The Ticket to Work and Work Incentive Advisory Panel of the Social
Security Administration (SSA) is holding a series of public meetings to
obtain public input across the country.  For groups working on employment
issues, this might be of benefit if you want to participate.

For more information on these events, please contact Conwal's meeting
coordinator at (703) 448-2300 and ask for Robin at extension 338,
[log in to unmask], or Rona at extension 326.

Kelly 


You are Cordially Invited by the Ticket to Work and Work Incentive Advisory
Panel TO GET INVOLVED

The Ticket to Work and Work Incentive Advisory Panel of the Social Security
Administration (SSA) is holding a series of public meetings to obtain public
input  across the country. The purpose of these meetings and teleconferences
is to collect ideas and reactions from all interested parties on the
proposed regulations the Social Security Administration issued on December
28, 2000.  These regulations spell out the program rules and the SSA
implementation plans for the new Ticket to Work and Work Incentive
Improvement Act programs.

The new “Ticket to Work and Self-Sufficiency Program'' is authorized by the
Ticket to Work and Work Incentives Improvement Act of 1999. The program will
provide SSA disabled beneficiaries with more choice in employment services,
vocational rehabilitation services, and other kinds of support services to
help them return to work.  The Ticket program will pay the new providers of
those services after a SSA beneficiary achieves a certain level of work.

The Panel is preparing a Report of Advice to the Commissioner of Social
Security Administration on the proposed regulations.  Your reactions to the
regulations that will affect the opportunities for Social Security
beneficiaries to go to work will help us frame our advice. We want to hear
from you in person, on the phone and by email. Even if we hear from you
briefly, a written version of your ideas will help us even more. Please
limit your oral comments to five minutes.

Please note that your comments to the Panel will NOT be considered as a
response to the SSA on the proposed regulations. The Panel strongly
encourages you to also make comments directly to the SSA in response to the
Notice of Proposed Rule Making. To be sure that your comments are
considered, SSA must receive them no later than February 26, 2001.

The Panel is interested in your response to a number of questions pertaining
to the proposed rule.  Please refer to the “Questions for the Public
regarding the NPRM” at the bottom of this notice.

For electronic information on the Ticket to Work and Work Incentives
Improvement Act see the www.ssa.gov/work web site and for a copy of the
Notice of Proposed Rule Making, look under the topic SSA at
www.access.gpo.goc/su-docs/fedreg/a001228c.html

For more information on these events, please contact Conwal, our meeting
coordinator at (703) 448 - 2300 ask for Robin at extension 338
[log in to unmask] or Rona at extension 326.


Date and Time   Event   Location
1/22/019:00 AM- 11:00 AM(Mountain Time) Northwest RegionalTeleconference
Call in 1-800-779-3141Pass code 12211
1/22/0112:00 PM - 2:00 PM(Mountain Time)        Regional Meeting        Hilton Salt Lake
City Center255 South West TempleSalt Lake City, UT801-328-2000
1/24/012:30 PM – 5:30 PM(Central Time)  Regional Meeting and Teleconference
Minnesota World Trade Conference Center, Presentation Room3rd Floor Tower30
E. 7th StreetSt. Paul, MNCall in 1-800-779-3141Pass code 12211
1/25/0110:30 AM –12:30 PM(Pacific Time) West Coast Teleconference       Call in
1-800-779-3141Pass code 12211
1/26/019:00 AM – 11:00 AM(Mountain Time)        Southwest Regional Teleconference
Call in 1-800-779-3141Pass code 12211
1/26/0112:00 PM – 2:00 PM(Mountain Time)        Regional Meeting        Pueblo Grand
Museum4619 East WashingtonPhoenix, AZ
1/29/019:00 AM – 11:00 AM12:00 PM – 2:00 PM(Eastern Time)       Regional Meeting
and Teleconference      Hyatt Regency265 Peachtree Street, NEAtlanta,
GA404-577-1234Call in 1-800-779-3141Pass code 12211
2/15/0110:30 AM – 12:30 PM(Pacific Time)        West Coast Teleconference       Call in
1-800-779-3141Pass code 12211
2/21/019:00 AM – 11:00 AM12:00 PM – 2:00 PM(Eastern Time)       Regional Meeting
and Teleconference      To be announcedCall in 1-800-779-3141Pass code 12211





THE TICKET TO WORK AND WORK INCENTIVES ADVISORY PANEL

QUESTIONS FOR THE PUBLIC ON THE PROPOSED RULES FOR
The Ticket to Work and Self-Sufficiency Program

On December 28, 2000, the U.S. Social Security Administration (SSA)
published a notice of proposed rule making (NPRM) in the Federal Register
for the Ticket to Work and Self-Sufficiency Program authorized by Public Law
106-170, the Ticket to Work and Work incentives Improvement Act of 1999.
The Ticket to Work program will provide beneficiaries with disabilities with
expanded access to employment services, vocational rehabilitation services
and other support services.

