The Social Security Administration released a Request for Information (RFI) to elicit ideas, strategies, and best practices related to improving adult economic outcomes for youth aged 14 to 25 with disabilities receiving Supplemental Security Income (SSI). Comments are due by February 2, 2018.
Youth receiving SSI confront challenges due to poor health, poverty, a lack of information to access the fragmented adult service system, and other barriers. Many youth face a lack of coordinated services, especially as they leave high school and their schools no longer provide youth support. SSA's redetermination of SSI eligibility at age 18 also generally results in 30-40 percent of youth losing SSI eligibility (and the accompanying automatic Medicaid access that most SSI recipients receive) because their condition does not meet the adult standard for disability.
The RFI includes 12 questions for respondents to consider when providing comments. The input SSA receives will inform its deliberations about potential policy changes and the design of future demonstration projects for transition-age SSI recipients.
The full RFI can be viewed and comments can be made directly through the regulations.gov website. A Federal Register notice is also available.
Docket number SSA-2017-00491. What specific programs or practices have shown promise at the Federal, State, or local level in improving the adult economic outcomes of youth with disabilities receiving SSI?
Benefits counseling in conjunction with employment experiences. Counseling services that include a review of changes to ALL public and private benefits based on age, secondary education participation, and employment.
2. Given the requirement of VR agencies to serve transition-age individuals, the availability of Individualized Education Programs (IEP) and Section 504 plans in school settings, and the availability of services and supports elsewhere available to youths, what should SSA's role be in assisting the transition of youths to adulthood?
Clearly defined guidance documents and web-based information designed for youth receiving benefits. Information needs to include how and when benefit reviews occur. Students who are approaching age 18 may benefit from a checklist that includes a timeline and documents required for redetermination.
3. How might SSA better support other agencies' youth transition-related activities?
Website access which allows customers to seek answers for benefit related questions and provides referrals to appropriate agencies for follow up supports. Increased communication between government agencies working with transition age youth. The need for specialized SSA reviewers who can work with transition age cases and provide definitive answers to youth and families.
a. What SSA policies interact with other agencies' services and supports?
Ticket to Work & OVR customer eligibility – Dept. of Corrections – Juvenile Justice, Dept. of Ed. – public, private, charter, and cyber schools, Dept. of Human Services – Children Youth and Families (foster care), Behavioral Health and Intellectual Disability Agencies
b. Do SSA's and other agencies' policies need to be modified (technically or administratively) to improve utilization of these services and supports? How?
More collaborative efforts are needed between agencies to improve communication and delivery of services.
4. Are there aspects of SSA's publications, mailings, and online information that SSA can improve to better support successful transitions to adulthood of youths receiving SSI?
Yes. The creation of a webpage for Transition-aged youth and their families that clearly and simply explains what happens at age 18 redeterminations is needed. Additional information concerning the use of disability reviews and the information that is required would also be helpful. The webpage should guide youth and families to benefits counselors in their respective states or to the state VR for assistance.
Brochures or one page guidance documents should be developed to present Frequently Asked Questions and address commonly held myths. The webpage for youth should identify how to obtain benefits with specific steps outlining the process with clear and concise steps that parents of all reading levels can understand. Links should be prominent and easy to follow.
5. How can SSA improve its existing work incentive policies, such as the Student Earned Income Exclusion (SEIE) and Impairment-Related Work Expenses (IRWE), to better support and increase SSI youth engagement in work? Are there alternative models that SSA should consider to replace existing work incentives?
Develop and allow for more specific work experiences and work trials for youth. Maintain medical benefits until the individual is fully independent and has at least a 12-month work history at a community integrated job with a salary above SGA.
WIOA has established VR requirements for wage follow-ups after the 90 days of customer employment. Workforce may be of assistance in tracking the progress of the youth in their employment as can the EN’s. SSA can track wages, but the local contacts could prove invaluable if an individual experiences a change in their health condition or loses the job due to no fault of their own. Perhaps extending the age of transition youth to 25 and requiring some sort of follow up as described above may be prudent.
6. How can SSA enhance and better target its existing service infrastructure including its Work Incentive Planning and Assistance (WIPA) program and Plan to Achieve Self Support (PASS), to increase SSI youth engagement in work and work activities?
Simplify it. Increase financial contributions to WIPAs so that more people can be reached. Expand their training opportunities (Cornell and VCU). Spaces fill quickly in both programs. Consideration of changes to the WIPA contract to stipulate the grant funds be based on State VR reimbursement and placement rates. Have the state VR’s manage the grant to the WIIPAs.
7. What lessons from SSA's youth demonstration projects, in particular the Youth Transition Demonstration (YTD) and the Promoting Readiness of Minors in SSI (PROMISE) project, should SSA apply to new policies and demonstrations? What partners were not included in those demonstrations that should have been? Why?
We are familiar with PROMISE and believe that all partners were identified. Due to differences between the states, each state would need to decide who would become primary and secondary partners. We would like to see a statewide website where transition age youth and their families could go to find information regarding the programs available and the rules / laws / eligibility requirements that are imposed. Another suggestion is to allow earnings from age 18-24 to be exempt from SSA wage earning rules so that the individual could build an ABLE account and have a support in place should they lose their job or choose to train for another or better job in the same field.
