SUPPLEMENTAL 

SECURITY INCOME

SSA Could 

Strengthen Its Efforts 

to Encourage 

Employment for 

Transition-Age Youth

Report to the Chairman, Subcommittee 

on Human Resources, Committee on 

Ways and Means, House of 

Representatives

May 2017

GAO-17-485

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-485, a report to the 

Chairman, Subcommittee on Human 

Resources, Committee on Ways and Means

House of Representatives

May 2017

SUPPLEMENTAL SECURITY INCOME

SSA Could Strengthen Its Efforts to Encourage 

Employment for Transition-Age Youth

What GAO Found

The Social Security Administration’s (SSA) primary approach for encouraging 

employment for transition-age youth (ages 14 to 17) with disabilities who receive 

Supplemental Security Income (SSI) is work incentives that allow them to keep 

at least some of their SSI benefits and Medicaid coverage while they work. But 

few transition-age youth benefit from these incentives. SSI is a means-tested 

program that provides cash benefits to eligible low-income aged, blind, and 

disabled individuals. SSA administers several work incentives that allow SSI 

recipients to exclude some income and expenses when calculating SSI benefits. 

The work incentive targeted specifically to younger SSI recipients is the Student 

Earned Income Exclusion (SEIE), which allows income to be excluded from 

benefits calculations if a recipient is a student under age 22. However, less than 

1.5 percent of all transition-age youth—and generally less than half of those with 

earnings—benefited from SEIE in 2012 through 2015. SSA does not analyze 

these data, and thus cannot determine why the majority of youth with earnings 

are not benefiting from SEIE, when they may be eligible. SSA data also show 

that almost no youth benefited from other incentives that allow them to exclude 

earnings used for specific purposes, such as the Impairment-Related Work 

Expenses incentive. The effectiveness of SSA-administered work incentives may 

be further limited because, according to SSA and other officials, youth and their 

families are often unaware of or do not understand them, and may fear that work 

will negatively affect their benefits or eligibility. SSA policy requires staff to 

provide accurate and meaningful information about relevant SSI policies to 

claimants and recipients. However, GAO found that SSA does not have sufficient 

procedures in place to ensure that information on work incentives and how work 

affects benefits and eligibility is consistently communicated to youth and their 

families. As a result, SSA may miss opportunities to promote work incentives and 

other supports, allay fears, and potentially reduce dependence of transition-age 

youth on SSI benefits.

SSA does not have a systematic way to connect transition-age youth on SSI to 

state Vocational Rehabilitation (VR) agencies that provide training and 

employment services under the VR State Grants program administered by the 

Department of Education (Education). Although youth receiving SSI are 

generally presumed to be eligible for VR services, GAO found that less than 1 

percent had an open VR service record in 2015 in four of the five states from 

which GAO collected VR data. Legislation in 1999 created the Ticket to Work 

and Self-Sufficiency program, which expanded the number and types of 

employment service providers for individuals with disabilities. However, SSA

limited eligibility to recipients age 18 and older. While transition-age youth 

receiving special education services can be connected to VR agencies through 

their schools, the extent to which this happens—and whether they are on SSI—is 

unknown because data to make such determinations are not systematically 

collected by SSA or schools. Federal standards for internal control call for 

agencies to use quality information to achieve their objectives. Without relevant 

data or additional options for connecting youth to VR services, SSA cannot 

ensure that transition-age youth on SSI are being connected to these services, 

which can help to prepare them for adulthood and the workforce.

View GAO-17-485. For more information, 

contact Daniel Bertoni at (202) 512-7215 or 

bertonid@gao.gov

Why GAO Did This Study

The number of individuals with

disabilities under age 18 receiving SSI 

benefits increased by about 44 percent 

from 2000 through 2016. Youth ages 

14 to 17 with disabilities face many

challenges achieving self-sufficiency 

as they transition to adulthood. GAO 

was asked to examine SSA’s efforts to 

encourage employment for these 

transition-age youth.

This report examines 1) SSA efforts to

encourage employment for transitionage youth on SSI as they move toward 

adulthood and their effectiveness; and 

2) the extent to which SSA helps 

ensure these youth receive vocational 

rehabilitation services. GAO analyzed 

SSA data on work incentives for 

calendar years 2012-2015, the most 

recent available, and data from five 

state VR agencies for calendar year 

2015; reviewed relevant laws, policies, 

and research; and interviewed SSA 

staff and state VR officials in several 

states chosen for their SSI youth 

populations and VR outcomes.

What GAO Recommends

GAO recommends SSA 1) analyze 

why youth on SSI with earnings did not 

benefit from SEIE, 2) improve 

communication about work incentives 

and rules, 3) work with Education to 

determine how many youth on SSI are 

not connected to VR services, and 4) 

explore options to further connect 

them. SSA agreed in whole or in part 

with three recommendations. SSA 

disagreed that its communication on 

work incentives and rules needs to be 

improved, stating field staff provides 

information to youth, and it has created 

new written material. GAO maintains 

SSA’s communication could be 

improved as presented in this report.
Page i GAO-17-485 Supplemental Security Income

Letter 1

Background 5

SSA’s Efforts to Encourage Employment Reach Few TransitionAge Youth and SSA Does Not Consistently Convey Information 

About Working 10

SSA Does Not Have a Systematic Way to Connect Transition-Age 

Youth on SSI to Vocational Rehabilitation Services and Data 

Sharing is Limited 25

Conclusions 34

Recommendations 36

Agency Comments and Our Evaluation 37

Appendix I Scope and Methodology 40

Appendix II Comments from the Social Security Administration 47

Appendix III Comments from the Department of Education 51

Appendix IV GAO Contact and Staff Acknowledgments 53

Table

Table 1: Key Employment Supports That Allow Supplemental 

Security Income (SSI) Recipients to Continue Receiving 

SSI Benefits While They Work, Calendar Year 2017 12

Figures

Figure 1: Percentage of Transition-Age Youth (Ages 14-17) on 

Supplemental Security Income with Earnings Who 

Benefited from the Student Earned Income Exclusion 

(SEIE), by Age, Calendar Year 2012 15

Figure 2: Source of Referral to Vocational Rehabilitation for Youth, 

Ages 14-17, for Vocational Rehabilitation Service 

Records Closed in Fiscal Year 2015 29

Contents
Page ii GAO-17-485 Supplemental Security Income

Abbreviations:

BWE Blind Work Expenses

CDR Continuing disability reviews

DAF Disability Analysis File

DDS State disability determination services

Education Department of Education

IDEA Individuals with Disabilities Education Act

IEP Individualized education program

IRWE Impairment-Related Work Expenses

ODD Office of Disability Determinations

PASS Plan to Achieve Self-Support

POMS Program Operations Manual System

PROMISE Promoting the Readiness of Minors in 

Supplemental Security Income 

RSA Rehabilitation Services Administration

Section 504 Section 504 of the Rehabilitation Act of 1973

SEIE Student Earned Income Exclusion

SGA Substantial gainful activity

SSA Social Security Administration

SSDI Social Security Disability Insurance 

SSI Supplemental Security Income 

Ticket to Work Ticket to Work and Self-Sufficiency program

VR Vocational Rehabilitation

WIOA Workforce Innovation and Opportunity Act

WIPA Work Incentives Planning and Assistance

YTD Youth Transition Demonstration

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Page 1 GAO-17-485 Supplemental Security Income

441 G St. N.W.

Washington, DC 20548

May 17, 2017

The Honorable Adrian Smith

Chairman

Subcommittee on Human Resources

Committee on Ways and Means

House of Representatives

Dear Mr. Chairman:

The Supplemental Security Income (SSI) program provides cash 

payments to eligible low-income individuals with disabilities, including 

children and teenagers. In December 2016, the Social Security 

Administration (SSA) paid SSI benefits to over 1.2 million recipients under 

age 18, and their numbers increased by about 44 percent from December 

2000 through December 2016.1

Transition-age youth (those ages 14 to 17) who receive SSI benefits face 

numerous challenges achieving self-sufficiency as they move into 

adulthood.2 We previously reported that transition-age youth with 

disabilities typically leave an environment in which they receive most of 

their services as entitlements through their schools to one in which 

services can be more difficult to access.

3 Furthermore, according to SSA 

officials and staff, as well as others, these youth may face real or 

 1

SSA Monthly Statistical Snapshot, December 2016 (released January 2017). In calendar 

year 2015, recipients under age 18 made up approximately 16 percent of the total SSI 

recipients and represented 18.5 percent of federal SSI payments (Social Security 

Administration, Annual Report of the Supplemental Security Income Program, 2016).

2

In this report, we use the term “transition-age” youth to refer to youth ages 14 to 17 

receiving SSI because when SSI recipients turn 18, their eligibility for SSI is generally 

required to be reassessed against adult criteria. Furthermore, our previous work has found 

that the transition from high school is an especially challenging time for individuals with 

disabilities because they are often no longer automatically entitled to transition services 

they received as students under the Individuals with Disabilities Education Act and must 

apply for and establish eligibility for services as adults, often from multiple agencies.

3

GAO, Youth with Autism: Roundtable Views of Services Needed During Transition into 

Adulthood, GAO-17-109 (Washington, D.C.: Oct. 18, 2016); Students with Disabilities: 

Better Federal Coordination Could Lessen Challenges in the Transition from High School, 

GAO-12-594 (Washington, D.C.: July 12, 2012). 

Letter
Page 2 GAO-17-485 Supplemental Security Income

perceived disincentives to employment such as fear of losing SSI or 

health care benefits.4

Outcomes associated with the ability of youth receiving SSI to achieve 

self-sufficiency as they transition to adulthood are poor across several 

measures. Specifically, these individuals have low employment rates as 

well as high dropout and arrest rates, when compared to other youth.5

Encouraging youth on SSI to prepare for their future as adults, including 

thinking about employment, is important because research has found that 

of all SSI recipients found ineligible for benefits after age 18—the age at 

which SSA is generally required to assess recipients against adult criteria 

for the program—about 40 percent are unemployed at age 19, and only 

about a quarter earned enough to replace their lost SSI benefits.6 Further, 

research suggests that individuals who begin receiving SSI prior to age 

18 accumulate over 25 years of benefits on average.7

Both SSA and the Department of Education (Education) play a role in 

helping transition-age youth prepare for employment or postsecondary 

education while in school.8 In particular, youth receiving SSI who are 

students may be eligible for work incentives administered by SSA that 

allow them to keep some or all of their benefits even if employed. In 

addition, many of these youth will likely receive transition services through 

their schools and are generally presumed eligible for services provided by 

state vocational rehabilitation (VR) agencies under the VR State Grants

 4

Because youth receiving SSI are also generally eligible for Medicaid, recipients may fear 

that losing SSI benefits may result in losing health insurance as well.

5

Hemmeter, J., Kauff, J., and Wittenburg, D., Changing Circumstances: Experiences of 

Child SSI Recipients Before and After Their Age-18 Redetermination for Adult Benefits. 

Journal of Vocational Rehabilitation 30 (2009) 201–221. Wittenburg, D. and Loprest, P.,

Early Transition Experiences of Transition-Age Child SSI Recipients, Journal of Disability 

Policy Studies, Winter 2007; 18, 3.

6

Hemmeter, J., Kauff, J., and Wittenburg, D., Changing Circumstances: Experiences of 

Child SSI Recipients Before and After Their Age 18 Redetermination for Adult Benefits.

Journal of Vocational Rehabilitation 30 (2009) 201–221.

7

Rupp, K. and Scott, C., Length of Stay on the Supplemental Security Income Disability 

Program. Social Security Bulletin, Vol. 58, No. 1, Spring 1995. 

8

Other federal agencies, including the Departments of Labor and Health and Human 

Services, play a role in assisting youth transition to the workforce. For example, the 

Department of Labor’s Job Corps and Youth Discretionary Grants support employment of 

youth, and its American Jobs Center system supports employment of youth and others.
Page 3 GAO-17-485 Supplemental Security Income

program administered by Education.9 Given the low employment rates of 

these youth, we were asked to examine SSA’s efforts to encourage 

employment for transition-age youth on SSI.

This report examines: (1) how SSA encourages employment for 

transition-age youth on SSI as they move toward adulthood, and the 

effectiveness of these efforts, and (2) the extent to which SSA helps 

ensure that transition-age youth on SSI receive vocational rehabilitation 

services.

To address these objectives, we reviewed relevant federal laws, 

regulations, and policies on SSA-administered work incentives and 

supports that are relevant to transition-age youth on SSI, as well as 

federal laws related to vocational rehabilitation (VR) services provided by 

state agencies and transition services provided by schools. To identify 

SSA’s approaches for encouraging work among transition-age youth and 

to assess their effectiveness, we reviewed SSA documents and 

interviewed SSA officials.10 We reviewed SSA data on the number of 

youth ages 14 to 17 using work incentives. Specifically, we analyzed data 

on the work incentive targeted to youth, the Student Earned Income 

Exclusion (SEIE), which allows an SSI recipient who is a student to earn 

additional income before his or her benefits are reduced, as well as other 

SSA-administered work incentives. We analyzed data for 2012 through 

2015, the most recent data available.