It is the duty of the Ticket to Work and Work Incentives Advisory Panel (the
Panel), also authorized by P.L. 106-170, to advise the President, the
Congress, and the Commissioner of Social Security on issues related to work
incentives programs, planning, and assistance for individuals with
disabilities.  The following questions to the public are posed by the Panel
to elicit input on the proposed rule.  The Panel will take the responses to
these questions into consideration when it develops its advice report.


TICKET AND EMPLOYMENT NETWORK QUESTIONS

1.      Which beneficiaries should get a ticket?  At what age should a
beneficiary receive a ticket?  A beneficiary is informed when Social
Security will perform a medical review (Continuing Disability Review or CDR)
to determine whether the person remains disabled when the person is first
awarded Social Security disability benefits.  This is part of what Social
Security calls a CDR “diary.”  If Social Security decides that a beneficiary
is expected to medically improve (Medical Improvement Expected or MIE) when
first awarded benefits, should the beneficiary be eligible for a Ticket?

2.      Consistent with language in the statute, if a beneficiary is currently a
client of the state VR, or applying for VR services, should the beneficiary
be able to deposit his/her ticket with a different provider, that is,
someone other that the state VR agency?

3.      How many tickets should a beneficiary receive?  The Ticket program makes
monthly payments to Employment Networks once a beneficiary earns enough
money to stop payment of monthly cash benefits.  A beneficiary could work
for many months and use up most of a Ticket’s value.  A provider would get
paid for services.  Then, a beneficiary could still return to the rolls
within the same period of disability.  Should this beneficiary be able to
get a second full value Ticket?

4.      What should happen with partially used Tickets? For example, a
beneficiary works fifty out of the sixty months in which outcome payments
can be made to a provider in his/her behalf, but then loses the job, remains
disabled and goes back on the rolls.  Should the ticket be reset back to
full value?  Or should that person’s Ticket only be valued at 10 more
remaining months of outcome payments to the Employment Network?"

5.      Who should be in an employment network?   Who should be in an employment
network providing services to Ticket holders (beneficiaries)?  Give us
examples of organizations or businesses that might provide more choice and
quality of services?  Should non-traditional support people be allowed to
contract as employment networks? ?  Should non-traditional support people be
allowed to be included as providers in an employment network?  Should a
beneficiary be allowed to be his/her own service provider?  Should
collectives of beneficiaries be in an employment network as group providers
to each other?  Should an employer be allowed to be a Ticket program
provider for employment outcomes in that company?

6.      The draft rules for ENs (Section 411.315 (c)) state:  "An entity (that
is, an employment network) must have applicable certificates, licenses, or
other credentials if such documentation is required by State law to provide
VR services, employment services or other support services in the State."
Do you agree or disagree with this level of certification? Please comment.

7.      What financial reporting would you see as needed by employment networks
to the Program Manager or Social Security?

8.      The Ticket “contract” is a two party signed voluntary contract between a
beneficiary and an employment network.  We want to know what measures to use
to ensure that employment networks are competent to deliver vocational
counseling, employment services and/or other supports.  Should staff of
Employment Networks have educational background or direct services
experience, including but not limited to vocational rehabilitation and
counseling, human relations, teaching or psychology?  Is this measure of
staff background the appropriate level of qualifications needed so that
employment networks provide quality services to Ticket holders?  What would
you require?  Please comment.

9.      The proposed regulations allow the Program Manager to assess whether a
beneficiary is making “timely progress towards self-supporting employment”
which will then keep Continuing Disability Review (CDR) protections in
place.  Should “timely progress” be measured by minimum standards for all
beneficiaries or should the terms and conditions specified in the IWP
determine timely progress?

10.     Should the State VR agency be allowed to use the Individual Plan for
Employment (IPE) as a substitute for the Individual Work Plan (IWP)?  If so,
should other individualized service delivery plans be acceptable
alternatives, provided they meet the minimum standards outlined in the
statute?


PAYMENT METHOD QUESTIONS

1.      How can the milestone payment system be structured to encourage providers
to serve eligible individuals including those who are harder to serve?

2.      One proposal is to pay milestone payments at three and seven months of
employment at SGA. Are three and seven-month milestone payments
reasonable/adequate? What payment amounts and timing of payments would allow
a wide array of SSI/SSDI beneficiaries to use the ticket as a means of
accessing employment and achieving self-sufficiency resulting in savings to
the Social Security trust fund?

