United States Government Accountability Office

GAO Report to Congressional Requesters

VOCATIONAL 

REHABILITATION 

Earnings Increased for 

Many SSA 

Beneficiaries after 

Completing VR 

Services, but Few 

Earned Enough to 

Leave SSA’s Disability 

Rolls 

March 2007 

 

GAO-07-332 
Contents 

Letter 1

Background 4

Summary 6

Observations from Phase One and Next Steps 8 

Appendix I Briefing Slides 11 

Appendix II Scope and Methodology 40 

Appendix III Comments from the Department of Education 51 

Appendix IV Comments from the Social Security Administration 53 

Appendix V GAO Contacts and Staff Acknowledgments 65 

Figure 

Figure 1: Data Sources Used to Create Analysis File on SSA 

Beneficiaries Who Completed VR in 2000 through 2003 41 

Page i GAO-07-332 Vocational Rehabilitation
Abbreviations 

DCF Disability Control File 

DI Disability Insurance 

MEF Master Earnings File 

MBR Master Beneficiary Record 

SGA Substantial Gainful Activity 

SSA Social Security Administration 

SSI Supplemental Security Income 

SSR Supplemental Security Record 

TRF Ticket Research File 

VR Vocational Rehabilitation 

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Page ii GAO-07-332 Vocational Rehabilitation
United States Government Accountability Office

Washington, DC 20548 

March 30, 2007 

The Honorable Charles B. Rangel 

Chairman 

The Honorable Jim McCrery 

Ranking Minority Member 

Committee on Ways and Means 

House of Representatives 

The Honorable Michael R. McNulty 

Chairman 

The Honorable Sam Johnson 

Ranking Minority Member 

Subcommittee on Social Security 

Committee on Ways and Means 

House of Representatives 

The Honorable Sander M. Levin 

House of Representatives 

In 2005, about 10 million working-age people with disabilities were 

beneficiaries of federal income support programs administered by the 

Social Security Administration (SSA)—namely the Disability Insurance 

(DI) program and the Supplemental Security Income (SSI) program. Both 

of these programs have grown dramatically over the past decade and the 

federal government’s cost of providing these benefits was almost $101 

billion in 2005. This growing cost and the need to redefine the relationship 

between impairments and the ability to work prompted us in 2003 to put 

federal disability programs on GAO’s high-risk list.1

As we have previously reported, the percentage of SSA beneficiaries who 

could return to work is unknown. Some beneficiaries are unlikely to work 

because of the severity of their disabilities. Those who do return to the 

workforce may face additional challenges to their ability to leave the 

disability rolls. These include a potential loss of health care insurance 

 1

 GAO, High-Risk Series: An Update, GAO-03-119 (Washington, D.C.: January 2003). 

Page 1 GAO-07-332 Vocational Rehabilitation
coverage, lack of access to technologies, and transportation difficulties.2

Nevertheless, we have reported in the past that some beneficiaries who do 

participate in the workforce have credited vocational rehabilitation 

services, in part, for their return.3

Administered by the Department of Education (Education) since 1973, the 

Vocational Rehabilitation (VR) program provides funds to states to offer 

an array of employment services that range from treatment of impairments 

to job counseling and placement. In 2005, the 80 state VR agencies were 

provided $2.6 billion in federal funds.

4

 The program serves about 1.2 

million people each year, and over a quarter of those who exit are SSA 

recipients. On average, participants stay in the VR program for 

approximately 2 years, and Education tracks employment and earnings 

outcomes for 3 months after they exit the program. 

You asked us to conduct a study examining long-term outcomes for SSA 

beneficiaries who participate in VR, on (1) the extent to which SSA 

disability beneficiaries who exit VR programs engage in work at the 

substantial gainful activity (SGA) level5

 and ultimately reduce or replace 

their benefits with earned income, (2) whether there are certain disability 

beneficiary characteristics associated with positive employment 

outcomes, and (3) whether some VR agencies have particular policies and

approaches that can be associated with positive employment outcomes. In 

agreement with your staff, the briefing we provided on February 2, 2007 

presented results on the first objective—namely, the number of SSA 

beneficiaries who gained employment or increased their earnings 

following VR, the extent to which their earnings were at the SGA level, 

whether they ultimately reduced or replaced their benefits with earned 

income, and whether they eventually left the rolls. This report formally 

conveys the information provided to you during that briefing, adjusted to 

 2

 GAO, Social Security: Disability Programs Lag in Promoting Return to Work, 

GAO/HEHS-97-46 (Washington, D.C.: March 1997). 

3

 GAO, Social Security Disability Insurance: Multiple Factors Affect Beneficiaries’

Ability to Return to Work, GAO/HEHS-98-39 (Washington, D.C.: January 1998). 

4

 Twenty-four states have separate blind and general agencies. Twenty-six states, the 

District of Columbia, and the five territories each have a single combined agency. 

5

 Individuals are considered to be engaged in substantial gainful activity (SGA) if they have

earnings above a certain amount each month (after the reduction of impairment-related 

work expenses). The amount of monthly earnings is set by SSA each year.

Page 2 GAO-07-332 Vocational Rehabilitation
reflect information provided by SSA in its review of our draft report. We 

will present the final results for objectives two and three in a future report. 

To answer the question posed in objective one, we obtained a newly 

available longitudinal data set—the Ticket Research File (TRF) subfile—

which contains information from several SSA and Education 

administrative databases on all SSA beneficiaries who left the VR program 

from 1998 through 2004. The longitudinal data enabled us to study 

outcomes far beyond the 90-day period that Education uses to track VR 

clients. The TRF subfile was matched by SSA with its Master Earnings File 

(MEF), which contains information on each beneficiary’s annual earnings 

from 1990 through 2004.6

 The combined data provide information about 

each beneficiary’s disability benefits, earnings, and VR participation. Using 

these data and focusing on SSA beneficiaries who completed VR services 

once between fiscal years 2000 and 2003,7

 we computed the number who 

had earnings after receiving VR services, the amount they earned, and 

whether their benefits were eventually reduced or discontinued. However, 

due to limitations with the data, we could not distinguish work-related 

earnings from other income sources; as a result, we reported on the 

number of beneficiaries who had earnings, but not employment, after VR. 

To assess the reliability of the SSA and Education data critical to our 

analyses, we (1) reviewed existing documentation related to the data, (2) 

interviewed knowledgeable agency officials about the data, and (3) tested 

the data for completeness and accuracy. Our findings are limited to, and

cannot be generalized beyond, the population we studied (i.e., SSA 

beneficiaries who completed VR once from fiscal year 2000 through 2003).

Additionally, because we were not able to identify a comparable control 

group, we cannot attribute positive earnings outcomes to the receipt of VR 

services. See appendix II for a more thorough discussion of our scope and 

 6

 SSA contracted with Mathematica Policy Research, Inc., to build the Ticket Research File 

(TRF). The SSA administrative databases used in the TRF include the Supplemental 

Security Record (SSR), the Master Beneficiary Record (MBR), the Numident, the 

831/832/833 Disability Files, and the Disability Control File (DCF). The earnings data from 

SSA’s MEF are annual earnings based on Internal Revenue Service W-2 tax filings and data

on the VR program came from the Department of Education’s RSA-911 database. 

7

 We excluded from our study SSA beneficiaries who may have exited VR (after receiving 

services) more than once between 2000 and 2003, to avoid double counting beneficiaries

who go through VR multiple times but leave the rolls only once. We also excluded those 

who did not successfully complete VR services (i.e., they may have applied for or started 

VR, but did not complete the VR process). Finally, we excluded DI and SSI beneficiaries 

who left the beneficiary rolls during the time period of our study due to death or their

reaching the age of 65 and becoming eligible for retirement benefits. 

Page 3 GAO-07-332 Vocational Rehabilitation
methods, including study limitations. We conducted our work between 

October 2005 and January 2007 in accordance with generally accepted 

government auditing standards. 

Although the DI and SSI programs use the same definition of disability for 

eligibility purposes, they were designed to serve different populations and 

have different benefit structures. DI provides benefits to workers with 

disabilities who generally have a qualifying work history.8

 The monthly DI 

benefit is, therefore, based on a worker’s contributions from prior 

earnings and differs for each beneficiary. In contrast, SSI provides cash 

support for people with low income, few resources, and who may have 

little or no workforce attachment. The base federal monthly SSI benefit is

generally the same for all beneficiaries.9

 Concurrent beneficiaries qualify 

for both programs because they have a qualifying work history, but still 

fall below the SSI income and resource thresholds. 

Background 

Once a beneficiary is determined eligible for disability, the two programs 

also differ in how subsequent earnings from work affect benefits. DI 

beneficiaries are allowed a 9-month trial work period,10 during which there 

are no limits on their earnings. Upon completion of the trial work period, 

beneficiaries move into a 36-month extended period of eligibility when 

their cash benefit ceases except for those months in which the beneficiary 

reports earning less than SGA.11 In 2006, SGA for nonblind beneficiaries 

was set at $860 per month.12 Recipients whose earnings are at least SGA 

 8

 A qualifying work history means beneficiaries have earned the required amount of work

credits within a certain period ending with the time period they became disabled. 

