CSAVR PRINCIPLES
The Public VR Program and
The Ticket
to Work and Work Incentives Improvement Act
What does the Ticket to Work legislation mean for the Public VR Program?
The Ticket to Work is one piece of a comprehensive legislative initiative seeking to maximize and encourage employment and self-sufficiency for individuals with disabilities. The Ticket to Work legislation is composed of three titles. The Ticket to Work and Self-Sufficiency Program is only the first title of the Act. The two additional titles of the legislation provide some of the most progressive changes in the Social Security disability programs in many decades. These include expansion of health care options, changes in work incentives, and many opportunities for states to demonstrate creativity and innovation through grant programs. Grant opportunities centered on benefits planning and systems change signify a positive emphasis in public disability policy that supports individuals with disabilities as they enter competitive employment. The Ticket to Work and Work Incentives Improvement Act (TWWIIA), with all of its various components, is a significant piece of disability legislation which can assist the Public VR Program in encouraging beneficiaries to seek employment opportunities.
The Public VR Program continues to seek ways to be the most responsive and effective system to support the employment goals of individuals with disabilities. State VR agencies effectively serve tens of thousands of SSI/SSDI individuals each year Historically, the number of SSI/SSDI beneficiaries who leave the rolls of SSA, due to Vocational Rehabilitation assistance, has steadily increased. In fiscal year 1983, SSA processed 1,813 claims for VR Cost Reimbursement. In fiscal year 2002, that number grew to 13,952. Though noteworthy, this only represents a fraction of SSI/SSDI beneficiaries who enter the workforce. There are many beneficiaries who are successfully placed in employment with assistance from the Public VR Program yet continue to receive a cash benefit from SSA. However, a majority of individuals on SSI and SSDI never seek assistance from the Public VR Program for fear of losing cash benefits and health care coverage. TWWIIA offers additional tools that VR can use to encourage greater self-sufficiency for SSI and SSDI beneficiaries thereby assisting more individuals to enter the workforce and leave the Social Security rolls.
The Ticket to Work and Self-Sufficiency Program provides additional opportunities and requirements for the Public VR Program, but does not change the fundamental requirements of Title I of the Rehabilitation Act.
The Public VR Program is required
by the Rehabilitation Act to serve all eligible consumers,
subject to the state’s Order of Selection criteria, if
applicable. Whereas, Employment Networks may choose who they
serve under the Ticket Program. This gives the Public VR Program
a unique role in the Ticket to Work Program in ensuring that
services are available to a diverse population of individuals
with disabilities and, particularly, to beneficiaries with the
most significant disabilities.
The Rehabilitation Act includes a
presumption of eligibility for beneficiaries on the SSI or SSDI
program, provided the individual intends to work. Under the
Ticket program, all ticket holders who intend to work will be
eligible for VR services, in accordance with Order of Selection
criteria when the state VR agency has established such an order.
Informed choice is a guiding principle and a statutory requirement for the Public VR Program. This is important in the Ticket to Work program where beneficiaries have other options for seeking vocational rehabilitation services. While marketing the services of the Public VR Program is encouraged, given Vocational Rehabilitation’s strong history and knowledge of preparing individuals with disabilities for employment, the choice of what to do with the Ticket belongs to the consumer. CSAVR supports each state VR agency developing ticket assignment procedures that satisfy the principles of informed choice and confidentiality.
The Ticket to Work presents both opportunities and challenges for the Public VR Program.
Opportunities:
TWWIIA provides additional options
and opportunities for the Public VR Program to encourage
employment leading to self-sufficiency. This involves focusing
on employment opportunities for SSI and SSDI beneficiaries to
earn incomes substantial enough for their cash benefits to stop.
Benefits counseling services have been introduced through the
Ticket legislation and are an integral component of this
approach.
TWWIIA provides an opportunity for
the Public VR Program to expand partnerships within the
community. There will be Employment Networks who wish to refer
to VR for services, those who wish to partner with VR to enhance
services, those who wish to maintain the current relationship,
and those who may want to partner in all of these ways. Some of
these relationships will require a formal agreement, while
others will not. The key purpose of the partnerships is to
increase opportunities for beneficiaries to engage in employment
and become self-sufficient.
TWWIIA provides an opportunity for
the Public VR Program to educate staff and the community on
recent changes in federal law that supports competitive
employment for individuals with disabilities. Some of these
changes include expansion of health care options, opportunities
to quickly return to cash benefits after a work attempt was not
sustainable, and a new federal focus on individuals with
disabilities as a critical component of a national workforce.
Assisting more individuals to enter competitive employment at higher wages will also expand the amount of reimbursement and outcome payments from Social Security. This expansion of income will ultimately increase VR’s capacity to serve eligible individuals.
Challenges:
The Public VR Program is required
to participate in the Ticket to Work Program. As with any new
program, there are additional requirements. Most of these
requirements are procedural, and include things such as
identification of ticket holders, tracking ticket assignment,
MIS changes, coordinating staff and agency efforts, negotiating
cooperative agreements with Employment Networks and deciding
between the ticket payment options and the traditional cost
reimbursement system.
Educating staff and the community
presents an opportunity for the Public VR Program but also
represents a challenge. In order to effectively communicate the
message, the VR agency needs to develop expertise on the ticket
program and how it impacts various stakeholders. Identifying and
prioritizing education for agencies and community groups is a
challenge, and the number of potential stakeholders can create
additional work and associated costs for the Public VR Program.
Beneficiaries eligible to receive
tickets may have more significant disabilities and higher
average service costs. Employment Networks serving under the
Ticket Program are permitted to choose who they want to serve.
For this reason, many beneficiaries with costly service needs
(e.g., expensive assistive technology, personal assistance,
etc.) may end up seeking assistance from the Public VR Program.
The Rehabilitation Act requires state agencies to serve all
eligible individuals, subject to the state’s order of selection
criteria, where applicable. In addition, the Public VR Program
may serve SSI/SSDI beneficiaries who assign their tickets to
other employment networks, which could potentially preclude VR
from recovering the cost of services from SSA.
In order for TWWIIA to be
successful, there must be access to ongoing benefits planning
services. Without an understanding of how the TWWIIA provisions
impact an individual’s benefits, it is unlikely that individuals
receiving SSI or SSDI will seek employment opportunities leading
to economic independence. There are limited resources for these
services, but it is clear that good benefits planning requires a
specialist and cannot be added to the job of a rehabilitation
counselor or other human service professionals.
Another critical component to the success of the Ticket to Work and Work Incentives Improvement Act is the full implementation of all the work incentive provisions. A number of these work incentives have already been established by the Social Security Administration. However, two work incentives that are critical and must be implemented at the state level include Medicaid buy-in and personal assistance services. Without these incentives, the Ticket program will be less attractive to beneficiaries. CSAVR encourages state Vocational Rehabilitation agencies to work with the Medicaid agency in their state to develop these work incentives.
