Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

Congressional research reportJan 24, 2014

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Ticket to Work and Self-Sufficiency Program:

Overview and Current Issues

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January 24, 2014

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

Summary

Title I of the Ticket to Work and Work Incentives Improvement Act of 1999 (P.L. 106-170) was

signed into law on December 17, 1999, and created a Ticket to Work and Self-Sufficiency

program, administered by the Social Security Administration (SSA). Through the Ticket to Work

legislation, Congress sought to address several major work disincentives for individuals with

disabilities. Ticket to Work provides a “ticket” or voucher to working-aged Social Security

Disability Insurance (SSDI) and Supplemental Security Income (SSI) beneficiaries to obtain

employment and other support services. Services are furnished through the current system of state

vocational rehabilitation (VR) agencies or a ticket holder’s choice of an approved public or

private sector, program-specific employment network (EN) to assist them in entering or reentering the workforce. Additional provisions are briefly described below.

The Ticket to Work program was phased in nationally in three stages, which began in February

2002 and concluded in September 2004. By statute, SSA contracts with program managers (PMs)

to administer program aspects related to ENs and ticket holders. As of December 31, 2013, SSA

has 666 ENs certified to provide employment support services for ticket holders in all 50 states

and the District of Columbia. Of the approximately 13.6 million “active” tickets that have been

issued by SSA, 319,972 (approximately 2.4%) are “in-use,” that is, a disability beneficiary has

assigned his or her ticket to an EN or state VR agency.

P.L. 106-170 also directed SSA to establish supplementary work incentive programs designed to

reduce dependence on disability benefits and encourage workforce participation. The Work

Incentives Planning and Assistance (WIPA) program was created to disseminate accurate

information to Social Security disability beneficiaries on work incentive projects. SSA established

cooperative agreements with community-based organizations to provide benefits planning,

assistance, and outreach services to beneficiaries. In addition, SSA established the Protection and

Advocacy for Beneficiaries of Social Security (PABSS) program with the aim of providing

information and advice about how to obtain vocational rehabilitation, employment, advocacy, or

other services that SSDI or SSI beneficiaries may need to secure or regain gainful employment.

The Ticket to Work program underwent major regulatory changes in July 2008, which, among

other adjustments, increased financial incentives for ENs and expanded the eligibility criteria for

Social Security disability beneficiaries to participate. The program has come under increased

scrutiny by policy makers due to low SSDI and SSI beneficiary participation and lower than

expected return-to-work rates among ticket holders. In addition, a May 2011 Government

Accountability Office (GAO) assessment reported a lack of oversight of the program that has led

to service approaches among some ENs that are out of line with the general goal of the Ticket

program, which is to reduce beneficiaries’ dependence on benefits through earnings from work.

Ticket to Work legislation also created state options to eliminate the dilemma faced by many

beneficiaries—choosing between work and health insurance coverage—through provisions that

allow for additional Medicaid eligibility options and an extension of Medicare eligibility. This

report only discusses the Ticket to Work program components administered by SSA and does not

address issues related to the Medicaid or Medicare programs.

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

Contents

Introduction...................................................................................................................................... 1

Background ...................................................................................................................................... 1

Legislative History of the Ticket to Work Program ......................................................................... 3

Ticket to Work and Self-Sufficiency Program ................................................................................. 5

Definition of a “Ticket” ............................................................................................................. 6

Eligibility Requirements for a Ticket ........................................................................................ 6

Employment Networks .............................................................................................................. 7

Program Manager ...................................................................................................................... 7

Employment Network Payment Systems .................................................................................. 8

Milestone-Outcome EN Payment System ........................................................................... 9

Outcome-Only EN Payment System ................................................................................. 10

State VR Agencies and ENs Serving the Same Ticket Holder (Partnership Plus)................... 10

Ticket Ending Period ............................................................................................................... 10

Other Provisions of Ticket to Work Legislation ............................................................................ 11

Expedited Reinstatement ......................................................................................................... 12

Work Incentives Planning and Assistance ............................................................................... 12

Protection and Advocacy for Beneficiaries of Social Security ................................................ 12

SSA Demonstration Projects ................................................................................................... 13

Benefit Offset National Demonstration ............................................................................. 13

Analysis of the Ticket to Work Program........................................................................................ 14

Low Participation Among Social Security Beneficiaries ........................................................ 15

Confusion on How Work Affects Benefits ........................................................................ 16

Employment Network Screening of Beneficiaries ............................................................ 16

Return-to-Work Rates Among Beneficiaries and Ticket Holders ............................................ 17

SSA Measurement of Return-to-Work Rates .................................................................... 17

Ticket Participation and Return-to-Work Rates Vary by Demographic Group ................. 18

Most Tickets Are Assigned to State VR Agencies ................................................................... 18

GAO Assessment of the Ticket to Work Program ................................................................... 19

Lack of Employment Network Oversight ......................................................................... 19

SSA Temporarily Suspended Timely Progress Reviews ................................................... 19

Impact of July 2008 Regulatory Changes................................................................................ 20

Issues for Congress ........................................................................................................................ 24

Expand Early Intervention Services for Disabling Conditions................................................ 25

Increase Management and Oversight of ENs .......................................................................... 26

Develop Longitudinal Measures of Return-To-Work .............................................................. 27

Figures

Figure 1. Sample Ticket ................................................................................................................... 6

Figure 2. Ticket to Work Payment Systems for Employment Networks, Calendar Year

2014 .............................................................................................................................................. 9

Figure 3. New Tickets Assigned, Calendar Years 2004-2010 ........................................................ 22

Figure 4. New Tickets Assigned to ENs, Calendar Years 2004-2010 ............................................ 23

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

Tables

Table 1. Data on the Ticket to Work Program................................................................................ 15

Table 2. The Percentage of Disability Beneficiaries Participating in Ticket to Work,

Calendar Years 2002-2010 .......................................................................................................... 16

Table 3. Distribution of EN Payments, Calendar Years 2002-2011 ............................................... 21

Table 4. Employment Outcomes Before and After the July 2008 Regulatory Changes ................ 24

Table A-1. Side-by-Side Comparison of Key Ticket to Work July 2008 Regulatory

Changes ...................................................................................................................................... 28

Appendixes

Appendix A. Compilation of Key Ticket to Work July 2008 Regulatory Changes ....................... 28

Appendix B. Description of Employment Network Payment Systems ......................................... 33

Appendix C. SSDI and SSI Employment Supports ....................................................................... 35

Appendix D. Acronyms ................................................................................................................. 37

Contacts

Author Contact Information........................................................................................................... 37

Acknowledgments ......................................................................................................................... 37

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

Introduction

Title I of the Ticket to Work and Work Incentives Improvement Act of 1999 (P.L. 106-170)

established the Ticket to Work and Self-Sufficiency program (hereinafter referred to as the Ticket

to Work or Ticket program), which is administered by the Social Security Administration (SSA).

The purpose of this program is to enhance work incentives for Social Security Disability

Insurance (SSDI) and Supplemental Security Income (SSI) beneficiaries. The legislation created a

“ticket” system to expand choices in the numbers and types of providers that SSDI and SSI

beneficiaries may choose to assist them in receiving employment services. The legislation also

expanded Medicare and Medicaid coverage for individuals with a disability who are working or

could work.1 Most notably, the Ticket to Work program created a market for public and private

providers of support services known as employment networks (ENs) to which Social Security

disability beneficiaries can voluntarily assign their tickets in exchange for a range of employment

support services. The goal of the Ticket program is to reduce dependence on disability benefits

and help Social Security disability beneficiaries enter or reenter the workforce. ENs would then

be eligible to receive payments from SSA based on ticket holders achieving employment

“milestones” or outcomes.

This report provides an overview of how the Ticket to Work program operates and addresses

several issues related to the Ticket program. First, it provides a brief background on the SSDI and

SSI programs and a legislative history on how the Ticket program evolved. Second, this report

provides an in-depth explanation on the various components and regulations of the Ticket to

Work program in its current form and prior to major regulatory changes in July 2008.2 Third, it

examines other work incentive programs created by Ticket to Work legislation and concludes

with a discussion on the issues surrounding implementation of the Ticket program.

Background

SSA administers two disability programs, SSDI and SSI, Titles II and XVI of the Social Security

Act respectively.3 SSDI is an insurance program for workers and their dependents for which

benefits are paid to individuals who have a disability and have worked and made contributions to

the U.S. Social Security system.4 Individuals who collect SSDI also become entitled to coverage

under the Medicare health insurance program (Title XVIII of the Social Security Act) after a 24month waiting period.5

This CRS report only addresses the SSA-administered components of the Ticket to Work program (Title I of P.L.

106-170) and does not include a discussion on the expanded healthcare services provided through Medicaid and

Medicare (Title II of P.L. 106-170). For more information on the Medicaid program, see CRS Report R43357,

Medicaid: An Overview, coordinated by (name redacted); for more information on the Medicare program, see CRS

Report R40425, Medicare Primer, coordinated by (name redacted) and (name redacted).

An expanded description of employment network (EN) payment systems is described in Appendix B.

For more information, see CRS Report RL32279, Primer on Disability Benefits: Social Security Disability Insurance

(SSDI) and Supplemental Security Income (SSI), by (name redacted).

To qualify for SSDI, disabled workers must earn at least one quarter of coverage (work credit) for each calendar year

after they turned 21 years old and have at least 20 quarters of coverage during the past 10 years. However, individuals

who become disabled before the age of 31 need fewer work credits to qualify for SSDI benefits. For more information,

see SSA, Benefits Planner: Number of Credits Needed For Disability Benefits, http://www.ssa.gov/retire2/credits3.htm.

For more information, see CRS Report RS22195, Social Security Disability Insurance (SSDI) and Medicare: The 24(continued...)

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

SSI is a means-tested disability program for low-income individuals who are aged, blind, or

disabled and have limited resources. In general, individuals are eligible for SSI if their countable

income falls below the federal benefit rate (FBR) and they have countable resources of less than

$2,000 for an individual.6 In most states, beneficiaries who collect SSI are automatically entitled

to coverage under the federal-state Medicaid health insurance program (Title XIX of the Social

Security Act).

Individuals are considered to have a disability if they meet the definition established under the

Social Security Act. Disability is defined as the inability to engage in any “substantial gainful

activity” (SGA) due to a medically determinable physical or mental impairment that is expected

to last for at least 12 months or result in death. SGA is defined in federal regulations as paid work

involving significant and productive physical or mental duties.7 For 2014, the monthly SGA

thresholds are $1,800 for individuals who are blind and $1,070 for individuals with other

disabilities.8 SGA limits are adjusted annually to reflect growth in average wages.9

In 2013, approximately 12.2 million beneficiaries collected monthly SSDI or SSI benefits.10

Together these two programs represent the largest disability benefit system in the nation, with

combined federal expenditures of approximately $146.8 billion in 2013.11 Although both SSDI

and SSI include a number of work incentives and offer rehabilitation services to individuals with

a disability, the number of people who leave the benefit rolls to work (i.e., engage in SGA) is very

small. In 2012, 0.4% of SSDI beneficiaries actually left the disability rolls because of work.12

The small incidence of return-to-work has been partially attributed to the built-in disincentives of

the SSDI and SSI programs. Because eligibility depends upon proving an inability to work,

recipients risk losing both cash benefits and health insurance coverage if they successfully

attempt to work.13

(...continued)

Month Waiting Period for SSDI Beneficiaries Under Age 65, by (name redacted).

The FBR is the maximum dollar amount paid to an SSI beneficiary. For 2014, the FBR is $721 for an individual

living independently and $1,082 for a couple living independently.

See 20 C.F.R. §404.1584 for SGA rules for beneficiaries who are blind and 20 C.F.R. §404.1571 for non-blind

beneficiaries. Under Section 223(d) of the Social Security Act, the Commissioner of SSA is given authority to

promulgate regulations prescribing the criteria for determining when earnings demonstrate an individual’s ability to

engage in SGA. The Social Security Act specifies a higher SGA amount for statutorily blind individuals. SGA for the

blind applies to SSDI benefits, but does not apply to SSI benefits. For more information, see CRS Report RS20479,

Social Security: Substantial Gainful Activity for the Blind, by (name redacted).

For past SGA levels, see http://www.socialsecurity.gov/OACT/COLA/sga.html.

For the SGA calculation method, see http://www.socialsecurity.gov/OACT/COLA/sgadet.html.

For SSDI, this combined figure includes the average monthly number of beneficiaries who were in current pay status

for the months in which a benefit was payable. For SSI, this combined figure includes only the average monthly

number of beneficiaries between the ages of 18 and 64 who were not concurrent SSDI/SSI beneficiaries and were in

current pay status for the month in which a payment was made. These are the same figures that SSA uses to compute

the Payment Calculation Base (PCB). For further explanation, see footnote 96 in Appendix B.

Total expenditures include only payments to beneficiaries described in footnote 10 and exclude any related

administrative costs. This figure is the annualized total of the average monthly benefit amounts that SSA uses to

compute the Payment Calculation Base (PCB). For further explanation, see footnote 96 in Appendix B.

