DRAFT
TICKET TO WORK AND SELF SUFFICIENCY

CRITICAL IMPLEMENTATION ISSUES


 CRITICAL ISSUES:

A) Up front funding must be made available to attract Employment Networks and to initiate services for an influx of Ticket holders.

B) The Ticket roll out schedule for 2.3million current SSI and SSDI recipients must be extended from the proposed 4 months to 18 months to avoid system overload. 


The Ticket to Work and Self Sufficiency program is a cornerstone of the Ticket to Work and Work Incentives Improvement Act (TWWIIA).  The Ticket to Work program will enable SSI and SSDI recipients to secure vocational rehabilitation and support services from Employment Networks (EN) or state Vocational Rehabilitation (VR) agencies.  Coupled with the work incentive improvements of TWWIIA the Ticket holds the great promise of enabling thousands of people with severe disabilities to return to work and independence.  

FUNDING

The Social Security Administration (SSA) will issue 2.3 million Tickets to SSI and SSDI recipients in thirteen states in the first phase of Ticket implementation.   Under SSA's current plan this will occur over a period of four months beginning in late fall 2001.  

The SSA has designed three outcome based payment formulas to place the emphasis on results - people getting jobs and getting people off the Social Security rolls.  

The lack of front end funding to attract Employment Networks and to initiate services for thousands of current SSI and SSDI recipients is a fatal flaw in the design.

SSA's proposed design and implementation plan would put Tickets in the hands of 2.3 million recipients.  These people will be encouraged to take advantage of the improved work incentives and to use their Ticket to access vocational and support services.  If only 4% of the 2.3 million Ticket holders actively seek services that puts 92,000 new people in the market for services.  That represents an influx of new demand that is approximately two and one half times the average annual number of SSI and SSDI recipients who seek and receive vocational rehabilitation services.

The average cost per case of successfully serving this population prior to TWWIIA is approximately $10,000 (per SSA's reimbursement reports).  The average duration of services is 2.5 years.

Payment under the Ticket program design is for successful cases only and will be made only after a person is on the job.  Since the Ticket program offers no up front funding to initiate services and no funding for cases that fail to secure employment, few organizations are willing to become Employment Networks.  Maximus, the project manager for SSA, reports the lack of final regulations and lack of up front funding as the most commonly stated reasons given by potential ENs for their unwillingness to become ENs.  While seeking thousands of new employment networks, as of August 23, 2001, only 141 organizations have applied to become ENs.  None of these organizations is committed or obligated by their EN status to serve a single individual under the Ticket program.  State Vocational Rehabilitation agencies are however, obligated by the Rehabilitation Act, to serve all eligible individuals.  Once a disabled person has been awarded social security benefits it can reasonable be assumed that they meet the eligibility requirements of the Rehabilitation Act. 

Enabling Ticket holders to achieve and sustain employment at income levels sufficient to get off and remain off cash benefits (required for full payment under Ticket) is likely to be a costly and time consuming venture.  When coupled with no front end funding this will be entirely too risky an undertaking for most organizations that might otherwise become ENs.

The lack of ENs, insufficient numbers of ENs or the unwillingness of ENs to take on high-risk cases means that state VR agencies will be the only choice in many cases.  This means that a large number of Ticket holders will turn to state VR agencies.  While state VR agencies are required to serve all eligible people they are not in a financial position to take on the numbers that the Ticket will generate.  If two thirds of Ticket holders actively seeking service (61,333 people) turn to state VR agencies and the average cost per cases were $3600 the total new cost would be approximately $221,000,000.  With no front end funding to initiate these cases state VR agencies will be forced to implement an Order of Selection, required by the Rehabilitation Act.  Simply put, this means that when a state VR agency does not have sufficient funds to serve all eligible people it must create waiting lists.  The Ticket to Work would become a Ticket to Wait.

All the state VR agencies support the expansion of choice that is fundamental to Ticket and the use of outcome incentives in funding to promote results, not process.  However, you can neither create new choice nor produce results without some investment.  This is new demand that the Ticket is attempting to create.  It must be met with a reasonable investment to overcome inertia.  



RECOMMENDATION

We strongly recommend that the Congress put partial up front funding into the Ticket to Work program.






  
TICKET ROLL OUT SCHEDULE

A critical Ticket to Work issue is the duration of the planned roll out of the 2.3 million Tickets in the 13 states.  SSA has proposed to complete the issuance of 2.3 million Tickets in a period of four months.  We understand the desire to allow individuals access to the Ticket program in a timely manner and not delay implementation.  However, this access needs to be balanced against the current state of support available to an individual consumer seeking employment.  SSA would issue 230,000 Tickets in month one, 460,000 Tickets in month two, 690,000 Tickets in month three and 920,000 Tickets in month four.  This will generate hundreds of thousands of calls to Maximus, to benefits advisors, to ENs and to state VR agencies.  All the players have an obligation to the Ticket holders to make certain that they receive timely, thorough and accurate responses to their inquiries.  They will want information, they will need to meet with benefits planners, they will need to meet with ENs (perhaps more than one) and with state VR agencies to determine what services are available and then to develop a plan for service if they decide to assign their Ticket.   In many states, benefits planning will be a critical step in the consumer understanding the impact of work by exploring all of the work incentives available.  The system of benefit support, encompassing not just SSI and SSDI but also food stamps, HUD vouchers, and medical benefits can be extremely complicated for an individual.  All these steps require human resources, expert skill and knowledge, and time to ensure that Ticket holders understand their rights and responsibilities, the impact on benefits of using their Ticket and to ensure the quality of the counseling and service plans.

To roll out 2.3 million Tickets in four months is to ensure the necessary time and care can not be taken by ENs, benefits advisors or state VR agency personnel.  Here again, waiting lists would be created.  People who might otherwise use their Ticket will become disinterested or frustrated and opt out.  Worse yet, people are likely to get incomplete or inaccurate information or advice and either opt out or make decisions to proceed with plans that are not in their best interest.

An extended roll out of Tickets is essential to the success of this program.  



RECOMMENDATION

We recommend that the Social Security Administration employ a roll out schedule that allows at a minimum 12 month and preferably 18 months for completion.







September 5, 2001