In addition, to further understand SSA’s approaches and the effectiveness 

of work incentives available to transition-age youth, we conducted a 

broad literature search and review on research or studies pertaining to 

SSA work incentives and demonstration projects that pertain to transitionage youth and reviewed information provided to youth and their families 

by SSA in-person and by mail. To inform both of our objectives, we visited 

two states—Florida and New York—where we interviewed local SSA field

 9

The Rehabilitation Act of 1973, as amended by the Workforce Innovation and 

Opportunity Act, sets the eligibility requirements for VR services. To be eligible, an 

individual must be an “individual with a disability,” which means that the individual (1) has 

a physical or mental impairment which constitutes or results in a substantial impediment to 

employment for the individual, and (2) can benefit in terms of an employment outcome 

from VR services; and the individual must also require VR services to prepare for, secure, 

retain, advance in, or regain certain employment. Individuals receiving SSI are generally 

presumed to meet these requirements.

10In the report, when we refer to SSA officials, we mean knowledgeable individuals in 

SSA’s central offices. 
Page 4 GAO-17-485 Supplemental Security Income

office technical or supervisory staff,11 school district personnel, Work 

Incentives Planning and Assistance (WIPA) project staff, and other 

stakeholders.12 We selected these states because we wanted to obtain 

information from officials in a state that was participating in the ongoing 

Education-led Promoting the Readiness of Minors in Supplemental 

Security Income (PROMISE) initiative (New York) and in a state of similar 

size that is not participating in the initiative (Florida).13 We also 

interviewed SSA staff in a field office in California to gather additional 

information. All three states are among the states with the largest 

populations of SSI recipients and transition-age youth on SSI. To 

understand SSA’s efforts to help ensure youth are connected to VR 

services, we interviewed and obtained information from cognizant SSA 

and Education officials and state VR agency staff in five states—Florida, 

New Mexico, New York, Oklahoma, and Washington—selected based on 

variation in the size of the youth population served, employment

outcomes, and geographic diversity. We also analyzed data from these 

VR agencies on the number of youth on SSI they served. We assessed 

the reliability of data we received from SSA, Education, and state VR 

agencies by interviewing knowledgeable officials and reviewing relevant 

documentation and found them to be sufficiently reliable for the purposes 

of our reporting objectives. (See app. I for more information on our scope 

and methodology).

We conducted this performance audit from February 2016 to May 2017 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

 11In the report, when we refer to SSA staff, we mean SSA field office personnel, which 

generally included staff with technical expertise, but also included supervisory and 

managerial staff. 

12WIPA projects are funded by SSA and provide community-based work incentive 

expertise to beneficiaries of Social Security Disability Insurance (SSDI) or SSI benefits 

based on disability.

13The PROMISE initiative is a joint initiative of the departments of Education, Health and 

Human Services, Labor, and the Social Security Administration. Under PROMISE, 

Education is funding states that have developed model demonstrations to promote 

positive outcomes for youth ages 14 to 16 who receive SSI and for their families. SSA is 

responsible for funding the PROMISE demonstration evaluation. PROMISE began in 

2013. A draft interim impact and services report is expected to SSA by 2018, and a draft 

of the final evaluation is expected to SSA in winter 2022.
Page 5 GAO-17-485 Supplemental Security Income

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

SSA administers the SSI program, one of the largest federal programs 

providing assistance to people with disabilities. The SSI program was 

established in 1972 under Title XVI of the Social Security Act.14 The 

program provides cash benefits to low-income individuals, including 

children and youth, who meet financial eligibility requirements and who 

are blind or have disabilities. In December 2016, SSA paid SSI benefits to 

over 8.25 million individuals, including more than 1.2 million under age 

18. In calendar year 2015, SSA paid almost $55 billion in SSI benefits. 

The average monthly payment in December 2016 was $542; however, 

the average payment for recipients under 18 was higher ($650).15

According to SSA, in many states, eligibility for SSI also confers eligibility 

for Medicaid benefits.16

 14The SSI program was established by the Social Security Amendments of 1972 and 

became effective in 1974. Pub. L. No. 92-603, § 301, 86 Stat. 1329, 1465 (codified as 

amended at 42 U.S.C. §§ 1381-1383f).

15For the SSI program, SSA defines income as anything the recipient receives that can be 

used to meet their needs for food or shelter. It may be cash or in-kind income, such as 

food or shelter. The maximum individual benefit ($735 per month in calendar year 2017, 

up from $733 in calendar year 2016) is referred to as the federal benefit rate (FBR). 

Countable income is what remains after eliminating all amounts not considered income 

and applying all appropriate income exclusions. Countable income is then subtracted from 

the monthly federal benefit rate to determine how much a recipient or claimant’s SSI 

payment should be.

16According to SSA, in 18 states SSI does not confer automatic eligibility for Medicaid;

however, SSI applicants who are not categorically eligible for SSI may be Medicaideligible, depending on state eligibility rules.

Background

SSI
Page 6 GAO-17-485 Supplemental Security Income

To be eligible for SSI on the basis of disability, an individual must meet 

both financial and medical requirements. To determine eligibility, SSA 

staff, located in more than 1,200 field offices across the country, review 

SSI applications and verify financial eligibility.17 Following SSA’s initial 

review, state disability determination services (DDS) offices assess 

applicants’ medical eligibility for SSI.18 SSI has two sets of medical 

eligibility requirements to determine disability; one for adults (individuals 

age 18 and older) and one for individuals under 18. To be considered 

disabled, individuals under age 18 must have a medically determinable 

physical or mental impairment (or combination of impairments) that 

causes marked and severe functional limitations and that has lasted or is 

expected to last for a continuous period of at least 12 months or result in 

death.19 For adults to be considered disabled, they must have a medically 

determinable physical or mental impairment (or combination of 

impairments) that prevents them from doing any substantial gainful 

activity (SGA), and that has lasted or is expected to last for a continuous 

period of at least 12 months or result in death.20

 17To be financially eligible for SSI, individuals must meet income and resource 

requirements. Specifically, in 2016, the monthly countable income of an eligible individual 

or eligible married couple must have been less than the maximum federal SSI benefit rate 

of $733 per month for an eligible individual and $1,100 per month for an eligible married 

couple. In addition, an individual’s or couple’s monthly countable resources must generally 

be $2,000 or less for an individual or $3,000 or less for a married couple living together in 

2016. Certain resources, such as a recipient’s home and vehicle, are excluded from 

countable resources. In cases in which a parent has resources, under certain 

circumstances some of those resources are counted when determining their child’s 

eligibility for SSI. This is known as “deeming.” Deeming stops the month after a child turns 

age 18.

18State disability determination services, which are fully funded by the federal government, 

are state agencies responsible for developing medical evidence and making the initial 

determination on whether or not a claimant is disabled or blind under the law. See 

https://www.ssa.gov/disability/determination.htm.

1942 U.S.C. § 1382c(a)(3)(C). If a child is blind, he or she must meet the same definition of 

blindness as applies to adults. 

2042 U.S.C. § 1382c(a)(3). The impairment must be of such severity that the individual is 

not only unable to do his or her previous work, but also cannot engage in any other kind of 

substantial gainful work which exists in the national economy. Substantial gainful activity is 

generally work activity involving significant physical or mental activities that are done for 

pay or profit, whether or not a profit is realized. 20 C.F.R. § 416.972. A person who is 

earning more than a certain monthly amount is ordinarily considered by SSA to be 

engaging in substantial gainful activity. For 2016, the substantial gainful activity threshold 

was $1,820 per month for blind recipients and $1,130 per month for individuals with other 

disabilities.

SSI Eligibility, Continuing 

Disability Reviews, and 

Redeterminations
Page 7 GAO-17-485 Supplemental Security Income

SSI recipients, including those under age 18, undergo periodic continuing 

disability reviews (CDR) to ensure they continue to meet medical eligibility 

criteria. When a DDS first finds an individual medically eligible for SSI, it 

also assesses the likelihood that his or her disability will improve and, 

depending on that likelihood, develops a schedule for future CDRs. For 

SSI recipients under age 18 whose impairment is considered likely to 

improve, federal law requires SSA to conduct a CDR at least once every 

3 years.21 Under SSA policy, in cases in which medical improvement is 

not expected, a CDR is scheduled once every 5 to 7 years.22 During 

these CDRs, DDS collects evidence such as medical and educational 

records to determine whether the individual continues to meet medical 

eligibility criteria based on their disability. In addition, SSA also 

periodically conducts redeterminations on a sample of SSI case files to 

determine whether individuals continue to meet financial eligibility 

requirements. All SSI recipients are required to report certain information 

to SSA to help ensure that they continue to receive the correct benefit 

amounts. For example, SSI recipients must notify SSA when their 

earnings change and this reported information, in turn, may trigger a 

redetermination.

Federal law also requires that SSI recipients undergo a redetermination at 

age 18 to evaluate whether they meet adult (rather than youth) medical 

eligibility criteria.23 At the same time, SSA assesses whether the recipient 

continues to meet nonmedical (financial) eligibility requirements. This 

redetermination generally occurs within the year after a youth turns 18. If 

SSA determines a recipient does not meet adult eligibility criteria, he or 

she receives an unfavorable redetermination and ceases to receive SSI 

benefits.24 SSA reported that in fiscal year 2015, almost 57 percent of age 

18 redeterminations resulted in an initial unfavorable determination by 

 2142 U.S.C. § 1382c(a)(3)(H)(ii)(I).

22Infants determined to be eligible for SSI due in part to low birth weight are generally to 

have a CDR within 12 months of birth. Children with a disability that is expected to 

improve are to be scheduled for a CDR at 6 to 18 month intervals under SSA policy. SSA 

may also conduct unscheduled CDRs if questions arise about a recipient’s disability. 

2342 U.S.C. § 1382c(a)(3)(H)(iii).

24Individuals who receive an unfavorable age 18 redetermination may appeal the 

decision. In addition, individuals who receive an unfavorable age 18 redetermination may 

continue to receive SSI benefits for some time under certain circumstances, for example, 

if they are participating in appropriate vocational rehabilitation or individualized education 

programs and SSA determines that continued participation will increase the likelihood that 

they will be permanently removed from the disability rolls.
Page 8 GAO-17-485 Supplemental Security Income

DDS; however, approximately half of those decisions were appealed, so 

the final percent with unfavorable redeterminations is likely lower.25

Education’s VR State Grants program, authorized under the 

Rehabilitation Act of 1973, as amended, assists individuals with 

disabilities, including transition-age youth who may also be receiving SSI, 

find and keep employment, among other things. This program, 

administered by Education’s Rehabilitation Services Administration (RSA) 

within the Office of Special Education and Rehabilitative Services, is the 

largest program authorized under this Act26 and provided approximately 

$3.1 billion in formula grants to state VR agencies in fiscal year 2016. The 

grants support a wide range of services, individualized based upon the 

needs of the eligible individual with a disability, including: assessments; 

counseling, guidance, referrals, and job placements; vocational and other 

training; transportation; and, in certain circumstances, postsecondary 

education and training.

27 Individuals must apply and be determined 

eligible by the state VR agency to receive individualized VR services. If 

VR agencies lack the financial and staff resources to serve all eligible 

individuals in the state, they are generally required to prioritize individuals 

with the most significant disabilities.28 Individuals receiving disability 

benefits, including transition-age youth on SSI, are generally presumed 

eligible for VR services and considered individuals with a significant 

disability. However, depending on their disability, including level of 

functional impairment, SSI recipients may not be considered as having a 

“most significant” disability by the VR agency; and, if the VR agency has 

 25According to a 2015 study, SSA eventually ceased eligibility in 37 percent of age 18 

redeterminations that occurred in fiscal year 2009 (a year for which 98 percent of reviews 

have now had a final decision rendered). Hemmeter, J. and Bailey, M.S., Childhood 

Continuing Disability Reviews and Age-18 Redeterminations for Supplemental Security 

Income Recipients: Outcomes and Subsequent Program Participation, Social Security 

Administration, Research and Statistics Notes, No. 2015-03, October 2015. 

26Congressional Research Service, Rehabilitation Act: Vocational Rehabilitation State 

Grants, R43855 (Washington, D.C.: Dec. 30, 2014).

27States are generally required to provide 21.3 percent of total expenditures, except the 

state share is 50 percent for the cost of construction of a facility for community 

rehabilitation program purposes.

28In cases in which a VR agency must close certain eligibility categories because it is 

unable to provide services to all eligible applicants, it is said to be in “order of selection 

status.”

Vocational Rehabilitation
Page 9 GAO-17-485 Supplemental Security Income

implemented an order of selection, the individual may be put on a waiting 

list to receive services.

In 2014, the Workforce Innovation and Opportunity Act (WIOA) was 

enacted, which, among other things, amended the Rehabilitation Act of 

1973 and required VR agencies to provide additional services to students 

and youth with disabilities.29 Specifically, WIOA requires that states 

reserve at least 15 percent of their state’s allotment of federal VR funds 

for the provision of pre-employment transition services to students with 

disabilities. To receive pre-employment transition services, a student with 

a disability need only be potentially eligible for VR services and does not 

have to apply to VR.