Social Security Administration, Annual Statistical Report on the Social Security Disability Insurance Program, 2012,

November 2013, Table 57, http://www.ssa.gov/policy/docs/statcomps/di_asr/2012/di_asr12.pdf.

David Stapleton, Stephen Bell, and David Wittenburg et al., BOND Implementation and Evaluation, Abt Associates,

Inc. and Mathematica Policy Research, Inc., BOND Final Design Report, December 3, 2010, p. 1, http://www.ssa.gov/

(continued...)

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

Legislative History of the Ticket to Work Program

Prior to the passage of Ticket to Work legislation, policy makers and advocates for individuals

with disabilities had long argued that work incentives under the law were complex and difficult to

understand.14 Some contended that several reasons for the high rate of unemployment among

beneficiaries included confusing rules, arcane procedures, and disincentives built into the Social

Security disability programs. Advocates noted surveys showed that most working-age people with

disabilities want to work15 and maintained that the numerous federal regulations and program

rules have the effect of discouraging otherwise qualified and eager job seekers with disabilities

from seeking employment. Return-to-work legislation subsequently became the subject of several

legislative proposals,16 congressional hearings,17 and a major component of the Clinton

Administration’s comprehensive strategy to increase employment among individuals with

disabilities.

On March 18, 1998, President William J. Clinton established the Presidential Task Force on the

Employment of Adults with Disabilities (PTFEAD). This Cabinet-level task force was charged

with conducting an extensive public policy review with the goal of increasing the employment of

individuals with disabilities and addressing other barriers to work among adults and young people

with disabilities.18 PTFEAD produced a series of reports that analyzed existing federal programs

(...continued)

disabilityresearch/documents/BOND_Design%20Report_FINAL_Del2-2_12-17-10.pdf. Stapleton et al. provide a

concise explanation about the effects of the loss of cash benefits among SSDI beneficiaries, also known as the “cash

cliff.”

For example, see the testimony of Jane L. Ross, director of Income Security Issues in the Health, Education and

Human Services Division at GAO in U.S. Congress, House Committee on Ways and Means, Subcommittee on Social

Security, Barriers Preventing Social Security Disability Recipients From Returning to Work, 105th Cong., 1st sess., July

23, 1997, serial no. 105-61 (Washington: GPO, 1999).

Peter Risher and Stacey Amorosi, The 1998 N.O.D./Harris Survey of Americans with Disabilities, National

Organization on Disability/Louis Harris & Associates, Inc., New York, NY, 1998.

Return-to-work legislation for Social Security disability beneficiaries had been introduced in prior Congresses before

the enactment of P.L. 106-170. For example, the Rehabilitation and Return to Work Opportunity Act of 1996 (H.R.

4230) introduced in the 104th Congress would have, among other provisions, extended healthcare coverage for Social

Security beneficiaries in addition to creating a milestone payment system to a network of private-sector rehabilitation

service providers for achieving certain employment outcomes for beneficiaries.

Additionally, the Transition to Work Act of 1997 (H.R. 534) introduced in the 106th Congress, would have provided a

“ticket” (similar to the “Ticket to Work”) for beneficiaries to redeem for public or private vocational rehabilitation

services. H.R. 534 also would have extended Medicare coverage to certain beneficiaries and provided tax credits to

employers of beneficiaries whose disability payments were terminated due to earnings from work.

For committee hearings held during the 106th Congress, see U.S. Congress, House Committee on Commerce,

Subcommittee on Health and Environment, The Work Incentives Improvement Act of 1999, 106th Cong., 1st sess.,

March 23, 1999, serial no. 106-15 (Washington: GPO, 1999); U.S. Congress, House Committee on Ways and Means,

Subcommittee on Social Security, Barriers Preventing Disability Beneficiaries From Returning to Work, 106th Cong.,

1st sess., March 11, 1999, serial no. 106-5 (Washington: GPO, 1999); and U.S. Congress, Senate Committee on

Finance, Work Incentives Improvement Act of 1999, 106th Cong., 1st sess., February 4, 1999, S.Hrg. 106-122

(Washington: GPO, 1999).

Executive Order 13078, “Increasing Employment of Adults With Disabilities, Establishment of National Task Force

on Employment of Adults with Disabilities,” 63 Federal Register 13111, March 18, 1998. Later amended by Executive

Order 13172, “Amendment of Executive Order 13078, To Expand the Role of the National Task Force on Adults With

Disabilities To Include Focus on Youth,” 65 Federal Register 64577, October 27, 2000 and Executive Order 13187,

“The President’s Disability Employment Partnership Board, made Chairperson of the Board a member and Vice Chair

of the National Task Force on Employment of Adults with Disabilities,” 66 Federal Register 3857, January 17, 2001.

(continued...)

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

and policies to determine and track changes that would be necessary to remove barriers to work,

address issues surrounding health insurance coverage, and analyze employment outcomes of

programs focused on youths with disabilities.19 Ultimately, PTFEAD’s recommendations

prompted the Clinton Administration to seek full funding in the FY2000 budget request for Ticket

to Work programs.20

Along with several initial cosponsors in the 106th Congress, Senator James M. Jeffords introduced

the Work Incentives Improvement Act of 1999 (S. 331) on January 18, 1999, and on March 18,

1999, Representative Rick Lazio introduced the Ticket to Work and Work Incentives

Improvement Act of 1999 (H.R. 1180). Ticket to Work legislation garnered broad bipartisan and

bicameral support. A conference report incorporating both bills into H.R. 1180 was passed by the

House on October 19, 1999, by a vote of 418 to 2 and by the Senate on November 19, 1999, on a

99 to 1 vote. President Clinton signed H.R. 1180 into law on December 17, 1999, which became

P.L. 106-170.

Specifically, the legislation authorized (1) “tickets” or vouchers to beneficiaries to give them

increased choice of rehabilitation providers and access to services needed to obtain and retain

employment,21 (2) payments to employment service providers based on ticket holder achieving

certain employment “milestones” or outcomes, (3) SSA demonstrations to test different

approaches to removing barriers to employment for Title II (SSDI) beneficiaries,22 and (4) options

for states to adopt a Medicaid “buy-in” program to allow beneficiaries to maintain health

coverage after returning to work and a continuation of Medicare coverage to certain beneficiaries

who are working.

On December 13, 1999, the Congressional Budget Office (CBO) produced final scoring on the

budgetary effects of H.R. 1180 as passed by the House and Senate.23 CBO estimated modest gains

in Social Security beneficiaries’ future participation in the proposed expanded network of

employment support services, beyond the services that were primarily offered by state VR

agencies.24 Overall, by FY2009, CBO projected that the Ticket to Work program (Title I of H.R.

(...continued)

In an initial report to the President, PTFEAD outlined four specific strategies to achieve the Administration’s goal of

increasing employment of individuals with disabilities, which included providing (1) access to healthcare, (2) economic

incentives to return to work, (3) accommodations to normalize the work environment, and (4) expanded access to

education, training, and rehabilitative services.18

See Presidential Task Force on Employment of Adults with Disabilities, Recharting the Course: The Third Report,

Washington, DC, December 15, 2000, and Presidential Task Force on Employment of Adults with Disabilities, People

with Disabilities – Strengthening the 21st Century Workforce Washington, DC, July 26, 2002.

See Presidential Task Force on Employment of Adults with Disabilities, Re-Charting the Course: The Second

Report, Washington, DC, November 15, 1999, p. 1. The Task Force also cited several other Administration initiatives

prompted by The First Report which, among other proposals, included (1) investments in assistive technology, (2) tax

credits for work-related expenses, (3) grants for work incentives, and (4) raising the SGA level for Social Security

disability programs. The Clinton Administration had also included a related return-to-work proposal in the FY1998

budget.

42 U.S.C §1148(a).

42 U.S.C. §234(a).

Congressional Budget Office, Pay-As-You-Go Estimate: H.R. 1180 – Ticket to Work and Work Incentives

Improvement Act of 1999 As cleared by the Congress on November 19, 1999, December 13, 1999, http://cbo.gov/

doc.cfm?index=1807&zzz=8279.

According to CBO, state VR agencies only served a fraction of Social Security disability beneficiaries.

Approximately 10%-15% of new beneficiaries were referred to state VR agencies and, of those individuals, about 10%

(continued...)

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

1180) would reduce direct spending by $53 million and $32 million for the SSDI and SSI

programs, respectively, through the combination of payments to ENs and the avoidance of

payments to beneficiaries whose benefits would be suspended or terminated due to earnings from

work.25

Ticket to Work and Self-Sufficiency Program

The Ticket to Work and Self-Sufficiency program was designed to address several barriers to

work for individuals with disabilities through greater access to healthcare and a broader pool of

employment service providers or ENs. Under the program, SSA provides eligible SSDI and SSI

beneficiaries with a “ticket” that can be used as a voucher to obtain VR, employment and other

support services from an approved EN or state VR agency. ENs are responsible for assisting

ticket recipients with entering or re-entering the workforce. The program is currently

administered by two contracted program managers (PMs) who report to SSA administrators.

Initial regulations for the implementation of the Ticket program were published in the Federal

period beginning in 2002.26 The program was initially available for eligible beneficiaries in 13

states and was extended to all states by September 2004.27

In an effort to provide greater financial incentives to ENs and expand Ticket eligibility to a

greater number of beneficiaries, the Ticket program underwent a number of regulatory

adjustments in July 2008.28 Among other changes, the new rules modified the payment schedule

for ENs and allowed disability beneficiaries with medical conditions that were expected to

improve to also participate in the Ticket program. These beneficiaries had been previously

excluded. Table A-1 in Appendix A shows a side-by-side comparison of the key components of

the Ticket to Work program that were subject to the July 2008 regulatory changes and new

provisions that were implemented.

(...continued)

were accepted for rehabilitative services. At the time, CBO estimated that about 2%-3% of SSDI recipients had benefits

withheld due to earnings from work, with only 1% of beneficiaries receiving VR services.

Ibid. Table 3. CBO also contended that there was little evidence that the additional Titles of H.R. 1180 would lead to

savings in the SSDI and SSI programs.

For further information on the initial program rules, see Federal Register, vol. 66, no. 249, December 28, 2001, pp.

67370-67442.

The initial 13 states were: Arizona, Colorado, Delaware, Florida, Illinois, Iowa, Massachusetts, New York,

Oklahoma, Oregon, South Carolina, Vermont, and Wisconsin. Beneficiaries in these states received tickets starting in

February 2002.

Implementation of the program in the second round of states began in November 2002. The second round included

Alaska, Arkansas, Connecticut, Georgia, Indiana, Kansas, Kentucky, Louisiana, Michigan, Mississippi, Missouri,

Montana, Nevada, New Hampshire, New Jersey, New Mexico, North Dakota, South Dakota, Tennessee, Virginia, and

the District of Columbia.

Implementation of the program in the third round of states began in November 2003 and included Alabama, California,

Hawaii, Idaho, Maine, Maryland, Minnesota, Nebraska, North Carolina, Ohio, Pennsylvania, Rhode Island, Texas,

Utah, Washington, West Virginia, Wyoming, American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, and

the Virgin Islands.

Social Security Administration, “Amendments to the Ticket to Work and Self-Sufficiency Program; Final Rule,” 73

Federal Register 29324, May 20, 2008.

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

Definition of a “Ticket”

According to SSA regulations, a “ticket” is a document that is issued to an eligible beneficiary

that authorizes payment by SSA to an EN or state VR agency that provides employment services,

vocational rehabilitation, and other support services to the beneficiary. Participation in the

program is voluntary and the beneficiary chooses when and whether to assign his or her ticket to

an EN.29 An example of a ticket is shown in Figure 1.

Figure 1. Sample Ticket

Source: Ticket to Work website at http://www.yourtickettowork.com/.

Eligibility Requirements for a Ticket

All individuals with disabilities who are between the ages of 18 and 64 are considered eligible for

a ticket if they are receiving federal SSDI or SSI cash benefits and are in current pay status.30 SSA

is prohibited from initiating a continuing disability review (CDR) during any period for which an

individual is participating in the Ticket program.31 Eligibility for a ticket terminates when

entitlement to SSDI or SSI terminates for reasons other than work activity or earnings.

For information on how long a ticket remains active once assigned, see the section of this report entitled “Ticket

Ending Period.”

Under rules prior to July 2008, individuals must have had a permanent impairment, a non-permanent impairment for

which medical improvement was possible but could not be predicted, or have had an impairment that was expected to

improve and have had at least one continuing disability review (CDR) which made a determination that the disability

continues.

Individuals receiving SSDI or SSI disability benefits are generally subject to periodic CDRs to determine if they

(continued...)

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Employment Networks

ENs may include any public or private entity that can provide directly, or arrange for other

organizations or entities to provide employment services, VR services, or other support services.

