Social Security Administration
Better Planning Could Make the Ticket Program More Effective Gao ID: GAO-05-248 March 2, 2005The Social Security Administration (SSA) manages the two largest federal disability benefit programs and made approximately $75 billion in payments to about 8 million beneficiaries (ages 18 through 64) in 2003. Given the size of its programs, even small improvements in SSA's ability to return beneficiaries to work offer the potential for significant savings. Until recently, Social Security beneficiaries who needed help returning to work generally had to seek services from state vocational rehabilitation (VR) agencies. Few beneficiaries used these services or successfully returned to work. Therefore, Congress passed the Ticket to Work and Work Incentives Improvement Act of 1999 (Ticket Act, P.L. 106-170) to create a Ticket to Work and Self-Sufficiency Program (the Ticket program). The program's goals are to expand the availability of service providers and to help enable beneficiaries to return to work, become selfsufficient, and stop receiving disability benefit payments. Eligible beneficiaries can use their tickets as vouchers to request vocational rehabilitation, employment, or other support services from the traditional state VR agencies or from new SSA-approved public or private providers, which are referred to as employment networks (EN). The act required SSA to implement the Ticket program and make tickets available to all eligible beneficiaries. SSA decided to use three phases to make tickets available: (1) beginning with 13 states in February 2002, (2) expanding to 20 more states and the District of Columbia in November 2002, and (3) expanding to the final 17 states and 5 territories in November 2003. The act also required SSA to perform several periodic and independent evaluations of the program. For example, SSA was mandated to periodically review the systems used to make payments to the providers and was also given authority to make needed changes. The act also required SSA to provide Congress with three independent evaluations of the effectiveness of program activities. Finally, the act created the Ticket to Work and Work Incentives Advisory Panel (the Advisory Panel) to include experts on employment and related services and representatives of individuals with disabilities to provide advice and reports on the program to SSA, the Congress, and the President. The Congress also mandated in the Social Security Protection Act of 2004 that GAO evaluate the Ticket program and provide a report to Congress by March 2, 2005. The statute requires that GAO (1) examine the annual and interim reports issued by the Commissioner of Social Security and the Advisory Panel, (2) assess the effectiveness of the activities carried out under the program, and (3) recommend legislative or administrative changes, if appropriate. To meet these requirements, our report examines: (1) the progress SSA has made in implementing and evaluating the Ticket program and achieving its goals, (2) the problems that have limited the program's ability to achieve its goals, (3) the recommendations to better achieve the goals of the program made by the Advisory Panel, researchers, and service providers, and (4) the challenges SSA faces in implementing changes to achieve the program's goals.
SSA has made progress implementing and evaluating the Ticket program, but the agency has had limited success in achieving the program's goals of expanding beneficiaries' choice of service providers and increasing beneficiaries' efforts to work and become self-sufficient. The Ticket program's ability to achieve its goals has been hindered by several factors, according to the Advisory Panel, researchers, and service providers. First, service providers believe that the program's payment system does not provide adequate compensation for the administrative costs of participating. Second, participation of eligible beneficiaries has been limited by the lack of ENs, the lack of outreach to provide information about the program, and the lack of incentives to encourage beneficiaries to participate. The Advisory Panel and others have suggested numerous changes to improve the Ticket program. The Advisory Panel and others believe that reforming the payment system is critical to expanding participation. In addition, they suggested numerous changes to reduce the administrative burden for service providers, such as having SSA provide additional services, guidance, and information to providers. SSA faces several challenges as it tries to improve the Ticket program's ability to achieve its goals. Although SSA has made some administrative changes to the program, the agency recognizes that additional changes are needed. However, SSA has deferred other reforms until it has performed additional assessments on changes that it believes could be costly. we believe rigorous planning is needed to provide sufficient and reliable information to adequately assess the numerous proposed reforms put forth by the Advisory Panel and others. Thorough and reliable analysis is particularly important because of the complexity and potential costs of this nationwide program, as well the opportunities that it could provide to beneficiaries who want to become self-sufficient. Without a well-defined plan to assess proposed changes, SSA may not be able to provide stakeholders with cost-effective and timely solutions to increase program participation and the number of beneficiaries who become selfsufficient and move off the disability rolls.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-05-248, Social Security Administration: Better Planning Could Make the Ticket Program More Effective
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Report to Congressional Committees:
United States Government Accountability Office:
GAO:
March 2005:
Social Security Administration:
Better Planning Could Make the Ticket Program More Effective:
GAO-05-248:
Contents:
Letter:
Appendix I: Briefing Slides:
Appendix II: Comments from the Social Security Administration:
Appendix III: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Staff Acknowledgments:
Abbreviations:
DI: Disability Insurance:
EN: Employment Network:
SSA: Social Security Administration:
SSI: Supplemental Security Income:
VR: Vocational Rehabilitation:
United States Government Accountability Office:
Washington, DC 20548:
March 2, 2005:
The Honorable Charles E. Grassley:
Chairman:
The Honorable Max Baucus:
Ranking Minority Member:
Committee on Finance:
United States Senate:
The Honorable William M. Thomas:
Chairman:
The Honorable Charles B. Rangel:
Ranking Minority Member:
Committee on Ways and Means:
House of Representatives:
The Social Security Administration (SSA) manages the two largest
federal disability benefit programs and made approximately $75 billion
in payments to about 8 million beneficiaries (ages 18 through 64) in
2003. Given the size of its programs, even small improvements in SSA's
ability to return beneficiaries to work offer the potential for
significant savings. Until recently, Social Security beneficiaries who
needed help returning to work generally had to seek services from state
vocational rehabilitation (VR) agencies. Few beneficiaries used these
services or successfully returned to work. Therefore, Congress passed
the Ticket to Work and Work Incentives Improvement Act of 1999 (Ticket
Act, P.L. 106-170) to create a Ticket to Work and Self-Sufficiency
Program (the Ticket program). The program's goals are to expand the
availability of service providers and to help enable beneficiaries to
return to work, become self-sufficient, and stop receiving disability
benefit payments. Eligible beneficiaries can use their tickets as
vouchers to request vocational rehabilitation, employment, or other
support services from the traditional state VR agencies or from new SSA-
approved public or private providers, which are referred to as
employment networks (EN).
