Supplemental Security Income: SSA Could Strengthen Its Efforts to Encourage Employment for Transition-Age Youth
Released: 2017-05-17T00:00:00


Highlights: section_title: Why GAO Did This Study
paragraphs: The number of individuals with disabilities under age 18 receiving SSI benefits increased by about 44 percent from 2000 through 2016. Youth ages 14 to 17 with disabilities face many challenges achieving self-sufficiency as they transition to adulthood. GAO was asked to examine SSA's efforts to encourage employment for these transition-age youth.

This report examines 1) SSA efforts to encourage employment for transition-age youth on SSI as they move toward adulthood and their effectiveness; and 2) the extent to which SSA helps ensure these youth receive vocational rehabilitation services. GAO analyzed SSA data on work incentives for calendar years 2012-2015, the most recent available, and data from five state VR agencies for calendar year 2015; reviewed relevant laws, policies, and research; and interviewed SSA staff and state VR officials in several states chosen for their SSI youth populations and VR outcomes.

section_title: What GAO Found
paragraphs: The Social Security Administration's (SSA) primary approach for encouraging employment for transition-age youth (ages 14 to 17) with disabilities who receive Supplemental Security Income (SSI) is work incentives that allow them to keep at least some of their SSI benefits and Medicaid coverage while they work. But few transition-age youth benefit from these incentives. SSI is a means-tested program that provides cash benefits to eligible low-income aged, blind, and disabled individuals. SSA administers several work incentives that allow SSI recipients to exclude some income and expenses when calculating SSI benefits. The work incentive targeted specifically to younger SSI recipients is the Student Earned Income Exclusion (SEIE), which allows income to be excluded from benefits calculations if a recipient is a student under age 22. However, less than 1.5 percent of all transition-age youth—and generally less than half of those with earnings—benefited from SEIE in 2012 through 2015. SSA does not analyze these data, and thus cannot determine why the majority of youth with earnings are not benefiting from SEIE, when they may be eligible. SSA data also show that almost no youth benefited from other incentives that allow them to exclude earnings used for specific purposes, such as the Impairment-Related Work Expenses incentive. The effectiveness of SSA-administered work incentives may be further limited because, according to SSA and other officials, youth and their families are often unaware of or do not understand them, and may fear that work will negatively affect their benefits or eligibility. SSA policy requires staff to provide accurate and meaningful information about relevant SSI policies to claimants and recipients. However, GAO found that SSA does not have sufficient procedures in place to ensure that information on work incentives and how work affects benefits and eligibility is consistently communicated to youth and their families. As a result, SSA may miss opportunities to promote work incentives and other supports, allay fears, and potentially reduce dependence of transition-age youth on SSI benefits.

SSA does not have a systematic way to connect transition-age youth on SSI to state Vocational Rehabilitation (VR) agencies that provide training and employment services under the VR State Grants program administered by the Department of Education (Education). Although youth receiving SSI are generally presumed to be eligible for VR services, GAO found that less than 1 percent had an open VR service record in 2015 in four of the five states from which GAO collected VR data. Legislation in 1999 created the Ticket to Work and Self-Sufficiency program, which expanded the number and types of employment service providers for individuals with disabilities. However, SSA limited eligibility to recipients age 18 and older. While transition-age youth receiving special education services can be connected to VR agencies through their schools, the extent to which this happens—and whether they are on SSI—is unknown because data to make such determinations are not systematically collected by SSA or schools. Federal standards for internal control call for agencies to use quality information to achieve their objectives. Without relevant data or additional options for connecting youth to VR services, SSA cannot ensure that transition-age youth on SSI are being connected to these services, which can help to prepare them for adulthood and the workforce.

section_title: What GAO Recommends
paragraphs: GAO recommends SSA 1) analyze why youth on SSI with earnings did not benefit from SEIE, 2) improve communication about work incentives and rules, 3) work with Education to determine how many youth on SSI are not connected to VR services, and 4) explore options to further connect them. SSA agreed in whole or in part with three recommendations. SSA disagreed that its communication on work incentives and rules needs to be improved, stating field staff provides information to youth, and it has created new written material. GAO maintains SSA's communication could be improved as presented in this report.

section_title: Letter
paragraphs: The Supplemental Security Income (SSI) program provides cash  payments to eligible low-income individuals with disabilities, including  children and teenagers. In December 2016, the Social Security  Administration (SSA) paid SSI benefits to over 1.2 million recipients under  age 18, and their numbers increased by about 44 percent from December  2000 through December 2016.

Transition-age youth (those ages 14 to 17) who receive SSI benefits face  numerous challenges achieving self-sufficiency as they move into  adulthood. We previously reported that transition-age youth with  disabilities typically leave an environment in which they receive most of  their services as entitlements through their schools to one in which  services can be more difficult to access. Furthermore, according to SSA  officials and staff, as well as others, these youth may face real or  perceived disincentives to employment such as fear of losing SSI or  health care benefits.

Outcomes associated with the ability of youth receiving SSI to achieve  self-sufficiency as they transition to adulthood are poor across several  measures. Specifically, these individuals have low employment rates as  well as high dropout and arrest rates, when compared to other youth.  Encouraging youth on SSI to prepare for their future as adults, including  thinking about employment, is important because research has found that  of all SSI recipients found ineligible for benefits after age 18—the age at  which SSA is generally required to assess recipients against adult criteria  for the program—about 40 percent are unemployed at age 19, and only  about a quarter earned enough to replace their lost SSI benefits. Further,  research suggests that individuals who begin receiving SSI prior to age  18 accumulate over 25 years of benefits on average.

Both SSA and the Department of Education (Education) play a role in  helping transition-age youth prepare for employment or postsecondary  education while in school. In particular, youth receiving SSI who are  students may be eligible for work incentives administered by SSA that  allow them to keep some or all of their benefits even if employed. In  addition, many of these youth will likely receive transition services through  their schools and are generally presumed eligible for services provided by  state vocational rehabilitation (VR) agencies under the VR State Grants  program administered by Education. Given the low employment rates of  these youth, we were asked to examine SSA’s efforts to encourage  employment for transition-age youth on SSI.

This report examines: (1) how SSA encourages employment for  transition-age youth on SSI as they move toward adulthood, and the  effectiveness of these efforts, and (2) the extent to which SSA helps  ensure that transition-age youth on SSI receive vocational rehabilitation  services.

To address these objectives, we reviewed relevant federal laws,  regulations, and policies on SSA-administered work incentives and  supports that are relevant to transition-age youth on SSI, as well as  federal laws related to vocational rehabilitation (VR) services provided by  state agencies and transition services provided by schools. To identify  SSA’s approaches for encouraging work among transition-age youth and  to assess their effectiveness, we reviewed SSA documents and  interviewed SSA officials. We reviewed SSA data on the number of  youth ages 14 to 17 using work incentives. Specifically, we analyzed data  on the work incentive targeted to youth, the Student Earned Income  Exclusion (SEIE), which allows an SSI recipient who is a student to earn  additional income before his or her benefits are reduced, as well as other  SSA-administered work incentives. We analyzed data for 2012 through  2015, the most recent data available.

In addition, to further understand SSA’s approaches and the effectiveness  of work incentives available to transition-age youth, we conducted a  broad literature search and review on research or studies pertaining to  SSA work incentives and demonstration projects that pertain to transition- age youth and reviewed information provided to youth and their families  by SSA in-person and by mail. To inform both of our objectives, we visited  two states—Florida and New York—where we interviewed local SSA field  office technical or supervisory staff, school district personnel, Work  Incentives Planning and Assistance (WIPA) project staff, and other  stakeholders. We selected these states because we wanted to obtain  information from officials in a state that was participating in the ongoing  Education-led Promoting the Readiness of Minors in Supplemental  Security Income (PROMISE) initiative (New York) and in a state of similar  size that is not participating in the initiative (Florida). We also  interviewed SSA staff in a field office in California to gather additional  information. All three states are among the states with the largest  populations of SSI recipients and transition-age youth on SSI. To  understand SSA’s efforts to help ensure youth are connected to VR  services, we interviewed and obtained information from cognizant SSA  and Education officials and state VR agency staff in five states—Florida,  New Mexico, New York, Oklahoma, and Washington—selected based on  variation in the size of the youth population served, employment  outcomes, and geographic diversity. We also analyzed data from these  VR agencies on the number of youth on SSI they served. We assessed  the reliability of data we received from SSA, Education, and state VR  agencies by interviewing knowledgeable officials and reviewing relevant  documentation and found them to be sufficiently reliable for the purposes  of our reporting objectives. (See app. I for more information on our scope  and methodology).

