Ticket to Work and Work Incentives Advisory Panel

Building on the Ticket: A New Paradigm for

Investing in Economic Self-Sufficiency for

People with Significant Disabilities

Final Report to the President and Congress

Year Eight of the Panel

###### 

**December 2007**

![](media/image1.jpeg){width="6.129861111111111in"
height="5.031944444444444in"}

*Front row, from the left*: Mary Katie Beckett, Cheryl Bates-Harris,
Libby Child, Berthy De La Rosa-Aponte

*Back row, from the left:* Loretta Goff, Russell Doumas, Torrey Westrom,
Frances Gracechild, Andrew Imparato, David Miller, Thomas Golden,
Dorothy Watson

TABLE OF CONTENTS

MESSAGE FROM THE CHAIR

[Executive Summary 1](#executive-summary)

[**[Elevate and Incorporate the Beneficiary Voice]{.smallcaps}**
2](#__RefHeading___Toc185405211)

[**[Optimize Current Work Incentives through Short-Term and Incremental
Policy Improvements]{.smallcaps}** 3](#__RefHeading___Toc185405212)

[**[Increase Economic Self-Sufficiency through Investment in Disability
Program Modernization]{.smallcaps}** 7](#__RefHeading___Toc185405213)

[Introduction 13](#introduction)

[History of the Panel 17](#history-of-the-panel)

[Findings: History and Trends 21](#findings-history-and-trends)

[Panel Recommendations 49](#panel-recommendations)

[**[Elevate and Incorporate the Beneficiary Voice]{.smallcaps}**
50](#__RefHeading___Toc185405218)

[**[Optimize Current Work Incentives through Short-Term and Incremental
Policy Improvements]{.smallcaps}** 58](#__RefHeading___Toc185405219)

[**[Increase Economic Self-Sufficiency through Investment in Disability
Program Modernization]{.smallcaps}** 74](#__RefHeading___Toc185405220)

[Call to Action 99](#call-to-action)

[Appendix A─Summary of the Ticket to Work and Work Incentives
Improvement\
Act of 1999 101](#__RefHeading___Toc185405222)

[Appendix B─The Panel 103](#__RefHeading___Toc185405223)

[Appendix C─Panel Recommendations December 1999 - December 2007
111](#__RefHeading___Toc185405224)

[Appendix D─Panel Outreach 2001 - 2007
145](#__RefHeading___Toc185405225)

[Appendix E─Panel Correspondence 2007 149](#__RefHeading___Toc185405226)

[Glossary 161](#__RefHeading___Toc185405227)

[End Notes 165](#__RefHeading___Toc185405228)

# A Message from the Chair {#a-message-from-the-chair .Exec-Heading}

On behalf of the Ticket to Work and Work Incentives Advisory Panel (the
Panel), I am privileged to issue this Final Report to the President,
Congress, and the Commissioner of the Social Security Administration
(SSA). The passage of the Ticket to Work and Work Incentives Improvement
Act (the Act) eight years ago represented the culmination of efforts by
diverse stakeholders who recognized the importance of removing barriers
to employment and labor market activity for individuals with
disabilities. Their contributions, in an inclusive workforce, benefit
not only the individuals themselves, but also employers, communities,
and our nation. In passing the Act, Congress recognized that the
contributions of individuals with disabilities cannot be fully realized
without choice and access to needed services, workplace supports and
health care.

The charge to the Panel was to provide advice on the Act's
implementation and make recommendations that would result in increased
employment and greater economic self-sufficiency for individuals with
disabilities. Through literature review, dialogue and discussion at
quarterly meetings, open forums, and field visits across the country,
the Panel has obtained substantial public input. The voices of
beneficiaries and other stakeholders have played a critical role in
shaping the Panel's final recommendations. These recommendations build
on findings from the Panel's Adequacy of Incentives Report, the \$1 for
\$2 Benefit Offset Report, the Employment Network Summit Report, the
Beneficiary Summit Report, the Work Incentive Utilization Report, as
well as the Panel's seven Interim Annual Reports.

Across federal agencies, efforts to coordinate and integrate services
and supports at a community level must improve and be united by a
consistent policy goal of work as a preferred option to promote
independence and enhanced community participation. No single set of
policy and practice actions can address all of the challenges identified
by beneficiaries and confirmed by other diverse stakeholders in the
public and private sectors. However, a key recommendation articulated at
the beneficiary summit and recommended by the Panel is the creation of a
National Disability Beneficiary Work Advocate's Office and a Beneficiary
Work Council within SSA. The purpose of these offices is to elevate and
incorporate the beneficiary voice on a permanent basis to impact future
policy development and procedures related to the disability programs.

I appreciate the dedication and commitment of Panel members and staff to
advance a comprehensive vision of employment and economic
self-sufficiency for current and future generations of youth and adults
with disabilities who receive disability benefits.

This final report shares what the Panel has learned, documents the
diverse experiences of beneficiaries, recommends short-term, incremental
improvements to current programs, and identifies critical investments
that must continue to be made on a national basis to advance and
modernize the current disability programs.

Following the Panel's sunset, I encourage Congress and relevant federal
agencies to maintain their focus on employment for people with
disabilities. Congress should conduct hearings annually on the progress
of the Ticket to Work program, design and execution of demonstrations,
and Medicaid Buy-In implementation. These hearings should solicit
recommendations from beneficiaries and other stakeholders, and should
highlight adequacy of incentives issues, including addressing the needs
of people receiving sub-minimum wages, those with high-cost
accommodations and individuals with a need for ongoing support and
services.

Respectfully Submitted,

![](media/image2.wmf){width="2.6222222222222222in"
height="0.6243055555555556in"}

Berthy De La Rosa-Aponte, Chair

Ticket to Work and Work Incentives Advisory Panel

# Executive Summary {#executive-summary .Exec-Heading}

The Ticket to Work and Work Incentives Improvement Act (the Act) was
signed into law on December 17, 1999. The overwhelming bipartisan
support of the legislation demonstrated the evolution of thinking and
attitudes about the interest in and capacity of people with disabilities
to work, contribute to our nation's economy, and reduce their reliance
on public benefits. Congress made clear its intent "to redesign
government programs to help individuals with disabilities return to
work," which "may result in significant savings and extend the life of
the Social Security Trust Fund."[^1] Congress calculated that if only an
additional one-half of one percent of the current Social Security
Disability Insurance (SSDI) and Supplemental Security Income (SSI)
beneficiaries were to cease receiving benefits as a result of
employment, the savings to the Social Security Trust Fund and the U.S.
Treasury would exceed 3.5 billon dollars over the work life of such
individuals.[^2] These savings would far exceed the cost of providing
incentives and services needed to assist the beneficiaries in entering
work and achieving financial independence to the best of their
abilities.[^3] To achieve these savings, Congress authorized the Ticket
to Work and Self-Sufficiency Program (the Ticket to Work program) to
allow individuals with disabilities greater choices to seek the services
necessary to obtain and retain employment and reduce their dependency on
cash benefit programs. To respond to the documented fear of losing
health care and related services, Congress authorized new options to
encourage states to adopt Medicaid Buy-In programs to allow individuals
with disabilities to purchase Medicaid coverage after becoming employed.
Congress also extended Medicare coverage to SSDI beneficiaries who are
working up to 8 ½ years. Further, section 121 of the Act authorized
investment in a national infrastructure for work incentives outreach to
ensure that beneficiaries have access to information and protection and
advocacy services as they navigate the return-to-work progress.[^4]

Section 101(f) of the Act established the Ticket to Work and Work
Incentives Advisory Panel (the Panel) within the Social Security
Administration (SSA). Panel duties include advising the President,
Congress and the Commissioner of SSA on issues related to work incentive
programs, planning and assistance for individuals with disabilities, and
the Ticket to Work program. This final report presents the findings and
conclusions of the Panel, together with its recommendations for
legislative and administrative actions. The Panel's recommendations take
into account the complexity and interrelationships of the multiple
support programs and entitlements serving people with disabilities.

The final Panel recommendations are organized into three major
groups[^5]:

1.  Elevate and incorporate the beneficiary voice in all aspects of
    program and policy development, evaluation and improvement;

2.  Optimize current work incentives through short-term and incremental
    policy improvements; and

3.  Increase economic self-sufficiency through investment in disability
    program modernization.

These recommendations not only focus on policy changes, but also
recognize the need for a more effective infrastructure to reach
beneficiaries and to respond and adapt to their evolving individual
needs. In order to achieve more dramatic reductions in barriers to work,
the Panel's final set of recommendations call for a continued national
dialogue and investment in fundamental changes needed in disability
policy and systems through which services are delivered.

[]{#__RefHeading___Toc185405211 .anchor}Elevate and Incorporate the
Beneficiary Voice

Since its inception, the Panel has contributed to the national dialogue
about employment for people with disabilities. While the Panel listened
to and learned from many stakeholder groups, they gained a valuable and
as yet underutilized perspective from program beneficiaries about the
need for changes in policy and program implementation. At the
beneficiary summit conducted by the Panel in February 2007, several
recommendations were identified as key to individuals participating in
all aspects of American life.

In the Advice Report to the Commissioner of Social Security issued by
the Panel in 2002 pertaining to the design of the Adequacy of Incentives
Study, the Panel recognized the value and importance of the beneficiary
voice, recommending that SSA develop a policy and practice for
incorporating the input and experiences of consumers, their families,
and/or their representatives as SSA develops new research designs,
including the Adequacy of Incentives Study.

Beneficiary summit delegates further reinforced this early Panel
recommendation by clearly stating the importance of establishing a
permanent way for SSA and Congress to hear beneficiary voices to help
drive future policy and program design.

**Recommendation 1:** Create through legislative authority within the
Social Security Administration, an Office of the National Disability
Beneficiary Work Council (Council) and a National Disability Beneficiary
Work Advocate (Advocate).

Modeled after the Internal Revenue Service (IRS) National Taxpayer
Advocate (NTA) and Taxpayer Advocacy Panel, the Council and the Advocate
would:

1.  Identify difficulties that SSDI and SSI disability program
    beneficiaries' experience when trying to work that could be
    addressed via more effective SSA customer service.

```{=html}
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4.  Propose changes in the administrative practices of SSA to mitigate
    those customer service issues, to the extent possible.

5.  Identify potential legislative changes to improve SSA's service to
    disability beneficiaries who want to work.

[]{#__RefHeading___Toc185405212 .anchor}Optimize Current Work Incentives
through Short-Term and Incremental Policy Improvements

Ticket to Work Program Improvements

No subject has dominated the attention of the Panel more than the
challenges of implementing the Ticket to Work program. During every
public meeting over the past seven years, the Panel has included
presentations by SSA on the status of implementation, strategies to
increase the level of participation by beneficiaries, and the expansion
of the number of ENs to serve them. Each quarterly meeting has also
included diverse stakeholders offering testimony on experiences with the
program and suggestions on how to improve it. The Panel has heard
examples of successful participation which offer hope about the
possibilities for the future and have led to suggested amendments to the
reimbursement system to attract more entities to become ENs and
recommendations to place more attention on marketing and outreach to
attract beneficiary interest. The Panel has submitted multiple
recommendations based on stakeholder input urging SSA to move forward
with a sense of urgency to enable beneficiaries to realize the promise
and full potential of the Act. Appendix C includes tables of Panel
legislative and regulatory recommendations made to-date, separated into
Panel recommendations for which Congress or SSA has not taken final
action and recommendations for which Congress or SSA has taken action.

Improving the employment outlook and labor market activity of
beneficiaries with disabilities requires continuous improvement in our
nation's largest disability programs. This requires not only continued
national dialogue regarding modernization of these programs but also
continued removal of disincentives inherent in the current programs and
immediate improvements to current work incentives to promote greater
utilization. For this reason, the Panel recommends the following
short-term improvements, outreach and ongoing oversight to build on
current Ticket to Work program outcomes and improve the lives of more
beneficiaries:

**Recommendation 2:** Congress should appropriate the funds necessary
for the Social Security Administration to support effective service
delivery, particularly related to the Ticket to Work program and
return-to-work such as work report processing and overpayments.

**Recommendation 3:** The Social Security Administration should publish
revised final regulations pertaining to the Ticket to Work program
(September 2005 Notice of Proposed Rule Making) no later than April 1,
2008.

**Recommendation 4:** The Social Security Administration should plan for
and, upon promulgation of the revised final regulations pertaining to
the Ticket to Work program (September 2005 Notice of Proposed Rule
Making), immediately implement a marketing plan for beneficiaries and
Employment Networks that is informed by evidence-based best practices,
the results of the Ticket to Work program evaluation, as well as
previously reported Panel recommendations.

**Recommendation 5:** Congress should extend the Medicaid Infrastructure
Grant and Demonstration to Maintain Independence and Employment program
authority through 2014 to stimulate innovation by states seeking to
refine comprehensive systems of employment supports for people with
disabilities.

**Recommendation 6:** Congress should renew, with greater Congressional
oversight, the Social Security Administration's demonstration authority
to design and evaluate additional strategies that overcome multiple
barriers to employment and support economic self-sufficiency for
individuals with significant disabilities and place urgency on getting
the demonstrations done.

**Recommendation 7:** Provide states flexibility in devising Medicaid
programs to reduce the marriage penalty for persons with disabilities.

**Recommendation 8:** The Social Security Administration should identify
business models for investing in independent living centers as
Employment Networks.

Work Incentive Improvements

The Panel finalized a set of recommendations in its report entitled
"UPDATE, SIMPLIFY, AND EDUCATE: A National Call to Optimize Incentives
to Work"[^6] to encourage Congress and federal agencies to make
incremental changes to current disability programs fostering a greater
investment in the work efforts of all beneficiaries. The recommended
actions were divided into three primary categories: Update, Simplify,
and Educate.

**Update** **Existing Work Incentives**. Update existing work incentives
to make them more applicable to the realities and employment support
needs of beneficiaries in 2007 and beyond.

**Recommendation 9:** The Social Security Administration should change
the order in which impairment -related work expenses are deducted when
calculating the Supplemental Security Income cash payment to allow for
up to a 100 percent cost recovery.

**Recommendation 10:** The Social Security Administration should allow
health insurance premiums to be used as impairment-related work
expenses, when the beneficiary can document that the coverage is
disability-related and supports work.

**Recommendation 11:** The Social Security Administration should
eliminate the condition that family members must suffer financial loss
for their compensation by the beneficiary to count as impairment-related
work expenses if they provide attendant care and/or transportation
to/from work to a person with a disability.

**Recommendation 12:** Congress should increase and index the key income
exclusion amounts and the resource limits under the Supplemental
Security Income program.

**Recommendation 13:** The Social Security Administration should approve
proposed rule changes to the Ticket to Work program to enable Employment
Networks to receive ticket outcome-only payments while a beneficiary is
receiving a Supplemental Security Income cash payment resulting from an
active Plan for Achieving Self-Support.

**Recommendation 14:** The Social Security Administration should allow
state vocational rehabilitation agencies to receive traditional cost
reimbursement if and when an individual is receiving a Supplemental
Security Income cash payment resulting from an active Plan for Achieving
Self-Support or claim of Blind Work Expenses.

**Simplify** **Work Incentives Programs**. Simplify the maze of work
incentives programs that exist not only within SSA but also in other
federal benefit programs so that those programs mutually support a
common work agenda and make work pay, while at the same time reduce the
risk of overpayments for beneficiaries and other unintended adverse
program interactions.

**Recommendation 15:** The Social Security Administration should reduce
the complexity and improve the consistency of work incentives across the
Supplemental Security Income and Social Security Disability Insurance
programs and other federal entitlements so that they universally support
work.

**Recommendation 16:** The Social Security Administration 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 allocate
sufficient resources to address post-entitlement workloads.

**Recommendation 17:** The Social Security Administration should
establish a cross-component internal Social Security Administration 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 18:** The Social Security Administration 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.

**Educate Stakeholders**. Educate and equip the array of stakeholders
supporting the return to work process, to ensure that beneficiaries
interested in going to work have access to customized, responsive,
timely, relevant and accurate information and services, including
accessible technology, to support their efforts.

**Recommendation 19:** The Social Security Administration and Congress
should strengthen both the Work Incentives Planning and Assistance and
Protection and Advocacy for Beneficiaries of Social Security networks by
establishing performance standards, adjusting funding levels and
resources to levels necessary to achieve the desired results, and
investing 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 20:** The Social Security Administration should
identify clear, objective performance standards and indicators to
evaluate the activities and impact of Area Work Incentives Coordinators
and Work Incentive Liaisons, and collect, analyze, document, and publish
evidence annually (by Social Security region and system-wide) of
customer satisfaction, improved employment outcomes, and advanced
self-sufficiency.

**Recommendation 21:** The Social Security Administration should collect
workload information on the number of Plan for Achieving Self-Support
applications submitted and approved, including the processing (wait)
time by state, and publish this information annually in the Social
Security Administration's SSI Disabled Recipients Who Work report. The
Social Security Administration should provide high quality training and
support, and fiscal resources for the effective administration and
outreach of the Plan for

Achieving Self-Support program. The Social Security Administration
should recruit, develop, and support Plan for Achieving Self-Support
specialists (travel, technology, et al).

**Recommendation 22:** The Social Security Administration should improve
reporting of data and analysis pertaining to Social Security Disability
Insurance (including Disabled Adult Children and concurrent Social
Security Disability/Supplemental Security Income beneficiaries) and
issue an annual report comparable to the Social Security
Administration's SSI Disabled Recipients Who Work report.

**Recommendation 23:** The Social Security Administration 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 24:** The Social Security Administration should
increase beneficiary awareness of earnings reporting requirements
including the waiver process for overpayments, and promote greater
self-efficacy.

[]{#__RefHeading___Toc185405213 .anchor}Increase Economic
Self-Sufficiency through Investment in Disability Program Modernization

Enactment and implementation of the Act has not produced the results
that Congress envisioned upon its passage.[^7] SSA has mailed more than
12 million tickets to individual beneficiaries in the last seven years.
Less than 184,000 tickets have been assigned as of September 30, 2007;
this amounts to an assignment rate of less than 1.5 percent. SSA
reported that, during the week of June 18, 2007, it made its first 60th
outcome payment to an EN for one of its beneficiaries with
disabilities. This means that this beneficiary has been successfully
employed at over the substantial gainful activity limit and off the
beneficiary rolls for 60 months. This is the first such payment SSA has
made since the program began.[^8] This contrasts with the estimate made
by the Congressional Budget Office (CBO) during the writing of the Act:

"Specifically, CBO estimates that the number of net additional
suspensions in DI\--that is, suspensions that would not occur in the
absence of the new program\--would equal 500 in 2003, 2,200 in 2004, and
an average of 4,600 annually between 2005 and 2007\...Over the 2003-2007
period, CBO estimates that there would be a total of 35,000 gross
rehabilitations of ticket holders..."[^9]

The Panel believes that incremental changes to the Ticket to Work
program and Social Security work incentives, while vital in the short
term, must be coupled with more sweeping policy changes and further
national dialogue regarding modernization of disability programs. As
long as eligibility for federal income support and health care programs
is based on the inability to engage in substantial gainful activity that
results from a medical impairment expected to last for at least one
year, the clear message to people with disabilities will be that they
are inherently unable to support themselves through work. This problem
was also cited in the U.S. House of Representatives Committee on
Commerce Report accompanying the Ticket to Work legislation.[^10] In
short, our largest public programs consistently tell our working-age
population with disabilities that we don't expect them to work or
participate fully in their communities.

This message has not changed in any meaningful way since the eligibility
criteria for SSDI were developed in 1956,[^11] and it is compounded by
messages from family, friends, community, other government programs, and
the media. Low expectations have combined with fundamental flaws in the
largest public programs serving Americans with disabilities to relegate
millions of Americans to the periphery of society. For many, our
disability programs become a poverty trap that is almost impossible to
escape. The statistics regarding people with significant disabilities
and the programs that serve them reinforce the need for fundamental
changes:

-   The employment rates of men and women with significant disabilities
    have not improved and may have declined between 1986 and 2004.[^12]

-   According to the Current Population Survey, the employment rate of
    working age people with a work limitation dropped from 24.5 percent
    in 2000 to 19.3 percent in 2004.[^13]

-   Partially as a result of changing demographics, including an aging
    population, disability income support programs are growing at rates
    that are outpacing the general population growth. Between 1989 and
    2005, the general U.S. population grew from 246.8 million to 296.5
    million. During that same period, the number of SSDI beneficiaries
    increased from 4.1 million to 8.3 million, and the annual total
    expenditures rose from \$23.8 billion to \$88.0 billion. The number
    of individuals receiving SSI due to disability or blindness rose
    from 3.1 million to 5.9 million, and the annual Federal expenditures
    rose from \$9.2 billion to \$29.2 billion.[^14]

-   Between 1989 and 2005, the number of SSI recipients under age
    18 increased from 299,200 to 1.0 million, growing as a percentage of
    the total SSI beneficiary population from 7 percent to 15
    percent. On average, people who enter SSI prior to age 18 remain on
    the rolls for 27 years.[^15]

This need to modernize disability programs has also been recognized by
the bipartisan Social Security Advisory Board;[^16] by the National
Council on Disability[^17] under Presidents Ronald Reagan, George H.W.
Bush, William Jefferson Clinton, and George W. Bush; by the Comptroller
General of the United States;[^18] and by disability advocacy groups
like the American Association of People with Disabilities,[^19] the
National Council on Independent Living and the World Institute on
Disability.[^20]

People with disabilities are a diverse population with varying needs,
access to intangible supports and work capacities. In addition, because
there are variations in local labor markets, no single program or policy
will be universally successful in promoting work and meeting the needs
of all people with significant disabilities. Rather, mutually supportive
and flexible programs and policies need to be designed and tested to
determine how best to support people with significant disabilities at
various stages of onset and disability management and levels of work
capacity. These policies and programs should build on demonstrations and
innovations that are producing results at the state and local levels,
and should allow for modernization at all levels of government.

The Panel proposes the following set of recommendations to promote
ongoing national dialogue regarding modernization and supports long-term
investment in an employment strategy for Americans with disabilities.
Key elements to this employment strategy are:

Raise Expectations

**Recommendation 25:** The President should take the lead to establish
and provide financial support for a comprehensive, cross agency,
culturally competent social marketing campaign to raise expectations
about the productive employment potential of people with disabilities.
This campaign should target people with disabilities, their families,
educators, employers, health care professionals and those that serve
people with disabilities and the community. This marketing campaign
should use the most accessible and effective media, including
television, radio, the internet, and mainstream and specialty magazines
and newspapers.

Promote Workforce Connection and Retention

**Recommendation 26:** Congress should create employer incentives to
increase the availability of effective workforce retention policies and
programs to keep working adults with newly-diagnosed or
recently-exacerbated medical conditions connected to the workforce.

**Recommendation 27:** The Social Security Administration should
implement a demonstration that tests the costs and benefits of
establishing a publicly supported short-term disability insurance
program at the state level modeled on the best programs that have been
developed in the private sector and by state governments, which would be
available to individuals with work histories who do not have private
disability insurance.

Enhance Job Opportunities

**Recommendation 28:** The President should implement a job creation
strategy that engages and incentivizes public and private sector
employers in targeting people with significant disabilities for jobs
that pay a living wage and have benefits that enable a beneficiary to
move successfully from benefit receipt to employment, through a new
level of collaboration among state and federal employment and economic
development programs, the business community and disability
organizations.

Improve Access to Health Care and Long-Term Services and Supports

**Recommendation 29**: Congress should work in a bipartisan fashion to
build on the goals of the Medicaid Buy-In and the Medicaid
Infrastructure Grant to ensure that people with significant disabilities
have access to affordable coverage for health care and long-term
services and supports that is comprehensive; portable; supported by
beneficiary contributions, where appropriate; independent from
qualifying for income support; and coordinated with employer-sponsored
benefits.

Create a Transition to Economic Self-Sufficiency Large-Scale
Demonstration Program

**Recommendation 30:** The Social Security Administration should design
and implement a large-scale demonstration project that studies the
feasibility, cost-effectiveness, and any unintended consequences of a
voluntary Transition to Economic Self-Sufficiency Program for young
people who are between 14 and 30 years old and qualify for Supplemental
Security Income and/or Social Security Disability Insurance. This
demonstration project would build on the goals of the Ticket to Work
program and evaluate the feasibility of a program that would transform
Supplemental Security Income and Social Security Disability Insurance by
establishing unified rules that: provide a graduated cash payment to
address the effects of disability-related barriers on income; build on
the Ticket to Work program to increase the availability of and consumer
control over employment-related services; promote optimal educational
outcomes; and enable program participants to maximize income and assets
without fear of losing critical supports.

Modernize the Social Security Definition of Disability

**Recommendation 31:** Congress and the Administration should take
action to evaluate the impact of modernizing the Social Security
definition of disability by defining disability in a manner that
acknowledges the interaction between the person's impairment and the
environment and does not require the individual to prove their inability
to engage in substantial gainful activity.

Coordinate Disability Programs at the Federal Level

**Recommendation 32:** The Domestic Policy Council should ensure ongoing
communication and collaboration among federal programs that provide
employment services and supports.

A Call to Action

Eight years ago, the President, Congress, and SSA agreed to invest in
human potential and to reduce or eliminate remaining barriers to
employment and economic participation for people with disabilities.
Today, costs and frustration increase with the slow pace of progress. To
an individual with significant disabilities, a timely intervention means
the difference between an independent life and one of poverty and
dependence.

The Panel urges Congress and SSA to take action on its recommendations,
acknowledging that people with significant disabilities must play a
central role in designing and implementing any new or modernized system.
An investment focused on modernization rebalances risk and aligns public
policy and systems in support of employment and self-sufficiency.

#  Introduction {#introduction .Exec-Heading}

"What more do we need to tell people that the system is broken? It's an
antiquated system...for individuals who were believed never to work
again. Persons with disabilities are missing out on one of life's most
valued gifts, the ability to work and feel productive by contributing to
society. Our disabilities must not also sentence us to a life of
poverty. We crave the equality and are willing and able to work."

Michelle Martini, Delegate from Wisconsin

Beneficiary Summit

Atlanta, Georgia

February, 2007

The Ticket to Work and Work Incentives Improvement Act of 1999 (the Act)
is administered by the Social Security Administration (SSA) and the U.S.
Department of Health and Human Services (HHS). It increases
beneficiaries' choices for rehabilitation, vocational services and other
employment supports, reduces barriers associated with choosing between
health care coverage and work, creates safety nets and protections that
support work, and provides a vehicle to ensure that more Americans with
disabilities are employed and reduce their dependence on public
benefits. Appendix A provides a summary of the provisions of the Act.

The overwhelming bipartisan support for the legislation represented a
continuing evolution in thinking and attitudes about the capacity of
people with disabilities to work, contribute to our nation's economy,
and reduce their reliance on public benefits. Nine years after the
passage of the Americans with Disabilities Act (ADA) of 1990, Congress
recognized that multiple barriers still remained for the full
participation of working-age adults with disabilities in the economic
mainstream. Citing innovations in assistive technology, medical
treatment and rehabilitation, as well as advances in public
understanding of disability and the desire of many beneficiaries to
work, the Act authorized a dynamic set of changes to policy and programs
intended to reduce or eliminate several of the most significant barriers
remaining to employment for beneficiaries of Supplemental Security
Income (SSI) and Social Security Disability Insurance (SSDI).

With passage of the Act, Congress made clear its intent "to redesign
government programs to help individuals with disabilities return to
work," which "may result in significant savings and extend the life of
the Social Security Trust Fund."[^21] Congress calculated that if only
an additional one-half of one percent of the current SSDI and SSI
beneficiaries were to cease receiving benefits as a result of
employment, the savings to the Social Security Trust Fund and to the
U.S. Treasury would exceed \$3.5 billon over the work life of such
individuals. Such savings would far exceed the cost of providing
incentives and services needed to assist beneficiaries in entering the
workforce and achieving financial independence.[^22]

The SSA Strategic Plan for FY 2006-2011[^23] states that the mission of
the agency is "to advance the economic security of the Nation's people
through compassionate and vigilant leadership in shaping and managing
America's Social Security programs." Millions of beneficiaries with
disabilities expect services and supports that are responsive to a
changing environment, including a choice to work with continued access
to health care and other needed work supports.

In its Strategic Plan, SSA identified as a major strategic objective to
"increase employment for people with disabilities by expanding
opportunities" with a long-term outcome "to achieve greater financial
independence through employment." SSA's Comprehensive Work Opportunity
Initiative (Figure 1 below) affirms that most individuals with
disabilities face multiple barriers to employment and need solutions
that are flexible and can be customized to individual circumstances.

This final report shares what the Panel has learned during the past
eight years and makes recommendations in three areas:

1.  Elevate and incorporate the beneficiary voice in all aspects of
    program and policy development, evaluation and improvement;

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6.  Optimize current work incentives through short-term and incremental
    policy improvements; and

7.  Increase economic self-sufficiency through investment in disability
    program modernization.

This final report offers short- and long-term recommendations that are
informed by the knowledge gained from the personal experiences and
professional expertise of Panel members, research findings culled from
data analysis and open forum discussions, and the syntheses of hundreds
of suggestions that reflect the diversity of the target population. The
final Panel recommendations not only focus on fundamental policy
changes, but also recognize the need for continued infrastructure
development to support implementation. Another consideration reflected
in the recommendations is a belief that an investment of resources is
required to reach beneficiaries and to respond and adapt to their
evolving individual needs.

**Figure 1. The Comprehensive Work Opportunity Initiative:**

Overcoming Barriers to Employment[^24]

![](media/image3.png){width="5.993055555555555in"
height="4.530555555555556in"}

While the Panel feels strongly that implementation of its short-term
recommendations will help reduce the multiple barriers to employment;
equally as important is a national dialogue and subsequent investment in
a modernized disability policy and service system. The modernized system
must achieve more dramatic reductions in barriers to work and improved
employment outcomes.

# History of the Panel {#history-of-the-panel .Exec-Heading}

The Panel was established under the Act in March 2000. Twelve
individuals serve on the Panel at a time: four appointed by the
President, four by the U.S. Senate, and four by the U.S. House of
Representatives. The appointees represent a cross section of experience
and expert knowledge as recipients, providers, employers and employees
in the fields of employment services, vocational rehabilitation,
veterans programs, and other disability-related support services. Most
Panel members are individuals with disabilities or their
representatives, with several having had personal experience as
beneficiaries of SSA disability programs. A list of current and former
Panel members is provided in Appendix B.[^25]

Duties of the Panel include advising the President, Congress, and the
Commissioner of SSA on issues related to work incentive programs,
planning and assistance for individuals with disabilities and the Ticket
to Work program. The Panel scheduled public meetings at least quarterly,
alternating locations between Washington, D.C. and, in its early years,
the Ticket to Work program roll-out states, to hear regional testimony.
The Panel submitted interim reports on the implementation of the Act to
the President and Congress on an annual basis. Appendix C includes two
tables of Panel legislative and regulatory recommendations made to-date,
separated into Panel recommendations for which Congress or SSA has not
taken final action and recommendations Congress or SSA have acted upon.
This is the eighth and final report. The Panel's legislated authority
ends on January 17, 2008.

##  {#section-1 .Annual-Report-Heading-2}

Listening to and Responding to the Needs of Diverse Stakeholders

##  {#section-2 .Annual-Report-Heading-2}

The challenge the Panel faces in crafting recommendations to the
President and Congress was articulated clearly in the recent report of
the Social Security Advisory Board (SSAB) entitled "*A Disability System
for the 21st Century*."

"The challenge is how to implement a strategy that meets the aspirations
of the ADA, fulfills the needs of persons with disabilities, maintains
the protections provided by the Social Security disability programs, and
is fiscally responsible and sustainable." [^26]

To meet its responsibilities, the Panel has used multiple strategies to
gather evidence and document results regarding the unmet needs,
concerns, and challenges facing diverse stakeholders at a local, state,
and national level.

During the past eight years, the Panel and other organizations such as
the U.S. Senate Committee on Finance, the U.S. House of Representatives
Committee on Ways and Means Subcommittee on Social Security, the SSAB,
the Government Accountability Office (GAO), the National Council on
Disability (NCD), and the National Academy for Social Insurance (NASI)
have engaged policy experts, federal officials, practitioners, and
persons with disabilities in public hearings, small group think tanks,
and qualitative and quantitative research studies to identify
improvements and, if necessary, transformative approaches to promote
employment and a better economic future for individuals with significant
disabilities. In addition to maintaining open and regular communication
with Congressional staff, federal agency officials, and national
disability organizations, the Panel conducted literature reviews and
engaged diverse stakeholders to share their findings and
recommendations. The Panel questioned stakeholders on the status of
implementation of the Act, with particular attention to the Ticket to
Work program, adoption by states of Medicaid Buy-In programs, and
strategies to improve coordination of work-related supports among
multiple federal agencies. The Panel sponsored targeted summits with
employment service providers and beneficiaries to explore issues of
critical importance to each group. Throughout all of these activities,
the Panel conducted ongoing analysis of data and information received.

Through letters detailing recommendations and informal discussions with
SSA and other federal agencies, the Panel has impacted program design,
communications, and resource allocation. With public comment
opportunities at each quarterly meeting and participation in a wide
range of relevant regional and national conferences, Panel members have
listened to and been part of discussions that helped inform future
decision-making.

Panel members have met regularly with lead staff at SSA and relevant
Congressional committees to advise them on ways to strengthen the Ticket
to Work and related work incentive programs. Panel members have also
participated extensively in a concerted effort to increase communication
with and outreach to the disability community. In Washington D.C. and
across the country, Panel members have engaged national organizations
representing employment networks (ENs) and persons with disabilities,
including multiple task forces of the Consortium for Citizens with
Disabilities, in discussions promoting work for beneficiaries. Panel
members have visited Social Security field offices, One-Stop Career
Centers that are part of the federally funded workforce investment
system, and workplaces where small business and large employers are
benefiting from the productivity and contributions of workers with
disabilities. Appendix D lists a sampling of the Panel's outreach
efforts since 2001.

In various venues nationwide, policymakers, practitioners, and persons
with disabilities have helped Panel members improve their understanding
of the diversity of beneficiaries as defined by age, level of
disability, gender, race, culture, and economic status. At quarterly
meetings, Panel members heard stakeholders from the public and private
sectors share important recommendations to promote policy and program
implementation improvements within SSA and other relevant federal
agencies. The Panel has listened to different voices\--all sharing the
common message that legislation must: a) ease the transition from SSA
disability programs to work; b) ensure access to medical benefits, when
needed; and c) encourage the advancement of financial/economic
self-sufficiency. Across federal agencies, service and support
coordination and integration at a community level must improve. In
addition, there must be a government-wide acceptance of work as a
preferred option to promote independence and enhanced community
participation for individuals with disabilities.

##  {#section-3 .Annual-Report-Heading-2}

Panel Strategic Plan for 2006-2007

##  {#section-4 .Annual-Report-Heading-2}

In 2005, the Panel undertook a formal strategic planning process to
guide final Panel action and decision-making. As a result, the Panel
again affirmed and elevated principles that have guided it since its
inception. First, all people should be afforded a meaningful opportunity
to participate in the economic mainstream with or without ongoing
supports and services. Second, the perspectives of beneficiaries must be
heard, communicated and integrated into the recommendations of the
Panel. The diversity of beneficiaries must be recognized to include
people from various age groups, with different impairments, levels of
education, work experience, capacities for working, culture, ethnicity,
and socioeconomic status. Third, programs should not harm those they are
designed to help.

The Panel recognized its important role promoting change specific to
available work incentive options and to the Ticket to Work program. It
also examined the larger context of programs and polices essential to
increased employment and economic self-sufficiency for people with
disabilities. The Panel identified three goals to frame final
recommendations:

1.  Elevate and incorporate the beneficiary perspective.

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8.  Improve implementation and marketing of the Ticket to Work program
    and other work incentives.

9.  Develop a national employment investment strategy to transform
    approaches to assets, income, health care and supports for people
    with disabilities that is person-centered, culturally competent, and
    respective of each person's values and experience.

# Findings: History and Trends {#findings-history-and-trends .Exec-Heading}

To understand the Panel's recommendations, which highlight the value of
work and examine the economic consequences of failing to improve and
modernize current policies and program implementation, it is important
to understand the historical context of the existing Social Security
disability programs, work incentive options, and various national
trends.

##  {#section-5 .Annual-Report-Heading-2}

Social Security Disability Programs: SSI, SSDI, and Work Incentives

SSI and SSDI

SSA manages the nation's two largest federal disability programs: SSDI
and SSI. The two programs provide safety-net supports of income and
health care for millions of individuals nationwide. Since 1985, the
number of individuals receiving disability benefits through the two
programs has grown significantly.

In the past 15 years, according to findings of the SSAB, the working age
population of the U.S. has grown by 18 percent. During that same period,
the number of persons receiving SSDI benefits has grown by 117 percent
and the number of working age SSI recipients has grown by 66 percent.
The number of disabled workers on SSDI has more than doubled since 1990
from 3.0 million to 6.8 million in 2006 (Figure 2). The 2006 report of
the SSAB indicated that 5.2 million individuals under age 65 receive SSI
based on disability.[^27]

According to SSA statistics, 28 percent of SSDI beneficiaries depend on
these benefits for 100 percent of their income and 47 percent of working
age SSI recipients depend solely on their income from SSI. In both
programs, the income payments represent more than 75 percent of the
total income for a majority of such beneficiaries. On an annual basis,
federal benefits paid to eligible individuals exceed \$125 billion.

Figure 2, Social Security Disability Insurance,

Disabled Worker Beneficiaries, 1990 - 2006

![](media/image4.wmf){width="5.963888888888889in"
height="3.3819444444444446in"}

Source: SSA\'s Performance and Accountability Report FY 2005

Note: Source of 2006 data is Year 2006 Statement of Michael J. Astrue
before the Senate Special Aging Committee, February 15, 2007.

After going through a long process to receive disability benefits, few
people currently risk losing them by returning to work. According to the
Office of Management and Budget's (OMB's) Program Assessment and Rating
Tool, in 2006, the average processing time for initial disability claims
was 88 days and the wait time for a hearing averaged 483 days.[^28]
After applying and finally being approved to receive benefits, only a
small percentage of beneficiaries with disabilities work and earn enough
to leave the disability rolls on a temporary or permanent basis.
Policymakers struggle to reconcile a program for which eligibility
requires individuals to prove a permanent inability to work with the
needs of individuals who want to return to work, but require a flexible
system that can provide supports that make work possible.

In 1956, Congress expanded the Social Security program to help people
who were over age 50 who were unable to engage in any substantial
gainful activity (SGA) by reason of a medically determinable physical or
mental impairment that could be expected to result in death, or to be of
a long continued and indefinite duration. The legislation combined cash
benefits with referral to state vocational rehabilitation (VR) agencies
to assist with services that might result in a return to work.

By June 1958, more than 800,000 individuals had been referred to VR
agencies, but only about 550 beneficiaries (0.02 percent of the
beneficiary population) had been successfully rehabilitated. 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 complete 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
beneficiaries' return 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 percent of the beneficiary
population.[^29]

In 1972, Title XVI of the Social Security Act created the SSI
needs-based program. 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 with earned and
unearned income are allowed a \$20 general income exclusion and a \$65
earned income exclusion, as well as, a \$1 benefit offset for every \$2
earned. Additional income exclusions are also applied, recognizing the
additional costs associated with employment and designed to ensure that
a recipient will always have higher gross income from working than if
they did not work.

Since the beginning of the SSI program in 1974, Congress has authorized
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.[^30] 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 Extended Period of Eligibility
(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 1987.

Even with these changes, few SSI or SSDI beneficiaries were leaving the
rolls for work. Loss of health care and other supports needed for work
were viewed as being the primary reason. A 1992 study found that about
10 percent of beneficiaries entitled in 1980-1981 performed some work
over a period of approximately 10 years, but only about 2 percent left
the rolls.[^31] Additional research showed that over 80 percent of
beneficiaries were unaware of the work incentives and few used
them.[^32] VR "seemed to have a positive effect on work resumption," but
only about 2 percent of beneficiaries received VR services. Physical
therapy, vocational training, general education, and job placement
efforts increased the tendency to go back to work.[^33]

Use of Work Incentives

The Panel has spent significant time learning about and listening to the
perspectives of diverse stakeholders regarding SSI and SSDI eligibility
requirements and the use of existing work incentives. For a more
detailed overview and analysis of the SSI and SSDI programs and
beneficiary use of work incentives, please see the Panel's work
incentive utilization report "*UPDATE, SIMPLIFY, AND EDUCATE: A National
Call to Optimize Incentives to Work."*[^34]

The Panel was dismayed to learn that, despite all the policy
improvements and work incentives outreach efforts since the inception of
the Act, work incentive utilization has been on a steady decline. Data
provided by SSA demonstrates that the number of workers using IRWEs and
Blind Work Expenses (BWE) has declined to its lowest level since 1990
(just 1.6 percent used IRWEs and 0.7 percent used BWEs). Plan for
Achieving Self-Support (PASS) utilization also continued to drop through
2005 (1582 plans) and leveled off in 2006 (1583 plans). In December
2006, 0.5 percent of SSI recipients had a PASS plan and only 409
individuals nationwide had earnings. Little or no data is available on
utilization of TWP, EPE, IRWEs or the provision of subsidies and special
considerations for SSDI beneficiaries.[^35]

The Integration of Work Incentives: Complexity of Rules

"I've Googled, researched, read, and asked questions from the person who
answers the phone at the help desk all the way up to the director of
programs, agencies, and fellow researchers to gain a fuller
understanding of the work incentives program. Yet, I am stopped dead in
my tracks when it comes to knowing what to do and how to survive Social
Security, access the Ticket program, and survive the mazes created from
the bureaucratic layers that Andy and I must traverse for him to have a
life like yours."

Donna Martinez

Mother of Andy, Ticket holder

Ticket to Work and Work Incentives

Advisory Panel Quarterly Meeting

Washington, DC

August, 2006

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

For SSDI beneficiaries, the complexity includes:

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

-   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.);

-   Restarting of benefits no later than the 37th month after the end of
    the 9-month (not necessarily consecutive) TWP;

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

-   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 during the EPE before payments are
    stopped if the beneficiary has earned SGA;

-   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; and

-   A maximum of 93 consecutive months of Medicare after cash benefits
    stop, starting with the last month of the 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 tying cash
benefits to health insurance, and the 1619 provisions provide for a
smoother transition. However, 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 for any
changes.

The Panel has heard a great deal of testimony about the significant fear
beneficiaries have of losing their benefits and their access to health
care, as well as their reluctance to risk losing their benefits after
undergoing a lengthy and rigorous eligibility process. Often, incentives
do not go far enough to offset the impairment-related expenses or the
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.

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

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 often-conflicting work incentives and eligibility
provisions.

According to a 2002 report by the GAO,[^36] concurrent beneficiaries
account for about 14 percent of SSA's disability population, and about
11 percent of concurrent beneficiaries work, compared to 8 percent of
SSI-only recipients. While a greater percentage of concurrent
beneficiaries appear to be working, the average median monthly earnings
of concurrent beneficiaries is less: \$250 compared to \$400 for
SSI-only recipients.

This GAO report explored the implications of uncoordinated program rules
on SSA payment inaccuracies. The GAO found that information affecting
benefits or eligibility is not reported timely and/or that information,
once reported, is not processed timely. Field office employees generally
specialize in only one of the programs, so the staff may not be fully
aware of rules for both, making it difficult for them to offer sound
guidance. 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.[^37]

SSA Workloads

The primary focus of SSA workloads for FY 2006-2011 continues to be the
disability program, which according to SSA's Strategic Plan[^38] "is in
need of the most improvement." The most significant external factors
affecting SSA's ability to improve service to applicants with
disabilities is the dramatic growth of workloads and the increasing
complexity of those workloads.

SSI redeterminations and CDRs represent two of SSA's main efforts
towards processing the information affecting benefits or eligibility in
a timely manner and helping to prevent and detect improper payments. SSI
redeterminations yield a savings of \$7 for every \$1 spent in
administering them, and CDRs in the SSDI program save \$10 in program
benefits for every \$1 spent.[^39] SSI redeterminations assess whether
an 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 policies
to increase the number of SSI redeterminations processed and to improve
the profiles that are used to select cases for review.[^40] In FY 2005,
SSA completed 1,724,875 redeterminations; it is estimated that this
effort produced \$1.5 billion in overpayments.[^41] CDRs conducted in
2005 are estimated to yield more than \$5 billion in program
savings.[^42] SSI redeterminations and CDRs have been identified as cost
effective efforts to detect and to reduce overpayments in the SSI and
SSDI programs. However, former SSA Commissioner Barnhart[^43] determined
that, due to budget cuts in FY 2006, 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 House Subcommittee on Social Security,[^44]
the lack of resources to conduct CDRs and SSI redeterminations will
adversely impact SSA's ability to significantly reduce overpayments.

More than 40 percent of SSA employees are expected to retire by 2014,
while SSA's workloads are expected to grow dramatically as the baby boom
generation approaches their peak disability and retirement years.
Consequently, the greatest human capital challenge facing SSA is to
maintain a high performing, smaller workforce that is prepared to
deliver quality service.

Future Financing Challenges

In a 2003 report, GAO[^45] designated the federal disability programs as
a high-risk area---one that requires urgent attention and organizational
transformation to ensure that programs function in the most economical,
efficient, and effective manner possible. This designation was based on
more than a decade of research focusing primarily on the nation's
largest disability programs, which includes the SSA disability programs.

In several reports, GAO has identified the challenges of future
financing of SSA programs. In a May 2005 report, GAO stated that SSA
"faces a long-term actuarial deficit and that benefit reductions and/or
revenue increases will be necessary to restore solvency."[^46] Further,
GAO reported that while the program does not face an immediate crisis,
it does have a \$4 trillion gap between promised and funded benefits in
current dollar terms over the next 75 years. Social Security's finances
have important implications for the overall federal budget. The current
Social Security surpluses will begin to decline in 2009, thereby putting
additional pressure on the balance of the federal budget. In addition,
in the near future, Social Security's benefit costs will start to grow
rapidly.

As a result of the aging population and slower labor force growth, fewer
workers will be contributing to Social Security. According to another
2005 GAO report on Social Security reform,[^47] while currently 3.3
workers support each Social Security beneficiary, only 2 workers are
expected to be supporting each beneficiary by 2040. In 2017, Social
Security is projected to pay out more in benefits than it receives in
revenues. After 2017, the gap between costs and income is expected to
grow continuously, and, unless action is taken to close this gap, the
trust funds are projected to be depleted in 2041. At that time, annual
income will only be sufficient to pay about 74 percent of benefits and
by 2079, income will only be sufficient to pay about 68 percent of
benefits.

**[Implementation of the Ticket to Work and Work Incentives Improvement
Act]{.underline}**

To further encourage beneficiaries to work, Congress enacted the Act,
which addressed the threat of losing health benefits by extending
Medicare coverage for working beneficiaries to 102 months from 36
months, and established a state option to offer a Medicaid Buy-In
program for workers with disabilities. The Act expanded work incentives,
providing SSDI beneficiaries and SSI recipients with the option to
receive a ticket. Ticket holders can use it to secure employment
services, training, and other supports from ENs of their choice. This is
a market-driven approach to expanding employment service options for
beneficiaries.

The Act also eliminated work-triggered CDRs; created a work incentive
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 Act was generally viewed as greatly
expanding both opportunities and incentives for people with disabilities
to go to work. The Ticket to Work program is outcome-based, authorizing
payments to ENs based upon employment outcomes.

This section analyzes the implementation of the three elements of the
Act: Title I, Ticket to Work and Self-Sufficiency and Related Programs;
Title II, Expanded Availability of Health Care Services; and Title III,
Demonstration Projects and Studies.

Ticket to Work and Self-Sufficiency and Related Programs

The Ticket to Work program provides eligible SSDI beneficiaries and SSI
recipients with a ticket voucher that can be used to access employment
services and supports from VR or an independent private not-for-profit
or for-profit entity that has been certified by SSA as an EN. The
rollout of the Ticket to Work program with mailing of tickets to
beneficiaries was staggered over a three-year period nationwide,
beginning with Phase One states in 2002. By 2004, all fifty states, the
District of Columbia and U.S. territories had become a part of the
Ticket to Work program and over 10 million tickets had been distributed
to beneficiaries. Program participation for beneficiaries is voluntary.

According to the latest evaluation data available from Mathematica
Policy Research, Inc., "As of December 2004, there were 9.23 million
ticket-eligible beneficiaries. About 30 percent of them are in the Phase
1 states, another 30 percent are in the Phase 2 states, and the
remaining 40 percent are in the Phase 3 states."[^48]

In addition, the most recent evaluation narrative reports that "\[b\]y
December 2004, 83,568 tickets were in use. Reflecting the rollout
schedule, 45 percent of the tickets were held by beneficiaries residing
in Phase 1 states, 30 percent in Phase 2 states, and 25 percent in Phase
3 states. Participation rates continued to rise steadily. The Phase 1
participation rate reached 1.38 percent in December 2004, the Phase 2
rate reached 0.90 percent, and the Phase 3 rate reached 0.56
percent."[^49]

Since the inception of the Ticket to Work program, SSA has experienced
great difficulty recruiting ENs. As of November 7, 2007, there are 79 VR
agencies and 1,247 other community providers operating as ENs. In
addition, SSA has yet to identify and implement effective means to
encourage beneficiaries to participate in the program. As of August 17,
2007, SSA has issued 12,850,338 tickets: 11,950 or 0.1 percent have been
assigned by beneficiaries to ENs that are not part of the VR system and
172,336 tickets have been assigned to VR agencies.[^50] Combined, only
1.4 percent of eligible beneficiaries have participated in the Ticket to
Work program. Based on employment outcomes achieved for a ticket holder,
an EN currently receives payments from SSA through two options: a
milestone payment system or an alternative five-year outcome-based set
of measures. As of June 15, 2007, SSA has made milestone or outcome
payments to ENs including VR agencies on behalf of only 3,061
beneficiaries.[^51]

No subject has dominated the attention of the Panel more than the
challenges faced by the Ticket to Work program. During every public
meeting over the past eight years, the Panel has included presentations
by SSA on the status of implementation, strategies to increase the level
of participation by beneficiaries, and efforts to expand the number of
ENs to serve them. Each quarterly meeting has also included diverse
stakeholders offering testimony on experiences with the program and
suggestions on how to improve it. The Panel has heard examples of
successful participation, which offer hope about the possibilities for
the future, leading the Panel to suggest amendments to the reimbursement
system and a greater focus on marketing and outreach to beneficiaries.
Based on stakeholder input, the Panel has submitted multiple
recommendations encouraging SSA to make urgent progress toward a
realization of the promise and full potential of the Act.

Evaluation of the Ticket to Work Program

The Act mandated that SSA conduct an evaluation study to determine
successes and problems in implementation of the Ticket to Work program.
Four broad areas are being studied via interviews, site visits, analysis
of SSA and Rehabilitation Services Administration data sets, and other
sources. The following areas of analysis are included in the evaluation:
process, participation (beneficiary and provider), impact/outcomes, and
adequacy of incentives. The evaluation contract was awarded to
Mathematica Policy Research, Inc., and has yielded three reports to
date.

In general, the Panel agrees with most evaluation findings. In fact, the
Panel's recommendations often mirror the concerns of evaluators. For
instance, the evaluation has found that, in general, Ticket to Work
program implementation has been successful, but the implementation has
not yielded the level of choice for beneficiaries that Congress
envisioned.

"...While \[the Ticket to Work program\] has expanded beneficiaries'
choice of providers, most of the participation has been with VR agencies
using the traditional payment system. Only 16 percent of Tickets are
being used under the two new payment systems. The pattern suggests that
\[the Ticket to Work program\] does not yet represent a dramatic break
from the past. Instead, its progress so far represents the introduction
of new choices and incentives whose ultimate effect will depend on the
eventual level of participation and the extent to which ENs and VR
agencies offer newer and more effective services."[^52]

The evaluation also identified several reasons for the low participation
rates of beneficiaries and ENs. The payment structure for ENs and the
role of VR agencies in the Ticket to Work program were cited as problems
in the evaluation. Many of the structural issues identified in the study
can be mitigated if SSA's September 2005 notice of proposed rulemaking
is made final. For example, the evaluation predicted the following:

"\[T\]he new regulations allow ENs to accept Tickets from the Ticket to
Work program participants who received employment services from an
\[state vocational rehabilitation agency\] SVRA under the cost
reimbursement system. In doing so, they will be able to reduce the
upfront costs for outreach, screening, and employment services, focus on
providing ongoing support services necessary for the Ticket to Work
program participants to maintain employment, and thereby improve their
chances of breaking even under the program."[^53]

In their most recent report, the evaluators reported positive results
with regard to SSA staff attitudes toward employment for beneficiaries.
"Changes in administrative procedures appear to have started a shift
toward an SSA culture that supports return-to-work. SSA staff members
interviewed for this report suggested a positive shift toward an SSA
culture that is clearly supporting return-to-work for beneficiaries. The
reported shift appears to stem from the fact that many employees who
serve beneficiaries with disabilities are learning about and becoming
more substantially involved in efforts to improve beneficiary earnings.
Many receive training in Ticket and, more broadly, the DI and SSI work
incentive programs; many have been introduced to and are now using new
data systems that track employment and other post-entitlement outcomes;
and many were involved in the effort to clear the post-entitlement
workload backlog."[^54]

The Panel is pleased to know of this positive development; however, the
anecdotal evidence heard through public comment and the beneficiary
summit indicates to the Panel that there may still be some work to do in
this area. Beneficiaries still report to the Panel that return-to-work
information imparted from SSA field offices is sometimes inconsistent
and/or incomplete.

The Panel does continue to have concerns about the evaluation's analysis
of the Adequacy of Incentives (AOI) Study. Congress recognized that the
Ticket to Work program would not be equally available to all individuals
with disabilities. In particular, some people with significant
disabilities might be involuntary non-participants. That is, they might
be willing to work but, because of their limited wage potential or their
need for ongoing support and services, high-cost accommodations, and/or
partial cash benefits, as well as outside factors, they might not find
an EN willing or able to take their ticket under the existing financial
incentives of the Ticket to Work program. These four groups are referred
to as the AOI groups.

To address this equity issue, Congress included a requirement in the
statute that SSA identify and implement a payment system that would
allow this population to participate in the Ticket to Work program.

The Panel recommended in 2002 that "While there is a need to take
advantage of what is known about the diagnostic categories with high
proportions of those most likely to fall into one of the four groups
relative to work capability, the Social Security Administration, in
addition to diagnostic data, should use other information, such as
survey information, information on earnings, onset date, and medical
improvement assessments. SSA should also go to outside data sources,
such as those identified in Expert Roundtable Recommendation 1, to
identify members of the four target groups."[^55] Evaluators have
examined the populations of beneficiaries targeted by SSA. The Panel
remains skeptical that the four AOI groups are adequately identified.

On a related topic, the proposed Ticket to Work regulations of September
2005 represent a likely improvement in service provision for some of the
AOI target populations. This is due to the decoupling of VR services
from those of ENs, thereby providing the possibility for both front-end,
more costly services/accommodations via VR and five years of
follow-along by an EN. However, the needs of the AOI target group
requiring long-term follow-along were not fully addressed in the
proposed regulations. An open question is what happens to individuals
requiring life-long or significantly long-term services and supports
after the five year follow-along available via the Ticket to Work
program.

Proposed Revisions to the Ticket to Work Program

Proposed revisions to the Ticket to Work program were published by SSA
in the Federal Register on September 30, 2005[^56] and included many
recommendations made by the Panel. On September 28, 2006, the one year
anniversary of the publication of proposed amendments, the Panel sent a
letter to the Commissioner of SSA emphasizing the importance and urgency
of issuing the final regulations. At the Panel's last quarterly meeting
in 2006, SSA reported that the final regulations would be further
delayed as a result of issues that needed to be addressed in a new
notice of proposed rulemaking (NPRM). The identified issue related to
the "Ticket in Use" by beneficiaries in higher education and the
procedures for suspension for a time-limited period of required CDRs. On
August 13, 2007, the NPRM was published in the Federal Register[^57]
along with several additional proposed amendments. A final rule is not
expected to be published until the spring of 2008. Without a final rule
offering significant improvements and thereby renewing EN and
beneficiary interest, efforts at marketing and outreach will remain
challenging. In the interim, SSA is identifying ways to effectively
market to beneficiaries. In the spring of 2007, SSA began holding pilot
Work Incentive Seminars. These seminars are community level, small group
informational sessions that give beneficiaries the opportunity to meet
with representatives from the Work Incentives Planning and Assistance
(WIPA) program, community work incentive coordinators (CWICs), ENs, and
other public and private community-based groups. The seminars provide a
customer-friendly environment for answering questions and demystifying
fears related to return to work. While the initial beneficiary turnout
for these events was minimal, response to the events appears positive.
No outcome data regarding the pilot seminars are currently available.

Work Incentives Planning, Assistance, and Outreach

"I truly do believe that if a beneficiary can get a good benefit
analysis and get the right community resources that they are going to
see the value in wanting to go to work and become self-sufficient."

Natalie Alden, Advocate

Advocacy Center, Jacksonville, FL

Testimony at the Ticket to Work and Work Incentives

Advisory Panel Quarterly Meeting

Washington, DC

June, 2006

Title I subtitle C of the Act authorized programs to inform, assist, and
protect beneficiaries interested in pursing work by establishing the
Benefits Planning, Assistance and Outreach (BPAO) program and the
Protection and Advocacy for Beneficiaries of Social Security (PABSS)
program. The Act also authorized SSA to create an internal corps of work
incentive specialists.

In 2000, SSA established 116 BPAO projects in all states, the District
of Columbia, and U.S. territories. The purpose of the BPAO program was
to provide SSI recipients and/or SSDI beneficiaries with accurate
information about work incentives to help them make informed choices
regarding work and its potential impact on their benefit status. BPAO
programs nationwide were administered by VR agencies, centers for
independent living and other community-based organizations.

Data on the activities of over 500 benefit specialists in the 116 BPAO
projects was reported to a centralized data management system at
Virginia Commonwealth University. The BPAO program operated from
2000-2006 and served over 252,000 beneficiaries nationwide.[^58] The
BPAO program served individuals with disabilities across the full range
of age and type of disability.

Over 84 percent of individuals served were between ages 22 and 59.
One-third of the individuals served identified psychiatric or emotional
disability as their primary disability. There was equal representation
of women (50.2 percent) and men (49.8 percent). The range of services
provided included information and referral (90.9 percent), problem
solving and advocacy (31.9 percent), benefits analysis and advice (43.4
percent), benefit support planning (13.9 percent), and benefits
management (5.3 percent).

The work incentives recommended most frequently included the Ticket to
Work program (53.6 percent), 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 randomly selected
beneficiaries who had received services from a BPAO provider, 89 percent
rated the services provided as "excellent", "very good", or "good."
Before receiving counseling, 28 percent indicated that they were
working, and 47 percent of respondents indicated that, after contact
with the BPAO, they found employment, which represents an increase of 19
percent.[^59] However, the Panel learned from beneficiaries about
challenges within this program. Some beneficiaries reported having to
wait weeks to get an appointment because there were not enough benefits
planners. Because of the size of some geographic areas, some
beneficiaries did not have access to benefits planners to address their
needs. Other beneficiaries shared that benefits planners could not
answer their questions or provided inaccurate information.[^60] In
response, the Panel sent a letter to the Commissioner of SSA in February
2005 recommending the development of minimum standards for effective
service delivery and minimum qualifications for benefit planners. The
Panel also suggested to SSA that all BPAO programs have agreements with
ENs and Disability Program Navigators (DPNs) in their geographic
catchment areas to better serve unserved and underserved populations.

In May 2006, SSA issued a new competitive Request for Application (RFA)
for the former BPAO program. The program was renamed the Work Incentives
Planning and Assistance (WIPA) program due to its increased emphasis on
work incentives, return-to-work supports, and jobs for beneficiaries.
This emphasis represented a shift from general information dissemination
and outreach to strategic and intentional outreach. It also demonstrated
a focus on practice and utilization that results in enhanced employment
outcomes.[^61]

The renamed program became effective September 30, 2006 with awards to
99 WIPA projects in 49 states. Of the 99 awardees, 84 previously served
as BPAO organizations. A second solicitation was offered from October
17, 2006 through December 15, 2006, resulting in another five WIPA
projects being awarded for states and territories that were previously
without permanent work incentives assistance grantees. SSA has awarded a
total of 104 WIPA grants.[^62] No administrative data is currently
available regarding the new WIPA initiative. Concerns have been
expressed by the Panel that it appears SSA has lessened data reporting
requirements for WIPA projects, which could potentially limit the
evaluation of this provision of the Act.

Protection and Advocacy for Beneficiaries of Social Security

In April 2001, SSA established a national system of services for the
protection and advocacy of beneficiaries. The Act defined the role of
PABSS programs as "providing information and advice about obtaining VR
and employment services and advocacy or other services that a disabled
beneficiary may need to secure or regain gainful employment." Services
are provided to individuals with disabilities across the full spectrum
of age and type of disability. PABSS grants were made to 57 states,
territories and Native American protection and advocacy agencies. Since
December 2001, PABSS programs have provided information and advocacy
services to over 9,500 beneficiaries. From Fiscal Year 2003 through
2006, PABSS programs documented over 14,003 client concerns across 13
major categories requiring individual assistance. The top four areas of
beneficiary concern were related to: Social Security overpayments (36
percent), VR (20 percent), benefits planning (12 percent), and
employment discrimination (10 percent). Outcomes achieved through the
PABSS programs include obtaining information concerning rights,
addressing overpayment situations, improving access to services from VR
or an EN, and regaining or obtaining employment.[^63] Diverse
stakeholders have reported to the Panel that the PABSS funding level of
seven million dollars is inadequate to meet the demand.[^64]

SSA Internal Corps of Work Incentive Specialists

Prior to the implementation of the Act, SSA recognized the importance of
marketing and outreach to beneficiaries regarding existing work
incentives. From July 2000 to September 2001, SSA piloted new field
positions, Employment Support Representatives (ESRs),[^65] to serve as
work incentive specialists improving access to information for
beneficiaries with disabilities who wanted to work. Thirty-two ESRs were
assigned to serve 54 cities. ESRs were trained on all Title II and Title
XVI employment support programs. An evaluation of the pilot program
identified the importance of locating ESRs onsite in SSA field offices
to provide expert assistance to beneficiaries in concert with other SSA
field staff. In 2002, for the first time, SSA created a Strategic
Partnerships and Outreach Team to be a part of its Office of Employment
Support Program's Division of Employment Policy. The team was created to
develop a more comprehensive approach to outreach and public information
focused on interdepartmental (federal, state, and local partners),
employer, and advocacy group relationships.

In 2004, SSA replaced the ESR pilot with permanent full-time Area Work
Incentive Coordinators (AWICs), which were no longer under the auspices
of the Office of Disability and Income Support Programs, but rather the
Office of Operations.[^66] AWICs were placed in 54 SSA field offices
nationwide to provide outreach to beneficiaries and timely and accurate
information on work incentives. AWICs are also responsible for training
Work Incentive Liaisons (WILs) in each field office. There are 1,335
individuals designated and trained as WILs to provide enhanced services
to beneficiaries. The services provided by WILs complement the role of
the AWIC with on-site assistance to other field office personnel
regarding employment support programs and direct involvement with high
profile individual cases. For the individual SSA staff member
functioning as a WIL, however, those services are performed in addition
to the individual's primary duties within the field office.

SSA has reported to the Panel on a quarterly basis on the outreach and
meetings attended and training offered by AWICs and WILs within and
outside SSA field offices to target audiences nationwide. To date,
however, no performance-based indicators have been made public to
objectively evaluate the individual performance of an AWIC or a WIL in a
specific geographic area, or, collectively, the impact of the positions
nationwide on improved customer satisfaction or change in employment
status of beneficiaries through the use of specific work
incentives.[^67]

As recently as August 2007, beneficiaries at a Panel meeting complained
about receiving inaccurate information from staff in SSA field offices,
and about the inadequate number of AWICs available to access timely and
consistent information to make informed decisions about work. Another
challenge to providing seamless work incentive assistance is that within
SSA, the work of AWICs and WILs is managed through an organizational
unit separate from the one responsible for WIPA and PABSS program
management.

The challenges to generating new beneficiary interest in employment and
work incentives through marketing, outreach, and the provision of
accurate and consistent information are formidable. These challenges, as
identified by stakeholders, include inadequate resources to support
AWICs, WIPA and PABSS programs; inadequate quality assurance mechanisms
to evaluate and improve service delivery; and a continuing need to
improve coordination among these specialists (AWICs, WILs, WIPA, and
PABSS) and other community partners.

Whether a beneficiary is seeking accurate information about the Ticket
to Work program or other work incentives, the cumulative evidence shared
with the Panel by individuals with disabilities indicates that these
fragmented activities do not reach the intended audience with the
necessary information. The Panel has repeatedly urged SSA to design,
develop, and implement a comprehensive marketing and outreach strategy
that effectively engages beneficiaries and ties in with other relevant
service delivery systems.

The Act offers beneficiaries the opportunity to access a variety of
supports and work incentives designed to reduce life-long dependence on
cash benefits. However, without a coordinated and comprehensive outreach
strategy that focuses not just on the Ticket to Work program, but also
on the range of work incentive options available, millions of
beneficiaries remain afraid to attempt to work.

Expanded Availability of Health Care Services

"I can\'t help but wonder how many other people really would go back to
work, but it\'s just so much easier in their mind to stay in that system
because of that fear \[of loss of medical benefits\]...I just feel like
you either have to be destitute or you have to be, you know, have been
in the system and have private insurance if you are going to get
diagnosed with something that\'s a chronic illness for life. And when
you want to be a contributing member of society you feel like the system
that is there to help you will only help you if you are completely down.
It won\'t help you to help yourself."

Velissa Cortessano

Testimony at the Ticket to Work and Work Incentives

Advisory Panel Quarterly Meeting

Miami, FL

November, 2005

Fear of losing health care coverage is one of the most significant
barriers to employment identified by beneficiaries. Congress has taken
several steps to mitigate the impact of health coverage on an
individual's willingness to attempt work.

Medicaid Buy-In Programs

The Act allows states to establish Medicaid Buy-In programs that expand
health care coverage to workers with disabilities whose income and
assets may otherwise make them ineligible for Medicaid coverage. Without
access to a buy-in, many beneficiaries who do work depress their
earnings because eligibility for Medicaid depends partly on income.
Participation in a state's Medicaid Buy-In program can:

1.  Ensure continued coverage for persons who can risk permanent loss of
    SSDI cash benefits because they only need the Medicaid benefits to
    supplement private health insurance.

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10. Enable Medically Needy program participants to increase their net or
    disposable income by moving to the Medicaid Buy-In program.

11. Enable SSI recipients to move from Medicaid with a lower earnings
    limit under Section 1619(b) to higher earnings ceilings under a
    Medicaid Buy-In.

12. Enable persons to move to a category of Medicaid eligibility with
    higher resource limits than the SSI program and thus increase their
    level of independence.

13. Enable persons to increase their work hours and pursue career
    opportunities.

A report issued by Mathematica Policy Research, Inc., in May 2007,
listed the following findings regarding what attracts Buy-In enrollees:

"About one-fifth of Buy-In participants who enrolled in 2005 were SSI
recipients in the prior year... For them, the Medicaid Buy-In is not a
pathway to new or additional health insurance but rather an opportunity
to expand earnings without losing their Medicaid coverage."

Slightly more than one-half (55 percent) of all participants in the
Buy-In program between 1997 and 2005 were Medicare beneficiaries at
enrollment...\[and\] may have enrolled in the Buy-In program to obtain
health services that Medicare does not cover. For this group, the Buy-In
program represents an opportunity to use Medicaid as a secondary
wraparound health insurance plan.

Other working-age adults who have enrolled in Medicaid Buy-In programs
include individuals who have a serious disabling condition but have not
been deemed "disabled" under SSA guidelines because they have
consistently worked or wanted to work... For these individuals, the
Medicaid Buy-In program offers an opportunity to pursue their personal
employment goals while obtaining access to affordable health
insurance."[^68]

In a separate Mathematica analysis, participants in the Medicaid Buy-In
who also utilized the work incentive under Section 1619 increased their
earnings by 56.6 percent, compared to an average 39.4 percent increase
for individuals not participating in 1619 programs.[^69]