The act required SSA to implement the Ticket program and make tickets
available to all eligible beneficiaries. SSA decided to use three
phases to make tickets available: (1) beginning with 13 states in
February 2002, (2) expanding to 20 more states and the District of
Columbia in November 2002, and (3) expanding to the final 17 states and
5 territories in November 2003. The act also required SSA to perform
several periodic and independent evaluations of the program. For
example, SSA was mandated to periodically review the systems used to
make payments to the providers and was also given authority to make
needed changes. The act also required SSA to provide Congress with
three independent evaluations of the effectiveness of program
activities. Finally, the act created the Ticket to Work and Work
Incentives Advisory Panel (the Advisory Panel) to include experts on
employment and related services and representatives of individuals with
disabilities to provide advice and reports on the program to SSA, the
Congress, and the President.
The Congress also mandated in the Social Security Protection Act of
2004 that GAO evaluate the Ticket program and provide a report to
Congress by March 2, 2005. The statute requires that GAO (1) examine
the annual and interim reports issued by the Commissioner of Social
Security and the Advisory Panel,[Footnote 1] (2) assess the
effectiveness of the activities carried out under the program, and (3)
recommend legislative or administrative changes, if appropriate. To
meet these requirements, our report examines: (1) the progress SSA has
made in implementing and evaluating the Ticket program and achieving
its goals, (2) the problems that have limited the program's ability to
achieve its goals, (3) the recommendations to better achieve the goals
of the program made by the Advisory Panel, researchers, and service
providers, and (4) the challenges SSA faces in implementing changes to
achieve the program's goals. On February 25, 2005 we briefed your staff
on the results of our analysis. This report formally conveys the
information provided during the briefing (see app. I).
To assess the Ticket program, we reviewed and evaluated the quality of
key studies conducted for SSA on the implementation and effectiveness
of the program. We also reviewed reports by the Advisory Panel and
other related documents. To supplement information in these reports, we
interviewed key stakeholders involved in implementing or evaluating the
program, such as SSA officials, state VR officials, and Advisory Panel
members. We also interviewed representatives of selected disability
organizations to obtain their views on the Ticket program. However, our
ability to evaluate the effectiveness of the Ticket program was limited
by SSA's lack of information on beneficiaries' work efforts prior to
the implementation of the Ticket program. We conducted our work between
August 2004 and January 2005 in accordance with generally accepted
government auditing standards.
In summary, we found:
* SSA has made progress implementing and evaluating the Ticket program,
but the agency has had limited success in achieving the program's goals
of expanding beneficiaries' choice of service providers and increasing
beneficiaries' efforts to work and become self-sufficient. Although SSA
experienced delays with the initial distribution of tickets, the agency
finished distributing tickets to eligible beneficiaries throughout the
nation in September 2004.[Footnote 2] As part of implementation, SSA
has also contracted for extensive assessments of its program's
performance. Despite SSA's completion of key implementation activities,
it has had limited success achieving its goal to encourage service
providers to join the program and provide services to beneficiaries. As
of August 2004, although SSA had contacted more than 50,000 potential
new service providers, only 1,164 had become ENs and, as of May 2004,
just 386 had accepted tickets and agreed to provide services to
beneficiaries. Furthermore, early results indicate that the program has
made little progress in achieving its goal of increasing beneficiaries'
efforts to work and to discontinue receiving SSA's disability benefits.
