September 12, 2001


The Honorable Joanne Wilson
Commissioner
Rehabilitation Services Administration
400 Maryland Avenue SW
Washington, DC 20202

Dear Commissioner Wilson:

The New York State Rehabilitation Council (SRC) is sending this letter to urge you to implore the Office of Management and Budget and the Social Security Administration's leadership to establish up front funding and a measured implementation process for the issuance of Tickets to Work.

	The role of our 40 person Council is to advise and work with our State vocational rehabilitation (VR) agency - the New York State Education Department's Office of Vocational and Educational Services for Individuals with Disabilities (VESID).  In that role we believe we have a responsibility to call on you to act to protect the great promise that Ticket to Work holds for people with disabilities.

	To be candid and to the point, this Council believes that the lack of front end funding and the planned four-month mail out of 600,000 Tickets to beneficiaries in our state will result in at least 24,000 new cases, very few new Employment Networks (EN) and no financial capacity to initiate services.  The lack of front end funding and the four month roll out of tickets would overwhelm VESID and we suspect other state VR agencies.  VESID does not have funding, counselors, and other resources in place to provide quality vocational rehabilitation services to such a large number of new consumers.  The consequence could be an order of selection that displaces thousands of people with disabilities who would otherwise receive Vocational Rehabilitation services. 
	
	This Council believes that the establishment by the SSA of up-front funding for the Ticket program is critical to provide adequate incentive for capacity building.  It will allow the establishment of Employment Networks that represent choice for people and it will enable Employment Networks and VR agencies to initiate services for those people.

	This Council believes that the mailing of these Tickets over an 18-month rather than a four-month period is vital to the overall success of the program.  This approach will provide necessary time for ENs and VR agencies to handle the caseload, to insure responsiveness and quality in service, and for benefits advisors to address peoples' questions.

As head of the federal agency with responsibility for effective implementation of the Rehabilitation Act we ask that you take advantage of your opportunity to comment on the proposed final regulations and strongly urge that up-front funding and the Ticket roll out schedule be addressed so that Ticket to Work does not have the unintended consequence of displacing other people with disabilities from VR services.  Ticket to Work should not become a Ticket to Wait.

						Sincerely,




						Terence J. Moakley
						Chair


cc:	Lawrence Gloeckler
	Ronald Calhoun
	SRC Members




State Rehabilitation Council



Council Goal:	  Raise the Employment Rate of People with Disabilities to a
	Rate that is Equal to the Rate of People without Disabilities