This may include state VR agencies,32 one-stop delivery systems under the Workforce Investment

Act (WIA) of 1998,33 public or private schools, or employers that conduct job training programs

and other employment support services. An entity applies to become an EN contractor by

completing a Request for Quotation (RFQ) to SSA’s Employment Networks Contract Team.34

ENs assume responsibility for the coordination and delivery of services to individuals who have

assigned tickets to them. SSA selects and enters into agreements with these employment

networks. ENs and beneficiaries together develop an individual work plan (IWP) that provides for

informed choice for each beneficiary in selecting an employment goal and specific services

needed to achieve that goal. ENs have been selected to conduct vocational rehabilitation and

other services for ticket holders in all 50 states and the District of Columbia. A listing of approved

ENs is available by state and service-type on the Ticket to Work website or by contacting the

program manager Maximus’ toll-free line.35

Program Manager

Ticket to Work legislation requires SSA to contract with one or more Program Managers (PMs)

through a competitive bidding process to assist SSA in administering the program. SSA

contracted with the Federal Services division of Maximus, a consulting and program management

firm, on September 29, 2000, to assume the responsibility of PM for the Ticket program.36 On

September 30, 2008, SSA awarded an additional contract to Maximus to serve as the Ticket

Program Data Operations Center Manager (TPDOCM), responsible for maintaining electronic

systems that support daily ticket operations and provide system support services and management

to SSA.37

A PM can be one or more organizations in the private or public sector with expertise and

experience in the field of VR or employment services. The PM is responsible for providing

information to beneficiaries and the general public about the program, recruiting and

recommending ENs to SSA, ensuring adequate availability of, and access to, services to

(...continued)

continue to meet the definition of disability.

Title I of the Rehabilitation Act of 1973, as amended, authorizes the federal government to make grants to states and

territories to provide vocational rehabilitation (VR) services to persons with disabilities who are interested in seeking

and retaining employment. State and territorial VR agencies work with clients to determine their optimal employment

outcomes and put together packages of services to help them meet these employment goals. See CRS Report R42148,

Vocational Rehabilitation Grants to States: Program Overview, by (name redacted).

WIA (P.L. 105-220) was enacted to facilitate increased coordination among federal workforce development

programs. For more information, see CRS Report R41135, The Workforce Investment Act and the One-Stop Delivery

System, by (name redacted).

An electronic version of the RFQ can be found on the SSA Work Site at http://www.ssa.gov/work/enrfp.html.

For a directory of ENs, see https://yourtickettowork.com/web/ttw/en-directory or call Maximus at 1-866-YourTicket

(1-866-968-7842).

For more information on Maximus Federal Services, see http://www.maximus.com/services/federal.

According to SSA, the five-year contract expired on September 29, 2013 (see http://ssa.gov/work/contracts.html).

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

beneficiaries, and providing assurance that ENs are complying with the terms of their agreements.

A PM is excluded from directly providing employment services to participating individuals.

SSA reassigned certain PM duties from Maximus, Inc. through a separate PM contract with Booz

Allen Hamilton, a strategy and technology-consulting firm. On September 29, 2010, Booz Allen

Hamilton was awarded a five-year PM contract to serve as Beneficiary Access and Support

Services (BASS) manager with responsibility for designing, implementing, and supporting the

marketing of the Ticket program as well as administering the program’s call centers, website, and

electronic mail.38 On September 29, 2010, Maximus was also awarded a five-year PM contract to

serve as the Operations Support Manager (OSM), handling all activities related to ENs, including

recruitment, training, and payments, in addition to managing data and other information related to

the Ticket program.39

Employment Network Payment Systems

P.L. 106-170 authorizes two payment options to ENs and state VR agencies acting as ENs for

achieving an employment outcome: a Milestone-Outcome payment system and an Outcome-only

payment system.40 Each EN or VR agency elects the payment system under which it will be paid

for each individual client.41

ENs use the ticket to claim payment from SSA for services they provide to ticket holders. They

are paid for each month, based on either payment option limits, in which a ticket holder is not

receiving benefits because the individual is working and has earnings above certain thresholds

(see Figure 2). ENs are prohibited from seeking additional compensation from ticket holders;

however, as a result of July 2008 regulatory changes, ENs are allowed to formally supplement a

client’s earnings through direct payments to the ticket holder.42

Prior to the awarding of PM contracts in 2010, the PM for BASS was known as the PM for Recruitment and

Outreach (PMRO).

According to SSA, the combined functions of the BASS and OSM contractors provide the services “necessary to

perform the PM’s role.” For more information, see Social Security Administration, DI 55005.001 General Questions

about the Program Manager’s (PM's) Role in the Ticket to Work Program, December 18, 2013, http://policy.ssa.gov/

poms.nsf/lnx/0455005001.

See Appendix A for an in-depth analysis of EN payment systems and a comparison of EN payment systems before

and after the July 2008 regulatory changes.

Under prior and current rules, state VR agencies can also receive payment for services to ticket holders through the

“cost-reimbursement” program, where SSA will reimburse the agency for the cost of services that they furnish to Social

Security disability beneficiaries. However, state VR agencies also serve as de facto ENs if they elect to be paid under

the EN payment systems. Under current rules both a state VR agency and an EN can receive payment for providing

services to the same beneficiary. See the section in this report entitled “State VR Agencies and ENs Serving the Same

Ticket Holder (Partnership Plus).”

See 20 C.F.R. §411.566. SSA treats EN payments to beneficiaries as unearned income.

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

Figure 2. Ticket to Work Payment Systems for Employment Networks, Calendar

Year 2014

Milestone-outcome payment

system system

Milestone-outcome

payment

Phase 1

Milestone 1 (1 month at $770/month)

$5,000

$10,000

$15,000

$20,000

$25,000

$30,000

$1,357

Milestone 2 (3 months at $770/month within 6

months)

$1,357

SSI ticket holder

Milestone 3 (6 months at $770/month within 12

months)

$1,357

SSDI ticket holder

Milestone 4 (9 months at $770/month within 18

months)

$1,357

Phase 2

Outcome

Total payout

$1,357

Gross earnings of $1070/month

($1800/month if blind)

$4,212

(up to 18 payments of $234/mo.)

$4,477

(up to 11 payments of $407/mo.)

Sufficent monthly earnings for a

"zero cash benefit"status

$14,040

$14,652

(up to 60 payments of $234/mo.)

(up to 36 payments of $407/mo.)

$23,680

Once ticket holder has satisfied

all three phases

$24,557

Outcome-only payment

Total payout

Sufficent monthly earnings for a

"zero cash benefit" status

(up to 60 payments of $436/mo.)

(up to 36 payments of $758/mo.)

$26,160

$27,288

Source: CRS table of estimated payments based on SSA regulations.

Notes: Totals and subtotals are rounded.

Milestone-Outcome EN Payment System

As illustrated in Figure 2, the Milestone-Outcome system provides payments to ENs of $1,357

for 2014 based on the completion of up to four Phase 1 milestones in which a ticket holder has

earnings from work above the trial work period (TWP) level ($770/month for 2014).43 In

addition, an EN can also receive up to 11 Phase 2 milestone payments for SSDI or concurrent44

ticket holders or up to 18 Phase 2 milestones for SSI ticket holders for months in which the

beneficiary has earnings above the SGA level ($1,070 for non-blind and $1,800 for the blind for

2014).45 Finally, ENs can receive up to 60 outcome payments for SSI ticket holders ($234/month

for 2014) and 36 payments for SSDI or concurrent ticket holders ($407/month for 2014) for

months in which the ticket holder has earnings from work sufficient for zero cash benefits. For

2014, ENs can receive up to $23,680 in total payments for SSI ticket holders and up to $24,557 in

total payments for SSDI ticket holders for the completion of all Milestone-Outcome phases.

A TWP allows a disability beneficiary to test their ability to work for up to nine months without affecting their cash

or Medicare benefits. SSDI payments will stop after a three-month grace period, following the nine-month trial work

period, when the beneficiary has monthly earnings at or above the SGA level.

A concurrent beneficiary is an individual who is simultaneously receiving SSDI and SSI benefits. For purposes of

Ticket to Work and other work incentives programs, concurrent beneficiaries are treated the same as SSDI

beneficiaries.

See 20 C.F.R. §§411.500(f) and 411.525(a)(2)(i).

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

Outcome-Only EN Payment System

Under the Outcome-only payment system, ENs can receive payment only for ticket holders that

have earnings sufficient for a zero cash benefit status. For 2014, ENs can receive up to 36

payments at $758 a month ($27,288 in total payments) for SSDI ticket holders and up to 60

payments at $436 a month ($26,160 in total payments) for SSI ticket holders (see Figure 2).

State VR Agencies and ENs Serving the Same Ticket Holder

(Partnership Plus)

Under prior rules, a state VR agency could elect to be paid under traditional cost-reimbursement

rules, but a ticket holder would have to assign their ticket exclusively to the VR agency. In this

instance, VR agencies could not elect to be paid under either EN payment system. The July 2008

regulatory changes established the Partnership Plus program, which encouraged partnerships

between state VR agencies and ENs and enables a ticket holder to use the services of both

entities.46

Under Partnership Plus, SSA will compensate both state VR agencies and ENs sequentially for

achieving successful employment outcomes for the same ticket holder. Following service delivery

to a ticket holder and the closing of a case, a state VR agency can be reimbursed by SSA under

the traditional cost-reimbursement system. Through a referral agreement, an EN can then provide

additional ongoing job retention and other employment supports that may be needed by the ticket

holder. The EN would then be eligible to receive Phase 2 Milestone-Outcome or Outcome-only

payments based on ticket holder earnings (see Table A-1).

Ticket Ending Period

Under SSA regulations, a ticket period ends when (1) entitlement to SSDI benefits ends or

eligibility for SSI disability benefits terminates for reasons other than work activity or earnings,

(2) after a state VR agency or EN has exhausted outcome payments based on that ticket, (3) the

beneficiary is no longer making timely progress toward self-supporting employment according to

SSA guidelines, or (4) the beneficiary withdraws from an EN and fails to re-assign his or her

ticket, within a three-month period.

Ticket holders are considered to be making timely progress toward self-supporting employment

when they show an increasing ability to work at levels that will reduce dependence on benefits or

by making progress toward the completion of a degree program.47 During the period in which a

ticket is active, SSA is prohibited from conducting CDRs; however, regulations set forth

guidelines for SSA to perform timely progress reviews (TPRs) to assess whether individuals are

making progress toward self-supporting employment or degree completion.

Beneficiaries are allowed up to a 12-month period to prepare for employment or school after the

ticket has been issued and must be actively participating in their employment or educational plans

during this period. After 12 months, beneficiaries need to show that they are progressing toward

20 C.F.R. §411. For more information, see https://yourtickettowork.com/web/ttw/basics2.

20 C.F.R. §411.180.

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

self-sufficiency by demonstrating increasing levels of earnings or college credit completion, in

order to continue using the ticket. The regulations indicate measures to assess beneficiaries’

progress through SSA’s performance of TPRs at

•

12 months in which the ticket holder is required to have worked 3 months above

the TWP level or completed 60% of full-time college credits,

•

24 months in which the ticket holder is required to have worked 6 months above

the TWP level or completed 75% of full-time college credits,

•

36 months in which the ticket holder is required to have worked 9 months at the

SGA level or completed a 2-year program or an additional 1 year of full-time

college credit,

•

48 months in which the ticket holder is required to have worked 9 months at the

SGA level or completed an additional 1 year of full-time college credit,

•

60 months in which the ticket holder is required to have earnings for 6 months

that are sufficient for a zero cash benefit or completed an additional 1 year of

full-time college credit,

•

72 months in which the ticket holder is required to have earnings for 6 months

that are sufficient for a zero cash benefit or completed a 4-year degree program,

and

•

successive 12-month periods in which the ticket holder is required to have

earnings for 6 months that are sufficient for a zero cash benefit status.

Once a ticket has been assigned, ticket holders also have the option of placing their ticket in an

inactive status during the initial 24-month period if they believe they will be unable to participate

in the program for a prolonged period of time. This inactive period would not count against their

time limitations for making progress, however, the individual would not be protected against

CDRs during this period. Prior SSA rules for timely progress required ticket holders to meet

similar monthly earnings thresholds at the higher SGA level (see Table A-1).

Other Provisions of Ticket to Work Legislation

P.L. 106-170 contained several other provisions to enhance the work opportunities for individuals

with disabilities. It lessened work disincentives under the Social Security statute, established SSA

demonstrations, and created an advisory panel.48 The legislation also established two grant

programs for the purpose of disseminating accurate information to beneficiaries with disabilities

on work incentive programs.

Section 101(f) of P.L. 106-170 established the Ticket to Work and Work Incentives Advisory Panel within SSA,

which responsible for advising the President, Congress, and SSA on issues related to work incentives programs,

planning, and assistance for individuals with disabilities. The Ticket to Work and Work Incentives Advisory Panel held

its first public meeting on July 24, 2000. The advisory panel met quarterly and these meetings were open to the public.

P.L. 106-170 contained a sunset provision that terminated the panel 30 days after the issuance of a final, detailed report

with legislative and administrative recommendations to the President and Congress. The advisory panel issued its final

report in December 2007.

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Expedited Reinstatement

Section 112 of P.L. 106-170 extended the time period that a SSDI, SSI, or concurrent beneficiary

who returned to work may request reinstatement of benefits.49 If a beneficiary loses eligibility for

SSDI or SSI benefits and payments due to earnings from work and his or her income falls below

SGA within five years, SSA may be able to restart benefits without requiring the individual to file

a completely new application. Although SSA requires individuals under this provision to apply

for benefit continuation, they may receive up to six months of provisional benefits while their

application is being reviewed.

