[NYAPRS Enews] SOAR and Employment for SSI/SSDI Beneficiaries

[Harvey Rosenthal]

NYAPRS Note: Here’s some excellent employment related resources, especially as regards the impact of work on people who receive SSA benefits. The excerpts below omit a number of very valuable charts and personal examples that you can find when you view the report in its entirety at http://www.prainc.com/soar/cms-assets/documents/employment041013.pdf.

SSI/SSDI Outreach, Access and Recovery for people who are homeless
SOAR and Employment for SSI/SSDI Beneficiaries  February 2013
Jen Elder, MSc
http://www.prainc.com/soar/cms-assets/documents/employment041013.pdf

Excerpts by NYAPRS

Introduction
Individuals who are disabled and receive cash and other benefits through the Social Security Administration’s (SSA) Supplemental Security Income (SSI) and Social Security Disability Insurance (SSDI) programs are eligible for employment supports to assist them in obtaining and maintaining employment. When SSI/SSDI benefits begin, lifelong employment goals do not end. In the spirit of SSI/SSDI Outreach, Access and Recovery (SOAR) as a stepping stone to recovery, people who receive SSI/SSDI are encouraged to seek employment and employment services throughout the application process and after benefits are obtained.
This issue brief describes:
                Misconceptions about employment and loss of disability benefits
                How earned income from employment affects SSI/SSDI benefits and Medicare/Medicaid coverage
                Employment resources and work incentives offered by SSA to current SSI/SSDI beneficiaries who want to find work or return to work
                The role SOAR programs can play in connecting individuals to employment resources

Getting the Facts Straight
Misinformation about working and retaining SSI/SSDI benefits can reduce the likelihood a person will attempt to return to work by creating unnecessary fear that they will lose their hard-won benefits. A significant majority of individuals with disabilities want to work.1 Removing fears and barriers to employment can be a critical step in recovery.
1 Cook, J.A. (2007). Executive summary of findings from the Employment Intervention Demonstration Program. Chicago: University of Chicago, Center on Mental Health Services Research and Policy.

Myths and Facts about Working and Retaining SSI/SSDI Benefits
Myth #1: Benefits end immediately when you return to work.
Fact: Cash benefits do not end immediately. For how work affects SSI payments see pages 3-4, for SSDI see pages 4-6.
Myth #2: You can work only 20 hours per week while receiving disability.
Fact: There is no limit to the number of hours you can work while receiving disability.
Myth #3: Health insurance ends immediately when you return to work.
Fact: You can still be eligible for Medicaid and Medicare, see page 7.
Myth #4: If Social Security knows you are working they will say you aren’t disabled anymore.
Fact: SSA suspends Continuing Disability Reviews while beneficiaries are using Ticket to Work and making progress towards employment goals, see page 2-3.

Employment is about more than income. Additional benefits can include:
                An improved standard of living through increased income
                A defined role in the community
                Feelings of self-worth and self-confidence
                New friendships and connections to others
                Added structure to daily life
                Purpose, by offering a consistent framework of goals and expectations
                Reduced dependency on health and behavioral healthcare services

SSA provides numerous employment resources and incentives to support individuals as they begin or return to work.

SSA Employment Resources for SSI/SSDI Beneficiaries

SSA’s Ticket to Work Program
Ticket to Work (TTW) is a free, voluntary program designed to help beneficiaries maintain their benefits while exploring employment. Using TTW, beneficiaries receive specialized employment supports, including career counseling, training, and job placement, through community providers known as Employment Networks (EN) or State Vocational Rehabilitation (VR) agencies. Individuals become eligible for TTW when SSI/SSDI payments begin, and they can begin receiving assistance by contacting a local Work Incentives Planning and Assistance (WIPA) Project (listed on http://www.ssa.gov). WIPA projects are grant-funded by SSA to provide free access to information about work incentives and benefits planning, and they assist with referrals to appropriate EN and VR agencies based on individual needs.
Both EN and VR agencies work with individuals to assess their skills, interests, needs, and employment goals. Beneficiaries using the Ticket develop a collaborative plan with an EN or VR agency that describes their vocational goals and the support services needed to attain them. SSA encourages individuals to talk with multiple ENs to find the agency that is the best fit for them. Ticket users may reassign their Ticket at any time to another agency if they feel the EN or VR they are working with does not fully meet their needs.
Any organization providing employment services for individuals with disabilities can apply to SSA to become an EN. As an approved EN, organizations qualify to receive compensation for assisting SSI/SSDI beneficiaries achieve employment-related milestones and outcomes as they move toward self-supported work. The New York State Office of Mental Health created the first statewide EN as a way to further recovery and employment of people with mental illness in New York.

