Social Security Disability
Ticket to Work Participation Has Increased, but Additional Oversight Needed
Gao ID: GAO-11-324 May 6, 2011
The Social Security Administration (SSA) pays billions of dollars in Disability Insurance and Supplemental Security Income to people with disabilities. The Ticket to Work program, established in 1999, provides eligible beneficiaries (ticket holder) with a ticket they may assign to approved service providers, called employment networks (EN). ENs are to provide services to help ticket holders obtain and retain employment and reduce dependence on SSA benefits. ENs receive payments from SSA once a ticket holder has earnings exceeding a set threshold. Due to low participation, SSA changed program regulations in 2008 to provide ENs and ticket holders with more incentives to participate. GAO examined (1) changes in ticket holder and EN participation over time, (2) the range of service approaches used by ENs, and (3) SSA's efforts to evaluate ticket holders and ENs to ensure program integrity and effectiveness. GAO analyzed SSA data, policies, and procedures, and interviewed representatives of 25 ENs, disability advocacy organizations, and SSA.
More ticket holders and ENs are participating in the Ticket to Work program since SSA revised regulations in 2008, but the overall participation rate remains low. Ticket holders assigning their tickets to ENs increased from about 22,000 in fiscal year 2007 to more than 49,000 as of July 2010. However, less than 1 percent of all ticket holders assigned their tickets to ENs and SSA has not yet studied whether regulatory changes enabled more ticket holders to obtain employment and exit the benefit rolls. During this time, ENs approved to serve ticket holders increased from 1,514 to 1,603, and SSA's ticket payments to ENs increased from $3.8 million to $13 million. However, 20 ENs, or less than 2 percent of those currently participating, have received the majority of total ticket payments from SSA. GAO found that ENs provide a range of services, including job search and retention assistance. Since the 2008 regulatory changes, which explicitly allowed ENs to pay ticket holders, an increasing number used service approaches such as sharing SSA's government-funded ticket payments with ticket holders. These ENs target ticket holders already working or ready to work, and accounted for a substantial and growing share of payments from SSA. Three ENs among those with the largest payment amounts reported providing limited or no direct services beyond passing back a portion of ticket payments to ticket holders who had sufficient earnings to qualify the ENs for payment. These ENs received a total of over $4 million in SSA payments-- nearly one-third of all SSA payments--in fiscal year 2009. Two of these ENs passed back 75 percent of SSA's ticket payments to ticket holders and kept the other 25 percent. The extent of these trends is unknown because SSA does not collect sufficient information on service approaches across all ENs. SSA lacks adequate management tools to systematically evaluate ticket holders and ENs. Since 2005, SSA has not consistently monitored or enforced ticket holders' progress toward self-supporting employment--a regulatory requirement. Ticket holders who show progress are generally exempt from medical reviews to determine their continued eligibility for benefits. Lack of systematic monitoring of timely progress has both program integrity and cost implications, such as the potential for ineligible beneficiaries to continue receiving benefits. During the course of GAO's review, SSA was beginning to resume the progress reviews, but it is too early to assess the effectiveness of these efforts. Moreover, SSA has not developed performance measures for approved ENs, as required by law, that can be used to assess their success in helping ticket holders obtain and retain employment and reduce dependency on disability benefits. Without such measures, multiple ENs communicate to ticket holders how to work and keep full disability benefits, despite the fact the ultimate goal of the Ticket program is to reduce dependence on benefits (to hear audio excerpts of GAO's calls with selected ENs, see http://www.gao.gov/products/GAO-11-324). Finally, SSA's EN approval process lacks systemic tools to ensure quality and clear and specific criteria for reviewing EN qualifications. GAO is recommending SSA take several steps, such as compiling service trend data and monitoring ticket holders' progress, to enhance program oversight. SSA agreed with two recommendations and offered alternative language for the other two to reflect actions it considers planned or under way.
Recommendations
Our 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:
Daniel Bertoni
Team:
Government Accountability Office: Education, Workforce, and Income Security
Phone:
(202) 512-5988
GAO-11-324, Social Security Disability: Ticket to Work Participation Has Increased, but Additional Oversight Needed
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United States Government Accountability Office:
GAO:
Report to Congressional Requesters:
May 2011:
Social Security Disability:
Ticket to Work Participation Has Increased, but Additional Oversight
Needed:
GAO-11-324:
GAO Highlights:
Highlights of GAO-11-324, a report to congressional requesters.
Why GAO Did This Study:
The Social Security Administration (SSA) pays billions of dollars in
Disability Insurance and Supplemental Security Income to people with
disabilities. The Ticket to Work program, established in 1999,
provides eligible beneficiaries (ticket holder) with a ticket they may
assign to approved service providers, called employment networks (EN).
ENs are to provide services to help ticket holders obtain and retain
employment and reduce dependence on SSA benefits. ENs receive payments
from SSA once a ticket holder has earnings exceeding a set threshold.
Due to low participation, SSA changed program regulations in 2008 to
provide ENs and ticket holders with more incentives to participate.
GAO examined (1) changes in ticket holder and EN participation over
time, (2) the range of service approaches used by ENs, and (3) SSA‘s
efforts to evaluate ticket holders and ENs to ensure program integrity
and effectiveness. GAO analyzed SSA data, policies, and procedures,
and interviewed Representatives of 25 ENs, disability advocacy
organizations, and SSA.
What GAO Found:
More ticket holders and ENs are participating in the Ticket to Work
program since SSA revised regulations in 2008, but the overall
participation rate remains low. Ticket holders assigning their tickets
to ENs increased from about 22,000 in fiscal year 2007 to more than
49,000 as of July 2010. However, less than 1 percent of all ticket
holders assigned their tickets to ENs and SSA has not yet studied
whether regulatory changes enabled more ticket holders to obtain
employment and exit the benefit rolls. During this time, ENs approved
to serve ticket holders increased from 1,514 to 1,603, and SSA‘s
ticket payments to ENs increased from $3.8 million to $13 million.
However, 20 ENs, or less than 2 percent of those currently
participating, have received the majority of total ticket payments
from SSA.
GAO found that ENs provide a range of services, including job search
and retention assistance. Since the 2008 regulatory changes, which
explicitly allowed ENs to pay ticket holders, an increasing number
used service approaches such as sharing SSA's government-funded ticket
payments with ticket holders. These ENs target ticket holders already
working or ready to work, and accounted for a substantial and growing
share of payments from SSA. Three ENs among those with the largest
payment amounts reported providing limited or no direct services
beyond passing back a portion of ticket payments to ticket holders who
had sufficient earnings to qualify the ENs for payment. These ENs
received a total of over $4 million in SSA payments”nearly one-third
of all SSA payments”in fiscal year 2009. Two of these ENs passed back
75 percent of SSA‘s ticket payments to ticket holders and kept the
other 25 percent. The extent of these trends is unknown because SSA
does not collect sufficient information on service approaches across
all ENs.
SSA lacks adequate management tools to systematically evaluate ticket
holders and ENs. Since 2005, SSA has not consistently monitored or
enforced ticket holders‘ progress toward self-supporting employment”a
regulatory requirement. Ticket holders who show progress are generally
exempt from medical reviews to determine their continued eligibility
for benefits. Lack of systematic monitoring of timely progress has
both program integrity and cost implications, such as the potential
for ineligible beneficiaries to continue receiving benefits. During
the course of GAO‘s review, SSA was beginning to resume the progress
reviews, but it is too early to assess the effectiveness of these
efforts. Moreover, SSA has not developed performance measures for
approved ENs, as required by law, that can be used to assess their
success in helping ticket holders obtain and retain employment and
reduce dependency on disability benefits. Without such measures,
multiple ENs communicate to ticket holders how to work and keep full
disability benefits, despite the fact the ultimate goal of the Ticket
program is to reduce dependence on benefits (to hear audio excerpts of
GAO‘s calls with selected ENs, see [hyperlink,
http://www.gao.gov/products/GAO-11-324]). Finally, SSA‘s EN approval
process lacks systemic tools to ensure quality and clear and specific
criteria for reviewing EN qualifications.
What GAO Recommends:
GAO is recommending SSA take several steps, such as compiling service
trend data and monitoring ticket holders‘ progress, to enhance program
oversight. SSA agreed with two recommendations and offered alternative
language for the other two to reflect actions it considers planned or
under way.
View [hyperlink, http://www.gao.gov/products/GAO-11-324] or key
components. For more information, contact Daniel Bertoni at (202) 512-
7215 or bertonid@gao.gov.
[End of section]
Contents:
Letter:
Background:
More Ticket Holders and Employment Networks Participating, but
Participation Rate Remains Low:
Employment Networks Vary in Service Approaches, but Increasingly Focus
on the Employed or Ready to Work:
SSA Lacks Adequate Management Tools for Evaluating Ticket Holders and
Employment Networks to Ensure Program Integrity and Effectiveness:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Picture of a Ticket to Work:
Appendix III: Ticket to Work Payment Structure for Employment Networks:
Appendix IV: Range of Services Provided by Interviewed Employment
Networks in 2009 and 2010:
Appendix V: Employment Networks Offer Services in Person, by Phone,
and Online:
Appendix VI: Timely Progress Requirements for Ticket Holders
Participating in the Ticket Program:
Appendix VII: Full Transcripts of Calls with Employment Networks on
Working Without Losing Benefits Indefinitely:
Appendix VIII: List of Employment Networks Interviewed For This Review:
Appendix IX: Comments from the Social Security Administration:
Appendix X: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Key Changes Resulting from 2008 Revision of Ticket
Regulations by SSA:
Table 2: SSA's Requirements for Proof of Qualifications for EN
Applicants, as described in SSA's RFP, as of September 3, 2009:
Figures:
Figure 1: Overview of EN Approval and Ticket Assignment Process:
Figure 2: Payments and Tickets Assigned to ENs with the Largest
Payments, Fiscal Years 2004-2010:
Figure 3: Excerpts from the Web Site of an Employment Network
Providing Shared Payments:
Figure 4: Percentage of ENs Using Certain Service Approaches and SSA
Payments Received, Fiscal Years 2007 and 2009:
Figure 5: Transcript Excerpt of Calls with Employment Networks on
Working Indefinitely Without Losing Benefits, September and October
2010:
Abbreviations:
CDR: continuing disability review:
DI: Social Security Disability Insurance:
EN: employment network:
OESP: Office of Employment Support Programs:
RFP: request for proposal:
SGA: substantial gainful activity:
SSA: Social Security Administration:
SSI: Supplemental Security Income:
VR: state vocational rehabilitation agency:
View GAO-11-324 key components:
* Transcript of Excerpt of Calls with Employment Networks on Working
Indefinitely Without Losing Benefits. [hyperlink,
http://www.gao.gov/products/GAO-11-324]
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
May 6, 2011:
The Honorable Charles E. Grassley:
Ranking Member:
Committee on the Judiciary:
United States Senate:
The Honorable Sam Johnson:
Chairman:
Subcommittee on Social Security:
Committee on Ways and Means:
House of Representatives:
In fiscal year 2010, the Social Security Administration (SSA) paid out
more than $165 billion in cash benefits to about 13.5 million people
with disabilities and their families[Footnote 1] through its
Disability Insurance (DI) and Supplemental Security Income (SSI)
programs.[Footnote 2] As the U.S. population ages, the number of SSA
disability beneficiaries is expected to grow, along with the cost of
providing benefits. Further, once on benefits, few ever leave the
disability rolls. Our prior work suggested that if even a small
percentage of these beneficiaries returned to work, both programs
would realize substantial savings to offset the cost of the programs.
[Footnote 3] The Ticket to Work and Work Incentives Improvement Act of
1999[Footnote 4] provided for the establishment of the Ticket to Work
and Self-Sufficiency Program (Ticket program) to provide eligible DI
and SSI beneficiaries with employment services, vocational
rehabilitation services, or other support services to help them obtain
and retain employment and reduce their dependency on benefits. SSA
provides each eligible beneficiary (ticket holder) with a ticket to
obtain services from SSA-approved public or private providers,
referred to as employment networks (EN), or from traditional state
vocational rehabilitation agencies (VR).[Footnote 5] Fully implemented
in 2004, the Ticket program experienced low participation in its early
years and, as a result, SSA revised its regulations in 2008 to attract
more ticket holders and ENs.[Footnote 6] In light of these changes, we
examined the following: (1) how participation of ticket holders and
employment networks in the Ticket to Work program changed over time;
(2) what is known about the range of service approaches used by
employment networks; and (3) the policies and processes SSA has to
evaluate ticket holders and employment networks to ensure program
integrity and effectiveness.
To address our research questions, we analyzed SSA data on program
participation; interviewed SSA officials, disability rights advocates,
and employment networks; and reviewed SSA policies and procedures for
the Ticket program. Specifically, we analyzed data on eligible ticket
holders and ENs[Footnote 7] approved by SSA from fiscal year 2004, the
first year the Ticket program was fully implemented,[Footnote 8]
through July 2010. To assess the reliability of the data we obtained
from SSA, we (1) reviewed existing documentation related to the data,
(2) interviewed knowledgeable agency officials about the data, and (3)
tested the data for completeness and accuracy. We found these data to
be sufficiently reliable for the purposes of our analysis. We also
reviewed relevant federal laws and regulations. We interviewed
Representatives of 25 ENs, including 20 ENs among those with the
largest payments in fiscal year 2007, the year prior to implementation
of new program regulations, and fiscal year 2009, the most recent year
with complete data.[Footnote 9] In addition, we conducted site visits
to 12 ENs[Footnote 10] representing those with some of the largest
payments from SSA and a range of service approaches. We compared SSA
and the SSA-contracted Ticket program manager's written policies and
procedures to Ticket program laws and regulations, and government
internal control standards.[Footnote 11] We also obtained a
nongeneralizeable sample of case files of approved, denied, and
terminated ENs to review proof of qualifications submitted to SSA and
EN performance information.[Footnote 12] Finally, an Investigator from
our Forensic Audits and Investigative Service team contacted selected
ENs, posing as a fictitious employer or relative of a ticket holder to
test for potential vulnerabilities in program management and oversight.
[Footnote 13] See appendix I for more details on our scope and methodology.
We conducted this performance audit from January 2010 to May 2011 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions. We believe that the evidence obtained
provides a reasonable basis for our findings and conclusions based on
our audit objectives.
Background:
DI and SSI Eligibility:
To be eligible for DI or SSI benefits, an individual generally must
have a medically determined physical or mental impairment that (1) has
lasted or is expected to last at least 1 year or result in death and
(2) prevents the individual from engaging in substantial gainful
activity (SGA).[Footnote 14] Once an individual is receiving benefits,
continuing disability reviews (CDR) are periodically conducted by SSA
to evaluate if the individual has medically improved to the point of
being able to work and is no longer eligible for benefits.[Footnote
15] Although the DI and SSI programs use the same definition of
disability for eligibility purposes, they were designed to serve
different populations. DI provides benefits to workers with
disabilities who have a qualifying work history; in contrast, SSI
provides cash support for people with low income, few resources, and
little or no workforce attachment. The DI and SSI programs also differ
in how work earnings affect benefits. DI beneficiaries are allowed a 9-
month trial work period during which their benefits continue
regardless of how much they earn.[Footnote 16] Upon completion of the
9-month trial work period, DI beneficiaries move into a 36-month re-
entitlement period (extended period of eligibility) in which their
monthly cash benefit ceases except in months in which earnings are
less than SGA.[Footnote 17] Recipients whose earnings are above SGA
after they complete the 36-month period should, under program rules,
stop receiving benefits and be removed from the disability rolls. In
contrast, SSI benefits are reduced by $1 for every $2 of earned income
exceeding $65 per month until benefits reach zero.[Footnote 18] If SSI
beneficiaries receive no benefits for 12 consecutive months due to
earned income, they are removed from the disability rolls.[Footnote 19]
Ticket Program Overview:
Congress established the Ticket to Work program in 1999 to assist DI
and SSI beneficiaries in obtaining and retaining employment, and
potentially bring about significant savings to the Disability
Insurance Trust Fund by reducing or eliminating their benefits.
[Footnote 20] This voluntary program was also designed to provide
beneficiaries with greater choice in public and private providers of
employment services, such as job preparation and placement and
vocational rehabilitation services. Prior to the establishment of the
Ticket program, DI and SSI beneficiaries who needed help returning to
work generally had to seek services from VRs.[Footnote 21]
When an individual becomes eligible for DI or SSI benefits, SSA mails
a ticket designating the beneficiary as a ticket holder (see appendix
II for a picture of a ticket). Generally, DI and SSI beneficiaries
from 18 to 64 years old are eligible ticket holders. They may choose
whether or not to use their tickets, and with which service providers.
Likewise, SSA-approved ENs, which are contracted by SSA for 5 years
with the option to extend, can decide whether or not to serve an
individual ticket holder. ENs can advertise their services in the
program's online directory used by ticket holders to find ENs in their
area. Ticket holders who assign their tickets and demonstrate "timely
progress" toward self-supporting employment, such as by fulfilling
minimum earnings or education requirements, are exempted from medical
CDRs.[Footnote 22] This provision provides an incentive for
individuals to assign their tickets who otherwise might not attempt to
work out of fear that a medical CDR would cause them to lose benefit
eligibility.
The ticket holder's ticket becomes "assigned" once the ticket holder
and EN decide to work together and submit an individual work plan
describing the services the EN will provide. A ticket holder can
unassign the ticket from the EN at any time, sometimes switching to a
different EN. When the ticket holder has sufficient earnings, the EN
becomes eligible for payments from SSA[Footnote 23] (see figure 1).
The EN can choose from two payment options: (1) milestone-outcome
payments that begin when the ticket holder has a specified level of
earnings and continue for a specified time after the ticket holder no
longer receives benefits due to earnings, or (2) outcome-only payments
that do not begin until the ticket holder is entirely off benefits.
