Social Security Disability: Ticket to Work Participation Has Increased, but Additional Oversight Needed
Published: 2011-05-06T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Social Security Administration (SSA) pays billions of dollars in Disability Insurance and Supplemental Security Income to people with disabilities. The Ticket to Work program, established in 1999, provides eligible beneficiaries (ticket holder) with a ticket they may assign to approved service providers, called employment networks (EN). ENs are to provide services to help ticket holders obtain and retain employment and reduce dependence on SSA benefits. ENs receive payments from SSA once a ticket holder has earnings exceeding a set threshold. Due to low participation, SSA changed program regulations in 2008 to provide ENs and ticket holders with more incentives to participate. GAO examined (1) changes in ticket holder and EN participation over time, (2) the range of service approaches used by ENs, and (3) SSA's efforts to evaluate ticket holders and ENs to ensure program integrity and effectiveness. GAO analyzed SSA data, policies, and procedures, and interviewed representatives of 25 ENs, disability advocacy organizations, and SSA.
section_title: What GAO Found
paragraphs: More ticket holders and ENs are participating in the Ticket to Work program since SSA revised regulations in 2008, but the overall participation rate remains low. Ticket holders assigning their tickets to ENs increased from about 22,000 in fiscal year 2007 to more than 49,000 as of July 2010. However, less than 1 percent of all ticket holders assigned their tickets to ENs and SSA has not yet studied whether regulatory changes enabled more ticket holders to obtain employment and exit the benefit rolls. During this time, ENs approved to serve ticket holders increased from 1,514 to 1,603, and SSA's ticket payments to ENs increased from $3.8 million to $13 million. However, 20 ENs, or less than 2 percent of those currently participating, have received the majority of total ticket payments from SSA. GAO found that ENs provide a range of services, including job search and retention assistance. Since the 2008 regulatory changes, which explicitly allowed ENs to pay ticket holders, an increasing number used service approaches such as sharing SSA's government-funded ticket payments with ticket holders. These ENs target ticket holders already working or ready to work, and accounted for a substantial and growing share of payments from SSA. Three ENs among those with the largest payment amounts reported providing limited or no direct services beyond passing back a portion of ticket payments to ticket holders who had sufficient earnings to qualify the ENs for payment. These ENs received a total of over $4 million in SSA payments-- nearly one-third of all SSA payments--in fiscal year 2009. Two of these ENs passed back 75 percent of SSA's ticket payments to ticket holders and kept the other 25 percent. The extent of these trends is unknown because SSA does not collect sufficient information on service approaches across all ENs. SSA lacks adequate management tools to systematically evaluate ticket holders and ENs. Since 2005, SSA has not consistently monitored or enforced ticket holders' progress toward self-supporting employment--a regulatory requirement. Ticket holders who show progress are generally exempt from medical reviews to determine their continued eligibility for benefits. Lack of systematic monitoring of timely progress has both program integrity and cost implications, such as the potential for ineligible beneficiaries to continue receiving benefits. During the course of GAO's review, SSA was beginning to resume the progress reviews, but it is too early to assess the effectiveness of these efforts. Moreover, SSA has not developed performance measures for approved ENs, as required by law, that can be used to assess their success in helping ticket holders obtain and retain employment and reduce dependency on disability benefits. Without such measures, multiple ENs communicate to ticket holders how to work and keep full disability benefits, despite the fact the ultimate goal of the Ticket program is to reduce dependence on benefits (to hear audio excerpts of GAO's calls with selected ENs, see http://www.gao.gov/products/GAO-11-324 ). Finally, SSA's EN approval process lacks systemic tools to ensure quality and clear and specific criteria for reviewing EN qualifications.
section_title: What GAO Recommends
paragraphs: GAO is recommending SSA take several steps, such as compiling service trend data and monitoring ticket holders' progress, to enhance program oversight. SSA agreed with two recommendations and offered alternative language for the other two to reflect actions it considers planned or under way.

section_title: Letter
paragraphs: In fiscal year 2010, the Social Security Administration (SSA) paid out more  than $165 billion in cash benefits to about 13.5 million people with  disabilities and their families through its Disability Insurance (DI) and  Supplemental Security Income (SSI) programs. As the U.S. population  ages, the number of SSA disability beneficiaries is expected to grow, along  with the cost of providing benefits. Further, once on benefits, few ever  leave the disability rolls. Our prior work suggested that if even a small  percentage of these beneficiaries returned to work, both programs would  realize substantial savings to offset the cost of the programs. The Ticket  to Work and Work Incentives Improvement Act of 1999 provided for the  establishment of the Ticket to Work and Self-Sufficiency Program (Ticket  program) to provide eligible DI and SSI beneficiaries with employment  services, vocational rehabilitation services, or other support services to  help them obtain and retain employment and reduce their dependency on  benefits. SSA provides each eligible beneficiary (ticket holder) with a  ticket to obtain services from SSA-approved public or private providers,  referred to as employment networks (EN), or from traditional state  vocational rehabilitation agencies (VR). Fully implemented in 2004, the  Ticket program experienced low participation in its early years and, as a  result, SSA revised its regulations in 2008 to attract more ticket holders  and ENs. In light of these changes, we examined the following: (1) how  participation of ticket holders and employment networks in the Ticket to  Work program changed over time; (2) what is known about the range of  service approaches used by employment networks; and (3) the policies  and processes SSA has to evaluate ticket holders and employment  networks to ensure program integrity and effectiveness.
To address our research questions, we analyzed SSA data on program  participation; interviewed SSA officials, disability rights advocates, and  employment networks; and reviewed SSA policies and procedures for the  Ticket program. Specifically, we analyzed data on eligible ticket holders  and ENs approved by SSA from fiscal year 2004, the first year the Ticket  program was fully implemented, through July 2010. To assess the  reliability of the data we obtained from SSA, we (1) reviewed existing  documentation related to the data, (2) interviewed knowledgeable agency  officials about the data, and (3) tested the data for completeness and  accuracy. We found these data to be sufficiently reliable for the purposes  of our analysis. We also reviewed relevant federal laws and regulations.  We interviewed representatives of 25 ENs, including 20 ENs among those  with the largest payments in fiscal year 2007, the year prior to  implementation of new program regulations, and fiscal year 2009, the most  recent year with complete data. In addition, we conducted site visits to 12  ENs representing those with some of the largest payments from SSA and  a range of service approaches. We compared SSA and the SSA-contracted  Ticket program manager’s written policies and procedures to Ticket  program laws and regulations, and government internal control  standards. We also obtained a nongeneralizeable sample of case files of  approved, denied, and terminated ENs to review proof of qualifications  submitted to SSA and EN performance information. Finally, an  investigator from our Forensic Audits and Investigative Service team  contacted selected ENs, posing as a fictitious employer or relative of a  ticket holder to test for potential vulnerabilities in program management  and oversight. See appendix I for more details on our scope and  methodology.
We conducted this performance audit from January 2010 to May 2011 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. We believe that the evidence obtained provides a reasonable  basis for our findings and conclusions based on our audit objectives.
subsections: section_title: Background
subsections: section_title: DI and SSI Eligibility
paragraphs: To be eligible for DI or SSI benefits, an individual generally must have a  medically determined physical or mental impairment that (1) has lasted or  is expected to last at least 1 year or result in death and (2) prevents the  individual from engaging in substantial gainful activity (SGA). Once an  individual is receiving benefits, continuing disability reviews (CDR) are  periodically conducted by SSA to evaluate if the individual has medically  improved to the point of being able to work and is no longer eligible for  benefits. Although the DI and SSI programs use the same definition of  disability for eligibility purposes, they were designed to serve different  populations. DI provides benefits to workers with disabilities who have a  qualifying work history; in contrast, SSI provides cash support for people  with low income, few resources, and little or no workforce attachment.  The DI and SSI programs also differ in how work earnings affect benefits.  DI beneficiaries are allowed a 9-month trial work period during which  their benefits continue regardless of how much they earn. Upon  completion of the 9-month trial work period, DI beneficiaries move into a  36-month re-entitlement period (extended period of eligibility) in which  their monthly cash benefit ceases except in months in which earnings are  less than SGA. Recipients whose earnings are above SGA after they  complete the 36-month period should, under program rules, stop receiving  benefits and be removed from the disability rolls. In contrast, SSI benefits  are reduced by $1 for every $2 of earned income exceeding $65 per month  until benefits reach zero. If SSI beneficiaries receive no benefits for 12  consecutive months due to earned income, they are removed from the  disability rolls.
section_title: Ticket Program Overview
paragraphs: Congress established the Ticket to Work program in 1999 to assist DI and  SSI beneficiaries in obtaining and retaining employment, and potentially  bring about significant savings to the Disability Insurance Trust Fund by  reducing or eliminating their benefits. This voluntary program was also  designed to provide beneficiaries with greater choice in public and private  providers of employment services, such as job preparation and placement  and vocational rehabilitation services. Prior to the establishment of the  Ticket program, DI and SSI beneficiaries who needed help returning to  work generally had to seek services from VRs.
When an individual becomes eligible for DI or SSI benefits, SSA mails a  ticket designating the beneficiary as a ticket holder (see app. II for a  picture of a ticket). Generally, DI and SSI beneficiaries from 18 to 64 years  old are eligible ticket holders. They may choose whether or not to use  their tickets, and with which service providers. Likewise, SSA-approved  ENs, which are contracted by SSA for 5 years with the option to extend,  can decide whether or not to serve an individual ticket holder. ENs can  advertise their services in the program’s online directory used by ticket  holders to find ENs in their area. Ticket holders who assign their tickets  and demonstrate “timely progress” toward self-supporting employment,  such as by fulfilling minimum earnings or education requirements, are  exempted from medical CDRs. This provision provides an incentive for  individuals to assign their tickets who otherwise might not attempt to  work out of fear that a medical CDR would cause them to lose benefit  eligibility.
The ticket holder’s ticket becomes “assigned” once the ticket holder and  EN decide to work together and submit an individual work plan describing  the services the EN will provide. A ticket holder can unassign the ticket  from the EN at any time, sometimes switching to a different EN. When the  ticket holder has sufficient earnings, the EN becomes eligible for  payments from SSA (see fig. 1). The EN can choose from two payment  options: (1) milestone-outcome payments that begin when the ticket  holder has a specified level of earnings and continue for a specified time  after the ticket holder no longer receives benefits due to earnings, or (2)  outcome-only payments that do not begin until the ticket holder is entirely  off benefits.
The Ticket law gives SSA authority to help ensure the quality of  participating ENs, and requires ENs to meet and maintain compliance with  general selection criteria (such as professional and educational  qualifications) and specific selection criteria (such as substantial expertise  and experience in providing employment services and supports). The law  also requires SSA to perform periodic quality assurance reviews of EN  service provision, and to develop performance measures for evaluating  ENs. ENs are required to annually report on outcomes achieved in  providing specific services. The law also requires SSA to terminate EN  contracts for inadequate performance. Additionally, the law requires SSA  to provide for independent evaluations to assess the Ticket program’s  effectiveness, including cost-effectiveness, types of services provided to  ticket holders who return to work and those who do not, and employment  outcomes for ticket holders.
