 48       | 20     | 164    | 897    |
+-------------------+----------+----------+--------+--------+--------+
| California        | 371      | 366      | 391    | 4,067  | 9,945  |
+-------------------+----------+----------+--------+--------+--------+
| Colorado          | 13       | 27       | 24     | 156    | 938    |
+-------------------+----------+----------+--------+--------+--------+
| Connecticut       | 9        | 108      | 32     | 132    | 1,171  |
+-------------------+----------+----------+--------+--------+--------+
| Delaware          | 0        | 27       | 9      | 46     | 303    |
+-------------------+----------+----------+--------+--------+--------+
| District of       | ^b^      | 0        | 3      | 63     | 282    |
| Columbia          |          |          |        |        |        |
+-------------------+----------+----------+--------+--------+--------+
| Florida           | 39       | 306      | 82     | 810    | 4,530  |
+-------------------+----------+----------+--------+--------+--------+
| Georgia           | 26       | 194      | 48     | 322    | 1,839  |
+-------------------+----------+----------+--------+--------+--------+
| Hawaii            | 5        | 7        | 8      | 58     | 338    |
+-------------------+----------+----------+--------+--------+--------+
| Idaho             | 23       | 8        | 4      | 91     | 613    |
+-------------------+----------+----------+--------+--------+--------+
| Illinois          | 43       | 191      | 57     | 702    | 3,603  |
+-------------------+----------+----------+--------+--------+--------+
| Indiana           | 30       | 94       | 38     | 225    | 1,589  |
+-------------------+----------+----------+--------+--------+--------+
| Iowa              | 53       | 50       | 47     | 159    | 1,592  |
+-------------------+----------+----------+--------+--------+--------+
| Kansas            | 25       | 286      | 30     | 140    | 1,037  |
+-------------------+----------+----------+--------+--------+--------+
| Kentucky          | 64       | 81       | 34     | 225    | 1,249  |
+-------------------+----------+----------+--------+--------+--------+
| Louisiana         | ^b^      | 96       | 34     | 332    | 1,539  |
+-------------------+----------+----------+--------+--------+--------+
| Maine             | 46       | 27       | 10     | 91     | 677    |
+-------------------+----------+----------+--------+--------+--------+
| Maryland          | 18       | 161      | 34     | 286    | 1,658  |
+-------------------+----------+----------+--------+--------+--------+
| Massachusetts     | 100      | 147      | 211    | 544    | 3,295  |
+-------------------+----------+----------+--------+--------+--------+
| Michigan          | 43       | 95       | 78     | 504    | 3,159  |
+-------------------+----------+----------+--------+--------+--------+
| Minnesota         | 52       | 113      | 44     | 279    | 2,493  |
+-------------------+----------+----------+--------+--------+--------+
| Mississippi       | 7        | 36       | 22     | 188    | 938    |
+-------------------+----------+----------+--------+--------+--------+
| Missouri          | 34       | 104      | 29     | 254    | 2,100  |
+-------------------+----------+----------+--------+--------+--------+
| Montana           | 17       | 9        | 9      | 60     | 456    |
+-------------------+----------+----------+--------+--------+--------+
| Nebraska          | 17       | 19       | 8      | 94     | 639    |
+-------------------+----------+----------+--------+--------+--------+
| Nevada            | b        | 19       | 13     | 104    | 561    |
+-------------------+----------+----------+--------+--------+--------+
| New Hampshire     | 12       | 19       | 6      | 35     | 402    |
+-------------------+----------+----------+--------+--------+--------+
| New Jersey        | 3        | 201      | 44     | 333    | 2,124  |
+-------------------+----------+----------+--------+--------+--------+
| New Mexico        | 0        | 56       | 15     | 127    | 645    |
+-------------------+----------+----------+--------+--------+--------+
| New York          | 86       | 477      | 185    | 1,598  | 7,568  |
+-------------------+----------+----------+--------+--------+--------+
| North Carolina    | 73       | 293      | 93     | 310    | 1,974  |
+-------------------+----------+----------+--------+--------+--------+
| North Dakota      | ^b^      | 7        | 3      | 35     | 357    |
+-------------------+----------+----------+--------+--------+--------+
| Ohio              | 26       | 106      | 80     | 576    | 3,546  |
+-------------------+----------+----------+--------+--------+--------+
| Oklahoma          | 6        | 65       | 21     | 132    | 1,019  |
+-------------------+----------+----------+--------+--------+--------+
| Oregon            | 31       | 36       | 20     | 153    | 1,079  |
+-------------------+----------+----------+--------+--------+--------+
| Pennsylvania      | 13       | 242      | 88     | 728    | 4,361  |
+-------------------+----------+----------+--------+--------+--------+
| Rhode Island      | 10       | 10       | 8      | 63     | 468    |
+-------------------+----------+----------+--------+--------+--------+
| South Carolina    | 20       | 60       | 31     | 153    | 992    |
+-------------------+----------+----------+--------+--------+--------+
| South Dakota      | 7        | 12       | 6      | 44     | 508    |
+-------------------+----------+----------+--------+--------+--------+
| Tennessee         | 20       | 101      | 36     | 223    | 1,360  |
+-------------------+----------+----------+--------+--------+--------+
| Texas             | 22       | 284      | 156    | 737    | 4,131  |
+-------------------+----------+----------+--------+--------+--------+
| Utah              | ^b^      | 36       | 13     | 100    | 690    |
+-------------------+----------+----------+--------+--------+--------+
| Vermont           | 30       | 9        | 4      | 60     | 418    |
+-------------------+----------+----------+--------+--------+--------+
| Virginia          | 7        | 465      | 58     | 331    | 2,018  |
+-------------------+----------+----------+--------+--------+--------+
| Washington        | 33       | 89       | 45     | 482    | 2,197  |
+-------------------+----------+----------+--------+--------+--------+
| West Virginia     | 11       | 25       | 13     | 150    | 654    |
+-------------------+----------+----------+--------+--------+--------+
| Wisconsin         | 78       | 234      | 64     | 308    | 2,284  |
+-------------------+----------+----------+--------+--------+--------+
| Wyoming           | ^b^      | ^b^      | 3      | 33     | 278    |
+-------------------+----------+----------+--------+--------+--------+
| Outlying area     |          |          |        |        |        |
+-------------------+----------+----------+--------+--------+--------+
| Northern Mariana  | ^b^      | ^b^      | ^b^    | ^b^    | ^b^    |
| Islands           |          |          |        |        |        |
+-------------------+----------+----------+--------+--------+--------+
| Source: SSI       |          |          |        |        |        |
| Disabled          |          |          |        |        |        |
| Recipients Who    |          |          |        |        |        |
| Work, 2006,       |          |          |        |        |        |
| Social Security   |          |          |        |        |        |
| Administration,   |          |          |        |        |        |
| 2007, Tables 14   |          |          |        |        |        |
| and 6.            |          |          |        |        |        |
+-------------------+----------+----------+--------+--------+--------+
| ^a^Includes 435   |          |          |        |        |        |
| persons with a    |          |          |        |        |        |
| PASS that         |          |          |        |        |        |
| excludes only     |          |          |        |        |        |
| resources.        |          |          |        |        |        |
+-------------------+----------+----------+--------+--------+--------+
| ^b^Data are not   |          |          |        |        |        |
| shown to avoid    |          |          |        |        |        |
| disclosure of     |          |          |        |        |        |
| information for   |          |          |        |        |        |
| particular        |          |          |        |        |        |
| individuals.      |          |          |        |        |        |
+-------------------+----------+----------+--------+--------+--------+

