Ticket to Work and Work Incentives Advisory Panel 

Building on the Ticket: A New Paradigm for 

Investing in Economic Self-Sufficiency for 

People with Significant Disabilities 

Final Report to the President and Congress 

Year Eight of the Panel

December 2007 
 

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

Rosa-Aponte 

Back row, from the left: Loretta Goff, Russell Doumas, Torrey Westrom, Frances Gracechild, Andrew 

Imparato, David Miller, Thomas Golden, Dorothy Watson 
 

TABLE OF CONTENTS 

MESSAGE FROM THE CHAIR

EXECUTIVE SUMMARY..................................................................................................................1

Elevate and Incorporate the Beneficiary Voice ........................................................................................................ 2

Optimize Current Work Incentives through Short-Term and Incremental Policy Improvements ................. 3

Increase Economic Self-Sufficiency through Investment in Disability Program Modernization .................... 7

INTRODUCTION.............................................................................................................................13

HISTORY OF THE PANEL ...........................................................................................................17

FINDINGS: HISTORY AND TRENDS .....................................................................................21

PANEL RECOMMENDATIONS..................................................................................................49

Elevate and Incorporate the Beneficiary Voice ......................................................................................................50

Optimize Current Work Incentives through Short-Term and Incremental Policy Improvements ...............58

Increase Economic Self-Sufficiency through Investment in Disability Program Modernization ..................74

CALL TO ACTION ...........................................................................................................................99

APPENDIX A─Summary of the Ticket to Work and Work Incentives Improvement 

Act of 1999 .............................................................................................................................. 101

APPENDIX B─The Panel ............................................................................................................. 103

APPENDIX C─Panel Recommendations December 1999 - December 2007 ..................... 111

APPENDIX D─Panel Outreach 2001 - 2007............................................................................. 145

APPENDIX E─Panel Correspondence 2007............................................................................. 149

GLOSSARY....................................................................................................................................... 161

END NOTES ................................................................................................................................... 165
 
A Message from the Chair 

On behalf of the Ticket to Work and Work Incentives Advisory Panel (the Panel), I am 

privileged to issue this Final Report to the President, Congress, and the Commissioner of 

the Social Security Administration (SSA). The passage of the Ticket to Work and Work 

Incentives Improvement Act (the Act) eight years ago represented the culmination of 

efforts by diverse stakeholders who recognized the importance of removing barriers to 

employment and labor market activity for individuals with disabilities. Their 

contributions, in an inclusive workforce, benefit not only the individuals themselves, but 

also employers, communities, and our nation. In passing the Act, Congress recognized 

that the contributions of individuals with disabilities cannot be fully realized without 

choice and access to needed services, workplace supports and health care. 

The charge to the Panel was to provide advice on the Act’s implementation and make 

recommendations that would result in increased employment and greater economic selfsufficiency for individuals with disabilities. Through literature review, dialogue and 

discussion at quarterly meetings, open forums, and field visits across the country, the 

Panel has obtained substantial public input. The voices of beneficiaries and other 

stakeholders have played a critical role in shaping the Panel’s final recommendations. 

These recommendations build on findings from the Panel’s Adequacy of Incentives 

Report, the $1 for $2 Benefit Offset Report, the Employment Network Summit Report, 

the Beneficiary Summit Report, the Work Incentive Utilization Report, as well as the 

Panel’s seven Interim Annual Reports. 

Across federal agencies, efforts to coordinate and integrate services and supports at a 

community level must improve and be united by a consistent policy goal of work as a 

preferred option to promote independence and enhanced community participation. No 

single set of policy and practice actions can address all of the challenges identified by 

beneficiaries and confirmed by other diverse stakeholders in the public and private 

sectors. However, a key recommendation articulated at the beneficiary summit and 

recommended by the Panel is the creation of a National Disability Beneficiary Work 

Advocate’s Office and a Beneficiary Work Council within SSA. The purpose of these 

offices is to elevate and incorporate the beneficiary voice on a permanent basis to impact 

future policy development and procedures related to the disability programs. 
Final Report to the President and Congress ii 

ii 

I appreciate the dedication and commitment of Panel members and staff to advance a 

comprehensive vision of employment and economic self-sufficiency for current and 

future generations of youth and adults with disabilities who receive disability benefits. 

This final report shares what the Panel has learned, documents the diverse experiences of 

beneficiaries, recommends short-term, incremental improvements to current programs, 

and identifies critical investments that must continue to be made on a national basis to 

advance and modernize the current disability programs. 

Following the Panel’s sunset, I encourage Congress and relevant federal agencies to 

maintain their focus on employment for people with disabilities. Congress should 

conduct hearings annually on the progress of the Ticket to Work program, design and 

execution of demonstrations, and Medicaid Buy-In implementation. These hearings 

should solicit recommendations from beneficiaries and other stakeholders, and should 

highlight adequacy of incentives issues, including addressing the needs of people 

receiving sub-minimum wages, those with high-cost accommodations and individuals 

with a need for ongoing support and services. 

Respectfully Submitted, 

Berthy De La Rosa-Aponte, Chair 

Ticket to Work and Work Incentives Advisory Panel 
Executive Summary 

The Ticket to Work and Work Incentives Improvement Act (the Act) was signed into 

law on December 17, 1999. The overwhelming bipartisan support of the legislation 

demonstrated the evolution of thinking and attitudes about the interest in and capacity of 

people with disabilities to work, contribute to our nation’s economy, and reduce their 

reliance on public benefits. Congress made clear its intent “to redesign government 

programs to help individuals with disabilities return to work,” which “may result in 

significant savings and extend the life of the Social Security Trust Fund.”1

 Congress 

calculated that if only an additional one-half of one percent of the current Social Security 

Disability Insurance (SSDI) and Supplemental Security Income (SSI) beneficiaries were 

to cease receiving benefits as a result of employment, the savings to the Social Security 

Trust Fund and the U.S. Treasury would exceed 3.5 billon dollars over the work life of 

such individuals.2

 These savings would far exceed the cost of providing incentives and 

services needed to assist the beneficiaries in entering work and achieving financial 

independence to the best of their abilities.3

 To achieve these savings, Congress 

authorized the Ticket to Work and Self-Sufficiency Program (the Ticket to Work 

program) to allow individuals with disabilities greater choices to seek the services 

necessary to obtain and retain employment and reduce their dependency on cash benefit 

programs. To respond to the documented fear of losing health care and related services, 

Congress authorized new options to encourage states to adopt Medicaid Buy-In 

programs to allow individuals with disabilities to purchase Medicaid coverage after 

becoming employed. Congress also extended Medicare coverage to SSDI beneficiaries 

who are working up to 8 1⁄2 years. Further, section 121 of the Act authorized investment 

in a national infrastructure for work incentives outreach to ensure that beneficiaries have 

access to information and protection and advocacy services as they navigate the returnto-work progress.4

Section 101(f) of the Act established the Ticket to Work and Work Incentives Advisory 

Panel (the Panel) within the Social Security Administration (SSA). Panel duties include 

advising the President, Congress and the Commissioner of SSA on issues related to work 

incentive programs, planning and assistance for individuals with disabilities, and the 

Ticket to Work program. This final report presents the findings and conclusions of the 

Panel, together with its recommendations for legislative and administrative actions. The 

Panel’s recommendations take into account the complexity and interrelationships of the 

multiple support programs and entitlements serving people with disabilities. 
Final Report to the President and Congress 2 

2 

The final Panel recommendations are organized into three major groups5: 

1. Elevate and incorporate the beneficiary voice in all aspects of program and 

policy development, evaluation and improvement; 

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

policy improvements; and 

3. Increase economic self-sufficiency through investment in disability 

program modernization. 

These recommendations not only focus on policy changes, but also recognize the need 

for a more effective infrastructure to reach beneficiaries and to respond and adapt to 

their evolving individual needs. In order to achieve more dramatic reductions in barriers 

to work, the Panel’s final set of recommendations call for a continued national dialogue 

and investment in fundamental changes needed in disability policy and systems through 

which services are delivered. 

Elevate and Incorporate the Beneficiary Voice 

Since its inception, the Panel has contributed to the national dialogue about employment 

for people with disabilities. While the Panel listened to and learned from many 

stakeholder groups, they gained a valuable and as yet underutilized perspective from 

program beneficiaries about the need for changes in policy and program implementation. 

At the beneficiary summit conducted by the Panel in February 2007, several 

recommendations were identified as key to individuals participating in all aspects of 

American life. 

In the Advice Report to the Commissioner of Social Security issued by the Panel in 2002 

pertaining to the design of the Adequacy of Incentives Study, the Panel recognized the 

value and importance of the beneficiary voice, recommending that SSA develop a policy 

and practice for incorporating the input and experiences of consumers, their families, 

and/or their representatives as SSA develops new research designs, including the 

Adequacy of Incentives Study. 

Beneficiary summit delegates further reinforced this early Panel recommendation by 

clearly stating the importance of establishing a permanent way for SSA and Congress to 

hear beneficiary voices to help drive future policy and program design. 

Recommendation 1: Create through legislative authority within the Social Security 

Administration, an Office of the National Disability Beneficiary Work Council 

(Council) and a National Disability Beneficiary Work Advocate (Advocate). 
Final Report to the President and Congress 3 

3 

Modeled after the Internal Revenue Service (IRS) National Taxpayer Advocate (NTA) 

and Taxpayer Advocacy Panel, the Council and the Advocate would: 

1. Identify difficulties that SSDI and SSI disability program beneficiaries’ 

experience when trying to work that could be addressed via more effective 

SSA customer service. 

2. Propose changes in the administrative practices of SSA to mitigate those 

customer service issues, to the extent possible. 

3. Identify potential legislative changes to improve SSA’s service to disability 

beneficiaries who want to work. 

Optimize Current Work Incentives through Short-Term and 

Incremental Policy Improvements 

Ticket to Work Program Improvements

No subject has dominated the attention of the Panel more than the challenges of 

implementing the Ticket to Work program. During every public meeting over the past 

seven years, the Panel has included presentations by SSA on the status of 

implementation, strategies to increase the level of participation by beneficiaries, and the 

expansion of the number of ENs to serve them. Each quarterly meeting has also 

included diverse stakeholders offering testimony on experiences with the program and 

suggestions on how to improve it. The Panel has heard examples of successful 

participation which offer hope about the possibilities for the future and have led to 

suggested amendments to the reimbursement system to attract more entities to become 

ENs and recommendations to place more attention on marketing and outreach to attract 

beneficiary interest. The Panel has submitted multiple recommendations based on 

stakeholder input urging SSA to move forward with a sense of urgency to enable 

beneficiaries to realize the promise and full potential of the Act. Appendix C includes 

tables of Panel legislative and regulatory recommendations made to-date, separated into 

Panel recommendations for which Congress or SSA has not taken final action and 

recommendations for which Congress or SSA has taken action. 

Improving the employment outlook and labor market activity of beneficiaries with 

disabilities requires continuous improvement in our nation’s largest disability programs. 

This requires not only continued national dialogue regarding modernization of these 

programs but also continued removal of disincentives inherent in the current programs 

and immediate improvements to current work incentives to promote greater utilization. 

For this reason, the Panel recommends the following short-term improvements, outreach 

and ongoing oversight to build on current Ticket to Work program outcomes and 

improve the lives of more beneficiaries: 
Final Report to the President and Congress 4 

4 

Recommendation 2: Congress should appropriate the funds necessary for the 

Social Security Administration to support effective service delivery, particularly related to 

the Ticket to Work program and return-to-work such as work report processing and 

overpayments. 

Recommendation 3: The Social Security Administration should publish revised 

final regulations pertaining to the Ticket to Work program (September 2005 Notice of 

Proposed Rule Making) no later than April 1, 2008. 

Recommendation 4: The Social Security Administration should plan for and, 

upon promulgation of the revised final regulations pertaining to the Ticket to Work 

program (September 2005 Notice of Proposed Rule Making), immediately implement a 

marketing plan for beneficiaries and Employment Networks that is informed by 

evidence-based best practices, the results of the Ticket to Work program evaluation, as 

well as previously reported Panel recommendations. 

 

Recommendation 5: Congress should extend the Medicaid Infrastructure Grant 

and Demonstration to Maintain Independence and Employment program authority 

through 2014 to stimulate innovation by states seeking to refine comprehensive systems 

of employment supports for people with disabilities. 

Recommendation 6: Congress should renew, with greater Congressional oversight, 

the Social Security Administration’s demonstration authority to design and evaluate 

additional strategies that overcome multiple barriers to employment and support economic 

self-sufficiency for individuals with significant disabilities and place urgency on getting the 

demonstrations done. 

Recommendation 7: Provide states flexibility in devising Medicaid programs to 

reduce the marriage penalty for persons with disabilities. 

Recommendation 8: The Social Security Administration should identify business 

models for investing in independent living centers as Employment Networks. 

Work Incentive Improvements 

The Panel finalized a set of recommendations in its report entitled “UPDATE, 

SIMPLIFY, AND EDUCATE: A National Call to Optimize Incentives to Work”6

 to 

encourage Congress and federal agencies to make incremental changes to current 

disability programs fostering a greater investment in the work efforts of all beneficiaries. 

The recommended actions were divided into three primary categories: Update, Simplify, 

and Educate. 
Final Report to the President and Congress 5 

5 

Update Existing Work Incentives. Update existing work incentives to make them 

more applicable to the realities and employment support needs of beneficiaries in 2007 

and beyond. 

Recommendation 9: The Social Security Administration should change the order 

in which impairment -related work expenses are deducted when calculating the 

Supplemental Security Income cash payment to allow for up to a 100 percent cost 

recovery. 

Recommendation 10: The Social Security Administration should allow health 

insurance premiums to be used as impairment-related work expenses, when the 

beneficiary can document that the coverage is disability-related and supports work. 

Recommendation 11: The Social Security Administration should eliminate the 

condition that family members must suffer financial loss for their compensation by the 

beneficiary to count as impairment-related work expenses if they provide attendant care 

and/or transportation to/from work to a person with a disability. 

 

Recommendation 12: Congress should increase and index the key income 

exclusion amounts and the resource limits under the Supplemental Security Income 

program. 

Recommendation 13: The Social Security Administration should approve 

proposed rule changes to the Ticket to Work program to enable Employment Networks 

to receive ticket outcome-only payments while a beneficiary is receiving a Supplemental 

Security Income cash payment resulting from an active Plan for Achieving Self-Support. 

Recommendation 14: The Social Security Administration should allow state 

vocational rehabilitation agencies to receive traditional cost reimbursement if and when 

an individual is receiving a Supplemental Security Income cash payment resulting from 

an active Plan for Achieving Self-Support or claim of Blind Work Expenses. 

Simplify Work Incentives Programs. Simplify the maze of work incentives programs 

that exist not only within SSA but also in other federal benefit programs so that those 

programs mutually support a common work agenda and make work pay, while at the 

same time reduce the risk of overpayments for beneficiaries and other unintended 

adverse program interactions. 

Recommendation 15: The Social Security Administration should reduce the 

complexity and improve the consistency of work incentives across the Supplemental 

Security Income and Social Security Disability Insurance programs and other federal 

entitlements so that they universally support work. 
Final Report to the President and Congress 6 

6 

Recommendation 16: The Social Security Administration should establish 

mechanisms to monitor post-entitlement workloads, develop performance standards 

(similar to those established for initial claims in terms of processing time and decisional 

accuracy), and allocate sufficient resources to address post-entitlement workloads. 

Recommendation 17: The Social Security Administration should establish a 

cross-component internal Social Security Administration Task Force on post-entitlement 

workload issues to identify resources needed to perform critical program integrity activities 

that address post-entitlement workloads such as processing work reports and preventing 

and detecting overpayments. Publish these findings annually. 

Recommendation 18: The Social Security Administration should continue to 

expand systems for reporting wages electronically, ensuring that concurrent beneficiaries 

have a single point of earnings reporting and that timely receipts are sent to all 

beneficiaries. 

Educate Stakeholders. Educate and equip the array of stakeholders supporting the 

return to work process, to ensure that beneficiaries interested in going to work have 

access to customized, responsive, timely, relevant and accurate information and services, 

including accessible technology, to support their efforts. 

Recommendation 19: The Social Security Administration and Congress should 

strengthen both the Work Incentives Planning and Assistance and Protection and 

Advocacy for Beneficiaries of Social Security networks by establishing performance 

standards, adjusting funding levels and resources to levels necessary to achieve the desired 

results, and investing in ongoing training and technical assistance that improves the 

accuracy of information and quality of services provided with particular attention to 

underserved populations and valued employment outcomes. 

Recommendation 20: The Social Security Administration should identify clear, 

objective performance standards and indicators to evaluate the activities and impact of 

Area Work Incentives Coordinators and Work Incentive Liaisons, and collect, analyze, 

document, and publish evidence annually (by Social Security region and system-wide) of 

customer satisfaction, improved employment outcomes, and advanced self-sufficiency. 

Recommendation 21: The Social Security Administration should collect workload 

information on the number of Plan for Achieving Self-Support applications submitted 

and approved, including the processing (wait) time by state, and publish this information 

annually in the Social Security Administration’s SSI Disabled Recipients Who Work 

report. The Social Security Administration should provide high quality training and 

support, and fiscal resources for the effective administration and outreach of the Plan for 
Final Report to the President and Congress 7 

7 

Achieving Self-Support program. The Social Security Administration should recruit, 

develop, and support Plan for Achieving Self-Support specialists (travel, technology, et 

al). 

Recommendation 22: The Social Security Administration should improve 

reporting of data and analysis pertaining to Social Security Disability Insurance 

(including Disabled Adult Children and concurrent Social Security 

Disability/Supplemental Security Income beneficiaries) and issue an annual report 

comparable to the Social Security Administration’s SSI Disabled Recipients Who 

Work report. 

Recommendation 23: The Social Security Administration should establish a 

performance management and return to work tracking system, providing benchmarks for 

each state, and track utilization over time as part of a continuous quality improvement 

plan. 

Recommendation 24: The Social Security Administration should increase 

beneficiary awareness of earnings reporting requirements including the waiver process for 

overpayments, and promote greater self-efficacy. 

Increase Economic Self-Sufficiency through Investment in 

Disability Program Modernization

Enactment and implementation of the Act has not produced the results that Congress 

envisioned upon its passage.7 SSA has mailed more than 12 million tickets to individual 

beneficiaries in the last seven years. Less than 184,000 tickets have been assigned as of 

September 30, 2007; this amounts to an assignment rate of less than 1.5 percent. SSA 

reported that, during the week of June 18, 2007, it made its first 60th outcome payment 

to an EN for one of its beneficiaries with disabilities. This means that this beneficiary has 

been successfully employed at over the substantial gainful activity limit and off the 

beneficiary rolls for 60 months. This is the first such payment SSA has made since the 

program began.8

 This contrasts with the estimate made by the Congressional Budget 

Office (CBO) during the writing of the Act: 

“Specifically, CBO estimates that the number of net 

additional suspensions in DI--that is, suspensions that would 

not occur in the absence of the new program--would equal 

500 in 2003, 2,200 in 2004, and an average of 4,600 annually 

between 2005 and 2007...Over the 2003-2007 period, CBO 

estimates that there would be a total of 35,000 gross 

rehabilitations of ticket holders...”9
Final Report to the President and Congress 8 

8 

The Panel believes that incremental changes to the Ticket to Work program and Social 

Security work incentives, while vital in the short term, must be coupled with more 

sweeping policy changes and further national dialogue regarding modernization of 

disability programs. As long as eligibility for federal income support and health care 

programs is based on the inability to engage in substantial gainful activity that results 

from a medical impairment expected to last for at least one year, the clear message to 

people with disabilities will be that they are inherently unable to support themselves 

through work. This problem was also cited in the U.S. House of Representatives 

Committee on Commerce Report accompanying the Ticket to Work legislation.10 In 

short, our largest public programs consistently tell our working-age population with 

disabilities that we don’t expect them to work or participate fully in their communities. 

This message has not changed in any meaningful way since the eligibility criteria for 

SSDI were developed in 1956,11 and it is compounded by messages from family, friends, 

community, other government programs, and the media. Low expectations have 

combined with fundamental flaws in the largest public programs serving Americans with 

disabilities to relegate millions of Americans to the periphery of society. For many, our 

disability programs become a poverty trap that is almost impossible to escape. The 

statistics regarding people with significant disabilities and the programs that serve them 

reinforce the need for fundamental changes: 

• The employment rates of men and women with significant 

disabilities have not improved and may have declined between 1986 

and 2004.12 

• According to the Current Population Survey, the employment rate 

of working age people with a work limitation dropped from 24.5 

percent in 2000 to 19.3 percent in 2004.13 

• Partially as a result of changing demographics, including an aging 

population, disability income support programs are growing at rates 

that are outpacing the general population growth. Between 1989 

and 2005, the general U.S. population grew from 246.8 million to 

296.5 million. During that same period, the number of 

SSDI beneficiaries increased from 4.1 million to 8.3 million, and the 

annual total expenditures rose from $23.8 billion to $88.0 billion. 

The number of individuals receiving SSI due to disability or 

blindness rose from 3.1 million to 5.9 million, and the annual 

Federal expenditures rose from $9.2 billion to $29.2 billion.14

• Between 1989 and 2005, the number of SSI recipients under age 

18 increased from 299,200 to 1.0 million, growing as a percentage 

of the total SSI beneficiary population from 7 percent to 15 
Final Report to the President and Congress 9 

9 

percent. On average, people who enter SSI prior to age 18 remain 

on the rolls for 27 years.15

This need to modernize disability programs has also been recognized by the bipartisan 

Social Security Advisory Board;16 by the National Council on Disability17 under 

Presidents Ronald Reagan, George H.W. Bush, William Jefferson Clinton, and George 

W. Bush; by the Comptroller General of the United States;18 and by disability advocacy 

groups like the American Association of People with Disabilities,19 the National Council 

on Independent Living and the World Institute on Disability.20 

People with disabilities are a diverse population with varying needs, access to intangible 

supports and work capacities. In addition, because there are variations in local labor 

markets, no single program or policy will be universally successful in promoting work 

and meeting the needs of all people with significant disabilities. Rather, mutually 

supportive and flexible programs and policies need to be designed and tested to 

determine how best to support people with significant disabilities at various stages of 

onset and disability management and levels of work capacity. These policies and 

programs should build on demonstrations and innovations that are producing results at 

the state and local levels, and should allow for modernization at all levels of government. 

The Panel proposes the following set of recommendations to promote ongoing national 

dialogue regarding modernization and supports long-term investment in an employment 

strategy for Americans with disabilities. Key elements to this employment strategy are: 

Raise Expectations 

Recommendation 25: The President should take the lead to establish and provide 

financial support for a comprehensive, cross agency, culturally competent social marketing 

campaign to raise expectations about the productive employment potential of people with 

disabilities. This campaign should target people with disabilities, their families, 

educators, employers, health care professionals and those that serve people with 

disabilities and the community. This marketing campaign should use the most accessible 

and effective media, including television, radio, the internet, and mainstream and 

specialty magazines and newspapers. 

Promote Workforce Connection and Retention 

Recommendation 26: Congress should create employer incentives to increase the 

availability of effective workforce retention policies and programs to keep working adults 

with newly-diagnosed or recently-exacerbated medical conditions connected to the 

workforce. 

Recommendation 27: The Social Security Administration should implement a 

demonstration that tests the costs and benefits of establishing a publicly supported short-
Final Report to the President and Congress 10 

10 

term disability insurance program at the state level modeled on the best programs that 

have been developed in the private sector and by state governments, which would be 

available to individuals with work histories who do not have private disability insurance. 

Enhance Job Opportunities 

Recommendation 28: The President should implement a job creation strategy that 

engages and incentivizes public and private sector employers in targeting people with 

significant disabilities for jobs that pay a living wage and have benefits that enable a 

beneficiary to move successfully from benefit receipt to employment, through a new level of 

collaboration among state and federal employment and economic development programs, 

the business community and disability organizations. 

 

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

Recommendation 29: Congress should work in a bipartisan fashion to build on 

the goals of the Medicaid Buy-In and the Medicaid Infrastructure Grant to ensure that 

people with significant disabilities have access to affordable coverage for health care and 

long-term services and supports that is comprehensive; portable; supported by beneficiary 

contributions, where appropriate; independent from qualifying for income support; and 

coordinated with employer-sponsored benefits. 

Create a Transition to Economic Self-Sufficiency Large-Scale 

Demonstration Program 

Recommendation 30: The Social Security Administration should design and 

implement a large-scale demonstration project that studies the feasibility, costeffectiveness, and any unintended consequences of a voluntary Transition to Economic 

Self-Sufficiency Program for young people who are between 14 and 30 years old and 

qualify for Supplemental Security Income and/or Social Security Disability Insurance. 

This demonstration project would build on the goals of the Ticket to Work program and 

evaluate the feasibility of a program that would transform Supplemental Security Income 

and Social Security Disability Insurance by establishing unified rules that: provide a 

graduated cash payment to address the effects of disability-related barriers on income; 

build on the Ticket to Work program to increase the availability of and consumer 

control over employment-related services; promote optimal educational outcomes; and 

enable program participants to maximize income and assets without fear of losing 

critical supports. 

Modernize the Social Security Definition of Disability 

Recommendation 31: Congress and the Administration should take action to 

evaluate the impact of modernizing the Social Security definition of disability by defining 
Final Report to the President and Congress 11 

11 

disability in a manner that acknowledges the interaction between the person’s 

impairment and the environment and does not require the individual to prove their 

inability to engage in substantial gainful activity. 

Coordinate Disability Programs at the Federal Level 

Recommendation 32: The Domestic Policy Council should ensure ongoing 

communication and collaboration among federal programs that provide employment 

services and supports. 

 

A Call to Action

Eight years ago, the President, Congress, and SSA agreed to invest in human potential 

and to reduce or eliminate remaining barriers to employment and economic participation 

for people with disabilities. Today, costs and frustration increase with the slow pace of 

progress. To an individual with significant disabilities, a timely intervention means the 

difference between an independent life and one of poverty and dependence. 

The Panel urges Congress and SSA to take action on its recommendations, 

acknowledging that people with significant disabilities must play a central role in 

designing and implementing any new or modernized system. An investment focused on 

modernization rebalances risk and aligns public policy and systems in support of 

employment and self-sufficiency. 
Final Report to the President and Congress 12 

12 
Final Report to the President and Congress 13 

13 

 Introduction 

“What more do we need to tell people that the system is broken? It’s an 

antiquated system...for individuals who were believed never to work 

again. Persons with disabilities are missing out on one of life’s most 

valued gifts, the ability to work and feel productive by contributing to 

society. Our disabilities must not also sentence us to a life of poverty. 

We crave the equality and are willing and able to work.” 

Michelle Martini, Delegate from Wisconsin 

Beneficiary Summit 

Atlanta, Georgia 

February, 2007 

 

The Ticket to Work and Work Incentives Improvement Act of 1999 (the Act) is 

administered by the Social Security Administration (SSA) and the U.S. Department of 

Health and Human Services (HHS). It increases beneficiaries’ choices for rehabilitation, 

vocational services and other employment supports, reduces barriers associated with 

choosing between health care coverage and work, creates safety nets and protections that 

support work, and provides a vehicle to ensure that more Americans with disabilities are 

employed and reduce their dependence on public benefits. Appendix A provides a 

summary of the provisions of the Act. 

The overwhelming bipartisan support for the legislation represented a continuing 

evolution in thinking and attitudes about the capacity of people with disabilities to work, 

contribute to our nation’s economy, and reduce their reliance on public benefits. Nine 

years after the passage of the Americans with Disabilities Act (ADA) of 1990, Congress 

recognized that multiple barriers still remained for the full participation of working-age 

adults with disabilities in the economic mainstream. Citing innovations in assistive 

technology, medical treatment and rehabilitation, as well as advances in public 

understanding of disability and the desire of many beneficiaries to work, the Act 

authorized a dynamic set of changes to policy and programs intended to reduce or 

eliminate several of the most significant barriers remaining to employment for 
Final Report to the President and Congress 14 

14 

beneficiaries of Supplemental Security Income (SSI) and Social Security Disability 

Insurance (SSDI). 

With passage of the Act, Congress made clear its intent “to redesign government 

programs to help individuals with disabilities return to work,” which “may result in 

significant savings and extend the life of the Social Security Trust Fund.”21 Congress 

calculated that if only an additional one-half of one percent of the current SSDI and SSI 

beneficiaries were to cease receiving benefits as a result of employment, the savings to 

the Social Security Trust Fund and to the U.S. Treasury would exceed $3.5 billon over 

the work life of such individuals. Such savings would far exceed the cost of providing 

incentives and services needed to assist beneficiaries in entering the workforce and 

achieving financial independence.22 

The SSA Strategic Plan for FY 2006-201123 states that the mission of the agency is “to 

advance the economic security of the Nation’s people through compassionate and 

vigilant leadership in shaping and managing America’s Social Security programs.” 

Millions of beneficiaries with disabilities expect services and supports that are responsive 

to a changing environment, including a choice to work with continued access to health 

care and other needed work supports. 

In its Strategic Plan, SSA identified as a major strategic objective to “increase 

employment for people with disabilities by expanding opportunities” with a long-term 

outcome “to achieve greater financial independence through employment.” SSA’s 

Comprehensive Work Opportunity Initiative (Figure 1 below) affirms that most 

individuals with disabilities face multiple barriers to employment and need solutions that 

are flexible and can be customized to individual circumstances. 

This final report shares what the Panel has learned during the past eight years and makes 

recommendations in three areas: 

1. Elevate and incorporate the beneficiary voice in all aspects of program and 

policy development, evaluation and improvement; 

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

policy improvements; and 

3. Increase economic self-sufficiency through investment in disability 

program modernization. 

This final report offers short- and long-term recommendations that are informed by the 

knowledge gained from the personal experiences and professional expertise of Panel 

members, research findings culled from data analysis and open forum discussions, and 

the syntheses of hundreds of suggestions that reflect the diversity of the target 

population. The final Panel recommendations not only focus on fundamental policy 

changes, but also recognize the need for continued infrastructure development to
Final Report to the President and Congress 15 

15 

support implementation. Another consideration reflected in the recommendations is a 

belief that an investment of resources is required to reach beneficiaries and to respond 

and adapt to their evolving individual needs. 

Figure 1. The Comprehensive Work Opportunity Initiative: 

Overcoming Barriers to Employment24

While the Panel feels strongly that implementation of its short-term recommendations 

will help reduce the multiple barriers to employment; equally as important is a national 

dialogue and subsequent investment in a modernized disability policy and service system. 

The modernized system must achieve more dramatic reductions in barriers to work and 

improved employment outcomes. 
Final Report to the President and Congress 16 

16 
Final Report to the President and Congress 17 

17 

History of the Panel 

The Panel was established under the Act in March 2000. Twelve individuals serve on the 

Panel at a time: four appointed by the President, four by the U.S. Senate, and four by the 

U.S. House of Representatives. The appointees represent a cross section of experience and 

expert knowledge as recipients, providers, employers and employees in the fields of 

employment services, vocational rehabilitation, veterans programs, and other disabilityrelated support services. Most Panel members are individuals with disabilities or their 

representatives, with several having had personal experience as beneficiaries of SSA disability 

programs. A list of current and former Panel members is provided in Appendix B.25

Duties of the Panel include advising the President, Congress, and the Commissioner of SSA 

on issues related to work incentive programs, planning and assistance for individuals with 

disabilities and the Ticket to Work program. The Panel scheduled public meetings at least 

quarterly, alternating locations between Washington, D.C. and, in its early years, the Ticket 

to Work program roll-out states, to hear regional testimony. The Panel submitted interim 

reports on the implementation of the Act to the President and Congress on an annual basis. 

Appendix C includes two tables of Panel legislative and regulatory recommendations made 

to-date, separated into Panel recommendations for which Congress or SSA has not taken 

final action and recommendations Congress or SSA have acted upon. This is the eighth and 

final report. The Panel’s legislated authority ends on January 17, 2008. 

Listening to and Responding to the Needs of Diverse Stakeholders

The challenge the Panel faces in crafting recommendations to the President and Congress 

was articulated clearly in the recent report of the Social Security Advisory Board (SSAB) 

entitled “A Disability System for the 21st Century.” 

“The challenge is how to implement a strategy that meets the 

aspirations of the ADA, fulfills the needs of persons with 

disabilities, maintains the protections provided by the Social 

Security disability programs, and is fiscally responsible and 

sustainable.” 26
Final Report to the President and Congress 18 

18 

To meet its responsibilities, the Panel has used multiple strategies to gather evidence and 

document results regarding the unmet needs, concerns, and challenges facing diverse 

stakeholders at a local, state, and national level. 

During the past eight years, the Panel and other organizations such as the U.S. Senate 

Committee on Finance, the U.S. House of Representatives Committee on Ways and Means 

Subcommittee on Social Security, the SSAB, the Government Accountability Office (GAO), 

the National Council on Disability (NCD), and the National Academy for Social Insurance 

(NASI) have engaged policy experts, federal officials, practitioners, and persons with 

disabilities in public hearings, small group think tanks, and qualitative and quantitative 

research studies to identify improvements and, if necessary, transformative approaches to 

promote employment and a better economic future for individuals with significant 

disabilities. In addition to maintaining open and regular communication with Congressional 

staff, federal agency officials, and national disability organizations, the Panel conducted 

literature reviews and engaged diverse stakeholders to share their findings and 

recommendations. The Panel questioned stakeholders on the status of implementation of 

the Act, with particular attention to the Ticket to Work program, adoption by states of 

Medicaid Buy-In programs, and strategies to improve coordination of work-related supports 

among multiple federal agencies. The Panel sponsored targeted summits with employment 

service providers and beneficiaries to explore issues of critical importance to each group. 

Throughout all of these activities, the Panel conducted ongoing analysis of data and 

information received. 

Through letters detailing recommendations and informal discussions with SSA and other 

federal agencies, the Panel has impacted program design, communications, and resource 

allocation. With public comment opportunities at each quarterly meeting and participation in 

a wide range of relevant regional and national conferences, Panel members have listened to 

and been part of discussions that helped inform future decision-making. 

Panel members have met regularly with lead staff at SSA and relevant Congressional 

committees to advise them on ways to strengthen the Ticket to Work and related work 

incentive programs. Panel members have also participated extensively in a concerted effort 

to increase communication with and outreach to the disability community. In Washington 

D.C. and across the country, Panel members have engaged national organizations 

representing employment networks (ENs) and persons with disabilities, including multiple 

task forces of the Consortium for Citizens with Disabilities, in discussions promoting work 

for beneficiaries. Panel members have visited Social Security field offices, One-Stop Career 

Centers that are part of the federally funded workforce investment system, and workplaces 

where small business and large employers are benefiting from the productivity and 

contributions of workers with disabilities. Appendix D lists a sampling of the Panel’s 

outreach efforts since 2001. 

In various venues nationwide, policymakers, practitioners, and persons with disabilities have 

helped Panel members improve their understanding of the diversity of beneficiaries as 
Final Report to the President and Congress 19 

19 

defined by age, level of disability, gender, race, culture, and economic status. At quarterly 

meetings, Panel members heard stakeholders from the public and private sectors share 

important recommendations to promote policy and program implementation improvements 

within SSA and other relevant federal agencies. The Panel has listened to different voices--

all sharing the common message that legislation must: a) ease the transition from SSA 

disability programs to work; b) ensure access to medical benefits, when needed; and c) 

encourage the advancement of financial/economic self-sufficiency. Across federal agencies, 

service and support coordination and integration at a community level must improve. In 

addition, there must be a government-wide acceptance of work as a preferred option to 

promote independence and enhanced community participation for individuals with 

disabilities. 

Panel Strategic Plan for 2006-2007

In 2005, the Panel undertook a formal strategic planning process to guide final Panel action 

and decision-making. As a result, the Panel again affirmed and elevated principles that have 

guided it since its inception. First, all people should be afforded a meaningful opportunity to 

participate in the economic mainstream with or without ongoing supports and services. 

Second, the perspectives of beneficiaries must be heard, communicated and integrated into 

the recommendations of the Panel. The diversity of beneficiaries must be recognized to 

include people from various age groups, with different impairments, levels of education, 

work experience, capacities for working, culture, ethnicity, and socioeconomic status. Third, 

programs should not harm those they are designed to help. 

The Panel recognized its important role promoting change specific to available work 

incentive options and to the Ticket to Work program. It also examined the larger context of 

programs and polices essential to increased employment and economic self-sufficiency for 

people with disabilities. The Panel identified three goals to frame final recommendations: 

1. Elevate and incorporate the beneficiary perspective. 

2. Improve implementation and marketing of the Ticket to Work program and 

other work incentives. 

3. Develop a national employment investment strategy to transform approaches 

to assets, income, health care and supports for people with disabilities that is 

person-centered, culturally competent, and respective of each person’s values 

and experience. 
Final Report to the President and Congress 20 

20 
Final Report to the President and Congress 21 

21 

Findings: History and Trends 

To understand the Panel’s recommendations, which highlight the value of work and examine 

the economic consequences of failing to improve and modernize current policies and 

program implementation, it is important to understand the historical context of the existing 

Social Security disability programs, work incentive options, and various national trends. 

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

SSI and SSDI 

SSA manages the nation’s two largest federal disability programs: SSDI and SSI. The two 

programs provide safety-net supports of income and health care for millions of individuals 

nationwide. Since 1985, the number of individuals receiving disability benefits through the 

two programs has grown significantly. 

In the past 15 years, according to findings of the SSAB, the working age population of the 

U.S. has grown by 18 percent. During that same period, the number of persons receiving 

SSDI benefits has grown by 117 percent and the number of working age SSI recipients has 

grown by 66 percent. The number of disabled workers on SSDI has more than doubled 

since 1990 from 3.0 million to 6.8 million in 2006 (Figure 2). The 2006 report of the SSAB 

indicated that 5.2 million individuals under age 65 receive SSI based on disability.27

According to SSA statistics, 28 percent of SSDI beneficiaries depend on these benefits for 

100 percent of their income and 47 percent of working age SSI recipients depend solely on 

their income from SSI. In both programs, the income payments represent more than 75 

percent of the total income for a majority of such beneficiaries. On an annual basis, federal 

benefits paid to eligible individuals exceed $125 billion. 
Final Report to the President and Congress 22 

22 

Figure 2, Social Security Disability Insurance, 

Disabled Worker Beneficiaries, 1990 - 2006 

0

1

2

3

4

5

6

7

8

1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006

Years

In Millions

Source: SSA's Performance and Accountability Report FY 2005 

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

February 15, 2007. 

After going through a long process to receive disability benefits, few people currently risk 

losing them by returning to work. According to the Office of Management and Budget’s 

(OMB’s) Program Assessment and Rating Tool, in 2006, the average processing time for 

initial disability claims was 88 days and the wait time for a hearing averaged 483 days.28 After 

applying and finally being approved to receive benefits, only a small percentage of 

beneficiaries with disabilities work and earn enough to leave the disability rolls on a 

temporary or permanent basis. Policymakers struggle to reconcile a program for which 

eligibility requires individuals to prove a permanent inability to work with the needs of 

individuals who want to return to work, but require a flexible system that can provide 

supports that make work possible. 

In 1956, Congress expanded the Social Security program to help people who were over age 

50 who were unable to engage in any substantial gainful activity (SGA) by reason of a 

medically determinable physical or mental impairment that could be expected to result in 

death, or to be of a long continued and indefinite duration. The legislation combined cash 

benefits with referral to state vocational rehabilitation (VR) agencies to assist with services 

that might result in a return to work. 

By June 1958, more than 800,000 individuals had been referred to VR agencies, but only 

about 550 beneficiaries (0.02 percent of the beneficiary population) had been successfully 
Final Report to the President and Congress 23 

23 

rehabilitated. Subsequent amendments added benefits for younger workers, disabled 

widows, individuals who became disabled prior to age 22, and those whose working parent 

died or became eligible for Social Security retirement benefits. The original requirement of a 

disability of indefinite duration was reduced to include disabilities lasting as little as a year, 

and health insurance under Medicare was added for beneficiaries who complete a 24-month 

waiting period. 

As the program evolved to include younger workers and shorter periods of disability, work 

incentive provisions were added to facilitate beneficiaries’ return to work. In 1960, the first 

SSDI work incentive provision was enacted, which provided a nine-month Trial Work 

Period (TWP) during which a beneficiary could test his or her ability to work without 

suffering a loss of benefits. If the beneficiary continued to work above SGA following 

completion of the TWP, benefits would be terminated. Still, few SSDI beneficiaries 

returned to work. In 1967, 14,500 were rehabilitated, which was 1.2 percent of the 

beneficiary population.29

In 1972, Title XVI of the Social Security Act created the SSI needs-based program. The 

program is a federally-administered income assistance program restricted to qualified 

individuals who have countable resources not exceeding $2,000 for an individual and $3,000 

for married couples. The SSI program includes cash assistance for children and adults with 

disabilities. SSI recipients with earned and unearned income are allowed a $20 general 

income exclusion and a $65 earned income exclusion, as well as, a $1 benefit offset for every 

$2 earned. Additional income exclusions are also applied, recognizing the additional costs 

associated with employment and designed to ensure that a recipient will always have higher 

gross income from working than if they did not work. 

Since the beginning of the SSI program in 1974, Congress has authorized work incentive 

provisions to provide beneficiaries with support to move from benefit dependency to 

independence through work. During the 1970s, the number of disability beneficiaries 

doubled. Ongoing beneficiary payments increased by a factor of five.30 In response to rising 

disability rolls, Congress provided additional incentives to support work for SSI and SSDI 

disability beneficiaries through the 1980 amendments to the Social Security Act. These 

incentives included the ability to deduct Impairment-Related Work Expenses (IRWE) in 

determining whether earnings demonstrate SGA, an Extended Period of Eligibility (EPE) 

within which to test ability to work while retaining disability status after completion of the 

TWP, provisions for SSI recipients to continue to receive SSI payments beyond SGA under 

certain conditions, and extension of Medicare coverage for SSDI beneficiaries. The Section 

1619 SSI/Medicaid work incentives began in 1981 and were made permanent effective July 

1987. 

Even with these changes, few SSI or SSDI beneficiaries were leaving the rolls for work. 