SSA’s Office of Employment Support Programs is responsible for  management and oversight of the Ticket program. The office contracts  with a private company (Ticket program manager) for day-to-day  operations, including front-line communication with ENs, such as  technical assistance and training, and processing ticket assignments and  EN payment requests. In addition, the program manager recruits ENs;  however, SSA’s Office of Employment Support Programs retains  responsibility for reviewing and approving applicants. The program  manager is also responsible for performing timely progress reviews of  ticket holders. SSA also contracts with another private company to  facilitate beneficiary participation in the program. Finally, SSA contracts  with a private research firm for ongoing evaluations of the program.
section_title: Changes to Ticket Program Regulations
paragraphs: Due to low participation rates by both ticket holders and ENs—in 2005, we  reported less than 1 percent of 9.5 million ticket holders had assigned their  tickets to an EN or VR and 386 of 1,164 contracted ENs were accepting  tickets—SSA revised the Ticket program regulations in 2008 (see table 1).  The changes lowered the ticket holder earnings threshold which triggers  payments to ENs. Previously, ENs were not eligible for SSA payment until  a ticket holder had earnings at the SGA level or above. Among other key  changes, the revised regulations added a first phase of four $1275  payments over a ticket holder’s first 9 months working at the trial work  level, which, in many cases, equates to part-time work. The EN is also  eligible for a second phase of smaller monthly payments when a ticket  holder has earnings above the SGA level, and a third and final phase of  payments (the outcome phase) once a ticket holder is earning above SGA  and no longer receives disability benefits (see app. III for details of the  payment structure under the revised regulations). Finally, an EN can now  serve a ticket holder formerly served by a VR.
section_title: Persisting Cost and Effectiveness Issues
paragraphs: The cost and viability of the Ticket program has been scrutinized by  researchers and policymakers since the program’s inception. At that time,  it was estimated that if an additional one-half of 1 percent of disability  beneficiaries went back to work, and ceased benefits, the savings to the  Social Security Trust Funds and Treasury would total $3.5 billion over  their working lives. The Congressional Budget Office (CBO) also  projected the Ticket program would lead to savings. However, in 2008,  SSA’s Office of the Inspector General (IG) found the percentage of  beneficiaries who cease benefits as a result of employment had remained  unchanged from before implementation and projected cost savings had  not materialized. The IG also found the percentage of beneficiaries who  had earnings after receiving services steadily decreased over time, and  recommended that SSA evaluate the program’s continued viability. As part  of its contract with SSA for program evaluations, Mathematica Policy  Research, Inc. has preliminary findings indicating the Ticket program  was not self-financing as of January 2010 and its impact on participants’  employment, earnings, or benefits was not large enough to offset the  program’s operating costs. In 2008, SSA’s Office of the Chief Actuary  estimated short-term effects of the regulatory changes, projecting  substantial up-front costs due to increases in the frequency and amount of  payments to ENs and benefit payments to beneficiaries exempted from  CDRs. The estimates noted that while these higher costs could be  partially offset by later increases in successful work attempts, resulting in  reduced or eliminated benefit payments, there would still be a net increase  in costs.
section_title: More Ticket Holders and Employment Networks Participating, but Participation Rate Remains Low
subsections: section_title: More Ticket Holders Assigned Their Tickets Since 2008 Regulatory Changes, but They Remain a Small Share of Those Eligible
paragraphs: The number of eligible ticket holders assigning their tickets to ENs  increased from about 22,000 in fiscal year 2007, prior to the 2008 changes  in regulations, to more than 49,000 as of July 2010. Despite the increase in  numbers, those assigning their tickets to ENs still only represented two- fifths of 1 percent of the approximately 12.1 million eligible ticket holders  as of July 2010, compared to one-fifth of 1 percent in fiscal year 2007  before the regulatory changes. SSA’s outreach contractor told us that  while they are beginning to place more emphasis on increasing ticket  holder participation, their earlier recruitment efforts prioritized increasing  the supply of ENs. According to EN representatives, ticket holder  participation remains low due, in part, to a lack of understanding and  awareness of the program. Some disability rights advocates and EN  representatives said a fear of losing benefits may also deter eligible ticket  holders from participating in the program, especially DI beneficiaries who,  after the 9-month trial work period, face an immediate cessation of  benefits in a given month when earnings exceed SGA. Some disability  rights advocates and EN representatives also said many ticket holders may  not know how going back to work affects their benefits, making it difficult  for them to agree to participate. Sixteen of the 25 EN representatives we  interviewed also told us their ENs screen ticket holders, and 12 said at  least half of them do not meet their screening criteria. For example, one  EN representative told us that certain ticket holders are often screened  out because they lack the education, work experience, and transportation  needed to obtain employment. In addition, according to some disability  rights advocates and EN representatives, some ticket holders may be  discouraged from participating by previous negative experiences with  ENs. For example, one EN representative said ticket holders who assigned  their tickets to ENs that provide inadequate support may become  frustrated and leave the program altogether.
Although the number of ticket holders assigning their tickets has  increased since the 2008 changes, whether the changes have impacted the  number of those returning to work and exiting the benefit rolls is  unknown. The law requires SSA to conduct ongoing independent  evaluations of ticket holders’ employment outcomes. Although SSA has  tentative plans to study exits from the benefit rolls since the program  regulations took effect in 2008, the decision to undertake this study  depends upon the results of other planned research. According to  researchers, some additional time may be needed before a full assessment  can be made. Preliminary research conducted for SSA by Mathematica  estimated that approximately 10 percent of beneficiaries who assigned  their tickets in 2006 will leave the rolls for at least 1 month; however, as  researchers have noted, this does not equate to long-term exits from the  rolls. Researchers have reported many beneficiaries return to work but  do not earn enough to leave the rolls, due in part to functional limitations  and subsequent declines in health. Whether or not ticket holders are able  to leave the rolls has implications for the program’s cost-effectiveness and  ultimately, its long-term viability. In preliminary research examining the  program prior to the 2008 regulatory changes, Mathematica found more  exits from the rolls would be needed to offset existing operational costs.  Yet without data on the number of ticket holders actually exiting the rolls  due to long-term employment, an accurate assessment of the program  cannot be made.
section_title: More Employment Networks Are Participating, but Fewer Than 2 Percent Receive the Bulk of SSA Ticket Payments
paragraphs: Although an increasing number of ENs are participating in the Ticket  program since the 2008 changes in regulations, many ENs are not actively  participating and ticket payments have remained concentrated with 20  ENs. The number of ENs contracted by SSA increased from 1,514 in fiscal  year 2007 to 1,603 as of July 2010. During this time, ENs accepting at least  one ticket also increased from 752 to 1,086. The majority of EN  representatives we interviewed said the regulatory changes provided  greater incentive for participation because ENs can now receive payments  earlier and be paid for ticket holders with part-time earnings. Twenty-three  of the 25 ENs we interviewed opted to receive payments under the  milestone-outcome option, which does not require that ticket holders have  sufficient earnings to leave the benefit rolls before ENs are eligible for  payments. One EN representative said that because SSA payments for  serving DI and SSI beneficiaries are now roughly equal, an EN has greater  incentive to serve SSI beneficiaries, who were previously associated with  lower payment amounts. Additionally, ENs receiving ticket payments from  SSA more than doubled, from 206 in fiscal year 2007 to 460 as of July 2010,  and total payments grew substantially, from $3.8 million in fiscal year 2007  to $13 million as of July 2010. According to SSA officials and program  manager representatives, the program’s goal is not more ENs, but more  ENs accepting tickets, serving ticket holders, and generating payments. To  this end, SSA officials reported that SSA has sought to identify ENs who  are still not accepting tickets to encourage them to participate or  terminate their contracts. For example, the program manager identifies  ENs not receiving payments within a certain amount of time and  encourages them to participate.
While the number of ENs accepting tickets has increased, a relative few  receive the bulk of all ticket payments: 20 ENs accounted for the majority  of all ticket payments in every fiscal year since the program was fully  implemented in 2004, but represented a small percentage of ENs with  tickets assigned (see fig. 2). In fiscal year 2009, 20 ENs representing 1.2  percent of all SSA-contracted ENs and 1.9 percent of those ENs accepting  tickets received 71 percent of total ticket payments. Reasons why EN  participation is not broader may be attributable to costs and other factors.  Several EN representatives told us that financing the upfront costs of  providing services can be challenging, even though SSA officials said the  2008 regulatory changes were intended to address the costs associated  with providing initial services. Some EN representatives said that when  ENs begin to receive outcome payments for clients they no longer  intensively serve, it can help to cover the upfront costs of providing  services to new clients. SSA officials noted that a number of ENs have  received outcome payments; however, a ticket holder must sustain  employment at the SGA level to generate an ongoing stream of outcome  payments for the EN. Some EN representatives also said providing  resource-intensive services, including driving clients to work or providing  career and personal counseling, could limit profitability. They also  reported that ticket payments are insufficient to support such costly  services, if they are an EN’s sole source of funding. Several EN  representatives also told us an EN’s ability to generate ticket payments  depends on effectively screening potential clients for motivation and  employability.
section_title: Employment Networks Vary in Service Approaches, but Increasingly Focus on the Employed or Ready to Work
paragraphs: ENs receiving among the largest payment amounts from SSA provide a  range of services, including assistance with job search and retention. But  since the 2008 changes in regulations, an increasing number used service  approaches targeting ticket holders who are already working or ready to  work, and they accounted for a greater share of payments from SSA.  However, SSA does not compile data on service provision trends and,  therefore, cannot use data on evolving service approaches to inform its  management and oversight of the program, or to tailor guidance to ENs.
subsections: section_title: Employment Networks Provide a Range of Services Including Assistance with Job Search and Retention
paragraphs: The ENs receiving among the largest payment amounts from SSA in fiscal  years 2007 and 2009 (the time period just before and after the 2008  changes in regulations) provide a range of services to ticket holders,  including job search and retention assistance and financial support (see  app. IV). Disability rights advocates, EN representatives, and SSA officials  we spoke with stressed the importance of a variety of available services  because needs of ticket holders vary. For example, a ticket holder  returning to the workforce after a short absence may need minimal job  search assistance; another with a severe disability may need ongoing  support at the workplace to perform job tasks. EN representatives said the  most commonly provided services are developing ticket holders’ job- seeking skills, such as resume writing and interview preparation, and  providing job-retention services, such as additional training and guidance  on difficult work situations. Compared to the ENs we interviewed, the VRs  included in our review reported providing a greater number of services  and more costly on-the-job and medical-related supports, such as  supported employment, and medical and therapeutic treatment. The VRs,  which receive federal and state operating funds, more frequently reported  providing funding for ticket holders’ education or vocational training,  assistive technology, or personal attendant services. Some disability rights  advocates and EN representatives told us the VR service approach may be  a good fit for those needing intensive services or training, but not for  ticket holders looking for quick job placement assistance or who need  long-term job retention services. Under requirements specific to VRs, they  may close cases after ticket holders are employed for 90 days.
