XII. TTW Program Implementation by SSA and the Program Manager
SSA and its contractors pay a critical role in implementing TTW in a market-based environment. They must ensure an adequate supply of employment service providers as well as adequate demand for employment services from beneficiaries and establish a structure to operate a successful program. To create and support this market, SSA and its subcontractors must undertake several important functions:
Inform Beneficiaries: A well-functioning market requires that beneficiaries understand their options and can make effective choices. SSA and the Program Manager inform beneficiaries through Ticket mailings, marketing TTW to beneficiaries, supporting the BPAO program, and direct interactions with beneficiaries through SSA field offices and the Program Manager toll-free telephone call center.
Inform Providers. A well-functioning market also requires that potential providers understand the opportunities for generating revenue from TTW and that ENs understand the rules for accepting Tickets and getting paid. SSA and the Program Manager deliver needed information through mailings to potential providers, conducting informational meetings around the country, and communicating through SSA field offices and the Program Manager telephone center.
Operate an Efficient Payment System. A key to the market is for SSA to manage the Ticket payment process so that it provides a financial incentive sufficient to encourage providers to participate actively. In particular, payments should be timely to minimize capital carrying costs for providers, they should be predictable so that providers can forecast their revenue, and the costs of generating the payments should leave the provider with net revenues that provide a reasonable return on investment. SSA and the Program Manager operate the payment system and process payments within the context of the complex rules of the DI, SSI, and TTW programs.
Improve the System. The Ticket act recognized that the initial specifications for TTW may not have been optimal and thus granted the commissioner the authority to make limited modifications to the program to improve its functioning. SSA has enhanced its internal systems at all levels of the organization to implement TTW. It has modified several aspects of the TTW program and has proposed a substantial revision to program operations and the payment systems.
Implementation of TTW has been a daunting challenge. SSA has distributed Tickets to more than 11 million beneficiaries, processed milestone-only and outcome-only payments to ENs, and launched several initiatives, including the BPAO program and expedited reinstatement. SSA has developed a new data system to manage the Ticket program, new case processing software called eWork and has trained field staff in TTW and other work incentives. The Program Manager has contacted over 50,000 employment providers and enrolled about 1,300 of them as ENs. SSA has accomplished these changes in the context of complex DI, SSI, and TTW program rules and existing work incentives and without additional funds to implement TTW. In such a context, these activities constitute a significant achievement in the scant five years of TTW operation.
However, the program still appears to suffer from core problems, including lack of beneficiary demand, low EN participation, and, most important, an inadequate payment structure (see Chapters VIII through XIII for a full discussion of these issues). Despite several beneficiary and EN marketing initiatives, both the supply of providers and demand for services remain low. The complexity of the market and the sluggishness of the provider and beneficiary response create little incentive for active participation in TTW. Providers and beneficiaries alike still lack basic information about how the program operates. The payment process is complex, slow, and uncertain, with little financial incentive to providers.
The Ticket act requires SSA to undertake a periodic review and revision of program regulations to ensure successful program implementation. After conducting a thorough review of the program, SSA promulgated regulations that expand eligibility to include beneficiaries whose medical condition is expected to improve, altered the way SVRAs participate in the program, and substantially changed the EN payment schedule. SSA’s major task during the coming year is to finalize and implement these new regulations.
This chapter describes implementation of TTW from the perspective of the organizations that implement the program—SSA and the Program Manager. From April through June 2005, we conducted site visits to three regional offices that encompassed large Phase 2 and 3 Ticket rollout states within their region.1 We interviewed the regional office Ticket coordinator in all three regions; in some instances, the director of the Center for Disability and the public affairs specialist were also present for the interview. In each region, we selected two field offices representing different states in each region according to which office had more experience processing return-to-work cases, including TTW cases. In each field office, we interviewed the area work incentives coordinator (AWIC), the work incentives liaison (WIL), the field office manager, and, in some cases, the SSI and DI technical experts. In September 2005, we interviewed representatives of the Office of Employment Support Programs (OESP), the Office of Systems, and the Program Manager. This chapter also builds on interviews, conducted for earlier evaluation reports, with five regional and three field offices (Livermore et al. 2003; Thornton et al. 2004).