Figure 1: Overview of EN Approval and Ticket Assignment Process:
[Refer to PDF for image: illustration]
1) Service provider sends application to become an employment network
(EN) to Social Security Administration (SSA).
SSA mails eligible beneficiaries a ticket.
Approved applicants receive contract.
2) Ticket holder can assign the ticket to an EN by signing an individual
work plan with that EN.
If the ticket holder meets an earnings threshold, EN is eligible for a
ticket payment from SSA.
EN provides the ticket holder with employment services.
Source: GAO analysis of Ticket program procedures.
[End of figure]
The Ticket law gives SSA authority to help ensure the quality of
participating ENs, and requires ENs to meet and maintain compliance
with general selection criteria (such as professional and educational
qualifications) and specific selection criteria (such as substantial
expertise and experience in providing employment services and
supports).[Footnote 24] The law also requires SSA to perform periodic
quality assurance reviews of EN service provision, and to develop
performance measures for evaluating ENs.[Footnote 25] ENs are required
to annually report on outcomes achieved in providing specific
services.[Footnote 26] The law also requires SSA to terminate EN
contracts for inadequate performance.[Footnote 27] Additionally, the
law requires SSA to provide for independent evaluations to assess the
Ticket program's effectiveness, including cost-effectiveness, types of
services provided to ticket holders who return to work and those who
do not, and employment outcomes for ticket holders.[Footnote 28]
SSA's Office of Employment Support Programs is responsible for
management and oversight of the Ticket program. The office contracts
with a private company (Ticket program manager) for day-to-day
operations, including front-line communication with ENs, such as
technical assistance and training, and processing ticket assignments
and EN payment requests. In addition, the program manager recruits
ENs; however, SSA's Office of Employment Support Programs retains
responsibility for reviewing and approving applicants. The program
manager is also responsible for performing timely progress reviews of
ticket holders. SSA also contracts with another private company to
facilitate beneficiary participation in the program.[Footnote 29]
Finally, SSA contracts with a private research firm for ongoing
evaluations of the program.[Footnote 30]
Changes to Ticket Program Regulations:
Due to low participation rates by both ticket holders and ENs--in
2005, we reported less than 1 percent of 9.5 million ticket holders
had assigned their tickets to an EN or VR[Footnote 31] and 386 of
1,164 contracted ENs were accepting tickets--SSA revised the Ticket
program regulations in 2008 (see table 1).[Footnote 32] The changes
lowered the ticket holder earnings threshold which triggers payments
to ENs. Previously, ENs were not eligible for SSA payment until a
ticket holder had earnings at the SGA level or above. Among other key
changes, the revised regulations added a first phase of four $1275
payments[Footnote 33] over a ticket holder's first 9 months working at
the trial work level, which, in many cases, equates to part-time work.
[Footnote 34] The EN is also eligible for a second phase of smaller
monthly payments when a ticket holder has earnings above the SGA
level, and a third and final phase of payments (the outcome phase)
once a ticket holder is earning above SGA and no longer receives
disability benefits (see appendix III for details of the payment
structure under the revised regulations). Finally, an EN can now serve
a ticket holder formerly served by a VR.[Footnote 35]
Table 1: Key Changes Resulting from 2008 Revision of Ticket
Regulations by SSA:
Category: Ticket holder eligibility criteria;
Prior regulations[A]: DI and SSI beneficiaries expected to experience
medical improvement are not automatically eligible to participate;
Current regulations (effective July 21, 2008)[B]: DI and SSI
beneficiaries expected to medically improve are eligible to
participate.
Category: Timely progress requirements for ticket holders;
Prior regulations[A]: Ticket holders who assign their ticket to an EN
or VR can qualify for exemption from medical CDRs only through work;
Current regulations (effective July 21, 2008)[B]: Ticket holders who
assign their ticket or obtain services from a VR under the traditional
cost-reimbursement system can qualify for exemption from medical CDRs
through education, training, or work.
Category: EN payments;
Prior regulations[A]: ENs are not eligible to receive payments from
SSA until a ticket holder earns at or above SGA;
Current regulations (effective July 21, 2008)[B]: ENs are eligible for
phase 1 milestone payments based on ticket holders' gross earnings at
trial work level, which in many cases equates to part-time work.
Category: EN payments;
Prior regulations[A]: There is no explicit guidance on whether ENs may
use ticket payments to pay ticket holders;
Current regulations (effective July 21, 2008)[B]: ENs may use outcome
or milestone payments to make payments to ticket holders.
Category: EN payments;
Prior regulations[A]: Total payments available to ENs for serving DI
ticket holders are about 70 percent higher than for serving SSI ticket
holders;
Current regulations (effective July 21, 2008)[B]: Total payments
available to ENs for serving DI and SSI ticket holders are roughly
equal.
Category: EN payments;
Prior regulations[A]: ENs are not eligible for payment if the ticket
holder initially assigned the ticket to a VR under the traditional
cost-reimbursement method;
Current regulations (effective July 21, 2008)[B]: ENs can receive
payments for tickets initially assigned to a VR, after VR case closure.
Source: GAO analysis of July 2008 changes to the regulations for the
Ticket to Work program.
[A] 20 C.F.R. pt. 411 (2007).
[B] 20 C.F.R. pt. 411 (2010).
[End of table]
Persisting Cost and Effectiveness Issues:
The cost and viability of the Ticket program has been scrutinized by
researchers and policymakers since the program's inception. At that
time, it was estimated that if an additional one-half of 1 percent of
disability beneficiaries went back to work, and ceased benefits, the
savings to the Social Security Trust Funds and Treasury would total
$3.5 billion over their working lives.[Footnote 36] The Congressional
Budget Office (CBO) also projected the Ticket program would lead to
savings.[Footnote 37] However, in 2008, SSA's Office of the Inspector
General (IG)[Footnote 38] found the percentage of beneficiaries who
cease benefits as a result of employment had remained unchanged from
before implementation[Footnote 39] and projected cost savings had not
materialized. The IG also found the percentage of beneficiaries who
had earnings after receiving services steadily decreased over time,
and recommended that SSA evaluate the program's continued viability.
As part of its contract with SSA for program evaluations, Mathematica
Policy Research, Inc.[Footnote 40] has preliminary findings indicating
the Ticket program was not self-financing as of January 2010 and its
impact on participants' employment, earnings, or benefits was not
large enough to offset the program's operating costs.[Footnote 41] In
2008, SSA's Office of the Chief Actuary estimated short-term effects
of the regulatory changes, projecting substantial up-front costs due
to increases in the frequency and amount of payments to ENs and
benefit payments to beneficiaries exempted from CDRs.[Footnote 42] The
estimates noted that while these higher costs could be partially
offset by later increases in successful work attempts, resulting in
reduced or eliminated benefit payments, there would still be a net
increase in costs.
More Ticket Holders and Employment Networks Participating, but
Participation Rate Remains Low:
More Ticket Holders Assigned Their Tickets Since 2008 Regulatory
Changes, but They Remain a Small Share of Those Eligible:
The number of eligible ticket holders assigning their tickets to ENs
increased from about 22,000 in fiscal year 2007, prior to the 2008
changes in regulations, to more than 49,000 as of July 2010.[Footnote
43] Despite the increase in numbers, those assigning their tickets to
ENs still only represented two-fifths of 1 percent of the
approximately 12.1 million eligible ticket holders[Footnote 44] as of
July 2010, compared to one-fifth of 1 percent in fiscal year 2007
before the regulatory changes.[Footnote 45] SSA's outreach contractor
told us that while they are beginning to place more emphasis on
increasing ticket holder participation, their earlier recruitment
efforts prioritized increasing the supply of ENs. According to EN
Representatives, ticket holder participation remains low due, in part,
to a lack of understanding and awareness of the program. Some
disability rights advocates and EN Representatives said a fear of
losing benefits may also deter eligible ticket holders from
participating in the program, especially DI beneficiaries who, after
the 9-month trial work period, face an immediate cessation of benefits
in a given month when earnings exceed SGA.[Footnote 46] Some
disability rights advocates and EN Representatives also said many
ticket holders may not know how going back to work affects their
benefits, making it difficult for them to agree to participate.
[Footnote 47] Sixteen of the 25 EN Representatives we interviewed also
told us their ENs screen ticket holders, and 12 said at least half of
them do not meet their screening criteria. For example, one EN
Representative told us that certain ticket holders are often screened
out because they lack the education, work experience, and
transportation needed to obtain employment. In addition, according to
some disability rights advocates and EN Representatives, some ticket
holders may be discouraged from participating by previous negative
experiences with ENs. For example, one EN Representative said ticket
holders who assigned their tickets to ENs that provide inadequate
support may become frustrated and leave the program altogether.
Although the number of ticket holders assigning their tickets has
increased since the 2008 changes, whether the changes have impacted
the number of those returning to work and exiting the benefit rolls is
unknown. The law requires SSA to conduct ongoing independent
evaluations of ticket holders' employment outcomes.[Footnote 48]
Although SSA has tentative plans to study exits from the benefit rolls
since the program regulations took effect in 2008, the decision to
undertake this study depends upon the results of other planned
research. According to researchers, some additional time may be needed
before a full assessment can be made. Preliminary research conducted
for SSA by Mathematica estimated that approximately 10 percent of
beneficiaries who assigned their tickets in 2006 will leave the rolls
for at least 1 month; however, as researchers have noted, this does
not equate to long-term exits from the rolls.[Footnote 49] Researchers
have reported many beneficiaries return to work but do not earn enough
to leave the rolls, due in part to functional limitations and
subsequent declines in health. Whether or not ticket holders are able
to leave the rolls has implications for the program's cost-
effectiveness and ultimately, its long-term viability. In preliminary
research examining the program prior to the 2008 regulatory changes,
Mathematica found more exits from the rolls would be needed to offset
existing operational costs.[Footnote 50] Yet without data on the
number of ticket holders actually exiting the rolls due to long-term
employment, an accurate assessment of the program cannot be made.
More Employment Networks Are Participating, but Fewer Than 2 Percent
Receive the Bulk of SSA Ticket Payments:
Although an increasing number of ENs are participating in the Ticket
program since the 2008 changes in regulations, many ENs are not
actively participating and ticket payments have remained concentrated
with 20 ENs. The number of ENs contracted by SSA increased from 1,514
in fiscal year 2007 to 1,603 as of July 2010.[Footnote 51] During this
time, ENs accepting at least one ticket also increased from 752 to
1,086. The majority of EN Representatives we interviewed said the
regulatory changes provided greater incentive for participation
because ENs can now receive payments earlier and be paid for ticket
holders with part-time earnings. Twenty-three of the 25 ENs we
interviewed opted to receive payments under the milestone-outcome
option, which does not require that ticket holders have sufficient
earnings to leave the benefit rolls before ENs are eligible for
payments. One EN Representative said that because SSA payments for
serving DI and SSI beneficiaries are now roughly equal, an EN has
greater incentive to serve SSI beneficiaries, who were previously
associated with lower payment amounts. Additionally, ENs receiving
ticket payments from SSA more than doubled, from 206 in fiscal year
2007 to 460 as of July 2010, and total payments grew substantially,
from $3.8 million in fiscal year 2007 to $13 million as of July 2010.
According to SSA officials and program manager Representatives, the
program's goal is not more ENs, but more ENs accepting tickets,
serving ticket holders, and generating payments. To this end, SSA
officials reported that SSA has sought to identify ENs who are still
not accepting tickets to encourage them to participate or terminate
their contracts. For example, the program manager identifies ENs not
receiving payments within a certain amount of time and encourages them
to participate.[Footnote 52]
While the number of ENs accepting tickets has increased, a relative
few receive the bulk of all ticket payments: 20 ENs accounted for the
majority of all ticket payments in every fiscal year since the program
was fully implemented in 2004, but represented a small percentage of
ENs with tickets assigned (see figure 2). In fiscal year 2009, 20 ENs
representing 1.2 percent of all SSA-contracted ENs and 1.9 percent of
those ENs accepting tickets received 71 percent of total ticket
payments.[Footnote 53] Reasons why EN participation is not broader may
be attributable to costs and other factors. Several EN Representatives
told us that financing the upfront costs of providing services can be
challenging, even though SSA officials said the 2008 regulatory
changes were intended to address the costs associated with providing
initial services. Some EN Representatives said that when ENs begin to
receive outcome payments for clients they no longer intensively serve,
it can help to cover the upfront costs of providing services to new
clients. SSA officials noted that a number of ENs have received
outcome payments; however, a ticket holder must sustain employment at
the SGA level to generate an ongoing stream of outcome payments for
the EN. Some EN Representatives also said providing resource-intensive
services, including driving clients to work or providing career and
personal counseling, could limit profitability. They also reported
that ticket payments are insufficient to support such costly services,
if they are an EN's sole source of funding. Several EN Representatives
also told us an EN's ability to generate ticket payments depends on
effectively screening potential clients for motivation and
employability.[Footnote 54]
Figure 2: Payments and Tickets Assigned to ENs with the Largest
Payments, Fiscal Years 2004-2010:
[Refer to PDF for image: 2 vertical bar graphs]
In each fiscal year, 20 ENs received the majority of ticket payments:
Fiscal year: 2004;
Share of 20 ENs with the largest payments: $604,653 (67%);
Total ticket payments: $0.9 billion.
Fiscal year: 2005;
Share of 20 ENs with the largest payments: $1.4 billion (59%);
Total ticket payments: $2.4 billion.
Fiscal year: 2006;
Share of 20 ENs with the largest payments: $2.1 billion (67%);
Total ticket payments: $3.1 billion.
Fiscal year: 2007;
Share of 20 ENs with the largest payments: $2.8 billion (72%);
Total ticket payments: $3.8 billion.
Fiscal year: 2008;
Share of 20 ENs with the largest payments: $4.2 billion (75%);
Total ticket payments: $5.7 billion.
Fiscal year: 2009;
Share of 20 ENs with the largest payments: $8.9 billion (71%);
Total ticket payments: $12.6 billion.
Fiscal year: 2010 (as of July);
Share of 20 ENs with the largest payments: $9.1 billion (66%);
Total ticket payments: $13.0 billion.
In each fiscal year, 20 ENs received the majority of ticket payments,
yet represented a small percentage of ENs with tickets assigned:
ENs with at least one ticket assigned:
Fiscal year: 2004;
Share of 20 ENs with the largest payments: 20 (3.4%);
Total ENs with tickets assigned: 582.
Fiscal year: 2005;
Share of 20 ENs with the largest payments: 20 (2.9%);
Total ENs with tickets assigned: 701.
Fiscal year: 2006;
Share of 20 ENs with the largest payments: 20 (2.7%);
Total ENs with tickets assigned: 740.
Fiscal year: 2007;
Share of 20 ENs with the largest payments: 20 (2.7%);
Total ENs with tickets assigned: 752.
Fiscal year: 2008;
Share of 20 ENs with the largest payments: 20 (2.5%);
Total ENs with tickets assigned: 815.
Fiscal year: 2009;
Share of 20 ENs with the largest payments: 20 (1.9%);
Total ENs with tickets assigned: 1,060.
Fiscal year: 2010 (as of July);
Share of 20 ENs with the largest payments: 20 (1.8%);
Total ENs with tickets assigned: 1,086.
Source: GAO analysis of SSA data.
[End of figure]
Employment Networks Vary in Service Approaches, but Increasingly Focus
on the Employed or Ready to Work:
ENs receiving among the largest payment amounts from SSA provide a
range of services, including assistance with job search and retention.
But since the 2008 changes in regulations, an increasing number used
service approaches targeting ticket holders who are already working or
ready to work, and they accounted for a greater share of payments from
SSA. However, SSA does not compile data on service provision trends
and, therefore, cannot use data on evolving service approaches to
inform its management and oversight of the program, or to tailor
guidance to ENs.
Employment Networks Provide a Range of Services Including Assistance
with Job Search and Retention:
The ENs receiving among the largest payment amounts from SSA in fiscal
years 2007 and 2009 (the time period just before and after the 2008
changes in regulations) provide a range of services to ticket holders,
including job search and retention assistance and financial support
(see appendix IV). Disability rights advocates, EN Representatives,
and SSA officials we spoke with stressed the importance of a variety
of available services because needs of ticket holders vary. For
example, a ticket holder returning to the workforce after a short
absence may need minimal job search assistance; another with a severe
disability may need ongoing support at the workplace to perform job
tasks. EN Representatives said the most commonly provided services are
developing ticket holders' job-seeking skills, such as resume writing
and interview preparation, and providing job-retention services, such
as additional training and guidance on difficult work situations.
Compared to the ENs we interviewed, the VRs included in our review
[Footnote 55] reported providing a greater number of services and more
costly on-the-job and medical-related supports, such as supported
employment,[Footnote 56] and medical and therapeutic treatment. The
VRs, which receive federal and state operating funds, more frequently
reported providing funding for ticket holders' education or vocational
training, assistive technology, or personal attendant services. Some
disability rights advocates and EN Representatives told us the VR
service approach may be a good fit for those needing intensive
services or training, but not for ticket holders looking for quick job
placement assistance or who need long-term job retention services.
Under requirements specific to VRs, they may close cases after ticket
holders are employed for 90 days.[Footnote 57]
The 25 ENs we interviewed also varied in areas served and methods of
delivery. Seven served local ticket holders,[Footnote 58] 12 served
ticket holders in one or multiple states, and the other 6 served
ticket holders nationwide. In general, ENs serving ticket holders
locally or statewide primarily offered services in person, while those
serving ticket holders in multiple states or nationwide primarily used
the phone or Internet for services (see appendix V). Some ENs offering
services in person told us some ticket holders prefer face-to-face
interaction, and the ENs also are better able to assess ticket
holders' needs and commitment to working. For example, one EN
Representative conducts 90-minute intake interviews with all potential
clients, asking about their disabilities, interests, and needs, and
describing how working will affect their benefits, and may meet with
the ticket holder's relatives. On the other hand, some ENs offering
services by phone or online said they can expand their geographical
reach, serve more ticket holders, and expend fewer resources. Some
disability advocates and EN Representatives said some ticket holders,
for example, those located in rural areas or whose mobility is limited
by their disability, prefer to interact by phone or online.