The 25 ENs we interviewed also varied in areas served and methods of  delivery. Seven served local ticket holders, 12 served ticket holders in  one or multiple states, and the other 6 served ticket holders nationwide. In  general, ENs serving ticket holders locally or statewide primarily offered  services in person, while those serving ticket holders in multiple states or  nationwide primarily used the phone or Internet for services (see app. V).  Some ENs offering services in person told us some ticket holders prefer  face-to-face interaction, and the ENs also are better able to assess ticket  holders’ needs and commitment to working. For example, one EN  representative conducts 90-minute intake interviews with all potential  clients, asking about their disabilities, interests, and needs, and describing  how working will affect their benefits, and may meet with the ticket  holder’s relatives. On the other hand, some ENs offering services by phone  or online said they can expand their geographical reach, serve more ticket  holders, and expend fewer resources. Some disability advocates and EN  representatives said some ticket holders, for example, those located in  rural areas or whose mobility is limited by their disability, prefer to  interact by phone or online.
section_title: Employment Networks Increasingly Use Approaches, Such as Sharing SSA Ticket Payments, That Target Those Already Employed or Ready to Work
paragraphs: Although ENs continue to provide a range of services, we found an  increasing number of ENs used service approaches targeting ticket  holders who are already working or ready to work, and ENs using these  approaches have accounted for a greater share of payments. The 2008  regulatory changes more explicitly allow ENs to pay ticket holders and we  found increasing numbers of ENs sharing SSA ticket payments with ticket  holders who have sufficient earnings to qualify the EN for payment. This  “shared payment” approach allows the EN to readily claim ticket payments  while providing no direct services because the ticket holder is already  working or able to find a job without assistance. These service  approaches accounted for an increasing proportion of total ticket  payments made by SSA. For example, in fiscal year 2007, 1 of the 20 ENs  among those with the largest payment amounts used this approach and  received about $787,000 in SSA payments, or one-fifth of all payments to  ENs. In fiscal year 2009, 3 of the 20 ENs among those with the largest  payment amounts used this approach and received over $4 million, or  nearly one-third of payments to all ENs. Two of the 3 ENs pass back 75  percent of SSA’s ticket payment to ticket holders, equating to about $950  per payment for some ticket holders, and retain 25 percent themselves;  and the third EN offers ticket holders $500 every 3 months. SSA officials  told us the decision to allow ENs to share payments with ticket holders  was made in 2001, prior to the program’s implementation and by officials  who have since left the agency. Yet in its 2008 changes, SSA for the first  time provided regulatory language that clearly permits the use of shared  payments. Some disability rights advocates and EN representatives said  that since program rules do not allow ticket holders to serve as their own  ENs, this approach allows them to receive a Ticket program payment for  their efforts to find a job on their own. Some EN representatives also said  the payment may help a ticket holder meet needed work-related expenses  such as transportation, clothing, and child care, increasing the likelihood  he or she will keep a job. However, the ENs sharing payments with ticket  holders told us they do not restrict or verify how the money is used. Two  of the ENs require ticket holders to sign a form affirming their intent to  use the payments for work-related expenses and the third simply provides  payments.
While the data indicate a large number of ticket holders assigned to  shared-payment ENs have earnings sufficient to generate SSA payments,  this is expected given these ENs target ticket holders who are already  working. Long-term outcomes of ticket holders receiving shared payments  compared to those receiving support services is unknown, because SSA  does not assess the relative outcomes of ticket holders based on services  received. A senior SSA official acknowledged that the program must  balance the demands it places on ENs to provide services with incentives  for them to participate, and Congress’ intent was to provide ticket holders  with a choice of services. However, the official also told us SSA officials  have some concerns about the shared payment approach because the  program was not intended to provide a wage subsidy, nor assist those who  can find employment on their own, but to provide tangible employment- related services to those who can benefit from them most. Along these  lines, near the end of our review, the official said SSA is considering  requiring ENs to provide a minimum level of services and to periodically  assess ticket holders’ need for additional services.
Some disability rights advocates and EN representatives raised concerns  about sharing payments while providing only limited or no other services.  This approach, they said, only works for ticket holders who can find  employment on their own, and raises questions about the value these ENs  add to the program. For example, one disability rights advocate said that it  would be preferable for SSA to give the ticket holder the entire payment  directly, rather than paying an EN a portion of the ticket payment to serve  as a middleman. Additionally, the representatives told us ticket holders  may need support after finding employment, such as counseling or help  with a disability-related relapse, but choose an EN using the shared- payment approach because they are enticed by the financial incentive and  do not anticipate future difficulties. In fact, at the time of our review, one  EN’s Web site explicitly encouraged ticket holders who need help finding a  job to contact their VR first, then return to the EN for shared payments  only when employed (see fig. 3). Because ENs using this approach  reported they tend to interact with ticket holders by phone or online,  ticket holders may find it difficult to get answers to questions. During our  review, we made phone calls to 6 ENs that offer shared payments and  frequently reached a recorded message. We were able to speak directly  with a representative for only 2 of the 6 ENs, and in one case, all  extensions for the EN’s toll-free number were out of service. Further,  some disability rights advocates expressed concerns that ticket holders  who decide they need additional support will have difficulty switching to  another EN: Some of the ticket’s value has been used, and fewer potential  payments may make the ticket holder a less desirable client for a  prospective EN. Further, according to one EN representative, because  these ENs do not provide a vocational assessment of strengths,  weaknesses, and aptitude, ticket holders may end up in a job that is a poor  fit, affecting their ability to retain it and, ultimately, reduce dependency on  benefits.
In addition to the shared payment approach which targets ticket holders  already working, two “employer-driven” service approaches which target  ticket holders who are ready to work have also accounted for a greater  share of SSA payments to ENs among those with the largest payment  amounts: the direct employment approach, in which the EN itself employs  ticket holders, and the staffing approach, in which the EN primarily works  with employers to develop and identify jobs for ticket holders, similar to a  staffing agency. While 4 of the 20 ENs among those with the largest  payments in fiscal year 2007 used employer-driven approaches, 6 did so in  fiscal year 2009. Payments to these ENs in fiscal year 2007 were about  $226,000 or 6 percent of all SSA payments; in fiscal year 2009, payments  increased to about $1.7 million, or 13.4 percent (see fig. 4). A  representative of one EN using an employer-driven approach told us the  EN plans to pay financial incentives to employers to hire ticket holders.  One key program official told us SSA does not restrict how ticket  payments are spent, and its handbook for ENs includes an example of an  EN providing employers with financial incentives. Both approaches  generally target ticket holders who are ready to work, facilitating earlier  SSA payments to the EN. For example, one EN looks for ticket holders  with a high school education, computer skills, and relevant work  experience, and screens out ticket holders with psychiatric or cognitive  impairments. SSA officials told us they expect ENs to accept ticket  assignments of ticket holders who are job ready, as well as individuals  they believe they can assist in becoming job ready. They said those who  are job ready may have the best chance of becoming financially  independent and leaving the benefit rolls. Some disability rights advocates  and EN representatives said the direct employment approach can provide  on-the-job supports for ticket holders, and the staffing approach could  increase the likelihood of a quick job match by responding to the needs of  employers. However, they also raised some concerns about these  approaches. For example, some disability rights advocates and EN  representatives said there is the potential for disclosure of a ticket holder’s  disability to an employer, although some may be uncomfortable having  this private information shared for fear of being treated differently by  supervisors or coworkers. Some EN representatives raised a concern that  once payments from SSA to the EN, or from the EN to the employer cease,  ticket holders could lose their jobs because the financial incentive is gone.  Some disability rights advocates and EN representatives also raised  concerns that under the staffing approach, ENs may focus primarily on an  employer’s needs and steer ticket holders into jobs that are not a good  match, decreasing the likelihood of job retention.
EN we interviewed using the hared payment approachEN we interviewed using employer-driven approacheEN we interviewed thuse other pproche  EN we did not interview (pproche nknown)
section_title: SSA Does Not Compile or Use Data on Service Provision Trends
paragraphs: SSA officials said they do not compile data on trends in service provision,  nor view it as SSA’s role. As a result, information on service provision is  limited. For example, although SSA compiles information on certain types  of service providers, such as mental health providers, as part of its efforts  to recruit specific providers, it does not obtain comprehensive information  on services provided by all ENs. Moreover, while service providers  applying to become ENs must indicate which services they intend to  provide using a checklist in the request for proposal, and approved ENs  must update this information on the annual periodic outcome report to  SSA, the checklist does not reflect all services, such as providing financial  assistance or incentives to ticket holders via shared payments. One key  program official acknowledged that some ENs note they offer all services  listed in the request for proposal (RFP) and annual periodic outcome  report while rarely or never providing some of them. Further, it is unclear  that SSA uses information it collects on service provision. For example,  while SSA officials told us the agency first approved an EN with a shared  payment approach because the EN pledged to offer job search assistance,  personal attendant support, and other services, we found this EN does not  provide such services and had not reported providing them in its last three  annual periodic outcome reports to SSA. During the course of our review,  SSA officials said they plan to begin restricting the services an EN can  advertise in the online service directory to services the EN has agreed to  provide ticket holders in individual work plans. This is intended to ensure  the directory of ENs and services more accurately reflects actual services  delivered.
Without sufficient data on trends in service provision, SSA lacks  information to inform its management and oversight of the program, or to  tailor guidance to ENs. Internal control standards state that program  managers need operational data to determine whether they are meeting  their goals for accountability. SSA has identified problems with certain  service approaches on an ad hoc basis, and responded with changes in  program requirements and procedures. In 2009, SSA provided further  clarifications regarding its 2008 regulatory requirements for phase 1  milestone 1 payments (payments made by SSA to an EN when a ticket  holder has 1 month of trial work-level earnings) and established a review  process after an investigation following a beneficiary complaint found  that some ENs employed ticket holders themselves just long enough to  qualify for this payment, according to SSA officials. Although SSA was  responsive and has since implemented additional oversight mechanisms,  the problem was identified by a third-party complaint and not through  systematic oversight on the agency’s part. In addition, because sufficient  data on the extent to which shared payment, employer-driven, or other  service approaches is not collected by SSA, we could not determine  approaches of ENs we did not review, despite the fact these ENs received  nearly $3.7 million, or nearly 30 percent of all payments from SSA in fiscal  year 2009. Finally, without sufficient information on service provision  trends, SSA is unable to provide guidance or best practices to ENs. For  instance, although some disability rights advocates and EN representatives  raised concerns that employer-driven approaches may pose conflicts of  interest if safeguards are not implemented, the EN contract does not  include guidance to ENs on how to avoid such issues.
section_title: SSA Lacks Adequate Management Tools for Evaluating Ticket Holders and Employment Networks to Ensure Program Integrity and Effectiveness
subsections: section_title: SSA Has Not Consistently Monitored Ticket Holders’ Timely Progress Toward Self-Supporting Employment
paragraphs: Since 2005, SSA has not consistently monitored or enforced the timely  progress of ticket holders who assign their tickets to ENs and VRs in order  to assess whether they should continue to be exempt from medical  continuing disability reviews (CDR)—a key tool for assessing continuing  eligibility for benefits. While timely progress by ticket holders is a  regulatory requirement, SSA instituted a moratorium on enforcing  progress review results—a responsibility of the Ticket program  manager—because of concerns expressed by service providers that the  work requirements for ticket holders were too stringent. SSA also  considered changes that would have eliminated timely progress reviews.  However, the final 2008 regulatory changes established more stringent  timely progress standards, such as minimum requirements for ticket  holders to meet within the first 2 years of ticket assignment, but added  provisions allowing for education or job training in lieu of employment  (see app. VI). SSA has acknowledged in the preamble to its program  regulations and in a 2005 internal memo the importance of timely progress  reviews for ensuring that ticket holders who have medically improved and  no longer meet SSA’s disability requirements do not receive benefits and  its disability programs do not incur unwarranted costs. Further, without  timely progress reviews, representatives of some of the ENs we  interviewed said some ticket holders “park” their tickets to get the CDR  exemption, for example, by assigning their ticket with no interest in  obtaining EN services or reducing their dependence on benefits. Resuming  timely progress reviews, they said, would be a positive motivator for ticket  holders to engage in EN services essential to obtaining and retaining  employment and, ultimately, reducing dependence on benefits.