Loss of health care and other supports needed for work were viewed as being the primary 

reason. A 1992 study found that about 10 percent of beneficiaries entitled in 1980-1981 

performed some work over a period of approximately 10 years, but only about 2 percent left 
Final Report to the President and Congress 24 

24 

the rolls.31 Additional research showed that over 80 percent of beneficiaries were unaware of 

the work incentives and few used them.32 VR “seemed to have a positive effect on work 

resumption,” but only about 2 percent of beneficiaries received VR services. Physical 

therapy, vocational training, general education, and job placement efforts increased the 

tendency to go back to work.33

Use of Work Incentives

The Panel has spent significant time learning about and listening to the perspectives of 

diverse stakeholders regarding SSI and SSDI eligibility requirements and the use of existing 

work incentives. For a more detailed overview and analysis of the SSI and SSDI programs 

and beneficiary use of work incentives, please see the Panel’s work incentive utilization 

report “UPDATE, SIMPLIFY, AND EDUCATE: A National Call to Optimize Incentives to 

Work.”34

The Panel was dismayed to learn that, despite all the policy improvements and work 

incentives outreach efforts since the inception of the Act, work incentive utilization has been 

on a steady decline. Data provided by SSA demonstrates that the number of workers using 

IRWEs and Blind Work Expenses (BWE) has declined to its lowest level since 1990 (just 1.6 

percent used IRWEs and 0.7 percent used BWEs). Plan for Achieving Self-Support (PASS) 

utilization also continued to drop through 2005 (1582 plans) and leveled off in 2006 (1583 

plans). In December 2006, 0.5 percent of SSI recipients had a PASS plan and only 409 

individuals nationwide had earnings. Little or no data is available on utilization of TWP, 

EPE, IRWEs or the provision of subsidies and special considerations for SSDI 

beneficiaries.35

The Integration of Work Incentives: Complexity of Rules 

“I’ve Googled, researched, read, and asked questions from the person who 

answers the phone at the help desk all the way up to the director of 

programs, agencies, and fellow researchers to gain a fuller understanding of 

the work incentives program. Yet, I am stopped dead in my tracks when it 

comes to knowing what to do and how to survive Social Security, access the 

Ticket program, and survive the mazes created from the bureaucratic layers 

that Andy and I must traverse for him to have a life like yours.” 

Donna Martinez 

Mother of Andy, Ticket holder 

Ticket to Work and Work Incentives 

Advisory Panel Quarterly Meeting 

Washington, DC 

August, 2006 
Final Report to the President and Congress 25 

25 

SSI and SSDI beneficiaries have to deal with the complexities of work incentives. It is not a 

matter of being informed about and using a single work incentive, but rather understanding 

all the work incentives applicable to a specific situation, how they interact, and managing and 

utilizing them to avoid pitfalls. 

For SSDI beneficiaries, the complexity includes: 

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

• A nine-month (not necessarily consecutive) TWP within a rolling 60 

month timeframe, which allows unlimited earnings but requires a 

"work" continuing disability review (CDR) (Note that rules governing 

whether or not a month of work counts as a TWP month include both 

hours worked and earnings thresholds unrelated to SGA.); 

• Restarting of benefits no later than the 37th month after the end of the 

9-month (not necessarily consecutive) TWP; 

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

• A 36-consecutive month EPE, during which earnings are limited to 

less than SGA, with no questions about why earnings dropped;

• A three-month grace period during the EPE before payments are 

stopped if the beneficiary has earned SGA; 

• A five-year period during which benefits can be reinstated if earnings 

are less than SGA, but unlike the EPE, it applies only if benefits ended 

because of work; and

• A maximum of 93 consecutive months of Medicare after cash benefits 

stop, starting with the last month of the 9 month (not necessarily 

consecutive) TWP. 

For SSI recipients, the complexities due to timing are not as great. The $1 for $2 reduction 

avoids the all-or-nothing situation tying cash benefits to health insurance, and the 1619 

provisions provide for a smoother transition. However, in the SSI program the complexity 

extends beyond an earnings test to include an extensive set of initial and continuing eligibility 

rules that govern not only all types of income but also resources, living arrangements, and 

documentation for any changes. 

The Panel has heard a great deal of testimony about the significant fear beneficiaries have of 

losing their benefits and their access to health care, as well as their reluctance to risk losing 

their benefits after undergoing a lengthy and rigorous eligibility process. Often, incentives do 
Final Report to the President and Congress 26 

26 

not go far enough to offset the impairment-related expenses or the other expenses 

associated with going to work. It may not be reasonable to expect beneficiaries to deal with 

confusing and seemingly arbitrary time frames and dollar amounts as they try to understand 

the impact of earnings on their benefits. 

Concurrent Beneficiary Efforts to Work and Use SSI and SSDI Work 

Incentives 

Work incentives and eligibility for both the SSI and the SSDI programs are complex. This 

complexity is compounded for concurrent beneficiaries (individuals receiving both SSI and 

SSDI benefits), who must navigate two sets of often-conflicting work incentives and 

eligibility provisions. 

According to a 2002 report by the GAO,36 concurrent beneficiaries account for about 14 

percent of SSA’s disability population, and about 11 percent of concurrent beneficiaries 

work, compared to 8 percent of SSI-only recipients. While a greater percentage of 

concurrent beneficiaries appear to be working, the average median monthly earnings of 

concurrent beneficiaries is less: $250 compared to $400 for SSI-only recipients. 

This GAO report explored the implications of uncoordinated program rules on SSA 

payment inaccuracies. The GAO found that information affecting benefits or eligibility is 

not reported timely and/or that information, once reported, is not processed timely. Field 

office employees generally specialize in only one of the programs, so the staff may not be 

fully aware of rules for both, making it difficult for them to offer sound guidance. Reliable 

public information materials clearly explaining the complex interaction of the two programs 

are not available, so it is difficult for beneficiaries to make informed decisions about 

working.37

SSA Workloads 

The primary focus of SSA workloads for FY 2006-2011 continues to be the disability 

program, which according to SSA’s Strategic Plan38 “is in need of the most improvement.” 

The most significant external factors affecting SSA’s ability to improve service to applicants 

with disabilities is the dramatic growth of workloads and the increasing complexity of those 

workloads. 

SSI redeterminations and CDRs represent two of SSA’s main efforts towards processing the 

information affecting benefits or eligibility in a timely manner and helping to prevent and 

detect improper payments. SSI redeterminations yield a savings of $7 for every $1 spent in 

administering them, and CDRs in the SSDI program save $10 in program benefits for every 

$1 spent.39 SSI redeterminations assess whether an SSI recipient continues to meet the 

financial eligibility requirements or has experienced a change of circumstances that would 

affect his or her monthly benefit amount. SSA is implementing policies to increase the 
Final Report to the President and Congress 27 

27 

number of SSI redeterminations processed and to improve the profiles that are used to select 

cases for review.40 In FY 2005, SSA completed 1,724,875 redeterminations; it is estimated 

that this effort produced $1.5 billion in overpayments.41 CDRs conducted in 2005 are 

estimated to yield more than $5 billion in program savings.42 SSI redeterminations and 

CDRs have been identified as cost effective efforts to detect and to reduce overpayments in 

the SSI and SSDI programs. However, former SSA Commissioner Barnhart43 determined 

that, due to budget cuts in FY 2006, workloads “such as processing retirement and disability 

claims have priority over other workloads, including...CDRs and SSI non-medical 

redeterminations.” According to testimony heard before the House Subcommittee on Social 

Security,44 the lack of resources to conduct CDRs and SSI redeterminations will adversely 

impact SSA’s ability to significantly reduce overpayments. 

More than 40 percent of SSA employees are expected to retire by 2014, while SSA’s 

workloads are expected to grow dramatically as the baby boom generation approaches their 

peak disability and retirement years. Consequently, the greatest human capital challenge 

facing SSA is to maintain a high performing, smaller workforce that is prepared to deliver 

quality service. 

Future Financing Challenges

In a 2003 report, GAO45 designated the federal disability programs as a high-risk area—one 

that requires urgent attention and organizational transformation to ensure that programs 

function in the most economical, efficient, and effective manner possible. This designation 

was based on more than a decade of research focusing primarily on the nation’s largest 

disability programs, which includes the SSA disability programs. 

In several reports, GAO has identified the challenges of future financing of SSA programs. 

In a May 2005 report, GAO stated that SSA “faces a long-term actuarial deficit and that 

benefit reductions and/or revenue increases will be necessary to restore solvency.”46 

Further, GAO reported that while the program does not face an immediate crisis, it does 

have a $4 trillion gap between promised and funded benefits in current dollar terms over the 

next 75 years. Social Security’s finances have important implications for the overall federal 

budget. The current Social Security surpluses will begin to decline in 2009, thereby putting 

additional pressure on the balance of the federal budget. In addition, in the near future, 

Social Security’s benefit costs will start to grow rapidly. 

As a result of the aging population and slower labor force growth, fewer workers will be 

contributing to Social Security. According to another 2005 GAO report on Social Security 

reform,47 while currently 3.3 workers support each Social Security beneficiary, only 2 workers 

are expected to be supporting each beneficiary by 2040. In 2017, Social Security is projected 

to pay out more in benefits than it receives in revenues. After 2017, the gap between costs 

and income is expected to grow continuously, and, unless action is taken to close this gap, 

the trust funds are projected to be depleted in 2041. At that time, annual income will only be 
Final Report to the President and Congress 28 

28 

sufficient to pay about 74 percent of benefits and by 2079, income will only be sufficient to 

pay about 68 percent of benefits. 

Implementation of the Ticket to Work and Work Incentives 

Improvement Act

To further encourage beneficiaries to work, Congress enacted the Act, which addressed the 

threat of losing health benefits by extending Medicare coverage for working beneficiaries to 

102 months from 36 months, and established a state option to offer a Medicaid Buy-In 

program for workers with disabilities. The Act expanded work incentives, providing SSDI 

beneficiaries and SSI recipients with the option to receive a ticket. Ticket holders can use it 

to secure employment services, training, and other supports from ENs of their choice. This 

is a market-driven approach to expanding employment service options for beneficiaries. 

The Act also eliminated work-triggered CDRs; created a work incentive outreach program to 

provide information, planning, and guidance to SSI and SSDI beneficiaries; and provided the 

expedited reinstatement (EXR) provision for both SSDI and SSI. The Act was generally 

viewed as greatly expanding both opportunities and incentives for people with disabilities to 

go to work. The Ticket to Work program is outcome-based, authorizing payments to ENs 

based upon employment outcomes. 

This section analyzes the implementation of the three elements of the Act: Title I, Ticket to 

Work and Self-Sufficiency and Related Programs; Title II, Expanded Availability of Health 

Care Services; and Title III, Demonstration Projects and Studies. 

Ticket to Work and Self-Sufficiency and Related Programs 

The Ticket to Work program provides eligible SSDI beneficiaries and SSI recipients with a 

ticket voucher that can be used to access employment services and supports from VR or an 

independent private not-for-profit or for-profit entity that has been certified by SSA as an 

EN. The rollout of the Ticket to Work program with mailing of tickets to beneficiaries was 

staggered over a three-year period nationwide, beginning with Phase One states in 2002. By 

2004, all fifty states, the District of Columbia and U.S. territories had become a part of the 

Ticket to Work program and over 10 million tickets had been distributed to beneficiaries. 

Program participation for beneficiaries is voluntary. 

According to the latest evaluation data available from Mathematica Policy Research, Inc., 

“As of December 2004, there were 9.23 million ticket-eligible beneficiaries. About 30 

percent of them are in the Phase 1 states, another 30 percent are in the Phase 2 states, and 

the remaining 40 percent are in the Phase 3 states.”48 

In addition, the most recent evaluation narrative reports that “[b]y December 2004, 83,568 

tickets were in use. Reflecting the rollout schedule, 45 percent of the tickets were held by 
Final Report to the President and Congress 29 

29 

beneficiaries residing in Phase 1 states, 30 percent in Phase 2 states, and 25 percent in Phase 

3 states. Participation rates continued to rise steadily. The Phase 1 participation rate reached 

1.38 percent in December 2004, the Phase 2 rate reached 0.90 percent, and the Phase 3 rate 

reached 0.56 percent.”49

Since the inception of the Ticket to Work program, SSA has experienced great difficulty 

recruiting ENs. As of November 7, 2007, there are 79 VR agencies and 1,247 other 

community providers operating as ENs. In addition, SSA has yet to identify and implement 

effective means to encourage beneficiaries to participate in the program. As of August 17, 

2007, SSA has issued 12,850,338 tickets: 11,950 or 0.1 percent have been assigned by 

beneficiaries to ENs that are not part of the VR system and 172,336 tickets have been 

assigned to VR agencies.50 Combined, only 1.4 percent of eligible beneficiaries have 

participated in the Ticket to Work program. Based on employment outcomes achieved for a 

ticket holder, an EN currently receives payments from SSA through two options: a 

milestone payment system or an alternative five-year outcome-based set of measures. As of 

June 15, 2007, SSA has made milestone or outcome payments to ENs including VR agencies 

on behalf of only 3,061 beneficiaries.51

No subject has dominated the attention of the Panel more than the challenges faced by the 

Ticket to Work program. During every public meeting over the past eight years, the Panel 

has included presentations by SSA on the status of implementation, strategies to increase the 

level of participation by beneficiaries, and efforts to expand the number of ENs to serve 

them. Each quarterly meeting has also included diverse stakeholders offering testimony on 

experiences with the program and suggestions on how to improve it. The Panel has heard 

examples of successful participation, which offer hope about the possibilities for the future, 

leading the Panel to suggest amendments to the reimbursement system and a greater focus 

on marketing and outreach to beneficiaries. Based on stakeholder input, the Panel has 

submitted multiple recommendations encouraging SSA to make urgent progress toward a 

realization of the promise and full potential of the Act. 

Evaluation of the Ticket to Work Program 

The Act mandated that SSA conduct an evaluation study to determine successes and 

problems in implementation of the Ticket to Work program. Four broad areas are being 

studied via interviews, site visits, analysis of SSA and Rehabilitation Services Administration 

data sets, and other sources. The following areas of analysis are included in the evaluation: 

process, participation (beneficiary and provider), impact/outcomes, and adequacy of 

incentives. The evaluation contract was awarded to Mathematica Policy Research, Inc., and 

has yielded three reports to date. 

In general, the Panel agrees with most evaluation findings. In fact, the Panel’s 

recommendations often mirror the concerns of evaluators. For instance, the evaluation has 

found that, in general, Ticket to Work program implementation has been successful, but the 
Final Report to the President and Congress 30 

30 

implementation has not yielded the level of choice for beneficiaries that Congress 

envisioned. 

“...While [the Ticket to Work program] has expanded 

beneficiaries’ choice of providers, most of the participation has 

been with VR agencies using the traditional payment system. 

Only 16 percent of Tickets are being used under the two new 

payment systems. The pattern suggests that [the Ticket to 

Work program] does not yet represent a dramatic break from 

the past. Instead, its progress so far represents the introduction 

of new choices and incentives whose ultimate effect will depend 

on the eventual level of participation and the extent to which 

ENs and VR agencies offer newer and more effective 

services.”52

The evaluation also identified several reasons for the low participation rates of beneficiaries 

and ENs. The payment structure for ENs and the role of VR agencies in the Ticket to 

Work program were cited as problems in the evaluation. Many of the structural issues 

identified in the study can be mitigated if SSA’s September 2005 notice of proposed 

rulemaking is made final. For example, the evaluation predicted the following: 

“[T]he new regulations allow ENs to accept Tickets from the Ticket to Work program 

participants who received employment services from an [state vocational rehabilitation 

agency] SVRA under the cost reimbursement system. In doing so, they will be able to reduce 

the upfront costs for outreach, screening, and employment services, focus on providing 

ongoing support services necessary for the Ticket to Work program participants to maintain 

employment, and thereby improve their chances of breaking even under the program.”53

In their most recent report, the evaluators reported positive results with regard to SSA staff 

attitudes toward employment for beneficiaries. “Changes in administrative procedures 

appear to have started a shift toward an SSA culture that supports return-to-work. SSA staff 

members interviewed for this report suggested a positive shift toward an SSA culture that is 

clearly supporting return-to-work for beneficiaries. The reported shift appears to stem from 

the fact that many employees who serve beneficiaries with disabilities are learning about and 

becoming more substantially involved in efforts to improve beneficiary earnings. Many 

receive training in Ticket and, more broadly, the DI and SSI work incentive programs; many 

have been introduced to and are now using new data systems that track employment and 

other post-entitlement outcomes; and many were involved in the effort to clear the postentitlement workload backlog.”54

The Panel is pleased to know of this positive development; however, the anecdotal evidence 

heard through public comment and the beneficiary summit indicates to the Panel that there 

may still be some work to do in this area. Beneficiaries still report to the Panel that return-
Final Report to the President and Congress 31 

31 

to-work information imparted from SSA field offices is sometimes inconsistent and/or 

incomplete. 

The Panel does continue to have concerns about the evaluation’s analysis of the Adequacy 

of Incentives (AOI) Study. Congress recognized that the Ticket to Work program would 

not be equally available to all individuals with disabilities. In particular, some people with 

significant disabilities might be involuntary non-participants. That is, they might be willing to 

work but, because of their limited wage potential or their need for ongoing support and 

services, high-cost accommodations, and/or partial cash benefits, as well as outside factors, 

they might not find an EN willing or able to take their ticket under the existing financial 

incentives of the Ticket to Work program. These four groups are referred to as the AOI 

groups. 

To address this equity issue, Congress included a requirement in the statute that SSA identify 

and implement a payment system that would allow this population to participate in the 

Ticket to Work program. 

The Panel recommended in 2002 that “While there is a need to take advantage of what is 

known about the diagnostic categories with high proportions of those most likely to fall into 

one of the four groups relative to work capability, the Social Security Administration, in 

addition to diagnostic data, should use other information, such as survey information, 

information on earnings, onset date, and medical improvement assessments. SSA should 

also go to outside data sources, such as those identified in Expert Roundtable 

Recommendation 1, to identify members of the four target groups.”55 Evaluators have 

examined the populations of beneficiaries targeted by SSA. The Panel remains skeptical that 

the four AOI groups are adequately identified. 

On a related topic, the proposed Ticket to Work regulations of September 2005 represent a 

likely improvement in service provision for some of the AOI target populations. This is due 

to the decoupling of VR services from those of ENs, thereby providing the possibility for 

both front-end, more costly services/accommodations via VR and five years of follow-along 

by an EN. However, the needs of the AOI target group requiring long-term follow-along 

were not fully addressed in the proposed regulations. An open question is what happens to 

individuals requiring life-long or significantly long-term services and supports after the five 

year follow-along available via the Ticket to Work program. 

Proposed Revisions to the Ticket to Work Program 

Proposed revisions to the Ticket to Work program were published by SSA in the Federal 

Register on September 30, 200556 and included many recommendations made by the Panel. 

On September 28, 2006, the one year anniversary of the publication of proposed 

amendments, the Panel sent a letter to the Commissioner of SSA emphasizing the 

importance and urgency of issuing the final regulations. At the Panel’s last quarterly meeting 

in 2006, SSA reported that the final regulations would be further delayed as a result of issues 
Final Report to the President and Congress 32 

32 

that needed to be addressed in a new notice of proposed rulemaking (NPRM). The 

identified issue related to the “Ticket in Use” by beneficiaries in higher education and the 

procedures for suspension for a time-limited period of required CDRs. On August 13, 2007, 

the NPRM was published in the Federal Register57 along with several additional proposed 

amendments. A final rule is not expected to be published until the spring of 2008. Without 

a final rule offering significant improvements and thereby renewing EN and beneficiary 

interest, efforts at marketing and outreach will remain challenging. In the interim, SSA is 

identifying ways to effectively market to beneficiaries. In the spring of 2007, SSA began 

holding pilot Work Incentive Seminars. These seminars are community level, small group 

informational sessions that give beneficiaries the opportunity to meet with representatives 

from the Work Incentives Planning and Assistance (WIPA) program, community work 

incentive coordinators (CWICs), ENs, and other public and private community-based 

groups. The seminars provide a customer-friendly environment for answering questions and 

demystifying fears related to return to work. While the initial beneficiary turnout for these 

events was minimal, response to the events appears positive. No outcome data regarding 

the pilot seminars are currently available. 

Work Incentives Planning, Assistance, and Outreach 

“I truly do believe that if a beneficiary can get a good benefit analysis and 

get the right community resources that they are going to see the value in 

wanting to go to work and become self-sufficient.” 

Natalie Alden, Advocate 

Advocacy Center, Jacksonville, FL 

Testimony at the Ticket to Work and Work Incentives 

Advisory Panel Quarterly Meeting 

Washington, DC 

June, 2006 

Title I subtitle C of the Act authorized programs to inform, assist, and protect beneficiaries 

interested in pursing work by establishing the Benefits Planning, Assistance and Outreach 

(BPAO) program and the Protection and Advocacy for Beneficiaries of Social Security 

(PABSS) program. The Act also authorized SSA to create an internal corps of work 

incentive specialists. 

In 2000, SSA established 116 BPAO projects in all states, the District of Columbia, and U.S. 

territories. The purpose of the BPAO program was to provide SSI recipients and/or SSDI 

beneficiaries with accurate information about work incentives to help them make informed 

choices regarding work and its potential impact on their benefit status. BPAO programs 
Final Report to the President and Congress 33 

33 

nationwide were administered by VR agencies, centers for independent living and other 

community-based organizations. 

Data on the activities of over 500 benefit specialists in the 116 BPAO projects was reported 

to a centralized data management system at Virginia Commonwealth University. The BPAO 

program operated from 2000-2006 and served over 252,000 beneficiaries nationwide.58 The 

BPAO program served individuals with disabilities across the full range of age and type of 

disability. 

Over 84 percent of individuals served were between ages 22 and 59. One-third of the 

individuals served identified psychiatric or emotional disability as their primary disability. 

There was equal representation of women (50.2 percent) and men (49.8 percent). The range 

of services provided included information and referral (90.9 percent), problem solving and 

advocacy (31.9 percent), benefits analysis and advice (43.4 percent), benefit support planning 

(13.9 percent), and benefits management (5.3 percent). 

The work incentives recommended most frequently included the Ticket to Work program 

(53.6 percent), EPE (49.9 percent), 1619(b) (31.9 percent), extended Medicare coverage for 

SSDI beneficiaries (28.9 percent), and Medicaid Buy-In (19.9 percent). 

According to a customer satisfaction survey of 1,764 randomly selected beneficiaries who 

had received services from a BPAO provider, 89 percent rated the services provided as 

“excellent”, “very good”, or “good.” Before receiving counseling, 28 percent indicated that 

they were working, and 47 percent of respondents indicated that, after contact with the 

BPAO, they found employment, which represents an increase of 19 percent.59 However, the 

Panel learned from beneficiaries about challenges within this program. Some beneficiaries 

reported having to wait weeks to get an appointment because there were not enough 

benefits planners. Because of the size of some geographic areas, some beneficiaries did not 

have access to benefits planners to address their needs. Other beneficiaries shared that 

benefits planners could not answer their questions or provided inaccurate information.60 In 

response, the Panel sent a letter to the Commissioner of SSA in February 2005 

recommending the development of minimum standards for effective service delivery and 

minimum qualifications for benefit planners. The Panel also suggested to SSA that all BPAO 

programs have agreements with ENs and Disability Program Navigators (DPNs) in their 

geographic catchment areas to better serve unserved and underserved populations. 

In May 2006, SSA issued a new competitive Request for Application (RFA) for the former 

BPAO program. The program was renamed the Work Incentives Planning and Assistance 

(WIPA) program due to its increased emphasis on work incentives, return-to-work supports, 

and jobs for beneficiaries. This emphasis represented a shift from general information 

dissemination and outreach to strategic and intentional outreach. It also demonstrated a 

focus on practice and utilization that results in enhanced employment outcomes.61 
Final Report to the President and Congress 34 

34 

The renamed program became effective September 30, 2006 with awards to 99 WIPA 

projects in 49 states. Of the 99 awardees, 84 previously served as BPAO organizations. A 

second solicitation was offered from October 17, 2006 through December 15, 2006, 

resulting in another five WIPA projects being awarded for states and territories that were 

previously without permanent work incentives assistance grantees. SSA has awarded a total 

of 104 WIPA grants.62 No administrative data is currently available regarding the new WIPA 

initiative. Concerns have been expressed by the Panel that it appears SSA has lessened data 

reporting requirements for WIPA projects, which could potentially limit the evaluation of 

this provision of the Act. 

Protection and Advocacy for Beneficiaries of Social Security 

In April 2001, SSA established a national system of services for the protection and advocacy 

of beneficiaries. The Act defined the role of PABSS programs as “providing information 

and advice about obtaining VR and employment services and advocacy or other services that 

a disabled beneficiary may need to secure or regain gainful employment.” Services are 

provided to individuals with disabilities across the full spectrum of age and type of disability. 

PABSS grants were made to 57 states, territories and Native American protection and 

advocacy agencies. Since December 2001, PABSS programs have provided information and 

advocacy services to over 9,500 beneficiaries. From Fiscal Year 2003 through 2006, PABSS 

programs documented over 14,003 client concerns across 13 major categories requiring 

individual assistance. The top four areas of beneficiary concern were related to: Social 

Security overpayments (36 percent), VR (20 percent), benefits planning (12 percent), and 

employment discrimination (10 percent). Outcomes achieved through the PABSS programs 

include obtaining information concerning rights, addressing overpayment situations, 

improving access to services from VR or an EN, and regaining or obtaining employment.63 

Diverse stakeholders have reported to the Panel that the PABSS funding level of seven 

million dollars is inadequate to meet the demand.64

SSA Internal Corps of Work Incentive Specialists 

Prior to the implementation of the Act, SSA recognized the importance of marketing and 

outreach to beneficiaries regarding existing work incentives. From July 2000 to September 

2001, SSA piloted new field positions, Employment Support Representatives (ESRs),65 to 

serve as work incentive specialists improving access to information for beneficiaries with 

disabilities who wanted to work. Thirty-two ESRs were assigned to serve 54 cities. ESRs 

were trained on all Title II and Title XVI employment support programs. An evaluation of 

the pilot program identified the importance of locating ESRs onsite in SSA field offices to 

provide expert assistance to beneficiaries in concert with other SSA field staff. In 2002, for 

the first time, SSA created a Strategic Partnerships and Outreach Team to be a part of its 

Office of Employment Support Program’s Division of Employment Policy. The team was 

created to develop a more comprehensive approach to outreach and public information 

focused on interdepartmental (federal, state, and local partners), employer, and advocacy 

group relationships. 
Final Report to the President and Congress 35 

35 

In 2004, SSA replaced the ESR pilot with permanent full-time Area Work Incentive 

Coordinators (AWICs), which were no longer under the auspices of the Office of Disability 

and Income Support Programs, but rather the Office of Operations.66 AWICs were placed 

in 54 SSA field offices nationwide to provide outreach to beneficiaries and timely and 

accurate information on work incentives. AWICs are also responsible for training Work 

Incentive Liaisons (WILs) in each field office. There are 1,335 individuals designated and 

trained as WILs to provide enhanced services to beneficiaries. The services provided by 

WILs complement the role of the AWIC with on-site assistance to other field office 

personnel regarding employment support programs and direct involvement with high profile 

individual cases. For the individual SSA staff member functioning as a WIL, however, those 

services are performed in addition to the individual’s primary duties within the field office. 

SSA has reported to the Panel on a quarterly basis on the outreach and meetings attended 

and training offered by AWICs and WILs within and outside SSA field offices to target 

audiences nationwide. To date, however, no performance-based indicators have been made 

public to objectively evaluate the individual performance of an AWIC or a WIL in a specific 

geographic area, or, collectively, the impact of the positions nationwide on improved 

customer satisfaction or change in employment status of beneficiaries through the use of 

specific work incentives.67 

As recently as August 2007, beneficiaries at a Panel meeting complained about receiving 

inaccurate information from staff in SSA field offices, and about the inadequate number of 

AWICs available to access timely and consistent information to make informed decisions 

about work. Another challenge to providing seamless work incentive assistance is that within 

SSA, the work of AWICs and WILs is managed through an organizational unit separate 

from the one responsible for WIPA and PABSS program management. 

The challenges to generating new beneficiary interest in employment and work incentives 

through marketing, outreach, and the provision of accurate and consistent information are 

formidable. These challenges, as identified by stakeholders, include inadequate resources to 

support AWICs, WIPA and PABSS programs; inadequate quality assurance mechanisms to 

evaluate and improve service delivery; and a continuing need to improve coordination 

among these specialists (AWICs, WILs, WIPA, and PABSS) and other community partners. 

Whether a beneficiary is seeking accurate information about the Ticket to Work program or 

other work incentives, the cumulative evidence shared with the Panel by individuals with 

disabilities indicates that these fragmented activities do not reach the intended audience with 

the necessary information. The Panel has repeatedly urged SSA to design, develop, and 

implement a comprehensive marketing and outreach strategy that effectively engages 

beneficiaries and ties in with other relevant service delivery systems. 

The Act offers beneficiaries the opportunity to access a variety of supports and work 

incentives designed to reduce life-long dependence on cash benefits. However, without a 
Final Report to the President and Congress 36 

36 

coordinated and comprehensive outreach strategy that focuses not just on the Ticket to 

Work program, but also on the range of work incentive options available, millions of 

beneficiaries remain afraid to attempt to work. 

Expanded Availability of Health Care Services 

“I can't help but wonder how many other people really would go back to 

work, but it's just so much easier in their mind to stay in that system 

because of that fear [of loss of medical benefits]...I just feel like you either 

have to be destitute or you have to be, you know, have been in the system 

and have private insurance if you are going to get diagnosed with something 

that's a chronic illness for life. And when you want to be a contributing 

member of society you feel like the system that is there to help you will only 

help you if you are completely down. It won't help you to help yourself.” 

Velissa Cortessano 

Testimony at the Ticket to Work and Work Incentives 

Advisory Panel Quarterly Meeting 

Miami, FL 

November, 2005 

Fear of losing health care coverage is one of the most significant barriers to employment 

identified by beneficiaries. Congress has taken several steps to mitigate the impact of health 

coverage on an individual’s willingness to attempt work.

Medicaid Buy-In Programs 

The Act allows states to establish Medicaid Buy-In programs that expand health care 

coverage to workers with disabilities whose income and assets may otherwise make them 

ineligible for Medicaid coverage. Without access to a buy-in, many beneficiaries who do 

work depress their earnings because eligibility for Medicaid depends partly on income. 

Participation in a state’s Medicaid Buy-In program can: 

1. Ensure continued coverage for persons who can risk permanent loss of SSDI 

cash benefits because they only need the Medicaid benefits to supplement 

private health insurance. 

2. Enable Medically Needy program participants to increase their net or 

disposable income by moving to the Medicaid Buy-In program. 

3. Enable SSI recipients to move from Medicaid with a lower earnings limit 

under Section 1619(b) to higher earnings ceilings under a Medicaid Buy-In. 
Final Report to the President and Congress 37 

37 

4. Enable persons to move to a category of Medicaid eligibility with higher 

resource limits than the SSI program and thus increase their level of 

independence. 

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

A report issued by Mathematica Policy Research, Inc., in May 2007, listed the following 

findings regarding what attracts Buy-In enrollees: 

“About one-fifth of Buy-In participants who enrolled in 2005 

were SSI recipients in the prior year... For them, the Medicaid 

Buy-In is not a pathway to new or additional health insurance 

but rather an opportunity to expand earnings without losing 

their Medicaid coverage.” 

Slightly more than one-half (55 percent) of all participants in the Buy-In program between 

1997 and 2005 were Medicare beneficiaries at enrollment...[and] may have enrolled in the 

Buy-In program to obtain health services that Medicare does not cover. For this group, the 

Buy-In program represents an opportunity to use Medicaid as a secondary wraparound 

health insurance plan. 

Other working-age adults who have enrolled in Medicaid Buy-In programs include 

individuals who have a serious disabling condition but have not been deemed “disabled” 

under SSA guidelines because they have consistently worked or wanted to work... For these 

individuals, the Medicaid Buy-In program offers an opportunity to pursue their personal 

employment goals while obtaining access to affordable health insurance.”68

In a separate Mathematica analysis, participants in the Medicaid Buy-In who also utilized the 

work incentive under Section 1619 increased their earnings by 56.6 percent, compared to an 

average 39.4 percent increase for individuals not participating in 1619 programs.69

Taken together, these findings indicate that at least some of the benefits of the Buy-In are 

being realized, both for beneficiaries and for some individuals with disabilities who are 

working and do not receive SSDI or SSI. 

States that have established Medicaid Buy-In programs allow workers with disabilities to pay 

premiums in order to buy into the Medicaid program. The Act gives states the flexibility to 

establish rules of eligibility in terms of both income and assets, as well as to create a sliding 

fee structure for participants who are required to pay more as earnings increase. As of 

December 2006, 33 states were operating Medicaid Buy-In programs, with total nationwide 

enrollment of nearly 80,871.70

No two states have developed the same rules for participation. The variability includes 

criteria for eligibility, premiums charged, and limits on unearned income. According to 
Final Report to the President and Congress 38 

38 

participation data through FY 2004, 71 percent (66,977) of enrollees were SSDI beneficiaries 

and only 1 percent (1,186) were SSI recipients. Twenty-five percent of enrollees were 

neither SSI nor SSDI beneficiaries.71

The Act and subsequent regulations prohibit states from setting minimum levels of work or 

earnings for participation in Medicaid Buy-In programs. This decision was intended to 

ensure that low earners (especially individuals with developmental disabilities) would not be 

denied eligibility. There are a variety of ways that states require participants to work. A 

common provision in a number of states requires that Medicaid Buy-In enrollees 

demonstrate that they are paying FICA taxes, or in the case of self-employment, show a 

quarterly IRS tax statement.72 A state can limit its Medicaid Buy-In program to those with 

substantial earnings and thereby require participants to work, by setting an unearned income 

limit that can be exempted for individuals with earnings generated through employment. 

This is the case in Nebraska’s Medicaid Buy–In program. Nebraska has crafted an unearned 

income limit equal to the federal SSI standard plus the $8 state SSI supplement, but then 

exempts persons from the limit if they have earnings in a month that is sufficient to be 

considered a TWP month. 

In Oregon, the Medicaid Buy-In program requires participants to pay as a monthly cost 

share any unearned income in excess of the SSI standard. A "special need" SSI state 

supplement can increase the applicable SSI standard for certain purposes, reducing payment 

liability. SSDI beneficiaries, with benefit amounts significantly above the SSI standard, only 

find participation in the Medicaid Buy-In program financially worthwhile if their earnings 

exceed the cost-sharing amount. 

A random sample of state Medicaid Buy-In participant surveys reveals the reasons for the 

current level of employment and for beneficiaries’ limiting work. In Iowa, 61 percent of 

survey respondents stated that they were limiting their work activity, and the reasons for 

doing so were as follows: The primary reason was the severity of their physical disability (78 

percent). Thirty-one percent reported that working has caused their health to get worse, 

with 63 percent reporting that their health has gotten worse for reasons unrelated to 

working. 

In Minnesota, survey participants identified that physical health problems (48 percent) and 

mental health problems (30 percent) prevented them from working sometime during the 

past year. In Vermont, when asked why they worked less than they believed they could over 

the last year, 22 percent of respondents reported it was due to their disability. Eighty-one 

percent of those who were continually enrolled in the Medicaid Buy-In program in Utah 

reported that their disability was what prevented them from working more hours. 

States must devise their Medicaid Buy-In programs within the constraints of federal SSDI 

law. Policymakers and other stakeholders must recognize that most SSDI beneficiaries 

participating in Medicaid Buy-In programs may be unwilling to earn more than SGA because 
Final Report to the President and Congress 39 

39 

of the SSDI cash cliff. For instance, four of the state Medicaid Buy-In surveys (Iowa, 

Kansas, Minnesota, and Utah) indicated that from 25 to nearly 55 percent of the participants 

in the Buy-In programs were adjusting their work activities to protect themselves against loss 

of SSDI benefits because of exceeding SGA.73

Mathematica Policy Research, Inc. has found through its analysis that some states 

implementing the Buy-In have included components that appear to positively impact the 

earnings of participants. These include: 

“In eight states—Nebraska, New York, Connecticut, New 

Jersey, Illinois, Maine, Kansas and Vermont—more than 50 

percent of participants increased their earnings after they 

enrolled in the Buy-In program. Some program features in these 

states may have contributed to this finding. For example, 

Connecticut has the highest income limit for the Buy-In 

program among all states, which might have diminished a 

constraint to increased employment. Nebraska, Maine, and 

Vermont do not provide a grace period for those who lose 

work, which may signal that work is a strict condition for 

participation, thus attracting participants who are more likely to 

work.”74

Demonstration to Maintain Independence and Employment 

In addition to the Medicaid Buy-In discussed above, Section 204 of the Act authorizes the 

creation of the Demonstration to Maintain Independence and Employment (DMIE). By 

including this provision, Congress recognized that tying health coverage to cash benefits for 

many individuals with disabilities creates a “catch 22” in which individuals leave the 

workforce prematurely, experience declines in their overall health, and begin receiving cash 

payments through SSI and/or SSDI primarily as a means to secure access to health care. 

The DMIE is designed to provide health care and other wrap-around employment supports 

to individuals with disabilities who are working and are not receiving cash benefits. Each 

state’s project is required to provide health care and supports to subgroups of individuals 

with disabilities such as those with mental illness or diabetes. States must set up the project 

with treatment and control groups and have a rigorous evaluation component. 

The types of services being provided through the DMIEs vary according to the target 

population for each project. For example, in Kansas where participants are drawn from the 

high-risk insurance pool, services focus on broad cost reductions to individuals accessing 

care, while in Minnesota where the target is individuals with psychiatric disabilities, a 

wellness navigator is made available to the treatment group, as well as comprehensive 

medical and behavioral services. 
Final Report to the President and Congress 40 

40 

At this time, four states are operating DMIEs—Hawaii, Kansas, Minnesota, and Texas, and 

the combined target size for all treatment groups is 2,767 individuals. In addition to the four 

states fully participating, a handful of others have either been unable to implement DMIEs 

for which they were approved or do not have sufficient evaluation components to allow for 

study of the project results.75

The concept behind the DMIE is sound and a valuable addition to the policy discussion 

regarding return-to-work. While the Panel views the DMIE projects as potentially valuable 

in terms of what might be learned about achieving continued workforce attachment through 

provision of health care and other employment supports, the tiny number of states 

participating is disappointing. 

Medicaid Infrastructure Grants 

Current Medicaid Infrastructure Grants (MIGs) authorized under the Act and administered 

by the Centers for Medicare and Medicaid Services (CMS) allow the majority of states to 

expand beyond the Medicaid Buy-In to other strategies that support beneficiaries’ entry into 

or return to work and advance their financial independence. Policy development, crossagency collaboration, and new approaches to engage the employer community are part of a 

growing number of state efforts to establish a comprehensive system of policy and program 

supports that encourage work, improve access to health care, and customize solutions to 

meet individual needs. 

More needs to be learned from Medicaid Buy-In participants about their fear of losing cash 

benefits and, as a result, limiting income to stay below the SGA level. In addition, more 

study is required regarding the impact of the variable state approaches to asset building and 

income growth. 

CMS, in a study of Medicaid Buy-In implementation, has identified significant differences in 

the percentage of people who increased their earnings after they enrolled in their state 

Medicaid Buy-In program. States with the most restrictive asset limits had the smallest 

increase in participant earnings.76 

Beneficiaries nationwide have identified the need for protection for former Buy-In 

participants who are no longer able to work. These individuals with disabilities still need 

access to Medicaid, but many are prevented from receiving SSI and thus Medicaid because 

of the assets they accumulated while they were Buy-In participants. 

Demonstration Projects and Studies 

SSA oversees demonstration projects and other initiatives to test alternative strategies to 

reduce barriers for individuals with disabilities who want to enter or return to work. Each of 

the demonstration projects cover multiple sites over several years, with some extending out 

ten years to evaluate long-term impact and individual outcomes. 
Final Report to the President and Congress 41 

41 

The Benefit Offset Demonstration will allow SSA to test the impact and cost of a sliding 

scale benefit offset for SSDI beneficiaries and applicants. Under this test, disability benefits 

will be reduced one dollar for every two dollars an SSDI beneficiary earns above a given 

threshold. An initial four-state pilot is underway in Connecticut, Utah, Vermont, and 

Wisconsin. The purpose of this pilot is to collect information that will be useful in 

developing a national study, which is expected to begin recruiting beneficiary participants in 

2009. 

The Youth Transition Process Demonstration is testing ways to increase self-sufficiency 

for youth with disabilities by modifying several work incentives to encourage increased 

income, savings, and asset development and improving coordination of service delivery 

among multiple government agencies, school systems, community providers, and employers. 

Currently, there are five pilots and possible expansion to pilots in three additional states by 

the end of 2007. 

Homeless Outreach Project and Evaluation (HOPE) are assisting eligible, homeless 

individuals in applying for SSI and SSDI benefits. These projects will help SSA demonstrate 

the effectiveness of using skilled medical and social service providers to identify homeless 

individuals with disabilities and assist them in applying for benefits. SSA awarded funds to 

41 projects to provide outreach services to the target population. Through July 1, 2007, 

HOPE grantees assisted 8,440 homeless individuals with their disability applications. Of 

those, 2,659 individuals have been awarded benefits. 

The Accelerated Benefits (AB) Demonstration Project will provide immediate health 

benefits to a random sample of newly entitled SSDI beneficiaries. For the participants, the 

24-month waiting period for Medicare will be waived, and participants will also be provided 

with appropriate employment supports based upon individual need. A project 

implementation and evaluation contract was awarded in January 2006. A health benefits 

plan for AB participants has been approved, and Phase I enrollments began in four sites 

(New York, Phoenix, Houston, and Minneapolis) in October 2007. Phase II enrollments are 

expected to begin in January 2008, and enrollment is expected to be completed by 

November 2008. An evaluation report is due by January 2011. 

A Mental Health Treatment Study (MHTS) is currently testing the impact of better 

access to treatment and other supports on beneficiary outcomes related to medical recovery 

and employment. The targeted population is SSDI beneficiaries with psychiatric disabilities. 

The project is being implemented in 22 cities, and enrollment began in October 2006. As of 

July 2007, there were 732 beneficiaries enrolled in the study. 

The Panel has received feedback from SSA, provider agencies, and beneficiaries about the 

development and implementation of these demonstration efforts. The Panel has noted 

consistent support for these initiatives, which recognize the diverse needs of beneficiaries 

and the importance of overcoming multiple barriers to employment. The strength of 
Final Report to the President and Congress 42 

42 

current efforts has been their recognition of the need to pursue new approaches and new 

policies that are counter to current rules and system design. The projects also underscore the 

need to improve coordination and collaboration at a federal, state, and local level. 

Involvement should include government across agencies and the private sector including 

community organizations and employers to build a seamless system of support that is 

responsive to the needs of beneficiaries. Stakeholder testimony, however, repeatedly 

questioned the slow pace of projects from concept to design, and from implementation to 

evaluation; this has been frustrating to beneficiaries and to the Panel. 

Are Beneficiaries Better Off Today?

To answer the question of whether beneficiaries are better off today, the Panel has sought 

comments and advice from beneficiaries, federal agency leadership, program managers, ENs, 

the workforce development system, and other relevant stakeholders in the public and private 

sectors and at all levels of government. Based on the body of evidence presented by SSA, 

CMS, external experts, and beneficiaries, progress has been made, but the full potential of 

disability employment programs has not been realized. A majority of states have established 

Medicaid Buy-In programs. MIGs, administered by CMS, have enabled states to design and 

implement a variety of policy and program reforms that respond to system fragmentation, 

complexity, and beneficiaries’ fear of loss of health care benefits. Also, MIGs provide 

expanded access to benefits planning and new options to increase income and build assets. 

