Transcript Impact of New TTW Regulations on WIPA/CWIC

The New and Improved Ticket Program
What CWICs Need to Know NOW!
Virginia Commonwealth University
WIPA NTC
August 2008
So, why all the changes?
The improvements in the Ticket Program
were specifically designed to accomplish
one main objective:
Increase the likelihood that beneficiaries
of the SSA disability programs will
become employed at a substantial level
and decrease dependence on disability
benefits!
How will the improvements increase
employment?
By…..
 Increasing the number of Employment
Networks (ENs) available to serve
beneficiaries
 Increasing the number of beneficiaries who
either assign their Tickets to an EN or receive
services from state VR agencies under the
cost reimbursement option (or both).
 Increasing the number of Tickets accepted by
ENs
Key EN Payment-Related Changes to
the Ticket Program

New milestone payment schedule for ENs
allows for incremental payments prior to a
beneficiary achieving SGA
 New payment schedule comparable for
serving a beneficiary receiving SSI or title II
disability benefits (SSDI, CDB, DWB)
 Milestone payments to ENs are based on
GROSS earnings instead of countable
earnings, which eliminates previous penalty for
using work incentives
 Simplification of how earnings are verified for
EN payments
Other Key Changes to the Ticket
Program
Beneficiaries may use state VR services
under cost reimbursement without
assigning the Ticket, while still getting
the medical CDR protections
 Beneficiaries designated as “Medical
Improvement Expected” (MIE) now get
Tickets immediately without having to
wait till after the first medical review

More key changes….
Using a Ticket for purposes of retaining
CDR protection may now include
completing a range of different
educational programs
 Progress review periods are all 12
months in duration with incremental
increases in work or educational
requirements for each period

Where do WIPAs fit into the new and
improved Ticket initiative?
WIPAs are all about promoting WORK – so is
the Ticket! WIPA services are critically
important for educating beneficiaries about
how to use the Ticket and other work
incentives to achieve their employment goals
 As a work incentive, the Ticket offers valuable
advantages to those beneficiaries for whom it
is applicable
 Like all work incentives, it will not help ALL
beneficiaries!

CWIC obligations to beneficiaries
under the Ticket Program include…
1. Screening all beneficiaries to identify Ticket
eligible individuals who would most benefit
from Ticket assignment and who would make
strong candidates for Ticket use and/or
assignment.
2. Explaining how the Ticket Program functions
and what benefits individuals receive from
using their Ticket.
3. Encouraging beneficiaries who are strong
Ticket candidates and would benefit from the
Ticket Program to consider Ticket
assignment.
CWIC obligations to beneficiaries
continued
Counseling beneficiaries on Ticket
assignment by providing information about
ENs in the area and helping the beneficiaries
select an EN which best matches the
individual’s service or support needs and
preferences.
5. Having “firewall” procedures in place which
prevent a conflict of interest when WIPA
services are provided by an agency that also
serves as an Employment Network.
6. Counseling beneficiaries on what constitutes
“timely progress” for each 12-month review
period in the Ticket program.
4.
Obligations to beneficiaries
continued
7. Having current and complete knowledge of
all ENs serving the WIPA project catchment
area and which of those ENs are currently
accepting Tickets.
8. Knowing what services the various ENs
provide, what participant eligibility
requirements are and any restrictions on
services or eligibility.
9. Referring beneficiaries to ENs based on
individual service or support needs and
preferences.
CWIC obligations to ENs under the
Ticket Program include…
Providing information to ENs about the WIPA
program, including: services provided, limits
on services, eligibility requirements, and
characteristics of a high priority WIPA
referral.
2. Providing individualized work incentives
planning and assistance to beneficiaries with
Tickets assigned to local ENs.
3. Assisting ENs to use BPQYs, Benefits
Summary & Analysis reports, and Work
Incentive Plans to plan employment services
and supports.
1.
Obligations to ENs continued
4. Assisting ENs to understand how paid
employment or self-employment affects a
beneficiary’s SSA disability benefits,
Medicaid/Medicare, and all other applicable
federal, state and local benefit programs.
5. Helping ENs to understand when and how
specific work incentives are applied to the
SSA disability benefit programs to help
beneficiaries achieve employment goals.
6. Working collaboratively with ENs to resolve
problems beneficiaries experience while
using a Ticket.
Obligations to ENs continued
7. Coordinating with ENs to insure that work
incentives are properly applied, work CDRs
are conducted in a timely fashion and cash
benefits are adjusted or ceased
appropriately.
8. Assisting with making Ticket assignment
changes such as placing the Ticket in
inactive status, un-assigning a Ticket, or reassigning a Ticket.
9. Helping resolve any problems encountered
with assigning or using a Ticket.
Limits on CWIC Role in the Ticket
Program