**Table B-2**

**Number and Percentage who work, by state or other area, December
2006**

  ------------------------------------------------------------------------
  State or area         All blind and\    Recipients who 
                        disabled          work           
                        recipients                       
  --------------------- ----------------- -------------- -----------------
                                          Number         Percentage of all
                                                         blind\
                                                         and disabled
                                                         recipients

  All areas             6,113,277         349,420        5.7

  Alabama               149,300           4,268          2.9

  Alaska                9,439             621            6.6

  Arizona               87,205            4,263          4.9

  Arkansas              84,700            3,858          4.6

  California            876,326           46,849         5.3

  Colorado              49,120            4,102          8.4

  Connecticut           47,747            3,941          8.3

  Delaware              13,041            969            7.4

  District of Columbia  20,021            795            4.0

  Florida               331,835           13,435         4.0

  Georgia               180,879           7,213          4.0

  Hawaii                16,810            926            5.5

  Idaho                 21,841            2,007          9.2

  Illinois              234,207           14,242         6.1

  Indiana               96,891            5,911          6.1

  Iowa                  41,920            6,985          16.7

  Kansas                37,313            4,282          11.5

  Kentucky              169,732           4,843          2.9

  Louisiana             142,044           5,428          3.8

  Maine                 30,857            2,193          7.1

  Maryland              82,612            6,277          7.6

  Massachusetts         132,997           9,812          7.4

  Michigan              211,639           13,664         6.5

  Minnesota             68,020            10,430         15.3

  Mississippi           110,460           3,164          2.9

  Missouri              112,676           7,635          6.8

  Montana               14,577            1,904          13.1

  Nebraska              21,214            3,133          14.8

  Nevada                26,206            1,814          6.9

  New Hampshire         14,003            1,313          9.4

  New Jersey            122,884           7,869          6.4

  New Mexico            47,370            2,316          4.9

  New York              513,648           31,382         6.1

  North Carolina        180,285           8,353          4.6

  North Dakota          7,438             1,396          18.8

  Ohio                  242,316           17,170         7.1

  Oklahoma              75,688            4,242          5.6

  Oregon                55,410            4,227          7.6

  Pennsylvania          301,386           16,180         5.4

  Rhode Island          27,265            1,641          6.0

  South Carolina        94,643            4,859          5.1

  South Dakota          11,626            2,114          18.2

  Tennessee             147,892           5,352          3.6

  Texas                 419,516           15,027         3.6

  Utah                  21,902            2,517          11.5

  Vermont               12,753            1,255          9.8

  Virginia              120,819           7,198          6.0

  Washington            106,134           6,415          6.0

  West Virginia         74,621            2,254          3.0

  Wisconsin             87,723            10,488         12.0

  Wyoming               5,658             875            15.5

  Outlying area                                          

  Northern Mariana      666               13             2.0
  Islands                                                

  Source: SSI Disabled                                   
  Recipients Who Work,                                   
  2006, Social Security                                  
  Administration, 2007,                                  
  Table 2.                                               

