2019 Red Book
Example of concurrent benefits with Employment Supports
Many individuals are eligible for benefits under both the Social Security Disability Insurance (SSDI) and Supplemental Security Income (SSI) programs at the same time. We use the term “concurrent” when individuals are eligible for benefits under both programs. Below we describe how a return to work may affect an individual’s concurrent benefits.
Armando files applications for SSDI benefits and SSI on February 27, 2017. His medical condition caused him to stop work beginning February 14, 2014. We call this date his “alleged onset date” of disability.
Armando was approved for disability benefits.
Armando receives an award letter on June 7, 2017, stating he is approved for disability benefits with his alleged onset date of February 14, 2017.
|March 2017||Armando’s SSI benefits begin the month after he filed his application. He is eligible for $735 per month (the Federal Benefit Rate [FBR] in 2017). Armando also becomes eligible for Medicaid.|
Armando’s SSDI benefits begin. This is the month after Armando completed his five-month waiting period. The five months began the first full month after Armando’s approved onset date of February 14, 2017. The five months were March, April, May, June, and July 2017. Armando is eligible to receive SSDI benefits beginning August 2017. His monthly benefit amount is $300, which reduces his SSI to $455:
$300 SSDI - $20 general income exclusion = $280 countable unearned income
$735 FBR - $280 countable unearned income = $455 SSI payment.
Armando qualifies for Medicare.
Armando qualifies for Medicare after 24 months of entitlement to SSDI benefits. Medicare Hospital Insurance (Part A) is premium-free; Medicare Supplementary Medical Insurance (Part B) is optional but there is a premium. Armando’s state pays his Part B premium for him because he is eligible for SSI and has been covered by Medicaid since March 2017. Armando now has both Medicare and Medicaid. Medicare is the primary payer and Medicaid is the secondary payer. If Medicaid eligibility lapses, the Medicare premiums would be deducted from SSDI benefits if they are still being issued. If no payments from Social Security are received, then Armando will be billed quarterly for his Medicare.
Armando wants to work.
|December 2012||Armando contacts his local Social Security office on December 7, 2021, to learn how a job will affect his SSDI, SSI, and health insurance benefits. Armando is a certified auto mechanic, and a local car dealership has offered him a job.|
Armando returns to work.
Armando begins work at the car dealership. The dealership pays him $2,000 a month.
How Armando’s work affects his SSDI benefits.
Armando’s trial work period (TWP) begins. During the TWP, Armando can continue to receive full SSDI benefits for at least nine months regardless of the amount of his earnings. Each month that Armando earns over the TWP amount ($880 in 2019) will count as a TWP service month. His TWP ends with the 9th TWP service month in a rolling 60-month period.
|September 2022||Armando provides pay stubs showing his steady work activity since January 2022. We determine Armando’s TWP months are January, February, March, April, May, June, July, August, and September 2022. Armando completes his TWP in September 2022.|
Armando’s extended period of eligibility (EPE) begins the month after his TWP ended. For the next 36 months (through September 2025), Armando will be paid benefits for any month he does not work over the substantial gainful activity (SGA in 2019 is $1,220) level. We refer to this 36-month time period as the re-entitlement period.
Is Armando performing SGA?
We know from Armando’s pay stubs that he receives $2,000 a month in wages. Armando tells us that he is able to complete only four car repairs a day, compared to his co-workers who complete an average of 6-8 car repairs a day. Armando believes he is paid the same salary as his fellow co-workers. If this is the case, Armando’s employer may be subsidizing his wages.
We contact the employer and learn that the employer is paying Armando $2,000 a month, the same rate as experienced employees who complete 6-8 repairs a day. The employer pays Armando the same rate as the experienced employees because he knows about Armando’s disability and understands it takes him longer to complete tasks. The employer calculates that the actual worth of Armando’s services is $1,800 a month. This means that Armando has a monthly subsidy of $200, which is the difference between what he is paid ($2,000) and what his employer says his services are worth ($1,800).
Armando takes a taxi to and from work and provides receipts showing this cost is $350 per month. Armando’s treating physician confirms that his condition prevents him from driving. He cannot take public transportation because crowded situations aggravate his condition. Since Armando pays for his work transportation and there is a medical need for him to take a taxi, we can deduct the cost of his transportation expenses as impairment-related work expenses (IRWE).
We use Armando’s subsidy and IRWE to determine if his earnings are SGA as follows:
$2,000 wages - $200 employer subsidy - $350 IRWE = $1,450 monthly earnings
$1,450 is over the monthly SGA level for 2019 of $1,220, so Armando is engaging in SGA in the first month of his EPE, October 2022. (Note: We used the SGA amount for 2019because at this time we do not know the SGA amount for 2022.)
Armando’s SGA level work activity affects his benefits in the EPE.
We stop Armando’s SSDI benefits. Armando does not meet our requirements in October 2022 because we determined he was engaging in SGA. We can pay Armando for the month of cessation and the two following months. We refer to these three months as the “grace period”. Armando’s grace period months are October, November, and December 2022.
For any month that Armando’s earnings fall below the SGA limit during his 36-month re-entitlement period, we can restart his benefits without a new application. If we restart Armando’s benefits during the re-entitlement period, he can continue to collect benefits if his work activity is below the SGA limit, even after the 36-month re-entitlement period ends.