The Individuals with Disabilities Education Act (IDEA) provides formula 

grants to states, which pass them to eligible local education agencies to 

assist in providing special education and related services. IDEA generally 

requires schools to provide special education and related services to 

students with disabilities specified under IDEA.30 For each student with an 

IDEA-specified disability, schools must establish an individualized 

education program (IEP) team that generally includes the child’s teacher 

and other school and school district personnel, the student’s parents, the 

student (as appropriate), and, at the discretion of the parent or public 

agency, others with relevant knowledge, including related service 

providers. The IEP team is required to develop a written IEP for each 

student that includes, among other information, a statement of the 

student’s academic achievement and functional performance, measurable 

academic and functional goals, and the special education and related 

services to be provided. Also under IDEA, beginning with the first IEP to 

be in effect when a student turns 16, or earlier if determined appropriate 

by the IEP team, and updated annually thereafter, the IEP must include, 

among other things, appropriate, measurable postsecondary goals for 

training, education, employment, and, where appropriate, independent 

living skills, and transition services needed to help the student reach 

 29WIOA was intended, in part, to increase access to and opportunities for employment, 

education, training, and support services for individuals with barriers to employment.

30Under IDEA, disabilities include intellectual disabilities, hearing impairments (including 

deafness), speech or language impairments, visual impairments (including blindness), 

serious emotional disturbance, orthopedic impairments, autism, traumatic brain injury, 

other health impairments, or specific learning disabilities. 20 U.S.C. § 1401(3).

Schools’ Role in Transition 

Planning for Youth with 

Disabilities
Page 10 GAO-17-485 Supplemental Security Income

these goals. Schools may invite representatives from VR agencies to 

these transition planning meetings.31

Students with disabilities who do not qualify for special education and an 

IEP under IDEA may qualify for services under section 504 of the 

Rehabilitation Act of 1973, as amended (section 504).32 Education’s 

section 504 regulations require school districts to provide qualified 

students regular or special education and related aids and services 

designed to meet the educational needs of students with disabilities as 

adequately as the needs of students without disabilities are met. 

Transition services may be documented in a 504 plan, but they are not a 

requirement of such plans.33

SSA’s role in encouraging employment for transition-age youth on SSI as 

they move into adulthood is focused on administering work incentives and 

other employment supports that allow them to keep at least some of their

benefits even if they have earnings. However, very few youth on SSI 

benefit from these supports.

 31Students and transition-age youth may receive transition services—including 

employment-related services—through other federal agencies and local service providers.

32Section 504 prohibits discrimination on the basis of disability by recipients of federal 

financial assistance. 

33Aside from section 504 and IDEA requirements, individuals can be referred to VR 

agencies by other school personnel, agencies, or service providers, or self-refer.

SSA’s Efforts to 

Encourage 

Employment Reach 

Few Transition-Age 

Youth and SSA Does 

Not Consistently 

Convey Information 

About Working

SSA Administers Work 

Incentives, but Few 

Transition-Age Youth 

Benefit from Them
Page 11 GAO-17-485 Supplemental Security Income

As a provider of means-tested transfer payments, SSA does not provide 

direct employment services to SSI recipients, including youth on SSI.

34

However, for recipients who want to work, the SSI program is designed to 

support their efforts and reduce their reliance on benefits, according to 

SSA’s Annual Report of the Supplemental Security Income Program.35

Federal law provides several work incentives and other employment 

supports that help SSI recipients—including youth—to enter, re-enter, or 

stay in the workforce. Most transition-age youth are also students, and 

the importance of education is emphasized by the primary work incentive 

for this population, the Student Earned Income Exclusion (SEIE), which 

encourages work, but requires recipients to attend school to be eligible for 

the exclusion. SSA also administers other work incentives and 

employment supports that are available, but not targeted to transition-age 

youth. See table 1 for a list of key work incentives and employment 

supports available to this population.

 34Direct employment services such as school-based preparatory services, work-based 

learning experiences, and family involvement and supports have been found to be best 

practices in helping youth with disabilities transition to adulthood. National Collaborative 

on Workforce and Disability, Guideposts for Success, Second Edition.

35Social Security Administration. Annual Report of the Supplemental Security Income 

Program, 2016. 
Page 12 GAO-17-485 Supplemental Security Income

Table 1: Key Employment Supports That Allow Supplemental Security Income (SSI) Recipients to Continue Receiving SSI 

Benefits While They Work, Calendar Year 2017

Employment 

Supports

Description Who is Eligible

Work incentives that exclude income from calculation of benefits

Earned Income 

Exclusion

SSA excludes the first $65 of earned income 

received in a month, plus one-half of the 

remaining earned income. This exclusion is 

applied in addition to the $20 general income 

exclusion, which applies to earned and unearned 

income.

All SSI recipients with earnings.

Student Earned 

Income Exclusion 

(SEIE)

SSA excludes up to $1,790 of earned income per 

month when figuring SSI recipients’ benefit 

amount. The maximum yearly exclusion for 2017 

is $7,200. The SEIE is applied before the general 

income exclusion or the earned income 

exclusion.

SSI recipient under age 22 with earnings who is also a 

student attending school regularly.

Work incentives that exclude work-related expenses or certain income needed for work

Impairment-Related 

Work Expenses

(IRWE) 

SSA deducts the cost of certain impairmentrelated items and services, such as medicines, 

medical devices, and service animals, that SSI 

recipients need to work from gross earnings. The 

IRWE is excluded from their earned income when 

determining monthly SSI benefits.

Non-blind SSI recipients with certain impairment-related 

services and items needed for work.

Blind Work Expenses 

(BWE) 

SSA excludes any earned income used to meet 

expenses that SSI recipients need to earn 

income.

Blind SSI recipients with deductible work expenses.

Plan to Achieve SelfSupport (PASS)PASS allows the setting aside of income for a 

specified period of time so that SSI recipients 

may pursue a work goal that will reduce or 

eliminate the need for SSI benefits. Income that 

is set aside is not included when determining 

monthly SSI benefits.

SSI recipients with a feasible work goal, specific savings 

or spending plan, and clearly identifiable accounting for 

the funds that he or she sets aside. Plan must be 

approved by SSA.

Other provisions that allow SSI recipients to maintain SSI or medical benefits

Continued Payments 

under Vocational 

Rehabilitation or 

similar program 

(Section 301) 

Allows individuals to continue to receive SSI 

benefits in certain circumstances, such as when 

they are enrolled in an appropriate vocational 

rehabilitation (VR) program, are between 18 and 

21 years old and have an individualized 

education program (IEP), or have a PASS.

SSI recipients who are found to no longer be disabled 

due to medical improvement or who are 18 years old and 

do not meet adult disability requirements, and who are 

participating in an appropriate VR program or similar 

services and whose participation in the program will 

increase the likelihood of permanent removal from the 

disability rolls.

Special SSI Payments 

for Persons Who Work

and Medicaid While 

Working

SSA provides special SSI payments for disabled

individuals with earned income above the 

substantial gainful activity (SGA) level.

Provides SSI “recipient status” for the purpose of 

Medicaid eligibility.

Certain SSI recipients who would cease to be eligible 

because of earnings over SGA as long as they meet 

specific conditions.

Source: Social Security Administration (SSA) Annual Report of the Supplemental Security Income Program 2015 and Social Security Administration 2016 Red Book: A Summary Guide to Employment 

Supports for Persons with Disabilities under the Social Security Disability Insurance (SSDI) and Supplemental Security Income (SSI) Programs. | GAO-17-485
Page 13 GAO-17-485 Supplemental Security Income

Few transition-age youth on SSI benefit from SEIE—the only SSAadministered work incentive targeted specifically to younger SSI 

recipients.36 SEIE allows SSI recipients under age 22 who also regularly 

attend school, college, university, or vocational or technical training to 

exclude a portion of their earnings—$1,790 a month, up to $7,200 a year, 

in 2017—from their countable income for the purposes of determining SSI 

eligibility and benefit amounts.37 Based on data provided by SSA, we 

found that 1.3 percent and 1.4 percent of all transition-age youth (ages 14 

to 17) on SSI had income excluded under SEIE in calendar years 2012 

and 2013, respectively.38

Our analysis of SSA data further suggests the possibility that some youth

who may be eligible may not be benefiting from this SSI provision. SSA 

data show that few transition-age youth benefit from SEIE, in part, 

because few have earned income. For example, in 2012, 3.3 percent 

(15,234 out of 455,363) of transition-age youth reported earned income. 

However, our analysis of SSA data found that even among those 

transition-age youth with earned income, most often less than half 

benefited from SEIE. The percentage of youth with earnings who 

benefited from SEIE in 2012 varied by age and month, but ranged from a 

 36In addition to potentially encouraging work, the SEIE is intended to help defray the cost 

of educational training, according to SSA.

37In 2016 these amounts were $1,780 and $7,180, respectively. 

38In 2012, 6,093 transition-age youth out of 455,363 total, and in 2013, 6,255 out of 

460,436 total, benefited from SEIE. We report data from 2012 and 2013 even though 

more recent data are available because SSA officials told us that data on recipients, 

earnings, and income exclusions can be updated retroactively, therefore, the most 

recently available data do not reflect a complete picture of the number of recipients with 

earnings or who benefited from the SEIE. Officials told us that although data adjustments 

can occur at any point, data from more than 2 years ago do not generally change 

significantly. While data from 2014 and 2015, the most recent full years of data available, 

may change, these data show a similar percentage of transition-age youth on SSI 

benefited from SEIE, 1.4 and 1.2, respectively. SSA officials also told us that while 

producing data we requested, the agency discovered a small proportion of cases for which 

earnings and work incentive data are not being correctly transferred from one data file to 

another. SSA officials estimated the undercount to affect approximately 0.1 percent of the 

overall population of transition-age youth ages 14 to 17, and approximately 5 percent of 

those with earnings, which suggests that the number of youth with earnings and benefiting 

from SEIE may be slightly larger than reported. According to SSA officials, this error 

affects only research statistics, not benefit payments to SSI recipients.

SEIE
Page 14 GAO-17-485 Supplemental Security Income

low of 28 percent to a high of 53 percent.39 (See fig. 1.) These 

percentages were similar in 2013 through 2015.40

 39The low was for 14-year-olds in December and the high was for 15-year-olds in 

September. In only 2 months did 40 percent or more of 14-year-olds with earnings 

received SEIE in calendar year 2012. For 15-, 16-, and 17-year-olds, the percentage of 

those with earnings who received SEIE was in the 40s in almost every month. Because 

the SEIE has an annual cap, some recipients may reach the cap before the end of the 

calendar year and no longer be eligible for the exclusion. According to SSA, these 

recipients would still be captured as having received SEIE in the months in which they 

received it before reaching the annual cap. In addition, previous research found that few 

reach this cap. According to this research, in most cases, SEIE recipients’ earned income 

was much lower than the calendar-year SEIE limit. Almost one-third of SEIE recipients 

used less than 10 percent of the annual limit, and approximately half used less than 20 

percent. Only about 2 percent of SEIE recipients used between 80 percent and 90 percent 

of the annual limit. Kemp, M., Recipients of Supplemental Security Income and the 

Student Earned Income Exclusion, Social Security Bulletin, Vol. 70, No. 2, 2010.

40As noted, data for more recent years is more likely to change. However, given the 

similarity in the percentages of previous years, it seems unlikely that the percentage of 

youth with earnings who received SEIE will change significantly.
Page 15 GAO-17-485 Supplemental Security Income

Figure 1: Percentage of Transition-Age Youth (Ages 14-17) on Supplemental 

Security Income with Earnings Who Benefited from the Student Earned Income 

Exclusion (SEIE), by Age, Calendar Year 2012

Note: According to SSA officials, a previously unknown error in SSA’s data transfer process resulted 

in a small proportion of cases in which earnings and work incentive data were not correctly 

transferred from one data file to another. SSA officials estimated this issue affects approximately 0.1 

percent of the overall population of transition-age youth ages 14 to 17, and approximately 5 percent 

of those with earnings. This should not substantially affect the percentage of youth with earnings 

receiving SEIE.

Given that SEIE should be applied automatically for all eligible students 

who have reported earned income, SSA officials offered the following 

possible reasons, other than SSA user or system error, for why youth with 

earnings might not have benefited from SEIE: they were not students or 

they did not report their student status to SSA. However, previous 

research found more than 94 percent of transition-age youth on SSI 

reported being enrolled in school.41 Further, although some youth on SSI 

may not report their student status, SSA policy instructs staff to develop 

and verify school attendance for youth under 18 who report that they 

 41Wittenburg, D. and Loprest, P., Early Transition Experiences of Transition-Age Child SSI 

Recipients, New Evidence From the National Survey of Children and Families, Journal of 

Disability Policy Studies, Winter 2007. 
Page 16 GAO-17-485 Supplemental Security Income

expect to earn over $65 in a month.42 SSA also has procedures for 

capturing an individual’s student status during his or her initial application 

and during a redetermination. Despite these procedures, the fact that 

many youth with earnings are not receiving SEIE suggests that SSA may 

not be confirming student status or applying SEIE in a timely manner or in 

accordance with policy.