  NOTE: Includes                                         
  section 1619(b)                                        
  participants.                                          
  ------------------------------------------------------------------------

**Table B-3**

**Section 1619(b) Participants and Their Average Earnings, by State or
Other Area, December 2006**

+---------------+--------------------------------+---------------------+
| State or area | 1619(a)                        | 1619(b)             |
+===============+================================+=====================+
|               | Average earnings (dollars)     | Average earnings    |
|               |                                | (dollars)           |
+---------------+--------------------------------+---------------------+
| All areas     | 1,166                          | 1,193               |
+---------------+--------------------------------+---------------------+
| Alabama       | 1,120                          | 1,224               |
+---------------+--------------------------------+---------------------+
| Alaska ^a^    | 1,131                          | 1,304               |
+---------------+--------------------------------+---------------------+
| Arizona       | 1,144                          | 1,280               |
+---------------+--------------------------------+---------------------+
| Arkansas      | 1,115                          | 1,147               |
+---------------+--------------------------------+---------------------+
| California    | 1,279                          | 1,549               |
+---------------+--------------------------------+---------------------+
| Colorado      | 1,155                          | 1,177               |
+---------------+--------------------------------+---------------------+
| Connecticut   | 1,135                          | 1,130               |
| ^a^           |                                |                     |
+---------------+--------------------------------+---------------------+
| Delaware      | 1,129                          | 1,244               |
+---------------+--------------------------------+---------------------+
| District of   | 1,104                          | 1,443               |
| Columbia      |                                |                     |
+---------------+--------------------------------+---------------------+
| Florida       | 1,115                          | 1,233               |
+---------------+--------------------------------+---------------------+
| Georgia       | 1,105                          | 1,153               |
+---------------+--------------------------------+---------------------+
| Hawaii ^a^    | 1,162                          | 1,311               |
+---------------+--------------------------------+---------------------+
| Idaho ^a^     | 1,178                          | 1,078               |
+---------------+--------------------------------+---------------------+
| Illinois ^a^  | 1,110                          | 1,182               |
+---------------+--------------------------------+---------------------+
| Indiana ^a^   | 1,107                          | 1,057               |
+---------------+--------------------------------+---------------------+
| Iowa          | 1,120                          | 891                 |
+---------------+--------------------------------+---------------------+
| Kansas ^a^    | 1,129                          | 1,015               |
+---------------+--------------------------------+---------------------+
| Kentucky      | 1,153                          | 1,280               |
+---------------+--------------------------------+---------------------+
| Louisiana     | 1,118                          | 1,187               |
+---------------+--------------------------------+---------------------+
| Maine         | 1,138                          | 1,056               |
+---------------+--------------------------------+---------------------+
| Maryland      | 1,134                          | 1,257               |
+---------------+--------------------------------+---------------------+
| Massachusetts | 1,183                          | 1,288               |
+---------------+--------------------------------+---------------------+
| Michigan      | 1,126                          | 1,064               |
+---------------+--------------------------------+---------------------+
| Minnesota ^a^ | 1,106                          | 973                 |
+---------------+--------------------------------+---------------------+
| Mississippi   | 1,114                          | 1,202               |
+---------------+--------------------------------+---------------------+
| Missouri ^a^  | 1,134                          | 986                 |
+---------------+--------------------------------+---------------------+
| Montana       | 1,153                          | 928                 |
+---------------+--------------------------------+---------------------+
| Nebraska ^a^  | 1,123                          | 979                 |
+---------------+--------------------------------+---------------------+
| Nevada ^a^    | 1,120                          | 1,377               |
+---------------+--------------------------------+---------------------+
| New Hampshire | 1,153                          | 1,064               |
| ^a^           |                                |                     |
+---------------+--------------------------------+---------------------+
| New Jersey    | 1,136                          | 1,249               |
+---------------+--------------------------------+---------------------+
| New Mexico    | 1,148                          | 1,124               |
+---------------+--------------------------------+---------------------+
| New York      | 1,172                          | 1,325               |
+---------------+--------------------------------+---------------------+
| North         | 1,102                          | 1,073               |
| Carolina      |                                |                     |
+---------------+--------------------------------+---------------------+
| North Dakota  | 1,126                          | 867                 |
| ^a^           |                                |                     |
+---------------+--------------------------------+---------------------+
| Ohio ^a^      | 1,109                          | 1,027               |
+---------------+--------------------------------+---------------------+
| Oklahoma ^a^  | 1,132                          | 1,002               |
+---------------+--------------------------------+---------------------+
| Oregon ^a^    | 1,153                          | 1,026               |
+---------------+--------------------------------+---------------------+
| Pennsylvania  | 1,120                          | 1,136               |
+---------------+--------------------------------+---------------------+
| Rhode Island  | 1,152                          | 1,216               |
+---------------+--------------------------------+---------------------+
| South         | 1,119                          | 1,013               |
| Carolina      |                                |                     |
+---------------+--------------------------------+---------------------+
| South Dakota  | 1,130                          | 863                 |
+---------------+--------------------------------+---------------------+
| Tennessee     | 1,119                          | 1,160               |
+---------------+--------------------------------+---------------------+
| Texas         | 1,115                          | 1,139               |
+---------------+--------------------------------+---------------------+
| Utah ^a^      | 1,119                          | 1,038               |
+---------------+--------------------------------+---------------------+
| Vermont       | 1,150                          | 1,090               |
+---------------+--------------------------------+---------------------+
| Virginia ^a^  | 1,128                          | 1,192               |
+---------------+--------------------------------+---------------------+
| Washington    | 1,138                          | 1,242               |
+---------------+--------------------------------+---------------------+
| West Virginia | 1,130                          | 1,332               |
+---------------+--------------------------------+---------------------+
| Wisconsin     | 1,117                          | 962                 |
+---------------+--------------------------------+---------------------+
| Wyoming       | 1,079                          | 999                 |
+---------------+--------------------------------+---------------------+
| Outlying area |                                |                     |
+---------------+--------------------------------+---------------------+
| Northern      | 964                            | 1,103               |
| Mariana       |                                |                     |
| Islands       |                                |                     |
+---------------+--------------------------------+---------------------+
|   ----        |                                |                     |
| ------------- |                                |                     |
|   Source: SSI |                                |                     |
|   Disabled    |                                |                     |
|   R           |                                |                     |
| ecipients Who |                                |                     |
|   Work, 2006, |                                |                     |
|   So          |                                |                     |
| cial Security |                                |                     |
|   Ad          |                                |                     |
| ministration, |                                |                     |
|   20          |                                |                     |
| 07, Tables 10 |                                |                     |
|   and 11.     |                                |                     |
|               |                                |                     |
|   ^           |                                |                     |
| a^For 1619(b) |                                |                     |
|   par         |                                |                     |
| ticipants \-- |                                |                     |
|   the Social  |                                |                     |
|   Security    |                                |                     |
|   A           |                                |                     |
| dministration |                                |                     |
|   identifies  |                                |                     |
|   persons as  |                                |                     |
|   potential   |                                |                     |
|   part        |                                |                     |
| icipants; the |                                |                     |
|   stat        |                                |                     |
| e makes final |                                |                     |
|   Medicaid    |                                |                     |
|   de          |                                |                     |
| terminations. |                                |                     |
|   ----        |                                |                     |
| ------------- |                                |                     |
+---------------+--------------------------------+---------------------+