During the course of our review, in November 2010, representatives of the  Ticket program manager reported they began limited resumption of the  timely progress reviews. Representatives of the program manager  reported, between November 19 and December 15, 2010, they mailed out  requests for information on timely progress (the first step in the review  process) to roughly 4,900—or 26 percent—of the 19,000 ticket holders  initially reported as due for review in November of that year. After  reviewing a draft of our report, SSA officials told us that by February 8,  2011, initial requests for information had been mailed to those ticket  holders–almost 3 months after they began their mailings. Given that SSA  estimates between 13,000 to 22,000 ticket holders will be due for timely  progress reviews each month of the first year of resumption, there is  potential for a significant backlog in reviews to determine which ticket  holders should continue to qualify for CDR exemption. To reduce the  workload, SSA and the program manager reported taking steps to develop  an automated earnings check to better identify ticket holders who met  timely progress based on their earnings, and eliminate the need to contact  them for a review. The agency also delayed resumption of timely progress  reviews to ensure this automated earnings check was operational,  according to one SSA official. However, as of December 15, 2010, program  manager representatives reported it still was not operational and began  resumption of timely progress reviews without this check in place. Once in  place, one SSA official anticipated these automated earnings checks would  reduce the volume of mailings and follow-up action needed to complete  timely progress reviews. However, representatives of the program  manager said such checks would have little impact on the number of  pending reviews: When operational, they estimated, the checks would  likely identify only a few hundred ticket holders as meeting timely  progress out of the 13,000 to 22,000 due for reviews each month. SSA  officials said that significant experience with the earnings check will be  needed to determine its ultimate impact on the workload. After reviewing  a draft of our report, they said the primary reason for conducting the  earnings check is to avoid placing unnecessary burden on ticket holders  and ENs, and any reduction in workload would be an additional benefit.
In addition to delays in monitoring timely progress, there are questions  about whether the program manager will have reliable information to  make timely progress determinations. At the time of our review, SSA and  program manager representatives told us they will rely on ticket holder  and EN self-reported information. For example, the progress review form  the program manager sends to ticket holders asks them to reply with a yes  or no answer as to whether they met the earnings requirement or the  education or training requirement, and asks for the name of the school and  number of credits completed. SSA and program manager representatives  told us they do not independently verify this self-reported information  with employment records or educational documentation. In our past work,  we have found that reliance on self-reported information alone can lead to  program integrity issues, such as overpayments of SSA benefits. Absent  some level of independent verification of the information ticket holders  provide, it is unclear to what extent the results of the timely progress  reviews are based on accurate information.
section_title: SSA Has Not Developed Performance Measures for Employment Networks
paragraphs: SSA has not developed performance measures for contracted ENs to  assess their success in helping assigned ticket holders obtain and retain  employment and reduce dependence on disability benefits. The Ticket law  directs SSA to develop performance measures for quality assurance in the  provision of services by ENs, and gives SSA the authority to terminate EN  contracts for inadequate performance. In addition, internal control  standards for the federal government also stress the use of performance  measures for proper stewardship of and accountability for government  resources, and for achieving effective and efficient program results. SSA  officials told us the historically low number of contracted ENs, and even  fewer that accept tickets, made it difficult to hold ENs to performance  standards. Since the increases in the number of ENs after the 2008  changes, officials said they may consider factoring performance into EN  contract extension reviews in the future. Near the conclusion of our audit  work, they told us they are considering future updates to the program  regulations that in their view will address EN performance expectations.  However, without performance measures, SSA is currently unable to  systematically evaluate EN performance, and ultimately determine  whether ENs should be allowed to remain in the program.
Lack of performance measures may mean ENs are unclear about program  goals and send mixed messages to ticket holders about expected  outcomes. Of the 25 ENs we interviewed, representatives of 15 said SSA  had not adequately articulated performance expectations for serving ticket  holders. SSA officials told us EN quality assurance is built into the Ticket  program’s payment system because ENs cannot get paid until a ticket  holder meets minimum earnings thresholds. However, the 2008 regulatory  changes lowered the earnings thresholds required for ENs to be eligible  for ticket payments, making it possible for ENs to be paid without a ticket  holder first achieving earnings at or above the SGA level. An EN with the  fourth-largest payment amount from SSA in fiscal year 2009 stated in its  last three annual periodic outcome reports that 100 percent of its ticket  holders placed in jobs had earnings of less than $10,000 per year— equating to less than the SGA level, if earnings were accrued regularly over  the course of 12 months. In fact, the EN’s phone message states that DI  ticket holders can work part time indefinitely without reducing SSA  benefits, and the Web site says most of its positions are designed so ticket  holders stay below income thresholds for benefit cutoff. Despite the fact  that SSA’s EN handbook states the ultimate goal of the program is to  reduce dependence and, whenever possible, eliminate reliance on benefits,  we found multiple ENs among those with the largest payment amounts  communicating through their Web sites, recorded phone messages, or in  our discussions with representatives that as long as DI ticket holders’  earnings stay below the SGA level, they can keep full disability benefits  (see fig. 5 for excerpts of calls and a link to audio excerpts. App. VII  provides full transcripts of the calls). While full-time employment may be  unattainable for certain ticket holders and one key program official told us  that part-time employment is acceptable under the 2008 regulations, the  official said it should be a starting point, not an end goal. Nonetheless,  our review indicates some ticket holders are being coached by ENs,  including some of those with the largest payment amounts, to work part  time so as not to jeopardize their benefits.
While SSA lacks performance measures to evaluate ENs, it does collect  some self-reported EN performance information. To comply with the  Ticket law, SSA requires ENs to submit annual periodic outcome reports,  including information on ticket holder job placements, job retention, and  disability benefits suspension and termination. SSA officials told us the  original purpose of these reports was to evaluate EN performance and, as  required by law, to make the reports available to beneficiaries. However,  officials said because the information is self reported it is not used to  evaluate ENs or shared with beneficiaries. Instead, officials said the  outcome reports are primarily used by the Ticket program manager to  update EN contact information, such as addresses and phone numbers. At  the time of our review, SSA was developing a report card with  performance information on each EN with 10 or more assigned tickets.  The report card is based on selected information from the annual periodic  outcome reports, as well as from a newly developed ticket holder  customer satisfaction survey, and is currently being piloted in California.  SSA officials said the primary purpose of the report cards will be to share  performance information with ticket holders, as required by law, to help  them make informed decisions when selecting an EN. SSA officials also  said they were beginning to solicit feedback from ENs on how the report  card might be used by the agency to evaluate EN performance, but were  unable to provide us with documentation on plans to use the report card  as a performance management tool. Further, because the report cards are  designed to be used by ticket holders, it is not clear they will include the  full extent of outcome-oriented performance information needed to  evaluate ENs against the program purpose, particularly in deciding  whether to extend an EN contract. For example, the report card does not  have any indicators for an EN’s success in moving ticket holders off  benefits. While it includes an indicator for ticket holders who retain a job  for at least 6 months, it does not include earnings information, which is  key to reducing and eventually ending SSA disability benefits.
section_title: SSA’s Approval Process for Employment Networks Lacks Systematic Mechanisms to Ensure Quality
paragraphs: SSA’s process for approving ENs to serve ticket holders lacks systematic  tools to ensure quality, such as requiring all applicants to submit a  comprehensive business plan for how their services will help ticket  holders obtain and retain employment and reduce dependency on benefits,  and providing clear and specific written criteria to SSA staff who review  qualifications of applicants. SSA’s RFP states an EN applicant must  provide applicable certificates, licenses, or other credentials for delivering  employment services, VR services, or other support services. An EN is  only required to submit a qualifications statement and business plan that  demonstrates expertise and/or experience at providing employment  services if it does not submit specified documents (see table 2). SSA  officials told us when the program was implemented almost all applicants  were approved because the agency wanted to increase participation. As of  June 2010, only 11 ENs had ever been denied an EN contract, 6 of those in  fiscal year 2010. However, SSA officials told us that, in recent years, they  have become more stringent in reviewing qualifications; and, in May 2009,  modified the RFP to require more detailed information from applicants  who submit a business plan. Near the conclusion of our review, the  officials told us they were considering changes to the RFP requiring all  ENs to submit a business plan that describes how the applicant’s services  will help the ticket holder achieve sustained employment. The officials  also said they were considering requiring ENs to demonstrate more  specific experience serving individuals with disabilities. However, these  changes were still pending at the time of our review.
SSA has not consistently required ENs directly hiring ticket holders to  submit a comprehensive business plan—a safeguard that could screen out  ENs with insufficient qualifications or questionable business practices. In  May 2009, as a result of questionable activities by some ENs which  temporarily hired ticket holders primarily to obtain early ticket  payments, SSA revised its RFP to require applicants intending to hire  ticket holders directly to provide additional information on the nature of  this employment in their business plans. Our case file review showed that  SSA subsequently denied one EN applicant in April 2010 because it had  not provided “a clearly elucidative business plan for assisting beneficiaries  in finding and retaining employment with a goal toward self-sufficiency.”  Yet of 9 RFP submissions by ENs approved by SSA in March and April  2010 which indicated in the RFP that they would directly employ ticket  holders, 7 were not required to provide a business plan because they  provided one of the other allowable proof of qualifications— documentation of certificates, licenses, or other credentials. As a result,  SSA lacked information to assess whether the nature and extent of the  proposed direct employment were consistent with the program’s purpose.
