Recent Program Implementation
This chapter describes the recent activities of SSA and the Program Manager in rolling out and implementing the TTW program. The major topics addressed in this chapter include the overall status of Phase 3 program implementation; development of SSA rules, regulations, and other guidance on TTW; the TTW call center; marketing and outreach plans and activities; EN enrollment; training and technical assistance; system enhancements; payment processing; the status of efforts to assess whether beneficiaries are making “timely progress”; and various other initiatives that relate to TTW. Most of the information presented in this chapter is drawn from interviews with SSA and Program Manager officials, but we also include comments from ENs where relevant.
Implementation of Phase 3 of Ticket rollout is now complete. As of the end of April 2005, more than 90,000 Tickets had been assigned by beneficiaries to SVRAs and ENs, and SSA had made over $1.5 million in payments (SSA 2005). The agency has also developed the rules, regulations, and other guidance needed to operate the program. Plans to increase marketing and outreach to beneficiaries are underway. The Program Manager has initiated new EN capitalization resource materials to help ENs pay for the upfront costs of serving TTW clients. SSA has also significantly enhanced its management information systems, such as eWork, to help process pay stubs and other beneficiary documentation. Because SSA received no special appropriation for these efforts, it implemented TTW as part of all its other activities and priorities.
Despite important progress, there are still problems to overcome. Certain regulations required by the Ticket Act have not been promulgated. It has become more difficult to recruit ENs, and more and more of them are dropping out of the program. Additional marketing efforts under discussion since Phase 1 have yet to be implemented, and payment processing is still problematic.
A. ROLLOUT SCHEDULE
Beginning in November 2003, Phase 3 of TTW was implemented in the final 17 states and U.S. territories (Table VII.1). (See Appendix A for an overall timeline of Ticket implementation and a list of states by phase.) The schedule for mailing Tickets was the same as the one used during Phase 2. Ten percent of Phase 3 Ticket-eligible beneficiaries were mailed Tickets each month from November 2003 through September 2004 based on the terminal digit of the eligible beneficiary’s Social Security number.1 Batch mailings were scheduled three times per month to ease the Program Manager’s call center workload in responding to telephone inquiries from beneficiaries after the Tickets were mailed. In addition, Tickets were mailed to individuals who filed new disability claims across the country during this period. In total, about 3.5 million beneficiaries received Tickets during Phase 3. The Program Manager will continue to mail approximately 75,000 Tickets per month to people newly awarded disability benefits or otherwise newly eligible for TTW nationwide.
Table VII.1. States and Territories Included in Phase 3 Ticket Implementation
|Hawaii||North Carolina||Washington||Northern Mariana Islands|
|Idaho||Ohio||West Virginia||Puerto Rico|
B. RULES, REGULATIONS, AND OTHER GUIDANCE
SSA continues to develop and issue regulations as mandated in TTW legislation; however, promulgation of many final regulations has been delayed. In August 2003, SSA issued a Notice of Proposed Rule Making (NPRM) on the Continuation of Benefit Payments to Certain Individuals Who Are Participating in a Program of Vocational Rehabilitation Services, Employment Services, or Other Support Services (Section 301 of the Ticket act). The proposed rule, 68 FR 45180, provides that, if a continuing disability review (CDR) is conducted with a beneficiary who is participating in an approved plan of rehabilitation, including an individual work plan (IWP) under TTW, benefits will not be terminated until the beneficiary completes the program. The rule makes it clear that TTW participants will be exempt from a CDR based on disability. The public comment period closed on September 30, 2003. SSA was reviewing comments as this report was drafted in spring 2005.
In October 2003, SSA published proposed regulations on expedited reinstatement of benefits (Section 112 of the Ticket Act). This provision, sometimes referred to as “easy back on,” would allow some beneficiaries who have left the rolls for work to have their benefits reinstated without filing a new application. SSA has received public comments on this provision and was in the final review process in spring 2005.
SSA is also drafting regulations on Exemption of Work Activity as a Basis for a Work Continuing Disability Review (Section 111 of the Ticket Act). This means that no CDR may be scheduled solely because of an individual’s work activity. In other words, work activity cannot be used as evidence that the individual is no longer disabled and eligible for SSI or DI benefits. The NPRM, signed by the SSA commissioner on June 4, 2004, was under review by the Office of Management and Budget in spring 2005.
SSA is drafting a final rule to refer eligible beneficiaries to agencies other than SVRAs for rehabilitation services. Under previous regulations, SSA was required to refer all beneficiaries to an SVRA for rehabilitation services. The TTW legislation repealed this requirement and substituted referral to an EN under TTW “or another program of vocational services, employment services, or other support services” (Sec. 1615). SSA has repealed the referral requirement to SVRAs but has not initiated a referral process to eligible ENs while the rules are being considered.