**Table B-4**

**Other Work Incentive Participants: Number, by Selected Characteristics
and Provision, December 2006**

  -------------------------------------------------------------------------------------------
  Characteristic                          Plans to         Impairment-related\   Blind\
                                          achieve\         work expenses\        work
                                          self-support\    (IRWE)                expenses\
                                          (PASS) ^a^                             (BWE)
  ----------------- --------------------- ---------------- --------------------- ------------
  Total                                   1,583            5,650                 2,370

  Age                                                                            

                    Under 18              1                4                     4

                    18--21                69               276                   84

                    22--29                308              1,813                 579

                    30--39                364              1,608                 678

                    40--49                461              1,102                 536

                    50--59                313              601                   364

                    60--64                57               145                   67

                    65 or older           10               101                   58

  Sex                                                                            

                    Male                  643              3,106                 1,273

                    Female                940              2,544                 1,097

  Earned income ^b^                                                              

                    Wages                 393              5,556                 2,296

                    Self-employment       101              117                   91

  Earnings                                                                       
  (dollars)                                                                      

                    None                  1,098            0                     0

                    65 or less            33               469                   150

                    66--99                9                227                   78

                    100--199              32               798                   229

                    200--299              26               696                   188

                    300--399              40               663                   154

                    400--499              36               493                   117

                    500--599              40               497                   116

                    600--699              44               364                   99

                    700--799              45               269                   103

                    800--899              29               231                   94

                    900--999              23               141                   86

                    1,000 or more         128              802                   956

  Unearned income                                                                
  ^b^                                                                            