New York Employment Services System: A Model Statewide Employment Network
New York Employment Services System (NYESS), spearheaded by the New York State (NYS) Office of Mental Health, is the first statewide Employment Network in the United States. NYESS coordinates access to all employment services and supports offered in New York State, regardless of the state agency providing or funding such supports. They help individual job seekers assess their skills, assist with resume development, and match them with job opportunities through the NYS Job Bank, using the One- Stop Operating System, a web-based job matching, case management, and reporting system, maintained by NYS Department of Labor.
NYESS generates tax-claiming documentation for businesses that hire individuals with disabilities through the system, as well as Ticket to Work milestone payments received when individuals maintain employment. These efforts result in millions of dollars of incentive payments that can be reinvested to sustain and expand employment supports throughout the state for individuals with disabilities.
Former NYS Mental Health Commissioner Michael Hogan states, “For too long getting federal disability has led to a life in poverty, without work, and with excess use of health care services. We see an alternative where people can achieve a working life with increased income, fulfillment, and independence.” NYESS provides a model for effective statewide coordination of employment supports, allowing New Yorkers with disabilities the opportunity to work, pay taxes, and achieve economic self-sufficiency.
TTW participants have the additional benefit of exemption from Continuing Disability Reviews (CDRs) that SSA periodically conducts on all beneficiaries to determine whether they continue to meet disability criteria under SSA’s SSI/SSDI regulations. Participants do not have to undergo a CDR as long as they are receiving services from an EN or VR agency and making progress towards their employment goals.

SSA Work Incentives
Work Incentives are SSI/SSDI rules and regulations allowing beneficiaries to maintain their health care and cash benefits while working. Since SSI is based on need and SSDI is based on a person’s past earnings and what they have paid into the system, an increase in income from work is going to affect each benefit program differently. For SSI recipients, the amount of their SSI check can change from month to month depending on their earned and unearned income. SSDI recipients may or may not be eligible to continue receiving their SSDI check, depending on their level of earnings from work. There are no partial or reduced checks for SSDI due to earned income. Most of SSA’s work incentive programs apply to either SSI or SSDI, as illustrated in Table 1.


Work Incentives for SSI Beneficiaries Only

Income exclusions
SSA adjusts a person’s SSI benefit amount based on unearned and earned income they receive. Income exclusions and other adjustments for people who are returning to work help reduce countable income and maintain a higher benefit amount. SSA created a general exclusion for all SSI recipients, where the first $20 of earned or unearned income does not count against their SSI payment. Unearned income, such as Temporary Assistance for Needy Families, alimony, veterans benefits, or state assistance, is counted dollar for dollar against their SSI payment. For example, if someone receives $200 alimony each month, their check will be reduced by $180, as the first $20 is not counted and the remaining unearned income is counted dollar for dollar.
The second exclusion is for individuals whose only other income besides their SSI check comes from working. The earned income exclusion is $65. When SSI and earnings from employment are a person’s sole income, he or she is eligible for both exclusions, totaling $85 dollars. This means that the first $85 dollars the person earns per month does not affect his or her SSI payment amount. Note that these are 2013 exclusion amounts and although they have not changed for some time, they could change in the future.
After SSA subtracts the exclusions from the person’s earnings, they will count one dollar for every two dollars of gross earnings; that is, they will divide the remainder by two to determine countable income. Social Security determines the new monthly benefit by subtracting the amount of countable income from the current monthly benefit….
As an individual’s wages may vary each month, SSI checks may also vary. Figure 2 provides an example of an individual who has increased their hours of work and now earns $1503 per month. Using the 2013 Federal Benefit Rate, this individual would still receive an SSI check of $1 per month, is still eligible for Medicaid, has more than doubled their income, and also has all of the other benefits from working. With this variation in SSI checks due to wages, it is important that SSI beneficiaries report their earnings each month to SSA to ensure accurate payments and avoid overpayment of SSI benefits.