Employment Networks Increasingly Use Approaches, Such as Sharing SSA
Ticket Payments, That Target Those Already Employed or Ready to Work:
Although ENs continue to provide a range of services, we found an
increasing number of ENs used service approaches targeting ticket
holders who are already working or ready to work, and ENs using these
approaches have accounted for a greater share of payments. The 2008
regulatory changes more explicitly allow ENs to pay ticket holders and
we found increasing numbers of ENs sharing SSA ticket payments with
ticket holders who have sufficient earnings to qualify the EN for
payment.[Footnote 59] This "shared payment" approach allows the EN to
readily claim ticket payments while providing no direct services
because the ticket holder is already working or able to find a job
without assistance.[Footnote 60] These service approaches accounted
for an increasing proportion of total ticket payments made by SSA. For
example, in fiscal year 2007, 1 of the 20 ENs among those with the
largest payment amounts used this approach and received about $787,000
in SSA payments, or one-fifth of all payments to ENs. In fiscal year
2009, 3 of the 20 ENs among those with the largest payment amounts
used this approach and received over $4 million, or nearly one-third
of payments to all ENs.[Footnote 61] Two of the 3 ENs pass back 75
percent of SSA's ticket payment to ticket holders, equating to about
$950 per payment for some ticket holders,[Footnote 62] and retain 25
percent themselves; and the third EN offers ticket holders $500 every
3 months.[Footnote 63] SSA officials told us the decision to allow ENs
to share payments with ticket holders was made in 2001, prior to the
program's implementation and by officials who have since left the
agency. Yet in its 2008 changes, SSA for the first time provided
regulatory language that clearly permits the use of shared payments.
[Footnote 64] Some disability rights advocates and EN Representatives
said that since program rules do not allow ticket holders to serve as
their own ENs, this approach allows them to receive a Ticket program
payment for their efforts to find a job on their own. Some EN
Representatives also said the payment may help a ticket holder meet
needed work-related expenses such as transportation, clothing, and
child care, increasing the likelihood he or she will keep a job.
However, the ENs sharing payments with ticket holders told us they do
not restrict or verify how the money is used. Two of the ENs require
ticket holders to sign a form affirming their intent to use the
payments for work-related expenses and the third simply provides
payments.
While the data indicate a large number of ticket holders assigned to
shared-payment ENs have earnings sufficient to generate SSA payments,
this is expected given these ENs target ticket holders who are already
working. Long-term outcomes of ticket holders receiving shared
payments compared to those receiving support services is unknown,
because SSA does not assess the relative outcomes of ticket holders
based on services received. A senior SSA official acknowledged that
the program must balance the demands it places on ENs to provide
services with incentives for them to participate, and Congress' intent
was to provide ticket holders with a choice of services. However, the
official also told us SSA officials have some concerns about the
shared payment approach because the program was not intended to
provide a wage subsidy, nor assist those who can find employment on
their own, but to provide tangible employment-related services to
those who can benefit from them most. Along these lines, near the end
of our review, the official said SSA is considering requiring ENs to
provide a minimum level of services and to periodically assess ticket
holders' need for additional services.
Some disability rights advocates and EN Representatives raised
concerns about sharing payments while providing only limited or no
other services. This approach, they said, only works for ticket
holders who can find employment on their own, and raises questions
about the value these ENs add to the program. For example, one
disability rights advocate said that it would be preferable for SSA to
give the ticket holder the entire payment directly, rather than paying
an EN a portion of the ticket payment to serve as a middleman.
Additionally, the Representatives told us ticket holders may need
support after finding employment, such as counseling or help with a
disability-related relapse, but choose an EN using the shared-payment
approach because they are enticed by the financial incentive and do
not anticipate future difficulties. In fact, at the time of our
review, one EN's Web site explicitly encouraged ticket holders who
need help finding a job to contact their VR first, then return to the
EN for shared payments only when employed (see figure 3).[Footnote 65]
Because ENs using this approach reported they tend to interact with
ticket holders by phone or online, ticket holders may find it
difficult to get answers to questions. During our review, we made
phone calls to 6 ENs that offer shared payments and frequently reached
a recorded message.[Footnote 66] We were able to speak directly with a
Representative for only 2 of the 6 ENs, and in one case, all
extensions for the EN's toll-free number were out of service. Further,
some disability rights advocates expressed concerns that ticket
holders who decide they need additional support will have difficulty
switching to another EN: Some of the ticket's value has been used, and
fewer potential payments may make the ticket holder a less desirable
client for a prospective EN.[Footnote 67] Further, according to one EN
Representative, because these ENs do not provide a vocational
assessment of strengths, weaknesses, and aptitude, ticket holders may
end up in a job that is a poor fit, affecting their ability to retain
it and, ultimately, reduce dependency on benefits.
Figure 3: Excerpts from the Web Site of an Employment Network
Providing Shared Payments:
[Refer to PDF for image: web site excerpt]
Will SSA make Ticket Payments directly to me?
No. The Ticket to Work program is structured such that SSA will only
make payments to Employment Networks, or ENs.... Of the payments [the
EN] receives from SSA for a given client, 75% are passed back to the
client in the form of Work Support Payments.
If other ENs do not give clients Work Support Payments, what do they
provide to clients?
Other ENs supply services. They may help clients hunt for work or
provide job coaching or career counseling services. They might provide
training, technical accommodations or transportation services. If you
think you might be better off with services rather than money, request
a list of ENs that provide services in your area by calling [the
program manager's phone number] or going to [the Ticket program Web
site]. Compare the options available to you.
What if I need help in finding a job or in paying for training in
order to get a job?
We strongly recommend that you contact your state vocational
rehabilitation (VR) agency. State VR agencies spend hundreds of
millions of dollars every year in assisting people with disabilities
prepare for work. State VR agencies will often pay for tuition, books,
supplies, license fees, tools, adaptive equipment, etc. VR agencies
can sometimes help with job placement as well.
We encourage you to get the help you need from your State VR agency
and then sign-up with [the EN] before you start work. Receiving help
from a State VR agency AND getting additional help from an EN is not
only permissible under the Ticket to Work program, it is encouraged.
Please note, if you do sign-up for services from your state VR agency
and their staff manage to help you find employment, your Ticket may be
worth slightly less than if you had never used VR services, but the
trade-off is usually worth it. Click here for more information on
receiving help from both your state VR agency and [the EN].
Source: Redacted excerpts from an EN Web site.
[End of figure]
In addition to the shared payment approach which targets ticket
holders already working, two "employer-driven" service approaches
which target ticket holders who are ready to work have also accounted
for a greater share of SSA payments to ENs among those with the
largest payment amounts: the direct employment approach, in which the
EN itself employs ticket holders, and the staffing approach, in which
the EN primarily works with employers to develop and identify jobs for
ticket holders, similar to a staffing agency. While 4 of the 20 ENs
among those with the largest payments in fiscal year 2007 used
employer-driven approaches, 6 did so in fiscal year 2009. Payments to
these ENs in fiscal year 2007 were about $226,000 or 6 percent of all
SSA payments; in fiscal year 2009, payments increased to about $1.7
million, or 13.4 percent[Footnote 68] (see figure 4). A Representative
of one EN using an employer-driven approach told us the EN plans to
pay financial incentives to employers to hire ticket holders.[Footnote
69] One key program official told us SSA does not restrict how ticket
payments are spent, and its handbook for ENs includes an example of an
EN providing employers with financial incentives. Both approaches
generally target ticket holders who are ready to work, facilitating
earlier SSA payments to the EN. For example, one EN looks for ticket
holders with a high school education, computer skills, and relevant
work experience, and screens out ticket holders with psychiatric or
cognitive impairments. SSA officials told us they expect ENs to accept
ticket assignments of ticket holders who are job ready, as well as
individuals they believe they can assist in becoming job ready. They
said those who are job ready may have the best chance of becoming
financially independent and leaving the benefit rolls. Some disability
rights advocates and EN Representatives said the direct employment
approach can provide on-the-job supports for ticket holders, and the
staffing approach could increase the likelihood of a quick job match
by responding to the needs of employers. However, they also raised
some concerns about these approaches. For example, some disability
rights advocates and EN Representatives said there is the potential
for disclosure of a ticket holder's disability to an employer,
although some may be uncomfortable having this private information
shared for fear of being treated differently by supervisors or
coworkers.[Footnote 70] Some EN Representatives raised a concern that
once payments from SSA to the EN, or from the EN to the employer
cease, ticket holders could lose their jobs because the financial
incentive is gone. Some disability rights advocates and EN
Representatives also raised concerns that under the staffing approach,
ENs may focus primarily on an employer's needs and steer ticket
holders into jobs that are not a good match, decreasing the likelihood
of job retention.
[Refer to PDF for image]
[End of figure]
Figure 4: Percentage of ENs Using Certain Service Approaches and SSA
Payments Received, Fiscal Years 2007 and 2009:
[Refer to PDF for image: 2 pie-charts]
FY 2007: $3,828,861:
ENs we interviewed using the shared payment approach[A]: 20.6%,
$787,768;
ENs we interviewed using employer-driven approaches[A]: 5.9%, $226,082;
ENs we interviewed that use other approaches[B]: 45.9%, $1,755,829;
ENs we did not interview (approaches unknown)[C]: 27.7%, $1,059,182.
FY 2008: $12,610,841:
ENs we interviewed using the shared payment approach[A]: 32.4%,
$4,081,094.
ENs we interviewed using employer-driven approaches[A]: 13.4%,
$1,695,823;
ENs we interviewed that use other approaches[B]: 24.8%, $3,129,551;
ENs we did not interview (approaches unknown)[C]: 29.4%, $3,704,373.
Source: GAO analysis of SSA data on ticket payments to ENs in fiscal
years 2007 and 2009 and EN interview responses.
[A] ENs may use more than one approach, but were categorized based on
the primary approach used. There was no overlap between those using
shared payment and employer-driven approaches as primary approaches.
[B] This category includes ENs we interviewed that were not using
shared payment or employer-driven approaches as primary approaches.
For example, some of these ENs primarily use job search assistance or
state VR agency approaches.
[C] This category refers to ENs that we did not interview. It is not
known what service approaches these ENs use.
[End of figure]
SSA Does Not Compile or Use Data on Service Provision Trends:
SSA officials said they do not compile data on trends in service
provision, nor view it as SSA's role. As a result, information on
service provision is limited. For example, although SSA compiles
information on certain types of service providers, such as mental
health providers, as part of its efforts to recruit specific
providers, it does not obtain comprehensive information on services
provided by all ENs. Moreover, while service providers applying to
become ENs must indicate which services they intend to provide using a
checklist in the request for proposal, and approved ENs must update
this information on the annual periodic outcome report to SSA, the
checklist does not reflect all services, such as providing financial
assistance or incentives to ticket holders via shared payments. One
key program official acknowledged that some ENs note they offer all
services listed in the request for proposal (RFP) and annual periodic
outcome report while rarely or never providing some of them. Further,
it is unclear that SSA uses information it collects on service
provision. For example, while SSA officials told us the agency first
approved an EN with a shared payment approach because the EN pledged
to offer job search assistance, personal attendant support, and other
services, we found this EN does not provide such services and had not
reported providing them in its last three annual periodic outcome
reports to SSA.[Footnote 71] During the course of our review, SSA
officials said they plan to begin restricting the services an EN can
advertise in the online service directory to services the EN has
agreed to provide ticket holders in individual work plans. This is
intended to ensure the directory of ENs and services more accurately
reflects actual services delivered.
Without sufficient data on trends in service provision, SSA lacks
information to inform its management and oversight of the program, or
to tailor guidance to ENs. Internal control standards state that
program managers need operational data to determine whether they are
meeting their goals for accountability.[Footnote 72] SSA has
identified problems with certain service approaches on an ad hoc
basis, and responded with changes in program requirements and
procedures. In 2009, SSA provided further clarifications regarding its
2008 regulatory requirements for phase 1 milestone 1 payments
(payments made by SSA to an EN when a ticket holder has 1 month of
trial work-level earnings) and established a review process[Footnote
73] after an investigation following a beneficiary complaint found
that some ENs employed ticket holders themselves just long enough to
qualify for this payment, according to SSA officials. Although SSA was
responsive and has since implemented additional oversight mechanisms,
the problem was identified by a third-party complaint and not through
systematic oversight on the agency's part. In addition, because
sufficient data on the extent to which shared payment, employer-
driven, or other service approaches is not collected by SSA, we could
not determine approaches of ENs we did not review, despite the fact
these ENs received nearly $3.7 million, or nearly 30 percent of all
payments from SSA in fiscal year 2009. Finally, without sufficient
information on service provision trends, SSA is unable to provide
guidance or best practices to ENs. For instance, although some
disability rights advocates and EN Representatives raised concerns
that employer-driven approaches may pose conflicts of interest if
safeguards are not implemented, the EN contract does not include
guidance to ENs on how to avoid such issues.
SSA Lacks Adequate Management Tools for Evaluating Ticket Holders and
Employment Networks to Ensure Program Integrity and Effectiveness:
SSA Has Not Consistently Monitored Ticket Holders' Timely Progress
Toward Self-Supporting Employment:
Since 2005, SSA has not consistently monitored or enforced the timely
progress of ticket holders who assign their tickets to ENs and VRs in
order to assess whether they should continue to be exempt from medical
continuing disability reviews (CDR)--a key tool for assessing
continuing eligibility for benefits. While timely progress by ticket
holders is a regulatory requirement,[Footnote 74] SSA instituted a
moratorium on enforcing progress review results[Footnote 75]--a
responsibility of the Ticket program manager--because of concerns
expressed by service providers that the work requirements for ticket
holders were too stringent.[Footnote 76] SSA also considered changes
that would have eliminated timely progress reviews. However, the final
2008 regulatory changes established more stringent timely progress
standards, such as minimum requirements for ticket holders to meet
within the first 2 years of ticket assignment, but added provisions
allowing for education or job training in lieu of employment (see
appendix VI).[Footnote 77] SSA has acknowledged in the preamble to its
program regulations and in a 2005 internal memo the importance of
timely progress reviews for ensuring that ticket holders who have
medically improved and no longer meet SSA's disability requirements do
not receive benefits and its disability programs do not incur
unwarranted costs. Further, without timely progress reviews,
Representatives of some of the ENs we interviewed said some ticket
holders "park" their tickets to get the CDR exemption, for example, by
assigning their ticket with no interest in obtaining EN services or
reducing their dependence on benefits. Resuming timely progress
reviews, they said, would be a positive motivator for ticket holders
to engage in EN services essential to obtaining and retaining
employment and, ultimately, reducing dependence on benefits.
During the course of our review, in November 2010, Representatives of
the Ticket program manager reported they began limited resumption of
the timely progress reviews. Representatives of the program manager
reported, between November 19 and December 15, 2010, they mailed out
requests for information on timely progress (the first step in the
review process) to roughly 4,900--or 26 percent--of the 19,000 ticket
holders initially reported as due for review in November of that year.
[Footnote 78] After reviewing a draft of our report, SSA officials
told us that by February 8, 2011, initial requests for information had
been mailed to those ticket holders-almost 3 months after they began
their mailings.[Footnote 79] Given that SSA estimates between 13,000
to 22,000 ticket holders will be due for timely progress reviews each
month of the first year of resumption, there is potential for a
significant backlog in reviews to determine which ticket holders
should continue to qualify for CDR exemption. To reduce the workload,
SSA and the program manager reported taking steps to develop an
automated earnings check to better identify ticket holders who met
timely progress based on their earnings, and eliminate the need to
contact them for a review. The agency also delayed resumption of
timely progress reviews[Footnote 80] to ensure this automated earnings
check was operational,[Footnote 81] according to one SSA official.
However, as of December 15, 2010, program manager Representatives
reported it still was not operational and began resumption of timely
progress reviews without this check in place. Once in place, one SSA
official anticipated these automated earnings checks would reduce the
volume of mailings and follow-up action needed to complete timely
progress reviews. However, Representatives of the program manager said
such checks would have little impact on the number of pending reviews:
When operational, they estimated, the checks would likely identify
only a few hundred ticket holders as meeting timely progress out of
the 13,000 to 22,000 due for reviews each month. SSA officials said
that significant experience with the earnings check will be needed to
determine its ultimate impact on the workload. After reviewing a draft
of our report, they said the primary reason for conducting the
earnings check is to avoid placing unnecessary burden on ticket
holders and ENs, and any reduction in workload would be an additional
benefit.
In addition to delays in monitoring timely progress, there are
questions about whether the program manager will have reliable
information to make timely progress determinations. At the time of our
review, SSA and program manager Representatives told us they will rely
on ticket holder and EN self-reported information.[Footnote 82] For
example, the progress review form the program manager sends to ticket
holders asks them to reply with a yes or no answer as to whether they
met the earnings requirement or the education or training requirement,
and asks for the name of the school and number of credits completed.
SSA and program manager Representatives told us they do not
independently verify this self-reported information with employment
records or educational documentation. In our past work, we have found
that reliance on self-reported information alone can lead to program
integrity issues, such as overpayments of SSA benefits.[Footnote 83]
Absent some level of independent verification of the information
ticket holders provide, it is unclear to what extent the results of
the timely progress reviews are based on accurate information.
SSA Has Not Developed Performance Measures for Employment Networks:
SSA has not developed performance measures for contracted ENs to
assess their success in helping assigned ticket holders obtain and
retain employment and reduce dependence on disability benefits. The
Ticket law directs SSA to develop performance measures for quality
assurance in the provision of services by ENs, and gives SSA the
authority to terminate EN contracts for inadequate performance.