Taken together, these findings indicate that at least some of the
benefits of the Buy-In are being realized, both for beneficiaries and
for some individuals with disabilities who are working and do not
receive SSDI or SSI.

States that have established Medicaid Buy-In programs allow workers with
disabilities to pay premiums in order to buy into the Medicaid program.
The Act gives states the flexibility to establish rules of eligibility
in terms of both income and assets, as well as to create a sliding fee
structure for participants who are required to pay more as earnings
increase. As of December 2006, 33 states were operating Medicaid Buy-In
programs, with total nationwide enrollment of nearly 80,871.[^70]

No two states have developed the same rules for participation. The
variability includes criteria for eligibility, premiums charged, and
limits on unearned income. According to participation data through FY
2004, 71 percent (66,977) of enrollees were SSDI beneficiaries and only
1 percent (1,186) were SSI recipients. Twenty-five percent of enrollees
were neither SSI nor SSDI beneficiaries.[^71]

The Act and subsequent regulations prohibit states from setting minimum
levels of work or earnings for participation in Medicaid Buy-In
programs. This decision was intended to ensure that low earners
(especially individuals with developmental disabilities) would not be
denied eligibility. There are a variety of ways that states require
participants to work. A common provision in a number of states requires
that Medicaid Buy-In enrollees demonstrate that they are paying FICA
taxes, or in the case of self-employment, show a quarterly IRS tax
statement.[^72] A state can limit its Medicaid Buy-In program to those
with substantial earnings and thereby require participants to work, by
setting an unearned income limit that can be exempted for individuals
with earnings generated through employment.

This is the case in Nebraska's Medicaid Buy--In program. Nebraska has
crafted an unearned income limit equal to the federal SSI standard plus
the \$8 state SSI supplement, but then exempts persons from the limit if
they have earnings in a month that is sufficient to be considered a TWP
month.

In Oregon, the Medicaid Buy-In program requires participants to pay as a
monthly cost share any unearned income in excess of the SSI standard. A
\"special need\" SSI state supplement can increase the applicable SSI
standard for certain purposes, reducing payment liability. SSDI
beneficiaries, with benefit amounts significantly above the SSI
standard, only find participation in the Medicaid Buy-In program
financially worthwhile if their earnings exceed the cost-sharing amount.

A random sample of state Medicaid Buy-In participant surveys reveals the
reasons for the current level of employment and for beneficiaries'
limiting work. In Iowa, 61 percent of survey respondents stated that
they were limiting their work activity, and the reasons for doing so
were as follows: The primary reason was the severity of their physical
disability (78 percent). Thirty-one percent reported that working has
caused their health to get worse, with 63 percent reporting that their
health has gotten worse for reasons unrelated to working.

In Minnesota, survey participants identified that physical health
problems (48 percent) and mental health problems (30 percent) prevented
them from working sometime during the past year. In Vermont, when asked
why they worked less than they believed they could over the last year,
22 percent of respondents reported it was due to their disability.
Eighty-one percent of those who were continually enrolled in the
Medicaid Buy-In program in Utah reported that their disability was what
prevented them from working more hours.

States must devise their Medicaid Buy-In programs within the constraints
of federal SSDI law. Policymakers and other stakeholders must recognize
that most SSDI beneficiaries participating in Medicaid Buy-In programs
may be unwilling to earn more than SGA because of the SSDI cash cliff.
For instance, four of the state Medicaid Buy-In surveys (Iowa, Kansas,
Minnesota, and Utah) indicated that from 25 to nearly 55 percent of the
participants in the Buy-In programs were adjusting their work activities
to protect themselves against loss of SSDI benefits because of exceeding
SGA.[^73]

Mathematica Policy Research, Inc. has found through its analysis that
some states implementing the Buy-In have included components that appear
to positively impact the earnings of participants. These include:

"In eight states---Nebraska, New York, Connecticut, New Jersey,
Illinois, Maine, Kansas and Vermont---more than 50 percent of
participants increased their earnings after they enrolled in the Buy-In
program. Some program features in these states may have contributed to
this finding. For example, Connecticut has the highest income limit for
the Buy-In program among all states, which might have diminished a
constraint to increased employment. Nebraska, Maine, and Vermont do not
provide a grace period for those who lose work, which may signal that
work is a strict condition for participation, thus attracting
participants who are more likely to work."[^74]

Demonstration to Maintain Independence and Employment

In addition to the Medicaid Buy-In discussed above, Section 204 of the
Act authorizes the creation of the Demonstration to Maintain
Independence and Employment (DMIE). By including this provision,
Congress recognized that tying health coverage to cash benefits for many
individuals with disabilities creates a "catch 22" in which individuals
leave the workforce prematurely, experience declines in their overall
health, and begin receiving cash payments through SSI and/or SSDI
primarily as a means to secure access to health care.

The DMIE is designed to provide health care and other wrap-around
employment supports to individuals with disabilities who are working and
are not receiving cash benefits. Each state's project is required to
provide health care and supports to subgroups of individuals with
disabilities such as those with mental illness or diabetes. States must
set up the project with treatment and control groups and have a rigorous
evaluation component.

The types of services being provided through the DMIEs vary according to
the target population for each project. For example, in Kansas where
participants are drawn from the high-risk insurance pool, services focus
on broad cost reductions to individuals accessing care, while in
Minnesota where the target is individuals with psychiatric disabilities,
a wellness navigator is made available to the treatment group, as well
as comprehensive medical and behavioral services.

At this time, four states are operating DMIEs---Hawaii, Kansas,
Minnesota, and Texas, and the combined target size for all treatment
groups is 2,767 individuals. In addition to the four states fully
participating, a handful of others have either been unable to implement
DMIEs for which they were approved or do not have sufficient evaluation
components to allow for study of the project results.[^75]

The concept behind the DMIE is sound and a valuable addition to the
policy discussion regarding return-to-work. While the Panel views the
DMIE projects as potentially valuable in terms of what might be learned
about achieving continued workforce attachment through provision of
health care and other employment supports, the tiny number of states
participating is disappointing.

Medicaid Infrastructure Grants

Current Medicaid Infrastructure Grants (MIGs) authorized under the Act
and administered by the Centers for Medicare and Medicaid Services (CMS)
allow the majority of states to expand beyond the Medicaid Buy-In to
other strategies that support beneficiaries' entry into or return to
work and advance their financial independence. Policy development,
cross-agency collaboration, and new approaches to engage the employer
community are part of a growing number of state efforts to establish a
comprehensive system of policy and program supports that encourage work,
improve access to health care, and customize solutions to meet
individual needs.

More needs to be learned from Medicaid Buy-In participants about their
fear of losing cash benefits and, as a result, limiting income to stay
below the SGA level. In addition, more study is required regarding the
impact of the variable state approaches to asset building and income
growth.

CMS, in a study of Medicaid Buy-In implementation, has identified
significant differences in the percentage of people who increased their
earnings after they enrolled in their state Medicaid Buy-In program.
States with the most restrictive asset limits had the smallest increase
in participant earnings.[^76]

Beneficiaries nationwide have identified the need for protection for
former Buy-In participants who are no longer able to work. These
individuals with disabilities still need access to Medicaid, but many
are prevented from receiving SSI and thus Medicaid because of the assets
they accumulated while they were Buy-In participants.

Demonstration Projects and Studies

SSA oversees demonstration projects and other initiatives to test
alternative strategies to reduce barriers for individuals with
disabilities who want to enter or return to work. Each of the
demonstration projects cover multiple sites over several years, with
some extending out ten years to evaluate long-term impact and individual
outcomes.

The **Benefit Offset Demonstration** will allow SSA to test the impact
and cost of a sliding scale benefit offset for SSDI beneficiaries and
applicants. Under this test, disability benefits will be reduced one
dollar for every two dollars an SSDI beneficiary earns above a given
threshold. An initial four-state pilot is underway in Connecticut, Utah,
Vermont, and Wisconsin. The purpose of this pilot is to collect
information that will be useful in developing a national study, which is
expected to begin recruiting beneficiary participants in 2009.

The **Youth Transition Process Demonstration** is testing ways to
increase self-sufficiency for youth with disabilities by modifying
several work incentives to encourage increased income, savings, and
asset development and improving coordination of service delivery among
multiple government agencies, school systems, community providers, and
employers. Currently, there are five pilots and possible expansion to
pilots in three additional states by the end of 2007.

**Homeless Outreach Project and Evaluation (HOPE)** are assisting
eligible, homeless individuals in applying for SSI and SSDI benefits.
These projects will help SSA demonstrate the effectiveness of using
skilled medical and social service providers to identify homeless
individuals with disabilities and assist them in applying for benefits.
SSA awarded funds to 41 projects to provide outreach services to the
target population. Through July 1, 2007, HOPE grantees assisted 8,440
homeless individuals with their disability applications. Of those, 2,659
individuals have been awarded benefits.

The **Accelerated Benefits (AB) Demonstration Project** will provide
immediate health benefits to a random sample of newly entitled SSDI
beneficiaries. For the participants, the 24-month waiting period for
Medicare will be waived, and participants will also be provided with
appropriate employment supports based upon individual need. A project
implementation and evaluation contract was awarded in January 2006. A
health benefits plan for AB participants has been approved, and Phase I
enrollments began in four sites (New York, Phoenix, Houston, and
Minneapolis) in October 2007. Phase II enrollments are expected to begin
in January 2008, and enrollment is expected to be completed by November
2008. An evaluation report is due by January 2011.

A **Mental Health Treatment Study (MHTS)** is currently testing the
impact of better access to treatment and other supports on beneficiary
outcomes related to medical recovery and employment. The targeted
population is SSDI beneficiaries with psychiatric disabilities. The
project is being implemented in 22 cities, and enrollment began in
October 2006. As of July 2007, there were 732 beneficiaries enrolled in
the study.

The Panel has received feedback from SSA, provider agencies, and
beneficiaries about the development and implementation of these
demonstration efforts. The Panel has noted consistent support for these
initiatives, which recognize the diverse needs of beneficiaries and the
importance of overcoming multiple barriers to employment. The strength
of current efforts has been their recognition of the need to pursue new
approaches and new policies that are counter to current rules and system
design. The projects also underscore the need to improve coordination
and collaboration at a federal, state, and local level. Involvement
should include government across agencies and the private sector
including community organizations and employers to build a seamless
system of support that is responsive to the needs of beneficiaries.
Stakeholder testimony, however, repeatedly questioned the slow pace of
projects from concept to design, and from implementation to evaluation;
this has been frustrating to beneficiaries and to the Panel.

Are Beneficiaries Better Off Today?

To answer the question of whether beneficiaries are better off today,
the Panel has sought comments and advice from beneficiaries, federal
agency leadership, program managers, ENs, the workforce development
system, and other relevant stakeholders in the public and private
sectors and at all levels of government. Based on the body of evidence
presented by SSA, CMS, external experts, and beneficiaries, progress has
been made, but the full potential of disability employment programs has
not been realized. A majority of states have established Medicaid Buy-In
programs. MIGs, administered by CMS, have enabled states to design and
implement a variety of policy and program reforms that respond to system
fragmentation, complexity, and beneficiaries' fear of loss of health
care benefits. Also, MIGs provide expanded access to benefits planning
and new options to increase income and build assets.

For the Panel, the greatest disappointment has been in implementation of
the Ticket to Work program. In September 2005, SSA published an NPRM on
Amendments to the Ticket to Work and Self-Sufficiency Program.[^77] The
amendments incorporated many of the Panel's priority recommendations.
The Panel was particularly pleased that the proposed amendments
addressed the multi-step nature of returning to work by redesigning the
payment system for ENs and offering more frequent and earlier payments.
Commenters addressing the Panel regarding the NPRM universally agreed
that the proposed changes would improve the program and stimulate new
interest by both beneficiaries and ENs. Unfortunately, SSA has yet to
publish final regulations, and does not expect to until the spring of
2008.

National Trends

The Panel's recommendations recognize the value of work and the economic
consequences of failing to improve programs. In addition, they represent
the Panel's contribution to an ongoing national dialogue regarding
modernization of current disability policies and systems. The Panel's
recommendations are informed by national trends related to education,
employment, and health care.

Education

The enactment of the Individuals with Disabilities Education Act (IDEA)
in 1975 mandated that youth with disabilities be provided a free and
appropriate public school education. Between 1976-77 and 2005-06,
enrollment in federally supported special education programs rose from 8
percent (3.7 million) to 14 percent (6.7 million) of children (three to
21 years old) in public schools. In addition, the percentage of students
with disabilities spending 80 percent or more of the school day in a
general classroom showed an overall increase from 45 to 52 percent
between 1995 and 2005.[^78]

In today's economy, graduating from high school is more critical than
ever to securing a good job and a promising future. Since an estimated
85 percent[^79] of current jobs and almost 90 percent[^80] of the
fastest-growing and best-paying jobs now require some postsecondary
education, a high school diploma and the skills to succeed in college
and the workplace are essential. Nationally, however, one-third of
students---about 1.23 million each year---leave high school without a
diploma.[^81]

According to the National High School Center, dropout prevention for
students with disabilities is a critical need. Students with
disabilities drop out of school at significantly higher rates than their
peers who do not have disabilities. Of those who do not complete high
school, about 61.2 percent are students with emotional/behavioral
disabilities, and about 35 percent are students with learning
disabilities. In the 2001-02 school year, only 51 percent of students
with disabilities exited school with a standard diploma.[^82] As with
students without disabilities who drop out, there are significant costs
to individuals with disabilities who do not complete high school. These
costs include unemployment, underemployment and higher rates of
incarceration. There are also significant costs to society related to
lost tax revenues and welfare expenditures.

The most recent data from the National Longitudinal Transition Study-2
(NLTS2) indicates that some progress is being made for youth with
disabilities who are two years out of high school. Of this group, 30
percent have taken postsecondary school classes, and 20 percent are
currently attending postsecondary school. However, this percentage is
less than half that of their peers in the general population. Their
rates of employment show that about 70 percent have worked for pay since
leaving high school and more than 40 percent were employed at the time
of the survey. This rate is substantially below the 63 percent
employment rate of their peers in the general population. Although, many
of these youth with disabilities have experienced an increase in their
hours and wages, receipt of benefits as part of a comprehensive package
is uncommon.[^83]

These mixed results have raised questions about the education
integration policies of the late 1990s for all students with an emphasis
on academics to the exclusion of vocational education, career education
and other experiences related to the development of social skills and
independent living.[^84] These policies can have an adverse impact on
youth with disabilities who are graduating from high school lacking
essential employment and life skills. The trends for youth with
disabilities demonstrate that they are attaining educational
achievement, but achieve lower employment rates than their peers without
disabilities. For youth with disabilities, this can lead to increased
poverty and greater reliance on income support programs and increased
attachment to public health insurance programs. These outcomes are
raising questions about the effectiveness of our current disability
policies, which were aimed at creating greater economic independence and
an improved standard of living for youth with disabilities.

Employment

Employment is one of the most complex subjects in the lives of Americans
with disabilities. According to a report from GAO on 21^st^ century
workforce challenges and opportunities,[^85] the U.S. workforce of the
21^st^ century faces a very different set of opportunities and
challenges than previous generations. Demographic and economic trends
indicate that the size and composition of the labor force, as well as
the characteristics of many jobs, are changing. A number of broad
economic trends are changing the nature of labor markets and employment
in the U.S. Three key factors have been identified that will affect
workers and employers, including people with disabilities, in the next
10 to 15 years: demographics, technological change, and
globalization.[^86]

As the baby boom generation (individuals born between 1946 and 1964)
approach retirement, the U.S. workforce will undergo a substantial
shift. In 2005, according to U.S. Census Bureau data, there were 193
million Americans aged 25 or older. This number is expected to increase
by 22 percent to almost 236 million by 2025. However, the number of
people 25 to 54 years old---the ages when labor force participation
rates are highest---will increase by only 3.8 percent.[^87] Looking at
this in another way, the size of the U.S. labor force doubled from 62.2
million workers in 1950 to 140.8 million in 2000; however, through 2050,
the labor force is projected to grow much more slowly. By 2010, the
annual growth rate is expected to slow to 0.6 percent and by the 2020s,
it is projected to slow to 0.4 percent. This represents a sharp decline
from the 2.6 percent average increases experienced during the 1970s and
1.3 percent average annual increases in the 1990s.[^88]

The aging population and slower workforce growth will impact the federal
government too. The proportion of the federal budget dedicated to
programs such as Medicare and Social Security will grow significantly as
more baby boomers reach their disability prone years. This will impact
the amount of funding available for discretionary programs such as
employment and training.

The projected slowdown in the growth of the nation's labor force has
made it more imperative that those who can work are supported in their
efforts to do so. The slow growth in the labor force should provide
opportunities to attract new workers from currently untapped resource
pools that are unrepresented or underrepresented in today's labor force
(e.g., people with disabilities and older workers). It is well
documented that labor force participation among people with a disability
is lower than among those without a disability. According to an August
2007 GAO report,[^89] "economic, medical, technological, and social
changes over the past several decades have increased opportunities for
individuals with disabilities to live with greater independence and more
fully participate in the workforce." The changes in the dynamics of the
21^st^ century workforce, including technological and medical changes,
will further enhance opportunities for individuals with disabilities to
participate competitively in the workforce.

For individuals who are participating in the workforce, wages determine
economic self-sufficiency. Several local governments in the U.S. have
enacted living wage ordinances that set a minimum wage higher than the
federal minimum for the purpose of requiring all jobs to meet the living
wage for a respective region. Living wage ordinances vary considerably
across the country in coverage, the wage level mandated, and possible
add-ons such as health care coverage mandates. What the living wage
programs generally have in common are a requirement to pay workers a
wage that reflects the market rate for the local economy, based on the
poverty threshold, usually for a family of four. Employers covered by
the statute are usually only those who receive contracts from the
government or receive some favorable treatment from the government
(e.g., a tax abatement or zoning change).[^90]

On May 25, 2007, President Bush passed legislation that amended the Fair
Labor Standards Act (FLSA) to increase the national minimum wage in
three steps: to \$5.85 per hour effective July 24, 2007; to \$6.55 per
hour effective July 24, 2008; and to \$7.25 per hour effective July 24,
2009.[^91] For people with disabilities who earn either the minimum wage
or close to it, these changes provide an opportunity for them to
increase their income.

A significant employment issue for SSI and SSDI beneficiaries using VR
services is that they have lower employment/earnings outcomes than other
VR clients. An analysis of the Longitudinal Study of Vocational
Rehabilitation Services Programs showed that only 23 percent of
beneficiaries who received services had earnings above \$500 per month
for at least nine months out of a 15-month period, compared to 54
percent of non-beneficiaries.[^92]

One likely explanation for a substantial portion of the remaining
difference is work disincentives faced by beneficiaries receiving VR
services. Another factor is the potential incongruity between SSA's goal
to see earnings maximized for as many beneficiaries as possible and
Section 102(b)(2)(B) of the Rehabilitation Act of 1973, which requires
state VR agencies to ensure that each individualized plan for employment
includes an outcome that reflects the individual's informed choice, even
if that choice is to work below SGA.

Health Care

In 2005, the U.S. spent nearly \$2 trillion on health care, while in
1970, this figure was only \$75 billion. These figures represent a jump
from 7.2 percent of the gross domestic product (GDP) devoted to health
care in 1970 to 16.0 percent in 2005. CMS projects that by 2016 health
care spending in the U.S. will comprise one-fifth of GDP.[^93] According
to data on per capita health care expenditures for developed countries
from the Organisation for Economic Cooperation and Development,[^94] in
2004, health care spending in the U.S. was the highest of countries with
above-average per capita national income. As a share of GDP, spending on
health care in the U.S. exceeds that of its European counterparts.[^95]
However, 2004 data reveal that almost half of all health care spending
in the U.S. was used to treat only 5 percent of the population.

Since 2001, according to data collected on income, poverty, and health
insurance coverage,[^96]^,^[^97] the number of people without health
insurance coverage has increased. In 2001, 41.2 million individuals were
without health insurance; this number rose to 45.3 million (15.6 percent
of the US population) in 2004, with a slight decrease to 44.8 million
(15.3 percent) in 2005, and another increase to 47.0 million (15.8
percent) in 2006. Present trends indicate that by 2013 the number of
individuals in the U.S. without health insurance could reach 56
million.[^98]

Lack of insurance is much more common among people with low incomes.
Some 24.4 percent of people with incomes below \$25,000 were uninsured
in 2005, almost triple the rate of 8.5 percent among people with incomes
over \$75,000.

The percentage of people covered by employment-based health insurance
decreased to 59.7 percent in 2006, from 60.2 percent in 2005. In 1987,
70 percent were covered by employer sponsored insurance.

The decline in employment-based health insurance coverage for American
workers is attributable to increasing health care costs, which are
causing some employers to drop coverage or to hire contract employees
who do not receive employee benefits. When health care premiums jumped
52 percent from 2000 to 2005, the rising cost of compensating workers
led businesses to cut jobs. Health insurance premiums have increased
from a range of eight to 14 percent per year since 2000; however,
inflation and changes in earnings are typically in the 3 to 4 percent
range. This means that workers have to spend more of their income each
year on health care to maintain coverage.[^99]

The percentage of people covered by government health programs also
decreased from 27.3 percent in 2005 to 27.0 percent in 2006. During this
time period, the percentage of people with Medicaid coverage was 12.9
percent (38.3 million) and Medicare coverage was 13.6 percent (40.3
million).[^100] Public programs account for about 45 percent of health
care spending. Currently, the Medicare program represents the only
universal, public health insurance program in the U.S. However, this
program only applies to individuals who are of retirement age (65 and
older) and to people receiving disability benefits after a two-year
waiting period.

Since the 1990s, the concept of health care for all in America has been
discussed by policy makers. Many countries have a united or national
health care system. In the past few years, states have begun to look at
strategies to expand health insurance coverage. The latest round of
state reforms, most of them enacted or proposed in 2006, present a
variety of new approaches to covering the uninsured, including new
mechanisms to subsidize coverage for low-income families, new variations
on employer and personal responsibility for insurance coverage, and new
strategies to facilitate the purchase of health insurance for small
businesses and for individuals without access to employer-sponsored
insurance. Several state efforts are characterized as comprehensive
because they attempt to reach near universal coverage.

Three states---Massachusetts, Vermont and Maine---were highlighted in a
report by the Commonwealth Fund, *State Strategies to Expand Health
Insurance Coverage: Trends and Lessons for Policymakers*.[^101] The
comprehensive reforms in these three states go further toward helping
low-income families purchase health insurance than in any other states.
One of the key elements shared by all three reforms is that they
subsidize coverage for families with annual incomes up to \$61,950 (300
percent of the federal poverty level for a family of four in 2007). Each
of these states uses Medicaid to partly fund its subsidized product,
demonstrating the importance of Medicaid as a financing source. To
reflect state specific priorities, each state combines this effort with
other local reforms. The following table identifies the key features of
the three state reforms.

**Table 1. Key Features of Comprehensive State Reforms**[^102]

+----------------+-----------------+-----------------------------------+
| Key Features   |                 |                                   |
| of             |                 |                                   |
| Comprehensive  |                 |                                   |
| State Reforms  |                 |                                   |
+----------------+-----------------+-----------------------------------+
| State          | Initiative      | Key Features                      |
+----------------+-----------------+-----------------------------------+
| Massachusetts  | Commonwealth    | Individual mandate                |
|                | Care            |                                   |
|                |                 | Employer Fair Share assessment    |
|                |                 |                                   |
|                |                 | Free Rider surcharge              |
|                |                 |                                   |
|                |                 | Health Insurance Connector        |
|                |                 |                                   |
|                |                 | Insurance market reform           |
|                |                 |                                   |
|                |                 | Commonwealth Care\*               |
+----------------+-----------------+-----------------------------------+
| Maine          | Dirigo Health   | DirigoChoice\*                    |
|                |                 |                                   |
|                |                 | Cost-containment reforms          |
|                |                 |                                   |
|                |                 | Maine Quality Forum               |
+----------------+-----------------+-----------------------------------+
| Vermont        | Catamount       | Employer assessment               |
|                | Health          |                                   |
|                |                 | Premium assistance for low-income |
|                |                 | workers                           |
|                |                 |                                   |
|                |                 | Catamount Health Plan\*           |
|                |                 |                                   |
|                |                 | Chronic care initiatives          |
+----------------+-----------------+-----------------------------------+
| \* Includes    |                 |                                   |
| subsidies for  |                 |                                   |
| low-income     |                 |                                   |
| worker         |                 |                                   |
+----------------+-----------------+-----------------------------------+

States that are attempting to cover the uninsured usually build these
reforms on prior efforts. For instance, Medicaid eligibility levels for
adults were expanded over time in these states to levels well above the
national average. Likewise, they all had strategies in place to improve
access to care or contain costs. These state-level efforts implement
health insurance reforms to provide more coverage to all citizens
including low-income and uninsured individuals.

#   {#section-6 .Exec-Heading}

# Panel Recommendations {#panel-recommendations .Exec-Heading}

"Millions of us are using these programs and no one knows better than we
do how they work or how they could work...We've got great ideas and
insights."

Jessica Lehman

Summit Planner from California

Beneficiary Summit

Atlanta, Georgia

February, 2007

The final Panel recommendations focus on policy changes and recognize
the need for an effective infrastructure and the investment of resources
to reach, respond, and adapt to evolving individual needs. Our nation's
largest disability programs will be modernized by the creation of
conditions and a policy environment to better support work beyond the
outcomes currently achieved with the existing work incentives. In
addition to updating and simplifying current work incentives, the Panel
recommends long-term strategies and an ongoing national dialogue
regarding changes needed to achieve more effective employment outcomes.
The Panel's comprehensive policy agenda begins with the establishment of
a permanent, elevated beneficiary voice.

Beneficiaries' perspectives and recommendations have played a primary
role in the development of Panel advice. Beneficiaries have presented a
human voice of experience that affirmed to the Panel that most people
with disabilities want to work, but are frustrated by the complexity of
rules of eligibility for work incentives and benefits. The multiple
systems of support offered by SSA and other federal agencies remain
fragmented with information about available resources difficult to
access, and, at times, unreliable. Well-intended policies have the
effect of limiting economic security and creating barriers to advancing
self-sufficiency.

The recommendations of the Panel to the President, Congress, SSA, and
other federal agencies begin with the call to create a permanent
mechanism to seek the advice and perspectives of beneficiaries impacted
by SSA's policies, procedures, and performance. The Panel focuses on
fundamental, comprehensive, systemic changes to align policy and program
supports with the needs and interests of individuals with significant
disabilities, so that individuals can work to advance their economic
self-sufficiency.

The Panel offers recommendations for immediate improvements to current
SSA programs; however, it also recognizes that continuous improvements
will not modernize a system in need of fundamental change. The
definition of disability must not be synonymous with the inability to
work. Access to public benefits must not condemn an individual with
significant disabilities to a life of poverty. Any new ideas and choices
presented should not jeopardize the safety net of current programs that
offer a fixed income and health care access. There are no simple
solutions; as costs continue to rise and the number of people who want
to contribute and be productive in our economy continues to grow, these
challenges need urgent attention. The Panel's recommendations should
further the ongoing dialogue and contribute to effective long-term
solutions.

The final Panel recommendations are organized into three major groups:

1.  Elevate and incorporate the beneficiary voice in all aspects of
    program and policy development, evaluation and improvement;

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14. Optimize current work incentives through short-term and incremental
    policy improvements; and

15. Increase economic self-sufficiency through investment in disability
    program modernization.

[]{#__RefHeading___Toc185405218 .anchor}Elevate and Incorporate the
Beneficiary Voice

The number of SSI and SSDI beneficiaries has grown rapidly in the past
15 years, and the employment rate of individuals with significant
disabilities has not improved. Conferences, public forums, and summits
with stakeholders from the public and private sectors have been held to
analyze the problem and propose solutions. Rarely, however, have
individuals who are using the SSI and/or SSDI programs been asked to
provide recommendations.

To better understand and address these issues, the Panel conducted a
beneficiary summit, *Voices for Change: Beneficiaries Paving the Way to
Work: A Roadmap to Program Improvement*. The summit, held in Atlanta,
Georgia on February 6 -7, 2007, was planned by and for beneficiaries and
gave the Panel direct, unfiltered input from beneficiaries. Summit
delegates discussed their experiences with Social Security disability
and employment programs and recommended changes to policy, procedures,
service delivery, information management, and systems collaboration.

The Panel selected seven beneficiaries with disabilities to assist in
planning the summit. Delegates were selected from a pool of over 300
applicants to achieve the broadest possible diversity in disability,
culture, age, race, and gender, as well as geographic representation
from all states, the District of Columbia, and most U.S. territories.

During the summit, delegates focused on four programmatic themes:
employment and work incentives; health care and long-term services and
supports; Social Security program communications, procedures, and
service delivery; and on the overall summit theme of future strategies
for raising the beneficiary perspective in policy development and
program implementation.

The findings from the summit as summarized in the report[^103] supported
and amplified the testimony the Panel had received from beneficiaries
over the past eight years. Key points included:

1.  People with disabilities want to work and participate in their
    community.

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16. People with disabilities are willing to take responsibility for
    their lives and are able to do many things with the right supports.

17. Existing work incentives are complicated, poorly understood, and
    underutilized, but they can be effective tools to return to work and
    achieve self-sufficiency.

18. For people with disabilities who are interested in working, it is
    difficult to get clear, accurate, consistent information about how
    to use Social Security and other government programs. Information
    should be accessible and culturally appropriate.

19. Social Security should consider the role of the family, as well as
    the person with a disability.

20. Beneficiaries have the potential to be a powerful voice for change.

The key recommendations made by the beneficiaries at the summit are
provided in Figure 3.

The summit experience demonstrates that beneficiaries are a valuable
resource for ideas and feedback. For example, they have had a powerful
impact in shaping the Panel's final recommendations. While Congress and
SSA hear from many experts and stakeholders in the disability system, to
date, they have not heard from beneficiaries in an organized way.

National Disability Beneficiary Work Council and National Disability
Beneficiary Work Advocate

**Recommendation 1:** Create through legislative authority, within the
Social Security Administration an Office of the National Disability
Beneficiary Work Council (the Council) and a National Disability
Beneficiary Work Advocate (the Advocate).

Figure 3. Key Summit Recommendations

Voices for Change: Beneficiaries Paving the Way to Work

*Key Summit Recommendations*

Employment and Work Incentives

-   Ensure access to health care and benefits

-   Develop and implement a Work Support Program

-   Raise the SSI resource limit to today's dollars

-   Change the SSDI Extended Period of Eligibility (EPE)

-   Remove the SSI marriage penalty

-   Raise the Substantial Gainful Activity (SGA)

-   Impose a statute of limitations on overpayments

-   Create a short-term disability status and revise EXR provisions

-   Improve the Plan for Achieving Self-Sufficiency (PASS) Program

-   Involve beneficiaries in the development and implementation of any
    new program

Health Care and Long Term Services and Supports

-   Support family caregivers who provide personal assistant and other
    services

-   Ensure access to a health care package for work, including
    self-employment

-   Remove the 24-month waiting period for Medicare

Program Communication, Procedures, and Service Delivery

-   Make SSA policies and procedures easier to find, understand, and
    accessible

-   Fund peer-to-peer mentoring to encourage work

-   Enforce standards and accountability for schools, for SSA, and VR

Raising the Beneficiary Voice

-   Advertise the results of the Summit

-   Create a sustainable beneficiary organization

-   Establish a beneficiary voice within the SSA, reporting to the
    Commissioner and Congress

-   Fund, plan and conduct future beneficiary summits and conferences

Modeled after the Internal Revenue Service (IRS) National Taxpayer
Advocate (NTA) and a Taxpayer Advocacy Panel, the Council and the
Advocate would:

1.  Identify difficulties that SSDI and SSI disability program
    beneficiaries' experience when trying to work that could be
    addressed via more effective SSA customer service.

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21. Propose changes in the administrative practices of SSA to mitigate
    those customer service issues, to the extent possible.

22. Identify potential legislative changes to improve SSA's service to
    disability beneficiaries who want to work.

The Council and the Advocate would be the main components of an
elevated, incorporated, permanent voice of beneficiaries within SSA.
They would ensure that beneficiaries have a direct impact on policies
and procedures related to the disability programs. The two entities
would monitor service delivery, customer satisfaction, and beneficiary
marketing and education related to employment.

The "business case" for including beneficiaries in the work of SSA to
facilitate employment and economic self-sufficiency for disability
beneficiaries can be drawn from the private sector. Private industry
routinely seeks direct input from the public in order to create
marketable products or services.

Before arriving at this recommendation, the Panel reviewed the way in
which SSA currently makes policy, addresses individual complaints and
cases, and receives feedback from beneficiaries. Panel members met with
SSA staff and visited a teleservice center and several field offices
across the country to learn how they currently address the employment
needs of beneficiaries.[^104] The Panel learned first-hand why the
current system needs improvement.

In these discussions, Panel members perceived that managers and
employees saw the provision of employment-related services as the
responsibility of other entities, such as VR agencies and WIPA projects.
Panel members learned that SSA gives an office credit for countable
activities (filing claims for benefits) but does not give credit for
spending time educating a beneficiary about employment and work
incentives. Generally, activities that get counted are the activities
that employees in the field offices focus on performing. It is clear
from the number of beneficiaries participating in employment that these
services, while technically available from a field office, are
underutilized and could be better coordinated, marketed, and provided to
beneficiaries.

With regard to customer satisfaction, teleservice callers are routinely
surveyed by SSA, but information regarding return to work is scarce.
Field offices rely on customer comment cards, proactively submitted by
beneficiaries. The data are kept at the office level, and Panel members
heard of no effort to aggregate or analyze the feedback received via the
cards. The Panel expects that the Council and the Advocate would monitor
and provide recommendations regarding two issues: 1) the provision of
accurate information and the treatment of employment issues by field
offices, and 2) the improved, coordinated collection and analysis of
customer satisfaction data at the local level.

SSA's Office of Public Inquiry (OPI) is responsible for front-line data
collection regarding feedback from the public. In addition, OPI answers
the public's questions and performs casework on behalf of beneficiaries.
However, the office does not solicit feedback, and there is no apparent
linkage between the volume and content of the requests received and
SSA's marketing, policy-making, or program development.

The SSA Office of Quality Performance (OQP) designs and executes
proactive consumer satisfaction surveys for both call center and field
office contacts. These surveys provide the agency with valuable
snapshots of how satisfied the overall SSA customer base is at a given
point. However, because beneficiaries participating in return to work
activities account for such a tiny subset of all SSA customers, OQP has
not studied their satisfaction with those services.

Beneficiaries who are dissatisfied with the employment service they
receive can request the assistance of the PABSS. It should be noted that
PABSS programs perform a valuable function in this process; however, as
outside entities, their ability to influence SSA's approach to overall
beneficiary employment is limited.

Finally, SSA does have an existing process for receiving public comment
when proposed regulations are published. The Panel's proposal is not
designed to replace this vital part of the regulatory process.
Unfortunately, the pubic comment process is not user-friendly, is
limited to proposed regulations, and is mainly utilized by the
stakeholders who already have a voice in the work of SSA. In addition,
the regulatory process is focused on SSA priorities, not necessarily
those of beneficiaries. The Panel believes that beneficiary input at the
front end of regulatory or policy development would improve the final
product.

The Panel is recommending creation of a Council and Advocate to enhance
the work of SSA. In addition to identifying problems, they would be an
active part of finding solutions.

The structure and functions proposed for the Council and the Advocate
are similar to a model that exists within the IRS. In the 1990s,
Congress determined that the IRS was not sufficiently accountable to
taxpayers, so they created an Office of the National Taxpayer Advocate
(NTA) and a Taxpayer Advocacy Panel. The NTA exists to represent the
interests of taxpayers in the work of the IRS. It performs a vital
function to build the public's trust and to act as an independent
liaison between taxpayers and the IRS. In addition, NTA staff works side
by side with IRS employees solving problems and offering support to the
IRS mission. The same could be done for SSA via this proposal.

The need for the Council and Advocate is three-fold:

1.  The perspective of beneficiaries is underrepresented in program and
    policy design within SSA.

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23. After years of redesign and re-engineering, SSA's disability claims
    processing and return to work programs are still problematic for
    individuals attempting to use them.

24. There is no coordinating entity within SSA that aggregates, analyzes
    and utilizes the disability beneficiary feedback that the agency
    currently receives.

Staffing and Structure

The Council would be made up of current or recent beneficiaries of SSI
and SSDI. Council terms should be staggered to ensure continuity and
members would be selected along a time continuum, so that the interests
of new beneficiaries (recent applicants), long-term beneficiaries,
beneficiaries attempting work, and those transitioning off of benefits
into the workforce are represented. At least one Council member should
be an individual who requires the assistance of a representative payee
or similar support person in order to participate on the Council.
Council members would be appointed by the President and Congress.

Selection criteria for Council members should be structured to achieve
representation from the broadest possible range of socioeconomic,
cultural, ethnic, racial, geographic, and disability backgrounds. The
Council should represent beneficiaries from all walks of life, and
Council members who are employed should represent the broad spectrum of
jobs that exist in our economy, including service, technology, and
manufacturing. In order to be an effective voice, the Council will need
staff support and its members should be paid. The Council's work could
be supported through the Office of the National Disability Beneficiary
Work Advocate.

The Advocate would be a current or former beneficiary not employed by
SSA for two years prior and five years after being appointed as the
Advocate. Qualified candidates must have demonstrated experience
advocating on behalf of individuals with disabilities to agencies like
SSA, HHS, VR agencies, and state human service agencies. The appointment
of the Advocate would begin with the Council's identification of several
qualified candidates. To ensure independence, the "short list" of
Advocate candidates would be provided to the President who would appoint
the Advocate for a six-year term, subject to Congressional consent. Only
the President would have the authority to remove the Advocate. Within
SSA, the Advocate would report directly to the Commissioner and to
Congress.

The Advocate would have staff from SSA's headquarters to enable the
individual to interact with the rest of SSA. Unlike the Advocate, the
staff could be drawn in whole or part from current SSA employees. In
addition to a headquarters presence, the advocate would have one staff
representative in each SSA regional office to conduct regular outreach
to beneficiaries in their communities, as well as visits to SSA field
offices. Current employees serving as AWICs or WILs in the field offices
could perform this function. The purpose of the outreach and field
office contact would be to identify emerging issues, challenges, and
best practices. Regional staff advocates should be individuals with
disabilities.

Joint functions of the Council and Advocate include:

1.  Represent the interests of disability program applicants and
    beneficiaries in the work of SSA.

2.  Supplement existing SSA research by conducting outreach and
    soliciting comments and recommendations from beneficiaries who
    represent geographic, cultural, ethnic, vocational, and
    socioeconomic diversity, as well as all age groups and disability
    types. Such outreach should include the planning and execution of a
    biennial beneficiary summit that includes diverse beneficiary
    representation.

3.  Provide a joint written report annually to Congress and the
    Commissioner of SSA that identifies the systemic problems that have
    emerged through the work of the Advocate and Council, as well as
    recommendations that offer solutions.

Functions of the Council would include:

1.  Identify highly qualified candidates as possible Advocate
    appointments.

2.  Receive direct testimony from beneficiaries nationwide through
    public meetings and hearings.

3.  Provide unfiltered feedback and recommendations to the Advocate
    regarding systemic issues that emerge through such contact with
    beneficiaries.

4.  Meet annually with the Commissioner of SSA to inform the
    Commissioner of the systemic issues and feedback the Council has
    received.

Functions of the Advocate would include:

1.  Assist in the development and/or review of SSA policies, procedures
    and marketing and training materials (for the public and service
    providers) related to employment. This assistance would focus on
    relevancy for the end user, accessibility, and assurance that
    documents are understandable and culturally appropriate.

2.  Facilitate intra- and inter-departmental program coordination, as it
    relates to effectively serving individuals with disabilities who
    want to work. The Office of the Actuary and CMS are good examples of
    the organizations with which the Panel envisions the Advocate
    interfacing.

3.  Identify, prioritize and advocate solutions to systemic problems
    impacting large numbers of beneficiaries, using data collected by
    the Council, the Advocate, SSA's Office of Public Inquiry and Office
    of Quality Performance and Office of Disability and Income Support
    Programs, PABSS, and other relevant programs.

4.  Identify possible legislative and administrative actions to problems
    identified, and, whenever possible, cost savings or offsets.

5.  Make recommendations for additions or changes to SSA's management
    information systems to better track internal issues affecting
    beneficiaries, particularly those working or trying to go to work.

6.  Ensure that the Advocate's contact information is widely available
    to beneficiaries.

7.  Present an interim annual report to Congress and the Commissioner,
    in addition to the joint report with the Council, which provides an
    update on the status of systemic issues and recommendations
    identified in the joint report. Both the joint report and the
    Advocate's status report should contain full and substantive
    analysis, including statistical information; steps taken by the
    Advocate to improve beneficiary services as well as SSA
    responsiveness; a summary of the most serious problems encountered
    by beneficiaries as well as recommendations for administrative and
    legislative action to resolve beneficiaries' problems; and other
    information as needed.

The Panel understands that resources are limited at SSA and across
government programs. The same could be said about the IRS, yet Congress,
in its wisdom, decided to invest in the NTA to make taxpayers more
willing to pay their taxes and better able to comply with complex rules
and regulations. In much the same way that the IRS benefits from the
NTA, the Council and the Advocate will substantially improve SSA's
customer service, create operational efficiencies and, for those who
choose employment, reduce beneficiaries' reliance on cash benefits.

"I want to own my own business and make...money. This will not be easy,
but I know it's possible if I get the supports I need so I can work and
have a good life."

Joseph Benito

Delegate from Florida

Beneficiary Summit

Atlanta, Georgia

February, 2007

[]{#__RefHeading___Toc185405219 .anchor}Optimize Current Work Incentives
through Short-Term and Incremental Policy Improvements

A fundamental objective of the Act was to create new choices for
beneficiaries in the assistance and support available through ENs. The
revised final Ticket to Work regulations might expand such choices even
further, but they will not be published until next year, well after the
Panel ceases to exist. For this reason, the Panel suggests the following
short-term improvements, outreach and ongoing oversight to build on
current Ticket to Work program outcomes and improve the lives of more
beneficiaries.

As a first step, we must improve SSA's current administrative funding
shortfalls. As discussed earlier, SSI redeterminations and CDRs
represent two of SSA's main efforts towards processing the information
affecting a beneficiary's benefits or eligibility in a timely manner and
helping to prevent and detect improper payments. SSI redeterminations
yield a savings of \$7 for every \$1 spent in administering them, and
CDRs in the SSDI program save \$10 in program benefits for every \$1
spent. Due to funding limitations, SSA has had to cut back on SSI
redeterminations and CDRs. This demonstrates that, without enhanced
funding, SSA will find it difficult, if not impossible, to perform tasks
beyond its core functions.

Insufficient funding for SSA to administer the SSDI/SSI programs
effectively has been well-documented for a decade. Budget constraints,
staff reductions and a continuing list of new responsibilities have now
taken a toll. The agency is facing increasingly difficult decisions as
it seeks to balance its traditional workloads with its growing
responsibilities that are outside its core mission, for example,
workloads in support of the New Medicare prescription drug program and
verifications of immigration status.

The Panel understands that SSA has done much to employ scarce resources
efficiently and increase overall productivity. Even with significant
improvements, however, there is a growing concern as expressed in recent
Congressional hearings and in the media about the detrimental effect on
service delivery of years of inadequate funding, staffing declines and
rising workloads.

The SSAB has over the years highlighted the need for increased resources
for SSA. In its August 1998 report, the SSAB made several references to
the need for more adequate resources.[^105] Every year since then, the
SSAB has issued one or more reports or other statements pointing out the
need for additional funding, and has issued some 21 different reports
and statements along these lines during the past 9 years.[^106]

The Panel understands that the House and Senate appropriations
committees have agreed to provide SSA with nearly \$10 billion for
operations in fiscal year 2008. (Although this may be a large amount
compared to funding for other discretionary programs, SSA\'s
administrative budget represents less than 2 percent of SSA\'s total
benefit outlays.)

If approved, the nearly \$10 billion might be enough to make some
improvements for the short term, but is unlikely be enough to
effectively administer what is in reality a new Ticket to Work program,
develop/implement program modifications to better serve beneficiaries
who are able to work, and keep up with post-entitlement work that
includes SSDI/SSI overpayments.

During a 2003 hearing before the House Ways and Means Social Security
Subcommittee, former Commissioner Barnhart highlighted SSA's challenges
keeping track of earnings, preventing large overpayments and resolving
them promptly when they do occur. Unfortunately, the Panel has heard
from numerous beneficiaries who have willingly reported the required
information to SSA in a timely way and have still received unexpected
letters from the agency demanding repayment of thousands of dollars in
overpayments that have occurred over a long period of time in one or
both programs.

The Panel expressed its concern about wage reporting, overpayments and
return to work in its 2001 Annual Report and again in its Year 3 report.
The Panel expressed its misgivings that SSA\'s long-standing problems
with overpayments will be exacerbated under the Ticket to Work program
as increasing numbers of beneficiaries start or return to work. The
Panel is aware that a 2003 pilot telephone wage reporting system for SSI
beneficiaries offers a glimmer of hope; however, it is unlikely to be
fully implemented when the enhanced final Ticket to Work regulations are
published. The Panel continues to be troubled that, with inadequate
resources, SSA may be unable to get beneficiary earnings posted to
accounts timely, appropriately verify the amounts reported, or to make
the needed adjustments in benefits. Overpayments create a disincentive
for SSDI, SSI and concurrent beneficiaries to work and also for ENs to
participate in the Ticket to Work program.

**Recommendation 2:** Congress should appropriate the funds necessary
for the Social Security Administration to support effective service
delivery, particularly related to the Ticket to Work program and
return-to-work, such as work report processing and overpayments.

The principle of self-determination values choice and control as
individuals with significant disabilities make decisions about
employment and advancing economic independence. A fundamental framework
of the Act was to create new choices for beneficiaries in the assistance
and support to be available through ENs. As discussed above in Section
1, in an effort to create new choices, SSA published an NPRM on
September 30, 2005, "Amendments to the Ticket to Work and
Self-Sufficiency Program." The Panel submitted comments to SSA
supporting the revised regulations, acknowledging that SSA had accepted
many of the Panel's recommendations for improving the program and
emphasizing that these changes should revitalize the program, stimulate
the growth of ENs and greatly increase the level of participation of
Ticket holders.[^107]

Unfortunately, for a variety of reasons, these regulations are not
expected to be published until the spring of 2008. On numerous
occasions, the Panel has urged SSA to publish the final revised Ticket
to Work regulations expeditiously. On September 28, 2006, the one-year
anniversary of the publication of the proposed amendments, the Panel
sent a letter to the Commissioner of SSA emphasizing the importance of
issuing the final regulations. [^108]

The September 2005 NPRM identified but did not address "Ticket in Use"
by beneficiaries in higher education and the suspension for a
time-limited period of required CDR. The Administrative Procedures Act
mandated a period of public comment on changes regarding the "Ticket in
Use," and SSA delayed the publication of the revised final regulations
to address this issue. On November 30, 2006, the Panel urged SSA to
reconsider the decision to delay release of the final Ticket to Work
regulations and that SSA address the "Ticket in Use" as a separate
issue.[^109] SSA did not accept this recommendation and published an
NPRM addressing "Ticket in Use" on August 13, 2007, "Amendments to the
Ticket to Work and Self-Sufficiency Program (Volume 72, Number 155)." On
October 5, 2007, the Panel submitted comments on this NPRM.[^110]

The broader revised final regulations address critical deterrents to the
participation of ENs in the Ticket to Work program. The Panel is gravely
concerned that not having the revised final regulations published yet is
severely dampening the enthusiasm of EN participation. Without a
reenergized pool of providers to choose from, the Ticket to Work program
remains a hollow promise for thousands of beneficiaries with
disabilities who could be moving toward becoming economically
self-sufficient.

The Panel hopes that Congress will continue to monitor program
implementation and that beneficiaries and other relevant stakeholders
will continue to suggest further program improvements.

**Recommendation 3:** The Social Security Administration should publish
revised final regulations pertaining to the Ticket to Work program
(September 2005 Notice of Proposed Rule Making) no later than April 1,
2008.

Coupled with publication of the revised final Ticket to Work
regulations, SSA needs to implement an effective marketing plan for the
enhanced program, as well as work incentive provisions.

Participation in the Ticket to Work program, by both ENs and
beneficiaries has been a concern since implementation began. Following
its EN Summit in May 2004, the Panel issued a report that stated,
"Thousands of people with disabilities and their advocates shared a
dream that the ...Act would greatly expand employment opportunities for
people on the Social Security Administration (SSA) disability rolls.
Three years after enactment of the law, it is clear that their dream is
faltering."[^111] Recommendations from that summit are reflected in the
proposed Ticket to Work regulations of September 2005, hence the Panel's
strong support for their full implementation. However, while the
regulations are crucial to increasing the participation of both ENs and
beneficiaries, even those improvements will not have the desired impact
unless they are accompanied by a coordinated, tested marketing strategy.
The EN summit report discussed elements of such an approach,[^112] and
the Panel continues its call for effective marketing of the
program.[^113]

This marketing plan needs to be informed by evidence-based best
practices, the results of the Ticket to Work program evaluation, as well
as previously reported Panel recommendations. The effective
implementation of this plan is critical to the future success of SSA's
comprehensive return-to-work initiative.

To date, the Panel has received partial information about the Agency's
progress developing the marketing plan. The roll-out of the Agency\'s
marketing plan should correspond with the release of the final
regulations.

**Recommendation 4:** The Social Security Administration should plan for
and (upon promulgation of the revised final regulations pertaining to
the Ticket to Work program (September 2005 Notice of Proposed
Rulemaking), immediately implement a marketing plan for beneficiaries
and Employment Networks that is informed by evidence-based best
practices, the results of the Ticket to Work program evaluation, as well
as previously reported Panel recommendations.

Implementation of Medicaid Buy-In programs continues to expand as
additional states are moving forward with legislative approval to
establish new programs. MIGs continue to promote linkages between
Medicaid and other employment-related service agencies and to enable
design and implementation of innovative approaches to support
individuals with disabilities in ways that advance their employment and
economic status. The MIG program will end in 2011 unless reauthorized by
Congress.

More needs to be learned about Medicaid Buy-In implementation and state
differences in eligibility and cost-sharing requirements. The MIGs
should continue to provide learning laboratories that respond to
beneficiary needs to become a part of the economic mainstream by
promoting linkages between Medicaid and other related services agencies.

**Recommendation 5:** Congress should extend the Medicaid Infrastructure
Grant and Demonstration to Maintain Independence and Employment program
authority through 2014 to stimulate innovation by states seeking to
refine comprehensive systems of employment supports for people with
disabilities.

[]{.mark}

SSA's authority to begin new demonstration projects ended on December
18, 2005. All projects initiated before December 17, 2005 can continue,
and SSA currently has several projects underway, including the Mental
Health Treatment Study, the Benefit Offset Demonstrations, and the Youth
Transition Demonstration.

Findings from these and other ongoing projects can help inform SSA about
which employment supports, work incentives, health benefit packages,
etc. are necessary for moving Social Security beneficiaries toward
self-sufficiency through employment. Unfortunately, progress in
beginning these demonstrations and moving toward research-based findings
has often been stalled. GAO cited this concern in a November 2004 report
that was critical of SSA's processes for planning and conducting
demonstrations.[^114]

The Panel urges Congress to renew SSA's demonstration authority with
greater Congressional oversight. In addition, Congress should require
that CMS and SSA work to coordinate their demonstration activities.

**Recommendation 6:** Congress should renew, with greater Congressional
oversight, the Social Security Administration's demonstration authority
to design and evaluate additional strategies that overcome multiple
barriers to employment and support economic self-sufficiency for
individuals with significant disabilities and place urgency on getting
the demonstrations done.

The testimony of many individual beneficiaries and the beneficiary
summit stressed that current SSI rules impose a significant "marriage
penalty" that prevents many recipients from getting married. In 2002,
SSA data were matched with that of the Survey of Income and Program
Participation. It was found that the poverty rate of SSI recipients
living alone is 78 percent, and the rate for two married recipients is
45.1 percent. This contrasts with the poverty rate for two SSI
recipients who live together but are not married. That rate is 9.8
percent.^.^[^115]

SSA has studied the impact of marriage on SSI recipients, most recently
in an issue paper published in December 2003. The report examined
options for greater equity between married and unmarried recipients
living together. Those options could be grouped into two broad areas:
benefit rates or income exclusions and deeming.

It is important to note that establishing parity between the treatment
of married and unmarried recipients does not necessarily hold all
recipients harmless, particularly when it comes to cash benefits. The
benefit rate option with the largest program cost increase would
eliminate the couple rate under SSI and pay the benefit rate for
individuals to both spouses. However, two other options under the
benefit rate category would actually reduce the benefit amount for some
SSI recipients.[^116]

The income exclusion and deeming options appeared to have a greater
impact on couples where only one spouse is an SSI recipient. In
addition, it appears that some of the income exclusion/deeming options
have a smaller impact in terms of program costs. Unfortunately, those
options are likely to make the program more complex at the same
time.[^117]

The Panel hopes that SSA will continue to examine these issues and that
Congress will attempt to equalize treatment of SSI beneficiaries,
whether married or not, in the same way that it removed financial
disincentives to marriage for all Americans via the tax code.[^118]
Since attachment to health care and long term services and supports was
the primary concern that most summit delegates cited about getting
married, the Panel recommends an interim measure that would provide
states with the opportunity to remove the disparity at least in terms of
Medicaid access. In addition to the Panel, the NCD also recommended
eliminating the "marriage penalty" in its testimony to Congress in
February 2007.[^119]

**Recommendation 7:** Congress should provide states flexibility in
devising Medicaid programs to reduce the marriage penalty for persons
with disabilities.

SSA's Ticket to Work regulations, both existing and proposed, are partly
designed to incentivize participation by ENs. Many unique entities, such
as private employers and one-stop career centers, have stepped forward
to serve as ENs, and the Panel is supportive of such innovations. To
that end, the nation's independent living centers (ILCs) are
well-positioned to join the EN/SSA/beneficiary partnership.

ILCs have played a pivotal role in the empowerment of people with
disabilities and their inclusion in the community. The ILC foundation is
embedded in consumer control over the management and delivery of
services. All ILCs provide the core services of individual and systems
advocacy, information and referral, peer support, and independent living
skills training. These services are the demonstration of the ILC
philosophy of self-direction and independence.

ILCs, as consumer organizations, can assist beneficiaries in their
efforts to achieve economic self-sufficiency. The staff members at these
centers understand first-hand the barriers to employment, since many are
former beneficiaries. It is that personal connection which places them
in a unique position to offer peer support and skills training necessary
for building confidence and informed choice.

ILCs are well-positioned to become ENs. However, their mission and
services are broadly directed at independence, inclusion and civil
rights. Consequently, their staff lacks the specific skills and training
necessary to assist in job development and placement. In order to
participate as ENs, ILCs would need additional financial support to
secure staff equipped to provide these services and other upfront costs.
SSA has an EN Capitalization Education Program which would be beneficial
to ILCs becoming ENs. The purpose of this program is to enable more
organizations to participate in the Ticket to Work program as ENs by
increasing access to funding sources that can support upfront costs of
providing employment and support services. This program has four target
segments of the disability and workforce development communities. The
Panel proposes that ILCs be added as a target segment. By doing so, this
will expand the options beneficiaries can access for needed services and
supports to obtain, regain, or maintain employment.

**Recommendation 8:** The Social Security Administration should identify
business models for investing in independent living centers as
Employment Networks.

Update, Simplify and Educate: Improve Beneficiaries' Experiences with
Work Incentives

Our nation's largest disability programs can be helped in the immediate
term by creating the conditions and a policy environment that would
better support work beyond the outcomes currently achieved with the
underutilization of existing work incentives. The recommendations
contained in the Panel's work incentive utilization report, *UPDATE,
SIMPLIFY, AND EDUCATE: A National Call to Optimize Incentives to Work,*
are intended to be incremental and achievable in the short term. The
Panel believes these recommendations will lay the foundation for the
proposed modernization activities and systems changes more applicable to
employment supports needed in the long run.

The recommended short-term actions are divided 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 should 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.

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25. **SIMPLIFYING** the maze of work incentives programs that exist not
    only within SSA but in 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.

26. **EDUCATING** and equipping the array of stakeholders involved in
    the return to work process so that it 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, ENs and other community providers,
    educators, and beneficiaries. Education should 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 should 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.

**UPDATE Existing Work Incentives**

Improve existing work incentives and ensure that they accommodate the
dynamic nature of disability while assuring access to health care as
work incentives are utilized.

*Update Impairment Related Work Expenses*

IRWE applies to both SSDI and SSI beneficiaries. However, under the SSI
program the reimbursement for expenses paid for by the beneficiary only
allows for up to a 50 percent cost recovery -- not dollar for dollar
with work expenses such as BWEs or PASS. This poses a considerable
barrier to work for those beneficiaries starting their work efforts in
entry-level positions that do not provide adequate income to offset the
loss of income associated with paying for these work-related expenses
and the potential loss of SSI cash benefits resulting from earnings.
This is important to beneficiaries trying to survive on limited income.

**Recommendation 9:** The Social Security Administration should change
the order in which impairment-related work expenses are deducted when
calculating the Supplemental Security Income cash payment to allow for
up to a 100 percent cost recovery.[^120]

While the definition of IRWE is the same regardless of the program,
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 routine 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.[^121] 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.

**Recommendation 10:** The Social Security Administration should allow
health insurance premiums to be used as impairment-related work
expenses, 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
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 they are
unable to take public transportation due to their disability. 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."[^122] This is the case even though, at age 18, parents no
longer have a legal responsible to care for their son or daughter unless
there is a court decision.