9

 States may supplement the federal monthly SSI benefit amount. Additionally, individual 

benefit amounts may vary based on a variety of other factors, such as earned and unearned 

income, and marital status. 

10 The trial work period is any 9 months within a 60-month period where the beneficiary 

earns above a certain amount ($620 per month or more in 2006). The 9 months do not have

to be consecutive, but rather can take place during any 60-month rolling consecutive time 

period. 

11 After the trial work period, if beneficiaries are working at SGA, they receive benefits for a

3-month grace period before cash benefits cease. Although cash DI benefits may cease 

most individuals with disabilities who work continue to receive at least 93 months of 

Medicare and they may be eligible to participate in Medicaid Buy-in (in some states). Also, 

after the 93-month period ends, they may be eligible to buy Medicare coverage as long as 

they still have a disability. 

12 SGA for blind beneficiaries was $1,450 per month. 

Page 4 GAO-07-332 Vocational Rehabilitation
upon completion of the extended period of eligibility will cease to receive 

benefits and will be removed from the disability rolls. In contrast, SSI 

benefits are reduced by $1 for every $2 of earned income that exceeds $65

per month, until their benefits reach zero (i.e., are suspended).13 If SSI 

beneficiaries’ monthly benefits are suspended for 12 consecutive months, 

they are taken off the disability rolls.14

Complexities inherent to the DI and SSI programs have been criticized for 

creating disincentives for beneficiaries to leave the rolls in favor of work. 

For example, many believe that the threat of losing health care coverage 

as a result of working for extended periods of time presents a significant 

obstacle to seek and maintain employment. In addition, the DI benefit 

structure has been referred to as having a “cash cliff,” because

beneficiaries who earn SGA stop receiving benefits entirely, whereas SSI 

benefits are reduced more gradually on a $1-benefit-reduction for $2-

earned-income basis. To reduce some of the disincentives that DI and SSI 

beneficiaries face in returning to work, Congress enacted the Ticket to 

Work and Work Incentives Improvement Act of 1999.

15 Among other 

provisions, the law provided vouchers for vocational services, additional 

Medicaid eligibility options, and extension of Medicare eligibility. SSA 

phased in the Ticket to Work provisions gradually over a 3-year period 

beginning in 2002. 

 13 There is a $20 general income exclusion that is first applied to unearned income. If the

beneficiary does not have any unearned income, then the $20 can be added to the $65 

exclusion for earned income. For example, if an SSI beneficiary earns $1,000 from work

during the month and receives no other income, the first $85 would be exempted leaving 

$915. Then, the $915 would be decreased by $1 for every $2 resulting in $457.50. As a result, 

the individual’s SSI benefit for that month would then be decreased by $457.50. 

14 Some SSI beneficiaries may continue to receive Medicaid coverage if their earnings

alone, or in combination with their other income, become too high to receive a cash

benefit. 

15 Ticket to Work and Work Incentives Improvement Act of 1999, Pub. L. No. 106-170 

(1999). 

Page 5 GAO-07-332 Vocational Rehabilitation
In summary, we found the following for disability beneficiaries who 

completed VR once during fiscal years 2000 to 2003: Summary 

• Earnings outcomes were mixed in the year following VR and also over 

time.16 Approximately 40 percent of the over 303,500 SSA disability 

beneficiaries in our study increased their earnings compared to the 

year prior to VR services, while 32 percent did not have any earnings 

and another 28 percent had fewer earnings. In comparison to DI and 

concurrent beneficiaries, more SSI beneficiaries—42 percent versus 36 

and 39 percent—increased their earnings in the year following VR. Of 

the disability beneficiaries who exited VR in fiscal year 2000, 33 percent 

sustained some level of earnings through 2004, although their median 

earnings decreased by 12 percent over this period. 

• Most beneficiaries’ annual earnings remained below annualized SGA in 

the year following VR.17 Specifically, 88 percent of all disability 

beneficiaries in our study had annual earnings below annualized SGA 

in the year following VR. Only a small percentage (5 percent) of 

beneficiaries from each cohort had annual earnings just below 

annualized SGA (i.e., earning over 75 percent of, but less than 

annualized SGA) in the year after VR. However, this does not provide 

evidence that beneficiaries either were or were not “parking”—i.e., 

deliberately remaining just below program income limits to retain 

benefits. Because SSA did not collect monthly earnings for DI 

beneficiaries during the timeframe of our study, we used annualized 

earnings for both DI and SSI beneficiaries, thereby limiting our ability 

to determine the extent of “parking” on a monthly basis.18 For 

beneficiaries who had earned income in the year after VR, their median 

annual earnings were $4,476. 

 16 Earnings were calculated using posted annual earnings in SSA’s Master Earnings File 

(MEF). The MEF data had several limitations that made it difficult to estimate 

beneficiaries’ earnings and earnings changes due to employment. See appendix II for

details. 

17 For the purposes of our study, annualized SGA is the monthly SGA amount for a given 

year multiplied by 12. 

18 The Supplemental Security Record (SSR) collects monthly data on SSI beneficiaries,

however, when we compared the SSR with the MEF, we found that the values between the

two data sources differed for our study population. Additionally, the most recent version of 

the SSR may not have been included in our TRF subfile. Therefore, we used the annual 

earnings from the MEF for both SSI and DI. 

Page 6 GAO-07-332 Vocational Rehabilitation
• Some beneficiaries in our study earned enough to have their benefits 

reduced in the year after VR, resulting in decreased DI and SSI program 

expenses. Benefit reductions from DI and concurrent beneficiaries in 

our four cohorts who did not receive DI benefits for 1 or more months 

due to work in the year after VR resulted in an estimated reduction in 

DI benefit payments of over $106 million.19 The average annual 

reduction in DI benefits due to work was $26.6 million. Of the 70,302 

SSI and concurrent beneficiaries in our study who had earnings gains 

from the year before VR to the year after VR, almost 50,000 (71 

percent) had a reduction in their SSI benefits. However, we were 

unable to reliably estimate SSI benefit reductions for SSI and 

concurrent beneficiaries because SSI benefit amounts can be affected 

by other factors besides earnings increases (e.g., changes in unearned 

income, spouse’s income, etc.), and, due to data limitations, we could 

not isolate the effect of beneficiaries’ earnings increases on their SSI 

benefit levels. 

• For the 2000 and 2001 exit cohorts, 10 percent of beneficiaries were 

able to leave the rolls20 at some point by 2005; however, about a quarter 

of those who left also returned for at least 1 month. While the SSI 

program saw the most departures, the lower rate of DI and concurrent 

beneficiaries leaving the rolls may be due to several factors. For 

example, DI beneficiaries are generally afforded a much longer

working period before cash benefits are completely discontinued, and

delays in the reporting of beneficiaries’ earnings data to SSA are much 

more likely to occur for DI beneficiaries. The median annual earned 

income for all beneficiaries leaving the rolls was $12,027.21 By way of 

comparison, the average annualized SGA was $9,618, and the average 

annualized disability benefit was $8,460 for the DI beneficiaries and 

 19 According to an SSA official, this may be an underestimate as we did not include DI

benefit reductions from auxiliary beneficiaries, such as a dependent child with disabilities.

See appendix II for details. 

20 For the purposes of our study, leaving the rolls is defined as the cessation of cash

disability benefits. 

21 Our estimates of disability beneficiaries’ earnings when leaving the rolls may be an

under- or overestimate because our data did not include earnings from certain sources not

covered by Social Security (e.g., earnings from state governments). See appendix II for 

details. 

Page 7 GAO-07-332 Vocational Rehabilitation
$4,452 for the SSI beneficiaries in our study in the year after VR.22

Those who returned were off the rolls for an average of 16 months. 

Although the lack of a comparable control group prevents us from 

attributing our results to the receipt of VR services, our study provides 

information about long-term earnings outcomes for disability beneficiaries 

1 or more years after exiting VR. Specifically, our study shows that after 

completing VR, a number of disability beneficiaries from the 2000 through 

2003 exit cohorts achieved positive earnings outcomes, and a few left the 

disability rolls for a period of time. While only a small number of the 

beneficiaries in our study left the disability rolls, SSA benefit reductions 

were realized as a result of increased beneficiaries’ earnings and 

subsequent reductions in their benefits. The decline in earnings in the 

years following VR suggests that many factors are likely involved in 

achieving long-term earnings gains. As research and our prior work 

suggests, a transition into the workforce for people with disabilities can be

a larger leap than it first appears—for example, the episodic nature of 

many chronic conditions can make it difficult for some beneficiaries to 

maintain steady employment levels. Moreover, it is unclear the extent to

which the potential loss of health care coverage may still present 

disincentives for SSA beneficiaries to seek and maintain employment with 

significant earnings. 