8. If SSA were to conduct a new demonstration project related to youth, which populations should SSA consider targeting, if any? How can SSA identify these populations? How many individuals enter these populations per year?
Address the 511 populations as they exit the workshops. What happens to those who do not get into competitive employment and are sitting at home? VR is addressing it with Section 511 programs. Other target populations could be those in the juvenile justice systems, behavioral and mental health population, foster care system, autism, those under 504 supports, those students with disabilities receiving education through alternative sources such as cyber schools, home schools, and private charter schools who do not receive Special Education funding.
9. Are there entities (for example, State VR agencies, medical practices, local education and training agencies, etc.) we could look to as exemplars based on current practices for serving youth with disabilities? What evidence exists to suggest these sites are effectively providing services that would lead to the increased self-sufficiency of youths with disabilities?
Project SEARCH has been in existence since the 1990’s and does have evidence based outcomes. PA-OVR has run multiple Innovation and Expansion projects and Pilot programs that have shown promise. PA-OVR Transition programs under WIOA have been up and running for at least 2 years and closure statistics are pending as students are being trained and participating in post-secondary education. Allow for Work based Learning Experiences (WBLE’s) for those above Transition age- 18 or above depending on when they leave school. Reimburse the state VR system for the cost of the WBLE’s.
10. In the absence of legislation renewing SSA's ability to refer Social Security Disability Insurance (SSDI) beneficiaries and SSI recipients directly to VR, how can SSA help connect youth to VR services?
SSA should have a separate website or section for Transition aged youth that would direct them to state VR services. It could be as simple as directing them to the website by providing a link. One suggestion may be to tie the WIPA programs to VR and have VR regulate the program. Monies from SSA would be based on the number of students and adults served. The monies would be supplied through grants based on reimbursement percentages or successful outcomes.
11. Should SSA expand the Ticket to Work (Ticket) program to include children or create a separate program for children with a similar mission (i.e., reimbursing service providers whose services result in increased employment and reduced need on cash benefits)?
Create a separate program
a. What services should such a program provide over and above the services youth with disabilities receiving SSI are already eligible for?
Benefits Counseling, WIPAs and AWICs specializing in Transition needs and community supports. Financial Literacy is one of the areas being developed by PA-OVR and some advocacy groups. Assist with monies for youth not eligible for PETS funding, i.e., those out of school.
b. What types of service providers should be allowed to participate in a youth Ticket program? Should such a program include all types of existing employment network providers or should it be limited organizations with existing providers that serve the broader youth population?
PA requires all those working with youth to obtain Child Clearance, FBI and State Police clearances. This certification also requires continuing education and is a requirement for many professional licenses at this point. EN’s should focus on employment and the adult population. Community based organizations, such as Centers for Independent Living would be best prepared to serve the needs of the students and families of youth with disabilities.
c. Is there a lower age limit the Ticket program (either the current program or a new child-specific program) should include that is consistent with other common Federal, State, and local policies that promote self-sufficiency?
Age 16
d. Since most children are in school, what outcomes or milestones should a program that included payments for child outcomes be tied to?
Remaining in school, obtaining passing grades, high school diploma or certificate, becoming a customer with the state VR agency, WBLE’s, job readiness programs, post-secondary exploration programs and post-secondary certificates, licenses and degrees. That way the state VR can monitor and prepare them for work or post-secondary education or individual efforts to enhance their earning potential by taking additional classes.
e. How effective are such incentive payments to service providers likely to be when serving youth? Are there alternatives to current incentive payment structures that SSA should consider (e.g., a payment structure based on state-wide youth employment or youth SSI participation metrics)?
Set up payment points similar to PA’s system for Project SEARCH. Reimburse VR for these activities as they occur.
f. How should the age-18 redetermination and the fact that over one-third of age-18 redeterminations result in the cessation of benefits because they do not have a condition that meets the adult standard for disability factor into such a program?
The 301 exemption standards seem to work well.
g. Are there specific populations among SSI youth, such as youth in foster care, that such a program should consider for allowable services, providers, and expenditures?
Juvenile Justice, Behavioral and Mental Health programs, ASD, those students attending non-traditional educational programs such as home school, private charter and cyber schools.
h. Would such a program be duplicative of the services provided by State VR agencies, which are already required to support the transition of youth with disabilities? Why or why not?
It would enhance the ability of State VR’s to reach these students and collaborate with SSA in attempts to secure competitive integrated employment at a living wage.
12. Since the implementation of WIOA, are there specific examples of effective services that are funded through the PROMISE grants but not funded through State VR agencies or other Federal and State funding sources?
In PA, a number of agencies provide the services listed. There needs to be a collaboration among these agencies to prevent duplication of services. There also needs to be expansion of some of the services so that all areas of the state have skilled providers who can assist with factors which influence the decision to enter competitive integrated employment. These factors could include family dynamics, medical concerns, advocacy, financial literacy, and employment opportunities. A one stop website that provides information and linkages to these service, as they relate to SSA, would be an excellent start. This would require significant collaboration and training, all of which could be led by PA-OVR. A project of this magnitude would require an increase in the OVR complement and funding to initiate the project, provide ongoing technical assistance, and ensure accurate outcome measurement.