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The Social Security Cost Reimbursement Program:. Identifying its Full Potential for Your State Vocational Rehabilitation Agency. Introductions, Federal . Ken McGill , Moderator, Ticket to Work Operations Support Manager
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The Social Security Cost Reimbursement Program: Identifying its Full Potential for Your State Vocational Rehabilitation Agency
Introductions, Federal • Ken McGill, Moderator, Ticket to Work Operations Support Manager • Nate Arnold, Vocational Rehabilitation/Partnership Plus Lead, SSA Office of Employment Support Programs • Kathy Schriver, Senior Analyst, SSA office of Employment Support Programs Cost Reimbursement Webinar - Part 1: The Basics
Introductions, State Partners • Abygail Medina, Chief, Social Security Programs Section, California Department of Rehabilitation • Eugenia Cox, Ticket to Work Program Coordinator, Oregon Office of Vocational Rehabilitation Services • Ann Lynn Banton, SSA/Ticket to Work Coordinator, Virginia Department for the Blind and Vision Impaired Cost Reimbursement Webinar - Part 1: The Basics
History of Cost Reimbursement • In response to criticism of prior approaches, Congress created Cost Reimbursement (CR) in 1981 as an outcome-based plan for funding employment successes for SSDI and SSI beneficiaries • Previously SSA transferred funds to State VR Agencies (SVRAs) without requirement for employment outcomes Cost Reimbursement Webinar - Part 1: The Basics
History (continued) • SSA CR began slowly in the 80s, then grew in the 90s to a $100+ million per year program • In recent years, CRs have decreased---less than $80 million for FY 2011 • CR $$$ nationally have dropped almost 50% since 2008 Cost Reimbursement Webinar - Part 1: The Basics
Timeline • 1998—Last reauthorization of Rehab Act • 1999---Ticket Legislation • 2001---Ticket regulations (1st version)---payment under either CR or Ticket program---not both • 2002-2004---Ticket program implemented in three phases Cost Reimbursement Webinar - Part 1: The Basics
Timeline (continued) • 2008---Ticket regulations (2nd version)---SSA authorized to make payment under both CR and Ticket programs on same beneficiary • Also in 2008---In-Use SVR status created for beneficiaries served under CR Cost Reimbursement Webinar - Part 1: The Basics
Note re: Timeline • 2002-2008----VR Agencies used SSA-1365 form to report Ticket and CR cases • Since 2008 regulations, VR Agencies use SSA- 1365 for Ticket assignments, and electronic reporting for In-Use SVR cases for CR (* SSA has set a deadline of 04/01/2012 for all VR agencies to implement electronic reporting method for CR cases) Cost Reimbursement Webinar - Part 1: The Basics
Reasons for Decrease in CR • Impact of the Ticket to Work---some cases are now being paid for via Ticket assignments to VR---or are assigned to ENs • Difficult economic conditions for employment outcomes • State budget issues---reductions in staff and staff turnover • SSA reinforced the rules for “Timely Filing” requirement in 2010 Cost Reimbursement Webinar - Part 1: The Basics
Opportunity for Improvement • This training is intended to assist SVRAs who want to maximize the use of CR • For new staff, staff looking for “brush-up” of existing knowledge, and other technical/ supervisory staff involved in CR Cost Reimbursement Webinar - Part 1: The Basics
Goals for Webinar Series • Offer a series of new training sessions for VR staff who work on CR claims • Offer chance for discussion and clarification of CR processes and issues • Help VR agencies improve their utilization of CR to increase State revenues for successful employment outcomes • Support Partnership Plus---options for collaboration between SSA and SVRAs Cost Reimbursement Webinar - Part 1: The Basics
The Webinar Series • Part 1: Background and Basics of CR, Identification of Beneficiaries (Nov. 8) • Part 2: Processing CR Claims (Nov. 30) • Part 3: Submitting CR Claims (Dec. 6) • Also---A wrap-up teleconference for Questions and Answers (Dec. 15) Cost Reimbursement Webinar - Part 1: The Basics
The Cost Reimbursement Basics Cost Reimbursement Webinar - Part 1: The Basics
What is the Cost Reimbursement Program? • The program allows SSA to reimburse SVRAs when a beneficiary has achieved 9 continuous months of work with earnings above the Substantial Gainful Activity (SGA) level after applicable deductions Cost Reimbursement Webinar - Part 1: The Basics
Is the Claimant in Benefits Status? • For a case to be eligible for CR, the individual must receive Social Security Disability Insurance (SSDI) or Supplemental Security Income (SSI) benefits based on disability during the period of VR • Not necessary to be Ticket-eligible • SSDI beneficiary must be 18 years old to be eligible for reimbursement • SSI beneficiary must be 16 years old to be eligible for reimbursement Cost Reimbursement Webinar - Part 1: The Basics
What is SGA? • Substantial Gainful Activity (SGA) is a monthly amount of earnings meant to define substantial work • The specific SGA level for each year is determined by SSA • SSA’s website link: www.ssa.gov/pressoffice/factsheets/colafacts2012.htm Cost Reimbursement Webinar - Part 1: The Basics
SGA Levels • SGA level for 2010 and 2011: Non-blind---$1,000 per month Blind--- $1,640 per month • SGA level for 2012: Non-blind---$1010 per month Blind---$1690 per month Cost Reimbursement Webinar - Part 1: The Basics