Work Incentives Planning and Assistance

P.L. 106-170 also authorized SSA to award one or more cooperative agreements with qualified

organizations to provide benefit planning, assistance, and outreach. These Work Incentives

Planning and Assistance (WIPA) programs are community-based organizations that receive grants

from SSA to provide services to Social Security disability beneficiaries with free access to longterm employment planning support. At its height, the WIPA program included 102 projects

nationwide.50 Each WIPA project has counselors called Community Work Incentives

Coordinators who

•

refer beneficiaries to ENs or VR agencies,

•

conduct outreach efforts to those beneficiaries (and their families) who are

potentially eligible to participate in federal or state employment support

programs, and

•

work in cooperation with federal, state, and private agencies and nonprofit

organizations that serve beneficiaries with disabilities.

The Benefits Planning Assistance and Outreach (BPAO) program, the predecessor to WIPA, had a

much narrower focus in assisting beneficiaries to make informed choices about work options.

Authorization for WIPA expired at the end of FY2011 and funding for the program lapsed on

June 30, 2012; however, the Consolidated and Further Continuing Appropriations Act, 2013 (P.L.

113-6), appropriated money for WIPA in FY2013.51 The disbursement period for FY2013 WIPA

funds is August 1, 2013, through July 31, 2014.52

Protection and Advocacy for Beneficiaries of Social Security

P.L. 106-170 also authorized SSA to award grants to state protection and advocacy systems

authorized by the Developmental Disabilities Assistance and Bill of Rights Act under the

42 U.S.C. §423.

For additional information on the WIPA program, see http://www.ssa.gov/work/WIPA.html.

For additional information on the current status of WIPA, please contact the author concerning the following:

Congressional Distribution Memorandum from (name redacted) and Edward Liu, CRS , Social Security

Administration (SSA): Reauthorization for the Work Incentives Planning and Assistance (WIPA) and Protection and

Advocacy for Beneficiaries of Social Security (PABSS) Programs, Fiscal Year 2012 and Beyond (November 5, 2012).

For more information, see Social Security Administration, WIPA: Frequently Asked Questions, 2013, p. 1,

http://www.ssa.gov/oag/grants/FAQ%20for%20WIPA.pdf.

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program. Awarded under the Protection and Advocacy for Beneficiaries of Social Security

(PABSS) program, these grants are in addition to the current Developmental Disability program

grants.53 The purpose of the grants is to provide information and advice about how to obtain

vocational rehabilitation, employment, advocacy, or other services that SSDI or SSI beneficiaries

may need to secure or regain gainful employment.

Ticket to Work legislation stipulates that states receive funds at a level that is at least the greater

of $100,000 or one-third of 1% of the amount appropriated and that grants to certain territories

must be at least $50,000. The minimum payments may be increased to reflect an inflation

adjustment in certain circumstances. Each protection and advocacy system that receives a grant

has to submit an annual report to SSA and the Ticket to Work and Work Incentives Advisory

Panel on the services provided to individuals. SSA awards grants to protection and advocacy

systems in each of the 50 states and the District of Columbia, as well as Puerto Rico, Guam,

American Samoa, the United States Virgin Islands, the Commonwealth of the Northern Mariana

Islands, and the protection and advocacy system for Native Americans.54 Like WIPA,

authorization for PABSS expired at the end of FY2011 and funding for the program lapsed on

September 30, 2012; however, the Consolidated and Further Continuing Appropriations Act, 2013

(P.L. 113-6) appropriated money for PABSS in FY2013.55

SSA Demonstration Projects

SSA conducts numerous research projects to better understand how to deliver effective services to

Social Security beneficiaries. The results of these projects can potentially lead to legislation or

rules changes to allow for better coordination between SSA and the states or identify ways to

serve beneficiaries more efficiently. Title III of P.L. 106-170 reinstated the Commissioner of

SSA’s authority to waive provisions of Title II of the Social Security Act for the purpose of

conducting demonstrations relating to alternative methods of treating the work activity of

individuals entitled to disability insurance benefits. SSA’s authority to initiate new SSDI projects

expired on December 18, 2005.56

Benefit Offset National Demonstration

P.L. 106-170 required SSA to conduct demonstration projects under which disability benefits

payable under SSDI are reduced gradually; $1 for every $2 of the beneficiary’s earnings above

SGA.57 This Benefit Offset Pilot Demonstration (BOPD) was initiated in August 2005 in four

states to adequately evaluate the appropriateness of a national implementation of such a

program.58 Under current law, individuals receiving disability benefits under SSDI who return to

For information on Developmental Disability Act programs administered by the Department of Health and Human

Services, see CRS Report RL34507, The Developmental Disabilities Act, by (name redacted).

For additional information on the PABSS program, see http://www.ssa.gov/work/protectionadvocacy.html.

For additional information on the current status of PABSS, please contact the author concerning the following:

Congressional Distribution Memorandum from (name redacted) and Edward Liu, CRS , Social Security

Administration (SSA): Reauthorization for the Work Incentives Planning and Assistance (WIPA) and Protection and

Advocacy for Beneficiaries of Social Security (PABSS) Programs, Fiscal Year 2012 and Beyond (November 5, 2012).

42 U.S.C. §434.

This demonstration was intended to create a similar benefit reduction methodology as is used under the SSI program

(Title XVI).

The four-state demonstration project was conducted in Connecticut, Utah, Vermont, and Wisconsin.

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

work have their benefits eliminated entirely after working above the SGA level, following a ninemonth TWP and three-month grace period. The BOPD was expected to reduce barriers to work

and allow beneficiaries to attain employment, increase earnings, and eventually become

financially self-sufficient. Participants also maintain eligibility for health care benefits and other

SSDI employment supports. The results of the four-state demonstration project helped to inform

the development and implementation of the Benefit Offset National Demonstration (BOND)

project at 10 sites across the country.59 The start-up tasks for the BOND project were completed

in 2010 and a three-month pilot commenced in January 2011. Full project implementation began

in late April 2011 and enrollment ended in September 2012. A final synthesis report on the BOND

is expected in 2017.

Analysis of the Ticket to Work Program

According to publicly available data on the SSA website, 13.6 million active tickets have been

issued to eligible beneficiaries as of December 31, 2013 (see Table 1).60 At the inception of the

program, tickets were issued to beneficiaries as the Ticket to Work program rolled out in phases.

Since the initial roll out, a letter and paper ticket explaining the program are automatically mailed

to eligible beneficiaries. Of the 13.6 million tickets issued, 319,972 (approximately 2.4%) have

been activated (i.e., the ticket has been assigned to an EN or state VR agency). Of all tickets that

are in use, nearly 9 out of 10 have been assigned to state VR agencies rather than ENs.

Assignment of tickets does not necessarily mean that the client is actively receiving services from

an EN or state VR agency, only that the beneficiary has notified the PM that an agency or EN has

been designated to provide services to them.

In addition, there are currently 666 ENs under contract to provide employment support services to

ticket recipients as of December 31, 2013. Of the ENs under contract, 594 (89.2%) have had

tickets assigned to them and 181 (27.2%) have received some type of payment from SSA for

achieving a designated payment milestone for months that a ticket-holder was working while

assigned to the EN. As of December 31, 2013, approximately $138.1 million in total payments

have been made to ENs.

Since the inception of the Ticket to Work program, a number of studies and evaluations have been

conducted through the Advisory Panel, GAO, and the academic community. Based on a review of

these various reports, the following sections provide a discussion of the key issues facing the

Ticket program and matters that may be of concern to Congress.

For additional information on the BOND project, see http://www.socialsecurity.gov/disabilityresearch/factsheets/

offsetnational.htm.

Social Security Administration, Ticket to Work December Monthly Status Report, January 2014, http://www.ssa.gov/

work/documents/monthlystatusreportdecember2013.pdf.

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Table 1. Data on the Ticket to Work Program

Category

Total as of December 31, 2013a

Tickets (Point in Time Data)

Active tickets (tickets issued to beneficiaries who are currently

ticket eligible)

13.6 million

Number of tickets assigned or “in use”

319,972 (2.4% of tickets issued)

Number of tickets in use with a state VR agency under Cost Reimbursement

system

251,402

Number of tickets assigned to state VR agencies

24,914

Number of tickets assigned to ENs

43,589

Employment Networks (ENs) (Point in Time Data)

Number of ENs under contract with SSA

666

Number of ENs with assigned tickets

594 (89.2% of ENs under contract)

Number of ENs that have received payment for employed ticket holders

181 (27.2% of ENs under contract)

Payments (Cumulative)

Value of EN payments

$138.1 million

Beneficiaries (Cumulative)

Number of beneficiaries placed or supported on a job by an EN

26,468

Number of beneficiaries with EN support for which benefits were not paid

due to work and earnings

8,914

Number of benefit-months not paid to beneficiaries due to work

and earnings

163,527

Number of benefit-years not paid to beneficiaries due to work

and earnings

13,627

SSA’s estimated benefits savings from Ticket to Work Program

$163.0 million

Source: CRS table adapted (with modifications) from the SSA’s December Monthly Status Report available at

http://www.ssa.gov/work/documents/monthlystatusreportdecember2013.pdf.

Subcategories under the “Tickets” category were calculated independently and at slightly different points in

time. Information on reporting procedures based on personal communication with a SSA official, January 31,

2013.

Low Participation Among Social Security Beneficiaries

The Ticket to Work program has come under increased scrutiny and criticism by policy makers

for low participation rates among eligible SSDI and SSI recipients. As shown in Table 2, only

4.1% of all beneficiaries receiving SSDI or SSI participated in the Ticket to Work program in

2010. Ticket to Work is a voluntary program, so there is no obligation upon the ticket holder to

activate the ticket. Researchers and disability advocates have identified several possible

contributing factors to the low participation rates.

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

Table 2. The Percentage of Disability Beneficiaries Participating in Ticket to Work,

Calendar Years 2002-2010

Calendar Year

2002

2003

2004

2005

2006

2007

2008

2009

2010

SSDI-Only

0.2%

0.5%

1.0%

1.4%

1.8%

2.2%

2.6%

3.1%

3.6%

SSI-Only

0.2%

0.5%

1.0%

1.5%

1.9%

2.3%

2.8%

3.3%

4.0%

Concurrent

0.3%

0.9%

1.9%

2.6%

3.3%

4.1%

4.9%

5.7%

6.4%

Total

0.2%

0.5%

1.1%

1.6%

2.0%

2.5%

3.0%

3.5%

4.1%

Participants

Source: Table prepared by CRS from Table III.1 in Jody Schimmel et al., Participant and Provider Outcomes Since

the Inception of Ticket to Work and the Effects of the 2008 Regulatory Changes, Mathematica Policy Research: Center

for Studying Disability Policy, Final Report, July 25, 2013, p. 22, http://www.mathematica-mpr.com/publications/

pdfs/disability/TTW_Part_Provid_Outcomes.pdf.

Notes: “Participants” include all beneficiaries (aged 18 to 64) who assigned their most recent ticket in the

calendar year and had not yet unassigned it.

Confusion on How Work Affects Benefits

First, beneficiaries that have just begun receiving cash payments from SSA may be reluctant to

participate in the Ticket to Work program for fear of losing benefits.61 Past research has also

shown that few beneficiaries were aware of SSA’s work incentives programs and, among those

who were aware, many were not persuaded to return to work because of them.62

To address some of the barriers to employment that many beneficiaries face, Ticket to Work

legislation specifically authorized the WIPA program to counsel beneficiaries on how work will

affect their benefits. A recent evaluation revealed, among other findings, that although WIPA

organizations provide support to beneficiaries who are enrolled in their services, many other

Social Security disability beneficiaries do not receive the ongoing assistance that the program was

intended to provide.63

Employment Network Screening of Beneficiaries

Second, ENs are only compensated by SSA when a ticket holder has an employment outcome

either at the TWP or SGA levels depending on the type of payment system or—for the MilestoneOutcome system—the phase that a ticket holder has progressed through. Further, ENs are given

Brigida Hernandez, Mary Joyce Cometa, and Jessica Velcoff et al., “Perspectives of people with disabilities on

employment, vocational rehabilitation, and the Ticket to Work program,” Journal of Vocational Rehabilitation, vol. 27,

no. 3 (2007).

John C. Hennessey and L. Scott Muller, “The Effect of Vocational Rehabilitation and Work Incentives on Helping

the Disabled-Worker Beneficiary Back to Work,” Social Security Bulletin, vol. 58, no. 1 (Spring 1995), pp. 15-28.

Hennessey and Muller’s study focused on SSDI beneficiaries and was conducted prior to the implementation of SSA’s

work incentives programs.

Jody Schimmel, Bonnie O’Day, and Allison Roche et al., Evaluation of the Work Incentives Planning and Assistance

(WIPA) Program: Beneficiaries Served, Services Provided and Program Costs, Mathematica Policy Research, Inc.,

Final Report, Washington , DC, September 16, 2010, http://www.mathematica-mpr.com/publications/PDFs/disability/

WIPA_fnlrpt.pdf.