We begin this chapter with a brief review of how SSA has organized implementation of TTW. We then describe efforts to inform beneficiaries about TTW and efforts to encourage providers to participate. We also present a discussion of EN payment processing issues and close with a review of SSA initiatives to improve the program, including the provision of training and technical assistance to field offices, the enhancement of system automation, and the promulgation of new regulations.
A. Implementation Overview
Congress did not allocate specific funds to SSA to implement TTW; accordingly, SSA reallocated existing resources to meet TTW implementation goals and distributed tasks related to TTW implementation throughout the agency. OESP took the lead, with substantial support from the Office of Systems and the Office of Operations, and with additional support from several other SSA offices. OESP developed the rules, regulations, systems, and processes within SSA to manage the program. Such an undertaking required a tremendous effort because the eligibility and payment rules mean that TTW must interact with every component of the SSI and DI programs. OESP administers and oversees contracts with the Program Manager and other organizations hired to market and implement the program. As of October 2005, OESP has been enrolling providers that want to become ENs. It also assists with payment processing by referring requests requiring additional documentation to the appropriate field office.
The Program Manager operates the toll-free telephone call center, processes Ticket assignments, and prepares payments for submission to SSA. Until October 2005, the Program Manager processed EN applications, marketed TTW to potential ENs, and participated in beneficiary marketing activities. As of October 2005, SSA split the Program Manager contract into two functions; SSA awarded to Maximus the toll-free telephone call center and payment-processing functions and awarded to Cherry Engineering Support Systems, Inc. (CESSI) the contract for the Program Manager for Recruitment and Outreach (PMRO), which is responsible for increasing awareness of and participation in TTW by both ENs and beneficiaries.
SSA has allocated a Ticket coordinator within each region to coordinate implementation activities at the regional level. The coordinator serves as the conduit for information from OESP to the field offices, coordinates training for field office staff, and troubleshoots other implementation issues. The AWICs report to the area director and work closely with the Ticket coordinator. The field offices respond to beneficiary requests for information about TTW; they also process earnings reports from beneficiaries and ENs as well as expedited reinstatements.
SSA has also done the following: implemented a comprehensive evaluation of TTW, solicited advice from two expert panels, produced information to help ENs find operating capital, modified the payment claims process, and drafted regulations specifying broader improvements to TTW.
B. Informing Beneficiaries
Beneficiaries are first informed about TTW when they receive the Ticket mailing. They are referred to the toll-free telephone call center, which is operated by the Program Manager, for more details. But the TTW participation rate remains low. Therefore, SSA and the Program Manager have initiated new approaches to marketing the program. Marketing to beneficiaries included development of promotional materials, expositions in 10 cities, and targeted mailings. In addition, SSA regional and field offices educate beneficiaries about TTW and other work incentives through the AWICs. These efforts are described below.
1. Ticket Distribution and Toll-Free Telephone Call Center
As of August 15, 2005, SSA had distributed almost 10.5 million Tickets to beneficiaries since TTW’s initiation.2 The rollout of TTW was completed in November 2004; since then, Tickets are issued only to “new accretions:” beneficiaries who have recently been determined eligible for SSI or DI benefits and beneficiaries originally awarded benefits under the “medical improvement expected” category whose benefits have been continued after a medical disability review. Once each month, these newly eligible beneficiaries are selected by SSA from the Integrated Disability Management System (IDMS),3 and Tickets are mailed to them. Between 75,000 and 80,000 Tickets are mailed each month, with mailings staggered throughout the month to enable the Program Manager to manage the spikes in call volume generated by the mailings. The mailings contain a brief letter with introductory information about TTW, a Ticket, and a brochure explaining the program in more detail and telling readers about ENs, SVRA, the BPAO program, and the protection and advocacy organization. The brochure directs interested beneficiaries to contact the Program Manager by telephone or Internet to obtain contact information for all of the referenced organizations. The brochure also informs beneficiaries that the program is voluntary and that CDRs are waived while Tickets are in use, but it does not state that the program goal is for beneficiaries eventually to leave the SSA rolls.
Representatives of the Program Manager report that the call volume has dropped, but not by as much as the decline in volume of Tickets mailed. Since the end of rollout, the TTW toll-free telephone call center receives 11,000 to 12,000 calls per month from TTW beneficiaries, down from 65,000 to 75,000 calls during some months early in Phase 1. The callers represent new Ticket recipients as well as beneficiaries requesting a reissue of a Ticket they have already received; about 3,000 reissued Tickets are mailed per month. The Program Manager has somewhat decreased the number of toll-free telephone call center staff but reports that the staff generally has no difficulty responding to callers during peak calling periods directly after Tickets are mailed.