SSA officials told us that the agency does not regularly analyze SEIE data 

and said they do not believe doing so would help them better understand 

SEIE’s effectiveness or reach.43 However, our recent data request 

uncovered potential undercounting of earnings and SEIE use. Federal 

standards for internal control state that an agency should identify,

analyze, and respond to risks related to achieving its objectives.44 Absent 

this analysis, SSA cannot know the extent to which various factors may 

contribute to the low percentage of transition-age youth with earnings 

receiving SEIE, or whether errors made by staff or data system errors are 

precluding some SSI recipients from receiving an income exclusion for 

which they are eligible.

Similarly, the number of transition-age youth on SSI who benefited from 

other SSA-administered work incentives and employment supports was 

either unknown or low. For example, SSI’s Earned Income Exclusion, 

which excludes the first $65 of income earned each month from benefit 

calculations and half of earnings after that, is available to the broadest set 

of SSI recipients with earnings. However, SSA officials told us that SSA 

has not conducted analysis to determine the extent to which transitionage youth on SSI benefit from this incentive. SSA officials told us that 

their systems automatically apply this exclusion to any earned income 

remaining after the SEIE has been applied and that any individual with 

 42SSA Program Operations Manual System (POMS). SI 00501.020 Student – SSI. 

Effective dates, Jan. 15, 2016 to present.

43We identified only one study about SEIE uptake through our literature review. Estimates 

presented in this study indicate that in 2005, the most recent year examined, out of more 

than 493,000 youth ages 12 to 17 on SSI, 7,320 received SEIE. The study also reported 

that SSA had not published detailed statistics on SEIE. Kemp, M., Recipients of 

Supplemental Security Income and the Student Earned Income Exclusion, Social Security 

Bulletin, Vol. 70, No. 2, 2010.

44GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014). 

Other Employment Supports
Page 17 GAO-17-485 Supplemental Security Income

earned income (whether or not the SEIE applies) automatically receives 

this exclusion.45

SSA data for Impairment-Related Work Expenses (IRWE), Blind Work 

Expenses (BWE), and the Plan to Achieve Self-Support (PASS) show low 

uptake by transition-age youth on SSI for each of these provisions as 

well. For example, SSA data show that no transition-age SSI recipients 

benefited from IRWE or BWE and no more than five had a PASS in any 

calendar year 2012 through 2015, the most recent data available. SSA 

staff at three field offices told us that, in their view, use of PASS by 

transition-age youth may be low because it is complex and has many 

requirements, including that the recipient develop long-term career 

goals.46

Another provision of federal law—referred to as the section 301 

provision—allows certain individuals to continue receiving SSI benefits 

even when SSA determines through an age 18 redetermination or CDR 

that they no longer have a medical disability.47 For example, recipients 

may retain their benefits if they are 18 to 21 years old and are receiving 

special education and related services through an IEP, or if they have a 

PASS, or if they are enrolled in VR or a similar program and meet other 

requirements. The possibility of these continued payments underscores 

the importance of ensuring transition-age youth are aware of the section 

301 provision and of the services that qualify them for it, such as IEPs, 

PASS, and VR. In 2015, the most recent year for which data are 

available, about 1,200 adults ages 18 and 19 benefited from this 

 45For eligible recipients, the SEIE is the first income exclusion applied. The General 

Income Exclusion and Earned Income Exclusion are applied to any income remaining 

after the SEIE is applied. Recipients with earnings who are not eligible for SEIE would 

generally receive the General Income Exclusion and Earned Income Exclusion.

46In our review of academic literature, we did not identify any studies conducted within the 

last 10 years that discussed usage rates of IRWE, BWE, or PASS among youth on SSI or 

whether they were effective in encouraging work. We identified one study of PASS from 

1998 that reported a decline in the number of active PASSes from December 1995 to 

September 1997 due to administrative changes. Berry, H., Analyzing a Work Incentive: 

The Plan for Achieving Self-Support and School-to-Work Transition, Career Development 

for Exceptional Individuals, Vol. 21, No. 1, 1998.

47This provision is so referred because it was originally put in place by section 301 of the 

Social Security Disability Amendments of 1980, which made numerous amendments to 

the Social Security Act. See Pub. L. No. 96-265, § 301(b), 94 Stat. 441, 450 (1980), 

codified as amended at 42 U.S.C. § 1383(a)(6). SSA’s Office of Disability Operations 

makes these determinations.
Page 18 GAO-17-485 Supplemental Security Income

provision. SSA officials told us that this provision has not been widely 

used because eligibility through an IEP only applies to individuals ages 18 

through 21, and because few youth under 18 were likely served by VR

agencies.

48 However, SSA officials were unable to provide data on the 

number of individuals who applied for and ultimately did not benefit 

because the agency does not maintain these data in a format that would 

allow for this type of analysis.

Lastly, other legal provisions may encourage work by allowing SSI 

recipients to maintain SSI benefits or Medicaid even if they earn over 

SGA, in certain circumstances, but the number of transition-age youth 

who benefit from these provisions is not known.49 Specifically, SSA does 

not analyze data to determine the extent to which transition-age youth 

may maintain SSI benefits or Medicaid under these provisions. Because 

youth typically do not exceed SGA, the number affected is likely small, 

according to SSA officials.

SSA has been involved in two initiatives to test ways to encourage 

employment of transition-age youth. The SSA-sponsored Youth 

Transition Demonstration (YTD) did not result in changes to SSA’s work 

provisions, according to SSA officials. The Promoting the Readiness of 

Minors in Supplemental Security Income (PROMISE) initiative, led by 

Education, is ongoing.

SSA’s YTD targeted individuals ages 14 to 25 at six demonstration sites 

who received or were likely to receive SSI or Social Security Disability 

Insurance (SSDI) benefits.50 YTD tested the impact of various waivers of 

SSA-administered work incentive rules in combination with a range of 

 48Education officials noted that since the enactment of WIOA’s amendments to the 

Rehabilitation Act of 1973, VR agencies are serving many youth under 18 through preemployment transition services. 

4942 U.S.C. §§ 1382h and 1396a(a)(10)(A)(i). To qualify for continuing SSI payments and 

Medicaid coverage, recipients must have been eligible for SSI payments for at least 1 

month before working at SGA level, still be disabled, and meet all other eligibility rules, 

including income and resources tests. To qualify for continued Medicaid coverage, 

recipients must have been eligible for an SSI payment for at least 1 month, be eligible for 

SSI payment except for earnings, still be disabled, still meet all other eligibility rules 

(including the resources test), need Medicaid in order to work, and have earned income 

that is insufficient to replace SSI, Medicaid, and any publicly funded attendant care. 

50There were approximately 5,000 youth in the YTD sample across the six sites. 

Demonstration Projects
Page 19 GAO-17-485 Supplemental Security Income

strategies and work supports on employment, income, and other 

outcomes.51 According to the YTD final evaluation in 2014, all six site 

locations were required to include certain program components, such as 

work-based experiences; benefits counseling; family supports, including 

transition-related information; and connections to service providers, 

including health care and transportation services. The sites had flexibility 

in the approaches they used to implement those program components.52

The final evaluation showed inconsistent results and SSA was unable to 

determine whether waivers contributed to positive outcomes at some 

sites. On the positive side, site-specific interim evaluations showed that, 

after 1 year, YTD increased participants’ use of benefits and incentive 

counseling, and their awareness of at least some work incentives, at all 

six sites. YTD also increased participants’ understanding of the effects of 

work on SSI benefits, medical coverage, or both, at three sites.53

However, the final 2014 YTD evaluation report found mixed results.54 For 

example, two of the six sites showed positive impacts on employment, 

two sites showed positive impacts on annual earnings, and two sites 

showed positive impacts on participation in productive activities, such as 

education, employment, or training.55 However, none of the sites saw an 

improvement in these 14- to 25-year olds’ self-determination and one site 

 51There was a first phase with seven YTD projects in 2003 and a second phase with five 

projects in 2007. Three projects from each of these phases were selected to be included 

in the national random impact study, for a total of six sites. SSA waivers tested under YTD 

included making the Earned Income Exclusion more generous by allowing YTD 

participants to exclude from countable income three-quarters of earnings over $65 a 

month rather than one-half of such earnings. It waived the 21-year-old age limit for SEIE. 

It also allowed participants to use PASS for additional purposes and loosened 

requirements for receiving payments under section 301, among other changes. 

52Fraker, T., et al. Final Report on the Youth Transition Demonstration Evaluation, 

Mathematica Center for Studying Disability Policy, Nov. 11, 2014.

53Interim reports present first-year evaluation findings for each project site. The final 

evaluation presents findings after 3 years.

54Fraker, T., et al. Final Report on the Youth Transition Demonstration Evaluation, 

Mathematica Center for Studying Disability Policy, Nov. 11, 2014. 

55The evaluation’s findings of statistically significant positive impacts on primary outcomes 

in the domain of paid employment and earnings in the third year following enrollment in 

two sites are based on youth survey responses that encompass both formal and informal 

jobs. The evaluation’s findings based on IRS records show no significant impacts on 

formal employment or earnings in these sites in the third calendar year following 

enrollment. The final evaluation also reported that five sites showed an increase in total 

income, but this income also included SSI cash benefits.
Page 20 GAO-17-485 Supplemental Security Income

saw an increase in delinquency.56 Moreover, SSA officials told us that the 

final evaluation could not determine the extent to which changes to work 

incentives had led to any of the positive effects experienced at some 

sites. SSA officials said that because all YTD participants were eligible for 

work incentive waivers and other services, isolating the effects of 

changes to work incentives from the effects of the other services was not 

possible.57 SSA officials also said they have not made program changes 

based on YTD results, but that YTD informed the development of the 

PROMISE initiative. Officials said SSA is conducting an internal study of 

YTD to assess longer term outcomes, which they hope to complete by the 

end of 2017.

SSA is currently a partner in the ongoing PROMISE initiative, which is 

being led by Education.58 Through PROMISE, Education provided funds 

to selected states to design and implement demonstration projects to 

improve outcomes for youth on SSI and their families. PROMISE targets 

transition-age youth who are 14, 15, and 16 years old and receiving SSI

and their families with interventions including vocational rehabilitation, 

case management, benefits counseling, financial literacy training, career 

and work-based learning experiences, and parent training and 

information. SSA provided data on youth receiving SSI to the PROMISE 

demonstration projects for enrollment purposes, is funding the PROMISE 

research evaluation of the demonstration, and, according to SSA officials, 

is providing technical assistance regarding SSA policies to project sites. 

SSA does not have a role in direct delivery of services. Education 

awarded six 5-year PROMISE grants in 2013, with most projects 

beginning services within the first year. An interim impact report is 

 56According to the YTD final evaluation report, program sites were offered technical 

assistance focused on helping project staff network with employers to identify competitive 

paid jobs and match youth with appropriate jobs. Researchers involved in the YTD 

evaluation noted that some sites were more open to receiving this technical assistance 

than others and suggested this might have resulted in positive outcomes in some 

instances.

57Officials noted that a relatively small percentage of demonstration participants used the 

work incentives, suggesting that the services drove the impacts. The YTD final report 

states that changes to work incentives were a good recruiting tool for YTD, but that future 

evaluations of interventions that include work incentives should consider specifying that 

the waiver period is shorter than the evaluation’s follow-up period, which would allow for 

an assessment of the intervention’s impacts during the post-waiver segment of the 

evaluation.

58In addition to Education and SSA, the departments of Labor and Health and Human 

Services are partners in the PROMISE initiative.
Page 21 GAO-17-485 Supplemental Security Income

scheduled for release in summer 2018, and a long-term evaluation is 

scheduled for winter 2022. During our New York site visit, we spoke with 

staff from organizations providing services under the PROMISE initiative 

who told us that, although they did not yet have outcome data, their early 

observations suggest positive effects, such as that youth are engaged, 

families are interested in having their children work and in receiving 

services to encourage work, and PROMISE is creating a more 

collaborative environment among service providers, VR, and schools.

According to SSA officials, VR staff, and other stakeholders with whom 

we spoke, transition-age youth and their families are often unaware of or 

do not understand SSA-administered work incentives and supports, and 

may fear that working will negatively affect their SSI or Medicaid 

benefits.59 Although we were unable to identify recent research or data 

corroborating these perspectives, a 2007 study using data collected in 

2001 and 2002, found that only 22 percent SSI recipients ages 14 to 17 

knew about the work incentives or discussed them with an SSA 

representative.60 Experts believe this lack of knowledge and associated 

concerns about the effect of work on benefits may reduce work attempts 

by transition-age youth. For example, in a planning report for YTD, the 

research organization Mathematica stated that “lack of knowledge about 

how work experiences, benefits, and SSA incentives interact leads to low 

utilization of the incentives among beneficiaries.”61 Similarly, staff in SSA 

field offices and state VR agencies, researchers, and others we spoke to 

said fear of losing health care or SSI benefits creates a barrier to 

employment for transition-age youth and some said that families may not 

encourage youth on SSI to work because of these fears. SSA officials 

also said that some families believe they are helping their children by 

preventing them from working because it will enable them to keep 

benefits longer or reduce the chance of an unfavorable age 18 

redetermination.