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autonomy to determine who they will accept as a client and many implement a screening process

that identifies the likelihood that a ticket holder will return to work. Therefore, there is a

disincentive for ENs to accept ticket holders who, in their view, may be unemployable without

the use of costly services. Some ENs face significant up-front costs associated with providing

employment services to ticket holders before receiving payments from SSA. ENs may focus on

those individuals that require the least amount of assistance, while individuals with the most

severe disabilities may be denied services by ENs.64

Return-to-Work Rates Among Beneficiaries and Ticket Holders

SSA annually reports the percentage of beneficiaries whose benefits were terminated in the

current year due to work.65 However, returning to work for an individual with a disability can be a

complex process that may not be captured in annual statistics.

SSA Measurement of Return-to-Work Rates

Researchers who have explored return-to-work rates among Social Security disability

beneficiaries observe that return-to-work rates—while low by many standards—are higher when

examining an individual’s progress toward gainful employment over several years (or

longitudinally), as opposed to the monthly or annual statistics that SSA generally reports, also

known as a cross-sectional statistic.66

For example, in any given year approximately one-half of 1% of SSDI beneficiaries leave the

disability rolls (or have their benefits terminated) because of work. Yet, this statistic includes a

large and entrenched group of beneficiaries who are added to, and remain on the disability rolls

from year to year with no prospects of employment. However, a longitudinal study of benefit

termination that followed a cohort of SSDI beneficiaries for 10 years from the time that they first

entered the disability rolls found that 3.7% (or more than 7 times the published SSA statistic) of

beneficiaries left the disability rolls within that time period.67 In addition, Ticket to Work

participants were more than two-and-a-half times more likely to leave the disability rolls for the

first time than non-participants.68

See David Stapleton, Gina Livermore, and Jesse Gregory, “Beneficiary Participation in Ticket to Work,” Journal of

Vocational Rehabilitation, vol. 27 (2007). The authors found that though 2004 (during the Ticket program’s infancy)

the majority of tickets were being assigned to state VR agencies, yet ticket holders assigned to ENs were more likely to

have earnings sufficient enough to exit the disability rolls. They conclude that this phenomenon may be reflective of

either (1) ENs only serving those with a higher likelihood of working or (2) ENs’ stronger focus on having their clients

achieve higher earnings.

For more information, see Social Security Administration, Annual Statistical Report on the Social Security Disability

Insurance Program, 2012, November 2013, Table 57, http://www.ssa.gov/policy/docs/statcomps/di_asr/2012/

di_asr12.pdf.

See Su Liu and David Stapleton, How Many SSDI Beneficiaries Leave the Rolls for Work? More Than You Might

Think, Mathematica Policy Research, Inc., April 2010, Number 10-01.

Ibid. While Liu and Stapleton’s study focused solely on the 1996 cohort of participating and nonparticipating SSDI

beneficiaries, a longitudinal strategy could have implications for more accurately measuring ticket holders’ progress

toward self-supporting employment.

Jody Schimmel, “Ticket to Work Participants and Other Beneficiaries Leaving the Disability Rolls Because of

Work,” Presented at the Center for Studying Disability Policy Research Forum, Washington, DC, May 19, 2010.

Schimmel found that in 2006, 2.4% of Ticket participants left the rolls for the first time compared with 0.9% of

nonparticipants and were more likely to remain off the rolls longer. SSDI ticket holders were also more likely to leave

(continued...)

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

Ticket Participation and Return-to-Work Rates Vary by Demographic Group

Some research has shown that return-to-work rates vary significantly depending on the age or

impairment of the ticket holder.69 Younger beneficiaries that may have many more working years

ahead of them and individuals with more recent work experience are more likely to return to

work.70 Conversely, individuals that are older and closer to retirement age or have experienced a

long-term separation from the workforce are the least likely to return to work.

In addition, individuals with sensory impairments including the deaf and blind are more likely to

attain gainful employment than individuals with more severe physical or neurological

impairments. Indeed, some research has found that individuals who are blind or have low vision

were more likely to assign their tickets than individuals with other disabilities.71

Most Tickets Are Assigned to State VR Agencies

One of the major purposes of Ticket to Work legislation was to expand the number of providers of

public and private employment services to provide choices for whom a ticket holder could seek

support. However, nearly 9 out of 10 tickets that are in use are assigned to state VR agencies. In

addition, GAO found that 20 ENs in 2010 (or less than 2% of all ENs) received the majority of

payments for assisting clients in achieving work goals.72 Ticket holders’ preference for assigning

their tickets to the state VR agencies may reduce the incentive for new ENs to enter the market to

compete for clientele.

Prior to implementation of the Ticket to Work program, state VR agencies managed all

employment support services for SSDI and SSI beneficiaries. Following Ticket to Work

legislation, ticket holders could choose to either seek services from ENs or state VR agencies, yet

the vast majority of tickets were continually assigned to the state VR agencies. The July 2008

regulatory changes introduced Partnership Plus, allowing ticket holders to seek assistance from

state VR agencies (which tend to be more adept at providing intensive vocational rehabilitation

services), and subsequently assign their tickets to ENs for additional employment services.

Growth in the number of ENs and the number of ticket holders assigning tickets to ENs has been

(...continued)

the rolls as compared to SSI ticket holders.

Jody Schimmel, Bonnie O’Day, and Allison Roche et al., Evaluation of the Work Incentives Planning and Assistance

(WIPA) Program: Beneficiaries Served, Services Provided and Program Costs, Mathematica Policy Research, Inc.,

Washington, DC, September 16, 2010.

For example, Liu and Stapleton’s longitudinal study of the 1996 SSDI cohort (see footnote 66) found that almost

10% of beneficiaries under 40 years old had benefits terminated within 10 years.

See Michele Capella-McDonnall, “Effectiveness of the Ticket to Work Program for Beneficiaries Who Are Blind or

Have Low Vision: Comparison with Other Beneficiaries,” Journal of Visual Impairment & Blindness, vol. 101, no. 5

(May 2007). The author shows that SSI beneficiaries who are blind or have low vision were approximately twice as

likely to assign their tickets than individuals with other disabilities. However, most tickets among these individuals

were assigned to state VR agencies as opposed to ENs, presumably because the blind are less likely to be employed at

earnings levels that are high enough to stop cash benefits, which is a disincentive for an EN to accept them as clients.

U.S. Government Accountability Office, Ticket to Work Participation Has Increased, but Additional Oversight

Needed, GAO-11-324, May 6, 2011, http://www.gao.gov/new.items/d11324.pdf (hereinafter, GAO-11-324).

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

observed, but ticket holders continue to have a clear preference for working with state VR

agencies.73

GAO Assessment of the Ticket to Work Program

In May 2011, GAO completed their latest audit of the Ticket to Work program. Although the

Ticket program has experienced growth among active ticket holders and ENs since inception,

GAO identified several deficiencies that could also be contributing factors to the

underperformance of the Ticket program. GAO specifically cited a need for increased managerial

oversight of ENs and a lack of TPRs performed by SSA on ticket holders.

Lack of Employment Network Oversight

GAO found that between FY2007 and July 2010, the number of ENs providing employment

support services to ticket holders and SSA payments to ENs increased dramatically, likely a result

of the July 2008 regulatory changes that offered additional financial incentives to ENs to

participate in the Ticket program.74 However, as mentioned earlier in this report, SSA payments

were concentrated among a small minority of ENs.

In addition, GAO cited issues related to “shared payments” between ENs and their working

Ticket to Work clients.75 Although EN payments to ticket beneficiaries had been deemed

acceptable by SSA as a way for ENs to supplement the earnings of their ticket clients for various

work-related purposes, this process was formalized by SSA in a new July 2008 regulatory

provision.76 GAO found that certain ENs were marketing these shared payments to potential

ticket clients as “work-support” payments that they would pass-on to the clients through an

agreement. Additionally, these ENs would specifically target ticket holders that were either

already working or ready to work, eliminating the need for the EN to provide any significant

employment services. According to a disability rights advocate interviewed by GAO, these ENs

essentially served as “middlemen” for SSA payments to ticket holders, dividing the payments

between themselves and their clients.

GAO also found deficiencies in (1) PMs’ ability to maintain up-to-date listings of ENs that were

still in business, (2) SSA accounting of services provided by each EN, and (3) an EN application

process that did not sufficiently vet unqualified ENs from being included in the network.

SSA Temporarily Suspended Timely Progress Reviews

SSA performs timely progress reviews (TPRs) to ensure that ticket-holders are making progress

toward attaining gainful employment that would eventually lead to reduced reliance or cessation

Ibid. According to a GAO analysis of Ticket to Work data, EN participation had increased from 1,514 to 1,603 in the

period following the July 2008 regulatory changes.

See GAO-11-324. According to GAO analysis of Ticket to Work data, the number of ENs increased from 1,514 to

1,603, while SSA payments to ENs increased from $3.8 million to $13 million during the same time period.

See GAO-11-324. ENs receive payments from SSA for ticket holders that have sufficient earnings. GAO found an

increasing number of ENs targeting ticket holders who were already working or able to find jobs without assistance and

using the shared payment approach.

See 20 C.F.R. §411.566.

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

of disability benefits. However, at the behest of ENs, SSA temporarily suspended TPRs in 2009.

During this time period, ticket holders were not subject to any oversight of their progress toward

self-supporting employment as SSA is prohibited from performing CDRs (as per Ticket

regulations).

GAO found evidence that this exemption was abused by some ticket holders that would activate

their tickets with an EN or state VR agency, but would not follow-through with seeking

employment support from the assigned organization or agency. Without the prospect of being

subject to a TPR, this strategy would protect ticket holders from any oversight, allowing

beneficiaries to continue receiving payments from SSA with little accountability. A TPR could

have served to identify these individuals, but SSA’s suspension of TPRs allowed this to go

unnoticed. Although SSA has since reinstated TPRs, GAO asserts that the resulting backlog will

be too overwhelming for SSA to effectively handle.

Impact of July 2008 Regulatory Changes

As noted earlier, SSA rolled out the Ticket to Work program in three phases from February 2002

to September 2004. Between August 2004 and January 2005, GAO conducted an audit of the

Ticket to Work program. In its March 2005 report, GAO noted less than 1% of the 9.5 million

beneficiaries who received a ticket assigned their ticket to an EN or state VR agency.77 In

addition, GAO found that just 386 of the 1,164-contracted ENs were accepting tickets.78 Although

the number of contracted ENs accepting tickets increased to 752 out of 1,514 in FY2007,

beneficiaries continued to assign their tickets primarily to state VR agencies.79

In a bid to attract more providers to the Ticket to Work program, SSA made substantial changes to

the EN payment system in July 2008. Specifically, SSA

•

increased the number of Milestone-Outcome payments,

•

lowered the ticket holder earnings threshold required to trigger a payment,

•

permitted ENs to serve a ticket holder who received services from a state VR

agency (Partnership Plus),

•

shortened the earnings period required to trigger a Milestone-Outcome payment,

•

increased the maximum payable Milestone-Outcome amount, and

•

increased the payment amounts for SSI-only ticket holders (see Table A-1).80

U.S. Government Accountability Office, Social Security Administration: Better Planning Could Make the Ticket

Program More Effectiv, GAO-05-248, March 2, 2005, p. 3, http://gao.gov/assets/250/245517.pdf.

Ibid.

GAO-11-324, pp. 11-13. In FY2007, only one-fifth of 1% of the beneficiaries who received a ticket assigned their

ticket to an EN.

See GAO-11-324, p. 8 and Jody Schimmel et al., Participant and Provider Outcomes Since the Inception of Ticket to

Work and the Effects of the 2008 Regulatory Changes, Mathematica Policy Research, Inc..: Center for Studying

Disability Policy, Final Report, July 25, 2013, pp. 8-9, http://www.mathematica-mpr.com/publications/pdfs/disability/

TTW_Part_Provid_Outcomes.pdf (hereinafter, Schimmel et al. 2013).

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

SSA believed that by increasing the financial incentives for ENs to participate in the Ticket to

Work program, the agency could “significantly enhance beneficiary choice and improve the

likelihood that beneficiaries would receive the most effective support.”81

EN Participation

Following the July 2008 regulatory changes, the number of ENs with at least one assigned ticket

during the calendar year nearly doubled, from 818 in 2007 to 1,600 in 2011 (Table 3). Note that

the metric “number of ENs with at least one assigned ticket during the calendar year” is different

from the point in time metric “number of ENs with assigned tickets” in Table 1. The percentage

of ENs receiving at least one payment also increased, from 23.0% in 2008 to 34.6% in 2011.