3.      Should milestone/outcome payments be negotiated on an individualized
basis? If so, what administrative methods should be in place to ensure the
process is moving the individual towards self-sufficiency?  Is there a
danger of overpayment of milestone/outcome payments in such a milestone
system?  If so, what administrative mechanisms could be put in place to
minimize overpayments?

4.      How can we provide payment to providers without encouraging them to
target individuals who are easier to serve?

5.      The statute defines the harder-to-serve population in section1148
(h)(5)(c) as individuals with a need for ongoing support and services;
individuals with a need for high-cost accommodations; individuals who earn a
subminimum wage; and individuals who work and receive partial cash benefits.
How can we design an effective and fair milestone/outcome payment structure
that will provide information leading to permanent solutions for the issues
raised regarding individuals in these categories?

6.      The substantial gainful activity (SGA) level for blind beneficiaries
currently is $1240. Will ENs be discouraged from serving these beneficiaries
because of the higher SGA?  For beneficiaries receiving SSI, will ENs be
discouraged from serving these beneficiaries because they must reach a
higher level of earnings before reaching 0-cash benefits status?

7.      Should the individual work plan (IWP) include statements by the
beneficiary and the employment network acknowledging their responsibilities
and understanding of the employment goals to be achieved?  How should
beneficiary employment information be provided to the employment network?

8.      How should documentation of beneficiary earnings be provided by the EN to
the Program manager to validate payments due to the EN?

9.      One payment proposal sets the total potential payment under the
milestone/outcome payment structure at 85% of the outcome-only payment
structure. Is this percentage appropriate?  Should the 85% be something
different?  One of the reasons for milestone payments in the law is to
provide equitable and fair access by individuals who are harder to serve.
What payment structure would be fair and equitable?

10.     How should milestone payments be amortized or spread out during the
outcome-only payment period and over what period of time?  One proposal
suggests recovering paid milestones within the first year of outcome-only
payments.  Is this an appropriate timeframe?  If not, what would be
appropriate?

11.     Should ENs ever receive outcome and/or milestone payments for a
beneficiary who is still receiving benefits?

12.     Should a developed and signed commitment on the IWP by the beneficiary
and the EN be a milestone with a milestone payment made accordingly?  If so,
what should that payment be?


DISPUTE RESOLUTION QUESTIONS

Disputes between Beneficiaries and Employment Networks

1.      Should the regulations include timelines for: (1) Employment Networks’
(EN) grievance procedures; (2) appeals to the Program Manager (PM); and (3)
review by the Social Security Administration (SSA)?  If so, how much time
should allowed at each level of appeal or review and what should be the
total number of days, weeks or months allowed between the time a beneficiary
files a complaint and a final decision by the SSA?

2.      Should use of mediation services be included in the regulations as an
option available to beneficiaries and ENs?  If so, at what point(s) during
the dispute resolution process? - At any point? Before or after the internal
grievance procedure?  Before or after an appeal to the PM?  Before an appeal
to the SSA?

3.      Who should pay for the costs of mediation?

4.      Do the regulations sufficiently provide for beneficiaries to be informed
about the availability of assistance from the State Protection and Advocacy
(P&A) system?

5.      When and how should information about the P&A’s assistance be provided to
beneficiaries and by whom?

6.      Should assistance from the P&A system be available to beneficiaries at
any time and not just during the dispute resolution process?

7.      Should the State P&A be provided information, that is, formal
notification, about all disputes in which a beneficiary files a complaint
with the EN unless the beneficiary specifically indicates that this
information should not be provided to the P&A?

8.      In an appeal to the PM, should the PM be required to request and accept
information from both the EN and the beneficiary regarding a dispute?

9.      Should the regulations describe the SSA review process that is available
to the parties if a dispute is not resolved at the PM level?

10.     What other concerns about the dispute resolution process for
beneficiaries should the final regulations address that the proposed
regulations do not address?

Disputes between ENs or Service Providers and PMs

1.      In disputes that are not resolved at the PM level and are forwarded to
the SSA for review, should SSA be required to request and accept information
from all parties regarding a dispute?

2.      Should the regulations include timelines for SSA to respond to disputes
between ENs and the PM?  If so, how much time should be allotted from the
date the dispute is submitted in writing to SSA by either party?

3.      Should an EN be permitted to have assistance or representation, at their
own cost, during the dispute process?

4.      What other concerns about the dispute resolution process for ENs should
the final regulations address that the proposed regulations do not address?

5.      Should use of mediation services be included in the regulations as an
option available to beneficiaries and ENs?  If so, at what point(s) during
the dispute resolution process? - At any point? Before or after the internal
grievance procedure?  Before or after an appeal to the PM?  Before an appeal
to the SSA?

6.      Who should pay for the costs of mediation?


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