 59There are many factors that may influence working or attempting to work, or create 

barriers to work. Examples include the nature of a youth’s disability, lack of transportation 

to and from work, or local economic conditions. 

60Wittenburg, D. and Loprest, P. Early Transition Experiences of Transition-Age Child SSI 

Recipients, Journal of Disability Policy Studies, Winter 2007; 18, 3. 

61Benefits counseling was among the elements of YTD; however, according to SSA 

officials, YTD did not result in changes to benefits counseling for youth on SSI more 

broadly. Rangarajan, A., et al. The Social Security Administration’s Youth Transition 

Demonstration Projects: Analysis Plan for Interim Reports, June 19, 2009.

SSA Misses Opportunities 

to Convey Information to 

Encourage Work and Allay 

Fears that Work May 

Result in Loss of Benefits
Page 22 GAO-17-485 Supplemental Security Income

Despite such gaps in knowledge or understanding of work incentives and 

the age 18 redetermination process among youth on SSI and their 

families, and contrary to general SSA policy, SSA staff may not be 

systematically conveying information about these topics during CDRs and 

other interviews. SSA policy states that interviewers are responsible for 

providing accurate and meaningful information about the SSI program, 

and for making the process of applying for and maintaining eligibility as 

understandable and uncomplicated as possible. SSA policy also states 

that recipients may not know the right questions to ask to obtain the 

information they need to make informed decisions.62 SSA officials we 

interviewed said, consistent with SSA policy, field staff collecting 

information during a CDR, financial eligibility redetermination, or age 18 

redetermination, would discuss work incentives with recipients. However, 

SSA field office staff we interviewed did not confirm such information 

sharing consistently occurs in SSA field offices. Staff said such 

conversations may not occur for a variety of reasons. For example, they 

said youth and their families do not generally seek out information on 

work incentives, and staff may not have time for such discussions or be 

experts on work incentives.63

SSA may also be missing opportunities to allay certain fears about how 

work might affect age 18 redeterminations. SSA policy indicates, and 

officials from the Office of Disability Determinations (ODD) confirmed, that 

although information on work history is collected and may be considered 

when determining whether a person meets medical criteria, it only 

influences financial eligibility when specific conditions are met. According 

to SSA officials, earnings are only considered when determining capacity 

to work if an individual has worked at or above SGA for a period long 

enough to gain work skills necessary for the job, and that such instances 

are rare. SSA officials told us that virtually all unfavorable age 18 

redeterminations result from a medical evaluation, not work history. The 

medical evaluation takes into account the medical evidence and, if 

needed, the physical and mental functional capacity of the individual. SSA 

officials could not provide specific data on the relationship of prior work to 

redetermination outcomes. However, they said few youth undergoing an 

 62SSA Program Operations Manual System (POMS) SI 00601.060 Supplemental Security 

Income (SSI) Interviewing. Effective dates, Oct. 6, 2016 to present.

63In follow-up emails from field office supervisors and managers, two confirmed that 

information on work incentives was not consistently discussed with transition-age youth 

and their families. The other three stated that such information was consistently provided, 

contradicting information provided during interviews.
Page 23 GAO-17-485 Supplemental Security Income

age 18 redetermination have a work history, and among those who do, a 

very small number have worked sufficiently above SGA to result in an

unfavorable redetermination on that basis.64 At the same time, SSA’s 

policies do not instruct staff to consistently convey information explaining 

how work may or may not affect the age 18 redetermination when 

speaking with youth and their families. Federal standards for internal 

control state that an agency should communicate the information 

necessary to achieve its objectives.65 Without standard procedures and 

language to guide SSA representatives and ensure they regularly and 

consistently discuss how work incentives can allow transition-age youth 

on SSI to work without jeopardizing their benefits, SSA may miss 

opportunities to allay misplaced fears, encourage work, and potentially 

reduce future dependence on benefits.

As part of its effort to increase awareness and understanding of work 

incentives and supports available to SSI recipients, SSA funds Work 

Incentives Planning and Assistance (WIPA) projects in every state, and 

relies on the projects to provide benefits information and counseling to 

transition-age youth.66 The projects typically provide general information 

on benefits or work supports and referrals to additional services, as 

needed, and individualized counseling on benefits and related services. 

WIPA projects are supposed to conduct outreach and provide information 

to disabled individuals, including transition-age youth, including advising 

them of work incentives available to them.67 However, the WIPA projects’

reach is limited. According to data from SSA’s contracted technical 

assistance provider for WIPA projects, WIPA projects served just 345 

 64Officials at two DDSs told us that, if they did not have access to work history information 

they could still make a determination of medical eligibility for an age 18 redetermination 

using other information.

65GAO-14-704G.

66WIPA projects provide services to SSDI beneficiaries as well. 

67SSA’s 2016 WIPA project terms and conditions stipulate that WIPA projects should 

serve beneficiaries ages 14 and older and conduct outreach targeting transition-age 

youth.
Page 24 GAO-17-485 Supplemental Security Income

youth ages 14 to 17 on SSI between July 2013 and June 2016.68 While 

staff at one of the two WIPA project locations we visited said that they 

work with youth under age 18 to the extent possible, they said schools 

typically assist this age group rather than WIPA projects. At the other 

location, WIPA project staff told us that most of their clients are adults 

because beneficiaries typically do not seek services until they are 

working. WIPA project staff said funding constraints limit their ability to 

serve everyone and to conduct outreach. When the WIPA program was 

established in 1999, the law put a limit of $23 million on the amount of 

grants, cooperative agreements, and contracts that can be awarded each 

fiscal year under this program, and the limit has not changed since then.

More recently, SSA has taken additional steps to provide written 

information about work incentives and supports to transition-age youth on 

SSI and their families by developing a new brochure; however, this 

brochure—while helpful for some—may not be sufficient to allay fear of 

work affecting benefits.69 SSA officials told us that lessons learned from 

YTD influenced the agency’s development of the brochure to inform 

youth, their families, and service providers about the age 18 

redetermination process and available resources. While the new brochure 

is a positive step, it does not contain key information that could help 

alleviate fear that work will mean losing benefits, such as how work is 

considered during the age 18 redetermination process or the 

circumstances under which youth can work and maintain Medicaid 

coverage.70 In addition, some stakeholders, including WIPA project and 

 68From August 2015 to July 2016 WIPA projects served more than 29,000 individuals, 

about one-third of whom were SSI recipients. The most recent data show that 78 percent 

of total WIPA project referrals are from SSA’s Ticket to Work Help Line (58 percent) or VR 

agencies (20 percent). However, youth who are not eligible for Ticket to Work and may not 

have an open service record with VR may not receive referrals through these sources. 

John Kregel and Susan O’Mara, The Social Security Work Incentives Planning and 

Assistance Program Annual Report Program Activities August 1, 2015 through July 17, 

2016, (Virginia Commonwealth University National Training and Data Center, Sept. 30, 

2016).

69SSA Publication No. 05-11005, What You Need To Know About Your Supplemental 

Security Income (SSI) When You Turn 18.

70A representative from one national advocacy organization we spoke with specifically 

said that including information on Medicaid would be helpful. Representatives from two 

other national advocacy organizations suggested adding additional information, such as 

the website that provides information on finding a local WIPA project. SSA officials told us 

they are considering modifying the brochure to include additional information on 

redeterminations, but did not elect to add information on Medicaid—which SSA officials 

told us most SSI recipients already receive—because it would have made the brochure 

prohibitively long.
Page 25 GAO-17-485 Supplemental Security Income

VR staff, told us that written material, such as a brochure, may not be 

sufficient to convey complex information on work incentives and how 

working affects benefits. For example, although SSA officials said one 

purpose of the brochure is to increase awareness of available resources, 

staff from WIPA’s technical assistance provider told us in December 2016 

that they did not believe the brochure, mailed in August 2016, had led to 

an increase in youth seeking WIPA project services. Federal standards 

for internal control state that an agency should communicate quality 

information needed to achieve its objectives with external parties, and 

that this information should be communicated using appropriate methods 

that consider factors including the intended audience and the nature of 

the information, among others.71 For example, results from YTD suggest 

that increased benefits counseling was associated with increased 

awareness of work incentives.

Having access to individualized training and employment services 

provided by VR agencies helps transition-age youth on SSI develop the 

skills they need to transition to adulthood and the workforce. However, 

SSA does not have a systematic way to connect these youth to state VR 

agencies that provide employment-oriented and other services to 

individuals with disabilities. To achieve successful transition to adulthood, 

it is important that transition-age youth with disabilities receive transition 

planning and employment-related services that help them prepare for and 

engage in gainful employment to the extent of their capabilities. Such

 71GAO-14-704G. 

SSA Does Not Have 

a Systematic Way to 

Connect TransitionAge Youth on SSI to 

Vocational 

Rehabilitation 

Services and Data 

Sharing is Limited

SSA Does Not Have a 

Systematic Way to 

Connect Transition-Age 

Youth to Vocational 

Rehabilitation Services
Page 26 GAO-17-485 Supplemental Security Income

services are provided by state VR agencies under the VR State Grants 

program, which is administered by Education’s Rehabilitation Services 

Administration, and may include individualized: assessments; counseling, 

guidance, referrals, and job placements; vocational and other training; 

transportation; and, in certain circumstances, postsecondary education 

and training. Participation in VR also may allow transition-age youth who 

would otherwise lose SSI benefits due to an unfavorable CDR or age 18 

redetermination to continue receiving SSI payments.72 Despite the 

advantages of participating in VR programs, our review of data from five 

state VR agencies found few transition-age youth (ages 14 to 17) 

receiving SSI who had open VR service records in calendar year 2015.73

Specifically, in four of the five states, the percentage of transition-age 

youth ages 14 to 17 on SSI with open VR service records was less than 1 

percent. In the fifth state, approximately 3 percent of such youth had an 

open VR service record.

74

Although there may be many reasons for low VR participation by 

transition-age SSI recipients at the five state VR agencies we spoke with, 

SSA’s stated inability to directly refer these youth to VR agencies does 

not help to improve participation rates. Prior to the enactment of the 

Ticket to Work and Work Incentives Improvement Act of 1999, SSA was 

required to consider each claimant’s need for vocational rehabilitation and 

refer SSI recipients ages 16-64 to state VR agencies.75 While the 

enactment of this Act expanded the pool of employment service providers 

available to recipients of SSI and other disability benefits, SSA limited the 

 72SSA Program Operations Manual System (POMS). DI 14505.010 Policy for Section 301 

Payments to Individuals Participating in a Vocational Rehabilitation or Similar Program. 

Effective dates January 6, 2017 to present. 

73According to Education, under the VR program, a service record is opened at 

application and is considered “open” until the service record is closed.

74Detailed national data on the number of individuals with disabilities currently receiving 

VR services, such as demographic information—including youth—are not currently 

available. To obtain these estimates, we compared data on the number of youth with open 

VR service records in 2015 provided by 5 state VR agencies to data provided by SSA on 

the number of youth receiving SSI in those states in 2015. SSA counted anyone who 

received SSI benefits for at least 1 month in the state in the count of SSI recipients. These 

data do not reflect the number of SSI youth who may have received pre-employment

transition services prior to applying for VR services.

75See Pub. L. No. 92-603, § 301, 86 Stat. 1329, 1465 (1972), as amended.
Page 27 GAO-17-485 Supplemental Security Income

Ticket to Work and Self-Sufficiency (Ticket to Work) program to adults.76

In addition, the Act removed the language that had required SSA to make 

direct referrals of benefit recipients to VR providers. SSA has interpreted 

this legal change as “eliminat[ing] SSA’s authority to refer [SSI] recipients 

for vocational rehabilitation (VR) services” in states in which the Ticket to 

Work program has been implemented.77 Because the Ticket to Work 

program has been implemented in all states, it is SSA’s view that it is 

prohibited from directly referring adults and youth on SSI to VR services.

Because SSA states that it can no longer makes direct referrals to VR 

agencies for services and the Ticket to Work program only supports 

adults, SSA lacks a mechanism to help connect youth on SSI to VR

services. In contrast, the Ticket to Work program provides SSA a welldeveloped structure to connect SSI recipients age 18 and older to VR 

agencies or other employment networks.78 Specifically, SSI recipients 

ages 18 to 64 are issued a ticket that can be used to obtain vocational 

rehabilitation, employment, or other support services from a state VR 

agency or an approved employment network of their choice. SSA has a 

Helpline number for the Ticket to Work program, and the program has its 

own website containing information on its benefits and how to access VR

agencies and other service providers. Since SSI recipients under age 18 

are not eligible for tickets, SSA has no structure in place to ensure 

transition-age youth are made aware of and encouraged to take 

advantage of available employment programs that can help reduce their 

reliance on benefits as they transition into adulthood.

 76When SSA developed regulations for the Ticket to Work program, it considered 

extending eligibility for tickets to individuals younger than 18, but decided not to, citing the 

concern that employment could interfere with their education. At the time, SSA said that it 

would reconsider the decision to exclude youth.