We conducted this performance audit from February 2016 to May 2017 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: SSA administers the SSI program, one of the largest federal programs  providing assistance to people with disabilities. The SSI program was  established in 1972 under Title XVI of the Social Security Act. The  program provides cash benefits to low-income individuals, including  children and youth, who meet financial eligibility requirements and who  are blind or have disabilities. In December 2016, SSA paid SSI benefits to  over 8.25 million individuals, including more than 1.2 million under age  18. In calendar year 2015, SSA paid almost $55 billion in SSI benefits.  The average monthly payment in December 2016 was $542; however,  the average payment for recipients under 18 was higher ($650).  According to SSA, in many states, eligibility for SSI also confers eligibility  for Medicaid benefits.
subsections: section_title: SSI Eligibility, Continuing Disability Reviews, and Redeterminations
paragraphs: To be eligible for SSI on the basis of disability, an individual must meet  both financial and medical requirements. To determine eligibility, SSA  staff, located in more than 1,200 field offices across the country, review  SSI applications and verify financial eligibility. Following SSA’s initial  review, state disability determination services (DDS) offices assess  applicants’ medical eligibility for SSI. SSI has two sets of medical  eligibility requirements to determine disability; one for adults (individuals  age 18 and older) and one for individuals under 18. To be considered  disabled, individuals under age 18 must have a medically determinable  physical or mental impairment (or combination of impairments) that  causes marked and severe functional limitations and that has lasted or is  expected to last for a continuous period of at least 12 months or result in  death. For adults to be considered disabled, they must have a medically  determinable physical or mental impairment (or combination of  impairments) that prevents them from doing any substantial gainful  activity (SGA), and that has lasted or is expected to last for a continuous  period of at least 12 months or result in death.

SSI recipients, including those under age 18, undergo periodic continuing  disability reviews (CDR) to ensure they continue to meet medical eligibility  criteria. When a DDS first finds an individual medically eligible for SSI, it  also assesses the likelihood that his or her disability will improve and,  depending on that likelihood, develops a schedule for future CDRs. For  SSI recipients under age 18 whose impairment is considered likely to  improve, federal law requires SSA to conduct a CDR at least once every  3 years. Under SSA policy, in cases in which medical improvement is  not expected, a CDR is scheduled once every 5 to 7 years. During  these CDRs, DDS collects evidence such as medical and educational  records to determine whether the individual continues to meet medical  eligibility criteria based on their disability. In addition, SSA also  periodically conducts redeterminations on a sample of SSI case files to  determine whether individuals continue to meet financial eligibility  requirements. All SSI recipients are required to report certain information  to SSA to help ensure that they continue to receive the correct benefit  amounts. For example, SSI recipients must notify SSA when their  earnings change and this reported information, in turn, may trigger a  redetermination.

Federal law also requires that SSI recipients undergo a redetermination at  age 18 to evaluate whether they meet adult (rather than youth) medical  eligibility criteria. At the same time, SSA assesses whether the recipient  continues to meet nonmedical (financial) eligibility requirements. This  redetermination generally occurs within the year after a youth turns 18. If  SSA determines a recipient does not meet adult eligibility criteria, he or  she receives an unfavorable redetermination and ceases to receive SSI  benefits. SSA reported that in fiscal year 2015, almost 57 percent of age  18 redeterminations resulted in an initial unfavorable determination by DDS; however, approximately half of those decisions were appealed, so  the final percent with unfavorable redeterminations is likely lower.

section_title: Vocational Rehabilitation
paragraphs: Education’s VR State Grants program, authorized under the  Rehabilitation Act of 1973, as amended, assists individuals with  disabilities, including transition-age youth who may also be receiving SSI,  find and keep employment, among other things. This program,  administered by Education’s Rehabilitation Services Administration (RSA)  within the Office of Special Education and Rehabilitative Services, is the  largest program authorized under this Act and provided approximately  $3.1 billion in formula grants to state VR agencies in fiscal year 2016. The  grants support a wide range of services, individualized based upon the  needs of the eligible individual with a disability, including: assessments;  counseling, guidance, referrals, and job placements; vocational and other  training; transportation; and, in certain circumstances, postsecondary  education and training. Individuals must apply and be determined  eligible by the state VR agency to receive individualized VR services. If  VR agencies lack the financial and staff resources to serve all eligible  individuals in the state, they are generally required to prioritize individuals  with the most significant disabilities. Individuals receiving disability  benefits, including transition-age youth on SSI, are generally presumed  eligible for VR services and considered individuals with a significant  disability. However, depending on their disability, including level of  functional impairment, SSI recipients may not be considered as having a  “most significant” disability by the VR agency; and, if the VR agency has  implemented an order of selection, the individual may be put on a waiting  list to receive services.

In 2014, the Workforce Innovation and Opportunity Act (WIOA) was  enacted, which, among other things, amended the Rehabilitation Act of  1973 and required VR agencies to provide additional services to students  and youth with disabilities. Specifically, WIOA requires that states  reserve at least 15 percent of their state’s allotment of federal VR funds  for the provision of pre-employment transition services to students with  disabilities. To receive pre-employment transition services, a student with  a disability need only be potentially eligible for VR services and does not  have to apply to VR.

section_title: Schools’ Role in Transition Planning for Youth with Disabilities
paragraphs: The Individuals with Disabilities Education Act (IDEA) provides formula  grants to states, which pass them to eligible local education agencies to  assist in providing special education and related services. IDEA generally  requires schools to provide special education and related services to  students with disabilities specified under IDEA. For each student with an  IDEA-specified disability, schools must establish an individualized  education program (IEP) team that generally includes the child’s teacher  and other school and school district personnel, the student’s parents, the  student (as appropriate), and, at the discretion of the parent or public  agency, others with relevant knowledge, including related service  providers. The IEP team is required to develop a written IEP for each  student that includes, among other information, a statement of the  student’s academic achievement and functional performance, measurable  academic and functional goals, and the special education and related  services to be provided. Also under IDEA, beginning with the first IEP to  be in effect when a student turns 16, or earlier if determined appropriate  by the IEP team, and updated annually thereafter, the IEP must include,  among other things, appropriate, measurable postsecondary goals for  training, education, employment, and, where appropriate, independent  living skills, and transition services needed to help the student reach  these goals. Schools may invite representatives from VR agencies to  these transition planning meetings.

Students with disabilities who do not qualify for special education and an  IEP under IDEA may qualify for services under section 504 of the  Rehabilitation Act of 1973, as amended (section 504). Education’s  section 504 regulations require school districts to provide qualified  students regular or special education and related aids and services  designed to meet the educational needs of students with disabilities as  adequately as the needs of students without disabilities are met.  Transition services may be documented in a 504 plan, but they are not a  requirement of such plans.

section_title: SSA’s Efforts to Encourage Employment Reach Few Transition-Age Youth and SSA Does Not Consistently Convey Information About Working
subsections: section_title: SSA Administers Work Incentives, but Few Transition-Age Youth Benefit from Them
paragraphs: SSA’s role in encouraging employment for transition-age youth on SSI as  they move into adulthood is focused on administering work incentives and  other employment supports that allow them to keep at least some of their  benefits even if they have earnings. However, very few youth on SSI  benefit from these supports.

As a provider of means-tested transfer payments, SSA does not provide  direct employment services to SSI recipients, including youth on SSI.  However, for recipients who want to work, the SSI program is designed to  support their efforts and reduce their reliance on benefits, according to  SSA’s Annual Report of the Supplemental Security Income Program.  Federal law provides several work incentives and other employment  supports that help SSI recipients—including youth—to enter, re-enter, or  stay in the workforce. Most transition-age youth are also students, and  the importance of education is emphasized by the primary work incentive  for this population, the Student Earned Income Exclusion (SEIE), which  encourages work, but requires recipients to attend school to be eligible for  the exclusion. SSA also administers other work incentives and  employment supports that are available, but not targeted to transition-age  youth. See table 1 for a list of key work incentives and employment  supports available to this population.