In addition, SSA does not have clear and specific criteria to clarify the RFP  requirements and help staff responsible for reviewing EN applications  assess whether an applicant’s documentation of qualifications is adequate.  While the RFP requires an applicant, if submitting a business plan, to  clearly demonstrate expertise and/or experience in providing employment  services and/or supports relevant to the requirements of the RFP, there is  no explicit requirement for all EN applicants to demonstrate experience  working with people with disabilities or in providing the specific services  listed in its application. SSA staff told us they use the criteria from the  RFP, their judgment, and their knowledge of the Ticket law to assess  qualifications. One SSA official said because a team of only three people is  responsible for reviewing EN applications, they learn on the job. If they  have questions, they ask other staff or their supervisor. However, without  clear and specific criteria, we found staff did not always hold applicants to  the same standards. For example, while one employee reported reviewing  EN qualifications against the EN’s proposed services in the submitted  RFP, the 38 applicant case files we reviewed for EN applicants approved  and denied in fiscal years 2009 and 2010 indicated staff do not consistently  link EN qualifications to promised services. We found 5 applicants who  were denied explicitly because they could not demonstrate experience or  expertise working with people with disabilities or in providing specific  services, such as work incentives counseling, self-employment assistance,  and supported employment. In contrast, 14 others who also did not  demonstrate such experience or expertise were approved, according to  the files. In one instance, an applicant approved by SSA in August 2009  indicated in its RFP submission it planned to provide career consulting,  job placement, supported employment, as well as various other services,  but submitted a beauty institute license as its only proof of qualifications  to provide such services.
section_title: Conclusions
paragraphs: SSA has achieved modest improvements in Ticket program participation  for ticket holders and ENs under the revised regulations finalized in 2008,  and we are encouraged that in recognition of program weaknesses, the  agency is considering various improvements. However, at this time, the  agency still lacks critical management and oversight mechanisms to assess  whether the program is achieving its original purpose, and ultimately,  whether the program is viable. SSA is considering studying ticket holders’  exits from the rolls following the implementation of the 2008 regulations;  however, it is unclear whether the agency will follow through with this  effort. It also has not collected adequate information on service provision  that could help the agency and policymakers analyze program trends,  including the increasing prevalence of sharing SSA ticket payments with  ticket holders. In this regard, SSA is not well positioned to assess the long- term success of the program or whether service approaches, such as  sharing payments with ticket holders, are consistent with program goals.  Moreover, without regular reviews of ticket holders’ timely progress  toward reducing dependence on benefits, they may remain exempt from  CDRs, regardless of whether they are in fact moving toward self- supporting employment. Even with resumption of these reviews, SSA may  be unable to keep pace with the volume of reviews and their reliance on  self-reported information raises questions about accuracy. Inadequate  monitoring of ticket holders’ progress raises program integrity concerns  and could result in benefit payments to beneficiaries who may no longer  be eligible. Further, absent assurance of EN quality and sustained  oversight of EN performance, ticket holders could encounter ENs  providing services or information that are inconsistent with the program’s  purpose of reducing or eliminating dependence on benefits. Ultimately,  SSA must balance its efforts to increase participation in the program with  a commitment to outcome-oriented results that emphasize reducing  beneficiaries’ dependence on benefits. Without improvements to existing  management tools and oversight procedures in the Ticket program, SSA  will not be able to provide reasonable assurance that, in a time of  increasing fiscal challenges, limited tax dollars are being effectively used  to achieve these important program objectives.
section_title: Recommendations for Executive Action
paragraphs: To inform assessments of the program’s cost and effectiveness and  enhance SSA’s oversight and monitoring of ENs and ticket holders, we  recommend that the Commissioner of Social Security take the following  four actions:    prioritize and carry through with a study of participating ticket holders’  exits from the rolls since revisions to the program’s regulations took effect  in 2008;   adopt a strategy for compiling and using data on trends in employment  network service provision to determine whether service approaches, such  as sharing SSA ticket payments with ticket holders, are consistent with  program goals of helping ticket holders find and retain employment and  reduce dependency on benefits; for example, SSA could revise existing  tools to compile information on service approaches used by all ENs;   develop a strategy to ensure on-time completion of timely progress  reviews of ticket holders and take steps to ensure the accuracy of  information used to make timely progress determinations; and   move forward to develop EN performance measures consistent with the  requirements of the Ticket law.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Social Security Administration. In  its written response, reproduced in appendix IX, SSA agreed with three of  the five recommendations in our draft report, including a recommendation  that the agency develop systematic mechanisms for reviewing the  qualifications of prospective ENs. SSA also offered alternative language  for the wording of two other recommendations. With regard to our  recommendation to prioritize and carry through with a study of  participating ticket holders’ exits from the rolls since revisions to the  regulations took effect in 2008, SSA stated that the agency already has  plans to study the effects of the revisions on the Ticket program. However,  as we discuss in the report, SSA’s tentative plans to study exits from the  rolls, in particular, have not yet been undertaken and depend upon the  results of other planned research. We are encouraged that SSA intends to  conduct this research. However, we continue to believe that prioritizing  and carrying through with a study of ticket holders’ exits from the rolls is  important and that, without such information, an accurate and complete  assessment of the program’s effectiveness cannot be made. With regard to  our recommendation that SSA develop a strategy to ensure on-time  completion of timely progress reviews of ticket holders and take steps to  ensure the accuracy of information used to make timely progress  determinations, SSA stated that it has a strategy in place, noting that it  restarted the timely progress reviews in November 2010. As we discuss in  the report, SSA began resumption of timely progress reviews for ticket  holders due for review in November 2010. However, according to SSA, it  did not carry out the initial step in the review process for these ticket  holders until February 2011. Moreover, SSA estimates between 13,000 to  22,000 ticket holders will be due for timely progress reviews each month  of the first year of resumption. Given SSA’s current rate of processing the  reviews and the volume of additional reviews which are imminent, we  continue to believe there is potential for significant backlog in completing  these reviews. SSA also stated that the agency will review a random  sample of beneficiaries’ cases to ensure the accuracy and reliability of  information they compile when making timely progress review decisions.  We welcome SSA’s review of beneficiaries’ cases, but continue to be  concerned that SSA may not have reliable information on the front end to  make timely progress determinations. Given that timely progress reviews  are intended to be used as a key program integrity tool—to ensure  appropriate exemptions from continuing disability reviews—we continue  to believe that SSA needs a strategic approach to ensure the promptness  and accuracy of timely progress determinations. SSA agreed with the  recommendation we made in our draft report that the agency develop  systematic mechanisms for reviewing the qualifications of prospective  ENs. After reviewing and providing comments on our draft report, the  agency posted a new Request for Quotation on April 27, 2011. This new  Request for Quotation, which replaces all previous RFPs, requires each EN  to submit a comprehensive business plan and includes more specific  criteria for assessing EN qualifications. We believe that this satisfies the  intent of the recommendation we made to the agency and should, if  properly implemented, improve EN oversight; thus, we have removed the  recommendation from our final report. SSA also provided technical  comments, which we incorporated into the report where appropriate.
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If you or your staff have any questions about 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 major contributions to this report are  listed in appendix X.
section_title: Appendix I: Scope and Methodology
paragraphs: Our review focused on (1) ticket holder and employment network (EN)  participation over time, (2) service approaches used by ENs, and (3) the  Social Security Administration’s (SSA) policies and processes for  evaluating ticket holders and ENs. To answer all of our research  objectives, we reviewed relevant federal laws and regulations, and SSA’s  Program Operations Manual System for the Ticket program, as well as  other written program policies and procedures. We conducted interviews  with SSA officials from the Office of Employment Support Programs  (OESP), SSA’s contracted Ticket program manager, and SSA’s contracted  Ticket program recruitment and outreach manager to learn about their  various roles and responsibilities and key management and oversight  functions, including approving ENs; reviewing individual work plans,  ticket assignments, EN annual periodic outcome reports, and reviewing  and processing EN requests for payment; as well as reviewing timely  progress of ticket holders. We also learned about the processes and  management of the Ticket program manager’s call center for beneficiaries.  We conducted interviews and case file reviews for selected ENs and state  vocational rehabilitation agencies (VR) that opted for the EN payment  system. Overall, the scope of our review was generally limited to ENs,  including VRs that opt for the EN payment system, although we examined  changes in the number of ticket holders using tickets with VRs paid  through the traditional SSA Vocational Rehabilitation Reimbursement  Program over time. During our review, we also consulted with outside  researchers, disability advocacy organizations, and other stakeholders.  Specifically, we interviewed representatives of Mathematica Policy  Research; the American Association of People with Disabilities;  Consortium for Citizens with Disabilities; Easter Seals Inc.; Goodwill  Industries International, Inc.; National Alliance on Mental Illness; National  Council on Independent Living; and the World Institute on Disability. For  background purposes and to better understand the various roles and  functions of entities related to the program, during our design phase, we  interviewed representatives of two state Protection and Advocacy   programs, a state Work Incentives Planning and Assistance project, and  an SSA regional Ticket coordinator. During this phase we also contacted  the SSA’s Office of the Inspector General, the Congressional Research  Service, the Congressional Budget Office, the National Council on  Disability, and Social Security Advisory Board to identify any related work  under way in this area.
To learn how ticket holder and EN participation in the Ticket to Work  program has changed over time, we obtained and analyzed data on eligible  ticket holders and ENs approved by SSA from fiscal year 2004, the year in  which the Ticket program was fully implemented, through July 2010.  Specifically to learn about ticket holder participation, we obtained data  from SSA’s Disability Control File and Comprehensive Work Opportunity  Support System, for each of these years on the universe of ticket holders,  and those who had assigned their tickets to ENs. Specifically to learn  about EN participation, we obtained data from the Disability Control File  and Comprehensive Work Opportunity Support System and for each of the  years mentioned above, on ENs with SSA-approved contracts, assigned  tickets, and payments from SSA. For the purposes of analyzing EN  participation, we did not examine VRs with which ticket holders use their  tickets. To assess the reliability of the data we obtained from SSA, we (1)  reviewed existing documentation related to the data, (2) interviewed  knowledgeable SSA staff about the data, and (3) tested the data for  completeness and accuracy. Our data analyst followed up with SSA staff  on an ongoing basis to clarify and resolve potential discrepancies she  encountered with the data. Based on these steps, we have found these data  to be sufficiently reliable for the purposes of our analysis. We also  interviewed SSA officials, disability advocacy organization  representatives, and employment network representatives and we  reviewed studies on ticket holder participation to learn about factors  influencing changes in participation.
To learn about service approaches used by ENs, between July and  September 2010, we interviewed representatives of 25 ENs, which include  20 ENs among those with the largest payments in fiscal year 2007, the year  prior to implementation of the new program regulations, and fiscal year  2009, the most recent year for which we had full data. Based on  preliminary data from SSA, we selected the 20 ENs with the largest  payments from SSA for our review of services provided by ENs, because  we wanted to be able to report on services provided by ENs actually  receiving payments from SSA, in effect, to provide a better sense of how  government (taxpayer) dollars are being spent. In making this selection,  we also determined that the amount of SSA payments received by these  ENs made up an extensive share of the total payments SSA provided to all  ENs. We subsequently received updated data from SSA, which we  confirmed with our own data analysis, and found these ENs accounted for  the 20 ENs with the largest payments in fiscal year 2007, the 19 ENs with  the largest payments in fiscal year 2009, and the EN receiving the 22nd  largest payment in fiscal year 2009. See appendix VIII for the ENs  interviewed as part of this review. We conducted site visits to Arizona,  California, Connecticut, Maryland, and Massachusetts to visit 10 of these  ENs and with representatives of 2 ENs that have no physical locations for  delivering services. We selected ENs for our site visits with a range of  service approaches. For these interviews, we asked ENs about the  services they provided to ticket holders, including the frequency of  providing these services, services they most commonly provide, the  geographic area they serve, and how their services had changed over  time. We also asked them about strengths and weaknesses of different  service approaches, and costs and incentives for participating in the Ticket  program. In addition to these interviews, we obtained and reviewed  documents from SSA for each of the 25 ENs we interviewed for  information on services provided by the ENs, as indicated in their request  for proposal submissions and their annual periodic outcome reports. We  also interviewed representatives of disability advocacy organizations, in  addition to the ENs we interviewed, to gain their perspectives on the  advantages and disadvantages of various service approaches used by ENs.  To determine the distribution of ticket payments to ENs using certain  service approaches in fiscal years 2007 and 2009, we categorized ENs  based on the primary service approach they used. We also interviewed  SSA officials to learn about SSA’s efforts to compile and use information  on trends in service provision. We did not assess the effectiveness of the  different service approaches we identified being used by ENs in the Ticket  program.