**Recommendation 11:** The Social Security Administration should
eliminate the condition that family members must suffer financial loss
for their compensation by the beneficiary to count as impairment-related
work expenses 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, \$20 general
income, \$30 infrequent/irregular earned income, and \$60
infrequent/irregular unearned income; in addition, there is a
\$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 the annual indexing of all
work incentives. "Raise the SSI resource limit to today's dollars" was a
key recommendation of the delegates to the beneficiary summit.

In March 2000, an SSA report on SSI exclusions mandated by the Act
included a range of detailed options for updating the dollar amounts and
the estimated costs.[^123] In a recent statement, the 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.[^124] 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 and it is impossible to predict what the
effect and costs would be of interacting with one another, as well as
how they would affect 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. Currently, for example, \$65 earned income exclusion is
worth less than \$15; \$20 general income exclusion is worth less than
\$5; and \$3000 resource limit is worth less than \$400 value.

**Recommendation 12:** Congress should increase and index the key income
exclusion amounts and the resource limits under the Supplemental
Security Income 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 can
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 13:** The Social Security Administration should approve
proposed rule changes to the Ticket to Work program to enable Employment
Networks to receive ticket outcome-only payments while a beneficiary is
receiving an Supplemental Security Income cash payment resulting from an
active Plan for Achieving Self-Support.

Update the Traditional Cost Reimbursement Program

The Traditional Cost Reimbursement Program administered by SSA with VR
agencies is based on sustained individual participant gross earnings
over SGA.[^125] 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 work incentives excluded by
the SSA under current procedures as they are not impairment-related. The
use of either of these incentives negatively impacts the ability of VR
agencies 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 service
providers in promoting use of BWE and PASS because their claim for
reimbursement may be disallowed.

**Recommendation 14:** The Social Security Administration should allow
state vocational rehabilitation agencies to receive traditional cost
reimbursement if and when an individual is receiving an Supplemental
Security Income cash payment resulting from an active Plan for Achieving
Self-Support or claim of Blind Work Expenses.

SIMPLIFY Existing Work Incentives

The myriad of work incentives programs that exist not only within SSA
but also within other federal benefit programs are complex, difficult to
understand, challenging to manage and do not appear to support a common,
universal approach to work. Beneficiaries may understand and know how to
use the work incentives, but other disincentives keep them from
working.[^126]

Align Existing Work Incentives

The two general types of governmental programs concerning disability are
employment support and income support. When the term "benefits" is
mentioned, many assume the reference is to either the SSDI or SSI
programs administered by SSA. Although these two 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 (HUD), Temporary Assistance for
Needy Families, Veterans' Benefits, 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 that most programs are fully or partially
funded with federal resources; however, many are administered at the
state or local level.

The interplay between employment earnings and public benefit programs is
very individualized. Although both programmatic constraints and work
incentives within public programs are consistently available to
participants, the multiplicity and diversity of program participation
make the issue complex. In other words, no two beneficiary or recipient
situations are the same. The work incentive provisions in one program
may be generous, while 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.[^127] 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 amount of
information beneficiaries need to maintain 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 that 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 100
percent income exclusion and not counted against 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 and support a universal work agenda.

SSA and their other federal partners should consider how to streamline
the work incentives and reduce their 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 15:** The Social Security Administration should reduce
the complexity and improve the consistency of work incentives across the
Supplemental Security Income and Social Security Disability Insurance
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.^.^[^128]^,^ [^129]
Overpayments are benefits that an 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.[^130] 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 CDRs represent two of SSA's main efforts
towards processing the information affecting a beneficiary's benefits or
eligibility in a timely manner and helping to prevent and detect
improper payments.

**Recommendation 16:** The Social Security Administration 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 17:** The Social Security Administration should
establish a cross-component internal Social Security Administration 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[^131] was conducted in 2003. Evaluation of the pilot[^132]^,^
[^133] determined that the telephonic wage reports were much more
accurate than traditional reporting techniques, 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[^134]^,^ [^135]^,^ [^136] 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 SSA's FY 2008 budget,[^137]
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 18:** The Social Security Administration 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.[^138]

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

There are a myriad of stakeholders who interact with and support 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,
including assistive technology, to support their efforts. These efforts
need to include SSA field personnel, ENs and other community providers,
educators, and beneficiaries to effectively use work incentive
provisions. Emphasis should be placed not only on continuing to increase
the awareness of beneficiaries regarding work incentives, but also on
educating families and service providers in supporting their use, and
enabling SSA to effectively administer them and keep informed regarding
the return to work efforts of beneficiaries through the collection,
organization and use of data about work incentive utilization for
decision making.

Expand Current Work Incentives Marketing and Outreach

SSA's Strategic Plan for 2006-2011 recognizes the importance of
increasing the 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.[^139] Title I, subtitle C of the Act authorizes important
strategies to inform, assist, and protect beneficiaries interested in
pursuing work by establishing the BPAO program (currently known as the
WIPA program), and the 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 achieve "greater financial independence
through employment." No measures are offered as to how SSA will track
the 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 to enable beneficiaries to make
informed decisions about work and to attract a new level of interest in
and use of available work incentives and supports are formidable.
Challenges identified by diverse stakeholders include inadequate
resource allocation to support either the internal infrastructure at SSA
of AWICs 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 Act offers 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 on the range of work incentive options, millions
of beneficiaries remain afraid to attempt to work and increase income.

The Panel continues to recommend a broad marketing and outreach strategy
addressing these challenges.

**Recommendation 19:** The Social Security Administration and Congress
should strengthen both the Work Incentives Planning and Assistance and
Protection and Advocacy for Beneficiaries of Social Security networks by
establishing performance standards, adjusting funding levels and
resources to levels necessary to achieve the desired results, and
investing 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 20:** The Social Security Administration should
identify clear, objective performance standards and indicators to
evaluate the activities and impact of Area Work Incentives Coordinators
and Work Incentive Liaisons, and collect, analyze, document, and publish
evidence annually (by Social Security region and system-wide) of
customer satisfaction, improved employment outcomes, and advanced
self-sufficiency.

PASS was enacted by Congress as a part of the original SSI legislation.
PASS is self-determined, and is one of a 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 4
below shows the number of PASS applications nationally in December of
each year, from 1990-2006.[^140] The number of PASS applications ranges
from 2255 in 1990, to a high of 10,329 in 1994, to a low of 1045 in 1999
in the aftermath of a 1996 GAO report and subsequent policy changes, to
1583 in 2006.

Through the work of the Adequacy of Incentives Advisory Group, several
critical recommendations were provided in 2004[^141] to address
disincentives and barriers in using PASS. These recommendations
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 the 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. Enhancements needed for the PASS program were also identified
as critical by delegates at the beneficiary summit. Beneficiaries
recommended providing federal or state matching funds, allowing a
successful PASS to continue after its scheduled end date by allowing it
to be enhanced to work toward greater self-sufficiency and expand
business opportunity, improving communication between the PASS cadre and
the application (appeal/denial) process, increasing the number of
trained PASS specialists available, increasing communication with youth
about work incentives including PASS, and simplifying and streamlining
the PASS application forms and process.

**Figure 4. PASS Utilization**

![](media/image5.wmf)

Current active approved PASS applications total 1,583 (December 2006),
averaging 30 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 states. 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. 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 level training. The
Panel believes that PASS use would increase significantly with an
enhanced focus on PASS outreach.

**Recommendation 21:** The Social Security Administration should collect
workload information on the number of Plan for Achieving Self-Support
applications submitted and approved, including the processing (wait)
time by state, and publish this information annually in Social Security
Administration's SSI Disabled Recipients Who Work report. SSA should
provide high quality training and support, and fiscal resources for the
effective administration and outreach of the Plan for Achieving
Self-Support program. The Social Security Administration should recruit,
develop, and support Plan for Achieving Self-Support specialists
(travel, technology, et al).

Improve Management by Data Practices

SSA should provide annual data reporting and analysis on SSDI work
incentive utilization, including state-to-state variation similar to the
annual data provided on the SSI program. This report should also include
the experiences of Disabled Adult Children and concurrent SSI/SSDI
beneficiaries. The Panel\'s understanding is that work incentive
utilization information is being collected as earnings of SSDI
beneficiaries are reported using e-Work.  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 to more fully utilize work incentives.

**Recommendation 22:** The Social Security Administration should improve
reporting of data and analysis pertaining to Social Security Disability
Insurance (including Disabled Adult Children and concurrent Social
Security Disability Insurance/Supplemental Security Income
beneficiaries) and issue an annual report comparable to the Social
Security Administration's SSI Disabled Recipients Who Work report*.*

**Recommendation 23:** The Social Security Administration 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

With the addition of benefits and work incentive specialists, through
first the BPAO and now the WIPA program,[^142] 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 avoiding and dealing with overpayment problems. The WIPA network is
limited, however, in their ability to provide the information necessary
to ensure that all beneficiaries are aware of earnings reporting
requirements. SSA should explore other approaches to expanding
beneficiary understanding in this area.

**Recommendation 24:** The Social Security Administration should
increase beneficiary awareness of earnings reporting requirements
including the waiver process for overpayments, and promote greater
self-efficacy.

The implementation of these recommendations will update and simplify
existing work incentives and enable the investment of time and resources
by SSA and other related community stakeholders to educate the target
audience about their availability and use. Expanded opportunities and
conditions for supporting work will be created and the target audience
will be better educated to make informed decisions. For policy makers,
it is an important place to start. However, these changes in program and
policy design represent only partial solutions to positively impact
employment and economic gains for current and future eligible
individuals with significant disabilities. These short term
recommendations represent one element of the modernization actions
required to establish an urgently needed framework in line with 21^st^
century expectations of beneficiaries and continued advancements in
technology and service delivery approaches.

[]{#__RefHeading___Toc185405220 .anchor}Increase Economic
Self-Sufficiency through Investment in Disability Program Modernization

"We want to get out there. We want to be part of the world. We want to
make money. We want to be able to have families and support our
children...We want to be able to tell our stories to other people, so
the next person that they meet, they won't be afraid to hire them.... We
want the same thing that everybody else wants, which includes work..."

Amber Carey

Testimony at the Ticket to Work and Work Incentives

Advisory Panel Quarterly Meeting

Washington, DC

November, 2006

Work is a valued activity, both for individuals and society. Work
fulfills the need of an individual to be productive, promotes
independence, enhances self-esteem, and allows for participation in the
mainstream of life in the United States.[^143] People with significant
disabilities face multiple barriers to employment that make it
difficult, if not impossible, to work or increase their work effort. Our
nation has reached a critical juncture that demands modernization of
disability programs for individuals with significant disabilities who
want to work and increase their earnings. Further action is necessary to
ensure that the goals of the ADA --- equality of opportunity, full
participation, independent living, and economic self-sufficiency --- are
supported by policies that have high expectations, receive adequate
resources to achieve program objectives, and deliver increased positive
outcomes.

The Panel believes that incremental changes to the Ticket to Work
program and Social Security work incentives, while vital in the short
term, must be coupled with a deliberative modernization of disability
programs. The Panel proposes that Congress and the Administration
increase economic self-sufficiency through a long-term investment in an
employment strategy for Americans with disabilities. Disability policy
and programs must be modernized to:

1.  Eliminate barriers to work;

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27. Enable people with significant disabilities to reduce their
    dependency on cash benefit programs; and

28. Empower Americans with disabilities to greatly improve their short
    and long-term financial independence and personal well-being.

During the last 18 months, GAO, NCD, and the SSAB have made public
reports of the urgent need for policy and procedure modifications by
both Congress and SSA. All three reports identify complex obstacles to
employment faced by beneficiaries and the need for "new approaches" and
"new solutions." The three federally mandated organizations
independently analyzed the many legislative changes, program
modifications, training initiatives, marketing and outreach efforts, and
technological improvements in processing claims and wage records in the
past 15 years to impact customer service and return-to-work outcomes.
The findings indicate that these policy and process changes have not
significantly improved program outcomes and that beneficiaries do not
trust SSA to make appropriate and timely decisions. After spending
sometimes years to convince SSA of the extent of their disability and
their inability to work, most beneficiaries are confused by messages
received from SSA that encourage return to work with the assistance of a
variety of work incentives that are neither simple to understand nor to
use. Each year, the Panel has listened to and learned from
beneficiaries, who have echoed and confirmed the findings of these three
independent bodies.

In the past year, the Panel listened to presentations about their body
of evidence from GAO, NCD, and the SSAB. These groups' conclusions and
recommendations support critical investments that must continue to be
made on a national basis to advance and modernize the current disability
programs. This report cites the recommendations of GAO, NCD, and the
SSAB and presents the Panel's findings in each recommendation area.

Government Accountability Office: Modernizing Federal Disability Policy

According to an August 2007 GAO report, *Modernizing Federal Disability
Policy*,[^144] economic, medical, technological, and social changes have
increased opportunities for individuals with disabilities to live with
greater independence and be full participants in the workforce. GAO's
analysis of the largest federal disability programs indicates that
"these programs are poorly positioned to provide meaningful and timely
support for persons with disabilities." The SSI and SSDI programs were
singled out by GAO as programs whose costs and enrollment are growing
rapidly and are expected to continue to grow even more rapidly in the
future. From 1996 to 2006, according to this report, these two programs
increased by 42 percent and 16 percent, respectively. GAO cited several
reasons for the current and future expected rapid growth of these two
programs. The demographic picture of baby boomers aging and the
documented correlation with increasing onset of disability, as well as
the low rate of return to work for individuals with disabilities
receiving cash and medical benefits, creates a situation in need of the
immediate attention of policymakers. During this same ten-year period,
the total inflation adjusted cash benefits for the two programs
increased by 68 percent and 18 percent, respectively.

GAO brought together a diverse array of experts to explore ways to
modernize disability programs and transform current disability policy to
align with changing social attitudes and technological advances. Forum
participants cited the complexity of disability issues including
transportation, housing, health care, education, and workforce
development. Improved coordination should aim to create "a federal,
state, and local system that ensures that policy, services, and
supports, are synchronized." For an individual with a disability, such a
system must seamlessly support the transitions from childhood to
adolescence to young adulthood to adulthood, and, finally, to
retirement. There was also a need expressed for greater focus on the
development of partnerships between the public and private sector,
including more collaboration with the employer community to identify the
right mix of education, supports, and incentives to maintain and expand
the participation of individuals with disabilities in the workforce.

The concluding observation from this report is that "to the extent that
federal disability programs are aligned with 21^st^ century realities,
benefits can be achieved for individuals with disabilities, business,
and government." As an independent evaluator of the impact of federal
disability programs, GAO cautions that the growth in size and the costs
of major federal disability programs (SSDI and SSI) are having an
adverse impact on the federal government's long-term structural deficit.
"Solutions are likely to require fundamental changes, including
regulatory and legislative action.... Without strong federal leadership
at this time to lead the transformation, there could be fewer options in
the future available."

National Council on Disability: New Solutions for Old Problems

In its report, *The Social Security Administration's Efforts to Promote
Employment for People with Disabilities: New Solutions for Old
Problems*,[^145] NCD studied whether the Ticket to Work program and
other new authorities under the Act were having any more success than
SSA's past attempts to impact the employment rate and earnings of
beneficiaries.

The major findings parallel the observations of the GAO Forum. The
findings also mirror the voices of experience captured in the Panel's
beneficiary summit. Five themes illustrated the confusion and
frustration of beneficiaries and the ineffectiveness and inequities of
both the SSDI and SSI programs.

**1. The mission of SSA\'s disability benefit programs is out of touch
with current thinking and expectations.**

"Years ago when the Americans with Disabilities Act (ADA) of 1990 was
enacted, prohibiting discrimination against individuals with
disabilities in employment, housing, education, and access to public
services, people were excited and thought it would give us more
opportunities. I must agree it did, it gave us ramps into buildings,
wider door ways, lowered telephone booths, etc. However, it did not give
us equality. Until we are given an opportunity to work without
stipulations, we will never be able to fully achieve our goals in life."

Robin Renshaw, Delegate from Nevada

Beneficiary Summit

Atlanta, Georgia

February, 2007

The current eligibility determination process places the emphasis on
inability to work at the SGA level in order to qualify for benefits.
Such a focus contributes to beneficiary confusion about SSA\'s
return-to-work efforts and compounds the challenges of intervention
occurring early in the disability determination process.

**2. Historically poor service and misinformation provided to
beneficiaries by SSA field office staff have perpetuated a culture of
mistrust and fear.**

"Information and referral is the first service any agency provides.
People with disabilities will feel more secure if all agencies are
speaking the same language."

Emilio Gandara, Delegate from Puerto Rico

Beneficiary Summit

Atlanta, Georgia

February, 2007

NCD\'s findings parallel the Panel\'s observations and documentation of
beneficiaries that \"misinformation is frequent and mistrust common.\"
There is a prevalent fear that attempts to work will result in a
determination that the disability has ended. Beneficiaries have cited
problems with accurate and timely processing of earnings reports by SSA
field office staff, leading to overpayments. As recently as July 2007,
WIPA projects in Oregon and California testified to the Panel about
their struggles to get accurate and timely information from SSA field
offices to help inform individual decisions about return to work. Their
testimony stated that the problems were not isolated incidents, but
instead examples of nationwide concerns.

**3. Asset limitations and income rules perpetuate long-term
impoverishment and dependence on public benefits.**

"I always tell people, it is okay to be a woman, just don't be a poor
woman. It's okay to be a person of color, but please don't be poor and
also a person of color. It's okay to be old, but please don't be poor.
You can be disabled and you can achieve a fairly high standard of living
in this country, but not if your disability is surrounded with poverty."

Frances Gracechild, Panel Member

Director of the Independent Living Center

Sacramento, CA

Public Comment at the Ticket to Work and Work Incentives

Advisory Panel Quarterly Meeting

Washington, DC

June, 2006

The Act recognizes the opportunity to overcome some of the most
significant barriers to employment for working age adults with
disabilities. Since 2001, millions of dollars have been expended
annually by SSA to implement the Ticket to Work program to provide new
service options for beneficiaries, and to expand education, outreach,
and counseling support through the BPAO (now WIPA) as well as the PABSS
programs. Internally at SSA, AWICs and WILs have been dedicated to
improving customer service. Modified program rules have allowed ticket
users protection from CDR provisions, and the level of earnings allowed
has increased during the TWP. Yet, despite these program improvements
and individual support choices, fundamental issues of income and asset
limits have not been addressed directly. The NCD report identified the
SSI program's strict asset limits as a major barrier to advancing
economic self-sufficiency. The stringent asset limitations create
disincentives to savings and depress interest in increasing income. The
asset limits contribute to a culture of dependency on public benefits
and long-term impoverishment. The lack of a gradual reduction in
benefits as earnings increase causes SSDI beneficiaries to depress
income by limiting their hours of work, perpetuating dependence on
Social Security and other public benefits.

**4. Coordination and collaboration among multiple publicly funded
systems with SSA remains poor and detracts rather than facilitates
return to work and advancement of self-sufficiency.**

"It's great to have a system in place, but if you don't have the right
people in the right places with the right qualifications and the right
training then you are almost guaranteed not to be as successful as you
could."

Robert Robertson, Director

Government Accountability Office

Education, Workforce and Income Security Group

Testimony at the Ticket to Work and Work Incentives

Advisory Panel Quarterly Meeting

San Juan, PR

February, 2006

The NCD report concludes that receipt of Social Security disability
benefits is "merely the last stop on a long journey that many people
with disabilities make from the point of disability onset to the point
at which disability is so severe that work is not possible." Along the
journey, individuals with disabilities encounter a myriad of polices and
procedures from other systems that do not work in concert with SSA and
may even work at cross purposes. Beneficiaries testifying before the
Panel repeatedly told of frustrating interactions with VR, the Medicaid
system, secondary and post secondary educational institutions, and
Social Security field offices that understood little about each other
and placed the burden of information gathering and fact finding back on
the beneficiary. The message was clear: it is the individual's
responsibility to navigate the complex maze of rules, despite the
partner programs' common mandated objective to improve employment
outcomes and/or advance self-sufficiency, community participation, and
reduce reliance on government benefits.

Analysis of performance measures across programs indicates that there
are no means to evaluate and encourage cross-system collaboration. As a
result, there are no penalties or sanctions for failure to advance
integrated service delivery. At the community level, there are
ineffective uses of resources across systems, flawed return-to-work
decisions based on incomplete information, and lost productivity of
individuals with disabilities.

**5. Disability is a dynamic process that requires flexible policies and
supports and recognizes one size does not fit all.**

"Either I have to figure out a way to keep benefits (personal assistance
services through Medicaid), so that I can get up in the morning, get
dressed and go to work, or I will just have to lay in bed all day, which
means not only am I not going to work, but then I will stay on these
benefits. It just makes a lot more sense to me to help people get out
and get into the workforce and they can pay taxes and help pay for some
of these services that they are receiving."

David Cox, Engineer

Stockton, AL

Public Comment at the Ticket to Work and Work Incentives

Advisory Panel Quarterly Meeting

Washington, DC

August, 2006

Beneficiaries represent a diverse group of individuals with
disabilities. Variables impacting work activities include the type and
severity of disability, age, age of onset of disability, level of
skills, education, prior work experience, the state in which an
individual lives, and the level of need for and availability of health
care and long-term employment-related supports and services. In
addition, an individual's needs may change over time as the nature and
severity of disability change. With these changes, the work activity may
vary as might the need for supports and services.

The NCD report's conclusions again parallel the body of evidence
collected and analyzed by the Panel. A framework for the development of
future public policy must be sensitive to the dynamic nature of
disability and its interface with work, reducing the fear and risk of
full loss of benefits by gradually reducing benefits as earnings
increase for SSDI beneficiaries, and ensuring the security of a fair and
decent level of income during periods of work incapacity.

Many beneficiaries who testified before the Panel described their
disabilities as episodic in nature based on their experience with
psychiatric disabilities, multiple sclerosis, and other conditions.
There are times when their conditions require them to stop working.
Eligibility criteria used by SSA for the disability programs do not
support easy transitions on and off benefits. For many individuals, the
resulting decision is to remain permanently unemployed and dependent on
the benefits.

The NCD report confirms the urgent need for policy and program changes.
"Although SSA has taken steps to improve its return to work services, a
more comprehensive change in the agency's process and underlying
philosophy is necessary in order to make SSA disability programs more
work oriented." NCD concluded that promoting employment and return to
work among beneficiaries "will require SSA to make a major paradigm
shift and totally redefine both its mission and how it conducts its work
on a day-to-day basis."

Social Security Advisory Board: A Disability System for the 21^st^
Century

The SSAB issued its report, *A Disability System for the 21^st^
Century*,[^146] in September 2006. The importance of the SSDI and SSI
programs in the lives of individuals with disabilities, especially since
a majority of beneficiaries depend on these income benefits for more
than 75 percent of total income, led the SSAB to focus much of its
attention on these programs over the ten years since the SSAB was
created. The SSAB "discovered that there is something about these
programs that was antithetical to another basic need -- the need to
pursue independence and a sense of contributing to one's own
self-support and to the good of society." The SSAB found that the most
apparent conflict was the Social Security definition of disability,
which equates disability with the inability to do any substantial work.

As the SSAB pointed out in its 2003 report, *The Social Security
Definition of Disability*,[^147] the definition of disability was
adopted some fifty years ago for a program that was limited to
individuals approaching retirement age. Policymakers, practitioners, and
persons with disabilities could not have foreseen the social,
technological, and medical changes that have influenced today's
thinking, or the changing expectations about the capacity of the target
audience to be productive members of the workforce in diverse business
settings. However, changing the definition of disability as the trigger
for eligibility to SSDI and/or SSI benefits is not without significant
challenges. Broadening eligibility could increase the costs of the
program and provide benefits to individuals beyond the currently
identified scope. Narrowing eligibility could prevent individuals who
are unable to engage in substantial work from receiving their benefits.
The SSAB, with expert input and presentations from diverse stakeholders,
determined that the problem is that these programs "...are not
integrated into an overall approach to disability that supports the
aspirations of people with disabilities to achieve their maximum
potential.... Correcting this problem will require a statutory change to
define disability in a way that encompasses such an integrated
approach."

The SSAB concluded that "it is time to set aside old paradigms and look
more broadly at what is possible." A modernized disability system must
invest in human capital and recognize that it is not inconsistent to
receive support and work simultaneously. In framing the essential
arguments for a modernized disability system, the SSAB incorporates
elements consistent with the findings and recommendations of the GAO and
NCD reports and with the body of evidence assembled by the Panel over
the past eight years.

According to the SSAB, a modernized disability system must incorporate
elements that embrace change and:

-   "Provide assistance and support to individuals and strive to
    maximize employment outcomes to the extent of each individual's
    capabilities;

-   Facilitate a culture shift within society to establish the
    expectation that individuals with disabilities can and should work
    to the extent of their capabilities and that society should assist
    individuals with disabilities in that endeavor;

-   Recognize and accommodate the dynamic nature of disability and its
    sometimes cyclical impact on work capacity; and

-   Facilitate rehabilitation and employment by coordinating and
    integrating the various sources of assistance and support that are
    now inconsistently provided by multiple uncoordinated
    programs."[^148]

The Panel supports such a disability system that would make the consumer
an active partner in designing appropriate services and supports. The
beneficiary voice would be elevated to shape the system and customize
individual responses that strengthen and support choice. Such a system
would encourage contributions by individuals to their own
self-sufficiency and yet be responsive to the continuum of individual
abilities and needs.

Making the Case for Change

The testimony of beneficiaries during the last eight years provided the
Panel with a unified voice for modernizing disability programs and
systems that support individual goals to advance self-sufficiency and be
a part of the economic mainstream. The evidence before the Panel affirms
the findings and conclusions of three independent authorities charged
with advising federal level policymakers about disability policy
direction and effectiveness. The Panel joins GAO, NCD, and the SSAB in
urging Congress to modernize disability policy. This modernized policy
should present contemporary choices for balancing security and economic
opportunity for current beneficiaries and future generations of youth
and adults with disabilities who want to work and more fully participate
in community life.

As a result of the Panel's discussions regarding modernization of
disability programs, the Panel learned of many promising ideas and
proposals from experts nationwide. These proposals included, but were
not limited to: the Wisconsin Department of Workforce Development's
"Making Work Pay," the Council of State Administrators of Vocational
Rehabilitation's "Rehabilitation Early Diversion (RED)" proposal, the
National Council on Independent Living (NCIL) proposal, "Being American:
The Way Out of Poverty," and the United Cerebral Palsy's (UCP) "Big Sky
Project."

Guiding Principles

Just as the ADA extended the reach of the nondiscrimination provisions
introduced by Section 504 of the Rehabilitation Act, it is time to
extend the reach of the Ticket to Work and Work Incentives Improvement
Act and modernize the income support and corollary health insurance
programs that serve Social Security beneficiaries. This modernization is
necessary so that people with significant disabilities have meaningful
opportunities to participate in the American economic mainstream and so
that we do not continue to support unnecessary dependence and force
people with disabilities to live in poverty in order to receive basic
government supports.

The Panel's recommendations for investing in disability program
modernization are based on ten guiding principles:

1.  Beneficiaries of public disability programs should be full
    participants in shaping the policies that will transform those
    programs.

2.  People with significant disabilities should be empowered to make
    informed choices about work opportunities.

3.  Disability policies should take into account differences in the
    needs and experiences of people with different types of
    disabilities.

4.  Disability policies should recognize the dynamic and cyclical nature
    of significant disability and assure appropriate public supports
    during periods of work capacity limitation or disruption.

5.  Work-oriented interventions should be provided timely in order to
    maintain a workforce connection for workers with new disabilities.

6.  Work should make individuals and their families economically better
    off than they are when they receive income supports and related
    assistance.

7.  Participation in work-oriented programs and services should be
    voluntary for youth and those adults who have been unable to
    establish or maintain an attachment to the workforce because of
    significant disabilities.

8.  Youth and others with significant disabilities should be provided
    the employment-related services and supports, internships and other
    opportunities and resources that will empower them to fully explore
    their vocational options (including self-employment) prior to
    entering a long-term income support program designed for individuals
    with limited work capacity.

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29. Disability programs should be as simple to understand and as easy to
    administer as possible, while balancing the need to address
    individual circumstances.

30. Disability programs should be effectively coordinated across
    agencies and among levels of government with clearly articulated
    benchmarks to evaluate success.

Long-Term Investment Outlook

The Panel is acutely aware of projected Old Age, Survivors, and
Disability Insurance trust fund shortfalls as well as long-term
projections for deficits in the federal budget.

The Panel believes that modernization proposals should be evaluated not
exclusively in terms of their short-term fiscal impact but also
according to the costs over the total life of the investment, including
long-term savings from decreased cash payments and increased tax
contributions. Recommendations for policy reform should also be
evaluated in the context of the costs of inaction, as reflected in
disability program growth trends and long-term economic predictions.
Given Congress's estimate, at the time of the Ticket to Work and Work
Incentives Improvement Act's passage in 1999, that a savings of \$3.5
billion could be expected when one half of one percent of the
beneficiary population left the benefit rolls because of employment, it
is not difficult to calculate substantial savings that can and will flow
from a well-designed system. Although the actuaries at SSA and the CBO
may be sparing in projecting potential long-term savings, Congress can
work with SSA, researchers, and other agencies to measure and
demonstrate the return on investment of different policy proposals.

A Comprehensive Approach

Because people with disabilities are a diverse population with varying
needs and work capacities, and because of variations in local labor
markets, no single program or policy will be universally successful in
promoting work and meeting the needs of all people with significant
disabilities. In short, there is no one-size-fits-all answer to the
challenges we face. Rather, mutually supportive and flexible programs
and policies need to be designed to support people with significant
disabilities at various stages of the onset and management of disability
and for varying levels of work capacity. These policies and programs
should build on demonstrations and innovations that are producing
results at the national, state and local levels. The Panel proposes the
following comprehensive set of recommendations to advance an ongoing
national dialogue regarding program modernization and sound long-term
investments in an employment strategy for Americans with disabilities.

**Raise Expectations**

Beneficiaries and disability advocates have consistently told the Panel
that people with significant disabilities are barraged with messages
that they are unable work. Many people with disabilities and their
families, as well as employers, health care professionals, educators,
and service providers, absorb these low expectations. Changing these low
expectations goes beyond simply including positive messages in the
material SSA provides about Social Security programs.

A social marketing campaign should be developed in close collaboration
with a diverse group of beneficiaries, their family members, educators,
employers, health care professionals, and those who serve people with
disabilities to identify the most effective mechanisms to transform
attitudes and expectations about employment and people with
disabilities. Messages could include:

-   For those who can work, work is not only an opportunity it is a
    personal responsibility to yourself, your family and your country.

-   People with significant disabilities want to be productive and can
    work if they are provided with the right supports.

-   Everybody loses when people with disabilities are not given an
    opportunity to work or are excluded from community life.

-   People with disabilities have a right to work.

-   Young people with disabilities should be provided every opportunity
    to work, live independently, and enjoy self-determination to the
    full extent of their abilities.

-   Families should be provided with the supports necessary to enable
    their children with disabilities to work and/or own a business and
    other income-generating assets to the full extent of their
    abilities.

-   Educators should expect students with significant disabilities to
    reach educational objectives and provide them with the
    individualized supports necessary to make it possible.

-   Employers should expect people with disabilities to compete
    effectively for jobs and promotions; they should expect employees
    with disabilities to help their companies innovate and reach a
    diverse and growing market including people with disabilities and
    their families.

-   Public and private programs and services are available to support
    people with disabilities in pursuing a career that matches their
    interests and abilities.

This type of marketing campaign is an essential component of the Panel's
strategy to increase employment, economic self-sufficiency, and
self-determination outcomes for people with significant disabilities.
People with disabilities and the influential people in their lives
should be instilled with the value of work, and employers should view
individuals with disabilities as a valuable talent pool.

**Recommendation 25:** The President should take the lead to establish
and provide financial support for a comprehensive, cross agency,
culturally competent social marketing campaign to raise expectations
about the productive employment potential of people with disabilities.
This campaign should target people with disabilities, their families,
educators, employers, health care professionals and those that serve
people with disabilities and the community. This marketing campaign
should use the most accessible and effective media, including
television, radio, the internet, and mainstream and specialty magazines
and newspapers.

Promote Workforce Connection and Retention

The private sector has developed many best practices in disability
management. For instance, when workers acquire new disabilities,
employers focus on timely intervention to ensure that workers have the
necessary health care and rehabilitation supports to recover from and
adapt to new disabilities. During the recovery process, employers and
insurers work intensively to assess and restore their employees' work
potential. Consequently, private sector disability insurers ask "what
can you do?" rather than require individuals to prove work incapacity.
People who acquire new disabilities may not be able to return to their
prior job. When that is not feasible, training and accommodations may
enable workers to transition to new jobs.

Managers using effective disability management practices recognize that
productivity and work are not an all-or-nothing proposition. Instead,
they allow workers to adjust their schedules or duties and provide
support during a restorative period to enable employees to remain at or
return to work. Some individuals may have to reduce the number of hours
they work or be unable to work for a period of time and then gradually
return to full- or part-time work.

In addition to minimizing the impact of a new disability, many employers
also have absence management programs oriented to preventing and
limiting disability. These programs promote workplace safety, minimize
injury, and provide wellness programs to improve worker health on and
off the job.

Employer-based disability management can reduce pressure on the Social
Security disability rolls by enabling employees to remain connected to
the workforce. Because disability management can reduce federal income
support expenditures, the federal government should play an active role
in supporting and encouraging private-sector efforts. The Panel
recommends that Congress, the President, and the Commissioner of SSA
work closely with states, employer organizations, disability
organizations, and the private insurance industry to explore ways that
public-private partnerships can help incentivize more employers to adopt
best practices in disability management.[^149] These best practices
should encompass the use of assistive technology.

Even the most effective disability management practices may not be
sufficient to enable people with significant disabilities to stay
connected to the workforce in the absence of comprehensive health care
and coverage for long term services and supports.

**Recommendation 26:** Congress should create employer incentives to
increase the availability of effective workforce retention policies and
programs to keep working adults with newly-diagnosed or
recently-exacerbated medical conditions connected to the workforce.

**Recommendation 27:** The Social Security Administration should
implement a demonstration that tests the costs and benefits of
establishing a publicly supported short-term disability insurance
program at the state level that is modeled on the best programs that
have been developed in the private sector and by state governments,
which would be available to individuals with work histories who do not
have private disability insurance.

Enhance Job Opportunities

Nothing changes work expectations more effectively than working. Work is
habit forming. People with disabilities who develop a work history are
more likely to view work as a natural part of their lives. Similarly,
employers who have successful records of employing people with
disabilities are more likely to expect that people with disabilities
will be productive employees. Most of the recommendations contained in
this report discuss programs and initiatives that can make work possible
and financially rewarding. However, the Panel is also aware that people
with disabilities cannot take advantage of these supports in the absence
of job opportunities.

A job creation strategy could take many forms. President Franklin Delano
Roosevelt created the Works Progress Administration (WPA) to help solve
the unemployment crisis that accompanied the Great Depression. The WPA
provided work opportunities to eight million Americans who built
schools, airports, dams, parks, bridges, and other public projects.
These workers developed and refined skills that they could carry to
private-sector employment. Similarly, the Comprehensive Employment
Training Act (CETA) signed by President Lyndon B. Johnson provided
disadvantaged job seekers with subsidized positions within the public
sector. In many cases, these positions led to permanent unsubsidized
positions. In 1982, President Ronald Reagan signed the Job Training
Partnership Act (JTPA) into law. The JTPA was a publicly funded job
training program that began a partnership with private sector employers.
JTPA programs were based at the local level and were guided in each
community by employer members of a private industry council. The
councils were a precursor to today\'s local workforce investment boards.

President George H.W. Bush signed the National and Community Service Act
into law in 1990. This legislation created a new independent federal
agency, the Commission on National and Community Service. In 1993,
President William Jefferson Clinton and Congress established the
AmeriCorps program through enactment of the National and Community
Service Trust Act of 1993, which built on the community service
legislation signed into law by President George H.W. Bush in 1990.
AmeriCorps is a network of national, state, and local service programs
that connect tens of thousands of Americans each year to volunteer
efforts addressing community needs in education, public health and
safety, and the environment. In addition to making critical and lasting
contributions to their communities, AmeriCorps participants develop
valuable skills that can help them prepare for private sector
employment. Participants also receive a monetary award to offset the
cost of higher education.

The WPA, CETA, JTPA and AmeriCorps programs offer powerful examples of
how the federal government can develop innovative approaches to engage
people in productive and skill-enhancing work that benefits local
communities. The President and Congress should explore ways that the
federal government can become more active in creating these types of
opportunities for people with disabilities.

An additional opportunity is presented by large-scale turnover in
federal jobs due to the retirement of the baby boom generation.[^150]
The federal government is developing initiatives to recruit more young
people into federal employment opportunities. By recruiting people with
disabilities into existing federal jobs and newly-created positions, the
government could simultaneously help meet its own hiring needs and help
prepare more people with disabilities to succeed in the private sector.

The President and Congress should also foster public-private
partnerships to improve recruitment and hiring of people with
disabilities in the private sector. Building on recent increases in
corporate interest in the disability market, corporate leaders could
encourage their counterparts at other companies to publicly commit to
increasing their recruitment, hiring, and promotion of people with
disabilities. Corporate-sponsored initiatives can change the
expectations of people with disabilities by showing that America's
strongest companies are dedicated to hiring them. These initiatives can
change corporate culture by sending a top-down message that people with
disabilities are a vital part of the workforce and should not be
overlooked. For these initiatives to have an impact, however, employers
need to set goals and benchmark their performance in recruitment,
retention, and promotion of their disabled workers.

**Recommendation 28:** The President should implement a job creation
strategy that engages and incentivizes public and private sector
employers in targeting people with significant disabilities for jobs
that pay a living wage and have benefits that enable a beneficiary to
move successfully from benefit receipt to employment, through a new
level of collaboration among state and federal employment and economic
development programs, the business community and disability
organizations.

Improve Access to Health Care and Long-Term Services and Supports

Millions of Americans lack access to basic health insurance coverage,
forcing them to make untenable choices between life-saving medicines and
treatments, preventive care, and basic life needs. Many people with
disabilities are counted among those who lack access to health care.
Moreover, people with disabilities face an additional crisis that is as
important as the lack of access: lack of appropriate programs that are
designed to meet their unique needs.

Both private and public health care insurance were developed in an era
when antiquated notions about people with disabilities prevailed. At the
time, disability was often presumed to mean inability to work. The
effect of these low expectations on health care coverage was profound.
Policymakers, employers, and actuaries designed employer-based health
coverage to meet the needs of non-disabled Americans and fashioned
Medicare and Medicaid to meet the needs of people with disabilities who
were expected to remain at home or in an institution. Consequently,
people with disabilities face a dual crisis:

-   Lack of access to basic health care coverage, including preventive
    care and assistance in living healthy lifestyles, and

-   Lack of affordable access to health care and long-term services and
    supports coverage designed to meet their needs if they want to work
    and participate fully in community life.

For millions of Americans with disabilities, access to health care
coverage is not merely important, but required. Foregoing health care
coverage is not an option because making such a decision would put
individuals' lives or well-being at risk. Because employer-based health
insurance is often not adequate, affordable, or available to meet the
needs of people with disabilities, many are compelled to seek Medicare
and Medicaid coverage. However, with limited exceptions, eligibility
restrictions for these programs typically discourage individuals from
earning and saving above certain thresholds. People with disabilities,
including current beneficiaries and participants in state Medicaid
Buy-In programs, identify fear of losing health care benefits as one of
the top reasons that they limit their efforts to work. Unless people
with disabilities have timely access to affordable, comprehensive health
care and long-term services and supports, our nation will continue to
dedicate valuable resources to keeping people at home instead of
enabling people to become as self-sufficient as possible.

Despite efforts to increase health care access through Medicaid and
Medicare, a number of challenges are faced by people with significant
disabilities in maintaining health care coverage:

-   Not all states offer access to Medicaid Buy-Ins for people with
    disabilities.

-   In those states that do offer Medicaid Buy-In programs, significant
    limits are often imposed on an individual's ability to earn income
    and accumulate assets.

-   In many states, Medicaid does not provide sufficient home- and
    community-based long term services and supports or enough options to
    serve individuals with a variety of needs and disabilities.

-   Medicaid services and supports vary greatly from state to state.

-   Medicaid often offers little choice in providers, particularly
    mental health providers, due to low reimbursement rates.

-   Medicare does not provide ongoing coverage for the personal
    assistance services and supports or mental health services that some
    individuals require in order to pursue and maintain work. The
    Medicare acute benefit is not based on contemporary medical
    standards.

-   Individuals who qualify for SSDI have to wait for two years before
    they are eligible for Medicare, and many individuals are unable to
    afford other interim coverage such as Consolidated Omnibus Budget
    Reconciliation Act (COBRA) coverage; during this period, one's
    ability to return to work may diminish along with one's health
    status.

The following principles should guide health care reform for people with
significant disabilities:

-   [Access For All]{.underline}. All people with significant
    disabilities should have access to affordable health care and
    long-term services and supports coverage, regardless of income level
    and independent of qualifying for or retaining access to long-term
    income support.

-   [Timeliness]{.underline}. People with disabilities should be able to
    access health care and long-term services and supports when needs
    arise, not based upon arbitrary eligibility delays.

-   [Comprehensiveness]{.underline}. To support work and efforts to
    achieve self-sufficiency, coverage should include acute care,
    specialized care, prescription drugs, assistive technology
    (including durable medical equipment) for use in the community as
    well as the home, mental health services, and consumer-directed
    long-term personal assistance services and supports.

-   [Portability]{.underline}. To enable people to pursue job
    opportunities wherever they may be, people with significant
    disabilities should be able to obtain standardized health care
    coverage in any state.

-   [Contributory]{.underline}. People with significant disabilities
    should contribute more toward the costs of health care as their
    incomes rise; individuals of lower income should be exempt from
    cost-sharing obligations.

-   [Public-Private Coordination]{.underline}. The federal government
    should offset the increased costs of coverage for people with
    significant disabilities by providing benefits that either wrap
    around a basic employer-provided benefit or enable employers to
    contribute to federal coverage in lieu of their basic employee
    benefit. Benefits should be coordinated to ensure timely coverage
    and avoid the delays commonly associated with overlapping insurance
    coverage.

Because health care reform has once again taken center stage in our
national debate, these reform principles should be pursued either as
part of broad, national reform and/or by building on the Medicare and
Medicaid programs. In addition, to the extent possible, these goals
should be accomplished in the context of a health care system used by
all Americans. Options could include:

-   [Reforming Medicaid]{.underline}. The existing federal-state
    partnerships for providing Medicaid could be expanded to guarantee
    an identical benefit consistent from state to state, supported by
    100 percent matching with federal funds. Medicaid recipients should
    play a significant role in the design and implementation of any
    reforms.

-   [Reforming Medicare]{.underline}. Coupled with reforming existing
    acute care benefits to meet the needs of individuals active in their
    communities and eliminating the two-year waiting period for SSDI
    beneficiaries, a new component of Medicare could be established to
    cover long-term services and supports similar to those currently
    available in some state Medicaid programs. Medicare beneficiaries
    should play a significant role in the design and implementation of
    any reforms. Modernizing Medicare is particularly important because
    many private health insurance policies are modeled on the acute
    health care coverage that is available under Medicare.

-   [Coordinated Reform of Medicare and Medicaid]{.underline}. Instead
    of transforming either Medicare or Medicaid to provide the full
    scope of comprehensive health care and long-term services and
    supports, policymakers could provide people with significant
    disabilities with access to both Medicare and Medicaid. Each program
    could be reformed to provide complementary coverage that, when
    combined, would provide the comprehensive coverage that people with
    significant disabilities need. For instance, Medicare could be
    reformed to provide comprehensive acute care coverage without a
    two-year waiting period, including better assistive technology and
    mental health services coverage. Similarly, Medicaid could be
    reformed to provide a uniform, federally supported long-term
    services and supports benefit to wrap around Medicare's acute care
    coverage.

-   [Comprehensive Health Reform]{.underline}. If Congress and SSA
    collaborate to increase access to health care coverage for all
    Americans, it may be possible to ensure that the needs of people
    with significant disabilities are incorporated into proposed
    solutions. Alternatively, Congress could reform Medicare and/or
    Medicaid to ensure that wraparound benefits to complement basic
    health care coverage are provided to all Americans.

The Panel views these options as viable approaches to providing people
with significant disabilities with the critical health care and
long-term services and supports they need to help achieve their
self-sufficiency goals. Irrespective of the specific reform path that is
pursued, people with significant disabilities, including SSI, SSDI,
Medicare and Medicaid beneficiaries, should be involved in policy
debates to ensure that the needs of people with disabilities are
properly addressed.

**Recommendation 29:** Congress should work in a bipartisan fashion to
build on the goals of the Medicaid Buy-In and the Medicaid
Infrastructure Grant to ensure that people with significant disabilities
have access to affordable coverage for health care and long-term
services and supports that is comprehensive; portable; supported by
beneficiary contributions, where appropriate; independent from
qualifying for income support; and coordinated with employer-sponsored
benefits.

Create a Transition to Economic Self-Sufficiency Large-Scale
Demonstration Program

The Panel believes that people with significant disabilities should have
access to supports to maximize their economic self-sufficiency. In
particular, young people should be provided a meaningful opportunity to
learn, plan and participate in the economic mainstream.

In accordance with the principle of "do no harm" and the desire to
continue the national dialogue about modernizing disability programs, a
large-scale Transition to Economic Self-Sufficiency (TESS) demonstration
project should assess the potential and unintended consequences of a new
approach to providing supports for particular beneficiary
subpopulations. The TESS demonstration should be designed to serve
people with significant disabilities ages 14 - 30 who face significant
barriers to work but who could increase self-sufficiency if provided
adequate supports.

The Panel believes it is critical to preserve the SSI and SSDI
entitlement programs. However, these entitlement programs, as currently
designed and implemented, are not sufficiently dynamic to meet the needs
of individuals who want and are able, with supports and services, to
achieve levels of self-sufficiency through work.

Work incentive reforms have increased options for pursuing employment
and career objectives while retaining access to critical supports.
However, these reforms are complicated, poorly administered and
restrained by an underlying philosophy that links income support (SSI
adult program and SSDI) to an inability to work. Statistics show that,
on average, people who enter SSI prior to age 18 remain on the rolls for
27 years.[^151]

Truly meeting the needs of young people with significant disabilities
requires that our nation adopt a philosophy guided by *investment*
rather than *maintenance*. A high return on investment can be expected
if our nation invests in youth before they have internalized low
expectations and become mired in well-intended programs that require a
commitment to unemployment or underemployment in exchange for critical
supports.

This recommendation for a large scale demonstration project pertaining
to TESS was considered controversial by a minority of Panel members, who
felt the recommendation raised considerable concerns. Panel members
Cheryl Bates-Harris, Thomas P. Golden and Dorothy Watson expressed
opposition to the TESS proposal stating that they did not feel the
recommendation was well justified and had not been thoroughly discussed
or adequately vetted with internal or external stakeholders.\
\
They believe that the TESS proposal, while well intentioned, is unclear
and vague as well as complex and costly. Rather than simplifying the
labyrinth of programs, it seems to add another layer of complexity. They
believe that for a major new proposal such as TESS, it is necessary to
be far more clear about its components, its costs, and how it will be
administered and implemented.

Features of the TESS Large-Scale Demonstration

Eligibility

Young people ages 14 - 30 should become eligible for the TESS
demonstration based on the nature of their disabilities and the
disability-related barriers to work they are likely to face. During
their participation in the TESS demonstration, young people with
disabilities should be encouraged to learn, plan, earn and save as much
as they can while maintaining access to cash benefits on a gradual
reduction basis.

Cash Benefits

Under current rules, SSI and SSDI beneficiaries' cash benefits are
reduced as earnings rise (gradually under SSI, or suddenly under SSDI).
As has been well documented, people with significant disabilities often
struggle to determine whether earning above the relevant thresholds is
worth the financial risk of losing access to cash benefits. In essence,
SSI and SSDI create incentives for beneficiaries to limit earnings.

The TESS demonstration should adopt a new philosophy for youth that
draws on features of the current SSI and SSDI programs. Under TESS,
individuals could receive cash benefits equivalent to the amount they
are entitled to under the traditional rules of SSI and/or SSDI. Cash
benefits under the TESS program could be reduced as follows.

-   TESS participants could keep all earned and unearned income without
    any impact on SSA cash benefits up to a specified threshold. For
    instance, all earned and unearned income up to 200 percent of SGA or
    the federal poverty level would be exempt from any reduction in cash
    benefits.

-   After reaching a designated income threshold, TESS participants'
    cash benefits would be reduced gradually, comparable to the existing
    two-for-one reduction in the SSI program, up to a second threshold.
    For instance, cash benefits could be gradually reduced between 200
    percent and 300 percent of SGA or the federal poverty level.

-   Individuals between the ages of 14 -- 30, with income above the
    second threshold would not receive any cash benefits. However, they
    would resume receipt of cash benefits on any occasion during which
    income fell below the specified thresholds for full or partial cash
    benefits.

-   The scope of the current PASS program could be expanded in
    conjunction with the TESS program to enable SSI and SSDI
    beneficiaries to establish Independence Accounts through PASS.

-   During any month in which TESS participants' cash benefits were
    subject to a reduction due to earnings, SSA could continue to pay a
    portion of the cash benefit into an Independence Account, as
    described below.

This approach to cash benefits for young people with significant
disabilities would clearly reward efforts to increase income by enabling
individuals to retain a significant portion of income and thereafter
reduce cash benefits gradually rather than suddenly.

Health Care and Long-Term Services and Supports

As described in recommendation 29, the Panel recommends that all people
with significant disabilities should have access to comprehensive health
care and long-term services and supports coverage. In the absence of
more far-reaching reform that would affect all people with significant
disabilities, Congress should, at minimum, guarantee participants in a
TESS demonstration access to the type of coverage recommended by the
Panel. TESS demonstration participants should retain access to this
coverage throughout their program participation, regardless of earnings
and asset levels. TESS demonstration participants should be required to
contribute to their coverage on a sliding-scale based on their income
(including an exemption for low-income earners).

Independence Accounts

The TESS demonstration should incorporate newly-established Independence
Accounts. As noted above, during a period which cash benefits are
reduced gradually, SSA could continue to contribute a portion of an
individual's cash benefit into an Independence Account. Funds
contributed to these accounts either by SSA or by individuals could be
used to acquire assets that increase self-sufficiency. For instance,
funds could be used to purchase assistive technology, vocational and
educational training, purchase a vehicle, participate in a retirement
plan, start a business, or save for a down payment on a home.

Career and Employment Services

The TESS demonstration should be consistent with the objectives of the
Ticket to Work program. Consequently, TESS participants should be
entitled to assign their tickets to ENs.

TESS demonstration participants should be provided an interdisciplinary,
person-centered assessment, focused on strengths and abilities, to
identify the education and training that will maximize their future
earning potential. Particular emphasis should be placed on integrating
career assessment and transition planning services with Individualized
Education Plans (IEPs) to ensure that services provided support the
needs and career interests of students. Ideally, TESS demonstration
participants and their families should have access to independent living
centers and other consumer-directed disability organizations to obtain
peer-to-peer mentoring.

The TESS demonstration should also provide comprehensive employment
services and supports that are flexible enough to accommodate the
individual needs of young people with significant disabilities. TESS
demonstration participants should have ongoing access to these services
and supports to adjust to new issues that emerge after transitioning to
work, including preparing for job changes as well as making financially
sound decisions regarding management of the personalized Independence
Accounts. The demonstration should provide all services in a culturally
competent manner and support a wide range of work options, including but
not limited to self-employment, customized employment, and public
service.

Employment services and supports for TESS demonstration participants
should be integrated with existing services for students and
beneficiaries to enable young people to evaluate how to best utilize the
TESS demonstration program. Existing services for students include VR,
ENs, and ILCs.

*Outreach to Youth below Age* *16*

Youth below the age of 16 should be exposed to work and career options
and should be encouraged to pursue their education in preparation for
life as working adults. The TESS demonstration should include an
outreach component that coordinates with school programs and sets
expectations among young people with disabilities age 14 to 30. The
primary outreach message must be that work is a viable option for them,
that there are many interesting career options available, and that
education is one key to success. In addition, TESS demonstration
grantees should be expected to coordinate with local education agencies
and Social Security field offices to identify children before age 14 who
are likely to be eligible for the TESS demonstration upon turning 14.

Improve Access to Internships and Transitional Work

The TESS demonstration should provide participants with access to
internships and transitional work opportunities. These opportunities
have proved effective in acquiring work skills and behaviors and gaining
access to job openings before they are advertised. A number of
innovative approaches to internships and transitional work are already
in place in communities around the country.

Financial Literacy Training and Asset Development Strategies

TESS demonstration participants should be provided financial literacy
training and assistance in asset development to leverage individual
development account programs, tax incentives like the Earned Income Tax
Credit, home ownership programs, and other policies and programs that
are designed to help low-wage workers achieve a greater degree of
economic self-sufficiency.

Integration with Other Disability Programs

Participants in the TESS demonstration should not be denied access to
other needed public benefits and assistance. Independence Account
resources should not be counted toward initial or continuing eligibility
for other public benefits. HUD, Medicaid, Mental Health, Food Stamps,
Energy Assistance, Transportation, VR and other programs providing
support to persons with disabilities should be integrated with the TESS
demonstration.

**Recommendation 30:** The Social Security Administration should design
and implement a large-scale demonstration project that studies the
feasibility, cost-effectiveness, and any unintended consequences of a
voluntary Transition to Economic Self-Sufficiency Program for young
people who are between 14 and 30 years old and qualify for Supplemental
Security Income and/or Social Security Disability Insurance. This
demonstration project should build on the goals of the Ticket to Work
program and evaluate the feasibility of a program that would transform
Supplemental Security Income and Social Security Disability Insurance by
establishing unified rules that: provide a graduated cash payment to
address the effects of disability-related barriers on income; build on
the Ticket to Work program to increase the availability of and consumer
control over employment-related services; promote optimal educational
outcomes; and enable program participants to maximize income and assets
without fear of losing critical supports.

Modernize the Social Security Definition of Disability

The Panel acknowledges that proposing any change to the definition of
disability raises legitimate fears. Consequently, the Panel believes
that any proposed change to the Social Security definition of disability
should be evaluated to assess the potential for any adverse impact on
beneficiary subpopulations.

The Social Security definition of disability has not changed in any
meaningful way since the eligibility criteria for SSDI were developed in
1956.[^152] This is inconsistent with fundamental changes in societal
thinking, advances in science, medicine and technology and the passage
of numerous laws. Beneficiaries have repeatedly told the Panel that they
view the Social Security definition of disability as one of the most
significant impediments to work. Beneficiaries describe applying for
Social Security as a pledge that they are unable to work. In addition,
even though beneficiaries recognize that disability is defined as the
inability to do any substantial gainful activity by reason of any