[Footnote 84] In addition, internal control standards for the federal
government also stress the use of performance measures for proper
stewardship of and accountability for government resources, and for
achieving effective and efficient program results.[Footnote 85] SSA
officials told us the historically low number of contracted ENs, and
even fewer that accept tickets, made it difficult to hold ENs to
performance standards. Since the increases in the number of ENs after
the 2008 changes, officials said they may consider factoring
performance into EN contract extension reviews in the future.[Footnote
86] Near the conclusion of our audit work, they told us they are
considering future updates to the program regulations that in their
view will address EN performance expectations. However, without
performance measures, SSA is currently unable to systematically
evaluate EN performance, and ultimately determine whether ENs should
be allowed to remain in the program.
Lack of performance measures may mean ENs are unclear about program
goals and send mixed messages to ticket holders about expected
outcomes. Of the 25 ENs we interviewed, Representatives of 15 said SSA
had not adequately articulated performance expectations for serving
ticket holders. SSA officials told us EN quality assurance is built
into the Ticket program's payment system because ENs cannot get paid
until a ticket holder meets minimum earnings thresholds. However, the
2008 regulatory changes lowered the earnings thresholds required for
ENs to be eligible for ticket payments, making it possible for ENs to
be paid without a ticket holder first achieving earnings at or above
the SGA level. An EN with the fourth-largest payment amount from SSA
in fiscal year 2009 stated in its last three annual periodic outcome
reports that 100 percent of its ticket holders placed in jobs had
earnings of less than $10,000 per year--equating to less than the SGA
level, if earnings were accrued regularly over the course of 12
months. In fact, the EN's phone message states that DI ticket holders
can work part time indefinitely without reducing SSA benefits, and the
Web site says most of its positions are designed so ticket holders
stay below income thresholds for benefit cutoff. Despite the fact that
SSA's EN handbook states the ultimate goal of the program is to reduce
dependence and, whenever possible, eliminate reliance on benefits, we
found multiple ENs among those with the largest payment amounts
communicating through their Web sites, recorded phone messages, or in
our discussions with Representatives that as long as DI ticket
holders' earnings stay below the SGA level, they can keep full
disability benefits (see figure 5 for excerpts of calls and a link to
audio excerpts. appendix VII provides full transcripts of the calls).
While full-time employment may be unattainable for certain ticket
holders and one key program official told us that part-time employment
is acceptable under the 2008 regulations, the official said it should
be a starting point, not an end goal.[Footnote 87] Nonetheless, our
review indicates some ticket holders are being coached by ENs,
including some of those with the largest payment amounts, to work part
time so as not to jeopardize their benefits.
Figure 5: Transcript Excerpt of Calls with Employment Networks on
Working Indefinitely Without Losing Benefits, September and October
2010:
[Refer to PDF for image: transcript excerpt]
A GAO Investigator phoned multiple ENs on behalf of a fictitious
brother, who was portrayed as a ticket holder, to learn about the
Ticket program and the services provided by the ENs. Below are
excerpts from three calls in which EN Representatives told the caller
that a DI ticket holder may collect full monthly benefits indefinitely
as long as he remains under the SGA earnings level, despite the fact
that the ultimate goal of the Ticket program is to reduce dependence
on benefits.
Call 1:
EN Representative: ’So this is a service where it's funded by the
government, and it‘s services of-–you know-–to the community where
they help people with disability find part-time work. Because if they-–
if you get any full-time work, then you know, they‘re gonna cut you
off. So we‘re not offering you full-time work. We‘re helping you find
part-time work.“
” Excerpt from Call One (Complete transcript in appendix VII)
Call 2:
EN Representative: ’What‘s important for your brother to know is that
right now, as of 2010, he can go out, work any job that he wants so
long as he stays under the $1,000 a month, he gets his cake and eat[s]
it too. He gets the–he gets his wages, and he gets his full SSDI
benefit, and the medical, and everything that goes along with it.
And that can–that can go from today until your brother retires, or
whatever.“
” Excerpt from Call Two (Complete transcript in appendix VII)
Call 3:
EN recording: ’As long as SSDI recipients remain under those earning
limits and their disability does not improve, they can work part-time
and continue to collect their full monthly SSDI check indefinitely.“
” Excerpt from Call Three (Complete transcript in appendix VII)
To hear additional audio excerpts from the three phone calls, go to
[hyperlink, http://www.gao.gov/products/GAO-11-324].
Sources: GAO and employment networks.
[End of figure]
While SSA lacks performance measures to evaluate ENs, it does collect
some self-reported EN performance information. To comply with the
Ticket law, SSA requires ENs to submit annual periodic outcome
reports, including information on ticket holder job placements, job
retention, and disability benefits suspension and termination.
[Footnote 88] SSA officials told us the original purpose of these
reports was to evaluate EN performance and, as required by law, to
make the reports available to beneficiaries. However, officials said
because the information is self reported it is not used to evaluate
ENs or shared with beneficiaries. Instead, officials said the outcome
reports are primarily used by the Ticket program manager to update EN
contact information, such as addresses and phone numbers. At the time
of our review, SSA was developing a report card with performance
information on each EN with 10 or more assigned tickets. The report
card is based on selected information from the annual periodic outcome
reports, as well as from a newly developed ticket holder customer
satisfaction survey, and is currently being piloted in California. SSA
officials said the primary purpose of the report cards will be to
share performance information with ticket holders, as required by law,
to help them make informed decisions when selecting an EN.[Footnote
89] SSA officials also said they were beginning to solicit feedback
from ENs on how the report card might be used by the agency to
evaluate EN performance, but were unable to provide us with
documentation on plans to use the report card as a performance
management tool. Further, because the report cards are designed to be
used by ticket holders, it is not clear they will include the full
extent of outcome-oriented performance information needed to evaluate
ENs against the program purpose, particularly in deciding whether to
extend an EN contract. For example, the report card does not have any
indicators for an EN's success in moving ticket holders off benefits.
While it includes an indicator for ticket holders who retain a job for
at least 6 months, it does not include earnings information, which is
key to reducing and eventually ending SSA disability benefits.
SSA's Approval Process for Employment Networks Lacks Systematic
Mechanisms to Ensure Quality:
SSA's process for approving ENs to serve ticket holders lacks
systematic tools to ensure quality, such as requiring all applicants
to submit a comprehensive business plan for how their services will
help ticket holders obtain and retain employment and reduce dependency
on benefits, and providing clear and specific written criteria to SSA
staff who review qualifications of applicants. SSA's RFP states an EN
applicant must provide applicable certificates, licenses, or other
credentials for delivering employment services, VR services, or other
support services. An EN is only required to submit a qualifications
statement and business plan that demonstrates expertise and/or
experience at providing employment services if it does not submit
specified documents[Footnote 90] (see table 2). SSA officials told us
when the program was implemented almost all applicants were approved
because the agency wanted to increase participation. As of June 2010,
only 11 ENs had ever been denied an EN contract, 6 of those in fiscal
year 2010. However, SSA officials told us that, in recent years, they
have become more stringent in reviewing qualifications; and, in May
2009, modified the RFP to require more detailed information from
applicants who submit a business plan. Near the conclusion of our
review, the officials told us they were considering changes to the RFP
requiring all ENs to submit a business plan that describes how the
applicant's services will help the ticket holder achieve sustained
employment. The officials also said they were considering requiring
ENs to demonstrate more specific experience serving individuals with
disabilities. However, these changes were still pending at the time of
our review.
Table 2: SSA's Requirements for Proof of Qualifications for EN
Applicants, as described in SSA's RFP, as of September 3, 2009:
RFP states applicant must provide one of the following to demonstrate
proof of qualifications:
* A copy of a license or certification as required by state law to
provide employment services, VR services, or other support services.
* Evidence of certification or accreditation from national
rehabilitation and employment services accrediting bodies establishing
an applicant's qualifications to provide or arrange for provision of
employment services, VR services, or other support services, when no
state law requirement.
* Proof of a contract or an equivalent vendor agreement with a VR or
other state agency to provide employment, VR, or other support
services.
* In the absence of the above, a qualifications statement and business
plan that clearly demonstrate the applicant's expertise and/or
experience in providing employment services and/or supports relevant
to the requirements of the RFP. The business plan must describe how
the applicant will provide services to assist the beneficiary in
achieving the beneficiary's employment goal and advancing to self-
supporting employment.[A] If an applicant proposes to provide EN
services to a beneficiary as the employer of the beneficiary, the
business plan must acknowledge that the EN will pay the beneficiary
(employee) upon services rendered.
Source: SSA's RFP for Employment Networks.
[A] According to the RFP, the business plan must discuss: (1) how the
applicant will recruit beneficiaries; (2) the types of beneficiaries
who will be recruited; (3) the services to be provided beneficiaries;
(4) for ENs that employ beneficiaries or assist in job hunting/
placement, the beneficiary's anticipated short-term monthly earnings;
(5) an explanation of how the applicant 's services will enable
beneficiaries to maximize their economic self-sufficiency and advance
to sustained, self-supporting employment; (5) time frame for setting
up EN operation; (6) goal for the number of ticket assignments
accepted in the first and second years of operations; (7) estimated
revenue that will be generated from the Ticket program during that
time frame; and (8) revenue sources outside the Ticket program.
[End of table]
SSA has not consistently required ENs directly hiring ticket holders
to submit a comprehensive business plan--a safeguard that could screen
out ENs with insufficient qualifications or questionable business
practices. In May 2009, as a result of questionable activities by some
ENs which temporarily hired ticket holders primarily to obtain early
ticket payments,[Footnote 91] SSA revised its RFP to require
applicants intending to hire ticket holders directly to provide
additional information on the nature of this employment in their
business plans. Our case file review showed that SSA subsequently
denied one EN applicant in April 2010 because it had not provided "a
clearly elucidative business plan for assisting beneficiaries in
finding and retaining employment with a goal toward self-sufficiency."
Yet of 9 RFP submissions by ENs approved by SSA in March and April
2010 which indicated in the RFP that they would directly employ ticket
holders, 7 were not required to provide a business plan because they
provided one of the other allowable proof of qualifications--
documentation of certificates, licenses, or other credentials. As a
result, SSA lacked information to assess whether the nature and extent
of the proposed direct employment were consistent with the program's
purpose.
In addition, SSA does not have clear and specific criteria to clarify
the RFP requirements and help staff responsible for reviewing EN
applications assess whether an applicant's documentation of
qualifications is adequate. While the RFP requires an applicant, if
submitting a business plan, to clearly demonstrate expertise and/or
experience in providing employment services and/or supports relevant
to the requirements of the RFP, there is no explicit requirement for
all EN applicants to demonstrate experience working with people with
disabilities or in providing the specific services listed in its
application. SSA staff told us they use the criteria from the RFP,
their judgment, and their knowledge of the Ticket law to assess
qualifications. One SSA official said because a team of only three
people is responsible for reviewing EN applications, they learn on the
job. If they have questions, they ask other staff or their supervisor.
However, without clear and specific criteria, we found staff did not
always hold applicants to the same standards. For example, while one
employee reported reviewing EN qualifications against the EN's
proposed services in the submitted RFP, the 38 applicant case files we
reviewed for EN applicants approved and denied in fiscal years 2009
and 2010 indicated staff do not consistently link EN qualifications to
promised services. We found 5 applicants who were denied explicitly
because they could not demonstrate experience or expertise working
with people with disabilities or in providing specific services, such
as work incentives counseling, self-employment assistance, and
supported employment. In contrast, 14 others who also did not
demonstrate such experience or expertise were approved, according to
the files[Footnote 92]. In one instance, an applicant approved by SSA
in August 2009 indicated in its RFP submission it planned to provide
career consulting, job placement, supported employment, as well as
various other services, but submitted a beauty institute license as
its only proof of qualifications to provide such services.
Conclusions:
SSA has achieved modest improvements in Ticket program participation
for ticket holders and ENs under the revised regulations finalized in
2008, and we are encouraged that in recognition of program weaknesses,
the agency is considering various improvements. However, at this time,
the agency still lacks critical management and oversight mechanisms to
assess whether the program is achieving its original purpose, and
ultimately, whether the program is viable. SSA is considering studying
ticket holders' exits from the rolls following the implementation of
the 2008 regulations; however, it is unclear whether the agency will
follow through with this effort. It also has not collected adequate
information on service provision that could help the agency and
policymakers analyze program trends, including the increasing
prevalence of sharing SSA ticket payments with ticket holders. In this
regard, SSA is not well positioned to assess the long-term success of
the program or whether service approaches, such as sharing payments
with ticket holders, are consistent with program goals. Moreover,
without regular reviews of ticket holders' timely progress toward
reducing dependence on benefits, they may remain exempt from CDRs,
regardless of whether they are in fact moving toward self-supporting
employment. Even with resumption of these reviews, SSA may be unable
to keep pace with the volume of reviews and their reliance on self-
reported information raises questions about accuracy. Inadequate
monitoring of ticket holders' progress raises program integrity
concerns and could result in benefit payments to beneficiaries who may
no longer be eligible. Further, absent assurance of EN quality and
sustained oversight of EN performance, ticket holders could encounter
ENs providing services or information that are inconsistent with the
program's purpose of reducing or eliminating dependence on benefits.
Ultimately, SSA must balance its efforts to increase participation in
the program with a commitment to outcome-oriented results that
emphasize reducing beneficiaries' dependence on benefits. Without
improvements to existing management tools and oversight procedures in
the Ticket program, SSA will not be able to provide reasonable
assurance that, in a time of increasing fiscal challenges, limited tax
dollars are being effectively used to achieve these important program
objectives.
Recommendations for Executive Action:
To inform assessments of the program's cost and effectiveness and
enhance SSA's oversight and monitoring of ENs and ticket holders, we
recommend that the Commissioner of Social Security take the following
four actions:
* prioritize and carry through with a study of participating ticket
holders' exits from the rolls since revisions to the program's
regulations took effect in 2008;
* adopt a strategy for compiling and using data on trends in
employment network service provision to determine whether service
approaches, such as sharing SSA ticket payments with ticket holders,
are consistent with program goals of helping ticket holders find and
retain employment and reduce dependency on benefits; for example, SSA
could revise existing tools to compile information on service
approaches used by all ENs;
* develop a strategy to ensure on-time completion of timely progress
reviews of ticket holders and take steps to ensure the accuracy of
information used to make timely progress determinations; and:
* move forward to develop EN performance measures consistent with the
requirements of the Ticket law.
Agency Comments and Our Evaluation:
We provided a draft of this report to the Social Security
Administration. In its written response, reproduced in appendix IX,
SSA agreed with three of the five recommendations in our draft report,
including a recommendation that the agency develop systematic
mechanisms for reviewing the qualifications of prospective ENs. SSA
also offered alternative language for the wording of two other
recommendations. With regard to our recommendation to prioritize and
carry through with a study of participating ticket holders' exits from
the rolls since revisions to the regulations took effect in 2008, SSA
stated that the agency already has plans to study the effects of the
revisions on the Ticket program. However, as we discuss in the report,
SSA's tentative plans to study exits from the rolls, in particular,
have not yet been undertaken and depend upon the results of other
planned research. We are encouraged that SSA intends to conduct this
research. However, we continue to believe that prioritizing and
carrying through with a study of ticket holders' exits from the rolls
is important and that, without such information, an accurate and
complete assessment of the program's effectiveness cannot be made.
With regard to our recommendation that SSA develop a strategy to
ensure on-time completion of timely progress reviews of ticket holders
and take steps to ensure the accuracy of information used to make
timely progress determinations, SSA stated that it has a strategy in
place, noting that it restarted the timely progress reviews in
November 2010. As we discuss in the report, SSA began resumption of
timely progress reviews for ticket holders due for review in November
2010. However, according to SSA, it did not carry out the initial step
in the review process for these ticket holders until February 2011.
Moreover, SSA estimates between 13,000 to 22,000 ticket holders will
be due for timely progress reviews each month of the first year of
resumption. Given SSA's current rate of processing the reviews and the
volume of additional reviews which are imminent, we continue to
believe there is potential for significant backlog in completing these
reviews. SSA also stated that the agency will review a random sample
of beneficiaries' cases to ensure the accuracy and reliability of
information they compile when making timely progress review decisions.
We welcome SSA's review of beneficiaries' cases, but continue to be
concerned that SSA may not have reliable information on the front end
to make timely progress determinations. Given that timely progress
reviews are intended to be used as a key program integrity tool--to
ensure appropriate exemptions from continuing disability reviews--we
continue to believe that SSA needs a strategic approach to ensure the
promptness and accuracy of timely progress determinations. SSA agreed
with the recommendation we made in our draft report that the agency
develop systematic mechanisms for reviewing the qualifications of
prospective ENs. After reviewing and providing comments on our draft
report, the agency posted a new Request for Quotation on April 27,
2011. This new Request for Quotation, which replaces all previous
RFPs, requires each EN to submit a comprehensive business plan and
includes more specific criteria for assessing EN qualifications. We
believe that this satisfies the intent of the recommendation we made
to the agency and should, if properly implemented, improve EN
oversight; thus, we have removed the recommendation from our final
report. SSA also provided technical comments, which we incorporated
into the report where appropriate.
As agreed with your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies of this report
to the Commissioner of Social Security, appropriate congressional
committees, and other interested parties. In addition, this report
will be available at no charge on GAO's Web site at [hyperlink,
http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-7215 or bertonid@gao.gov. Contact points for
our Offices of Congressional Relations and Public Affairs may be found
on the last page of this report. GAO staff who made major
contributions to this report are listed in appendix X.