To analyze the policies and processes SSA has to evaluate employment  networks and ticket holders, we compared SSA’s and the SSA-contracted  Ticket program manager’s written policies and procedures over key ENs  and ticket holder evaluation efforts to the Ticket program laws and  regulations, and government internal control standards. We conducted in- depth interviews with OESP and the Ticket program manager staff  responsible for these key evaluation efforts, including the approval of ENs,  ongoing evaluation of EN performance, and assessment of the timely  progress of ticket holders who assign their tickets. To supplement our  review of SSA’s efforts to evaluate EN for approval and ongoing  performance, we obtained a nongeneralizeable sample of case files of  approved, denied, and terminated ENs to review proof of qualifications  submitted to SSA and for EN performance information. Specifically, we  sampled files for: (1) 20 of the most recently approved ENs as of April 30,  2010, (2) 11 denied EN applicants, which constitute all applicants denied  as of June 2010, (3) 17 ENs which had been put on notice by SSA of  potential termination—some of which were subsequently terminated, and  (4) 25 ENs comprising 20 ENs among those with the largest payment  amounts made by SSA in fiscal years 2007 and 2009. Within this sample, in  order to assess SSA’s controls over approval determinations, we focused  our review on the 38 case files for applicants approved and denied in fiscal  years 2009 and 2010. We also interviewed ENs for their perspectives on  SSA’s performance expectations and their responsibilities regarding the  timely progress of ticket holders. Finally, an investigator from our  Forensic Audits and Investigative Service team contacted selected ENs,  posing as a fictitious employer or relative of a ticket holder, to test for  potential vulnerabilities in program management and oversight. The  investigator phoned 16 ENs, including 9 from among the 25 we  interviewed and 7 ENs we identified using the online EN service directory,  interviews, and e-mail alerts. We judgmentally selected ENs who  advertised paying a portion of the ticket payment to ticket holders or  providing financial incentives to employers, or whose services were  unclear. The investigator called 8 of the 16 to clarify services provided by  the ENs. In five of the recordings or calls, the EN representatives  discussed how work could affect benefits. In three of these, the EN  representatives explicitly told the caller how to remain on benefits  indefinitely while working. Although this is not generalizable across all  ENs, it illustrates potential vulnerabilities in program management and  oversight. Because of the program’s goal of helping ticket holders obtain  and retain employment and reduce dependence on disability benefits, for  inclusion in our report we focused on those portions of these three phone  calls in which an EN representative discussed how to remain on benefits.  The full transcripts of the three calls are provided in appendix VII.
We conducted this performance audit from January 2010 to May 2011 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.
section_title: Appendix II: Picture of a Ticket to Work
section_title: Appendix III: Ticket to Work Payment Structure for Employment Networks
paragraphs: Appendix III: Ticket to Work Payment  Structure for Employment Networks EN payment amount for 2010 (in doll) $3,960 (p to 1yment of $220/month) $4,202 (p to 11 pyment of $32/month) $13,200 (p to 60 pyment of $220/month) $13,752 (p to 36 pyment of $32/month) (p to 60 pyment of $409/month) (p to 36 pyment of $711/month)
section_title: Appendix IV: Range of Services Provided by Interviewed Employment Networks in 2009 and 2010
paragraphs: Appendix IV: Range of Services Provided by  Interviewed Employment Networks in 2009  and 2010 ■ Provide finncil incentive to  employer to hire ticket holder  ■ Directly employ ticket holder  ■ Provide informtion on finncil  incentive to employer or help them pply for finncil incentive■ Provide enefit nd/or work  incentive coeling  ■ Provide independent living ervice■ Provide finnciassnce or incentive to ticket holder■ Provide medicnd therpetic  tretment nd ervice■ Directly provide voctionassssment nd evuation ■ Develop ticket holders’ jo eeking  kill (e.g., resume writing, interview kill) ■ Asst ticket holder in rting   business or with elf-employment ■ Provide ervice fter the ticket  holder i employed  ■ Mtch ticket holder with pecific jobs ■ Provide link to jo rch engineor abase of jo informtion ■ Asst ticket holder in identifying  nd ccessing riety of locsupport ervice (e.g., child cre or trporttion ervice) ■ Assss for nd provide asstive technology (e.g., custom compter interfcefor peron with phyicl or enory disabilitie) ■ Provide supported employment ervice  (i.e., ticket holder with evere disabilitie re  plced in competitive jobs with jo coche or  triner who provide individualized, ongoing  support ervice to id with jo retention)
section_title: Appendix V: Employment Networks Offer Services in Person, by Phone, and Online
paragraphs: Nine of the 25 EN interviewed, inclding the one pictred  above, primrily provide ervice over the telephone.
Five of the 25 EN we interviewed primrily  interct with ticket holder online, inclding  thi one, which dverti work-from-home jo opening on it We ite.
One EN relies equally on phone and online interaction to deliver services.
section_title: Appendix VI: Timely Progress Requirements for Ticket Holders Participating in the Ticket Program
subsections: section_title: Second
paragraphs: Complete additional academic year  of fll-time dy (none)
Complete   2-yer progrnd earn deree  or certificate (none) (none) (none) (none)
section_title: Appendix VII: Full Transcripts of Calls with Employment Networks on Working Without Losing Benefits Indefinitely
paragraphs: Of the 16 employment networks (EN) called by an investigator from our  Forensic Audits and Investigative Service team, 8 were contacted to clarify  the services they provide (see app. I for more information on our scope  and methodology). In five of the recordings or calls, the EN  representatives discussed how work could affect benefits. In three of  these, the EN representatives explicitly told the caller how to remain on  benefits indefinitely while working. Because the program’s goal is to help  ticket holders obtain and retain employment and reduce dependence on  disability benefits, for inclusion in our report we focused on those  portions of these three phone calls in which an EN representative  discussed how to remain on benefits. The full transcripts of these three  calls are provided below.
Call 1: Caller is a GAO investigator phoning EN on behalf of his  fictitious brother who is a ticket holder, to learn about the Ticket  program and services provided by the EN. The EN representative  describes how the EN assists ticket holders in finding part-time  employment and tells the caller a Social Security Disability  Insurance (DI) ticket holder may collect full monthly benefits  indefinitely as long as he remains under the substantial gainful  activity (SGA) earnings level.  (Whereupon, an outgoing call was placed by the GAO Investigator to an  EN representative.)  (Phone rings.)
EN REPRESENTATIVE: Good afternoon, (inaudible), (name) speaking. How may I help you?
GAO INVESTIGATOR: Yeah, hi, um uh, is this—what’s—is this a  company that helps disabled people?
EN REPRESENTATIVE: Yes.
GAO INVESTIGATOR: Okay. Uh, I want to talk to somebody, if I  could, um, about, um—my brother is disabled, and I’m trying to help him.  He’s trying to find a job, and I want to see what kind of services your uh  company provides.
EN REPRESENTATIVE: Okay. One second. What’s your name?
GAO INVESTIGATOR: .
EN REPRESENTATIVE: ? Hold on.  (20 second pause.)
EN REPRESENTATIVE 2: Hi, this is  from . How  can I help you?
GAO INVESTIGATOR: Yeah, hi. I’m trying to get some information,  if I could. My, my brother’s disabled, and he—he wants to try to go back to  work part time.
EN REPRESENTATIVE 2: Okay.
GAO INVESTIGATOR: And I’m trying to—  EN REPRESENTATIVE 2: Is he receiving SSI and SSD—or SSD?
GAO INVESTIGATOR: Yeah, he’s receiving um SSD.
EN REPRESENTATIVE 2: Okay. So then he would qualify then.
Because the program is called Ticket to Work program, and the program is  for people that’s getting SSI and SSD. So he would qualify and what would  happen is they would look for part-time work for that individual, and he  would keep half of the benefits. The benefits would not get cut off. So he  would work part time, and then it would supplement the benefits. Um.
GAO INVESTIGATOR: Okay. Now, do you all help him find a job?
EN REPRESENTATIVE 2: Yes, we do.
GAO INVESTIGATOR: Okay. All right, all right. Well, that’s good.
EN REPRESENTATIVE 2: Yes.
GAO INVESTIGATOR: And what other type of services do you guys  provide?
EN REPRESENTATIVE 2: Um. They have um, direct—(name), are  they still doing  counseling?
EN REPRESENTATIVE 3: (off phone)
EN REPRESENTATIVE 2: Residential?
EN REPRESENTATIVE 3: (off phone)
EN REPRESENTATIVE 2: Okay.
EN REPRESENTATIVE 3: (off phone)
EN REPRESENTATIVE 2: Okay. Because the caller wants to know,  like, if they have any additional services that they have. So, it’s um  residential counseling.
GAO INVESTIGATOR: Residential—what’s that, residential  counseling? What’s that?
EN REPRESENTATIVE: Okay. Um. Residential counseling is um  for people, they train you, you get certifications and everything, to work  in—yeah, you work at a group home, residential areas, um.
EN REPRESENTATIVE 3: (off phone)
EN REPRESENTATIVE: Yes.
EN REPRESENTATIVE 3: (off phone)
EN REPRESENTATIVE: Yes.
EN REPRESENTATIVE 3: (off phone)
EN REPRESENTATIVE: Okay.
EN REPRESENTATIVE 3: (off phone)
GAO INVESTIGATOR: You’re, you’re talking to somebody else, I’m  not hearing what they’re saying.
EN REPRESENTATIVE: Oh, okay. Yes, the program entails where  you could work in the group homes, residential areas. And um for like  adolescents and stuff like that. That’s for the residential training that they  have. And then if he had—  GAO INVESTIGATOR: So they teach you—  EN REPRESENTATIVE: If he, if he had any prior work experience,  what they’d do is they’d look for the jobs that they either have on their  resume, if they have one, or um they’ll like set up whatever, set that  interview up for him to get the job.
Because with most of the people that come in, they never had jobs  before. You know, they’ve just, you know, been on disability. So, you  know, we’ll add additional things, and we have resume specialists here, we  have the job developers.
This is pretty much a company that’s dealing with people with  disability. So in order for you to qualify for the Ticket to Work program,  you have to be getting SSI and SSD. So.
GAO INVESTIGATOR: Mmm. Okay. And how much do you all  charge for these services?
EN REPRESENTATIVE: This is free. This is free. This is funded by  the government, so everything is free. So what he would—oh, okay. Hello?
GAO INVESTIGATOR: Yeah. You’re saying it’s free? I mean, you’re  not, I gotta think, you’re not doing it for free. Do the payments go to you or  something, and then——  EN REPRESENTATIVE: Well, this is a government-funded  program, so I don’t—you, when you come in, you don’t have to pay no fee.  This is not a temp agency where you have to pay a fee.
GAO INVESTIGATOR: Okay.
EN REPRESENTATIVE: So this is a service where it’s funded by  the government, and it’s services of—you know—to the community where  they help people with disability find part-time work. Because if they—if  you get any full-time work, then you know, they’re gonna cut you off. So  we’re not offering you full-time work. We’re helping you find part-time  work.
GAO INVESTIGATOR: Mmm, okay. All right, yeah. Because that  way he avoids getting his payment cut off?
EN REPRESENTATIVE: No, that’s not going to happen. No.
GAO INVESTIGATOR: Okay, okay. Well, that’s good. And, and  what kinds of jobs are you talking about here?
EN REPRESENTATIVE: Well, they have maintenance, um,  janitorial. They have, um, a list of jobs. Um, and like I was, right, like I was  saying you to before, if he worked before, then they can help him on the  jobs that he has on his resume.