Observations from 

Phase One and Next 

Steps 

Much remains to be understood about the various factors that make it 

possible for persons with disabilities to participate in the workforce. State 

differences and local conditions may also be influences. Our next report 

will present our findings on some of these factors at the agency level—

specifically, state economies, individual VR agency policies, and types of

disabilities. We will analyze these factors’ statistical significance and effect 

on beneficiaries’ earnings outcomes. 

We received written comments on a draft of this report from Education, 

which oversees the VR program, and SSA, which manages some of the 

 22 The average annualized SGA is an average of the annualized SGA amounts for 2000 to

2004 in 2004 dollars. The average DI and SSI benefits in the year after VR include 

concurrent beneficiaries.

Page 8 GAO-07-332 Vocational Rehabilitation
data we used in this report for purposes of evaluating its Ticket to Work

efforts. In its response, Education, while acknowledging the limitations of 

the report, said our findings were consistent with its data regarding 

earnings of SSA beneficiaries upon closure from VR. See appendix III for 

Education’s complete comments. 

In its response, SSA expressed concern that limitations in our data and 

analysis prevent us from adequately addressing the research objectives. 

We believe that our final report appropriately acknowledges the 

limitations in our data and analysis and accurately and fairly addresses the 

report’s objectives, as agreed with the congressional requesters. SSA also 

expressed concern that our report, particularly the slides, could be 

misleading as discussed below and addressed in appendix IV. We believe 

that our final report does not overstate our findings and that we have 

adequately eliminated cause for misinterpretation. For example, SSA 

stated that policy makers could misinterpret the relative effectiveness of 

VR services from our study. However, we indicate in the letter and the 

slides that our findings cannot be attributed to completion of the VR 

program because we were not able to identify a comparable control group. 

Additionally, SSA indicated that our study population may have biased our

findings. We defined our study population, in part, based on interviews 

with SSA and Education, and state that our findings reflect only the 

outcomes of the individuals included in our study population and cannot 

be generalized to others. SSA also expressed concern that our estimate of 

benefit reductions may overstate the impact of SSI beneficiary earnings. 

We agree that data limitations prevented us from isolating the effect of 

earnings on SSI benefit reductions, so we removed the estimate from our 

final report. We adjusted our language to address these as well as 

additional SSA comments of a more technical nature to improve the clarity 

of the report. See appendix IV for a reprinting of all of SSA’s comments as 

well as our more detailed responses. 

Copies of this report are being sent to the Secretary of Education, the 

Commissioner of SSA, appropriate congressional committees, and other 

interested parties. This report is also available at no charge on GAO’s Web 

site at http://www.gao.gov. 

Page 9 GAO-07-332 Vocational Rehabilitation
If you have any questions about this report, please contact me at (202) 512-

7215. Contact points for our Offices of Congressional Relations and Public

Affairs may be found on the last page of this report. GAO staff who made 

major contributions to this report are listed in appendix V. 

Denise M. Fantone 

Acting Director, Education, Workforce, 

 and Income Security Issues 

Page 10 GAO-07-332 Vocational Rehabilitation
Appendix I: Briefing Slides Appendix I: Briefing Slides 

1

Earnings Increased for Many SSA 

Beneficiaries after Completing VR Services, 

but Few Earned Enough to Leave SSA’s

Disability Rolls

Briefing to Congressional Staff*

February 2, 2007

*The briefing slides were subsequently updated to reflect comments that SSA provided on our draft

report. See appendix IV for SSA’s comments and our response.

VOCATIONAL REHABILITATION

Page 11 GAO-07-332 Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 12 GAO-07-332

2

Significant Challenges for Disability 

Beneficiaries to Participating in the Workforce

In 2005, about 10 million* working-age people were receiving Social Security

Administration (SSA) disability benefits. Some disability beneficiaries may 

never work because of the severity of their disability. Those who do work

may still face additional challenges in leaving the disability rolls:

• potential loss of health insurance coverage,

• lack of access to technologies that could increase their work potential,

• transportation difficulties, or

• other potential barriers, such as tight labor markets.

• According to SSA, historically, very few disability beneficiaries have left the 

rolls because they increased their earnings through work. In 1999, the

Ticket to Work Act was passed to reduce the disincentives for SSA

beneficiaries to return to work.

*As of December 2005.

Introduction:

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 13 GAO-07-332

3

A Small Percentage of Disability Beneficiaries

Use VR Services

The Department of Education funds state Vocational Rehabilitation (VR)

agencies that provide an array of services to people with disabilities.

Although a very small percentage of all SSA disability beneficiaries choose to

participate in the VR program, over 25% who completed VR were SSA 

beneficiaries, according to Education’s data.*

In an earlier study, we reported that some disability beneficiaries who have

participated in the workforce indicated that vocational rehabilitation played 

a role in their ability to return to work.

*From 2002 through 2005, SSA disability beneficiaries increased from a quarter to over one-third of the 

population who completed VR.

Introduction (continued):

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 14 GAO-07-332

4

Examine Employment Outcomes for Disability 

Beneficiaries Who Have Completed VR

Phase One:

Today’s briefing is on the extent to which disability beneficiaries who completed 

VR once in fiscal years 2000 through 2003 subsequently earned income at the

substantial gainful activity (SGA) level* and ultimately reduced or replaced their

benefits with earned income in one or more years after VR.

Phase Two of our study, to be completed in May 2007, will examine:

• whether there are certain disability beneficiary characteristics associated with

positive employment outcomes, and

• whether some VR agencies have particular policies and approaches that can 

be associated with positive employment outcomes. 

* Individuals are considered to be engaged in substantial gainful activity if they have earnings above a certain amount

(after the reduction of impairment-related work expenses).

Study Objectives:

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 15 GAO-07-332

5

Scope and Methods for Phase One

Obtained disability beneficiary information from SSA on:

• those who completed the VR program from 1998 through 2004, 

• their benefit amounts from 1994 through 2004, and

• their annual posted earnings from 1990 through 2004.

Computed for the fiscal year 2000 to 2003 exit cohorts in the calendar year 

following VR completion and over time:*

• the number of beneficiaries with earnings through 2004,

• the amounts they earned through 2004, and

• whether their benefits were eventually reduced (through 2004) or

discontinued due to earnings (for the 2000 and 2001 exit cohorts

through 2005).

We determined the data critical to our analyses were sufficiently reliable for

our use and conducted our work in accordance with generally accepted

government auditing standards. See appendix II for details on scope and 

methods.

*Our cohorts included only beneficiaries who exited VR with services once during the timeframe of our study.

Scope and Methods:

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 16 GAO-07-332

6

Study Limitations

• Our results cannot be generalized to the larger population of all disability

beneficiaries because we looked only at those who completed VR. 

Beneficiaries who participate in or complete VR may have certain

characteristics that make them different from other SSA beneficiaries and,

therefore, either more or less likely to succeed in the workforce. Also,

without a control group, we could not isolate the impact of VR services on

earnings. That is, we could not determine whether these beneficiaries

would have been either more or less likely to achieve positive outcomes in 

the absence of the VR program.

• Due to data limitations, we used annual instead of monthly earnings data 

for both DI and SSI beneficiaries, which restricted our ability to evaluate 

earnings one year after VR and relative to SGA.

Limitations:

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 17 GAO-07-332

7

Study Limitations

• We may have under- or overestimated beneficiaries’ annual earnings, 

earnings changes, and earnings when leaving the rolls due to work

because our data did not include earnings from sources not covered by

Social Security (e.g., earnings from state governments), and included some

earnings unrelated to employment.

• DI benefit reductions are likely underestimates because they did not 

include benefit reductions for dependents.

• We were unable to estimate SSI benefit reductions due to work because, 

unlike DI benefits, SSI benefits may be affected by changes in unearned

income and assets, and data limitations prevented us from isolating SSI

benefit changes due solely to changes in earned income.

• See appendix II for a detailed discussion of our study limitations.

Limitations (continued):

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 18 GAO-07-332

8

Phase One Findings for the 2000 to 2003 Exit

Cohorts

1) Beneficiaries’ earnings outcomes were mixed in the 1 to 4 years following VR

completion.

2) 88% of beneficiaries’ annual earnings remained below annualized SGA in the year 

after VR.

3) Some earned enough income to have their benefits reduced in the year after VR, 

resulting in decreased DI and SSI program expenses:

• Disability Insurance (DI) and concurrent* beneficiaries who did not receive DI benefits in

some months due to earnings resulted in more than an estimated $106 million in benefit 

reductions.**

• 71% of Supplemental Security Income (SSI) and concurrent* beneficiaries who increased

their earnings also had their SSI benefits reduced, but data limitations prevented us from

determining the extent to which this was due to increased earnings versus some other

change in their income.

4) 2000/2001 Cohorts: By 2005, 10% of beneficiaries earned enough to leave the rolls,

but about a quarter subsequently returned for at least 1 month.

*Concurrent beneficiaries receive benefits from both DI and SSI programs. 

**Total DI benefit reductions may be underestimated because benefit reductions for dependents are not included.

Summary:

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 19 GAO-07-332

9

SSA Administers Two Disability Programs

The Social Security Administration (SSA) administers two disability benefit

programs: Disability Insurance (DI) and Supplemental Security Income

(SSI).