Few transition-age youth on SSI benefit from SEIE—the only SSA- administered work incentive targeted specifically to younger SSI  recipients. SEIE allows SSI recipients under age 22 who also regularly  attend school, college, university, or vocational or technical training to  exclude a portion of their earnings—$1,790 a month, up to $7,200 a year,  in 2017—from their countable income for the purposes of determining SSI  eligibility and benefit amounts. Based on data provided by SSA, we  found that 1.3 percent and 1.4 percent of all transition-age youth (ages 14  to 17) on SSI had income excluded under SEIE in calendar years 2012  and 2013, respectively.

Our analysis of SSA data further suggests the possibility that some youth  who may be eligible may not be benefiting from this SSI provision. SSA  data show that few transition-age youth benefit from SEIE, in part,  because few have earned income. For example, in 2012, 3.3 percent  (15,234 out of 455,363) of transition-age youth reported earned income.  However, our analysis of SSA data found that even among those  transition-age youth with earned income, most often less than half  benefited from SEIE. The percentage of youth with earnings who  benefited from SEIE in 2012 varied by age and month, but ranged from a  low of 28 percent to a high of 53 percent. (See fig. 1.) These  percentages were similar in 2013 through 2015.

Given that SEIE should be applied automatically for all eligible students  who have reported earned income, SSA officials offered the following  possible reasons, other than SSA user or system error, for why youth with  earnings might not have benefited from SEIE: they were not students or  they did not report their student status to SSA. However, previous  research found more than 94 percent of transition-age youth on SSI  reported being enrolled in school. Further, although some youth on SSI  may not report their student status, SSA policy instructs staff to develop  and verify school attendance for youth under 18 who report that they  expect to earn over $65 in a month. SSA also has procedures for  capturing an individual’s student status during his or her initial application  and during a redetermination. Despite these procedures, the fact that  many youth with earnings are not receiving SEIE suggests that SSA may  not be confirming student status or applying SEIE in a timely manner or in  accordance with policy.

SSA officials told us that the agency does not regularly analyze SEIE data  and said they do not believe doing so would help them better understand  SEIE’s effectiveness or reach. However, our recent data request  uncovered potential undercounting of earnings and SEIE use. Federal  standards for internal control state that an agency should identify,  analyze, and respond to risks related to achieving its objectives. Absent  this analysis, SSA cannot know the extent to which various factors may  contribute to the low percentage of transition-age youth with earnings  receiving SEIE, or whether errors made by staff or data system errors are  precluding some SSI recipients from receiving an income exclusion for  which they are eligible.
subsections: section_title: Other Employment Supports
paragraphs: Similarly, the number of transition-age youth on SSI who benefited from  other SSA-administered work incentives and employment supports was  either unknown or low. For example, SSI’s Earned Income Exclusion,  which excludes the first $65 of income earned each month from benefit  calculations and half of earnings after that, is available to the broadest set  of SSI recipients with earnings. However, SSA officials told us that SSA  has not conducted analysis to determine the extent to which transition- age youth on SSI benefit from this incentive. SSA officials told us that  their systems automatically apply this exclusion to any earned income  remaining after the SEIE has been applied and that any individual with  earned income (whether or not the SEIE applies) automatically receives  this exclusion.

SSA data for Impairment-Related Work Expenses (IRWE), Blind Work  Expenses (BWE), and the Plan to Achieve Self-Support (PASS) show low  uptake by transition-age youth on SSI for each of these provisions as  well. For example, SSA data show that no transition-age SSI recipients  benefited from IRWE or BWE and no more than five had a PASS in any  calendar year 2012 through 2015, the most recent data available. SSA  staff at three field offices told us that, in their view, use of PASS by  transition-age youth may be low because it is complex and has many  requirements, including that the recipient develop long-term career  goals.

Another provision of federal law—referred to as the section 301  provision—allows certain individuals to continue receiving SSI benefits  even when SSA determines through an age 18 redetermination or CDR  that they no longer have a medical disability. For example, recipients  may retain their benefits if they are 18 to 21 years old and are receiving  special education and related services through an IEP, or if they have a  PASS, or if they are enrolled in VR or a similar program and meet other  requirements. The possibility of these continued payments underscores  the importance of ensuring transition-age youth are aware of the section  301 provision and of the services that qualify them for it, such as IEPs,  PASS, and VR. In 2015, the most recent year for which data are  available, about 1,200 adults ages 18 and 19 benefited from this  provision. SSA officials told us that this provision has not been widely  used because eligibility through an IEP only applies to individuals ages 18  through 21, and because few youth under 18 were likely served by VR  agencies. However, SSA officials were unable to provide data on the  number of individuals who applied for and ultimately did not benefit  because the agency does not maintain these data in a format that would  allow for this type of analysis.

Lastly, other legal provisions may encourage work by allowing SSI  recipients to maintain SSI benefits or Medicaid even if they earn over  SGA, in certain circumstances, but the number of transition-age youth  who benefit from these provisions is not known. Specifically, SSA does  not analyze data to determine the extent to which transition-age youth  may maintain SSI benefits or Medicaid under these provisions. Because  youth typically do not exceed SGA, the number affected is likely small,  according to SSA officials.

section_title: Demonstration Projects
paragraphs: SSA has been involved in two initiatives to test ways to encourage  employment of transition-age youth. The SSA-sponsored Youth  Transition Demonstration (YTD) did not result in changes to SSA’s work  provisions, according to SSA officials. The Promoting the Readiness of  Minors in Supplemental Security Income (PROMISE) initiative, led by  Education, is ongoing.

SSA’s YTD targeted individuals ages 14 to 25 at six demonstration sites  who received or were likely to receive SSI or Social Security Disability  Insurance (SSDI) benefits. YTD tested the impact of various waivers of  SSA-administered work incentive rules in combination with a range of  strategies and work supports on employment, income, and other  outcomes. According to the YTD final evaluation in 2014, all six site  locations were required to include certain program components, such as  work-based experiences; benefits counseling; family supports, including  transition-related information; and connections to service providers,  including health care and transportation services. The sites had flexibility  in the approaches they used to implement those program components.

The final evaluation showed inconsistent results and SSA was unable to  determine whether waivers contributed to positive outcomes at some  sites. On the positive side, site-specific interim evaluations showed that,  after 1 year, YTD increased participants’ use of benefits and incentive  counseling, and their awareness of at least some work incentives, at all  six sites. YTD also increased participants’ understanding of the effects of  work on SSI benefits, medical coverage, or both, at three sites.  However, the final 2014 YTD evaluation report found mixed results. For  example, two of the six sites showed positive impacts on employment,  two sites showed positive impacts on annual earnings, and two sites  showed positive impacts on participation in productive activities, such as  education, employment, or training. However, none of the sites saw an  improvement in these 14- to 25-year olds’ self-determination and one site  saw an increase in delinquency. Moreover, SSA officials told us that the  final evaluation could not determine the extent to which changes to work  incentives had led to any of the positive effects experienced at some  sites. SSA officials said that because all YTD participants were eligible for  work incentive waivers and other services, isolating the effects of  changes to work incentives from the effects of the other services was not  possible. SSA officials also said they have not made program changes  based on YTD results, but that YTD informed the development of the  PROMISE initiative. Officials said SSA is conducting an internal study of  YTD to assess longer term outcomes, which they hope to complete by the  end of 2017.