What is Tolerance? • Tolerance is a dollar amount that is added to the SGA level to expedite the processing of claims • Tolerance takes into consideration any subsidies or impairment related work expenses (IRWE) that the beneficiary might have Cost Reimbursement Webinar - Part 1: The Basics
Tolerance (continued) • Therefore, if a CR case demonstrates beneficiary earnings at the level of SGA plus applicable tolerance level, SSA can pay the claim without further development with local field offices re subsidy and IRWE • If an individual is blind---$100 per month is added to the SGA level and for non-blind $200 per month is added to the SGA level Cost Reimbursement Webinar - Part 1: The Basics
Tolerance (continued) Sample calculation for 2011: • $1000 + $200 = $1200 (non-blind) • $1640 + $100 = $1740 (blind) Note: Tolerance is only used when benefits are not terminated. Cost Reimbursement Webinar - Part 1: The Basics
What is a Continuous Period of SGA? A continuous period of SGA is defined by SSA as 9 months of SGA-level work within a 12 month period. Cost Reimbursement Webinar - Part 1: The Basics
Timely Filing • For claims based on the beneficiary’s completion of a continuous period of SGA, a VR agency has 12 months after the 9th month of SGA to file the claim with SSA • For example, if the 9th month of SGA is October 2010, the claim must be submitted by October 2011 • The filing deadline may be waived if “good cause” for late filing is established (for example, loss of records due to storm damage or other unforeseen or uncontrollable circumstances) Cost Reimbursement Webinar - Part 1: The Basics
What is “Savings to the Trust Fund”? • The amount payable for a Cost Reimbursement claim may be limited in a small number of cases by a “savings to the trust fund” formula determined by SSA’s Actuaries. The formula is based on the beneficiary’s age, sex, current and future benefits • When the limit for an individual is reached, no further cost reimbursement may be paid Cost Reimbursement Webinar - Part 1: The Basics
State VR Agency Perspective • California Department of Rehabilitation • Oregon Office of Vocational Rehabilitation Services • Virginia Department for the Blind and Vision Impaired Cost Reimbursement Webinar - Part 1: The Basics
State VR Agency PerspectiveCalifornia Department of Rehabilitation • Avg. 900 claims/yr; Avg. 92% allowance rate • Electronic Claims Process on Successful Closures (Status 26) • Manual Claims process (ie. open, Sec .301) • Cost Reimbursement Tracker (J Morrow) • Self-Employment, Out-of-State, No UI match • BWE, IRWE, Subsidies Cost Reimbursement Webinar - Part 1: The Basics
State VR Agency PerspectiveCalifornia Department of Rehabilitation • Resources: • SSA/VR Regional Coordinator • OESP Claims Processing staff • State VR Agency Reimbursement Specialist • EN Portal (pilot) Cost Reimbursement Webinar - Part 1: The Basics
State VR Agency Perspective Oregon Office of Vocational Rehabilitation Services • Oregon--- mainly uses CR program with an average of 200 - 300 claims per year • Ticket assignments & payments only for shared clients with Mental Health Supported Employment agencies at this point • Two dedicated staff positions for Cost Reimbursement and Ticket programs Cost Reimbursement Webinar - Part 1: The Basics
State VR Agency Perspective Oregon Office of Vocational Rehabilitation Services • Tools----Oregon uses the Morrow Ticket Tracking system to produce both CR & Ticket payment claims (www.vocrehabtracker.com) • This system incorporates client case information, State UI wage data and SVES data to identify and produce a claim with all the required elements for submittal • Electronic data reports from MAXIMUS Cost Reimbursement Webinar - Part 1: The Basics
State VR Agency Perspective Oregon Office of Vocational Rehabilitation Services • SSA really wants state VR agencies to be successful • The Cost Reimbursement program can be operated differently within our individual states & programs, but remember that the rules are the same for everyone • Keep an open mind, question and clarify and remember that we all can learn new things from SSA, MAXIMUS and other State VR agencies • Working together as a team will make you and your programs successful • Never be afraid to ask for help or guidance Cost Reimbursement Webinar - Part 1: The Basics
State VR Agency Perspective Virginia Department for the Blind and Vision Impaired • Virginia Blind only uses the CR program at this time • There is only one dedicated staff position for the Cost Reimbursement and Ticket to Work programs • Virginia Blind uses the SVES – State Verification and Exchange System to track SSA entitlement periods Cost Reimbursement Webinar - Part 1: The Basics
State VR Agency Perspective Virginia Department for the Blind and Vision Impaired • Smaller agencies can do well with the CR program • Although smaller agencies may not have a large number of claims filed in a given year the amount received back for a CR most likely will be more for that one CR claim than several CR claims from a larger agency – So for CR – SIZE DOES NOT MATTER!! • Most importantly, if you are not clear as to whether an individual’s entitlement period falls within the VR period of the case, contact the SSA Provider Operations Team! • Making that phone call or sending that email may benefit in receipt of thousands of dollars for your State’s Vocational Rehabilitation Program!! Cost Reimbursement Webinar - Part 1: The Basics
Questions? Cost Reimbursement Webinar - Part 1: The Basics