For the Panel, the greatest disappointment has been in implementation of the Ticket to 

Work program. In September 2005, SSA published an NPRM on Amendments to the 

Ticket to Work and Self-Sufficiency Program.77 The amendments incorporated many of the 

Panel’s priority recommendations. The Panel was particularly pleased that the proposed 

amendments addressed the multi-step nature of returning to work by redesigning the 

payment system for ENs and offering more frequent and earlier payments. Commenters 

addressing the Panel regarding the NPRM universally agreed that the proposed changes 

would improve the program and stimulate new interest by both beneficiaries and ENs. 

Unfortunately, SSA has yet to publish final regulations, and does not expect to until the 

spring of 2008. 

National Trends

The Panel’s recommendations recognize the value of work and the economic consequences 

of failing to improve programs. In addition, they represent the Panel’s contribution to an 

ongoing national dialogue regarding modernization of current disability policies and systems. 

The Panel’s recommendations are informed by national trends related to education, 

employment, and health care. 
Final Report to the President and Congress 43 

43 

Education 

The enactment of the Individuals with Disabilities Education Act (IDEA) in 1975 mandated 

that youth with disabilities be provided a free and appropriate public school education. 

Between 1976-77 and 2005-06, enrollment in federally supported special education programs 

rose from 8 percent (3.7 million) to 14 percent (6.7 million) of children (three to 21 years 

old) in public schools. In addition, the percentage of students with disabilities spending 80 

percent or more of the school day in a general classroom showed an overall increase from 45 

to 52 percent between 1995 and 2005.78

In today’s economy, graduating from high school is more critical than ever to securing a 

good job and a promising future. Since an estimated 85 percent79 of current jobs and almost 

90 percent80 of the fastest-growing and best-paying jobs now require some postsecondary 

education, a high school diploma and the skills to succeed in college and the workplace are 

essential. Nationally, however, one-third of students—about 1.23 million each year—leave 

high school without a diploma.81 

According to the National High School Center, dropout prevention for students with 

disabilities is a critical need. Students with disabilities drop out of school at significantly 

higher rates than their peers who do not have disabilities. Of those who do not complete 

high school, about 61.2 percent are students with emotional/behavioral disabilities, and 

about 35 percent are students with learning disabilities. In the 2001-02 school year, only 51 

percent of students with disabilities exited school with a standard diploma.82 As with 

students without disabilities who drop out, there are significant costs to individuals with 

disabilities who do not complete high school. These costs include unemployment, 

underemployment and higher rates of incarceration. There are also significant costs to 

society related to lost tax revenues and welfare expenditures. 

The most recent data from the National Longitudinal Transition Study-2 (NLTS2) indicates 

that some progress is being made for youth with disabilities who are two years out of high 

school. Of this group, 30 percent have taken postsecondary school classes, and 20 percent 

are currently attending postsecondary school. However, this percentage is less than half that 

of their peers in the general population. Their rates of employment show that about 70 

percent have worked for pay since leaving high school and more than 40 percent were 

employed at the time of the survey. This rate is substantially below the 63 percent 

employment rate of their peers in the general population. Although, many of these youth 

with disabilities have experienced an increase in their hours and wages, receipt of benefits as 

part of a comprehensive package is uncommon.83 

These mixed results have raised questions about the education integration policies of the late 

1990s for all students with an emphasis on academics to the exclusion of vocational 

education, career education and other experiences related to the development of social skills 

and independent living.84 These policies can have an adverse impact on youth with 

disabilities who are graduating from high school lacking essential employment and life skills. 
Final Report to the President and Congress 44 

44 

The trends for youth with disabilities demonstrate that they are attaining educational 

achievement, but achieve lower employment rates than their peers without disabilities. For 

youth with disabilities, this can lead to increased poverty and greater reliance on income 

support programs and increased attachment to public health insurance programs. These 

outcomes are raising questions about the effectiveness of our current disability policies, 

which were aimed at creating greater economic independence and an improved standard of 

living for youth with disabilities. 

 

Employment 

Employment is one of the most complex subjects in the lives of Americans with disabilities. 

According to a report from GAO on 21st century workforce challenges and opportunities,85

the U.S. workforce of the 21st century faces a very different set of opportunities and 

challenges than previous generations. Demographic and economic trends indicate that the 

size and composition of the labor force, as well as the characteristics of many jobs, are 

changing. A number of broad economic trends are changing the nature of labor markets 

and employment in the U.S. Three key factors have been identified that will affect workers 

and employers, including people with disabilities, in the next 10 to 15 years: demographics, 

technological change, and globalization.86 

As the baby boom generation (individuals born between 1946 and 1964) approach 

retirement, the U.S. workforce will undergo a substantial shift. In 2005, according to U.S. 

Census Bureau data, there were 193 million Americans aged 25 or older. This number is 

expected to increase by 22 percent to almost 236 million by 2025. However, the number of 

people 25 to 54 years old—the ages when labor force participation rates are highest—will 

increase by only 3.8 percent.87 Looking at this in another way, the size of the U.S. labor force 

doubled from 62.2 million workers in 1950 to 140.8 million in 2000; however, through 2050, 

the labor force is projected to grow much more slowly. By 2010, the annual growth rate is 

expected to slow to 0.6 percent and by the 2020s, it is projected to slow to 0.4 percent. This 

represents a sharp decline from the 2.6 percent average increases experienced during the 

1970s and 1.3 percent average annual increases in the 1990s.88

The aging population and slower workforce growth will impact the federal government too. 

The proportion of the federal budget dedicated to programs such as Medicare and Social 

Security will grow significantly as more baby boomers reach their disability prone years. This 

will impact the amount of funding available for discretionary programs such as employment 

and training. 

The projected slowdown in the growth of the nation’s labor force has made it more 

imperative that those who can work are supported in their efforts to do so. The slow 

growth in the labor force should provide opportunities to attract new workers from 

currently untapped resource pools that are unrepresented or underrepresented in today’s 

labor force (e.g., people with disabilities and older workers). It is well documented that labor 

force participation among people with a disability is lower than among those without a 
Final Report to the President and Congress 45 

45 

disability. According to an August 2007 GAO report,89 “economic, medical, technological, 

and social changes over the past several decades have increased opportunities for individuals 

with disabilities to live with greater independence and more fully participate in the 

workforce.” The changes in the dynamics of the 21st century workforce, including 

technological and medical changes, will further enhance opportunities for individuals with 

disabilities to participate competitively in the workforce. 

For individuals who are participating in the workforce, wages determine economic selfsufficiency. Several local governments in the U.S. have enacted living wage ordinances that 

set a minimum wage higher than the federal minimum for the purpose of requiring all jobs 

to meet the living wage for a respective region. Living wage ordinances vary considerably 

across the country in coverage, the wage level mandated, and possible add-ons such as health 

care coverage mandates. What the living wage programs generally have in common are a 

requirement to pay workers a wage that reflects the market rate for the local economy, based 

on the poverty threshold, usually for a family of four. Employers covered by the statute are 

usually only those who receive contracts from the government or receive some favorable 

treatment from the government (e.g., a tax abatement or zoning change).90

On May 25, 2007, President Bush passed legislation that amended the Fair Labor Standards 

Act (FLSA) to increase the national minimum wage in three steps: to $5.85 per hour 

effective July 24, 2007; to $6.55 per hour effective July 24, 2008; and to $7.25 per hour 

effective July 24, 2009.91 For people with disabilities who earn either the minimum wage or 

close to it, these changes provide an opportunity for them to increase their income. 

A significant employment issue for SSI and SSDI beneficiaries using VR services is that they 

have lower employment/earnings outcomes than other VR clients. An analysis of the 

Longitudinal Study of Vocational Rehabilitation Services Programs showed that only 23 

percent of beneficiaries who received services had earnings above $500 per month for at 

least nine months out of a 15-month period, compared to 54 percent of non-beneficiaries.92 

One likely explanation for a substantial portion of the remaining difference is work 

disincentives faced by beneficiaries receiving VR services. Another factor is the potential 

incongruity between SSA’s goal to see earnings maximized for as many beneficiaries as 

possible and Section 102(b)(2)(B) of the Rehabilitation Act of 1973, which requires state VR 

agencies to ensure that each individualized plan for employment includes an outcome that 

reflects the individual’s informed choice, even if that choice is to work below SGA. 

 

Health Care 

In 2005, the U.S. spent nearly $2 trillion on health care, while in 1970, this figure was only 

$75 billion. These figures represent a jump from 7.2 percent of the gross domestic product 

(GDP) devoted to health care in 1970 to 16.0 percent in 2005. CMS projects that by 2016 

health care spending in the U.S. will comprise one-fifth of GDP.93 According to data on per 

capita health care expenditures for developed countries from the Organisation for Economic 
Final Report to the President and Congress 46 

46 

Cooperation and Development,94 in 2004, health care spending in the U.S. was the highest of 

countries with above-average per capita national income. As a share of GDP, spending on 

health care in the U.S. exceeds that of its European counterparts.95 However, 2004 data 

reveal that almost half of all health care spending in the U.S. was used to treat only 5 percent 

of the population. 

Since 2001, according to data collected on income, poverty, and health insurance 

coverage,96,97 the number of people without health insurance coverage has increased. In 

2001, 41.2 million individuals were without health insurance; this number rose to 45.3 

million (15.6 percent of the US population) in 2004, with a slight decrease to 44.8 million 

(15.3 percent) in 2005, and another increase to 47.0 million (15.8 percent) in 2006. Present 

trends indicate that by 2013 the number of individuals in the U.S. without health insurance 

could reach 56 million.98 

Lack of insurance is much more common among people with low incomes. Some 24.4 

percent of people with incomes below $25,000 were uninsured in 2005, almost triple the rate 

of 8.5 percent among people with incomes over $75,000. 

The percentage of people covered by employment-based health insurance decreased to 59.7 

percent in 2006, from 60.2 percent in 2005. In 1987, 70 percent were covered by employer 

sponsored insurance. 

The decline in employment-based health insurance coverage for American workers is 

attributable to increasing health care costs, which are causing some employers to drop 

coverage or to hire contract employees who do not receive employee benefits. When health 

care premiums jumped 52 percent from 2000 to 2005, the rising cost of compensating 

workers led businesses to cut jobs. Health insurance premiums have increased from a range 

of eight to 14 percent per year since 2000; however, inflation and changes in earnings are 

typically in the 3 to 4 percent range. This means that workers have to spend more of their 

income each year on health care to maintain coverage.99 

The percentage of people covered by government health programs also decreased from 27.3 

percent in 2005 to 27.0 percent in 2006. During this time period, the percentage of people 

with Medicaid coverage was 12.9 percent (38.3 million) and Medicare coverage was 13.6 

percent (40.3 million).100 Public programs account for about 45 percent of health care 

spending. Currently, the Medicare program represents the only universal, public health 

insurance program in the U.S. However, this program only applies to individuals who are of 

retirement age (65 and older) and to people receiving disability benefits after a two-year 

waiting period. 

Since the 1990s, the concept of health care for all in America has been discussed by policy 

makers. Many countries have a united or national health care system. In the past few years, 

states have begun to look at strategies to expand health insurance coverage. The latest 

round of state reforms, most of them enacted or proposed in 2006, present a variety of new 
Final Report to the President and Congress 47 

47 

approaches to covering the uninsured, including new mechanisms to subsidize coverage for 

low-income families, new variations on employer and personal responsibility for insurance 

coverage, and new strategies to facilitate the purchase of health insurance for small 

businesses and for individuals without access to employer-sponsored insurance. Several 

state efforts are characterized as comprehensive because they attempt to reach near universal 

coverage. 

Three states—Massachusetts, Vermont and Maine—were highlighted in a report by the 

Commonwealth Fund, State Strategies to Expand Health Insurance Coverage: Trends and Lessons for 

Policymakers.

101 The comprehensive reforms in these three states go further toward helping 

low-income families purchase health insurance than in any other states. One of the key 

elements shared by all three reforms is that they subsidize coverage for families with annual 

incomes up to $61,950 (300 percent of the federal poverty level for a family of four in 2007). 

Each of these states uses Medicaid to partly fund its subsidized product, demonstrating the 

importance of Medicaid as a financing source. To reflect state specific priorities, each state 

combines this effort with other local reforms. The following table identifies the key features 

of the three state reforms. 

Table 1. Key Features of Comprehensive State Reforms102

Key Features of Comprehensive State Reforms 

State Initiative Key Features 

Massachusetts Commonwealth Care Individual mandate 

Employer Fair Share assessment 

Free Rider surcharge 

Health Insurance Connector 

Insurance market reform 

Commonwealth Care* 

Maine Dirigo Health DirigoChoice* 

Cost-containment reforms 

Maine Quality Forum 

Vermont Catamount Health Employer assessment 

Premium assistance for low-income workers 

Catamount Health Plan* 

Chronic care initiatives 

* Includes subsidies for low-income worker 

States that are attempting to cover the uninsured usually build these reforms on prior efforts. 

For instance, Medicaid eligibility levels for adults were expanded over time in these states to 

levels well above the national average. Likewise, they all had strategies in place to improve 

access to care or contain costs. These state-level efforts implement health insurance reforms 

to provide more coverage to all citizens including low-income and uninsured individuals. 
Final Report to the President and Congress 48 

48 
Final Report to the President and Congress 49 

49 

Panel Recommendations 

“Millions of us are using these programs and no one knows better than we 

do how they work or how they could work...We’ve got great ideas and 

insights.” 

Jessica Lehman 

Summit Planner from California 

Beneficiary Summit 

Atlanta, Georgia 

February, 2007 

The final Panel recommendations focus on policy changes and recognize the need for an 

effective infrastructure and the investment of resources to reach, respond, and adapt to 

evolving individual needs. Our nation’s largest disability programs will be modernized by 

the creation of conditions and a policy environment to better support work beyond the 

outcomes currently achieved with the existing work incentives. In addition to updating and 

simplifying current work incentives, the Panel recommends long-term strategies and an 

ongoing national dialogue regarding changes needed to achieve more effective employment 

outcomes. The Panel’s comprehensive policy agenda begins with the establishment of a 

permanent, elevated beneficiary voice. 

Beneficiaries’ perspectives and recommendations have played a primary role in the 

development of Panel advice. Beneficiaries have presented a human voice of experience that 

affirmed to the Panel that most people with disabilities want to work, but are frustrated by 

the complexity of rules of eligibility for work incentives and benefits. The multiple systems 

of support offered by SSA and other federal agencies remain fragmented with information 

about available resources difficult to access, and, at times, unreliable. Well-intended policies 

have the effect of limiting economic security and creating barriers to advancing selfsufficiency. 

The recommendations of the Panel to the President, Congress, SSA, and other federal 

agencies begin with the call to create a permanent mechanism to seek the advice and 

perspectives of beneficiaries impacted by SSA’s policies, procedures, and performance. The 
Final Report to the President and Congress 50 

50 

Panel focuses on fundamental, comprehensive, systemic changes to align policy and program 

supports with the needs and interests of individuals with significant disabilities, so that 

individuals can work to advance their economic self-sufficiency. 

The Panel offers recommendations for immediate improvements to current SSA programs; 

however, it also recognizes that continuous improvements will not modernize a system in 

need of fundamental change. The definition of disability must not be synonymous with the 

inability to work. Access to public benefits must not condemn an individual with significant 

disabilities to a life of poverty. Any new ideas and choices presented should not jeopardize 

the safety net of current programs that offer a fixed income and health care access. There 

are no simple solutions; as costs continue to rise and the number of people who want to 

contribute and be productive in our economy continues to grow, these challenges need 

urgent attention. The Panel’s recommendations should further the ongoing dialogue and 

contribute to effective long-term solutions. 

The final Panel recommendations are organized into three major groups: 

1. Elevate and incorporate the beneficiary voice in all aspects of program and 

policy development, evaluation and improvement; 

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

improvements; and 

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

modernization. 

Elevate and Incorporate the Beneficiary Voice 

The number of SSI and SSDI beneficiaries has grown rapidly in the past 15 years, and the 

employment rate of individuals with significant disabilities has not improved. Conferences, 

public forums, and summits with stakeholders from the public and private sectors have been 

held to analyze the problem and propose solutions. Rarely, however, have individuals who 

are using the SSI and/or SSDI programs been asked to provide recommendations. 

To better understand and address these issues, the Panel conducted a beneficiary summit, 

Voices for Change: Beneficiaries Paving the Way to Work: A Roadmap to Program Improvement. The 

summit, held in Atlanta, Georgia on February 6 -7, 2007, was planned by and for 

beneficiaries and gave the Panel direct, unfiltered input from beneficiaries. Summit delegates 

discussed their experiences with Social Security disability and employment programs and 

recommended changes to policy, procedures, service delivery, information management, and 

systems collaboration. 

The Panel selected seven beneficiaries with disabilities to assist in planning the summit. 

Delegates were selected from a pool of over 300 applicants to achieve the broadest possible 
Final Report to the President and Congress 51 

51 

diversity in disability, culture, age, race, and gender, as well as geographic representation 

from all states, the District of Columbia, and most U.S. territories. 

 

During the summit, delegates focused on four programmatic themes: employment and work 

incentives; health care and long-term services and supports; Social Security program 

communications, procedures, and service delivery; and on the overall summit theme of 

future strategies for raising the beneficiary perspective in policy development and program 

implementation. 

 

The findings from the summit as summarized in the report103 supported and amplified the 

testimony the Panel had received from beneficiaries over the past eight years. Key points 

included: 

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

2. People with disabilities are willing to take responsibility for their lives and are 

able to do many things with the right supports. 

3. Existing work incentives are complicated, poorly understood, and 

underutilized, but they can be effective tools to return to work and achieve 

self-sufficiency. 

4. For people with disabilities who are interested in working, it is difficult to get 

clear, accurate, consistent information about how to use Social Security and 

other government programs. Information should be accessible and culturally 

appropriate. 

5. Social Security should consider the role of the family, as well as the person 

with a disability. 

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

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

The summit experience demonstrates that beneficiaries are a valuable resource for ideas and 

feedback. For example, they have had a powerful impact in shaping the Panel’s final 

recommendations. While Congress and SSA hear from many experts and stakeholders in 

the disability system, to date, they have not heard from beneficiaries in an organized way. 

National Disability Beneficiary Work Council and National Disability 

Beneficiary Work Advocate 

Recommendation 1: Create through legislative authority, within the Social Security 

Administration an Office of the National Disability Beneficiary Work Council (the 

Council) and a National Disability Beneficiary Work Advocate (the Advocate). 
Final Report to the President and Congress 52 

52 

Figure 3. Key Summit Recommendations 

Voices for Change: Beneficiaries Paving the Way to Work 

Key Summit Recommendations 

Employment and Work Incentives 

• Ensure access to health care and benefits 

• Develop and implement a Work Support Program 

• Raise the SSI resource limit to today’s dollars 

• Change the SSDI Extended Period of Eligibility (EPE) 

• Remove the SSI marriage penalty 

• Raise the Substantial Gainful Activity (SGA) 

• Impose a statute of limitations on overpayments 

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

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

• Involve beneficiaries in the development and implementation of any new 

program 

Health Care and Long Term Services and Supports 

• Support family caregivers who provide personal assistant and other services 

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

• Remove the 24-month waiting period for Medicare 

 

Program Communication, Procedures, and Service Delivery 

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

• Fund peer-to-peer mentoring to encourage work 

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

Raising the Beneficiary Voice 

• Advertise the results of the Summit 

• Create a sustainable beneficiary organization 

• Establish a beneficiary voice within the SSA, reporting to the Commissioner 

and Congress 

• Fund, plan and conduct future beneficiary summits and conferences 
Final Report to the President and Congress 53 

53 

Modeled after the Internal Revenue Service (IRS) National Taxpayer Advocate (NTA) and a 

Taxpayer Advocacy Panel, the Council and the Advocate would: 

1. Identify difficulties that SSDI and SSI disability program beneficiaries’ 

experience when trying to work that could be addressed via more effective 

SSA customer service. 

2. Propose changes in the administrative practices of SSA to mitigate those 

customer service issues, to the extent possible. 

3. Identify potential legislative changes to improve SSA’s service to disability 

beneficiaries who want to work. 

The Council and the Advocate would be the main components of an elevated, incorporated, 

permanent voice of beneficiaries within SSA. They would ensure that beneficiaries have a 

direct impact on policies and procedures related to the disability programs. The two entities 

would monitor service delivery, customer satisfaction, and beneficiary marketing and 

education related to employment. 

The “business case” for including beneficiaries in the work of SSA to facilitate employment 

and economic self-sufficiency for disability beneficiaries can be drawn from the private 

sector. Private industry routinely seeks direct input from the public in order to create 

marketable products or services. 

 

Before arriving at this recommendation, the Panel reviewed the way in which SSA currently 

makes policy, addresses individual complaints and cases, and receives feedback from 

beneficiaries. Panel members met with SSA staff and visited a teleservice center and several 

field offices across the country to learn how they currently address the employment needs of 

beneficiaries.104 The Panel learned first-hand why the current system needs improvement. 

In these discussions, Panel members perceived that managers and employees saw the 

provision of employment-related services as the responsibility of other entities, such as VR 

agencies and WIPA projects. Panel members learned that SSA gives an office credit for 

countable activities (filing claims for benefits) but does not give credit for spending time 

educating a beneficiary about employment and work incentives. Generally, activities that get 

counted are the activities that employees in the field offices focus on performing. It is clear 

from the number of beneficiaries participating in employment that these services, while 

technically available from a field office, are underutilized and could be better coordinated, 

marketed, and provided to beneficiaries. 

With regard to customer satisfaction, teleservice callers are routinely surveyed by SSA, but 

information regarding return to work is scarce. Field offices rely on customer comment 

cards, proactively submitted by beneficiaries. The data are kept at the office level, and Panel 

members heard of no effort to aggregate or analyze the feedback received via the cards. The 

Panel expects that the Council and the Advocate would monitor and provide 
Final Report to the President and Congress 54 

54 

recommendations regarding two issues: 1) the provision of accurate information and the 

treatment of employment issues by field offices, and 2) the improved, coordinated collection 

and analysis of customer satisfaction data at the local level. 

SSA’s Office of Public Inquiry (OPI) is responsible for front-line data collection regarding 

feedback from the public. In addition, OPI answers the public’s questions and performs 

casework on behalf of beneficiaries. However, the office does not solicit feedback, and 

there is no apparent linkage between the volume and content of the requests received and 

SSA’s marketing, policy-making, or program development. 

The SSA Office of Quality Performance (OQP) designs and executes proactive consumer 

satisfaction surveys for both call center and field office contacts. These surveys provide the 

agency with valuable snapshots of how satisfied the overall SSA customer base is at a given 

point. However, because beneficiaries participating in return to work activities account for 

such a tiny subset of all SSA customers, OQP has not studied their satisfaction with those 

services. 

Beneficiaries who are dissatisfied with the employment service they receive can request the 

assistance of the PABSS. It should be noted that PABSS programs perform a valuable 

function in this process; however, as outside entities, their ability to influence SSA’s 

approach to overall beneficiary employment is limited. 

Finally, SSA does have an existing process for receiving public comment when proposed 

regulations are published. The Panel’s proposal is not designed to replace this vital part of 

the regulatory process. Unfortunately, the pubic comment process is not user-friendly, is 

limited to proposed regulations, and is mainly utilized by the stakeholders who already have 

a voice in the work of SSA. In addition, the regulatory process is focused on SSA priorities, 

not necessarily those of beneficiaries. The Panel believes that beneficiary input at the front 

end of regulatory or policy development would improve the final product. 

The Panel is recommending creation of a Council and Advocate to enhance the work of 

SSA. In addition to identifying problems, they would be an active part of finding solutions. 

The structure and functions proposed for the Council and the Advocate are similar to a 

model that exists within the IRS. In the 1990s, Congress determined that the IRS was not 

sufficiently accountable to taxpayers, so they created an Office of the National Taxpayer 

Advocate (NTA) and a Taxpayer Advocacy Panel. The NTA exists to represent the interests 

of taxpayers in the work of the IRS. It performs a vital function to build the public’s trust 

and to act as an independent liaison between taxpayers and the IRS. In addition, NTA staff 

works side by side with IRS employees solving problems and offering support to the IRS 

mission. The same could be done for SSA via this proposal. 
Final Report to the President and Congress 55 

55 

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

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

design within SSA. 

2. After years of redesign and re-engineering, SSA’s disability claims processing 

and return to work programs are still problematic for individuals attempting to 

use them. 

3. There is no coordinating entity within SSA that aggregates, analyzes and 

utilizes the disability beneficiary feedback that the agency currently receives. 

Staffing and Structure 

The Council would be made up of current or recent beneficiaries of SSI and SSDI. Council 

terms should be staggered to ensure continuity and members would be selected along a time 

continuum, so that the interests of new beneficiaries (recent applicants), long-term 

beneficiaries, beneficiaries attempting work, and those transitioning off of benefits into the 

workforce are represented. At least one Council member should be an individual who 

requires the assistance of a representative payee or similar support person in order to 

participate on the Council. Council members would be appointed by the President and 

Congress. 

Selection criteria for Council members should be structured to achieve representation from 

the broadest possible range of socioeconomic, cultural, ethnic, racial, geographic, and 

disability backgrounds. The Council should represent beneficiaries from all walks of life, and 

Council members who are employed should represent the broad spectrum of jobs that exist 

in our economy, including service, technology, and manufacturing. In order to be an 

effective voice, the Council will need staff support and its members should be paid. The 

Council’s work could be supported through the Office of the National Disability Beneficiary 

Work Advocate. 

The Advocate would be a current or former beneficiary not employed by SSA for two years 

prior and five years after being appointed as the Advocate. Qualified candidates must have 

demonstrated experience advocating on behalf of individuals with disabilities to agencies like 

SSA, HHS, VR agencies, and state human service agencies. The appointment of the 

Advocate would begin with the Council’s identification of several qualified candidates. To 

ensure independence, the “short list” of Advocate candidates would be provided to the 

President who would appoint the Advocate for a six-year term, subject to Congressional 

consent. Only the President would have the authority to remove the Advocate. Within SSA, 

the Advocate would report directly to the Commissioner and to Congress. 

The Advocate would have staff from SSA’s headquarters to enable the individual to interact 

with the rest of SSA. Unlike the Advocate, the staff could be drawn in whole or part from 

current SSA employees. In addition to a headquarters presence, the advocate would have 
Final Report to the President and Congress 56 

56 

one staff representative in each SSA regional office to conduct regular outreach to 

beneficiaries in their communities, as well as visits to SSA field offices. Current employees 

serving as AWICs or WILs in the field offices could perform this function. The purpose of 

the outreach and field office contact would be to identify emerging issues, challenges, and 

best practices. Regional staff advocates should be individuals with disabilities. 

Joint functions of the Council and Advocate include: 

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

work of SSA. 

2. Supplement existing SSA research by conducting outreach and soliciting 

comments and recommendations from beneficiaries who represent 

geographic, cultural, ethnic, vocational, and socioeconomic diversity, as well as 

all age groups and disability types. Such outreach should include the planning 

and execution of a biennial beneficiary summit that includes diverse 

beneficiary representation. 

3. Provide a joint written report annually to Congress and the Commissioner of 

SSA that identifies the systemic problems that have emerged through the work 

of the Advocate and Council, as well as recommendations that offer solutions. 

Functions of the Council would include: 

1. Identify highly qualified candidates as possible Advocate appointments. 

2. Receive direct testimony from beneficiaries nationwide through public 

meetings and hearings. 

3. Provide unfiltered feedback and recommendations to the Advocate regarding 

systemic issues that emerge through such contact with beneficiaries. 

4. Meet annually with the Commissioner of SSA to inform the Commissioner of 

the systemic issues and feedback the Council has received. 

Functions of the Advocate would include: 

1. Assist in the development and/or review of SSA policies, procedures and 

marketing and training materials (for the public and service providers) related 

to employment. This assistance would focus on relevancy for the end user, 

accessibility, and assurance that documents are understandable and culturally 

appropriate. 

2. Facilitate intra- and inter-departmental program coordination, as it relates to 

effectively serving individuals with disabilities who want to work. The Office 

of the Actuary and CMS are good examples of the organizations with which 

the Panel envisions the Advocate interfacing. 
Final Report to the President and Congress 57 

57 

3. Identify, prioritize and advocate solutions to systemic problems impacting 

large numbers of beneficiaries, using data collected by the Council, the 

Advocate, SSA’s Office of Public Inquiry and Office of Quality Performance 

and Office of Disability and Income Support Programs, PABSS, and other 

relevant programs. 

4. Identify possible legislative and administrative actions to problems identified, 

and, whenever possible, cost savings or offsets. 

5. Make recommendations for additions or changes to SSA’s management 

information systems to better track internal issues affecting beneficiaries, 

particularly those working or trying to go to work. 

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

beneficiaries. 

7. Present an interim annual report to Congress and the Commissioner, in 

addition to the joint report with the Council, which provides an update on the 

status of systemic issues and recommendations identified in the joint report. 

Both the joint report and the Advocate’s status report should contain full and 

substantive analysis, including statistical information; steps taken by the 

Advocate to improve beneficiary services as well as SSA responsiveness; a 

summary of the most serious problems encountered by beneficiaries as well as 

recommendations for administrative and legislative action to resolve 

beneficiaries’ problems; and other information as needed. 

The Panel understands that resources are limited at SSA and across government programs. 

The same could be said about the IRS, yet Congress, in its wisdom, decided to invest in the 

NTA to make taxpayers more willing to pay their taxes and better able to comply with 

complex rules and regulations. In much the same way that the IRS benefits from the NTA, 

the Council and the Advocate will substantially improve SSA’s customer service, create 

operational efficiencies and, for those who choose employment, reduce beneficiaries’ 

reliance on cash benefits. 

“I want to own my own business and make...money. This will not be 

easy, but I know it’s possible if I get the supports I need so I can work and 

have a good life.” 

Joseph Benito 

Delegate from Florida 

Beneficiary Summit 

Atlanta, Georgia 

February, 2007 
Final Report to the President and Congress 58 

58 

Optimize Current Work Incentives through Short-Term and 

Incremental Policy Improvements

 

A fundamental objective of the Act was to create new choices for beneficiaries in the 

assistance and support available through ENs. The revised final Ticket to Work regulations 

might expand such choices even further, but they will not be published until next year, well 

after the Panel ceases to exist. For this reason, the Panel suggests the following short-term 

improvements, outreach and ongoing oversight to build on current Ticket to Work program 

outcomes and improve the lives of more beneficiaries. 

As a first step, we must improve SSA’s current administrative funding shortfalls. As 

discussed earlier, SSI redeterminations and CDRs represent two of SSA’s main efforts 

towards processing the information affecting a beneficiary’s benefits or eligibility in a timely 

manner and helping to prevent and detect improper payments. SSI redeterminations yield a 

savings of $7 for every $1 spent in administering them, and CDRs in the SSDI program save 

$10 in program benefits for every $1 spent. Due to funding limitations, SSA has had to cut 

back on SSI redeterminations and CDRs. This demonstrates that, without enhanced funding, 

SSA will find it difficult, if not impossible, to perform tasks beyond its core functions. 

Insufficient funding for SSA to administer the SSDI/SSI programs effectively has been welldocumented for a decade. Budget constraints, staff reductions and a continuing list of new 

responsibilities have now taken a toll. The agency is facing increasingly difficult decisions as 

it seeks to balance its traditional workloads with its growing responsibilities that are outside 

its core mission, for example, workloads in support of the New Medicare prescription drug 

program and verifications of immigration status. 

The Panel understands that SSA has done much to employ scarce resources efficiently and 

increase overall productivity. Even with significant improvements, however, there is a 

growing concern as expressed in recent Congressional hearings and in the media about the 

detrimental effect on service delivery of years of inadequate funding, staffing declines and 

rising workloads. 

 

The SSAB has over the years highlighted the need for increased resources for SSA. In its 

August 1998 report, the SSAB made several references to the need for more adequate 

resources.105 Every year since then, the SSAB has issued one or more reports or other 

statements pointing out the need for additional funding, and has issued some 21 different 

reports and statements along these lines during the past 9 years.106 

 

The Panel understands that the House and Senate appropriations committees have agreed to 

provide SSA with nearly $10 billion for operations in fiscal year 2008. (Although this may be 

a large amount compared to funding for other discretionary programs, SSA's administrative 

budget represents less than 2 percent of SSA's total benefit outlays.) 

 
Final Report to the President and Congress 59 

59 

If approved, the nearly $10 billion might be enough to make some improvements for the 

short term, but is unlikely be enough to effectively administer what is in reality a new Ticket 

to Work program, develop/implement program modifications to better serve beneficiaries 

who are able to work, and keep up with post-entitlement work that includes SSDI/SSI 

overpayments. 

During a 2003 hearing before the House Ways and Means Social Security Subcommittee, 

former Commissioner Barnhart highlighted SSA’s challenges keeping track of earnings, 

preventing large overpayments and resolving them promptly when they do occur. 

Unfortunately, the Panel has heard from numerous beneficiaries who have willingly reported 

the required information to SSA in a timely way and have still received unexpected letters 

from the agency demanding repayment of thousands of dollars in overpayments that have 

occurred over a long period of time in one or both programs. 

 

The Panel expressed its concern about wage reporting, overpayments and return to work in 

its 2001 Annual Report and again in its Year 3 report. The Panel expressed its misgivings 

that SSA's long-standing problems with overpayments will be exacerbated under the Ticket 

to Work program as increasing numbers of beneficiaries start or return to work. The Panel 

is aware that a 2003 pilot telephone wage reporting system for SSI beneficiaries offers a 

glimmer of hope; however, it is unlikely to be fully implemented when the enhanced final 

Ticket to Work regulations are published. The Panel continues to be troubled that, with 

inadequate resources, SSA may be unable to get beneficiary earnings posted to accounts 

timely, appropriately verify the amounts reported, or to make the needed adjustments in 

benefits. Overpayments create a disincentive for SSDI, SSI and concurrent beneficiaries to 

work and also for ENs to participate in the Ticket to Work program. 

Recommendation 2: Congress should appropriate the funds necessary for the Social 

Security Administration to support effective service delivery, particularly related to the Ticket 

to Work program and return-to-work, such as work report processing and overpayments. 

 

The principle of self-determination values choice and control as individuals with significant 

disabilities make decisions about employment and advancing economic independence. A 

fundamental framework of the Act was to create new choices for beneficiaries in the 

assistance and support to be available through ENs. As discussed above in Section 1, in an 

effort to create new choices, SSA published an NPRM on September 30, 2005, 

“Amendments to the Ticket to Work and Self-Sufficiency Program.” The Panel submitted 

comments to SSA supporting the revised regulations, acknowledging that SSA had accepted 

many of the Panel’s recommendations for improving the program and emphasizing that 

these changes should revitalize the program, stimulate the growth of ENs and greatly 

increase the level of participation of Ticket holders.107 

Unfortunately, for a variety of reasons, these regulations are not expected to be published 

until the spring of 2008. On numerous occasions, the Panel has urged SSA to publish the 

final revised Ticket to Work regulations expeditiously. On September 28, 2006, the one-year 
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60 

anniversary of the publication of the proposed amendments, the Panel sent a letter to the 

Commissioner of SSA emphasizing the importance of issuing the final regulations. 108 

The September 2005 NPRM identified but did not address “Ticket in Use” by beneficiaries 

in higher education and the suspension for a time-limited period of required CDR. The 

Administrative Procedures Act mandated a period of public comment on changes regarding 

the “Ticket in Use,” and SSA delayed the publication of the revised final regulations to 

address this issue. On November 30, 2006, the Panel urged SSA to reconsider the decision 

to delay release of the final Ticket to Work regulations and that SSA address the “Ticket in 

Use” as a separate issue.109 SSA did not accept this recommendation and published an 

NPRM addressing “Ticket in Use” on August 13, 2007, “Amendments to the Ticket to 

Work and Self-Sufficiency Program (Volume 72, Number 155).” On October 5, 2007, the 

Panel submitted comments on this NPRM.110 

The broader revised final regulations address critical deterrents to the participation of ENs 

in the Ticket to Work program. The Panel is gravely concerned that not having the revised 

final regulations published yet is severely dampening the enthusiasm of EN participation. 

Without a reenergized pool of providers to choose from, the Ticket to Work program 

remains a hollow promise for thousands of beneficiaries with disabilities who could be 

moving toward becoming economically self-sufficient. 

The Panel hopes that Congress will continue to monitor program implementation and that 

beneficiaries and other relevant stakeholders will continue to suggest further program 

improvements. 

Recommendation 3: The Social Security Administration should publish revised final 

regulations pertaining to the Ticket to Work program (September 2005 Notice of Proposed 

Rule Making) no later than April 1, 2008. 

Coupled with publication of the revised final Ticket to Work regulations, SSA needs to 

implement an effective marketing plan for the enhanced program, as well as work incentive 

provisions. 

Participation in the Ticket to Work program, by both ENs and beneficiaries has been a 

concern since implementation began. Following its EN Summit in May 2004, the Panel 

issued a report that stated, “Thousands of people with disabilities and their advocates shared 

a dream that the ...Act would greatly expand employment opportunities for people on the 

Social Security Administration (SSA) disability rolls. Three years after enactment of the law, 

it is clear that their dream is faltering.”111 Recommendations from that summit are reflected 

in the proposed Ticket to Work regulations of September 2005, hence the Panel’s strong 

support for their full implementation. However, while the regulations are crucial to 

increasing the participation of both ENs and beneficiaries, even those improvements will 

not have the desired impact unless they are accompanied by a coordinated, tested marketing 
Final Report to the President and Congress 61 

61 

strategy. The EN summit report discussed elements of such an approach,112 and the Panel 

continues its call for effective marketing of the program.113 

This marketing plan needs to be informed by evidence-based best practices, the results of 

the Ticket to Work program evaluation, as well as previously reported Panel 

recommendations. The effective implementation of this plan is critical to the future success 

of SSA’s comprehensive return-to-work initiative. 

 

To date, the Panel has received partial information about the Agency’s progress developing 

the marketing plan. The roll-out of the Agency's marketing plan should correspond with the 

release of the final regulations. 

Recommendation 4: The Social Security Administration should plan for and (upon 

promulgation of the revised final regulations pertaining to the Ticket to Work program 

(September 2005 Notice of Proposed Rulemaking), immediately implement a marketing 

plan for beneficiaries and Employment Networks that is informed by evidence-based best 

practices, the results of the Ticket to Work program evaluation, as well as previously 

reported Panel recommendations. 

Implementation of Medicaid Buy-In programs continues to expand as additional states are 

moving forward with legislative approval to establish new programs. MIGs continue to 

promote linkages between Medicaid and other employment-related service agencies and to 

enable design and implementation of innovative approaches to support individuals with 

disabilities in ways that advance their employment and economic status. The MIG program 

will end in 2011 unless reauthorized by Congress. 

More needs to be learned about Medicaid Buy-In implementation and state differences in 

eligibility and cost-sharing requirements. The MIGs should continue to provide learning 

laboratories that respond to beneficiary needs to become a part of the economic mainstream 

by promoting linkages between Medicaid and other related services agencies. 

Recommendation 5: Congress should extend the Medicaid Infrastructure Grant and 

Demonstration to Maintain Independence and Employment program authority through 

2014 to stimulate innovation by states seeking to refine comprehensive systems of 

employment supports for people with disabilities. 

SSA’s authority to begin new demonstration projects ended on December 18, 2005. All 

projects initiated before December 17, 2005 can continue, and SSA currently has several 

projects underway, including the Mental Health Treatment Study, the Benefit Offset 

Demonstrations, and the Youth Transition Demonstration. 

Findings from these and other ongoing projects can help inform SSA about which 

employment supports, work incentives, health benefit packages, etc. are necessary for 

moving Social Security beneficiaries toward self-sufficiency through employment. 
Final Report to the President and Congress 62 

62 

Unfortunately, progress in beginning these demonstrations and moving toward researchbased findings has often been stalled. GAO cited this concern in a November 2004 report 

that was critical of SSA’s processes for planning and conducting demonstrations.

114 

The Panel urges Congress to renew SSA’s demonstration authority with greater 

Congressional oversight. In addition, Congress should require that CMS and SSA work to 

coordinate their demonstration activities. 

Recommendation 6: Congress should renew, with greater Congressional oversight, the 

Social Security Administration’s demonstration authority to design and evaluate additional 

strategies that overcome multiple barriers to employment and support economic self-sufficiency 

for individuals with significant disabilities and place urgency on getting the demonstrations 

done. 

 

The testimony of many individual beneficiaries and the beneficiary summit stressed that 

current SSI rules impose a significant “marriage penalty” that prevents many recipients from 

getting married. In 2002, SSA data were matched with that of the Survey of Income and 

Program Participation. It was found that the poverty rate of SSI recipients living alone is 78 

percent, and the rate for two married recipients is 45.1 percent. This contrasts with the 

poverty rate for two SSI recipients who live together but are not married. That rate is 9.8 

percent..115

SSA has studied the impact of marriage on SSI recipients, most recently in an issue paper 

published in December 2003. The report examined options for greater equity between 

married and unmarried recipients living together. Those options could be grouped into two 

broad areas: benefit rates or income exclusions and deeming. 

It is important to note that establishing parity between the treatment of married and 

unmarried recipients does not necessarily hold all recipients harmless, particularly when it 

comes to cash benefits. The benefit rate option with the largest program cost increase 

would eliminate the couple rate under SSI and pay the benefit rate for individuals to both 

spouses. However, two other options under the benefit rate category would actually reduce 

the benefit amount for some SSI recipients.116

The income exclusion and deeming options appeared to have a greater impact on couples 

where only one spouse is an SSI recipient. In addition, it appears that some of the income 

exclusion/deeming options have a smaller impact in terms of program costs. Unfortunately, 

those options are likely to make the program more complex at the same time.117

The Panel hopes that SSA will continue to examine these issues and that Congress will 

attempt to equalize treatment of SSI beneficiaries, whether married or not, in the same way 

that it removed financial disincentives to marriage for all Americans via the tax code.118 Since 

attachment to health care and long term services and supports was the primary concern that 

most summit delegates cited about getting married, the Panel recommends an interim 
Final Report to the President and Congress 63 

63 

measure that would provide states with the opportunity to remove the disparity at least in 

terms of Medicaid access. In addition to the Panel, the NCD also recommended eliminating 

the “marriage penalty” in its testimony to Congress in February 2007.119

Recommendation 7: Congress should provide states flexibility in devising Medicaid 

programs to reduce the marriage penalty for persons with disabilities. 

SSA’s Ticket to Work regulations, both existing and proposed, are partly designed to 

incentivize participation by ENs. Many unique entities, such as private employers and onestop career centers, have stepped forward to serve as ENs, and the Panel is supportive of 

such innovations. To that end, the nation’s independent living centers (ILCs) are wellpositioned to join the EN/SSA/beneficiary partnership. 