Will Armando’s entitlement to SSDI terminate?
Armando’s entitlement will terminate if his work activity continues over the SGA level. This is the first month after the end of the 36-month EPE. Armando’s entitlement may stop earlier than October 2025 if he no longer meets our disability requirements.
How does Armando’s work activity affect his SSI benefit?
SGA rules are different for SSI. For SSI disability benefits, we only consider SGA when the initial claim is filed (unless the disability is blindness, then we do not consider SGA at all). We do not consider SGA after a person becomes eligible for SSI. However, we must determine whether the person continues to meet the non-disability requirements, including income and resources. We determine the effect of Armando’s earnings on his SSI eligibility and payment amount on a month-by-month basis.
Armando’s income for January 2022 through December 2022 is SSDI of $300 per month and wages of $2,000 per month. Because Armando’s monthly income does not change, the calculation will be the same for all months in 2022.
First, we figure his countable unearned income by subtracting the $20 general income exclusion from his SSDI:
$300 SSDI - $20 = $280 countable unearned income
Next, we calculate his countable earned income by first subtracting the $65 earned income exclusion from his wages:
$2,000 - $65 = $1,935
From this amount, we deduct the $350 IRWE for the taxi transportation:
$1,935 - $350 IRWE = $1,585
Armando’s subsidy is not an earned income exclusion for SSI; subsidy applies only to the SSDI SGA determination. This means we cannot subtract the $200 monthly subsidy when we figure his SSI payment and eligibility. However, the IRWE deduction applies to both the SSDI SGA and SSI payment determinations.
The second step in figuring Armando’s earned income is to divide this result by 2:
$1,585 ÷ 2 = $792.50 countable earned income
We now add the countable unearned income and the countable earned income to determine total countable income:
$280 countable unearned income + 792.50 countable earned income = $1,072.50 total countable income
Finally, we subtract the total countable income from the SSI FBR to determine SSI eligibility and payment amount:
$771 (FBR in January 201) - $1,072.50 countable income = $0 SSI payment (Note: We used the FBR for 2019 because at this time we do not know the FBR for 2022.)
Armando will not receive SSI payments for January 2022 through December 2022 because of his SSDI benefits and monthly earnings. However, he is still eligible for SSI and Medicaid While Working (under section 1619(b) of the Social Security Act) as long as his earnings remain under his state’s threshold amount, he needs the Medicaid coverage, and he continues to be eligible for SSI except for his earnings.
Armando will not receive SSDI benefits beginning January 2023 as long as he works over the SGA level.
Armando reports that he received a pay increase to $2,300 per month beginning in January.
His IRWE has increased to $400 per month. Armando’s only income is his wages since he is not receiving an SSDI payment. Here is how we figure his SSI eligibility and payment amount for January 2023.
We subtract both the general income exclusion and earned income exclusion from monthly earnings:
$2,300 wages - $20 general income exclusion - $65 earned income exclusion = $2,215
$2,215 - $400 IRWE = $1,415 ÷ 2 = $907.50 countable earned income
$771 (FBR in January 2019) - $907.50 countable income = $0 SSI payment (Note: We used the FBR for 2019 because at this time we do not know the FBR for 2022.)Armando is not eligible for any SSI payment unless his earnings or IRWE change.
Will Armando continue to have Medicaid?
Medicaid will continue as long as Armando’s earnings are below his state’s threshold amount, he needs the Medicaid coverage, and he continues to be eligible for SSI except for his earnings. During this time, he is eligible for an SSI payment for any month that his countable income is under the FBR amount. When Armando’s earnings exceed the state threshold amount, his Medicaid will end. However, he may then be eligible to buy into Medicaid if he resides in a state that has the optional Medicaid buy-in program.
Will Armando continue to have Medicare?
Armando will no longer receive SSDI payments, but his Medicare coverage will continue for at least 93 months after his TWP (which ended September 2022) as long as he continues to have a disabling impairment (has not medically improved). Armando’s Medicare coverage will terminate on July 1, 2030.
Armando could then choose to purchase Premium Medicare Hospital Insurance coverage (Part A). If he purchases Part A, he can purchase Part B. He can qualify for the Part A reduced rate since he has earned at least 30 quarters of coverage. We will base Armando’s Medicare Insurance (Parts A and B) premiums on the rates in 2030, the year his premium-free coverage ends.
Armando will have to file an application with Social Security if he decides to purchase Medicare coverage in 2030. He will also have to undergo a medical continuing disability review. Armando can purchase Medicare coverage if we determine that his medical condition has not improved after conducting this review.
If Armando still has Medicare when he turns age 65, it will automatically convert to Medicare under the Aged provisions.
Summary of Example with Concurrent Benefits
|03/17||SSI benefits and Medicaid start|
|SSDI benefits start|
|SSI stops due to earnings|
|Work at SGA continues|
|SSDI benefits cease, grace months|
|for payment are 10/022-12/22|
|SSDI benefits stop|
|Extended Medicare begins|
|SSDI termination month|
|Medicaid ends if earnings are over state|
|Extended Medicare stops|
|May be able to purchase Premium HI|
|and/or buy into Medicaid|
|Last month to file for EXR if no longer working and|