Of the 9.5 million beneficiaries receiving tickets, less than 1 percent
(62,901) have assigned their tickets to an EN or state VR agency, as of
August 2004. Lastly, about 160 beneficiaries have had sufficient
earnings to result in the discontinuance of their disability benefit
payments and payments to ENs, as of March 2004.[Footnote 3]
* The Ticket program's ability to achieve its goals has been hindered
by several factors, according to the Advisory Panel, researchers, and
service providers. First, service providers believe that the program's
payment system does not provide adequate compensation for the
administrative costs of participating. Second, participation of
eligible beneficiaries has been limited by the lack of ENs, the lack of
outreach to provide information about the program, and the lack of
incentives to encourage beneficiaries to participate. Beneficiary
participation was also reduced by SSA's rules that exclude from the
Ticket program some potential participants, such as adult beneficiaries
who are expected to experience medical improvement. Finally, external
factors, such as a decline in the availability of jobs in the economy,
may have discouraged program participation or reduced the success of
beneficiaries' work activities.
* The Advisory Panel and others have suggested numerous changes to
improve the Ticket program. The Advisory Panel and others believe that
reforming the payment system is critical to expanding participation. In
addition, they suggested numerous changes to reduce the administrative
burden for service providers, such as having SSA provide additional
services, guidance, and information to providers. To address limited
beneficiary participation, the Advisory Panel and others have a number
of suggestions, such as using a national campaign to market the
program. The Advisory Panel also suggested that SSA include in the
Ticket program beneficiaries it had previously excluded.
* SSA faces several challenges as it tries to improve the Ticket
program's ability to achieve its goals. Although SSA has made some
administrative changes to the program, the agency recognizes that
additional changes are needed. However, SSA has deferred other reforms
until it has performed additional assessments on changes that it
believes could be costly. For example, SSA officials explained that
reforms to the EN payment structure could increase Ticket program
costs, but may not provide a commensurate decrease in benefit payments.
In addition, some proposed changes go beyond the substantial authority
provided to the agency in the Ticket Act and may require legislative
actions or coordination with other agencies. To determine the most
effective reforms, SSA officials told us they needed more time to
collect and evaluate information on the program's performance, reasons
for limited beneficiary participation, and the potential impact of
reforms. However, the agency lacks a plan that defines when and how it
will assess proposed changes and identify cost-effective reforms.
In conclusion, we believe rigorous planning is needed to provide
sufficient and reliable information to adequately assess the numerous
proposed reforms put forth by the Advisory Panel and others. Thorough
and reliable analysis is particularly important because of the
complexity and potential costs of this nationwide program, as well as
the opportunities that it could provide to beneficiaries who want to
become self-sufficient. Without a well-defined plan to assess proposed
changes, SSA may not be able to provide stakeholders with cost-
effective and timely solutions to increase program participation and
the number of beneficiaries who become self-sufficient and move off the
disability rolls.
GAO is making one recommendation to the Commissioner of Social
Security. We recommend that SSA's Commissioner provide to Congress a
plan that defines how and when the agency will assess proposed changes
so that it may provide timely and cost-effective solutions to increase
program participation and the number of beneficiaries who become self-
sufficient and move off the disability rolls.
In commenting on the draft of this report, SSA said that, although more
could be done, it already had a plan to improve the effectiveness of
the Ticket program. SSA pointed to its evaluation plan and other
related efforts as its plan for improving the program. In our draft
report, we recognized that SSA does have an extensive plan for
evaluating the performance of the Ticket program. But, the agency's
current plan does not specifically incorporate efforts to assess the
potential costs and benefits of implementing changes proposed by the
Advisory Panel and other stakeholders. As such, we continue to see a
need for SSA to better delineate how and when the agency will assess
the numerous recommendations put forth by the Advisory Panel and other
stakeholders. We have revised our recommendation to clarify this point
and, as needed, have made changes to address comments from the agency
regarding appendix I. The agency's comments are provided in appendix II.
Copies of this report are being sent to the Commissioner of SSA,
appropriate congressional committees, and other interested parties.
This report is also available at no charge on GAO's Web site at http:/
/www.gao.gov. If you have any questions about this report, please
contact me or Carol Dawn Petersen at (202) 512-7215. Other contacts and
staff acknowledgments are listed in appendix III.
Signed by:
Robert E. Robertson:
Director, Education, Workforce, and Income Security Issues:
[End of section]
Appendix I: Briefing Slides:
Congressional Briefing:
SOCIAL SECURITY ADMINISTRATION:
Better Planning Could Make the Ticket Program More Effective:
Background:
* The Social Security Administration (SSA) manages the nation's two
largest disability programs: Disability Insurance (DI) and Supplemental
Security Income (SSI);
* Approximately $75 billion was paid to about 8 million DI and SSI
beneficiaries (aged 18 to 64) in 2003.
* Until recently beneficiaries who needed help returning to work
generally had to seek services from state vocational rehabilitation
(VR) agencies. Few beneficiaries used these services or returned to
work.
* Even small improvements in SSA's ability to return beneficiaries to
work offer the potential for significant savings.