ILCs have played a pivotal role in the empowerment of people with disabilities and their 

inclusion in the community. The ILC foundation is embedded in consumer control over the 

management and delivery of services. All ILCs provide the core services of individual and 

systems advocacy, information and referral, peer support, and independent living skills 

training. These services are the demonstration of the ILC philosophy of self-direction and 

independence. 

 

ILCs, as consumer organizations, can assist beneficiaries in their efforts to achieve economic 

self-sufficiency. The staff members at these centers understand first-hand the barriers to 

employment, since many are former beneficiaries. It is that personal connection which 

places them in a unique position to offer peer support and skills training necessary for 

building confidence and informed choice. 

ILCs are well-positioned to become ENs. However, their mission and services are broadly 

directed at independence, inclusion and civil rights. Consequently, their staff lacks the 

specific skills and training necessary to assist in job development and placement. In order to 

participate as ENs, ILCs would need additional financial support to secure staff equipped to 

provide these services and other upfront costs. SSA has an EN Capitalization Education 

Program which would be beneficial to ILCs becoming ENs. The purpose of this program is 

to enable more organizations to participate in the Ticket to Work program as ENs by 

increasing access to funding sources that can support upfront costs of providing 

employment and support services. This program has four target segments of the disability 

and workforce development communities. The Panel proposes that ILCs be added as a 

target segment. By doing so, this will expand the options beneficiaries can access for needed 

services and supports to obtain, regain, or maintain employment. 

Recommendation 8: The Social Security Administration should identify business 

models for investing in independent living centers as Employment Networks. 
Final Report to the President and Congress 64 

64 

Update, Simplify and Educate: Improve Beneficiaries’ Experiences 

with Work Incentives

Our nation’s largest disability programs can be helped in the immediate term by creating the 

conditions and a policy environment that would better support work beyond the outcomes 

currently achieved with the underutilization of existing work incentives. The 

recommendations contained in the Panel’s work incentive utilization report, UPDATE, 

SIMPLIFY, AND EDUCATE: A National Call to Optimize Incentives to Work, are intended to 

be incremental and achievable in the short term. The Panel believes these recommendations 

will lay the foundation for the proposed modernization activities and systems changes more 

applicable to employment supports needed in the long run. 

The recommended short-term actions are divided into three primary categories: 

1. UPDATING existing work incentives to make them more applicable to the 

realities and employment support needs of beneficiaries in 2007 and beyond. 

This should include improving existing work incentives and ensuring that they 

accommodate the dynamic nature of disability while assuring access to health 

care as work incentives are utilized. 

2. SIMPLIFYING the maze of work incentives programs that exist not only 

within SSA but in other federal benefit programs so that those programs 

mutually support a common work agenda and make work pay, while at the 

same time reducing the risk of overpayments for beneficiaries and other 

unintended adverse program interactions. 

3. EDUCATING and equipping the array of stakeholders involved in the return 

to work process so that it is multi-pronged, focused on ensuring that 

beneficiaries interested in going to work have access to customized, 

responsive, timely, relevant and accurate information and services to support 

their efforts. The stakeholders that need to be included in order for work 

incentive provisions to be effective include: SSA field personnel, ENs and 

other community providers, educators, and beneficiaries. Education should 

include increasing the awareness of beneficiaries regarding work incentives 

through information dissemination, expanded outreach, and increased 

numbers of work incentive practitioners available and providing ongoing 

training of SSA personnel. It should also include putting in place systems to 

inform SSA regarding return-to-work efforts by improving the collection, 

organization and use of data about work incentive utilization for decision 

making. 
Final Report to the President and Congress 65 

65 

UPDATE Existing Work Incentives 

Improve existing work incentives and ensure that they accommodate the dynamic nature of 

disability while assuring access to health care as work incentives are utilized. 

Update Impairment Related Work Expenses 

IRWE applies to both SSDI and SSI beneficiaries. However, under the SSI program the 

reimbursement for expenses paid for by the beneficiary only allows for up to a 50 percent 

cost recovery – not dollar for dollar with work expenses such as BWEs or PASS. This poses 

a considerable barrier to work for those beneficiaries starting their work efforts in entry-level 

positions that do not provide adequate income to offset the loss of income associated with 

paying for these work-related expenses and the potential loss of SSI cash benefits resulting 

from earnings. This is important to beneficiaries trying to survive on limited income. 

Recommendation 9: The Social Security Administration should change the order in 

which impairment-related work expenses are deducted when calculating the Supplemental 

Security Income cash payment to allow for up to a 100 percent cost recovery.120

While the definition of IRWE is the same regardless of the program, items and/or services 

can be allowed as IRWE even if they are also needed for normal daily activities. However, 

the cost of routine drugs and routine medical services, such as a yearly physical, are not 

deductible unless they are needed to control the impairment and enable the person to work. 

The cost of health insurance premiums is listed in the Program Operations Manual System 

as a “non-deductible” item.121 One could argue that because Medicare is only available to 

individuals who have a disability (or are retired), the premium cost should be recognized as 

an impairment related expense and necessary for work. Certain individuals will purchase 

supplemental coverage due to co-insurance or deductibles. 

Recommendation 10: The Social Security Administration should allow health 

insurance premiums to be used as impairment-related work expenses, when the beneficiary 

can document that the coverage is disability-related and supports work. 

The assistance of family members in providing transportation to and from work and 

attendant care services is essential. Delegates to the beneficiary summit selected “Support 

family caregivers who provide personal assistant and other services” as one of their key 

recommendations. Many beneficiaries rely on family members to drive them to and from 

work because they are unable to drive themselves, cannot afford a car, public transportation 

is not available, and/or they are unable to take public transportation due to their disability. 

They also rely on family members to provide attendant care services because other providers 

are difficult to find and often are unreliable. If a person with a disability pays a family 

member to perform attendant care services, the payment will generally not be deductible as 
Final Report to the President and Congress 66 

66 

an IRWE unless it is established that the family member has been “otherwise employed and 

suffers economic loss by reducing the number of work hours or terminating his or her own 

employment in order to perform such service.”122 This is the case even though, at age 18, 

parents no longer have a legal responsible to care for their son or daughter unless there is a 

court decision. 

Recommendation 11: The Social Security Administration should eliminate the 

condition that family members must suffer financial loss for their compensation by the 

beneficiary to count as impairment-related work expenses if they provide attendant care 

and/or transportation to/from work to a person with a disability. 

Update Income Exclusions 

The four key income exclusions are: $65 earned income, $20 general income, $30 

infrequent/irregular earned income, and $60 infrequent/irregular unearned income; in 

addition, there is a $2000/$3000 resource limit. These amounts were not indexed when the 

SSI was enacted in 1972 and have not changed despite the 1996 Disability Advisory Panel’s 

call to action regarding the annual indexing of all work incentives. “Raise the SSI resource 

limit to today’s dollars” was a key recommendation of the delegates to the beneficiary 

summit. 

In March 2000, an SSA report on SSI exclusions mandated by the Act included a range of 

detailed options for updating the dollar amounts and the estimated costs.123 In a recent 

statement, the SSAB calculated that if the earned income and the general income exclusions 

had kept pace with inflation, they would exceed $90 and $290 per month, allowing disabled 

beneficiaries to earn up to $380 per month without reducing their benefits.124 The upcoming 

increase in minimum wage means that beneficiaries will be able to work even fewer hours 

before impacting their benefits. The Panel recognizes, as did the SSAB that changes could be 

expensive and it is impossible to predict what the effect and costs would be of interacting 

with one another, as well as how they would affect other SSI provisions and related 

programs such as Medicaid and state supplementation. Nevertheless, the current exclusions 

are failing to meet congressional intent because of their significantly reduced value. 

Currently, for example, $65 earned income exclusion is worth less than $15; $20 general 

income exclusion is worth less than $5; and $3000 resource limit is worth less than $400 

value. 

Recommendation 12: Congress should increase and index the key income exclusion 

amounts and the resource limits under the Supplemental Security Income program. 

Update PASS and the Ticket to Work Program 

Disincentives for use of PASS can be found in existing policies that regulate the interaction 

of PASS and rehabilitation programs. PASS could be used to supplement the Ticket to 
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67 

Work program by providing the initial investment in employment supports, which the ticket 

payments can then maintain. Under current policies, an EN cannot receive a ticket 

outcome-only payment while the individual is receiving an SSI cash payment resulting from 

an active PASS. This creates a disincentive for ENs to support PASS use. Also, PASS 

funds cannot be used to pay an EN for services. 

Recommendation 13: The Social Security Administration should approve proposed 

rule changes to the Ticket to Work program to enable Employment Networks to receive 

ticket outcome-only payments while a beneficiary is receiving an Supplemental Security 

Income cash payment resulting from an active Plan for Achieving Self-Support. 

Update the Traditional Cost Reimbursement Program 

The Traditional Cost Reimbursement Program administered by SSA with VR agencies is 

based on sustained individual participant gross earnings over SGA.125 While utilization of 

most work incentives do not count against the agency seeking reimbursement, two specific 

incentives can impact an agency receiving their reimbursement if the programs are used by 

the beneficiary: BWE and PASS. These are work incentives excluded by the SSA under 

current procedures as they are not impairment-related. The use of either of these incentives 

negatively impacts the ability of VR agencies to claim reimbursement because earnings often 

fall below SGA once BWE and PASS have been accounted for. The unintended negative 

consequence is that the policy provides a disincentive to VR service providers in promoting 

use of BWE and PASS because their claim for reimbursement may be disallowed. 

Recommendation 14: The Social Security Administration should allow state 

vocational rehabilitation agencies to receive traditional cost reimbursement if and when an 

individual is receiving an Supplemental Security Income cash payment resulting from an 

active Plan for Achieving Self-Support or claim of Blind Work Expenses. 

SIMPLIFY Existing Work Incentives 

The myriad of work incentives programs that exist not only within SSA but also within other 

federal benefit programs are complex, difficult to understand, challenging to manage and do 

not appear to support a common, universal approach to work. Beneficiaries may understand 

and know how to use the work incentives, but other disincentives keep them from 

working.126 

Align Existing Work Incentives 

The two general types of governmental programs concerning disability are employment 

support and income support. When the term “benefits” is mentioned, many assume the 

reference is to either the SSDI or SSI programs administered by SSA. Although these two 

SSA programs are the primary public disability support programs in this country, the scope 
Final Report to the President and Congress 68 

68 

and complexity of the broader benefits circumstances for individuals with disabilities 

frequently extends beyond Social Security. Other equally important income support and 

employment support programs that provide benefits to individuals with disabilities include, 

but are not limited to Housing and Urban Development (HUD), Temporary Assistance for 

Needy Families, Veterans’ Benefits, Worker’s Compensation, Unemployment Insurance, 

Food Stamps, Energy Assistance, and programs operating under the authority and funding 

connected with the Workforce Investment Act. Adding to the complexity is that most 

programs are fully or partially funded with federal resources; however, many are 

administered at the state or local level. 

The interplay between employment earnings and public benefit programs is very 

individualized. Although both programmatic constraints and work incentives within public 

programs are consistently available to participants, the multiplicity and diversity of program 

participation make the issue complex. In other words, no two beneficiary or recipient 

situations are the same. The work incentive provisions in one program may be generous, 

while they may be limited in another, which unintentionally negates the potential of the work 

incentives available in the first program. 

There are two primary ways that work incentives can be simplified. First, SSA should 

conduct a careful review of their existing work incentives and develop legislative proposals 

to remove the complexity.127 As discussed earlier, the dollar amounts governing specific 

incentives vary greatly. For example, the SGA and TWP amounts are different. Simply 

adjusting and aligning existing work incentives would go a long way toward simplifying and 

minimizing the amount of information beneficiaries need to maintain and manage as they 

attempt to go to work. Second, SSA and their federal partners who administer other meanstested entitlements should evaluate their existing work incentives and ensure that they all 

mutually and universally support a common work agenda. For example, a beneficiary who 

receives SSDI and is also residing in HUD-sponsored housing has specific complexities to 

manage when first attempting to work. When that individual decides to begin working they 

are entitled to a nine-month TWP during which there are no limits on their earning potential 

and impact on their cash benefit. In comparison, for HUD, the first 12 months of earnings 

are subject to 100 percent income exclusion and not counted against in the computation of 

their rent share. This requires the beneficiary to know in great depth how earnings are 

treated by each public entitlement or benefit they receive and they must track using different 

time tables the points at which their gross monthly income may be impacted. This is one 

example across two programs where the work incentives provided do not clearly align and 

support a universal work agenda. 

SSA and their other federal partners should consider how to streamline the work incentives 

and reduce their complexity. Making work incentives easier to understand will make it easier 

for beneficiaries to use them successfully in their path to work, as well as make them easier 

to administer. 
Final Report to the President and Congress 69 

69 

Recommendation 15: The Social Security Administration should reduce the 

complexity and improve the consistency of work incentives across the Supplemental Security 

Income and Social Security Disability Insurance programs and other federal entitlements so 

that they universally support work. 

Address Post-Entitlement Issues 

Existing work incentive provisions demonstrate a commitment by SSA to support the 

employment efforts of people with disabilities. The work incentives, however, also illustrate 

how complicated the issue of benefit levels and eligibility become when a disability 

beneficiary pursues employment and experiences changes in earned income. SSA recognizes 

that while many individuals may want to return to work, there are multiple barriers that may 

hinder employment. Work related overpayments are identified as one of these barriers..128, 129 

Overpayments are benefits that an SSI and/or SSDI beneficiary receives for which Social 

Security determines the beneficiary was not entitled. There are two primary reasons why an 

overpayment situation would occur in either program: beneficiaries do not report 

information affecting benefits or eligibility in a timely manner, and/or SSA does not process 

the information affecting a beneficiary’s benefits or eligibility in a timely manner.130 

Overpayments, or the risk of experiencing an overpayment, can affect a beneficiary’s 

decision to go to work, or the decision to continue working. 

SSI redeterminations and CDRs represent two of SSA’s main efforts towards processing the 

information affecting a beneficiary’s benefits or eligibility in a timely manner and helping to 

prevent and detect improper payments. 

Recommendation 16: The Social Security Administration should establish 

mechanisms to monitor post-entitlement workloads, develop performance standards (similar 

to those established for initial claims in terms of processing time and decisional accuracy), 

and Congress should allocate sufficient resources to address post-entitlement workloads. 

Recommendation 17: The Social Security Administration should establish a crosscomponent internal Social Security Administration Task Force on post-entitlement 

workload issues to identify resources needed to perform critical program integrity activities 

that address post-entitlement workloads such as processing work reports and preventing and 

detecting overpayments. Publish these findings annually. 

Simplify Wage Reporting 

SSI recipients are required to report changes in their income, resources and living 

arrangements that may affect eligibility or payment amount. SSA conducted wage reporting 

pilots for workers at risk for wage-related overpayments to develop easier ways for recipients 

to report their wages in a timely manner. Through a pilot conducted in 2003 and again in 

2006, SSA is using telephone voice recognition/touchtone technology as a means to 
Final Report to the President and Congress 70 

70 

improve wage and income reporting by determining if, given an easily accessible automated 

format, individuals will increase compliance with reporting responsibilities. The initial SSI 

Monthly Wage Reporting Pilot131 was conducted in 2003. Evaluation of the pilot132, 133

determined that the telephonic wage reports were much more accurate than traditional 

reporting techniques, and the use of a system like this could prevent approximately $200 in 

annual SSI overpayments for every person who reported wages monthly. Further, it was 

estimated that if 10,000 beneficiaries participated, $2 million in overpayments would be 

prevented per year. This pilot required a password authentication process, which half of the 

participants found difficult to use. As a result, SSA made software changes and in January 

2006134, 135, 136 began a new telephone wage reporting pilot using a knowledge-based 

authentication process. No data on the impact of the new pilot was found. In SSA’s FY 

2008 budget,137 reference is made to “expanded telephone wage reporting” as one way that 

SSA is developing easier ways for SSI recipients to report their wages. 

Recommendation 18: The Social Security Administration should continue to expand 

systems for reporting wages electronically, ensuring that concurrent beneficiaries have a single 

point of earnings reporting and that timely receipts are sent to all beneficiaries.138 

EDUCATE Beneficiaries and their Supporters Regarding Work and Use of 

Work Incentives 

There are a myriad of stakeholders who interact with and support the return to work 

process—including the beneficiary, their family members, service providers, and other 

entities. Going to work is a multi-pronged process that should be focused on ensuring that 

beneficiaries interested in going to work have access to customized, responsive, timely, 

relevant and accurate information and services, including assistive technology, to support 

their efforts. These efforts need to include SSA field personnel, ENs and other community 

providers, educators, and beneficiaries to effectively use work incentive provisions. 

Emphasis should be placed not only on continuing to increase the awareness of beneficiaries 

regarding work incentives, but also on educating families and service providers in supporting 

their use, and enabling SSA to effectively administer them and keep informed regarding the 

return to work efforts of beneficiaries through the collection, organization and use of data 

about work incentive utilization for decision making. 

Expand Current Work Incentives Marketing and Outreach 

SSA’s Strategic Plan for 2006-2011 recognizes the importance of increasing the awareness of 

beneficiaries of opportunities to achieve greater financial independence through 

employment. As part of the Strategic Plan and in support of the President’s New Freedom 

Initiative, SSA details three specific objectives: 1) provide improved marketing materials to 

beneficiaries with disabilities to increase awareness of the Ticket to Work program; 2) make 

beneficiary planning services more available and useable for beneficiaries to increase their 
Final Report to the President and Congress 71 

71 

awareness of return to work options; and 3) focus on the improvement and expansion of the 

agency’s partnerships with other public and private community-based organizations.139 Title 

I, subtitle C of the Act authorizes important strategies to inform, assist, and protect 

beneficiaries interested in pursuing work by establishing the BPAO program (currently 

known as the WIPA program), and the PABSS program. The Act also authorized that SSA 

create an internal corps of work incentive specialists. 

In the SSA Strategic Plan, there is no specific mention of the WIPA or PABSS programs as a 

method to ensure that individuals with disabilities who want to work have the opportunity to 

do so, or even to increase awareness of opportunities to achieve “greater financial 

independence through employment.” No measures are offered as to how SSA will track the 

level of achievement of these proposed long-term outcomes through internal staff capacity 

or external (WIPA and PABSS) program relationships. 

The challenges of marketing and outreach to beneficiaries to provide accurate, consistent 

information to enable beneficiaries to make informed decisions about work and to attract a 

new level of interest in and use of available work incentives and supports are formidable. 

Challenges identified by diverse stakeholders include inadequate resource allocation to 

support either the internal infrastructure at SSA of AWICs or the external support systems 

of WIPA and PABSS programs, inadequate quality assurance mechanisms to continue to 

evaluate and improve timely and effective service delivery systems, and a continuing need to 

improve coordination and clarify complimentary roles and responsibilities among these 

specialists (AWICs, WILs, WIPA, and PABSS) and other relevant community partner 

agencies and organizations. 

The Act offers beneficiaries a new opportunity to access a variety of supports and work 

incentives that will change expectations about life long dependence on cash benefits for 

subsistence. Without a coordinated comprehensive outreach strategy that focuses not just 

on the Ticket to Work program but also on the range of work incentive options, millions of 

beneficiaries remain afraid to attempt to work and increase income. 

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

these challenges. 

Recommendation 19: The Social Security Administration and Congress should 

strengthen both the Work Incentives Planning and Assistance and Protection and Advocacy 

for Beneficiaries of Social Security networks by establishing performance standards, adjusting 

funding levels and resources to levels necessary to achieve the desired results, and investing in 

ongoing training and technical assistance that improves the accuracy of information and 

quality of services provided with particular attention to underserved populations and valued 

employment outcomes. 

Recommendation 20: The Social Security Administration should identify clear, 

objective performance standards and indicators to evaluate the activities and impact of Area 
Final Report to the President and Congress 72 

72 

Work Incentives Coordinators and Work Incentive Liaisons, and collect, analyze, 

document, and publish evidence annually (by Social Security region and system-wide) of 

customer satisfaction, improved employment outcomes, and advanced self-sufficiency. 

PASS was enacted by Congress as a part of the original SSI legislation. PASS is selfdetermined, and is one of a very few tools that can provide critical supports to assist 

individuals in achieving self-sufficiency. Despite the enormous potential of PASS, the desire 

of many individuals with disabilities to work, and several policy and legislative changes to the 

program, PASS is currently significantly underutilized. Figure 4 below shows the number of 

PASS applications nationally in December of each year, from 1990-2006.140 The number of 

PASS applications ranges from 2255 in 1990, to a high of 10,329 in 1994, to a low of 1045 in 

1999 in the aftermath of a 1996 GAO report and subsequent policy changes, to 1583 in 

2006. 

Through the work of the Adequacy of Incentives Advisory Group, several critical 

recommendations were provided in 2004141 to address disincentives and barriers in using 

PASS. These recommendations included: allowing for the use of PASS and ticket payments 

at the same time; providing outreach to targeted groups of beneficiaries who could benefit 

from the use of PASS and the ticket; partnering with vocational providers to promote PASS 

as an option; and partnering with traditional financial institutions to incorporate PASS as 

collateral or assist in financing. Enhancements needed for the PASS program were also 

identified as critical by delegates at the beneficiary summit. Beneficiaries recommended 

providing federal or state matching funds, allowing a successful PASS to continue after its 

scheduled end date by allowing it to be enhanced to work toward greater self-sufficiency and 

expand business opportunity, improving communication between the PASS cadre and the 

application (appeal/denial) process, increasing the number of trained PASS specialists 

available, increasing communication with youth about work incentives including PASS, and 

simplifying and streamlining the PASS application forms and process. 

Figure 4. PASS Utilization 

2255

3570

5847

8130

10329

4704

1998

1074 1045 1382 1600 1721 1705 1598 1582 1583

10322

0

2000

4000

6000

8000

0000

2000

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

1996 GAO Report

and Policy Changes

Ticket to Work

and BPAO
Final Report to the President and Congress 73 

73 

Current active approved PASS applications total 1,583 (December 2006), averaging 30 PASS 

applications per state, and outlying areas. Some PASS specialists and offices cover one state 

or one area of one state; other PASS specialists cover entire regions of states. There is 

currently no publicly available workload information on the number of PASS applications 

submitted and approved or on processing (wait) times. However, based on subjective 

experiences, there appears to be a wide variance in PASS office work load. Based on 

statistics presented earlier, PASS approvals vary widely. While SSA engaged in an active 

national training campaign for PASS specialists in the spring of 1996, it is not clear whether 

SSA continues with national level training. The Panel believes that PASS use would increase 

significantly with an enhanced focus on PASS outreach. 

Recommendation 21: The Social Security Administration should collect workload 

information on the number of Plan for Achieving Self-Support applications submitted and 

approved, including the processing (wait) time by state, and publish this information 

annually in Social Security Administration’s SSI Disabled Recipients Who Work report. 

SSA should provide high quality training and support, and fiscal resources for the effective 

administration and outreach of the Plan for Achieving Self-Support program. The Social 

Security Administration should recruit, develop, and support Plan for Achieving SelfSupport specialists (travel, technology, et al). 

Improve Management by Data Practices 

SSA should provide annual data reporting and analysis on SSDI work incentive utilization, 

including state-to-state variation similar to the annual data provided on the SSI program. 

This report should also include the experiences of Disabled Adult Children and concurrent 

SSI/SSDI beneficiaries. The Panel's understanding is that work incentive utilization 

information is being collected as earnings of SSDI beneficiaries are reported using e-Work. 

Analysis and reporting of work incentive utilization data will provide insight into the 

performance of the SSDI and SSI programs with regard to returning beneficiaries to work. 

This could provide SSA with a better understanding of how to support local AWICs in 

encouraging other SSA staff, CWICs, community agencies and beneficiaries to more fully 

utilize work incentives. 

Recommendation 22: The Social Security Administration should improve reporting of 

data and analysis pertaining to Social Security Disability Insurance (including Disabled 

Adult Children and concurrent Social Security Disability Insurance/Supplemental Security 

Income beneficiaries) and issue an annual report comparable to the Social Security 

Administration’s SSI Disabled Recipients Who Work report.

Recommendation 23: The Social Security Administration should establish a 

performance management and return to work tracking system, providing benchmarks for 

each state, and track utilization over time as part of a continuous quality improvement plan. 
Final Report to the President and Congress 74 

74 

Improve Beneficiary Communication 

With the addition of benefits and work incentive specialists, through first the BPAO and 

now the WIPA program,142 SSA has provided one way for SSI and SSDI beneficiaries to 

become more aware of the impact of work on their benefits. These projects represent a 

significant resource available to beneficiaries for information and guidance on work and 

disability benefit issues, which should include timely wage reporting and avoiding and 

dealing with overpayment problems. The WIPA network is limited, however, in their ability 

to provide the information necessary to ensure that all beneficiaries are aware of earnings 

reporting requirements. SSA should explore other approaches to expanding beneficiary 

understanding in this area. 

Recommendation 24: The Social Security Administration should increase beneficiary 

awareness of earnings reporting requirements including the waiver process for overpayments, 

and promote greater self-efficacy. 

The implementation of these recommendations will update and simplify existing work 

incentives and enable the investment of time and resources by SSA and other related 

community stakeholders to educate the target audience about their availability and use. 

Expanded opportunities and conditions for supporting work will be created and the target 

audience will be better educated to make informed decisions. For policy makers, it is an 

important place to start. However, these changes in program and policy design represent 

only partial solutions to positively impact employment and economic gains for current and 

future eligible individuals with significant disabilities. These short term recommendations 

represent one element of the modernization actions required to establish an urgently needed 

framework in line with 21st century expectations of beneficiaries and continued 

advancements in technology and service delivery approaches. 

Increase Economic Self-Sufficiency through Investment in Disability 

Program Modernization

“We want to get out there. We want to be part of the world. We want to 

make money. We want to be able to have families and support our 

children...We want to be able to tell our stories to other people, so the next 

person that they meet, they won’t be afraid to hire them.... We want the 

same thing that everybody else wants, which includes work...” 

Amber Carey 

Testimony at the Ticket to Work and Work Incentives 

Advisory Panel Quarterly Meeting 

Washington, DC 

November, 2006 
Final Report to the President and Congress 75 

75 

Work is a valued activity, both for individuals and society. Work fulfills the need of an 

individual to be productive, promotes independence, enhances self-esteem, and allows for 

participation in the mainstream of life in the United States.143 People with significant 

disabilities face multiple barriers to employment that make it difficult, if not impossible, to 

work or increase their work effort. Our nation has reached a critical juncture that demands 

modernization of disability programs for individuals with significant disabilities who want to 

work and increase their earnings. Further action is necessary to ensure that the goals of the 

ADA — equality of opportunity, full participation, independent living, and economic selfsufficiency — are supported by policies that have high expectations, receive adequate 

resources to achieve program objectives, and deliver increased positive outcomes. 

The Panel believes that incremental changes to the Ticket to Work program and Social 

Security work incentives, while vital in the short term, must be coupled with a deliberative 

modernization of disability programs. The Panel proposes that Congress and the 

Administration increase economic self-sufficiency through a long-term investment in an 

employment strategy for Americans with disabilities. Disability policy and programs must be 

modernized to: 

1. Eliminate barriers to work; 

2. Enable people with significant disabilities to reduce their dependency on cash 

benefit programs; and 

3. Empower Americans with disabilities to greatly improve their short and longterm financial independence and personal well-being. 

During the last 18 months, GAO, NCD, and the SSAB have made public reports of the 

urgent need for policy and procedure modifications by both Congress and SSA. All three 

reports identify complex obstacles to employment faced by beneficiaries and the need for 

“new approaches” and “new solutions.” The three federally mandated organizations 

independently analyzed the many legislative changes, program modifications, training 

initiatives, marketing and outreach efforts, and technological improvements in processing 

claims and wage records in the past 15 years to impact customer service and return-to-work 

outcomes. The findings indicate that these policy and process changes have not significantly 

improved program outcomes and that beneficiaries do not trust SSA to make appropriate 

and timely decisions. After spending sometimes years to convince SSA of the extent of their 

disability and their inability to work, most beneficiaries are confused by messages received 

from SSA that encourage return to work with the assistance of a variety of work incentives 

that are neither simple to understand nor to use. Each year, the Panel has listened to and 

learned from beneficiaries, who have echoed and confirmed the findings of these three 

independent bodies. 

In the past year, the Panel listened to presentations about their body of evidence from GAO, 

NCD, and the SSAB. These groups’ conclusions and recommendations support critical 

investments that must continue to be made on a national basis to advance and modernize 
Final Report to the President and Congress 76 

76 

the current disability programs. This report cites the recommendations of GAO, NCD, and 

the SSAB and presents the Panel’s findings in each recommendation area. 

Government Accountability Office: Modernizing Federal Disability Policy 

According to an August 2007 GAO report, Modernizing Federal Disability Policy,

144 economic, 

medical, technological, and social changes have increased opportunities for individuals with 

disabilities to live with greater independence and be full participants in the workforce. 

GAO’s analysis of the largest federal disability programs indicates that “these programs are 

poorly positioned to provide meaningful and timely support for persons with disabilities.” 

The SSI and SSDI programs were singled out by GAO as programs whose costs and 

enrollment are growing rapidly and are expected to continue to grow even more rapidly in 

the future. From 1996 to 2006, according to this report, these two programs increased by 42 

percent and 16 percent, respectively. GAO cited several reasons for the current and future 

expected rapid growth of these two programs. The demographic picture of baby boomers 

aging and the documented correlation with increasing onset of disability, as well as the low 

rate of return to work for individuals with disabilities receiving cash and medical benefits, 

creates a situation in need of the immediate attention of policymakers. During this same 

ten-year period, the total inflation adjusted cash benefits for the two programs increased by 

68 percent and 18 percent, respectively. 

GAO brought together a diverse array of experts to explore ways to modernize disability 

programs and transform current disability policy to align with changing social attitudes and 

technological advances. Forum participants cited the complexity of disability issues 

including transportation, housing, health care, education, and workforce development. 

Improved coordination should aim to create “a federal, state, and local system that ensures 

that policy, services, and supports, are synchronized.” For an individual with a disability, 

such a system must seamlessly support the transitions from childhood to adolescence to 

young adulthood to adulthood, and, finally, to retirement. There was also a need expressed 

for greater focus on the development of partnerships between the public and private sector, 

including more collaboration with the employer community to identify the right mix of 

education, supports, and incentives to maintain and expand the participation of individuals 

with disabilities in the workforce. 

The concluding observation from this report is that “to the extent that federal disability 

programs are aligned with 21st century realities, benefits can be achieved for individuals with 

disabilities, business, and government.” As an independent evaluator of the impact of 

federal disability programs, GAO cautions that the growth in size and the costs of major 

federal disability programs (SSDI and SSI) are having an adverse impact on the federal 

government’s long-term structural deficit. “Solutions are likely to require fundamental 

changes, including regulatory and legislative action.... Without strong federal leadership at 

this time to lead the transformation, there could be fewer options in the future available.” 
Final Report to the President and Congress 77 

77 

National Council on Disability: New Solutions for Old Problems 

In its report, The Social Security Administration’s Efforts to Promote Employment for People with 

Disabilities: New Solutions for Old Problems,

145 NCD studied whether the Ticket to Work 

program and other new authorities under the Act were having any more success than SSA’s 

past attempts to impact the employment rate and earnings of beneficiaries. 

The major findings parallel the observations of the GAO Forum. The findings also mirror 

the voices of experience captured in the Panel’s beneficiary summit. Five themes illustrated 

the confusion and frustration of beneficiaries and the ineffectiveness and inequities of both 

the SSDI and SSI programs. 

1. The mission of SSA's disability benefit programs is out of touch with current 

thinking and expectations. 

“Years ago when the Americans with Disabilities Act (ADA) of 1990 

was enacted, prohibiting discrimination against individuals with disabilities 

in employment, housing, education, and access to public services, people were 

excited and thought it would give us more opportunities. I must agree it did, 

it gave us ramps into buildings, wider door ways, lowered telephone booths, 

etc. However, it did not give us equality. Until we are given an opportunity 

to work without stipulations, we will never be able to fully achieve our goals 

in life.” 

Robin Renshaw, Delegate from Nevada 

Beneficiary Summit 

Atlanta, Georgia 

February, 2007 

The current eligibility determination process places the emphasis on inability to work at the 

SGA level in order to qualify for benefits. Such a focus contributes to beneficiary confusion 

about SSA's return-to-work efforts and compounds the challenges of intervention occurring 

early in the disability determination process. 
Final Report to the President and Congress 78 

78 

2. Historically poor service and misinformation provided to beneficiaries by SSA 

field office staff have perpetuated a culture of mistrust and fear. 

“Information and referral is the first service any agency provides. People 

with disabilities will feel more secure if all agencies are speaking the same 

language.” 

Emilio Gandara, Delegate from Puerto Rico 

Beneficiary Summit 

Atlanta, Georgia 

February, 2007 

NCD's findings parallel the Panel's observations and documentation of beneficiaries that 

"misinformation is frequent and mistrust common." There is a prevalent fear that attempts 

to work will result in a determination that the disability has ended. Beneficiaries have cited 

problems with accurate and timely processing of earnings reports by SSA field office staff, 

leading to overpayments. As recently as July 2007, WIPA projects in Oregon and California 

testified to the Panel about their struggles to get accurate and timely information from SSA 

field offices to help inform individual decisions about return to work. Their testimony 

stated that the problems were not isolated incidents, but instead examples of nationwide 

concerns. 

3. Asset limitations and income rules perpetuate long-term impoverishment and 

dependence on public benefits. 

“I always tell people, it is okay to be a woman, just don’t be a poor woman. 

It’s okay to be a person of color, but please don’t be poor and also a person 

of color. It’s okay to be old, but please don’t be poor. You can be disabled 

and you can achieve a fairly high standard of living in this country, but not 

if your disability is surrounded with poverty.” 

Frances Gracechild, Panel Member 

Director of the Independent Living Center 

Sacramento, CA 

Public Comment at the Ticket to Work and Work Incentives 

Advisory Panel Quarterly Meeting 

Washington, DC 

June, 2006 

The Act recognizes the opportunity to overcome some of the most significant barriers to 

employment for working age adults with disabilities. Since 2001, millions of dollars have 

been expended annually by SSA to implement the Ticket to Work program to provide new 

service options for beneficiaries, and to expand education, outreach, and counseling support 

through the BPAO (now WIPA) as well as the PABSS programs. Internally at SSA, AWICs 
Final Report to the President and Congress 79 

79 

and WILs have been dedicated to improving customer service. Modified program rules have 

allowed ticket users protection from CDR provisions, and the level of earnings allowed has 

increased during the TWP. Yet, despite these program improvements and individual 

support choices, fundamental issues of income and asset limits have not been addressed 

directly. The NCD report identified the SSI program’s strict asset limits as a major barrier to 

advancing economic self-sufficiency. The stringent asset limitations create disincentives to 

savings and depress interest in increasing income. The asset limits contribute to a culture of 

dependency on public benefits and long-term impoverishment. The lack of a gradual 

reduction in benefits as earnings increase causes SSDI beneficiaries to depress income by 

limiting their hours of work, perpetuating dependence on Social Security and other public 

benefits. 

4. Coordination and collaboration among multiple publicly funded systems with 

SSA remains poor and detracts rather than facilitates return to work and 

advancement of self-sufficiency. 

“It’s great to have a system in place, but if you don’t have the right people 

in the right places with the right qualifications and the right training then 

you are almost guaranteed not to be as successful as you could.” 

Robert Robertson, Director 

Government Accountability Office 

Education, Workforce and Income Security Group 

Testimony at the Ticket to Work and Work Incentives 

Advisory Panel Quarterly Meeting 

San Juan, PR 

February, 2006 

The NCD report concludes that receipt of Social Security disability benefits is “merely the 

last stop on a long journey that many people with disabilities make from the point of 

disability onset to the point at which disability is so severe that work is not possible.” Along 

the journey, individuals with disabilities encounter a myriad of polices and procedures from 

other systems that do not work in concert with SSA and may even work at cross purposes. 

Beneficiaries testifying before the Panel repeatedly told of frustrating interactions with VR, 

the Medicaid system, secondary and post secondary educational institutions, and Social 

Security field offices that understood little about each other and placed the burden of 

information gathering and fact finding back on the beneficiary. The message was clear: it is 

the individual’s responsibility to navigate the complex maze of rules, despite the partner 

programs’ common mandated objective to improve employment outcomes and/or advance 

self-sufficiency, community participation, and reduce reliance on government benefits. 

Analysis of performance measures across programs indicates that there are no means to 

evaluate and encourage cross-system collaboration. As a result, there are no penalties or 

sanctions for failure to advance integrated service delivery. At the community level, there 
Final Report to the President and Congress 80 

80 

are ineffective uses of resources across systems, flawed return-to-work decisions based on 

incomplete information, and lost productivity of individuals with disabilities. 

5. Disability is a dynamic process that requires flexible policies and supports and 

recognizes one size does not fit all. 

“Either I have to figure out a way to keep benefits (personal assistance 

services through Medicaid), so that I can get up in the morning, get dressed 

and go to work, or I will just have to lay in bed all day, which means not 

only am I not going to work, but then I will stay on these benefits. It just 

makes a lot more sense to me to help people get out and get into the 

workforce and they can pay taxes and help pay for some of these services 

that they are receiving.” 

David Cox, Engineer 

Stockton, AL 

Public Comment at the Ticket to Work and Work Incentives 

Advisory Panel Quarterly Meeting 

Washington, DC 

August, 2006 

Beneficiaries represent a diverse group of individuals with disabilities. Variables impacting 

work activities include the type and severity of disability, age, age of onset of disability, level 

of skills, education, prior work experience, the state in which an individual lives, and the 

level of need for and availability of health care and long-term employment-related supports 

and services. In addition, an individual’s needs may change over time as the nature and 

severity of disability change. With these changes, the work activity may vary as might the 

need for supports and services. 

The NCD report’s conclusions again parallel the body of evidence collected and analyzed by 

the Panel. A framework for the development of future public policy must be sensitive to the 

dynamic nature of disability and its interface with work, reducing the fear and risk of full loss 

of benefits by gradually reducing benefits as earnings increase for SSDI beneficiaries, and 

ensuring the security of a fair and decent level of income during periods of work incapacity. 

Many beneficiaries who testified before the Panel described their disabilities as episodic in 

nature based on their experience with psychiatric disabilities, multiple sclerosis, and other 

conditions. There are times when their conditions require them to stop working. Eligibility 

criteria used by SSA for the disability programs do not support easy transitions on and off 

benefits. For many individuals, the resulting decision is to remain permanently unemployed 

and dependent on the benefits. 

The NCD report confirms the urgent need for policy and program changes. “Although SSA 

has taken steps to improve its return to work services, a more comprehensive change in the 
Final Report to the President and Congress 81 

81 

agency’s process and underlying philosophy is necessary in order to make SSA disability 

programs more work oriented.” NCD concluded that promoting employment and return to 

work among beneficiaries “will require SSA to make a major paradigm shift and totally 

redefine both its mission and how it conducts its work on a day-to-day basis.” 

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

The SSAB issued its report, A Disability System for the 21st Century,

146 in September 2006. The 

importance of the SSDI and SSI programs in the lives of individuals with disabilities, 

especially since a majority of beneficiaries depend on these income benefits for more than 75 

percent of total income, led the SSAB to focus much of its attention on these programs over 

the ten years since the SSAB was created. The SSAB “discovered that there is something 

about these programs that was antithetical to another basic need – the need to pursue 

independence and a sense of contributing to one’s own self-support and to the good of 

society.” The SSAB found that the most apparent conflict was the Social Security definition 

of disability, which equates disability with the inability to do any substantial work. 

As the SSAB pointed out in its 2003 report, The Social Security Definition of Disability,

147 the 

definition of disability was adopted some fifty years ago for a program that was limited to 

individuals approaching retirement age. Policymakers, practitioners, and persons with 

disabilities could not have foreseen the social, technological, and medical changes that have 

influenced today’s thinking, or the changing expectations about the capacity of the target 

audience to be productive members of the workforce in diverse business settings. However, 

changing the definition of disability as the trigger for eligibility to SSDI and/or SSI benefits 

is not without significant challenges. Broadening eligibility could increase the costs of the 

program and provide benefits to individuals beyond the currently identified scope. 

Narrowing eligibility could prevent individuals who are unable to engage in substantial work 

from receiving their benefits. The SSAB, with expert input and presentations from diverse 

stakeholders, determined that the problem is that these programs “...are not integrated into 

an overall approach to disability that supports the aspirations of people with disabilities to 

achieve their maximum potential.... Correcting this problem will require a statutory change 

to define disability in a way that encompasses such an integrated approach.” 

The SSAB concluded that “it is time to set aside old paradigms and look more broadly at 

what is possible.” A modernized disability system must invest in human capital and 

recognize that it is not inconsistent to receive support and work simultaneously. In framing 

the essential arguments for a modernized disability system, the SSAB incorporates elements 

consistent with the findings and recommendations of the GAO and NCD reports and with 

the body of evidence assembled by the Panel over the past eight years. 

According to the SSAB, a modernized disability system must incorporate elements that 

embrace change and: 
Final Report to the President and Congress 82 

82 

• “Provide assistance and support to individuals and strive to maximize 

employment outcomes to the extent of each individual’s capabilities; 

• Facilitate a culture shift within society to establish the expectation that 

individuals with disabilities can and should work to the extent of their 

capabilities and that society should assist individuals with disabilities in 

that endeavor; 

• Recognize and accommodate the dynamic nature of disability and its 

sometimes cyclical impact on work capacity; and 

• Facilitate rehabilitation and employment by coordinating and 

integrating the various sources of assistance and support that are now 

inconsistently provided by multiple uncoordinated programs.”148

The Panel supports such a disability system that would make the consumer an active partner 

in designing appropriate services and supports. The beneficiary voice would be elevated to 

shape the system and customize individual responses that strengthen and support choice. 

Such a system would encourage contributions by individuals to their own self-sufficiency 

and yet be responsive to the continuum of individual abilities and needs. 

Making the Case for Change 

The testimony of beneficiaries during the last eight years provided the Panel with a unified 

voice for modernizing disability programs and systems that support individual goals to 

advance self-sufficiency and be a part of the economic mainstream. The evidence before the 

Panel affirms the findings and conclusions of three independent authorities charged with 

advising federal level policymakers about disability policy direction and effectiveness. The 

Panel joins GAO, NCD, and the SSAB in urging Congress to modernize disability policy. 

This modernized policy should present contemporary choices for balancing security and 

economic opportunity for current beneficiaries and future generations of youth and adults 

with disabilities who want to work and more fully participate in community life. 