medically determinable physical or mental impairment which can be
expected to result in death or which has lasted or can be expected to
last for a continuous period of not less than 12 months and does not
require permanent inability to work, the reality is that meeting the
definition discourages future work. To meet this definition, one must
have a severe impairment(s) that makes them unable to do their past
relevant work (*see* [[§ 404.1560]{.underline}](../404-1560.htm)(b)) or
any other substantial gainful work that exists in the national economy.
Chapter 20, Title 20, CFR, Subpart P, Section 404.1505.

As long as eligibility is defined for our largest federal income support
and health care programs based on an inability to engage in SGA that
results from medical impairment expected to last for at least one year,
we will continue to send a clear message to people with significant
disabilities that they are inherently unable to support themselves. In
short, our largest public programs consistently tell our working-age
population with disabilities that we do not expect them to work or
participate fully in their communities when they qualify for these
income and health care supports.

People with disabilities should never be obligated to attest that their
disabilities *prevent* them from working. Doing so implies that working
is not a feasible option even if adequate supports were provided.

**Recommendation 31:** Congress and the Administration should take
action to evaluate the impact of modernizing the Social Security
definition of disability by defining disability in a manner that
acknowledges the interaction between the person's impairment and the
environment and does not require the individual to prove their inability
to engage in substantial gainful activity.

Coordinate Disability Programs at the Federal Level

For more than two decades, reports by NCD and GAO[^153] have
consistently described a fragmented disability service delivery
infrastructure marked by:

-   Widespread confusion among consumers;

-   Overlapping and at times inconsistent responsibilities; and

-   Lack of accurate information about eligibility, work incentives, and
    means tested resource limits of multiple public benefits.

The Panel believes that the White House Domestic Policy Council should
take the lead in improving communication and collaboration among federal
programs that provide employment services and supports. They should
coordinate with representatives from agencies with significant
disability programs, including SSA, the Departments of Health and Human
Services, Education, Labor, Transportation, Veterans Affairs, and HUD.
The Domestic Policy Council should also coordinate with representatives
from GAO, OMB and beneficiaries that represent the broadest diversity in
disability, culture, age, race, and gender. It is particularly important
that the council ensure that SSA and CMS coordinate their efforts at the
highest levels because SSA and CMS account for the vast majority of
disability program expenditures, and the lack of access to health care
and long term services and supports is consistently identified as one of
the most critical barriers to work for people with disabilities.

The Domestic Policy Council should continue to identify opportunities to
improve coordination and collaboration across agencies at a federal and
a state level. Options should be explored and evaluated for direct
positive impact on beneficiaries at a local level.

**Recommendation 32:** The Domestic Policy Council should ensure ongoing
communication and collaboration among federal programs that provide
employment services and supports.

# Call to Action {#call-to-action .Exec-Heading}

"From my perspective, the Work Incentives Improvement Act of 1999
represents a natural and important progression in federal policy for
individuals with disabilities. That is, federal policy increasingly
reflects the premise that individuals with disabilities are cherished by
their families, valued and respected in their communities, and are an
asset and resource to our national economy. Today, most federal policy
promotes opportunities for these individuals, regardless of the severity
of their disabilities, to contribute to their maximum potential-at home,
in school, at work, and in the community."

U.S. Senator James Jeffords

Floor Statement, November 18, 1999

The Panel's call for national dialog and investment in disability
program modernization is consistent with the conclusions of GAO,[^154]
the SSAB,[^155] NCD,[^156] the American Association of People with
Disabilities,[^157] the National Council on Independent Living and the
World Institute on Disability,[^158] and beneficiaries.[^159] Our
commitment to modernization is the natural extension of the legislation
that created the Panel. The Act embraced the concept that supports and
work can go hand in hand --- that people with significant disabilities
should have access to health care and other critical supports rather
than be forced to stay out of the workforce to get them.

At a time when policymakers predict a shortfall of workers as the baby
boom generation retires, and some policymakers are trying to curb the
flow of new immigrant workers, our nation cannot afford to squander the
potential of Americans with disabilities who want to work. Nor can we
continue to undervalue the future work potential of the millions of
children and youth with disabilities who are making their way through
our education system now, and in the future. Finally, with thousands of
wounded American soldiers returning from Iraq and Afghanistan,
communities need to prepare for an influx of working-age veterans with
disabilities. Increasing economic self-sufficiency for people with
disabilities will occur only when we modernize the four largest programs
serving Americans with significant disabilities: SSI, SSDI, Medicaid,
and Medicare.

We can no longer delay modernizing our largest disability programs.
These programs must shift from the current emphasis on inability to work
and dependence on government with no path out of poverty to an emphasis
on investment in individuals with disabilities promoting work and
advancing self-sufficiency.

Eight years ago, the President, Congress, and SSA agreed to invest in
human potential to reduce or eliminate remaining barriers to employment
and economic participation for people with significant disabilities.
Today, costs and frustration increase with the slow pace of progress.
The promise of the Ticket to Work program has yet to be realized. Even
if implementation of the Act had moved forward with greater speed and
impact, additional modernization is needed to balance economic security
and opportunity for individuals with significant disabilities.

The Panel urges Congress to take action on these recommendations and not
to further delay a focus on a modernization that rebalances risk and
aligns public policy and systems in support of employment and advancing
economic self-sufficiency.

[]{#__RefHeading___Toc185405222 .anchor}Appendix A

**Summary of the Ticket to Work and Work Incentives Improvement Act of
1999**

The Ticket to Work and Work Incentives Improvement Act (the Act), which
was enacted on December 17, 1999, is administered by the Social Security
Administration (SSA) and the Department of Health and Human Services
(HHS). The Act increases beneficiaries' choices for rehabilitation and
vocational services, reduces barriers that require people with
disabilities to choose between health care coverage and work, and
ensures that more Americans with disabilities have opportunities to work
and lessen their dependence on public benefits. Different provisions of
the law became effective at various times, generally beginning one year
after enactment.

**[Summary of Title I---Ticket to Work and Self-Sufficiency and Related
Programs]{.underline}**

*Subtitle A---Ticket to Work and Self-Sufficiency and Related Programs*

Subtitle A established the Ticket to Work program, under which most
beneficiaries would receive a \"ticket\" that they could use to obtain
vocational rehabilitation, employment, or other support services from an
approved provider of their choice. This voluntary program was phased in
nationally over three years. It established a program manager,
Employment Networks (ENs), and payment systems; called for a report on
the adequacy of incentives and the establishment of a dispute resolution
mechanism; provided for suspension of continuing disability reviews for
persons using the ticket; and established the Ticket to Work and Work
Incentives Advisory Panel to advise the Commissioner of SSA, the
President, and Congress on the Ticket to Work program and issues related
to work incentive programs, planning and assistance for individuals with
disabilities.

*Subtitle B---Elimination of Disincentives to Work*

Subtitle B eliminated the work activity standard as a basis for
reviewing an individual\'s disability status and provided for expedited
reinstatement of benefits if the person does not continue working.

*Subtitle C---Work Incentives Planning and Outreach*

Subtitle C set up the Work Incentives Outreach Program, including
external Benefits Planning, Assistance, and Outreach (BPAO) programs and
the internal corps of Social Security experts on work incentives and
employment. It established a grant program for a protection and advocacy
(P&A) agency in each state to assist beneficiaries.

**[Summary of Title II---Expanded Availability of Health Care
Services]{.underline}**

Title II expanded state options under Medicaid for workers with
disabilities. It called for a General Accounting Office study on
extending Medicare coverage for Social Security beneficiaries, and
established state infrastructure grant authority and demonstration
projects. Title II required a demonstration of coverage under Medicaid
of workers with potentially severe disabilities and allowed disabled
beneficiaries to suspend Medigap coverage. Title II also extended
Medicare coverage to SSDI beneficiaries who are working to up to 8 1/2
years.

**[Summary of Title III---Demonstration Projects and
Studies]{.underline}**

Title III amends Title II to provide for a permanent extension of
disability insurance program demonstration project authority and called
for specific studies and reports, including a demonstration study of a
\$1 reduction in benefits for every \$2 earned.

[]{#__RefHeading___Toc185405223 .anchor}Appendix B

The Panel

**Current Panel Members**

**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 U.S.
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 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. Mrs. De La Rosa-Aponte was
appointed to the Panel by the U.S. House of Representatives to serve a
4-year term ending in 2007 and designated by President George W. Bush 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, Temporary Assistance
for Needy Families, and other work programs that impact people with
disabilities, including Department of Labor One-Stops. Since the passage
of Ticket to Work and Work Incentive Improvement Act she has conducted
national training on the Act and Vocational Rehabilitation Services and
has conducted extensive training on the intersection issues of the
Ticket to Work program with state vocational rehabilitation services.
Cheryl currently co-chairs the Consortium for Citizens with Disabilities
(CCD) Work Incentives Implementation Task Force and the CCD Employment
and Training Task Force and is an active member of the CCD Social
Security Task Force. President George W. Bush 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 many
presentations about children with health care needs before various
audiences including Congressional committees. 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, IA office. The U.S. 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 President George W. Bush 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
(CEO) 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 M.A. in Rehabilitation Administration from
the University of San Francisco and a B.A. in Political Science from the
University of Kentucky. The U.S. House of Representatives appointed him
to the Panel in 2005.

**Loretta Goff** **─** Loretta Goff is a Registered Nurse with a B.S. in
Health Care Administration, a M.S. 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 from the New York State Commission 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 U.S. House of Representatives in 2005. 

**Thomas P. 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 the 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 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 Aid to Families with Dependent Children
(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, Ms. Gracechild identifies with other people
reaching beyond oppressive stereotypes to live a life of dignity and
purpose. Ms. Gracechild was appointed to the Panel by the U.S. House of
Representatives in 2000.

**Andrew J. Imparato ─** Andrew Imparato is President and CEO of the
American Association of People With Disabilities (AAPD). Mr. Imparato
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 University. 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 U. S. Senate re-appointed him to serve a
4-year term ending in 2008.

**David Miller** **─** David 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
throughout the United States. CSD is the nation's largest provider of
telecommunication relay services for the deaf. Mr. Miller was formerly
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. Mr. Miller was appointed
to the Panel by the U.S. Senate in 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 multiple 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. President George W.
Bush 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 including training/employment
opportunities for persons with disabilities, transportation, energy and
rural development issues. He has a J.D. 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 two children.  President
George W. Bush appointed him to the Panel in 2002.

**Former Panel Members**

**Richard Burkhauser** **─** Richard V. Burkhauser is the Sarah Gibson
Blandings Professor of Public Policy in the Department of Policy
Analysis and Management, Cornell University. His professional career has
focused on how public policies affect the economic behavior and
well-being of vulnerable populations, e.g., people with disabilities,
older persons, and low-skilled workers. He has published widely on these
topics in journals of demography, economics, gerontology, and public
policy. As Co-Principal Investigator of the National Institute on
Disability and Rehabilitation Research (NIDRR) Center for Economic
Research on Employment Policy for Persons with Disabilities and the
Co-Principal Investigator of the NIDRR Center on Disability Demographics
and Statistics, he has carried out an extensive program of technical
assistance and presentations to government agencies, policymakers and
consumers on the employment and economic well-being of people with
disabilities. Mr. Burkhauser received his Ph.D. in Economics from the
University of Chicago in 1976. He was appointed to the Panel by the U.S.
Senate to serve from 2000 to 2002.

**Kristin Flaten** **─** Kristin Flaten lives in St. Paul, Minnesota.
She is the owner of INITIATIVES, a small business dedicated to enhancing
the lives of persons with mental illnesses through providing educational
services, advocacy, benefit analysis, and access to health care. She has
consulted for SSA and other federal agencies on disability issues. Ms.
Flaten conducts many speaking engagements on mental illnesses, recovery,
suicide prevention, SSA programs, and health care benefits. Her
audiences include community groups, churches, and county staff. In
addition, Ms. Flaten provides testimony to the Minnesota legislature and
at public hearings. Also, she provides individual advocacy concerning
benefits and access to health care. She was appointed by President
William Jefferson Clinton to serve on the Panel from 2000 to 2002.

**Christine M. Griffin** **─** Christine M. Griffin was sworn in on
January 3, 2006 as a Commissioner of the U.S. Equal Employment
Opportunity Commission (EEOC). Ms. Griffin's work experience in labor
and employment law includes positions in both the public and private
sectors. Most recently, she served as the Executive Director of the
Disability Law Center in Boston from 1996 to 2005. The Law Center
provides legal advocacy on disability issues that promote the
fundamental rights of all people with disabilities to participate fully
and equally in the social and economic life of Massachusetts. As
Executive Director, she provided leadership for the Law Center's 25
employees and conducted its overall management, including programmatic
and fiscal planning, priority setting and implementation, and
fundraising. A native of Boston, Ms. Griffin is a graduate of the
Massachusetts Maritime Academy and served as its Interim President from
1993 to 1994. She is also a graduate of Boston College Law School and,
upon graduation, was awarded a Skadden Arps Fellowship at the Disability
Law Center. Ms. Griffin was appointed by President William Jefferson
Clinton and served on the Panel from 2000 to 2004.

**Larry Henderson** **─** Larry Henderson has been employed as the
Executive Director of Independent Resources, Inc., a center for
independent living, for the past 13 years. He has been active in the
disability field for almost 20 years. He is the past Chair of the State
Independent Living Council as well as the Developmental Disabilities
Council, where he still chairs the Adult Issues Committee. He has acted
as a consultant and trainer for the Rehabilitation Research and Training
Center on Independent Living Management in the development of their
Executive Management Simulation, and often serves as a consultant for
the Department of Education, Rehabilitation Services Administration
grant review teams. He was appointed by the U.S. Senate and served as
one of the original 12 members of the Panel.

**Jerome Kleckley** **─** Jerome Kleckley, MSW, LMSW is a United States
Navy veteran and has been a valuable staff member at United Spinal
Association since joining as a social work intern in 1992. Mr. Kleckley
has served as Housing Coordinator, Medical Transportation Program
Coordinator and, from 1997 to January 2007, as Director of Social
Services. He is presently the Vice President of Social Services and
National Peer Mentor Coordinator. He is currently spearheading
development and implementation of United Spinal's new Peer Support
Network, which includes an innovative Peer Mentor Program, a Peer Mentor
Support Group, Spinal Cord Injury Resource Materials, and a Network Data
Base. Mr. Kleckley holds a master's degree in social work from Fordham
University and a bachelor's degree from York College. He lives New City,
New York. He was appointed by the U.S. House of Representatives to serve
on the Panel from 2000 to 2005.

**Stephanie Smith Lee** **─** Stephanie Smith Lee has thirty years of
experience in public policy, including serving as Director of the Office
of Special Education Programs (OSEP) in the U.S. Department of
Education, in senior Congressional staff positions, as a foundation
administrator, and as a nationally recognized disability parent leader.
Since her daughter, Laura, was born with Down syndrome in 1982, she has
organized and led successful bipartisan, collaborative efforts to
improve special education and disability policy at the local, state, and
federal levels. As OSEP Director from 2002 through March 2005, Ms. Lee
directed the policy development, program planning, monitoring,
evaluation, research and implementation of the Federal special education
law. She provided leadership in focusing OSEP's work on accountability
for results, reforming the monitoring system, promoting inclusion and
the use of universal design principles, improving early childhood
education, and promoting improved transition and postsecondary results
for students with disabilities. Ms. Lee also provided leadership in the
development of the No Child Left Behind Act regulations, guidance, and
implementation related to students with disabilities. Ms. Lee was
appointed by the U.S. Senate to serve on the Panel from 2000-2002.

**Bryon MacDonald** **─** Bryon MacDonald is founder and Program Manager
of the California World Incentives Initiative (CWII) at the World
Institute on Disability (WID). He manages WID's team of Disabilities
Benefits 101 benefit program analysts and technology experts. Since
2000, the program has supported public policy education activities and
provides multi-media information services on health, benefits, work and
disability. Prior to his current position, Mr. MacDonald was a
consultant and a Community Advocate for the Center for Independent
Living Berkeley/Oakland. He served as a Mental Health Advocate from 1990
to 1996 at the Mental Health Association of Alameda County. Mr.
MacDonald received his B.A. in English from Fordham University.
President William Jefferson Clinton appointed him to the Panel from
2000-2004.

**Sarah W. Mitchell** **─** Sarah W. Mitchell, R.N., M.S.W., J.D., is
Executive Director/CEO of New Jersey Protection and Advocacy, Inc., the
designated P&A system for people with disabilities in New Jersey. Prior
to this she taught nursing at the University of Michigan, served as
Assistant Dean at Rutgers Law School and as an associate at the
Philadelphia law firm of Dechert, and clerked on the Third Circuit Court
of Appeals. Ms. Mitchell is a past president of the National Association
of Protection and Advocacy Systems and a past member of the American Bar
Association's Commission on Mental and Physical Disability Law.
President William Jefferson Clinton appointed her to a four-year term as
the first Chair of the Panel. Her term ended in 2004.

**Vincent Randazzo** **─** Vincent Randazzo is a Senior Vice President
and the Director of Government Relations for Wachovia Corporation in
Charlotte, North Carolina, where he is responsible for formulating and
directing all activities relating to federal and state legislation and
public policies relating to the company and its lines of business. Prior
to joining Wachovia in November 2003, Mr. Randazzo spent two years as
the Director of Public Policy for the Washington, D.C.-based Business
Roundtable, an association of chief executive officers of leading U.S.
companies. He was responsible for the strategic development and
management of federal legislative and regulatory issues and programs,
including fiscal policy, civil justice reform and health and retirement
policy. Mr. Randazzo is a graduate of Eastern Michigan University with a
Bachelor of Science degree in political science and George Mason
University with a Master of Arts degree in economics. He is the parent
of a child with developmental disabilities. He was appointed by the U.S.
Senate to serve on the Panel from 2002 to 2003.

**Stephen Start** **─** In 1979 Stephen Start founded and, until his
retirement in 2007, successfully managed SL Start. He has a Bachelor of
Science degree in Psychology, and is a Certified Vocational Evaluator
and Certified Rehabilitation Counselor. Mr. Start has 30 years of
multi-state experience in employment and provision of vocational
rehabilitation services, and is a presenter and author of numerous
articles. Mr. Start co-founded and co-chaired the Return to Work
Coalition of providers and advocates that formed with the single purpose
of promoting legislative reform for SSA\'s disability programs return to
work policies. This group had a major impact on the development and
passage of the Ticket to Work and Work Incentive Improvement Act of
1999. Mr. Start was appointed by the U.S. House of Representatives to be
a member of the Panel from 2000 to 2004.

**Susan Webb** **─** Susan Webb has 33 years of personal experience with
a significant disability and is a former beneficiary of Social Security
Disability Insurance. Susan left the rolls in 1977 to pursue a career.
She worked for 12 years as a telecommunications professional with AT&T,
during which she acquired a B.S. in Industrial and Organizational
Psychology and later an M.B.A. Susan is a certified Senior Professional
in Human Resources (SPHR) and Director of ABIL Employment Services (AES)
in Phoenix, Arizona. AES is contracted by SSA as an Employment Network
(EN) under the Ticket to Work program and is one of the top-producing
ENs in the country. Ms. Webb is President of the National Employment
Network Association and was appointed by the U. S. House of
Representatives to the Panel from 2000 to 2002.

***Panel Staff***

Jill Houghton, Executive Director

Michael Anzick

Shirletta Banks

Patricia Laird

Jenn Rigger

Debra Tidwell-Peters

[]{#__RefHeading___Toc185405224 .anchor}Appendix C

##  {#section-7 .Annual-Report-Heading-2}

Tables -- Panel Recommendations

Ticket to Work and Work Incentives Advisory Panel

Recommendations from December 1999 - December 2007

Table 1: NO FINAL ACTION TAKEN

+--------+---------------+----------+-------+-----------+------------+
| [I     | [Recommend    | [Date    | [Sour | [         | [Relevan   |
| ssue]{ | ation]{.mark} | ]{.mark} | ce]{. | Submitted | ce]{.mark} |
| .mark} |               |          | mark} | T         |            |
|        |               |          |       | o]{.mark} |            |
+========+===============+==========+=======+===========+============+
| Re     |               |          |       |           |            |
| quires |               |          |       |           |            |
| Legis  |               |          |       |           |            |
| lative |               |          |       |           |            |
| Action |               |          |       |           |            |
| and    |               |          |       |           |            |
| Gr     |               |          |       |           |            |
| anting |               |          |       |           |            |
| of     |               |          |       |           |            |
| Sta    |               |          |       |           |            |
| tutory |               |          |       |           |            |
| Aut    |               |          |       |           |            |
| hority |               |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| SSA    | Congress      | June 18, | A     | Congress  | No longer  |
| rep    | should pass a | 2002     | dvice |           | relevant   |
| orting | technical     |          | R     |           |            |
|        | amendment to  |          | eport |           |            |
|        | require       |          | on    |           |            |
|        | interim       |          | the   |           |            |
|        | reporting     |          | Ade   |           |            |
|        |               |          | quacy |           |            |
|        |               |          | of    |           |            |
|        |               |          | Incen |           |            |
|        |               |          | tives |           |            |
|        |               |          | (AOI) |           |            |
|        |               |          | Study |           |            |
+--------+---------------+----------+-------+-----------+------------+
| AOI    | Extend        | June 18, | A     | Congress  | No longer  |
|        | deadline for  | 2002     | dvice |           | relevant   |
|        | Adequacy of   |          | R     |           |            |
|        | Incentives    |          | eport |           |            |
|        | Report        |          | on    |           |            |
|        |               |          | the   |           |            |
|        |               |          | Ade   |           |            |
|        |               |          | quacy |           |            |
|        |               |          | of    |           |            |
|        |               |          | Incen |           |            |
|        |               |          | tives |           |            |
|        |               |          | (AOI) |           |            |
|        |               |          | Study |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Public | Congress      | August   | Adv   | Congress  | Relevant   |
| edu    | should direct | 2002     | isory |           |            |
| cation | SSA to spend  |          | Panel |           |            |
| and    | more on       |          | A     |           |            |
| field  | public        |          | nnual |           |            |
| tr     | education and |          | Re    |           |            |
| aining | field         |          | port: |           |            |
|        | training      |          | Year  |           |            |
|        |               |          | Two   |           |            |
+--------+---------------+----------+-------+-----------+------------+
| \$1    | \$1 for \$2   | August   | Adv   | Congress  | Relevant   |
| for    | benefit       | 2002     | isory |           |            |
| \$2    | offset:       |          | Panel |           |            |
| Demo   | Congress      |          | A     |           |            |
|        | should amend  |          | nnual |           |            |
|        | statute to    |          | Re    |           |            |
|        | allow         |          | port: |           |            |
|        | deferred      |          | Year  |           |            |
|        | research on   |          | Two   |           |            |
|        | induced entry |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| B      | Reiterate the | May 2003 | A     | Congress  | No longer  |
| enefit | 2001          |          | nnual |           | relevant   |
| pa     | re            |          | Re    |           |            |
| yments | commendations |          | port: |           |            |
|        | to authorize  |          | Year  |           |            |
|        | benefits      |          | Three |           |            |
|        | payments for  |          |       |           |            |
|        | reductions in |          |       |           |            |
|        | benefits      |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| P      | Conduct       | May 2003 | A     | Congress  | Relevant   |
| rogram | review and    |          | nnual |           |            |
| integ  | comparison of |          | Re    |           |            |
| ration | the Ticket to |          | port: |           |            |
|        | Work and Work |          | Year  |           |            |
|        | Incentives    |          | Three |           |            |
|        | Improvement   |          |       |           |            |
|        | Act and the   |          |       |           |            |
|        | Social        |          |       |           |            |
|        | Security Act  |          |       |           |            |
|        | and the       |          |       |           |            |
|        | R             |          |       |           |            |
|        | ehabilitation |          |       |           |            |
|        | Act during    |          |       |           |            |
|        | upcoming      |          |       |           |            |
|        | re            |          |       |           |            |
|        | authorization |          |       |           |            |
|        | of the        |          |       |           |            |
|        | R             |          |       |           |            |
|        | ehabilitation |          |       |           |            |
|        | Act and take  |          |       |           |            |
|        | action on     |          |       |           |            |
|        | in            |          |       |           |            |
|        | consistencies |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Tr     | Congress      | May 2003 | A     | Congress  | Relevant   |
| aining | should        |          | nnual |           |            |
| &      | provide       |          | Re    |           |            |
| Tec    | financial     |          | port: |           |            |
| hnical | resources for |          | Year  |           |            |
| Assi   | a dedicated   |          | Three |           |            |
| stance | corps of work |          |       |           |            |
|        | incentive     |          |       |           |            |
|        | specialists   |          |       |           |            |
|        | (such as      |          |       |           |            |
|        | ESRs)         |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| P      | Congress      | May 2003 | A     | Congress  | Relevant   |
| rogram | should direct |          | nnual |           |            |
| integ  | SSA to work   |          | Re    |           |            |
| ration | closely with  |          | port: |           |            |
| and    | other Federal |          | Year  |           |            |
| tr     | and State     |          | Three |           |            |
| aining | systems to    |          |       |           |            |
| &      | develop a     |          |       |           |            |
|        | national      |          |       |           |            |
| Tec    | training plan |          |       |           |            |
| hnical | and with      |          |       |           |            |
| Assi   | Congress to   |          |       |           |            |
| stance | earmark       |          |       |           |            |
|        | funding       |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| EN     | Congress      | Feb.     | A     | Congress  | No longer  |
|        | should        | 2004     | dvice |           | relevant   |
|        | develop       |          | R     |           |            |
|        | statutory     |          | eport |           |            |
|        | language that |          | on    |           |            |
|        | articulates   |          | E     |           |            |
|        | its original  |          | mploy |           |            |
|        | intent that   |          | -ment |           |            |
|        | the Ticket is |          | Net   |           |            |
|        | a             |          | works |           |            |
|        | supplemental  |          |       |           |            |
|        | funding       |          |       |           |            |
|        | source        |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| EN     | Congress      | Feb.     | A     | Congress  | No longer  |
|        | should direct | 2004     | dvice |           | relevant   |
|        | Commissioner  |          | R     |           |            |
|        | to implement  |          | eport |           |            |
|        | Ticket to     |          | on    |           |            |
|        | Work program  |          | E     |           |            |
|        | as a          |          | mploy |           |            |
|        | complement to |          | -ment |           |            |
|        | SSA VR        |          | Net   |           |            |
|        | Reimbursement |          | works |           |            |
|        | Program       |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| EN     | Amend statute | Feb.     | A     | Congress  | No longer  |
|        | to permit     | 2004     | dvice |           | relevant   |
|        | Ticket to     |          | R     |           |            |
|        | Work program  |          | eport |           |            |
|        | to increase   |          | on    |           |            |
|        | sum of        |          | E     |           |            |
|        | payments for  |          | mploy |           |            |
|        | serving SSI   |          | -ment |           |            |
|        | recipients to |          | Net   |           |            |
|        | level equal   |          | works |           |            |
|        | to sum of     |          |       |           |            |
|        | payments for  |          |       |           |            |
|        | serving SSDI  |          |       |           |            |
|        | beneficiaries |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| EN     | Commissioner  | Feb.     | A     | Com       | Relevant   |
|        | and Congress  | 2004     | dvice | missioner |            |
|        | make clear    |          | R     | and\      |            |
|        | that payments |          | eport | Congress  |            |
|        | to ENs should |          | on    |           |            |
|        | supplement    |          | E     |           |            |
|        | funding from  |          | mploy |           |            |
|        | other public  |          | -ment |           |            |
|        | programs,     |          | Net   |           |            |
|        | consistent    |          | works |           |            |
|        | with AOI      |          |       |           |            |
|        | group         |          |       |           |            |
|        | re            |          |       |           |            |
|        | commendations |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| EN     | Congress      | Feb.     | A     | Congress  | Relevant   |
|        | should amend  | 2004     | dvice |           |            |
|        | statute to    |          | R     |           |            |
|        | permit        |          | eport |           |            |
|        | American      |          | on    |           |            |
|        | Indian VR     |          | E     |           |            |
|        | programs to   |          | mploy |           |            |
|        | be ENs        |          | -ment |           |            |
|        | without       |          | Net   |           |            |
|        | application   |          | works |           |            |
|        | and be        |          |       |           |            |
|        | eligible for  |          |       |           |            |
|        | SSA           |          |       |           |            |
|        | reimbursement |          |       |           |            |
|        | program       |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| BPAO   | Increase the  | Feb.     | A     | Associate | Relevant   |
|        | amount of     | 2005     | nnual | Com       |            |
|        | resources     |          | Re    | missioner | In RFA,    |
|        | allocated to  |          | port: |           | SSA        |
|        | the national  |          | Yr.   |           | a          |
|        | network.      |          | 6,    |           | nticipated |
|        |               |          | Adv   |           | min.       |
|        |               |          | isory |           | awards of  |
|        |               |          | L     |           | \$100,000  |
|        |               |          | etter |           | for        |
|        |               |          |       |           | individ.   |
|        |               |          |       |           | state WIPA |
|        |               |          |       |           | projects   |
|        |               |          |       |           | (Min.      |
|        |               |          |       |           | awards for |
|        |               |          |       |           | t          |
|        |               |          |       |           | erritories |
|        |               |          |       |           | remain at  |
|        |               |          |       |           | \$50,000)  |
|        |               |          |       |           | and a max. |
|        |               |          |       |           | of         |
|        |               |          |       |           | \$300,000  |
|        |               |          |       |           | available  |
|        |               |          |       |           | to fund    |
|        |               |          |       |           | specific   |
|        |               |          |       |           | WIPA       |
|        |               |          |       |           | projects   |
|        |               |          |       |           | annually.  |
+--------+---------------+----------+-------+-----------+------------+
| BPAO   | Remove the    | Feb.     | A     | Associate | Relevant   |
|        | individual    | 2005     | nnual | Com       |            |
|        | awards cap    |          | Re    | missioner |            |
|        | for projects  |          | port: |           |            |
|        | to ensure     |          | Yr.   |           |            |
|        | that programs |          | 6,    |           |            |
|        | based in      |          | Adv   |           |            |
|        | rural         |          | isory |           |            |
|        | settings have |          | L     |           |            |
|        | the resources |          | etter |           |            |
|        | they need to  |          |       |           |            |
|        | provide       |          |       |           |            |
|        | equitable     |          |       |           |            |
|        | services to   |          |       |           |            |
|        | their urban   |          |       |           |            |
|        | and           |          |       |           |            |
|        | metropolitan  |          |       |           |            |
|        | counterparts  |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| R      | Renewal of    | Dec.     | A     | Co        | Relevant   |
| enewal | SSA's         | 2005     | nnual | ngressman |            |
| of     | demonstration |          | Re    | McCrery   |            |
| SSA's  | authority to  |          | port: | and       |            |
| Demo   | begin new     |          | Yr.   | Senator   |            |
|        | demonstration |          | 6,    | Grassley  |            |
| Aut    | projects      |          | Adv   |           |            |
| hority |               |          | isory |           |            |
|        |               |          | L     |           |            |
|        |               |          | etter |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Re     |               |          |       |           |            |
| quires |               |          |       |           |            |
| Promul |               |          |       |           |            |
| gation |               |          |       |           |            |
| of     |               |          |       |           |            |
| Regula |               |          |       |           |            |
| tions, |               |          |       |           |            |
| an     |               |          |       |           |            |
| Ad     |               |          |       |           |            |
| minist |               |          |       |           |            |
| rative |               |          |       |           |            |
| C      |               |          |       |           |            |
| hange, |               |          |       |           |            |
| or     |               |          |       |           |            |
| P      |               |          |       |           |            |
| rogram |               |          |       |           |            |
| Coordi |               |          |       |           |            |
| nation |               |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| D      | All decisions | July 23, | Final | Com       | Relevant   |
| ispute | made by SSA   | 2001     | A     | missioner |            |
| reso   | in reference  |          | dvice |           |            |
| lution | to disputes   |          | R     |           |            |
|        | should be     |          | eport |           |            |
|        | subject to    |          | on    |           |            |
|        | external      |          | T     |           |            |
|        | review        |          | icket |           |            |
|        |               |          | to    |           |            |
|        |               |          | Work  |           |            |
|        |               |          | pr    |           |            |
|        |               |          | ogram |           |            |
|        |               |          | N     |           |            |
|        |               |          | otice |           |            |
|        |               |          | of    |           |            |
|        |               |          | Pro   |           |            |
|        |               |          | posed |           |            |
|        |               |          | Rule  |           |            |
|        |               |          | M     |           |            |
|        |               |          | aking |           |            |
+--------+---------------+----------+-------+-----------+------------+
| D      | Information   | July 23, | Final | Com       | Relevant,  |
| ispute | on P&A        | 2001     | A     | missioner | I          |
| reso   | services      |          | dvice |           | nformation |
| lution | should be     |          | R     |           | currently  |
|        | accessible to |          | eport |           | available  |
|        | beneficiaries |          | on    |           | via        |
|        |               |          | T     |           | letter,    |
|        |               |          | icket |           | IWP        |
|        |               |          | to    |           |            |
|        |               |          | Work  |           |            |
|        |               |          | pr    |           |            |
|        |               |          | ogram |           |            |
|        |               |          | N     |           |            |
|        |               |          | otice |           |            |
|        |               |          | of    |           |            |
|        |               |          | Pro   |           |            |
|        |               |          | posed |           |            |
|        |               |          | Rule  |           |            |
|        |               |          | M     |           |            |
|        |               |          | aking |           |            |
+--------+---------------+----------+-------+-----------+------------+
| D      | B             | July 23, | Final | Com       | Relevant   |
| ispute | eneficiary\'s | 2001     | A     | missioner |            |
| reso   | filing        |          | dvice |           | None       |
| lution | complaints    |          | R     |           |            |
|        | with project  |          | eport |           |            |
|        | manager       |          | on    |           |            |
|        | against EN    |          | T     |           |            |
|        | should        |          | icket |           |            |
|        | trigger a     |          | to    |           |            |
|        | notice to P&A |          | Work  |           |            |
|        |               |          | pr    |           |            |
|        |               |          | ogram |           |            |
|        |               |          | N     |           |            |
|        |               |          | otice |           |            |
|        |               |          | of    |           |            |
|        |               |          | Pro   |           |            |
|        |               |          | posed |           |            |
|        |               |          | Rule  |           |            |
|        |               |          | M     |           |            |
|        |               |          | aking |           |            |
+--------+---------------+----------+-------+-----------+------------+
| D      | All notices   | July 23, | Final | Com       | Relevant   |
| ispute | should be in  | 2001     | A     | missioner |            |
| reso   | an accessible |          | dvice |           |            |
| lution | format        |          | R     |           |            |
|        |               |          | eport |           |            |
|        |               |          | on    |           |            |
|        |               |          | T     |           |            |
|        |               |          | icket |           |            |
|        |               |          | to    |           |            |
|        |               |          | Work  |           |            |
|        |               |          | pr    |           |            |
|        |               |          | ogram |           |            |
|        |               |          | N     |           |            |
|        |               |          | otice |           |            |
|        |               |          | of    |           |            |
|        |               |          | Pro   |           |            |
|        |               |          | posed |           |            |
|        |               |          | Rule  |           |            |
|        |               |          | M     |           |            |
|        |               |          | aking |           |            |
+--------+---------------+----------+-------+-----------+------------+
| D      | SSA should    | July 23, | Final | Com       | Relevant   |
| ispute | establish     | 2001     | A     | missioner |            |
| reso   | specified     |          | dvice |           |            |
| lution | timeline for  |          | R     |           |            |
|        | dispute       |          | eport |           |            |
|        | resolution    |          | on    |           |            |
|        | outlined      |          | T     |           |            |
|        |               |          | icket |           |            |
|        |               |          | to    |           |            |
|        |               |          | Work  |           |            |
|        |               |          | pr    |           |            |
|        |               |          | ogram |           |            |
|        |               |          | N     |           |            |
|        |               |          | otice |           |            |
|        |               |          | of    |           |            |
|        |               |          | Pro   |           |            |
|        |               |          | posed |           |            |
|        |               |          | Rule  |           |            |
|        |               |          | M     |           |            |
|        |               |          | aking |           |            |
+--------+---------------+----------+-------+-----------+------------+
| D      | During        | July 23, | Final | Com       | Relevant   |
| ispute | appeals       | 2001     | A     | missioner |            |
| reso   | process,      |          | dvice |           |            |
| lution | beneficiaries |          | R     |           |            |
|        | should        |          | eport |           |            |
|        | receive the   |          | on    |           |            |
|        | same level of |          | T     |           |            |
|        | support and   |          | icket |           |            |
|        | service       |          | to    |           |            |
|        |               |          | Work  |           |            |
|        |               |          | pr    |           |            |
|        |               |          | ogram |           |            |
|        |               |          | N     |           |            |
|        |               |          | otice |           |            |
|        |               |          | of    |           |            |
|        |               |          | Pro   |           |            |
|        |               |          | posed |           |            |
|        |               |          | Rule  |           |            |
|        |               |          | M     |           |            |
|        |               |          | aking |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Be     | SSA should    | July 23, | Final | Com       | Relevant   |
| nefits | interpret     | 2001     | A     | missioner |            |
|        | benefits not  |          | dvice |           |            |
|        | payable as a  |          | R     |           |            |
|        | reduction in  |          | eport |           |            |
|        | benefits      |          | on    |           |            |
|        |               |          | T     |           |            |
|        |               |          | icket |           |            |
|        |               |          | to    |           |            |
|        |               |          | Work  |           |            |
|        |               |          | pr    |           |            |
|        |               |          | ogram |           |            |
|        |               |          | N     |           |            |
|        |               |          | otice |           |            |
|        |               |          | of    |           |            |
|        |               |          | Pro   |           |            |
|        |               |          | posed |           |            |
|        |               |          | Rule  |           |            |
|        |               |          | M     |           |            |
|        |               |          | aking |           |            |
+--------+---------------+----------+-------+-----------+------------+
| EN     | SSA should    | July 23, | Final | Com       | No longer  |
| P      | address       | 2001     | A     | missioner | relevant.  |
| ayment | efficacy of   |          | dvice |           |            |
|        | i             |          | R     |           |            |
|        | ndividualized |          | eport |           |            |
|        | milestones in |          | on    |           |            |
|        | AOI report    |          | T     |           |            |
|        |               |          | icket |           |            |
|        |               |          | to    |           |            |
|        |               |          | Work  |           |            |
|        |               |          | pr    |           |            |
|        |               |          | ogram |           |            |
|        |               |          | N     |           |            |
|        |               |          | otice |           |            |
|        |               |          | of    |           |            |
|        |               |          | Pro   |           |            |
|        |               |          | posed |           |            |
|        |               |          | Rule  |           |            |
|        |               |          | M     |           |            |
|        |               |          | aking |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Ticket | SSA should    | July 23, | Final | Com       | No longer  |
| to     | commission a  | 2001     | A     | missioner | relevant   |
| Work   | full-cost     |          | dvice |           |            |
| p      | benefit study |          | R     |           |            |
| rogram | to evaluate   |          | eport |           |            |
| eval   | program       |          | on    |           |            |
| uation |               |          | T     |           |            |
|        |               |          | icket |           |            |
|        |               |          | to    |           |            |
|        |               |          | Work  |           |            |
|        |               |          | pr    |           |            |
|        |               |          | ogram |           |            |
|        |               |          | N     |           |            |
|        |               |          | otice |           |            |
|        |               |          | of    |           |            |
|        |               |          | Pro   |           |            |
|        |               |          | posed |           |            |
|        |               |          | Rule  |           |            |
|        |               |          | M     |           |            |
|        |               |          | aking |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Alt    | SSA should    | July 23, | Final | Com       | No longer  |
| ernate | permit other  | 2001     | A     | missioner | relevant   |
| plans  | service       |          | dvice |           |            |
|        | delivery      |          | R     |           |            |
|        | plans to be   |          | eport |           |            |
|        | used as a     |          | on    |           |            |
|        | substitute    |          | T     |           |            |
|        | for IWP       |          | icket |           |            |
|        |               |          | to    |           |            |
|        |               |          | Work  |           |            |
|        |               |          | pr    |           |            |
|        |               |          | ogram |           |            |
|        |               |          | N     |           |            |
|        |               |          | otice |           |            |
|        |               |          | of    |           |            |
|        |               |          | Pro   |           |            |
|        |               |          | posed |           |            |
|        |               |          | Rule  |           |            |
|        |               |          | M     |           |            |
|        |               |          | aking |           |            |
+--------+---------------+----------+-------+-----------+------------+
| AOI    | Establish     | June 18, | A     | Com       | Relevant   |
|        | ongoing       | 2002     | dvice | missioner |            |
|        | structure for |          | R     |           |            |
|        | review of     |          | eport |           |            |
|        | emerging      |          | on    |           |            |
|        | information   |          | the   |           |            |
|        | for AOI       |          | Ade   |           |            |
|        |               |          | quacy |           |            |
|        |               |          | of    |           |            |
|        |               |          | Incen |           |            |
|        |               |          | tives |           |            |
|        |               |          | (AOI) |           |            |
|        |               |          | Study |           |            |
+--------+---------------+----------+-------+-----------+------------+
| SSA    | SSA to        | June 18, | A     | Com       | No longer  |
| rep    | provide       | 2002     | dvice | missioner | relevant   |
| orting | Panel,        |          | R     |           |            |
|        | Congress, and |          | eport |           |            |
|        | President     |          | on    |           |            |
|        | with ongoing  |          | the   |           |            |
|        | interim       |          | Ade   |           |            |
|        | reporting     |          | quacy |           |            |
|        |               |          | of    |           |            |
|        |               |          | Incen |           |            |
|        |               |          | tives |           |            |
|        |               |          | (AOI) |           |            |
|        |               |          | Study |           |            |
+--------+---------------+----------+-------+-----------+------------+
| AOI    | Identifying   | June 18, | A     | Com       | Relevant   |
|        | the four      | 2002     | dvice | missioner |            |
|        | groups: SSA   |          | R     |           |            |
|        | should use    |          | eport |           |            |
|        | other data    |          | on    |           |            |
|        | sources       |          | the   |           |            |
|        |               |          | Ade   |           |            |
|        |               |          | quacy |           |            |
|        |               |          | of    |           |            |
|        |               |          | Incen |           |            |
|        |               |          | tives |           |            |
|        |               |          | (AOI) |           |            |
|        |               |          | Study |           |            |
+--------+---------------+----------+-------+-----------+------------+
| AOI -  | SSA should    | June 18, | A     | Com       | Relevant   |
| EN and | identify data | 2002     | dvice | missioner |            |
| data   | elements ENs  |          | R     |           |            |
|        | should        |          | eport |           |            |
|        | collect for   |          | on    |           |            |
|        | AOI           |          | the   |           |            |
|        |               |          | Ade   |           |            |
|        |               |          | quacy |           |            |
|        |               |          | of    |           |            |
|        |               |          | Incen |           |            |
|        |               |          | tives |           |            |
|        |               |          | (AOI) |           |            |
|        |               |          | Study |           |            |
+--------+---------------+----------+-------+-----------+------------+
| \$1    | Deferring the | August   | A     | Com       | No longer  |
| for    | induced entry | 2002     | dvice | missioner | relevant   |
| \$2    | evaluation in |          | R     |           |            |
| Demo   | \$1 for \$2   |          | eport |           |            |
|        | demonstration |          | on    |           |            |
|        |               |          | \$1   |           |            |
|        |               |          | for   |           |            |
|        |               |          | \$2   |           |            |
|        |               |          | Be    |           |            |
|        |               |          | nefit |           |            |
|        |               |          | O     |           |            |
|        |               |          | ffset |           |            |
|        |               |          | Res   |           |            |
|        |               |          | earch |           |            |
+--------+---------------+----------+-------+-----------+------------+
| \$1    | Induced entry | August   | A     | Com       | No longer  |
| for    | evaluation    | 2002     | dvice | missioner | relevant   |
| \$2    | proposal      |          | R     |           |            |
| Demo   | should        |          | eport |           |            |
|        | include at    |          | on    |           |            |
|        | least five    |          | \$1   |           |            |
|        | independent   |          | for   |           |            |
|        | designs from  |          | \$2   |           |            |
|        | outside       |          | Be    |           |            |
|        | experts       |          | nefit |           |            |
|        |               |          | O     |           |            |
|        |               |          | ffset |           |            |
|        |               |          | Res   |           |            |
|        |               |          | earch |           |            |
+--------+---------------+----------+-------+-----------+------------+
| \$1    | Induced entry | August   | A     | Com       | No longer  |
| for    | should follow | 2002     | dvice | missioner | relevant   |
| \$2    | and report on |          | R     |           |            |
| Demo   | parallel      |          | eport |           |            |
|        | research      |          | on    |           |            |
|        | projects      |          | \$1   |           |            |
|        | across the    |          | for   |           |            |
|        | country that  |          | \$2   |           |            |
|        | analyze       |          | Be    |           |            |
|        | determinants  |          | nefit |           |            |
|        | of return to  |          | O     |           |            |
|        | work          |          | ffset |           |            |
|        |               |          | Res   |           |            |
|        |               |          | earch |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Access | Tr            | August   | Adv   | Com       | Relevant   |
| to     | ansition-aged | 2002     | isory | missioner |            |
| ti     | youth should  |          | Panel |           |            |
| cket - | be eligible   |          | A     |           |            |
| youth  | for tickets   |          | nnual |           |            |
|        |               |          | Re    |           |            |
|        |               |          | port: |           |            |
|        |               |          | Year  |           |            |
|        |               |          | Two   |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Wage   | Process       | August   | Adv   | Com       | Relevant   |
| rep    | monthly       | 2002     | isory | missioner |            |
| orting | earning       |          | Panel |           |            |
|        | reports       |          | A     |           |            |
|        | without       |          | nnual |           |            |
|        | generating    |          | Re    |           |            |
|        | overpayments  |          | port: |           |            |
|        |               |          | Year  |           |            |
|        |               |          | Two   |           |            |
+--------+---------------+----------+-------+-----------+------------+
| AOI    | Adequacy of   | August   | Adv   | Congress  | No longer  |
|        | incentives:   | 2002     | isory |           | relevant   |
|        | delay report  |          | Panel |           |            |
|        | to Congress   |          | A     |           |            |
|        | and get       |          | nnual |           |            |
|        | interim       |          | Re    |           |            |
|        | reports from  |          | port: |           |            |
|        | SSA           |          | Year  |           |            |
|        |               |          | Two   |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Mar    | Urge SSA to   | May 2003 | A     | Congress  | Relevant   |
| keting | develop       |          | nnual |           | (see       |
| and    | immediate     |          | Re    |           | action on  |
| public | national      |          | port: |           | marketing  |
| edu    | marketing and |          | Year  |           | in Annual  |
| cation | public        |          | Three |           | Report:    |
|        | education     |          |       |           | Year Two)  |
|        | campaign to   |          |       |           |            |
|        | explain       |          |       |           |            |
|        | available     |          |       |           |            |
|        | programs      |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| VR     | SSA and RSA   | Oct. 21, | Adv   | Assistant | Relevant   |
|        | should        | 2003     | isory | Secretary |            |
|        | formulate     |          | L     | Robert    |            |
|        | joint policy  |          | etter | P         |            |
|        | governing the |          |       | asternack |            |
|        | contents of   |          |       |           |            |
|        | VR-EN         |          |       |           |            |
|        | agreements    |          |       |           |            |
|        | and           |          |       |           |            |
|        | disseminate a |          |       |           |            |
|        | model         |          |       |           |            |
|        | agreement     |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| EN     | Commissioner  | Feb.     | A     | Com       | Relevant   |
|        | should        | 2004     | dvice | missioner |            |
|        | conduct an    |          | R     |           |            |
|        | assessment of |          | eport |           |            |
|        | the Ticket to |          | on    |           |            |
|        | Work program  |          | E     |           |            |
|        | and State VR  |          | mploy |           |            |
|        | Program       |          | -ment |           |            |
|        | running in    |          | Net   |           |            |
|        | combination   |          | works |           |            |
+--------+---------------+----------+-------+-----------+------------+
| EN     | Test two or   | Feb.     | A     | Com       | Relevant   |
|        | three         | 2004     | dvice | missioner |            |
|        | creative      |          | R     |           |            |
|        | approaches    |          | eport |           |            |
|        | that increase |          | on    |           |            |
|        | EN and        |          | E     |           |            |
|        | beneficiary   |          | mploy |           |            |
|        | participation |          | -ment |           |            |
|        |               |          | Net   |           |            |
|        |               |          | works |           |            |
+--------+---------------+----------+-------+-----------+------------+
| EN     | Panel and     | Feb.     | A     | Com       | No longer  |
|        | Commissioner  | 2004     | dvice | missioner | relevant   |
|        | should        |          | R     |           |            |
|        | convene       |          | eport |           |            |
|        | meeting with  |          | on    |           |            |
|        | stakeholders  |          | E     |           |            |
|        | to develop    |          | mploy |           |            |
|        | national      |          | -ment |           |            |
|        | training and  |          | Net   |           |            |
|        | communication |          | works |           |            |
|        | conference    |          |       |           |            |
|        | for all ENs   |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Mark   | SSA           | May 2004 | A     | Com       | Relevant   |
| eting, | immediately   |          | nnual | missioner |            |
| Public | launch a      |          | Re    |           |            |
| Educ   | national      |          | port: |           |            |
| ation, | campaign for  |          | Yr.   |           |            |
| Tr     | public        |          | 5,    |           |            |
| aining | education and |          | Adv   |           |            |
|        | training on   |          | isory |           |            |
|        | the Ticket to |          | L     |           |            |
|        | Work program, |          | etter |           |            |
|        | SSDI and SSI  |          |       |           |            |
|        | work          |          |       |           |            |
|        | incentives    |          |       |           |            |
|        | and related   |          |       |           |            |
|        | employment    |          |       |           |            |
|        | support       |          |       |           |            |
|        | programs and  |          |       |           |            |
|        | services      |          |       |           |            |
|        | especially    |          |       |           |            |
|        | for SSA field |          |       |           |            |
|        | staff.        |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| BPAO   | Require       | Feb.     | A     | Associate | Relevant   |
|        | response      | 2005     | nnual | Com       |            |
|        |               |          | Re    | missioner |            |
|        | /a            |          | port: |           |            |
|        | cknowledgment |          | Yr.   |           |            |
|        | to the        |          | 6,    |           |            |
|        | beneficiary   |          | Adv   |           |            |
|        | within a      |          | isory |           |            |
|        | specified     |          | L     |           |            |
|        | period of     |          | etter |           |            |
|        | time say 24   |          |       |           |            |
|        | hours         |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| BPAO   | Provide a     | Feb.     | A     | Associate | Relevant   |
|        | point of      | 2005     | nnual | Com       |            |
|        | contact so    |          | Re    | missioner |            |
|        | that          |          | port: |           |            |
|        | individuals   |          | Yr.   |           |            |
|        | having        |          | 6,    |           |            |
|        | difficulty    |          | Adv   |           |            |
|        | receiving     |          | isory |           |            |
|        | services from |          | L     |           |            |
|        | BPAO can let  |          | etter |           |            |
|        | SSA know      |          |       |           |            |
|        | about the     |          |       |           |            |
|        | specific      |          |       |           |            |
|        | reason for    |          |       |           |            |
|        | example, no   |          |       |           |            |
|        | response at   |          |       |           |            |
|        | all or long   |          |       |           |            |
|        | wait for an   |          |       |           |            |
|        | appointment   |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| BPAO   | Continue to   | Feb.     | A     | Associate | Relevant   |
|        | use a         | 2005     | nnual |           |            |
|        | national core |          | Re    | Com       |            |
|        | com           |          | port: | missioner |            |
|        | petency-based |          | Yr.   |           |            |
|        | curriculum    |          | 6,    |           |            |
|        | that          |          | Adv   |           |            |
|        | establishes   |          | isory |           |            |
|        | minimum       |          | L     |           |            |
|        | standards for |          | etter |           |            |
|        | effective     |          |       |           |            |
|        | service       |          |       |           |            |
|        | delivery and  |          |       |           |            |