2. Marketing to Beneficiaries
In September 2003, SSA awarded a two-year contract to Fleishman-Hillard to develop a strategic marketing plan, conduct 10 expositions around the country, and create marketing materials to support TTW and other employment support programs. The strategic marketing plan was scheduled for completion on September 30, 2005, and was not available for review as of this writing.4
The purpose of the expositions was to generate interest in TTW among SSA beneficiaries and employment service providers. The expositions were held in 10 states from June through September 2005 ( New Jersey, Vermont, Illinois, Minnesota, Pennsylvania, Kansas, Montana, Mississippi, California, and Washington) and were based on the theme “It Pays to Check It Out!” No accurate data are available on attendance, but estimates range from 1,000 to 3,000 attendees for all 10 events. Attendees included beneficiaries, EN representatives, BPAO program staff, disability program navigators, and SVRA representatives. During the expositions, SSA reissued about 200 Tickets and accepted 70 Part D Medicare applications. The expositions allowed time for meetings between beneficiaries and representatives of BPAO, disability program navigators, and SSA officials. In addition to motivational speakers, the expositions featured stories of beneficiary success in using TTW and enabled beneficiaries to practice their interview skills and log on to www.monster.com to identify job openings. Given that almost 2.7 million Tickets were mailed to the 10 states with expositions, the expositions constituted a relatively small public awareness campaign.
Fleishman-Hillard has also assisted SSA by developing TTW marketing/promotional materials, including posters, brochures, and a day planner to track progress in finding employment along the same theme as the expositions. SSA officials distributed the materials at the expositions, where participants could evaluate the marketing materials by filling out an evaluation form.
SSA conducted a pilot test of the marketing materials in July 2005 by targeting different brochures to particular beneficiary groups to see which type of information elicited the greatest response. SSA mailed two waves of information to approximately 338,000 people in five states— Illinois, New York, Michigan, Arizona, and Florida. The first mailing targeted randomly selected beneficiaries who had been mailed Tickets but had not yet assigned them: SSI and DI beneficiaries in Illinois, New York, and Michigan; SSI beneficiaries only in Arizona; and DI beneficiaries only in Florida. The second mailing in each state targeted randomly selected beneficiaries in the same populations that had contacted the Program Manager at least once but had not assigned their Ticket. SSA mailed four publications: one general flier, one general postcard, one general pamphlet with the telephone number of the Florida BPAO (mailed only to Florida beneficiaries), and one general pamphlet with contact information for an EN, the Arizona Bridge to Independent Living (mailed only to Arizona beneficiaries). The two pamphlets note on the cover page that it is possible to work and keep medical coverage, but they provide no further details about TTW.
The Program Manager tracked the volume of calls to the toll-free telephone call centers from beneficiaries in the states where the mailings were conducted and where the expositions were held. Call volume to the Program Manager increased by 35 percent during the month after the first mailing, but information on calls by state was not tabulated. Because callers did not provide identifying information other than their city and state, it was impossible to determine whether they called in response to a mailing or an exposition, or for some other reason; in addition, the effects of the four publications and the target groups in different states cannot be disentangled. SSA officials say that they will not track whether beneficiaries who received the various mailings assign their Tickets; thus, unfortunately, the impact of the marketing efforts cannot be fully evaluated.
As of October 2005, CESSI assumed responsibility for PMRO, which includes conferences, presentations, and partnerships that can increase beneficiary awareness of TTW and beneficiary willingness to participate. In addition, PMRO will collaborate with BPAOs to conduct work incentive seminars in order to interact individually with beneficiaries to educate them about TTW and other work incentives and counsel them with respect to their specific circumstances and concerns.
