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The New and Improved Ticket Program What CWICs Need to Know NOW!. Virginia Commonwealth University WIPA NTC August 2008. So, why all the changes?. The improvements in the Ticket Program were specifically designed to accomplish one main objective:
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The New and Improved Ticket ProgramWhat CWICs Need to Know NOW! Virginia Commonwealth University WIPA NTC August 2008
So, why all the changes? The improvements in the Ticket Program were specifically designed to accomplish one main objective: Increase the likelihood that beneficiaries of the SSA disability programs will become employed at a substantial level and decrease dependence on disability benefits!
How will the improvements increase employment? By….. • Increasing the number of Employment Networks (ENs) available to serve beneficiaries • Increasing the number of beneficiaries who either assign their Tickets to an EN or receive services from state VR agencies under the cost reimbursement option (or both). • Increasing the number of Tickets accepted by ENs
Key EN Payment-Related Changes to the Ticket Program • New milestone payment schedule for ENs allows for incremental payments prior to a beneficiary achieving SGA • New payment schedule comparable for serving a beneficiary receiving SSI or title II disability benefits (SSDI, CDB, DWB) • Milestone payments to ENs are based on GROSS earnings instead of countable earnings, which eliminates previous penalty for using work incentives • Simplification of how earnings are verified for EN payments
Other Key Changes to the Ticket Program • Beneficiaries may use state VR services under cost reimbursement without assigning the Ticket, while still getting the medical CDR protections • Beneficiaries designated as “Medical Improvement Expected” (MIE) now get Tickets immediately without having to wait till after the first medical review
More key changes…. • Using a Ticket for purposes of retaining CDR protection may now include completing a range of different educational programs • Progress review periods are all 12 months in duration with incremental increases in work or educational requirements for each period
Where do WIPAs fit into the new and improved Ticket initiative? • WIPAs are all about promoting WORK – so is the Ticket! WIPA services are critically important for educating beneficiaries about how to use the Ticket and other work incentives to achieve their employment goals • As a work incentive, the Ticket offers valuable advantages to those beneficiaries for whom it is applicable • Like all work incentives, it will not help ALL beneficiaries!
CWIC obligations to beneficiaries under the Ticket Program include… 1. Screening all beneficiaries to identify Ticket eligible individuals who would most benefit from Ticket assignment and who would make strong candidates for Ticket use and/or assignment. 2. Explaining how the Ticket Program functions and what benefits individuals receive from using their Ticket. 3. Encouraging beneficiaries who are strong Ticket candidates and would benefit from the Ticket Program to consider Ticket assignment.
CWIC obligations to beneficiaries continued 4. Counseling beneficiaries on Ticket assignment by providing information about ENs in the area and helping the beneficiaries select an EN which best matches the individual’s service or support needs and preferences. 5. Having “firewall” procedures in place which prevent a conflict of interest when WIPA services are provided by an agency that also serves as an Employment Network. 6. Counseling beneficiaries on what constitutes “timely progress” for each 12-month review period in the Ticket program.
Obligations to beneficiaries continued 7. Having current and complete knowledge of all ENs serving the WIPA project catchment area and which of those ENs are currently accepting Tickets. 8. Knowing what services the various ENs provide, what participant eligibility requirements are and any restrictions on services or eligibility. 9. Referring beneficiaries to ENs based on individual service or support needs and preferences.
CWIC obligations to ENs under the Ticket Program include… 1. Providing information to ENs about the WIPA program, including: services provided, limits on services, eligibility requirements, and characteristics of a high priority WIPA referral. 2. Providing individualized work incentives planning and assistance to beneficiaries with Tickets assigned to local ENs. 3. Assisting ENs to use BPQYs, Benefits Summary & Analysis reports, and Work Incentive Plans to plan employment services and supports.