77SSA Program Operations Manual System (POMS) DI 55001.500 Repeal of Referral 

Authority for Rehabilitation Services In States Where the Ticket to Work Program Is 

Implemented. Effective dates, May 2, 2013 to present. The Ticket to Work program has 

been implemented in all states.

78Under the Ticket to Work program, beneficiaries can obtain employment, vocational 

rehabilitation, or other services from an employment network of their choice which is 

willing to provide them. An employment network is an entity that enters into an agreement 

with SSA to either provide or coordinate the delivery of services to beneficiaries. State VR 

agencies may participate in the Ticket to Work program as an employment network. SSA 

will reimburse employment networks and VR agencies for services provided to disability 

beneficiaries if they achieve certain employment outcomes.
Page 28 GAO-17-485 Supplemental Security Income

In February 2016, SSA issued an advanced notice of proposed 

rulemaking in which it solicited public input on how to improve the Ticket 

to Work program, including how the program could encourage youth to 

pursue work-related opportunities.79 SSA officials said that they have no 

timeline for further actions related to this notice at this time. In addition, an 

SSA official said they are in the early stages of considering a new 

initiative under SSA’s demonstration authority that would test whether 

having a state DDS make direct referrals of age 18 redetermination cases 

to VR agencies would result in increased VR services, increased 

employment outcomes, and reduced dependency on SSI. This initiative 

would involve the DDS and VR agencies located in one state. The SSA 

official said they are still working out the details, but said that if the project 

is feasible it would ideally begin sometime in 2017 and last at least 1 to 2 

years.

Without direct referrals from SSA and access to the Ticket to Work 

program, the primary way that youth on SSI are connected to VR is 

through their schools. While referrals to VR agencies can come from 

other sources, national Education data show elementary and secondary 

schools are the primary source of referrals for transition-age youth (see 

fig. 2). Specifically, for transition-age youth with VR service records that 

were closed in fiscal year 2015, over 80 percent had been referred to VR 

agencies by elementary and secondary schools.80

 79Revising the Ticket to Work Program Rules, 81 Fed. Reg. 7041 (Feb. 10, 2016). The 

comment period for this notice closed in April 2016. As of May 5, 2017, SSA had not 

published a related notice of proposed rulemaking.

80Education officials stated that most of these referrals would have been made by 

secondary schools because elementary school students are well under the age at which 

work is a realistic consideration. One exception might be referrals to VR agencies serving 

individuals who are blind. 
Page 29 GAO-17-485 Supplemental Security Income

Figure 2: Source of Referral to Vocational Rehabilitation for Youth, Ages 14-17, for 

Vocational Rehabilitation Service Records Closed in Fiscal Year 2015

a “All other Sources” includes all other categories reported by the Department of Education’s 

Rehabilitation Services Administration, including, for example, medical health providers, community 

rehabilitation programs, state departments of correction/juvenile justice, mental health providers, and 

one-stop employment/training centers. Education officials stated that most of these referrals would 

have been made by secondary schools because elementary school students are well under the age 

at which work is a realistic consideration. One exception might be referrals to vocational rehabilitation

agencies serving individuals who are blind.

Students with disabilities can be connected to VR agencies through 

transition services provided by their schools as required under IDEA. 

IDEA requires states and school districts to identify, locate, and evaluate 

children suspected of having a disability, as defined in IDEA, and who are 

in need of special education and related services. For students age 16, or 

younger if determined appropriate by the IEP team, schools must develop 

and implement an IEP that incorporates postsecondary goals and 

provides access to appropriate transition services. The transition planning 

process develops a student’s postsecondary goals for training, education, 

and employment, among other things. Although IDEA does not 

specifically require school districts to include VR agencies in transition 

planning, Education’s regulations require school districts to invite a 

representative from a VR agency or from other agencies likely to be 

providing transition services to a student’s IEP team meetings, when 

appropriate, and with the prior consent of the parents or student who has 
Page 30 GAO-17-485 Supplemental Security Income

reached the age of majority.81 According to Education guidance, VR 

agency involvement during the transition planning phase of an IEP helps 

provide a bridge to VR services for eligible students preparing for life after 

school.82

Rehabilitation Services Administration officials and a few VR agencies 

told us that staff from VR agencies are invited to transition planning 

meetings by schools, but due to capacity constraints, these staff may not 

attend all such meetings. Furthermore, the relationship between VR 

agencies and schools and school districts varies, based on interviews we 

had with school and school district officials in the two states we visited. 

For example, school officials in two districts said that the VR agency staff 

are more involved and meet with students weekly, and as a result, 

students with IEPs are more likely to be connected to VR services. Some 

officials in the other school districts we visited described the relationship 

more as a “hand-off” of the student from the school to the VR agency. For 

example, VR agency staff would typically meet with students approaching 

graduation. Regardless of the relationship, a student makes the choice to 

apply or not to apply for VR services.

While VR and SSA officials we interviewed said that most students on 

SSI have IEPs, and that their IEPs can help connect them to VR services, 

we found that neither schools nor SSA collect or analyze data that would 

allow them to determine the extent to which youth on SSI do, in fact, have 

IEPs that would help them connect with VR services.83 Although schools 

 8134 C.F.R. § 300.321(b)(3). When students eligible for special education under IDEA 

apply for VR services, federal regulations related to the Rehabilitation Act of 1973 require 

that VR agencies coordinate with education officials to facilitate the transition of students 

with disabilities by developing individualized plans for employment as early as possible 

during the transition period, but no later than when the student determined to be eligible 

for VR services leaves school.

82U.S. Department of Education, Office of Special Education and Rehabilitative Services, 

Rehabilitative Services Administration, Technical Assistance Circular RSA-TAC-14-03, 

May 6, 2014. 

83Eligibility requirements for receiving special education and related services under an IEP 

pursuant to IDEA differ from the eligibility criteria for SSI. For example, SSI recipients with 

disabilities that do not adversely affect educational performance may not qualify as a child 

with a disability under IDEA and be eligible for special education and related services. A 

student who has a disability but who does not qualify for an IEP may qualify for a 504 

plan. Section 504 does not specifically require that eligible students with disabilities 

receive transition services as defined in IDEA. However, school districts could provide 

students covered by Section 504 with services to facilitate the pursuit of postsecondary 

goals related to training, education, or employment, depending on the individual needs of 

the student. 
Page 31 GAO-17-485 Supplemental Security Income

document information on students with IEPs, school officials told us they 

do not collect information on whether students are receiving SSI benefits, 

and they have no systematic way to obtain this information. SSA 

maintains data on whether a student is receiving SSI and collects 

information on whether a recipient is receiving special education, or has 

an IEP, in certain cases.84 However, SSA officials said they do not 

analyze these data to determine how many youth on SSI have IEPs that 

could facilitate connecting them to VR services. Based on data collected 

in 2001-2002 for the National Survey of SSI Children and Families, one 

study found that approximately 70 percent of surveyed youth on SSI had 

an IEP at some point during their schooling, which seems to indicate that 

about one-third of these youth lack an established path that may connect 

them to services to help them transition into employment or 

postsecondary education, and potentially reduce their dependence on 

SSI. In addition, youth who have dropped out of school also lack an IEP 

pathway to VR services. Federal standards for internal control state that 

agencies should use quality information to achieve their objectives. 

Absent data on whether youth on SSI have IEPs that can help them 

connect to transition services or additional options for connecting youth to 

VR services, SSA cannot ensure that these youth are receiving or have 

access to services they need to help them prepare for adulthood and the 

workforce.

With enactment of WIOA in 2014, more transition-age SSI recipients are 

potentially connected to VR services, although the extent to which this 

occurs is not known. Under WIOA’s amendments to the Rehabilitation Act 

of 1973, VR agencies are now required to provide pre-employment

transition services to students with disabilities beginning at age 16 (or 

younger if a state elects a younger minimum age).85 WIOA’s amendments 

to the Rehabilitation Act of 1973 also require states to reserve at least 15 

percent of their state allotment of federal VR funds to provide these 

services to students, including job exploration counseling, work-based 

 84SSA obtains IEP information in cases in which there is an appeal of an initial SSI 

benefits claim, or to assist with disability determinations, continuing disability reviews, and 

age 18 redeterminations.

85For the VR program, a student with a disability is between 16 (or younger, if the state 

uses a younger age for eligibility for pre-employment transition services) and 21 years old 

(or older, if a state’s law permits a higher maximum age for the receipt of services under 

IDEA). To be a “student with a disability,” the individual must also be eligible for and 

receiving special education or related services under IDEA, or be an individual with a 

disability for purposes of section 504 of the Rehabilitation Act of 1973.
Page 32 GAO-17-485 Supplemental Security Income

learning experiences, transition or postsecondary educational programs 

counseling, workplace readiness training, and instruction in selfadvocacy.86 Students with disabilities are eligible for pre-employment 

transition services even if they have not applied or been found eligible for 

VR’s regular services. Most VR agencies we interviewed are in the early 

stages of implementing WIOA’s amendments to the Rehabilitation Act of 

1973, and as such, the extent to which the new provisions will increase 

participation by youth on SSI is not known. While certain WIOA

amendments broadly support all students with disabilities, they do not 

specifically target youth on SSI. In addition, some state VR agency 

officials told us they do not determine an individual’s SSI status prior to 

the application process for VR services, and thus may not be able to 

capture data on the number of youth on SSI they serve through preemployment transition services.

Data and information sharing about transition-age youth on SSI—which 

could potentially facilitate provision of services—is limited between SSA, 

VR agencies, and Education, and officials said there are privacy 

considerations about sharing information. SSA does not systematically 

provide Education or VR agencies with data that would allow them to 

identify transition-age youth on SSI for outreach on services. VR agency 

staff we interviewed told us that when an individual applies to VR for 

services, the agency can query SSA on the individual’s disability benefits, 

including SSI benefits. However, this query can only be conducted on a 

case-by-case basis, some VR officials said, and VR agencies do not have 

access to broader information about the population of youth on SSI who 

would be eligible for VR services in their area. VR officials in four of five 

states where we conducted interviews said having such data would be 

beneficial because it would help them conduct outreach in a more 

focused way. Officials in the fifth state said that having such information 

might be useful because it would allow them to determine the extent to 

which they are reaching the population of youth on SSI. Education 

officials also told us that, if available and consistent with applicable 

privacy laws, VR agencies might use information on youth receiving SSI 

to conduct outreach to youth who may not be connected to the school 

system, such as youth who have dropped out of school, are homeless, 

migrants, or seasonal workers. Education officials within the 

 86WIOA authorizes numerous other pre-employment activities, which can be provided if 

additional funds are available after required activities are provided.

Data and Information 

Sharing About SSI Youth 

is Limited Among SSA, 

Vocational Rehabilitation 

Agencies, and Education
Page 33 GAO-17-485 Supplemental Security Income

Rehabilitation Services Administration also said that generally state VR 

agencies have the capacity to conduct outreach, and additional data from 

SSA would be helpful.

Although access to more comprehensive SSA data might improve 

outreach by VR agencies, privacy concerns and other factors inhibit data 

sharing by SSA. Both SSA and Education have raised privacy and legal 

concerns about sharing SSI recipient data, indicating that such sharing 

may be prohibited under federal law; however, SSA has participated in 

other data sharing arrangements. In each instance, steps were taken to 

protect personal information and address privacy requirements. SSA 

officials told us that, as part of the Ticket to Work program, SSA has 

provided information on eligible beneficiaries to non-VR employment 

networks that asked for this information. While the agency stopped this 

practice in March 2015, due to privacy concerns, SSA officials said they 

are currently conducting an initiative in which SSA provides employment 

networks encrypted data on eligible beneficiaries via secure messaging. 

This includes the name and address or the name and phone number of 

potentially eligible beneficiaries for conducting outreach. SSA officials 

said they anticipated continuing this project for several months before 

evaluating the process and deciding how to proceed. However, SSA 

officials said they have not provided similar information to VR agencies 

because (1) the demand for VR services is generally high and negates 

the need to conduct outreach and (2) they do not have the legal authority 

to refer individuals to VR. In addition, under the PROMISE initiative, SSA 

provided identifying information on groups of SSI recipients, such as 

contact information, to facilitate outreach and enrollment. According to 

SSA and Education officials, that data sharing was permitted because it 

was conducted for research purposes. Nevertheless, steps were taken to 

ensure privacy requirements were met, such as obtaining consent from 

SSI youth and their parents or guardians about participating, and using 

unique identification numbers in lieu of Social Security numbers.

Finally, SSA and Education have a data sharing agreement in place; 

however the shared data are currently not used for VR outreach or 

program management purposes. The data sharing agreement establishes 

procedures and conditions for the merging of SSA and Education 
Page 34 GAO-17-485 Supplemental Security Income

administrative data to support research and program evaluation.87 The 

data sharing agreement specifies that SSA will remove personally 

identifiable information, including Social Security numbers, before sharing 

merged files with Education. Under this agreement, SSA has access to 

data on the number and the characteristics of individuals exiting the VR 

program each fiscal year, which according to Education, only includes 

closed, not open, service records. As such, neither SSA nor Education 

know the extent to which youth on SSI are receiving VR services. 