According to the SSA Quarterly Update on the Ticket to Work and Work Incentives Improvement Act Implementation (February 2005), the agency is also considering proposed rules that would revisit several issues in the TTW final rules published in December 2001, including Ticket eligibility, SVRA participation, and EN payment provisions. Once the NPRM is published, SSA intends to hold town meetings with beneficiaries and other stakeholders to obtain their feedback on the proposed changes. Details on what SSA is considering were not included in the update.
C. THE TTW CALL CENTER
The Program Manager continues to operate the call center, answering inquiries from beneficiaries, ENs, SVRAs, and the general public. The center received about 270,000 calls during the first 10 months of 2004. Most calls come from beneficiaries seeking information on how participation affects their benefits and on the ENs serving their areas. Other calls come from EN and SVRA representatives who want to find out whether a beneficiary’s Ticket is assignable, confirm that a Ticket has been assigned, or discuss information required for payment. Although the call center has 62 staff, Program Manager interviewees said that the center had some trouble handling the volume of calls, which totaled about 65,000 to 75,000 in some months during the Phase 3 Ticket mailing.
The EN representatives we interviewed offered mixed reviews of the call center’s performance. On the positive side, some ENs were pleased with the information and assistance they received, particularly during the application process; others said call center staff were helpful later on in answering questions about the payment process. Many said they frequently called to obtain information or solve a problem; others said they appreciated the occasional calls from the Program Manager staff to identify any other ongoing issues. A few EN representatives singled out particular staff members as reliably helpful.
On the negative side, however, over half of the EN representatives we interviewed said that the Program Manager staff had occasionally either provided inconsistent information or communicated poorly, although some said that the quality of service had significantly improved in the past year. Several EN representatives believe that the inconsistent information was a result of the fact that different call center staff gave different answers to the same question. According to one EN representative, it was a question of “never being able to get the same person twice.” For example, some EN representatives complained about submitting virtually identical paperwork on different clients and having it accepted by one person but rejected by another. Some ENs complained about staff turnover at the Program Manager call center and thought that new staff did not yet have enough training to give reliable responses. A few ENs expressed an interest in having a primary contact person they could rely on “to develop consistency and a rapport.” Also, a few ENs thought that the Program Manager had not done enough to explain TTW to beneficiaries—for example, that a Ticket does not entitle a beneficiary to a job. Similarly, a couple of ENs thought that the Program Manager should provide Ticket holders with information about the types of disabilities or the specific area of a state an EN will serve. Some EN representatives complained that beneficiaries did not have correct information about TTW in general and about their ENs in particular.2
In response to these criticisms, Program Manager staff said that, although they try to assign one contact person to each EN, staff turnover makes it difficult to sustain such an arrangement. As a result, EN representatives may call and request to speak with their contact or leave messages for specific staff members, but they may be routed to someone else if the person is busy or not on duty. Program Manager staff also asserted that call center staff can provide callers only with the list of national ENs or ENs in their states, although representatives of SSA’s Office of Employment Support Programs (OESP) assert that it is possible for the Program Manager to provide lists of ENs by county or zip code. In any case, the Program Manager representatives assert that matching beneficiaries to ENs is outside the scope of their contract. It is up to beneficiaries, they said, to peruse the list carefully to determine which clients and geographic locations each EN serves. The Program Manager also said it encourages ENs to be honest about which clients they can assist and not to “oversell” their services. At the time of our interview in September 2004, the Program Manager planned to reassess call center staffing levels during October and November, when Tickets would be mailed to new awardees only. Program Manager staff may be able to spend more time with each caller as the number of calls diminishes.
D. MARKETING AND OUTREACH
SSA and Program Manager staff are conducting a variety of marketing and outreach activities to address the low EN and beneficiary participation rates.
1. Outreach to ENs
The Program Manager began recruiting ENs for Phase 3 early in 2003 and continued intensive outreach throughout the following summer. To date, the first wave of outreach to ENs in all states and territories is complete. Since TTW was launched, the Program Manager has conducted 91 recruitment fairs attended by almost 8,000 people across the country. In fall 2003, Program Manager staff attempted to boost EN participation across the country by contacting about 50,000 organizations with the potential to provide TTW services, telling them about TTW progress, including changes in the payment certification procedure, and noting that 7 million people had Tickets and that many were looking for services and jobs. Program Manager staff said that, to date, this intensive campaign has generated only mild interest in TTW among those contacted.