While both use the same definition of disability, the programs serve somewhat 

different populations: 

• DI – people with disabilities who generally have a qualifying work

history*, and

• SSI – people with disabilities who fall below certain income and 

resource thresholds and who do not have a qualifying work history.

Some (concurrent beneficiaries) qualify for both programs: They have a work 

history, but also fall below SSI’s income and resource thresholds.

*A qualifying work history means beneficiaries have earned the required number of work credits within a certain 

period ending with the time they became disabled.

Background:

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 20 GAO-07-332

10

Each Program Has Distinct Provisions

Table 1: SSA Disability Program Characteristics

Background (continued):

Note: SSI benefits are also reduced $1 for $1 for any unearned income after the $20 general income exclusion.

Disability beneficiaries may also leave the rolls when they no longer meet SSA’s definition of disability or reach

age 65 and are converted to retirement benefits.

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 21 GAO-07-332

11

Earnings Outcomes Were Mixed 1 Year after 

VR 

About 40% of the beneficiaries in our study (i.e., over 303,500 beneficiaries 

who completed VR once in 2000 to 2003) increased their annual earnings. 

The percentages by beneficiary type were:

• 42% of all SSI beneficiaries,

• 36% of all DI beneficiaries, and

• 39% of all concurrent beneficiaries in our study.

Of the remainder:

• 32% did not have any earnings, and 

• 28% had fewer earnings.

Finding One: Earnings Outcomes Were Mixed

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 22 GAO-07-332

12

Changes in Earnings 1 Year after VR

Finding One: Earnings Outcomes Were Mixed (cont.)

Figure 1: Changes in Disability Beneficiaries’ Annual Earnings from the Year before VR to the Year after VR

for the 2000 to 2003 Cohorts (N=303,529).

aBeneficiaries’ median annual earnings in the year before VR were $2,830.

*

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 23 GAO-07-332

13

The Total Percentage with Earnings

Decreased 1 to 4 Years after VR Completion

Finding One: Earnings Outcomes Were Mixed (cont.)

Figure 2: Total Percentage of Beneficiaries with Earnings in Each Year after VR.

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 24 GAO-07-332

14

2000 Cohort: 33% Had Some Level of Earnings 

over a Consecutive 4-Year Period

Of the 55% (41,367) who had 

earnings the year after VR:

• 42% were DI,

• 40% were SSI, and

• 18% were concurrent

beneficiaries.

By 2004, the percentage of those 

who had earnings in each

consecutive year was 33% - a

40% decrease. Proportionately,

fewer SSI and concurrent 

beneficiaries sustained some

earnings in each year.

Finding One: Earnings Outcomes Were Mixed (cont.)

Figure 3: Percentage of Beneficiaries from the

Fiscal Year 2000 Cohort Who Had Earnings for 4 

Consecutive Years after VR.

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 25 GAO-07-332

15

2000 Cohort: Median Earnings Fell Slightly for 

Those with 4 Years of Consecutive Earnings

Of the 33% (24,583) who had some

level of earnings for 4 consecutive

years after VR, their median

earnings declined by 12%.

Our data do not allow us to determine 

the reasons for the decrease in

earnings (e.g., whether the 

beneficiaries worked fewer hours

or their wages decreased).

Finding One: Earnings Outcomes Were Mixed (cont.)

Figure 4: Median Annual Earnings for the Fiscal

Year 2000 Cohort Beneficiaries Who Had Earnings

for 4 Consecutive Years after VR (N=24,583).

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 26 GAO-07-332

16

88% of Beneficiaries Had Annual Earnings

Below Annualized SGA 1 Year after VR

Finding Two: Earnings Remained Below SGA

Note: Figure represents percentage of annualized SGA in the year after VR for all exit cohorts combined and 

includes those who did not have any earnings. Annualized SGA is the monthly SGA for a given year

multiplied by 12. 

Figure 5: Percentage of Annualized SGA Earned by Beneficiaries in the Year after VR for the 2000 to 2003 Cohorts 

(N=303,528).

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 27 GAO-07-332

17

Annual Earnings after VR Do Not Provide 

Evidence of “Parking”

Only a small percentage of beneficiaries from each cohort had annual

earnings just below annualized SGA:

• In the year after VR, 5% of beneficiaries earned just below the annualized SGA

level (see figure on previous slide).*

• By 2004, the percentage of beneficiaries just below annualized SGA had 

decreased to 3.8% for both the 2000 and 2001 cohorts.

However, this does not provide evidence that beneficiaries either were or

were not “parking” – i.e., deliberately remaining just below monthly program

income limits so as not to lose their disability benefits. Because monthly

earnings for DI beneficiaries were not collected for the timeframe of our 

study, we used annualized earnings for both DI and SSI beneficiaries,

thereby limiting our ability to determine the extent of “parking” on a monthly 

basis.

*Consistent with past GAO reports, we considered annual earnings that were over 75% of, but less than annualized

SGA, to be just below the annualized SGA level.

Finding Two: Earnings Remained Below SGA (cont.)

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 28 GAO-07-332

18

Median Earnings Were $4,476 in the Year after 

VR for Those Who Had Earnings

In the year after VR, the median annual earnings for all disability beneficiaries 

from the 2000 to 2003 cohorts who had earnings (almost 153,000 people) 

were $4,476 or less than half of the average annualized SGA of $9,618.*

Specifically, median annual earnings by program were:

• $5,474 for DI,

• $3,757 for SSI, and

• $3,596 for concurrent beneficiaries.

*Median earnings and average annualized SGA are in 2004 dollars. The average annualized SGA is the annualized

SGA averaged over the 2000 to 2004 time period.

Finding Two: Earnings Remained Below SGA (cont.)

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 29 GAO-07-332

19

2000/2001 Cohorts: Fewer Earned at or above 

Annualized SGA over Time

The percentage who had annual earnings at or above annualized SGA 

decreased slightly from 1 year after VR through 2004, as follows:

• 2000 Cohort – decreased from 14.6% in 2001 to 11.8% in 2004, 

and

• 2001 Cohort – decreased from 12.4% in 2002 to 11.0% in 2004.

Finding Two: Earnings Remained Below SGA (cont.)

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 30 GAO-07-332

20

DI: Benefit Reductions Due to Work Totaled 

About $106 Million

Almost 9% of DI and concurrent beneficiaries in our study did not receive any 

DI benefits at some point in the year after VR due to work, with the majority

not receiving DI benefits for over half the year.

DI benefit reductions for DI and concurrent beneficiaries in our study totaled

over an estimated $106 million (2004 dollars):*

• 2000 cohort – over 4,700 beneficiaries had their benefits reduced by $30.0 

million in 2001,

• 2001 cohort – almost 4,600 beneficiaries had their benefits reduced by

$29.8 million in 2002,

• 2002 cohort – almost 3,700 beneficiaries had their benefits reduced by

$22.9 million in 2003, and 

• 2003 cohort – almost 3,700 beneficiaries had their benefits reduced by

$23.8 million in 2004.

The average annual benefit reduction across cohorts was $26.6 million.

*This may be an underestimate as we did not include benefit reductions for auxiliary beneficiaries, such as a 

dependent child with disabilities. See appendix II for details.

Finding Three: Some Reduced Their Benefits

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 31 GAO-07-332

21

SSI: Benefit Reductions Due to Work Cannot

Be Reliably Estimated

Of the 70,302 SSI and concurrent beneficiaries in our study who had earnings 

gains from the year before VR to the year after VR, almost 50,000 (71%) 

had a reduction in their SSI benefits. 

• For concurrent beneficiaries (who comprised over 16,000 of the 

50,000 who had earnings gains and benefit reductions), 70% may 

have earned enough to also increase their DI benefit during the same

time period.

We were unable to reliably estimate SSI benefit reductions due to earnings for 

SSI and concurrent beneficiaries because SSI benefit amounts can be 

affected by other factors besides earnings increases (such as changes in

unearned income, spouse’s income, etc.), and, due to data limitations, we

could not isolate the effect of beneficiaries’ earnings increases on their 

benefit levels.

Finding Three: Some Reduced Their Benefits (cont.)

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 32 GAO-07-332

22

2000/2001 Cohorts: 10% Were Able to Leave 

the Rolls at Some Point before 2005

Of the beneficiaries who completed VR in 2000 or 2001 (for whom we have 

the most years of earnings data), the percentages who left the rolls by

program were:

• 16% of all SSI beneficiaries (over 9,600 people),

• 9% of all DI beneficiaries (almost 5,900 people), and

• 3% of all concurrent beneficiaries (over 800 people) in our study.*

While 3% of the concurrent beneficiaries in our study had their benefits from

both programs discontinued, during the same time period:

• 19% of concurrent beneficiaries stopped receiving only their SSI benefits,

and 

• 4% stopped receiving only their DI benefits.