CWICs should not provide training, technical
assistance or other information on EN
payment mechanisms under the Ticket to
Work Program. ENs with questions about
how services are paid for under the Ticket
should be referred to Maximus.
CWICs are not required to provide intensive
training on SSA work incentives to ENs or
the State VR agency.
More Limits on CWIC Role


CWICs are not required to provide technical
assistance to ENs on the affect of
employment on SSA disability benefits or the
application of work incentives, except when
working collaboratively to serve specific
beneficiaries who have assigned Tickets in
use.
WIPA projects are not expected to provide
vocational rehabilitation, career counseling,
or job placement services of any type.
CWICs should refer beneficiaries to the local
agencies for these services as appropriate
New Eligibility Rules for Ticket
All SSI and Title II disability beneficiaries in
cash payment status are eligible to receive a
Ticket, except:

Beneficiaries who are under age 18 or who are
full retirement age or older;
 Childhood SSI beneficiaries who have attained
age 18, but who have not had a
redetermination under the adult disability
standard.
Others NOT Eligible for a Ticket

Persons receiving payments under Section
301;
 Persons receiving payments while appealing
termination based on medical improvement;
 Persons receiving provisional payments
while waiting for an EXR determination; and
 Persons getting presumptive disability
payments.
What are the benefits of assigning and
using a Ticket?

Enhanced access to services and supports
from a broader array of ENs in addition to the
state VR agency
 Protection from medical CDRs while Ticket is
assigned and in use, and the beneficiary is
making “timely progress”
 Protection from medical CDRs while accessing
services from state VR agency using the cost
reimbursement option, although Ticket is NOT
considered to be “assigned”.
Definition of “Using a Ticket”
Using a Ticket means that a beneficiary
has assigned a Ticket to an EN or state
VR agency acting as an EN, or has a
Ticket in VR cost reimbursement status,
AND
 the beneficiary is making timely progress
toward self-supporting employment

When is a Ticket considered to be in
use?

A Ticket is considered to be in use effective
the day the Ticket is assigned to an EN or the
state VR agency acting as an EN
 If the beneficiary is receiving services from a
state VR agency under the cost
reimbursement option, the Ticket is considered
to be “in use” for the purposes of CDR
protection even though the value of the Ticket
is not consumed and it is still available for
assignment after the state VR agency closes
the case. The date of the IPE marks the start
of “in use” status in these cases.
The New & Improved Timely
Progress Definition!




Complete the specified goals of work and
earnings, or
Attain a GED in the first year, or
Complete the specified number of course
requirements for a training program at an
educational institution consisting of technical,
trade, or vocational school, or
Complete the specified number of post
secondary education credits at an
educational institution in pursuit of a degree
or certification.
Progress Certification Periods

SSA eliminated the initial 24-month period and
replaced it with two 12 month progress
certification periods. Subsequent certification
periods are all 12 months long
 Different levels of work, education or training
are required in each of the different 12 month
progress certification periods
 Maximus will review progress at the end of
each 12 month certification period to see if the
applicable requirements were met and Ticket
continues to be in use
New Rule - Variance Tolerance!

