February 11, 2005

Ms. Sue Suter
Associate Commissioner, Office of Employment Support Programs
Social Security Administration
6401 Security Blvd.
Baltimore, MD 21235

Dear Sue,

Thank you for providing the Ticket to Work and Work Incentives Advisory Panel the opportunity to provide you with our recommendations for possible consideration as you finalize the Benefits Planning, Assistance and Outreach (BPA&O) Request for Applications (RFA) that the Agency will be releasing in early 2005.

The Panel continues to strongly support the work incentives outreach provision of the Ticket to Work and Work Incentives Improvement Act which authorizes BPA&O services. We have heard considerable public comment on the effectiveness and positive impact of the BPA&O program as well as some constructive feedback that could potentially enhance the effectiveness of this national network. As the Ticket to Work Act cites, benefits planning is a critical employment support and piece of an effective return-to-work agenda.

Based on past experiences with the Ticket rollout, we can reasonably expect a substantial increase in workloads as the Agency proceeds with several major changes including: the continued sponsorship of this national BPA&O network and several other initiatives such as modifying existing regulations to encourage more beneficiaries and EN's to participate in the program and implementing a comprehensive marketing program to beneficiaries most of whom remain confused about what a ticket is and why they might want to use it. In view of the expected demands on BPA&O services, we recommend enhancements in five critical areas that we feel could further reinforce the role of benefits planning in fostering the positive employment outcomes and improved economic self-sufficiency of beneficiaries.

1. RESOURCE ISSUES

There are 117 BPA&O programs in the United States comprising 550 benefits specialist across 192 sites. To date, the network of BPA&O programs has impacted over 150,000 beneficiaries nationwide in the past four years. In the past two years BPA&O Programs have experienced unprecedented growth in the number of beneficiaries accessing their services. As they have built collaborative relationships in the communities they serve and as word has spread so has the demand for these critical services. This has forced some programs to establish waiting lists, often resulting in one to three month delays in service-time ill-afforded for someone who is ready, willing and able to work and opportunity lost for the Agency.

Many BPA&O programs report staff turnover which inadvertently impacts service delivery. We note that a human resource study conducted in federal regions I, II and V by Cornell University (2002) documented that the pay scales for benefits specialists varied drastically across programs with the highest salaries going to specialists employed within state agency-based BPA&O programs. The limited financial resources available to these programs and caps on awards appear to limit their ability to provide substantial enough compensation packages and career advancement opportunities to incent the ongoing employment of benefits specialist once hired and trained. Often these well-trained specialists are enticed to job opportunities outside the BPA&O infrastructure although still within the employment supports realm. This human resource obstacle inevitably winds up costing both the BPA&O program and the Agency considerable dollars.

Finally, geographic access to BPA&O services and supports is not equitable. BPA&O programs based in rural settings face resource barriers on several fronts. First, because their beneficiary population is small so is their award. Many of these locations cover thousands of square miles with no more than a $50,000 award. This amount of money barely covers one full time equivalent much less the travel dollars that are needed to ensure access for all beneficiaries. Given lack of public transportation this requires that the benefits specialist travel up to four to five hours in some cases to provide services to beneficiaries on the outskirts of their geographic catchment area. A benefit specialist could spend an entire day just traveling and that is without the time needed to conduct an interview with the beneficiary and complete a benefits analysis. The resource picture is bleak and as the demand for this service grows so should the resources. In our most recent Annual Report (July 2004) the Panel noted concern about the beneficiary demand for services and the funding levels. We recommend the following:

• Increase the amount of resources allocated to the national network.
  
• Remove the individual awards cap for projects to ensure that programs based in rural settings have the resources they need to provide equitable services to their urban and metropolitan counterparts.
  
• Require response/acknowledgment to the beneficiary within a specified period of time say 24 hours.
  
• Require Management Information reports to include data on beneficiary waiting times for a response, an appointment and for services.
  
• Provide a point of contact so that individuals having difficulty receiving services from BPAO can let SSA know about the specific reason for example, no response at all or long wait for an appointment.
  
• Provide special consideration to proposals that develop workable ways to effectively deal with limited resources .

2. UN/UNDER-SERVED POPULATIONS

The National BPA&O Database maintained by Virginia Commonwealth University documents that services and supports are equitably distributed between men and woman and disability beneficiaries and SSI recipients / concurrent beneficiaries. Over 80% of services are provided to individual's aged 22-59 with fewer than 8% of services going to transition-aged youth. While the majority of emphasis has been on “working-aged” individuals, in sync with the Agency's increased priority on transition-aged youth, efforts are needed to increase outreach to transition-aged youth—preparing them for employment and future Ticket use.

Another area in need of further study is the extent to which specific disability groups receive equitable access to services. While over 33% of individuals served by BPA&O programs have had a psychiatric or emotional disability fewer than 9% have been individuals with mental retardation. Many BPA&O programs are based in community agencies that provide specialized rehabilitation services to specific disability groups and measures should be taken to ensure that they are able to provide equitable access to all disability populations. Finally, at the 2004 Annual Conference of the Consortia of Administrators for Native American Rehabilitation (CANAR) a member of the Ticket to Work Panel conducted a focus group with approximately 45 Native American vocational rehabilitation (VR) specialists. One of the barriers identified by this group was that some BPA&O programs have limited access to tribal lands and further that they do not have formal agreements with Section 121 VR Programs or Tribal Councils to ensure access. The Panel recommends the following:

• Require BPA&O programs to state how they will target and serve transition-aged youth.
  
• Require BPA&O programs to state how they will ensure equitable access to and services for all disability groups regardless of their primary agency's affiliation.
  
• Require BPA&O programs that cover tribal lands and sovereign nations to provide clear and convincing documentation of how they will ensure equitable access and services for Native American and Alaskan Native populations. Examples of this might be formal agreements with Tribal government, Section 121 VR Programs, etc.