|        | ethical       |          |       |           |            |
|        | c             |          |       |           |            |
|        | onsiderations |          |       |           |            |
|        | when          |          |       |           |            |
|        | preparing     |          |       |           |            |
|        | benefits      |          |       |           |            |
|        | specialists   |          |       |           |            |
|        | for the field |          |       |           |            |
|        | and that they |          |       |           |            |
|        | have access   |          |       |           |            |
|        | to ongoing    |          |       |           |            |
|        | technical     |          |       |           |            |
|        | support       |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| BPAO   | Provide an    | Feb.     | A     | Associate | Relevant   |
|        | incentive to  | 2005     | nnual | Com       |            |
|        | BPAO programs |          | Re    | missioner |            |
|        | and ENs for   |          | port: |           |            |
|        | working       |          | Yr.   |           |            |
|        | together to   |          | 6,    |           |            |
|        | promote       |          | Adv   |           |            |
|        | employment    |          | isory |           |            |
|        | success       |          | L     |           |            |
|        |               |          | etter |           |            |
+--------+---------------+----------+-------+-----------+------------+
| PASS   | Provide       | S        | A     | Com       | Relevant   |
| \--    | specific      | eptember | nnual | missioner |            |
|        | examples as   | 2005     | Re    |           |            |
| Reas   | well as       |          | port: |           |            |
| onable | further       |          | Yr.   |           |            |
| length | delineating   |          | 6,    |           |            |
| of     | that          |          | Adv   |           |            |
| time   | "reasonable   |          | isory |           |            |
| to     | period" for   |          | L     |           |            |
| a      | completion of |          | etter |           |            |
| chieve | a PASS will   |          | [R    |           |            |
|        | depend in     |          | e.]{. |           |            |
| goal   | large part on |          | under |           |            |
|        | the impact of |          | line} |           |            |
|        | the           |          | NPRM  |           |            |
|        | individual's  |          | July  |           |            |
|        | impairment on |          | 11,   |           |            |
|        | their stated  |          | 2005  |           |            |
|        | goal(s)       |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| PASS   | SSA refine    | S        | A     | Com       | Relevant   |
|        | its policies  | eptember | nnual | missioner |            |
| Ref    | to clarify    | 2005     | Re    |           |            |
| errals | when it will  |          | port: |           |            |
|        | refer, to     |          | Yr.   |           |            |
|        | what type of  |          | 6,    |           |            |
|        | organization  |          | Adv   |           |            |
|        | s/individuals |          | isory |           |            |
|        | to which it   |          | L     |           |            |
|        | will refer,   |          | etter |           |            |
|        | and what      |          | [R    |           |            |
|        | level of      |          | e.]{. |           |            |
|        | support       |          | under |           |            |
|        | applicants    |          | line} |           |            |
|        | can expect    |          | NPRM  |           |            |
|        | SSA/PASS      |          | July  |           |            |
|        | Cadre, BPAOs, |          | 11,   |           |            |
|        | Independent   |          | 2005  |           |            |
|        | Living        |          |       |           |            |
|        | Centers, ENs  |          |       |           |            |
|        | and so forth  |          |       |           |            |
|        | to provide    |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| PASS   | SSA expand on | S        | A     | Com       | Relevant   |
|        | what is       | eptember | nnual | missioner |            |
| Plan   | intended      | 2005     | Re    |           |            |
| ending | under the     |          | port: |           |            |
| date   | NPRM and      |          | Yr.   |           |            |
|        | specifically  |          | 6,    |           |            |
|        | address the   |          | Ad    |           |            |
|        | issue of SSA  |          | visoy |           |            |
|        | providing     |          | L     |           |            |
|        | what seems to |          | etter |           |            |
|        | be special    |          | [R    |           |            |
|        | assistance    |          | e.]{. |           |            |
|        | that is       |          | under |           |            |
|        | limited to    |          | line} |           |            |
|        | establishing  |          | NPRM  |           |            |
|        | an ending     |          | July  |           |            |
|        | date          |          | 11,   |           |            |
|        |               |          | 2005  |           |            |
+--------+---------------+----------+-------+-----------+------------+
| PASS   | Panel         | S        | A     | Com       | No longer  |
|        | supported     | eptember | nnual | missioner | relevant;  |
| O      | continuation  | 2005     | Re    |           | SSA added  |
| ccupat | of            |          | port: |           | language   |
| ion-al | credentialing |          | Yr.   |           | defining   |
|        | policy.       |          | 6,    |           | feasible   |
| Goals  | However,      |          | Adv   |           | employ.    |
|        | recommended   |          | isory |           | goal as    |
|        | SSA clarify   |          | L     |           | "is one    |
|        | what weight,  |          | etter |           | that you   |
|        | if any, will  |          | [R    |           | have a     |
|        | be given to   |          | e.]{. |           | reasonable |
|        | occupational  |          | under |           | likelihood |
|        | goals         |          | line} |           | of         |
|        | developed     |          | NPRM  |           | a          |
|        | with          |          | July  |           | chieving." |
|        | assistance of |          | 11,   |           | And it     |
|        | BPAOs and     |          | 2005  |           | created 2  |
|        | others, for   |          |       |           | new sect.  |
|        | example,      |          |       |           | to explain |
|        | Small         |          |       |           | "a viable  |
|        | Business      |          |       |           | plan"      |
+--------+---------------+----------+-------+-----------+------------+
| PASS   | SSA expand on | S        | A     | Com       | Relevant   |
|        | what the      | eptember | nnual | missioner |            |
| Annual | annual review | 2005     | Re    |           |            |
| review | entails and   |          | port: |           |            |
| of     | how it is     |          | Yr.   |           |            |
| plan   | conducted.    |          | 6,    |           |            |
|        | Further, SSA  |          | Adv   |           |            |
|        | consider      |          | isory |           |            |
|        | providing     |          | L     |           |            |
|        | more details  |          | etter |           |            |
|        | and an        |          | [R    |           |            |
|        | example of    |          | e.]{. |           |            |
|        | what the      |          | under |           |            |
|        | beneficiary   |          | line} |           |            |
|        | can expect.   |          | NPRM  |           |            |
|        | Finally, that |          | July  |           |            |
|        | PASS          |          | 11,   |           |            |
|        | specialists   |          | 2005  |           |            |
|        | customize     |          |       |           |            |
|        | timelines for |          |       |           |            |
|        | progress      |          |       |           |            |
|        | reviews based |          |       |           |            |
|        | on the        |          |       |           |            |
|        | specific      |          |       |           |            |
|        | support needs |          |       |           |            |
|        | of the        |          |       |           |            |
|        | beneficiary   |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| PASS - | SSA 1)        | S        | A     | Com       | Relevant   |
| G      | provide       | eptember | nnual | missioner |            |
| eneral | additional    | 2005     | Re    |           |            |
|        | training for  |          | port: |           |            |
|        | the PASS      |          | Yr.   |           |            |
|        | Cadre; 2)     |          | 6,    |           |            |
|        | review the    |          | Adv   |           |            |
|        | i             |          | isory |           |            |
|        | mplementation |          | L     |           |            |
|        | policies in   |          | etter |           |            |
|        | selected      |          | [R    |           |            |
|        | States to     |          | e.]{. |           |            |
|        | assess ways   |          | under |           |            |
|        | to increase   |          | line} |           |            |
|        | PASS          |          | NPRM  |           |            |
|        | p             |          | July  |           |            |
|        | articipation; |          | 11,   |           |            |
|        | and 3)explore |          | 2005  |           |            |
|        | strategies to |          |       |           |            |
|        | maximize      |          |       |           |            |
|        | utilization   |          |       |           |            |
|        | of PASS and   |          |       |           |            |
|        | other work    |          |       |           |            |
|        | incentives    |          |       |           |            |
|        | and consider  |          |       |           |            |
|        | how the       |          |       |           |            |
|        | Ticket to     |          |       |           |            |
|        | Work and PASS |          |       |           |            |
|        | Programs can  |          |       |           |            |
|        | better        |          |       |           |            |
|        | complement    |          |       |           |            |
|        | each other    |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Admin. | SSA           | October  | A     | Com       | Relevant   |
| Review | communicate a | 2005     | nnual | missioner |            |
| P      | return to     |          | Re    |           |            |
| rocess | work          |          | port: |           |            |
| --     | philosophy in |          | Yr.   |           |            |
| Disa   | all stages of |          | 6,    |           |            |
| bility | the           |          | Adv   |           |            |
| Claims | disability    |          | isory |           |            |
|        | determination |          | L     |           |            |
|        | process,      |          | etter |           |            |
|        | especially in |          | [R    |           |            |
|        | the early     |          | e.]{. |           |            |
|        | stages        |          | under |           |            |
|        |               |          | line} |           |            |
|        |               |          | NPRM  |           |            |
|        |               |          | July  |           |            |
|        |               |          | 27,   |           |            |
|        |               |          | 2005  |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Admin. | Disability    | October  | A     | Com       | Relevant   |
| Review | Program       | 2005     | nnual | missioner |            |
| P      | Policy        |          | Re    |           |            |
| rocess | Council: SSA  |          | port: |           |            |
| --     | develop a     |          | Yr.   |           |            |
| Disa   | procedure for |          | 6,    |           |            |
| bility | adding a      |          | Adv   |           |            |
| Claims | member to     |          | isory |           |            |
|        | represent     |          | L     |           |            |
|        | beneficiaries |          | etter |           |            |
|        |               |          | [R    |           |            |
|        |               |          | e.]{. |           |            |
|        |               |          | under |           |            |
|        |               |          | line} |           |            |
|        |               |          | NPRM  |           |            |
|        |               |          | July  |           |            |
|        |               |          | 27,   |           |            |
|        |               |          | 2005  |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Admin. | Federal       | October  | A     | Com       | Relevant   |
| Review | Reviewing     | 2005     | nnual | missioner |            |
| P      | Officials:    |          | Re    |           |            |
| rocess | the final     |          | port: |           |            |
| --     | rule be       |          | Yr.   |           |            |
| Disa   | written       |          | 6,    |           |            |
| bility | broadly       |          | Adv   |           |            |
| Claims | enough to     |          | isory |           |            |
|        | allow SSA to  |          | L     |           |            |
|        | also hire     |          | etter |           |            |
|        | paralegals or |          | [R    |           |            |
|        | other legal   |          | e.]{. |           |            |
|        | professionals |          | under |           |            |
|        | with          |          | line} |           |            |
|        | specified     |          | NPRM  |           |            |
|        | qu            |          | July  |           |            |
|        | alifications. |          | 27,   |           |            |
|        | We propose    |          | 2005  |           |            |
|        | that SSA      |          |       |           |            |
|        | certify that  |          |       |           |            |
|        | these other   |          |       |           |            |
|        | legal         |          |       |           |            |
|        | professionals |          |       |           |            |
|        | are qualified |          |       |           |            |
|        | using a       |          |       |           |            |
|        | process like  |          |       |           |            |
|        | that which is |          |       |           |            |
|        | proposed to   |          |       |           |            |
|        | certify       |          |       |           |            |
|        | members of    |          |       |           |            |
|        | the national  |          |       |           |            |
|        | network of    |          |       |           |            |
|        | experts in    |          |       |           |            |
|        | the Federal   |          |       |           |            |
|        | Expert Unit   |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Admin. | Use of        | October  | A     | Com       | No longer  |
| Review | standardized  | 2005     | nnual | missioner | relevant   |
| P      | decision      |          | Re    |           |            |
| rocess | writing       |          | port: |           |            |
| --     | formats:      |          | Yr.   |           |            |
| Disa   | Beneficiaries |          | 6,    |           |            |
| bility | and advocates |          | L     |           |            |
| Claims | participate   |          | etter |           |            |
|        | in the        |          | [R    |           |            |
|        | drafting of   |          | e.]{. |           |            |
|        | these         |          | under |           |            |
|        | standardized  |          | line} |           |            |
|        | formats and   |          | NPRM  |           |            |
|        | that \"plain  |          | July  |           |            |
|        | language\" be |          | 27,   |           |            |
|        | used          |          | 2005  |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Access | All SSI and   | July 23, | Final | Com       | Relevant,  |
| to     | SSDI adult    | 2001     | A     | missioner | Sept. 2005 |
| ticket | beneficiaries |          | dvice |           | NPRM on    |
|        | including     |          | R     |           | Ticket to  |
|        | those         |          | eport |           | Work       |
|        | designated as |          | on    |           | program    |
|        | medical       |          | T     |           | allows     |
|        | improvement   |          | icket |           | those with |
|        | expected      |          | to    |           | MIE to     |
|        | should be     |          | Work  |           | eligible   |
|        | eligible to   |          | pr    |           |            |
|        | participate   |          | ogram |           |            |
|        | in program    |          | N     |           |            |
|        |               |          | otice |           |            |
|        |               |          | of    |           |            |
|        |               |          | Pro   |           |            |
|        |               |          | posed |           |            |
|        |               |          | Rule  |           |            |
|        |               |          | M     |           |            |
|        |               |          | aking |           |            |
+--------+---------------+----------+-------+-----------+------------+
| EN     | Congress and  | May 2003 | A     | Congress  | Relevant,  |
|        | SSA review EN |          | nnual |           | NPRM Sept. |
|        | payment       |          | Re    |           | 2005       |
|        | system to     |          | port: |           | includes   |
|        | adjust and    |          | Year  |           | this       |
|        | enrich        |          | Three |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Access | Make Ticket   | Dec. 17, | A     | Com       | Relevant,  |
| to     | to Work       | 1999--   | nnual | missioner | Waiting on |
| ticket | program       | December | In    |           | final      |
|        | available for | 16, 2000 | terim |           | r          |
|        | all           |          | Pro   |           | egulations |
|        | beneficiaries |          | gress |           | per NPRM   |
|        |               |          | Re    |           | Sept. 2005 |
|        |               |          | port: |           |            |
|        |               |          | Year  |           |            |
|        |               |          | One   |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Access | All SSI and   | July 23, | Final | Com       | Relevant,  |
| to     | SSDI adult    | 2001     | A     | missioner | Sept. 2005 |
| ticket | beneficiaries |          | dvice |           | NPRM on    |
|        | including     |          | R     |           | Ticket to  |
|        | those         |          | eport |           | Work       |
|        | designated as |          | on    |           | program    |
|        | medical       |          | T     |           | allows     |
|        | improvement   |          | icket |           | those with |
|        | expected      |          | to    |           | MIE to     |
|        | should be     |          | Work  |           | eligible   |
|        | eligible to   |          | pr    |           |            |
|        | participate   |          | ogram |           |            |
|        | in program    |          | N     |           |            |
|        |               |          | otice |           |            |
|        |               |          | of    |           |            |
|        |               |          | Pro   |           |            |
|        |               |          | posed |           |            |
|        |               |          | Rule  |           |            |
|        |               |          | M     |           |            |
|        |               |          | aking |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Access | SSA should    | July 23, | Final | Com       | Relevant,  |
| to     | conduct       | 2001     | A     | missioner | No cost    |
| ticket | cost-benefit  |          | dvice |           | benefit    |
|        | analysis on   |          | R     |           | analysis   |
|        | beneficiary   |          | eport |           | per NPRM   |
|        | receiving     |          | on    |           | Sept. 2005 |
|        | more than 1   |          | T     |           |            |
|        | ticket per    |          | icket |           |            |
|        | period of     |          | to    |           |            |
|        | disability/   |          | Work  |           |            |
|        |               |          | pr    |           |            |
|        | entitlement   |          | ogram |           |            |
|        |               |          | N     |           |            |
|        |               |          | otice |           |            |
|        |               |          | of    |           |            |
|        |               |          | Pro   |           |            |
|        |               |          | posed |           |            |
|        |               |          | Rule  |           |            |
|        |               |          | M     |           |            |
|        |               |          | aking |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Timely | Timely        | July 23, | Final | Com       | Relevant   |
| pr     | progress      | 2001     | A     | missioner |            |
| ogress | should be     |          | dvice |           | NPRM Sept. |
|        | defined by    |          | R     |           | 2005       |
|        | terms and     |          | eport |           | addressed  |
|        | conditions of |          | on    |           | this       |
|        | IWP           |          | T     |           | issue;     |
|        |               |          | icket |           | waiting    |
|        |               |          | to    |           | for final  |
|        |               |          | Work  |           | r          |
|        |               |          | pr    |           | egulations |
|        |               |          | ogram |           |            |
|        |               |          | N     |           |            |
|        |               |          | otice |           |            |
|        |               |          | of    |           |            |
|        |               |          | Pro   |           |            |
|        |               |          | posed |           |            |
|        |               |          | Rule  |           |            |
|        |               |          | M     |           |            |
|        |               |          | aking |           |            |
+--------+---------------+----------+-------+-----------+------------+
| EN     | SSA should    | July 23, | Final | Com       | Relevant   |
| P      | develop two   | 2001     | A     | missioner |            |
| ayment | mile          |          | dvice |           | NPRM Sept. |
|        | stone/outcome |          | R     |           | 2005       |
|        |               |          | eport |           | addressed  |
|        | systems---one |          | on    |           | this       |
|        | for SSI and   |          | T     |           | issue;     |
|        | one for SSDI  |          | icket |           | waiting    |
|        |               |          | to    |           | for final  |
|        |               |          | Work  |           | re         |
|        |               |          | pr    |           | gulations. |
|        |               |          | ogram |           |            |
|        |               |          | N     |           |            |
|        |               |          | otice |           |            |
|        |               |          | of    |           |            |
|        |               |          | Pro   |           |            |
|        |               |          | posed |           |            |
|        |               |          | Rule  |           |            |
|        |               |          | M     |           |            |
|        |               |          | aking |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Ticket | SSA should    | July 23, | Final | Com       | Relevant   |
| assi   | clarify that  | 2001     | A     | missioner |            |
| gnment | SSA           |          | dvice |           | NPRM Sept. |
|        | beneficiary   |          | R     |           | 2005       |
|        | has choice    |          | eport |           | addressed  |
|        | about         |          | on    |           | this       |
|        | assigning     |          | T     |           | issue;     |
|        | ticket to     |          | icket |           | waiting    |
|        | State VR      |          | to    |           | for final  |
|        |               |          | Work  |           | r          |
|        |               |          | pr    |           | egulations |
|        |               |          | ogram |           |            |
|        |               |          | N     |           |            |
|        |               |          | otice |           |            |
|        |               |          | of    |           |            |
|        |               |          | Pro   |           |            |
|        |               |          | posed |           |            |
|        |               |          | Rule  |           |            |
|        |               |          | M     |           |            |
|        |               |          | aking |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Access | Beneficiaries | August   | Adv   | Com       | Relevant   |
| to     | designated as | 2002     | isory | missioner |            |
| ti     | medical       |          | Panel |           | NPRM Sept. |
| cket - | improvement   |          | A     |           | 2005       |
| MIE    | expected      |          | nnual |           | addressed  |
|        | should be     |          | Re    |           | this       |
|        | eligible for  |          | port: |           | issue;     |
|        | tickets       |          | Year  |           | waiting    |
|        |               |          | Two   |           | for final  |
|        |               |          |       |           | r          |
|        |               |          |       |           | egulations |
+--------+---------------+----------+-------+-----------+------------+
| Ticket | Amend         | Oct. 21, | Adv   | Deputy    | Relevant   |
| assi   | Transmittal   | 2003     | isory | Com       |            |
| gnment | 17 to end the |          | L     | missioner | NPRM Sept. |
|        | current use   |          | etter | Martin    | 2005       |
|        | of signed     |          |       | Gerry     | addressed  |
|        | State VR IPE  |          |       |           | this       |
|        | as            |          |       |           | issue;     |
|        | documentation |          |       |           | waiting    |
|        | needed for    |          |       |           | for final  |
|        | assignment of |          |       |           | r          |
|        | ticket        |          |       |           | egulations |
+--------+---------------+----------+-------+-----------+------------+
| VR     | Cost          | Oct. 21, | Adv   | Deputy    | Relevant   |
| p      | reimbursement | 2003     | isory | Com       |            |
| ayment | should be     |          | L     | missioner | NPRM Sept. |
|        | separate from |          | etter | Martin    | 2005       |
|        | the Ticket to |          |       | Gerry     | addressed  |
|        | Work program  |          |       |           | this       |
|        |               |          |       |           | issue;     |
|        |               |          |       |           | waiting    |
|        |               |          |       |           | for final  |
|        |               |          |       |           | r          |
|        |               |          |       |           | egulations |
+--------+---------------+----------+-------+-----------+------------+
| Ticket | Ticket should | October  | Adv   | Assistant | Relevant,  |
| use    | not be        | 21, 2003 | isory | Secretary | pending    |
|        | considered a  |          | L     | Robert    | final      |
|        | comparable    |          | etter | P         | re         |
|        | benefit under |          |       | asternack | gulations. |
|        | Title I of    |          |       | (Justesen | RSA        |
|        | the           |          |       | for       | interprets |
|        | R             |          |       | Pa        | Ticket     |
|        | ehabilitation |          |       | sternack) | services   |
|        | Act           |          |       |           | that an EN |
|        |               |          |       |           | provides   |
|        |               |          |       |           | that\      |
|        |               |          |       |           | are        |
|        |               |          |       |           | similar to |
|        |               |          |       |           | VR         |
|        |               |          |       |           | services   |
|        |               |          |       |           | as a comp. |
|        |               |          |       |           | benefit    |
|        |               |          |       |           | and thus   |
|        |               |          |       |           | not avail. |
|        |               |          |       |           | under      |
|        |               |          |       |           | Title I    |
+--------+---------------+----------+-------+-----------+------------+
| EN     | Modify EN     | Feb.     | A     | Com       | Relevant   |
|        | payment       | 2004     | dvice | missioner |            |
|        | system to     |          | R     |           | NPRM Sept. |
|        | move more     |          | eport |           | 2005       |
|        | payment up    |          | on    |           | addressed  |
|        | front         |          | E     |           | this       |
|        |               |          | mploy |           | issue;     |
|        |               |          | -ment |           | waiting    |
|        |               |          | Net   |           | for final  |
|        |               |          | works |           | r          |
|        |               |          |       |           | egulations |
+--------+---------------+----------+-------+-----------+------------+
| EN     | Commissioner  | Feb.     | A     | Com       | Relevant   |
|        | implement     | 2004     | dvice | missioner |            |
|        | modified EN   |          | R     |           | NPRM Sept. |
|        | payment       |          | eport |           | 2005       |
|        | system        |          | on    |           | addressed  |
|        | consistent    |          | E     |           | this       |
|        | with          |          | mploy |           | issue;     |
|        | re            |          | -ment |           | waiting    |
|        | commendations |          | Net   |           | for final  |
|        | of AOI        |          | works |           | r          |
|        | Advisory      |          |       |           | egulations |
|        | Group         |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| EN     | Commissioner  | Feb.     | A     | Com       | Relevant   |
|        | should        | 2004     | dvice | missioner | NPRM Sept. |
|        | implement the |          | R     |           | 2005       |
|        | Panel\'s      |          | eport |           | addressed  |
|        | re            |          | on    |           | this       |
|        | commendations |          | E     |           | issue;     |
|        | related to    |          | mploy |           | waiting    |
|        | payment       |          | -ment |           | for final  |
|        | systems and   |          | Net   |           | r          |
|        | claims        |          | works |           | egulations |
|        | a             |          |       |           |            |
|        | dministration |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| EN     | Commissioner  | Feb.     | A     | Com       | Relevant   |
|        | should refine | 2004     | dvice | missioner | NPRM Sept. |
|        | EN payment    |          | R     |           | 2005       |
|        | processing    |          | eport |           | addressed  |
|        | time to meet  |          | on    |           | this       |
|        | business      |          | E     |           | issue;     |
|        | standards     |          | mploy |           | waiting    |
|        |               |          | -ment |           | for final  |
|        |               |          | Net   |           | r          |
|        |               |          | works |           | egulations |
+--------+---------------+----------+-------+-----------+------------+
| Amend. | All SSI and   | Dec.     | A     | Com       | Relevant   |
| to     | SSDI adult    | 2005     | nnual | missioner |            |
| Ticket | beneficiaries |          | Re    |           | Allows     |
| to     | including     |          | port: |           | those with |
| Work   | those         |          | Yr.   |           | MIE to be  |
| p      | designated as |          | 6,    |           | eligible;  |
| rogram | medical       |          | Adv   |           | waiting    |
| --     | improvement   |          | isory |           | for final  |
| NPRM   | expected      |          | L     |           | r          |
| Sept.  | should be     |          | etter |           | egulations |
| 2005   | eligible to   |          | [R    |           |            |
|        | participate   |          | e.]{. |           |            |
|        | in program    |          | under |           |            |
|        |               |          | line} |           |            |
|        |               |          | NPRM  |           |            |
|        |               |          | Sept. |           |            |
|        |               |          | 2005  |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Amend. | EN payments   | Dec.     | A     | Com       | Relevant   |
| to     | should be     | 2005     | nnual | missioner |            |
| Ticket | more frequent |          | Re    |           | Revised    |
| to     | and earlier   |          | port: |           | payment    |
| Work   |               |          | Yr.   |           | system;    |
| p      |               |          | 6,    |           | waiting    |
| rogram |               |          | Adv   |           | for final  |
| --     |               |          | isory |           | r          |
| NPRM   |               |          | L     |           | egulations |
| Sept.  |               |          | etter |           |            |
| 2005   |               |          | [R    |           |            |
|        |               |          | e.]{. |           |            |
|        |               |          | under |           |            |
|        |               |          | line} |           |            |
|        |               |          | NPRM  |           |            |
|        |               |          | Sept. |           |            |
|        |               |          | 2005  |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Amend. | Equalizing    | Dec.     | A     | Com       | Relevant   |
| to     | payment       | 2005     | nnual | missioner |            |
| Ticket | amount for    |          | Re    |           | Proposed;  |
| to     | SSI and DI    |          | port: |           | waiting    |
| Work   | beneficiaries |          | Yr.   |           | for final  |
| p      |               |          | 6,    |           | r          |
| rogram |               |          | Adv   |           | egulations |
| --     |               |          | isory |           |            |
| NPRM   |               |          | L     |           |            |
| Sept.  |               |          | etter |           |            |
| 2005   |               |          | [R    |           |            |
|        |               |          | e.]{. |           |            |
|        |               |          | under |           |            |
|        |               |          | line} |           |            |
|        |               |          | NPRM  |           |            |
|        |               |          | Sept. |           |            |
|        |               |          | 2005  |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Amend. | It appears    | Dec.     | A     | Com       | Relevant   |
| to     | that under    | 2005     | nnual | missioner | Waiting    |
| Ticket | the right     |          | Re    |           | for final  |
| to     | scenario an   |          | port: |           | r          |
| Work   | EN could      |          | Yr.   |           | egulations |
| p      | receive up to |          | 6,    |           |            |
| rogram | \$7,000 of    |          | Adv   |           |            |
| --     | their         |          | isory |           |            |
| NPRM   | milestone     |          | L     |           |            |
| Sept.  | payments      |          | etter |           |            |
| 2005   | within three  |          | [R    |           |            |
|        | months and    |          | e.]{. |           |            |
|        | over half of  |          | under |           |            |
|        | the ticket    |          | line} |           |            |
|        | payments      |          | NPRM  |           |            |
|        | within the    |          | Sept. |           |            |
|        | first year.   |          | 2005  |           |            |
|        | This could    |          |       |           |            |
|        | leave a       |          |       |           |            |
|        | financial     |          |       |           |            |
|        | disincentive  |          |       |           |            |
|        | to continue   |          |       |           |            |
|        | serving a     |          |       |           |            |
|        | beneficiary   |          |       |           |            |
|        | under this    |          |       |           |            |
|        | example after |          |       |           |            |
|        | the first     |          |       |           |            |
|        | year. SSA     |          |       |           |            |
|        | should review |          |       |           |            |
|        | the lump sum  |          |       |           |            |
|        | milestone     |          |       |           |            |
|        | payment       |          |       |           |            |
|        | provision to  |          |       |           |            |
|        | ensure that   |          |       |           |            |
|        | beneficiaries |          |       |           |            |
|        | do not lose   |          |       |           |            |
|        | this          |          |       |           |            |
|        | protection.   |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Amend. | Beneficiary   | Dec.     | A     | Com       | Relevant   |
| to     | should be     | 2005     | nnual | missioner | Clarified; |
| Ticket | eligible for  |          | Re    |           | waiting    |
| to     | more than one |          | port: |           | for final  |
| Work   | ticket in a   |          | Yr.   |           | r          |
| p      | period of     |          | 6,    |           | egulations |
| rogram | entitlement   |          | Adv   |           |            |
| --     | for SSDI/SSI  |          | isory |           |            |
| NPRM   | benefits when |          | L     |           |            |
| Sept.  | their         |          | etter |           |            |
| 2005   | disability is |          | [R    |           |            |
|        | likely to     |          | e.]{. |           |            |
|        | require some  |          | under |           |            |
|        | indefinite    |          | line} |           |            |
|        | supports to   |          | NPRM  |           |            |
|        | remain        |          | Sept. |           |            |
|        | employed      |          | 2005  |           |            |
|        | (including    |          |       |           |            |
|        | sel           |          |       |           |            |
|        | f-employment) |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Amend. | SSA clarify   | Dec.     | A     | Com       | Relevant   |
| to     | that proposed | 2005     | nnual | missioner | Waiting    |
| Ticket | rule changes  |          | Re    |           | for final  |
| to     | apply for     |          | port: |           | r          |
| Work   | both "new"    |          | Yr.   |           | egulations |
| p      | and "old"     |          | 6,    |           |            |
| rogram | tickets and   |          | Adv   |           |            |
| --     | implements    |          | isory |           |            |
| NPRM   | appropriate   |          | L     |           |            |
| Sept.  | measures to   |          | etter |           |            |
| 2005   | transition    |          | [R    |           |            |
|        | the "old"     |          | e.]{. |           |            |
|        | tickets to    |          | under |           |            |
|        | new rules     |          | line} |           |            |
|        |               |          | NPRM  |           |            |
|        |               |          | Sept. |           |            |
|        |               |          | 2005  |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Amend. | Proposed new  | Dec.     | A     | Com       | Relevant   |
| to     | rules will    | 2005     | nnual | missioner | Waiting    |
| Ticket | require       |          | Re    |           | for final  |
| to     | additional    |          | port: |           | r          |
| Work   | training of   |          | Yr.   |           | egulations |
| p      | ENs, VR, and  |          | 6,    |           |            |
| rogram | b             |          | Adv   |           |            |
| --     | eneficiaries. |          | isory |           |            |
| NPRM   | The Panel     |          | L     |           |            |
| Sept.  | urges SSA to  |          | etter |           |            |
| 2005   | be sure the   |          | [R    |           |            |
|        | necessary     |          | e.]{. |           |            |
|        | measures are  |          | under |           |            |
|        | in place to   |          | line} |           |            |
|        | educate all   |          | NPRM  |           |            |
|        | appropriate   |          | Sept. |           |            |
|        | parties of    |          | 2005  |           |            |
|        | the changes   |          |       |           |            |
|        | and how they  |          |       |           |            |
|        | work          |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Amend. | SSA establish | Dec.     | A     | Com       | Relevant   |
| to     | a             | 2005     | nnual | missioner |            |
| Ticket | cross-federal |          | Re    |           | Waiting    |
| to     | agency task   |          | port: |           | for final  |
| Work   | force on      |          | Yr.   |           | r          |
| p      | transition to |          | 6,    |           | egulations |
| rogram | develop       |          | Adv   |           |            |
| --     | unified       |          | isory |           |            |
| NPRM   | s             |          | L     |           |            |
| Sept.  | chool-to-work |          | etter |           |            |
| 2005   | system that   |          | [R    |           |            |
|        | removes       |          | e.]{. |           |            |
|        | conflicting   |          | under |           |            |
|        | incentives    |          | line} |           |            |
|        |               |          | NPRM  |           |            |
|        |               |          | Sept. |           |            |
|        |               |          | 2005  |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Amend. | Urge          | Dec.     | A     | Com       | Relevant   |
| to     | expeditious   | 2005     | nnual | missioner | Waiting    |
| Ticket | i             |          | Re    |           | for final  |
| to     | mplementation |          | port: |           | r          |
| Work   | of these new  |          | Yr.   |           | egulations |
| p      | rule changes  |          | 6,    |           |            |
| rogram | to help       |          | Adv   |           |            |
| --     | reignite the  |          | isory |           |            |
| NPRM   | level of      |          | L     |           |            |
| Sept.  | interest in   |          | etter |           |            |
| 2005   | the Ticket to |          | [R    |           |            |
|        | Work program  |          | e.]{. |           |            |
|        | by ENs and    |          | under |           |            |
|        | beneficiaries |          | line} |           |            |
|        |               |          | NPRM  |           |            |
|        |               |          | Sept. |           |            |
|        |               |          | 2005  |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Is     | SSA to        | May 2006 | A     | Com       | Relevant   |
| suance | continue      |          | nnual | missioner |            |
| of     | automatically |          | Re    |           | Waiting    |
| Re     | issuing       |          | port: |           | for final  |
| ceipts | receipts      |          | Yr.   |           | r          |
| --     | after its     |          | 7,    |           | egulations |
| Rep    | centralized   |          | Adv   |           |            |
| orting | computer file |          | isory |           |            |
| of     | is fully      |          | L     |           |            |
| c      | operational   |          | etter |           |            |
| hanges |               |          |       |           |            |
| in     |               |          |       |           |            |
| work   |               |          |       |           |            |
| or     |               |          |       |           |            |
| ea     |               |          |       |           |            |
| rnings |               |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Amend. | Permitting    | Dec.     | A     | Com       | Relevant   |
| to     | beneficiary   | 2005     | nnual | missioner |            |
| Ticket | to be own EN  |          | Re    |           |            |
| to     |               |          | port: |           |            |
| Work   |               |          | Yr.   |           |            |
| p      |               |          | 6,    |           |            |
| rogram |               |          | Adv   |           |            |
| --     |               |          | isory |           |            |
| NPRM   |               |          | L     |           |            |
| Sept.  |               |          | etter |           |            |
| 2005   |               |          | [R    |           |            |
|        |               |          | e.]{. |           |            |
|        |               |          | under |           |            |
|        |               |          | line} |           |            |
|        |               |          | NPRM  |           |            |
|        |               |          | Sept. |           |            |
|        |               |          | 2005  |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Amend. | Beneficiary   | Dec.     | A     | Com       | Relevant   |
| to     | should be     | 2005     | nnual | missioner |            |
| Ticket | eligible for  |          | Re    |           | Clarified; |
| to     | more than one |          | port: |           | waiting    |
| Work   | ticket in a   |          | Yr.   |           | for final  |
| p      | period of     |          | 6,    |           | r          |
| rogram | entitlement   |          | Adv   |           | egulations |
| --     | for SSDI/SSI  |          | isory |           |            |
| NPRM   | benefits when |          | L     |           |            |
| Sept.  | their         |          | etter |           |            |
| 2005   | disability is |          | [R    |           |            |
|        | likely to     |          | e.]{. |           |            |
|        | require some  |          | under |           |            |
|        | indefinite    |          | line} |           |            |
|        | supports to   |          | NPRM  |           |            |
|        | remain        |          | Sept. |           |            |
|        | employed      |          | 2005  |           |            |
|        | (including    |          |       |           |            |
|        | sel           |          |       |           |            |
|        | f-employment) |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Final  | Issuing the   | Sept.    | Adv   | Com       | No longer  |
| regs.  | final         | 2006     | isory | missioner | relevant   |
| per    | regulations   |          | L     |           |            |
| NPRM   | as soon as    |          | etter |           |            |
| Sept.  | possible, but |          |       |           |            |
| 2005   | not later     |          |       |           |            |
|        | than this     |          |       |           |            |
|        | fall (2006)   |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Final  | Reconsider    | Nov.     | Adv   | Com       | No longer  |
| regs.  | the decision  | 2006     | isory | missioner | relevant   |
| per    | to delay      |          | L     |           |            |
| NPRM   | release of    |          | etter |           |            |
| Sept.  | the final     |          |       |           |            |
| 2005   | Ticket to     |          |       |           |            |
|        | Work          |          |       |           |            |
|        | regulations   |          |       |           |            |
|        | and note that |          |       |           |            |
|        | this delay    |          |       |           |            |
|        | also affects  |          |       |           |            |
|        | the Agency's  |          |       |           |            |
|        | plan to       |          |       |           |            |
|        | market the    |          |       |           |            |
|        | Ticket to     |          |       |           |            |
|        | Work program, |          |       |           |            |
|        | along with    |          |       |           |            |
|        | work          |          |       |           |            |
|        | incentives    |          |       |           |            |
|        | programs      |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| NPRM,  | SSA must      | Oct.     | Adv   | Com       | Relevant   |
| July   | clearly       | 2007     | isory | missioner |            |
| 2007   | communicate   |          | L     |           |            |
|        | to            |          | etter |           |            |
|        | beneficiaries |          |       |           |            |
|        | that they'll  |          |       |           |            |
|        | be required   |          |       |           |            |
|        | to            |          |       |           |            |
|        | demonstrate   |          |       |           |            |
|        | timely        |          |       |           |            |
|        | progress in   |          |       |           |            |
|        | 12 months     |          |       |           |            |
|        | instead of 24 |          |       |           |            |
|        | months as     |          |       |           |            |
|        | currently     |          |       |           |            |
|        | required,     |          |       |           |            |
|        | before it has |          |       |           |            |
|        | a negative    |          |       |           |            |
|        | impact on     |          |       |           |            |
|        | their planned |          |       |           |            |
|        | goals         |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| NPRM,  | SSA should    | Oct.     | Adv   | Com       | Relevant   |
| July   | include       | 2007     | isory | missioner |            |
| 2007   | provisions in |          | L     |           |            |
|        | the proposed  |          | etter |           |            |
|        | amendments to |          |       |           |            |
|        | account for   |          |       |           |            |
|        | disab         |          |       |           |            |
|        | ility-related |          |       |           |            |
|        | stumbling     |          |       |           |            |
|        | blocks, such  |          |       |           |            |
|        | as an         |          |       |           |            |
|        | inability to  |          |       |           |            |
|        | get needed    |          |       |           |            |
|        | supports and  |          |       |           |            |
|        | a             |          |       |           |            |
|        | ccommodations |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| NPRM,  | SSA should    | Oct.     | Adv   | Com       | Relevant   |
| July   | provide a     | 2007     | isory | missioner |            |
| 2007   | larger        |          | L     |           |            |
|        | threshold for |          | etter |           |            |
|        | beneficiaries |          |       |           |            |
|        | who may       |          |       |           |            |
|        | require a     |          |       |           |            |
|        | longer period |          |       |           |            |
|        | of time to    |          |       |           |            |
|        | complete      |          |       |           |            |
|        | their         |          |       |           |            |
|        | educational   |          |       |           |            |
|        | studies       |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| NPRM,  | SSA should    | Oct.     | Adv   | Com       | Relevant   |
| July   | include       | 2007     | isory | missioner |            |
| 2007   | training      |          | L     |           |            |
|        | programs of   |          | etter |           |            |
|        | the           |          |       |           |            |
|        | Department of |          |       |           |            |
|        | Veterans      |          |       |           |            |
|        | Affairs and   |          |       |           |            |
|        | the           |          |       |           |            |
|        | Department of |          |       |           |            |
|        | Education     |          |       |           |            |
|        | under the     |          |       |           |            |
|        | definition of |          |       |           |            |
|        | "vocational   |          |       |           |            |
|        | or technical  |          |       |           |            |
|        | training      |          |       |           |            |
|        | programs."    |          |       |           |            |
|        | This should   |          |       |           |            |
|        | include       |          |       |           |            |
|        | disabi        |          |       |           |            |
|        | lity-specific |          |       |           |            |
|        | training,     |          |       |           |            |
|        | such as       |          |       |           |            |
|        | orientation   |          |       |           |            |
|        | and mobility, |          |       |           |            |
|        | Braille,      |          |       |           |            |
|        | assistive     |          |       |           |            |
|        | technology,   |          |       |           |            |
|        | and similar   |          |       |           |            |
|        | skills        |          |       |           |            |
|        | necessary for |          |       |           |            |
|        | vocational    |          |       |           |            |
|        | functioning   |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| NPRM,  | Timely        | Oct.     | Adv   | Com       | Relevant   |
| July   | progress      | 2007     | isory | missioner |            |
| 2007   | should be     |          | L     |           |            |
|        | i             |          | etter |           |            |
|        | ndividualized |          |       |           |            |
|        | based on the  |          |       |           |            |
|        | terms and     |          |       |           |            |
|        | conditions of |          |       |           |            |
|        | the IPE/IWP   |          |       |           |            |
|        | and           |          |       |           |            |
|        | accommodate   |          |       |           |            |
|        | episodic      |          |       |           |            |
|        | disabilities. |          |       |           |            |
|        | It should be  |          |       |           |            |
|        | possible for  |          |       |           |            |
|        | the IPE/IWP   |          |       |           |            |
|        | to be revised |          |       |           |            |
|        | and updated   |          |       |           |            |
|        | as the needs  |          |       |           |            |
|        | and           |          |       |           |            |
|        | circumstances |          |       |           |            |
|        | of the        |          |       |           |            |
|        | individual    |          |       |           |            |
|        | changes --    |          |       |           |            |
|        | both for      |          |       |           |            |
|        | postsecondary |          |       |           |            |
|        | education and |          |       |           |            |
|        | vocatio       |          |       |           |            |
|        | nal/technical |          |       |           |            |
|        | training      |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| NPRM,  | SSA should    | Oct.     | Adv   | Com       | Relevant   |
| July   | explain its   | 2007     | isory | missioner |            |
| 2007   | plan for      |          | L     |           |            |
|        | implementing  |          | etter |           |            |
|        | the proposed  |          |       |           |            |
|        | amendments,   |          |       |           |            |
|        | answering,    |          |       |           |            |
|        | for example,  |          |       |           |            |
|        | the following |          |       |           |            |
|        | questions: 1) |          |       |           |            |
|        | Will the      |          |       |           |            |
|        | amendments    |          |       |           |            |
|        | become        |          |       |           |            |
|        | effective     |          |       |           |            |
|        | after 60      |          |       |           |            |
|        | days? 2) Will |          |       |           |            |
|        | the           |          |       |           |            |
|        | amendments be |          |       |           |            |
|        | applied to    |          |       |           |            |
|        | everyone or   |          |       |           |            |
|        | only to newly |          |       |           |            |
|        | assigned      |          |       |           |            |
|        | tickets? 3)   |          |       |           |            |
|        | What          |          |       |           |            |
|        | procedure     |          |       |           |            |
|        | will be used  |          |       |           |            |
|        | to determine  |          |       |           |            |
|        | progress -- a |          |       |           |            |
|        | questionnaire |          |       |           |            |
|        | or an         |          |       |           |            |
|        | interview, or |          |       |           |            |
|        | something     |          |       |           |            |
|        | else?         |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| IRWE   | Change the    | Dec.     | Opt   | Com       | Relevant   |
|        | order in      | 2007     | imize | missioner |            |
|        | which IRWE    |          | Work  |           |            |
|        | are deducted  |          | Incen |           |            |
|        | when          |          | tives |           |            |
|        | calculating   |          | R     |           |            |
|        | the SSI cash  |          | eport |           |            |
|        | payment to    |          |       |           |            |
|        | allow for up  |          |       |           |            |
|        | to a 100      |          |       |           |            |
|        | percent cost  |          |       |           |            |
|        | recovery      |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| IRWE   | Allow health  | Dec.     | Opt   | Com       | Relevant   |
|        | insurance     | 2007     | imize | missioner |            |
|        | premiums to   |          | Work  |           |            |
|        | be used as    |          | Incen |           |            |
|        | IRWE, when    |          | tives |           |            |
|        | the           |          | R     |           |            |
|        | beneficiary   |          | eport |           |            |
|        | can document  |          |       |           |            |
|        | that the      |          |       |           |            |
|        | coverage is   |          |       |           |            |
|        | disab         |          |       |           |            |
|        | ility-related |          |       |           |            |
|        | and supports  |          |       |           |            |
|        | work          |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| IRWE   | Eliminate the | Dec.     | Opt   | Com       | Relevant   |
|        | condition     | 2007     | imize | missioner |            |
|        | that family   |          | Work  |           |            |
|        | members must  |          | Incen |           |            |
|        | suffer        |          | tives |           |            |
|        | financial     |          | R     |           |            |
|        | loss for      |          | eport |           |            |
|        | their         |          |       |           |            |
|        | compensation  |          |       |           |            |
|        | by the        |          |       |           |            |
|        | beneficiary   |          |       |           |            |
|        | to count as   |          |       |           |            |
|        | IRWE if they  |          |       |           |            |
|        | provide       |          |       |           |            |
|        | attendant     |          |       |           |            |
|        | care and/or   |          |       |           |            |
|        | t             |          |       |           |            |
|        | ransportation |          |       |           |            |
|        | to/from work  |          |       |           |            |
|        | to a person   |          |       |           |            |
|        | with a        |          |       |           |            |
|        | disability    |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| SSI    | Increase and  | Dec.     | Opt   | Com       | Relevant   |
| I      | index the key | 2007     | imize | missioner |            |
| ncome/ | income        |          | Work  |           |            |
|        | exclusion     |          | Incen |           |            |
| Re     | amounts and   |          | tives |           |            |
| source | the resource  |          | R     |           |            |
| Limits | limits under  |          | eport |           |            |
|        | the SSI       |          |       |           |            |
|        | program       |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| EN     | Approve       | Dec.     | Opt   | Com       | Relevant   |
|        | proposed rule | 2007     | imize | missioner |            |
|        | changes to    |          | Work  |           |            |
|        | the Ticket to |          | Incen |           |            |
|        | Work program  |          | tives |           |            |
|        | to enable ENs |          | R     |           |            |
|        | to receive    |          | eport |           |            |
|        | ticket        |          |       |           |            |
|        | outcome-only  |          |       |           |            |
|        | payments      |          |       |           |            |
|        | while a       |          |       |           |            |
|        | beneficiary   |          |       |           |            |
|        | is receiving  |          |       |           |            |
|        | an SSI cash   |          |       |           |            |
|        | payment       |          |       |           |            |
|        | resulting     |          |       |           |            |
|        | from an       |          |       |           |            |
|        | active PASS   |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| VR     | Allow SVRAs   | Dec.     | Opt   | Com       | Relevant   |
| P      | to receive    | 2007     | imize | missioner |            |
| ayment | traditional   |          | Work  |           |            |
|        | cost          |          | Incen |           |            |
|        | reimbursement |          | tives |           |            |
|        | if and when   |          | R     |           |            |
|        | an individual |          | eport |           |            |
|        | is receiving  |          |       |           |            |
|        | an SSI cash   |          |       |           |            |
|        | payment       |          |       |           |            |
|        | resulting     |          |       |           |            |
|        | from an       |          |       |           |            |
|        | active PASS   |          |       |           |            |
|        | or claim of   |          |       |           |            |
|        | BWE           |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Work   | Reduce the    | Dec.     | Opt   | Com       | Relevant   |
| Ince   | complexity    | 2007     | imize | missioner |            |
| ntives | and improve   |          | Work  |           |            |
|        | the           |          | Incen |           |            |
|        | consistency   |          | tives |           |            |
|        | of work       |          | R     |           |            |
|        | incentives    |          | eport |           |            |
|        | across the    |          |       |           |            |
|        | SSI and SSDI  |          |       |           |            |
|        | programs and  |          |       |           |            |
|        | other federal |          |       |           |            |
|        | entitlements  |          |       |           |            |
|        | so that they  |          |       |           |            |
|        | universally   |          |       |           |            |
|        | support work  |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| P      | Establish     | Dec.     | Opt   | Com       | Relevant   |
| ost-en | mechanisms to | 2007     | imize | missioner |            |
| title. | monitor       |          | Work  |           |            |
| Wor    | pos           |          | Incen |           |            |
| kloads | t-entitlement |          | tives |           |            |
|        | workloads,    |          | R     |           |            |
|        | develop       |          | eport |           |            |
|        | performance   |          |       |           |            |
|        | standards     |          |       |           |            |
|        | (similar to   |          |       |           |            |
|        | those         |          |       |           |            |
|        | established   |          |       |           |            |
|        | for initial   |          |       |           |            |
|        | claims in     |          |       |           |            |
|        | terms of      |          |       |           |            |
|        | processing    |          |       |           |            |
|        | time and      |          |       |           |            |
|        | decisional    |          |       |           |            |
|        | accuracy),    |          |       |           |            |
|        | and allocate  |          |       |           |            |
|        | sufficient    |          |       |           |            |
|        | resources to  |          |       |           |            |
|        | address       |          |       |           |            |
|        | pos           |          |       |           |            |
|        | t-entitlement |          |       |           |            |
|        | workloads     |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| P      | Establish a   | Dec.     | Opt   | Com       | Relevant   |
| ost-en | cr            | 2007     | imize | missioner |            |
| title. | oss-component |          | Work  |           |            |
|        | internal SSA  |          | Incen |           |            |
| Wor    | Task Force on |          | tives |           |            |
| kloads | pos           |          | R     |           |            |
|        | t-entitlement |          | eport |           |            |
|        | workload      |          |       |           |            |
|        | issues to     |          |       |           |            |
|        | identify      |          |       |           |            |
|        | resources     |          |       |           |            |
|        | needed to     |          |       |           |            |
|        | perform       |          |       |           |            |
|        | critical      |          |       |           |            |
|        | program       |          |       |           |            |
|        | integrity     |          |       |           |            |
|        | activities    |          |       |           |            |
|        | that address  |          |       |           |            |
|        | pos           |          |       |           |            |
|        | t-entitlement |          |       |           |            |
|        | workloads     |          |       |           |            |
|        | such as       |          |       |           |            |
|        | processing    |          |       |           |            |
|        | work reports  |          |       |           |            |
|        | and           |          |       |           |            |
|        | preventing    |          |       |           |            |
|        | and detecting |          |       |           |            |
|        | overpayments. |          |       |           |            |
|        | Publish these |          |       |           |            |
|        | findings      |          |       |           |            |
|        | annually      |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Wage   | Continue to   | Dec.     | Opt   | Com       | Relevant   |
| Rep    | expand        | 2007     | imize | missioner |            |
| orting | systems for   |          | Work  |           |            |
|        | reporting     |          | Incen |           |            |
|        | wages         |          | tives |           |            |
|        | el            |          | R     |           |            |
|        | ectronically, |          | eport |           |            |
|        | ensuring that |          |       |           |            |