Obligations to ENs continued 4. Assisting ENs to understand how paid employment or self-employment affects a beneficiary’s SSA disability benefits, Medicaid/Medicare, and all other applicable federal, state and local benefit programs. 5. Helping ENs to understand when and how specific work incentives are applied to the SSA disability benefit programs to help beneficiaries achieve employment goals. 6. Working collaboratively with ENs to resolve problems beneficiaries experience while using a Ticket.
Obligations to ENs continued 7. Coordinating with ENs to insure that work incentives are properly applied, work CDRs are conducted in a timely fashion and cash benefits are adjusted or ceased appropriately. 8. Assisting with making Ticket assignment changes such as placing the Ticket in inactive status, un-assigning a Ticket, or re-assigning a Ticket. 9. Helping resolve any problems encountered with assigning or using a Ticket.
Limits on CWIC Role in the Ticket Program • CWICs should not provide training, technical assistance or other information on EN payment mechanisms under the Ticket to Work Program. ENs with questions about how services are paid for under the Ticket should be referred to Maximus. • CWICs are not required to provide intensive training on SSA work incentives to ENs or the State VR agency.
More Limits on CWIC Role • CWICs are not required to provide technical assistance to ENs on the affect of employment on SSA disability benefits or the application of work incentives, except when working collaboratively to serve specific beneficiaries who have assigned Tickets in use. • WIPA projects are not expected to provide vocational rehabilitation, career counseling, or job placement services of any type. CWICs should refer beneficiaries to the local agencies for these services as appropriate
New Eligibility Rules for Ticket • All SSI and Title II disability beneficiaries in cash payment status are eligible to receive a Ticket, except: • Beneficiaries who are under age 18 or who are full retirement age or older; • Childhood SSI beneficiaries who have attained age 18, but who have not had a redetermination under the adult disability standard.
Others NOT Eligible for a Ticket • Persons receiving payments under Section 301; • Persons receiving payments while appealing termination based on medical improvement; • Persons receiving provisional payments while waiting for an EXR determination; and • Persons getting presumptive disability payments.
What are the benefits of assigning and using a Ticket? • Enhanced access to services and supports from a broader array of ENs in addition to the state VR agency • Protection from medical CDRs while Ticket is assigned and in use, and the beneficiary is making “timely progress” • Protection from medical CDRs while accessing services from state VR agency using the cost reimbursement option, although Ticket is NOT considered to be “assigned”.
Definition of “Using a Ticket” • Using a Ticket means that a beneficiary has assigned a Ticket to an EN or state VR agency acting as an EN, or has a Ticket in VR cost reimbursement status, AND • the beneficiary is making timely progress toward self-supporting employment
When is a Ticket considered to be in use? • A Ticket is considered to be in use effective the day the Ticket is assigned to an EN or the state VR agency acting as an EN • If the beneficiary is receiving services from a state VR agency under the cost reimbursement option, the Ticket is considered to be “in use” for the purposes of CDR protection even though the value of the Ticket is not consumed and it is still available for assignment after the state VR agency closes the case. The date of the IPE marks the start of “in use” status in these cases.
The New & Improved Timely Progress Definition! • Complete the specified goals of work and earnings, or • Attain a GED in the first year, or • Complete the specified number of course requirements for a training program at an educational institution consisting of technical, trade, or vocational school, or • Complete the specified number of post secondary education credits at an educational institution in pursuit of a degree or certification.
Progress Certification Periods • SSA eliminated the initial 24-month period and replaced it with two 12 month progress certification periods. Subsequent certification periods are all 12 months long • Different levels of work, education or training are required in each of the different 12 month progress certification periods • Maximus will review progress at the end of each 12 month certification period to see if the applicable requirements were met and Ticket continues to be in use
New Rule - Variance Tolerance! • SSA considers the beneficiary to be making timely progress when the completed course hours or course requirements are within 10% of the specified goal. • In addition, SSA considers a beneficiary to have met the requirements of a 12-month period when the percentage of the educational or vocational training requirement completed and the percentage of the work requirement completed adds up to within 10% of the specified goal.