Current marketing efforts involve presentations at conferences and events hosted by other organizations; in total, Program Manager staff have presented at about 350 events since TTW was established. Those we interviewed noted that nontraditional providers, which are defined as entities whose services and programs are not targeted solely to people with disabilities, constituted a majority of attendees at the conferences.
SSA has contracted with Booz-Allen-Hamilton to develop recommendations for drawing more service providers into the program and for supporting those who have already enrolled. Based on the contractor’s recommendations, the Program Manager has developed outreach materials tailored to specific segments of the provider population, such as government services, disability- and nondisability-specific service providers, faith-based organizations, employers, insurance companies, educational institutions, and health management agencies. For example, Program Manager staff said that employers want to know how TTW will affect the bottom line, whereas faith-based organizations are interested in how the program will advance their mission.
The dynamics of marketing and recruitment continue to be shaped by many of TTW’s continuing problems. EN recruitment apparently continues to be hampered by perceived flaws in the way TTW has been designed and operationalized, including high financial risk for providers, a narrow definition of acceptable beneficiary outcomes, the potential for causing providers to lose SVRA and other government funding, administrative burdens, five-year client tracking requirements, and the general complexity of the program. Because TTW was fully implemented in many states as of the Phase 3 rollout, word about the negative experiences of ENs, SVRAs, and Ticket holders had spread to Phase 3 states. Prospective Phase 3 ENs from all sectors, including traditional disability service providers, told the Program Manager that they are less inclined to get involved because of the “bad press” the program was getting.
Program Manager staff have reported that negative reviews of TTW, low beneficiary enrollment, and negative SVRA reaction during Phases 1 and 2 changed EN recruitment efforts from “a hard sell” to “an almost impossible task.” By the Phase 3 rollout, they said, enthusiasm for TTW had diminished significantly. According to Program Manager staff, “TTW is a product that nobody wants to buy. Interest in TTW has absolutely fizzled.” Marketing strategies, no matter how well executed, have failed to persuade potential ENs that know about the program to participate in it. For instance, Program Manager staff estimate that, in recruiting providers, it takes about 400 telephone contacts to get one provider to become an EN. They also report that conference organizers discouraged them from participating in conferences where they might meet representatives of potential ENs. In addition, EN representatives have told them not to call again until there is something new to report.
To make EN recruiting efforts more cost-effective, the Program Manager initiated the City Campaign in November 2004 in five metropolitan areas: Dallas-Fort Worth, Detroit, Los Angeles, Miami, and New York City. To operate the City Campaign, the Program Manager formed the National Alliance, an organization that is led by the National Association of Workforce Boards and includes the U.S. Chamber of Commerce’s Center for Workforce Preparation, the National Association of Counties, the U.S. Conference of Mayors, and the Amherst H. Wilder Foundation. The Program Manager and National Alliance will work to form collaborations at the community level—with city governments, state agencies, for-profit and nonprofit service providers, business leaders, and consumer groups—to promote TTW. The Program Manager intends to hold regional EN recruitment events by using a “peer-to-peer” approach and featuring “successful” ENs—defined as those that actively participate in TTW, taking Tickets, and receiving payments—and other Ticket partners, including representatives of Benefits Planning Assistance and Outreach (BPAO) programs and Protection and Advocacy for Beneficiaries of Social Security (PABSS) programs, as the primary spokespersons. Program Manager staff hope that, by creating these larger consortia and support systems, TTW can be better sustained in large metropolitan areas.
2. Outreach to Beneficiaries
In addition to trying to interest more service providers in becoming active ENs, SSA officials said in an interview in August 2004 that they plan to reach out directly to beneficiaries to promote the program. One aspect of this effort involves revising existing TTW informational materials, such as the TTW brochure, by simplifying the language and using a question-and-answer format. SSA also is developing a TTW poster, video, and newsletter for distribution via e-mail and print. The video and newsletter will promote TTW by providing examples of beneficiaries who have successfully used their Tickets to become more self-sufficient. SSA staff continue to attend disability advocacy and other conferences to make presentations and stage exhibits.
In September 2003, SSA awarded a two-year contract to Fleishman-Hillard to develop a strategic marketing plan, part of which would involve creating marketing materials to support TTW and other employment support programs. Fleishman-Hillard reviewed all marketing and public relations materials developed by SSA, such as brochures, flyers, and press releases; audited SSA’s Web site; examined all news coverage of TTW; held several focus groups, including one with the Ticket to Work and Work Incentives Improvement Act Advisory Panel; surveyed a random sample of SSA beneficiaries; and conducted an e-mail survey of other interested parties, including advocates, service providers, and employers.3 Fleishman-Hillard presented the strategic marketing plan, along with survey results and draft marketing materials, to SSA in early November 2004. After SSA signed off on the materials, Fleischman-Hillard finalized them in February 2005 and market tested them at TTW conferences and expositions in June through September 2005 at 10 sites across the country. Disability beneficiaries, service providers, employers, and other interested parties will be attending the expositions. In early FY2006, SSA will use the results from the market testing to choose a strategy for a nationwide marketing campaign.