As a result of the Panel’s discussions regarding modernization of disability programs, the 

Panel learned of many promising ideas and proposals from experts nationwide. These 

proposals included, but were not limited to: the Wisconsin Department of Workforce 

Development’s “Making Work Pay,” the Council of State Administrators of Vocational 

Rehabilitation’s “Rehabilitation Early Diversion (RED)” proposal, the National Council on 

Independent Living (NCIL) proposal, “Being American: The Way Out of Poverty,” and the 

United Cerebral Palsy’s (UCP) “Big Sky Project.” 
Final Report to the President and Congress 83 

83 

Guiding Principles 

Just as the ADA extended the reach of the nondiscrimination provisions introduced by 

Section 504 of the Rehabilitation Act, it is time to extend the reach of the Ticket to Work 

and Work Incentives Improvement Act and modernize the income support and corollary 

health insurance programs that serve Social Security beneficiaries. This modernization is 

necessary so that people with significant disabilities have meaningful opportunities to 

participate in the American economic mainstream and so that we do not continue to support 

unnecessary dependence and force people with disabilities to live in poverty in order to 

receive basic government supports. 

The Panel’s recommendations for investing in disability program modernization are based 

on ten guiding principles: 

1. Beneficiaries of public disability programs should be full participants in 

shaping the policies that will transform those programs. 

2. People with significant disabilities should be empowered to make informed 

choices about work opportunities. 

3. Disability policies should take into account differences in the needs and 

experiences of people with different types of disabilities. 

4. Disability policies should recognize the dynamic and cyclical nature of 

significant disability and assure appropriate public supports during periods of 

work capacity limitation or disruption. 

5. Work-oriented interventions should be provided timely in order to maintain a 

workforce connection for workers with new disabilities. 

6. Work should make individuals and their families economically better off than 

they are when they receive income supports and related assistance. 

7. Participation in work-oriented programs and services should be voluntary for 

youth and those adults who have been unable to establish or maintain an 

attachment to the workforce because of significant disabilities. 

8. Youth and others with significant disabilities should be provided the 

employment-related services and supports, internships and other 

opportunities and resources that will empower them to fully explore their 

vocational options (including self-employment) prior to entering a long-term 

income support program designed for individuals with limited work capacity. 

9. Disability programs should be as simple to understand and as easy to 

administer as possible, while balancing the need to address individual 

circumstances. 
Final Report to the President and Congress 84 

84 

10. Disability programs should be effectively coordinated across agencies and 

among levels of government with clearly articulated benchmarks to evaluate 

success. 

Long-Term Investment Outlook 

The Panel is acutely aware of projected Old Age, Survivors, and Disability Insurance trust 

fund shortfalls as well as long-term projections for deficits in the federal budget. 

The Panel believes that modernization proposals should be evaluated not exclusively in 

terms of their short-term fiscal impact but also according to the costs over the total life of 

the investment, including long-term savings from decreased cash payments and increased tax 

contributions. Recommendations for policy reform should also be evaluated in the context 

of the costs of inaction, as reflected in disability program growth trends and long-term 

economic predictions. Given Congress’s estimate, at the time of the Ticket to Work and 

Work Incentives Improvement Act’s passage in 1999, that a savings of $3.5 billion could be 

expected when one half of one percent of the beneficiary population left the benefit rolls 

because of employment, it is not difficult to calculate substantial savings that can and will 

flow from a well-designed system. Although the actuaries at SSA and the CBO may be 

sparing in projecting potential long-term savings, Congress can work with SSA, researchers, 

and other agencies to measure and demonstrate the return on investment of different policy 

proposals. 

A Comprehensive Approach 

Because people with disabilities are a diverse population with varying needs and work 

capacities, and because of variations in local labor markets, no single program or policy will 

be universally successful in promoting work and meeting the needs of all people with 

significant disabilities. In short, there is no one-size-fits-all answer to the challenges we face. 

Rather, mutually supportive and flexible programs and policies need to be designed to 

support people with significant disabilities at various stages of the onset and management of 

disability and for varying levels of work capacity. These policies and programs should build 

on demonstrations and innovations that are producing results at the national, state and local 

levels. The Panel proposes the following comprehensive set of recommendations to advance 

an ongoing national dialogue regarding program modernization and sound long-term 

investments in an employment strategy for Americans with disabilities. 

Raise Expectations 

Beneficiaries and disability advocates have consistently told the Panel that people with 

significant disabilities are barraged with messages that they are unable work. Many people 

with disabilities and their families, as well as employers, health care professionals, educators, 

and service providers, absorb these low expectations. Changing these low expectations goes 
Final Report to the President and Congress 85 

85 

beyond simply including positive messages in the material SSA provides about Social 

Security programs. 

A social marketing campaign should be developed in close collaboration with a diverse 

group of beneficiaries, their family members, educators, employers, health care professionals, 

and those who serve people with disabilities to identify the most effective mechanisms to 

transform attitudes and expectations about employment and people with disabilities. 

Messages could include: 

• For those who can work, work is not only an opportunity it is a 

personal responsibility to yourself, your family and your country. 

• People with significant disabilities want to be productive and can work 

if they are provided with the right supports. 

• Everybody loses when people with disabilities are not given an 

opportunity to work or are excluded from community life. 

• People with disabilities have a right to work. 

• Young people with disabilities should be provided every opportunity to 

work, live independently, and enjoy self-determination to the full 

extent of their abilities. 

• Families should be provided with the supports necessary to enable 

their children with disabilities to work and/or own a business and 

other income-generating assets to the full extent of their abilities. 

• Educators should expect students with significant disabilities to reach 

educational objectives and provide them with the individualized 

supports necessary to make it possible. 

• Employers should expect people with disabilities to compete effectively 

for jobs and promotions; they should expect employees with 

disabilities to help their companies innovate and reach a diverse and 

growing market including people with disabilities and their families. 

• Public and private programs and services are available to support 

people with disabilities in pursuing a career that matches their interests 

and abilities. 

This type of marketing campaign is an essential component of the Panel’s strategy to 

increase employment, economic self-sufficiency, and self-determination outcomes for people 

with significant disabilities. People with disabilities and the influential people in their lives 
Final Report to the President and Congress 86 

86 

should be instilled with the value of work, and employers should view individuals with 

disabilities as a valuable talent pool. 

Recommendation 25: The President should take the lead to establish and provide 

financial support for a comprehensive, cross agency, culturally competent social marketing 

campaign to raise expectations about the productive employment potential of people with 

disabilities. This campaign should target people with disabilities, their families, educators, 

employers, health care professionals and those that serve people with disabilities and the 

community. This marketing campaign should use the most accessible and effective media, 

including television, radio, the internet, and mainstream and specialty magazines and 

newspapers. 

Promote Workforce Connection and Retention 

The private sector has developed many best practices in disability management. For instance, 

when workers acquire new disabilities, employers focus on timely intervention to ensure that 

workers have the necessary health care and rehabilitation supports to recover from and 

adapt to new disabilities. During the recovery process, employers and insurers work 

intensively to assess and restore their employees’ work potential. Consequently, private 

sector disability insurers ask “what can you do?” rather than require individuals to prove 

work incapacity. People who acquire new disabilities may not be able to return to their prior 

job. When that is not feasible, training and accommodations may enable workers to 

transition to new jobs. 

Managers using effective disability management practices recognize that productivity and 

work are not an all-or-nothing proposition. Instead, they allow workers to adjust their 

schedules or duties and provide support during a restorative period to enable employees to 

remain at or return to work. Some individuals may have to reduce the number of hours they 

work or be unable to work for a period of time and then gradually return to full- or part-time 

work. 

In addition to minimizing the impact of a new disability, many employers also have absence 

management programs oriented to preventing and limiting disability. These programs 

promote workplace safety, minimize injury, and provide wellness programs to improve 

worker health on and off the job. 

Employer-based disability management can reduce pressure on the Social Security disability 

rolls by enabling employees to remain connected to the workforce. Because disability 

management can reduce federal income support expenditures, the federal government 

should play an active role in supporting and encouraging private-sector efforts. The Panel 

recommends that Congress, the President, and the Commissioner of SSA work closely with 

states, employer organizations, disability organizations, and the private insurance industry to 

explore ways that public-private partnerships can help incentivize more employers to adopt 
Final Report to the President and Congress 87 

87 

best practices in disability management.149 These best practices should encompass the use of 

assistive technology. 

Even the most effective disability management practices may not be sufficient to enable 

people with significant disabilities to stay connected to the workforce in the absence of 

comprehensive health care and coverage for long term services and supports. 

Recommendation 26: Congress should create employer incentives to increase the 

availability of effective workforce retention policies and programs to keep working adults with 

newly-diagnosed or recently-exacerbated medical conditions connected to the workforce. 

Recommendation 27: The Social Security Administration should implement a 

demonstration that tests the costs and benefits of establishing a publicly supported short-term 

disability insurance program at the state level that is modeled on the best programs that have 

been developed in the private sector and by state governments, which would be available to 

individuals with work histories who do not have private disability insurance. 

Enhance Job Opportunities

Nothing changes work expectations more effectively than working. Work is habit forming. 

People with disabilities who develop a work history are more likely to view work as a natural 

part of their lives. Similarly, employers who have successful records of employing people 

with disabilities are more likely to expect that people with disabilities will be productive 

employees. Most of the recommendations contained in this report discuss programs and 

initiatives that can make work possible and financially rewarding. However, the Panel is also 

aware that people with disabilities cannot take advantage of these supports in the absence of 

job opportunities. 

A job creation strategy could take many forms. President Franklin Delano Roosevelt created 

the Works Progress Administration (WPA) to help solve the unemployment crisis that 

accompanied the Great Depression. The WPA provided work opportunities to eight million 

Americans who built schools, airports, dams, parks, bridges, and other public projects. 

These workers developed and refined skills that they could carry to private-sector 

employment. Similarly, the Comprehensive Employment Training Act (CETA) signed by 

President Lyndon B. Johnson provided disadvantaged job seekers with subsidized positions 

within the public sector. In many cases, these positions led to permanent unsubsidized 

positions. In 1982, President Ronald Reagan signed the Job Training Partnership Act (JTPA) 

into law. The JTPA was a publicly funded job training program that began a partnership 

with private sector employers. JTPA programs were based at the local level and were guided 

in each community by employer members of a private industry council. The councils were a 

precursor to today's local workforce investment boards.

President George H.W. Bush signed the National and Community Service Act into law in 

1990. This legislation created a new independent federal agency, the Commission on 
Final Report to the President and Congress 88 

88 

National and Community Service. In 1993, President William Jefferson Clinton and 

Congress established the AmeriCorps program through enactment of the National and 

Community Service Trust Act of 1993, which built on the community service legislation 

signed into law by President George H.W. Bush in 1990. AmeriCorps is a network of 

national, state, and local service programs that connect tens of thousands of Americans each 

year to volunteer efforts addressing community needs in education, public health and safety, 

and the environment. In addition to making critical and lasting contributions to their 

communities, AmeriCorps participants develop valuable skills that can help them prepare for 

private sector employment. Participants also receive a monetary award to offset the cost of 

higher education. 

The WPA, CETA, JTPA and AmeriCorps programs offer powerful examples of how the 

federal government can develop innovative approaches to engage people in productive and 

skill-enhancing work that benefits local communities. The President and Congress should 

explore ways that the federal government can become more active in creating these types of 

opportunities for people with disabilities. 

An additional opportunity is presented by large-scale turnover in federal jobs due to the 

retirement of the baby boom generation.150 The federal government is developing initiatives 

to recruit more young people into federal employment opportunities. By recruiting people 

with disabilities into existing federal jobs and newly-created positions, the government could 

simultaneously help meet its own hiring needs and help prepare more people with disabilities 

to succeed in the private sector. 

The President and Congress should also foster public-private partnerships to improve 

recruitment and hiring of people with disabilities in the private sector. Building on recent 

increases in corporate interest in the disability market, corporate leaders could encourage 

their counterparts at other companies to publicly commit to increasing their recruitment, 

hiring, and promotion of people with disabilities. Corporate-sponsored initiatives can change 

the expectations of people with disabilities by showing that America’s strongest companies 

are dedicated to hiring them. These initiatives can change corporate culture by sending a topdown message that people with disabilities are a vital part of the workforce and should not 

be overlooked. For these initiatives to have an impact, however, employers need to set goals 

and benchmark their performance in recruitment, retention, and promotion of their disabled 

workers. 

Recommendation 28: The President should implement a job creation strategy that 

engages and incentivizes public and private sector employers in targeting people with 

significant disabilities for jobs that pay a living wage and have benefits that enable a 

beneficiary to move successfully from benefit receipt to employment, through a new level of 

collaboration among state and federal employment and economic development programs, the 

business community and disability organizations. 

 
Final Report to the President and Congress 89 

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

Millions of Americans lack access to basic health insurance coverage, forcing them to make 

untenable choices between life-saving medicines and treatments, preventive care, and basic 

life needs. Many people with disabilities are counted among those who lack access to health 

care. Moreover, people with disabilities face an additional crisis that is as important as the 

lack of access: lack of appropriate programs that are designed to meet their unique needs. 

Both private and public health care insurance were developed in an era when antiquated 

notions about people with disabilities prevailed. At the time, disability was often presumed 

to mean inability to work. The effect of these low expectations on health care coverage was 

profound. Policymakers, employers, and actuaries designed employer-based health coverage 

to meet the needs of non-disabled Americans and fashioned Medicare and Medicaid to meet 

the needs of people with disabilities who were expected to remain at home or in an 

institution. Consequently, people with disabilities face a dual crisis: 

• Lack of access to basic health care coverage, including preventive care 

and assistance in living healthy lifestyles, and 

• Lack of affordable access to health care and long-term services and 

supports coverage designed to meet their needs if they want to work 

and participate fully in community life. 

For millions of Americans with disabilities, access to health care coverage is not merely 

important, but required. Foregoing health care coverage is not an option because making 

such a decision would put individuals’ lives or well-being at risk. Because employer-based 

health insurance is often not adequate, affordable, or available to meet the needs of people 

with disabilities, many are compelled to seek Medicare and Medicaid coverage. However, 

with limited exceptions, eligibility restrictions for these programs typically discourage 

individuals from earning and saving above certain thresholds. People with disabilities, 

including current beneficiaries and participants in state Medicaid Buy-In programs, identify 

fear of losing health care benefits as one of the top reasons that they limit their efforts to 

work. Unless people with disabilities have timely access to affordable, comprehensive health 

care and long-term services and supports, our nation will continue to dedicate valuable 

resources to keeping people at home instead of enabling people to become as self-sufficient 

as possible. 

Despite efforts to increase health care access through Medicaid and Medicare, a number of 

challenges are faced by people with significant disabilities in maintaining health care 

coverage: 

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

disabilities. 
Final Report to the President and Congress 90 

90 

• In those states that do offer Medicaid Buy-In programs, significant 

limits are often imposed on an individual’s ability to earn income and 

accumulate assets. 

• In many states, Medicaid does not provide sufficient home- and 

community-based long term services and supports or enough options 

to serve individuals with a variety of needs and disabilities. 

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

• Medicaid often offers little choice in providers, particularly mental 

health providers, due to low reimbursement rates. 

• Medicare does not provide ongoing coverage for the personal 

assistance services and supports or mental health services that some 

individuals require in order to pursue and maintain work. The Medicare 

acute benefit is not based on contemporary medical standards. 

• Individuals who qualify for SSDI have to wait for two years before 

they are eligible for Medicare, and many individuals are unable to 

afford other interim coverage such as Consolidated Omnibus Budget 

Reconciliation Act (COBRA) coverage; during this period, one’s ability 

to return to work may diminish along with one’s health status. 

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

disabilities: 

• Access For All. All people with significant disabilities should have 

access to affordable health care and long-term services and supports 

coverage, regardless of income level and independent of qualifying for 

or retaining access to long-term income support. 

• Timeliness. People with disabilities should be able to access health care 

and long-term services and supports when needs arise, not based upon 

arbitrary eligibility delays. 

• Comprehensiveness. To support work and efforts to achieve selfsufficiency, coverage should include acute care, specialized care, 

prescription drugs, assistive technology (including durable medical 

equipment) for use in the community as well as the home, mental 

health services, and consumer-directed long-term personal assistance 

services and supports. 
Final Report to the President and Congress 91 

91 

• Portability. To enable people to pursue job opportunities wherever 

they may be, people with significant disabilities should be able to 

obtain standardized health care coverage in any state. 

• Contributory. People with significant disabilities should contribute 

more toward the costs of health care as their incomes rise; individuals 

of lower income should be exempt from cost-sharing obligations. 

• Public-Private Coordination. The federal government should offset the 

increased costs of coverage for people with significant disabilities by 

providing benefits that either wrap around a basic employer-provided 

benefit or enable employers to contribute to federal coverage in lieu of 

their basic employee benefit. Benefits should be coordinated to ensure 

timely coverage and avoid the delays commonly associated with 

overlapping insurance coverage. 

Because health care reform has once again taken center stage in our national debate, these 

reform principles should be pursued either as part of broad, national reform and/or by 

building on the Medicare and Medicaid programs. In addition, to the extent possible, these 

goals should be accomplished in the context of a health care system used by all Americans. 

Options could include: 

• Reforming Medicaid. The existing federal-state partnerships for 

providing Medicaid could be expanded to guarantee an identical benefit 

consistent from state to state, supported by 100 percent matching with 

federal funds. Medicaid recipients should play a significant role in the 

design and implementation of any reforms. 

• Reforming Medicare. Coupled with reforming existing acute care 

benefits to meet the needs of individuals active in their communities 

and eliminating the two-year waiting period for SSDI beneficiaries, a 

new component of Medicare could be established to cover long-term 

services and supports similar to those currently available in some state 

Medicaid programs. Medicare beneficiaries should play a significant 

role in the design and implementation of any reforms. Modernizing 

Medicare is particularly important because many private health 

insurance policies are modeled on the acute health care coverage that is 

available under Medicare. 

• Coordinated Reform of Medicare and Medicaid. Instead of 

transforming either Medicare or Medicaid to provide the full scope of 

comprehensive health care and long-term services and supports, 

policymakers could provide people with significant disabilities with 

access to both Medicare and Medicaid. Each program could be 
Final Report to the President and Congress 92 

92 

reformed to provide complementary coverage that, when combined, 

would provide the comprehensive coverage that people with significant 

disabilities need. For instance, Medicare could be reformed to provide 

comprehensive acute care coverage without a two-year waiting period, 

including better assistive technology and mental health services 

coverage. Similarly, Medicaid could be reformed to provide a uniform, 

federally supported long-term services and supports benefit to wrap 

around Medicare’s acute care coverage. 

• Comprehensive Health Reform. If Congress and SSA collaborate to 

increase access to health care coverage for all Americans, it may be 

possible to ensure that the needs of people with significant disabilities 

are incorporated into proposed solutions. Alternatively, Congress could 

reform Medicare and/or Medicaid to ensure that wraparound benefits 

to complement basic health care coverage are provided to all 

Americans. 

The Panel views these options as viable approaches to providing people with significant 

disabilities with the critical health care and long-term services and supports they need to help 

achieve their self-sufficiency goals. Irrespective of the specific reform path that is pursued, 

people with significant disabilities, including SSI, SSDI, Medicare and Medicaid beneficiaries, 

should be involved in policy debates to ensure that the needs of people with disabilities are 

properly addressed. 

Recommendation 29: Congress should work in a bipartisan fashion to build on the 

goals of the Medicaid Buy-In and the Medicaid Infrastructure Grant to ensure that people 

with significant disabilities have access to affordable coverage for health care and long-term 

services and supports that is comprehensive; portable; supported by beneficiary contributions, 

where appropriate; independent from qualifying for income support; and coordinated with 

employer-sponsored benefits. 

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

Program 

The Panel believes that people with significant disabilities should have access to supports to 

maximize their economic self-sufficiency. In particular, young people should be provided a 

meaningful opportunity to learn, plan and participate in the economic mainstream. 

In accordance with the principle of “do no harm” and the desire to continue the national 

dialogue about modernizing disability programs, a large-scale Transition to Economic SelfSufficiency (TESS) demonstration project should assess the potential and unintended 

consequences of a new approach to providing supports for particular beneficiary 

subpopulations. The TESS demonstration should be designed to serve people with 
Final Report to the President and Congress 93 

93 

significant disabilities ages 14 - 30 who face significant barriers to work but who could 

increase self-sufficiency if provided adequate supports. 

The Panel believes it is critical to preserve the SSI and SSDI entitlement programs. 

However, these entitlement programs, as currently designed and implemented, are not 

sufficiently dynamic to meet the needs of individuals who want and are able, with supports 

and services, to achieve levels of self-sufficiency through work. 

Work incentive reforms have increased options for pursuing employment and career 

objectives while retaining access to critical supports. However, these reforms are 

complicated, poorly administered and restrained by an underlying philosophy that links 

income support (SSI adult program and SSDI) to an inability to work. Statistics show that, 

on average, people who enter SSI prior to age 18 remain on the rolls for 27 years.151

Truly meeting the needs of young people with significant disabilities requires that our nation 

adopt a philosophy guided by investment rather than maintenance. A high return on investment 

can be expected if our nation invests in youth before they have internalized low expectations 

and become mired in well-intended programs that require a commitment to unemployment 

or underemployment in exchange for critical supports. 

This recommendation for a large scale demonstration project pertaining to TESS was 

considered controversial by a minority of Panel members, who felt the recommendation 

raised considerable concerns. Panel members Cheryl Bates-Harris, Thomas P. Golden and 

Dorothy Watson expressed opposition to the TESS proposal stating that they did not feel 

the recommendation was well justified and had not been thoroughly discussed or adequately 

vetted with internal or external stakeholders. 

They believe that the TESS proposal, while well intentioned, is unclear and vague as well as 

complex and costly. Rather than simplifying the labyrinth of programs, it seems to add 

another layer of complexity. They believe that for a major new proposal such as TESS, it is 

necessary to be far more clear about its components, its costs, and how it will be 

administered and implemented. 

Features of the TESS Large-Scale Demonstration 

Eligibility 

Young people ages 14 - 30 should become eligible for the TESS demonstration based on the 

nature of their disabilities and the disability-related barriers to work they are likely to face. 

During their participation in the TESS demonstration, young people with disabilities should 

be encouraged to learn, plan, earn and save as much as they can while maintaining access to 

cash benefits on a gradual reduction basis. 
Final Report to the President and Congress 94 

94 

Cash Benefits 

Under current rules, SSI and SSDI beneficiaries’ cash benefits are reduced as earnings rise 

(gradually under SSI, or suddenly under SSDI). As has been well documented, people with 

significant disabilities often struggle to determine whether earning above the relevant 

thresholds is worth the financial risk of losing access to cash benefits. In essence, SSI and 

SSDI create incentives for beneficiaries to limit earnings. 

The TESS demonstration should adopt a new philosophy for youth that draws on features 

of the current SSI and SSDI programs. Under TESS, individuals could receive cash benefits 

equivalent to the amount they are entitled to under the traditional rules of SSI and/or SSDI. 

Cash benefits under the TESS program could be reduced as follows. 

• TESS participants could keep all earned and unearned income without 

any impact on SSA cash benefits up to a specified threshold. For 

instance, all earned and unearned income up to 200 percent of SGA or 

the federal poverty level would be exempt from any reduction in cash 

benefits. 

• After reaching a designated income threshold, TESS participants’ cash 

benefits would be reduced gradually, comparable to the existing twofor-one reduction in the SSI program, up to a second threshold. For 

instance, cash benefits could be gradually reduced between 200 percent 

and 300 percent of SGA or the federal poverty level. 

• Individuals between the ages of 14 – 30, with income above the second 

threshold would not receive any cash benefits. However, they would 

resume receipt of cash benefits on any occasion during which income 

fell below the specified thresholds for full or partial cash benefits. 

• The scope of the current PASS program could be expanded in 

conjunction with the TESS program to enable SSI and SSDI 

beneficiaries to establish Independence Accounts through PASS. 

• During any month in which TESS participants’ cash benefits were 

subject to a reduction due to earnings, SSA could continue to pay a 

portion of the cash benefit into an Independence Account, as 

described below. 

This approach to cash benefits for young people with significant disabilities would clearly 

reward efforts to increase income by enabling individuals to retain a significant portion of 

income and thereafter reduce cash benefits gradually rather than suddenly. 
Final Report to the President and Congress 95 

95 

Health Care and Long-Term Services and Supports 

As described in recommendation 29, the Panel recommends that all people with significant 

disabilities should have access to comprehensive health care and long-term services and 

supports coverage. In the absence of more far-reaching reform that would affect all people 

with significant disabilities, Congress should, at minimum, guarantee participants in a TESS 

demonstration access to the type of coverage recommended by the Panel. TESS 

demonstration participants should retain access to this coverage throughout their program 

participation, regardless of earnings and asset levels. TESS demonstration participants 

should be required to contribute to their coverage on a sliding-scale based on their income 

(including an exemption for low-income earners). 

Independence Accounts 

The TESS demonstration should incorporate newly-established Independence Accounts. As 

noted above, during a period which cash benefits are reduced gradually, SSA could continue 

to contribute a portion of an individual’s cash benefit into an Independence Account. Funds 

contributed to these accounts either by SSA or by individuals could be used to acquire assets 

that increase self-sufficiency. For instance, funds could be used to purchase assistive 

technology, vocational and educational training, purchase a vehicle, participate in a 

retirement plan, start a business, or save for a down payment on a home. 

Career and Employment Services 

The TESS demonstration should be consistent with the objectives of the Ticket to Work 

program. Consequently, TESS participants should be entitled to assign their tickets to ENs. 

TESS demonstration participants should be provided an interdisciplinary, person-centered 

assessment, focused on strengths and abilities, to identify the education and training that will 

maximize their future earning potential. Particular emphasis should be placed on integrating 

career assessment and transition planning services with Individualized Education Plans 

(IEPs) to ensure that services provided support the needs and career interests of students. 

Ideally, TESS demonstration participants and their families should have access to 

independent living centers and other consumer-directed disability organizations to obtain 

peer-to-peer mentoring. 

The TESS demonstration should also provide comprehensive employment services and 

supports that are flexible enough to accommodate the individual needs of young people with 

significant disabilities. TESS demonstration participants should have ongoing access to these 

services and supports to adjust to new issues that emerge after transitioning to work, 

including preparing for job changes as well as making financially sound decisions regarding 

management of the personalized Independence Accounts. The demonstration should 

provide all services in a culturally competent manner and support a wide range of work 
Final Report to the President and Congress 96 

96 

options, including but not limited to self-employment, customized employment, and public 

service. 

Employment services and supports for TESS demonstration participants should be 

integrated with existing services for students and beneficiaries to enable young people to 

evaluate how to best utilize the TESS demonstration program. Existing services for students 

include VR, ENs, and ILCs. 

Outreach to Youth below Age 16 

Youth below the age of 16 should be exposed to work and career options and should be 

encouraged to pursue their education in preparation for life as working adults. The TESS 

demonstration should include an outreach component that coordinates with school 

programs and sets expectations among young people with disabilities age 14 to 30. The 

primary outreach message must be that work is a viable option for them, that there are many 

interesting career options available, and that education is one key to success. In addition, 

TESS demonstration grantees should be expected to coordinate with local education 

agencies and Social Security field offices to identify children before age 14 who are likely to 

be eligible for the TESS demonstration upon turning 14. 

Improve Access to Internships and Transitional Work 

The TESS demonstration should provide participants with access to internships and 

transitional work opportunities. These opportunities have proved effective in acquiring work 

skills and behaviors and gaining access to job openings before they are advertised. A number 

of innovative approaches to internships and transitional work are already in place in 

communities around the country. 

Financial Literacy Training and Asset Development Strategies 

TESS demonstration participants should be provided financial literacy training and 

assistance in asset development to leverage individual development account programs, tax 

incentives like the Earned Income Tax Credit, home ownership programs, and other policies 

and programs that are designed to help low-wage workers achieve a greater degree of 

economic self-sufficiency. 

Integration with Other Disability Programs 

Participants in the TESS demonstration should not be denied access to other needed public 

benefits and assistance. Independence Account resources should not be counted toward 

initial or continuing eligibility for other public benefits. HUD, Medicaid, Mental Health, 

Food Stamps, Energy Assistance, Transportation, VR and other programs providing support 

to persons with disabilities should be integrated with the TESS demonstration. 
Final Report to the President and Congress 97 

97 

Recommendation 30: The Social Security Administration should design and 

implement a large-scale demonstration project that studies the feasibility, cost-effectiveness, 

and any unintended consequences of a voluntary Transition to Economic Self-Sufficiency 

Program for young people who are between 14 and 30 years old and qualify for 

Supplemental Security Income and/or Social Security Disability Insurance. This 

demonstration project should build on the goals of the Ticket to Work program and evaluate 

the feasibility of a program that would transform Supplemental Security Income and Social 

Security Disability Insurance by establishing unified rules that: provide a graduated cash 

payment to address the effects of disability-related barriers on income; build on the Ticket to 

Work program to increase the availability of and consumer control over employment-related 

services; promote optimal educational outcomes; and enable program participants to 

maximize income and assets without fear of losing critical supports. 

Modernize the Social Security Definition of Disability 

The Panel acknowledges that proposing any change to the definition of disability raises 

legitimate fears. Consequently, the Panel believes that any proposed change to the Social 

Security definition of disability should be evaluated to assess the potential for any adverse 

impact on beneficiary subpopulations. 

The Social Security definition of disability has not changed in any meaningful way since the 

eligibility criteria for SSDI were developed in 1956.152 This is inconsistent with fundamental 

changes in societal thinking, advances in science, medicine and technology and the passage 

of numerous laws. Beneficiaries have repeatedly told the Panel that they view the Social 

Security definition of disability as one of the most significant impediments to work. 

Beneficiaries describe applying for Social Security as a pledge that they are unable to work. 

In addition, even though beneficiaries recognize that disability is defined as the inability to 

do any substantial gainful activity by reason of any medically determinable physical or mental 

impairment which can be expected to result in death or which has lasted or can be expected 

to last for a continuous period of not less than 12 months and does not require permanent 

inability to work, the reality is that meeting the definition discourages future work. To meet 

this definition, one must have a severe impairment(s) that makes them unable to do their 

past relevant work (see § 404.1560(b)) or any other substantial gainful work that exists in the 

national economy. Chapter 20, Title 20, CFR, Subpart P, Section 404.1505. 

As long as eligibility is defined for our largest federal income support and health care 

programs based on an inability to engage in SGA that results from medical impairment 

expected to last for at least one year, we will continue to send a clear message to people with 

significant disabilities that they are inherently unable to support themselves. In short, our 

largest public programs consistently tell our working-age population with disabilities that we 

do not expect them to work or participate fully in their communities when they qualify for 

these income and health care supports. 
Final Report to the President and Congress 98 

98 

People with disabilities should never be obligated to attest that their disabilities prevent them 

from working. Doing so implies that working is not a feasible option even if adequate 

supports were provided. 

Recommendation 31: Congress and the Administration should take action to 

evaluate the impact of modernizing the Social Security definition of disability by defining 

disability in a manner that acknowledges the interaction between the person’s impairment 

and the environment and does not require the individual to prove their inability to engage in 

substantial gainful activity. 

Coordinate Disability Programs at the Federal Level 

For more than two decades, reports by NCD and GAO153 have consistently described a 

fragmented disability service delivery infrastructure marked by: 

• Widespread confusion among consumers; 

• Overlapping and at times inconsistent responsibilities; and 

• Lack of accurate information about eligibility, work incentives, and 

means tested resource limits of multiple public benefits. 

The Panel believes that the White House Domestic Policy Council should take the lead in 

improving communication and collaboration among federal programs that provide 

employment services and supports. They should coordinate with representatives from 

agencies with significant disability programs, including SSA, the Departments of Health and 

Human Services, Education, Labor, Transportation, Veterans Affairs, and HUD. The 

Domestic Policy Council should also coordinate with representatives from GAO, OMB and 

beneficiaries that represent the broadest diversity in disability, culture, age, race, and gender. 

It is particularly important that the council ensure that SSA and CMS coordinate their efforts 

at the highest levels because SSA and CMS account for the vast majority of disability 

program expenditures, and the lack of access to health care and long term services and 

supports is consistently identified as one of the most critical barriers to work for people with 

disabilities. 

The Domestic Policy Council should continue to identify opportunities to improve 

coordination and collaboration across agencies at a federal and a state level. Options should 

be explored and evaluated for direct positive impact on beneficiaries at a local level. 

Recommendation 32: The Domestic Policy Council should ensure ongoing 

communication and collaboration among federal programs that provide employment services 

and supports. 
Final Report to the President and Congress 99 

99 

 

Call to Action 

“From my perspective, the Work Incentives Improvement Act of 1999 

represents a natural and important progression in federal policy for 

individuals with disabilities. That is, federal policy increasingly reflects the 

premise that individuals with disabilities are cherished by their families, 

valued and respected in their communities, and are an asset and resource to 

our national economy. Today, most federal policy promotes opportunities for 

these individuals, regardless of the severity of their disabilities, to contribute 

to their maximum potential-at home, in school, at work, and in the 

community.” 

U.S. Senator James Jeffords 

Floor Statement, November 18, 1999 

The Panel’s call for national dialog and investment in disability program modernization is 

consistent with the conclusions of GAO,154 the SSAB,155 NCD,156 the American Association 

of People with Disabilities,157 the National Council on Independent Living and the World 

Institute on Disability,158 and beneficiaries.159 Our commitment to modernization is the 

natural extension of the legislation that created the Panel. The Act embraced the concept 

that supports and work can go hand in hand — that people with significant disabilities 

should have access to health care and other critical supports rather than be forced to stay out 

of the workforce to get them. 

At a time when policymakers predict a shortfall of workers as the baby boom generation 

retires, and some policymakers are trying to curb the flow of new immigrant workers, our 

nation cannot afford to squander the potential of Americans with disabilities who want to 

work. Nor can we continue to undervalue the future work potential of the millions of 

children and youth with disabilities who are making their way through our education system 

now, and in the future. Finally, with thousands of wounded American soldiers returning 

from Iraq and Afghanistan, communities need to prepare for an influx of working-age 

veterans with disabilities. Increasing economic self-sufficiency for people with disabilities will 
Final Report to the President and Congress 100 

100 

occur only when we modernize the four largest programs serving Americans with significant 

disabilities: SSI, SSDI, Medicaid, and Medicare. 

We can no longer delay modernizing our largest disability programs. These programs must 

shift from the current emphasis on inability to work and dependence on government with 

no path out of poverty to an emphasis on investment in individuals with disabilities 

promoting work and advancing self-sufficiency. 

Eight years ago, the President, Congress, and SSA agreed to invest in human potential to 

reduce or eliminate remaining barriers to employment and economic participation for people 

with significant disabilities. Today, costs and frustration increase with the slow pace of 

progress. The promise of the Ticket to Work program has yet to be realized. Even if 

implementation of the Act had moved forward with greater speed and impact, additional 

modernization is needed to balance economic security and opportunity for individuals with 

significant disabilities. 

The Panel urges Congress to take action on these recommendations and not to further delay 

a focus on a modernization that rebalances risk and aligns public policy and systems in 

support of employment and advancing economic self-sufficiency. 
Final Report to the President and Congress 101 

101 

Appendix A 

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

The Ticket to Work and Work Incentives Improvement Act (the Act), which was enacted on 

December 17, 1999, is administered by the Social Security Administration (SSA) and the 

Department of Health and Human Services (HHS). The Act increases beneficiaries’ choices 

for rehabilitation and vocational services, reduces barriers that require people with 

disabilities to choose between health care coverage and work, and ensures that more 

Americans with disabilities have opportunities to work and lessen their dependence on 

public benefits. Different provisions of the law became effective at various times, generally 

beginning one year after enactment. 

Summary of Title I—Ticket to Work and Self-Sufficiency and Related Programs

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

Subtitle A established the Ticket to Work program, under which most beneficiaries would 

receive a "ticket" that they could use to obtain vocational rehabilitation, employment, or 

other support services from an approved provider of their choice. This voluntary program 

was phased in nationally over three years. It established a program manager, Employment 

Networks (ENs), and payment systems; called for a report on the adequacy of incentives and 

the establishment of a dispute resolution mechanism; provided for suspension of continuing 

disability reviews for persons using the ticket; and established the Ticket to Work and Work 

Incentives Advisory Panel to advise the Commissioner of SSA, the President, and Congress 

on the Ticket to Work program and issues related to work incentive programs, planning and 

assistance for individuals with disabilities. 

Subtitle B—Elimination of Disincentives to Work 

Subtitle B eliminated the work activity standard as a basis for reviewing an individual's 

disability status and provided for expedited reinstatement of benefits if the person does not 

continue working. 

Subtitle C—Work Incentives Planning and Outreach 

Subtitle C set up the Work Incentives Outreach Program, including external Benefits 

Planning, Assistance, and Outreach (BPAO) programs and the internal corps of Social 

Security experts on work incentives and employment. It established a grant program for a 

protection and advocacy (P&A) agency in each state to assist beneficiaries. 
Final Report to the President and Congress 102 

102 

Summary of Title II—Expanded Availability of Health Care Services 

Title II expanded state options under Medicaid for workers with disabilities. It called for a 

General Accounting Office study on extending Medicare coverage for Social Security 

beneficiaries, and established state infrastructure grant authority and demonstration projects. 

Title II required a demonstration of coverage under Medicaid of workers with potentially 

severe disabilities and allowed disabled beneficiaries to suspend Medigap coverage. Title II 

also extended Medicare coverage to SSDI beneficiaries who are working to up to 8 1/2 

years. 

Summary of Title III—Demonstration Projects and Studies 

Title III amends Title II to provide for a permanent extension of disability insurance 

program demonstration project authority and called for specific studies and reports, 

including a demonstration study of a $1 reduction in benefits for every $2 earned. 
Final Report to the President and Congress 103 

103 

Appendix B 

The Panel

Current Panel Members 

Berthy De La Rosa-Aponte, Chair ─ Berthy De La Rosa-Aponte has been a disability 

advocate for over 20 years. She resides in Florida with her husband Milton Aponte and Luz 

Elena (Lucy), the youngest of her three children who has significant developmental 

disabilities. Mrs. De La Rosa-Aponte holds a Masters of Arts Degree and is a naturalized 

U.S. citizen, born in Colombia, South America. Her professional experience has been in the 

social service and educational fields. She has served on numerous state and local boards. 

Currently, Mrs. De La Rosa-Aponte serves as a member of the National Advisory Board on 

Improving Healthcare Services for Seniors and People With Disabilities for the 

AMERIGROUP Corporation. In addition, she serves as Vice Chair for the University of 

South Florida, University Center of Excellence For People with Developmental Disabilities 

and as a member of the local Memorial Hospital System Special Needs Advisory Board. 

Mrs. De La Rosa-Aponte was appointed to the Panel by the U.S. House of Representatives 

to serve a 4-year term ending in 2007 and designated by President George W. Bush to chair 

the Panel for a 4-year term ending in 2008. 

Cheryl Bates-Harris ─ Cheryl Bates-Harris, from Rising Sun, Maryland, is a Senior 

Disability Advocacy Specialist for the National Disability Rights Network, where she has 

over 20 years experience and expertise working with people with disabilities. She has an indepth knowledge of cross disability issues and continues to focus on employment issues of 

people with disabilities, including Vocational Rehabilitation, Social Security and Return to 

Work, Temporary Assistance for Needy Families, and other work programs that impact 

people with disabilities, including Department of Labor One-Stops. Since the passage of 

Ticket to Work and Work Incentive Improvement Act she has conducted national training 

on the Act and Vocational Rehabilitation Services and has conducted extensive training on 

the intersection issues of the Ticket to Work program with state vocational rehabilitation 

services. Cheryl currently co-chairs the Consortium for Citizens with Disabilities (CCD) 

Work Incentives Implementation Task Force and the CCD Employment and Training Task 

Force and is an active member of the CCD Social Security Task Force. President George W. 

Bush appointed her to serve on the Panel in 2004. 

Katie Beckett ─ Katie Beckett is 29 years old and currently working towards a graduate 

degree studying writing for children and young adults. Katie has been an advocate all her life 

and has done many presentations about children with health care needs before various 

audiences including Congressional committees. She is a co-founder of Kids as SelfAdvocates (KASA) and former co-chair of the KASA Board. Currently, Ms. Beckett is 

working as a volunteer Data Entry Specialist with Senator Hillary Clinton’s presidential 
Final Report to the President and Congress 104 

104 

campaign in the Cedar Rapids, IA office. The U.S. Senate appointed her to serve on the 

Panel beginning in 2002. 

Libby Child ─ Libby Child was Manager, Integrated Disability Management Services for 

Steelcase, Inc. for 25 years before resigning in December 2002 to pursue consulting, writing 

endeavors and teaching workers’ compensation classes for Michigan State University. At 

Steelcase, she was responsible for the fully integrated claims system where workers' 

compensation, short-term and long-term disability, permanent and total disability and 

compliance with the Family Medical Leave Act were fully coordinated and managed in one 

integrated unit. Since 1990, Ms. Child has lectured extensively throughout the United States 

on the topics of workers' compensation and integrated disability management and continues 

to serve on many disability related boards, commissions and councils nationally and in the 

state of Michigan, representing employers’ interests. Ms. Child is also a member of the 

National Academy of Social Insurance. She resides in Grand Rapids, MI. She was 

appointed to the Panel by President George W. Bush to serve a term starting January 2003. 

J. Russell Doumas ─ Russ Doumas has more than 34 years of experience serving 

individuals with disabilities. He is the Chief Executive Officer (CEO) for TESH, a 

community-based non-profit rehabilitation organization serving children and adults in Coeur 

d’Alene, Idaho. Prior to July 2005, he was the President of Job Point in Columbia, Missouri 

– a position he held since 1982. His responsibilities included operating a comprehensive 

employment and training center serving persons with disabilities and the economically 

disadvantaged. For ten years prior to that he was the Director of Metro Industrial Services in 

Lexington, Kentucky. Currently, he serves on the Idaho State Rehabilitation Council and as 

Secretary/Treasurer of the Idaho Association of Community Rehabilitation Programs. Mr. 

Doumas holds a M.A. in Rehabilitation Administration from the University of San Francisco 

and a B.A. in Political Science from the University of Kentucky. The U.S. House of 

Representatives appointed him to the Panel in 2005. 

Loretta Goff ─ Loretta Goff is a Registered Nurse with a B.S. in Health Care 

Administration, a M.S. in Community Mental Health Counseling and extensive experience 

with the New York State Office of Mental Hygiene and Office of Mental Retardation and 

Developmental Disabilities. In 2003, she retired from the New York State Commission on 

Quality of Care for the Mentally Disabled after 25 years of service as a Protection and 

Advocacy Specialist, where she provided oversight and advocacy for individuals with 

disabilities in New York State. Since retirement, she has served as a Compliance Evaluator in 

the Wyatt Settlement Agreement in Alabama, a member of the New York State Protection 

and Advocacy for Individuals with Mental Illness Advisory Council, and has been recently 

appointed to the New York State Commission on Quality Care and Advocacy for Persons 

with Disabilities Advisory Council. She was appointed to the Panel by the U.S. House of 

Representatives in 2005. 