Signed by:
Daniel Bertoni:
Director, Education, Workforce, and Income Security Issues:
[End of section]
Appendix I: Scope and Methodology:
Our review focused on (1) ticket holder and employment network (EN)
participation over time, (2) service approaches used by ENs, and (3)
the Social Security Administration's (SSA) policies and processes for
evaluating ticket holders and ENs. To answer all of our research
objectives, we reviewed relevant federal laws and regulations, and
SSA's Program Operations Manual System for the Ticket program, as well
as other written program policies and procedures. We conducted
interviews with SSA officials from the Office of Employment Support
Programs (OESP), SSA's contracted Ticket program manager, and SSA's
contracted Ticket program recruitment and outreach manager to learn
about their various roles and responsibilities and key management and
oversight functions, including approving ENs; reviewing individual
work plans, ticket assignments, EN annual periodic outcome reports,
and reviewing and processing EN requests for payment; as well as
reviewing timely progress of ticket holders. We also learned about the
processes and management of the Ticket program manager's call center
for beneficiaries. We conducted interviews and case file reviews for
selected ENs and state vocational rehabilitation agencies (VR) that
opted for the EN payment system. Overall, the scope of our review was
generally limited to ENs, including VRs that opt for the EN payment
system, although we examined changes in the number of ticket holders
using tickets with VRs paid through the traditional SSA Vocational
Rehabilitation Reimbursement Program over time. During our review, we
also consulted with outside researchers, disability advocacy
organizations, and other stakeholders. Specifically, we interviewed
Representatives of Mathematica Policy Research; the American
Association of People with Disabilities; Consortium for Citizens with
Disabilities;[Footnote 93] Easter Seals Inc.; Goodwill Industries
International, Inc.; National Alliance on Mental Illness; National
Council on Independent Living; and the World Institute on Disability.
For background purposes and to better understand the various roles and
functions of entities related to the program, during our design phase,
we interviewed Representatives of two state Protection and Advocacy
programs,[Footnote 94] a state Work Incentives Planning and Assistance
project,[Footnote 95] and an SSA regional Ticket coordinator. During
this phase we also contacted the SSA's Office of the Inspector
General, the Congressional Research Service, the Congressional Budget
Office, the National Council on Disability, and Social Security
Advisory Board to identify any related work under way in this area.
To learn how ticket holder and EN participation in the Ticket to Work
program has changed over time, we obtained and analyzed data on
eligible ticket holders and ENs[Footnote 96] approved by SSA from
fiscal year 2004, the year in which the Ticket program was fully
implemented,[Footnote 97] through July 2010. Specifically to learn
about ticket holder participation, we obtained data from SSA's
Disability Control File and Comprehensive Work Opportunity Support
System, for each of these years on the universe of ticket holders, and
those who had assigned their tickets to ENs.[Footnote 98] Specifically
to learn about EN participation, we obtained data from the Disability
Control File and Comprehensive Work Opportunity Support System and for
each of the years mentioned above, on ENs with SSA-approved contracts,
assigned tickets, and payments from SSA.[Footnote 99] For the purposes
of analyzing EN participation, we did not examine VRs with which
ticket holders use their tickets.[Footnote 100] To assess the
reliability of the data we obtained from SSA, we (1) reviewed existing
documentation related to the data, (2) interviewed knowledgeable SSA
staff about the data, and (3) tested the data for completeness and
accuracy. Our data analyst followed up with SSA staff on an ongoing
basis to clarify and resolve potential discrepancies she encountered
with the data. Based on these steps, we have found these data to be
sufficiently reliable for the purposes of our analysis. We also
interviewed SSA officials, disability advocacy organization
Representatives, and employment network Representatives and we
reviewed studies on ticket holder participation to learn about factors
influencing changes in participation.
To learn about service approaches used by ENs, between July and
September 2010, we interviewed Representatives of 25 ENs,[Footnote
101] which include 20 ENs among those with the largest payments in
fiscal year 2007, the year prior to implementation of the new program
regulations, and fiscal year 2009, the most recent year for which we
had full data.[Footnote 102] Based on preliminary data from SSA, we
selected the 20 ENs with the largest payments from SSA for our review
of services provided by ENs, because we wanted to be able to report on
services provided by ENs actually receiving payments from SSA, in
effect, to provide a better sense of how government (taxpayer) dollars
are being spent. In making this selection, we also determined that the
amount of SSA payments received by these ENs made up an extensive
share of the total payments SSA provided to all ENs.[Footnote 103] We
subsequently received updated data from SSA, which we confirmed with
our own data analysis, and found these ENs accounted for the 20 ENs
with the largest payments in fiscal year 2007, the 19 ENs with the
largest payments in fiscal year 2009, and the EN receiving the 22nd
largest payment in fiscal year 2009. See appendix VIII for the ENs
interviewed as part of this review. We conducted site visits to
Arizona, California, Connecticut, Maryland, and Massachusetts to visit
10 of these ENs and with Representatives of 2 ENs that have no
physical locations for delivering services. We selected ENs for our
site visits with a range of service approaches.[Footnote 104] For
these interviews, we asked ENs about the services they provided to
ticket holders, including the frequency of providing these services,
services they most commonly provide, the geographic area they serve,
and how their services had changed over time.[Footnote 105] We also
asked them about strengths and weaknesses of different service
approaches, and costs and incentives for participating in the Ticket
program. In addition to these interviews, we obtained and reviewed
documents from SSA for each of the 25 ENs we interviewed for
information on services provided by the ENs, as indicated in their
request for proposal submissions and their annual periodic outcome
reports. We also interviewed Representatives of disability advocacy
organizations, in addition to the ENs we interviewed, to gain their
perspectives on the advantages and disadvantages of various service
approaches used by ENs. To determine the distribution of ticket
payments to ENs using certain service approaches in fiscal years 2007
and 2009, we categorized ENs based on the primary service approach
they used. We also interviewed SSA officials to learn about SSA's
efforts to compile and use information on trends in service provision.
We did not assess the effectiveness of the different service
approaches we identified being used by ENs in the Ticket program.
To analyze the policies and processes SSA has to evaluate employment
networks and ticket holders, we compared SSA's and the SSA-contracted
Ticket program manager's written policies and procedures over key ENs
and ticket holder evaluation efforts to the Ticket program laws and
regulations, and government internal control standards. We conducted
in-depth interviews with OESP and the Ticket program manager staff
responsible for these key evaluation efforts, including the approval
of ENs, ongoing evaluation of EN performance, and assessment of the
timely progress of ticket holders who assign their tickets. To
supplement our review of SSA's efforts to evaluate EN for approval and
ongoing performance, we obtained a nongeneralizeable sample of case
files of approved, denied, and terminated ENs to review proof of
qualifications submitted to SSA and for EN performance information.
Specifically, we sampled files for: (1) 20 of the most recently
approved ENs as of April 30, 2010, (2) 11 denied EN applicants, which
constitute all applicants denied as of June 2010, (3) 17 ENs which had
been put on notice by SSA of potential termination--some of which were
subsequently terminated, and (4) 25 ENs comprising 20 ENs among those
with the largest payment amounts made by SSA in fiscal years 2007 and
2009. Within this sample, in order to assess SSA's controls over
approval determinations, we focused our review on the 38 case files
for applicants approved and denied in fiscal years 2009 and 2010. We
also interviewed ENs for their perspectives on SSA's performance
expectations and their responsibilities regarding the timely progress
of ticket holders. Finally, an Investigator from our Forensic Audits
and Investigative Service team contacted selected ENs, posing as a
fictitious employer or relative of a ticket holder, to test for
potential vulnerabilities in program management and oversight. The
Investigator phoned 16 ENs, including 9 from among the 25 we
interviewed and 7 ENs we identified using the online EN service
directory, interviews, and e-mail alerts. We judgmentally selected ENs
who advertised paying a portion of the ticket payment to ticket
holders or providing financial incentives to employers, or whose
services were unclear. The Investigator called 8 of the 16 to clarify
services provided by the ENs. In five of the recordings or calls, the
EN Representatives discussed how work could affect benefits. In three
of these, the EN Representatives explicitly told the caller how to
remain on benefits indefinitely while working. Although this is not
generalizable across all ENs, it illustrates potential vulnerabilities
in program management and oversight. Because of the program's goal of
helping ticket holders obtain and retain employment and reduce
dependence on disability benefits, for inclusion in our report we
focused on those portions of these three phone calls in which an EN
Representative discussed how to remain on benefits. The full
transcripts of the three calls are provided in appendix VII.
We conducted this performance audit from January 2010 to May 2011 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives.
[End of section]
Appendix II: Picture of a Ticket to Work:
[Refer to PDF for image: photograph]
Social Security Administration:
Ticket to Work and Self-Sufficiency:
Claim Account Number: 123456-7890:
Issue Date: March 12, 2007:
Form SSA-1359 (2-2002):
This ticket is Issued to you by the Social Security Administration
under the Ticket to Work and Self-Sufficiency Program. If you want
help in returning to work or going to work for the first time, you may
offer this ticket to an Employment Network of your choosing or take it
to your State vocational rehabilitation agency for services. If you
choose an Employment Network and it agrees to take your ticket, or if
you choose your State agency and you qualify for services, these
providers can offer you services to help you go to work.
An Employment Network provides the services at no cost to you. The
Social Security Administration will pay the Employment Network if you
assign your ticket to it, and the Employment Network helps you go to
work and complies with other requirements of the Program. An
Employment Network serving under the Program has agreed to abide by
the rules and regulations of the Program under the terms of its
agreement with the Social Security Administration for providing
services under the Program. Your State agency can tell you about Its
rules for getting services.
Signed by:
Michael J. Astrue:
Commissioner of Social Security:
Ticket Number 123-456-7890-TWI:
Source: SSA.
[End of figure]
[End of section]
Appendix III: Ticket to Work Payment Structure for Employment Networks:
[Refer to PDF for image: illustrated horizontal bar graph]
EN payment amount for 2010:
Milestone-outcome payment method:
Phase I: Milestone 1:
SSI Ticket holder‘s minimum earnings: 1 month at $720/month: $1,275;
DI Ticket holder‘s minimum earnings: 1 month at $720/month: $1,275.
Phase I: Milestone 2:
SSI Ticket holder‘s minimum earnings: 3 months at $720/month within 6
months: $1,275;
DI Ticket holder‘s minimum earnings: 3 months at $720/month within 6
months: $1,275.
Phase I: Milestone 3:
SSI Ticket holder‘s minimum earnings: 6 months at $720/month within 12
months: $1,275;
DI Ticket holder‘s minimum earnings: 6 months at $720/month within 12
months: $1,275.
Phase I: Milestone 4:
SSI Ticket holder‘s minimum earnings: 9 months at $720/month within 18
months: $1,275;
DI Ticket holder‘s minimum earnings: 9 months at $720/month within 18
months: $1,275.
Phase II: Gross earnings of $1,000/month ($1,640/month if blind);
SSI Ticket holder: $3,960 (up to 18 payments of $220/month);
DI Ticket holder: $4,202 (up to 11 payments of $382/month).
Outcome: Sufficient monthly earnings for a ’zero cash benefit“ status:
SSI Ticket holder: $13,200 (up to 60 payments of $220/month);
DI Ticket holder: $13,752 (up to 36 payments of $382/month).
Total payout:
SSI Ticket holder: Phase I, Phase II, Outcome: $22,260;
DI Ticket holder: Phase I, Phase II, Outcome: $23,054.
Outcome-only payment method:
Total payout: Sufficient monthly earnings for a ’zero cash benefit“
status:
SSI Ticket holder (up to 60 payments of $409/month): $24,540;
DI Ticket holder: (up to 36 payments of $711/month): $25,596.
Source: GAO analysis of SSA‘s EN payment structure.
[End of section]
Appendix IV: Range of Services Provided by Interviewed Employment
Networks in 2009 and 2010:
[Refer to PDF for image: illustration]
Employment Network Services:
Financial support services:
* Provide financial incentives to employers to hire ticket holders;
* Provide information on financial incentives to employers or help
them apply for financial incentives;
* Provide financial assistance or incentives to ticket holders.
Job search assistance:
* Directly provide vocational assessment and evaluation;
* Develop ticket holders‘ job seeking skills (e.g., resume writing,
interview skills);
* Assist ticket holders in starting a business or with self-employment;
* Match ticket holders with specific jobs;
* Provide links to job search engines or a database of job information;
* Provide Web site resources on job seeking tips.
On-the-job support:
* Provide direct vocational and/or on-the-job training;
* Assess for and provide assistive technology (e.g., custom computer
interfaces for persons with physical or sensory disabilities);
* Job accommodations or personal attendant services;
* Provide supported employment services (i.e., ticket holders with
severe disabilities are placed in competitive jobs with job coaches or
trainers who provide individualized, ongoing support services to aid
with job retention).
Job retention support:
* Provide services after the ticket holder is employed;
* Assist ticket holders in identifying and accessing a variety of local
support services (e.g., child care or transportation services).
Other support services:
* Directly employ ticket holders;
* Provide benefits and/or work incentives counseling;
* Provide independent living services;
* Provide medical and therapeutic treatment and services.
Source: GAO analysis of EN interview responses.
Notes: Some services may apply to more than one service category. Some
ENs reported providing additional services not included in this figure.
We conducted interviews with ENs in July through September 2010, and
we asked ENs about services they provided to ticket holders within the
last year.
[End of section]
Appendix V: Employment Networks Offer Services in Person, by Phone,
and Online:
[Refer to PDF for image: 2 photographs and associated web site]
Photograph 1:
Thirteen of the 25 ENs we interviewed primarily provide services in
person, like the EN pictured above.
Photograph 2:
Nine of the 25 ENs interviewed, including the one pictured above,
primarily provide services over the telephone.
Web site:
Five of the 25 ENs we interviewed primarily interact with ticket
holders online, including this one, which advertises work-from-home
job openings on its Web site.
Work At Home Positions:
All applicants must be legally able to work in the United States, have
excellent communication skills, a working Internet connection and the
ability to work independently. Click the job title box for more
details on any job.
(Unsure about working at home? Check to see if it is a good fit for
you by clicking here.)
Part-Time Certified Field Associate Scheduler:
Customer Care Professionals (CCP's) will be making outbound calls for
scheduling contractors like mystery shoppers, merchandise servers. 1
year retail sales and customer service experience required. High
School diploma or equivalent, 18 and older. Note: No
Background/Credit/Drug Screening.
Seasonal Work From Home Customer Care Associate:
Representatives will assist customers who are placing inbound phone or
online orders. Must be high school graduate or equivalent and pass
Credit, Criminal, Drug screening.
Customer Care Professional - Prepaid Credit Card Financial Services:
Customer service position for work related to prepaid debit cards,
retail cash reload and payment networks. Must be able relay
information specific to the credit card and provide resolution of
general customer issues as well as demonstrated ability to up sell and
cross sell. Requires computer literacy to navigate between multiple
browser and application. Must High school diploma and be 18 years old.
Sources: GAO photos and excerpt from EN Web site.
[A] One EN relies equally on phone and online interaction to deliver
services.
[End of section]
Appendix VI: Timely Progress Requirements for Ticket Holders
Participating in the Ticket Program:
[Refer to PDF for image: illustrated table]
Ticket holders must meet minimum requirements in either the earnings,
education, or training categories during each annual review[A]:
Timely progress review: First;
After 12 months of ticket use:
Earnings: Trial work level: 3 of 12 months at $720/month[B];
Education: Complete a high school diploma or GED or complete
60% of full-time college course load for an academic year;
Training: Complete 60% of full-time course load for an academic year.
Timely progress review: Second;
13-24 months of ticket use:
Earnings: Trial work level: 6 of 12 months at $720/month;
Education: Complete 75% of full-time college course load for an
academic year;
Training: Complete 75% of full-time course load for an academic year.
Timely progress review: Third;
25-36 months of ticket use:
Earnings: Substantial gainful activity (SGA) level 9 of 12 months at
$1,000/month[B];
Education: Complete a 2- or 4-year degree program Or complete an
additional academic year of full-time study;
Training: Complete a 2-year program and earn degree or certificate.
Timely progress review: Fourth;
37-48 months of ticket use:
Earnings: SGA level 9 of 12 months at $1,000/month;
Education: Complete an additional academic year of full-time study;
Training: (none).
Timely progress review: Fifth;
49-60 months of ticket use:
Earnings: SGA level with no cash benefits 6 of 12 months at
$1,000/month;
Education: Complete an additional academic year of full-time study or
complete a 4-year degree program;
Training: (none).
Timely progress review: Sixth;
61-72 months of ticket use:
73-84 months of ticket use and each year after:
Earnings: SGA level with no cash benefits 6 of 12 months at
$1,000/month;
Education: Complete a 4-year degree program;
Training: (none).
Timely progress review: Seventh;
73-84 months of ticket use and each year after:
Earnings: SGA level with no cash benefits 6 of 12 months at
$1,000/month;
Education: (none);
Training: (none).
Source: GAO analysis of SSA‘s timely progress requirements for ticket
holders.
[A] In the first four reviews, ticket holders can also meet minimum
requirements by completing a combination of work, education, and
training that totals 100 percent.
[B] The trial work level for 2010 is $720 per month. SGA level for
2010 is $1,000 per month, and $1,640 for blind beneficiaries.
[End of figure]
[End of section]
Appendix VII: Full Transcripts of Calls with Employment Networks on
Working Without Losing Benefits Indefinitely:
Of the 16 employment networks (EN) called by an Investigator from our
Forensic Audits and Investigative Service team, 8 were contacted to
clarify the services they provide (see appendix I for more information
on our scope and methodology). In five of the recordings or calls, the
EN Representatives discussed how work could affect benefits. In three
of these, the EN Representatives explicitly told the caller how to
remain on benefits indefinitely while working. Because the program's
goal is to help ticket holders obtain and retain employment and reduce
dependence on disability benefits, for inclusion in our report we
focused on those portions of these three phone calls in which an EN
Representative discussed how to remain on benefits. The full
transcripts of these three calls are provided below.
Call 1: Caller is a GAO Investigator phoning EN on behalf of his
fictitious brother who is a ticket holder, to learn about the Ticket
program and services provided by the EN. The EN Representative
describes how the EN assists ticket holders in finding part-time
employment and tells the caller a Social Security Disability Insurance
(DI) ticket holder may collect full monthly benefits indefinitely as
long as he remains under the substantial gainful activity (SGA)
earnings level.