*Leaving the rolls is defined as cessation of cash disability benefits due to work even though the individual remains 

medically eligible. Concurrent beneficiaries were considered to have left the rolls if their benefits were 

discontinued from both programs. Those concurrent beneficiaries who left only DI or SSI were not included in the

percentages who left the rolls for those specific programs. 

Finding Four: 10% Left, but Some of These Returned

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 33 GAO-07-332

23

Differences in Program Rates of Leaving the 

Rolls May Be Affected by Several Factors

The fact that more SSI beneficiaries from the 2000 and 2001 cohorts left the 

rolls...

• 16% of all SSI,

• 9% of all DI, and

• 3% of all concurrent beneficiaries in our study left the rolls.

...may be due to several factors, including:

• program rule differences, such as DI being afforded a much longer 

working period before cash benefits cease entirely, and

• delays in the reporting of earnings data to SSA, with delays more likely

for DI.

Finding Four: 10% Left, but Some of These Returned

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 34 GAO-07-332

24

2000/2001 Cohorts: Annual Earnings of Many 

Beneficiaries Who Left the Rolls Were Low 

Finding Four: 10% Left, But Some of These Returned

Note: Excludes those beneficiaries who left the rolls due to work, but did not have any earnings. See appendix II for 

details.

Figure 6: Annual Earnings Distribution (in 2004 dollars) for Beneficiaries from the 2000 and 2001

Cohorts in the Year They Left the Rolls through 2004 (N=15,066).

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 35 GAO-07-332

25

2000/2001 Cohorts: Annual Earnings for 

Those Who Left the Rolls Differed by Program

Beneficiaries’ median annual earnings (in 2004 dollars) in the year they left 

the rolls was $12,027. By program, median earnings were: 

• $17,166 for DI,

• $14,323 for concurrent, and

• $ 8,128 for SSI beneficiaries in our study.*

By comparison, the average annualized SGA for 2000 to 2004 was $9,618

and the average annualized disability benefits (in 2004 dollars) for the 2000

to 2003 cohorts in the year after VR were:

• $8,460 for DI, and

• $4,452 for SSI beneficiaries in our study.**

*Excludes those beneficiaries who left the rolls due to work, but did not have any earnings. Earnings for those who 

left the rolls are only through 2004, as we did not have 2005 earnings data. 

** Includes concurrents.

Finding Four: 10% Left, But Some of These Returned

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 36 GAO-07-332

26

2000/2001 Cohorts: About a Quarter of Those 

Who Left the Rolls Returned by 2005

By 2005, of the over 16,000 beneficiaries in our study who had left the rolls,

24% (over 3,900 people) were again receiving disability benefits for at least 

1 month. By beneficiary type: 

• 25% of DI beneficiaries who left the rolls returned, 

• 21% of SSI beneficiaries who left the rolls returned, and 

• 48% of concurrent beneficiaries who left the rolls returned (to DI, SSI,

or both).

Those who returned had been off the rolls for an average of 16 months.

Finding Four: 10% Left, But Some of These Returned

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 37 GAO-07-332

27

2000/2001 Cohorts: Percentage Who Left the 

Rolls and Returned by Program

Finding Four: 10% Left, But Some of These Returned

Figure 7: Percentage of Beneficiaries from the 2000 and 2001 Cohorts Who Left the Rolls and Returned for at Least 

1 Month by 2005 (N=157,915)

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 38 GAO-07-332

28

Observations from Phase One

• A number of disability beneficiaries who completed VR in 2000 to 2003

achieved positive earnings outcomes, and a few left the disability rolls; 

however, because we were not able to identify a comparable control 

group, we cannot attribute these outcomes to receipt of VR services.

• Benefit reductions were realized for our exit cohorts as a result of

increased beneficiary earnings even for some beneficiaries who did not

leave the rolls, although we were unable to reliably estimate SSI benefit 

reductions due to data limitations.

• The decline in earnings in the years following VR suggests that many

complex factors are likely involved in achieving long-term employment.

Observations and Next Steps:

Vocational Rehabilitation
Appendix I: Briefing Slides 

Page 39 GAO-07-332

29

Next Steps

Our next report will analyze beneficiary characteristics at the agency level.

• We will present our findings on factors that may affect the success of

beneficiaries in the workforce – specifically, state economies,

individual VR agency policies, and types of disabilities. 

• We will analyze their statistical significance and effect on earnings

outcomes.

Observations and Next Steps:

Vocational Rehabilitation
Appendix II: Scope and Methodology Appendix II: Scope and Methodology 

To conduct our work, we obtained a newly available longitudinal data 

set—a subfile of the Ticket Research File (TRF)—which contains 

information from several Social Security Administration (SSA) and 

Department of Education (Education) administrative databases on all SSA 

disability beneficiaries who completed the federal-state vocational 

rehabilitation (VR) program between 1998 and 2004.1

 SSA merged this data 

set with its Master Earnings File (MEF), which contains information on 

each beneficiary’s annual earnings from 1990 through 2004. (See figure 1 

for a depiction of data sets used in our analysis.) The combined data 

provide information about each beneficiary’s disability benefits, earnings, 

and VR participation.2

 With these data on long-term benefits and earnings,

we were able to study disability beneficiaries’ earnings levels far beyond 

the 90-day period that Education uses to track VR clients, as well as the 

effect that earnings changes had on benefit levels. 

 1

In 2003, SSA contracted with Mathematica Policy Research to conduct a full evaluation of

the Ticket to Work Program. As part of this evaluation, Mathematica constructed the Ticket 

Research File (TRF), a compilation of longitudinal data from SSA. An extract of the TRF 

was merged with vocational rehabilitation data from the Department of Education’s RSA911 database by an SSA official. 

2

 Education’s data on VR closures were available from 1998 to 2004. Data from SSA’s TRF 

database were available from 1994 to 2004 with MEF earnings data available from 1990 to 

2004. Social Security’s MEF data are annual earnings based on Internal Revenue Service W2 tax filings. At the time we obtained this data set from SSA, earnings data for 2005 were

not available. 

Page 40 GAO-07-332 Vocational Rehabilitation
Appendix II: Scope and Methodology 

Figure 1: Data Sources Used to Create Analysis File on SSA Beneficiaries Who Completed VR in 2000 through 2003 

SSA Education

SSA SSA

GAO

Ticket Research File (TRF)

extract

Rehabilitation Services 

Administration 911 Database

(RSA-911)

TRF subfile Master Earnings File

Analysis file on SSA 

beneficiaries

who completed VR

Source: GAO analysis.

We assessed the reliability of the databases used to create the TRF subfile 

and the Master Earnings File and determined that, despite the limitations 

outlined below, the data that were critical to our analyses were sufficiently 

reliable for our use. Specifically, we performed the following 

• reviewed documentation regarding the planning and construction of 

the administrative databases used to construct the TRF subfile, the 

results of data reliability tests conducted by SSA’s database contractor, 

and whether documented plans were implemented; 

• conducted multiple interviews with SSA and Education officials who 

work with the databases from which the TRF subfile and earnings data 

were drawn to understand the construction of the data fields;

Page 41 GAO-07-332 Vocational Rehabilitation
Appendix II: Scope and Methodology 

• conducted our own electronic data testing to assess the accuracy and 

completeness of the data used in our analyses; and 

• consulted with GAO staff knowledgeable about these data sets. 

Study Population In consultation with SSA officials and contractors as well as Education 

officials, we selected as our study population working-age individuals 

receiving DI only, SSI only, or both DI and SSI benefits concurrently, who 

exited VR after having received services.3

 To use the most recent data 

available, we further refined this population to include those beneficiaries 

who 

• began receiving VR services no earlier than 1995 and who completed 

VR after having received services in fiscal years 2000 through 2003; 

• had received a DI or SSI benefit payment at least once during the 3

months before application for VR services (Beneficiaries were defined

as concurrent if they received both DI and SSI benefits for at least 1 

month in the 3 months before VR application. We selected a 3-month 

window to account for the fact that many beneficiaries, SSI 

beneficiaries in particular, fluctuate in their receipt of benefits for any 

given month.); and 

• exited VR once during the timeframe of our study. 

We excluded from our study population those disability beneficiaries who 

• started VR prior to 1995 (Earlier disability benefit information was not 

available, therefore, including beneficiaries who started VR prior to 

1995 would have limited our analyses of benefit changes before and 

after VR.);4

• completed VR after 2003, and for whom we lacked at least 1 year of 

long-term outcome data; 

• applied for or started VR services, but did not complete VR; 

• began receiving disability benefits after receiving VR services because 

these beneficiaries may have differed in certain important 

characteristics from those receiving benefits before VR participation; 

 3

 Our study population included disabled adult children and disabled widow(er)s, who may 

receive DI benefits based on their parents’ or spouses’ Social Security earnings record. 

While their benefits are paid from the Old-Age and Survivors Insurance Trust Fund, these 

individuals are disabled and are eligible for VR services. 

4

 Approximately 90 percent of VR consumers spend 5 years or less in VR, therefore, 

excluding those who started VR prior to 1995 decreased our population by 10 percent with 

the greatest effect on the 2000 cohort. 