                    None                  317              2,367                 1,217

                    Social Security       1,228            2,978                 1,023

                    Other pensions        18               30                    6

                    Income based on need  0                1                     0

                    Asset income          58               345                   153

                    Other                 54               195                   63

  Source: SSI                                                                    
  Disabled                                                                       
  Recipients Who                                                                 
  Work, 2006,                                                                    
  Social Security                                                                
  Administration,                                                                
  2007, Tables 15.                                                               

  a\.               Includes 435 persons                                         
                    with a PASS that                                             
                    excludes only                                                
                    resources.                                                   

  b\.               The sum of the                                               
                    entries may be                                               
                    greater than the                                             
                    total because some                                           
                    recipients may                                               
                    receive more than one                                        
                    type of earned or                                            
                    unearned income or                                           
                    both earned and                                              
                    unearned income.                                             
  -------------------------------------------------------------------------------------------

  -------------------------------------------------------------- --------
                                                                 

  -------------------------------------------------------------- --------

# Appendix C \-- Acknowledgements {#appendix-c----acknowledgements .Closing}

The Panel would like to extend their sincere appreciation to the
following individuals who provided their considerable expertise to the
background analysis, research and information that went into the
development of this report.

Cayte Anderson

Pathways Projects

1 W. Wilson Street, Rm 951

Madison, WI 53703

Chris Clasby, MSW

MATP Project Coordinator

University of Montana Rural Institute/MonTECH

634 Eddy Ave., CHC-024

Missoula, MT 59812

Laura Farah

Program Associate, Law, Health Policy & Disability Center

University of Iowa College of Law

281 Beech Street

Belmont, MA 02478

Dorothy Firsching

Ursa Major Consulting, LLC

9536 Stevebrook Road.

Fairfax, VA 22032

David Hammis

Griffin - Hammis

317 Franklin Street

Middletown, Ohio 45042

Allen Jensen

Director, Work Incentives Project

Center for Health Services Research and Policy

The George Washington University

School of Public Health and Health Services

2021 K Street, NW, Suite 800

Washington, DC 20006

David Mank, Ph.D.

Director, Indiana Institute on Disability and Community (Office of
Research and University Graduate School)

Indiana University

2853 East Tenth Street

Bloomington, Indiana 47408

Michael Morris

National Disability Institute

1667 K Street, NW - Suite 600

Washington, DC 20006

Mary Ridgely

Independent Consultant

Pathways Projects

1 W. Wilson Street, Room 951

Madison, WI 53703

Becky Roberts

President

International Leadership Consulting, LLC

Catoctin Consulting, LLC

39859 The Narrows Rd.

Waterford, VA 20197

Molly Sullivan

Griffin - Hammis

317 Franklin Street

Middletown, Ohio 45042

**Contact Information**

Ticket to Work and Work Incentives Advisory Panel

Social Security Administration

400 Virginia Avenue, SW -- Suite 700

Washington, DC 20024

Phone at (202) 358-6430

Fax at (202) 358-6440

Email to: <TWWIIAPanel@ssa.gov>

Website:
[www.socialsecurity.gov/work/panel](http://www.socialsecurity.gov/work/panel)

Anyone requiring materials in alternate formats or needing further
information regarding this document or the Ticket to Work and Work
Incentives Advisory Panel should contact the Panel staff. Records are
maintained of all Panel proceedings in accordance with the Federal
Advisory Committee Act and are available for public inspection at the
Panel office, by appointment.

***Advisory Panel Staff***

Jill Houghton, Executive Director

Michael Anzick

Shirletta Banks

Patricia Laird

Jenn Rigger

Debra Tidwell-Peters

[^1]: Throughout the paper, references to returning to work also include
    the efforts of people who may be attempting to enter the workforce
    for the first time.

[^2]: Note that individuals eligible for SSI are termed "SSI
    recipients", because SSI is an entitlement program, while
    individuals eligible for SSDI are termed "SSDI beneficiaries" as
    SSDI is an insurance program. This report will use the term
    "beneficiaries" when referring to both groups collectively.

[^3]: Social Security Administration. Kearney, John R., 2007, Social
    Security and the \"D\" in OASDI: The History of a Federal Program
    Insuring Earners Against Disability, Social Security Bulletin, Vol.
    66, No. 3, August 2006. Washington, DC.
    http://www.ssa.gov/policy/docs/ssb/v66n3/v66n3p1.html

[^4]: Social Security Advisory Board. The Social Security Definition of
    Disability, October 2003, pp 8-10. Washington, DC.
    http://www.ssab.gov/documents/SocialSecurityDefinitionOfDisability_002.pdf

[^5]: Ibid.

[^6]: Ibid.

[^7]: Ibid.

[^8]: Social Security Administration. Muller, L. Scott, 1992, Disability
    Beneficiaries Who Work and Their Experience Under Program Work
    Incentives, Social Security Bulletin Vol.55, No.2:2-19, April 1992.
    Washington, DC.

[^9]: Social Security Administration. Hennessey, John C. and L. Scott
    Muller 1994, Work Efforts of Disabled-Worker Beneficiaries:
    Preliminary Findings from the New Beneficiary Follow-up Survey,
    Social Security Bulletin Vol. 57, No.3:42-51, July 2004. Washington,
    DC.