3 . TRAINING AND QUALITY ASSURANCE

The goal of the work incentives outreach provision of the Ticket to Work and Work Incentives Improvement Act is to ensure that beneficiaries have access to the information they need, when they need it to support informed decision making in regard to employment. However, one must look more broadly at the Ticket to Work Act to understand that the employment supports outlined in the law were not meant to be isolated from one another. Each provision of the law carefully details an essential employment support, that when coupled together, leading to a goal of employment and greater economic self-sufficiency. Our understanding is the work incentive improvements built into the law were put there to remove fears associated with going to work—fear of losing healthcare and not being able to get back on benefits if one needed as a result of their disability. The work incentive outreach provision was to ensure that beneficiaries had access to the information they needed to make an informed choice about work. Protection and advocacy services were built in to ensure legal representation and advocacy in the case that a beneficiary experienced an obstacle on the way to work. Finally, the Ticket to Work and Self-Sufficiency Program was the top of the employment supports pyramid which provided the vehicle by which to obtain work.

The Agency conducted a customer satisfaction survey in year two of the BPA&O project as part of their program evaluation. The customer survey elicited opinions of the information and services provided by benefits specialists in BPA&O organizations, and addressed participant work activity before and after counseling. Respondents' recollection of work activity indicated that benefits counseling had a positive impact in this area. It was unclear from the survey the type of work in which beneficiaries were participating. It would be useful to obtain more information about the work activity, such as was it paid integrated employment.

BPA&O programs have a responsibility to present a myriad of options that exist for a beneficiary when it comes to making decisions about work that include total economic self-sufficiency. BPA&O programs are well positioned to help a beneficiary understand the total dollar value of disability benefits and public entitlements that they receive and the earnings they would need to completely offset that. This information is also critical to Employment Networks (EN) as they consider the earnings levels that they need to place beneficiaries at to maximize potential for employment success. To ensure that all BPA&O programs adhere to a common philosophy and set of service delivery standards quality assurance measures must be put into place.

Further, we believe that Benefits Specialists must be well-versed and equipped to provide services and supports not only on the Agency's return to work programs and work incentive provisions but other state and federal entitlements as well. While the Agency has established a seven-day core training curriculum that encompasses all of it's disability, return to work and work incentive programs as well as other federal entitlements and programs, the panel has received extensive public comments that the time allotted to cover all the information in the national curriculum is not sufficient and that the number of days for the program should be extended to allow for in-depth and through coverage of content. Finally, while we commend the Agency for the extensive efforts to ensure a minimum level of competency for benefits specialists in regard to SSA and other federal programs, we are concerned there seem to be minimal guidance to BPA&O Programs regarding state training requirements and many other programs. In fact, we understand that many BPA&O programs may not have formal training that their benefits specialists receive in regard to SSA and other federal programs. To accomplish this end we make the following recommendations:

• Continue to use a national core competency-based curriculum that establishes minimum standards for effective service delivery and ethical considerations when preparing benefits specialists for the field and that they have access to ongoing technical support.
  
• Increase the duration of the initial five-day training session to realistically reflect the breadth and complexity of the SSA's disability programs including the Ticket to Work program and other relevant federal programs.
  
• Establish minimum qualifications for new Benefit Specialists and timeframes for conducting training about State and local programs.
  
• Require that BPA&O programs have a quality assurance plan that is in alignment with standards set by the Agency and that a grievance procedure be established within each BPA&O program. Require that evidence of compliance with this plan be submitted regularly.
  
• Require that BPA&O programs notify beneficiaries of the established grievance procedure and the availability of PABSS services.
  
• Require data collection strategies to provide a full picture of the benefits counseling process (rather than snapshots of the individual's journey) and address the identification or resolution of barriers and the outcomes achieved by the individual.

4. PARTNERSHIP

As described above, partnership and collaboration of the critical employment supports detailed in the Ticket to Work Act are essential. Some BPA&O programs have developed model partnerships with ENs to maximize the employment success of the beneficiaries they both serve. This promising practice must be reinforced and incentivized by the Agency. A Customer Satisfaction Survey conducted by the Agency showed that in some cases beneficiaries reported not knowing what to do with the information they had been given by BPA&O programs—what was the next step down the road to work. To eliminate or minimize this occurrence we recommend the following:

• Require BPA&O programs to have agreements with ENs, and also Disability Program Navigators, in their geographic catchment area to promote positive working relationships.
  
• Provide an incentive to BPA&O programs and ENs for working together to promote employment success.

In addition, to the above specific recommendations we urge a stronger linkage with SSA. Individuals in the SSA field offices need a familiarity with the BPAO programs, and need to work together with the benefits counselor when appropriate to resolve issues. Field offices staff need to have confidence that the benefits counselors are providing accurate information. SSA staff should be trained to a level where they feel comfortable making assertions about the SSA disability programs, but should work together with the benefits counselors to explore detail and to understand the impact work may have on a variety of federal, state and local benefits. While we have no specific recommendation, this may mean making greater efforts at joint problem solving.

In line with our recommendations in other critical areas, we feel that partnerships can position BPA&Os to enhance limited resources and to better serve un/underserved populations. For example, inter state cooperation to serve boarder areas or special populations, and use of video or distance learning technology, allow BPA&Os to generate and keep program income. Colocating BPA&O services in agencies already serving disability groups, such as Independent Living Centers and One-Stop Work Centers could add value to existing resources and assist in reaching the un/underserved. This is also true of colocating services such as BPA&O with Disability Navigators.

We appreciate your consideration of our recommendations. If you or your staff have any questions, please contact Jill Houghton, Executive Director, at (202)358-6430.

Sincerely,