Page 42 GAO-07-332 Vocational Rehabilitation
Appendix II: Scope and Methodology 

• reached age 65 or died at any point in their VR participation or during 

the timeframe of our study (We excluded the beneficiaries who died or 

reached age 65 because they would have left the disability rolls for 

reasons unrelated to employment. For example, beneficiaries who 

reach age 65 convert to SSA retirement benefits.); and 

• participated in VR more than once during the timeframe of our study. 

About 17 percent of the beneficiaries in our data, who received VR 

services more than once during the timeframe of our study, were 

excluded to avoid double counting beneficiaries who may have 

received services multiple times, but who left the rolls only once. 

Our final study population included 303,529 DI, SSI, or concurrent 

beneficiaries who had completed VR once during the timeframe of our 

study. 

We were not able to compare the earnings of beneficiaries who completed 

VR with a control group that had not completed VR because we could not

identify a group that was sufficiently similar to those who completed VR to 

feel confident that any differences in outcomes that we found would be 

attributable to the VR program and not to the differences in individual 

characteristics. 

Analysis of Outcomes—An 

Overview

Using the TRF subfile combined with data from SSA’s Master Earnings 

File, we computed for the fiscal year 2000 through 2003 exit cohorts the 

number of beneficiaries who had earnings after receiving VR services, the

amount they earned, how their earnings compared to the substantial 

gainful activity (SGA) amount,5

 and whether their benefits were eventually 

reduced or discontinued. We conducted separate analyses for DI, SSI, and 

concurrent beneficiaries because the programs differ in structure and 

incentives. On the advice of SSA officials, we used only the nonblind SGA 

amount in our calculations because the data did not indicate which 

beneficiaries were legally blind—a requirement to receive the blind SGA 

amount.6

 5

 Individuals are considered to be engaged in substantial gainful activity (SGA) if they have

earnings above a certain amount each month (after the reduction of impairment-related 

work expenses). The amount of monthly earnings is set by SSA each year.

6

 Only a fraction of those individuals reporting visual impairments meet the criteria to be 

considered legally blind. While there was not an indicator for legal blindness in the version 

of the TRF subfile that we received from SSA, it will be included in subsequent versions.

Page 43 GAO-07-332 Vocational Rehabilitation
Appendix II: Scope and Methodology 

When we compared dollar amounts (i.e., earnings, benefits, and SGA 

levels) across cohorts and years, we needed a way to control for the 

impact of changes in the economy and inflation over time. To control for 

these changes, we standardized the dollar amounts in our calculations 

using the Consumer Price Index for All Urban Consumers (CPI-U). The 

CPI-U, maintained by the Bureau of Labor Statistics, represents changes in 

prices of all goods and services purchased for consumption by urban 

households. The CPI-U can be used to adjust for the effects of inflation, so

that comparisons can be made from one year to the next using 

standardized dollars. We standardized the value of earnings, benefits, and 

SGA levels to 2004 dollars because this was the most recent year for which 

earnings data were available at the time of our analysis. 

We assessed earnings outcomes using annual earnings data. Specifically, 

we computed 

Analysis of Earnings Outcomes 

• the amount earned in the year after VR and how those earnings differed 

from the year prior to VR;

7

 and 

• whether beneficiaries had some level of earnings over 4 consecutive 

years (for the 2000 cohort only because we had the most years of data 

for this group). 

To ensure we fully captured beneficiaries’ earnings before entry into VR, 

we compared earnings from the year before VR to the year after VR as well 

as earnings from 2 years before VR to the 2 years after VR. Because the 

results between these two analyses were consistent, we reported only the 

differences between the year before VR and the year after VR to allow us 

to incorporate as many cohorts as possible in our analyses. We also 

compared the date beneficiaries were determined to be eligible for 

disability benefits with their date of application to VR to ensure their 

earnings in the year before VR were after being found eligible for disability 

benefits, but prior to receipt of VR services. 

To compare annual earnings with SGA, we created an annualized SGA 

amount. SGA, a monthly earnings amount updated each year by SSA, is 

used to determine whether an individual is engaging in substantial work. 

We used annual earnings for both DI and SSI because, at the time of our 

Analysis of Annual Earnings in 

Relation to Annualized 

Substantial Gainful Activity 

(SGA) Level 

 7

 To determine a beneficiary’s earnings in the year after VR, we calculated earnings in the 

calendar year after the year in which beneficiaries completed VR. For example, if a

beneficiary completed VR in October 2000, earnings from January 2001 through December 

2001 would have been used to determine earnings in the year after VR. 

Page 44 GAO-07-332 Vocational Rehabilitation
Appendix II: Scope and Methodology 

study, only annual earnings were collected for DI beneficiaries.8 To 

present comparable information between beneficiaries’ annual earnings 

and SGA, we created an annualized SGA amount for each cohort by 

multiplying SGA for a given year by 12. The nonblind monthly SGA levels 

for the years of our study were: 2000—$700; 2001—$740; 2002—$780; 

2003—$800; and 2004—$810. 

To determine what percentage of annualized SGA each cohort earned in 

the year after VR, we compared beneficiaries’ annual earnings for each 

cohort to the annualized SGA amount for that year. For example, we 

compared the 2000 cohort’s 2001 earnings to the 2001 annualized SGA 

level. When we computed the median annual earnings for beneficiaries 

who had earnings—irrespective of cohort—in the year after VR and for 

those who left the rolls, we averaged the annualized SGA amount from 

2000 through 2004 and standardized it in 2004 dollars as a point of 

reference.9

To determine whether beneficiaries might have been “parking,” or earning 

amounts that were close to, but never exceeding, annualized SGA, we 

analyzed the percentage of beneficiaries in our study whose annual 

earnings were just below annualized SGA. If beneficiaries were parking, 

we would expect to find their annual earnings just below the annualized 

SGA level. While there are no clear criteria for identifying the point at 

which a beneficiary can be said to be earning “just below” SGA, consistent 

with our prior work we considered parking to be earning over 75 percent 

of, but less than, annualized SGA.10

We determined the number of SSI and concurrent beneficiaries who had 

SSI benefit reductions by comparing benefit levels in the year before VR to 

the year after VR. Because SSI benefit reductions can occur as a result of 

Analysis of SSI Benefit Changes 

and Reductions 

 8

 The Supplemental Security Record (SSR) collects monthly data on SSI beneficiaries, 

however, when we compared the SSR with the MEF, we found that the values between the

two data sources differed for our study population. Additionally, the most recent version of 

the SSR may not have been included in our TRF subfile. Therefore, we used the annual 

earnings from the MEF for both SSI and DI. 

9

For the purposes of our study, to compute the average annualized SGA we converted the

nonblind monthly SGA amounts for each year (2000 to 2004) into 2004 dollars. We then 

multiplied the monthly rates by 12, added the annual amounts for all years, and determined 

the average. 

10 GAO, SSA Disability: SGA Levels Appear to Affect the Work Behavior of Relatively Few 

Beneficiaries, but More Data Needed, GAO-02-224 (Washington, D.C.: January 2002).

Page 45 GAO-07-332 Vocational Rehabilitation
Appendix II: Scope and Methodology 

an increase in income from sources other than earnings, we examined 

benefit changes, and the resulting reductions, for only those beneficiaries 

who had an earnings gain from the year before VR to the year after VR.11

To identify whether SSI and concurrent beneficiaries had SSI benefit 

changes from the calendar year before VR to the calendar year after VR,

we used the benefit “due” field because it is not affected by under- or 

overpayments.12 Of the concurrent beneficiaries who had an earnings gain 

and a benefit reduction, we determined how many also had a DI benefit 

increase during the same time period. 

We calculated the reduction of DI benefit payments for each cohort in the 

year after VR based on the number of months DI and concurrent 

beneficiaries were in DI benefit suspension or termination.13 For the 

calendar year after VR completion, we calculated the percentage of 

beneficiaries who did not receive DI benefits for 1 or more months 

because they were in either benefit suspension or termination. We also 

determined the percentage who were in benefit suspension or termination 

for the majority of the year after VR by dividing the number who were in 

benefit suspension or termination for 7 to 12 months of the year by the 

total number who were in benefit suspension or termination for 1 month 

or more. To determine the estimated reduction in benefit payments 

resulting from benefit suspensions or terminations, we multiplied each DI 

and concurrent beneficiaries’ monthly benefit amount (in 2004 dollars) by

the number of months they were in benefit suspension or termination and 

summed the amounts for each cohort in the year after VR. 

Analysis of Reduction of DI 

Benefit Payments 

 11 SSI monthly benefits could increase or decrease for a variety of reasons, including 

changes in marital status, living arrangements, or unearned income. 

12 We also computed the average benefit reduction amount for beneficiaries with earnings

gains, and the total benefit reduction amount, for all cohorts in the year after VR. To 

estimate the total benefit reductions resulting from SSI benefit changes, we summed the

total SSI benefit changes (in 2004 dollars) for each cohort in the year after VR. We

ultimately decided not to report these estimates because we could not determine the extent 

to which benefit reductions were due to changes in earnings or due to changes in other 

factors. 