|        | concurrent    |          |       |           |            |
|        | beneficiaries |          |       |           |            |
|        | have a single |          |       |           |            |
|        | point of      |          |       |           |            |
|        | earnings      |          |       |           |            |
|        | reporting and |          |       |           |            |
|        | that timely   |          |       |           |            |
|        | receipts are  |          |       |           |            |
|        | sent to all   |          |       |           |            |
|        | beneficiaries |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Pe     | Strengthen    | Dec.     | Opt   | Com       | Relevant   |
| rform. | both the WIPA | 2007     | imize | missioner |            |
| sta    | and PABSS     |          | Work  |           |            |
| ndards | networks by   |          | Incen |           |            |
| for    | establishing  |          | tives |           |            |
| WIPA/  | performance   |          | R     |           |            |
|        | standards,    |          | eport |           |            |
| PABSS  | 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      |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Pe     | Identify      | Dec.     | Opt   | Com       | Relevant   |
| rform. | clear,        | 2007     | imize | missioner |            |
| sta    | objective     |          | Work  |           |            |
| ndards | performance   |          | Incen |           |            |
| for    | standards and |          | tives |           |            |
| WIPA/  | indicators to |          | R     |           |            |
|        | evaluate the  |          | eport |           |            |
| PABSS  | activities    |          |       |           |            |
|        | and impact of |          |       |           |            |
|        | AWICs and     |          |       |           |            |
|        | WILs, and     |          |       |           |            |
|        | collect,      |          |       |           |            |
|        | analyze,      |          |       |           |            |
|        | document, and |          |       |           |            |
|        | publish       |          |       |           |            |
|        | evidence      |          |       |           |            |
|        | annually (by  |          |       |           |            |
|        | SSA region    |          |       |           |            |
|        | and           |          |       |           |            |
|        | system-wide)  |          |       |           |            |
|        | of customer   |          |       |           |            |
|        | satisfaction, |          |       |           |            |
|        | improved      |          |       |           |            |
|        | employment    |          |       |           |            |
|        | outcomes, and |          |       |           |            |
|        | advanced      |          |       |           |            |
|        | sel           |          |       |           |            |
|        | f-sufficiency |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| PASS   | Collect       | Dec.     | Opt   | Com       | Relevant   |
|        | workload      | 2007     | imize | missioner |            |
|        | information   |          | Work  |           |            |
|        | on the number |          | Incen |           |            |
|        | of PASS       |          | tives |           |            |
|        | applications  |          | R     |           |            |
|        | submitted and |          | eport |           |            |
|        | 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 |          |       |           |            |
|        | a             |          |       |           |            |
|        | dministration |          |       |           |            |
|        | and outreach  |          |       |           |            |
|        | of the PASS   |          |       |           |            |
|        | program.      |          |       |           |            |
|        | Recruit,      |          |       |           |            |
|        | develop, and  |          |       |           |            |
|        | support PASS  |          |       |           |            |
|        | specialists   |          |       |           |            |
|        | (travel,      |          |       |           |            |
|        | technology,   |          |       |           |            |
|        | et al)        |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Data   | Improve       | Dec.     | Opt   | Com       | Relevant   |
| rep    | reporting of  | 2007     | imize | missioner |            |
| orting | data and      |          | Work  |           |            |
|        | analysis      |          | Incen |           |            |
|        | pertaining    |          | tives |           |            |
|        | to SSDI       |          | R     |           |            |
|        | (including    |          | eport |           |            |
|        | Disabled      |          |       |           |            |
|        | Adult         |          |       |           |            |
|        | Children and  |          |       |           |            |
|        | concurrent    |          |       |           |            |
|        | SSDI/SSI      |          |       |           |            |
|        | b             |          |       |           |            |
|        | eneficiaries) |          |       |           |            |
|        | and issue an  |          |       |           |            |
|        | annual report |          |       |           |            |
|        | comparable to |          |       |           |            |
|        | SSA's **SSI   |          |       |           |            |
|        | Disabled      |          |       |           |            |
|        | Recipients    |          |       |           |            |
|        | Who Work      |          |       |           |            |
|        | report**      |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| MIS    | Establish a   | Dec.     | Opt   | Com       | Relevant   |
| for    | performance   | 2007     | imize | missioner |            |
| re     | management    |          | Work  |           |            |
| turn-t | and return to |          | Incen |           |            |
| o-work | work tracking |          | tives |           |            |
|        | system,       |          | R     |           |            |
|        | providing     |          | eport |           |            |
|        | benchmarks    |          |       |           |            |
|        | for each      |          |       |           |            |
|        | state, and    |          |       |           |            |
|        | track         |          |       |           |            |
|        | utilization   |          |       |           |            |
|        | over time as  |          |       |           |            |
|        | part of a     |          |       |           |            |
|        | continuous    |          |       |           |            |
|        | quality       |          |       |           |            |
|        | improvement   |          |       |           |            |
|        | plan.         |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| Wage   | Increase      | Dec.     | Opt   | Com       | Relevant   |
| rep    | beneficiary   | 2007     | imize | missioner |            |
| orting | awareness of  |          | Work  |           |            |
|        | earnings      |          | Incen |           |            |
|        | reporting     |          | tives |           |            |
|        | requirements  |          | R     |           |            |
|        | and promote   |          | eport |           |            |
|        | greater       |          |       |           |            |
|        | self-efficacy |          |       |           |            |
+--------+---------------+----------+-------+-----------+------------+
| \$1    | Ensure that   | August   | A     | Com       | Relevant   |
| for    | employment    | 2002     | dvice | missioner | Possibly   |
| \$2    | supports are  |          | R     |           | included   |
| Demo   | in place for  |          | eport |           | in design  |
|        | \$1 for \$2   |          | on    |           | of         |
|        | demonstration |          | \$1   |           | national   |
|        |               |          | for   |           | benefits   |
|        |               |          | \$2   |           | offset     |
|        |               |          | Be    |           | demo       |
|        |               |          | nefit |           | nstration; |
|        |               |          | O     |           | see        |
|        |               |          | ffset |           | details    |
|        |               |          | Res   |           | when       |
|        |               |          | earch |           | available  |
+--------+---------------+----------+-------+-----------+------------+
| \$1    | Use SGA as    | August   | A     | Com       | Relevant   |
| for    | disregard     | 2002     | dvice | missioner | Possibly   |
| \$2    | level for \$1 |          | R     |           | included   |
| Demo   | for \$2       |          | eport |           | in design  |
|        | current       |          | on    |           | of         |
|        | beneficiaries |          | \$1   |           | national   |
|        | demonstration |          | for   |           | benefits   |
|        |               |          | \$2   |           | offset     |
|        |               |          | Be    |           | demo       |
|        |               |          | nefit |           | nstration; |
|        |               |          | O     |           | see        |
|        |               |          | ffset |           | details    |
|        |               |          | Res   |           | when       |
|        |               |          | earch |           | available  |
+--------+---------------+----------+-------+-----------+------------+
| \$1    | Endorses SSA  | August   | A     | Com       | Relevant   |
| for    | sample size   | 2002     | dvice | missioner | Possibly   |
| \$2    | of 5,000 in   |          | R     |           | included   |
| Demo   | \$1 for \$2   |          | eport |           | in design  |
|        | demonstration |          | on    |           | of         |
|        |               |          | \$1   |           | national   |
|        |               |          | for   |           | benefits   |
|        |               |          | \$2   |           | offset     |
|        |               |          | Be    |           | demo       |
|        |               |          | nefit |           | nstration; |
|        |               |          | O     |           | see        |
|        |               |          | ffset |           | details    |
|        |               |          | Res   |           | when       |
|        |               |          | earch |           | available  |
+--------+---------------+----------+-------+-----------+------------+
| \$1    | Use monthly   | August   | A     | Com       | Relevant   |
| for    | accounting    | 2002     | dvice | missioner | Possibly   |
| \$2    | period        |          | R     |           | included   |
| Demo   | consistent    |          | eport |           | in design  |
|        | with SSI      |          | on    |           | of         |
|        | accounting in |          | \$1   |           | national   |
|        | \$1 for \$2   |          | for   |           | benefits   |
|        | demonstration |          | \$2   |           | offset     |
|        |               |          | Be    |           | demo       |
|        |               |          | nefit |           | nstration; |
|        |               |          | O     |           | see        |
|        |               |          | ffset |           | details    |
|        |               |          | Res   |           | when       |
|        |               |          | earch |           | available  |
+--------+---------------+----------+-------+-----------+------------+

Ticket to Work and Work Incentives Advisory Panel Recommendations

December 1999 to November 2007

Table 2: FINAL ACTION TAKEN

+-----------+-----------+---+-------+--------+----------+----------------+
| [Issu     | [Reco     |   | [Da   | [So    | [S       | [Action        |
| e]{.mark} | mmendatio |   | te]{. | urce]{ | ubmitted | Taken]{.mark}  |
|           | n]{.mark} |   | mark} | .mark} | To       |                |
|           |           |   |       |        | ]{.mark} |                |
+===========+===========+===+=======+========+==========+================+
| Funding   | Projects  |   | March | Ad     | Pr       | Congress       |
| for PWI & | with      |   | 1,    | visory | esident\ | preserved      |
| Supported | Industry  |   | 2002  | Letter | Bush     | grant programs |
| E         | and       |   |       |        |          |                |
| mployment | Supported |   |       |        |          |                |
|           | E         |   |       |        |          |                |
|           | mployment |   |       |        |          |                |
|           | grants    |   |       |        |          |                |
|           | should be |   |       |        |          |                |
|           | preserved |   |       |        |          |                |
|           | at the    |   |       |        |          |                |
|           | Federal   |   |       |        |          |                |
|           | level     |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| Work      | Re        |   | April | Letter | Clay     | HR 743         |
| Op        | authorize |   | 11,   | to the | Shaw     | reauthorized   |
| portunity | the Work  |   | 2002  | Hon    |          | and extended   |
| Tax       | Op        |   |       | orable |          | the credit;    |
| Credit    | portunity |   |       | Clay   |          | again in 2006  |
|           | Tax       |   |       | Shaw   |          |                |
|           | Credit    |   |       |        |          |                |
|           | and       |   |       |        |          |                |
|           | extend it |   |       |        |          |                |
|           | to        |   |       |        |          |                |
|           | employers |   |       |        |          |                |
|           | who hire  |   |       |        |          |                |
|           | people    |   |       |        |          |                |
|           | with      |   |       |        |          |                |
|           | dis       |   |       |        |          |                |
|           | abilities |   |       |        |          |                |
|           | who used  |   |       |        |          |                |
|           | a ticket  |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| P&A       | Congress  |   | A     | Ad     | Congress | SSA removed    |
|           | should    |   | ugust | visory |          | restriction,   |
|           | direct    |   | 2002  | Panel  |          | and HR 743,    |
|           | SSA to    |   |       | Annual |          | signed on      |
|           | remove    |   |       | R      |          | March 2, 2004, |
|           | the       |   |       | eport: |          | removed others |
|           | res       |   |       | Year   |          |                |
|           | trictions |   |       | Two    |          |                |
|           | on P&A    |   |       |        |          |                |
|           | grantee   |   |       |        |          |                |
|           | a         |   |       |        |          |                |
|           | ctivities |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| P&A       | Congress  |   | May   | Annual | Congress | SSA removed    |
|           | should    |   | 2003  | R      |          | some           |
|           | direct    |   |       | eport: |          | restrictions,\ |
|           | SSA to    |   |       | Year   |          | and HR 743,    |
|           | remove    |   |       | Three  |          | signed on      |
|           | res       |   |       |        |          | March 2, 2004, |
|           | trictions |   |       |        |          | removed others |
|           | on the    |   |       |        |          |                |
|           | use of    |   |       |        |          |                |
|           | P&A grant |   |       |        |          |                |
|           | funds     |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| BPAO      | Re        |   | Nov.  | Ad     | Con      | HR 743         |
|           | authorize |   | 20,   | visory | gressman | reauthorized   |
|           | BPAO      |   | 2003  | Letter | Shaw and |                |
|           | Program   |   |       |        | Senator  |                |
|           | and       |   |       |        | Grassley |                |
|           | double    |   |       |        |          |                |
|           | funding   |   |       |        |          |                |
|           | to        |   |       |        |          |                |
|           | \$4       |   |       |        |          |                |
|           | 6,000,000 |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| P&A       | Re        | N |       | Ad     | Con      | HR 743         |
|           | authorize | o |       | visory | gressman | reauthorized   |
|           | the P&A   | v |       | Letter | Shaw and | the P&A        |
|           | program,  | . |       |        | Senator  | Program        |
|           | increase  | 2 |       |        | Grassley |                |
|           | the min.  | 0 |       |        |          |                |
|           | amt. of   | , |       |        |          |                |
|           | each      | 2 |       |        |          |                |
|           | State     | 0 |       |        |          |                |
|           | grant to  | 0 |       |        |          |                |
|           | \         | 3 |       |        |          |                |
|           | $200,000, |   |       |        |          |                |
|           | and       |   |       |        |          |                |
|           | increase  |   |       |        |          |                |
|           | funding   |   |       |        |          |                |
|           | for the   |   |       |        |          |                |
|           | program   |   |       |        |          |                |
|           | as a      |   |       |        |          |                |
|           | whole to  |   |       |        |          |                |
|           | \$1       |   |       |        |          |                |
|           | 4,000,000 |   |       |        |          |                |
|           | per FY    |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| Comment   | Use the   | D |       | Annual | Comm     | Period used 60 |
| Period    | longest   | e |       | I      | issioner | days           |
|           | comment   | c |       | nterim |          |                |
|           | period    | . |       | Pr     |          |                |
|           | possible  | 1 |       | ogress |          |                |
|           | during    | 7 |       | R      |          |                |
|           | r         | , |       | eport: |          |                |
|           | egulatory | 1 |       | Year   |          |                |
|           | process   | 9 |       | One    |          |                |
|           | to allow  | 9 |       |        |          |                |
|           | maximum   | 9 |       |        |          |                |
|           | public    | - |       |        |          |                |
|           | comment.  | - |       |        |          |                |
|           |           | D |       |        |          |                |
|           |           | e |       |        |          |                |
|           |           | c |       |        |          |                |
|           |           | . |       |        |          |                |
|           |           | 1 |       |        |          |                |
|           |           | 6 |       |        |          |                |
|           |           | , |       |        |          |                |
|           |           | 2 |       |        |          |                |
|           |           | 0 |       |        |          |                |
|           |           | 0 |       |        |          |                |
|           |           | 0 |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| CDR       | 18        | J |       | Final  | Congress | Possibly if VR |
|           | -year-old | u |       | Advice |          | client with    |
|           | bene      | l |       | Report |          | IWP, waiting   |
|           | ficiaries | y |       | on     |          | on final       |
|           | should    | 2 |       | Ticket |          | regulations    |
|           | receive   | 3 |       | to     |          | per NPRM Sept. |
|           | same      | , |       | Work   |          | 2005           |
|           | p         | 2 |       | p      |          |                |
|           | rotection | 0 |       | rogram |          |                |
|           | from      | 0 |       | Notice |          |                |
|           | redeter   | 1 |       | of     |          |                |
|           | minations |   |       | Pr     |          |                |
|           | as other  |   |       | oposed |          |                |
|           | ticket    |   |       | Rule   |          |                |
|           | users do  |   |       | Making |          |                |
|           | from CDR  |   |       | (NPRM) |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| EN        | EN        | J |       | Final  | Comm     | Final          |
|           | required  | u |       | Advice | issioner | Regulations    |
|           | to retain | l |       | Report |          | Dec. 2001      |
|           | staff     | y |       | on     |          |                |
|           | based on  | 2 |       | Ticket |          |                |
|           | education | 3 |       | to     |          |                |
|           | and       | , |       | Work   |          |                |
|           | e         | 2 |       | p      |          |                |
|           | xperience | 0 |       | rogram |          |                |
|           |           | 0 |       | NPRM   |          |                |
|           |           | 1 |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| EN        | SSA       | J |       | Final  | Comm     | Final          |
|           | should    | u |       | Advice | issioner | Regulations    |
|           | simplify  | l |       | Report |          | Dec. 2001 and  |
|           | EN        | y |       | on     |          | September,     |
|           | reporting | 2 |       | Ticket |          | 2005 NPRM      |
|           | req       | 3 |       | to     |          |                |
|           | uirements | , |       | Work   |          |                |
|           |           | 2 |       | p      |          |                |
|           |           | 0 |       | rogram |          |                |
|           |           | 0 |       | NPRM   |          |                |
|           |           | 1 |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| Dispute   | All       | J |       | Final  | Comm     | Improvement,   |
| r         | bene      | u |       | Advice | issioner | Overpayment    |
| esolution | ficiaries | l |       | Report |          |                |
|           | should    | y |       | on     |          |                |
|           | have      | 2 |       | Ticket |          |                |
|           | access to | 3 |       | to     |          |                |
|           | P&A       | , |       | Work   |          |                |
|           |           | 2 |       | p      |          |                |
|           |           | 0 |       | rogram |          |                |
|           |           | 0 |       | NPRM   |          |                |
|           |           | 1 |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| Dispute   | Mediation | J |       | Final  | Comm     | Pilot Program  |
| r         | should be | u |       | Advice | issioner |                |
| esolution | made      | l |       | Report |          |                |
|           | available | y |       | on     |          |                |
|           | to        | 2 |       | Ticket |          |                |
|           | resolve   | 3 |       | to     |          |                |
|           | disputes  | , |       | Work   |          |                |
|           |           | 2 |       | p      |          |                |
|           |           | 0 |       | rogram |          |                |
|           |           | 0 |       | NPRM   |          |                |
|           |           | 1 |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| Dispute   | In        | J |       | Final  | Comm     | Some, Letter,  |
| r         | formation | u |       | Advice | issioner | IWP            |
| esolution | on P&A    | l |       | Report |          |                |
|           | services  | y |       | on     |          |                |
|           | should be | 2 |       | Ticket |          |                |
|           | a         | 3 |       | to     |          |                |
|           | ccessible | , |       | Work   |          |                |
|           | to        | 2 |       | p      |          |                |
|           | bene      | 0 |       | rogram |          |                |
|           | ficiaries | 0 |       |        |          |                |
|           |           | 1 |       | NPRM   |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| Dispute   | All       | J |       | Final  | Comm     | Policy         |
| r         | parties   | u |       | Advice | issioner |                |
| esolution | in        | l |       | Report |          |                |
|           | disputes  | y |       | on     |          |                |
|           | should    | 2 |       | Ticket |          |                |
|           | have      | 3 |       | to     |          |                |
|           | access to | , |       | Work   |          |                |
|           | all       | 2 |       | p      |          |                |
|           | in        | 0 |       | rogram |          |                |
|           | formation | 0 |       | NPRM   |          |                |
|           |           | 1 |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| EN        | SSA       | J |       | Final  | Comm     | Improvement    |
| Payment   | should    | u |       | Advice | issioner | from two to    |
|           | adopt     | l |       | Report |          | three.         |
|           | payment   | y |       | on     |          |                |
|           | structure | 2 |       | Ticket |          |                |
|           | that pays | 3 |       | to     |          |                |
|           | four      | , |       | Work   |          |                |
|           | milestone | 2 |       | p      |          |                |
|           | payments  | 0 |       | rogram |          |                |
|           |           | 0 |       | NPRM   |          |                |
|           |           | 1 |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| VR        | Resolve   | J |       | Final  | Comm     | Resolved in    |
| payment   | the       | u |       | Advice | issioner | final          |
| option    | conflict  | l |       | Report |          | regulation     |
|           | between   | y |       | on     |          | Dec. 2001      |
|           | sections  | 2 |       | Ticket |          |                |
|           | 411.510   | 3 |       | to     |          |                |
|           | and       | , |       | Work   |          |                |
|           | 411.390   | 2 |       | p      |          |                |
|           |           | 0 |       | rogram |          |                |
|           |           | 0 |       | NPRM   |          |                |
|           |           | 1 |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| Ticket to | Swift     | N |       | Ad     | P        | Final          |
| Work      | issuance  | o |       | visory | resident | regulations    |
| re        | of the    | v |       | Letter |          | were issued in |
| gulations | final     | . |       |        |          | December 2001. |
| --        | ticket-   | 3 |       |        |          |                |
| initial   | imp       | 0 |       |        |          |                |
| set       | lementing | , |       |        |          |                |
|           | re        | 2 |       |        |          |                |
|           | gulations | 0 |       |        |          |                |
|           |           | 0 |       |        |          |                |
|           |           | 1 |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| Funding   | Restore   | J |       | Ad     | Commi    | Funding        |
| for BPAO  | funding   | a |       | visory | ssioner\ | restored.      |
| & P&A     | for BPAO  | n |       | Letter | Barnhart |                |
|           | and P&A   | . |       |        |          |                |
|           | Programs  | 7 |       |        |          |                |
|           | to        | , |       |        |          |                |
|           | maximum   | 2 |       |        |          |                |
|           | a         | 0 |       |        |          |                |
|           | uthorized | 0 |       |        |          |                |
|           | in the    | 2 |       |        |          |                |
|           | statute   |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| AOI       | Convene   | J |       | Advice | Comm     | In 2003,       |
|           | an        | u |       | Report | issioner | convened the   |
|           | ongoing   | n |       | on the |          | AOI Advisory   |
|           | Adequacy  | e |       | Ad     |          | Group for 1    |
|           | of        | 1 |       | equacy |          | year.          |
|           | I         | 8 |       | of     |          |                |
|           | ncentives | , |       | Ince   |          |                |
|           | Advisory  | 2 |       | ntives |          |                |
|           | Team      | 0 |       | (AOI)  |          |                |
|           |           | 0 |       | Study  |          |                |
|           |           | 2 |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| AOI       | Data      | J |       | Advice | Comm     | AOI data       |
|           | collected | u |       | Report | issioner | included in    |
|           | for AOI   | n |       | on the |          | Ticket to Work |
|           | should be | e |       | Ad     |          | program\       |
|           | provided  | 1 |       | equacy |          | eval. research |
|           | in SSA\'s | 8 |       | of     |          | design.        |
|           | overall   | , |       | Ince   |          |                |
|           | Ticket to | 2 |       | ntives |          |                |
|           | Work      | 0 |       | (AOI)  |          |                |
|           | program   | 0 |       | Study  |          |                |
|           | eval.     | 2 |       |        |          |                |
|           | research  |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| Be        | SSA\'s    | J |       | Advice | Comm     | Survey design  |
| neficiary | be        | u |       | Report | issioner | includes\      |
| survey    | neficiary | n |       | on the |          | face-to-face   |
|           | survey    | e |       | Ad     |          | interviews and |
|           | should    | 1 |       | equacy |          | other          |
|           | include   | 8 |       | of     |          | a              |
|           | fac       | , |       | Ince   |          | ccommodations. |
|           | e-to-face | 2 |       | ntives |          |                |
|           | i         | 0 |       | (AOI)  |          |                |
|           | nterviews | 0 |       | Study  |          |                |
|           | and       | 2 |       |        |          |                |
|           | special   |   |       |        |          |                |
|           | accom     |   |       |        |          |                |
|           | modations |   |       |        |          |                |
|           | for AOI   |   |       |        |          |                |
|           | p         |   |       |        |          |                |
|           | opulation |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| AOI -     | Review    | J |       | Advice | Comm     | Reviewed       |
| Research  | existing  | u |       | Report | issioner | existing       |
|           | research  | n |       | on the |          | research and   |
|           | and       | e |       | Ad     |          | best practices |
|           | conduct   | 1 |       | equacy |          | at AOI         |
|           | supp      | 8 |       | of     |          | technical      |
|           | lementary | , |       | Ince   |          | workshop (May  |
|           | research  | 2 |       | ntives |          | 2002)          |
|           |           | 0 |       | (AOI)  |          |                |
|           |           | 0 |       | Study  |          |                |
|           |           | 2 |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| AOI and   | Data      | J |       | Advice | Comm     | Study design   |
| data      | collected | u |       | Report | issioner | includes       |
|           | should    | n |       | on the |          | information on |
|           | include   | e |       | Ad     |          | demographics   |
|           | attention | 1 |       | equacy |          | and diversity. |
|           | to        | 8 |       | of     |          |                |
|           | national  | , |       | Ince   |          |                |
|           | dem       | 2 |       | ntives |          |                |
|           | ographics | 0 |       | (AOI)  |          |                |
|           | and       | 0 |       | Study  |          |                |
|           | diversity | 2 |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| AOI -     | Conduct   | J |       | Advice | Comm     | Conducted      |
| Research  | or        | u |       | Report | issioner | interview with |
|           | c         | n |       | on the |          | ENs on AOI     |
|           | ommission | e |       | Ad     |          | issues in      |
|           | qu        | 1 |       | equacy |          | evaluation     |
|           | alitative | 8 |       | of     |          | design         |
|           | research  | , |       | Ince   |          | contract       |
|           | with ENs  | 2 |       | ntives |          |                |
|           | on AOI    | 0 |       | (AOI)  |          |                |
|           | issues    | 0 |       | Study  |          |                |
|           | including | 2 |       |        |          |                |
|           | payments  |   |       |        |          |                |
|           | and wages |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| SSA       | Implement | J |       | Ad     | Comm     | Discontinued   |
| infra     | the       | u |       | visory | issioner | ESR position,  |
| structure | E         | l |       | Letter |          | created the    |
|           | mployment | y |       |        |          | AWIC position  |
|           | Support   | 1 |       |        |          | with 58 staff. |
|           | Repre     | , |       |        |          |                |
|           | sentative | 2 |       |        |          |                |
|           | position  | 0 |       |        |          |                |
|           | in SSA    | 0 |       |        |          |                |
|           | Field     | 2 |       |        |          |                |
|           | Offices   |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| \$1 for   | \$1 to    | A |       | Advice | Comm     | Request for    |
| \$2 Demo  | \$2       | u |       | Report | issioner | information    |
|           | demo      | g |       | on \$1 |          | published      |
|           | nstration | u |       | for    |          | September 2003 |
|           | for       | s |       | \$2    |          |                |
|           | current   | t |       | B      |          |                |
|           | benef     | 2 |       | enefit |          |                |
|           | iciaries: | 0 |       | Offset |          |                |
|           | Panel     | 0 |       | Re     |          |                |
|           | endorses  | 2 |       | search |          |                |
|           | using     |   |       |        |          |                |
|           | demo      |   |       |        |          |                |
|           | projects  |   |       |        |          |                |
|           | for \$1   |   |       |        |          |                |
|           | for \$2   |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| Ticket    | Apply for | D |       | Ad     | Comm.    | Final          |
| access    | EXR -     | e |       | visory |          | regulations    |
|           | clarify   | c |       | Letter |          | Sept. 2005     |
|           | special   | . |       | [Re]{  |          | provided       |
|           | circ      | 1 |       | .under |          | examples.      |
|           | umstances | 8 |       | line}. |          |                |
|           | by        | , |       | NPRM   |          |                |
|           | example   | 2 |       | Oct.   |          |                |
|           |           | 0 |       | 2003   |          |                |
|           |           | 0 |       | on the |          |                |
|           |           | 3 |       | R      |          |                |
|           |           |   |       | einsta |          |                |
|           |           |   |       | tement |          |                |
|           |           |   |       | of     |          |                |
|           |           |   |       | Entit  |          |                |
|           |           |   |       | lement |          |                |
|           |           |   |       | to     |          |                |
|           |           |   |       | Disa   |          |                |
|           |           |   |       | bility |          |                |
|           |           |   |       | Be     |          |                |
|           |           |   |       | nefits |          |                |
|           |           |   |       | (EXR)  |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| Ticket    | E         | D |       | Ad     | Comm     | Final          |
| access    | xplicitly | e |       | visory | issioner | regulations    |
|           | state     | c |       | Letter |          | Sept. 2005     |
|           | that a    | . |       | [Re]{  |          | stated "if you |
|           | person    | 1 |       | .under |          | are reinstated |
|           | entitled  | 8 |       | line}. |          | under the      |
|           | to        | , |       | NPRM   |          | **ex.**        |
|           | benefits  | 2 |       | Oct.   |          | **r            |
|           | pursuant  | 0 |       | 2003   |          | einstatement** |
|           | to        | 0 |       | on the |          |                |
|           | expedited | 3 |       | R      |          | prov., under   |
|           | rein      |   |       | einsta |          | Sec.           |
|           | statement |   |       | tement |          | **404**.1592b  |
|           | is        |   |       | of     |          | through        |
|           | im        |   |       | Entit  |          | **404**.1592f  |
|           | mediately |   |       | lement |          | or Sec. Sec.   |
|           | eligible  |   |       | to     |          |                |
|           | for a     |   |       | Disa   |          | **416**.999 -  |
|           | ticket    |   |       | bility |          | **416**.999d,  |
|           |           |   |       | Be     |          | you may be     |
|           |           |   |       | nefits |          | eligible for a |
|           |           |   |       | (EXR)  |          | new ticket     |
|           |           |   |       |        |          | under Sec.     |
|           |           |   |       |        |          | 411.125(c)"    |
|           |           |   |       |        |          | (ticket        |
|           |           |   |       |        |          | eligibility).  |
+-----------+-----------+---+-------+--------+----------+----------------+
| E         | E         | A |       | Ad     | Comm     | Discontinued   |
| mployment | mployment | u |       | visory | issioner | ESR position;  |
| Support   | Support   | g |       | Panel  |          | created the    |
| Reps/AWIC | Repres    | u |       | Annual |          | AWIC position  |
|           | entatives | s |       | R      |          | with 58 staff. |
|           | (ESR):    | t |       | eport: |          |                |
|           | The       | 2 |       | Year   |          |                |
|           | statute   | 0 |       | Two    |          |                |
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|           | "The      | 2 |       |        |          |                |
|           | Com       |   |       |        |          |                |
|           | missioner |   |       |        |          |                |
|           | should    |   |       |        |          |                |
|           | establish |   |       |        |          |                |
|           | a corps   |   |       |        |          |                |
|           | of        |   |       |        |          |                |
|           | trained,  |   |       |        |          |                |
|           | ac        |   |       |        |          |                |
|           | cessible, |   |       |        |          |                |
|           | and       |   |       |        |          |                |
|           | r         |   |       |        |          |                |
|           | esponsive |   |       |        |          |                |
|           | work      |   |       |        |          |                |
|           | i         |   |       |        |          |                |
|           | ncentives |   |       |        |          |                |
|           | sp        |   |       |        |          |                |
|           | ecialists |   |       |        |          |                |
|           | within    |   |       |        |          |                |
|           | the       |   |       |        |          |                |
|           | Social    |   |       |        |          |                |
|           | Security  |   |       |        |          |                |
|           | Adminis   |   |       |        |          |                |
|           | tration." |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| Marketing | SSA       | A |       | Ad     | Comm     | Awarded        |
| and       | should    | u |       | visory | issioner | contracts in\  |
| public    | im        | g |       | Panel  |          | 2003 to        |
| education | mediately | u |       | Annual |          | analyze data   |
|           | implement | s |       | R      |          | collected from |
|           | a         | t |       | eport: |          | ENs, to        |
|           | national  | 2 |       | Year   |          | develop        |
|           | marketing | 0 |       | Two    |          | strategies to  |
|           | and       | 0 |       |        |          | increase EN    |
|           | public    | 2 |       |        |          | participation, |
|           | in        |   |       |        |          | and to develop |
|           | formation |   |       |        |          | a strat.       |
|           | program   |   |       |        |          | marketing plan |
|           |           |   |       |        |          | targeted at    |
|           |           |   |       |        |          | beneficiaries  |
|           |           |   |       |        |          | by the end of  |
|           |           |   |       |        |          | FY 04; third   |
|           |           |   |       |        |          | contract to    |
|           |           |   |       |        |          | analyze        |
|           |           |   |       |        |          | beneficiary    |
|           |           |   |       |        |          | data and       |
|           |           |   |       |        |          | develop a plan |
|           |           |   |       |        |          | for maximizing |
|           |           |   |       |        |          | participation  |
|           |           |   |       |        |          | of             |
|           |           |   |       |        |          | beneficiaries. |
|           |           |   |       |        |          | Awarded        |
|           |           |   |       |        |          | contract in    |
|           |           |   |       |        |          | 2005 to        |
|           |           |   |       |        |          | develop        |
|           |           |   |       |        |          | marketing and  |
|           |           |   |       |        |          | outreach       |
|           |           |   |       |        |          | strategy --    |
|           |           |   |       |        |          | still being    |
|           |           |   |       |        |          | developed      |
+-----------+-----------+---+-------+--------+----------+----------------+
| EN --     | EN        | A |       | Ad     | Comm     | SSA interprets |
| payment   | reim      | u |       | visory | issioner | "benefits not  |
|           | bursement | g |       | Panel  |          | payable" as    |
|           | for       | u |       | Annual |          | zero benefits  |
|           | clients   | s |       | R      |          |                |
|           | receiving | t |       | eport: |          |                |
|           | partial   | 2 |       | Year   |          |                |
|           | benefits  | 0 |       | Two    |          |                |
|           |           | 0 |       |        |          |                |
|           |           | 2 |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| CDR       | Request   | S |       | Ad     | Comm     | Clarified in   |
| p         | Commis    | e |       | visory | issioner | final          |
| rotection | sioner\'s | p |       | Letter |          | regulations    |
|           | support   | t |       | [Re.]  |          | June 2005      |
|           | of        | . |       | {.unde |          |                |
|           | Panel\'s  | 2 |       | rline} |          |                |
|           | recom     | 0 |       | NPRM   |          |                |
|           | mendation | 0 |       | Aug.   |          |                |
|           | to        | 3 |       | 2003   |          |                |
|           | Congress  |   |       | on     |          |                |
|           | to extend |   |       | Contin |          |                |
|           | ticket    |   |       | uation |          |                |
|           | CDR       |   |       | of     |          |                |
|           | p         |   |       | B      |          |                |
|           | rotection |   |       | enefit |          |                |
|           | to any    |   |       | Pa     |          |                |
|           | and all   |   |       | yments |          |                |
|           | bene      |   |       |        |          |                |
|           | ficiaries |   |       |        |          |                |
|           | who are   |   |       |        |          |                |
|           | part      |   |       |        |          |                |
|           | icipating |   |       |        |          |                |
|           | in an     |   |       |        |          |                |
|           | approved  |   |       |        |          |                |
|           | program   |   |       |        |          |                |
|           | of VR     |   |       |        |          |                |
|           | services, |   |       |        |          |                |
|           | e         |   |       |        |          |                |
|           | mployment |   |       |        |          |                |
|           | services, |   |       |        |          |                |
|           | or other  |   |       |        |          |                |
|           | e         |   |       |        |          |                |
|           | mployment |   |       |        |          |                |
|           | support   |   |       |        |          |                |
|           | services  |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| Post      | Clarify   | S |       | Ad     | Comm     | Final          |
| en        | that      | e |       | visory | issioner | regulations    |
| titlement | par       | p |       | Letter |          | June 2005      |
| benefits  | ticipants | t |       | [Re.]  |          |                |
|           | in other  | . |       | {.unde |          |                |
|           | approved  | 2 |       | rline} |          |                |
|           | rehab     | 0 |       | NPRM   |          |                |
|           | ilitation | 0 |       | Aug.   |          |                |
|           | plans are | 3 |       | 2003   |          |                |
|           | eligible  |   |       | on     |          |                |
|           | for       |   |       | Contin |          |                |
|           | con       |   |       | uation |          |                |
|           | tinuation |   |       | of     |          |                |
|           | of        |   |       | B      |          |                |
|           | benefits  |   |       | enefit |          |                |
|           |           |   |       | Pa     |          |                |
|           |           |   |       | yments |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| EN        | Once      | F |       | Advice | Comm     | In 2003, SSA   |
|           | be        | e |       | Report | issioner | initiated a    |
|           | neficiary | b |       | on     |          | quarterly      |
|           | is        | . |       | Empl   |          | regime for     |
|           | certified | 2 |       | oyment |          | paying ENs     |
|           | as        | 0 |       | Ne     |          | that usually   |
|           | employed, | 0 |       | tworks |          | would not      |
|           | Com       | 4 |       |        |          | require        |
|           | missioner |   |       |        |          | reporting      |
|           | should    |   |       |        |          | earnings       |
|           | continue  |   |       |        |          |                |
|           | to pay    |   |       |        |          |                |
|           | the EN on |   |       |        |          |                |
|           | a monthly |   |       |        |          |                |
|           | basis     |   |       |        |          |                |
|           | unless    |   |       |        |          |                |
|           | be        |   |       |        |          |                |
|           | neficiary |   |       |        |          |                |
|           | status    |   |       |        |          |                |
|           | changes   |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| Marketing | SSA       | M |       | Annual | Comm     | Partially -    |
|           | notify    | a |       | R      | issioner | did follow up  |
|           | bene      | y |       | eport: |          | after all      |
|           | ficiaries | 2 |       | Yr. 5, |          | phase ins      |
|           | at least  | 0 |       | Ad     |          | completed but  |
|           | once a    | 0 |       | visory |          | not annually   |
|           | year      | 4 |       | Letter |          |                |
|           | until SSA |   |       |        |          |                |
|           | has fully |   |       |        |          |                |
|           | im        |   |       |        |          |                |
|           | plemented |   |       |        |          |                |
|           | c         |   |       |        |          |                |
|           | ontinuous |   |       |        |          |                |
|           | public    |   |       |        |          |                |
|           | education |   |       |        |          |                |
|           | and       |   |       |        |          |                |
|           | marketing |   |       |        |          |                |
|           | campaigns |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| BPAO      | Require   | F |       | Annual | A        | In RFA,        |
|           | M         | e |       | R      | ssociate | management     |
|           | anagement | b |       | eport: | Comm     | information    |
|           | In        | . |       | Yr. 6, | issioner | data           |
|           | formation | 2 |       | Ad     |          | collection     |
|           | reports   | 0 |       | visory |          | must include   |
|           | to        | 0 |       | Letter |          | the data       |
|           | include   | 5 |       |        |          | element of     |
|           | data on   |   |       |        |          | beneficiary\'s |
|           | be        |   |       |        |          | waiting time   |
|           | neficiary |   |       |        |          | for a response |
|           | waiting   |   |       |        |          |                |
|           | times for |   |       |        |          |                |
|           | a         |   |       |        |          |                |
|           | response, |   |       |        |          |                |
|           | an        |   |       |        |          |                |
|           | ap        |   |       |        |          |                |
|           | pointment |   |       |        |          |                |
|           | and for   |   |       |        |          |                |
|           | services  |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| BPAO      | Provide   | F |       | Annual | A        | In RFA, in     |
|           | special   | e |       | R      | ssociate | selecting      |
|           | cons      | b |       | eport: | Comm     | eligible       |
|           | ideration | . |       | Yr. 6, | issioner | applicants to  |
|           | to        | 2 |       | Ad     |          | be funded,     |
|           | proposals | 0 |       | visory |          | consideration  |
|           | that      | 0 |       | Letter |          | may be given   |
|           | develop   | 5 |       |        |          | to issues such |
|           | workable  |   |       |        |          | as experience, |
|           | ways to   |   |       |        |          | past           |
|           | ef        |   |       |        |          | performance,   |
|           | fectively |   |       |        |          | proposed       |
|           | deal with |   |       |        |          | costs, etc.    |
|           | limited   |   |       |        |          |                |
|           | r         |   |       |        |          |                |
|           | esources. |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| BPAO      | Require   | F |       | Annual | A        | In RFA, the    |
|           | BPA&O     | e |       | R      | ssociate | applicants     |
|           | programs  | b |       | eport: | Comm     | must also      |
|           | to state  | . |       | Yr. 6, | issioner | describe how   |
|           | how they  | 2 |       | Ad     |          | they will      |
|           | will      | 0 |       | visory |          | address any    |
|           | target    | 0 |       | Letter |          | special        |
|           | and serve | 5 |       |        |          | cultural       |
|           | transi    |   |       |        |          | requirements   |
|           | tion-aged |   |       |        |          | of pops (e.g., |
|           | youth.    |   |       |        |          | Native         |
|           |           |   |       |        |          | Americans)     |
|           |           |   |       |        |          | within the     |
|           |           |   |       |        |          | targeted geo.  |
|           |           |   |       |        |          | area, as well  |
|           |           |   |       |        |          | as non-English |
|           |           |   |       |        |          | speaking pops  |
|           |           |   |       |        |          | and SSI bens.  |
|           |           |   |       |        |          | as young as    |
|           |           |   |       |        |          | age 14. Each   |
|           |           |   |       |        |          | project must   |
|           |           |   |       |        |          | make WIPA      |
|           |           |   |       |        |          | services       |
|           |           |   |       |        |          | available to   |
|           |           |   |       |        |          | SSI            |
|           |           |   |       |        |          | beneficiaries  |
|           |           |   |       |        |          | as young as    |
|           |           |   |       |        |          | age 14 and     |
|           |           |   |       |        |          | state how they |
|           |           |   |       |        |          | will target    |
|           |           |   |       |        |          | and serve      |
|           |           |   |       |        |          | t              |
|           |           |   |       |        |          | ransition-aged |
|           |           |   |       |        |          | youth. Where   |
|           |           |   |       |        |          | applicable,    |
|           |           |   |       |        |          | applicants     |
|           |           |   |       |        |          | must indicate  |
|           |           |   |       |        |          | the ability to |
|           |           |   |       |        |          | work closely   |
|           |           |   |       |        |          | with the SSA   |
|           |           |   |       |        |          | Youth          |
|           |           |   |       |        |          | Transition     |
|           |           |   |       |        |          | Process        |
|           |           |   |       |        |          | Demonstration  |
|           |           |   |       |        |          | (YTD) projects |
|           |           |   |       |        |          | that are       |
|           |           |   |       |        |          | currently      |
|           |           |   |       |        |          | located in     |
|           |           |   |       |        |          | California,    |
|           |           |   |       |        |          | Colorado,      |
|           |           |   |       |        |          | Iowa, New      |
|           |           |   |       |        |          | York, Maryland |
|           |           |   |       |        |          | and            |
|           |           |   |       |        |          | Mississippi    |
+-----------+-----------+---+-------+--------+----------+----------------+
| BPAO      | Require   | F |       | Annual | A        | In RFA,        |
|           | BPA&O     | e |       | R      | ssociate | awardees must  |
|           | programs  | b |       | eport: | Comm     | state how they |
|           | to state  | . |       | Yr. 6, | issioner | will ensure    |
|           | how they  | 2 |       | Ad     |          | equitable      |
|           | will      | 0 |       | visory |          | access and     |
|           | ensure    | 0 |       | Letter |          | services for   |
|           | equitable | 5 |       |        |          | all            |
|           | access to |   |       |        |          | beneficiary    |
|           | and       |   |       |        |          | disability     |
|           | services  |   |       |        |          | groups. This   |
|           | for all   |   |       |        |          | requirement    |
|           | d         |   |       |        |          | may be met by  |
|           | isability |   |       |        |          | partnering     |
|           | groups    |   |       |        |          | with other     |
|           | r         |   |       |        |          | c              |
|           | egardless |   |       |        |          | ommunity-based |
|           | of their  |   |       |        |          | organizations  |
|           | primary   |   |       |        |          |                |
|           | agency\'s |   |       |        |          |                |
|           | af        |   |       |        |          |                |
|           | filiation |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| BPAO      | Require   | F |       | Annual | A        | In RFA,        |
|           | BPA&O     | e |       | R      | ssociate | applicants who |
|           | programs  | b |       | eport: | Comm     | serve tribal   |
|           | that      | . |       | Yr. 6, | issioner | lands and      |
|           | cover     | 2 |       | Ad     |          | sovereign      |
|           | tribal    | 0 |       | visory |          | nations must   |
|           | lands and | 0 |       | Letter |          | also provide   |
|           | sovereign | 5 |       |        |          | documentation  |
|           | nations   |   |       |        |          | of how they    |
|           | to        |   |       |        |          | will ensure    |
|           | provide   |   |       |        |          | equitable      |
|           | clear and |   |       |        |          | access and     |
|           | c         |   |       |        |          | services for   |
|           | onvincing |   |       |        |          | N              |
|           | docu      |   |       |        |          | ative-American |
|           | mentation |   |       |        |          | and            |
|           | of how    |   |       |        |          | Alaskan-Native |
|           | they will |   |       |        |          | populations.   |
|           | ensure    |   |       |        |          | Applicants     |
|           | equitable |   |       |        |          | must indicate  |
|           | access    |   |       |        |          | if formal      |
|           | and       |   |       |        |          | agreements     |
|           | services  |   |       |        |          | with tribal    |
|           | for       |   |       |        |          | govts or       |
|           | Native    |   |       |        |          | Section 121 VR |
|           | American  |   |       |        |          | Programs, etc. |
|           | and AK    |   |       |        |          | are in place   |
|           | Native    |   |       |        |          |                |
|           | pop       |   |       |        |          |                |
|           | ulations. |   |       |        |          |                |
|           | Examples  |   |       |        |          |                |
|           | of this   |   |       |        |          |                |
|           | might be  |   |       |        |          |                |
|           | formal    |   |       |        |          |                |
|           | a         |   |       |        |          |                |
|           | greements |   |       |        |          |                |
|           | with      |   |       |        |          |                |
|           | Tribal    |   |       |        |          |                |
|           | govt,     |   |       |        |          |                |
|           | Section   |   |       |        |          |                |
|           | 121 VR    |   |       |        |          |                |
|           | Programs, |   |       |        |          |                |
|           | etc.      |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| BPAO      | Increase  | F |       | Annual | A        | In RFA, upon   |
|           | the       | e |       | R      | ssociate | award, the     |
|           | duration  | b |       | eport: | Comm     | WIPA           |
|           | of the    | . |       | Yr. 6, | issioner | cooperative    |
|           | initial   | 2 |       | Ad     |          | agreement      |
|           | five-day  | 0 |       | visory |          | awardees       |
|           | training  | 0 |       | Letter |          | shall:         |
|           | session   | 5 |       |        |          |                |
|           | to        |   |       |        |          | Employ CWICs   |
|           | real      |   |       |        |          | and require    |
|           | istically |   |       |        |          | them to        |
|           | reflect   |   |       |        |          | complete an    |
|           | the       |   |       |        |          | approved       |
|           | breadth   |   |       |        |          | initial four   |
|           | and       |   |       |        |          | day training   |
|           | c         |   |       |        |          | session within |
|           | omplexity |   |       |        |          | 3 months of    |
|           | of the    |   |       |        |          | award. SSA, or |
|           | SSA\'s    |   |       |        |          | its designated |
|           | d         |   |       |        |          | technical      |
|           | isability |   |       |        |          | assistance and |
|           | programs  |   |       |        |          | training       |
|           | including |   |       |        |          | contractor,    |
|           | the       |   |       |        |          | will provide   |
|           | Ticket to |   |       |        |          | technical      |
|           | Work      |   |       |        |          | assistance and |
|           | program   |   |       |        |          | training to    |
|           | and other |   |       |        |          | WIPA projects  |
|           | relevant  |   |       |        |          | about SSA\'s   |
|           | federal   |   |       |        |          | programs and   |
|           | programs. |   |       |        |          | work           |
|           |           |   |       |        |          | incentives     |
|           |           |   |       |        |          | (e.g., TWP,    |
|           |           |   |       |        |          | EPE, IRWE,     |
|           |           |   |       |        |          | PASS, 1619(a)  |
|           |           |   |       |        |          | and (b), and   |
|           |           |   |       |        |          | Medicaid       |
|           |           |   |       |        |          | Buy-In         |
|           |           |   |       |        |          | provisions/    |
|           |           |   |       |        |          |                |
|           |           |   |       |        |          | Balanced       |
|           |           |   |       |        |          | Budget Act;    |
|           |           |   |       |        |          | Medicare and   |
|           |           |   |       |        |          | Medicaid; and  |
|           |           |   |       |        |          | on other       |
|           |           |   |       |        |          | Federal work   |
|           |           |   |       |        |          | incentives     |
|           |           |   |       |        |          | programs.      |
+-----------+-----------+---+-------+--------+----------+----------------+
| BPAO      | Establish | F |       | Annual | A        | In RFA,        |
|           | minimum   | e |       | R      | ssociate | applicants     |
|           | quali     | b |       | eport: | Comm     | must ensure    |
|           | fications | . |       | Yr. 6, | issioner | that CWICs     |
|           | for new   | 2 |       | Ad     |          | have the       |
|           | Benefit   | 0 |       | visory |          | skills         |
|           | Sp        | 0 |       | Letter |          | required to    |
|           | ecialists | 5 |       |        |          | provide work   |
|           | and       |   |       |        |          | incentives     |
|           | t         |   |       |        |          | planning and   |
|           | imeframes |   |       |        |          | assistance     |
|           | for       |   |       |        |          | services that  |
|           | c         |   |       |        |          | assist         |
|           | onducting |   |       |        |          | beneficiaries. |
|           | training  |   |       |        |          | WIPA awardees  |
|           | about     |   |       |        |          | will be        |
|           | State and |   |       |        |          | required to    |
|           | local     |   |       |        |          | provide        |
|           | programs. |   |       |        |          | documentation  |
|           |           |   |       |        |          | to SSA that    |
|           |           |   |       |        |          | CWIC personnel |
|           |           |   |       |        |          | meet the       |
|           |           |   |       |        |          | requirements   |
|           |           |   |       |        |          | below. SSA     |
|           |           |   |       |        |          | will use this  |
|           |           |   |       |        |          | documentation  |
|           |           |   |       |        |          | to credential  |
|           |           |   |       |        |          | CWIC personnel |
|           |           |   |       |        |          | before they    |
|           |           |   |       |        |          | may begin      |
|           |           |   |       |        |          | providing      |
|           |           |   |       |        |          | beneficiary    |
|           |           |   |       |        |          | services. WIPA |
|           |           |   |       |        |          | awardees must  |
|           |           |   |       |        |          | provide        |
|           |           |   |       |        |          | training and   |
|           |           |   |       |        |          | technical      |
|           |           |   |       |        |          | assistance to  |
|           |           |   |       |        |          | their CWICs    |
|           |           |   |       |        |          | about          |
|           |           |   |       |        |          | applicable     |
|           |           |   |       |        |          | State and      |
|           |           |   |       |        |          | local programs |
|           |           |   |       |        |          | and the        |
|           |           |   |       |        |          | effects that   |
|           |           |   |       |        |          | these programs |
|           |           |   |       |        |          | have on other  |
|           |           |   |       |        |          | programs\'     |
|           |           |   |       |        |          | eligibility    |
|           |           |   |       |        |          | and benefits   |
+-----------+-----------+---+-------+--------+----------+----------------+
| BPAO      | Require   | F |       | Annual | A        | In RFA,        |
|           | that      | e |       | R      | ssociate | provide a      |
|           | BPA&O     | b |       | eport: | Comm     | written        |
|           | programs  | . |       | Yr. 6, | issioner | Quality        |
|           | have a    | 2 |       | Ad     |          | Assurance (QA) |
|           | quality   | 0 |       | visory |          | plan that      |
|           | assurance | 0 |       | Letter |          | demonstrates   |
|           | plan that | 5 |       |        |          | the efficacy   |
|           | is in     |   |       |        |          | of the service |
|           | alignment |   |       |        |          | delivery plan. |
|           | with      |   |       |        |          |                |
|           | standards |   |       |        |          |                |
|           | set by    |   |       |        |          |                |
|           | the       |   |       |        |          |                |
|           | Agency    |   |       |        |          |                |
|           | and that  |   |       |        |          |                |
|           | a         |   |       |        |          |                |
|           | grievance |   |       |        |          |                |
|           | procedure |   |       |        |          |                |
|           | be        |   |       |        |          |                |
|           | es        |   |       |        |          |                |
|           | tablished |   |       |        |          |                |
|           | within    |   |       |        |          |                |
|           | each      |   |       |        |          |                |
|           | BPA&O     |   |       |        |          |                |
|           | program.  |   |       |        |          |                |
|           | Require   |   |       |        |          |                |
|           | that      |   |       |        |          |                |
|           | evidence  |   |       |        |          |                |
|           | of        |   |       |        |          |                |
|           | c         |   |       |        |          |                |
|           | ompliance |   |       |        |          |                |
|           | with this |   |       |        |          |                |
|           | plan be   |   |       |        |          |                |
|           | submitted |   |       |        |          |                |
|           | r         |   |       |        |          |                |