SSA is currently a partner in the ongoing PROMISE initiative, which is  being led by Education. Through PROMISE, Education provided funds  to selected states to design and implement demonstration projects to  improve outcomes for youth on SSI and their families. PROMISE targets  transition-age youth who are 14, 15, and 16 years old and receiving SSI  and their families with interventions including vocational rehabilitation,  case management, benefits counseling, financial literacy training, career  and work-based learning experiences, and parent training and  information. SSA provided data on youth receiving SSI to the PROMISE  demonstration projects for enrollment purposes, is funding the PROMISE  research evaluation of the demonstration, and, according to SSA officials,  is providing technical assistance regarding SSA policies to project sites.  SSA does not have a role in direct delivery of services. Education  awarded six 5-year PROMISE grants in 2013, with most projects  beginning services within the first year. An interim impact report is  scheduled for release in summer 2018, and a long-term evaluation is  scheduled for winter 2022. During our New York site visit, we spoke with  staff from organizations providing services under the PROMISE initiative  who told us that, although they did not yet have outcome data, their early  observations suggest positive effects, such as that youth are engaged,  families are interested in having their children work and in receiving  services to encourage work, and PROMISE is creating a more  collaborative environment among service providers, VR, and schools.

section_title: SSA Misses Opportunities to Convey Information to Encourage Work and Allay Fears that Work May Result in Loss of Benefits
paragraphs: According to SSA officials, VR staff, and other stakeholders with whom  we spoke, transition-age youth and their families are often unaware of or  do not understand SSA-administered work incentives and supports, and  may fear that working will negatively affect their SSI or Medicaid  benefits. Although we were unable to identify recent research or data  corroborating these perspectives, a 2007 study using data collected in  2001 and 2002, found that only 22 percent SSI recipients ages 14 to 17  knew about the work incentives or discussed them with an SSA  representative. Experts believe this lack of knowledge and associated  concerns about the effect of work on benefits may reduce work attempts  by transition-age youth. For example, in a planning report for YTD, the  research organization Mathematica stated that “lack of knowledge about  how work experiences, benefits, and SSA incentives interact leads to low  utilization of the incentives among beneficiaries.” Similarly, staff in SSA  field offices and state VR agencies, researchers, and others we spoke to  said fear of losing health care or SSI benefits creates a barrier to  employment for transition-age youth and some said that families may not  encourage youth on SSI to work because of these fears. SSA officials  also said that some families believe they are helping their children by  preventing them from working because it will enable them to keep  benefits longer or reduce the chance of an unfavorable age 18  redetermination.

Despite such gaps in knowledge or understanding of work incentives and  the age 18 redetermination process among youth on SSI and their  families, and contrary to general SSA policy, SSA staff may not be  systematically conveying information about these topics during CDRs and  other interviews. SSA policy states that interviewers are responsible for  providing accurate and meaningful information about the SSI program,  and for making the process of applying for and maintaining eligibility as  understandable and uncomplicated as possible. SSA policy also states  that recipients may not know the right questions to ask to obtain the  information they need to make informed decisions. SSA officials we  interviewed said, consistent with SSA policy, field staff collecting  information during a CDR, financial eligibility redetermination, or age 18  redetermination, would discuss work incentives with recipients. However,  SSA field office staff we interviewed did not confirm such information  sharing consistently occurs in SSA field offices. Staff said such  conversations may not occur for a variety of reasons. For example, they  said youth and their families do not generally seek out information on  work incentives, and staff may not have time for such discussions or be  experts on work incentives.

SSA may also be missing opportunities to allay certain fears about how  work might affect age 18 redeterminations. SSA policy indicates, and  officials from the Office of Disability Determinations (ODD) confirmed, that  although information on work history is collected and may be considered  when determining whether a person meets medical criteria, it only  influences financial eligibility when specific conditions are met. According  to SSA officials, earnings are only considered when determining capacity  to work if an individual has worked at or above SGA for a period long  enough to gain work skills necessary for the job, and that such instances  are rare. SSA officials told us that virtually all unfavorable age 18  redeterminations result from a medical evaluation, not work history. The  medical evaluation takes into account the medical evidence and, if  needed, the physical and mental functional capacity of the individual. SSA  officials could not provide specific data on the relationship of prior work to  redetermination outcomes. However, they said few youth undergoing an  age 18 redetermination have a work history, and among those who do, a  very small number have worked sufficiently above SGA to result in an  unfavorable redetermination on that basis. At the same time, SSA’s  policies do not instruct staff to consistently convey information explaining  how work may or may not affect the age 18 redetermination when  speaking with youth and their families. Federal standards for internal  control state that an agency should communicate the information  necessary to achieve its objectives. Without standard procedures and  language to guide SSA representatives and ensure they regularly and  consistently discuss how work incentives can allow transition-age youth  on SSI to work without jeopardizing their benefits, SSA may miss  opportunities to allay misplaced fears, encourage work, and potentially  reduce future dependence on benefits.

As part of its effort to increase awareness and understanding of work  incentives and supports available to SSI recipients, SSA funds Work  Incentives Planning and Assistance (WIPA) projects in every state, and  relies on the projects to provide benefits information and counseling to  transition-age youth. The projects typically provide general information  on benefits or work supports and referrals to additional services, as  needed, and individualized counseling on benefits and related services.  WIPA projects are supposed to conduct outreach and provide information  to disabled individuals, including transition-age youth, including advising  them of work incentives available to them. However, the WIPA projects’  reach is limited. According to data from SSA’s contracted technical  assistance provider for WIPA projects, WIPA projects served just 345  youth ages 14 to 17 on SSI between July 2013 and June 2016. While  staff at one of the two WIPA project locations we visited said that they  work with youth under age 18 to the extent possible, they said schools  typically assist this age group rather than WIPA projects. At the other  location, WIPA project staff told us that most of their clients are adults  because beneficiaries typically do not seek services until they are  working. WIPA project staff said funding constraints limit their ability to  serve everyone and to conduct outreach. When the WIPA program was  established in 1999, the law put a limit of $23 million on the amount of  grants, cooperative agreements, and contracts that can be awarded each  fiscal year under this program, and the limit has not changed since then.

More recently, SSA has taken additional steps to provide written  information about work incentives and supports to transition-age youth on  SSI and their families by developing a new brochure; however, this  brochure—while helpful for some—may not be sufficient to allay fear of  work affecting benefits. SSA officials told us that lessons learned from  YTD influenced the agency’s development of the brochure to inform  youth, their families, and service providers about the age 18  redetermination process and available resources. While the new brochure  is a positive step, it does not contain key information that could help  alleviate fear that work will mean losing benefits, such as how work is  considered during the age 18 redetermination process or the  circumstances under which youth can work and maintain Medicaid  coverage. In addition, some stakeholders, including WIPA project and VR staff, told us that written material, such as a brochure, may not be  sufficient to convey complex information on work incentives and how  working affects benefits. For example, although SSA officials said one  purpose of the brochure is to increase awareness of available resources,  staff from WIPA’s technical assistance provider told us in December 2016  that they did not believe the brochure, mailed in August 2016, had led to  an increase in youth seeking WIPA project services. Federal standards  for internal control state that an agency should communicate quality  information needed to achieve its objectives with external parties, and  that this information should be communicated using appropriate methods  that consider factors including the intended audience and the nature of  the information, among others. For example, results from YTD suggest  that increased benefits counseling was associated with increased  awareness of work incentives.

section_title: SSA Does Not Have a Systematic Way to Connect Transition- Age Youth on SSI to Vocational Rehabilitation Services and Data Sharing is Limited
subsections: section_title: SSA Does Not Have a Systematic Way to Connect Transition-Age Youth to Vocational Rehabilitation Services
paragraphs: Having access to individualized training and employment services  provided by VR agencies helps transition-age youth on SSI develop the  skills they need to transition to adulthood and the workforce. However,  SSA does not have a systematic way to connect these youth to state VR  agencies that provide employment-oriented and other services to  individuals with disabilities. To achieve successful transition to adulthood,  it is important that transition-age youth with disabilities receive transition  planning and employment-related services that help them prepare for and  engage in gainful employment to the extent of their capabilities. Such  services are provided by state VR agencies under the VR State Grants  program, which is administered by Education’s Rehabilitation Services  Administration, and may include individualized: assessments; counseling,  guidance, referrals, and job placements; vocational and other training;  transportation; and, in certain circumstances, postsecondary education  and training. Participation in VR also may allow transition-age youth who  would otherwise lose SSI benefits due to an unfavorable CDR or age 18  redetermination to continue receiving SSI payments. Despite the  advantages of participating in VR programs, our review of data from five  state VR agencies found few transition-age youth (ages 14 to 17)  receiving SSI who had open VR service records in calendar year 2015.  Specifically, in four of the five states, the percentage of transition-age  youth ages 14 to 17 on SSI with open VR service records was less than 1  percent. In the fifth state, approximately 3 percent of such youth had an  open VR service record.