GAO INVESTIGATOR: Okay.
EN REPRESENTATIVE: So if he did any kind of security or  maintenance, whatever he would have on his resume, that’s the type of job  that he would—that they would find for him.
And also, he would have to let them know what he’s looking for,  too. Because they’re here to help him—  GAO INVESTIGATOR: Oh, okay.
EN REPRESENTATIVE: So they—he has to give him an idea, or  whoever comes with him would have to give the job developers an idea of  what kind of work he’s looking for.
GAO INVESTIGATOR: Okay. All right. And how does it—how do  we get this started? Does he have to come in there, or can he just—you  know he’s—I’m trying to help him here a little bit, but—  EN REPRESENTATIVE: Yes. Yes.
GAO INVESTIGATOR: What’s next?
EN REPRESENTATIVE: Okay. Yes. He can come in. The days for  that is .
GAO INVESTIGATOR: Okay. And, and what happens at that time?
EN REPRESENTATIVE: When he comes in, he has to bring a  resume if he has one. If he doesn’t, it’s not a problem. His Social and birth  certificate, and that’s it.
GAO INVESTIGATOR: Okay, okay. All right. And um—All right. So  if he gets a job and he’s working and all that, I assume that eventually his  benefits will be cut off?
EN REPRESENTATIVE: No. No. They will not be — because this is the Ticket to Work program, so this is um not like uh real  employment. This is like we said, we deal with people with disability, so  we get them part time work only, that—it would supplement. His benefits  would be supplemented, but it would not get cut off.
GAO INVESTIGATOR: Okay.
EN REPRESENTATIVE: Now, if he’s making enough money, or if  he’s working a full-time job where they’re gonna you know—of course,  they’re gonna say “Okay, well you might not need assistance any more.”  But if it’s, you know, part-time, and it’s not too much money, and th-this is  not full time, then yes, he would qualify.
GAO INVESTIGATOR: Okay. All right. So as long as he doesn’t  make too much money, he won’t get cut off.
EN REPRESENTATIVE: Exactly.
EN REPRESENTATIVE: Do you have the address here?
GAO INVESTIGATOR: Um, no, why don’t you give that to me?
EN REPRESENTATIVE: Let me know when you’re ready.
GAO INVESTIGATOR: Yeah, go ahead.
EN REPRESENTATIVE: Okay. The address is   GAO INVESTIGATOR: ?
GAO INVESTIGATOR: Okay. All right. Good. Well, thank you very  much. You’ve been real helpful.
EN REPRESENTATIVE: You’re very welcome.
GAO INVESTIGATOR: All right. Bye-bye.  (Whereupon, the call was concluded.)
Call 2: Caller is a GAO investigator phoning EN on behalf of his  fictitious brother who is a ticket holder to learn about the Ticket  program and services provided by the EN. The EN representative  describes how the EN assists ticket holders in finding employment  and tells the caller that a DI ticket holder may collect full monthly  benefits indefinitely as long as he remains under the SGA earnings  level.  (Whereupon, an outgoing call was placed by the GAO Investigator  to an EN representative.)  (Phone rings.)
EN REPRESENTATIVE: Ticket to Work,  speaking.
GAO INVESTIGATOR: Yeah, hi. This is ?
EN REPRESENTATIVE: Yeah, absolutely.
GAO INVESTIGATOR: Um, okay. Listen, I’m calling—I got your  number off the EN directory.
EN REPRESENTATIVE: Yeah, okay.
GAO INVESTIGATOR: I’m calling on behalf of my brother.
EN REPRESENTATIVE: Okay.
GAO INVESTIGATOR: He’s disabled, and it looks like he’s going to  try to get back to work.
EN REPRESENTATIVE: Okay.
GAO INVESTIGATOR: So, um, I’m trying to figure out what you  guys do.
EN REPRESENTATIVE: Um, well, let me ask you. Does he have  any, uh, prior work history?
GAO INVESTIGATOR: Yeah, yeah. He’s got experience working in,  you know, office-type work.
EN REPRESENTATIVE: Oh, really?
GAO INVESTIGATOR: Administrative type stuff. Uh-huh.
EN REPRESENTATIVE: When’s the last time that he worked?
GAO INVESTIGATOR: It’s been like a year and a half, or so.
EN REPRESENTATIVE: Yeah, that’s not a problem. Um.
GAO INVESTIGATOR: What kind of jobs—do you have those kind  of jobs?
EN REPRESENTATIVE: Well, we don’t have a magic hat, you  know? What we’re going to do—our position here is to, you know, work  with our clients in—on a partner arrangement, to where we assist them,  uh, in giving them job leads and helping them through the application  process, and uh, help them through—you know—with interviewing, uh,  tools and skills if they require that.
Um, but we don’t—we’re not in a position where we simply go out  and just get jobs for people. We don’t find that, uh, that it has a very high  success rate, uh, simply because, um, because the individual that’s getting  the job, they’re the one that has to perform.
And they have to follow through.
GAO INVESTIGATOR: Okay.
EN REPRESENTATIVE: Well, what I will do is, we sign people on,  and what I do is I go through and I create resumes for them, or update  their current—or older resumes, help try to fill those gaps that are missing,  so that they’re—they look proper when their employer looks at it.
I help my clients do cover sheets to send out along with their  resumes for, you know, job applications, and, uh, basically try to—and  then I send them job leads all the time on an ongoing basis. So that’s one  that’s really important, but it’s also important that the client does it as  well.
GAO INVESTIGATOR: Okay, right.
EN REPRESENTATIVE: So it’s a partnership. I mean I need to see  that the person is working with me, so that I know that, you know, my  time that I’m investing in them, it’s gonna pay off, not so much for me, but  for them in the end.
Because it takes that individual to stay employed. I can’t, you  know, call them every morning and tell them to get up and go to work. And  so they have to have initiative on their own.
And that’s how I really determine, really how much effort that I’m  putting into each client, is whether they’re participating on their end as  well.
GAO INVESTIGATOR: Okay, well, he’s not lazy. He just was not  physically able to—you know, he’s got a heart condition. That’s what the  problem was.
EN REPRESENTATIVE: Oh, I see. He was not physically able to do  what?
GAO INVESTIGATOR: Well, it was kind of just stressful for him,  you know? I mean, you know, he gets—he just can’t take a lot of stress,  basically.
EN REPRESENTATIVE: Uh-huh. So as far as looking for jobs, or as  far as maintaining jobs?
GAO INVESTIGATOR: Yeah, probably maintaining jobs.
EN REPRESENTATIVE: Uh-huh.
GAO INVESTIGATOR: But now what do you all charge for your  services?
EN REPRESENTATIVE: Nothing. It’s free. The services are free, so  long as the individual is eligible for the Ticket to Work program.
GAO INVESTIGATOR: Yeah, he’s got the ticket.
EN REPRESENTATIVE: Yeah, see, so. And if he’s already got, you  know, previous job skills, it’s probably something that we’d be able to help  him with. But he needs to really, you know, determine, you know, to what  degree he’s able to work, or even wants to work. Because with any given  situation, I mean, an employer’s gonna want to see performance, plain and  simple.
GAO INVESTIGATOR: Right.
EN REPRESENTATIVE: And if—and if the individual is not  performing, then it’s likely that they’re going to lose their—that position.
GAO INVESTIGATOR: Right. He doesn’t have to work full time,  though?
EN REPRESENTATIVE: No, not at all. He can work part time. Um,  but those—those jobs are—what—they’re probably more difficult to find,  just because most employers are looking to fill a position, as opposed to  finding two people to fill a position.
GAO INVESTIGATOR: Mmhm.
EN REPRESENTATIVE: But there are part-time jobs out there. I  have a lot of clients that come to me and say “You know what, I don’t think  I can work full time.” And so we just—we hit the dusty trail, and we just  start hammering away, and looking until we find something that actually  suits them.
And the big thing is, really is, you know, what type of work that  they’re looking to do. The clerical work, um, uh, I can find part-time  clerical work, but in most cases it’s going to be in an office environment, a  medical environment, or, uh, like an intake environment, like bringing in  new memberships, like at clubs and stuff.
And so all of those are going to have a certain degree of stress. I  mean, no matter what. Because they’re multitasking. They’re having to  greet people as they’re coming in, they’re having to answer the phone  calls, they’re having to file and input intake information.
So there’s a certain degree of stress with any of them. The ones  that you want to stay away from most certainly are the law firms. The law  firms are just—they’re chaotic. And I’ve had—I’ve placed people in those  jobs before, and uh, and they don’t normally pan out, especially with  people that have, uh, any type of mental disability.
Um, it just gets way overwhelming for them. And it’s not like they  don’t know how to do the work; it just becomes something that’s so  overwhelming that it just becomes a stressful situation.
GAO INVESTIGATOR: Yeah. I mean, it’s not the mental part for  him. It’s more that the stress affects him. You know what I mean?
EN REPRESENTATIVE: Right, yes. So, and it does. Stress affects  us both mentally and physically. And, uh, so what it would be is just a  means of being able to take the time, you know, look around, and  interview jobs as well as they interview you, and find something that, you  know, your brother feels like he would be comfortable dealing.
And then all you can do is try it. And if it feels—if it works, then it  does. And if not, then it doesn’t. And the Ticket to Work program is kind of  designed—what benefit is your brother collecting? SSDI or SSI?
GAO INVESTIGATOR: Disability.
EN REPRESENTATIVE: Oh, Disability. So, so you’ve got all the  perks that go along with the Ticket to Work program. There’s a—you  can—you can earn up to S1,000 a month, and it doesn’t affect your benefit  at all.
GAO INVESTIGATOR: Oh, wow. Okay.
EN REPRESENTATIVE: Yeah, so you can work basically any part- time job that’s being offered, for you know, from 7.50, which is minimum  wage, up to around $10 or $11 an hour working part-time, and you’re not  gonna exceed that.
GAO INVESTIGATOR: And how long—I mean, if he gets a job and  continues to work, I mean will—eventually will he be off of the Ticket to  Work program?
EN REPRESENTATIVE: No, no. It’s an ongoing thing. I mean, he’ll  stay with us until he unassigns his ticket.
GAO INVESTIGATOR: Oh, wow.
EN REPRESENTATIVE: And what it is, basically, is—the Ticket to  Work program is designed—I don’t know if you’re aware of continuing  medical reviews?
GAO INVESTIGATOR: Yeah, right. I mean, periodically—  EN REPRESENTATIVE: Yeah, exactly. And those are one of the  safeguards that—when you’re under the Ticket to Work program, those  are basically put on hold. So they’re not subject to that anymore. And the  service continues.
So say your brother goes to work, and then that particular job  doesn’t work out. Well, then he just calls (name) back up, and says “You  know what, (name)? That one didn’t work out,” for, you know, whatever  reasons. “I decided it just wasn’t a good fit,” or “It became too stressful,”  or whatever. Then we just start again.
GAO INVESTIGATOR: Mmhm. Yeah, but if he gets into a job that  seems to work for him, and it’s not too stressful and—I mean, he can just  continue to do that indefinitely, huh? And still receive the benefits of both  Ticket to Work and—and—disability?
EN REPRESENTATIVE: Exactly. Yeah. It’s a win/win situation.
What it basically is, is the ticket—it’s like, if your brother had no prior  work experience at all, they allow you like a trial work period, where it’s 9  months and you can make as much as you want and it doesn’t affect your  benefit at all.