(Whereupon, an outgoing call was placed by the GAO Investigator to an
EN Representative.)
(Phone rings.)
EN Representative: Good afternoon, (inaudible), (name) speaking. How
may I help you?
GAO Investigator: Yeah, hi, um uh, is this--what's--is this a company
that helps disabled people?
EN Representative: Yes.
GAO Investigator: Okay. Uh, I want to talk to somebody, if I could,
um, about, um--my brother is disabled, and I'm trying to help him.
He's trying to find a job, and I want to see what kind of services
your uh company provides.
EN Representative: Okay. One second. What's your name?
GAO Investigator: [Name].
EN Representative: [Repeats name]? Hold on.
(20 second pause.)
EN Representative 2: Hi, this is [name] from [inaudible]. How can I
help you?
GAO Investigator: Yeah, hi. I'm trying to get some information, if I
could. My, my brother's disabled, and he--he wants to try to go back
to work part time.
EN Representative 2: Okay.
GAO Investigator: And I'm trying to--:
EN Representative 2: Is he receiving SSI and SSD--or SSD?
GAO Investigator: Yeah, he's receiving um SSD.
EN Representative 2: Okay. So then he would qualify then. Because the
program is called Ticket to Work program, and the program is for
people that's getting SSI and SSD. So he would qualify and what would
happen is they would look for part-time work for that individual, and
he would keep half of the benefits. The benefits would not get cut
off. So he would work part time, and then it would supplement the
benefits. Um.
GAO Investigator: Okay. Now, do you all help him find a job?
EN Representative 2: Yes, we do.
GAO Investigator: Okay. All right, all right. Well, that's good.
EN Representative 2: Yes.
GAO Investigator: And what other type of services do you guys provide?
EN Representative 2: Um. They have um, direct--(name), are they still
doing [inaudible] counseling?
EN Representative 3: (off phone):
EN Representative 2: Residential?
EN Representative 3: (off phone):
EN Representative 2: Okay.
EN Representative 3: (off phone):
EN Representative 2: Okay. Because the caller wants to know, like, if
they have any additional services that they have. So, it's um
residential counseling.
GAO Investigator: Residential--what's that, residential counseling?
What's that?
EN Representative: Okay. Um. Residential counseling is um for people,
they train you, you get certifications and everything, to work in--
yeah, you work at a group home, residential areas, um.
EN Representative 3: (off phone):
EN Representative: Yes.
EN Representative 3: (off phone):
EN Representative: Yes.
EN Representative 3: (off phone):
EN Representative: Okay.
EN Representative 3: (off phone):
GAO Investigator: You're, you're talking to somebody else, I'm not
hearing what they're saying.
EN Representative: Oh, okay. Yes, the program entails where you could
work in the group homes, residential areas. And um for like
adolescents and stuff like that. That's for the residential training
that they have. And then if he had--:
GAO Investigator: So they teach you--:
EN Representative: If he, if he had any prior work experience, what
they'd do is they'd look for the jobs that they either have on their
resume, if they have one, or um they'll like set up whatever, set that
interview up for him to get the job.
Because with most of the people that come in, they never had jobs
before. You know, they've just, you know, been on disability. So, you
know, we'll add additional things, and we have resume specialists
here, we have the job developers.
This is pretty much a company that's dealing with people with
disability. So in order for you to qualify for the Ticket to Work
program, you have to be getting SSI and SSD. So.
GAO Investigator: Mmm. Okay. And how much do you all charge for these
services?
EN Representative: This is free. This is free. This is funded by the
government, so everything is free. So what he would--oh, okay. Hello?
GAO Investigator: Yeah. You're saying it's free? I mean, you're not, I
gotta think, you're not doing it for free. Do the payments go to you
or something, and then--[inaudible]--:
EN Representative: Well, this is a government-funded program, so I
don't--you, when you come in, you don't have to pay no fee. This is
not a temp agency where you have to pay a fee.
GAO Investigator: Okay.
EN Representative: So this is a service where it's funded by the
government, and it's services of--you know--to the community where
they help people with disability find part-time work. Because if they--
if you get any full-time work, then you know, they're gonna cut you
off. So we're not offering you full-time work. We're helping you find
part-time work.
GAO Investigator: Mmm, okay. All right, yeah. Because that way he
avoids getting his payment cut off?
EN Representative: No, that's not going to happen. No.
GAO Investigator: Okay, okay. Well, that's good. And, and what kinds
of jobs are you talking about here?
EN Representative: Well, they have maintenance, um, janitorial. They
have, um, a list of jobs. Um, and like I was, right, like I was saying
you to before, if he worked before, then they can help him on the jobs
that he has on his resume.
GAO Investigator: Okay.
EN Representative: So if he did any kind of security or maintenance,
whatever he would have on his resume, that's the type of job that he
would--that they would find for him.
And also, he would have to let them know what he's looking for, too.
Because they're here to help him--:
GAO Investigator: Oh, okay.
EN Representative: So they--he has to give him an idea, or whoever
comes with him would have to give the job developers an idea of what
kind of work he's looking for.
GAO Investigator: Okay. All right. And how does it--how do we get this
started? Does he have to come in there, or can he just--you know he's-
-I'm trying to help him here a little bit, but--:
EN Representative: Yes. Yes.
GAO Investigator: What's next?
EN Representative: Okay. Yes. He can come in. The days for that is
[gives days and times].
GAO Investigator: Okay. And, and what happens at that time?
EN Representative: When he comes in, he has to bring a resume if he
has one. If he doesn't, it's not a problem. His Social and birth
certificate, and that's it.
GAO Investigator: Okay, okay. All right. And um--All right. So if he
gets a job and he's working and all that, I assume that eventually his
benefits will be cut off?
EN Representative: No. No. They will not be [inaudible]--because this
is the Ticket to Work program, so this is um not like uh real
employment. This is like we said, we deal with people with disability,
so we get them part time work only, that--it would supplement. His
benefits would be supplemented, but it would not get cut off.
GAO Investigator: Okay.
EN Representative: Now, if he's making enough money, or if he's
working a full-time job where they're gonna you know--of course,
they're gonna say "Okay, well you might not need assistance any more."
But if it's, you know, part-time, and it's not too much money, and th-
this is not full time, then yes, he would qualify.
GAO Investigator: Okay. All right. So as long as he doesn't make too
much money, he won't get cut off.
EN Representative: Exactly.
GAO Investigator: Okay. All right. Well, that sounds good. All right.
So I have--:
EN Representative: Do you have the address here?
GAO Investigator: Um, no, why don't you give that to me?
EN Representative: Let me know when you're ready.
GAO Investigator: Yeah, go ahead.
EN Representative: Okay. The address is [gives address]
GAO Investigator: [repeats address]?
[discussion about address and directions]
GAO Investigator: Okay. All right. Good. Well, thank you very much.
You've been real helpful.
EN Representative: You're very welcome.
GAO Investigator: All right. Bye-bye.
(Whereupon, the call was concluded.)
Call 2: Caller is a GAO Investigator phoning EN on behalf of his
fictitious brother who is a ticket holder to learn about the Ticket
program and services provided by the EN. The EN Representative
describes how the EN assists ticket holders in finding employment and
tells the caller that a DI ticket holder may collect full monthly
benefits indefinitely as long as he remains under the SGA earnings
level.
(Whereupon, an outgoing call was placed by the GAO Investigator to an
EN Representative.)
(Phone rings.)
EN Representative: Ticket to Work, [name] speaking.
GAO Investigator: Yeah, hi. This is [name of EN]?
EN Representative: Yeah, absolutely.
GAO Investigator: Um, okay. Listen, I'm calling--I got your number off
the EN directory.
EN Representative: Yeah, okay.
GAO Investigator: I'm calling on behalf of my brother.
EN Representative: Okay.
GAO Investigator: He's disabled, and it looks like he's going to try
to get back to work.
EN Representative: Okay.
GAO Investigator: So, um, I'm trying to figure out what you guys do.
EN Representative: Um, well, let me ask you. Does he have any, uh,
prior work history?
GAO Investigator: Yeah, yeah. He's got experience working in, you
know, office-type work.
EN Representative: Oh, really?
GAO Investigator: Administrative type stuff. Uh-huh.
EN Representative: When's the last time that he worked?
GAO Investigator: It's been like a year and a half, or so.
EN Representative: Yeah, that's not a problem. Um.
GAO Investigator: What kind of jobs--do you have those kind of jobs?
EN Representative: Well, we don't have a magic hat, you know? What
we're going to do--our position here is to, you know, work with our
clients in--on a partner arrangement, to where we assist them, uh, in
giving them job leads and helping them through the application
process, and uh, help them through--you know--with interviewing, uh,
tools and skills if they require that.
Um, but we don't--we're not in a position where we simply go out and
just get jobs for people. We don't find that, uh, that it has a very
high success rate, uh, simply because, um, because the individual
that's getting the job, they're the one that has to perform.
And they have to follow through.
GAO Investigator: Okay.
EN Representative: You know--you know what I mean? So if--:
GAO Investigator: So what do you do? Like if he finds something, you
help him--:
EN Representative: Well, what I will do is, we sign people on, and
what I do is I go through and I create resumes for them, or update
their current--or older resumes, help try to fill those gaps that are
missing, so that they're--they look proper when their employer looks
at it.
I help my clients do cover sheets to send out along with their resumes
for, you know, job applications, and, uh, basically try to--and then I
send them job leads all the time on an ongoing basis. So that's one
that's really important, but it's also important that the client does
it as well.
GAO Investigator: Okay, right.
EN Representative: So it's a partnership. I mean I need to see that
the person is working with me, so that I know that, you know, my time
that I'm investing in them, it's gonna pay off, not so much for me,
but for them in the end.
Because it takes that individual to stay employed. I can't, you know,
call them every morning and tell them to get up and go to work. And so
they have to have initiative on their own.
And that's how I really determine, really how much effort that I'm
putting into each client, is whether they're participating on their
end as well.
GAO Investigator: Okay, well, he's not lazy. He just was not
physically able to--you know, he's got a heart condition. That's what
the problem was.
EN Representative: Oh, I see. He was not physically able to do what?
GAO Investigator: Well, it was kind of just stressful for him, you
know? I mean, you know, he gets--he just can't take a lot of stress,
basically.
EN Representative: Uh-huh. So as far as looking for jobs, or as far as
maintaining jobs?
GAO Investigator: Yeah, probably maintaining jobs.
EN Representative: Uh-huh.
GAO Investigator: But now what do you all charge for your services?
EN Representative: Nothing. It's free. The services are free, so long
as the individual is eligible for the Ticket to Work program.
GAO Investigator: Yeah, he's got the ticket.
EN Representative: Yeah, see, so. And if he's already got, you know,
previous job skills, it's probably something that we'd be able to help
him with. But he needs to really, you know, determine, you know, to
what degree he's able to work, or even wants to work. Because with any
given situation, I mean, an employer's gonna want to see performance,
plain and simple.
GAO Investigator: Right.
EN Representative: And if--and if the individual is not performing,
then it's likely that they're going to lose their--that position.
GAO Investigator: Right. He doesn't have to work full time, though?
EN Representative: No, not at all. He can work part time. Um, but
those--those jobs are--what--they're probably more difficult to find,
just because most employers are looking to fill a position, as opposed
to finding two people to fill a position.
GAO Investigator: Mmhm.
EN Representative: But there are part-time jobs out there. I have a
lot of clients that come to me and say "You know what, I don't think I
can work full time." And so we just--we hit the dusty trail, and we
just start hammering away, and looking until we find something that
actually suits them.
And the big thing is, really is, you know, what type of work that
they're looking to do. The clerical work, um, uh, I can find part-time
clerical work, but in most cases it's going to be in an office
environment, a medical environment, or, uh, like an intake
environment, like bringing in new memberships, like at clubs and stuff.
And so all of those are going to have a certain degree of stress. I
mean, no matter what. Because they're multitasking. They're having to
greet people as they're coming in, they're having to answer the phone
calls, they're having to file and input intake information.
So there's a certain degree of stress with any of them. The ones that
you want to stay away from most certainly are the law firms. The law
firms are just--they're chaotic. And I've had--I've placed people in
those jobs before, and uh, and they don't normally pan out, especially
with people that have, uh, any type of mental disability.
Um, it just gets way overwhelming for them. And it's not like they
don't know how to do the work; it just becomes something that's so
overwhelming that it just becomes a stressful situation.
GAO Investigator: Yeah. I mean, it's not the mental part for him. It's
more that the stress affects him. You know what I mean?
EN Representative: Right, yes. So, and it does. Stress affects us both
mentally and physically. And, uh, so what it would be is just a means
of being able to take the time, you know, look around, and interview
jobs as well as they interview you, and find something that, you know,
your brother feels like he would be comfortable dealing.
And then all you can do is try it. And if it feels--if it works, then
it does. And if not, then it doesn't. And the Ticket to Work program
is kind of designed--what benefit is your brother collecting? SSDI or
SSI?
GAO Investigator: Disability.
EN Representative: Oh, Disability. So, so you've got all the perks
that go along with the Ticket to Work program. There's a--you can--you
can earn up to S1,000 a month, and it doesn't affect your benefit at
all.
GAO Investigator: Oh, wow. Okay.
EN Representative: Yeah, so you can work basically any part-time job
that's being offered, for you know, from 7.50, which is minimum wage,
up to around $10 or $11 an hour working part-time, and you're not
gonna exceed that.
GAO Investigator: And how long--I mean, if he gets a job and continues
to work, I mean will--eventually will he be off of the Ticket to Work
program?
EN Representative: No, no. It's an ongoing thing. I mean, he'll stay
with us until he unassigns his ticket.
GAO Investigator: Oh, wow.
EN Representative: And what it is, basically, is--the Ticket to Work
program is designed--I don't know if you're aware of continuing
medical reviews?
GAO Investigator: Yeah, right. I mean, periodically--:
EN Representative: Yeah, exactly. And those are one of the safeguards
that--when you're under the Ticket to Work program, those are
basically put on hold. So they're not subject to that anymore. And the
service continues.
So say your brother goes to work, and then that particular job doesn't
work out. Well, then he just calls (name) back up, and says "You know
what, (name)? That one didn't work out," for, you know, whatever
reasons. "I decided it just wasn't a good fit," or "It became too
stressful," or whatever. Then we just start again.
GAO Investigator: Mmhm. Yeah, but if he gets into a job that seems to
work for him, and it's not too stressful and--I mean, he can just
continue to do that indefinitely, huh? And still receive the benefits
of both Ticket to Work and--and--disability?
EN Representative: Exactly. Yeah. It's a win/win situation. What it
basically is, is the ticket--it's like, if your brother had no prior
work experience at all, they allow you like a trial work period, where
it's 9 months and you can make as much as you want and it doesn't
affect your benefit at all.
And then after that, then it starts to affect your SSDI. And if you--
and they consider anything over $1,000 a month substantial gainful
activity. And if you were to go over that $1,000 a month, they would
take the cash benefit away from your brother.
And so my job is to--to look at what portions of the program are still
available to your brother. He may have used those trial work months
without ever knowing it. It goes from the date that he's eligible to
receive the benefit, or the date that he's receiving the cash benefit.
Any month that he worked over $1,000--or over $720 a month in gross
income counts as one of those trial work months.
And those really aren't important so much like in your case, because
your brother doesn't want to go to work full time. So it's not gonna
be something that's applied. What's important for your brother to know
is that right now, as of 2010, he can go out, work any job that he
wants so long as he stays under the $1,000 a month, he gets his cake
and eat[s] it too. He gets the--he gets his wages, and he gets his
full SSDI benefit, and the medical, and everything that goes along
with it. And that can--that can go from today until your brother
retires, or whatever. You know what I mean?
GAO Investigator: Mmhm.
EN Representative: Nothing's gonna be affected.
GAO Investigator: Okay.
EN Representative: And that's what most people come to me for, they--
they come to me and say "You know what? I don't want to lose my cash
benefit. How do I do that?" And--and that's exactly how you do that.
SSI's a lot different than what the SSDI is, but the SSDI has all the
benefits of, you know, being able to work up to that 1,000 a month and
not affect anything.
GAO Investigator: All right. So the problem really is, I mean, if he
ended up working full time and making too much money, that's where the
problem comes in, huh?
EN Representative: Yeah, exactly. What ends up happening is that, you
know, once he goes over the SGA, then Social Security looks at it and
they go "Oh, hey, look. This guy's working at--now he's making $1,500
a month, or $2,000 a month."
They then look at that, and consider that self-sufficient in the eyes
of the government. And--and then they will eliminate the cash benefit.
But all of his medical and everything stays in place. That--that will
continue, uh, I think it's like 93 months. It's like 8 years, I think
it is, it continues.
And then at some point that would be affected, but that's only if he's
working above the substantial activity, which is over $1,000 a month.
But the--I think most--you know that, to get into this--either they're
going to go full at it, and they're fully capable, physically and
mentally, to go back into the work system full time and not worry
about the SSDI, because they can make much more working full time.
Or they have the other disposition, whereas "I don't think I'm ever
gonna wanna work full time. I just want something to supplement my
benefit."
GAO Investigator: I see. Okay.
EN Representative: That's the two sides of the coin. That's basically
the only two sides that are there. One is you're either satisfied
supplementing, or you apply yourself to the point where you just
simply get off of it and you're happy because you're making--how much
is your brother's SSDI amount per month?
GAO Investigator: Oh, man. I've got to check with him. I'm not even
sure.
EN Representative: Yeah.
GAO Investigator: I mean, I'm helping him out, but you know, I don't
know all his affairs, you know what I mean?
EN Representative: Right--yeah, yeah. And the thing of that is, is
people that are only getting--if you have--SSDI is based on work
history. So if you've got a lot of work history, then it means you
paid in a lot to Social Security, and that's what dictates what that
cash benefit is from SSDI.
So, you know, I've got some people that come to me and they say "I'm
collecting $2,500 a month on SSDI." And I'm like "Why the Hell would
you want to go to work?"