Plan to Achieve Self Support
Generally, a person receiving SSI cannot save much money, as anything over the resource limit of $2,000 (for individuals) results in loss of SSI eligibility. However, SSA’s Plan to Achieve Self-Support (PASS) allows an SSI recipient to save money for an educational or vocational goal in a separate account, which is not counted as a resource or countable income when determining their SSI payment. The PASS must be written and approved by SSA, and the goal must be reasonable to attain in three years. For example, a man working part-time as a line cook in a restaurant would like to attend culinary school to get a job as a chef at a local hotel. The tuition for culinary school is $3,000. With an approved PASS, savings to pay this tuition would not be counted as a resource and would not eliminate his SSI eligibility.

Work Incentives for SSDI Beneficiaries Only
Since SSDI is an insurance program, recipients are offered a trial work period to see whether they are able to return to work. There are no adjustments to the benefit amount during this time. If the person’s work attempt is successful over a period of time, their benefits are suspended. However, if they struggle to work enough to maintain substantial gainful activity (SGA), which is $1,040 per month in 2013, safety nets are in place that allow reinstatement of SSDI benefits.

Trial Work Period and Extended Period of Eligibility
The Trial Work Period (TWP) gives individuals the opportunity to go back to work, earn as much money as they are able, and preserve their cash benefit during that time. Social Security currently allows for nine months of trial work, which do not have to be consecutive, within a five-year period. Beneficiaries continue to receive their full benefit check during the TWP. A month of work does not count toward the TWP unless the individual’s earnings meet the TWP earnings threshold, which in 2013 is $750 per month. For example, if an individual goes to work and is earning $500 a month, which is below the trial work threshold, they will continue to receive their full benefits. However, if an individual goes back to work and earns $1200 a month, they are over the trial work threshold and those months will count toward their TWP.
Once an individual has worked at or above the TWP threshold for nine total months, SSA will evaluate the individual’s work and earnings to determine if they are earning above the SGA amount. This first month after the TWP marks the beginning of an Extended Period of Eligibility (EPE), a 36 month re-entitlement period, during which benefits can be reinstated without a new application. If an individual is earning SGA in this first month following the TWP, their SSDI benefits will stop after a three-month grace period. If an individual is not earning SGA, their benefits will continue as usual until they work a month above SGA. They would continue working and continue to receive their SSDI benefits. When this assessment is made, a person’s countable earnings can be reduced using two other work incentive programs discussed below. The Subsidy and the Impairment Related Work Expenses programs can reduce a person’s countable income. If reduced below SGA, they can continue receiving their SSDI benefits.
If a person’s benefits are stopped after their TWP due to earnings above SGA, they still have a safety net available to them. During the EPE, for any month when the person’s earnings fall below SGA, they will be eligible to receive their full SSDI check. This program can relieve concerns about not being able to maintain a job long-term or worries about what will happen if their condition worsens. If a person is unable to earn SGA through employment, they can report that to SSA, and they will be issued their SSDI check for that month. If an individual struggles to maintain SGA after the EPE, they will be eligible for another safety net, Expedited Reinstatement of Benefits, discussed below.

Subsidy
This program, for SSDI beneficiaries only, works by valuing the extra support received from an employer on the job. That support can come in the form of extra hours of supervision, time spent with a job coach or mentor, or a reduced workload. A worker who is subsidized is paid the same amount as other workers who are in the same job function. The Subsidy is not an amount of money that is given to the person from SSA, but rather is a value that is put on the support provided.
For example, Jane receives SSDI, and is working at a grocery store alongside her coworker Eric who does not have a disability. Jane and Eric are paid the same hourly rate, but Jane is expected to unpack only eight boxes, while Eric is expected to unpack ten. Jane’s employer is subsidizing her employment by allowing her to have a reduced workload but paying her the same wage as a full workload. Assuming the value of Jane’s subsidy is $200, if she earns $1,100 that month, SSA would count her earnings at $900. The Subsidy can be very useful throughout the EPE when SSA calculates whether a person is earning SGA. If earnings can be reduced below SGA with the application of a subsidy, as in the example above, benefit payments would continue.

Work Incentives for Both SSDI and SSI Beneficiaries
Impairment Related Work Expenses
Impairment related work expenses (IRWEs) are applicable to both SSI and SSDI beneficiaries, but they are applied at different times and in different ways. An IRWE is an out-of-pocket expense that enables the person to go to work. The expense must be related to the disability, such as medication co-pays, special equipment, and special transportation. An example of a work-related expense that is not an IRWE would be the company uniform, since all employees must buy the uniform and it is not related specifically to the person’s disability. Social Security does not reimburse beneficiaries for IRWEs, but rather reduces the calculated countable income. For SSI recipients, the IRWE is subtracted along with general and earned income exclusions to calculate countable income. For SSDI recipients, the IRWE is similar to the Subsidy and is subtracted from earnings during the EPE to determine whether the earnings met SGA.