* Congress passed the Ticket to Work and Work Incentives Improvement
Act of 1999 (the Ticket Act) to:
- create a program to expand the availability of service providers;
- help enable beneficiaries:
-- return to work,
-- become self-sufficient, and,
-- stop receiving disability benefit payments.
* Eligible beneficiaries can use their tickets as vouchers to request
vocational rehabilitation, employment, or other support services.
* Tickets can be used at VR agencies or at new SSA-approved public or
private providers, known as employment networks (EN).
- required SSA to take specific steps to implement and evaluate the
program,
- gave SSA considerable authority to make changes to the program, and,
- created the Ticket to Work and Work Incentives Advisory Panel (the
Advisory Panel).
* SSA made tickets available to eligible beneficiaries in three phases:
(1) beginning with 13 states in February 2002,
(2) expanding to 20 more states and the District of Columbia in
November 2002, and,
(3) expanding to the final 17 states and 5 territories in November
2003.
Congressional mandate and objectives:
* Congress mandated in the Social Security Protection Act of 2004 that
GAO assess the Ticket program and make recommendations, as appropriate,
to Congress by March 2, 2005.
* To address the mandate, we reviewed the:
(1) progress SSA has made in implementing and evaluating the Ticket
program and achieving its goals,
(2) problems that have limited the program's ability to achieve its
goals,
(3) recommendations that the Advisory Panel and others have made to
achieve the program's goals, and,
(4) challenges that SSA faces in implementing changes to achieve the
program's goals.
Scope and methods:
To assess the Ticket program, we:
* reviewed and assessed the quality of key studies conducted for SSA,
* reviewed reports by the Advisory Panel and other related documents,
* interviewed key stakeholders, such as SSA officials, state VR
officials, and Advisory Panel members, and,
* interviewed representatives of selected disability organizations to
obtain their views on the Ticket program.
We conducted our work between August 2004 and January 2005 in
accordance with generally accepted government auditing standards.
Key findings:
* SSA has made progress implementing and evaluating the Ticket program,
but has had limited success achieving the program's goals;
* Inadequate incentives for service providers and beneficiaries to
participate, limited marketing, and other factors have hindered the
program's success;
* The Advisory Panel, researchers, and service providers have suggested
improvements to the payment structure and program design;
* SSA faces several challenges implementing changes to meet program
goals:
SSA has made progress implementing the program, but has had limited
success achieving program goals:
* SSA implemented the Ticket program after delays establishing
regulations;
* SSA continues to evaluate the program's ability to meet its goals;
* SSA has had limited success achieving its goal of expanding the
number of ENs;
* SSA has had limited success achieving its goal of increasing
beneficiaries' efforts to work and leave SSA's disability rolls;
After experiencing delays, SSA has implemented the Ticket program:
* The Ticket Act required SSA to issue final program regulations by
December 2000, but it did not do so until December 2001.
* Difficulties establishing the regulations and other administrative
problems delayed ticket distribution;
* SSA was required to start making tickets available in December 2000,
but did not do so until February 2002.
* As of September 2004, SSA had distributed tickets to all eligible
beneficiaries.
SSA continues to evaluate the program:
* As part of implementation, SSA has contracted for extensive
assessments of the program.
Contractors have:
* provided SSA with reports on the early implementation of the program
and
* developed extensive plans to:
- perform additional evaluations,
- provide annual reports, and
- report on the program's cost-effectiveness and its impact on
beneficiaries' work outcomes in 2006, 2007, and 2008.
SSA has had limited success expanding the number of ENs:
Despite contacting over 50,000 organizations, as of August 2004:
* A total of 1,164 ENs (or about 2 percent of the organizations
contacted) were enrolled.
* On average, there is 1 EN for every 8,167 ticket holders.
* ENs held 5,603 tickets, or 9 percent of the tickets being used by
beneficiaries.
* State VR agencies held 56,488 tickets, or 91 percent of the tickets
being used by beneficiaries.
SSA has had limited success increasing beneficiaries' efforts to work:
As of August 2004:
* 9.5 million beneficiaries have received tickets.
* 62,901 of them (or less than 1 percent) have used their tickets.
* 687 ticket holders had earnings that resulted in an outcome or
milestone payment to a service provider.
As of March 2004:
* About 160 ticket holders have had sufficient earnings to result in
discontinuance of their disability benefits and payments to ENs.
Numerous problems have limited the program's ability to achieve its
goals:
The Advisory Panel, researchers, and/or service providers have
identified the following key problems:
* Various features of the EN payment system;
* Some EN administrative requirements;
* Insufficient incentives and safeguards for beneficiaries;
* Insufficient marketing to beneficiaries;
* Exclusion of some beneficiaries from the program;
* A weak economy and other external factors.
Key problems with the payment system:
* ENs receive no up-front funding to cover costs and assume significant
financial risk for assisting beneficiaries.
* EN payments are small and contingent on a beneficiary's achieving
sufficient earnings.
* Earnings must be maintained for 60 months or more to ensure ENs
receive the maximum payment.