Thomas P. Golden ─ Thomas P. Golden is on faculty at Cornell University and serves as 

the Associate Director of the Employment and Disability Institute in the ILR School. Since 
Final Report to the President and Congress 105 

105 

joining the faculty in 1991, he has directed several state and national initiatives focusing on 

training, technical assistance, and organizational development related to work incentives, 

transition systems change and employment for people with disabilities. Thomas is a 

founding member of the National Association of Benefits and Work Incentive Specialists 

and a member of the National Academy on Social Insurance. He currently serves on the 

Board of the U.S. International Disabilities Council, is a Trustee at Eastern Nazarene College 

in Boston, MA, and is the incoming Chair of the New York State Rehabilitation Council. 

Thomas was originally appointed to the Panel by President William Jefferson Clinton for a 

two-year term and re-appointed twice by the U.S. Senate. 

Frances Gracechild ─ When Frances Gracechild joined the disability rights movement as 

Executive Director of Resources for Independent Living in 1981, she came with a rich and 

diverse background in civil rights advocacy. Frances is passionately interested in the root 

causes of poverty. Both as an Aid to Families with Dependent Children (AFDC) social 

worker and later as a teacher in the barrio of San Bernardino she came to appreciate the day 

to day struggle of those left out of the American dream. Through her own struggle with the 

disabling effects of childhood polio, Ms. Gracechild identifies with other people reaching 

beyond oppressive stereotypes to live a life of dignity and purpose. Ms. Gracechild was 

appointed to the Panel by the U.S. House of Representatives in 2000. 

Andrew J. Imparato ─ Andrew Imparato is President and CEO of the American 

Association of People With Disabilities (AAPD). Mr. Imparato has extensive experience in 

public policy work on behalf of people with disabilities. He has served as General Counsel 

and Director of Policy with the National Council on Disability, as attorney-advisor to 

Commissioner Paul Steven Miller at the U.S. Equal Employment Opportunity Commission, 

and as Counsel to the U.S. Senate Sub-committee on Disability Policy, chaired by Senator 

Tom Harkin of Iowa. He graduated with distinction from Stanford Law School and received 

his undergraduate degree summa cum laude from Yale University. He is a member of the 

Massachusetts Bar Association. He was appointed as President and CEO of AAPD in 

November of 1999. He is nationally known as a speaker and author on disability issues 

particularly for his work to dispel myths about people with mental illness. The U. S. Senate 

re-appointed him to serve a 4-year term ending in 2008. 

David Miller ─ David Miller is the Chief Compliance officer for Communication Services 

for the Deaf (CSD) in Sioux Falls, SD. He is responsible for goal setting, organizational 

accreditation, quality assurance, performance management and policy compliance. CSD 

provides telecommunication, interpreting, educational and community support services for 

deaf and hard of hearing consumers in various locations throughout the United States. CSD 

is the nation’s largest provider of telecommunication relay services for the deaf. Mr. Miller 

was formerly the State Director of Rehabilitation Services in South Dakota and was 

responsible for administering vocational rehabilitation, independent living, personal 

attendant and disability determination services. Mr. Miller holds a masters degree in 

rehabilitation counseling and has 30 plus years of leadership experience in the development 
Final Report to the President and Congress 106 

106 

and management of large public and private disability programs. Mr. Miller was appointed to 

the Panel by the U.S. Senate in 2003. 

Dorothy Watson ─ Dorothy Watson is an independent consultant who recently retired 

from the Social Security Administration (SSA). During her lengthy career she served in a 

series of operational, staff and executive positions involving multiple programs. For over 15 

years she provided objective technical assistance on numerous disability reform proposals 

originating in the Executive and in the Legislative branch of the federal government. She 

served a stint on Capitol Hill as Professional Staff to the Senate Special Committee on Aging 

during the intense debate on SSA solvency and disability reforms. This experience provided 

a unique view of the legislative and regulatory process. Dorothy was an invited participant of 

the Disability Research Institute’s Adequacy of Incentives Advisory Group that made 

recommendations for improvements in the Ticket to Work program. She is a member of the 

National Academy of Social Insurance. President George W. Bush appointed her to a fouryear term ending in 2008. 

Torrey Westrom ─ In 1987, Torrey Westrom lost his eyesight in a farm related car accident. 

He graduated from Bemidji State University in 1995 with a B.A. in political science and a 

minor in business administration. In 1996, at the age of 23, he was elected to the Minnesota 

House of Representatives and became Minnesota's first elected blind state representative. In 

2003, he was appointed by the Speaker of the House as the Chairman of the Regulated 

Industries Committee. He served as the committee's chairman until 2007. As a 

representative, he works on a wide-array of policy issues including training/employment 

opportunities for persons with disabilities, transportation, energy and rural development 

issues. He has a J.D. from William Mitchell College of Law, is a member of the Minnesota 

Bar and owns his own law practice. He lives in Elbow Lake, MN with his wife and two 

children. President George W. Bush appointed him to the Panel in 2002. 

 

Former Panel Members 

Richard Burkhauser ─ Richard V. Burkhauser is the Sarah Gibson Blandings Professor of 

Public Policy in the Department of Policy Analysis and Management, Cornell University. His 

professional career has focused on how public policies affect the economic behavior and 

well-being of vulnerable populations, e.g., people with disabilities, older persons, and lowskilled workers. He has published widely on these topics in journals of demography, 

economics, gerontology, and public policy. As Co-Principal Investigator of the National 

Institute on Disability and Rehabilitation Research (NIDRR) Center for Economic Research 

on Employment Policy for Persons with Disabilities and the Co-Principal Investigator of the 

NIDRR Center on Disability Demographics and Statistics, he has carried out an extensive 

program of technical assistance and presentations to government agencies, policymakers and 

consumers on the employment and economic well-being of people with disabilities. Mr. 

Burkhauser received his Ph.D. in Economics from the University of Chicago in 1976. He 

was appointed to the Panel by the U.S. Senate to serve from 2000 to 2002. 
Final Report to the President and Congress 107 

107 

Kristin Flaten ─ Kristin Flaten lives in St. Paul, Minnesota. She is the owner of 

INITIATIVES, a small business dedicated to enhancing the lives of persons with mental 

illnesses through providing educational services, advocacy, benefit analysis, and access to 

health care. She has consulted for SSA and other federal agencies on disability issues. Ms. 

Flaten conducts many speaking engagements on mental illnesses, recovery, suicide 

prevention, SSA programs, and health care benefits. Her audiences include community 

groups, churches, and county staff. In addition, Ms. Flaten provides testimony to the 

Minnesota legislature and at public hearings. Also, she provides individual advocacy 

concerning benefits and access to health care. She was appointed by President William 

Jefferson Clinton to serve on the Panel from 2000 to 2002. 

Christine M. Griffin ─ Christine M. Griffin was sworn in on January 3, 2006 as a 

Commissioner of the U.S. Equal Employment Opportunity Commission (EEOC). Ms. 

Griffin’s work experience in labor and employment law includes positions in both the public 

and private sectors. Most recently, she served as the Executive Director of the Disability 

Law Center in Boston from 1996 to 2005. The Law Center provides legal advocacy on 

disability issues that promote the fundamental rights of all people with disabilities to 

participate fully and equally in the social and economic life of Massachusetts. As Executive 

Director, she provided leadership for the Law Center’s 25 employees and conducted its 

overall management, including programmatic and fiscal planning, priority setting and 

implementation, and fundraising. A native of Boston, Ms. Griffin is a graduate of the 

Massachusetts Maritime Academy and served as its Interim President from 1993 to 1994. 

She is also a graduate of Boston College Law School and, upon graduation, was awarded a 

Skadden Arps Fellowship at the Disability Law Center. Ms. Griffin was appointed by 

President William Jefferson Clinton and served on the Panel from 2000 to 2004. 

Larry Henderson ─ Larry Henderson has been employed as the Executive Director of 

Independent Resources, Inc., a center for independent living, for the past 13 years. He has 

been active in the disability field for almost 20 years. He is the past Chair of the State 

Independent Living Council as well as the Developmental Disabilities Council, where he still 

chairs the Adult Issues Committee. He has acted as a consultant and trainer for the 

Rehabilitation Research and Training Center on Independent Living Management in the 

development of their Executive Management Simulation, and often serves as a consultant 

for the Department of Education, Rehabilitation Services Administration grant review 

teams. He was appointed by the U.S. Senate and served as one of the original 12 members of 

the Panel. 

Jerome Kleckley ─ Jerome Kleckley, MSW, LMSW is a United States Navy veteran and has 

been a valuable staff member at United Spinal Association since joining as a social work 

intern in 1992. Mr. Kleckley has served as Housing Coordinator, Medical Transportation 

Program Coordinator and, from 1997 to January 2007, as Director of Social Services. He is 

presently the Vice President of Social Services and National Peer Mentor Coordinator. He is 

currently spearheading development and implementation of United Spinal’s new Peer 

Support Network, which includes an innovative Peer Mentor Program, a Peer Mentor 
Final Report to the President and Congress 108 

108 

Support Group, Spinal Cord Injury Resource Materials, and a Network Data Base. Mr. 

Kleckley holds a master’s degree in social work from Fordham University and a bachelor’s 

degree from York College. He lives New City, New York. He was appointed by the U.S. 

House of Representatives to serve on the Panel from 2000 to 2005. 

Stephanie Smith Lee ─ Stephanie Smith Lee has thirty years of experience in public policy, 

including serving as Director of the Office of Special Education Programs (OSEP) in the 

U.S. Department of Education, in senior Congressional staff positions, as a foundation 

administrator, and as a nationally recognized disability parent leader. Since her daughter, 

Laura, was born with Down syndrome in 1982, she has organized and led successful 

bipartisan, collaborative efforts to improve special education and disability policy at the local, 

state, and federal levels. As OSEP Director from 2002 through March 2005, Ms. Lee 

directed the policy development, program planning, monitoring, evaluation, research and 

implementation of the Federal special education law. She provided leadership in focusing 

OSEP’s work on accountability for results, reforming the monitoring system, promoting 

inclusion and the use of universal design principles, improving early childhood education, 

and promoting improved transition and postsecondary results for students with disabilities. 

Ms. Lee also provided leadership in the development of the No Child Left Behind Act 

regulations, guidance, and implementation related to students with disabilities. Ms. Lee was 

appointed by the U.S. Senate to serve on the Panel from 2000-2002. 

Bryon MacDonald ─ Bryon MacDonald is founder and Program Manager of the California 

World Incentives Initiative (CWII) at the World Institute on Disability (WID). He manages 

WID’s team of Disabilities Benefits 101 benefit program analysts and technology experts. 

Since 2000, the program has supported public policy education activities and provides multimedia information services on health, benefits, work and disability. Prior to his current 

position, Mr. MacDonald was a consultant and a Community Advocate for the Center for 

Independent Living Berkeley/Oakland. He served as a Mental Health Advocate from 1990 

to 1996 at the Mental Health Association of Alameda County. Mr. MacDonald received his 

B.A. in English from Fordham University. President William Jefferson Clinton appointed 

him to the Panel from 2000-2004. 

Sarah W. Mitchell ─ Sarah W. Mitchell, R.N., M.S.W., J.D., is Executive Director/CEO of 

New Jersey Protection and Advocacy, Inc., the designated P&A system for people with 

disabilities in New Jersey. Prior to this she taught nursing at the University of Michigan, 

served as Assistant Dean at Rutgers Law School and as an associate at the Philadelphia law 

firm of Dechert, and clerked on the Third Circuit Court of Appeals. Ms. Mitchell is a past 

president of the National Association of Protection and Advocacy Systems and a past 

member of the American Bar Association’s Commission on Mental and Physical Disability 

Law. President William Jefferson Clinton appointed her to a four-year term as the first 

Chair of the Panel. Her term ended in 2004. 

Vincent Randazzo ─ Vincent Randazzo is a Senior Vice President and the Director of 

Government Relations for Wachovia Corporation in Charlotte, North Carolina, where he is 
Final Report to the President and Congress 109 

109 

responsible for formulating and directing all activities relating to federal and state legislation 

and public policies relating to the company and its lines of business. Prior to joining 

Wachovia in November 2003, Mr. Randazzo spent two years as the Director of Public Policy 

for the Washington, D.C.-based Business Roundtable, an association of chief executive 

officers of leading U.S. companies. He was responsible for the strategic development and 

management of federal legislative and regulatory issues and programs, including fiscal policy, 

civil justice reform and health and retirement policy. Mr. Randazzo is a graduate of Eastern 

Michigan University with a Bachelor of Science degree in political science and George 

Mason University with a Master of Arts degree in economics. He is the parent of a child 

with developmental disabilities. He was appointed by the U.S. Senate to serve on the Panel 

from 2002 to 2003. 

Stephen Start ─ In 1979 Stephen Start founded and, until his retirement in 2007, 

successfully managed SL Start. He has a Bachelor of Science degree in Psychology, and is a 

Certified Vocational Evaluator and Certified Rehabilitation Counselor. Mr. Start has 30 years 

of multi-state experience in employment and provision of vocational rehabilitation services, 

and is a presenter and author of numerous articles. Mr. Start co-founded and co-chaired the 

Return to Work Coalition of providers and advocates that formed with the single purpose of 

promoting legislative reform for SSA's disability programs return to work policies. This 

group had a major impact on the development and passage of the Ticket to Work and Work 

Incentive Improvement Act of 1999. Mr. Start was appointed by the U.S. House of 

Representatives to be a member of the Panel from 2000 to 2004. 

Susan Webb ─ Susan Webb has 33 years of personal experience with a significant disability 

and is a former beneficiary of Social Security Disability Insurance. Susan left the rolls in 

1977 to pursue a career. She worked for 12 years as a telecommunications professional with 

AT&T, during which she acquired a B.S. in Industrial and Organizational Psychology and 

later an M.B.A. Susan is a certified Senior Professional in Human Resources (SPHR) and 

Director of ABIL Employment Services (AES) in Phoenix, Arizona. AES is contracted by 

SSA as an Employment Network (EN) under the Ticket to Work program and is one of the 

top-producing ENs in the country. Ms. Webb is President of the National Employment 

Network Association and was appointed by the U. S. House of Representatives to the Panel 

from 2000 to 2002. 

Panel Staff 

Jill Houghton, Executive Director 

Michael Anzick 

Shirletta Banks 

Patricia Laird 

Jenn Rigger 

Debra Tidwell-Peters 
Final Report to the President and Congress 110 

110 
Final Report to the President and Congress 111 

111 

Appendix C 

Tables – Panel Recommendations 

Ticket to Work and Work Incentives Advisory Panel 

 Recommendations from December 1999 - December 2007 

Table 1: NO FINAL ACTION TAKEN 

Issue Recommendation Date Source Submitted To Relevance 

Requires Legislative Action and Granting of Statutory Authority 

SSA reporting Congress should pass a 

technical amendment to 

require interim reporting 

June 18, 2002 Advice 

Report on 

the 

Adequacy 

of 

Incentives 

(AOI) 

Study 

Congress No longer relevant

AOI Extend deadline for 

Adequacy of Incentives 

Report 

June 18, 2002 Advice 

Report on 

the 

Adequacy 

of 

Incentives 

(AOI) 

Study 

Congress No longer relevant

Public 

education and 

field training 

Congress should direct 

SSA to spend more on 

public education and 

field training 

August 2002 Advisory 

Panel 

Annual 

Report: 

Year Two

Congress Relevant 

$1 for $2 

Demo 

$1 for $2 benefit offset: 

Congress should amend 

statute to allow deferred 

research on induced 

entry 

August 2002 Advisory 

Panel 

Annual 

Report: 

Year Two

Congress Relevant 

Benefit 

payments 

Reiterate the 2001 

recommendations to 

authorize benefits 

payments for reductions 

in benefits 

May 2003 Annual 

Report: 

Year Three

Congress No longer relevant
Final Report to the President and Congress 112 

112 

Issue Recommendation Date Source Submitted To Relevance 

Program 

integration 

Conduct review and 

comparison of the 

Ticket to Work and 

Work Incentives 

Improvement Act and 

the Social Security Act 

and the Rehabilitation 

Act during upcoming 

reauthorization of the 

Rehabilitation Act and 

take action on 

inconsistencies 

May 2003 Annual 

Report: 

Year Three

Congress Relevant 

Training & 

Technical 

Assistance 

Congress should provide 

financial resources for a 

dedicated corps of work 

incentive specialists 

(such as ESRs) 

May 2003 Annual 

Report: 

Year Three

Congress Relevant 

Program 

integration 

and training 

& 

Technical 

Assistance 

Congress should direct 

SSA to work closely 

with other Federal and 

State systems to develop 

a national training plan 

and with Congress to 

earmark funding 

May 2003 Annual 

Report: 

Year Three

Congress Relevant 

EN Congress should 

develop statutory 

language that articulates 

its original intent that 

the Ticket is a 

supplemental funding 

source 

Feb. 2004 Advice 

Report on 

Employment 

Networks

Congress No longer relevant

EN Congress should direct 

Commissioner to 

implement Ticket to 

Work program as a 

complement to SSA VR 

Reimbursement 

Program 

Feb. 2004 Advice 

Report on 

Employment 

Networks

Congress No longer relevant

EN Amend statute to permit 

Ticket to Work program 

to increase sum of 

payments for serving 

SSI recipients to level 

equal to sum of 

payments for serving 

SSDI beneficiaries 

Feb. 2004 Advice 

Report on 

Employment 

Networks

Congress No longer relevant
Final Report to the President and Congress 113 

113 

Issue Recommendation Date Source Submitted To Relevance 

EN Commissioner and 

Congress make clear 

that payments to ENs 

should supplement 

funding from other 

public programs, 

consistent with AOI 

group recommendations 

Feb. 2004 Advice 

Report on 

Employment 

Networks

Commissioner 

and 

Congress 

Relevant 

EN Congress should amend 

statute to permit 

American Indian VR 

programs to be ENs 

without application and 

be eligible for SSA 

reimbursement program 

Feb. 2004 Advice 

Report on 

Employment 

Networks

Congress Relevant 

BPAO Increase the amount of 

resources allocated to 

the national network. 

Feb. 2005 Annual 

Report: Yr. 

6, Advisory 

Letter 

Associate 

Commissioner 

Relevant 

In RFA, SSA 

anticipated min. 

awards of $100,000 

for individ. state 

WIPA projects 

(Min. awards for 

territories remain at 

$50,000) and a max. 

of $300,000 

available to fund 

specific WIPA 

projects annually. 

BPAO Remove the individual 

awards cap for projects 

to ensure that programs 

based in rural settings 

have the resources they 

need to provide 

equitable services to 

their urban and 

metropolitan 

counterparts 

Feb. 2005 Annual 

Report: Yr. 

6, Advisory 

Letter 

Associate 

Commissioner 

Relevant 

Renewal of 

SSA’s Demo 

Authority 

Renewal of SSA’s 

demonstration authority 

to begin new 

demonstration projects 

Dec. 2005 Annual 

Report: Yr. 

6, Advisory 

Letter 

Congressman 

McCrery and 

Senator Grassley 

Relevant 
Final Report to the President and Congress 114 

114 

Issue Recommendation Date Source Submitted To Relevance 

Requires Promulgation of Regulations, an Administrative Change, or Program Coordination 

Dispute 

resolution 

All decisions made by 

SSA in reference to 

disputes should be 

subject to external 

review 

July 23, 2001 Final 

Advice 

Report on 

Ticket to 

Work 

program 

Notice of 

Proposed 

Rule 

Making 

Commissioner Relevant 

Dispute 

resolution 

Information on P&A 

services should be 

accessible to 

beneficiaries 

July 23, 2001 Final 

Advice 

Report on 

Ticket to 

Work 

program 

Notice of 

Proposed 

Rule 

Making 

Commissioner Relevant, 

Information 

currently available 

via letter, IWP 

Dispute 

resolution 

Beneficiary's filing 

complaints with project 

manager against EN 

should trigger a notice 

to P&A 

July 23, 2001 Final 

Advice 

Report on 

Ticket to 

Work 

program 

Notice of 

Proposed 

Rule 

Making 

Commissioner Relevant 

None 

Dispute 

resolution 

All notices should be in 

an accessible format 

July 23, 2001 Final 

Advice 

Report on 

Ticket to 

Work 

program 

Notice of 

Proposed 

Rule 

Making 

Commissioner Relevant 
Final Report to the President and Congress 115 

115 

Issue Recommendation Date Source Submitted To Relevance 

Dispute 

resolution 

SSA should establish 

specified timeline for 

dispute resolution 

outlined 

July 23, 2001 Final 

Advice 

Report on 

Ticket to 

Work 

program 

Notice of 

Proposed 

Rule 

Making 

Commissioner Relevant 

Dispute 

resolution 

During appeals process, 

beneficiaries should 

receive the same level of 

support and service 

July 23, 2001 Final 

Advice 

Report on 

Ticket to 

Work 

program 

Notice of 

Proposed 

Rule 

Making 

Commissioner Relevant 

Benefits SSA should interpret 

benefits not payable as a 

reduction in benefits 

July 23, 2001 Final 

Advice 

Report on 

Ticket to 

Work 

program 

Notice of 

Proposed 

Rule 

Making 

Commissioner Relevant 

EN Payment SSA should address 

efficacy of individualized 

milestones in AOI 

report 

July 23, 2001 Final 

Advice 

Report on 

Ticket to 

Work 

program 

Notice of 

Proposed 

Rule 

Making 

Commissioner No longer relevant.

Ticket to 

Work 

program 

evaluation 

SSA should commission 

a full-cost benefit study 

to evaluate program 

July 23, 2001 Final 

Advice 

Report on 

Ticket to 

Work 

program 

Notice of 

Proposed 

Rule 

Making 

Commissioner No longer relevant
Final Report to the President and Congress 116 

116 

Issue Recommendation Date Source Submitted To Relevance 

Alternate 

plans 

SSA should permit other 

service delivery plans to 

be used as a substitute 

for IWP 

July 23, 2001 Final 

Advice 

Report on 

Ticket to 

Work 

program 

Notice of 

Proposed 

Rule 

Making 

Commissioner No longer relevant

AOI Establish ongoing 

structure for review of 

emerging information 

for AOI 

June 18, 2002 Advice 

Report on 

the 

Adequacy 

of 

Incentives 

(AOI) 

Study 

Commissioner Relevant 

SSA reporting SSA to provide Panel, 

Congress, and President 

with ongoing interim 

reporting 

June 18, 2002 Advice 

Report on 

the 

Adequacy 

of 

Incentives 

(AOI) 

Study 

Commissioner No longer relevant

AOI Identifying the four 

groups: SSA should use 

other data sources 

June 18, 2002 Advice 

Report on 

the 

Adequacy 

of 

Incentives 

(AOI) 

Study 

Commissioner Relevant 

AOI - EN 

and data 

SSA should identify data 

elements ENs should 

collect for AOI 

June 18, 2002 Advice 

Report on 

the 

Adequacy 

of 

Incentives 

(AOI) 

Study 

Commissioner Relevant 

$1 for $2 

Demo 

Deferring the induced 

entry evaluation in $1 

for $2 demonstration 

August 2002 Advice 

Report on 

$1 for $2 

Benefit 

Offset 

Research 

Commissioner No longer relevant
Final Report to the President and Congress 117 

117 

Issue Recommendation Date Source Submitted To Relevance 

$1 for $2 

Demo 

Induced entry evaluation 

proposal should include 

at least five independent 

designs from outside 

experts 

August 2002 Advice 

Report on 

$1 for $2 

Benefit 

Offset 

Research 

Commissioner No longer relevant

$1 for $2 

Demo 

Induced entry should 

follow and report on 

parallel research projects 

across the country that 

analyze determinants of 

return to work 

August 2002 Advice 

Report on 

$1 for $2 

Benefit 

Offset 

Research 

Commissioner No longer relevant

Access to 

ticket - youth 

Transition-aged youth 

should be eligible for 

tickets 

August 2002 Advisory 

Panel 

Annual 

Report: 

Year Two

Commissioner Relevant 

Wage 

reporting 

Process monthly earning 

reports without 

generating overpayments 

August 2002 Advisory 

Panel 

Annual 

Report: 

Year Two

Commissioner Relevant 

AOI Adequacy of incentives: 

delay report to Congress 

and get interim reports 

from SSA 

August 2002 Advisory 

Panel 

Annual 

Report: 

Year Two

Congress No longer relevant

Marketing 

and public 

education 

Urge SSA to develop 

immediate national 

marketing and public 

education campaign to 

explain available 

programs 

May 2003 Annual 

Report: 

Year Three

Congress Relevant (see action 

on marketing in 

Annual Report: Year 

Two) 

VR SSA and RSA should 

formulate joint policy 

governing the contents 

of VR-EN agreements 

and disseminate a model 

agreement 

Oct. 21, 2003 Advisory 

Letter 

Assistant 

Secretary Robert 

Pasternack 

Relevant 

EN Commissioner should 

conduct an assessment 

of the Ticket to Work 

program and State VR 

Program running in 

combination 

Feb. 2004 Advice 

Report on 

Employment 

Networks

Commissioner Relevant 
Final Report to the President and Congress 118 

118 

Issue Recommendation Date Source Submitted To Relevance 

EN Test two or three 

creative approaches that 

increase EN and 

beneficiary participation 

Feb. 2004 Advice 

Report on 

Employment 

Networks

Commissioner Relevant 

EN Panel and 

Commissioner should 

convene meeting with 

stakeholders to develop 

national training and 

communication 

conference for all ENs 

Feb. 2004 Advice 

Report on 

Employment 

Networks

Commissioner No longer relevant

Marketing, 

Public 

Education, 

Training 

SSA immediately launch 

a national campaign for 

public education and 

training on the Ticket to 

Work program, SSDI 

and SSI work incentives 

and related employment 

support programs and 

services especially for 

SSA field staff. 

May 2004 Annual 

Report: Yr. 

5, Advisory 

Letter 

Commissioner Relevant 

BPAO Require response 

/acknowledgment to the 

beneficiary within a 

specified period of time 

say 24 hours 

Feb. 2005 Annual 

Report: Yr. 

6, Advisory 

Letter 

Associate 

Commissioner 

Relevant 

BPAO Provide a point of 

contact so that 

individuals having 

difficulty receiving 

services from BPAO can 

let SSA know about the 

specific reason for 

example, no response at 

all or long wait for an 

appointment 

Feb. 2005 Annual 

Report: Yr. 

6, Advisory 

Letter 

Associate 

Commissioner 

Relevant 
Final Report to the President and Congress 119 

119 

Issue Recommendation Date Source Submitted To Relevance 

BPAO Continue to use a 

national core 

competency-based 

curriculum that 

establishes minimum 

standards for effective 

service delivery and 

ethical considerations 

when preparing benefits 

specialists for the field 

and that they have 

access to ongoing 

technical support 

Feb. 2005 Annual 

Report: Yr. 

6, Advisory 

Letter 

Associate 

Commissioner 

Relevant 

BPAO Provide an incentive to 

BPAO programs and 

ENs for working 

together to promote 

employment success 

Feb. 2005 Annual 

Report: Yr. 

6, Advisory 

Letter 

Associate 

Commissioner 

Relevant 

PASS -- 

Reasonable 

length of time 

to achieve 

goal 

Provide specific 

examples as well as 

further delineating that 

“reasonable period” for 

completion of a PASS 

will depend in large part 

on the impact of the 

individual’s impairment 

on their stated goal(s) 

September 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM July 

11, 2005 

Commissioner Relevant 

PASS 

Referrals 

SSA refine its policies to 

clarify when it will refer, 

to what type of 

organizations/individual

s to which it will refer, 

and what level of 

support applicants can 

expect SSA/PASS 

Cadre, BPAOs, 

Independent Living 

Centers, ENs and so 

forth to provide 

September 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM July 

11, 2005 

Commissioner Relevant 

PASS 

Plan ending 

date 

SSA expand on what is 

intended under the 

NPRM and specifically 

address the issue of SSA 

providing what seems to 

be special assistance that 

is limited to establishing 

an ending date 

September 2005 Annual 

Report: Yr. 

6, Advisoy 

Letter Re.

NPRM July 

11, 2005 

Commissioner Relevant 
Final Report to the President and Congress 120 

120 

Issue Recommendation Date Source Submitted To Relevance 

PASS 

Occupation-al 

Goals 

Panel supported 

continuation of 

credentialing policy. 

However, recommended 

SSA clarify what weight, 

if any, will be given to 

occupational goals 

developed with 

assistance of BPAOs 

and others, for example, 

Small Business 

September 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM July 

11, 2005 

Commissioner No longer relevant; 

SSA added language 

defining feasible 

employ. goal as “is 

one that you have a 

reasonable 

likelihood of 

achieving.” And it 

created 2 new sect. 

to explain “a viable 

plan” 

PASS 

Annual 

review of plan 

SSA expand on what the 

annual review entails 

and how it is conducted. 

Further, SSA consider 

providing more details 

and an example of what 

the beneficiary can 

expect. Finally, that 

PASS specialists 

customize timelines for 

progress reviews based 

on the specific support 

needs of the beneficiary 

September 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM July 

11, 2005 

Commissioner Relevant 

PASS - 

General 

SSA 1) provide 

additional training for 

the PASS Cadre; 2) 

review the 

implementation policies 

in selected States to 

assess ways to increase 

PASS participation; and 

3)explore strategies to 

maximize utilization of 

PASS and other work 

incentives and consider 

how the Ticket to Work 

and PASS Programs can 

better complement each 

other 

September 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM July 

11, 2005 

Commissioner Relevant 

Admin. 

Review 

Process – 

Disability 

Claims 

SSA communicate a 

return to work 

philosophy in all stages 

of the disability 

determination process, 

especially in the early 

stages 

October 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM July 

27, 2005 

Commissioner Relevant 
Final Report to the President and Congress 121 

121 

Issue Recommendation Date Source Submitted To Relevance 

Admin. 

Review 

Process – 

Disability 

Claims 

Disability Program 

Policy Council: SSA 

develop a procedure for 

adding a member to 

represent beneficiaries 

October 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM July 

27, 2005 

Commissioner Relevant 

Admin. 

Review 

Process – 

Disability 

Claims 

Federal Reviewing 

Officials: the final rule 

be written broadly 

enough to allow SSA to 

also hire paralegals or 

other legal professionals 

with specified 

qualifications. We 

propose that SSA certify 

that these other legal 

professionals are 

qualified using a process 

like that which is 

proposed to certify 

members of the national 

network of experts in 

the Federal Expert Unit 

October 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM July 

27, 2005 

Commissioner Relevant 

Admin. 

Review 

Process – 

Disability 

Claims 

Use of standardized 

decision writing formats: 

Beneficiaries and 

advocates participate in 

the drafting of these 

standardized formats 

and that "plain 

language" be used 

October 2005 Annual 

Report: Yr. 

6, Letter Re.

NPRM July 

27, 2005 

Commissioner No longer relevant

Access to 

ticket 

All SSI and SSDI adult 

beneficiaries including 

those designated as 

medical improvement 

expected should be 

eligible to participate in 

program 

July 23, 2001 Final 

Advice 

Report on 

Ticket to 

Work 

program 

Notice of 

Proposed 

Rule 

Making 

Commissioner Relevant, Sept. 2005 

NPRM on Ticket to 

Work program 

allows those with 

MIE to eligible 

EN Congress and SSA 

review EN payment 

system to adjust and 

enrich 

May 2003 Annual 

Report: 

Year Three 

Congress Relevant, NPRM 

Sept. 2005 includes 

this 
Final Report to the President and Congress 122 

122 

Issue Recommendation Date Source Submitted To Relevance 

Access to 

ticket 

Make Ticket to Work 

program available for all 

beneficiaries 

Dec. 17, 1999–

December 16, 

2000 

Annual 

Interim 

Progress 

Report: 

Year One 

Commissioner Relevant, Waiting 

on final regulations 

per NPRM Sept. 

2005 

Access to 

ticket 

All SSI and SSDI adult 

beneficiaries including 

those designated as 

medical improvement 

expected should be 

eligible to participate in 

program 

July 23, 2001 Final 

Advice 

Report on 

Ticket to 

Work 

program 

Notice of 

Proposed 

Rule 

Making 

Commissioner Relevant, Sept. 2005 

NPRM on Ticket to 

Work program 

allows those with 

MIE to eligible 

Access to 

ticket 

SSA should conduct 

cost-benefit analysis on 

beneficiary receiving 

more than 1 ticket per 

period of disability/ 

entitlement 

July 23, 2001 Final 

Advice 

Report on 

Ticket to 

Work 

program 

Notice of 

Proposed 

Rule 

Making 

Commissioner Relevant, No cost 

benefit analysis per 

NPRM Sept. 2005

Timely 

progress 

Timely progress should 

be defined by terms and 

conditions of IWP 

July 23, 2001 Final 

Advice 

Report on 

Ticket to 

Work 

program 

Notice of 

Proposed 

Rule 

Making 

Commissioner Relevant 

NPRM Sept. 2005 

addressed this issue; 

waiting for final 

regulations 

EN Payment SSA should develop two 

milestone/outcome 

systems—one for SSI 

and one for SSDI 

July 23, 2001 Final 

Advice 

Report on 

Ticket to 

Work 

program 

Notice of 

Proposed 

Rule 

Making 

Commissioner Relevant 

NPRM Sept. 2005 

addressed this issue; 

waiting for final 

regulations. 
Final Report to the President and Congress 123 

123 

Issue Recommendation Date Source Submitted To Relevance 

Ticket 

assignment 

SSA should clarify that 

SSA beneficiary has 

choice about assigning 

ticket to State VR 

July 23, 2001 Final 

Advice 

Report on 

Ticket to 

Work 

program 

Notice of 

Proposed 

Rule 

Making 

Commissioner Relevant 

NPRM Sept. 2005 

addressed this issue; 

waiting for final 

regulations 

Access to 

ticket - MIE 

Beneficiaries designated 

as medical improvement 

expected should be 

eligible for tickets 

August 2002 Advisory 

Panel 

Annual 

Report: 

Year Two 

Commissioner Relevant 

NPRM Sept. 2005 

addressed this issue; 

waiting for final 

regulations 

Ticket 

assignment 

Amend Transmittal 17 

to end the current use of 

signed State VR IPE as 

documentation needed 

for assignment of ticket 

Oct. 21, 2003 Advisory 

Letter 

Deputy 

Commissioner 

Martin Gerry 

Relevant 

NPRM Sept. 2005 

addressed this issue; 

waiting for final 

regulations 

VR payment Cost reimbursement 

should be separate from 

the Ticket to Work 

program 

Oct. 21, 2003 Advisory 

Letter 

Deputy 

Commissioner 

Martin Gerry 

Relevant 

NPRM Sept. 2005 

addressed this issue; 

waiting for final 

regulations 

Ticket use Ticket should not be 

considered a comparable 

benefit under Title I of 

the Rehabilitation Act 

October 21, 

2003 

Advisory 

Letter 

Assistant 

Secretary Robert 

Pasternack 

(Justesen for 

Pasternack) 

Relevant, pending 

final regulations. 

RSA interprets 

Ticket services that 

an EN provides that 

are similar to VR 

services as a comp. 

benefit and thus not 

avail. under Title I 

EN Modify EN payment 

system to move more 

payment up front 

Feb. 2004 Advice 

Report on 

Employment 

Networks 

Commissioner Relevant 

NPRM Sept. 2005 

addressed this issue; 

waiting for final 

regulations 

EN Commissioner 

implement modified EN 

payment system 

consistent with 

recommendations of 

AOI Advisory Group 

Feb. 2004 Advice 

Report on 

Employment 

Networks 

Commissioner Relevant 

NPRM Sept. 2005 

addressed this issue; 

waiting for final 

regulations 
Final Report to the President and Congress 124 

124 

Issue Recommendation Date Source Submitted To Relevance 

EN Commissioner should 

implement the Panel's 

recommendations 

related to payment 

systems and claims 

administration 

Feb. 2004 Advice 

Report on 

Employment 

Networks 

Commissioner Relevant NPRM 

Sept. 2005 

addressed this issue; 

waiting for final 

regulations 

EN Commissioner should 

refine EN payment 

processing time to meet 

business standards 

Feb. 2004 Advice 

Report on 

Employment 

Networks 

Commissioner Relevant NPRM 

Sept. 2005 

addressed this issue; 

waiting for final 

regulations 

Amend. to 

Ticket to 

Work 

program – 

NPRM Sept. 

2005 

All SSI and SSDI adult 

beneficiaries including 

those designated as 

medical improvement 

expected should be 

eligible to participate in 

program 

Dec. 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM 

Sept. 2005

Commissioner Relevant 

Allows those with 

MIE to be eligible; 

waiting for final 

regulations 

Amend. to 

Ticket to 

Work 

program – 

NPRM Sept. 

2005 

EN payments should be 

more frequent and 

earlier 

Dec. 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM 

Sept. 2005

Commissioner Relevant 

Revised payment 

system; waiting for 

final regulations 

Amend. to 

Ticket to 

Work 

program – 

NPRM Sept. 

2005 

Equalizing payment 

amount for SSI and DI 

beneficiaries 

Dec. 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM 

Sept. 2005

Commissioner Relevant 

Proposed; waiting 

for final regulations

Amend. to 

Ticket to 

Work 

program – 

NPRM Sept. 

2005 

It appears that under the 

right scenario an EN 

could receive up to 

$7,000 of their milestone 

payments within three 

months and over half of 

the ticket payments 

within the first year. 

This could leave a 

financial disincentive to 

continue serving a 

beneficiary under this 

example after the first 

year. SSA should review 

the lump sum milestone 

payment provision to 

ensure that beneficiaries 

do not lose this 

protection. 

Dec. 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM 

Sept. 2005

Commissioner Relevant Waiting for 

final regulations 
Final Report to the President and Congress 125 

125 

Issue Recommendation Date Source Submitted To Relevance 

Amend. to 

Ticket to 

Work 

program – 

NPRM Sept. 

2005 

Beneficiary should be 

eligible for more than 

one ticket in a period of 

entitlement for 

SSDI/SSI benefits when 

their disability is likely to 

require some indefinite 

supports to remain 

employed (including 

self-employment) 

Dec. 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM 

Sept. 2005

Commissioner Relevant Clarified; 

waiting for final 

regulations 

Amend. to 

Ticket to 

Work 

program – 

NPRM Sept. 

2005 

SSA clarify that 

proposed rule changes 

apply for both “new” 

and “old” tickets and 

implements appropriate 

measures to transition 

the “old” tickets to new 

rules 

Dec. 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM 

Sept. 2005

Commissioner Relevant Waiting for 

final regulations 

Amend. to 

Ticket to 

Work 

program – 

NPRM Sept. 

2005 

Proposed new rules will 

require additional 

training of ENs, VR, 

and beneficiaries. The 

Panel urges SSA to be 

sure the necessary 

measures are in place to 

educate all appropriate 

parties of the changes 

and how they work 

Dec. 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM 

Sept. 2005

Commissioner Relevant Waiting for 

final regulations 

Amend. to 

Ticket to 

Work 

program – 

NPRM Sept. 

2005 

SSA establish a crossfederal agency task force 

on transition to develop 

unified school-to-work 

system that removes 

conflicting incentives 

Dec. 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM 

Sept. 2005

Commissioner Relevant 

Waiting for final 

regulations 

Amend. to 

Ticket to 

Work 

program – 

NPRM Sept. 

2005 

Urge expeditious 

implementation of these 

new rule changes to help 

reignite the level of 

interest in the Ticket to 

Work program by ENs 

and beneficiaries 

Dec. 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM 

Sept. 2005

Commissioner Relevant Waiting for 

final regulations 

Issuance of 

Receipts – 

Reporting of 

changes in 

work or 

earnings 

SSA to continue 

automatically issuing 

receipts after its 

centralized computer file 

is fully operational 

May 2006 Annual 

Report: Yr. 

7, Advisory 

Letter 

Commissioner Relevant 

Waiting for final 

regulations 
Final Report to the President and Congress 126 

126 

Issue Recommendation Date Source Submitted To Relevance 

Amend. to 

Ticket to 

Work 

program – 

NPRM Sept. 

2005 

Permitting beneficiary to 

be own EN 

Dec. 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM 

Sept. 2005

Commissioner Relevant 

Amend. to 

Ticket to 

Work 

program – 

NPRM Sept. 

2005 

Beneficiary should be 

eligible for more than 

one ticket in a period of 

entitlement for 

SSDI/SSI benefits when 

their disability is likely to 

require some indefinite 

supports to remain 

employed (including 

self-employment) 

Dec. 2005 Annual 

Report: Yr. 

6, Advisory 

Letter Re.

NPRM 

Sept. 2005

Commissioner Relevant 

Clarified; waiting 

for final regulations

Final regs. per 

NPRM Sept. 

2005 

Issuing the final 

regulations as soon as 

possible, but not later 

than this fall (2006) 

Sept. 2006 Advisory 

Letter 

Commissioner No longer relevant

Final regs. per 

NPRM Sept. 

2005 

Reconsider the decision 

to delay release of the 

final Ticket to Work 

regulations and note that 

this delay also affects the 

Agency’s plan to market 

the Ticket to Work 

program, along with 

work incentives 

programs 

Nov. 2006 Advisory 

Letter 

Commissioner No longer relevant

NPRM, July 

2007 

SSA must clearly 

communicate to 

beneficiaries that they’ll 

be required to 

demonstrate timely 

progress in 12 months 

instead of 24 months as 

currently required, 

before it has a negative 

impact on their planned 

goals 

Oct. 2007 Advisory 

Letter 

Commissioner Relevant 
Final Report to the President and Congress 127 

127 

Issue Recommendation Date Source Submitted To Relevance 

NPRM, July 

2007 

SSA should include 

provisions in the 

proposed amendments 

to account for disabilityrelated stumbling blocks, 

such as an inability to 

get needed supports and 

accommodations 

Oct. 2007 Advisory 

Letter 

Commissioner Relevant 

NPRM, July 

2007 

SSA should provide a 

larger threshold for 

beneficiaries who may 

require a longer period 

of time to complete 

their educational studies 

Oct. 2007 Advisory 

Letter 

Commissioner Relevant 

NPRM, July 

2007 

SSA should include 

training programs of the 

Department of Veterans 

Affairs and the 

Department of 

Education under the 

definition of “vocational 

or technical training 

programs.” This should 

include disability-specific 

training, such as 

orientation and mobility, 

Braille, assistive 

technology, and similar 

skills necessary for 

vocational functioning 

Oct. 2007 Advisory 

Letter 

Commissioner Relevant 

NPRM, July 

2007 

Timely progress should 

be individualized based 

on the terms and 

conditions of the 

IPE/IWP and 

accommodate episodic 

disabilities. It should be 

possible for the 

IPE/IWP to be revised 

and updated as the 

needs and circumstances 

of the individual changes 

– both for 

postsecondary education 

and vocational/technical 

training 

Oct. 2007 Advisory 

Letter 

Commissioner Relevant 
Final Report to the President and Congress 128 

128 

Issue Recommendation Date Source Submitted To Relevance 

NPRM, July 

2007 

SSA should explain its 

plan for implementing 

the proposed 

amendments, answering, 

for example, the 

following questions: 1) 

Will the amendments 

become effective after 

60 days? 2) Will the 

amendments be applied 

to everyone or only to 

newly assigned tickets? 