Although there may be many reasons for low VR participation by  transition-age SSI recipients at the five state VR agencies we spoke with,  SSA’s stated inability to directly refer these youth to VR agencies does  not help to improve participation rates. Prior to the enactment of the  Ticket to Work and Work Incentives Improvement Act of 1999, SSA was  required to consider each claimant’s need for vocational rehabilitation and  refer SSI recipients ages 16-64 to state VR agencies. While the  enactment of this Act expanded the pool of employment service providers  available to recipients of SSI and other disability benefits, SSA limited the  Ticket to Work and Self-Sufficiency (Ticket to Work) program to adults.  In addition, the Act removed the language that had required SSA to make  direct referrals of benefit recipients to VR providers. SSA has interpreted  this legal change as “eliminat SSA’s authority to refer  recipients  for vocational rehabilitation (VR) services” in states in which the Ticket to  Work program has been implemented. Because the Ticket to Work  program has been implemented in all states, it is SSA’s view that it is  prohibited from directly referring adults and youth on SSI to VR services.

Because SSA states that it can no longer makes direct referrals to VR  agencies for services and the Ticket to Work program only supports  adults, SSA lacks a mechanism to help connect youth on SSI to VR  services. In contrast, the Ticket to Work program provides SSA a well- developed structure to connect SSI recipients age 18 and older to VR  agencies or other employment networks. Specifically, SSI recipients  ages 18 to 64 are issued a ticket that can be used to obtain vocational  rehabilitation, employment, or other support services from a state VR  agency or an approved employment network of their choice. SSA has a  Helpline number for the Ticket to Work program, and the program has its  own website containing information on its benefits and how to access VR  agencies and other service providers. Since SSI recipients under age 18  are not eligible for tickets, SSA has no structure in place to ensure  transition-age youth are made aware of and encouraged to take  advantage of available employment programs that can help reduce their  reliance on benefits as they transition into adulthood.

In February 2016, SSA issued an advanced notice of proposed  rulemaking in which it solicited public input on how to improve the Ticket  to Work program, including how the program could encourage youth to  pursue work-related opportunities. SSA officials said that they have no  timeline for further actions related to this notice at this time. In addition, an  SSA official said they are in the early stages of considering a new  initiative under SSA’s demonstration authority that would test whether  having a state DDS make direct referrals of age 18 redetermination cases  to VR agencies would result in increased VR services, increased  employment outcomes, and reduced dependency on SSI. This initiative  would involve the DDS and VR agencies located in one state. The SSA  official said they are still working out the details, but said that if the project  is feasible it would ideally begin sometime in 2017 and last at least 1 to 2  years.

Without direct referrals from SSA and access to the Ticket to Work  program, the primary way that youth on SSI are connected to VR is  through their schools. While referrals to VR agencies can come from  other sources, national Education data show elementary and secondary  schools are the primary source of referrals for transition-age youth (see  fig. 2). Specifically, for transition-age youth with VR service records that  were closed in fiscal year 2015, over 80 percent had been referred to VR  agencies by elementary and secondary schools.

Students with disabilities can be connected to VR agencies through  transition services provided by their schools as required under IDEA.  IDEA requires states and school districts to identify, locate, and evaluate  children suspected of having a disability, as defined in IDEA, and who are  in need of special education and related services. For students age 16, or  younger if determined appropriate by the IEP team, schools must develop  and implement an IEP that incorporates postsecondary goals and  provides access to appropriate transition services. The transition planning  process develops a student’s postsecondary goals for training, education,  and employment, among other things. Although IDEA does not  specifically require school districts to include VR agencies in transition  planning, Education’s regulations require school districts to invite a  representative from a VR agency or from other agencies likely to be  providing transition services to a student’s IEP team meetings, when  appropriate, and with the prior consent of the parents or student who has  reached the age of majority. According to Education guidance, VR  agency involvement during the transition planning phase of an IEP helps  provide a bridge to VR services for eligible students preparing for life after  school.

Rehabilitation Services Administration officials and a few VR agencies  told us that staff from VR agencies are invited to transition planning  meetings by schools, but due to capacity constraints, these staff may not  attend all such meetings. Furthermore, the relationship between VR  agencies and schools and school districts varies, based on interviews we  had with school and school district officials in the two states we visited.  For example, school officials in two districts said that the VR agency staff  are more involved and meet with students weekly, and as a result,  students with IEPs are more likely to be connected to VR services. Some  officials in the other school districts we visited described the relationship  more as a “hand-off” of the student from the school to the VR agency. For  example, VR agency staff would typically meet with students approaching  graduation. Regardless of the relationship, a student makes the choice to  apply or not to apply for VR services.

While VR and SSA officials we interviewed said that most students on  SSI have IEPs, and that their IEPs can help connect them to VR services,  we found that neither schools nor SSA collect or analyze data that would  allow them to determine the extent to which youth on SSI do, in fact, have  IEPs that would help them connect with VR services. Although schools document information on students with IEPs, school officials told us they  do not collect information on whether students are receiving SSI benefits,  and they have no systematic way to obtain this information. SSA  maintains data on whether a student is receiving SSI and collects  information on whether a recipient is receiving special education, or has  an IEP, in certain cases. However, SSA officials said they do not  analyze these data to determine how many youth on SSI have IEPs that  could facilitate connecting them to VR services. Based on data collected  in 2001-2002 for the National Survey of SSI Children and Families, one  study found that approximately 70 percent of surveyed youth on SSI had  an IEP at some point during their schooling, which seems to indicate that  about one-third of these youth lack an established path that may connect  them to services to help them transition into employment or  postsecondary education, and potentially reduce their dependence on  SSI. In addition, youth who have dropped out of school also lack an IEP  pathway to VR services. Federal standards for internal control state that  agencies should use quality information to achieve their objectives.  Absent data on whether youth on SSI have IEPs that can help them  connect to transition services or additional options for connecting youth to  VR services, SSA cannot ensure that these youth are receiving or have  access to services they need to help them prepare for adulthood and the  workforce.

With enactment of WIOA in 2014, more transition-age SSI recipients are  potentially connected to VR services, although the extent to which this  occurs is not known. Under WIOA’s amendments to the Rehabilitation Act  of 1973, VR agencies are now required to provide pre-employment  transition services to students with disabilities beginning at age 16 (or  younger if a state elects a younger minimum age). WIOA’s amendments  to the Rehabilitation Act of 1973 also require states to reserve at least 15  percent of their state allotment of federal VR funds to provide these  services to students, including job exploration counseling, work-based  learning experiences, transition or postsecondary educational programs  counseling, workplace readiness training, and instruction in self- advocacy. Students with disabilities are eligible for pre-employment  transition services even if they have not applied or been found eligible for  VR’s regular services. Most VR agencies we interviewed are in the early  stages of implementing WIOA’s amendments to the Rehabilitation Act of  1973, and as such, the extent to which the new provisions will increase  participation by youth on SSI is not known. While certain WIOA  amendments broadly support all students with disabilities, they do not  specifically target youth on SSI. In addition, some state VR agency  officials told us they do not determine an individual’s SSI status prior to  the application process for VR services, and thus may not be able to  capture data on the number of youth on SSI they serve through pre- employment transition services.

section_title: Data and Information Sharing About SSI Youth is Limited Among SSA, Vocational Rehabilitation Agencies, and Education
paragraphs: Data and information sharing about transition-age youth on SSI—which  could potentially facilitate provision of services—is limited between SSA,  VR agencies, and Education, and officials said there are privacy  considerations about sharing information. SSA does not systematically  provide Education or VR agencies with data that would allow them to  identify transition-age youth on SSI for outreach on services. VR agency  staff we interviewed told us that when an individual applies to VR for  services, the agency can query SSA on the individual’s disability benefits,  including SSI benefits. However, this query can only be conducted on a  case-by-case basis, some VR officials said, and VR agencies do not have  access to broader information about the population of youth on SSI who  would be eligible for VR services in their area. VR officials in four of five  states where we conducted interviews said having such data would be  beneficial because it would help them conduct outreach in a more  focused way. Officials in the fifth state said that having such information  might be useful because it would allow them to determine the extent to  which they are reaching the population of youth on SSI. Education  officials also told us that, if available and consistent with applicable  privacy laws, VR agencies might use information on youth receiving SSI  to conduct outreach to youth who may not be connected to the school  system, such as youth who have dropped out of school, are homeless,  migrants, or seasonal workers. Education officials within the  Rehabilitation Services Administration also said that generally state VR  agencies have the capacity to conduct outreach, and additional data from  SSA would be helpful.