* Of the two EN payment options, most ENs have selected the milestone-
outcome option because it can provide earlier payments, but total
payments can be 15 percent less than the outcome-only option.
The payment system creates:
* a disincentive for ENs to serve certain beneficiaries, such as those
who need extensive services or cannot work full-time jobs,
* confusion among ENs about whether funding from other federal and
state programs can be used to assist beneficiaries with tickets, and,
* competition between ENs and state VR agencies that has:
- kept some service providers from participating because they did not
want to change their ongoing relationships with VR agencies and
- led to some financial and service agreements between VR agencies and
ENs that may put EMS at a financial disadvantage.
Key problems with EN administrative requirements:
* Screening beneficiaries: ENs can receive only contact information for
beneficiaries and would like more information and guidance to help
screen them.
* Educating beneficiaries: Beneficiaries receive little information
from SSA on the program, so ENs report being inundated with inquiries.
* Tracking beneficiaries' earnings: While SSA has reduced some
reporting requirements, ENs report continued difficulty obtaining
earnings information and determining the level of earnings needed to
qualify for payments.
Key problems with incentives and safeguards for beneficiaries:
According to the Advisory Panel and researchers, some beneficiaries may
have little incentive to participate because they continue to:
* have limited choice in service providers and,
* fear that working could result in:
- the inability to retain or easily reinstate benefits when their
efforts to work are unsuccessful and,
- overpayments from SSA that may cause a financial strain during
repayment.
SSA is currently surveying beneficiaries to determine what factors
influence their participation.
Program safeguards may not protect benefits in some cases and may
increase beneficiaries' fears about working because:
* reinstatement of benefits can be expedited only when a beneficiary's
job loss is caused by his or her disability and,
* SSA can reevaluate a beneficiary's eligibility for disability
benefits if it determines that the beneficiary's progress in the Ticket
program is insufficient.
Key problems with marketing:
As of September 2004, SSA's information to all eligible beneficiaries
about the program has been limited to a brief cover letter and a
pamphlet mailed with the ticket.
Although SSA employed its field staff and contracted with community
organizations to provide outreach, the Advisory Panel reports that
these efforts have been insufficient to meet the needs of beneficiaries.
SSA has also contracted for a national marketing campaign aign and
recently taken actions to implement new marketing activities; howevr,
the Advisory Panel and others believe tht SSA should have moved more
quickly to increase beneficiaries' awareness and interest in the
program.
Key problem with exclusion of certain beneficiaries:
SSA excludes from the Ticket program:
* adult beneficiaries who are expected to improve medically,
* SSI beneficiaries under 18 years of age, and,
* SSI beneficiaries 18 years of age and older awaiting reevaluation of
disability status using adult standards.
Researchers believe that:
* adult beneficiaries who are expected to improve medically would
likely benefit from vocational services and return to work, and,
* SSI beneficiaries who may be preparing to transition from school to
work would also benefit from the program.
External factors may also hinder the program's success:
The Advisory Panel and researchers have noted the following external
factors may have hindered the program's success:
* a weak economy and reduced job availability,
* possible employer discrimination against people with disabilities,
and,
* states' limited participation in Medicaid buy-in programs to make
health care more affordable for beneficiaries who want to work.
Suggested reforms to address key problems:
The Advisory Panel, researchers, and/or service providers have
suggested making reforms to:
* EN payment system;
* EN administrative requirements;
* incentives and safeguards for beneficiaries;
* marketing to beneficiaries;
* eligibility policies for beneficiaries.
Suggested reforms to the payment system:
According to the Advisory Panel, researchers, and/or service providers,
the Ticket program should:
* assist ENs with obtaining up-front funding;
* provide larger and earlier payments;
* shorten the payment period from 5 years to 3 years;
* reduce the difference between the maximum payments for the two EN
payment options;
According to the Advisory Panel and/or others, the Ticket program
should:
* Enhance the potential for beneficiaries to receive needed services
and reduce service provider competition by:
- allowing a VR agency and an EN to receive payments when serving a
beneficiary with both short-and long-term needs;
- reducing the minimum earnings needed to trigger EN payments for
beneficiaries who cannot work full-time jobs;
- clarifying that EN payments should not disqualify a beneficiary from
receiving funds or services from other federal and state programs;
- creating guidance for developing VR-EN agreements and a model
agreement to equitably share the benefits and risks of participating;
Suggested reforms to reduce EN administrative burdens:
According to the Advisory Panel and/or others, the Ticket program
should:
* provide more information about beneficiaries to ENs to enable them to
screen beneficiaries more effectively;
* provide more information to beneficiaries to reduce the demand for
information from ENs;
* track earnings for ENs or provide case tracking software to ENs;
* establish national technical assistance and training for ENs to
provide best practices for program administration;
Suggested reforms to strengthen incentives and safeguards for
beneficiaries:
According to the Advisory Panel and/or others, the Ticket program
should:
provide incentive payments to beneficiaries who complete a work plan to
become self-sufficient;
create Individual Development Accounts so working beneficiaries can
retain earnings to support their work efforts;
not require beneficiaries to reimburse SSA for any overpayments made
more than 6 months after the beneficiaries have reported heir earnings;
expedite reinstatement of benefits for reasons other than job loss
caused by the beneficiary's disability;
have the service provider determine that the beneficiary's progress is
insufficient before SSA can reevaluate the beneficiary's eligibility
for disability benefits;
Suggested marketing reforms:
According to the Advisory Panel and/or others, the Ticket program
should:
* Inform eligible beneficiaries about the Ticket program at least once
a year;
Increase marketing by:
* immediately developing and implementing a nationwide marketing
campaign to beneficiaries and other potential participants, and/or;
* targeting marketing efforts to beneficiaries who are most likely to
pursue employment;
* Expand community planning and outreach efforts to inform
beneficiaries of work incentives and to clarify program rules;
Suggested reforms to beneficiary eligibility policies:
* The Advisory Panel and/or others have suggested that SSA expand
eligibility to these additional groups of beneficiaries;
* adult beneficiaries who are expected to improve medically,
* SSI beneficiaries under 18 years of age, and,
* SSI beneficiaries 18 years of age and older awaiting reevaluation of
disability status using adult standards.