13 Beneficiaries who do not receive their benefit in a given month during the extended 

period of eligibility are in benefit suspension. Those who have completed the extended 

period of eligibility and no longer receive a benefit are considered to have been terminated 

from the disability rolls. 

Page 46 GAO-07-332 Vocational Rehabilitation
Appendix II: Scope and Methodology 

To determine whether disability beneficiaries in our study left the rolls 

before 2005 and if they returned before 2005, we used data from the TRF 

subfile that indicated the month in which a beneficiary left the rolls 

because of work. We also calculated beneficiaries’ earnings in the year 

they left the rolls. We included beneficiaries who left the rolls after their 

VR application date and counted them as having returned if they returned 

for 1 month or more. Concurrent beneficiaries were considered to have

left the rolls only if they stopped receiving benefits from both programs, 

and to have returned to the rolls if they returned to either program. 

Analysis of Departures from 

and Returns to the Disability 

Rolls 

Our data indicated that some beneficiaries in our study who left the rolls 

due to work also did not have any earnings. According to SSA, some 

beneficiaries may have earned enough to leave the rolls, but then stopped 

working in the same year that their benefits ceased. Additionally, some 

beneficiaries may have had earnings from sources that were not covered

by Social Security—for example, earnings from state governments—and, 

therefore, would not be in our earnings data. While we included all 

beneficiaries that the data indicated left the rolls due to work in our 

calculations of the number who left the rolls, we eliminated those with 

zero earnings in the MEF from the earnings calculations of those who left 

the rolls to avoid an artificial reduction in median earnings. 

Limitations of our 

Analyses 

Our results cannot be generalized to the larger population of all SSA 

disability beneficiaries because we looked only at beneficiaries who 

completed VR. Because VR participation is voluntary, beneficiaries who 

participate in VR may have certain characteristics that make them 

different from other SSA beneficiaries and, therefore, more likely or less 

likely to succeed in the workforce. Also, without a control group, we 

cannot isolate the impact of VR services on outcomes. That is, we cannot 

determine whether these beneficiaries would have been either more or 

less likely to achieve positive outcomes in the absence of the VR program. 

Our earnings data had several limitations that made it difficult to estimate 

beneficiaries’ earnings and earnings changes due to employment. For 

example, while the beneficiary earnings data were provided to SSA by the 

Internal Revenue Service and are considered to be the most 

comprehensive and accurate measure of earnings available, they excluded 

several categories of workers who participated in alternative retirement 

Limitations in Analyzing 

Earnings 

Page 47 GAO-07-332 Vocational Rehabilitation
Appendix II: Scope and Methodology 

systems and whose earnings may not have been reported to SSA.14 Such 

omissions could have resulted in an under- or overestimate of beneficiary 

earnings. On the other hand, some earnings reported to SSA may have 

included income derived from work activity in a previous year, such as 

commissions or bonuses. Further, the earnings data included some forms 

of nonwork income, such as sick leave earnings and profit sharing. These 

additional sources of income could not be identified and separated out of

SSA’s data and, therefore, could result in an overestimation of 

beneficiaries’ earnings due to employment in a particular year, and either 

an over- or under-estimate of earnings changes over time. The data did not 

allow us to estimate the magnitude of the effect of these factors on our 

analyses. 

In addition, our use of annual earnings data limited our ability to analyze 

outcomes in the year following VR. Specifically, we were limited to using

all earnings in the calendar year after VR, irrespective of the time gap 

between VR completion and the first month of the next calendar year. The 

start month for calculating earnings in the year after VR could have ranged

from the 1st to the 12th month after VR, depending on which month the 

beneficiary exited. For example, beneficiaries who exited VR in June 2000 

would have their 2001 annual earnings calculated beginning in January 

2001—6 months after their exit from VR. Whereas beneficiaries who 

completed VR in December 2000, would have been out of VR for 1 month 

when their 2001 annual earnings calculation started in January 2001. We

have no indication of clustering in earnings relative to VR completion, and, 

therefore, expect a fairly even distribution of earnings over time. We do 

not expect the time lag in the earnings calculation to vary systematically 

by year or cohort. 

The earnings data also limited our ability to assess the extent of “parking” 

on a monthly basis. Beneficiaries may work inconsistently throughout the 

year and not have earnings in some months. Because the Master Earnings 

File only contains annual earnings data, we were not able to identify 

parking that might have occurred among beneficiaries, who, for example, 

worked for only a few months during the year and limited their earnings to 

a level near, but not exceeding, the monthly SGA level in each of those 

months. 

Limitations in Analyzing 

“Parking” 

 14 Workers who may have been excluded include federal civilian employees hired before

1984 and certain state and local government employees. 

Page 48 GAO-07-332 Vocational Rehabilitation
Appendix II: Scope and Methodology 

Our calculations on DI benefit reductions may have resulted in under- and

overestimates. For example, in calculating the DI reduction in benefit 

payments from beneficiaries in benefit suspension or termination, we did 

not include the reduction in benefit payments for auxiliary beneficiaries—

such as a dependent child with disabilities—who would also not have 

received a benefit. According to an SSA official, this could result in an 

underestimate of benefit payment reductions. Additionally, we used the 

Consumer Price Index to inflate DI benefit amounts to 2004 dollars. Using 

another inflation standard—such as the wage index—may have produced

different results. 

Limitations in Analyzing 

Benefit Reductions 

With respect to SSI, while we attempted to capture SSI benefit changes 

due to earnings by limiting our analysis to beneficiaries with earnings 

gains, our data did not allow us to completely exclude benefit changes that 

may have been due to other factors. Therefore, we did not report 

estimated SSI benefit reduction amounts. 

Our finding that more SSI than DI beneficiaries ultimately left the rolls is 

likely due to several factors, including the different structures of the DI 

and SSI programs. DI beneficiaries are allowed a trial work period (9 

months) and an extended period of eligibility (36 months) before they are 

considered off the rolls.15 In contrast, SSI beneficiaries who earn enough 

so that they do not receive a benefit for 12 months are taken off the rolls. 

Therefore, given the 4-year timeframe of our study, many DI beneficiaries 

may not yet have entered or completed their extended period of eligibility 

or reached the point where they would be considered off the rolls. 

Limitations in Analyzing 

Beneficiaries Who Left the 

Rolls 

In addition, delays in the reporting of earnings may also have contributed 

to our finding that relatively more SSI than DI beneficiaries left the rolls 

due to work. There can be a significant delay—up to 3 years—between 

when beneficiaries begin work and when SSA is notified or learns of their 

earnings. This delay is more likely to occur with DI beneficiaries, whose 

earnings were reviewed on a yearly basis as compared to monthly earnings 

reviews for SSI beneficiaries during the timeframe of our study. Because 

of this reporting delay, the TRF subfile data that indicated whether a 

beneficiary left the rolls may not have contained completely up-to-date 

data, especially for later cohorts. 

 15 The 9-month trial work period must occur within a 60-month period. 

Page 49 GAO-07-332 Vocational Rehabilitation
Appendix II: Scope and Methodology 

We may have under- or overestimated the earnings of those beneficiaries 

who left the rolls. Because our data did not include earnings from sources 

not covered by Social Security and we could not include their earnings in 

our analysis, we may have underestimated the earnings of beneficiaries in 

the 2000 and 2001 cohorts in the year they left the rolls. However, if the 

beneficiaries who had noncovered earnings earned less on average than 

those whose earnings were included in our data, it is possible that we 

could have overestimated earnings for those beneficiaries who left the 

rolls. 

Page 50 GAO-07-332 Vocational Rehabilitation
Appendix III: Comments from the Department Appendix III: Comments from the of Education 

Department of Education 

Page 51 GAO-07-332 Vocational Rehabilitation
Appendix III: Comments from the Department 

of Education 

Page 52 GAO-07-332 Vocational Rehabilitation
Appendix IV: Comments from the Social Appendix IV Security Administration : Comments from the Social 

Security Administration 

Note: GAO’s comments 

supplementing those in 

the report text appear at 

the end of this appendix. 

Page 53 GAO-07-332 Vocational Rehabilitation
Appendix IV: Comments from the Social 

Security Administration 

See comment 1. 

See comment 2. 

Page 54 GAO-07-332 Vocational Rehabilitation
Appendix IV: Comments from the Social 

Security Administration 

See comment 3. 

Page 55 GAO-07-332 Vocational Rehabilitation
Appendix IV: Comments from the Social 

Security Administration 

See comment 4. 

Page 56 GAO-07-332 Vocational Rehabilitation
Appendix IV: Comments from the Social 

Security Administration 

See comment 5. 

See comment 6. 

Page 57 GAO-07-332 Vocational Rehabilitation
Appendix IV: Comments from the Social 

Security Administration 

See comment 7. 

See comment 8. 

Page 58 GAO-07-332 Vocational Rehabilitation
Appendix IV: Comments from the Social 

Security Administration 

See comment 9. 