[^10]: Social Security Administration. Hennessey, John C. and L. Scott
    Muller 1995,The Effect of Vocational Rehabilitation and Work
    Incentives on Helping the Disabled-Worker Beneficiary Back to Work,
    Social Security Bulletin Vol. 58, No.1:15-28, January 1995.
    Washington, DC.
    http://www.ssa.gov/policy/docs/ssb/v58n1/v58n1p15.pdf

[^11]: Before publication of final rules on August 9, 2006, the
    evaluation period for this exclusion was on a monthly rather than a
    quarterly basis, and the total could not be greater than \$10 of
    earned income or \$20 of unearned income, if the SSI recipient
    received the income only once in a calendar quarter from a single
    source, or if the income could not have been reasonably expected.

[^12]: SSDI beneficiaries who do not also qualify for SSI because their
    income is too high can set aside part of their SSDI benefit payment
    to finance their PASS expenses, possibly making them eligible for
    SSI.

[^13]: This continued payment authority is sometimes referred to as
    "section 301," as it originated in section 301 of the Social
    Security Disability Amendments of 1980 (P.L. 96-265). Expanded by
    subsequent legislation, it allows continued payment of SSI benefits
    to individuals whose disability is medically ceased, if the
    individual is participating in the Ticket to Work program or another
    approved program of vocational rehabilitation services, employment
    services, or other support services, or if the individual is a
    student aged 18-21 who is participating in an Individualized
    Education Program (IEP) in an approved educational institution.
    Benefits continue if SSA determines that completion of the program
    will increase the likelihood that the individual will be permanently
    removed from the disability or blindness benefit rolls. Final rules
    regarding the expansion of payment authority were published on June
    24, 2005 (70 FR 36494), with the PASS inclusion specified in SSA's
    Program Operations Manual System, Section SI 00870.010 (February,
    2006). (From: Social Security Administration. Annual Report of the
    SSI Program. May 2006. P.2, Footnote 2. Office of the Chief Actuary,
    Washington, DC.)

[^14]: See Appendix B.

[^15]: States with more than 15 percent of SSI recipients with earnings:
    Iowa, Minnesota, North Dakota, South Dakota; Wyoming. States with
    less than 5 percent of SSI recipients with earning: Alabama,
    Arizona, Arkansas, District of Columbia, Florida, Georgia, Kentucky,
    Louisiana, Mississippi, New Mexico, North Carolina, Tennessee, West
    Virginia. See Appendix B (Table B-2).

[^16]: See Appendix B (Table B-4).

[^17]: SSA has collected data on IRWE, BWE, PASS, 1619(a) and 1619(b)
    utilization by SSI recipients, and has published this information
    annually in the Annual Report of the SSI Program and its SSI
    Disabled Recipients Who Work publications.

[^18]: Social Security Administration. SSI Disabled Recipients Who Work,
    Reports from 1990 -- 2006. Washington, DC.
    http://www.ssa.gov/policy/. See Appendix B (Table B-1).

[^19]: For example, Virginia (482), New York (479), and California (475)
    led in IRWE utilization, but while California also led with 414 PASS
    plans, no other state came close and half of the states had fewer
    than 20 beneficiaries with PASS plans. Some states, like Vermont,
    had 4 times as many beneficiaries with PASS plans as with IRWE. No
    pattern or trend emerged. Social Security Administration. SSI Annual
    Statistical Report, 2005. Table 31. Office of Policy. Washington,
    DC.
    http://www.ssa.gov/policy/docs/statcomps/ssi_asr/2005/sect06.html#table31

[^20]: Social Security Advisory Board. The Social Security Definition of
    Disability, October 2003, pp 8-10. Washington, DC.
    http://www.ssab.gov/documents/SocialSecurityDefinitionOfDisability_002.pdf

[^21]: Social Security Administration. Simplifying the Supplemental
    Security Income Program: Challenges and Opportunities, Office of
    Policy, December 2000. Washington, DC.
    http://www.ssa.gov/policy/programs/SSI/simplification/simplification.pdf

[^22]: U.S. General Accounting Office. 2002. SSA Disability: Enhanced
    Procedures and Guidance Could Improve Service and Reduce
    Overpayments to Concurrent Beneficiaries. GAO-02-802. Washington,
    DC: September 2002. http://www.gao.gov/new.items/d02802.pdf

[^23]: For additional information, see Livermore, G. A. (2003). Wage
    Reporting and Earnings-Related Overpayments in the Social Security
    Disability Programs: Status, Implications, and Suggestions for
    Improvements. Report prepared for the Ticket to Work and Work
    Incentives Advisory Panel. Cornell Center for Policy Research:
    Washington, DC
    http://www.ssa.gov/work/panel/panel_documents/briefingpapers.html

[^24]: This recommendation is identical to one recommended by the U.S.
    Department of Human Services, 1986 Disability Advisory Council.

[^25]: Social Security Administration. Program Operations Manual System
    (POMS) DI 10520.001 Impairment-Related Work Expenses (IRWE).
    http://www.ssa.gov/regulations

[^26]: Social Security Administration. Program Operations Manual System
    (POMS) DI 10520.001 Impairment-Related Work Expenses (IRWE).
    http://www.ssa.gov/regulations

[^27]: Social Security Administration. Report on Supplemental Security
    Income: Income and Resource Exclusions and Disability Insurance
    Earnings-Related Provisions, March 2000. Office of Policy.
    Washington, DC.