In 2005, SSA also recontacted some beneficiaries in two stages to test the effectiveness of outreach materials and information. In the first stage, SSA will mail a postcard, brochure, or other marketing materials to a random sample of 350,000 beneficiaries in five states (Arizona, Florida, Illinois, Michigan, and New York). Six focus groups were conducted to help decide the best messages. Different beneficiary samples will receive different types of information on programs and services, such as state Medicaid buy-in programs, the local BPAO, or the Program Manager’s toll-free number. The Program Manager is tracking beneficiary responses, providing another field test of marketing materials and messages. In the second stage, SSA will send follow-up mailers to about 500,000 beneficiaries in particular target groups, including those who requested a Ticket through the Ticket on Demand program and those who worked to some extent during the past year. SSA officials noted that only 10 percent of individuals making a request through Ticket on Demand ever assigned their Tickets.
Finally, under contract to SSA, the ARC is matching SSA beneficiary and U.S. Census data to analyze characteristics of the SSA beneficiary population. The idea is to give SSA guidance on the characteristics of beneficiaries most likely to work so that these individuals can be targeted with additional marketing materials. (See Chapters II and III for discussions of participant characteristics.)
3. Outreach to Employers
SSA reaches out to employers primarily through Ticket to Hire (TTH), a nationwide disability employment service. TTH was developed by SSA with support from the Department of Labor (DOL) as an enhancement to TTW when TTW was initiated. TTH matches employers with ENs and SVRAs that are working with SSA beneficiaries seeking employment. TTH enables employers to post job openings that are then e-mailed to ENs and SVRAs, which in turn convey the information to the beneficiaries they serve. About 1,360 employers are now enrolled; all SVRAs and ENs are automatically enrolled.
TTH is marketed to ENs and employers through a monthly newsletter. However, the contractor that operates the program also sponsored 26 focus groups in 13 cities during 2004. Participants included human resource personnel from companies ranging in size from 15 to over 2,500 employees and representing a variety of industries. The focus groups revealed that employers are concerned about finding and hiring qualified personnel, finding personnel with the right work ethic, and managing costs and benefits. Messages reflecting the business case for hiring people with disabilities were tested in order to identify the messages that resonate most among various employer groups.
E. EN ENROLLMENT
The Program Manager continues to enroll providers as ENs in TTW, although the monthly number of EN applications has fallen from around 35 to about 20 in recent months. About 95 percent of applications are reportedly incomplete upon receipt by the Program Manager; therefore, the Program Manager must work with applicants to obtain the missing information, a process that can take two to three months. Although Program Manager officials think the application process is not difficult, many agencies, particularly faith-based organizations, are unfamiliar with the contracting process and fail to complete all of the necessary paperwork. Program Manager staff have observed that the timeline from provider awareness to decision making to action can take up to a year—much longer than originally anticipated. This is especially true for nontraditional providers (those whose service population is not solely people with disabilities), which currently comprise about 40 percent of ENs.
As of September 30, 2004, about 1,400 entities had applied to become ENs, 1,170 of which were enrolled by the Program Manager. About 300 providers were waiting for their EN contracts to be approved by SSA’s Office of Acquisitions and Grants (OAG). OAG offices flooded in spring 2004, and the agency was forced to relocate, halting operations for several weeks. Although the backlog of contracts has subsequently been approved, provider representatives were understandably upset about the delay, and Program Manager staff have expended significant time and effort to keep the ENs from withdrawing their applications.
F. TRAINING AND TECHNICAL ASSISTANCE ACTIVITIES
During 2004, the Program Manager gradually shifted some of its efforts and resources from recruiting new ENs to providing technical assistance and customer service to existing ENs or to organizations that wanted to apply to become ENs. The shift is partly a response to the EN dropout rate, which has reached about 10 percent of enrolled ENs. Program Manager staff said that, to keep ENs involved, they will need to nurture the relationships, establish trust, and offer more assistance. Technical assistance takes place by telephone, through an online discussion group, and through distance learning courses on the Web and CD-ROM. Program Manager staff help providers with the application process and follow them through the submission of earnings documentation. Program Manager staff also advise ENs on developing an infrastructure to provide disability employment services, writing IWPs, accepting Tickets, and other aspects of service administration. In addition, staff contact each EN by telephone every month to discuss any problems or answer questions. The Program Manager has developed and posted on its Web site information about “EN best practices.” We will obtain EN reactions to this assistance during interviews for the next evaluation report.