Furthermore, the share of ENs that reported accepting ticket assignments increased from 51% in

July 2008 to 60% in December 2011.82

Table 3. Distribution of EN Payments, Calendar Years 2002-2011

Calendar Years

Number of ENs

with at Least One

Assigned Ticket

During the

Calendar Year

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

175

375

591

714

776

818

1,003

1,275

1,500

1,600

Percentage Distribution of Total

ENs by Number of Payments

Received

0 Payments

89.1%

76.0%

68.5%

65.8%

72.7%

77.0%

77.4%

68.5%

60.7%

65.4%

1-10 Payments

10.9%

17.3%

23.2%

18.6%

12.6%

9.4%

10.7%

18.4%

19.3%

16.3%

11-50 Payments

5.3%

6.4%

12.7%

11.6%

10.3%

7.9%

9.4%

14.8%

13.6%

51-100 Payments

1.1%

1.2%

1.3%

1.4%

1.6%

2.2%

1.8%

3.1%

2.3%

101-250 Payments

0.3%

1.1%

1.2%

0.9%

1.1%

1.3%

251-500 Payments

0.3%

0.1%

0.4%

0.6%

0.5%

0.3%

0.6%

501-1,000

Payments

0.1%

0.4%

0.5%

0.3%

0.4%

Source: Table prepared by CRS from Table II.2 in Jody Schimmel et al., Participant and Provider Outcomes Since

the Inception of Ticket to Work and the Effects of the 2008 Regulatory Changes, Mathematica Policy Research, Inc..:

Center for Studying Disability Policy, Final Report, July 25, 2013, p. 14, http://www.mathematica-mpr.com/

publications/pdfs/disability/TTW_Part_Provid_Outcomes.pdf.

Notes: Subtotals may not equal 100% due to rounding.

The July 2008 regulatory changes also contributed to an increase in the number of new tickets

assigned under the EN payment system. As shown in Figure 3, the number of new tickets

assigned under the traditional state VR cost-reimbursement system increased only 19.4% between

Social Security Administration, “Amendments to the Ticket To Work and Self-Sufficiency Program,” 73 Federal

Schimmel et al. 2013, p. 13. Figure not shown in Table 3.

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

2007 and 2010 (from 62,000 to 74,000), whereas the number of new tickets assigned under the

EN payment system increased 566.7% during the same period (from 3,000 to 20,000).

Figure 3. New Tickets Assigned, Calendar Years 2004-2010

(in thousands)

100

EN Payment System

Thousands

Traditional State VR

Payment System

2005

2006

2007

2008

2009

2010

2004

Source: Graph prepared by CRS based on presentation materials from Jody Schimmel, “The 2008 TTW

Regulatory Changes: Effects on Participation and Participant Work Activity,” Mathematica Seminar, Washington,

DC, December 12, 2013, p. 28, http://www.disabilitypolicyresearch.org/Forums/20131212/combined.pdf.

Notes: New tickets assigned under the EN payment system include tickets assigned to state VR agencies as well

as tickets assigned to ENs. The traditional state VR payment system is known as “VR cost reimbursement.”

Most of the growth in in new tickets assigned under the EN payment system is the result of an

increase in tickets assigned under the Milestone-Outcome payment system. As Figure 4

illustrates, the number of new tickets assigned under the Milestone-Outcome payment system

increased 472.5% following the 2008 regulatory changes (from 3,417 in 2007 to 19,564 in 2010),

whereas the number of new tickets assigned under the Outcome-Only payment system decreased

53.5% (from 751 in 2007 to 349 in 2010). The increased use of the Milestone-Outcome payment

system may stem from the 2008 regulatory changes that increased the number and maximum

payable amount under the Milestone-Outcome payment system.83 The reduction in the earnings

period required to trigger a Milestone-Outcome payment may have also played a role in

increasing the number of new tickets assigned under the Milestone-Outcome payment system.84

See Jody Schimmel, “The 2008 TTW Regulatory Changes: Effects on Participation and Participant Work Activity,”

Mathematica Seminar, Washington, DC, December 12, 2013, p. 30, http://www.disabilitypolicyresearch.org/Forums/

20131212/combined.pdf.

Ibid.

Congressional Research Service

Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

Figure 4. New Tickets Assigned to ENs, Calendar Years 2004-2010

19,564

Milestone-Outcome

14,272

Outcome-Only

9,559

5,216

3,688

1,131

2004

1,057

2005

3,323

1,193

2006

3,417

751

2007

595

2008

545

2009

349

2010

Source: Graph prepared by CRS based on presentation materials from Jody Schimmel, “The 2008 TTW

Regulatory Changes: Effects on Participation and Participant Work Activity,” Mathematica Seminar, Washington,

DC, December 12, 2013, p. 29, http://www.disabilitypolicyresearch.org/Forums/20131212/combined.pdf.

Notes: New tickets assigned under the EN payment system include tickets assigned to state VR agencies as well

as tickets assigned to ENs.

Employment Outcomes

The impact of the 2008 regulatory changes on employment outcomes remains inconclusive, due

in part to the economic recession of 2007-2009. The weak labor market during this period may

have made it more difficult for ticket holders to obtain employment. According to a 2013 Ticket

to Work evaluation report from Mathematica, “it is not possible to disentangle the impacts of the

regulatory changes from the impacts of the recession and other external factors.”85

As shown in Table 4, post-2008 change participants worked an average of 18.7 fewer hours per

month than pre-change participants did. The likelihood of being employed, however, did not

significantly differ between pre and post-change participants. Post-change participants with a

ticket assigned to an EN were employed an average of 9.2 months longer than pre-change

participants under the EN payment system.

Schimmel et al. 2013, p. 69.

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

Table 4. Employment Outcomes Before and After the July 2008 Regulatory Changes

Employment Outcomes of Ticket to Work Participants

Pre 2008 Regulatory Change

Participants

Post 2008 Regulatory Changes

Participants (Difference)

All

State VR

Agency

All

State VR

Agency

Percentage Employed at Interview

24.0

23.7

24.1

-3.8

0.3

-4.7

Average Total Hours Worked Per

Month

98.6

108.1

95.8

-18.7a

-17.5a

-19.1a

Average Job Tenure (months)b

18.6

13.8

20.0

1.8

9.2a

-0.4

Source: Table prepared by CRS from Table 2 in Crystal Blyler, Denise Hoffman, and Gina Livermore, Ticket to

Work Participants: Then and Now, Mathematica Policy Research, Inc.: Center for Studying Disability Policy,

Number 13-02, May 2013, p. 3, http://www.mathematica-mpr.com/publications/pdfs/disability/

TTW_thenandnow_IB.pdf.

Notes: The pre-change sample was created using data from the 2005 and 2006 National Beneficiary Survey

(NBS). The post-change sample was created using data from the 2010 NBS.

Difference is statistically significant at the 0.05 level, two-tailed t-test.

Asked only of respondents who were working at interview.

Issues for Congress

The Ticket to Work program introduced a new dynamic in the way SSA interacts with Social

Security disability beneficiaries. Rather than simply making determinations of disability, ensuring

that beneficiaries receive benefits, and recertifying eligibility, Ticket to Work further tasks SSA

with facilitating a voluntary return-to-work program for the very same individuals who have been

deemed unable to work.

Since inception, SSA has faced several challenges in implementing the Ticket to Work program,

including creating a way to increase participation rates and expand the number and quality of ENs

that serve individuals with disabilities who are seeking to reenter the workforce. SSA has sought

to address many of these challenges by implementing changes to various program components

based on periodic assessments and recommendations.86 However, others have asserted that

In the past, the Ticket to Work & Work Incentives Advisory Panel identified several challenges related to the

administration of the Ticket program that restricted participation among ticket holders and ENs. For example, several

rules changes that SSA has implemented appeared as recommendations in one or more reports from the Advisory

Panel, including, but not limited to (1) expanding the program to include beneficiaries whose conditions were expected

to improve (Ticket to Work and Work Incentives Advisory Panel, Advice Report to the Commissioner Of Social

Security Administration on the Notice of Proposed Rulemaking for the Ticket to Work and Self Sufficiency Program,

Washington, DC, July 26, 2001, pp. 14-17, http://www.ssa.gov/work/panel/panel_documents/pdf_versions/

final_report.pdf.); (2) allowing state VR agencies and ENs to serve the same beneficiary and receive payment for

employment outcomes (Ticket to Work and Work Incentives Advisory Panel, 2005 Annual Report to the President and

Congress: Year Six, Washington, DC, March 2006, http://www.ssa.gov/work/panel/panel_documents/

Year6AnnualReport%20final_3-31-06.doc.); and (3) bringing greater equity between the total potential payments to

ENs for SSDI and SSI ticket holders (Ticket to Work and Work Incentives Advisory Panel, Advice Report to Congress

and the Commissioner of the Social Security Administration, The Crisis in EN Participation - A Blueprint for Action,

Washington, DC, February 2004, http://www.ssa.gov/work/panel/panel_documents/pdf_versions/

CrisisEnParticipation.pdf).

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Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

creating a more effective system to address the employment challenges of individuals with

disabilities requires greater integration of existing disability systems,87 tailoring rehabilitation

programs to the needs of each individual, and increasing the return-to-work incentives for people

who want to rejoin or remain in the workforce, but would find it difficult without ongoing

supports.88

Expand Early Intervention Services for Disabling Conditions

Some research suggests that Social Security disability programs have been slowly reactive, that

is, providing benefits after a disability has become long-term and more difficult to rehabilitate.89

Some evidence supports the notion that supplying an individual with the necessary medical and

rehabilitative support as soon as possible after the onset of a disability may help prevent the

condition from worsening over time and enable that individual to return to work sooner or avoid

leaving the workforce altogether.90

Recent attachment to the workforce is a significant factor in a disabled individuals’ ability to

return to employment following a disabling condition. In other words, the longer disabled

individuals are separated from the workforce, the less likely they will be able to return to gainful

employment due to factors that may include outdated skills, inadequate accommodations, or a

U.S. Government Accountability Office, Federal Disability Programs: More Strategic Coordination Could Help

Overcome Challenges to Needed Transformation, GAO-08-635, May 2008, http://www.gao.gov/new.items/

d08635.pdf.

U.S. General Accounting Office, Social Security Disability Insurance: Multiple Factors Affect Beneficiaries’ Ability

to Return to Work, HEHS-98-39, January 12, 1998, http://www.gao.gov/archive/1998/he98039.pdf.

See Bonnie O’Day and Monroe Berkowitz, “Disability Benefit Programs: Can We Improve the Return-to-Work

Record?,” in Handbook of Disability Studies, ed. Gary L. Albrecht, Katherine D. Seelman, and Michael Bury

(Thousand Oaks, CA: Sage Publications, 2001), pp. 633-641; Joann Sim, “Improving Return-to-Work Strategies in the

United States Disability Programs, with Analysis of Program Practices in Germany and Sweden,” Social Security

Bulletin, vol. 59, no. 3 (1999); and the testimony of Jane L. Ross, Director of Income Security Issues in the Health,

Education and Human Services Division at GAO in U.S. Congress, House Committee on Ways and Means,

Subcommittee on Social Security, Barriers Preventing Social Security Disability Recipients From Returning to Work,

105th Cong., 1st sess., July 23, 1997, Serial no. 105-61 (Washington: GPO, 1999).

O’Day and Berkowitz suggest that “[i]f there are services ... medical, technological or vocational, that can return the

person to work, they should be brought to bear before the applicant is thoroughly demoralized and persuaded that the

only feasible life is one on benefits” (p. 636). Citing practices in Sweden and Germany, the authors illustrate that

rehabilitative services are often provided much earlier in these countries once a worker has been identified as having an

impairment.

In her testimony, Ross highlighted “early intervention” as one of three practices that show the most promise in

returning individuals with disabilities to work, in addition to providing various types of return-to-work assistance and

using cash and health benefits as incentives for beneficiaries to work.

Using a cross-national comparison, Sim illustrates that the laws and policies of disability systems in Germany and

Sweden require assessments of full and partially disabling conditions as soon as possible. However, in the U.S.

individuals must be fully disabled to receive government assistance, yet “[t]he optimum period for early intervention

may have already passed by the time an applicant walks into the Social Security office” (p. 47). Sim further notes that

the application process for disability benefits under SSA provides no early referral for rehabilitation services and very

few referrals even after an individual receives benefits.

More recent studies have also touted the importance of early rehabilitative efforts. For example, see U.S. Government

Accountability Office, Federal Disability Programs: More Strategic Coordination Could Help Overcome Challenges

to Needed Transformation, GAO-08-635, May 2008, p. 15, http://www.gao.gov/new.items/d08635.pdf.

See Sophie Mitra and Debra Brucker, “The Early Intervention Project: An Innovative Initiative to Return Disability

Insurance Applicants to Work,” Journal of Disability Policy Studies, vol. 15, no. 3 (Winter 2004).

Congressional Research Service

Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

lack of motivation. These challenges are exacerbated by a recent economic downturn that has

resulted in higher unemployment rates for both the disabled and nondisabled alike.

Yet, for individuals with disabilities to receive the health insurance coverage, rehabilitative

services and employment supports available through the Ticket to Work program, they must first

go through the often protracted process of applying for benefits and demonstrating to SSA that

they are unable to work due to a long-lasting impairment. Additionally, if a claim is denied and an

individual files for a reconsideration or appeal, the application process can be further extended by

months or years in some cases. The timeline can be even longer for most SSDI claimants who

must sustain a five-month wait from disability-onset before they even become eligible to apply

for benefits.91

Congress may move to consider authorizing SSA to expand non-monetary benefits, including

medical and rehabilitative services to SSDI and SSI applicants who have not yet been approved

for full benefits.92 The lengthy application process for benefit payments may be hindering their

ability to take full advantage of the services that will enable them to eventually leave the benefit

rolls due to work. The cumulative passage of time that occurs from disability-onset, the benefits

application period and—for SSDI applicants—the additional five-month wait for eligibility,

disengages individuals from work, may increase the severity of any untreated medical conditions,

and will likely entrench their reliance on cash payments if and when a claim is eventually

approved. An early intervention process that focuses on providing targeted support soon after the

onset of a disability for an individual who has recently left the workforce, or is still on the job,

may allow that person to continue working or quickly return to work following a brief absence. A

successful early intervention effort could allow a claimant to continue working in at least a parttime capacity and receive reduced benefits or preclude the need for SSA to ever provide full

disability benefits.