At the SSA regional and field office levels, AWICs5 work closely with SSA’s public affairs specialists to educate beneficiaries and service providers about the TTW program and other work incentives. For example, SSA organized programs in each state before TTW rollout to educate community-based service providers, advocates, SVRAs, and beneficiaries about TTW, SSA work incentives, health insurance, and services provided by BPAO and ENs. During the first year after each phase of rollout, AWICs we interviewed for the study said that they were proactive—contacting service providers, advocacy organizations, and other organizations promoting employment—and offered to make presentations at or participate in conferences and other outreach activities. Now that TTW is completely rolled out, AWICs are more reactive—they participate as they are invited. As demand for TTW outreach has slowed with the completion of rollout, AWICs said that SSA officials have asked them to assist with marketing the Medicare Part D drug benefit; however, AWICs are still available to conduct employment-related outreach as needed.
C. Informing Providers
To increase the supply of ENs, the Program Manager developed or refined several approaches to marketing TTW, including the City Campaign (discussed below), targeting its marketing to large providers in areas with major concentrations of beneficiaries, participating in provider conferences and expositions, and reaching out through printed information. The Program Manager has also provided new technical assistance and training for ENs, including new support for submitting payment requests, the continuation of capitalization seminars, and the release of two volumes of a publication entitled “Inside Employment Networks.”
1. Marketing to Providers
To make more efficient use of resources and to target recruitment efforts in areas with a large number of beneficiaries, the Program Manager initiated the City Campaign in November 2004 to boost EN interest in TTW in five metropolitan areas with the greatest concentration of beneficiaries. Such areas may be most likely to have a sufficient number of beneficiaries interested in work to support an active TTW market. To carry out the City Campaign, the Program Manager formed the National Alliance for the Ticket to Work, which is led by the National Association of Workforce Boards and includes several national private and government organizations. The Program Manager and the National Alliance worked during the late spring and summer of 2005 to form community-level collaborations—with city governments, state agencies, for-profit and nonprofit service providers, business leaders, and consumer groups—to promote TTW. The Program Manager held regional EN recruitment events in each of the five cities to bring together participating ENs and other Ticket partners, such as representatives of BPAO programs and One-Stop Employment Centers. According to the Program Manager, nearly 1,000 people attended the events, including providers, employers, and community representatives. To continue the community outreach effort following completion of the City Campaign on September 30, 2005, the National Alliance selected eight ENs throughout the five communities to serve as sustainability champions and offer technical assistance to ENs and other organizations in their region. The organizations received capacity-building training and technical support from the Program Manager and Fieldstone Alliance6 throughout the summer.
The Program Manager has not noted an increase in EN enrollment or Ticket assignments in the five City Campaign metropolitan areas, and SSA staff expressed disappointment that the national organizations did not play a stronger role in the campaign. But Program Manager staff points to a different type of success whereby EN networks have attracted funding for ENs to provide upfront services to Ticket holders from the Community Technology Foundation in California. The foundation awarded $100,000 to each of three ENs in California: one to increase services to individuals with multiple sclerosis who speak languages other than English; one to expand services to rural populations; and one to support a Ticket outreach program in Greater Los Angeles. They hope that these models will spur the development of similar approaches in other cities. Officials from the Program Manager assert that it is too early to tell what other positive impacts the City Campaign will generate.
As in years past, the Program Manager staff continues to send workshop proposals to national and state organizations’ planning conferences. They also generate articles for newsletters and distribute a monthly newsletter called “Inside Ticket.” Often, providers ignore the Program Manager’s efforts to promote TTW through other organizations because, according to Program Manager officials, “The providers feel there is nothing new to report.” They are growing increasingly frustrated with trying to sell a program in which interest is diminishing. “When bad press precedes you and people have already heard that ENs have not received payments and are losing money, it makes the program a hard sell,” one Program Manager representative said.
Under PMRO, awarded in October 2005, CESSI plans to attend conferences, deliver presentations, and forge partnerships to recruit traditional and nontraditional ENs.
2. Training and Technical Assistance for ENs
Although the Program Manager has continued to assist ENs with enrollment in TTW, and with development of the IWP and other aspects of service provision, the Program Manager by far devoted the most effort during 2005 to assist ENs in submitting documentation and receiving payment. Technical assistance takes place by telephone, through an online discussion group, and through distance learning courses on the web and on CD-ROM. Program Manager staff also continue to contact each EN by telephone every month to discuss assigned Tickets and problems or to answer questions.