3) What procedure will 

be used to determine 

progress – a 

questionnaire or an 

interview, or something 

else? 

Oct. 2007 Advisory 

Letter 

Commissioner Relevant 

IRWE Change the order in 

which IRWE are 

deducted when 

calculating the SSI cash 

payment to allow for up 

to a 100 percent cost 

recovery 

Dec. 2007 Optimize 

Work 

Incentives 

Report 

Commissioner Relevant 

IRWE Allow health insurance 

premiums to be used as 

IRWE, when the 

beneficiary can 

document that the 

coverage is disabilityrelated and supports 

work 

Dec. 2007 Optimize 

Work 

Incentives 

Report 

Commissioner Relevant 

IRWE Eliminate the condition 

that family members 

must suffer financial loss 

for their compensation 

by the beneficiary to 

count as IRWE if they 

provide attendant care 

and/or transportation 

to/from work to a 

person with a disability 

Dec. 2007 Optimize 

Work 

Incentives 

Report 

Commissioner Relevant 

SSI Income/ 

Resource 

Limits 

Increase and index the 

key income exclusion 

amounts and the 

resource limits under the 

SSI program 

Dec. 2007 Optimize 

Work 

Incentives 

Report 

Commissioner Relevant 
Final Report to the President and Congress 129 

129 

Issue Recommendation Date Source Submitted To Relevance 

EN Approve proposed rule 

changes to the Ticket to 

Work program to enable 

ENs to receive ticket 

outcome-only payments 

while a beneficiary is 

receiving an SSI cash 

payment resulting from 

an active PASS 

Dec. 2007 Optimize 

Work 

Incentives 

Report 

Commissioner Relevant 

VR Payment Allow SVRAs to receive 

traditional cost 

reimbursement if and 

when an individual is 

receiving an SSI cash 

payment resulting from 

an active PASS or claim 

of BWE 

Dec. 2007 Optimize 

Work 

Incentives 

Report 

Commissioner Relevant 

Work 

Incentives 

Reduce the complexity 

and improve the 

consistency of work 

incentives across the SSI 

and SSDI programs and 

other federal 

entitlements so that they 

universally support work 

Dec. 2007 Optimize 

Work 

Incentives 

Report 

Commissioner Relevant 

Post-entitle. 

Workloads 

Establish mechanisms to 

monitor postentitlement workloads, 

develop performance 

standards (similar to 

those established for 

initial claims in terms of 

processing time and 

decisional accuracy), and 

allocate sufficient 

resources to address 

post-entitlement 

workloads 

Dec. 2007 Optimize 

Work 

Incentives 

Report 

Commissioner Relevant 
Final Report to the President and Congress 130 

130 

Issue Recommendation Date Source Submitted To Relevance 

Post-entitle. 

Workloads 

Establish a crosscomponent internal SSA 

Task Force on postentitlement workload 

issues to identify 

resources needed to 

perform critical program 

integrity activities that 

address post-entitlement 

workloads such as 

processing work reports 

and preventing and 

detecting overpayments. 

Publish these findings 

annually 

Dec. 2007 Optimize 

Work 

Incentives 

Report 

Commissioner Relevant 

Wage 

Reporting 

Continue to expand 

systems for reporting 

wages electronically, 

ensuring that concurrent 

beneficiaries have a 

single point of earnings 

reporting and that timely 

receipts are sent to all 

beneficiaries 

Dec. 2007 Optimize 

Work 

Incentives 

Report 

Commissioner Relevant 

Perform. 

standards for 

WIPA/ 

PABSS 

Strengthen both the 

WIPA and PABSS 

networks by establishing 

performance standards, 

adjusting funding levels 

and resources to levels 

necessary to achieve the 

desired results, and 

invest in ongoing 

training and technical 

assistance that improves 

the accuracy of 

information and quality 

of services provided 

with particular attention 

to underserved 

populations and valued 

employment outcomes 

Dec. 2007 Optimize 

Work 

Incentives 

Report 

Commissioner Relevant 
Final Report to the President and Congress 131 

131 

Issue Recommendation Date Source Submitted To Relevance 

Perform. 

standards for 

WIPA/ 

PABSS 

Identify clear, objective 

performance standards 

and indicators to 

evaluate the activities 

and impact of AWICs 

and WILs, and collect, 

analyze, document, and 

publish evidence 

annually (by SSA region 

and system-wide) of 

customer satisfaction, 

improved employment 

outcomes, and advanced 

self-sufficiency 

Dec. 2007 Optimize 

Work 

Incentives 

Report 

Commissioner Relevant 

PASS Collect workload 

information on the 

number of PASS 

applications submitted 

and approved, including 

the processing (wait) 

time by state, and 

publish this information 

annually in SSA’s SSI 

Disabled Recipients 

Who Work report. 

Provide high quality 

training and support, 

and fiscal resources for 

the effective 

administration and 

outreach of the PASS 

program. Recruit, 

develop, and support 

PASS specialists (travel, 

technology, et al) 

Dec. 2007 Optimize 

Work 

Incentives 

Report 

Commissioner Relevant 

Data 

reporting 

Improve reporting of 

data and analysis 

pertaining to SSDI 

(including Disabled 

Adult Children and 

concurrent SSDI/SSI 

beneficiaries) and issue 

an annual report 

comparable to SSA’s SSI 

Disabled Recipients 

Who Work report 

Dec. 2007 Optimize 

Work 

Incentives 

Report 

Commissioner Relevant 
Final Report to the President and Congress 132 

132 

Issue Recommendation Date Source Submitted To Relevance 

MIS for 

return-towork 

Establish a performance 

management and return 

to work tracking system, 

providing benchmarks 

for each state, and track 

utilization over time as 

part of a continuous 

quality improvement 

plan. 

Dec. 2007 Optimize 

Work 

Incentives 

Report 

Commissioner Relevant 

Wage 

reporting 

Increase beneficiary 

awareness of earnings 

reporting requirements 

and promote greater 

self-efficacy 

Dec. 2007 Optimize 

Work 

Incentives 

Report 

Commissioner Relevant 

$1 for $2 

Demo 

Ensure that employment 

supports are in place for 

$1 for $2 demonstration 

August 2002 Advice 

Report on 

$1 for $2 

Benefit 

Offset 

Research 

Commissioner Relevant Possibly 

included in design 

of national benefits 

offset 

demonstration; see 

details when 

available 

$1 for $2 

Demo 

Use SGA as disregard 

level for $1 for $2 

current beneficiaries 

demonstration 

August 2002 Advice 

Report on 

$1 for $2 

Benefit 

Offset 

Research 

Commissioner Relevant Possibly 

included in design 

of national benefits 

offset 

demonstration; see 

details when 

available 

$1 for $2 

Demo 

Endorses SSA sample 

size of 5,000 in $1 for $2 

demonstration 

August 2002 Advice 

Report on 

$1 for $2 

Benefit 

Offset 

Research 

Commissioner Relevant Possibly 

included in design 

of national benefits 

offset 

demonstration; see 

details when 

available 

$1 for $2 

Demo 

Use monthly accounting 

period consistent with 

SSI accounting in $1 for 

$2 demonstration 

August 2002 Advice 

Report on 

$1 for $2 

Benefit 

Offset 

Research 

Commissioner Relevant Possibly 

included in design 

of national benefits 

offset 

demonstration; see 

details when 

available 
Final Report to the President and Congress 133 

133 

Ticket to Work and Work Incentives Advisory Panel Recommendations 

December 1999 to November 2007 

Table 2: FINAL ACTION TAKEN 

Issue Recommendation Date Source Submitted To Action Taken 

Funding for PWI 

& Supported 

Employment 

Projects with 

Industry and 

Supported 

Employment 

grants should be 

preserved at the 

Federal level 

March 1, 

2002 

Advisory 

Letter 

President 

Bush 

Congress preserved grant 

programs 

Work 

Opportunity Tax 

Credit 

Reauthorize the 

Work Opportunity 

Tax Credit and 

extend it to 

employers who 

hire people with 

disabilities who 

used a ticket 

April 11, 

2002 

Letter to the 

Honorable 

Clay Shaw 

Clay Shaw HR 743 reauthorized and 

extended the credit; again 

in 2006 

P&A Congress should 

direct SSA to 

remove the 

restrictions on 

P&A grantee 

activities 

August 

2002 

Advisory 

Panel Annual 

Report: Year 

Two 

Congress SSA removed restriction, 

and HR 743, signed on 

March 2, 2004, removed 

others 

P&A Congress should 

direct SSA to 

remove restrictions 

on the use of P&A 

grant funds 

May 2003 Annual 

Report: Year 

Three 

Congress SSA removed some 

restrictions, 

and HR 743, signed on 

March 2, 2004, removed 

others 

BPAO Reauthorize BPAO 

Program and 

double funding to 

$46,000,000 

Nov. 20, 

2003 

Advisory 

Letter 

Congressman 

Shaw and 

Senator Grassley

HR 743 reauthorized 

P&A Reauthorize the 

P&A program, 

increase the min. 

amt. of each State 

grant to $200,000, 

and increase 

funding for the 

program as a 

whole to 

$14,000,000 per 

FY 

Nov. 20, 

2003 

Advisory 

Letter 

Congressman 

Shaw and 

Senator Grassley

HR 743 reauthorized the 

P&A Program 
Final Report to the President and Congress 134 

134 

Issue Recommendation Date Source Submitted To Action Taken 

Comment Period Use the longest 

comment period 

possible during 

regulatory process 

to allow maximum 

public comment. 

Dec. 17, 

1999–Dec. 

16, 2000 

Annual 

Interim 

Progress 

Report: Year 

One 

Commissioner Period used 60 days 

CDR 18-year-old 

beneficiaries 

should receive 

same protection 

from 

redeterminations 

as other ticket 

users do from 

CDR 

July 23, 

2001 

Final Advice 

Report on 

Ticket to 

Work 

program 

Notice of 

Proposed 

Rule Making 

(NPRM) 

Congress Possibly if VR client with 

IWP, waiting on final 

regulations per NPRM 

Sept. 2005 

EN EN required to 

retain staff based 

on education and 

experience 

July 23, 

2001 

Final Advice 

Report on 

Ticket to 

Work 

program 

NPRM 

Commissioner Final Regulations Dec. 

2001 

EN SSA should 

simplify EN 

reporting 

requirements 

July 23, 

2001 

Final Advice 

Report on 

Ticket to 

Work 

program 

NPRM 

Commissioner Final Regulations Dec. 

2001 and September, 2005 

NPRM 

Dispute resolution All beneficiaries 

should have access 

to P&A 

July 23, 

2001 

Final Advice 

Report on 

Ticket to 

Work 

program 

NPRM 

Commissioner Improvement, 

Overpayment 

Dispute resolution Mediation should 

be made available 

to resolve disputes 

July 23, 

2001 

Final Advice 

Report on 

Ticket to 

Work 

program 

NPRM 

Commissioner Pilot Program 

Dispute resolution Information on 

P&A services 

should be 

accessible to 

beneficiaries 

July 23, 

2001 

Final Advice 

Report on 

Ticket to 

Work 

program 

NPRM 

Commissioner Some, Letter, IWP 
Final Report to the President and Congress 135 

135 

Issue Recommendation Date Source Submitted To Action Taken 

Dispute resolution All parties in 

disputes should 

have access to all 

information 

July 23, 

2001 

Final Advice 

Report on 

Ticket to 

Work 

program 

NPRM 

Commissioner Policy 

EN Payment SSA should adopt 

payment structure 

that pays four 

milestone 

payments 

July 23, 

2001 

Final Advice 

Report on 

Ticket to 

Work 

program 

NPRM 

Commissioner Improvement from two to 

three. 

VR payment 

option 

Resolve the 

conflict between 

sections 411.510 

and 411.390 

July 23, 

2001 

Final Advice 

Report on 

Ticket to 

Work 

program 

NPRM 

Commissioner Resolved in final 

regulation Dec. 2001 

Ticket to Work 

regulations – 

initial set 

Swift issuance of 

the final ticketimplementing 

regulations 

Nov. 30, 

2001 

Advisory 

Letter 

President Final regulations were 

issued in December 2001.

Funding for 

BPAO & P&A 

Restore funding 

for BPAO and 

P&A Programs to 

maximum 

authorized in the 

statute 

Jan. 7, 2002 Advisory 

Letter 

Commissioner 

Barnhart 

Funding restored. 

AOI Convene an 

ongoing Adequacy 

of Incentives 

Advisory Team 

June 18, 

2002 

Advice 

Report on the 

Adequacy of 

Incentives 

(AOI) Study 

Commissioner In 2003, convened the 

AOI Advisory Group for 

1 year. 

AOI Data collected for 

AOI should be 

provided in SSA's 

overall Ticket to 

Work program 

eval. research 

June 18, 

2002 

Advice 

Report on the 

Adequacy of 

Incentives 

(AOI) Study 

Commissioner AOI data included in 

Ticket to Work program 

eval. research design. 

 

Beneficiary survey SSA's beneficiary 

survey should 

include face-toface interviews and 

special 

accommodations 

for AOI 

population 

June 18, 

2002 

Advice 

Report on the 

Adequacy of 

Incentives 

(AOI) Study 

Commissioner Survey design includes 

face-to-face interviews 

and other 

accommodations. 
Final Report to the President and Congress 136 

136 

Issue Recommendation Date Source Submitted To Action Taken 

AOI - Research Review existing 

research and 

conduct 

supplementary 

research 

June 18, 

2002 

Advice 

Report on the 

Adequacy of 

Incentives 

(AOI) Study

 

Commissioner Reviewed existing 

research and best 

practices at AOI technical 

workshop (May 2002) 

AOI and data Data collected 

should include 

attention to 

national 

demographics and 

diversity 

June 18, 

2002 

Advice 

Report on the 

Adequacy of 

Incentives 

(AOI) Study 

Commissioner Study design includes 

information on 

demographics and 

diversity. 

AOI - Research Conduct or 

commission 

qualitative research 

with ENs on AOI 

issues including 

payments and 

wages 

June 18, 

2002 

Advice 

Report on the 

Adequacy of 

Incentives 

(AOI) Study 

Commissioner Conducted interview with 

ENs on AOI issues in 

evaluation design contract 

SSA infrastructure Implement the 

Employment 

Support 

Representative 

position in SSA 

Field Offices 

July 1, 2002 Advisory 

Letter 

Commissioner Discontinued ESR 

position, created the 

AWIC position with 58 

staff. 

$1 for $2 Demo $1 to $2 

demonstration for 

current 

beneficiaries: Panel 

endorses using 

demo projects for 

$1 for $2 

August 

2002 

Advice 

Report on $1 

for $2 Benefit 

Offset 

Research 

Commissioner Request for information 

published September 2003 

Ticket access Apply for EXR - 

clarify special 

circumstances by 

example 

Dec. 18, 

2003 

Advisory 

Letter Re. 

NPRM Oct. 

2003 on the 

Reinstatement 

of 

Entitlement 

to Disability 

Benefits 

(EXR) 

Comm. Final regulations Sept. 

2005 provided examples.
Final Report to the President and Congress 137 

137 

Issue Recommendation Date Source Submitted To Action Taken 

Ticket access Explicitly state that 

a person entitled 

to benefits 

pursuant to 

expedited 

reinstatement is 

immediately 

eligible for a ticket 

Dec. 18, 

2003 

Advisory 

Letter Re. 

NPRM Oct. 

2003 on the 

Reinstatement 

of 

Entitlement 

to Disability 

Benefits 

(EXR) 

Commissioner 

 

Final regulations Sept. 

2005 stated “if you are 

reinstated under the ex. 

reinstatement 

prov., under Sec. 

404.1592b through 

404.1592f or Sec. Sec. 

416.999 - 416.999d, you 

may be eligible for a new 

ticket under Sec. 

411.125(c)” (ticket 

eligibility). 

Employment 

Support 

Reps/AWIC 

Employment 

Support 

Representatives 

(ESR): The statute 

says, “The 

Commissioner 

should establish a 

corps of trained, 

accessible, and 

responsive work 

incentives 

specialists within 

the Social Security 

Administration.” 

August 

2002 

Advisory 

Panel Annual 

Report: Year 

Two 

Commissioner Discontinued ESR 

position; created the 

AWIC position with 58 

staff. 

Marketing and 

public education 

SSA should 

immediately 

implement a 

national marketing 

and public 

information 

program 

August 

2002 

Advisory 

Panel Annual 

Report: Year 

Two 

Commissioner Awarded contracts in 

2003 to analyze data 

collected from ENs, to 

develop strategies to 

increase EN participation, 

and to develop a strat. 

marketing plan targeted at 

beneficiaries by the end of 

FY 04; third contract to 

analyze beneficiary data 

and develop a plan for 

maximizing participation 

of beneficiaries. Awarded 

contract in 2005 to 

develop marketing and 

outreach strategy – still 

being developed 

EN – payment EN 

reimbursement for 

clients receiving 

partial benefits 

August 

2002 

Advisory 

Panel Annual 

Report: Year 

Two 

 

Commissioner SSA interprets “benefits 

not payable” as zero 

benefits 
Final Report to the President and Congress 138 

138 

Issue Recommendation Date Source Submitted To Action Taken 

CDR protection Request 

Commissioner's 

support of Panel's 

recommendation 

to Congress to 

extend ticket CDR 

protection to any 

and all 

beneficiaries who 

are participating in 

an approved 

program of VR 

services, 

employment 

services, or other 

employment 

support services 

Sept. 2003 Advisory 

Letter Re.

NPRM Aug. 

2003 on 

Continuation 

of Benefit 

Payments 

Commissioner Clarified in final 

regulations June 2005 

Post entitlement 

benefits 

Clarify that 

participants in 

other approved 

rehabilitation plans 

are eligible for 

continuation of 

benefits 

Sept. 2003 Advisory 

Letter Re. 

NPRM Aug. 

2003 on 

Continuation 

of Benefit 

Payments 

Commissioner 

 

Final regulations June 

2005 

EN Once beneficiary is 

certified as 

employed, 

Commissioner 

should continue to 

pay the EN on a 

monthly basis 

unless beneficiary 

status changes 

Feb. 2004 Advice 

Report on 

Employment 

Networks 

Commissioner In 2003, SSA initiated a 

quarterly regime for 

paying ENs that usually 

would not require 

reporting earnings 

Marketing SSA notify 

beneficiaries at 

least once a year 

until SSA has fully 

implemented 

continuous public 

education and 

marketing 

campaigns 

May 2004 Annual 

Report: Yr. 5, 

Advisory 

Letter 

Commissioner Partially - did follow up 

after all phase ins 

completed but not 

annually 
Final Report to the President and Congress 139 

139 

Issue Recommendation Date Source Submitted To Action Taken 

BPAO Require 

Management 

Information 

reports to include 

data on beneficiary 

waiting times for a 

response, an 

appointment and 

for services 

Feb. 2005 Annual 

Report: Yr. 6, 

Advisory 

Letter 

Associate 

Commissioner

In RFA, management 

information data 

collection must include 

the data element of 

beneficiary's waiting time 

for a response 

BPAO Provide special 

consideration to 

proposals that 

develop workable 

ways to effectively 

deal with limited 

resources.

Feb. 2005 Annual 

Report: Yr. 6,

Advisory 

Letter 

Associate 

Commissioner

In RFA, in selecting 

eligible applicants to be 

funded, consideration may 

be given to issues such as 

experience, past 

performance, proposed 

costs, etc. 

BPAO Require BPA&O 

programs to state 

how they will 

target and serve 

transition-aged 

youth. 

Feb. 2005 Annual 

Report: Yr. 6, 

Advisory 

Letter 

Associate 

Commissioner

In RFA, the applicants 

must also describe how 

they will address any 

special cultural 

requirements of pops 

(e.g., Native Americans) 

within the targeted geo. 

area, as well as nonEnglish speaking pops 

and SSI bens. as young as 

age 14. Each project must 

make WIPA services 

available to SSI 

beneficiaries as young as 

age 14 and state how they 

will target and serve 

transition-aged youth. 

Where applicable, 

applicants must indicate 

the ability to work closely 

with the SSA Youth 

Transition Process 

Demonstration (YTD) 

projects that are currently 

located in California, 

Colorado, Iowa, New 

York, Maryland and 

Mississippi 
Final Report to the President and Congress 140 

140 

Issue Recommendation Date Source Submitted To Action Taken 

BPAO Require BPA&O 

programs to state 

how they will 

ensure equitable 

access to and 

services for all 

disability groups 

regardless of their 

primary agency's 

affiliation 

Feb. 2005 Annual 

Report: Yr. 6, 

Advisory 

Letter 

Associate 

Commissioner

In RFA, awardees must 

state how they will ensure 

equitable access and 

services for all beneficiary 

disability groups. This 

requirement may be met 

by partnering with other 

community-based 

organizations 

BPAO Require BPA&O 

programs that 

cover tribal lands 

and sovereign 

nations to provide 

clear and 

convincing 

documentation of 

how they will 

ensure equitable 

access and services 

for Native 

American and AK 

Native 

populations. 

Examples of this 

might be formal 

agreements with 

Tribal govt, 

Section 121 VR 

Programs, etc. 

 

Feb. 2005 Annual 

Report: Yr. 6, 

Advisory 

Letter 

Associate 

Commissioner

In RFA, applicants who 

serve tribal lands and 

sovereign nations must 

also provide 

documentation of how 

they will ensure equitable 

access and services for 

Native-American and 

Alaskan-Native 

populations. Applicants 

must indicate if formal 

agreements with tribal 

govts or Section 121 VR 

Programs, etc. are in place
Final Report to the President and Congress 141 

141 

Issue Recommendation Date Source Submitted To Action Taken 

BPAO Increase the 

duration of the 

initial five-day 

training session to 

realistically reflect 

the breadth and 

complexity of the 

SSA's disability 

programs 

including the 

Ticket to Work 

program and other 

relevant federal 

programs. 

Feb. 2005 Annual 

Report: Yr. 6, 

Advisory 

Letter 

Associate 

Commissioner

In RFA, upon award, the 

WIPA cooperative 

agreement awardees shall:

Employ CWICs and 

require them to complete 

an approved initial four 

day training session within 

3 months of award. SSA, 

or its designated technical 

assistance and training 

contractor, will provide 

technical assistance and 

training to WIPA projects 

about SSA's programs and 

work incentives (e.g., 

TWP, EPE, IRWE, PASS, 

1619(a) and (b), and 

Medicaid Buy-In 

provisions/ 

Balanced Budget Act; 

Medicare and Medicaid; 

and on other Federal 

work incentives programs.

BPAO Establish 

minimum 

qualifications for 

new Benefit 

Specialists and 

timeframes for 

conducting 

training about 

State and local 

programs. 

 

Feb. 2005 Annual 

Report: Yr. 6, 

Advisory 

Letter 

Associate 

Commissioner

In RFA, applicants must 

ensure that CWICs have 

the skills required to 

provide work incentives 

planning and assistance 

services that assist 

beneficiaries. WIPA 

awardees will be required 

to provide documentation 

to SSA that CWIC 

personnel meet the 

requirements below. SSA 

will use this 

documentation to 

credential CWIC 

personnel before they may 

begin providing 

beneficiary services. 

WIPA awardees must 

provide training and 

technical assistance to 

their CWICs about 

applicable State and local 

programs and the effects 

that these programs have 

on other programs' 

eligibility and benefits 
Final Report to the President and Congress 142 

142 

Issue Recommendation Date Source Submitted To Action Taken 

BPAO Require that 

BPA&O programs 

have a quality 

assurance plan that 

is in alignment 

with standards set 

by the Agency and 

that a grievance 

procedure be 

established within 

each BPA&O 

program. Require 

that evidence of 

compliance with 

this plan be 

submitted 

regularly. 

Feb. 2005 Annual 

Report: Yr. 6, 

Advisory 

Letter 

Associate 

Commissioner

In RFA, provide a written 

Quality Assurance (QA) 

plan that demonstrates the 

efficacy of the service 

delivery plan. 

BPAO Require that 

BPA&O programs 

notify beneficiaries 

of the established 

grievance 

procedure and the 

availability of 

PABSS services. 

Feb. 2005 Annual 

Report: Yr. 6, 

Advisory 

Letter 

Associate 

Commissioner

In RFA, [Applicants must 

establish] ...written 

grievance procedures for 

beneficiaries and evidence 

of its compliance which 

will be submitted to SSA 

quarterly. (NOTE: No 

reference to dissemination 

of procedure to 

beneficiaries) 

BPAO Require data 

collection 

strategies to 

provide a full 

picture of the 

benefits counseling 

process (rather 

than snapshots of 

the individual's 

journey) and 

address the 

identification or 

resolution of 

barriers and the 

outcomes achieved 

by the individual 

Feb. 2005 Annual 

Report: Yr. 6, 

Advisory 

Letter 

Associate 

Commissioner

In RFA, projects will 

collect, analyze, and 

summarize the specific 

data elements listed 

below: 

A. Beneficiary info 

B. Employment info and 

Outcomes (current and 

proposed goals--when 

applicable) 

C. Program Manager for 

Recruitment and 

Outreach (PMRO) 

Activities 

D. Benefits: (current and 

expected changes if 

employment goals are 

reached) 

E. Incentives to be used: 

F. Services to be used 

G. Monthly WIPA 

activities performed 
Final Report to the President and Congress 143 

143 

Issue Recommendation Date Source Submitted To Action Taken 

BPAO Require BPA&O 

programs to have 

agreements with 

ENs, and also 

Disability Program 

Navigators, in 

their geographic 

catchment area to 

promote positive 

working 

relationships. 

Feb. 2005 Annual 

Report: Yr. 6, 

Advisory 

Letter 

Associate 

Commissioner

In RFA, were encouraged 

to collaborate. 

PASS 

Occupational 

Goals 

Panel supported 

continuation of 

credentialing 

policy. However, 

recommended SSA 

clarify what 

weight, if any, will 

be given to 

occupational goals 

developed with 

assistance of 

BPAOs and 

others, for 

example, Small 

Business 

July 2005 Annual 

Report: Yr. 6, 

Advisory 

Letter Re.

NPRM July 

11, 2005 

Commissioner Did not adopt; however, it 

added language defining 

feasible employment goal 

as “is one that you have a 

reasonable likelihood of 

achieving.” And it created 

two new sections to 

explain “a viable plan”. 

PASS 

Dependence on 

SSI 

SSA provide more 

clarity regarding 

how much of a 

reduction is 

“substantial” and 

then ensure that 

this criterion is 

consistently 

implemented 

July 2005 Annual 

Report: Yr. 6, 

Advisory 

Letter Re.

NPRM July 

11, 2005 

Commissioner SSA partially adopted the 

Panel’s recommendation 

by providing examples as 

a means of clarification of 

the meaning of 

“substantial” 

Admin. Review 

Process – 

Disability Claims 

Resources to 

establish the 

dedicated Quick 

Disability 

Determination 

units are not 

diverted from the 

resources 

necessary for 

adjudicating more 

difficult cases in a 

timely manor 

Oct. 2005 Annual 

Report: Yr. 6, 

Advisory 

Letter Re.

NPRM July 

27, 2005 

Commissioner Without specifically 

addressing the Panel’s 

recommendation, it 

appears that the Final 

Rule is consistent with 

this recommendation. 

The goal is to enhance 

productivity throughout 

the system, so resources 

can be available for all 

cases as needed 
Final Report to the President and Congress 144 

144 

Issue Recommendation Date Source Submitted To Action Taken 

Admin. Review 

Process – 

Disability Claims 

Time periods for 

introducing 

evidence for the 

record: The rules 

should require 

greater clarity in 

terms of what 

constitutes "just 

cause." 

Oct. 2005 Annual 

Report: Yr. 6, 

Advisory 

Letter Re.

NPRM July 

27, 2005 

Commissioner SSA has lengthened the 

period of time permitted 

for introducing evidence.
Final Report to the President and Congress 145 

145 

 

Appendix D 

Panel Outreach 2001-2007 

Outreach Event Date 

Panel website and listserv created 2001 – 2002 

Regional meetings held in Arizona, Georgia, Minnesota, and 

California – Panel Event 

January - February 2001 

Experts Roundtable – Panel held regarding design of the 

Adequacy of Incentives Study. 

July 27, 2001 

Experts Roundtable – Panel held regarding SSA’s plan for 

evaluating the effects of $1 for $2 benefit offset current 

beneficiaries and on induced entry. 

November 16, 2001 

National Workforce Inclusion Conference. Panel members 

participated in two presentations: legal issues in 

implementation of the regulations, and ENs and the Ticket to 

Work program. 

March 2002 

Employment Network Summit – Panel Event May 2003 

SSI/SSDI Consumer Panel February 2004 Quarterly 

Panel Meeting 

Florida TWWIIA Programs and Projects Panel February 2004 Quarterly 

Panel Meeting 

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

Meeting 

Public Transportation and ADA Experts Panel May 2004 Quarterly Panel 

Meeting 

EN Presentation on Ticket to Work Program May 2004 Quarterly Panel 

Meeting 

Public Housing Experts Panel May 2004 Quarterly Panel 

Meeting 

California Consumer Panel August 2004 Quarterly 

Panel Meeting 

California Workforce Inclusion Panel August 2004 Quarterly 

Panel Meeting 

Public Roundtable Discussion August 2004 Quarterly 

Panel Meeting 

Medicaid Buy-In Panel February 2005 Quarterly 

Panel Meeting 
Final Report to the President and Congress 146 

146 

Outreach Event Date 

Louisiana Consumer Panel February 2005 Quarterly 

Panel Meeting 

Provider and Employer Panel February 2005 Quarterly 

Panel Meeting 

Florida Freedom Initiative Panel May 2005 Quarterly Panel 

Meeting 

Youth Transition Demonstration Panel May 2005 Quarterly Panel 

Meeting 

Employer Best Practices Panel August 2005 Quarterly 

Panel Meeting 

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

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

The Minnesota/Wisconsin Employment Forum January 12, 2006 

SSA Town Hall Meeting December 15, 2005 

2nd Annual Ticket to Work Conference – Panel co-hosted this 

event with Movimiento para el Alcance de Vida 

Independiente (MAVI) 

February 2006 Quarterly 

Panel Meeting 

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

Panel Meeting 

President’s Committee on Intellectual Disabilities’ Asset 

Development Roundtable 

March 2006 

New Freedom Initiative Workgroup Meeting/Office of 

Disability/U.S. Dept. of Health and Human Services 

April 2006 

Medicaid Buy-In and Medicaid Infrastructure Grants: 

Beneficiary Perspectives Panel 

June 2006 Quarterly Panel 

Meeting 

Benefits Planning Assistance and Outreach: Beneficiary 

Perspectives Panel 

June 2006 Quarterly Panel 

Meeting 

Building Bridges Blueprint for Success Conference May 26, 2006 

Annual Florida Conference on Supported Employment August 2006 

Meeting with CCD Task Forces September 2006 

HSC Foundation Youth Transitions Summit September 2006 

US Business Leadership Network Conference October 2006 

TASH Conference November 2006 

Beneficiary Perspectives on Community Level Infrastructure 

Panel 

November 2006 Quarterly 

Panel Meeting 

Beneficiary Summit – Panel Event February 2007 
Final Report to the President and Congress 147 

147 

Outreach Event Date 

Perspectives from Stakeholders Panel April 2007 Quarterly Panel 

Meeting 

Rhode Island Medicaid Infrastructure Grant Summit April 2007 

Oregon “Building Futures: Transition to Education and 

Employment” Conference 

May 2007 

Family Voices May 2007 

SSA Teleservice Center and district field offices May – June 2007 

Walgreens Distribution Center Opening June 2007, South Carolina

Proyecto Visión Conference June 2007, Florida 
Final Report to the President and Congress 148 

148 
Final Report to the President and Congress 149 

149 

Appendix E 

Panel Correspondence 2007 
Final Report to the President and Congress 150 

150 

October 5, 2007 

Michael J. Astrue 

Commissioner 

Social Security Administration 

P.O. Box 17703 

Baltimore, MD 21235-6401 

RE: Notice of Proposed Rule Making: Amendments to 

 the Ticket to Work and Self-Sufficiency Program 

 (Volume 72, Number 155) 

Dear Commissioner Astrue: 

I am writing on behalf of the Ticket to Work and Work Incentives Advisory Panel (the 

Panel) to provide comments on the Notice of Proposed Rule Making (NPRM) released on 

August 13, 2007. The NPRM calls for simplifying and improving the definition of “using a 

ticket” and requirements for measuring “timely progress” toward self-supporting 

employment. 

Overall, the Panel supports these proposed amendments. In particular, we are pleased that, 

in addition to employment, the proposed amendments allow for participation in an 

educational program to count toward an individual’s timely progress by crediting attendance 

at post secondary school or vocational/technical training. While there are jobs for which 

training can be completed in a relatively short time period, there are others requiring a longer 

period of education or training. An individual in a certified educational/training program, 

internship, apprenticeship, etc. should not be required to interrupt this program to meet the 

work requirements of “timely progress.” 

The Panel is concerned, however, about the potential impact on the 178,000 current 

beneficiaries with assigned tickets who will have to demonstrate timely progress in 12 

months instead of 24 months as currently required. SSA must clearly communicate this 

change to these beneficiaries, before it has a negative impact on their planned goals. 

TICKET TO WORK & WORK INCENTIVES ADVISORY 

PANEL 
Final Report to the President and Congress 151 

151 

The Panel believes these proposed amendments would be most effective for people with 

disabilities currently attending college or vocational technical school whose earnings are 

below specified SSI and SSDI earnings thresholds. However, these amendments would not 

be particularly helpful for people who, for a variety of reasons, cannot participate in full-time 

postsecondary education or vocational/technical training. We provide details below and a 

compilation of recommendations in the conclusion. 

 

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

The proposed amendments require the equivalent of full-time attendance in postsecondary 

education (12 credit hours per semester – or 24 credits per 12 month period). For 

completion of the vocational or technical training program requirements, an individual must 

have finished at least 50 percent of the course requirements of the program by the end of 

this 12-month period. 

Completing these requirements can be difficult for people with certain disabilities who rely 

on services such as public transportation, attendant care, etc. For example, a beneficiary 

using para-transit, who needs to be in class by 11:00 a.m., may need to be picked up at their 

home by 8:00 a.m. (This occurs because para-transit often requires a window of time before 

and after the customer wants to be picked up and is usually allowed up to an hour and a half 

to drop off the customer. Most often, the transit system will be faster than the 2-3 hours, 

but the customer cannot depend upon a consistent trip time and must always plan for the 

worst-case scenario.) Their return trip may require as many hours, filling a large percentage 

of the individual’s day with transportation time – not enough time to allow them to 

complete 12 college credits (a full-time schedule). The Social Security Administration (SSA) 

should include provisions in the proposed amendments to account for disability-related 

stumbling blocks, such as an inability to get needed supports and accommodations. 

The proposed amendments also provide credit for post secondary education or 

vocational/technical training, but not for high school completion or GED preparation for 

beneficiaries who had previously dropped out of school and may now be completing those 

educational requirements (without further aspiring to college or vocational/technical 

training). This provides unequal continuing disability review (CDR) protection for those 

beneficiaries who critically need this level of training if they are going to obtain stable 

employment above substantial gainful activity (SGA). SSA needs to consider an individual 

threshold around education and/or training more suited to the employment preparation 

needs of the individual. SSA should provide a larger threshold for beneficiaries who may 

require a longer period of time to complete their educational studies. 

In addition, to be more inclusive, SSA should include training programs of the Department 

of Veterans Affairs and the Department of Education under the definition of “vocational or 

technical training programs.” 
Final Report to the President and Congress 152 

152 

Individualizing Timely Progress 

The Panel recognizes that people with disabilities are a diverse group, and one-size-fits-all 

approaches designed to move them toward self-supporting employment can be problematic. 

Timely progress should be individualized based on the terms and conditions of the 

Individualized Plan for Employment/Individual Work Plan (IPE/IWP) and accommodate 

episodic disabilities. It should be possible for the IPE/IWP to be revised and updated as the 

needs and circumstances of the individual changes – both for postsecondary education and 

vocational/technical training. 

For example, individuals who become blind may not need postsecondary education or GED 

preparation. Instead, they may need adjustment-to-blindness training, which includes 

training on Braille, orientation and mobility, adjustment to daily living, and assistive 

technology. The definition of educational training should be flexible enough to 

accommodate this. 

Plans for Implementing the Proposed Amendments 

The current rules have been in place since 2003. Tickets currently assigned fall under the old 

rules which did not require timely progress reviews until after the first 24 months of plan. 

SSA should explain its plan for implementing the proposed amendments, answering, for 

example, the following questions: 1) Will the amendments become effective after 60 days? 

2) Will the amendments be applied to everyone or only to newly assigned tickets? 3) What 

procedure will be used to determine progress – a questionnaire or an interview, or something 

else? 

Other Improvements 

Documentation Improvements – Reducing Administrative Burden—The proposed amendments call 

for requiring parallel documentation for milestone payments for timely progress. The Panel 

recognizes that this change is positive because it will reduce the reporting burden on ENs. 

Improvements to “Extension Period”—The proposed amendments would change the duration of 

the extension period from three months to 90 days, making it consistent with the proposed 

90-day period included in the September 2005 NPRM. This is a positive change. 

Conclusion 

The Panel is pleased that SSA is moving forward toward publishing final Ticket regulations. 

We continue to urge expeditious implementation of these new rule changes to help reignite 

the level of interest in the Ticket Program by ENs and beneficiaries. 

Overall, the Panel supports the proposed amendments and offers the following 

recommendations (drawn from above) to improve the amendments: 
Final Report to the President and Congress 153 

153 

Recommendations 

SSA must clearly communicate to beneficiaries that they’ll be required to demonstrate timely 

progress in 12 months instead of 24 months as currently required, before it has a negative 

impact on their planned goals. 

SSA should include provisions in the proposed amendments to account for disability-related 

stumbling blocks, such as an inability to get needed supports and accommodations. 

SSA should provide a larger threshold for beneficiaries who may require a longer period of 

time to complete their educational studies. 

SSA should include training programs of the Department of Veterans Affairs and the 

Department of Education under the definition of “vocational or technical training 

programs.” This should include disability-specific training, such as orientation and mobility, 

Braille, assistive technology, and similar skills necessary for vocational functioning. 

Timely progress should be individualized based on the terms and conditions of the 

IPE/IWP and accommodate episodic disabilities. It should be possible for the IPE/IWP to 

be revised and updated as the needs and circumstances of the individual changes – both for 

postsecondary education and vocational/technical training. 

SSA should explain its plan for implementing the proposed amendments, answering, for 

example, the following questions: 1) Will the amendments become effective after 60 days? 

2) Will the amendments be applied to everyone or only to newly assigned tickets? 3) What 

procedure will be used to determine progress – a questionnaire or an interview, or something 

else? 

We are pleased to offer SSA this advice. If you have any questions, please contact the 

Panel’s Executive Director, Jill Houghton. She can be reached at 202-358-6419. 

Sincerely, 

Berthy De La Rosa-Aponte 

Chair 

Ticket to Work and Work Incentives Advisory Panel 
Final Report to the President and Congress 154 

154 
Final Report to the President and Congress 155 

155 

Statement of 

Berthy De La Rosa Aponte, Chair 

Ticket to Work and Work Incentives Advisory Panel, 

Social Security Administration 

Submitted to the Senate Committee on Finance 

Hearing on 

“Barriers to Work for Individuals Receiving Social Security 

Disability Benefits” 

June 21, 2007

As Chair of the Ticket to Work and Work Incentives Advisory Panel (the Panel), I 

respectfully submit the following statement on behalf of the Panel. We appreciate this 

opportunity. 

The topic of today’s hearing, “Barriers to Work for Individuals Receiving Social Security 

Disability Benefits,” represents one of the core issues to which the Panel has been devoting 

much of its work since Congress established the Panel in 2000 as part of the Ticket to Work 

and Work Incentives Improvement Act of 1999 (the Act). The Panel will continue to focus 

on this issue through our sunset date of December 2007. 

At each of the Panel’s meetings, we have heard from diverse stakeholders, including 

beneficiaries who have shared their perspectives and advice on the need for immediate 

improvements to current programs under the Act, as well as approaches to more 

comprehensive, systemic changes to policy and system design. We have also conducted 

extensive policy research, consulted both nationally and internationally with experts in the 

field of return to work, and provided the President, Congress and the Commissioner of the 

Social Security Administration (SSA) with recommendations and counsel for enhancing the 

return to work efforts of disability beneficiaries. 

Beneficiaries’ perspectives and recommendations have played a primary role in the 

development of Panel advice and will continue to play a critical role as we develop the 

recommendations in our Final Report, which will be released at the end of 2007. 

Beneficiaries have affirmed to the Panel that most people with disabilities want to work but 

are challenged by system fragmentation and complexity, fear of loss of health care benefits 

and overpayments, and well intended policies that have the effect of limiting economic 

security and advancement. It is estimated that, in 2005, 104,100 non-employed SSI 

beneficiaries were actively looking for work, and 103,200 non-employed SSDI beneficiaries 

were actively looking for work.160 
Final Report to the President and Congress 156 

156 

Over the years, the Panel has provided recommendations related to SSA’s work incentives, 

health care programs, administrative and programmatic operations and budgetary issues, as 

well as the work of other federal programs charged with the responsibility of removing 

barriers to employment and economic self-sufficiency for individuals with disabilities. Below 

are key recommendations that the Panel has made and that we reiterate now as you consider 

strategies and approaches for removing barriers to work. 

Our recommendations are organized into the following categories: 1) Ticket to Work and 

Self-Sufficiency Program-Related Issues; 2) Marketing and Outreach on Work Incentives; 3) 

Improving/Simplifying Specific Work Incentives; and 4) Training for Work Incentives 

Specialists. 

Ticket to Work and Self-Sufficiency Program-Related Issues 

On September 30, 2005, SSA published a Notice of Proposed Rule Making called 

“Amendments to the Ticket to Work and Self-Sufficiency Program.” These proposed 

amendments incorporated many of the Panel’s priority recommendations. We were 

particularly pleased that the proposed amendments accounted for and addressed the multistep nature of returning to work by calling for a new payment system for Employment 

Networks (ENs), offering more frequent and earlier payments. 

The Panel was hopeful that the proposed changes would improve the program. 

Unfortunately, SSA has not yet published the final regulations, and the program continues to 

face significant problems. In fact, the number of active ENs working with Social Security 

beneficiaries has been in a statistical decline for the past eight months. 

The Panel continues to hold hope for a demand-driven approach to supporting beneficiaries 

in going to work; however, without significant enhancements and aggressive outreach, we 

fear the Ticket Program will not recover from initial design flaws and ongoing beneficiary 

and EN disenchantment. 