SSA considers the beneficiary to be making
timely progress when the completed course
hours or course requirements are within 10%
of the specified goal.
 In addition, SSA considers a beneficiary to
have met the requirements of a 12-month
period when the percentage of the educational
or vocational training requirement completed
and the percentage of the work requirement
completed adds up to within 10% of the
specified goal.
First 12 Month Progress Certification
Period




Obtained a HS diploma or GED
certificate.
Enrolled in 2 or 4-year degree or
certification program and have
completed 60% of full time course load
for 1 year.
Enrolled in vocational/technical
program and have completed 60% of
full time course load for 1 year.
Worked at least 3 out of 12 months with
gross earnings at TWP level or above.
Second 12 Month Progress
Certification Period



Enrolled in vocational/technical
program and have completed 75% of
full time course load for 1 year.
Enrolled in 2 or 4-year degree or
certification program and have
completed 75% of full time course load
for 1 year.
Worked at least 6 out of 12 months with
gross earnings at TWP level or above.
Third 12 Month Progress Certification
Period



Completed the technical, trade or
vocational program.
Completed a 2-year degree or
certification program, or for a 4-year
program, completed an additional
academic year of full time study.
Worked at least 9 out of 12 months with
gross earnings at non-blind SGA level
or above.
Fourth 12 Month Progress
Certification Period


Enrolled in a 4-year degree program
and have completed an additional
academic year of full time study.
Must have worked at least 9 out of 12
months with gross earnings at nonblind SGA level or above.
Fifth 12 Month Progress Certification
Period


Enrolled in a 4-year degree program
and have either completed an
additional academic year of full time
study or completed the program and
have earned a degree or certification.
Worked at least 6 out of 12 months with
earnings that precludes payment of
cash disability benefits.
Sixth and Subsequent 12 month
Progress Certification Periods
Completed the 4-year degree program
 Worked in at least 6 months within the
12 month period and have earnings in
each of these 6 months sufficient to
preclude Social Security disability
and/or Federal SSI payments

What about beneficiaries who
already had Tickets in assignment?

SSA will determine which 12-month progress
certification period the beneficiary is in as of
July 21, 2008 using the new rules in 411.226
(a)(1) (see next slide)
 SSA will not conduct a progress review at the
end of the progress certification period the
beneficiary is in on July 21, 2008, but will
conduct a progress review at the end of the
next progress certification period
 SSA will use the timely progress guidelines
under the new Ticket rules beginning with the
next 12-month progress certification period
More about Transitional Ticket
Cases

SSA will determine the applicable 12-month
progress certification period and the number of
months remaining in that period as of July 21,
2008 by counting all months during which the
beneficiary’s Ticket was assigned and in use
during the period 

Beginning with the month following the month in
which you first assigned your Ticket under the rules
in effect prior to July 21, 2008; and
Ending with the close of June 2008.
What about people being served by
VR under cost reimbursement?

If, on June 30, 2008, a beneficiary has a Ticket
in use and assigned to a State VR agency
which chose to be paid for services under the
cost reimbursement payment system, the
period of using a Ticket may continue.
 While the Ticket may still be considered in-use
for the purpose of the suspension of medical
CDRs, it will no longer be considered assigned
to that State VR agency effective July 21,
2008.
Temporary Moratorium on Timely
Progress Requirements
SSA has placed a moratorium on timely
progress reviews through January 2010
and will revisit the issue in January, 2009
to decide whether initial notifications
containing the new guidelines can go out
to beneficiaries at that time in
preparation for the reviews to start a year
later.
Brief Review of Other Ticket
Provisions and Rules
Things that haven’t changed, or
changed very little with the new
regulations……
Determining Ticket Status


Ticket to Work Query provides general information
about current Ticket status. This screen will show date
when VR case work begins and ends when a VR cost
reimbursement case is involved. The new indicators are
“SVR In Use” or “SVR Not In Use”
General Ticket Query provides current Ticket
information as well as more specific data such as the
date the system selected the beneficiary’s record, the
date the system mailed the Ticket, and the current
status of the Ticket. This screen will have the same
change as the Ticket to Work Query screen when a VR
cost reimbursement case is involved.
Determining Ticket Status
Continued

Ticket Status Range Query provides detailed
historical record of Ticket activity by EN.
 Ticket Use History (TKUH) query provides a
complete historical record of Ticket activity for
each beneficiary once the Ticket has been
assigned or in use with a state VR agency.
Under “In-Use” field, there will be new
indicators “S” for “SVR In Use” or “R” for SVR
Not In Use”.
Ticket and Work Incentives
SSA treats the earnings of a Ticket user
in the exact same fashion as a non-user.
There are NO special work incentives
afforded to Ticket users, nor restrictions
on using available work incentives
 Using a Ticket does provide the
beneficiary protection against the
initiation of Medical CDRs
 Work CDRs will continue and may result
in termination of benefits

Ticket Limits
One Ticket is provided per period of
entitlement to SSI or Social Security
disability benefits. A new period of
entitlement may result in a new Ticket
being issued
 A new Ticket may be issued if
entitlement is terminated, but is later
reinstated (EXR).
 There are no limits on the total number
of Tickets a person may receive.