Education officials said that beginning in July 2017, due to requirements 

in WIOA, Education will begin collecting data from VR programs on a 

quarterly basis for both current program participants and those who have 

exited the program. Education and SSA officials said these data on open 

service records, in combination with SSA’s recipient data, could also be 

used to determine in a more regular and timely manner the total 

population of youth on SSI receiving VR services. However, SSA officials 

said without knowing exactly what the data will include, they do not know 

whether it will prove useful and therefore do not yet have any plans to 

analyze these data. SSA officials told us that without more information on 

how WIOA amendments to the Rehabilitation Act of 1973 will change 

services to youth, they were unsure what additional outreach should be 

conducted, or whether additional initiatives or data will be necessary to 

connect youth on SSI to VR services.

Many individuals with disabilities want to work for the financial and 

personal rewards that employment can provide, and it is in SSA’s interest 

to help SSI recipients find employment and ultimately reduce or end their 

dependence on SSI. Helping transition-age youth on SSI engage in work 

prior to age 18 is critical given that research finds SSI recipients often 

 87These merged data are intended to inform research that helps both agencies 

understand and address program issues, for example, assessing the effects of VR 

services on SSA beneficiaries, supporting demonstration projects pertaining to youth in 

transition, and identifying incentives and disincentives associated with SSA benefit 

programs when an individual receiving SSI begins earning income. SSA data files merged 

pursuant to the Memorandum of Agreement include the: Supplemental Security Income 

Record (SSR), Master Beneficiary Record (MBR), Disability Determination Service 

Processing File (also known as the 831/832), Master Files of Social Security Number 

(SSN) Holders and SSN Applications (NUMIDENT) file, Completed Determination Record 

- Continuing Disability Determinations (also known as the Disability Control File (DCF)), 

the Earnings Recording and Self-Employment Income System (also known as the Master 

Earnings File (MEF)), Hearings and Appeals Case Control System, and Hearing Office 

Tracking System of Claimant Cases. The Education data file to be merged is the 

Rehabilitation Services Administration’s (RSA) Case Service Report (RSA-911).

Conclusions
Page 35 GAO-17-485 Supplemental Security Income

continue receiving benefits for decades, resulting in high costs to the 

federal government. Yet few transition-age youth on SSI are working, and 

many of those who do work are not benefiting from provisions under 

federal law to exclude some of their income and retain still-needed 

benefits.

While SSA maintains data on the number of SSI recipients who work and 

use work incentives and employment supports, by not regularly analyzing 

these data, SSA cannot ensure transition-age youth are receiving work 

incentives for which they are eligible. SSA does not know, for example, 

why many transition-age youth with income are not receiving the SEIE, 

which is targeted specifically to this population. In addition, lacking 

procedures that ensure systematic, consistent communication with youth 

and families about work incentives and redetermination rules, SSA is 

forgoing opportunities to encourage employment and potentially allay 

fears that may create a barrier to employment.

SSA also states that it is hindered in its ability to connect transition-age 

youth to VR services because it is no longer allowed to directly refer them 

and SSI recipients under 18 are not included in its program that assists 

adults with making this connection. SSA must rely primarily on schools to 

make this connection for students. However, SSA is well positioned to 

work with Education to determine the extent to which transition-age youth 

on SSI are not being connected to VR services for which they are eligible, 

and to assess options to better ensure they receive them, as appropriate. 

Without further efforts, the program risks unwarranted costs and the youth 

it serves may be less likely to obtain self-sufficiency.
Page 36 GAO-17-485 Supplemental Security Income

We recommend that the Acting Commissioner of the Social Security 

Administration take the following actions:

1. Analyze the SEIE data to determine why a large proportion of 

transition-age youth on SSI with reported earnings did not benefit from 

the SEIE and, if warranted, take actions to ensure that those eligible 

for the incentive benefit from it.

2. Analyze options to improve communication about SSA-administered 

work incentives and the implications of work on SSI benefits, with a 

goal of increasing understanding of SSI program rules and work 

incentives among transition-age youth and their families. This should 

include, but not necessarily be limited to, updating SSAs procedures 

for staff meeting with SSI applicants, recipients, and their families to 

regularly and consistently discuss – when applicable—how work 

incentives can prevent reductions in benefit levels and how work 

history is considered during eligibility redeterminations.

3. Work with the Secretary of Education to determine the extent to which 

youth on SSI are not receiving transition services through schools that 

can connect them to VR agencies and services.

4. Explore various options for increasing connections to VR agencies 

and services, including their potential costs and benefits. One option, 

among others, could be to expand the Ticket to Work program to 

include youth.

Recommendations
Page 37 GAO-17-485 Supplemental Security Income

We provided a draft of the report to SSA and Education for their review. In 

written comments, SSA agreed with two of our recommendations, 

partially agreed with one, and disagreed with one. We have reproduced 

SSA’s and Education’s comments in appendices II and III. We have 

incorporated them—as well as technical comments provided—in the 

report, as appropriate.

In its comments, SSA suggested GAO clarify SSI’s role as part of a 

broader social safety net, and explain that the SSI program does not have 

provisions for SSA to ensure recipients have access to a variety of 

services provided by federal and state agencies. We agree, and added 

additional information in the report suggested by SSA to help convey this. 

SSA also commented that the draft report did not accurately portray 

efforts to encourage work and explain work incentives to youth receiving 

SSI, citing efforts made to produce a new brochure targeting youth and 

directing WIPA projects to further target youth—both of which were 

results of the YTD project. We discussed SSA’s new brochure in our 

report, and stated that it will be helpful for some SSI beneficiaries. We 

also discussed SSA’s use of WIPA projects to provide benefits 

information and counseling, and noted that SSA has instructed WIPA 

projects to serve beneficiaries ages 14 and older and conduct outreach 

targeting transition-age youth.

SSA agreed with our recommendation to analyze Student Earned Income 

Exclusion (SEIE) data to determine why a large portion of transition-age 

youth with reported income did not benefit from SEIE and take steps, if 

warranted, to ensure they do. SSA also agreed to explore various options 

for increasing connections to Vocational Rehabilitation (VR), stating that 

in addition to assessing options for referring youth to VR and/or changing 

the Ticket to Work program, the agency will continue to research other 

options for supporting transitioning youth.

SSA partially agreed with our recommendation that SSA work with 

Education to determine the extent to which youth on SSI are not receiving 

transition services through schools that can connect them to VR. SSA 

noted its ongoing collaboration with Education and other agencies 

through the Promoting Readiness of Minors in SSI (PROMISE) project, 

stating the initiative is testing the provision of VR services to youth 

receiving SSI and will provide some evidence related to the role of 

schools and VR services for this population. SSA also stated it will 

continue to pursue research in this area. We agree that the PROMISE 

initiative has the potential to provide useful information on whether the 

Agency Comments 

and Our Evaluation
Page 38 GAO-17-485 Supplemental Security Income

services and supports provided improve education and employment 

outcomes for transition-age youth; however, a final PROMISE evaluation 

is not expected until winter 2022. In addition, the PROMISE initiative was 

not designed to determine the extent to which youth on SSI are receiving 

transition services through schools or are otherwise connected to VR 

services. SSA also noted that it works with Education and other agencies 

through the Federal Partners in Transition (FPT) Workgroup to improve 

the provision of transition services to students with disabilities, and that 

the FPT has issued a blueprint of agencies’ efforts. While the FPT can be 

a promising vehicle for helping connect youth on SSI to key transition 

services, as of September 2016, the FPT had not set timelines or 

milestones to achieve its broad goal to support positive outcomes for 

youth with disabilities, nor does it have a list or specific activities and 

tasks it will undertake. Therefore, we continue to believe additional 

collaboration by SSA with Education would be beneficial. SSA also noted 

several concerns related to complying with this recommendation, such as 

legal (privacy) concerns with data sharing, the capacity of state VR 

agencies to serve more individuals, and the receptivity of youth on SSI to 

receiving services. While we acknowledge that legal and privacy issues

can present challenges to collaboration, we believe that SSA can take 

steps to explore actions it could take after considering such legal issues. 

We note that SSA has implemented approaches for sharing sensitive 

information under its Ticket to Work program, and prior surveys have 

yielded information to help understand how many youth on SSI have had 

an IEP at some point during school. Finally, while low state VR capacity 

or individual motivation can obstruct receipt of VR services, they should 

not prevent SSA from working with Education to determine the extent to 

which SSI youth are sufficiently informed of VR resources that are 

potentially available to them. 

SSA disagreed with our recommendation that it analyze options to 

improve communication about SSA-administered work incentives and the 

implications of work on SSI benefits. SSA stated that it already analyzed, 

and continuously monitors and solicits feedback on, options to improve 

communications. SSA also said it requires staff to meet with SSI 

recipients regularly and instructs staff to discuss relevant work incentives, 

and that there is no indication that staff are not providing youth with 

appropriate work incentive information. However, SSA did not explain 

how it knows or ensures that staff are providing this information. As noted 

in our report, staff in local SSA offices we visited told us that they do not 

regularly or consistently discuss work incentives with youth or families—

when, for example, such information is not specifically requested, or if 

staff lack time. Further, SSA policies do not instruct staff to consistently 
Page 39 GAO-17-485 Supplemental Security Income

convey information to youth and families on how work may or may not 

affect age 18 redetermination. SSA said that its new brochure provides 

information on age-18 redeterminations, as well as work incentives and 

other resources. While we acknowledged that the new brochure is a 

positive development, we noted that it could contain additional relevant 

information, for example, on Medicaid eligibility. We also noted that 

written information may not be sufficient for conveying complex 

information. We agree with SSA that WIPA projects play an important role 

providing work incentives counseling to SSI youth; however, as we noted

in our report, WIPA projects have limited capacity for serving youth along 

with other SSI recipients and disability insurance beneficiaries. Therefore, 

we continue to believe that there are opportunities for SSA to improve its 

communication with transition-age youth and their families, including 

through in-person or telephone interactions. 

Education agreed to cooperate with SSA efforts to determine the extent to 

which youth on SSI are being connected to VR agencies and services 

through schools and on options to increase connections to VR agencies 

and services. Education noted that privacy statutes might complicate or 

limit use of student data. While we acknowledge that privacy laws can 

present challenges in this area, we believe that Education can take steps 

to explore actions it could take after considering these laws.

We are sending copies of this report to appropriate congressional 

committees, the Secretary of Education, the Acting Commissioner of the 

Social Security Administration, and other interested parties. In addition, 

the report will be available at no charge on the GAO website at 

http://www.gao.gov.

If you or your staff have any questions concerning this report, please 

contact me at (202) 512-7215 or bertonid@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. GAO staff who made key contributions to 

this report are listed in appendix IV.

Sincerely yours,

Daniel Bertoni, Director

Education, Workforce, and Income Security Issues
Appendix I: Scope and Methodology

Page 40 GAO-17-485 Supplemental Security Income

This report examines 1) how the Social Security Administration (SSA) 

encourages employment for transition-age youth on Supplemental 

Security Income (SSI) as they move toward adulthood, and the 

effectiveness of these efforts, and 2) the extent to which SSA helps 

ensure transition-age youth on SSI receive vocational rehabilitation 

services.

We focused our review on transition-age youth ages 14 to 17 because 

when SSI recipients turn 18, their eligibility for SSI is reassessed against 

adult criteria. Furthermore, our previous work has found that the transition 

from high school is an especially challenging time for individuals with 

disabilities because they are often no longer automatically entitled to 

transition services they received as students and must apply for and 

establish eligibility for services as adults, often from multiple agencies.1 In 

addition, research suggests that early interventions may improve later 

outcomes for youth with disabilities.2

To address both our research objectives, we reviewed relevant federal 

laws, regulations, policies, documents, and publications; interviewed SSA 

 1

GAO, Youth with Autism: Roundtable Views of Services Needed During Transition into 

Adulthood, GAO-17-109 (Washington, D.C.: Oct. 18, 2016); Students with Disabilities: 

Better Federal Coordination Could Lessen Challenges in Transition from High School. 

GAO-12-594. (Washington, D.C.: July 2012).

2

In addition, according to the Department of Labor, as a general rule, the Fair Labor 

Standards Act of 1938 (FLSA) sets 14 years of age as the minimum age for employment, 

and limits the number of hours worked by minors under the age of 16.

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 41 GAO-17-485 Supplemental Security Income

officials and staff3 and Education officials, advocates, and researchers; 

and conducted site visits to two states.4 In particular:

• To understand SSA’s approaches to encourage employment among 

transition-age youth, we reviewed SSA’s 2016 Annual Report of the 

Supplemental Security Income Program, most recent SSI Annual 

Statistical Reports, 2016 Red Book: A Summary Guide to 

Employment Supports for Persons with Disabilities Under the Social 

Security Disability Insurance (SSDI) and Supplemental Security 

Income (SSI) Programs, various policies outlined in SSA’s Program 

Operations Manual System (POMS), the agency’s Fiscal Years 2014-

2018 Agency Strategic Plan, SSA “Spotlights” (handouts related to 

applying for and receiving SSI), and information about SSA’s Youth 

 3

At SSA, we interviewed officials in the Office of Disability Determinations, the Office of 

Public Services and Operations Support, and in several offices within the Office of 

Retirement and Disability Policy, among others. We also interviewed SSA staff in five SSA 

field offices. In the report, when we refer to SSA officials, we mean knowledgeable 

individuals in SSA’s central offices; when we refer to SSA staff, we mean SSA field office 

personnel, which generally included staff with technical expertise, but also included

supervisory and managerial staff.