In September 2002, the Program Manager initiated a “capitalization initiative” to acquaint ENs with grants, loans, and other resources that could help fund Ticket services until beneficiary employment generates TTW revenues. As of March 2005, 18 capitalization training conferences had been conducted, and the materials had been presented at various workshops across the country. The Program Manager had also developed an extensive resource manual to augment the training and made it available on CD-ROM and on its Web site. The relatively few ENs we interviewed that had carefully reviewed the material had generally positive comments about the manual. One person, for example, said, “The manual is well put together and contains standard, good information one needs” to seek additional funding. Other ENs, however, were more skeptical about its usefulness or had not even heard of it. For more information on this issue, see Chapter V.
G. SYSTEMS ENHANCEMENTS
SSA has made significant progress in improving its automated systems during the past year, particularly in the areas of tracking and verifying earnings, administering continuing disability reviews, and determining when benefits become zero for EN payment purposes. During the past year, SSA completed its conversion to the Integrated Disability Management System (IDMS), which houses the Disability Control File (DCF).4 The DCF is the file for managing disability benefit post-entitlement activity. It contains a complete history of SSI and DI beneficiary records, including medical information, monthly earnings, work and medical continuing disability review information, and relevant information about TTW eligibility. One practical implication of the IDMS is that if a Ticket is shown to be in use and a medical CDR is scheduled, the CDR is automatically rejected, since such reviews are suspended for beneficiaries who use their Tickets.
A new web-based initiative known as the eWork System interfaces with the IDMS and automates the documentation of all SSI and DI earnings information. The eWork System is a management tool that enables SSA field office staff to enter beneficiary earnings data only once and have it populate all other relevant administrative data system fields. It processes work reports, initiates CDRs, and tracks the number of months remaining in the trial work period. It also enables SSA field office staff and Telephone Service representatives to generate a receipt when a beneficiary receiving SSI, SSDI, or concurrent benefits reports earnings. When SSI recipients report monthly income, eWork records that information, prints receipts for the recipients, and posts a message to the field office that action is needed (e.g., a reduction in the monthly payment amount). In addition to eWork’s other advantages, staff expect it to reduce the incidence of overpayments because it automates the processing of earnings information. The eWork System is also available to the AWICs to monitor the progress of field office staff in processing work CDRs; the AWIC can view a list of pending work CDRs in a particular office to check the date on which any given CDR was requested and what information is outstanding. The field offices have been pilot testing eWork throughout the past year, and it was fully rolled out to all field offices in November 2004. According to an SSA staff member, “Overwhelmingly, field office staffs absolutely love the eWork application because it cuts down the number of key strokes and handoffs per case.”
In August 2004, SSA staff indicated that there were still “bugs” to be resolved in the IDMS and eWork System. The most frequent and serious problem was erroneous terminations of Tickets. The IDMS has been incorrectly terminating the Tickets of beneficiaries who have achieved SGA-level earnings and are no longer eligible for cash benefits. Program Manager staff could not process EN payments when the Ticket was terminated. The problem appears to have surfaced in April 2003 and was still unresolved in spring 2004. Two of the ENs we interviewed mentioned they encountered this problem. SSA and the Program Manager have devised a manual process for handling these cases and paying ENs, but it is time-consuming, inefficient, and inconvenient. Another problem is that the IDMS was unable to associate a Ticket mail date if a beneficiary received a second Ticket.5 A valid mail date is required for any Ticket transaction, such as Ticket assignment. The inability of beneficiaries to assign their valid second Tickets has frustrated beneficiaries and ENs as well as field office and Program Manager staff.
In addition to remedying the problems described above, SSA Ticket staff (OESP) have requested the systems staff to incorporate the handling of expedited reinstatements into future IDMS updates. The process is not automated at this time. Staff have also explored the possibility of developing an interface between the Vocational Rehabilitation Management Information System database, which contains SVRA claims for cost reimbursement, and IDMS so that SSA will not generate duplicate payments for Ticket holders working jointly with SVRAs and ENs. No timeframe has been established for this enhancement. SSA is also exploring the possibility of using eWork to generate Ticket notices, such as Ticket eligibility or ineligibility, suspension, or termination.