Expedited Reinstatement of Benefits
Both SSI and SSDI recipients are able to apply for Expedited Reinstatement of Benefits (EXR) for five years after they lose eligibility for benefits based on earnings. This safety net allows an expedited return to payment and medical benefits, without a new disability application, for those who can no longer work above SGA. Social Security will review the request to determine if the disabling condition is the same as, or related to, the impairment in the original claim, and applicants can receive up to six months of provisional benefits while the decision is processed.

Beneficiaries Can Retain Health Insurance While Working
A common myth about returning to work is that beneficiaries will immediately lose their Medicaid or Medicare coverage. The health insurance benefit is often as valuable to an individual as the cash payments, so it is important to know what will happen to Medicaid and Medicare when a person goes to work.

Retaining Medicaid Eligibility
As noted earlier, receiving the minimum SSI check of $1 per month retains beneficiaries’ eligibility for Medicaid. In addition, Federal Rule 1619B continues Medicaid eligibility even if SSI payments stop due to earnings from work and those earnings are below a certain threshold. This earnings threshold is different in each state and varies widely. Please see http://www.ssa. gov/disabilityresearch/wi/1619b.htm for current amounts. As long as the individual’s earnings remain under that threshold and meet the other eligibility requirements for SSI, they can remain eligible for Medicaid. If an individual is earning over the 1619(b) threshold amount, they may still qualify for Medicaid if they have IRWEs, PASS, or their medical expenses are higher than the average Medicaid expenses in their state. If these factors apply, SSA can calculate an individualized 1619(b) threshold amount. Additionally, many states offer Medicaid buy-in programs, allowing individuals who earn over the 1619(b) threshold amount to pay premiums and retain their Medicaid. To find out more about these programs, contact your local or state Medicaid office (http:// www.medicaid.gov<http://www.medicaid.gov>).

Retaining Medicare Eligibility
SSDI beneficiaries are eligible for Medicare as long as they receive a benefit payment. If payments stop at the end of the TWP, their Medicare coverage will continue for 93 months after the last month of the TWP. After 93 months, Medicare can be purchased under certain conditions and Medicare Part A premiums would then apply.

How SOAR Programs Can Connect Individuals to Employment Resources
The challenge for front-line staff is to maintain hope that employment is possible and worth the effort. For people who may be fearful of losing benefits, knowledge of these supports and programs can encourage them to consider employment. To help cultivate hope, SOAR coordinators and organizations can:
                Talk about work frequently – before, during, and after the completion of the benefits application for SSI/SSDI. Income support goal-setting does not end when a person receives SSI/SSDI.
                Develop expertise around the Ticket to Work Program and work incentives offered by SSA, and give clear examples of how part-time, full-time, or occasional work will affect benefits.
                Print listings of current job openings, GED classes, other employment resources and services.
                Offer space and guidance for peer-led employment support groups, including resumé and work habit discussion groups.
                Research evidence-based practices, such as Supported Employment, through SAMHSA’s evidence-based practice toolkits (http://www. samhsa.gov).
                Provide transportation to job interviews and employment services and assist in finding appropriate job interview attire, uniforms, work boots, tools, safety equipment, etc.
                Identify and collaborate with potential employers and promote employment support services and other resources that assist people transitioning into the workforce.

Social Security Administration Resources
For comprehensive information on all of SSA’s employment programs and services, consult The Red Book, available at http://www.socialsecurity. gov/redbook.  You also may also visit http://www. socialsecurity.gov/work/ or call 1-800-772-1213 between 7:00 am and 7:00 p.m. Monday through Friday. For specific information on SSA’s disability benefits programs, visit http://www.socialsecurity.gov/disability.
Find your local office by going to the SSA office locator at http://www.socialsecurity.gov/locator. Print copies of SSA public information materials (including the Red Book) may be requested by faxing 410-965-2037 or downloading from www.ssa.gov<http://www.ssa.gov>.

For More Information
To learn more about SOAR in your state or to start SOAR in your community, contact the national SOAR technical assistance team at soar at prainc.com or check out the SOAR website at http://www.prainc.com/soar.
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