To meet the increased demand for technical assistance on submitting payments, t he Program Manager established a new unit to deal with payment matters. Because of the high turnover in EN staff, however, retraining is often necessary. The EN and Program Manager officials we interviewed for the study agree that each payment involves several contacts, a process that is time-consuming, cumbersome, and often frustrating for all concerned. Because of their dissatisfaction with the payment system, some ENs have threatened to drop out of TTW, although they sometimes remain providers once they begin receiving payments but refuse to accept new Tickets. (See Chapter X and Section C below for a fuller discussion of payment issues.)
The Program Manager continued to hold EN capitalization seminars throughout the country during 2004 and 2005 in order to assist ENs in raising money to cover the upfront costs of serving TTW beneficiaries. The goal is to assist ENs in locating and applying for additional funding to support their efforts in advance of receiving Ticket payments. Thornton et al. (2006; Chapters V and VII) provide more details about EN reactions to the capitalization initiative.
The Program Manager has produced two volumes of a publication entitled “Inside Employment Networks” and made them available on its website (www.yourtickettowork.com/marketing_best_practices). The booklets highlight ENs that, according to the Program Manager, appear to be seeing some success with TTW. The publications describe those ENs’ program models, screening processes, and “promising practices.” The Program Manager selected ENs for inclusion in the booklets in accordance with staff perceptions as to whether an EN would have positive comments about TTW. In fact, many of the ENs highlighted in the booklets appear to be experiencing problems with TTW implementation; some say they are losing money on the program. The publications contain no definition of “promising practices” or what constitutes a successful EN. Still, the booklets, which provide a glimpse of the variety of approaches taken by ENs to serve TTW beneficiaries, may be helpful for agencies considering the role of EN.
D. Operating an Efficient Payment System
During spring and summer 2005, SSA implemented several initiatives to expedite the payment process. First, it enabled ENs to use the COPP on the Program Manager’s Web site. Second, SSA staff prioritized the EN payment workload into three categories: payments that are payable right away (those that include evidence of work and earnings), payments for which the EN has submitted a COPP request, and payments needing additional documentation. OESP is expediting payments in the first two categories and sending those in the third category to field offices. Third, SSA staff has initiated an EN help desk staffed by experienced SSA staff to assist ENs in solving payment problems.
The number of requests for payment on behalf of beneficiaries who have begun working up to the SGA level continues to rise. The Program Manager now receives 400 to 600 payment requests per month, an increase of about 160 percent over the 2004–2005 period. At present, more than 7,600 payment requests have been processed on behalf of 1,363 beneficiaries, for an average of five or six payment requests per beneficiary. (See Chapter VIII for additional payment information.)
The EN and Program Manager officials we interviewed for the study reported that obtaining complete earnings documentation from beneficiaries continues to be a time-consuming process that often involves numerous faxes and telephone calls over several months. In many cases, an EN cannot obtain the necessary information from either the beneficiary or the employer, and therefore cannot get paid. To help address this situation, SSA lets ENs submit requests for payments under a “Good Faith” process that does not require any evidence that the beneficiary is working. SSA then sends these unverified cases to the SSA field offices and will pay the ENs if the field office can substantiate earnings.
While SSA is clearly trying to help ENs obtain the earnings verifications, turning to the field offices may not speed up the process substantially. The field offices must fit earnings verification into schedules that are already quite full with ongoing application and processing work. In addition, the verifications can be very time consuming because the field office staff must copies of pay stubs or other documentation of earnings from beneficiaries or employers, which is exactly what the ENs tried and failed to do. The field office staff must also use that documentation to calculate exactly when the beneficiary earned enough to go off cash benefits in order to determine the month in which TTW payments can start to be made. The field office staff we interviewed expressed frustration because they had been told that ENs and the Program Manager would do the earnings verification and pointed out that they have not been allocated additional staff to carry out these activities.
OESP officials assert that, with proper evidence provided, it takes less than 30 days for ENs to receive a milestone payment and only slightly longer to receive an outcome payment, but, as noted earlier, the evidence is frequently not available. ENs assert that anywhere from 3 to 6 months must elapse before they receive payment. As explained in Chapter VIII, the median lag time was 6 months (Exhibit VIII.10). First payments took longer to process, having a median lag time of almost 9 months; only 69 percent of first payments had been made within 12 months. OESP officials noted that these figures include time to process the “Good Faith” cases, which take much longer to process.