Reassigning a Ticket





Beneficiaries may reassign their Ticket for any reason,
at any time
Contact Maximus in writing to notify them of intent to
reassign the Ticket
A 90-day extension period is provided to secure
another provider (used to be 3-months under old rules)
Beneficiaries do not have to be in current cash benefit
payment status to reassign their Tickets during the 90day period.
The 12 month certification period now always resumes
where it left off when the beneficiary reassigns to a
new EN or the previous EN.
Extension Period
A 90-day period during which an “in use”
Ticket may be unassigned for the purpose of
reassignment
 The Ticket is still considered "in use”
 The Ticket may be assigned to either an EN or
the state VR agency acting as an EN after this
90-day period
 Beneficiaries may assign their Ticket during
the 90-day period after their case is closed by
the state VR agency when services are
delivered under the cost-reimbursement option

Extension Period Continued

If the Ticket is not reassigned during the
extension period, it is considered not in use
after the close of the extension period. This
means that medical CDRs may be initiated
 The extension period doesn’t count in
determining whether the beneficiary is making
timely progress toward his/her work goals.
 Beneficiaries may not assign their Ticket to
more than 1 provider of services at a time.
Inactive Status

Beneficiaries may place their Ticket in inactive
status if they are temporarily or indefinitely
unable to make timely progress.
 A written request to Maximus is required in
order to place a Ticket in inactive status.
 Months in inactive status don’t count in
deciding whether the beneficiary is making
timely progress during progress certification
periods.
 The Ticket is not in use during inactive status
CDR Protection for Ticket Users

SSA may not initiate a CDR while a
beneficiary is “using a Ticket”
 Under the new rules, this applies when a
Ticket is assigned to an EN or the state VR
agency acting as an EN, or when the
beneficiary is receiving services from a state
VR agency under the cost reimbursement
option.
 If a Ticket is assigned after a medical CDR is
initiated, SSA will complete the review.
When is a CDR “Initiated”?


The CDR initiation date is the date on the
notice sent to the beneficiary that informs
him/her that SSA is beginning to review
the disability case. For CDR mailers, the
system displays the initiation date as the
last day of the month the notice is sent.
The CDR initiation date is NOT the same
thing as the diaried date since CDRs are
rarely initiated on the exact diaried date.
The End of “Using a Ticket” Status

The last day of the month before the month in
which the Ticket terminates
 60th month for which an outcome payment is
due to an EN
 Day before the effective date of a decision that
the beneficiary no longer meets timely
progress requirements
 When the beneficiary fails to reassign the
Ticket by the end of a 90-day extension
period.
When a Ticket Terminates

Month in which entitlement for SSI or Title II
disability benefits is terminated for reasons
other than work activity (Note: suspension of
SSI benefits/payments will not cause a Ticket
to terminate), or
 Month in which SSA makes a final
determination not to reinstate benefits, or
 For DWBs – the month in which the person
attains full retirement age, or
 For all SSI recipients – the month following the
month the person turns 65, or
When a Ticket Terminates
Continued

The month after the month in which the
outcome payment period ends, or
 The month the Ticket holder again becomes
entitled to SSI or title II disability benefits or is
awarded Expedited Reinstatement of benefits,
or
 The month the Ticket holder becomes entitled
to a Social Security or SSI non-disabilitybased benefit, or
 The month the Ticket holder dies.
It is time to actively embrace the
Ticket to Work!
The Ticket to Work is one more
valuable tool in the work incentives
toolbox that CWICs can use to support
a beneficiary’s employment efforts and
goals
 CWICs are responsible for learning to
use this tool skillfully