First 12 Month Progress Certification Period • Obtained a HS diploma or GED certificate. • Enrolled in 2 or 4-year degree or certification program and have completed 60% of full time course load for 1 year. • Enrolled in vocational/technical program and have completed 60% of full time course load for 1 year. • Worked at least 3 out of 12 months with gross earnings at TWP level or above.
Second 12 Month Progress Certification Period • Enrolled in vocational/technical program and have completed 75% of full time course load for 1 year. • Enrolled in 2 or 4-year degree or certification program and have completed 75% of full time course load for 1 year. • Worked at least 6 out of 12 months with gross earnings at TWP level or above.
Third 12 Month Progress Certification Period • Completed the technical, trade or vocational program. • Completed a 2-year degree or certification program, or for a 4-year program, completed an additional academic year of full time study. • Worked at least 9 out of 12 months with gross earnings at non-blind SGA level or above.
Fourth 12 Month Progress Certification Period • Enrolled in a 4-year degree program and have completed an additional academic year of full time study. • Must have worked at least 9 out of 12 months with gross earnings at non-blind SGA level or above.
Fifth 12 Month Progress Certification Period • Enrolled in a 4-year degree program and have either completed an additional academic year of full time study or completed the program and have earned a degree or certification. • Worked at least 6 out of 12 months with earnings that precludes payment of cash disability benefits.
Sixth and Subsequent 12 month Progress Certification Periods • Completed the 4-year degree program • Worked in at least 6 months within the 12 month period and have earnings in each of these 6 months sufficient to preclude Social Security disability and/or Federal SSI payments
What about beneficiaries who already had Tickets in assignment? • SSA will determine which 12-month progress certification period the beneficiary is in as of July 21, 2008 using the new rules in 411.226 (a)(1) (see next slide) • SSA will not conduct a progress review at the end of the progress certification period the beneficiary is in on July 21, 2008, but will conduct a progress review at the end of the next progress certification period • SSA will use the timely progress guidelines under the new Ticket rules beginning with the next 12-month progress certification period
More about Transitional Ticket Cases • SSA will determine the applicable 12-month progress certification period and the number of months remaining in that period as of July 21, 2008 by counting all months during which the beneficiary’s Ticket was assigned and in use during the period - • Beginning with the month following the month in which you first assigned your Ticket under the rules in effect prior to July 21, 2008; and • Ending with the close of June 2008.
What about people being served by VR under cost reimbursement? • If, on June 30, 2008, a beneficiary has a Ticket in use and assigned to a State VR agency which chose to be paid for services under the cost reimbursement payment system, the period of using a Ticket may continue. • While the Ticket may still be considered in-use for the purpose of the suspension of medical CDRs, it will no longer be considered assigned to that State VR agency effective July 21, 2008.
Temporary Moratorium on Timely Progress Requirements SSA has placed a moratorium on timely progress reviews through January 2010 and will revisit the issue in January, 2009 to decide whether initial notifications containing the new guidelines can go out to beneficiaries at that time in preparation for the reviews to start a year later.
Brief Review of Other Ticket Provisions and Rules Things that haven’t changed, or changed very little with the new regulations……
Determining Ticket Status • Ticket to Work Query provides general information about current Ticket status. This screen will show date when VR case work begins and ends when a VR cost reimbursement case is involved. The new indicators are “SVR In Use” or “SVR Not In Use” • General Ticket Query provides current Ticket information as well as more specific data such as the date the system selected the beneficiary’s record, the date the system mailed the Ticket, and the current status of the Ticket. This screen will have the same change as the Ticket to Work Query screen when a VR cost reimbursement case is involved.
Determining Ticket Status Continued • Ticket Status Range Query provides detailed historical record of Ticket activity by EN. • Ticket Use History (TKUH) query provides a complete historical record of Ticket activity for each beneficiary once the Ticket has been assigned or in use with a state VR agency. Under “In-Use” field, there will be new indicators “S” for “SVR In Use” or “R” for SVR Not In Use”.