Increase Management and Oversight of ENs

As mentioned earlier, nearly 9 out of 10 ticket holders assign their tickets to state VR agencies as

opposed to ENs. This may be a relic of the pre-Ticket to Work era when state VR agencies served

all SSDI and SSI beneficiaries. VR agencies are in the advantageous position of being well

established in the disability community and being authorized to offer any necessary services to

beneficiaries for which the agencies are reimbursed based on appropriated funds. In addition, VR

agencies currently have a performance measurement process in place that identifies the outcomes

of their services to clients. Ticket to Work legislation also gives VR agencies the added option of

“acting as ENs” through electing to be paid under a Ticket to Work payment system.

However, the services offered by ENs vary and according to GAO, Ticket to Work PMs do not

keep an accurate, up-to-date listing of which services are offered by which EN. ENs also have the

option of selecting which ticket holder they will serve, and are more likely to accept tickets from

individuals that are either working or ready to work, as opposed to state VR agencies which are

For more information, see CRS Report RS22220, Social Security Disability Insurance (SSDI): The Five-Month

Waiting Period for Benefits, by (name redacted).

For an analysis of reform proposals designed to promote accommodative and rehabilitative employment supports, see

CRS Report R43054, Social Security Disability Insurance (SSDI) Reform: An Overview of Proposals to Reduce the

Growth in SSDI Rolls, by (name redacted).

Congressional Research Service

Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

required to prioritize individuals with the most severe disabilities.93 This has possibly led to

service approaches by ENs in which the Ticket to Work revenue sharing provisions have become

out of line with the general goals of the Ticket program. In addition, SSA does not currently have

a system in place to measure EN performance as required by law.94

In line with GAO recommendations for the Ticket to Work program, Congress may consider

authorizing SSA to

•

develop a system to ensure that ticket holders are provided with accurate

information on the services that each EN provides so they can make informed

choices when seeking services;

•

determine whether EN incentives, especially the Ticket program revenue sharing

provisions, are consistent with the goals of the Ticket to Work program; and

•

develop performance measures to identify employment outcomes of ticket

holders served by ENs.

Develop Longitudinal Measures of Return-To-Work

Consideration may also want to be given for how SSA measures return-to-work rates. The current

“snapshot” measurement of beneficiaries whose benefits are terminated due to work is important

to identify due to annual appropriations decisions. However, this cross-sectional statistic includes

a large group of beneficiaries who are added to and remain on the disability rolls every year, but

will never work.95 Supplementing cross-sectional data with a longitudinal measurement of returnto-work rates of annual SSDI and SSI cohorts could help to provide a more accurate picture of

how SSA’s work incentives are enabling individuals with disabilities to return to the workforce.

While the Partnership Plus program was designed to allow state VR agencies and ENs to provide services to the

same individual, there is little evidence to suggest that ENs have benefitted from this arrangement.

42 U.S.C. §1320b-19(d)(2) and (6).

Paul O’Leary, “Implications of Recent Ticket to Work Evaluation Findings for Disability Policy,” Presented at the

Policy Research Forum Center for Studying Disabilities, Washington, DC, March 19, 2010.

Congressional Research Service

Appendix A. Compilation of Key Ticket to Work July 2008

Regulatory Changes

Table A-1. Side-by-Side Comparison of Key Ticket to Work July 2008 Regulatory Changes

Program

Component

Code of Federal

Regulations (C.F.R.)

Citation

Prior Regulation

Current Regulation

Changes Related to Ticket Holders

Return-to-Work

Concept

20 C.F.R. §411.525(a)(2)

Payments are only available once the ticket

holder’s earnings reach the Substantial Gainful

Activity (SGA) level.a

Creates a three-phase return-to-work process that addresses the

incremental and episodic nature of returning to work for individuals with

disabilities. Payment systems and SSA timely progress measures are

designed to facilitate a gradual return to self-sufficiency.

Ticket Eligibility

20 C.F.R. §411.125

Only SSI and SSDI beneficiaries aged 18-64

that are

All SSDI and SSI beneficiaries aged 18-64 are eligible.

SSA Performance

of Timely Progress

Reviews (TPRs) for

the purposes of

Ticket Holder

protection from

Continuing

Disability Reviews

(CDRs)

20 C.F.R. §411.180

•

Medical Improvement Not Expected

(MINE) and Medical Improvement

Possible (MIP), or

•

Medical Improvement Expected (MIE)

after having had at least one Continuing

Disability Review (CDR).

TPRs performed at

TPRs performed atb

•

24 months and required “active”

participation, but no work requirement,

•

12 months and requiring 3 months of work at TWP level or 60% of

full-time college credits,

•

36 months and required 3 months of

work above SGA level,

•

24 months and requiring 6 months of work at TWP level or 75% of

full-time college credits,

•

48 months and required 6 months of

work above SGA level,

•

60 months and required 6 months of

work above SGA sufficient for a zero

cash benefit, and

36 months and requiring 9 months of work at SGA level or

completion of 2-year program or an additional 1 year of full-time

college credit,

•

48 months and requiring 9 months of work at SGA level or an

additional 1 year of full-time college credit,

•

60 months and requiring 6 months at zero cash benefit level or an

additional 1 year of full-time college credit,

•

CRS-28

successive 12 month periods and

required 6 months of work above SGA

sufficient for a zero cash benefit.

Program

Component

Code of Federal

Regulations (C.F.R.)

Citation

Prior Regulation

Current Regulation

•

72 months and requiring 6 months at zero cash benefit level or

completion of 4-year college program, and

•

successive 12 month periods requiring 6 months at zero cash benefit

level.

Changes Related to EN Payments and Payment Systems

Outcome-only EN

Payment System

Milestone-Outcome

EN Payment

System

20 C.F.R. §411.525(a)(1)(i)

20 C.F.R. §411.550

20 C.F.R. §411.500(f)(1)

Monthly payments equal to 40% of the

payment calculation base (PCB) for up to 60

months when a ticket holder is not receiving a

cash benefit due to work activity above SGA.c

Up to four milestone payments can be made

to an EN for ticket holder earnings from

work above SGA in:

•

Milestone 1: One month equals 34% of

PCB payment to EN,

•

Milestone 2: Three months equals 68%

of PCB payment to EN,

•

Milestone 3: Seven months equals 136%

of PCB payment to EN, and

•

20 C.F.R. §411.525(a)(2)(ii)

CRS-29

Payments equal to 67% of the respective SSDI or SSI PCB for each month

a ticket holder’s earnings are sufficient for a zero cash benefit status:

•

for up to 36 months for SSDI beneficiaries ($758 for 2014). Total

potential payments equal $27,288 for 2014, or

•

for up to 60 months for SSI beneficiaries ($436 for 2014). Total

potential payments equal $26,160 for 2014.

PHASE 1:

Up to four Phase 1 milestone payments can be made to ENs equal to

120% of SSDI PCB ($1,357 for 2014) for ticket holder earnings from work

at the Trial Work Period (TWP) level ind

•

Milestone 1: One month,

•

Milestone 2: Three of the last six months,

•

Milestone 3: Six of the last 12 months, and

•

Milestone 4: Nine of the last 18 months.e

Milestone 4: 12 months equals 170% of

PCB payment to EN.

(No equivalent to Phase 2 in prior

regulations)

PHASE 2:

Monthly Phase 2 milestone payments can be made to ENs equal to 36% of

the respective SSDI or SSI PCB for each month of ticket holder gross

earnings at the SGA level (before deductions for Work Incentives) based

on the following:

•

up to 11 payments for SSDI ticket holders ($407 for 2014), or

•

up to 18 payments for SSI ticket holders ($234 for 2014).

Program

Component

Code of Federal

Regulations (C.F.R.)

Citation

20 C.F.R. §411.525(a)(2)(iv)

20 C.F.R. §411.545

20 C.F.R. §411.530

Total Potential

Payments to ENs

Effect of Ticket

Holder Recent

Work and Earnings

on EN Milestone

Payments

EN Overpayments

Due to Benefits

Eligibility Errors

CRS-30

20 C.F.R. §411.525(b)

20 C.F.R. §411.535(a)(1)(ii)

20 C.F.R. §411.555(c)

Prior Regulation

Up to 60 outcome payments can be made to

ENs equal to 34% of the respective SSDI or

SSI PCB for each month of ticket holder gross

earnings from work above SGA. Each

outcome payment made to an EN is reduced

by 1/60th of the total milestone payment.

•

Total potential payments of MilestoneOutcome approximately 85% of Outcomeonly.

•

Total potential payments for SSI ticket

holders are approximately 58% of total

potential payment for SSDI ticket holders

No Provision

ENs had to repay SSA if Ticket payments

were made and SSA retroactively determined

that the ticket holder was not eligible for

disability benefits.

Current Regulation

OUTCOME PHASE:

Monthly Outcome Phase payments can be made to ENs equal to 36% of

the respective SSDI or SSI PCB for each month of ticket holder earnings

sufficient for a zero cash benefit status for

•

up to 36 payments for SSDI ticket holders ($407 for 2014), or

•

up to 60 payments for SSI ticket holders ($234 for 2014).

•

Total potential payments for Milestone-Outcome approximately 90% of

Outcome-only.

•

Total potential payments for SSI ticket holders are approximately

96% of total potential payment for SSDI ticket holders. For SSDI and

SSI ticket holders in 2014, total potential payments for:

•

Milestone-Outcome equal $23,680 for SSI and $24,557 for SSDI or

concurrent beneficiaries, and

•

Outcome-only equal $26,160 for SSI and $27,288 for SSDI or

concurrent beneficiaries.

Some Phase 1 milestone payments may not be available to an EN if the

ticket holder worked above the TWP level during the 18 months prior to

Ticket assignment based on the following:

•

Milestone 1 payment is not available to an EN if ticket holder earnings

were above TWP level in the month prior to Ticket assignment,

•

Milestone 2 payment is not available to an EN if ticket holder earnings

in 3 of the last 6 months were above TWP level,

•

Milestone 3 payment is not available to an EN if ticket holder earnings

in 6 of the last 12 months were above TWP level, and

•

Milestone 4 payment is not available to an EN if ticket holder earnings

in 9 of the last 18 months were above the TWP level.

SSA will not seek an adjustment if a retroactive determination or decision

about a ticket holder’s right to benefits causes an overpayment to the EN.

Program

Component

EN Payments to

Beneficiaries

Code of Federal

Regulations (C.F.R.)

Citation

20 C.F.R. §411.566

Prior Regulation

Current Regulation

No Provision

Payments to beneficiaries are allowed. SSA treats EN payments to

beneficiaries as unearned income.

Other Changes Related to ENs

EN Reporting

Ticket be taken out

of Assignment

20 C.F.R. §411.145(a)

ENs were not required to report to the PM

when they wanted a Ticket taken out of

assignment.

ENs are required to report to the PM when they want a Ticket taken out

of assignment.

EN Qualification

for Department of

Labor (DOL)

Workforce

Investment Boards

(WIBs) and OneStop Centers and

American Indian

Vocational

Rehabilitation (VR)

Service Projects

20 C.F.R. §411.310

No Provision

WIBs and One-Stop Career Centers and American Indian VR Service

Projects are automatically qualified to be ENs, and are only required to

submit a streamlined contract to SSA. These entities must comply with

other general and specific requirements associated with being an EN.

Rules for a State VR Agency and EN Serving the Same Ticket Holder (PARTNERSHIP PLUS)

Rules for Ticket

Holders Assigning

Tickets to a State

Vocational

Rehabilitation (VR)

Agency

20 C.F.R. §§411.166(a),

411.135, 411.140,

411.535(a)(iii) & 411.585

A State VR agency could elect to be paid

under Cost Reimbursement rules, but Ticket

must be assigned to the VR agency to be

eligible to submit for Cost Reimbursement.

No payments allowed under either EN

payment system if VR had ticket assigned

under Cost Reimbursement.

If a ticket holder assigns a ticket to a State VR agency, then:

1. the VR agency provides services under Cost Reimbursement method,

then a new “in use-SVR” status provides CDR protection for ticket

holder, but

2. the ticket holder cannot assign the Ticket to an EN while VR has an

open case. CDR protection is extended for 90 days after VR case closure,

and

3. the VR and EN can both receive payment sequentially, VR under Cost

Reimbursement and EN under the elected EN payment system after VR

case closure and assignment of Ticket to the EN. An EN who accepts a

ticket after VR achieves an employment outcome and closes the case is

only eligible for Phase 2 Milestone-Outcome and Outcome-only payments.

Phase 1 Milestone–Outcome payments will not be available.