GAO Investigator: Yeah.
EN Representative: You know what I mean? Those are hard cases, because
I have to go out and find that person a job that makes--that wants to
go to work full time, that makes more than that $2,500 a month.
Otherwise it doesn't make any sense to get off the benefits.
Just like being on unemployment. If you're making, you know, you know,
$2,000 a month on unemployment and you can't find a job--full-time job
that pays you more than that, what's the incentive to get off of it?
Financially, it doesn't make any sense.
So those that are below, say, $1,000 a month on that SSDI benefit, if
they want to go to work full time it makes sense, because they can
make $3,000 a month or $2,000 a month, and who cares about the 900?
You're already 1,000 ahead of the game, plus you have your medical.
GAO Investigator: Mmhm, mmhm.
EN Representative: But those that are making you know, $1,000, maybe
$1,500 or so on the cash benefit, and--and they're not able to work
full time, then it benefits them just to work part time and supplement
that SSDI, and be happy with that.
But then that's $1,000 a month, or $800 a month, or whatever, in your
pocket every month, and not have it affect your benefit, you know?
GAO Investigator: Mmhm, mmhm. All right. Well, sounds good. So the
next thing for him to do for you all would be what?
EN Representative: Um, uh. What I would want to see is really a
detailed picture of what his past work history was. And, uh, what
positions that he held, and for the lengths of time that he held.
GAO Investigator: Uh-huh.
EN Representative: And then to find out what his cash benefit is, so
that we know what we're working with.
Um, and if he's interested in putting himself back to work part time,
then I can take that--most of that information I can get over the
phone, um, and kind of--kind of put together a little picture for
myself of--of, you know, where your brother is on his benefit, and
what his past work history and stuff is.
Then I can call and find out whether his ticket's available for
assignment, which I'm sure it is. Has he gone to any DVRs [state
vocational rehabilitation agencies], or any other employment networks
at this point?
GAO Investigator: No--no.
EN Representative: Yeah. And how long has he been on the cash benefit,
receiving the SSDI?
GAO Investigator: Um, it's been maybe a couple years, maybe.
EN Representative: Yeah, okay.
GAO Investigator: Somewhere in that neighborhood.
EN Representative: Yeah. And then if he's really interested in, you
know, going out and finding himself a job, then, you know, I can
schedule an appointment. He can come in, we can fill out the
paperwork. There's only a few forms to fill out. Um, and then we can
go ahead and start with preparing, you know, resumes and start the job
searching process.
And it's basically just an ongoing thing. Every single day, I have a
list of clients that are looking for employment. I go through probably
50 or so job sites that are offering employment, and try to match
people up.
And at the same time, they're looking also, you know what I mean? To
see what's out there. And I suggest that they do, just because I have
people come to me and go "I want a job in data entry." And I go, "All
right, but do you know how many of those jobs are out there and what
they're looking for to fill those positions?"
And if they don't, then they get restless with me, and they go "Hey,
how hard can it be?" Well, it's not hard. There's thousands of data-
entry jobs out there. But each one of those data-entry jobs are
looking for specific skills that they want to fill.
And some of my clients that want to do that, they want to be in a
situation where they're not pressured, where they're not dealing with
the public so much. Um, but those types of companies are like coding
companies, and--like medical coding and billing companies. That's data
entry. Well, you need to be certified to do that.
GAO Investigator: Gotcha. Well, listen. Let me--let me have him give
you a call.
EN Representative: That would be perfect.
GAO Investigator: I was just trying to kind of, you know, screen
through some of these, because there's--:
EN Representative: Exactly.
GAO Investigator: --got just a bunch of numbers off the directory. All
right. Well, thanks very much. I appreciate it.
EN Representative: You're very welcome.
GAO Investigator: All right. Bye.
EN Representative: Bye.
(Whereupon, the call was concluded.)
Call 3: EN's recorded outgoing message. The message states that DI
ticket holders may collect full monthly benefits indefinitely as long
as they remain under the SGA earnings level. Note: the recorded
message provides outdated information on the SGA level. For 2010,
individuals were considered engaged in SGA if they had earnings above
$1,000 per month or $1,640 per month for blind beneficiaries.
(Whereupon, an outgoing call was placed by the GAO Investigator to an
EN Representative.)
(Phone rings.)
EN Recording: You have reached [EN name]. [EN name] is a non-profit
organization authorized to work with Social Security beneficiaries
under the Ticket to Work program. Our costs are covered by government
funds. No fees are charged to individuals with disabilities. Please
listen to all of our menu options, and then press the designated key.
For information on the types of home-based jobs available through [EN
name], press one. For information on how you can work part-time and
continue to collect Social Security disability benefits, press two.
For information on the qualifications needed in order to hold an [name
of EN] home-based job, press three. For information on the equipment
you will need to work from home, press four. For information on how
you can obtain training and equipment from your state vocational
rehabilitation agency if you do not have the required skills or
equipment, press five. For information on how to apply to [name of EN]
for a home-based position, press six.
(Call redirected after pressing 2.)
EN Recording: About 70 percent of the home agents working through [EN
name] receive Social Security benefits. Most receive SSDI, which means
they are allowed to earn up to $900 per month if they have a general
disability and $1,500 per month if they are blind. As long as SSDI
recipients remain under those earning limits and their disability does
not improve, they can work part-time and continue to collect their
full monthly SSDI check indefinitely.
For those receiving SSI, the rules are different. Those on SSI will
lose approximately 50 cents of their SSI check for every dollar earned
from a job.
More details are available on our Web site, [name of Web site]. I'll
spell that. [name of Web site] To return to the main menu, press zero.
(Call redirected.)
EN Recording: You have reached [EN name]
(Call redirected.)
EN Recording: To apply for [name of EN]'s home-based jobs, you must go
to our Web site, which is [name of Web site]. I'll spell that. [name
of Web site] And complete an online application.
If you do not currently have a computer or Internet access, go to your
local library or use a friend's system to apply. If you are given a
job offer, chances are very good that your state VR agency will
provide you with the tools you need to perform the work.
Again, the Web site for [name of EN] is [name of Web site]. To return
to the main menu, press zero.
(Whereupon, the call was concluded.)
[End of section]
Appendix VIII: List of Employment Networks Interviewed For This Review:
AATakeCharge Milestone, LLC:
Adelante Development Center, Inc.
American Rehabilitation Corporation:
ARG, LLC:
Arizona Bridge to Independent Living:
Asian Rehabilitation Service, Inc.
Bureau of Rehabilitation Services, Connecticut Department of Social
Services:
Bureau of Vocational Rehabilitation, Division of Career Technology and
Adult Learning, New Hampshire Department of Education:
Cerebral Palsy Research Foundation of Kansas, Inc.
Diagnostic Enterprises, Inc.
disABLEd WORKERS, LLC:
Division of Vocational Rehabilitation, Vermont Agency of Human
Services Employment Options:
Louisiana Rehabilitation Services, Louisiana Workforce Development,
Louisiana Workforce Commission:
National Telecommuting Institute, Inc.
Oklahoma Department of Rehabilitation Services:
Relational DataSearch:
Rewards for Working, Inc.
Service First of Northern California:
TakeCharge Vocational Rehabilitation Services, LLC (AAA):
The Workplace CA:
Ticket to Work Services, LLC:
Tulare County Office of Education Vocational Rehabilitation Services,
Bureau of Rehabilitation Services, State of Indiana:
Walgreen Co.
[End of section]
Appendix IX: Comments from the Social Security Administration:
Social Security:
Office of the Commissioner:
Social Security Administration:
Baltimore, MD 21235-0001:
March 23, 2011:
Mr. Daniel Bertoni:
Director, Education, Workforce, and Income Security Issues:
United States Government Accountability Office:
441 G Street, NW:
Washington, D.C. 20548:
Dear Mr. Bertoni:
Thank you for the opportunity to review your draft report, "Social
Security Disability: Ticket to Work Participation Has Increased, But
Additional Oversight Needed“ (GA0-11-324). Our response is enclosed.
If you have any questions, please contact me or have your staff
contact Chris Molander, Senior Advisor, Audit Management and Liaison
Staff, at (410) 965-7401.
Sincerely,
Signed by:
Dean S. Landis:
Deputy Chief of Staff:
Enclosure:
[End of letter]
Comments On The Government Accountability Office (GAO) Draft
Report, "Social Security Disability: Ticket To Work Participation
Has Increased, But Additional Oversight Needed" (GAO-11-324):
Thank you for the opportunity to review the subject report. We offer
the following responses to the recommendations:
Recommendation 1:
Prioritize and carry through with a study of participating Ticket-
holders' exits from the rolls since revisions to the program's
regulations took effect in 2008.
Response:
We disagree with this recommendation as worded. Since 2003, we have
performed studies similar to the one proposed with assistance from
Mathematica Policy Research, Inc. In correspondence provided during
your study, we informed you that we had already planned to
study the effects of the 2008 regulations on the TTW program. We
provided a copy of that plan on February 17, 2011.
Please revise the recommendation to read:
"Continue your study of participating Ticket-holders' exits from the
rolls since the revisions to the program's regulations took effect in
2008."
Recommendation 2:
Adopt a strategy for compiling and using data on trends in employment
network service provision to determine whether service approaches,
such as sharing SSA ticket payments with Ticket-holders, are
consistent with program goals of helping Ticket-holders find and
retain employment and reduce dependency on benefits; for example, SSA
could revise existing tools to compile information on service
approaches used by all Employment Networks (ENs).
Response:
We agree. We will require every EN to provide a business plan
describing its service approach. We will include this requirement in
the Request for Quotation (RFQ) that we post to Federal Business
Opportunities (FedBizOps). We will cluster EN service approaches into
categories and analyze each approach to assess whether it is
consistent with program goals.
Recommendation 3:
Develop a strategy to ensure on-time completion of timely progress
reviews of Ticket-holders and take steps to ensure the accuracy of
information used to make timely progress determinations.
Response:
We disagree with this recommendation as worded. We already have a
strategy in place. As the report acknowledged, in November 2010 we
restarted timely progress reviews of Ticket-holders to ensure they are
making progress towards self-sufficiency. In addition, each year we
will review a random sample of beneficiaries' cases to ensure the
accuracy and reliability of the information we compile when making
timely progress review decisions.
Please revise the recommendation to read:
"Continue to address on-time completion of timely progress reviews of
Ticket-holders and take steps to ensure the accuracy of information
used to make timely progress determinations."
Recommendation 4:
Move forward to develop EN performance measures consistent with the
requirement of the Ticket law.
Response:
We agree. We have strengthened oversight of ENs by developing a
performance measurement system to further assess whether ENs are
meeting beneficiaries' needs. We will require remediation plans from
ENs who do not meet defined standards. If ENs do not comply with
standards, we will impose penalties, including contract terminations.
As part of this process, we will issue a performance report card to
every EN. We are piloting the report card in California and plan
nationwide implementation by the end of this calendar year.
Recommendation 5:
Develop systematic mechanisms for reviewing the qualifications of
prospective ENs. Specifically, SSA should expedite updates to its
approval process to require that all prospective ENs submit a
comprehensive business plan describing how their services will meet
the program's purpose of helping Ticket-holders obtain and retain
employment and reduce dependence on SSA disability benefits. SSA
should also develop clear and specific criteria for SSA staff who
review prospective ENs' qualifications.
Response:
We agree. As we noted under Recommendation 2, we will require every EN
to submit a business plan describing how it will assist beneficiaries
in obtaining and retaining employment. The plan must describe how the
EN will obtain beneficiary referrals; how, where, and by whom services
will be provided; and other information regarding service delivery. We
will also require the EN to submit any proposed changes to its
business model.
Additionally, we will incorporate the new RFQ requirements into our
existing contracting approval checklist. This checklist is part of the
automated review system housed in our Comprehensive Work Opportunity
Support Software. We will train staff to ensure we apply the new
guidelines in a consistent manner and will conduct random audits to
ensure staff compliance.
[End of section]
Appendix X: GAO Contact and Staff Acknowledgments:
GAO Contact:
Daniel Bertoni, (202) 512-7215 or bertonid@gao.gov:
Staff Acknowledgments:
Jeremy Cox, Assistant Director, and Cady S. Panetta, Analyst-in-
Charge, managed this report and Kristen Jones made significant
contributions to all aspects of the report. Other staff who made key
contributions to the report include Wesley Sholtes and Margeaux
Randolph. Luann Moy and Vanessa Taylor assisted with the methodology
and data analysis. Craig Winslow provided legal assistance. Paul
Desaulniers provided investigative assistance. Susan Aschoff and James
Bennett helped prepare the final report and the graphics.
[End of section]
Footnotes:
[1] These data are from the fiscal year 2012 President's Budget.
[2] DI benefits are financed by payroll taxes paid into the Federal
Disability Insurance Trust Fund by covered workers and their
employers, with tax amounts based on a worker's earnings. 42 U.S.C. §
401(b). The Congressional Budget Office projected the Trust Fund will
be exhausted by 2018 if no changes are made to current funding and
benefit formulas. The SSI program is funded through general revenues.
42 U.S.C. § 1381.
[3] GAO, Social Security Disability Insurance: Factors Affecting
Beneficiaries' Return to Work, [hyperlink,
http://www.gao.gov/products/GAO/T-HEHS-98-230] (Washington, D.C.: July
1998).
[4] Pub. L. No. 106-170, § 101, 113 Stat. 1860, 1863-73 (codified as
amended at 42 U.S.C. § 1320b-19).
[5] Administered by the Department of Education since 1973, the
Vocational Rehabilitation program provides funds to states to offer
employment services ranging from treatment of impairments to job
counseling and placement. 29 U.S.C. §§ 721 and 731. Under SSA's
Vocational Rehabilitation Reimbursement Program, established before
the Ticket program, SSA reimburses VRs for costs of providing services
to a beneficiary when the beneficiary has earnings above an
established threshold over the course of 9 months. 42 U.S.C §§
422(d)(1) and 1382d(d). With the establishment of the Ticket program,
VRs can choose to be paid under the EN payment system or traditional
cost-reimbursement system.
[6] Amendments to the Ticket to Work and Self-Sufficiency Program, 73
Fed. Reg. 29,324 (May 20, 2008).
[7] The scope of our review was generally limited to ENs and VRs paid
as ENs, although we examined changes in the number of ticket holders
using tickets with VRs which were paid through the cost-reimbursement
system over time.
[8] SSA began mailing tickets to eligible beneficiaries in 13 states
in February 2002, and expanded the program to all 50 states by
September 2004.
[9] Using preliminary data from SSA, we selected the 20 ENs with the
largest payments in fiscal years 2007 and 2009. We subsequently
received updated data from SSA, which we confirmed with our own data
analysis, and found these ENs accounted for the 20 ENs with the
largest payments in fiscal year 2007, the 19 ENs with the largest
payments in fiscal year 2009, and the EN receiving the 22ND largest
payment in fiscal year 2009. There was significant overlap in ENs with
the largest payments in fiscal years 2007 and 2009: 13 ENs were among
those with the largest payments in both years. Additionally, two of
these 2007 ENs later merged, so we did not conduct separate interviews.
[10] Two of the 12 ENs we visited had no physical location for
providing services; however, we met with Representatives of the ENs in
person.
[11] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]
(Washington, D.C.: November 1999).
[12] For our case file review, we sampled files for (1) recently
approved ENs, (2) denied EN applicants, (3) ENs on SSA notice of
potential termination, including several subsequently terminated, and
(4) ENs among those with the largest payments from SSA in fiscal years
2007 and 2009. See appendix I for further details.
[13] The Investigator phoned 16 ENs, including 9 from among the 25 we
interviewed and 7 ENs we identified using the online EN service
directory, interviews, and e-mail alerts. We judgmentally selected ENs
who advertised paying a portion of the ticket payment to ticket
holders or providing financial incentives to employers, or whose
services were unclear.
[14] 42 U.S.C. §§ 416(i) and 1382c(a)(3). Under thresholds set
annually by SSA, individuals are considered engaged in SGA if they had
earnings in 2010 above $1,000 per month for nonblind beneficiaries and
$1,640 per month for blind beneficiaries.
[15] 20 C.F.R. § 404.1589 (2009). CDRs may be conducted generally
every 6 to 18 months, 3, or 5 to 7 years, depending on the
beneficiary's disability. 20 C.F.R. § 404.1590(d) (2009).
[16] 20 C.F.R. § 404.1592(a) (2009). The trial work period is reached
when a beneficiary accumulates 9 months of earnings of at least the
trial work level amount in a 60-month period. 20 C.F.R. §
404.1592(e)(2) (2009). In 2010, the trial work level was $720 per
month.
[17] 20 C.F.R. § 404.1592(a) and (d) (2009).
[18] 20 C.F.R. § 416.1112(c)(5) and (7) (2009). SSI beneficiaries also
receive a general income exclusion in which the first $20 of earned or
unearned income in a month does not reduce benefits. 20 C.F.R. §
416.1124(c)(12) (2009).
[19] 20 C.F.R. § 416.1335 (2009).
[20] Pub. L. No. 106-170, § 2, 113 Stat. 1860, 1862-63.
[21] H.R. Rep. No. 106-220 (pt. 1) at 10.
[22] The Ticket law mandated that during any period for which an
individual is using, as defined by SSA, a ticket, SSA may not initiate
a CDR. 42 U.S.C. § 1320b-19(i). In its program regulations, SSA
defines "using" a ticket as making "timely progress toward self-
supporting employment," and outlines specific requirements a ticket
holder must meet in order to demonstrate timely progress and obtain or
maintain CDR exemption. 20 C.F.R. § 411.166 (2009).
[23] 42 U.S.C. § 1320b-19(h). SSA makes payments to ENs for DI
beneficiaries through the Federal Disability Insurance Trust Fund and
to ENs for SSI beneficiaries through appropriations from general
revenues. 42 U.S.C. §§ 401(b) and 1381.