|           | egularly. |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| BPAO      | Require   | F |       | Annual | A        | In RFA,        |
|           | that      | e |       | R      | ssociate | \[Applicants   |
|           | BPA&O     | b |       | eport: | Comm     | must           |
|           | programs  | . |       | Yr. 6, | issioner | establish\]    |
|           | notify    | 2 |       | Ad     |          | ...written     |
|           | bene      | 0 |       | visory |          | grievance      |
|           | ficiaries | 0 |       | Letter |          | procedures for |
|           | of the    | 5 |       |        |          | beneficiaries  |
|           | es        |   |       |        |          | and evidence   |
|           | tablished |   |       |        |          | of its         |
|           | grievance |   |       |        |          | compliance     |
|           | procedure |   |       |        |          | which will be  |
|           | and the   |   |       |        |          | submitted to   |
|           | ava       |   |       |        |          | SSA quarterly. |
|           | ilability |   |       |        |          | (NOTE: No      |
|           | of PABSS  |   |       |        |          | reference to   |
|           | services. |   |       |        |          | dissemination  |
|           |           |   |       |        |          | of procedure   |
|           |           |   |       |        |          | to             |
|           |           |   |       |        |          | beneficiaries) |
+-----------+-----------+---+-------+--------+----------+----------------+
| BPAO      | Require   | F |       | Annual | A        | In RFA,        |
|           | data      | e |       | R      | ssociate | projects will  |
|           | c         | b |       | eport: | Comm     | collect,       |
|           | ollection | . |       | Yr. 6, | issioner | analyze, and   |
|           | s         | 2 |       | Ad     |          | summarize the  |
|           | trategies | 0 |       | visory |          | specific data  |
|           | to        | 0 |       | Letter |          | elements       |
|           | provide a | 5 |       |        |          | listed below:  |
|           | full      |   |       |        |          |                |
|           | picture   |   |       |        |          | A. Beneficiary |
|           | of the    |   |       |        |          | info           |
|           | benefits  |   |       |        |          |                |
|           | c         |   |       |        |          | B. Employment  |
|           | ounseling |   |       |        |          | info and       |
|           | process   |   |       |        |          | Outcomes       |
|           | (rather   |   |       |        |          | (current and   |
|           | than      |   |       |        |          | proposed       |
|           | snapshots |   |       |        |          | goals\--when   |
|           | of the    |   |       |        |          | applicable)    |
|           | indi      |   |       |        |          |                |
|           | vidual\'s |   |       |        |          | C. Program     |
|           | journey)  |   |       |        |          | Manager for    |
|           | and       |   |       |        |          | Recruitment    |
|           | address   |   |       |        |          | and Outreach   |
|           | the       |   |       |        |          | (PMRO)         |
|           | ident     |   |       |        |          | Activities     |
|           | ification |   |       |        |          |                |
|           | or        |   |       |        |          | D. Benefits:   |
|           | r         |   |       |        |          | (current and   |
|           | esolution |   |       |        |          | expected       |
|           | of        |   |       |        |          | changes if     |
|           | barriers  |   |       |        |          | employment     |
|           | and the   |   |       |        |          | goals are      |
|           | outcomes  |   |       |        |          | reached)       |
|           | achieved  |   |       |        |          |                |
|           | by the    |   |       |        |          | E. Incentives  |
|           | i         |   |       |        |          | to be used:    |
|           | ndividual |   |       |        |          |                |
|           |           |   |       |        |          | F. Services to |
|           |           |   |       |        |          | be used        |
|           |           |   |       |        |          |                |
|           |           |   |       |        |          | G. Monthly     |
|           |           |   |       |        |          | WIPA           |
|           |           |   |       |        |          | activities     |
|           |           |   |       |        |          | performed      |
+-----------+-----------+---+-------+--------+----------+----------------+
| BPAO      | Require   | F |       | Annual | A        | In RFA, were   |
|           | BPA&O     | e |       | R      | ssociate | encouraged to  |
|           | programs  | b |       | eport: | Comm     | collaborate.   |
|           | to have   | . |       | Yr. 6, | issioner |                |
|           | a         | 2 |       | Ad     |          |                |
|           | greements | 0 |       | visory |          |                |
|           | with ENs, | 0 |       | Letter |          |                |
|           | and also  | 5 |       |        |          |                |
|           | D         |   |       |        |          |                |
|           | isability |   |       |        |          |                |
|           | Program   |   |       |        |          |                |
|           | Na        |   |       |        |          |                |
|           | vigators, |   |       |        |          |                |
|           | in their  |   |       |        |          |                |
|           | g         |   |       |        |          |                |
|           | eographic |   |       |        |          |                |
|           | catchment |   |       |        |          |                |
|           | area to   |   |       |        |          |                |
|           | promote   |   |       |        |          |                |
|           | positive  |   |       |        |          |                |
|           | working   |   |       |        |          |                |
|           | relat     |   |       |        |          |                |
|           | ionships. |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| PASS      | Panel     | J |       | Annual | Comm     | Did not adopt; |
|           | supported | u |       | R      | issioner | however, it    |
| Occ       | con       | l |       | eport: |          | added language |
| upational | tinuation | y |       | Yr. 6, |          | defining       |
|           | of        | 2 |       | Ad     |          | feasible       |
| Goals     | cred      | 0 |       | visory |          | employment     |
|           | entialing | 0 |       | Letter |          | goal as "is    |
|           | policy.   | 5 |       | [Re.]  |          | one that you   |
|           | However,  |   |       | {.unde |          | have a         |
|           | re        |   |       | rline} |          | reasonable     |
|           | commended |   |       | NPRM   |          | likelihood of  |
|           | SSA       |   |       | July   |          | achieving."    |
|           | clarify   |   |       | 11,    |          | And it created |
|           | what      |   |       | 2005   |          | two new        |
|           | weight,   |   |       |        |          | sections to    |
|           | if any,   |   |       |        |          | explain "a     |
|           | will be   |   |       |        |          | viable plan".  |
|           | given to  |   |       |        |          |                |
|           | occ       |   |       |        |          |                |
|           | upational |   |       |        |          |                |
|           | goals     |   |       |        |          |                |
|           | developed |   |       |        |          |                |
|           | with      |   |       |        |          |                |
|           | a         |   |       |        |          |                |
|           | ssistance |   |       |        |          |                |
|           | of BPAOs  |   |       |        |          |                |
|           | and       |   |       |        |          |                |
|           | others,   |   |       |        |          |                |
|           | for       |   |       |        |          |                |
|           | example,  |   |       |        |          |                |
|           | Small     |   |       |        |          |                |
|           | Business  |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| PASS      | SSA       | J |       | Annual | Comm     | SSA partially  |
|           | provide   | u |       | R      | issioner | adopted the    |
| D         | more      | l |       | eport: |          | Panel's        |
| ependence | clarity   | y |       | Yr. 6, |          | recommendation |
| on SSI    | regarding | 2 |       | Ad     |          | by providing   |
|           | how much  | 0 |       | visory |          | examples as a  |
|           | of a      | 0 |       | Letter |          | means of       |
|           | reduction | 5 |       | [Re.]  |          | clarification  |
|           | is        |   |       | {.unde |          | of the meaning |
|           | "sub      |   |       | rline} |          | of             |
|           | stantial" |   |       | NPRM   |          | "substantial"  |
|           | and then  |   |       | July   |          |                |
|           | ensure    |   |       | 11,    |          |                |
|           | that this |   |       | 2005   |          |                |
|           | criterion |   |       |        |          |                |
|           | is        |   |       |        |          |                |
|           | con       |   |       |        |          |                |
|           | sistently |   |       |        |          |                |
|           | im        |   |       |        |          |                |
|           | plemented |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| Admin.    | Resources | O |       | Annual | Comm     | Without        |
| Review    | to        | c |       | R      | issioner | specifically   |
| Process   | establish | t |       | eport: |          | addressing the |
| --        | the       | . |       | Yr. 6, |          | Panel's        |
| D         | dedicated | 2 |       | Ad     |          | r              |
| isability | Quick     | 0 |       | visory |          | ecommendation, |
| Claims    | D         | 0 |       | Letter |          | it appears     |
|           | isability | 5 |       | [Re.]  |          | that the Final |
|           | Dete      |   |       | {.unde |          | Rule is        |
|           | rmination |   |       | rline} |          | consistent     |
|           | units are |   |       | NPRM   |          | with this      |
|           | not       |   |       | July   |          | r              |
|           | diverted  |   |       | 27,    |          | ecommendation. |
|           | from the  |   |       | 2005   |          | The goal is to |
|           | resources |   |       |        |          | enhance        |
|           | necessary |   |       |        |          | productivity   |
|           | for       |   |       |        |          | throughout the |
|           | adj       |   |       |        |          | system, so     |
|           | udicating |   |       |        |          | resources can  |
|           | more      |   |       |        |          | be available   |
|           | difficult |   |       |        |          | for all cases  |
|           | cases in  |   |       |        |          | as needed      |
|           | a timely  |   |       |        |          |                |
|           | manor     |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+
| Admin.    | Time      | O |       | Annual | Comm     | SSA has        |
| Review    | periods   | c |       | R      | issioner | lengthened the |
| Process   | for       | t |       | eport: |          | period of time |
| --        | in        | . |       | Yr. 6, |          | permitted for  |
| D         | troducing | 2 |       | Ad     |          | introducing    |
| isability | evidence  | 0 |       | visory |          | evidence.      |
| Claims    | for the   | 0 |       | Letter |          |                |
|           | record:   | 5 |       | [Re.]  |          |                |
|           | The rules |   |       | {.unde |          |                |
|           | should    |   |       | rline} |          |                |
|           | require   |   |       | NPRM   |          |                |
|           | greater   |   |       | July   |          |                |
|           | clarity   |   |       | 27,    |          |                |
|           | in terms  |   |       | 2005   |          |                |
|           | of what   |   |       |        |          |                |
|           | co        |   |       |        |          |                |
|           | nstitutes |   |       |        |          |                |
|           | \"just    |   |       |        |          |                |
|           | cause.\"  |   |       |        |          |                |
+-----------+-----------+---+-------+--------+----------+----------------+

 

[]{#__RefHeading___Toc185405225 .anchor}Appendix D

## Panel Outreach 2001-2007 {#panel-outreach-2001-2007 .Annual-Report-Heading-2}

##  {#section-8 .Annual-Report-Heading-2}

  -----------------------------------------------------------------------
  Outreach Event                                   Date
  ------------------------------------------------ ----------------------
  Panel website and listserv created               2001 -- 2002

  Regional meetings held in Arizona, Georgia,      January - February
  Minnesota, and California -- Panel Event         2001

  Experts Roundtable -- Panel held regarding       July 27, 2001
  design of the Adequacy of Incentives Study.      

  Experts Roundtable -- Panel held regarding SSA's November 16, 2001
  plan for evaluating the effects of \$1 for \$2   
  benefit offset current beneficiaries and on      
  induced entry.                                   

  National Workforce Inclusion Conference. Panel   March 2002
  members participated in two presentations: legal 
  issues in implementation of the regulations, and 
  ENs and the Ticket to Work program.              

  Employment Network Summit -- Panel Event         May 2003

  **SSI/SSDI Consumer Panel**                      February 2004
                                                   Quarterly Panel
                                                   Meeting

  **Florida TWWIIA Programs and Projects Panel**   February 2004
                                                   Quarterly Panel
                                                   Meeting

  **Consumer Panel - Delaware, Virginia,           May 2004 Quarterly
  Maryland**                                       Panel Meeting

  **Public Transportation and ADA Experts Panel**  May 2004 Quarterly
                                                   Panel Meeting

  **EN Presentation on Ticket to Work Program**    May 2004 Quarterly
                                                   Panel Meeting

  **Public Housing Experts Panel**                 May 2004 Quarterly
                                                   Panel Meeting

  **California Consumer Panel**                    August 2004 Quarterly
                                                   Panel Meeting

  **California Workforce Inclusion Panel**         August 2004 Quarterly
                                                   Panel Meeting

  **Public Roundtable Discussion**                 August 2004 Quarterly
                                                   Panel Meeting

  Medicaid Buy-In Panel                            February 2005
                                                   Quarterly Panel
                                                   Meeting

  Louisiana Consumer Panel                         February 2005
                                                   Quarterly Panel
                                                   Meeting

  Provider and Employer Panel                      February 2005
                                                   Quarterly Panel
                                                   Meeting

  Florida Freedom Initiative Panel                 May 2005 Quarterly
                                                   Panel Meeting

  Youth Transition Demonstration Panel             May 2005 Quarterly
                                                   Panel Meeting

  Employer Best Practices Panel                    August 2005 Quarterly
                                                   Panel Meeting

  SSA Ticket Expos -- Panel members attended 4 out June- September 2005
  10                                               

  National Academy of Social Insurance Conference  January 19-20, 2006

  The Minnesota/Wisconsin Employment Forum         January 12, 2006

  SSA Town Hall Meeting                            December 15, 2005

  2^nd^ Annual Ticket to Work Conference -- Panel  February 2006
  co-hosted this event with Movimiento para el     Quarterly Panel
  Alcance de Vida Independiente (MAVI)             Meeting

  Puerto Rico and U.S. Virgin Islands Panel        February 2006
                                                   Quarterly Panel
                                                   Meeting

  President's Committee on Intellectual            March 2006
  Disabilities' Asset Development Roundtable       

  New Freedom Initiative Workgroup Meeting/Office  April 2006
  of Disability/U.S. Dept. of Health and Human     
  Services                                         

  Medicaid Buy-In and Medicaid Infrastructure      June 2006 Quarterly
  Grants: Beneficiary Perspectives Panel           Panel Meeting

  Benefits Planning Assistance and Outreach:       June 2006 Quarterly
  Beneficiary Perspectives Panel                   Panel Meeting

  Building Bridges Blueprint for Success           May 26, 2006
  Conference                                       

  **Annual Florida Conference on Supported         August 2006
  Employment**                                     

  Meeting with CCD Task Forces                     September 2006

  HSC Foundation Youth Transitions Summit          September 2006

  US Business Leadership Network Conference        October 2006

  TASH conference                                  November 2006

  Beneficiary Perspectives on Community Level      November 2006
  Infrastructure Panel                             Quarterly Panel
                                                   Meeting

  Beneficiary Summit -- Panel Event                February 2007

  Perspectives from Stakeholders Panel             April 2007 Quarterly
                                                   Panel Meeting

  Rhode Island Medicaid Infrastructure Grant       April 2007
  Summit                                           

  Oregon "Building Futures: Transition to          May 2007
  Education and Employment" Conference             

  Family Voices                                    May 2007

  SSA Teleservice Center and district field        May -- June 2007
  offices                                          

  Walgreens Distribution Center Opening            June 2007, South
                                                   Carolina

  Proyecto Visión Conference                       June 2007, Florida
  -----------------------------------------------------------------------

[]{#__RefHeading___Toc185405226 .anchor}Appendix E

## Panel Correspondence 2007 {#panel-correspondence-2007 .Annual-Report-Heading-2}

  ----------------------------------------------------- -------------------------------------------------- -----------------------------------------------------
  ![](media/image6.jpeg){width="0.9743055555555555in"   TICKET TO WORK & WORK INCENTIVES ADVISORY PANEL    ![](media/image7.jpeg){width="0.9736111111111111in"
  height="0.8444444444444444in"}                                                                           height="0.9965277777777778in"}

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

October 5, 2007

Michael J. Astrue

Commissioner

Social Security Administration

P.O. Box 17703

Baltimore, MD 21235-6401

RE: Notice of Proposed Rule Making: Amendments to the Ticket to Work and
Self-Sufficiency Program (Volume 72, Number 155)

Dear Commissioner Astrue:

I am writing on behalf of the Ticket to Work and Work Incentives
Advisory Panel (the Panel) to provide comments on the Notice of Proposed
Rule Making (NPRM) released on August 13, 2007. The NPRM calls for
simplifying and improving the definition of "using a ticket" and
requirements for measuring "timely progress" toward self-supporting
employment.

Overall, the Panel supports these proposed amendments. In particular, we
are pleased that, in addition to employment, the proposed amendments
allow for participation in an educational program to count toward an
individual's timely progress by crediting attendance at post secondary
school or vocational/technical training. While there are jobs for which
training can be completed in a relatively short time period, there are
others requiring a longer period of education or training. An individual
in a certified educational/training program, internship, apprenticeship,
etc. should not be required to interrupt this program to meet the work
requirements of "timely progress."

The Panel is concerned, however, about the potential impact on the
178,000 current beneficiaries with assigned tickets who will have to
demonstrate timely progress in 12 months instead of 24 months as
currently required. SSA must clearly communicate this change to these
beneficiaries, before it has a negative impact on their planned goals.

The Panel believes these proposed amendments would be most effective for
people with disabilities currently attending college or vocational
technical school whose earnings are below specified SSI and SSDI
earnings thresholds. However, these amendments would not be particularly
helpful for people who, for a variety of reasons, cannot participate in
full-time postsecondary education or vocational/technical training. We
provide details below and a compilation of recommendations in the
conclusion.

Potential Problems with Giving Credit for Participating in an
Education/Training Program

The proposed amendments require the equivalent of full-time attendance
in postsecondary education (12 credit hours per semester -- or 24
credits per 12 month period). For completion of the vocational or
technical training program requirements, an individual must have
finished at least 50 percent of the course requirements of the program
by the end of this 12-month period.

Completing these requirements can be difficult for people with certain
disabilities who rely on services such as public transportation,
attendant care, etc. For example, a beneficiary using para-transit, who
needs to be in class by 11:00 a.m., may need to be picked up at their
home by 8:00 a.m. (This occurs because para-transit often requires a
window of time before and after the customer wants to be picked up and
is usually allowed up to an hour and a half to drop off the customer.
Most often, the transit system will be faster than the 2-3 hours, but
the customer cannot depend upon a consistent trip time and must always
plan for the worst-case scenario.) Their return trip may require as many
hours, filling a large percentage of the individual's day with
transportation time -- not enough time to allow them to complete 12
college credits (a full-time schedule). The Social Security
Administration (SSA) should include provisions in the proposed
amendments to account for disability-related stumbling blocks, such as
an inability to get needed supports and accommodations.

The proposed amendments also provide credit for post secondary education
or vocational/technical training, but not for high school completion or
GED preparation for beneficiaries who had previously dropped out of
school and may now be completing those educational requirements (without
further aspiring to college or vocational/technical training). This
provides unequal continuing disability review (CDR) protection for those
beneficiaries who critically need this level of training if they are
going to obtain stable employment above substantial gainful activity
(SGA). SSA needs to consider an individual threshold around education
and/or training more suited to the employment preparation needs of the
individual. SSA should provide a larger threshold for beneficiaries who
may require a longer period of time to complete their educational
studies.

In addition, to be more inclusive, SSA should include training programs
of the Department of Veterans Affairs and the Department of Education
under the definition of "vocational or technical training programs."

Individualizing Timely Progress

The Panel recognizes that people with disabilities are a diverse group,
and one-size-fits-all approaches designed to move them toward
self-supporting employment can be problematic. Timely progress should be
individualized based on the terms and conditions of the Individualized
Plan for Employment/Individual Work Plan (IPE/IWP) and accommodate
episodic disabilities. It should be possible for the IPE/IWP to be
revised and updated as the needs and circumstances of the individual
changes -- both for postsecondary education and vocational/technical
training.

For example, individuals who become blind may not need postsecondary
education or GED preparation. Instead, they may need
adjustment-to-blindness training, which includes training on Braille,
orientation and mobility, adjustment to daily living, and assistive
technology. The definition of educational training should be flexible
enough to accommodate this.

Plans for Implementing the Proposed Amendments

The current rules have been in place since 2003. Tickets currently
assigned fall under the old rules which did not require timely progress
reviews until after the first 24 months of plan. SSA should explain its
plan for implementing the proposed amendments, answering, for example,
the following questions: 1) Will the amendments become effective after
60 days? 2) Will the amendments be applied to everyone or only to newly
assigned tickets? 3) What procedure will be used to determine progress
-- a questionnaire or an interview, or something else?

Other Improvements

*Documentation Improvements -- Reducing Administrative Burden*---The
proposed amendments call for requiring parallel documentation for
milestone payments for timely progress. The Panel recognizes that this
change is positive because it will reduce the reporting burden on ENs.

*Improvements to "Extension Period"*---The proposed amendments would
change the duration of the extension period from three months to 90
days, making it consistent with the proposed 90-day period included in
the September 2005 NPRM. This is a positive change.

Conclusion

The Panel is pleased that SSA is moving forward toward publishing final
Ticket regulations. We continue to urge expeditious implementation of
these new rule changes to help reignite the level of interest in the
Ticket Program by ENs and beneficiaries.

Overall, the Panel supports the proposed amendments and offers the
following recommendations (drawn from above) to improve the amendments:

Recommendations

SSA must clearly communicate to beneficiaries that they'll be required
to demonstrate timely progress in 12 months instead of 24 months as
currently required, before it has a negative impact on their planned
goals.

SSA should include provisions in the proposed amendments to account for
disability-related stumbling blocks, such as an inability to get needed
supports and accommodations.

SSA should provide a larger threshold for beneficiaries who may require
a longer period of time to complete their educational studies.

SSA should include training programs of the Department of Veterans
Affairs and the Department of Education under the definition of
"vocational or technical training programs." This should include
disability-specific training, such as orientation and mobility, Braille,
assistive technology, and similar skills necessary for vocational
functioning.

Timely progress should be individualized based on the terms and
conditions of the IPE/IWP and accommodate episodic disabilities. It
should be possible for the IPE/IWP to be revised and updated as the
needs and circumstances of the individual changes -- both for
postsecondary education and vocational/technical training.

SSA should explain its plan for implementing the proposed amendments,
answering, for example, the following questions: 1) Will the amendments
become effective after 60 days? 2) Will the amendments be applied to
everyone or only to newly assigned tickets? 3) What procedure will be
used to determine progress -- a questionnaire or an interview, or
something else?

We are pleased to offer SSA this advice. If you have any questions,
please contact the Panel's Executive Director, Jill Houghton. She can be
reached at 202-358-6419.

Sincerely,

![](media/image2.wmf){width="2.6222222222222222in"
height="0.6243055555555556in"}

Berthy De La Rosa-Aponte

Chair

Ticket to Work and Work Incentives Advisory Panel

**Statement of**

**Berthy De La Rosa Aponte, Chair**

**Ticket to Work and Work Incentives Advisory Panel,\
Social Security Administration**

**Submitted to the Senate Committee on Finance**

**Hearing on**

**"Barriers to Work for Individuals Receiving Social Security**

**Disability Benefits"**

**June 21, 2007**

As Chair of the Ticket to Work and Work Incentives Advisory Panel (the
Panel), I respectfully submit the following statement on behalf of the
Panel. We appreciate this opportunity.

The topic of today's hearing, "Barriers to Work for Individuals
Receiving Social Security Disability Benefits," represents one of the
core issues to which the Panel has been devoting much of its work since
Congress established the Panel in 2000 as part of the Ticket to Work and
Work Incentives Improvement Act of 1999 (the Act). The Panel will
continue to focus on this issue through our sunset date of December
2007.

At each of the Panel's meetings, we have heard from diverse
stakeholders, including beneficiaries who have shared their perspectives
and advice on the need for immediate improvements to current programs
under the Act, as well as approaches to more comprehensive, systemic
changes to policy and system design. We have also conducted extensive
policy research, consulted both nationally and internationally with
experts in the field of return to work, and provided the President,
Congress and the Commissioner of the Social Security Administration
(SSA) with recommendations and counsel for enhancing the return to work
efforts of disability beneficiaries.

Beneficiaries' perspectives and recommendations have played a primary
role in the development of Panel advice and will continue to play a
critical role as we develop the recommendations in our Final Report,
which will be released at the end of 2007. Beneficiaries have affirmed
to the Panel that most people with disabilities want to work but are
challenged by system fragmentation and complexity, fear of loss of
health care benefits and overpayments, and well intended policies that
have the effect of limiting economic security and advancement. It is
estimated that, in 2005, 104,100 non-employed SSI beneficiaries were
actively looking for work, and 103,200 non-employed SSDI beneficiaries
were actively looking for work.[^160]

Over the years, the Panel has provided recommendations related to SSA's
work incentives, health care programs, administrative and programmatic
operations and budgetary issues, as well as the work of other federal
programs charged with the responsibility of removing barriers to
employment and economic self-sufficiency for individuals with
disabilities. Below are key recommendations that the Panel has made and
that we reiterate now as you consider strategies and approaches for
removing barriers to work.

Our recommendations are organized into the following categories: 1)
Ticket to Work and Self-Sufficiency Program-Related Issues; 2) Marketing
and Outreach on Work Incentives; 3) Improving/Simplifying Specific Work
Incentives; and 4) Training for Work Incentives Specialists.

Ticket to Work and Self-Sufficiency Program-Related Issues

On September 30, 2005, SSA published a Notice of Proposed Rule Making
called "Amendments to the Ticket to Work and Self-Sufficiency Program."
These proposed amendments incorporated many of the Panel's priority
recommendations. We were particularly pleased that the proposed
amendments accounted for and addressed the multi-step nature of
returning to work by calling for a new payment system for Employment
Networks (ENs), offering more frequent and earlier payments.

The Panel was hopeful that the proposed changes would improve the
program. Unfortunately, SSA has not yet published the final regulations,
and the program continues to face significant problems. In fact, the
number of active ENs working with Social Security beneficiaries has been
in a statistical decline for the past eight months.

The Panel continues to hold hope for a demand-driven approach to
supporting beneficiaries in going to work; however, without significant
enhancements and aggressive outreach, we fear the Ticket Program will
not recover from initial design flaws and ongoing beneficiary and EN
disenchantment.

Specifically, the Panel recommends:

All SSI and SSDI adult beneficiaries, including those designated as
medical improvement expected, should be eligible to participate in the
Ticket Program.[^161]

Payments to ENs should be more frequent and earlier to reduce ENs'
financial risk. One caution is that SSA should review the lump sum
milestone payment provisions to ensure Tickets retain sufficient value
so beneficiaries continue to be able to negotiate for needed services
later in their return to work efforts.[^162]

SSA should rewrite the regulations and modify transmittal 17 to make it
clear that:

Beneficiaries' eligibility for vocational rehabilitation (VR) service or
the scope of those services should not be adversely affected by where
they assign their Ticket. Eligibility for VR services and VR client
status should not dictate when or where beneficiaries can use their
Ticket.

ENs should receive payments from SSA for beneficiaries who, with EN
assistance, continue in employment above substantial gainful activity
(SGA) after VR has been paid under the traditional cost reimbursement
system.[^163]

Transition-aged youth should be eligible for Tickets.[^164]

Request Commissioner of SSA's support of Panel\'s recommendation to
Congress to extend Ticket continuing disability review (CDR) protection
to any and all beneficiaries who are participating in an approved
program of VR services, employment services, or other employment support
services.[^165]

Explicitly state that a person entitled to benefits pursuant to
expedited reinstatement is immediately eligible for a new Ticket.[^166]

Amend statute to permit the Ticket Program to increase the sum of
payments for serving SSI beneficiaries to a level equal to the sum of
payments for serving SSDI beneficiaries.[^167]

Beneficiaries should be eligible for more than one Ticket in a period of
entitlement for SSDI/SSI benefits when their disability is likely to
require some indefinite supports to remain employed (including
self-employment).[^168]

Marketing and Outreach on Work Incentives

A coordinated marketing and substantial nationwide public education
campaign, targeted to beneficiaries, their families and disability
service providers, is needed to increase awareness of SSA's work
incentives and to debunk some of the widely held misperceptions about
the negative consequences of work for beneficiaries. As referenced
earlier, there are substantial numbers of disability beneficiaries
actively engaged in looking for work who could face greater likelihood
of success if they knew what supports were available and how existing
work incentives could provide an important safety net in their return to
work.

Specifically the Panel recommends:

SSA should immediately develop a national marketing and public education
campaign to explain available programs.[^169]

Expand resources available to broaden the impact of the work incentives
planning and assistance network.[^170]

Expand resources available to broaden the impact of protection and
advocacy services and supports.[^171]

Improving/Simplifying Specific Work Incentives

Across the board, SSA needs to reduce the complexity and improve the
consistency of work incentives for both the SSDI and the SSI programs.
We are pleased to announce that the Panel, in consultation with national
experts, is preparing an advice report for the President, Congress, and
SSA on work incentives utilization. We will be deliberating on this
report during our July 2007 quarterly meeting, and plan to publish it
this summer.

This Panel is considering ten themes or high level recommendations that
form an overall basis for increasing the utilization of work incentives,
and more importantly, improve the employment status of beneficiaries
with disabilities.

Increase awareness of beneficiaries about work incentives (including
better understanding and expanding outreach efforts).

Improve the collection, organization, and use of data about work
incentive utilization for decision making.

Improve SSA customer service and the knowledge base of accurate
information (training and technical assistance to SSA personnel)
delivered to beneficiaries.

Integrate planning and delivery of work incentive programs across the
myriad of federal programs involved.

Increase the number of trained work incentive planning specialists
dedicated to assisting beneficiaries.

Conduct studies and create demonstration projects to exemplify improved
work incentives utilization.

Increase the limits on liquid cash and assets for the purposes of future
security for beneficiaries.

Assure accessible health care as work incentives are utilized.

Reduce the risk of overpayments for beneficiaries.

Ensure that work incentives accommodate the dynamic nature of
disability.

Training for Work Incentives Specialists

The Panel has continued to recommend that Congress appropriate funds for
training of SSA staff and work incentives specialists to explain work
incentives to beneficiaries, and is currently reviewing how beneficiary
support is provided within the current field office structure.

The Panel has also supported funding private organizations to provide
work incentives training and support, beginning with the Benefits
Planning, Assistance, and Outreach Program and now the Work Incentives
Planning and Assistance Program as well as the Protection and Advocacy
for Beneficiaries of Social Security Program.

Specifically, the Panel recommends:

Congress should direct SSA to spend more on public education and field
training.[^172]

Next Steps for Panel

The Panel's three goals are driving our work: 1) [Goal 1]{.underline} --
Elevate and Incorporate the Beneficiary Perspective; [Goal
2]{.underline} -- Improve Implementation and Marketing of the Ticket to
Work and Work Incentives Improvement Act; and [Goal 3]{.underline} --
Develop A National Employment Investment Strategy to Transform
Approaches to Assets, Income, Health Care, and Supports for People with
Disabilities that is Person-Centered, Culturally Competent, and
Respectful of Each Person's Values and Experiences

The recommendations we have offered to date are part of our continuous
improvement goal, and our forthcoming advice report on work incentives
utilization will provide more detailed recommendations for increasing
utilization of work incentives.

The Panel will also be publishing two other reports in line with our
other goals. These reports will feed into our Final Report.

[Beneficiary Summit Report]{.underline} -- "Voices for Change:
Beneficiaries Paving the Way to Work"

This report will include the Beneficiary summit recommendations. In
addition, the Panel will be developing recommendations for ensuring
beneficiary input for future policy development separate from this
report.

National Employment Investment Strategy Report

The Panel recognizes that more will need to be done outside the current
structure to more substantially remove barriers to work for people with
disabilities. This report will lay out a comprehensive approach to
promoting employment for people with disabilities -- today and in the
future.

Conclusion

It is essential that SSA act sooner rather than later to decrease the
complexity of work incentives, to improve the consistency of work
incentives for both the SSDI and the SSI programs, and to remove
barriers to work. Social Security beneficiaries with disabilities have
waited far too long for improvements. This urgency applies particularly
to youth who are transitioning from school to work. Now is the time for
SSA to integrate a return-to-work philosophy and culture into its
service to the public, especially for new beneficiaries.

Thank you for this opportunity.

END NOTES

[]{#__RefHeading___Toc185405227 .anchor}Glossary

AB ─ Accelerated Benefits Demonstration Project

ADA ─ Americans with Disabilities Act of 1990

AOI ─ Adequacy of Incentives

AWICs ─ Area Work Incentives Coordinators

BPAO ─ Benefits Planning, Assistance and Outreach

BWE ─ Blind Work Expenses

CDR ─ Continuing Disability Review(s)

CILs ─ Centers for Independent Living

CMS ─ Centers for Medicare and Medicaid Services

COBRA ─ Consolidated Omnibus Budget Reconciliation Act

DOL ─ Department of Labor

DPNs ─ Disability Program Navigator(s)

ENs ─ Employment Networks(s)

EPE ─ Extended Period of Eligibility

ESRs ─ Employment Support Representatives

FLSA ─ Fair Labor Standards Act

GAO ─ Government Accountability Office

GDP ─ Gross Domestic Project

HHS ─ Department of Health and Human Services

HOPE ─ Homeless Outreach Projects and Evaluation

IDEA ─ Individuals with Disabilities Education Act

IEPs ─ Individualized Education Plan(s)

IRS ─ Internal Revenue Service

IRWE ─ Impairment Related Work Expense

MHTS ─ Mental Health Treatment Study

MIG ─ Medicaid Infrastructure Grant(s)

NASI ─ National Academy of Social Insurance

NCD ─ National Council on Disability

NCIL ─ National Council on Independent Living

NEIS ─ National Employment Investment Strategy

NPRM ─ Notice of Proposed Rulemaking

NTA ─ National Taxpayer Advocate

OMB ─ Office of Management and Budget

OPI ─ Office of Public Inquiry

OQP ─ Office of Quality Performance

PABSS ─ Protection and Advocacy for Beneficiaries of Social Security

PASS ─ Plan for Achieving Self Support

RED ─ Rehabilitation Early Diversion

SGA ─ Substantial Gainful Activity

SSA ─ Social Security Administration

SSI ─ Supplemental Security Income

SSAB ─ Social Security Advisory Board

SSDI ─ Social Security Disability Insurance

SVRAs ─ State Vocational Rehabilitation Agencies

TESS ─ Transition to Economic Self-Sufficiency

TWP ─ Trial Work Period

UCP ─ United Cerebral Palsy

VR ─ Vocational Rehabilitation

WILs ─ Work Incentive Liaison(s)

WIPA ─ Work Incentives Planning and Assistance

**Panel 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

Anyone requiring materials in alternative formats or for 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.

[]{#__RefHeading___Toc185405228 .anchor}End No**tes**

[^1]: Section 2(a)(11), Public Law 106-170, "Ticket to Work and Work
    Incentives Improvement Act," December 17, 1999.

[^2]: Bliley, Thomas J. Committee on Commerce, U. S. House of
    Representatives, Report 106-220, Part 1, "Work Incentives
    Improvement Act of 1999," July 1, 1999, p. 2.

[^3]: Section 2(a)(11), Public Law 106-170, "Ticket to Work and Work
    Incentives Improvement Act," December 17, 1999.

[^4]: Section 121, Public Law 106-170, "Ticket to Work and Work
    Incentives Improvement Act," December 17, 1999.

[^5]: Listing of the former panel members does not necessarily
    constitute an endorsement of recommendations included within this
    report. These recommendations are the result of a majority vote
    reached by current Panel members.

[^6]: Ticket to Work and Work Incentives Advisory Panel, "UPDATE,
    SIMPLIFY, AND EDUCATE: A National Call to Optimize Incentives to
    Work," December 2007.

[^7]: Committee on Commerce, U.S. House of Representatives, Report
    106-220, Part 1, "Work Incentives Improvement Act of 1999," p. 7.

[^8]: Social Security Administration, "SSA Quarterly Update to the
    Ticket Panel, Third Quarter 2007," July, 2007.

[^9]: **Committee on Commerce, U.S. House of Representatives, Report
    106-220, Part 1, H.R. 1180, Ticket to Work and Work Incentives
    Improvement Act of 1999, July 1, 1999, p. 7.**

[^10]: Ibid., p. 5.

[^11]: In 1972, the Supplemental Security Income program was created and
    the definition of disability was changed slightly from a permanent
    disability to one lasting at least 12 months.

[^12]: **Burkhauser, R., D.S. Stapleton. "The decline in the employment
    rate for people with disabilities: Bad data, bad health, or bad
    policy? Journal of Vocational Rehabilitation, 20 (3), 185 -- 201,
    IOS Press, 2004.
    <http://digitalcommons.ilr.cornell.edu/edicollect/158>**

[^13]: Houtenville, A. J., W. A. Erickson, C.G. Lee. Disability
    Statistics from the Current Population Survey (CPS). Cornell
    University Rehabilitation Research and Training Center on Disability
    Demographics and Statistics (StatsRRTC), April 4, 2005. Retrieved
    November 13, 2007 from
    [www.disabilitystatistics.org](http://www.disabilitystatistics.org/)

[^14]: Social Security Advisory Board. "A Disability System for the 21st
    Century," September 2006, pp. 6-7.
    <http://www.ssab.gov/documents/disability-system-21st.pdf>

[^15]: Ibid.

[^16]: Social Security Advisory Board. "The Social Security Definition
    of Disability," October 2003.

[^17]: **National Council on Disability. "Toward Independence: An
    Assessment of Federal Laws and Programs Affecting Persons with
    Disabilities," February 1986; "On the Threshold of Independence,"
    January 1988; "Achieving Independence: The Challenge for the 21st
    Century, A Decade of Progress in Disability Policy Setting an Agenda
    for the Future," July 26, 1996; "The Social Security
    Administration's Efforts to Promote Employment for People with
    Disabilities: New Solutions for Old Problems," November 30, 2005;
    "Empowerment for Americans with Disabilities: Breaking Barriers to
    Careers and Full Employment," October 1, 2007.**

[^18]: Walker, David M. Social Security Reform Presentations, 1999 and
    2001. "[Truth and Transparency: The Federal Government\'s Financial
    Condition and Fiscal
    Outlook](http://www.gao.gov/cghome/2003/npc917.pdf)," September 17,
    2003.

[^19]: Imparato, Andrew. "Community Services and Supports: Planning
    Across the Generations," Testimony Before the U.S. Senate Committee
    on Health, Education, Labor, and Pensions, July 10, 2007.

[^20]: National Council on Independent Living. "Being American: the Way
    Out of Poverty," September 30, 2006.

[^21]: Ticket to Work and Work Incentives Improvement Act of 1999. H.R.
    1180. January, 1999.

[^22]: Section 2(a)(11), Public Law 106-170, "Ticket to Work and Work
    Incentives Improvement Act," December 17, 1999.

[^23]: Social Security Administration. Strategic Plan. (FY 2006 -- FY
    2011). Baltimore, MD: Author. http://www.ssa.gov/strategicplan.html

[^24]: Social Security Administration, "SSA Strategic Plan. (FY 2006 --
    FY 2011)," Baltimore, MD, p. 12.

[^25]: Listing of past Panel members does not necessarily provide an
    endorsement of their support for recommendations included within
    this report. These recommendations are the result of a majority vote
    reached by current Panel members.

[^26]: Social Security Advisory Board. (2006). A Disability System for
    the 21st Century. Washington, DC. September 2006.
    http://www.ssab.gov/documents/disability-system-21st.pdf

[^27]: Ibid, p 3.

[^28]: Office of Management and Budget, Program Assessment and Rating
    Tool, Social Security Disability Insurance, www.expectmore.gov

[^29]: Social Security Advisory Board. (2006). A Disability System for
    the 21st Century. Washington, DC. September 2006.
    http://www.ssab.gov/documents/disability-system-21st.pdf

[^30]: Ibid^.^

[^31]: Muller, L. Scott, "Disability Beneficiaries Who Work and Their
    Experience Under Program Work Incentives," Social Security Bulletin
    55(2):2-19(1992), Social Security Administration.

[^32]: Hennessey, John C. and L. Scott Muller, "Work Efforts of
    Disabled-Worker Beneficiaries: Preliminary Findings from the New
    Beneficiary Follow-up Survey," Social Security Bulletin 57(3):42-51,
    Social Security Administration, 1995.

[^33]: Hennessey, John C. and L. Scott Muller, "The Effect of Vocational
    Rehabilitation and work Incentives on Helping the Disabled-Worker
    Beneficiary Back to Work," Social Security Bulletin 58(1):15-28,
    Social Security Administration, 1995.

[^34]: Ticket to Work and Work Incentives Advisory Panel, "UPDATE,
    SIMPLIFY, AND EDUCATE: A National Call to Optimize Incentives to
    Work," December 2007.

[^35]: Social Security Administration, "SSI Disabled Recipients Who
    Work," Tables 14 and 6, 2006.

[^36]: 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.

[^37]: Livermore, G. A., "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. 2003.
    http://www.ssa.gov/work/panel/panel_documents/briefingpapers.html

[^38]: Social Security Administration. Strategic Plan FY 2006 -- FY
    2011. Baltimore, MD. http://www.ssa.gov/strategicplan.html

[^39]: Office of Management and Budget. Budget of the United States
    Government, FY 2008.
    <http://www.whitehouse.gov/omb/budget/fy2008/budget.html>

[^40]: 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 SSA FY 2008 and Revised Final FY 2007 APP Appendix
    A: Service -- Improper Service Through Technology (1.3 a-g)
    Means/Strategies.)

[^41]: Social Security Administration, "Social Security Administration
    Budget, Justification of Estimates for Appropriations Committees FY
    2008," Baltimore, MD, p. 179,
    http://www.socialsecurity.gov/budget/2008cjapp508.pdfFiscal Year
    2008, p. 179.

[^42]: Office of Management and Budget, "Budget of the United States
    Government, FY 2008,
    <http://www.whitehouse.gov/omb/budget/fy2008/budget.html>

[^43]: U.S. House of Representatives Committee on Ways and Means,
    Hearing before the Subcommittee on Social Security: "Social Security
    Service Delivery Challenges," 109th Cong, 2nd Session, Washington,
    DC, May 11, 2006.

[^44]: Ibid, pp. 29, 39-40, 51, and 60.

[^45]: U.S. General Accounting Office, "Major Management Challenges and
    Program Risks: Social Security Administration," GAO-03-117.
    Washington, DC: January 2003.

[^46]: U.S. Government Accountability Office. 2005. Social Security
    Reform: Early Action Would Be Prudent. GAO-05-397T. Washington,
    D.C.: March 9, 2005. The General Accounting Office (GAO) changed its
    name to the Government Accountability Office in 2004.

[^47]: U.S. Government Accountability Office. 2005. Social Security
    Reform: Answers to Key Questions. GAO-05-193SP. Washington, D.C.:
    May 2005.

[^48]: Craig Thornton et al, "Evaluation of the Ticket to Work Program:
    Assessment of Post-Rollout Implementation and Early Impacts, Volume
    1," May 2007, p. 34.

[^49]: Ibid, p. 35^.^

[^50]: Social Security Administration, \"Ticket Tracker,\" The Work
    Site. <http://www.ssa.gov/work/Ticket/ticket_info.html>

[^51]: Maximus, "Inside Ticket Quarterly Newsletter. Ticket to Work
    Newsletter (Summer 2007),"
    http://www.yourtickettowork.com/marketing_inside_ticket_quarterly.

[^52]: Thornton, Craig et al, "Evaluation of the Ticket to Work Program
    Initial Evaluation Report," February 2004, p. 71.

[^53]: Thornton, Craig et al, "Evaluation of the Ticket to Work Program:
    Assessment of Post-Rollout Implementation and Early Impacts, Volume
    1," May 2007, p. 131.

[^54]: Ibid, p. 254.

[^55]: Ticket to Work and Work Incentives Advisory Panel, "Advice Report
    to the Commissioner of the Social Security Administration: Design
    Issues Relating to the Adequacy of Incentives Study," June 18, 2002,
    http://www.ssa.gov/work/panel/panel_documents/reports.html

[^56]: Social Security Administration, "Amendments to the Ticket to Work
    and Self-Sufficiency Program: Notice of proposed rulemaking," 70
    Federal Register 189 (September 30, 2005), pp. 57222-57237.

[^57]: Social Security Administration, "Improvements to the Ticket to
    Work and Self-Sufficiency Program: Notice of proposed rulemaking,"
    72 Federal Register 155 (August 13, 2007), pp. 45191-45199.

[^58]: Virginia Commonwealth University Benefits Assistance Resource
    Center, http://www.vcu-barc.org/

[^59]: Social Security Administration, "BPAO 2004 Customer Satisfaction
    Survey Results," 2004.

[^60]: Public Comment, Ticket to Work and Work Advisory Panel Quarterly
    Meetings 2004, 2005, 2006.

[^61]: Bruyere, Susanne and Thomas Golden. "Evaluation and Future
    Prospects of US Return to Work Policies for Social Security
    Beneficiaries," Employment and Disability Institute, 2007.

[^62]: Social Security Administration, "Work Incentives Planning and
    Assistance (WIPA) Cooperative Agreement Awards," The Work Site.
    <http://www.socialsecurity.gov/work/ServiceProviders/WIPADirectory.html>

[^63]: Protection and Advocacy for Beneficiaries of Social Security FY
    2006 Final Report, March 2007.

[^64]: Ticket to Work and Work Incentives Advisory Panel, "Annual Report
    to the President and Congress, Year Five," December, 2005.

[^65]: Livermore, G. A., "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, 2003,
    http://www.ssa.gov/work/panel/panel_documents/briefingpapers.html

[^66]: National Council on Disability, "The Social Security
    Administration\'s Efforts to Promote Employment for People with
    Disabilities: New Solutions for Old Problems," November 30, 2005.

[^67]: Bruyere, Susanne and Thomas Golden, "Evaluation and Future
    Prospects of US Return to Work Policies for Social Security
    Beneficiaries," Employment and Disability Institute, 2007, p 79.

[^68]: Ireys, Henry et al, "The Interaction of Policy and Enrollment in
    the Medicaid Buy-In Program, 2005 Final Report," Mathematica Policy
    Research, Inc. pp. 3 - 4.

[^69]: Liu, Su and Bob Weathers, "Do Participants Increase Their
    Earnings After Enrolling in the Medicaid Buy-In Program?",
    Mathematica Policy Research, Inc., May, 2007, p. 2.

[^70]: Schimmel, Jody et al. "How Do Buy-In Participants Compare with
    Other Medicaid Enrollees with Disabilities?", Mathematica Policy
    Research, Inc., Working with Disability Policy Brief, Number 5, June
    2007, www.mathematica-mpr.com/publications/PDFs/WWDcompare.pdf

[^71]: Liu, S. and H.T. Ireys, "Participation in the Medicaid Buy-in
    program: A statistical profile from integrated data. Final Report,"
    Mathematica Policy Research, Inc., May 2006.

[^72]: For state-by-state information on state's Medicaid Buy-In work
    requirements go to www.medicaidbuyin.org and go to "Medicaid Buy-In
    Programs: Development, Program Design and Enrollment" and see Table
    4 - Work-Related Policies and Protections.

[^73]: *Iowa*: Iowa Department of Human Services, "Iowa: Medicaid for
    Employed People with Disabilities: A Client Profile and Program
    Evaluation," Figure 6-9, March 11, 2005, p. 46.
    http://www.dhs.state.ia/dhs_homepage/docs/MEPD-04_report-master.pdf

    *Kansas*: University of Kansas Medicaid Infrastructure Change
    Evaluation Project, "Satisfaction Survey of Medicaid Buy-In
    Participants," Reported in Policy Brief #6, November 2004,
    http://www.workinghealthy.org/WHpolicybrierno6.pdf

    *Minnesota*: Minnesota Department of Human Services, "How MA-EPD
    Does the Job-Survey of Minnesotans Enrolled in the Medical
    Assistance for Employed Persons with Disabilities Program," Table
    21, August, 2004, p. 36.
    http://www.dhs.state.mn.us/main/group/disabilities/documents/pub/dhs_id_029455.pdf

    *Utah*: UWIN Evaluation Team, Utah State University and University
    of Utah, "Self Reported Experiences of Individuals with Disabilities
    Involved in the Utah Medicaid Work Incentives Program," Table 21,
    April 13, 2003, p. 36.
    http:www.uwin.org/uwin/webpage/products/MWIreportFINAL4-15-03.pdf

[^74]: Liu, Su and Bob Weathers, "Do Participants Increase Their
    Earnings After Enrolling in the Medicaid Buy-In Program?",
    Mathematica Policy Research, Inc., May, 2007, p. 3.

[^75]: Gimm, Gilbert W. and Bob Weathers, "What Is the Demonstration to
    Maintain Independence and Employment (DMIE) and Who Is
    Participating? Working with Disability Work and Insurance In Brief
    #6,\" Mathematica Policy Research, Inc. August, 2007.

[^76]: Gimm, Gilbert W., et al, "Who Are the Top Earners in the Medicaid
    Buy-In Program," Working with Disability Work and Insurance in Brief
    #3, Mathematica Policy Research, Inc., March, 2007.

[^77]: Social Security Administration, "Amendments to the Ticket to Work
    and Self-Sufficiency Program: Notice of proposed rulemaking," 70
    Federal Register 189, September 30, 2005, pp. 57222-57237.

[^78]: U.S. Department of Education, National Center for Education
    Statistics, "The Condition of Education 2007," (NCES 2007-064).
    Washington, DC, 2007.

[^79]: American Counsel on Education Business-Higher Education Forum,
    "Building a Nation of Learners: The Need for Changes in Teaching and
    Learning to Meet Global Challenges," Washington, 2003.

[^80]: U.S. Department of Labor, "America\'s Dynamic Workforce,"
    Washington, DC, 2006.
    http://www.dol.gov/asp/media/reports/workforce2006/ADW2006_Full_Text.pdf

[^81]: EPE Research Center, Editorial Projects in Education \[EPE\],
    "Diplomas count 2007: Ready for what? Preparing students for
    college, careers, and life after high school," Education Week,
    26(40), 2007. http://www.edweek.org/ew/toc/2007/06/12/index.html

[^82]: U.S. Department of Education, Office of Special Education and
    Rehabilitative Services, Office of Special Education Programs, 26th
    Annual (2004) "Report to Congress on the Implementation of the
    Individuals with Disabilities Education Act, Vol. 1," Washington,
    DC, April, 2006

[^83]: Wagner, M., L. Newman, R. Cameto, N. Garza, and P. Levine, "After
    High School: A First Look at the Postschool Experiences of Youth
    with Disabilities. A Report from the National Longitudinal
    Transition Study-2 (NLTS2)," Menlo Park, CA, SRI International,
    2005, Available at
    www.nlts2.org/reports/2005_04/nlts2_report_2005_04_complete.pdf

[^84]: Horvath-Rose, A.E., D.C. Stapleton, and B. O\'Day, "Trends in
    Outcomes for Young People with Disabilities: Are We Making
    Progress?," Journal of Vocational Rehabilitation Volume 21, Number
    3, 2004, pp. 175 -- 18.
    http://digitalcommons.ilr.cornell.edu/edicollect/93

[^85]: U.S. General Accounting Office, "Highlights of a GAO Forum,
    Workforce Challenges and Opportunities For the 21^st^ Century:
    Changing Labor Force Dynamics and the Role of Government Policies,"
    GAO-04-845SP," Washington, DC, June, 2004.

[^86]: Karoly, Lynn A. and Constantijn W.A. Panis, "The 21^st^ Century
    at Work: Forces Shaping the Future Workforce and Workplace in the
    United States," MG-164, Santa Monica, California, The RAND
    Corporation, 2004.

[^87]: Purcell, Patrick, "Older Workers: Employment and Retirement
    Trends. CRS Report for Congress," RL30629, Congressional Research
    Service, Updated September 7, 2007.

[^88]: Karoly, Lynn A. and Constantijn W.A. Panis, "The 21^st^ Century
    at Work: Forces Shaping the Future Workforce and Workplace in the
    United States," MG-164, Santa Monica, California, The RAND
    Corporation, 2004.

[^89]: U.S. Government Accountability Office. "Modernizing Federal
    Disability Policy," GAO-07-934SP, Washington, DC, August 2007.

[^90]: Turner, Mark D., and Burt S. Barnow, "Living Wage and Earned
    Income Tax Credit: A Comparative Analysis," The Employment Policies
    Institute, January, 2003, www.EPIonline.org

[^91]: U.S. Department of Labor Employment Standards Administration Wage
    and Hour Division: http://www.dol.gov/esa/whd

[^92]: Stapleton, David C., and William A. Erickson, "Characteristics or
    Incentives: Why Do Employment Outcomes for the SSA Beneficiary
    Clients of VR Agencies Differ, on Average, from Those of Other
    Clients?," Cornell University Institute for Policy Research, 2005.

[^93]: U.S. Department of Health and Human Services, Centers for
    Medicare and Medicaid Services, "National Health Expenditure
    Projections 2006-2016," January 2007.

[^94]: Organisation for Economic Cooperation and Development, "OECD
    Health Data 2007," updated July 2007.

[^95]: Kaiser Family Foundation, "Health Care Spending in the United
    States and OECD Countries," January 2007.

[^96]: DeNavas-Walt, Carfmen, Bernadette D. Proctor, and Cheryl Hill
    Lee, U.S. Census Bureau, Current Population Reports, P60-231,
    "Income, Poverty, and Health Insurance Coverage in the United
    States: 2005," Washington, D.C., 2006.

[^97]: **DeNavas-Walt, Carmen, Bernadette D. Proctor, and Jessica Smith,
    U.S. Census Bureau, Current Population Reports, P60-233, "Income,
    Poverty, and Health Insurance Coverage in the United States: 2006,"
    Washington, D.C., 2007.**

[^98]: Gilmer, T., and R. Kronick, "It's the Premiums, Stupid:
    Projections of the Uninsured Through 2013," Health Affairs Web
    Exclusive, w5-143--w5-151, April 5, 2005.

[^99]: Kaiser Commission on Medicaid and the Uninsured, "Changes in
    Employees' Health Insurance Coverage, 2001--2005," Washington, D.C.,
    Henry J. Kaiser Family Foundation, October, 2006.

[^100]: Kaiser Family Foundation and Health Research and Educational
    Trust, "Employer Health Benefits 2006: Annual Survey," Washington,
    DC, Kaiser Family Foundation, 2006.

[^101]: Burton, A., I. Friedenzohn, and E. Martinez-Vidal, "State
    Strategies to Expand Health Insurance Coverage: Trends and Lessons
    for Policymakers," The Commonwealth Fund, February 2007.

[^102]: The Robert Wood Johnson Foundation, State Coverage Initiatives,
    <http://statecoverage.net/matrix/index.htm>l

[^103]: Ticket to Work and Work Incentives Advisory Panel, Report from
    the Beneficiary Summit. "Voices for Change: Beneficiaries Paving the
    Way to Work, A Roadmap to Program Improvement," July 26, 2007.

[^104]: Panel members visited a teleservice center and field office in
    the Seattle area, and field offices in the Sacramento, Washington,
    DC, and Long Island areas. This was not a comprehensive study, but
    we did come away with some consistent impressions.

[^105]: Social Security Advisory Board, "Annual Report Fiscal Year
    1998," October 1998.

[^106]: Social Security Advisory Board, Letter to Subcommittee on Social
    Security of the Committee on Ways and Means, U.S. House of
    Representatives, February 14, 2007.

[^107]: Ticket to Work and Work Incentives Advisory Panel, Letter to
    Commissioner Barnhart. "Notice of Proposed Rule Making: Amendments
    to the Ticket to Work and Self-Sufficiency Program (Volume 70,
    Number 189)," December 22, 2005. Note: This letter includes
    references to Panel recommendations made to date.

[^108]: Ticket to Work and Work Incentives Advisory Panel, Letter to
    Commissioner Barnhart. "Notice of Proposed Rule Making: Amendments
    to the Ticket to Work and Self-Sufficiency Program (Volume 70,
    Number 189), Publication of Final Rule," September 28, 2006.

[^109]: Ticket to Work and Work Incentives Advisory Panel, Letter to
    Commissioner Barnhart. "Publication of Final Rule, Ticket to Work
    and Self-Sufficiency Program; Follow Up to Panel's September 28,
    2006 Letter," November 30, 2006.

[^110]: Ticket to Work and Work Incentives Advisory Panel, Letter to
    Commissioner Astrue. "Notice of Proposed Rule Making: Amendments to
    the Ticket to Work and Self-Sufficiency Program (Volume 72, Number
    155)," October 5, 2007.

[^111]: The Ticket to Work and Work Incentives Advisory Panel, "The
    Crisis in EN Participation ---A Blueprint for Action," February,
    2004, p. ii.

[^112]: Ibid, pp. 12-14.

[^113]: Ticket to Work and Work Incentives Advisory Panel, Letter to
    Commissioner Barnhart. "Marketing the Ticket to Work program and
    Work Incentives," November 6, 2006.

[^114]: U.S. Government Accountability Office, "Improved Processes for
    Planning and Conducting Demonstrations May Help SSA More Effectively
    Use Its Demonstration Authority," GAO-05-19, Washington, DC,
    November 4, 2004.

[^115]: Balkus, Richard and Susan Wilschke, "Treatment of Married
    Couples in the SSI Program," Issue Paper No 2003-01, Social Security
    Administration Office of Policy, 2003.

[^116]: Ibid.

[^117]: Ibid.

[^118]: PL 108-311, Working Families Tax Relief Act of 2004, October 4,
    2004.

[^119]: Vaughn, John, Chairperson, National Council on Disability.
    "Testimony Presented to the Subcommittee on Social Security of the
    House Committee on Ways and Means Regarding Social Security
    Disability Backlogs," February 14, 2007.

[^120]: This recommendation is identical to one recommended by the 1986
    Disability Advisory Council.

[^121]: Program Operations Manual System (POMS) DI 10520.001.
    Impairment-Related Work Expenses (IRWE),
    http://www.ssa.gov/regulations.

[^122]: Program Operations Manual System (POMS) DI 10520.010.
    Definitions, http://www.ssa.gov/regulations.

[^123]: Social Security Administration, "Report on Supplemental Security
    Income: Income and Resource Exclusions and Disability Insurance
    Earnings-Related Provisions," Office of Policy, Washington, DC,
    March 2000.

[^124]: Social Security Advisory Board, "Statement on the Supplemental
    Security Income Program," Washington, DC, May 2005, p. 8.
    http://www.ssab.gov/documents/2005SSIReport.pdf

[^125]: Social Security Administration, "Vocational Rehabilitation
    Provider's Handbook, Updated 1/18/06," Baltimore, MD,
    http://www.ssa.gov/work/ServiceProviders/providers.html

[^126]: 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.,
    "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, 2003.

[^127]: 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.

[^128]: Social Security Administration, "SSA Strategic Plan FY 2006 --
    FY 2011," Baltimore, MD, http://www.ssa.gov/strategicplan.html

[^129]: Social Security Administration, "Social Security Administration
    Budget, Justification of Estimates for Appropriations Committees, FY
    2008," Baltimore, MD.
    http://www.socialsecurity.gov/budget/2008cjapp508.pdf

[^130]: Livermore, G.A. "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., 2003.

[^131]: Ibid, p. 24.

[^132]: Social Security Administration, "Performance and Accountability
    Report for Fiscal Year 2004," Baltimore, MD.
    http://www.ssa.gov/finance/fy04_accountability.html

[^133]: Social Security Advisory Board, "Statement on the Supplemental
    Security Income Program," May 2005, p.8.
    http://www.ssab.gov/documents/2005SSIReport.pdf

[^134]: Office of Management and Budget, "Agency Information Collection
    Activities: Proposed Request," Federal Register Vol. 70 No. 172,
    September 7, 2005, p. 53266. http://www.gpoaccess.gov/fr/index.html

[^135]: Social Security Administration, "Annual Report of the
    Supplemental Security Income Program," Baltimore, MD, May, 2006.

[^136]: Office of Management and Budget. Budget of the United States
    Government, FY 2007.

[^137]: Office of Management and Budget. Budget of the United States
    Government, FY 2008.

    [[http://www.whitehouse.gov/omb/budget/fy2008/budget.html]{.underline}](http://www.whitehouse.gov/omb/budget/fy2008/budget.html)

[^138]: 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).
    http://www.ssa.gov/work/panel/panel_documents/official_correspondence.html

[^139]: Social Security Administration, "SSA Strategic Plan for
    2006-2011," Baltimore, MD. http://www.ssa.gov/strategicplan.html

[^140]: Social Security Administration, "SSI Disabled Recipients Who
    Work," 1990-2006 Reports^.^

[^141]: Gallagher, Tanya M., "Enhancing earnings and Income Through
    Self-Determination for AOI Targeted Groups," Adequacy of Incentives
    (AOI) Advisory Group, August 2004, 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

[^142]: Social Security Administration, "Cooperative Agreements for Work
    Incentives Planning and Assistance Projects: Program Announcement
    No. SSA-OESP-06-1," 71 Federal Register 94, May 16, 2006, pp.
    28401-28413. http://www.gpoaccess.gov/fr/index.html

[^143]: Section 100, Rehabilitation Act of 1973 (as amended)/Workforce
    Investment Act.

[^144]: U.S. Government Accountability Office, "Modernizing Federal
    Disability Policy," GAO-07-934SP, Washington, DC, August 2007.

[^145]: National Council on Disability, "The Social Security
    Administration\'s Efforts to Promote Employment for People with
    Disabilities: New Solutions for Old Problems," Washington, DC,
    November 30, 2005.

[^146]: Social Security Advisory Board, "A Disability System for the
    21st Century," Washington, DC, September, 2006.

[^147]: Social Security Advisory Board, "The Social Security Definition
    of Disability," Washington, D.C., 2003.

[^148]: Social Security Advisory Board, "A Disability System for the
    21^st^ Century," September 2006.
    http://www.ssab.gov/documents/disability-system-21st.pdf

[^149]: Ibid.

[^150]: Office of Personnel Management, "Federal Retirement
    Projections,"
    [**http://www.opm.gov/feddata/retire/rs2004_projections.pdf**](http://www.opm.gov/feddata/retire/rs2004_projections.pdf).)
    OPM projects 18.5 percent of the (Non-Seasonal, Full-Time Permanent
    (NSFTP) workforce will retire through Fiscal Year 2010
    (approximately 290,000).

[^151]: Social Security Advisory Board, "A Disability System for the
    21^st^ Century," September 2006.
    http://www.ssab.gov/documents/disability-system-21st.pdf

[^152]: In 1972, the Supplemental Security Income (SSI) program was
    created and the definition of disability was changed slightly from a
    permanent disability to one lasting at least 12 months.

[^153]: See, e.g., GAO, "Wide Array of Programs Needs to be Examined in
    Light of 21^st^ Century Challenges," Report No. GAO-05-626 (2005);
    NCD, "The Social Security Administration\'s Efforts to Promote
    Employment for People with Disabilities New Solutions for Old
    Problems," National Council on Disability (2005); NCD, "Achieving
    Independence: The Challenge for the 21st Century - A Decade of
    Progress in Disability Policy Setting an Agenda for the Future,"
    (1996); NCD, "Furthering the Goals of the Americans with
    Disabilities Act Through Disability Policy Research in the 1990s,"
    (1992); NCD, "ADA Watch-Year One: A Report to the President and the
    Congress on Progress in Implementing the Americans with Disabilities
    Act," (1993); NCD, "Sharing the Risk and Ensuring Independence: A
    Disability Perspective on Access to Health Insurance and
    Health-Related   Services, A Report to the President and Congress of
    the United States," (1993); NCD, "Inclusionary Education for
    Students with Disabilities: Keeping the Promise," (1994).

[^154]: Walker, David M., Comptroller General of the United States,
    Social Security Reform presentations, 1999 and 2001. "[Truth and
    Transparency: The Federal Government\'s Financial Condition and
    Fiscal Outlook](http://www.gao.gov/cghome/2003/npc917.pdf),"
    September 17, 2003.

[^155]: Social Security Advisory Board, "The Social Security Definition
    of Disability," 2003).

[^156]: National Council on Disability, "Toward Independence: An
    Assessment of Federal Laws and Programs Affecting Persons with
    Disabilities," February 1986; National Council on Disability, "On
    the Threshold of Independence," January, 1988; National Council on
    Disability, "The Social Security Administration's Efforts to Promote
    Employment for People with Disabilities: New Solutions for Old
    Problems," November 30, 2005; National Council on Disability,
    "Empowerment for Americans with Disabilities: Breaking Barriers to
    Careers and Full Employment," October 1, 2007.

[^157]: Imparato, Andrew, "Community Services and Supports: Planning
    Across the Generations," Testimony Before the U.S. Senate Committee
    on Health, Education, Labor, and Pensions, July 10, 2007.

[^158]: National Council on Independent Living, "Being American: the Way
    Out of Poverty," September 30, 2006.

[^159]: Ticket to Work and Work Incentives Advisory Panel, "Voices for
    Change: Beneficiaries Paving the Way to Work, A Roadmap to Program
    Improvement," July 26, 2007.

[^160]: Houtenville, A. J., Erickson, W. A., Lee, C. G., "Disability
    Statistics, from the American Community Survey (ACS)," Ithaca, NY:
    Cornell University, Rehabilitation Research and Training Center on
    Disability Demographics and Statistics (StatsRRTC), March 16, 2007,
    www.disabilitystatistics.org.

[^161]: Ticket to Work and Work Incentives Advisory Panel, "Final Advice
    Report on Ticket Program Notice of Proposed Rule Making," July 2001.

[^162]: Ticket to Work and Work Incentives Advisory Panel, "Annual
    Report to the President, Congress, and the Commissioner of SSA: Year
    Six," Advisory Letter to Commissioner Re. NPRM September 2005.
    http://www.ssa.gov/work/panel/panel_documents/reports.html

[^163]: Ibid.

[^164]: Ticket to Work and Work Incentives Advisory Panel, "Annual
    Report to the President, Congress, and the Commissioner of SSA: Year
    Two," August, 2002.
    http://www.ssa.gov/work/panel/panel_documents/reports.html

[^165]: Ticket to Work and Work Incentives Advisory Panel, Advisory
    Letter to Commissioner Re. NPRM on Continuation of Benefit Payments,
    August, 2003.

[^166]: Ticket to Work and Work Incentives Advisory Panel, Advisory
    Letter to Commissioner Re. NPRM on the Reinstatement of Entitlement
    to Disability Benefits (EXR), October, 2003.

[^167]: Ticket to Work and Work Incentives Advisory Panel, "Advice
    Report on Employment Networks," February, 2004.
    <http://www.ssa.gov/work/panel/panel_documents/reports.html>

[^168]: Ticket to Work and Work Incentives Advisory Panel, "Annual
    Report to the President, Congress, and the Commissioner of SSA: Year
    Six," Advisory Letter to Commissioner Re. NPRM September 2005
    <http://www.ssa.gov/work/panel/panel_documents/reports.html>

[^169]: Ticket to Work and Work Incentives Advisory Panel, "Annual
    Report to the President, Congress, and the Commissioner of SSA: Year
    Three," May, 2003.
    http://www.ssa.gov/work/panel/panel_documents/reports.html

[^170]: Ticket to Work and Work Incentives Advisory Panel, Letter to Sue
    Suter, Associate Commissioner, SSA's Office of Employment Support
    Programs, February 11, 2005.

[^171]: Ticket to Work and Work Incentives Advisory Panel, Letter to
    Congressman Shaw and Senator Grassley, November 20, 2003.

[^172]: Annual Report Year 2.