Ticket and Work Incentives • SSA treats the earnings of a Ticket user in the exact same fashion as a non-user. There are NO special work incentives afforded to Ticket users, nor restrictions on using available work incentives • Using a Ticket does provide the beneficiary protection against the initiation of Medical CDRs • Work CDRs will continue and may result in termination of benefits
Ticket Limits • One Ticket is provided per period of entitlement to SSI or Social Security disability benefits. A new period of entitlement may result in a new Ticket being issued • A new Ticket may be issued if entitlement is terminated, but is later reinstated (EXR). • There are no limits on the total number of Tickets a person may receive.
Reassigning a Ticket • Beneficiaries may reassign their Ticket for any reason, at any time • Contact Maximus in writing to notify them of intent to reassign the Ticket • A 90-day extension period is provided to secure another provider (used to be 3-months under old rules) • Beneficiaries do not have to be in current cash benefit payment status to reassign their Tickets during the 90-day period. • The 12 month certification period now always resumes where it left off when the beneficiary reassigns to a new EN or the previous EN.
Extension Period • A 90-day period during which an “in use” Ticket may be unassigned for the purpose of reassignment • The Ticket is still considered "in use” • The Ticket may be assigned to either an EN or the state VR agency acting as an EN after this 90-day period • Beneficiaries may assign their Ticket during the 90-day period after their case is closed by the state VR agency when services are delivered under the cost-reimbursement option
Extension Period Continued • If the Ticket is not reassigned during the extension period, it is considered not in use after the close of the extension period. This means that medical CDRs may be initiated • The extension period doesn’t count in determining whether the beneficiary is making timely progress toward his/her work goals. • Beneficiaries may not assign their Ticket to more than 1 provider of services at a time.
Inactive Status • Beneficiaries may place their Ticket in inactive status if they are temporarily or indefinitely unable to make timely progress. • A written request to Maximus is required in order to place a Ticket in inactive status. • Months in inactive status don’t count in deciding whether the beneficiary is making timely progress during progress certification periods. • The Ticket is not in use during inactive status
CDR Protection for Ticket Users • SSA may not initiate a CDR while a beneficiary is “using a Ticket” • Under the new rules, this applies when a Ticket is assigned to an EN or the state VR agency acting as an EN, or when the beneficiary is receiving services from a state VR agency under the cost reimbursement option. • If a Ticket is assigned after a medical CDR is initiated, SSA will complete the review.
When is a CDR “Initiated”? • The CDR initiation date is the date on the notice sent to the beneficiary that informs him/her that SSA is beginning to review the disability case. For CDR mailers, the system displays the initiation date as the last day of the month the notice is sent. • The CDR initiation date is NOT the same thing as the diaried date since CDRs are rarely initiated on the exact diaried date.
The End of “Using a Ticket” Status • The last day of the month before the month in which the Ticket terminates • 60th month for which an outcome payment is due to an EN • Day before the effective date of a decision that the beneficiary no longer meets timely progress requirements • When the beneficiary fails to reassign the Ticket by the end of a 90-day extension period.
When a Ticket Terminates • Month in which entitlement for SSI or Title II disability benefits is terminated for reasons other than work activity (Note: suspension of SSI benefits/payments will not cause a Ticket to terminate), or • Month in which SSA makes a final determination not to reinstate benefits, or • For DWBs – the month in which the person attains full retirement age, or • For all SSI recipients – the month following the month the person turns 65, or
When a Ticket Terminates Continued • The month after the month in which the outcome payment period ends, or • The month the Ticket holder again becomes entitled to SSI or title II disability benefits or is awarded Expedited Reinstatement of benefits, or • The month the Ticket holder becomes entitled to a Social Security or SSI non-disability-based benefit, or • The month the Ticket holder dies.
It is time to actively embrace the Ticket to Work! • The Ticket to Work is one more valuable tool in the work incentives toolbox that CWICs can use to support a beneficiary’s employment efforts and goals • CWICs are responsible for learning to use this tool skillfully