Source: CRS table with information from SSA, “Amendments to the Ticket to Work and Self-Sufficiency Program; Final Rule,” 73 Federal Register 29324, May 20, 2008.

Payment estimates are based on SSA regulations.

CRS-31

For 2014 the substantial gainful activity (SGA) levels are $1,070 for individuals with disabilities other than blindness and $1,800 for individuals who are blind.

20 C.F.R. §411.166(h). A 10% variance tolerance applies.

20 C.F.R. §411.500. For 2014, the Payment Calculation Base (PCB) is $1,130.89 for SSDI and $650.44 for SSI. See http://www.socialsecurity.gov/OACT/COLA/

pcb.html.

For 2014, the income level for a Trial Work Period (TWP) is $770.

20 C.F.R. §411.525(a)(2)(i). Payment of Milestone 4 requires substantial completion of services outlined in the ticket holder’s Individualized Work Plan (IWP).

CRS-32

Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

Appendix B. Description of Employment Network

Payment Systems

Milestone-Outcome EN Payment System

Four Phase 1 Milestones

Four Phase 1 milestones are available to compensate ENs for initial efforts that a beneficiary

makes toward self-supporting employment. Milestone completion is based on earnings that a

beneficiary makes above the TWP threshold. All Phase 1 payments to ENs are equal to 120% of

the national average disability payment under SSDI (referred to as the “payment calculation base”

or PCB) for ticket holders with earnings from work based on the following schedule:96

•

Milestone 1: A beneficiary has worked for one calendar month and has gross

earnings from employment for each of those months that are above the TWP

threshold.

•

Milestone 2: A beneficiary has worked for three calendar months within a sixmonth period and has gross earnings from employment for each of those months

that are above the TWP threshold. The month used to meet the first milestone can

be included in the three months used to meet the second milestone.

•

Milestone 3: A beneficiary has worked for 6 calendar months within a 12-month

period and has gross earnings from employment for each of those months that are

above the TWP threshold. Any of the months used to meet the first and second

milestones can be included in the 6 months used to meet the third milestone.

•

Milestone 4: A beneficiary has worked for 9 calendar months within an 18-month

period and has gross earnings from employment for each of those months that are

above the TWP threshold. Any of the months used to meet the first 3 milestones

can be included in the 12 months used to meet the fourth milestone.

See 20 C.F.R. §411.500. For 2014 the PCB for SSDI is $1,130.89 per month and $650.44 per month for SSI. In

December of each year, SSA calculates a PCB for both the SSDI and SSI programs for the forthcoming year.

For SSDI or concurrent beneficiaries, the PCB is determined by the average monthly disability insurance benefit

payable for months during the preceding calendar year to all beneficiaries who are in current pay status for the month

for which the benefit is payable. For example, in 2013, there was an average of 8,893,675 SSDI beneficiaries per month

with total average monthly payments amounting to $10,057,808,483. Therefore, the 2014 SSDI PCB (or the average

monthly payment per beneficiary in 2013) is $1,130.89 (i.e., $10,057,808,483 divided by 8,893,675).

For SSI beneficiaries, the PCB is determined by the average monthly payment of SSI benefits (excluding state

supplementation) for months during the preceding calendar year to all beneficiaries who (1) have attained age 18 but

have not attained the age of 65, (2) are not concurrent SSDI/SSI beneficiaries, and (3) are in current pay status for the

month for which the payment is made. For example, in 2013 the average number of SSI beneficiaries each month

meeting the PCB criteria was 3,345,895, and the average total monthly payments for these individuals was

$2,176,308,201. Therefore, the 2014 SSI PCB (or the average monthly payment per beneficiary in 2013) is $650.44

(i.e., $2,176,308,201 divided by 3,345,895).

For PCBs in prior years, see http://www.socialsecurity.gov/OACT/COLA/pcb.html.

Congressional Research Service

Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

Phase 2 Milestones

Following the successful completion of Phase 1 milestones and as a ticket holder’s earnings

progress toward self-sufficiency, ENs can become eligible to receive a series of Phase 2 milestone

payments. The earnings standard is increased to the SGA threshold for Phase 2 milestones

($1,070/month or $1,800/month if blind for 2014) as opposed to the lower TWP threshold

($770/month for 2014) under Phase 1 milestones. Monthly payments to ENs are equal to 36% of

the respective PCB for SSDI ($1,130.89 for 2014) or SSI ($650.44 for 2014) for each month that

a ticket holder’s gross earnings from work are above SGA based on the following schedule:97

•

up to 11 payments for SSDI ticket holders ($471 for 2014), or

•

up to 18 payments for SSI ticket holders ($234 for 2014).

Outcome Phase

If a ticket holder’s work activity satisfies the requirements for both Phase 1 and Phase 2

milestones under the Milestone-Outcome payment system, ENs can potentially collect additional

monthly payments in an “outcome” phase for ticket holders that have earnings sufficient for a

zero cash benefit status. That is, the ticket holder has sustained earnings long enough at the SGA

level that they are no longer receiving any cash payments from SSA. For ticket holders that

qualify for the outcome phase, ENs can receive additional payments that are also equal to 36% of

the respective PCB based on the following schedule:

•

up to 36 payments for SSDI ticket holders ($407 for 2014), or

•

up to 60 payments for SSI ticket holders ($234 for 2014).

Outcome-Only EN Payment System

Under the Outcome-only payment system, ENs can receive payment for ticket holders that have

earnings sufficient for a zero cash benefit status. Payments for SSDI ticket holders can be made

for up to 36 months and up to 60 months for SSI ticket holders. Payments to ENs are equal to

67% of the PCB for SSDI ($758 for 2014) and SSI ($436 for 2014).

Payments to ENs are determined based on ticket holders’ gross earnings before any applicable deductions for work

incentives.

Congressional Research Service

Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

Appendix C. SSDI and SSI Employment Supports

Provision

Description

SSDI, SSI or Concurrent Eligibility

Subsidies and Special Conditions

A subsidy is support provided by an individual’s employer that may result in the

beneficiary receiving more pay than the actual value of the services performed.

Special conditions refer to support provided by an employer or other entity.

Because of a specific support, a beneficiary may receive more pay than the actual

value of the services performed.

SSA does not consider subsidies or special conditions when figuring payment

amounts and will only use earnings that represent the real value of the work

performed to decide if the work is at the SGA level.

Unsuccessful Work Attempt

(UWA)

A UWA is an effort to do substantial work, in employment or self-employment,

which a beneficiary stops or reduces to below the SGA level after a short time

(6 months or less) because of (1) an impairment or (2) the removal of special

conditions related to an impairment and essential to the further performance of

work.

When SSA makes an SGA decision to determine if disability payments continue

or cease because of work, SSA does not count earnings during a UWA.

Impairment-Related Work

Expenses (IRWE)

If SSA decides that a beneficiary’s “countable earnings” demonstrate

performance of SGA, SSA will deduct the cost of certain impairment-related

items and services from their gross earnings that the beneficiary needs to work.

Continued Payment under

Vocational Rehabilitation or

Similar Program (Section 301)

If SSA finds that a beneficiary no longer has a disabling impairment due to

medical improvement, payments usually stop. However, if the individual is

participating in an appropriate program of vocational rehabilitation or similar

services, benefits may continue until participation in the program ends.

Expedited Reinstatement (EXR)

EXR is a safety net for people who successfully return to work and lose their

entitlement to SSDI or SSI benefits and payments. If cash payments ended

because of work and earnings, and the individual stops working within 5 years of

when their benefits ended, SSA may be able to start benefits again.

SSDI Eligibility Only

Trial Work Period (TWP)

The TWP allows beneficiaries to test their ability to work for at least nine

months. During a TWP, beneficiaries will receive full SSDI benefits regardless of

how high their earnings might be as long as they report their work activity and

have a disabling impairment.

Extended Period of Eligibility

(EPE)

The EPE begins the month after the TWP ends, even if the beneficiary is not

working that month. The first 36 months of the EPE is the re-entitlement period.

The EPE allows an individual to resume receiving benefits if they are not working

during the re-entitlement period.

During the 36-month re-entitlement period, a beneficiary will get benefits for

months that their earnings or work activities are below the substantial gainful

activity (SGA) level as long as they continue to have a disabling impairment. SSA

suspends benefits for months that earnings are above the SGA level.

Unincurred Business Expenses

(Self-Employment)

Unincurred Business Expenses are contributions made by others to a

beneficiaries’ self-employment business effort. For example, if the state VR

agency gives an individual a computer for their business, or a friend works for a

beneficiary’s business as unpaid help, these are unincurred business expenses.

SSA generally follows the Internal Revenue Service (IRS) rules to figure net

earnings from self-employment. The IRS only allows individuals to deduct

expenses actually paid or incurred debt. When SSA makes an SGA decision, they

also deduct unincurred business expenses from net earnings to attain an

Congressional Research Service

Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

accurate measure of the value of a beneficiary’s work.

Continuation of Medicare

Coverage

Most persons with disabilities who work will continue to receive at least 93

consecutive months of Hospital Insurance (Part A); Supplemental Medical

Insurance (Part B), if enrolled; and Prescription Drug coverage (Part D), if

enrolled, after the 9-month TWP. Beneficiaries do not pay a premium for Part A.

Although cash benefits may cease due to work, health insurance coverage will

continue.

Medicare for Persons with

Disabilities Who Work

After premium-free Medicare coverage ends due to work, some persons who

have returned to work may buy continued Medicare coverage, as long as they

remain medically disabled. Some persons with low incomes and limited

resources may be eligible for state assistance with these costs under various

Medicare Savings Programs. A state Health and Human Services agency makes

the determination about whether a beneficiary qualifies for this assistance.

SSI Eligibility Only

Earned Income Exclusion

SSA does not count the first $65 of the earnings that a beneficiary receives in a

month, plus one-half of the remaining earnings. In other words, SSA counts less

than one-half of earnings when figuring SSI payment amounts.

This exclusion is applied in addition to the $20 general income exclusion. SSA

applies the $20 general income exclusion first to any unearned income that a

beneficiary may receive.

Student Earned Income Exclusion

If a beneficiary is under age 22 and regularly attending school, SSA does not

count up to $1,750 of earned income per month (for 2014) when figuring SSI

payment amounts. The maximum yearly exclusion is $7,060 for 2014. These

amounts are usually adjusted each year based on the cost-of-living.

Plan to Achieve Self Support

(PASS)

A PASS allows a beneficiary to set aside other income besides SSI and/or

resources for a specified period of time so that they may pursue a work goal.

For example, if a beneficiary receives SSDI, wages, or other income, they could

set aside some of that money to pay expenses for education, vocational training,

or starting a business as long as the expenses are related to achieving a work

goal.

SSA does not count the income set aside under a PASS when figuring SSI

payment amounts. SSA also does not count the resources set aside under a

PASS when determining initial and continuing eligibility for SSI.

Property Essential to Self-Support

(PESS)

SSA does not count some resources that are essential to self-support when

deciding continuing eligibility for SSI.

Special SSI Payments for Persons

Who Work – Section 1619(a)

A beneficiary can receive SSI cash payments even when their earned income

(gross wages and/or net earnings from self-employment) is at the SGA level. This

provision eliminates the need for the TWP or EPE Eligibility under SSI.

Reinstating SSI Eligibility Without

a New Application

If a beneficiary has been ineligible for SSI and/or Medicaid for any reason other

than work or medical recovery, SSA may be able to restart SSI cash payments

and/or Medicaid coverage within 12 months without a new application.

Beneficiaries should contact SSA about restarting benefits when their situation

changes.

Special benefits if you are Eligible

Under 1619 and Enter a Medical

Facility

If a beneficiary is working and eligible under Section 1619, they may receive an

SSI cash benefit for up to two months while in a Medicaid facility or a public

medical or psychiatric facility.

Medicaid While Working—

Section 1619(b)

If a beneficiary returns to work and meets certain qualifications, their Medicaid

coverage can continue, even if earnings (alone or in combination with other

income) become too high for an SSI cash payment.

Congressional Research Service

Ticket to Work and Self-Sufficiency Program: Overview and Current Issues

Appendix D. Acronyms

BOND

Benefit Offset National Demonstration

BOPD

Benefits Offset Pilot Demonstration

BPAO

Benefits Planning Assistance and Outreach

CBO

Congressional Budget Office

CDR

Continuing Disability Review

EPE

Extended Period of Eligibility

EXR

Expedited Reinstatement

Employment Network

FBR

Federal Benefit Rate

GAO

Government Accountability Office

IWP

Individualized Work Plan

PABSS

Protection and Advocacy for Beneficiaries of Social Security

PCB

Payment Calculation Base

Program Manager

PTFEAD

Presidential Task Force on the Employment of Adults with Disabilities

SGA

Substantial Gainful Activity

SSI

Supplemental Security Income

SSDI

Social Security Disability Insurance

TPR

Timely Progress Review

TTW

Ticket to Work

TWP

Trial Work Period

Vocational Rehabilitation

WIPA

Work Incentives & Planning Assistance

Author Contact Information

(name redacted)

Analyst in Income Security

[redacted]@crs.loc.gov, 7-....

Acknowledgments

This report was originally written by (name redacted). All questions should be addressed to the current

author.

Congressional Research Service

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