4

At Education, we interviewed officials in the Rehabilitation Services Administration and 

the office that oversees it, the Office of Special Education and Rehabilitative Services. We 

spoke to a representative of the National Disability Rights Network (NDRN), which is the 

nonprofit membership organization for the Protection and Advocacy (P&A) Systems and 

the Client Assistance Programs (CAP) for individuals with disabilities. Collectively, the 

Network is the largest provider of “legally based advocacy services” to people with 

disabilities in the United States. We also spoke with members of the Consortium for 

Citizens with Disabilities (CCD) Social Security Task Force. CCD is a coalition of 

approximately 100 national disability organizations working together to advocate for 

national public policy that ensures the self-determination, independence, empowerment, 

integration and inclusion of children and adults with disabilities in all aspects of society. 

We also spoke to researchers at Mathematica, whose work focuses on interventions for 

youth with disabilities as they transition to adulthood, vocational rehabilitation and 

vocational rehabilitation and employment for youth with disabilities, and who have been 

involved in the evaluations of the Youth Transition Demonstration and the Promoting 

Readiness of Minors in Supplemental Security Income (PROMISE) initiative. Mathematica 

Policy Research’s Center for Studying Disability Policy is one of the two cooperatively 

funded research centers that make up the Disability Research Consortium.
Appendix I: Scope and Methodology

Page 42 GAO-17-485 Supplemental Security Income

Transition Demonstration (YTD) and the Promoting the Readiness of 

Minors in Supplemental Security Income (PROMISE) initiative.5

• To determine the extent to which youth benefit from SSAadministered work incentives or other employment supports, we 

reviewed or analyzed available data from SSA on the number of 

transition-age youth benefiting from various work incentives, as 

follows:

• For the Student Earned Income Exclusion (SEIE), the Plan to Achieve 

Self-Support (PASS), Impairment-Related Work Expenses (IRWE), 

and Blind Work Expenses (BWE), we analyzed data provided by SSA 

from its Disability Analysis File (DAF) for SSI recipients ages 14 to 17 

for calendar years 2012, 2013, 2014, and 2015.6 A new version of the 

DAF is created each year in March and the 2015 file is the most 

current available version. According to SSA officials, SSA continues to 

update data as it obtains new information from recipients, so data 

from more recent years, while complete as of the time the data were 

obtained by SSA, do not reflect possible future changes to recipient 

files. Therefore, while we report data from each year, we focus on 

data from 2012 and 2013 which, according to SSA, provide a more 

complete picture of recipients with earned income and who benefited 

from work incentives and supports.

 5

The Youth Transition Demonstration (YTD) was a demonstration undertaken by SSA to 

assist youth ages 14 to 25 with disabilities to successfully transition from school to 

economic self-sufficiency. The beneficiaries who participated in this demonstration were 

youth who were receiving SSI or Social Security Disability Insurance (SSDI) payments 

based on their own disability, or who were at risk of receiving SSI or SSDI benefits. The 

demonstration began in 2006 and was completed in 2012. The PROMISE initiative is a 

joint initiative between the Departments of Education, Health and Human Services, and 

Labor, and the Social Security Administration intended to improve the provision and 

coordination of services and supports for child SSI recipients ages 14 to 16 and their 

families to enable them to achieve improved outcomes. Education is funding the initiative 

and SSA is funding a national evaluator to evaluate the PROMISE initiative. PROMISE 

began in 2013 and the final evaluation is scheduled for 2022.

6

A PASS enables SSI recipients to exclude from countable income amounts used for 

certain expenses, such as the cost of transportation to and from work, pursuing an 

education, and purchasing assistive technology, to achieve a specific SSA-approved work 

goal. For IRWE SSA deducts the cost of certain impairment-related items and services, 

such as medicines, medical devices, and service animals, that SSI recipients need to work 

from gross earnings when determining monthly SSI benefits. For BWE, SSA excludes any 

earned income used to meet expenses that blind SSI recipients need to earn income. The 

DAF data do not include separate variables for IRWE and BWE; both incentives are 

captured under the IRWE. 
Appendix I: Scope and Methodology

Page 43 GAO-17-485 Supplemental Security Income

• We reviewed data from the Supplemental Security Record provided 

by SSA on the number of SSI recipients ages 18 and 19 who received 

continuing disability payments under Section 301 of the Social 

Security Disability Amendments of 1980.

• We also reviewed annual Work Incentives Planning and Assistance 

(WIPA) project reports by the Work Incentives Planning and 

Assistance National Training and Data Center and data provided by 

the Center.

To assess the reliability of these data, we interviewed SSA officials, 

reviewed written answers to questions we provided to SSA, and reviewed 

available documentation. According to SSA officials, while producing the 

data we requested, the agency discovered a previously unknown error in 

its data transfer process. The error has resulted in a small proportion of 

cases in which earnings and work incentive data are not being correctly 

transferred from one data file to another. SSA officials estimated this 

issue affects approximately 0.1 percent of the overall population of 

transition-age youth ages 14 to 17, and approximately 5 percent of those 

with earnings. According to SSA, this suggests that the number of youth 

with earnings and the number benefiting from SSA-administered work 

incentives may be approximately 5 percent larger than reported. 

However, because SSA believes that the undercount is approximately the 

same for the number of transition-age youth with earnings and the 

number receiving SEIE, the percentage of these youth receiving SEIE 

would not change substantially. We do not believe this issue materially 

changes our findings—regarding low use of SEIE and low percentage of 

youth with earnings receiving SEIE—and we found the data to be 

sufficiently reliable for the purposes of our reporting objectives.

We also conducted a literature review designed to identify research 

published over the last 10 years related to participation in, and outcomes 

related to, SSA-administered work incentives and demonstration projects 

that pertain to transition-age youth.7 Our search used broad key terms 

including those related to relevant work incentives, YTD and PROMISE, 

and vocational rehabilitation for youth on SSI. The search identified 218 

studies or articles. After reviewing abstracts of studies for key parameters 

we determined that some studies were duplicative, some were outside 

the 10 year timeframe, and some were not published articles. This 

 7

Our literature search was also designed to identify literature related to collaboration 

between SSA and VR which informed our second research objective.
Appendix I: Scope and Methodology

Page 44 GAO-17-485 Supplemental Security Income

information, combined with a review of abstracts for key terms (such as 

confirming the studies discussed youth on SSI) enabled us to narrow the 

list to 111 results. We then conducted a more thorough review of study 

abstracts to determine whether the studies were not relevant, were 

suitable for background purposes (such as 40 articles about vocational 

rehabilitation), or were focused on SSI work incentives and demonstration 

projects. Ultimately, we identified 19 studies that focused on SSI work 

incentives and demonstration projects. Of these, 12 focused on YTD and 

7 focused on incentives.8 However, 5 discussed work incentives in broad 

terms, for example describing that work incentives could help improve 

employment opportunities without discussing a specific example. Only 2 

of the studies discussed specific work incentives—including a study over 

10 years old that we included because it was the only study that 

discussed PASS—and none addressed the specific effects of these 

incentives on encouraging work. After determining the studies were 

methodologically sound, we incorporated key findings as appropriate in 

our report.

To determine how youth on SSI and their families are informed about SSI 

program rules, work incentives, eligibility for VR, and other supports, we 

reviewed relevant procedures and information and notices provided by 

SSA to SSI recipients, their families, and their representative payees. We 

also interviewed staff in five SSA field offices in three states: two each in 

Florida and New York, and one in California. We selected the three states 

because they each served a large population of SSI recipients and youth 

on SSI and based on geographic variation. We further selected New York 

because it was participating in the ongoing PROMISE initiative. In each 

state, we interviewed a variety of SSA staff, including, for example, district 

managers, technical experts, claims representatives, Area Work Incentive 

Coordinators, and a Work Incentives Liaison, among others. At the 

California SSA field office we also observed an age 18 redetermination 

interview. 

In Florida and New York, we also interviewed staff at VR offices, a 

combination of school and school district personnel in six school districts, 

 8

We identified additional studies on YTD; however, they were descriptive in nature or 

addressed interim outcomes or outcomes at specific program sites. Because a final 

evaluation of YTD is available, we did not include all of those studies.
Appendix I: Scope and Methodology

Page 45 GAO-17-485 Supplemental Security Income

and staff at a WIPA project in each selected state.9 In New York, we also 

interviewed state officials responsible for implementing PROMISE as well 

as several PROMISE service providers. We interviewed these individuals 

to gather information about the services they provide to transition-age 

youth on SSI and their opinions on SSA’s effectiveness in encouraging 

work among this population and SSA efforts to connect these youth to VR 

services. The results of our interviews with SSA field office staff, VR 

officials and staff, school and school district personnel, and service 

providers are not generalizable, but provide insight into a variety of 

issues, including, how SSA and its staff communicate with transition-age 

youth on work-related issues; transition services these youth receive; and 

barriers they face to employment.

To determine how SSA helps to ensure transition-age youth on SSI 

receive VR services available to SSI recipients, we reviewed SSA policies 

and interviewed SSA officials, state Disability Determination Service 

officials in the Florida and New York, and VR officials in five states—

Florida, New Mexico, New York, Oklahoma, and Washington. Florida and 

New York were selected because these were the two states in which we 

conducted our site visits. New Mexico, Oklahoma, and Washington were 

selected based on variation in the size of the population of youth under 18 

receiving SSI who are served by the VR agencies, the rate of successful 

employment outcomes for transition-age youth receiving VR services, and 

geography. The results of our interviews with state VR agency officials 

are not generalizable.

We also collected data from state VR agencies in the five states on the 

number of transition-age youth on SSI with open VR service records in 

calendar year 2015, to analyze the extent to which youth were receiving 

VR services. The VR agencies from which we collected data did not all 

define “open service records” in exactly the same way. One state 

included only service records for which an individual plan for employment 

had been developed; the other states classified open service records to 

include individuals in other statuses, such as any individual who was 

beyond referral status. To assess the reliability of these data, we provided 

written questions to state VR officials and reviewed relevant 

documentation where available. We found the data were sufficiently 

reliable for our purposes.

 9

WIPA projects provide community-based work incentive expertise and counseling about 

benefits and the effect of work on those benefits to SSI and Social Security Disability 

Insurance (SSDI) beneficiaries. WIPA projects are funded by SSA.
Appendix I: Scope and Methodology

Page 46 GAO-17-485 Supplemental Security Income

We compared the data provided by these state VR agencies to the 

number of transition-age youth in current pay status in 2015 according to 

data provided by SSA from the DAF. While SSA officials told us the 

number of recipients is unlikely to change significantly in its data, as 

noted previously, the DAF file is updated each year with new information 

obtained by SSA, and officials told us that the more recent years of the 

DAF are more likely to change than years further past. However, given 

the small number of transition-age youth with open VR service records in 

comparison to the number receiving SSI, any changes to the number of 

SSI recipients in the DAF would not significantly change the percentage 

of transition-age youth with open VR service records. When calculating 

the number of transition-age youth on SSI in the state, we counted any 

such youth who received SSI benefits for at least 1 month in the state. 

Some of these recipients did not live in the state for the entire year. In 

addition, we reviewed data provided by SSA on reimbursements the 

agency made to state VR agencies for successful work outcomes for 

transition-age youth on SSI for 2012 through 2014. We found SSA’s data 

to be sufficiently reliable for reporting on the extent to which transition-age 

youth benefited from SSA’s work incentives.

We conducted this performance audit from February 2016 to May 2017 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Comments from the Social 

Security Administration

Page 47 GAO-17-485 Supplemental Security Income

Appendix II: Comments from the Social 

Security Administration
Appendix II: Comments from the Social 

Security Administration

Page 48 GAO-17-485 Supplemental Security Income
Appendix II: Comments from the Social 

Security Administration

Page 49 GAO-17-485 Supplemental Security Income
Appendix II: Comments from the Social 

Security Administration

Page 50 GAO-17-485 Supplemental Security Income
Appendix III: Comments from the Department 

of Education

Page 51 GAO-17-485 Supplemental Security Income

Appendix III: Comments from the 

Department of Education
Appendix III: Comments from the Department 

of Education

Page 52 GAO-17-485 Supplemental Security Income
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 53 GAO-17-485 Supplemental Security Income

Daniel Bertoni, Director, (202) 512-7215 or bertonid@gao.gov

In addition to the contact named above, Michele Grgich (Assistant 

Director), David Barish (Analyst-in-Charge), Divya Bali, Susan Chin, and 

MacKenzie Cooper made key contributions to this report. In addition, key 

support was provided by Susan Aschoff, James Bennett, Dan 

Concepcion, Alex Galuten, Gloria Proa, Monica Savoy, Almeta Spencer, 

Barbara Steel-Lowney, and Nicholas Weeks.

Appendix IV: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100673)
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