And then after that, then it starts to affect your SSDI. And if you— and they consider anything over $1,000 a month substantial gainful  activity. And if you were to go over that $1,000 a month, they would take  the cash benefit away from your brother.
And so my job is to—to look at what portions of the program are  still available to your brother. He may have used those trial work months  without ever knowing it. It goes from the date that he’s eligible to receive  the benefit, or the date that he’s receiving the cash benefit. Any month that  he worked over $1,000—or over $720 a month in gross income counts as  one of those trial work months.
And those really aren’t important so much like in your case,  because your brother doesn’t want to go to work full time. So it’s not  gonna be something that’s applied. What’s important for your brother to  know is that right now, as of 2010, he can go out, work any job that he  wants so long as he stays under the $1,000 a month, he gets his cake and  eat it too. He gets the—he gets his wages, and he gets his full SSDI  benefit, and the medical, and everything that goes along with it. And that  can—that can go from today until your brother retires, or whatever. You  know what I mean?
GAO INVESTIGATOR: Mmhm.
EN REPRESENTATIVE: Nothing’s gonna be affected.
GAO INVESTIGATOR: Okay.
EN REPRESENTATIVE: And that’s what most people come to me  for, they—they come to me and say “You know what? I don’t want to lose  my cash benefit. How do I do that?” And—and that’s exactly how you do  that.
SSI’s a lot different than what the SSDI is, but the SSDI has all the  benefits of, you know, being able to work up to that 1,000 a month and not  affect anything.
GAO INVESTIGATOR: All right. So the problem really is, I mean, if  he ended up working full time and making too much money, that’s where  the problem comes in, huh?
EN REPRESENTATIVE: Yeah, exactly. What ends up happening is  that, you know, once he goes over the SGA, then Social Security looks at it  and they go “Oh, hey, look. This guy’s working at—now he’s making $1,500  a month, or $2,000 a month.”
They then look at that, and consider that self-sufficient in the eyes  of the government. And—and then they will eliminate the cash benefit. But  all of his medical and everything stays in place. That—that will continue,  uh, I think it’s like 93 months. It’s like 8 years, I think it is, it continues.
And then at some point that would be affected, but that’s only if  he’s working above the substantial activity, which is over $1,000 a month.
But the—I think most—you know that, to get into this—either  they’re going to go full at it, and they’re fully capable, physically and  mentally, to go back into the work system full time and not worry about  the SSDI, because they can make much more working full time.
Or they have the other disposition, whereas “I don’t think I’m ever  gonna wanna work full time. I just want something to supplement my  benefit.”
GAO INVESTIGATOR: I see. Okay.
EN REPRESENTATIVE: That’s the two sides of the coin. That’s  basically the only two sides that are there. One is you’re either satisfied  supplementing, or you apply yourself to the point where you just simply  get off of it and you’re happy because you’re making—how much is your  brother’s SSDI amount per month?
GAO INVESTIGATOR: Oh, man. I’ve got to check with him. I’m not  even sure.
EN REPRESENTATIVE: Yeah.
GAO INVESTIGATOR: I mean, I’m helping him out, but you know, I  don’t know all his affairs, you know what I mean?
EN REPRESENTATIVE: Right—yeah, yeah. And the thing of that  is, is people that are only getting—if you have—SSDI is based on work  history. So if you’ve got a lot of work history, then it means you paid in a  lot to Social Security, and that’s what dictates what that cash benefit is  from SSDI.
So, you know, I’ve got some people that come to me and they say  “I’m collecting $2,500 a month on SSDI.” And I’m like “Why the Hell would  you want to go to work?”
GAO INVESTIGATOR: Yeah.
EN REPRESENTATIVE: You know what I mean? Those are hard  cases, because I have to go out and find that person a job that makes—that  wants to go to work full time, that makes more than that $2,500 a month.  Otherwise it doesn’t make any sense to get off the benefits.
Just like being on unemployment. If you’re making, you know, you  know, $2,000 a month on unemployment and you can’t find a job—full- time job that pays you more than that, what’s the incentive to get off of it?  Financially, it doesn’t make any sense.
So those that are below, say, $1,000 a month on that SSDI benefit,  if they want to go to work full time it makes sense, because they can make  $3,000 a month or $2,000 a month, and who cares about the 900? You’re  already 1,000 ahead of the game, plus you have your medical.
GAO INVESTIGATOR: Mmhm, mmhm.
EN REPRESENTATIVE: But those that are making you know,  $1,000, maybe $1,500 or so on the cash benefit, and—and they’re not able  to work full time, then it benefits them just to work part time and  supplement that SSDI, and be happy with that.
But then that’s $1,000 a month, or $800 a month, or whatever, in  your pocket every month, and not have it affect your benefit, you know?
GAO INVESTIGATOR: Mmhm, mmhm. All right. Well, sounds good.
So the next thing for him to do for you all would be what?
EN REPRESENTATIVE: Um, uh. What I would want to see is really  a detailed picture of what his past work history was. And, uh, what  positions that he held, and for the lengths of time that he held.
GAO INVESTIGATOR: Uh-huh.
EN REPRESENTATIVE: And then to find out what his cash benefit  is, so that we know what we’re working with.
Um, and if he’s interested in putting himself back to work part  time, then I can take that—most of that information I can get over the  phone, um, and kind of—kind of put together a little picture for myself  of—of, you know, where your brother is on his benefit, and what his past  work history and stuff is.
Then I can call and find out whether his ticket’s available for  assignment, which I’m sure it is. Has he gone to any DVRs [state vocational  rehabilitation agencies], or any other employment networks at this point?
GAO INVESTIGATOR: No—no.
EN REPRESENTATIVE: Yeah. And how long has he been on the  cash benefit, receiving the SSDI?
GAO INVESTIGATOR: Um, it’s been maybe a couple years, maybe.
EN REPRESENTATIVE: Yeah, okay.
GAO INVESTIGATOR: Somewhere in that neighborhood.
EN REPRESENTATIVE: Yeah. And then if he’s really interested in,  you know, going out and finding himself a job, then, you know, I can  schedule an appointment. He can come in, we can fill out the paperwork.  There’s only a few forms to fill out. Um, and then we can go ahead and  start with preparing, you know, resumes and start the job searching  process.
And it’s basically just an ongoing thing. Every single day, I have a  list of clients that are looking for employment. I go through probably 50 or  so job sites that are offering employment, and try to match people up.
And at the same time, they’re looking also, you know what I mean?
To see what’s out there. And I suggest that they do, just because I have  people come to me and go “I want a job in data entry.” And I go, “All right,  but do you know how many of those jobs are out there and what they’re  looking for to fill those positions?”
And if they don’t, then they get restless with me, and they go “Hey,  how hard can it be?” Well, it’s not hard. There’s thousands of data-entry  jobs out there. But each one of those data-entry jobs are looking for  specific skills that they want to fill.
And some of my clients that want to do that, they want to be in a  situation where they’re not pressured, where they’re not dealing with the  public so much. Um, but those types of companies are like coding  companies, and—like medical coding and billing companies. That’s data  entry. Well, you need to be certified to do that.
GAO INVESTIGATOR: Gotcha. Well, listen. Let me—let me have  him give you a call.
EN REPRESENTATIVE: That would be perfect.
GAO INVESTIGATOR: I was just trying to kind of, you know,  screen through some of these, because there’s—  EN REPRESENTATIVE: Exactly.
GAO INVESTIGATOR: —got just a bunch of numbers off the  directory. All right. Well, thanks very much. I appreciate it.
EN REPRESENTATIVE: You’re very welcome.
GAO INVESTIGATOR: All right. Bye.
EN REPRESENTATIVE: Bye.  (Whereupon, the call was concluded.)  (Whereupon, an outgoing call was placed by the GAO Investigator to an  EN representative.)  (Phone rings.)
EN RECORDING: You have reached .  is a  non-profit organization authorized to work with Social Security  beneficiaries under the Ticket to Work program. Our costs are covered by  government funds. No fees are charged to individuals with disabilities.  Please listen to all of our menu options, and then press the designated key.  For information on the types of home-based jobs available through [EN  name], press one. For information on how you can work part-time and  continue to collect Social Security disability benefits, press two.
For information on the qualifications needed in order to hold an   home-based job, press three. For information on the  equipment you will need to work from home, press four. For information  on how you can obtain training and equipment from your state vocational  rehabilitation agency if you do not have the required skills or equipment,  press five. For information on how to apply to  for a home- based position, press six.  (Call redirected after pressing 2.)
EN RECORDING: About 70 percent of the home agents working  through  receive Social Security benefits. Most receive SSDI,  which means they are allowed to earn up to $900 per month if they have a  general disability and $1,500 per month if they are blind. As long as SSDI  recipients remain under those earning limits and their disability does not  improve, they can work part-time and continue to collect their full  monthly SSDI check indefinitely.
For those receiving SSI, the rules are different. Those on SSI will  lose approximately 50 cents of their SSI check for every dollar earned  from a job.
More details are available on our Web site, . I’ll  spell that.  To return to the main menu, press zero.  (Call redirected.)
EN RECORDING: You have reached   (Call redirected.)
EN RECORDING: To apply for ’s home-based jobs,  you must go to our Web site, which is . I’ll spell that.   And complete an online application.
If you do not currently have a computer or Internet access, go to  your local library or use a friend’s system to apply. If you are given a job  offer, chances are very good that your state VR agency will provide you  with the tools you need to perform the work.
Again, the Web site for  is . To  return to the main menu, press zero. (Whereupon, the call was concluded.)
section_title: Appendix VIII: List of Employment Networks Interviewed For This Review
paragraphs: AATakeCharge Milestone, LLC  Adelante Development Center, Inc.  American Rehabilitation Corporation  ARG, LLC  Arizona Bridge to Independent Living  Asian Rehabilitation Service, Inc.  Bureau of Rehabilitation Services, Connecticut Department of Social  Services  Bureau of Vocational Rehabilitation, Division of Career Technology and  Adult Learning, New Hampshire Department of Education  Cerebral Palsy Research Foundation of Kansas, Inc.  Diagnostic Enterprises, Inc.  disABLEd WORKERS, LLC  Division of Vocational Rehabilitation, Vermont Agency of Human Services  Employment Options  Louisiana Rehabilitation Services, Louisiana Workforce Development,  Louisiana Workforce Commission  National Telecommuting Institute, Inc.  Oklahoma Department of Rehabilitation Services  Relational DataSearch  Rewards for Working, Inc.  Service First of Northern California  TakeCharge Vocational Rehabilitation Services, LLC (AAA)  The Workplace CA  Ticket to Work Services, LLC  Tulare County Office of Education  Vocational Rehabilitation Services, Bureau of Rehabilitation Services,  State of Indiana  Walgreen Co.
section_title: Appendix IX: Comments from the Social Security Administration
section_title: Appendix X: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: Jeremy Cox, Assistant Director, and Cady S. Panetta, Analyst-in-Charge,  managed this report and Kristen Jones made significant contributions to  all aspects of the report. Other staff who made key contributions to the  report include Wesley Sholtes and Margeaux Randolph. Luann Moy and  Vanessa Taylor assisted with the methodology and data analysis. Craig  Winslow provided legal assistance. Paul Desaulniers provided  investigative assistance. Susan Aschoff and James Bennett helped prepare  the final report and the graphics.