Specifically, the Panel recommends: 

All SSI and SSDI adult beneficiaries, including those designated as medical improvement 

expected, should be eligible to participate in the Ticket Program.161

Payments to ENs should be more frequent and earlier to reduce ENs’ financial risk. One 

caution is that SSA should review the lump sum milestone payment provisions to ensure 

Tickets retain sufficient value so beneficiaries continue to be able to negotiate for needed 

services later in their return to work efforts.162

SSA should rewrite the regulations and modify transmittal 17 to make it clear that: 
Final Report to the President and Congress 157 

157 

Beneficiaries’ eligibility for vocational rehabilitation (VR) service or the scope of those 

services should not be adversely affected by where they assign their Ticket. Eligibility for VR 

services and VR client status should not dictate when or where beneficiaries can use their 

Ticket. 

ENs should receive payments from SSA for beneficiaries who, with EN assistance, continue 

in employment above substantial gainful activity (SGA) after VR has been paid under the 

traditional cost reimbursement system.163

Transition-aged youth should be eligible for Tickets.164

Request Commissioner of SSA’s support of Panel's recommendation to Congress to extend 

Ticket continuing disability review (CDR) protection to any and all beneficiaries who are 

participating in an approved program of VR services, employment services, or other 

employment support services.165 

Explicitly state that a person entitled to benefits pursuant to expedited reinstatement is 

immediately eligible for a new Ticket.166

Amend statute to permit the Ticket Program to increase the sum of payments for serving 

SSI beneficiaries to a level equal to the sum of payments for serving SSDI beneficiaries.167

Beneficiaries should be eligible for more than one Ticket in a period of entitlement for 

SSDI/SSI benefits when their disability is likely to require some indefinite supports to 

remain employed (including self-employment).168

Marketing and Outreach on Work Incentives 

A coordinated marketing and substantial nationwide public education campaign, targeted to 

beneficiaries, their families and disability service providers, is needed to increase awareness 

of SSA’s work incentives and to debunk some of the widely held misperceptions about the 

negative consequences of work for beneficiaries. As referenced earlier, there are substantial 

numbers of disability beneficiaries actively engaged in looking for work who could face 

greater likelihood of success if they knew what supports were available and how existing 

work incentives could provide an important safety net in their return to work. 

Specifically the Panel recommends: 

SSA should immediately develop a national marketing and public education campaign to 

explain available programs.169

Expand resources available to broaden the impact of the work incentives planning and 

assistance network.170
Final Report to the President and Congress 158 

158 

Expand resources available to broaden the impact of protection and advocacy services and 

supports.171

Improving/Simplifying Specific Work Incentives 

Across the board, SSA needs to reduce the complexity and improve the consistency of work 

incentives for both the SSDI and the SSI programs. We are pleased to announce that the 

Panel, in consultation with national experts, is preparing an advice report for the President, 

Congress, and SSA on work incentives utilization. We will be deliberating on this report 

during our July 2007 quarterly meeting, and plan to publish it this summer. 

This Panel is considering ten themes or high level recommendations that form an overall 

basis for increasing the utilization of work incentives, and more importantly, improve the 

employment status of beneficiaries with disabilities. 

Increase awareness of beneficiaries about work incentives (including better understanding 

and expanding outreach efforts). 

 

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

decision making. 

Improve SSA customer service and the knowledge base of accurate information (training 

and technical assistance to SSA personnel) delivered to beneficiaries. 

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

programs involved. 

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

beneficiaries. 

Conduct studies and create demonstration projects to exemplify improved work incentives 

utilization. 

 

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

beneficiaries. 

Assure accessible health care as work incentives are utilized. 

Reduce the risk of overpayments for beneficiaries. 

Ensure that work incentives accommodate the dynamic nature of disability. 

Training for Work Incentives Specialists 
Final Report to the President and Congress 159 

159 

The Panel has continued to recommend that Congress appropriate funds for training of SSA 

staff and work incentives specialists to explain work incentives to beneficiaries, and is 

currently reviewing how beneficiary support is provided within the current field office 

structure. 

The Panel has also supported funding private organizations to provide work incentives 

training and support, beginning with the Benefits Planning, Assistance, and Outreach 

Program and now the Work Incentives Planning and Assistance Program as well as the 

Protection and Advocacy for Beneficiaries of Social Security Program. 

Specifically, the Panel recommends: 

Congress should direct SSA to spend more on public education and field training.1

Next Steps for Panel 

The Panel’s three goals are driving our work: 1) Goal 1 – Elevate and Incorporate the 

Beneficiary Perspective; Goal 2 – Improve Implementation and Marketing of the Ticket to 

Work and Work Incentives Improvement Act; and Goal 3 – Develop A National 

Employment Investment Strategy to Transform Approaches to Assets, Income, Health 

Care, and Supports for People with Disabilities that is Person-Centered, Culturally 

Competent, and Respectful of Each Person’s Values and Experiences 

The recommendations we have offered to date are part of our continuous improvement 

goal, and our forthcoming advice report on work incentives utilization will provide more 

detailed recommendations for increasing utilization of work incentives. 

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

reports will feed into our Final Report. 

Beneficiary Summit Report – “Voices for Change: Beneficiaries Paving the Way to Work” 

This report will include the Beneficiary summit recommendations. In addition, the Panel 

will be developing recommendations for ensuring beneficiary input for future policy 

development separate from this report. 

National Employment Investment Strategy Report 

The Panel recognizes that more will need to be done outside the current structure to more 

substantially remove barriers to work for people with disabilities. This report will lay out a 

comprehensive approach to promoting employment for people with disabilities – today and 

in the future. 

 

1

 Annual Report Year 2. 
Final Report to the President and Congress 160 

160 

Conclusion 

It is essential that SSA act sooner rather than later to decrease the complexity of work 

incentives, to improve the consistency of work incentives for both the SSDI and the SSI 

programs, and to remove barriers to work. Social Security beneficiaries with disabilities have 

waited far too long for improvements. This urgency applies particularly to youth who are 

transitioning from school to work. Now is the time for SSA to integrate a return-to-work 

philosophy and culture into its service to the public, especially for new beneficiaries. 

Thank you for this opportunity. 

END NOTES 
Final Report to the President and Congress 161 

161 

Glossary 

AB ─ Accelerated Benefits Demonstration Project 

ADA ─ Americans with Disabilities Act of 1990 

AOI ─ Adequacy of Incentives 

AWICs ─ Area Work Incentives Coordinators 

BPAO ─ Benefits Planning, Assistance and Outreach 

BWE ─ Blind Work Expenses 

CDR ─ Continuing Disability Review(s) 

CILs ─ Centers for Independent Living 

CMS ─ Centers for Medicare and Medicaid Services 

COBRA ─ Consolidated Omnibus Budget Reconciliation 

Act 

DOL ─ Department of Labor 

DPNs ─ Disability Program Navigator(s) 

ENs ─ Employment Networks(s) 

EPE ─ Extended Period of Eligibility 

ESRs ─ Employment Support Representatives 

FLSA ─ Fair Labor Standards Act 

GAO ─ Government Accountability Office 

GDP ─ Gross Domestic Project 

HHS ─ Department of Health and Human Services 

HOPE ─ Homeless Outreach Projects and Evaluation 

IDEA ─ Individuals with Disabilities Education Act 

IEPs ─ Individualized Education Plan(s) 

IRS ─ Internal Revenue Service 

IRWE ─ Impairment Related Work Expense 

MHTS ─ Mental Health Treatment Study 

MIG ─ Medicaid Infrastructure Grant(s) 

NASI ─ National Academy of Social Insurance 

NCD ─ National Council on Disability 

NCIL ─ National Council on Independent Living 

NEIS ─ National Employment Investment Strategy 

NPRM ─ Notice of Proposed Rulemaking 

NTA ─ National Taxpayer Advocate 

OMB ─ Office of Management and Budget 

OPI ─ Office of Public Inquiry 

OQP ─ Office of Quality Performance 

PABSS ─ Protection and Advocacy for Beneficiaries of 

Social Security 

PASS ─ Plan for Achieving Self Support 

RED ─ Rehabilitation Early Diversion 
Final Report to the President and Congress 162 

162 

SGA ─ Substantial Gainful Activity 

SSA ─ Social Security Administration 

SSI ─ Supplemental Security Income 

SSAB ─ Social Security Advisory Board 

SSDI ─ Social Security Disability Insurance 

SVRAs ─ State Vocational Rehabilitation Agencies 

TESS ─ Transition to Economic Self-Sufficiency 

TWP ─ Trial Work Period 

UCP ─ United Cerebral Palsy 

VR ─ Vocational Rehabilitation 

WILs ─ Work Incentive Liaison(s) 

WIPA ─ Work Incentives Planning and Assistance 
Final Report to the President and Congress 163 

163 

Panel Contact Information 

Ticket to Work and Work Incentives Advisory Panel 

Social Security Administration 

400 Virginia Avenue, SW 

Suite 700 

Washington, DC 20024 

Phone at (202) 358-6430 

Fax at (202) 358-6440 

Email to: TWWIIAPanel@ssa.gov 

Website: www.socialsecurity.gov/work/panel 

Anyone requiring materials in alternative formats or for further information regarding this 

document or the Ticket to Work and Work Incentives Advisory Panel should contact the 

Panel staff. Records are maintained of all Panel proceedings in accordance with the Federal 

Advisory Committee Act and are available for public inspection at the Panel office, by 

appointment. 
Final Report to the President and Congress 164 

164 
Final Report to the President and Congress 165 

165 

End Notes 

1 Section 2(a)(11), Public Law 106-170, “Ticket to Work and Work Incentives Improvement Act,” 

December 17, 1999. 

2 Bliley, Thomas J. Committee on Commerce, U. S. House of Representatives, Report 106-220, 

Part 1, “Work Incentives Improvement Act of 1999,” July 1, 1999, p. 2.

3

 Section 2(a)(11), Public Law 106-170, “Ticket to Work and Work Incentives Improvement Act,” 

December 17, 1999. 

4 Section 121, Public Law 106-170, “Ticket to Work and Work Incentives Improvement Act,” 

December 17, 1999.

5 Listing of the former panel members does not necessarily constitute an endorsement of 

recommendations included within this report. These recommendations are the result of a majority 

vote reached by current Panel members.

6 Ticket to Work and Work Incentives Advisory Panel, “UPDATE, SIMPLIFY, AND 

EDUCATE: A National Call to Optimize Incentives to Work,” December 2007.

7 Committee on Commerce, U.S. House of Representatives, Report 106-220, Part 1, “Work 

Incentives Improvement Act of 1999,” p. 7.

8 Social Security Administration, “SSA Quarterly Update to the Ticket Panel, Third Quarter 2007,” 

July, 2007.

9 Committee on Commerce, U.S. House of Representatives, Report 106-220, Part 1, H.R. 1180, 

Ticket to Work and Work Incentives Improvement Act of 1999, July 1, 1999, p. 7.

10 Ibid., p. 5.

11 In 1972, the Supplemental Security Income program was created and the definition of disability 

was changed slightly from a permanent disability to one lasting at least 12 months.

12Burkhauser, R., D.S. Stapleton. “The decline in the employment rate for people with disabilities: 

Bad data, bad health, or bad policy? Journal of Vocational Rehabilitation, 20 (3), 185 – 201, IOS 

Press, 2004. http://digitalcommons.ilr.cornell.edu/edicollect/158

13 Houtenville, A. J., W. A. Erickson, C.G. Lee. Disability Statistics from the Current Population 

Survey (CPS). Cornell University Rehabilitation Research and Training Center on Disability 

Demographics and Statistics (StatsRRTC), April 4, 2005. Retrieved November 13, 2007 from 

www.disabilitystatistics.org

14 Social Security Advisory Board. “A Disability System for the 21st Century,” September 2006, 

pp. 6-7. http://www.ssab.gov/documents/disability-system-21st.pdf

15 Ibid.

16 Social Security Advisory Board. “The Social Security Definition of Disability,” October 2003.

17National Council on Disability. “Toward Independence: An Assessment of Federal Laws and 

Programs Affecting Persons with Disabilities,” February 1986; “On the Threshold of 

Independence,” January 1988; “Achieving Independence: The Challenge for the 21st Century, A 

Decade of Progress in Disability Policy Setting an Agenda for the Future,” July 26, 1996; “The 

Social Security Administration’s Efforts to Promote Employment for People with Disabilities: 
Final Report to the President and Congress 166 

166 

New Solutions for Old Problems,” November 30, 2005; “Empowerment for Americans with 

Disabilities: Breaking Barriers to Careers and Full Employment,” October 1, 2007.

18 Walker, David M. Social Security Reform Presentations, 1999 and 2001. “Truth and 

Transparency: The Federal Government's Financial Condition and Fiscal Outlook,” September 17, 

2003.

19 Imparato, Andrew. “Community Services and Supports: Planning Across the Generations,” 

Testimony Before the U.S. Senate Committee on Health, Education, Labor, and Pensions, July 10, 

2007.

20 National Council on Independent Living. “Being American: the Way Out of Poverty,” 

September 30, 2006. 

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

22 Section 2(a)(11), Public Law 106-170, “Ticket to Work and Work Incentives Improvement Act,” 

December 17, 1999. 

23 Social Security Administration. Strategic Plan. (FY 2006 – FY 2011). Baltimore, MD: Author. 

http://www.ssa.gov/strategicplan.html

24 Social Security Administration, “SSA Strategic Plan. (FY 2006 – FY 2011),” Baltimore, MD, p. 

12. 

25 Listing of past Panel members does not necessarily provide an endorsement of their support for 

recommendations included within this report. These recommendations are the result of a majority 

vote reached by current Panel members.

26 Social Security Advisory Board. (2006). A Disability System for the 21st Century. Washington, 

DC. September 2006. http://www.ssab.gov/documents/disability-system-21st.pdf

27 Ibid, p 3.

28 Office of Management and Budget, Program Assessment and Rating Tool, Social Security 

Disability Insurance, www.expectmore.gov

29 Social Security Advisory Board. (2006). A Disability System for the 21st Century. Washington, 

DC. September 2006. http://www.ssab.gov/documents/disability-system-21st.pdf

30 Ibid. 

31 Muller, L. Scott, “Disability Beneficiaries Who Work and Their Experience Under Program 

Work Incentives,” Social Security Bulletin 55(2):2-19(1992), Social Security Administration.

32 Hennessey, John C. and L. Scott Muller, “Work Efforts of Disabled-Worker Beneficiaries: 

Preliminary Findings from the New Beneficiary Follow-up Survey,” Social Security Bulletin 

57(3):42-51, Social Security Administration, 1995.

33 Hennessey, John C. and L. Scott Muller, “The Effect of Vocational Rehabilitation and work 

Incentives on Helping the Disabled-Worker Beneficiary Back to Work,” Social Security Bulletin 

58(1):15-28, Social Security Administration, 1995.

34 Ticket to Work and Work Incentives Advisory Panel, “UPDATE, SIMPLIFY, AND 

EDUCATE: A National Call to Optimize Incentives to Work,” December 2007. 

35 Social Security Administration, “SSI Disabled Recipients Who Work,” Tables 14 and 6, 2006. 
Final Report to the President and Congress 167 

167 

36 U.S. General Accounting Office. 2002. SSA Disability: Enhanced Procedures and Guidance 

Could Improve Service and Reduce Overpayments to Concurrent Beneficiaries. GAO-02-802. 

Washington, DC: September 2002.

37 Livermore, G. A., “Wage Reporting and Earnings-Related Overpayments in the Social Security 

Disability Programs: Status, Implications, and Suggestions for Improvements.” Report prepared 

for the Ticket to Work and Work Incentives Advisory Panel. Cornell Center for Policy Research: 

Washington, DC. 2003. http://www.ssa.gov/work/panel/panel_documents/briefingpapers.html

38 Social Security Administration. Strategic Plan FY 2006 – FY 2011. Baltimore, MD. 

http://www.ssa.gov/strategicplan.html

39Office of Management and Budget. Budget of the United States Government, FY 2008. 

http://www.whitehouse.gov/omb/budget/fy2008/budget.html

40 The prevention of SSI overpayments will be accomplished by testing and implementing, as 

appropriate, electronic means for SSA to access records of financial institutions to detect 

unreported resources. Social Security has tested methods to electronically access recipient 

financial account records, and this tool has been expanded to additional field offices in the New 

York Region. This process is also being used to study and identify characteristics of records likely 

to have accounts over the SSI lines. The results of the study will be used to determine if it is 

feasible to support development of systems changes and expansion of the initiative nationwide. 

(From SSA FY 2008 and Revised Final FY 2007 APP Appendix A: Service – Improper Service 

Through Technology (1.3 a-g) Means/Strategies.)

41 Social Security Administration, “Social Security Administration Budget, Justification of 

Estimates for Appropriations Committees FY 2008,” Baltimore, MD, p. 179, 

http://www.socialsecurity.gov/budget/2008cjapp508.pdfFiscal Year 2008, p. 179. 

42 Office of Management and Budget, “Budget of the United States Government, FY 2008, 

http://www.whitehouse.gov/omb/budget/fy2008/budget.html 

43 U.S. House of Representatives Committee on Ways and Means, Hearing before the 

Subcommittee on Social Security: “Social Security Service Delivery Challenges,” 109th Cong, 2nd 

Session, Washington, DC, May 11, 2006.

44 Ibid, pp. 29, 39-40, 51, and 60.

45 U.S. General Accounting Office, “Major Management Challenges and Program Risks: Social 

Security Administration,” GAO-03-117. Washington, DC: January 2003.

46 U.S. Government Accountability Office. 2005. Social Security Reform: Early Action Would Be 

Prudent. GAO-05-397T. Washington, D.C.: March 9, 2005. The General Accounting Office 

(GAO) changed its name to the Government Accountability Office in 2004.

47 U.S. Government Accountability Office. 2005. Social Security Reform: Answers to Key 

Questions. GAO-05-193SP. Washington, D.C.: May 2005.

48 Craig Thornton et al, “Evaluation of the Ticket to Work Program: Assessment of Post-Rollout 

Implementation and Early Impacts, Volume 1,” May 2007, p. 34.

49 Ibid, p. 35. 

50 Social Security Administration, "Ticket Tracker," The Work Site. 

http://www.ssa.gov/work/Ticket/ticket_info.html 
Final Report to the President and Congress 168 

168 

51 Maximus, “Inside Ticket Quarterly Newsletter. Ticket to Work Newsletter (Summer 2007),” 

http://www.yourtickettowork.com/marketing_inside_ticket_quarterly.

52 Thornton, Craig et al, “Evaluation of the Ticket to Work Program Initial Evaluation Report,” 

February 2004, p. 71.

53 Thornton, Craig et al, “Evaluation of the Ticket to Work Program: Assessment of Post-Rollout 

Implementation and Early Impacts, Volume 1,” May 2007, p. 131.

54 Ibid, p. 254.

55 Ticket to Work and Work Incentives Advisory Panel, “Advice Report to the Commissioner of 

the Social Security Administration: Design Issues Relating to the Adequacy of Incentives Study,” 

June 18, 2002, http://www.ssa.gov/work/panel/panel_documents/reports.html

56 Social Security Administration, “Amendments to the Ticket to Work and Self-Sufficiency 

Program: Notice of proposed rulemaking,” 70 Federal Register 189 (September 30, 2005), pp. 

57222-57237.

57 Social Security Administration, “Improvements to the Ticket to Work and Self-Sufficiency 

Program: Notice of proposed rulemaking,” 72 Federal Register 155 (August 13, 2007), pp. 45191-

45199.

58 Virginia Commonwealth University Benefits Assistance Resource Center, http://www.vcubarc.org/

59 Social Security Administration, “BPAO 2004 Customer Satisfaction Survey Results,” 2004.

60 Public Comment, Ticket to Work and Work Advisory Panel Quarterly Meetings 2004, 2005, 

2006.

61 Bruyere, Susanne and Thomas Golden. “Evaluation and Future Prospects of US Return to 

Work Policies for Social Security Beneficiaries,” Employment and Disability Institute, 2007.

62 Social Security Administration, “Work Incentives Planning and Assistance (WIPA) Cooperative 

Agreement Awards,” The Work Site. 

http://www.socialsecurity.gov/work/ServiceProviders/WIPADirectory.html 

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

64 Ticket to Work and Work Incentives Advisory Panel, “Annual Report to the President and 

Congress, Year Five,” December, 2005.

65 Livermore, G. A., “Wage Reporting and Earnings-Related Overpayments in the Social Security 

Disability Programs: Status, Implications, and Suggestions for Improvements,” Report prepared 

for the Ticket to Work and Work Incentives Advisory Panel. Cornell Center for Policy Research, 

Washington, DC, 2003, http://www.ssa.gov/work/panel/panel_documents/briefingpapers.html

66 National Council on Disability, “The Social Security Administration's Efforts to Promote 

Employment for People with Disabilities: New Solutions for Old Problems,” November 30, 

2005.

67 Bruyere, Susanne and Thomas Golden, “Evaluation and Future Prospects of US Return to Work 

Policies for Social Security Beneficiaries,” Employment and Disability Institute, 2007, p 79.

68 Ireys, Henry et al, “The Interaction of Policy and Enrollment in the Medicaid Buy-In Program, 

2005 Final Report,” Mathematica Policy Research, Inc. pp. 3 - 4.
Final Report to the President and Congress 169 

169 

69 Liu, Su and Bob Weathers, “Do Participants Increase Their Earnings After Enrolling in the 

Medicaid Buy-In Program?”, Mathematica Policy Research, Inc., May, 2007, p. 2. 

70 Schimmel, Jody et al. “How Do Buy-In Participants Compare with Other Medicaid Enrollees 

with Disabilities?”, Mathematica Policy Research, Inc., Working with Disability Policy Brief, 

Number 5, June 2007, www.mathematica-mpr.com/publications/PDFs/WWDcompare.pdf

71 Liu, S. and H.T. Ireys, “Participation in the Medicaid Buy-in program: A statistical profile from 

integrated data. Final Report,” Mathematica Policy Research, Inc., May 2006.

72 For state-by-state information on state’s Medicaid Buy-In work requirements go to 

www.medicaidbuyin.org and go to “Medicaid Buy-In Programs: Development, Program Design 

and Enrollment” and see Table 4 - Work-Related Policies and Protections.

73 Iowa: Iowa Department of Human Services, “Iowa: Medicaid for Employed People with 

Disabilities: A Client Profile and Program Evaluation,” Figure 6-9, March 11, 2005, p. 46. 

http://www.dhs.state.ia/dhs_homepage/docs/MEPD-04_report-master.pdf 

Kansas: University of Kansas Medicaid Infrastructure Change Evaluation Project, “Satisfaction 

Survey of Medicaid Buy-In Participants,” Reported in Policy Brief #6, November 2004, 

http://www.workinghealthy.org/WHpolicybrierno6.pdf 

Minnesota: Minnesota Department of Human Services, “How MA-EPD Does the Job-Survey of 

Minnesotans Enrolled in the Medical Assistance for Employed Persons with Disabilities 

Program,” Table 21, August, 2004, p. 36. 

http://www.dhs.state.mn.us/main/group/disabilities/documents/pub/dhs_id_029455.pdf 

Utah: UWIN Evaluation Team, Utah State University and University of Utah, “Self Reported 

Experiences of Individuals with Disabilities Involved in the Utah Medicaid Work Incentives 

Program,” Table 21, April 13, 2003, p. 36. 

http:www.uwin.org/uwin/webpage/products/MWIreportFINAL4-15-03.pdf 

74 Liu, Su and Bob Weathers, “Do Participants Increase Their Earnings After Enrolling in the 

Medicaid Buy-In Program?”, Mathematica Policy Research, Inc., May, 2007, p. 3.

75 Gimm, Gilbert W. and Bob Weathers, “What Is the Demonstration to Maintain Independence 

and Employment (DMIE) and Who Is Participating? Working with Disability Work and 

Insurance In Brief #6," Mathematica Policy Research, Inc. August, 2007.

76 Gimm, Gilbert W., et al, “Who Are the Top Earners in the Medicaid Buy-In Program,” 

Working with Disability Work and Insurance in Brief #3, Mathematica Policy Research, Inc., 

March, 2007. 

77 Social Security Administration, “Amendments to the Ticket to Work and Self-Sufficiency 

Program: Notice of proposed rulemaking,” 70 Federal Register 189, September 30, 2005, pp. 

57222-57237.

78 U.S. Department of Education, National Center for Education Statistics, “The Condition of 

Education 2007,” (NCES 2007-064). Washington, DC, 2007.

79American Counsel on Education Business-Higher Education Forum, “Building a Nation of 

Learners: The Need for Changes in Teaching and Learning to Meet Global Challenges,” 

Washington, 2003.

80 U.S. Department of Labor, “America's Dynamic Workforce,” Washington, DC, 2006. 

http://www.dol.gov/asp/media/reports/workforce2006/ADW2006_Full_Text.pdf
Final Report to the President and Congress 170 

170 

81 EPE Research Center, Editorial Projects in Education [EPE], “Diplomas count 2007: Ready for 

what? Preparing students for college, careers, and life after high school,” Education Week, 26(40), 

2007. http://www.edweek.org/ew/toc/2007/06/12/index.html

82 U.S. Department of Education, Office of Special Education and Rehabilitative Services, Office 

of Special Education Programs, 26th Annual (2004) “Report to Congress on the Implementation 

of the Individuals with Disabilities Education Act, Vol. 1,” Washington, DC, April, 2006 

83 Wagner, M., L. Newman, R. Cameto, N. Garza, and P. Levine, “After High School: A First 

Look at the Postschool Experiences of Youth with Disabilities. A Report from the National 

Longitudinal Transition Study-2 (NLTS2),” Menlo Park, CA, SRI International, 2005, Available at 

www.nlts2.org/reports/2005_04/nlts2_report_2005_04_complete.pdf 

84 Horvath-Rose, A.E., D.C. Stapleton, and B. O'Day, “Trends in Outcomes for Young People 

with Disabilities: Are We Making Progress?,” Journal of Vocational Rehabilitation Volume 21, 

Number 3, 2004, pp. 175 – 18. http://digitalcommons.ilr.cornell.edu/edicollect/93

85 U.S. General Accounting Office, “Highlights of a GAO Forum, Workforce Challenges and 

Opportunities For the 21st Century: Changing Labor Force Dynamics and the Role of 

Government Policies,” GAO-04-845SP,” Washington, DC, June, 2004.

86 Karoly, Lynn A. and Constantijn W.A. Panis, “The 21st Century at Work: Forces Shaping the 

Future Workforce and Workplace in the United States,” MG-164, Santa Monica, California, The 

RAND Corporation, 2004.

87 Purcell, Patrick, “Older Workers: Employment and Retirement Trends. CRS Report for 

Congress,” RL30629, Congressional Research Service, Updated September 7, 2007.

88Karoly, Lynn A. and Constantijn W.A. Panis, “The 21st Century at Work: Forces Shaping the 

Future Workforce and Workplace in the United States,” MG-164, Santa Monica, California, The 

RAND Corporation, 2004.

89 U.S. Government Accountability Office. “Modernizing Federal Disability Policy,” GAO-07-

934SP, Washington, DC, August 2007.

90 Turner, Mark D., and Burt S. Barnow, “Living Wage and Earned Income Tax Credit: A 

Comparative Analysis,” The Employment Policies Institute, January, 2003, www.EPIonline.org

91 U.S. Department of Labor Employment Standards Administration Wage and Hour Division: 

http://www.dol.gov/esa/whd

92 Stapleton, David C., and William A. Erickson, “Characteristics or Incentives: Why Do 

Employment Outcomes for the SSA Beneficiary Clients of VR Agencies Differ, on Average, from 

Those of Other Clients?,” Cornell University Institute for Policy Research, 2005.

93 U.S. Department of Health and Human Services, Centers for Medicare and Medicaid Services, 

“National Health Expenditure Projections 2006-2016,” January 2007.

94 Organisation for Economic Cooperation and Development, “OECD Health Data 2007,” 

updated July 2007.

95 Kaiser Family Foundation, “Health Care Spending in the United States and OECD Countries,” 

January 2007.
Final Report to the President and Congress 171 

171 

96 DeNavas-Walt, Carfmen, Bernadette D. Proctor, and Cheryl Hill Lee, U.S. Census Bureau, 

Current Population Reports, P60-231, “Income, Poverty, and Health Insurance Coverage in the 

United States: 2005,” Washington, D.C., 2006.

97DeNavas-Walt, Carmen, Bernadette D. Proctor, and Jessica Smith, U.S. Census Bureau, Current 

Population Reports, P60-233, “Income, Poverty, and Health Insurance Coverage in the United 

States: 2006,” Washington, D.C., 2007.

98 Gilmer, T., and R. Kronick, “It’s the Premiums, Stupid: Projections of the Uninsured Through 

2013,” Health Affairs Web Exclusive, w5-143–w5-151, April 5, 2005.

99 Kaiser Commission on Medicaid and the Uninsured, “Changes in Employees’ Health Insurance 

Coverage, 2001–2005,” Washington, D.C., Henry J. Kaiser Family Foundation, October, 2006.

100 Kaiser Family Foundation and Health Research and Educational Trust, “Employer Health 

Benefits 2006: Annual Survey,” Washington, DC, Kaiser Family Foundation, 2006.

101 Burton, A., I. Friedenzohn, and E. Martinez-Vidal, “State Strategies to Expand Health 

Insurance Coverage: Trends and Lessons for Policymakers,” The Commonwealth Fund, February 

2007.

102 The Robert Wood Johnson Foundation, State Coverage Initiatives, 

http://statecoverage.net/matrix/index.html

103 Ticket to Work and Work Incentives Advisory Panel, Report from the Beneficiary Summit. 

“Voices for Change: Beneficiaries Paving the Way to Work, A Roadmap to Program 

Improvement,” July 26, 2007.

104 Panel members visited a teleservice center and field office in the Seattle area, and field offices in 

the Sacramento, Washington, DC, and Long Island areas. This was not a comprehensive study, 

but we did come away with some consistent impressions.

105 Social Security Advisory Board, “Annual Report Fiscal Year 1998,” October 1998.

106 Social Security Advisory Board, Letter to Subcommittee on Social Security of the Committee on 

Ways and Means, U.S. House of Representatives, February 14, 2007. 

107 Ticket to Work and Work Incentives Advisory Panel, Letter to Commissioner Barnhart. 

“Notice of Proposed Rule Making: Amendments to the Ticket to Work and Self-Sufficiency 

Program (Volume 70, Number 189),” December 22, 2005. Note: This letter includes references 

to Panel recommendations made to date. 

108 Ticket to Work and Work Incentives Advisory Panel, Letter to Commissioner Barnhart. 

“Notice of Proposed Rule Making: Amendments to the Ticket to Work and Self-Sufficiency 

Program (Volume 70, Number 189), Publication of Final Rule,” September 28, 2006. 

109 Ticket to Work and Work Incentives Advisory Panel, Letter to Commissioner Barnhart. 

“Publication of Final Rule, Ticket to Work and Self-Sufficiency Program; Follow Up to Panel’s 

September 28, 2006 Letter,” November 30, 2006. 

110 Ticket to Work and Work Incentives Advisory Panel, Letter to Commissioner Astrue. “Notice 

of Proposed Rule Making: Amendments to the Ticket to Work and Self-Sufficiency Program 

(Volume 72, Number 155),” October 5, 2007. 

111 The Ticket to Work and Work Incentives Advisory Panel, “The Crisis in EN Participation —A 

Blueprint for Action,” February, 2004, p. ii. 
Final Report to the President and Congress 172 

172 

112 Ibid, pp. 12-14. 

113 Ticket to Work and Work Incentives Advisory Panel, Letter to Commissioner Barnhart. 

“Marketing the Ticket to Work program and Work Incentives,” November 6, 2006.

114 U.S. Government Accountability Office, “Improved Processes for Planning and Conducting 

Demonstrations May Help SSA More Effectively Use Its Demonstration Authority,” GAO-05-19, 

Washington, DC, November 4, 2004. 

115 Balkus, Richard and Susan Wilschke, “Treatment of Married Couples in the SSI Program,” 

Issue Paper No 2003-01, Social Security Administration Office of Policy, 2003. 

116 Ibid.

117 Ibid. 

118 PL 108-311, Working Families Tax Relief Act of 2004, October 4, 2004.

119 Vaughn, John, Chairperson, National Council on Disability. “Testimony Presented to the 

Subcommittee on Social Security of the House Committee on Ways and Means Regarding Social 

Security Disability Backlogs,” February 14, 2007. 

120 This recommendation is identical to one recommended by the 1986 Disability Advisory 

Council. 

121 Program Operations Manual System (POMS) DI 10520.001. Impairment-Related Work 

Expenses (IRWE), http://www.ssa.gov/regulations.

122 Program Operations Manual System (POMS) DI 10520.010. Definitions, 

http://www.ssa.gov/regulations.

123 Social Security Administration, “Report on Supplemental Security Income: Income and 

Resource Exclusions and Disability Insurance Earnings-Related Provisions,” Office of Policy, 

Washington, DC, March 2000.

124 Social Security Advisory Board, “Statement on the Supplemental Security Income Program,” 

Washington, DC, May 2005, p. 8. http://www.ssab.gov/documents/2005SSIReport.pdf

125 Social Security Administration, “Vocational Rehabilitation Provider’s Handbook, Updated 

1/18/06,” Baltimore, MD, http://www.ssa.gov/work/ServiceProviders/providers.html

126 For additional information see: 1) U.S. General Accounting Office, “SSA Disability: Enhanced 

Procedures and Guidance Could Improve Service and Reduce Overpayments to Concurrent 

Beneficiaries,” GAO-02-802, Washington, DC, September 2002. 

http://www.gao.gov/new.items/d02802.pdf and 2) Livermore, G. A., “Wage Reporting and 

Earnings-related Overpayments in the Social Security Disability Programs: Status, Implications, 

and Suggestions for Improvements,” Report prepared for the Ticket to Work and Work 

Incentives Advisory Panel, 2003. 

127 U.S. General Accounting Office, “SSA Disability: Enhanced Procedures and Guidance Could 

Improve Service and Reduce Overpayments to Concurrent Beneficiaries,” GAO-02-802, 

Washington, DC, September 2002.

128 Social Security Administration, “SSA Strategic Plan FY 2006 – FY 2011,” Baltimore, MD, 

http://www.ssa.gov/strategicplan.html
Final Report to the President and Congress 173 

173 

129 Social Security Administration, “Social Security Administration Budget, Justification of 

Estimates for Appropriations Committees, FY 2008,” Baltimore, MD. 

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

130 Livermore, G.A. “Wage Reporting and Earnings-related Overpayments in the Social Security 

Disability Programs: Status, Implications, and Suggestions for Improvements,” Report prepared 

for the Ticket to Work and Work Incentives Advisory Panel., 2003.

131 Ibid, p. 24.

132 Social Security Administration, “Performance and Accountability Report for Fiscal Year 2004,” 

Baltimore, MD. http://www.ssa.gov/finance/fy04_accountability.html

133 Social Security Advisory Board, “Statement on the Supplemental Security Income Program,” 

May 2005, p.8. http://www.ssab.gov/documents/2005SSIReport.pdf

134 Office of Management and Budget, “Agency Information Collection Activities: Proposed 

Request,” Federal Register Vol. 70 No. 172, September 7, 2005, p. 53266. 

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

135 Social Security Administration, “Annual Report of the Supplemental Security Income 

Program,” Baltimore, MD, May, 2006. 

136 Office of Management and Budget. Budget of the United States Government, FY 2007.

137Office of Management and Budget. Budget of the United States Government, FY 2008. 

http://www.whitehouse.gov/omb/budget/fy2008/budget.html

138 See the Panel’s May 3, 2006 letter to Commissioner Barnhart (Issuance of Receipts to 

Acknowledge Submission of Reports of Changes in Work or Earnings Status of Beneficiaries with 

Disabilities). http://www.ssa.gov/work/panel/panel_documents/official_correspondence.html

139 Social Security Administration, “SSA Strategic Plan for 2006-2011,” Baltimore, MD. 

http://www.ssa.gov/strategicplan.html

140 Social Security Administration, “SSI Disabled Recipients Who Work,” 1990-2006 Reports.

141 Gallagher, Tanya M., “Enhancing earnings and Income Through Self-Determination for AOI 

Targeted Groups,” Adequacy of Incentives (AOI) Advisory Group, August 2004, September 

2004. Report prepared for the Social Security Administration. Disability Research Institute: 

University of Illinois at Urbana-Champaign. http://www.dri.uiuc.edu/research/p03-

08h/AOIFinal.pdf 

142 Social Security Administration, “Cooperative Agreements for Work Incentives Planning and 

Assistance Projects: Program Announcement No. SSA-OESP-06-1,” 71 Federal Register 94, May 

16, 2006, pp. 28401-28413. http://www.gpoaccess.gov/fr/index.html 

143 Section 100, Rehabilitation Act of 1973 (as amended)/Workforce Investment Act. 

144 U.S. Government Accountability Office, “Modernizing Federal Disability Policy,” GAO-07-

934SP, Washington, DC, August 2007. 

145 National Council on Disability, “The Social Security Administration's Efforts to Promote 

Employment for People with Disabilities: New Solutions for Old Problems,” Washington, DC, 

November 30, 2005. 
Final Report to the President and Congress 174 

174 

146 Social Security Advisory Board, “A Disability System for the 21st Century,” Washington, DC, 

September, 2006. 

147 Social Security Advisory Board, “The Social Security Definition of Disability,” Washington, 

D.C., 2003. 

148 Social Security Advisory Board, “A Disability System for the 21st Century,” September 2006. 

http://www.ssab.gov/documents/disability-system-21st.pdf 

149 Ibid. 

150 Office of Personnel Management, “Federal Retirement Projections,” 

http://www.opm.gov/feddata/retire/rs2004_projections.pdf.) OPM projects 18.5 percent of the 

(Non-Seasonal, Full-Time Permanent (NSFTP) workforce will retire through Fiscal Year 2010 

(approximately 290,000). 

151 Social Security Advisory Board, “A Disability System for the 21st Century,” September 2006. 

http://www.ssab.gov/documents/disability-system-21st.pdf 

152 In 1972, the Supplemental Security Income (SSI) program was created and the definition of 

disability was changed slightly from a permanent disability to one lasting at least 12 months. 

153 See, e.g., GAO, “Wide Array of Programs Needs to be Examined in Light of 21st Century 

Challenges,” Report No. GAO-05-626 (2005); NCD, “The Social Security Administration's 

Efforts to Promote Employment for People with Disabilities New Solutions for Old Problems,” 

National Council on Disability (2005); NCD, “Achieving Independence: The Challenge for the 

21st Century - A Decade of Progress in Disability Policy Setting an Agenda for the Future,” 

(1996); NCD, “Furthering the Goals of the Americans with Disabilities Act Through Disability 

Policy Research in the 1990s,” (1992); NCD, “ADA Watch-Year One: A Report to the President 

and the Congress on Progress in Implementing the Americans with Disabilities Act,” (1993); 

NCD, “Sharing the Risk and Ensuring Independence: A Disability Perspective on Access to 

Health Insurance and Health-Related Services, A Report to the President and Congress of the 

United States,” (1993); NCD, “Inclusionary Education for Students with Disabilities: Keeping the 

Promise,” (1994). 

154 Walker, David M., Comptroller General of the United States, Social Security Reform 

presentations, 1999 and 2001. “Truth and Transparency: The Federal Government's Financial 

Condition and Fiscal Outlook,” September 17, 2003. 

155 Social Security Advisory Board, “The Social Security Definition of Disability,” 2003). 

156 National Council on Disability, “Toward Independence: An Assessment of Federal Laws and 

Programs Affecting Persons with Disabilities,” February 1986; National Council on Disability, 

“On the Threshold of Independence,” January, 1988; National Council on Disability, “The Social 

Security Administration’s Efforts to Promote Employment for People with Disabilities: New 

Solutions for Old Problems,” November 30, 2005; National Council on Disability, 

“Empowerment for Americans with Disabilities: Breaking Barriers to Careers and Full 

Employment,” October 1, 2007. 

157 Imparato, Andrew, “Community Services and Supports: Planning Across the Generations,” 

Testimony Before the U.S. Senate Committee on Health, Education, Labor, and Pensions, July 10, 

2007. 

158 National Council on Independent Living, “Being American: the Way Out of Poverty,” 

September 30, 2006. 
Final Report to the President and Congress 175 

175 

159 Ticket to Work and Work Incentives Advisory Panel, “Voices for Change: Beneficiaries Paving 

the Way to Work, A Roadmap to Program Improvement,” July 26, 2007. 

160 Houtenville, A. J., Erickson, W. A., Lee, C. G., “Disability Statistics, from the American 

Community Survey (ACS),” Ithaca, NY: Cornell University, Rehabilitation Research and Training 

Center on Disability Demographics and Statistics (StatsRRTC), March 16, 2007, 

www.disabilitystatistics.org. 

161 Ticket to Work and Work Incentives Advisory Panel, “Final Advice Report on Ticket Program 

Notice of Proposed Rule Making,” July 2001. 

162 Ticket to Work and Work Incentives Advisory Panel, “Annual Report to the President, 

Congress, and the Commissioner of SSA: Year Six,” Advisory Letter to Commissioner Re. NPRM 

September 2005. http://www.ssa.gov/work/panel/panel_documents/reports.html 

163 Ibid. 

164 Ticket to Work and Work Incentives Advisory Panel, “Annual Report to the President, 

Congress, and the Commissioner of SSA: Year Two,” August, 2002. 

http://www.ssa.gov/work/panel/panel_documents/reports.html 

165 Ticket to Work and Work Incentives Advisory Panel, Advisory Letter to Commissioner Re. 

NPRM on Continuation of Benefit Payments, August, 2003. 

166 Ticket to Work and Work Incentives Advisory Panel, Advisory Letter to Commissioner Re. 

NPRM on the Reinstatement of Entitlement to Disability Benefits (EXR), October, 2003. 

167 Ticket to Work and Work Incentives Advisory Panel, “Advice Report on Employment 

Networks,” February, 2004. http://www.ssa.gov/work/panel/panel_documents/reports.html

168 Ticket to Work and Work Incentives Advisory Panel, “Annual Report to the President, 

Congress, and the Commissioner of SSA: Year Six,” Advisory Letter to Commissioner Re. NPRM 

September 2005 http://www.ssa.gov/work/panel/panel_documents/reports.html

169 Ticket to Work and Work Incentives Advisory Panel, “Annual Report to the President, 

Congress, and the Commissioner of SSA: Year Three,” May, 2003. 

http://www.ssa.gov/work/panel/panel_documents/reports.html 

170 Ticket to Work and Work Incentives Advisory Panel, Letter to Sue Suter, Associate 

Commissioner, SSA’s Office of Employment Support Programs, February 11, 2005. 

171 Ticket to Work and Work Incentives Advisory Panel, Letter to Congressman Shaw and Senator 

Grassley, November 20, 2003.