Although access to more comprehensive SSA data might improve  outreach by VR agencies, privacy concerns and other factors inhibit data  sharing by SSA. Both SSA and Education have raised privacy and legal  concerns about sharing SSI recipient data, indicating that such sharing  may be prohibited under federal law; however, SSA has participated in  other data sharing arrangements. In each instance, steps were taken to  protect personal information and address privacy requirements. SSA  officials told us that, as part of the Ticket to Work program, SSA has  provided information on eligible beneficiaries to non-VR employment  networks that asked for this information. While the agency stopped this  practice in March 2015, due to privacy concerns, SSA officials said they  are currently conducting an initiative in which SSA provides employment  networks encrypted data on eligible beneficiaries via secure messaging.  This includes the name and address or the name and phone number of  potentially eligible beneficiaries for conducting outreach. SSA officials  said they anticipated continuing this project for several months before  evaluating the process and deciding how to proceed. However, SSA  officials said they have not provided similar information to VR agencies  because (1) the demand for VR services is generally high and negates  the need to conduct outreach and (2) they do not have the legal authority  to refer individuals to VR. In addition, under the PROMISE initiative, SSA  provided identifying information on groups of SSI recipients, such as  contact information, to facilitate outreach and enrollment. According to  SSA and Education officials, that data sharing was permitted because it  was conducted for research purposes. Nevertheless, steps were taken to  ensure privacy requirements were met, such as obtaining consent from  SSI youth and their parents or guardians about participating, and using  unique identification numbers in lieu of Social Security numbers.

Finally, SSA and Education have a data sharing agreement in place;  however the shared data are currently not used for VR outreach or  program management purposes. The data sharing agreement establishes  procedures and conditions for the merging of SSA and Education  administrative data to support research and program evaluation. The  data sharing agreement specifies that SSA will remove personally  identifiable information, including Social Security numbers, before sharing  merged files with Education. Under this agreement, SSA has access to  data on the number and the characteristics of individuals exiting the VR  program each fiscal year, which according to Education, only includes  closed, not open, service records. As such, neither SSA nor Education  know the extent to which youth on SSI are receiving VR services.  Education officials said that beginning in July 2017, due to requirements  in WIOA, Education will begin collecting data from VR programs on a  quarterly basis for both current program participants and those who have  exited the program. Education and SSA officials said these data on open  service records, in combination with SSA’s recipient data, could also be  used to determine in a more regular and timely manner the total  population of youth on SSI receiving VR services. However, SSA officials  said without knowing exactly what the data will include, they do not know  whether it will prove useful and therefore do not yet have any plans to  analyze these data. SSA officials told us that without more information on  how WIOA amendments to the Rehabilitation Act of 1973 will change  services to youth, they were unsure what additional outreach should be  conducted, or whether additional initiatives or data will be necessary to  connect youth on SSI to VR services.

section_title: Conclusions
paragraphs: Many individuals with disabilities want to work for the financial and  personal rewards that employment can provide, and it is in SSA’s interest  to help SSI recipients find employment and ultimately reduce or end their  dependence on SSI. Helping transition-age youth on SSI engage in work  prior to age 18 is critical given that research finds SSI recipients often  continue receiving benefits for decades, resulting in high costs to the  federal government. Yet few transition-age youth on SSI are working, and  many of those who do work are not benefiting from provisions under  federal law to exclude some of their income and retain still-needed  benefits.

While SSA maintains data on the number of SSI recipients who work and  use work incentives and employment supports, by not regularly analyzing  these data, SSA cannot ensure transition-age youth are receiving work  incentives for which they are eligible. SSA does not know, for example,  why many transition-age youth with income are not receiving the SEIE,  which is targeted specifically to this population. In addition, lacking  procedures that ensure systematic, consistent communication with youth  and families about work incentives and redetermination rules, SSA is  forgoing opportunities to encourage employment and potentially allay  fears that may create a barrier to employment.

SSA also states that it is hindered in its ability to connect transition-age  youth to VR services because it is no longer allowed to directly refer them  and SSI recipients under 18 are not included in its program that assists  adults with making this connection. SSA must rely primarily on schools to  make this connection for students. However, SSA is well positioned to  work with Education to determine the extent to which transition-age youth  on SSI are not being connected to VR services for which they are eligible,  and to assess options to better ensure they receive them, as appropriate.  Without further efforts, the program risks unwarranted costs and the youth  it serves may be less likely to obtain self-sufficiency.

section_title: Recommendations
paragraphs: We recommend that the Acting Commissioner of the Social Security  Administration take the following actions:  1.  Analyze the SEIE data to determine why a large proportion of  transition-age youth on SSI with reported earnings did not benefit from  the SEIE and, if warranted, take actions to ensure that those eligible  for the incentive benefit from it.  2.  Analyze options to improve communication about SSA-administered  work incentives and the implications of work on SSI benefits, with a  goal of increasing understanding of SSI program rules and work  incentives among transition-age youth and their families. This should  include, but not necessarily be limited to, updating SSAs procedures  for staff meeting with SSI applicants, recipients, and their families to  regularly and consistently discuss – when applicable—how work  incentives can prevent reductions in benefit levels and how work  history is considered during eligibility redeterminations.  3.  Work with the Secretary of Education to determine the extent to which  youth on SSI are not receiving transition services through schools that  can connect them to VR agencies and services.  4.  Explore various options for increasing connections to VR agencies  and services, including their potential costs and benefits. One option,  among others, could be to expand the Ticket to Work program to  include youth.

section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of the report to SSA and Education for their review. In  written comments, SSA agreed with two of our recommendations,  partially agreed with one, and disagreed with one. We have reproduced  SSA’s and Education’s comments in appendices II and III. We have  incorporated them—as well as technical comments provided—in the  report, as appropriate.

In its comments, SSA suggested GAO clarify SSI’s role as part of a  broader social safety net, and explain that the SSI program does not have  provisions for SSA to ensure recipients have access to a variety of  services provided by federal and state agencies. We agree, and added  additional information in the report suggested by SSA to help convey this.  SSA also commented that the draft report did not accurately portray  efforts to encourage work and explain work incentives to youth receiving  SSI, citing efforts made to produce a new brochure targeting youth and  directing WIPA projects to further target youth—both of which were  results of the YTD project. We discussed SSA’s new brochure in our  report, and stated that it will be helpful for some SSI beneficiaries. We  also discussed SSA’s use of WIPA projects to provide benefits  information and counseling, and noted that SSA has instructed WIPA  projects to serve beneficiaries ages 14 and older and conduct outreach  targeting transition-age youth.

SSA agreed with our recommendation to analyze Student Earned Income  Exclusion (SEIE) data to determine why a large portion of transition-age  youth with reported income did not benefit from SEIE and take steps, if  warranted, to ensure they do. SSA also agreed to explore various options  for increasing connections to Vocational Rehabilitation (VR), stating that  in addition to assessing options for referring youth to VR and/or changing  the Ticket to Work program, the agency will continue to research other  options for supporting transitioning youth.

SSA partially agreed with our recommendation that SSA work with  Education to determine the extent to which youth on SSI are not receiving  transition services through schools that can connect them to VR. SSA  noted its ongoing collaboration with Education and other agencies  through the Promoting Readiness of Minors in SSI (PROMISE) project,  stating the initiative is testing the provision of VR services to youth  receiving SSI and will provide some evidence related to the role of  schools and VR services for this population. SSA also stated it will  continue to pursue research in this area. We agree that the PROMISE  initiative has the potential to provide useful information on whether the  services and supports provided improve education and employment  outcomes for transition-age youth; however, a final PROMISE evaluation  is not expected until winter 2022. In addition, the PROMISE initiative was  not designed to determine the extent to which youth on SSI are receiving  transition services through schools or are otherwise connected to VR  services. SSA also noted that it works with Education and other agencies  through the Federal Partners in Transition (FPT) Workgroup to improve  the provision of transition services to students with disabilities, and that  the FPT has issued a blueprint of agencies’ efforts. While the FPT can be  a promising vehicle for helping connect youth on SSI to key transition  services, as of September 2016, the FPT had not set timelines or  milestones to achieve its broad goal to support positive outcomes for  youth with disabilities, nor does it have a list or specific activities and  tasks it will undertake. Therefore, we continue to believe additional  collaboration by SSA with Education would be beneficial. SSA also noted  several concerns related to complying with this recommendation, such as  legal (privacy) concerns with data sharing, the capacity of state VR  agencies to serve more individuals, and the receptivity of youth on SSI to  receiving services. While we acknowledge that legal and privacy issues  can present challenges to collaboration, we believe that SSA can take  steps to explore actions it could take after considering such legal issues.  We note that SSA has implemented approaches for sharing sensitive  information under its Ticket to Work program, and prior surveys have  yielded information to help understand how many youth on SSI have had  an IEP at some point during school. Finally, while low state VR capacity  or individual motivation can obstruct receipt of VR services, they should  not prevent SSA from working with Education to determine the extent to  which SSI youth are sufficiently informed of VR resources that are  potentially available to them.

