New Ticket Program Rules Implement July 21!
More Teleconferences On the Way
SSA plans another useful teleconference to explain how the EN payment process will work under the new Ticket Program rules. The NENA Board will attend and ask questions, and we encourage all ENs to attend. Watch your email inbox for announcements by SSA. Also, NENA is develping a teleconference to describe models for the new partnership between State VR Agencies and ENs. Watch your email inbox for more information about that from NENA.
Advice to ENs
Congratulations to SSA for successfully adopting a new set of “regs” (regulations) for the Ticket to Work Program! As expected, the new regs improve revenue for providers and increase opportunities for consumers. Based on our recent conversations with experienced employment networks (ENs) and SSA staff, NENA offers advice in this bulletin.
The Good News The new regs will increase revenue to ENs in several ways:
• Part-time work is supported, Phase 1 Milestones can be paid when consumer earnings reach $670 per month, the Trial Work Period (TWP) threshold in 2008.
• ENs are paid sooner, Milestone 1 can be paid after $335 of earnings in a month or less
• Parity for SSI and SSDI consumers, both generate $1177 payments for each Phase 1 Milestone in 2008
• Easier to earn all four Phase 1 Milestone payments, because now you have longer (18 months) to meet an easier standard (only 9 months of employment at TWP levels)
• Higher total EN payments under new rules;
• All SSA disability beneficiaries (18-64) can assign tickets, “medical improvement expected” (MIEs) are no longer excluded, and they may have the best employment prospects;
• Partnership between State VR agencies and ENs is supported, opening new business opportunities for ENs in a larger market for services.
To review SSA’s materials about the new regulations, go to this link: http://www.ssa.gov/work/newregs.html
To look at SSA’s Q&A about the new regulations, go to this link:
http://www.ssa.gov/work/documents/SSA-63-035%20Q%20and%20A%20Regs.pdf
New Requirements
SSA has also included new requirements aimed at ensuring quality of services.
1. To earn timely payment of the 4th Phase 1 Milestone, ENs must document that they have “substantially” met the terms of their Individual Work Plan (IWP). This will be interpreted as providing at least half of the services and supports listed to be provided in the first 9 months, according to Dan O’Brien, the Acting Deputy Associate Commissioner of OESP at SSA.
If ENs don’t provide this documentation, yet the consumer’s earnings otherwise would qualify the EN for the 4th Phase 1 Milestone, the EN will not receive this payment until the consumer is out of “cash status,” into “outcome status” and generating monthly outcome payments. At this point, there’s a “reconciliation phase” where the EN may qualify for additional payments, including the delayed 4th Phase 1 Milestone.
This puts some risks on the EN. What if the Ticket consumer doesn’t keep working and never reaches outcome status? Then the 4th Phase 1 Milestone would NOT be paid, even if the consumer’s earnings otherwise would have qualified the EN for the payment.
To avoid this scenario, NENA has some advice:
A) Take your IWP seriously, it’s a legal contract for services.
B) Don’t “over-promise” in the IWP. Commit only to providing services that you or your partners can fulfill, and that are core to the consumer’s employment success and transition off benefits.
C) Divide the IWP into at least 2 timeframes, one for the first 9 months of qualifying employment at TWP earnings, and a second group for services provided after that.
D) In real-time while providing services, document services and time spent. Then send this documentation in with your payment request for the 4th Phase 1 Milestone. Also, you may need this documentation in case of a “split ticket” where the consumer unassigns their ticket from you and re-assigns to another EN or State VR Agency.
2) SSA added a “significant recent work activity” provision to avoid a scenario where providers earn large sums without providing any new services for consumers already working before assigning their ticket. If a consumer has not yet assigned their ticket, yet had earnings that would have qualified for any of the Phase 1 Milestones, then the EN may not qualify for those Milestones after the person assigns their ticket. On the effective date of the ticket assignment, if the consumer:
--earned $335 in the last month, the EN can’t earn the first Phase 1 Milestone and begins accumulating earnings toward the second Milestone;
--earned above the TWP level in 3 of the last 6 months, the EN can’t earn the first two Phase 1 Milestones, and begins accumulating earnings toward the third Milestone;
--earned above the TWP level in 6 of the last 12 months, the EN can’t earn the first three Phase 1 Milestones, and begins accumulating earnings toward the fourth Milestone;
--earned above the TWP level in 9 of the last 18 months, the EN can’t earn any of the Phase 1 Milestones, and begins accumulating earnings toward the first Phase 2 Milestone.
NENA’s advice on how to work with this requirement:
A) Remember this rule applies only to tickets assigned on or after Monday, July 21. If you know of any consumers who are interested in the Ticket Program and have “significant recent work activity,” then move quickly to develop an IWP and get their ticket assigned on or before Friday, July 18.
B) After July 21, don’t be afraid to accept tickets from people who have “significant recent work activity.” Although your EN will miss some of the Phase 1 Milestones, it’s also true that your organization will avoid the cost of providing the intensive services that usually occur during those Milestones.
Join NENA to get through your learning curve on these new “regs” as efficiently as possible. Only an association of-by-and-for ENs speaks your language, focuses on your precise concerns, and advocates for your needs with Social Security. NENA helps you succeed – individually and collectively – as ENs. Click here for the high-security NENA membership form.
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