To speed the payment process and enable ENs to receive payments without submitting beneficiary pay stubs, the Program Manager implemented COPP in late 2003. ENs can use the process if the beneficiary is no longer on the rolls and SSA has previously made outcome-only payments for the beneficiary. Only a few ENs have used the process because most ENs’ beneficiaries do not meet the above requirements. Through July 2005, 457 payments were made under COPP, or 8.3 percent of all claims other than first claims paid during that period. However, three EN officials we spoke with who had tried to use COPP said that wage verification by ENs was still required. Other SSA initiatives to speed payment processing time were implemented in spring 2005; thus, our analysis does not address their impact, if any. (Chapter VIII provides a fuller discussion of processing time for EN payments.)
E. Systems Enhancements
The seeds of a cultural shift appear to be taking root at all levels of SSA. Although the agency’s primary mission is to distribute disability and retirement checks to eligible individuals, SSA appears to be integrating return-to-work issues into operations throughout the organization. While OESP has taken the lead in TTW implementation, the Office of Systems and Office of Operations has provided substantial support. SSA has designated a full-time Ticket coordinator in each region to manage all TTW activities and serve as a liaison between OESP and field offices. Thirty-two AWICs, generally located in field offices, train the office staff, provide technical assistance in answering work-incentive questions, and conduct community outreach on Ticket and other return-to-work issues. Most field offices have a WIL, who serves as the expert at the local level. Numerous enhancements to SSA data collection systems have helped field offices to both process work reports and track beneficiary earnings. Although attention to employment issues varies somewhat from one field office to another, it is clear that SSA is placing a stronger emphasis on return-to-work.
1. Training and Technical Assistance to Regional and Field Office Staff
The general trend since completion of the phase-in period has been minimal involvement on the part of field offices with the Ticket specifically and greater involvement with work incentives in general, with TTW one component of the work incentives. During Ticket rollout, SSA devoted significant effort to training regional office and field office staff, primarily using the “train the trainer” approach used before TTW rollout in Phase 1 states. AWICs and WILs continue to use the interactive video training tapes and provide new and refresher training to field staff on management information systems such as eWork and IDMS (described below) and on processing work reports. The training varies, depending on staff positions; telephone service representatives receive enough training to handle basic questions from beneficiaries, while claims representatives receive more in-depth training.
OESP has provided refresher training for Ticket coordinators and AWICS on systems issues, particularly with respect to using eWork, processing earnings reports, and handling requests for expedited reinstatement. For any changes in procedure and protocols, the Ticket coordinator reads the daily “policy net,” a daily e-mail that covers agency regulatory and policy changes, and then passes it on to the AWIC, who shares it with field office staff.
SSA staff training in Phase 3 states was somewhat scaled back from that provided in Phase 1 states due to limited budgets and the limited number of beneficiaries using their Tickets. Field office managers in three Phase 1 and 2 states told us that training was provided several years ago. Given the infrequent interaction with ticket holders and the high turnover of field office staff, the managers said that refresher training on more technical aspects of TTW and other work incentives is needed.
2. Systems Automation
SSA had to develop several enhancements to its systems to accommodate TTW. Congress did not make a special appropriation to SSA for TTW implementation. Instead, SSA had to fund TTW implementation activities out of its administrative budget, which was already under considerable pressure as the agency dealt with rising numbers of disability claims and the government-wide cap on administrative expenses. Therefore, system enhancements have occurred and will continue to occur in stages.
Since enactment of the TTW legislation, SSA has made significant progress in improving its automated systems, particularly in the areas of tracking and verifying earnings, administering continuing disability reviews, and determining when benefits become zero for EN payment purposes. Before these automation improvements, most of these functions were performed manually or required entry of the same information into several data systems.
During the past year, SSA has continued to improve its automated systems, particularly for tracking and verifying earnings and processing payments to ENs. The web-based initiative known as eWork was fully rolled out to all field offices in November 2004. It automates the documentation of all DI earnings information and enables field office staff to enter earnings information only once. eWork then populates all other relevant administrative data system fields and processes work reports, initiates CDRs, and tracks the number of months remaining in the trial work period. It also permits SSA field office staff and telephone service representatives to generate a receipt when a beneficiary receives SSI, DI, 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, such as a reduction in the monthly payment amount, is needed; all these operations were previously handled manually.