SSA faces challenges in achieving program goals:
* SSA has made some administrative changes, but recognizes additional
changes are needed to meet program goals.
* SSA has deferred making other reforms until it has performed
additional assessments on changes that it believes could be costly.
* For example, a SSA official explained that reforms to the EN payment
system could increase program costs without providing a commensurate
decrease in benefit payments.
SSA faces challenges in achieving program goals (continued):
* Some proposed changes may require congressional action or SSA's
coordination with other agencies.
* To assess potential reforms, SSA wants to gather more information on
the program's performance, reasons for limited beneficiary
participation, and the potential impact of reforms.
* As part of this effort, the agency has an extensive and long-term
plan to evaluate the program; however, it does not have a plan that
clearly outlines when and how it will assess proposed changes and
identify cost-effective reforms.
Conclusions:
* Given the complexity and size of the Ticket program, rigorous
planning is needed to ensure that SSA has sufficient and reliable
information to assess the numerous changes put forth by the Advisory
Panel and other stakeholders.
* Without a plan that specifies how and when it will assess the
proposed changes, SSA may not be able to provide stakeholders with
cost- effective and timely solutions to increase program participation
and the number of beneficiaries who become self-sufficient and move off
the disability rolls.
Agency recommendation:
SSA should provide Congress with a plan that defines how and when the
agency will assess proposed changes so that it may provide timely and
cost-effective solutions to increase program participation and the
number of beneficiaries who become self-sufficient and move off the
disability rolls.
[End of slide presentation]
[End of section]
Appendix II: Comments from the Social Security Administration:
SOCIAL SECURITY:
The Commissioner:
February 14, 2005:
Mr. Robert E. Robertson:
Director, Education, Workforce and Income Security Issues:
U.S. Government Accountability Office:
Room 5-T-57:
441 G Street, NW:
Washington, D.C. 20548:
Dear Mr. Robertson:
Thank you for the opportunity to review and comment on the draft report
"SOCIAL SECURITY Administration: Better Planning Could Make the Ticket
Program More Effective" (GAO-05-248). Our comments on the report are
enclosed.
If you have any questions, please have your staff contact Candace
Skurnik, Director, Audit Management and Liaison Staff at (410) 965-
4636.
Sincerely,
Signed by:
Jo Anne B. Barnhart:
Enclosure:
COMMENTS ON THE GOVERNMENT ACCOUNTABILITY OFFICE (GAO) DRAFT REPORT
"SOCIAL SECURITY ADMINISTRATION: BETTER PLANNING COULD MAKE THE TICKET
PROGRAM MORE EFFECTIVE" (GAO-05-248):
We appreciate the opportunity to comment on the GAO draft report
concerning the Social Security Administration's (SSA) progress in
implementing the Ticket to Work program.
The report notes that the Ticket to Work program has expanded the
choices beneficiaries have for obtaining return to work services. The
basic principle of the Ticket to Work program is to provide
beneficiaries with opportunities for long-term work success in part by
leveraging market forces.
Over the years, legislative and regulatory changes have added various
work incentives to both the Social Security Disability Insurance (SSDI)
and Supplemental Security Income (SSI) programs. These incentives were
intended to assist beneficiaries of both programs to transition to
employment. The Ticket to Work program introduced an entirely different
approach that empowers beneficiaries to secure employment support
services. SSA recruits service providers and pays for outcomes rather
than reimbursing for the services provided. The Ticket to Work program
encourages a greater Agency emphasis on return to work and expands the
services and opportunities we make available to persons with
disabilities on our rolls.
The Ticket to Work program is now operating in all States and
territories. As we implement the program, we will continue to assess
and evaluate the effectiveness of our initial plan, including what
changes are needed, and what adjustments would enhance our success.