[24] 42 U.S.C. § 1320b-19(f)(1)(C).
[25] 42 U.S.C. § 1320b-19(d)(2) and (6).
[26] 42 U.S.C. § 1320b-19(f)(4).
[27] 42 U.S.C. § 1320b-19(d)(5).
[28] Pub. L. No. 106-170, § 101(d)(4), 113 Stat. 1860, 1875-76
(codified at 42 U.S.C § 1320b-19 note).
[29] SSA's contracts for the Ticket program manager and beneficiary
outreach manager are for 5 years. During the course of our review, at
the beginning of fiscal year 2011, SSA awarded new contracts for both
and shifted some of the roles and responsibilities. Under the new
contracts, the Ticket program manager is responsible for EN
recruitment, which previously was a responsibility of the beneficiary
outreach manager.
[30] SSA contracts with Mathematica Policy Research, Inc. for
evaluations of the Ticket program.
[31] ENs held 9 percent and VRs held 91 percent of the tickets
assigned by beneficiaries. GAO, Social Security Administration: Better
Planning Could Make the Ticket Program More Effective, [hyperlink,
http://www.gao.gov/products/GAO-05-248] (Washington, D.C.: March 2005).
[32] Amendment to the Ticket to Work and Self-Sufficiency Program, 73
Fed. Reg. 29,324 (May 20, 2008).
[33] These payment amounts are for 2010.
[34] Some phase 1 payments to an EN are limited if the ticket holder
earned above the trial work level in the 18 months prior to ticket
assignment. 20 C.F.R. § 411.535(a)(1)(i) (2009).
[35] Known as Partnership Plus, the regulations allow an EN to accept
a ticket after a VR, using the cost-reimbursement system, closes its
case with the ticket holder. 20 C.F.R. § 411.585 (2009). An EN who
accepts a ticket holder after a VR achieves an employment outcome is
only eligible for phase 2 (milestone) and outcome payments, not phase
1 payments. 20 C.F.R. § 411.535(a)(1)(iii) (2009).
[36] Pub. L. No.106-170, § 2(a)(12), 113 Stat. 1860, 1863.
[37] CBO, Pay-As-You-Go Estimate: H.R. 1180 Ticket to Work and Work
Incentives Improvement Act of 1999, (Washington, D.C., Dec. 13, 1999).
The CBO estimated the Ticket program would reduce annual outlays by $7
million, $27 million, and $60 million in fiscal years 2004, 2005, and
2006 and $110 million in fiscal year 2009.
[38] SSA Office of the Inspector General, Ticket to Work and Self-
Sufficiency Program Cost Effectiveness, A-02-07-17048 Audit Report,
(Washington, D.C., August 2008).
[39] These figures are based on SSA data from calendar year 2002
through calendar year 2006.
[40] Craig Thornton, Work Activity and Use of Employment Supports
Under the Original Ticket to Work Regulations. Can the Ticket to Work
Program Be Self-Financing? Mathematica Policy Research, forthcoming.
[41] Mathematica's draft report estimated SSA spent approximately
$34.1 million in fiscal year 2008 to run the Ticket program, including
costs of contracts SSA issued to organizations that operate key Ticket
program components.
[42] Memorandum from the Office of the Chief Actuary, "Estimates of
the Short-Range Effects on OASDI Benefit Payments and Federal SSI
Payments of Changes Specified in a Proposed Final Rule for the Ticket
to Work Program," Feb. 4, 2008.
[43] Overall ticket holder participation, including tickets used with
VRs participating in the cost-reimbursement system or assigned to ENs,
increased from about 266,000 in fiscal year 2007 to more than 318,000
in July 2010. Our review was generally limited to ENs and VRs paid as
ENs, and did not focus on VRs paid through the cost-reimbursement
system.
[44] All numbers referring to eligible ticket holders are as of the
last day of the fiscal year.
[45] As of July 2010, 2.6 percent of eligible ticket holders used
their tickets with VRs participating in the cost-reimbursement system
or assigned their tickets to ENs, an increase from 2.1 percent in
fiscal year 2004.
[46] While SSI beneficiaries experience a gradual reduction in
benefits based on how much they earn above SGA, DI beneficiaries,
following their trial work period, experience what is referred to as a
"cash cliff" in which they lose all benefits in a given month upon
reaching SGA. One EN Representative said this creates an incentive for
DI beneficiaries enrolled in the Ticket program to find work with
wages below SGA. 20 C.F.R. § 404.1592(a) (2009).
[47] The law provided for the establishment of a work incentives
planning and assistance program to disseminate accurate information to
disabled beneficiaries on work incentives programs and issues related
to such programs. Pub. L. No. 106-170, § 121, 113 Stat. 1860, 1887-90
(codified as amended at 42 U.S.C. § 1320b-20). However, one EN
Representative told us this assistance is not always timely and
referring ticket holders to these services may mean the EN loses a
potential client.
[48] Pub. L. No. 106-170, § 101(d)(4), 113 Stat. 1869, 1875-76
(codifed at 42 U.S.C. § 1320b-19 note).
[49] Craig Thornton, Work Activity and Use of Employment Supports
Under the Original Ticket to Work Regulations. Can the Ticket to Work
Program Be Self-Financing? Mathematica Policy Research (forthcoming).
Mathematica has prepared more recent studies for SSA on beneficiaries
leaving the rolls for work prior to the 2008 changes, but these were
not finalized at the time of our audit work.
[50] Ibid.
[51] In fiscal year 2004 (the first year all 50 states participated in
the Ticket program), 1,286 ENs had contracts.
[52] SSA officials told us they also use a "secret shopper" effort to
test whether ENs are knowledgeable and courteous when interacting with
potential clients. They refer ENs with problems to the program manager
for follow-up action. SSA officials told us the contracts of ENs that
do not respond to the program manager or that are no longer interested
in providing services are terminated.
[53] Fiscal year 2009 was the most recent year for which we had
complete data.
[54] Upon reviewing our draft report, SSA officials told us they plan
to implement contract changes requiring ENs to conduct a career
counseling and guidance session with ticket holders to make this type
of assessment before accepting the ticket assignment.
[55] Of the 25 ENs included in our review, 6 were VR agencies that use
the EN payment system rather than the VR reimbursement system.
[56] Through supported employment, ticket holders with the most severe
disabilities are placed in competitive jobs with qualified job coaches
or trainers to provide individualized ongoing support.
[57] 34 C.F.R. § 361.56 (2009). The Partnership Plus option, created
in the 2008 program changes, allows ENs to provide follow-on services
to ticket holders served by VRs.
[58] The local area includes the EN's town, city, or county. One of
the 25 serves multiple counties.
[59] Some milestone payments may not be available to an EN if, during
the 18 months prior to the ticket holder assigning the ticket, the
ticket holder worked and had earnings equal to or above the trial work
level amount.
[60] Seventeen of the 25 ENs in our review reported providing some
form of financial assistance to ticket holders; however, while other
ENs provide financial assistance for ticket holders who are looking
for work, such as paying for transportation to a job interview or for
a job application fee, ENs who share payments do so only if the ticket
holder has earnings sufficient to generate a ticket payment to the EN
from SSA. Paying ticket holders is also a primary activity of ENs
using the shared payment approach, and these ENs also generally
reported providing larger amounts.
[61] Although our review was limited to those ENs receiving among the
largest payments in fiscal years 2007 and 2009, through our EN
interviews and background review of the EN directory, we identified
several other ENs using the shared payment approach.
[62] This refers to milestone payments. Under the outcome payment
method, DI ticket holders who have sufficient earnings to leave the
benefit rolls could receive up to about $19,200.
[63] According to a Representative from the third EN, it also provides
some ticket holders with benefit planning assistance, although we did
not independently verify the services ENs reported providing in our
interviews.
[64] 20 C.F.R. § 411.566 (2009). The revised regulations explicitly
permit ENs to use outcome or milestone payments to make payments to
ticket holders.
[65] After reviewing a draft of our report, agency officials told us
they directed the EN to remove this statement from its Web site, and
noted that under current regulations, an EN may only refer ticket
holders whose ticket assignments they hold to a VR if the EN has a
written agreement with the VR. After receiving the agency's comments,
we found this language was still on the EN's Web site as of April 13,
2011.
[66] The EN contract states ENs are expected to be accessible to
ticket holders by providing toll-free phone numbers. Additionally, SSA
officials told us they review ENs to ensure they answer or return
phone calls in a timely manner.
[67] According to one disability rights advocate, using up the value
of a ticket could be an issue for any ticket holder who wants to
switch ENs, regardless of the approach used by the EN (see the
sequence of payments available to ENs in appendix III).
[68] For example, one locally based EN using the direct employment
approach reported hiring ticket holders to work in businesses owned by
the EN, including a document destruction business and a packaging and
assembly business. Two national ENs using the staffing approach
reported matching ticket holders with work-from-home jobs through
arrangements with employers.
[69] A Representative of one additional EN using an employer-driven
approach reported plans to offer employers two-thirds of the ticket
payment for each ticket holder hired, but toward the end of our
review, this Representative told us these plans had changed and the EN
will offer employers assistance in applying for the Work Opportunity
Tax Credit, and not a portion of the ticket payment, because the tax
credit is sufficient to generate employer interest.
[70] By law, prospective employers generally may not inquire as to
whether a job applicant has a disability. 42 U.S.C. § 12112(d)(2)(A).
[71] Our review of annual periodic outcome reports was limited to
reports from 2007 to 2009, the most recent available. Aside from
providing Web links to job search tools, the EN provides only payments.
[72] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1].
[73] Under SSA's review process, payment technicians identify ENs that
meet two of the following criteria: (1) EN employs the ticket holder,
(2) EN has submitted multiple requests for phase 1 milestone 1
payments, and (3) amount of ticket holder earnings claimed in these
requests is less than the full trial work-level amount.
[74] Ticket holders who assign their tickets are generally required to
make timely progress toward self-supporting employment. 20 C.F.R. §
411.180 (2009). A ticket holder who does not meet the timely progress
requirements is no longer exempt from medical continuing disability
reviews. 20 C.F.R. § 411.210(a) (2009).
[75] A January 2005 SSA internal memo indicated that the program
manager would continue conducting the reviews but suspend adverse
actions resulting from the reviews. While multiple interviews with SSA
and program manager officials, as well as other documentation,
clarified that the timely progress reviews were, in fact, suspended
altogether, SSA officials were unable to provide us with information
to clarify when this occurred.
[76] According to SSA documents, the moratorium occurred as a result
of concerns by service providers that the timely progress requirements
did not allow sufficient time for ticket holders to prepare for work
and the work requirement was too early. Under the prior regulations,
timely progress requirements were based on earnings at or above the
SGA level and did not allow for education and training alternatives as
they do under the regulations finalized in 2008. 20 C.F.R. § 411.191
(2007). Specifically, under the old regulations, a ticket holder with
an assigned ticket had to show, by the 24-month review, "active
participation" in the program; by the 36-month review, earnings at SGA
for 3 of 12 months; by the 48-month review, earnings at SGA for 6 of
12 months; and by the 60-month review and each successive 12-month
review, earnings above SGA for 6 of 12 months and no cash benefits.
See appendix VI for the requirements under the 2008 regulatory changes.
[77] Amendments to the Ticket to Work and Self-Sufficiency Program, 73
Fed. Reg. 29,324, 29,341-43 (May 20, 2008).The regulatory changes in
2008 modified rather than eliminated the timely progress requirements.
According to SSA officials, eliminating the requirements was
considered too costly because it would have provided all ticket
holders assigning tickets with CDR exemption.
[78] Ticket holders are due for timely progress reviews at the end of
each 12-month period for which the ticket is assigned to an EN or VR,
or in use with a VR under the cost-reimbursement payment system.
[79] In December 2010, Representatives of the program manager reported
that 19,000 ticket holders were due for review in November 2010. After
reviewing a draft of our report, SSA officials told us the number of
reviews scheduled for the program manager to complete for November
2010 should reflect 12,900. However, we were unable to independently
verify the actual numbers due for review in November 2010 or the
number of mailings sent out by February 2011.
[80] SSA and Ticket program manager staff reported they anticipated
resuming timely progress reviews in September 2010. In preparation, in
September 2009 the Ticket program manager began sending ticket holders
advance notice they would be due for review in a year. During the
course of our review, the Ticket program manager developed Web-based
training for ENs and VRs on timely progress requirements and reviews.
[81] According to Ticket program manager Representatives, the
automated earnings check will check wage data from the U.S. Department
of Health and Human Services' Office of Child Support Enforcement to
identify ticket holders with earnings sufficient to meet timely
progress.
[82] SSA and Ticket program manager business procedures for timely
progress state they will contact the ticket holder first. If the
ticket holder does not respond within 45 days, the program manager
sends a request to the EN asking it to certify whether the ticket
holder met timely progress.
[83] GAO, Supplemental Security Income: SSA Could Enhance Its Ability
to Detect Residency Violations, [hyperlink,
http://www.gao.gov/products/GAO-03-724] (Washington, D.C.: July 29,
2003) and GAO, Benefit and Loan Programs: Improved Data Sharing Could
Enhance Program Integrity, [hyperlink,
http://www.gao.gov/products/GAO/HEHA-00-119] (Washington, D.C.: Sept.
13, 2000).
[84] 42 U.S.C. § 1320b-19(d)(5) and (6).
[85] GAO, Internal Control Standards: Internal Control Management and
Evaluation Tool, [hyperlink, http://www.gao.gov/products/GAO-01-1008G]
(Washington, D.C.: August 2001).
[86] SSA officials told us they do not use the contract extension as
an opportunity to reassess performance and qualifications. For a
contract to be extended, according to SSA officials, the EN must
primarily show that their insurance is up to date.
[87] SSA officials told us that changes to the Ticket program manager
contract, made during our review, will help clarify performance
expectations for ENs because the program manager will be held to goals
for increasing the number of ENs that take ticket assignments, and the
percentage of their ticket holders working at a level that qualifies
the EN for ticket payment. However, these goals do not assess EN
performance in helping ticket holders retain employment and reduce
dependence on benefits, and do not directly hold ENs accountable for
performance.
[88] 42 U.S.C. § 1320b-19(f)(4).
[89] 42 U.S.C. § 1320b-19(d)(6).
[90] Since before the 2008 changes to the program regulations, SSA
provided EN applicants with the alternative of demonstrating other
qualifications if the applicant did not have a state license,
certification, or accreditation; however, in May 2009, SSA
specifically required that this alternative documentation include a
qualifications statement and business plan, and outlined the specific
elements the business plan must include. See table 2 for RFP proof of
qualifications requirements.
[91] Under the new regulations, an EN was eligible for the phase 1
milestone 1 payment of $1275 (for 2010) when a ticket holder earned
half of the trial work level ($360 for 2010) in 1 month. Through a
beneficiary complaint and further investigation, SSA officials
reported they found some ENs were only requesting phase 1 milestone 1
payments, and found they were hiring ticket holders directly just long
enough to qualify for this payment. In addition to modifying the
requirements for this payment and establishing a review of payment
requests, SSA also modified the RFP to require EN applicants to
disclose in their business plans the nature of any direct employment
they intended to provide ticket holders.
[92] As part of this review, we did not assess whether these
applicants should have been approved, but whether potential criteria
informally used by SSA staff to make approval decisions, in the
absence of specific written criteria, were applied consistently.
[93] From the Consortium for Citizens with Disabilities, we
interviewed Representatives of the Employment and Training Task Force.
The task force members we spoke with represented several different
organizations, including the Inter-National Association of Business,
Industry & Rehabilitation; National Disability Rights Network;
National Down Syndrome Congress; and Paralyzed Veterans of America.
[94] The Ticket law authorizes SSA to award grants to state protection
and advocacy systems to provide information and advice about how to
obtain vocational rehabilitation, employment, advocacy, or other
services that DI or SSI beneficiaries may need to secure or regain
gainful employment. 42 U.S.C. § 1320b-21.
[95] Work Incentives Planning and Assistance projects provide benefit
planning and assistance services to DI and SSI beneficiaries with
disabilities through SSA grants.
[96] The scope of our data analysis was generally limited to ENs and
VRs paid as ENs, although we examined data changes in ticket holders'
use of VRs paid through the traditional cost-reimbursement system over
time to provide additional context on ticket holder participation.
[97] SSA began mailing tickets to eligible beneficiaries in February
2002, starting with 13 states and expanded the program to all 50
states by September 2004.
[98] We included in our count of ticket assignments tickets assigned
at any point during the fiscal year.
[99] To provide a count of ENs with contracts and assigned tickets
within each fiscal year, we included ENs with contracts and tickets
assigned at any point during the fiscal year.
[100] VRs can choose between the EN payment system or they may select
the traditional cost-reimbursement method of payment under SSA's
Vocational Rehabilitation Reimbursement Program. 42 U.S.C. § 1320b-
19(c)(1). Under this program, SSA has reimbursed VRs since 1981
(before the Ticket program was established) for the costs of providing
services to beneficiaries with disabilities when the beneficiary has
sufficient earnings for a continuous 9-month time period.
[101] This includes VRs opting for the EN payment system, rather than
the VR cost-reimbursement system.
[102] There was significant overlap in the ENs among those with the
largest payments in fiscal years 2007 and 2009: 13 ENs were amongst
those with the largest payments in both years. Additionally, 2 of the
ENs among those with the largest payments in fiscal year 2007 merged,
so we did not conduct separate interviews for these ENs.
[103] The share of total payments SSA provided to the 20 ENs accounted
for 72 percent and 71 percent of total SSA payments to all ENs in
fiscal years 2007 and 2009, respectively.
[104] We identified service approaches based on our review of case
files, EN Web sites, and disability employment literature, as well as
through interviews with Representatives of disability rights advocacy
organizations and SSA. We validated these service approaches through
interviews with the 25 ENs.
[105] We did not independently verify services ENs reported providing
in our interviews.
[106] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]
(Washington, D.C.: November 1999).
[End of section]
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