Field office managers, AWICs, and WILs reported that staff had mixed feelings about eWork. Staff who used it frequently, including AWICs and WILs, viewed the system favorably, and one staff member even described it as “awesome.” Staff members note that it reduces duplication of data entry, increases accountability by providing receipts of employment reports to the beneficiary, and allows rapid access to case information, such as number of trial work months used. Field office managers said that less frequent users found eWork difficult, particularly because they did not use it often enough to become proficient in its application. Some managers have solved the proficiency problem by assigning all return-to-work cases to the WIL so that other staff do not need to learn the system; others distribute return-to-work cases among all claims representatives in a field office so that all staff learn the system. All field office staff we interviewed for the report wished that eWork could be used to automate SSI as well as DI earnings information, but headquarters staff said that such change would be difficult.
eWork will be integrated into the computer center at SSA headquarters during the next year. While the integration will have little effect at the field office level, it will enable SSA to back up data, provide 24-hour technical support, allow disaster recovery, and increase security.
SSA has also made significant progress in remedying “bugs” in IDMS, which is the data system that includes management of disability benefit post-entitlement activity. Until August 2005, IDMS was incorrectly terminating the Tickets of beneficiaries who had achieved SGA-level earnings and were no longer eligible for cash benefits. Program Manager staff were not able to process EN payments because the Ticket had been terminated, requiring SSA headquarters staff to process the payments manually. Addressing incorrect terminations and the introduction of other programming improvements have reduced the number of manual payments SSA must make from about 70 per month as of August 2004 to about 4 per month in late 2005. Another bug that has been remedied in the past two years was t he inability of IDMS to associate a Ticket mail date with a beneficiary’s Social Security Number if a beneficiary received a second Ticket.
At the end of June 2005, SSA began working with Lockheed Martin to develop the requirements analysis for the Comprehensive Work Opportunities Support System (CWOSS). The system will replace the system owned by the Program Manager and used to track EN applications, Ticket assignments, and EN payments. CWOSS will be government- owned and comply with Section 508 of the Rehabilitation Act, which mandates accessibility of computer software for people with disabilities. CWOSS will interact with SSA’s other Ticket and disability-related systems to improve Ticket assignment, initiate SSA work report verification, store EN data, and generate lists of appropriate ENs for beneficiaries and lists of beneficiaries for appropriate ENs. SSA staff expect the system to increase the overall efficiency of Ticket program administration.
3. Rules and Regulations
SSA continues to develop and issue regulations as mandated by the Ticket Act. On September 30, 2005, SSA proposed regulations (discussed in Chapter IX) that would modify several matters in the TTW final rules, including SVRA participation and EN payment provisions. SSA officials have reviewed comments on the regulations and hope that the regulations will be adopted in 2007. Meanwhile, SSA continues to draft other regulations to implement TTW, some of which have become final during this reporting period. The proposed and final regulations are described below.
Timely Progress. Two years after a Ticket is issued, the Ticket act requires a series of reviews to determine whether TTW participants are making “timely progress” toward self-supporting employment. So long as beneficiaries are determined to make timely progress, their assigned Tickets are considered to be in use. SSA asked for comments on how to implement the timely progress provisions in the September 30, 2005, proposed regulations. Due to the complexity of administering the timely progress reviews, SSA suspended the timely progress review requirements until the proposed regulations become effective.
Under the previous regulations, the timely progress reviews, which were to begin in March 2004, determined whether the beneficiary was “actively participating” in his or her IWP and making progress toward employment. During the 24-month review, the beneficiary must have been actively trying to achieve the goals set forth in the IWP. At the 36-month review, the beneficiary must have earned the SGA level for at least 3 months during the past year; at the 48-month review, the beneficiary must have worked for at least 6 months during the past year. If the beneficiary did not pass the review, the beneficiary was determined to be no longer using the Ticket and subject to CDR and potential loss of benefits.
Because of the complexity of implementing the timely progress requirements, the reviews did not start until November 2004. During 2005, the Program Manager sent a notice to each EN (including SVRAs) that had held a beneficiary’s Ticket for 24 months (and every 12 months thereafter) and asked whether the beneficiary was participating in his or her IWP, whether and how much the beneficiary had worked during the past 12 months, and whether the EN could foresee the beneficiary fulfilling the IWP requirements. If the EN did not respond, the Program Manager assumed that the answers to the above questions were “yes” and took no further action. If the responses were “no,” the Program Manager sent a letter to the beneficiary explaining that he or she had not met the timely progress requirements and encouraged the beneficiary to more actively participate in TTW. When TTW participants were asked in the NBS if they were aware that, to remain in the program, they must participate in the activities described in their IWP during the first few years and work for three to six months each year during the later years of their participation, 32 percent of respondents were aware of the requirements (Exhibit IV.5).