[^28]: Social Security Advisory Board. Statement on the Supplemental
    Security Income Program, May 2005, p.8. Washington, DC.
    http://www.ssab.gov/documents/2005SSIReport.pdf

[^29]: Social Security Administration, Vocational Rehabilitation
    Provider's Handbook, Chapter 12. Baltimore, MD.
    <http://www.ssa.gov/work/ServiceProviders/providers.html>

[^30]: For additional information see 1) U.S. General Accounting Office.
    SSA Disability: Enhanced Procedures and Guidance Could Improve
    Service and Reduce Overpayments to Concurrent Beneficiaries.
    GAO-02-802. Washington, DC: September 2002.
    http://www.gao.gov/new.items/d02802.pdf and 2) Livermore, G. A.
    (2003). Wage Reporting and Earnings-Related Overpayments in the
    Social Security Disability Programs: Status, Implications, and
    Suggestions for Improvements. Report prepared for the Ticket to Work
    and Work Incentives Advisory Panel. Cornell Center for Policy
    Research: Washington, DC
    http://www.ssa.gov/work/panel/panel_documents/briefingpapers.html

[^31]: U.S. General Accounting Office. SSA Disability: Enhanced
    Procedures and Guidance Could Improve Service and Reduce
    Overpayments to Concurrent Beneficiaries. GAO-02-802. Washington,
    DC: September 2002 http://www.gao.gov/new.items/d02802.pdf

[^32]: Social Security Administration. Strategic Plan FY 2006 -- FY
    2011. Baltimore, MD. http://www.ssa.gov/strategicplan.html.

[^33]: Social Security Administration. Social Security Administration
    Budget, Justification of Estimates for Appropriations Committees FY
    2008. Baltimore, MD.
    http://www.socialsecurity.gov/budget/2008cjapp508.pdf

[^34]: Livermore, G. A. (2003). Wage Reporting and Earnings-Related
    Overpayments in the Social Security Disability Programs: Status,
    Implications, and Suggestions for Improvements. Report prepared for
    the Ticket to Work and Work Incentives Advisory Panel. Cornell
    Center for Policy Research: Washington, DC
    http://www.ssa.gov/work/panel/panel_documents/briefingpapers.html

[^35]: U.S. Office of Management and Budget. Budget of the United States
    Government, FY 2007 and FY 2008. http://www.whitehouse.gov/omb

[^36]: The prevention of SSI overpayments will be accomplished by
    testing and implementing, as appropriate, electronic means for SSA
    to access records of financial institutions to detect unreported
    resources. Social Security has tested methods to electronically
    access recipient financial account records, and this tool has been
    expanded to additional field offices in the New York Region. This
    process is also being used to study and identify characteristics of
    records likely to have accounts over the SSI lines. The results of
    the study will be used to determine if it is feasible to support
    development of systems changes and expansion of the initiative
    nationwide. (From Social Security Administration. Social Security
    Administration Budget, FY 2008 and Revised Final FY 2007 APP,
    Appendix A: Service -- Improve Service Through Technology (1.3 a-g)
    Means/Strategies p.51. Baltimore, MD.
    http://www.socialsecurity.gov/budget/2008cjapp508.pdf)

[^37]: Social Security Administration. Fiscal Year 2008, p. 179.

[^38]: U.S. Office of Management and Budget. Budget of the United States
    Government, FY 2008. http://www.whitehouse.gov/omb

[^39]: U.S. Government Printing Office. U.S. House of Representatives.
    Committee on Ways and Means. Social Security Service Delivery
    Challenges: Hearing before the Subcommittee on Social Security of
    the House of Representatives. 109th Congress, 2nd Session, May 2006.
    Washington, DC.
    http://www.gpoaccess.gov/chearings/index.htmlWashington, DC., GPO.,
    2007.

[^40]: Ibid, pp. 29, 39-40, 51, and 60.

[^41]: Livermore, G. A. (2003), p. 24.

[^42]: Social Security Administration. Performance and Accountability
    Report for Fiscal Year 2004. Baltimore, MD.
    http://www.ssa.gov/finance/fy04_accountability.html

[^43]: Social Security Advisory Board. Statement on the Supplemental
    Security Income Program, May 2005, p.8. Washington, DC.
    http://www.ssab.gov/documents/2005SSIReport.pdf

[^44]: U.S. Government Printing Office. Federal Register. Agency
    Information Collection Activities: Proposed Request, Vol. 70 No.
    172, September 7, 2005, p. 53266.
    http://www.gpoaccess.gov/fr/index.html

[^45]: Social Security Administration. Annual Report of the SSI Program.
    May 2006. Office of the Actuary. Washington, DC..