During the past year, SSA has gained read-only access to quarterly unemployment insurance data through the U.S. Department of Health and Human Services, Office of Child Support and Enforcement (OCSE), enabling claims representatives to query beneficiary earnings data to verify work activity. In the past, SSA verified earnings on the basis of annual earnings data from the Internal Revenue Service; that information is generally available 12 to 18 months after wages are paid. SSA has used the quarterly OCSE data since 1998 to check for unreported SSI earnings through batch processing under earnings enforcement practices (Federal Register, Vol. 63, No. 167). The new agreement with HHS allows SSA to extend these earnings enforcement practices to SSDI beneficiaries. Although SSA has not documented how access to the new data affects overpayments, staff expect that more timely access to earnings data should dramatically reduce overpayments, particularly in the SSI program, where overpayments generally occur.
Providing timely payments to ENs continues to be a challenge. The multi-step process requires the cooperation of several key players. First, the EN must provide proper wage and earnings information to the Program Manager. The information must then be verified with the SSA field office, generally requiring a work CDR. As explained below, processing the first EN payment on a beneficiary is particularly problematic, as it requires cooperation and coordination among several disparate entities, including the Program Manager, SSA Baltimore staff, SSA regional and field office staff, and the EN.
First, the EN must provide the proper wage and earnings information, including the start and end dates of the pay period, the date of payment, the amount of earnings for the pay period and year, and the employer’s contact information. Program Manager staff have reported that obtaining complete earnings documentation from ENs is a time-consuming process, often involving several faxes and telephone calls over several months. The date of payment, dates of the pay period, or year-to-date earnings are often missing.6 ENs are not paid until all required documentation is provided. If an EN cannot obtain this information from the beneficiary or the employer, the SSA central office must contact the field office to initiate a work CDR to document earnings and zero benefits so the EN can get paid.
Delays can occur even if the EN submits all of the required information. To process a claim, SSA technicians compare the documentation submitted by the EN with SSA’s beneficiary claims data to determine whether the beneficiary has reported his/her earnings to SSA. If the information is inconsistent, the field office must be contacted to initiate a work CDR to ensure that the payment to the EN is made correctly. There are two types of CDRs: a disability CDR, which examines whether a person still has a disability that qualifies him/her for benefits, and a work CDR, which examines whether a beneficiary is working and therefore whether benefits should be reduced. Unlike a work CDR, a disability CDR cannot be initiated if the beneficiary is using a Ticket. Resolving apparent inconsistencies between pay stubs and SSA employment records can be particularly problematic if the beneficiary has not reported earnings and therefore was “overpaid,” i.e., received cash benefits to which he/she was not entitled.
According to SSA staff, processing the initial EN claim can run from one to three months at best. However, SSA staff reported that the turnaround time is shrinking as technicians become more familiar with the payment system and field offices recognize the importance of responding to information requests. In fact, the number of processed claims nearly doubled from December 2003 to January 2004. SSA staff noted that an advantage of the EN payment process is that SSA is notified more quickly about beneficiary wages, thus reducing the number and amount of beneficiary overpayments.
In response to EN concerns about the burden of tracking earnings and the monthly submission of earnings documentation for payment, SSA and the Program Manager implemented the Certification Outcomes Payment Process (COPP) in late 2003. COPP is a simplified outcome payment request option that enables ENs to receive payments without submitting beneficiary earnings documentation. ENs can certify earnings evidence on a outcome payment) for a given beneficiary.
To use COPP, an EN prepares a request for payment on business stationery and sends it to the Program Manager. The request must include a statement agreeing to relinquish incorrectly issued EN outcome payments; earnings documentation, however, is not required. The requests are processed immediately after SSA receives them. If the paperwork is in order and no other problems surface, the payment can be made in as little as two weeks. As of August 2004, 11 payments had been made under this process.7 Program Manager staff suggested that the small number of payments probably reflects both the small number of beneficiaries and ENs that currently qualify for outcome payments. Some ENs may not want to take the risk of being paid for a beneficiary who has stopped working and then be required to pay SSA the resulting overpayment. SSA will make payments based on the new system, provided that no information in the agency’s records contradicts the request. SSA will conduct post payment validation reviews to verify work or earnings.
Although the EN payment process is automated, certain management information must still be entered manually, including the number of EN payments made, payments by states, payments by EN, payments by type (milestone or outcome), and the trust fund from which payments are made. In certain cases, EN payments must be made manually because of the systems errors related to Ticket terminations noted previously. Staff estimate that 16 types of errors necessitate a manual payment, resulting in up to 70 beneficiaries each month for whom EN payments must be made manually. These payments represent an average 23 percent of all payments in months in which manual payments were made and a high of 30 percent in some months.
