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                                                               SCVRD Response to the NPRM
	Amendments to the Ticket to Work and Self-Sufficiency Program
	General
	The South Carolina Vocational Rehabilitation Department (SCVRD) appreciates the
	opportunity to respond to the Notice of Proposed Rulemaking (NPRM) regarding the
|	Ticket to Work and Self-Sufficiency Program. In general, SCVRD is pleased with the
]	proposed revisions. The proposed revisions clearly indicate that SSA has listened to its
	stakeholder's concerns and is attempting to strengthen the current system to streamline
	services to Social Security beneficiaries and recipients. Our comments are arranged
consistent with specific sections in 20 CFR 411 and the additional matters of comments
are address separately.
Comments and Recommendations on Proposed Revisions
Sec. 411.125 Who is eligible to receive a ticket under the Ticket to Work program?
COMMENTS:
SCVRD supports the revision to include social security cases that are medically expected to improve. Inclusion of this population will increase chances of early intervention and decrease prolonged dependence on disability benefits.
Section 411.135 - What do I do when I receive a ticket?
COMMENTS:
This paragraph should reflect that State VR programs are based on eligibility. The current paragraph reads: "Alternately, you may choose to take your ticket and receive services from your State VR agency by entering into and signing an individualized plan for employment. If a State VR provides services to you, it will decide whether to accept your ticket."
Title I of the Rehabilitation Act establishes clearly defined eligibility criteria and does not permit State VR agencies to provide services to persons unless eligibility is met.
In addition, the paragraph states: "If a State VR agency decides to be paid under the cost reimbursement payment system, you have not assigned your ticket and you may assign your ticket after State VR services end." Currently, the State VR agencies complete the State Agency Ticket Assignment Form - Ticket to Work and Self-Sufficiency Program Form SSA-1365 for the PM to assign the ticket and payment method. Will this form still be required for State VRs seeking cost reimbursement? Also, how will the PM know that the State VR services have ended? Will providing the PM with "services ended dates" be a new requirement?
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SCVRD Response to the NPRM Amendments to the Ticket to Work and Self-Sufficiency Program
Sec. 411.150 Can I reassign my ticket?
COMMENTS:
Paragraph (a) states "... You may not reassign your ticket to a State VR agency if we previously made payment to a State VR under the cost reimbursement payment system with respect to you, and you were considered to be "using a ticket" while you received services from the State VR agency." The concern is that State VR agencies cannot seek reimbursement until 9 out of 12 months of Substantial Gainful Activity are met. This usually does not occur until 1 year after a case has been closed. If reassignment of a ticket can take place 90 days after State VR agencies choosing cost reimbursement has ended, it is possible that a ticket can get reassigned to other State VR agencies acting as an EN prior to cost reimbursement being paid.
Additional Areas for Comments
1.	Should a beneficiary be eligible for more than one ticket in a period of
entitlement for SSDI or SSI benefits?
For individuals who may need long-term support, multiple tickets may provide them with the ability to receive ongoing support. However, if the intent of the Ticket Program is to decrease a persons dependence on government benefits, then multiple ticket eligibility may be misleading.
Recommendation: SSA could establish a process for individuals in need of long-term supports. There could be criteria outlined that will allow for an individual's case to be reviewed and if the severity of the disability requires long-term support, then the individual may be eligible for multiple tickets.
2.	Whether and how can the definition of "using a ticket" be simplified?
The influx of Timely Progress Reviews has caused concerns to arise regarding
the usage of tax payers' dollars for a program that provides no direct services to
persons with disabilities. The direct services are being provided by the State
VRs and ENs. Although we do receive reimbursement for cases that meet
specified success criteria, it has been noted that an exorbitant amount of money
is being spent on the processing of ticket assignments and mail outs.   For
example, the State Ticket Tracker updated on August 30, 2005 notes that a total
of 10,940,975 tickets have been issued. If each packet mailed to the
beneficiary/recipient costs $0.37 to mail, postage costs would exceed $4 million
	dollars. With only 1% of the total tickets assigned, $4 million dollars for postage
	could have been used for direct services to aid persons with disabilities to gain
the skills needed to return to work. Also, the $4 million dollars does not include the ticket assignment confirmations that are mailed to each state when a ticket is assigned, nor does it include the timely progress reviews and decision reports.