SSA disagreed with our recommendation that it analyze options to  improve communication about SSA-administered work incentives and the  implications of work on SSI benefits. SSA stated that it already analyzed,  and continuously monitors and solicits feedback on, options to improve  communications. SSA also said it requires staff to meet with SSI  recipients regularly and instructs staff to discuss relevant work incentives,  and that there is no indication that staff are not providing youth with  appropriate work incentive information. However, SSA did not explain  how it knows or ensures that staff are providing this information. As noted  in our report, staff in local SSA offices we visited told us that they do not  regularly or consistently discuss work incentives with youth or families— when, for example, such information is not specifically requested, or if  staff lack time. Further, SSA policies do not instruct staff to consistently  convey information to youth and families on how work may or may not  affect age 18 redetermination. SSA said that its new brochure provides  information on age-18 redeterminations, as well as work incentives and  other resources. While we acknowledged that the new brochure is a  positive development, we noted that it could contain additional relevant  information, for example, on Medicaid eligibility. We also noted that  written information may not be sufficient for conveying complex  information. We agree with SSA that WIPA projects play an important role  providing work incentives counseling to SSI youth; however, as we noted  in our report, WIPA projects have limited capacity for serving youth along  with other SSI recipients and disability insurance beneficiaries. Therefore,  we continue to believe that there are opportunities for SSA to improve its  communication with transition-age youth and their families, including  through in-person or telephone interactions.

Education agreed to cooperate with SSA efforts to determine the extent to  which youth on SSI are being connected to VR agencies and services  through schools and on options to increase connections to VR agencies  and services. Education noted that privacy statutes might complicate or  limit use of student data. While we acknowledge that privacy laws can  present challenges in this area, we believe that Education can take steps  to explore actions it could take after considering these laws.

We are sending copies of this report to appropriate congressional  committees, the Secretary of Education, the Acting Commissioner of the  Social Security Administration, and other interested parties. In addition,  the report will be available at no charge on the GAO website at  http://www.gao.gov.

If you or your staff have any questions concerning this report, please  contact me at (202) 512-7215 or bertonid@gao.gov. Contact points for  our Offices of Congressional Relations and Public Affairs may be found  on the last page of this report. GAO staff who made key contributions to  this report are listed in appendix IV.

section_title: Appendix I: Scope and Methodology
paragraphs: This report examines 1) how the Social Security Administration (SSA)  encourages employment for transition-age youth on Supplemental  Security Income (SSI) as they move toward adulthood, and the  effectiveness of these efforts, and 2) the extent to which SSA helps  ensure transition-age youth on SSI receive vocational rehabilitation  services.

We focused our review on transition-age youth ages 14 to 17 because  when SSI recipients turn 18, their eligibility for SSI is reassessed against  adult criteria. Furthermore, our previous work has found that the transition  from high school is an especially challenging time for individuals with  disabilities because they are often no longer automatically entitled to  transition services they received as students and must apply for and  establish eligibility for services as adults, often from multiple agencies. In  addition, research suggests that early interventions may improve later  outcomes for youth with disabilities.

To address both our research objectives, we reviewed relevant federal  laws, regulations, policies, documents, and publications; interviewed SSA  officials and staff and Education officials, advocates, and researchers;  and conducted site visits to two states. In particular:

To understand SSA’s approaches to encourage employment among  transition-age youth, we reviewed SSA’s 2016 Annual Report of the  Supplemental Security Income Program, most recent SSI Annual  Statistical Reports, 2016 Red Book: A Summary Guide to  Employment Supports for Persons with Disabilities Under the Social  Security Disability Insurance (SSDI) and Supplemental Security  Income (SSI) Programs, various policies outlined in SSA’s Program  Operations Manual System (POMS), the agency’s Fiscal Years 2014- 2018 Agency Strategic Plan, SSA “Spotlights” (handouts related to  applying for and receiving SSI), and information about SSA’s Youth  Transition Demonstration (YTD) and the Promoting the Readiness of  Minors in Supplemental Security Income (PROMISE) initiative.

To determine the extent to which youth benefit from SSA- administered work incentives or other employment supports, we  reviewed or analyzed available data from SSA on the number of  transition-age youth benefiting from various work incentives, as  follows:

For the Student Earned Income Exclusion (SEIE), the Plan to Achieve  Self-Support (PASS), Impairment-Related Work Expenses (IRWE),  and Blind Work Expenses (BWE), we analyzed data provided by SSA  from its Disability Analysis File (DAF) for SSI recipients ages 14 to 17  for calendar years 2012, 2013, 2014, and 2015. A new version of the  DAF is created each year in March and the 2015 file is the most  current available version. According to SSA officials, SSA continues to  update data as it obtains new information from recipients, so data  from more recent years, while complete as of the time the data were  obtained by SSA, do not reflect possible future changes to recipient  files. Therefore, while we report data from each year, we focus on  data from 2012 and 2013 which, according to SSA, provide a more  complete picture of recipients with earned income and who benefited  from work incentives and supports.

We reviewed data from the Supplemental Security Record provided  by SSA on the number of SSI recipients ages 18 and 19 who received  continuing disability payments under Section 301 of the Social  Security Disability Amendments of 1980.

We also reviewed annual Work Incentives Planning and Assistance  (WIPA) project reports by the Work Incentives Planning and  Assistance National Training and Data Center and data provided by  the Center.

To assess the reliability of these data, we interviewed SSA officials,  reviewed written answers to questions we provided to SSA, and reviewed  available documentation. According to SSA officials, while producing the  data we requested, the agency discovered a previously unknown error in  its data transfer process. The error has resulted in a small proportion of  cases in which earnings and work incentive data are not being correctly  transferred from one data file to another. SSA officials estimated this  issue affects approximately 0.1 percent of the overall population of  transition-age youth ages 14 to 17, and approximately 5 percent of those  with earnings. According to SSA, this suggests that the number of youth  with earnings and the number benefiting from SSA-administered work  incentives may be approximately 5 percent larger than reported.  However, because SSA believes that the undercount is approximately the  same for the number of transition-age youth with earnings and the  number receiving SEIE, the percentage of these youth receiving SEIE  would not change substantially. We do not believe this issue materially  changes our findings—regarding low use of SEIE and low percentage of  youth with earnings receiving SEIE—and we found the data to be  sufficiently reliable for the purposes of our reporting objectives.

We also conducted a literature review designed to identify research  published over the last 10 years related to participation in, and outcomes  related to, SSA-administered work incentives and demonstration projects  that pertain to transition-age youth. Our search used broad key terms  including those related to relevant work incentives, YTD and PROMISE,  and vocational rehabilitation for youth on SSI. The search identified 218  studies or articles. After reviewing abstracts of studies for key parameters  we determined that some studies were duplicative, some were outside  the 10 year timeframe, and some were not published articles. This  information, combined with a review of abstracts for key terms (such as  confirming the studies discussed youth on SSI) enabled us to narrow the  list to 111 results. We then conducted a more thorough review of study  abstracts to determine whether the studies were not relevant, were  suitable for background purposes (such as 40 articles about vocational  rehabilitation), or were focused on SSI work incentives and demonstration  projects. Ultimately, we identified 19 studies that focused on SSI work  incentives and demonstration projects. Of these, 12 focused on YTD and  7 focused on incentives. However, 5 discussed work incentives in broad  terms, for example describing that work incentives could help improve  employment opportunities without discussing a specific example. Only 2  of the studies discussed specific work incentives—including a study over  10 years old that we included because it was the only study that  discussed PASS—and none addressed the specific effects of these  incentives on encouraging work. After determining the studies were  methodologically sound, we incorporated key findings as appropriate in  our report.