EN staff expressed frustration with both the documentation required for beneficiary earnings and the delay in receiving payments. ENs reported that the process of obtaining earnings documentation from beneficiaries is extremely time-consuming; they are baffled by the laborious process of continuously collecting earnings evidence from beneficiaries.8
In addition, Program Manager staff reported that some ENs operating under the milestone-outcome system are confused about the standard for receiving milestone versus outcome payments. Milestone payments cannot be made after the first month in which benefits are not payable due to earnings. This means that if the EN successfully helps a Ticket holder earn enough to leave the benefit rolls before the third milestone payment is made, it immediately receives only the much smaller outcome payments. The milestone payment the EN would have received is included in subsequent outcome payments but spread over the period of time in which outcome payments would be paid.9 In effect, ENs are penalized for moving beneficiaries off the rolls too quickly. ENs may believe that they are entitled to a second or third milestone payment totaling several hundred dollars when, in fact, the beneficiary has worked at the SGA level in earlier months, in which case ENs are therefore entitled only to a monthly outcome payment that is much smaller than the milestone payment they had been expecting. EN representatives we interviewed became frustrated when they received only the smaller payment amount.
I. TIMELY PROGRESS
The Ticket Act requires a series of reviews, beginning two years after a Ticket is assigned, to determine whether TTW participants are making “timely progress” toward self-supporting employment, which is defined as working at levels that will reduce or eliminate dependence on DI or SSI benefits. So long as beneficiaries are determined to be making timely progress, their assigned Tickets are considered in use and they are exempt from disability CDRs. The purpose of the review process is threefold: (1) to determine whether the beneficiary is “actively participating” in his/her IWP; (2) to examine whether a goal in the IWP is to work at least three months at the SGA level by the time of the second review; and (3) to assess whether the beneficiary can reasonably be expected to reach that goal. The Program Manager sends a notice to each EN (including SVRAs) that has held beneficiaries’ Tickets for 24 months and requests answers to the following questions:
- Has the beneficiary been participating in his/her IWP?
- Has the beneficiary been working 3 out of the past 12 months?
- Does the EN foresee the beneficiary fulfilling the requirements of the IWP?
If there is no response from the EN, the Program Manager will assume that the answers to the above questions are “yes,” and no further action will be taken. If the response is “no” to any one of the three questions, the Program Manager unassigns the Ticket, and the beneficiary becomes subject to a CDR.
The Ticket Act requires the first review to take place 24 months after each Ticket is assigned and annually thereafter. Because the first Tickets were assigned in March 2002, the first review was scheduled to begin in March 2004, but it did not occur. At the time of our interview in September 2004, SSA and the Program Manager were in the final phases of the planning process to initiate the first review. The Program Manager is currently awaiting SSA’s approval of systems specifications to generate the required notices to ENs. Given delays in generating the first timely progress notices, the process and timing of the second annual notice has not yet been determined.
J. OTHER SSA INITIATIVES TO SUPPORT TTW
SSA has sponsored a variety of initiatives to support TTW, including enhanced support of the SSA field offices and the BPAO and PABSS programs.
Field Office Support for TTW. During FY2003, SSA designated and trained 58 full-time staff positions as AWICs and 1,535 work incentives liaisons (WILs) to provide the SSA field offices with expertise on TTW and other work incentives. Each AWIC provides technical support and training to 20 to 30 field offices and networks with community agencies and other organizations that provide employment services to people with disabilities. The WILs provide technical assistance to staff and field office management, including assistance on complex cases. The WILs also process cases involving work incentives and maintain ongoing contact with beneficiaries. WILs are also involved in TTW marketing and outreach, but their level of involvement varies according to the needs of the SSA field office. During 2004, SSA developed interactive video training materials for the WILs and other SSA staff who have direct contact with beneficiaries.
We did not interview Regional Office or Field Office staff for this report, but SSA headquarters staff said they received positive feedback from the field offices and beneficiaries on the AWICs and WILs. These staff also pointed out that TTW has had little impact on the field office workload, e.g., the number of work CDRs, the number of individuals who achieve SGA and need benefits adjustments, or the number of individuals using the work incentives and needing benefits adjustments. We will be interviewing SSA regional and field office representatives for the next evaluation report.
According to the EN representatives we interviewed, contact between EN staff and SSA field office staff is minimal. A few representatives stated that they sometimes contact the SSA field office to obtain information about a beneficiary’s status, to obtain work incentive information, or to conduct work incentive training.
Benefits Planning Assistance and Outreach Programs. BPAO programs help beneficiaries interested in returning to work understand all the relevant Social Security work incentives and other federal, state, and local public benefits that may be affected by their work activity. As of February 2005, over 153,000 beneficiaries had received assistance from 114 BPAOs. In 2002, SSA sponsored a survey on consumer satisfaction with BPAOs (results available at http://www.vcu-barc.org/NatReport/customersatisfaction.html).