While, as the report points out, we have had limited success with the
program so far, participation in the Ticket to Work program has shown
steady growth, and we anticipate continued success in our efforts to
enlist employment networks (EN) and encourage beneficiary
participation. However, due to the relative infancy of the program, and
the slow growth in participation, SSA has been impeded in the
collection of objective information on EN and beneficiary experiences.
The report indicates that SSA does not have a plan to identify and
evaluate possible changes to improve the Ticket to Work program. This
is not accurate. SSA's plan to improve the effectiveness of the Ticket
to Work program is built, in part, upon SSA's contract with our
independent Ticket to Work evaluator, Mathematica Policy Research, Inc.
(MPR). The statement of work for the evaluation contract provides, in
part: "The evaluation will also provide feedback to policymakers
through periodic reports detailing data collection, findings and
recommendations for program modifications." In conducting the
evaluation, MPR utilizes a Technical Evaluation Support Group (TESG) of
technically qualified evaluation experts, knowledgeable return-to-work
practitioners, and program experts. TESG members provide feedback to
MPR and SSA on evaluation methodology and findings. The support group
also provides policy context for the results and provides advice on
emerging issues related to the Ticket to Work program. MPR has provided
SSA policy-makers with briefings as findings are developed. To this
end, SSA has also refined and focused its information gathering to
address specific areas where more information is needed. For example,
SSA has asked MPR to develop an EN cost model for the 2004 evaluation
report to better understand the cost and revenue constraints faced by
ENs. We expect to have this report in Spring 2005, and we will consider
appropriate changes based on the information reported.
SSA has a well-defined plan for improving the effectiveness of the
Ticket to Work program that includes a set schedule for the collection
and evaluation of program data. We will make changes to the program
based on evidence that those changes will improve the overall
effectiveness of the program.
The draft report fails to acknowledge the very detailed conversations
in the SSA staff interviews that GAO held during the study. During
these conversations, SSA staff - attempted to make clear to the
auditors that the Agency has devoted a significant amount of resources
to attempting to understand the dynamics of the current program and to
investigating alternative approaches. The Agency will continue to
explore a variety of possible changes to the program to determine
whether there is clear evidence that any of the changes would be likely
to result in improvements to the program's performance. More
specifically, the entrance and exit conferences, the staff interviews
and GAO's requests for information mostly centered on the
recommendations made by the Ticket to Work and Work Incentives Advisory
Panel (Panel), service providers, and researchers, and on SSA's
challenges in implementing changes to the programs. We summarize below
the Agency's approach and limitations in sorting through this
collection of recommendations.
As we have moved forward with this program, we have listened carefully
to interested individuals and organizations, including the Panel,
service providers, and advocates. This draft report lists many of the
criticisms and suggestions for change that have been presented.
In the Ticket to Work and Work Incentives Improvement Act of 1999,
Congress mandated that SSA study whether the Ticket to Work program
provides adequate incentives for ENs to serve beneficiaries in four
targeted groups. SSA responded by using the Disability Research
Institute to commission an Adequacy of Incentives (AOI) Advisory Group.
The AOI Advisory Group was charged with developing specific
recommendations for regulatory changes to the Ticket program with
reference to those targeted groups. The AOI Advisory Group concluded
that beneficiaries with disabilities in the targeted groups may
represent much more than a small percentage of Ticket holders and
broadened their recommendations in an effort to improve the adequacy of
incentives for serving all beneficiaries. In addition, these
recommendations reflected the overarching goals of the President's New
Freedom Initiative-maximizing economic self-sufficiency, independent
living, and informed choice of individuals with disabilities.
As SSA deliberates on making modifications to the current Ticket to
Work regulations, we are considering recommendations from a broad
spectrum including the AOI Advisory Group and the Panel. The statute
itself limits our ability to consider some of the recommendations that
have been made. For example, the statute limits monthly outcome
payments to ENs for SSI and SSDI beneficiaries to a percentage of
average SSI and SSDI benefit levels and allows outcome payments to ENs
only on behalf of individuals who are not receiving a disability
benefit payment because of work or earnings. These provisions limit our
ability to make outcome payments to ENs serving SSI only beneficiaries
that are equivalent to those paid to ENs serving beneficiaries on the
SSDI rolls. These provisions further prohibit us from making outcome
payments to ENs who help SSI beneficiaries to reduce, but not totally
eliminate their Federal SSI benefit.
We have made continual improvements in our administration of the Ticket
to Work program since the first ticket was issued 3 years ago this
month. As new information has revealed appropriate program
improvements, SSA has acted to make these changes. Efforts to date, in
this regard, include:
* The EN capitalization initiative to assist ENs to identify and access
other funding streams;
* The EN Certification Payment Request Process to ease the EN's
earnings documentation requirements;
* A marketing campaign, including a contract with the professional
marketing firm Fleishman Hilliard to develop a comprehensive marketing
strategy and materials, to increase awareness and interest in the
Ticket to Work Program among beneficiaries and service providers. As
part of this effort, we have already held focus groups with
beneficiaries and other interested parties to get their input and
reaction to test marketing products;
* The "Cities Campaign" to expand EN recruitment efforts through
outreach and collaboration with local organizations in five large
metropolitan areas; and:
* The newly created EN Association.