[^46]: U.S. Office of Management and Budget. Budget of the United States
    Government, FY 2007. http://www.whitehouse.gov/omb

[^47]: Ibid, FY 2008.

[^48]: See the Panel's May 3, 2006 letter to Commissioner Barnhart
    (Issuance of Receipts to Acknowledge Submission of Reports of
    Changes in Work or Earnings Status of Beneficiaries with
    Disabilities) for additional details.
    http://www.ssa.gov/work/panel/panel_documents/official_correspondence.html

[^49]: Social Security Administration. Strategic Plan FY 2006 -- FY
    2011. Baltimore, MD. http://www.ssa.gov/strategicplan.html

[^50]: The Benefits Planning Assistance and Outreach (BPAO) program was
    the predecessor of today's Work Incentives Planning and Assistance
    (WIPA).

[^51]: Virginia Commonwealth University. Rehabilitation Research
    &Training Center on Workplace Supports. Benefits Assistance Resource
    Center. BPAO National General Report.
    http://www.vcu-barc.org/NatReport/CurrentReport.html

[^52]: Ibid.

[^53]: Ibid.

[^54]: Ibid.

[^55]: Ibid.

[^56]: Ticket to Work and Work Incentives Advisory Panel. Annual Report
    to the President and Congress, Year Four, July 2004, p17.
    Washington, DC.
    http://www.ssa.gov/work/panel/panel_documents/reports.html

[^57]: Ibid, p17.

[^58]: Ticket to Work and Work Incentives Advisory Panel. Quarterly
    Meetings. Minutes: 2004, 2005, 2006. Public Comment. Washington, DC.
    http://www.ssa.gov/work/panel/meeting_information/minutes.html

[^59]: Social Security Administration. Social Security Quarterly Update,
    November 2006. Report prepared for the Ticket to Work and Work
    Incentives Advisory Panel.

[^60]: Golden, T.P., Zeitzer, I. & Bruyere, S.M. Evaluation and Future
    Prospects of US Return to Work Policies for Social Security
    Beneficiaries. Korean Journal on Disability & Employment., 2007, pp.
    59, 53-90.

[^61]: National Disability Rights Network. Protection and Advocacy for
    Beneficiaries of Social Security FY 2006 Final Report, March 2007.

[^62]: Ticket to Work and Work Incentives Advisory Panel. Annual Report
    to the President and Congress, Year Five. December 2005. Washington,
    DC. http://www.ssa.gov/work/panel/panel_documents/reports.html

[^63]: Golden, T.P., Zeitzer, I. & Bruyere, S.M, 2007, p79.

[^64]: Social Security Administration. SSI Disabled Recipients Who Work,
    1990-2006 Reports. Washington, DC. http://www.ssa.gov/policy/

[^65]: Gallagher, Tanya M. Enhancing Earnings and Income Through
    Self-Determination for AOI Targeted Groups, Adequacy of Incentives
    (AOI) Advisory Group, September 2004. Report prepared for the Social
    Security Administration. Disability Research Institute: University
    of Illinois at Urbana-Champaign.
    http://www.dri.uiuc.edu/research/p03-08h/AOIFinal.pdf

[^66]: See Appendix B (Table B-1).

[^67]: Jensen, Allen and Silverstein, Robert (2005). Gradual Reduction
    Choice Option and Related Policy Proposals. This research was
    developed as part of a research project funded through a sub-award
    from the Disability Research Institute (DRI) at the University of
    Illinois at Urbana-Champaign.
    [[http://www.dri.uiuc.edu/research/p05-12h/gradualreduction.pdf]{.underline}](http://www.dri.uiuc.edu/research/p05-12h/gradualreduction.pdf)

[^68]: U.S. Government Printing Office. Federal Register. Cooperative
    Agreements for Work Incentives Planning and Assistance Projects:
    Program Announcement No. SSA-OESP-06-1, Vol. 71 No. 94, May 16,
    2006, pp. 28401-28413. http://www.gpoaccess.gov/fr/index.html

[^69]: Ticket to Work and Work Incentives Advisory Panel. Annual Report
    to the President and Congress, Year Seven, March 2007, p19.
    Washington, DC.
    http://www.ssa.gov/work/panel/panel_documents/reports.html

[^70]: Ticket to Work and Work Incentives Improvement Act of 1999,
    Public Law 106-170; Sec. 203 (f).
    http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=106_cong_public_laws&docid=f:publ170.106

[^71]: U. S. Department of Health and Human Services. The Centers for
    Medicare and Medicaid Services. Funding Opportunity Number
    HHS-2008-CMS-MIG-0001**.**
    ww.cms.hhs.gov/TWWIA/downloads/2008_MIG_Solicitation.pdf

[^72]: Gimm, Gilbert W. and Bob Weathers. What is the Demonstration to
    Maintain Independence and Employment (DMIE) and Who is
    Participating. Mathematica Policy Research, Inc. Work and Insurance
    in Brief. Number 6, August 2007.
    <http://www.mathematica-mpr.com/publications/redirect_pubsdb.asp?strSite=pdfs/WWDdemonstration.pdf>