The vast majority of ENs we interviewed said they had extensive interactions with BPAOs; many said they refer all of their Ticket holders to BPAOs or that staff had daily contact with BPAOs. On the whole, the EN representatives said they had positive experiences with BPAOs. In the words of one representative, “This is by far the best service enhancement that has happened under TTW. The BPAO is invaluable to the success of clients and staff. They are educated and empowered by it.” A number of EN representatives wished BPAOs had more funding because they felt BPAO staff were “overworked” or “stretched too thin.” One EN representative, however, complained that BPAO representatives in his area routinely counseled Ticket holders to take part-time jobs that paid low enough to maintain DI benefits, essentially discouraging beneficiaries from participating in the Ticket program.
Protection and Advocacy for Beneficiaries of Social Security Programs. PABSS provides information and advocacy services to SSA beneficiaries, including assisting beneficiaries who received erroneous CDRs or overpayment notices from SSA. Most ENs we interviewed are aware of the PABSS program generally, and several have conducted joint or cross-training with their local PABSS program on TTW issues. A few ENs have worked with PABSS to resolve employment discrimination issues for beneficiaries. Only one EN representative mentioned a dispute between a beneficiary and the EN in which PABSS had been involved.
Disability Program Navigator. DOL and SSA funded the establishment of about 200 disability program navigators in One-Stop career centers in 17 states across the country. The navigator initiative provides resources to the One-Stop system for more effective service delivery to people with disabilities and includes an important link to the local employment market. DOL is sponsoring a process evaluation in all 17 states and will review and evaluate outcomes in selected states.
K. SUMMARY AND CONCLUSION
SSA and the Program Manager continue to move forward in implementing TTW and have made some changes along the way. At this writing, all three phases of Ticket distribution have been completed. A capitalization initiative, which provides information to ENs to help them fund TTW services, and a certification outcomes payment process have been developed and implemented. In addition, SSA has implemented a new internal Web-based initiative known as eWork, which automates the documentation of all SSI and DI earnings information, processes work reports, initiates work CDRs, and tracks the number of months remaining in the trial work period. The eWork program also enables SSA field office staff and telephone service representatives to generate a work report receipt.
Despite good intentions, however, these recent activities do not appear to be having a dramatic impact on many key aspects of TTW operations. Persistent problems and the pace of certain implementation activities continue to affect program operations. Program Manager staff reported that recruiting and retaining ENs is becoming more difficult. With TTW in its fourth year of implementation, two-thirds of eligible beneficiaries reported that they were unaware of TTW while ENs commonly cited a lack of demand for services as a major reason for low Ticket assignment rates (see Chapter V), yet SSA’s marketing initiatives are still in the pilot testing phase. Few of the ENs we interviewed are aware of the capitalization initiative, and only a handful use the new payment process. Automation of payments to ENs and termination of Ticket eligibility when an individual loses cash benefits also continue to be problematic.
1 In both Phases 2 and 3, Tickets were not mailed during December. Return to Text.
2 We will report on beneficiary perceptions of the Program Manager in the next evaluation report, based on results of the beneficiary survey. Return to Text.
3 Witeck-Combs conducted the stakeholders’ survey, and Harris Interactive conducted the beneficiaries’ survey under contract to Fleishman-Hillard. Return to Text.
4 For background information on the creation of the DCF, see the initial evaluation report. Return to Text.
5 Beneficiaries would be issued a second Ticket any time they go back on benefits after their eligibility had ceased—for example, if (1) they went to zero cash benefits (e.g., based on employment earnings) and then stopped working after the end of their extended period of eligibility (EPE) and applied for benefits through expedited reinstatement, or (2) a CDR determined they were ineligible for continued benefits, but they later filed a new disability claim. Return to Text.
6 Compounding the issue are the different rules under SSI and DI related to the use of earned versus paid dates for earnings when determining eligibility and benefit amounts. Return to Text.
7 As of July 2004, about 65 ENs had been paid at least three outcome payments on behalf of approximately 220 beneficiaries; these ENs could have used COPP, at least in theory. Although not all of these beneficiaries may still be generating payments, we conclude that the number of payments made under the COPP system is relatively small. Return to Text.
8 For related information, see Chapter V. Return to Text.
9 While the EN gives up milestone payments if the beneficiary leaves the rolls before the milestones are payable, the outcome payments under the milestone system fully offset (in nominal terms) the nonpayment of the milestones. The outcome payments are larger by 1/60 of the milestone amounts not paid. The difference in these larger amounts is spread over all 60 outcome months. What the EN loses is the immediate payment of these amounts. The total amount received will be less only if the EN does not get all 60 outcome payments. The total value of the payments will be less due to discounting and added risk. Return to Text.