The process of, first, determining which ENs should receive the timely progress notices and, second, generating the appropriate letter to each beneficiary proved extremely cumbersome for the Program Manager. SVRA and EN officials also reported that responding to the timely progress notices presented a significant administrative burden. Given that an SVRA may have had hundreds of Ticket assignments, the process of determining the employment status of each beneficiary was arduous and time-consuming. ENs we interviewed that had Tickets for 24 months or longer said that tracking down a beneficiary to determine his or her status added to the burdensome and bureaucratic program requirements--with little positive results. Because a non-response to the notice gave a “pass” to the beneficiary, some interviewed SVRAs and ENs with a large number of Tickets have opted not to respond. These factors undoubtedly contributed to SSA’s decision to suspend the timely progress reviews.
Continuation of Benefits Final Rules. The final rules on continuation of benefits (also known as the 301 regulation) were published in the Federal Register on June 24, 2005, and became effective on July 25, 2005 (70 FR 36494). The rules provide that if a medical CDR is conducted with a beneficiary who is participating in an approved plan of rehabilitation, including the IWP under TTW, benefits will continue until the beneficiary completes the program. The regulations make it clear that TTW program participants will be exempt from benefit termination based on medical improvement of a disability.
Expedited Reinstatement (EXR) Final Rules. This provision, sometimes referred to as “easy back on,” implements Section 112 of the TTW legislation and allows beneficiaries who have left the rolls for work to have their benefits reinstated without filing a new application if they lose their job because of their disability. The purpose of the provision was to assure beneficiaries that their benefits could be immediately restored if their attempt to work failed, thus removing concerns about benefit reinstatement as a work disincentive.
Implementing the EXR has been problematic, and there seems to be little advantage to relying on EXR versus filing a new application for benefits. Field office staff estimate about a three-month delay between the time of the EXR application and the time at which payments begin. Forms for the EXR cannot be completed on the web, although the current EXR paper process has proven cumbersome, according to field office staff. The staff ask first ask for the paper files to be sent from the SSA Claims Processing Center and then send them on to the Disability Determination Service. In some cases, the beneficiary may receive a higher level of benefits by submitting a new application because of his or her recent work efforts. Making the benefit determination is extremely complex, according to field office staff. During the coming year, SSA will automate the EXR process and presumably see some decrease in delays. One advantage of EXR is that field office staff can request immediate monthly payments for emergencies and ensure that funds are available in a few days, but the request is still performed manually.
Referral of Eligible Beneficiaries to Agencies Other Than SVRAs. SSA is drafting a final rule to refer eligible beneficiaries to agencies other than SVRAs for rehabilitation services. Under previous regulations, SSA had to refer all beneficiaries to an SVRA for rehabilitation services. The TTW legislation repealed the referral-to-SVRA requirement and substituted referral to an EN “or another program of vocational services, employment services, or other support services” under TTW (Sec. 1615). SSA has drafted a Notice of Proposed Rule Making on Continuing Disability Reviews, which is due to be published in the Federal Register.
The current complexity of TTW and the sluggishness of the provider and beneficiary response create little incentive for active participation in TTW. Providers and beneficiaries alike still lack basic information about how the program operates, and despite several initiatives by SSA and the Program Manager, the payment process remains complex, slow, and uncertain, with little financial incentive to providers. Such obstacles are not unusual for a relatively new program. The regulations SSA recently promulgated alter the way SVRAs participate in the program and substantially change the EN payment schedule to address the most important program issue reported by EN officials—an inadequate payment structure. To reinvigorate the program, both the supply of providers and demand for services will need to be addressed.
5 The AWIC position was created in 2003; outreach before that date was handled by the employment services representative (ESR) or other staff. The ESR position was abolished when the AWIC position was created. See Thornton (2003) for a fuller discussion of this issue. (back)
6 Fieldstone Alliance is a nonprofit organization that offers consulting, publishing, training, network development, demonstration projects, and capacity building to strengthen nonprofits and their communities, intermediaries, and funders. (back)