We are closely examining the desirability of making changes to the
existing Ticket to Work regulations in order to take advantage of the
flexibility provided to SSA under the law to address many of the issues
and recommendations raised by our stakeholders and cited in this
report. Regulatory changes related to the EN payment structure and the
interplay between ENs and State vocational rehabilitation agencies are
being carefully evaluated.
In addition, we are preparing to do targeted mailings to nearly a
million beneficiaries with tickets to stimulate interest in the Ticket
program and to test how to best deliver these messages to our entire
beneficiary population.
We have the following comments on the GAO recommendation:
Recommendation:
SSA's Commissioner provide to Congress a plan that defines how and when
the agency intends to identify cost-effective solutions to increase
program participation and the number of beneficiaries who become self-
sufficient and move off the disability rolls.
Response:
As noted above, SSA has a plan to improve the effectiveness of the
Ticket to Work program. That plan is built upon SSA's contract with
MPR, our independent Ticket to Work evaluator. As mentioned previously,
the statement of work for the evaluation contract provides, in part:
"The evaluation will also provide feedback to policymakers through
periodic reports detailing data collection, findings and
recommendations for program modifications." Further, the activities
described above further address the recommendation and some of the
concerns cited in the report. We agree that more needs to be done.
We have the following comments regarding the slides in Appendix 1:
Slide 7: Key Findings:
Bullet 2 states that the Ticket program's success has been hindered by,
among other things, "[flack of incentives for service providers and
beneficiaries to participate." This statement seems overly broad in
that it suggests an absence of any incentives for service providers and
beneficiaries to participate in the program. The program provides an
incentive for service providers to participate by providing milestone
and/or outcome payments to providers when a beneficiary achieves a
particular level of work. The Ticket program provides an incentive for
beneficiaries to participate by providing protection against the start
of a continuing disability review for a beneficiary who is "using" a
ticket. In addition, the Title II and Title XVI programs provide
various work incentives to encourage beneficiaries to attempt to work,
including the trial work period and the extended period of eligibility
under Title II and the section 1619 provisions under Title XVI.
Slide 14: Key problems with the Pa Payment system:
To fully explain the problems, we would suggest adding a bullet:
* EN payment system imposes significant financial risks for the
administrative costs of participating ENs:
Slide 17: Key problems with incentives and safeguards for beneficiaries:
We would note that participation or nonparticipation in the Ticket
program does not have any effect on SSA overpayments that result from
work. Accordingly, the fifth bullet dealing with the financial strain
of overpayments should be reworded. We suggest:
* potential overpayments and the ensuing financial strain that might
occur during the period when the overpayments need to be repaid:
Slide 19: Key problems with marketing:
The first bullet fails to mention the pamphlet, "The Ticket to Work and
Self-Sufficiency Program" that is included with the "brief cover letter
mailed with the ticket." That statement also fails to recognize the
ongoing extensive outreach campaign being carried out in all field
components. Agency employees have conducted numerous outreach and
information sessions on the Ticket to Work program in communities
across the country, exhibited at numerous conferences and conducted
Ticket to Work workshops for beneficiaries and their families, public
and private agency staff and employers. Along with providing details on
the Ticket to Work program, these sessions also feature explanations of
SSDI and SSI work incentives. Our efforts include working with program
and contract staff to develop a national Ticket to Work marketing
campaign, to design new products that inform beneficiaries, employers
and service providers about the Ticket program and to evaluate the
effectiveness of our communication activities.
Slide 25: Suggested reforms to reduce EN administrative burdens:
The first bullet raises privacy concerns. ENs should request the
beneficiary to provide any needed information for effective screening.
Any additional information given to beneficiaries about the Ticket
program, as referenced in the second bullet, will help not only the EN,
but all concerned. Fleishman-Hilliard currently has a marketing
contract that includes marketing the Ticket program to beneficiaries.
[End of section]
Appendix III: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Carol Dawn Petersen, Assistant Director (202) 512-7215;
Julie DeVault, Analyst in Charge (415) 904-2269:
Staff Acknowledgments:
In addition to the individuals mentioned above, the following staff
members made major contributions to this report: Gretta L. Goodwin,
Theresa Lo, Cady S. Panetta, Tovah Rom, Daniel Schwimer, and Dianne
Whitman-Miner.
FOOTNOTES
[1] While the mandate also required GAO to examine states' annual and
interim reports on the Ticket program, we were unable to undertake this
effort because states have not been required to, nor have they
evaluated, the implementation and effectiveness of the Ticket program.
[2] SSA continues to distribute tickets to additional beneficiaries as
they become eligible for the Ticket program.
[3] SSA was unable to provide us with more current data.
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