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SCVRD Response to the NPRM Amendments to the Ticket to Work and Self-Sufficiency Program
For example, SCVRD has 2,500 plus tickets in assignment. Each week this number grows by at least 10 new ticket assignments. Based on our calculations, the documentation that we will receive over the next few years relating to the tickets that are in assignment as of today, our agency will receive 50,000 plus sheets of paper relating to Timely Progress. The process of opening each envelope, researching wage information, contacting the beneficiary/recipient, researching case status information, documenting receipt of Timely Progress Reports, mailing/faxing the information to the Program Manager, and filing Timely Progress Reports has become overwhelming for our staff. We estimate that processing one Timely Progress Review takes approximately 20 minutes per review.
SCVRD believes that the Ticket to Work program has had a positive impact on those beneficiaries/recipients that want to return to work. However, it would seem that federal dollars may be spent on a concept instead of direct services that would increase the likelihood of persons with disabilities becoming less reliant on government benefits. Consideration to utilizing monies to create a stronger buy-in/extended medical coverage program for beneficiaries/recipients is recommended.
As the Ticket to Work program continues to evolve, SCVRD feels that it is imperative to provide input regarding the effects of the current legislation. Attention to the amount of money being spent on postage and paper stock and resolution to the issues surrounding the burden of Timely Progress Reports need to occur quickly in order to maintain the highest quality of service to social security beneficiaries.
Recommendation: SCVRD suggests utilizing the Individualized Plan for Employment (IPE) or Individual Work Plan (IWP) to define "using a ticket". Each of these plans are mutually developed and have established timeframes, activities, and services required for reaching an employment outcome. This will ensure that timely progress is consistent with the individual's strengths and employment outcome.
For individuals who are utilizing the ticket program, we suggest that State VR continue to utilize the SSA form 1365 without a signature to notify the PM that an IPE has been developed. Upon completion of service, State VR could notify the PM of case closure. Any wage requirements relating to "timely progress" could be the responsibility of the PM and/or beneficiaries/recipients.
3. Is the evidence requirement for EN payments unnecessarily
burdensome?
Yes. Social Security beneficiaries/recipients are required to report wages. If the
individual is working and providing wages in accordance with the law, there
should be no evidence of wages required. These wages could be documented
within the Social Security Administration's system.
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SCVRD Response to the NPRM Amendments to the Ticket to Work and Self-Sufficiency Program
Recommendation: A full integration of systems in which payments are automatically made when Social Security beneficiaries/recipients report their wages is needed. This system could be used to develop a national system of verified wage earnings for both EN and State VR to utilize when seeking wage information.
4. Is there any circumstances under which SSA should pay both Phase 1 and Phase 2 milestones to an EN for beneficiaries who assign their ticket after payment to the State Agency under cost reimbursement payment system has be made?
Cost Reimbursement requires that an individual work 9 out of 12 months at Substantial Gainful Activity. Usually the request for cost reimbursement takes place a year after the case is closed. After the development of an Individualized Plan for Employment (IPE), State VR clients are required to work 120 days before their case is closed. After case closure, they have a 90 day period before they can assign their ticket to an EN. This equates to approximately 7 months. Therefore, 7 months after an individual has begun working, they can assign their ticket to an EN. The EN could begin seeking Phase 1 payments prior to State VRs request for Cost Reimbursement.
The concern is will SSA allow for Phase 1 and Phase 2 payments to be made prior to VRs seeking cost reimbursement?
	Additional Recommendation
	Ticket Eligibility for Beneficiaries who are 16 and 17:
16 and 17 year old beneficiaries should be eligible to participate in the Ticket
Program. By making transition-aged youth ineligible for the Ticket Program, the
wrong message is being sent to youth and their parents and may encourage
lifelong dependence on benefits. At age 18 beneficiaries who are participating in
the Ticket to Work program and meeting timely progress should receive the
	same protection from redetermination that other ticket users receive from CDRs.
OPS Referral to State VRs
With the proposed regulation changes, EN and State VRs are no longer in
	competition with each other. Hence, it would seem appropriate for the state DDS
	to have the ability to refer individuals to the State VRs.
i
	Thank you for the opportunity to comment.
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