Page 59 GAO-07-332 Vocational Rehabilitation
Appendix IV: Comments from the Social 

Security Administration 

See comment 10. 

See comment 11. 

Page 60 GAO-07-332 Vocational Rehabilitation
Appendix IV: Comments from the Social 

Security Administration 

The following are GAO’s comments on the Social Security 

Administration’s letter dated March 2, 2007. 

1. We agree that there is some potential for readers to misinterpret the 

title. Therefore, we adjusted it to indicate that we analyzed 

beneficiaries’ earnings after completing VR services, rather than 

workforce participation. Additionally, we removed the reference to 

SGA because we acknowledge the limitations of using annual earnings 

data in determining whether beneficiaries were earning SGA. 

GAO’s Comments 

2. We clarified our description of the Ticket Research File. 

3. Regarding the scope of our review, we disagree that our study 

population biases our findings or that we have characterized our 

findings as representing VR effectiveness for all beneficiaries 

completing VR. We indicate that our findings are based on the 

outcomes of the individuals included in our study population, are not 

intended to represent potential outcomes for groups outside this 

population, and cannot be attributed to VR. In accordance with our 

objective to determine whether beneficiaries eventually replace their 

benefits with earned income, we focused on those beneficiaries who 

could have potentially left the rolls due to work following completion 

of VR services; therefore, we excluded people who retired or died 

during the timeframe of our study because they would have left the 

disability rolls for reasons unrelated to an increase in earnings. We 

clarified why these groups were excluded in our discussion of scope 

and methods in appendix II. We also stated in this appendix that our 

findings cannot be attributed to VR because we were unable to identify 

a control group. 

We agree that the left-due-to-work variable distinguishes between 

those who left the rolls due to work and those who were ineligible for 

benefits for other reasons. However, the left-due-to-work variable was 

not developed by SSA’s contractor until several months into our study. 

Once the variable was available, we incorporated it into our analysis. 

However we disagree, for reasons discussed in the preceding 

paragraph, that it was inappropriate to exclude those beneficiaries 

who died or reached 65 during the timeframe of our study. 

SSA noted that the report should clarify which disability beneficiaries 

are included in our study. We adjusted our language to better reflect 

which beneficiaries were included, why we excluded certain

beneficiaries, and the numbers and percentages of beneficiaries in our 

study population as appropriate. 

Page 61 GAO-07-332 Vocational Rehabilitation
Appendix IV: Comments from the Social 

Security Administration 

4. We agree with SSA that “benefit reductions” more accurately describes 

the analysis we conducted than “program savings” and have changed 

the report accordingly. We also clarified that benefit reductions 

included the sum of one year following VR for all four cohorts and 

added an annual average in the letter’s Summary section and in the 

slides. 

While SSA stated that our methodology does not permit an assessment 

of the possible outcome in the absence of VR, we explicitly state in the

letter and the slides that we could not isolate the impact of VR because 

we did not have a control group. However, we added language in the 

scope and methods section of the letter reemphasizing this point. 

We clarified, in our Scope and Methods discussion in appendix II, that 

our estimates of average annual beneficiaries’ earnings when leaving 

the rolls could be either an underestimate or an overestimate 

depending on the average annual earnings of those not included in the 

data (i.e., those beneficiaries who had earnings not covered by Social

Security). 

5. Regarding our numerical estimates of SGA, we agree that SGA is a 

monthly figure and that using annual earnings data is not ideal for 

assessing whether beneficiaries are “parking” on a monthly basis. 

However, SSA did not collect monthly earnings data on DI 

beneficiaries during the timeframe of our study. As a result, we limited 

our analysis to comparing annual earnings to an annualized SGA figure 

and included language regarding this limitation in both the letter and 

slides. Although our original language indicated that the finding was 

“not suggestive of parking,” to further ensure that our finding is not 

misunderstood, we adjusted the language in the report to indicate that

we found no evidence of parking. We also added language to the 

limitations section in appendix II. 

In a 2002 report, where we examined the effect of SGA on earnings for 

DI beneficiaries, we recommended, and SSA agreed, that it needed to

improve its earnings data collection methods.1

 According to SSA 

officials, since the timeframe of our study, SSA has begun collecting 

earnings information for DI beneficiaries through EWORK. To the 

extent that the data in this system are reliable, they may, in the future, 

provide an opportunity for a more precise analysis of “parking.” 

 1

 GAO, SSA Disability: SGA Levels Appear to Affect the Work Behavior of Relatively Few

Beneficiaries, but More Data Needed, GAO-02-224 (Washington, D.C.: January 2002).

Page 62 GAO-07-332 Vocational Rehabilitation
Appendix IV: Comments from the Social 

Security Administration 

SSA noted that because we used annual earnings data we could have 

captured low annual earnings in the year after VR for beneficiaries 

who may have completed VR mid-year, worked for the next several 

months, but then did not sustain their earnings. We agree that we were 

not able to capture earnings immediately after VR completion for 

beneficiaries who exited mid-year. However, Education already 

reports on employment and earnings 3 months after beneficiaries exit 

VR. The purpose of our study was to explore long-term outcomes. 

While we agree it would have been preferable to report earnings 

beginning with the month immediately upon exiting the VR program, 

we were unable to do so because SSA did not collect monthly earnings 

data for DI beneficiaries during the time period of our study. 

6. We agree with SSA’s point that other factors besides work-related 

earnings (e.g., changes in unearned income and assets) may cause SSI 

benefits to increase or decrease, and that it is possible that concurrent 

beneficiaries may experience an SSI benefit reduction and a DI benefit 

increase due to the same increase in earnings. We initially limited our 

analysis to SSI and concurrent beneficiaries with earnings gains to 

better ensure that SSI benefit reductions were related, in part, to those 

earnings gains. However, we were still not able to determine what 

portion of remaining SSI benefit reductions were due to increased 

beneficiary earnings. Therefore, we have removed this estimate from 

our final report. 

We disagree with SSA that, for our study, SSI earnings could have been 

more accurately tracked and calculated using the monthly earnings in 

the Supplemental Security Record (SSR) rather than the annual 

earnings in the Master Earnings File (MEF). While the SSR provides 

earnings on a monthly basis, it relies on self-reported data that then 

must be verified; and the TRF subfile that SSA provided for our 

analysis may not have included the most recent version of the SSR 

data. The MEF contains annual earnings based on Internal Revenue 

Service W-2 tax filings. When we compared SSI earnings between the 

SSR and MEF data that we had for our study population, we found that 

the values differed between the two data sets; therefore, we used the 

MEF as we believed it to be more reliable. 

7. We disagree that the report does not adequately discuss Ticket to 

Work because our study objectives did not include measuring the 

effects of the Ticket to Work program. Therefore, we did not include 

the additional language suggested by SSA, as it might detract from the 

report’s focus. However, we corrected the language in the letter to 

Page 63 GAO-07-332 Vocational Rehabilitation
Appendix IV: Comments from the Social 

Security Administration 

indicate that the Ticket to Work program was phased in gradually 

starting in 2002. 

8. We agree that our analysis of whether beneficiaries were employed 

was based on posted earnings in SSA’s Master Earnings File (MEF). 

Because SSA’s data does not allow us to distinguish earnings due to 

current employment from other earnings (such as commissions from 

previous employment or vacation pay), we replaced references to 

employment with earnings throughout the report. 

SSA also had concerns about the use of “sustained work” because it is 

suggestive of working month after month for several years. While we 

had defined our usage of the term, we changed it to “earnings in 

consecutive years” to avoid misinterpretation. 

9. We agree with most of SSA’s comments regarding our description of 

SSI benefits and DI work incentives and have made the suggested 

changes. 

10. We disagree that a fuller discussion of extended Medicaid and 

Medicare benefits is needed for this report. However, we added 

language to the letter indicating that it is unclear the extent to which 

loss of health care coverage remains a disincentive for SSA 

beneficiaries returning to work. 

11. Regarding the clarity of the term “left the rolls” and how return to the 

rolls was measured, we added language to our report clarifying that 

leaving the rolls is defined as cessation of disability cash benefits and 

that beneficiaries who left the rolls were counted as returning if they 

returned for 1 month or more. 

Page 64 GAO-07-332 Vocational Rehabilitation
A

A

ppendix V: GAO Contacts and Staff 

cknowledgments 

Page 65 GAO-07-332

Appendix V: GAO Contacts and Staff 

Acknowledgments 

Denise M. Fantone, Acting Director, (202) 512-7215, fantoned@gao.gov

In addition to the contact named above Robert Robertson, Director; 

Michele Grgich, Assistant Director; Amy Anderson; Melinda Cordero; Erin 

M. Godtland; Robert Marek; and Nisha Unadkat made significant 

contributions to all phases of this report. In addition, Robert J. Aiken, 

Susan Bernstein, Anna Maria Ortiz, Daniel A. Schwimer, Doug Sloane, and 

Susan B. Wallace provided technical assistance. 

Vocational Rehabilitation

GAO Contact 

Acknowledgments 

(130629) 
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