To determine how youth on SSI and their families are informed about SSI  program rules, work incentives, eligibility for VR, and other supports, we  reviewed relevant procedures and information and notices provided by  SSA to SSI recipients, their families, and their representative payees. We  also interviewed staff in five SSA field offices in three states: two each in  Florida and New York, and one in California. We selected the three states  because they each served a large population of SSI recipients and youth  on SSI and based on geographic variation. We further selected New York  because it was participating in the ongoing PROMISE initiative. In each  state, we interviewed a variety of SSA staff, including, for example, district  managers, technical experts, claims representatives, Area Work Incentive  Coordinators, and a Work Incentives Liaison, among others. At the  California SSA field office we also observed an age 18 redetermination  interview.

In Florida and New York, we also interviewed staff at VR offices, a  combination of school and school district personnel in six school districts,  and staff at a WIPA project in each selected state. In New York, we also  interviewed state officials responsible for implementing PROMISE as well  as several PROMISE service providers. We interviewed these individuals  to gather information about the services they provide to transition-age  youth on SSI and their opinions on SSA’s effectiveness in encouraging  work among this population and SSA efforts to connect these youth to VR  services. The results of our interviews with SSA field office staff, VR  officials and staff, school and school district personnel, and service  providers are not generalizable, but provide insight into a variety of  issues, including, how SSA and its staff communicate with transition-age  youth on work-related issues; transition services these youth receive; and  barriers they face to employment.

To determine how SSA helps to ensure transition-age youth on SSI  receive VR services available to SSI recipients, we reviewed SSA policies  and interviewed SSA officials, state Disability Determination Service  officials in the Florida and New York, and VR officials in five states— Florida, New Mexico, New York, Oklahoma, and Washington. Florida and  New York were selected because these were the two states in which we  conducted our site visits. New Mexico, Oklahoma, and Washington were  selected based on variation in the size of the population of youth under 18  receiving SSI who are served by the VR agencies, the rate of successful  employment outcomes for transition-age youth receiving VR services, and  geography. The results of our interviews with state VR agency officials  are not generalizable.

We also collected data from state VR agencies in the five states on the  number of transition-age youth on SSI with open VR service records in  calendar year 2015, to analyze the extent to which youth were receiving  VR services. The VR agencies from which we collected data did not all  define “open service records” in exactly the same way. One state  included only service records for which an individual plan for employment  had been developed; the other states classified open service records to  include individuals in other statuses, such as any individual who was  beyond referral status. To assess the reliability of these data, we provided  written questions to state VR officials and reviewed relevant  documentation where available. We found the data were sufficiently  reliable for our purposes.

We compared the data provided by these state VR agencies to the  number of transition-age youth in current pay status in 2015 according to  data provided by SSA from the DAF. While SSA officials told us the  number of recipients is unlikely to change significantly in its data, as  noted previously, the DAF file is updated each year with new information  obtained by SSA, and officials told us that the more recent years of the  DAF are more likely to change than years further past. However, given  the small number of transition-age youth with open VR service records in  comparison to the number receiving SSI, any changes to the number of  SSI recipients in the DAF would not significantly change the percentage  of transition-age youth with open VR service records. When calculating  the number of transition-age youth on SSI in the state, we counted any  such youth who received SSI benefits for at least 1 month in the state.  Some of these recipients did not live in the state for the entire year. In  addition, we reviewed data provided by SSA on reimbursements the  agency made to state VR agencies for successful work outcomes for  transition-age youth on SSI for 2012 through 2014. We found SSA’s data  to be sufficiently reliable for reporting on the extent to which transition-age  youth benefited from SSA’s work incentives.

We conducted this performance audit from February 2016 to May 2017 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

section_title: Appendix II: Comments from the Social Security Administration

section_title: Appendix III: Comments from the Department of Education

section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact

section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Michele Grgich (Assistant  Director), David Barish (Analyst-in-Charge), Divya Bali, Susan Chin, and  MacKenzie Cooper made key contributions to this report. In addition, key  support was provided by Susan Aschoff, James Bennett, Dan  Concepcion, Alex Galuten, Gloria Proa, Monica Savoy, Almeta Spencer,  Barbara Steel-Lowney, and Nicholas Weeks.


Question-summary annotations: questions: question: What is the SSA's primary approach for encouraging employment for transition-age youth with disabilities?
answer: The Social Security Administration's (SSA) primary approach for encouraging employment for transition-age youth (ages 14 to 17) with disabilities who receive Supplemental Security Income (SSI) is work incentives that allow them to keep at least some of their SSI benefits and Medicaid coverage while they work.
child_questions: question: Why is this approach ineffective?
answer: But few transition-age youth benefit from these incentives.

question: How does SSI plan to change their approach?
answer: SSI is a means-tested program that provides cash benefits to eligible low-income aged, blind, and disabled individuals.

question: What do SSA's incentives allow of its recipients?
answer: SSA administers several work incentives that allow SSI recipients to exclude some income and expenses when calculating SSI benefits. The work incentive targeted specifically to younger SSI recipients is the Student Earned Income Exclusion (SEIE), which allows income to be excluded from benefits calculations if a recipient is a student under age 22.
child_questions: question: How has the SEIE failed?
answer: However, less than 1.5 percent of all transition-age youth—and generally less than half of those with earnings—benefited from SEIE in 2012 through 2015. SSA does not analyze these data, and thus cannot determine why the majority of youth with earnings are not benefiting from SEIE, when they may be eligible.
child_questions: question: How have other programs also failed?
answer: SSA data also show that almost no youth benefited from other incentives that allow them to exclude earnings used for specific purposes, such as the Impairment-Related Work Expenses incentive. The effectiveness of SSA-administered work incentives may be further limited because, according to SSA and other officials, youth and their families are often unaware of or do not understand them, and may fear that work will negatively affect their benefits or eligibility.

question: How does SSA's communication of SSI policies fail to communicate this information to youth and their families?
answer: SSA policy requires staff to provide accurate and meaningful information about relevant SSI policies to claimants and recipients. However, GAO found that SSA does not have sufficient procedures in place to ensure that information on work incentives and how work affects benefits and eligibility is consistently communicated to youth and their families.
child_questions: question: How does this hurt the SSA's effectiveness?
answer: As a result, SSA may miss opportunities to promote work incentives and other supports, allay fears, and potentially reduce dependence of transition-age youth on SSI benefits.

questions: question: What does the SSA lack for its SSI program regarding VR agencies?
answer: SSA does not have a systematic way to connect transition-age youth on SSI to state Vocational Rehabilitation (VR) agencies that provide training and employment services under the VR State Grants program administered by the Department of Education (Education).
child_questions: question: What did GAO find regarding youth participation in VR?
answer: Although youth receiving SSI are generally presumed to be eligible for VR services, GAO found that less than 1 percent had an open VR service record in 2015 in four of the five states from which GAO collected VR data.

question: Why was the Ticket to Work and Self-Sufficiency program created?
answer: Legislation in 1999 created the Ticket to Work and Self-Sufficiency program, which expanded the number and types of employment service providers for individuals with disabilities.

question: How has the SSA limited the reach of VR?
answer: However, SSA limited eligibility to recipients age 18 and older. While transition-age youth receiving special education services can be connected to VR agencies through their schools, the extent to which this happens—and whether they are on SSI—is unknown because data to make such determinations are not systematically collected by SSA or schools.
child_questions: question: Why can't data be collected to make such determinations?
answer: Federal standards for internal control call for agencies to use quality information to achieve their objectives.

question: Why does the lack of data collection harm SSA's implementation of VR?
answer: Without relevant data or additional options for connecting youth to VR services, SSA cannot ensure that transition-age youth on SSI are being connected to these services, which can help to prepare them for adulthood and the workforce.

questions: question: What are GAO's recommendations to improve SSA's programs for transition-age youth?
answer: GAO recommends SSA 1) analyze why youth on SSI with earnings did not benefit from SEIE, 2) improve communication about work incentives and rules, 3) work with Education to determine how many youth on SSI are not connected to VR services, and 4) explore options to further connect them.
child_questions: question: How did SSA respond to these recommendations?
answer: SSA agreed in whole or in part with three recommendations. SSA disagreed that its communication on work incentives and rules needs to be improved, stating field staff provides information to youth, and it has created new written material.
child_questions: question: What was GAO's response to SSA?
answer: GAO maintains SSA's communication could be improved as presented in this report.