Frequently Asked Questions (FAQs)


Becoming an Employment Network (EN)

1. What qualifications must an applicant have to become an Employment Network (EN)?

An EN may be any public or private entity or consortium of organizations that is deemed qualified to provide or coordinate the provision of employment services, vocational rehabilitation services, and other support services to assist Social Security disability beneficiaries to find and maintain employment that leads to financial independence. The Social Security Administration approves organizations as ENs. To be approved to function as an EN, an organization must meet both general and specific qualifications that are spelled out in the EN Request for Application (RFA). General qualifications include a minimum of two years of experience providing employment, vocational rehabilitation and/or other support services to individuals with disabilities. This experience must be immediately prior to the date the organization is applying to become an EN. An organization that has three years of experience in the five years prior to applying can also qualify. The specific qualifications related to such experience would be demonstrated by having an applicable license or certificate if required by state law or, in the absence of a state requirement, either certification or accreditation from a national rehabilitation and employment services accrediting body or documentation of a contract or agreement with a Federal or state government agency or a grant from a public or private agency to provide employment, Vocational Rehabilitation (VR) and other support services to individuals with disabilities.

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2. How does an organization apply to become an EN?

Any organization considering applying to become an EN should read Part III, Section 1 (Qualification Requirements for ENs) of the RFA, which spells out all general and specific qualifications and how to submit proof of qualifications. The RFA is available on Social Security's Work Site at https://www.ssa.gov/work/enrfa.html. Assistance in completing the RFA can be obtained by contacting the Employment Network Service Team at Social Security by email at ENService@ssa.gov; toll free by phone at 866.584.5180 or 866.584.5181 (TDD); or by fax at 410.597.0429.

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3. Can organizations that receive funding from other sources, like a Medicaid Home and Community Based Waiver, be ENs? If so, are there any restrictions?

The Ticket to Work program (Ticket Program) is an outcome-based program. Social Security compensates ENs for milestones and outcomes that beneficiaries achieve after going to work and achieving designated levels of work and earnings. As a result, every EN must initially use funding from other sources to provide services to beneficiaries under the Ticket program. The sources of the funding an EN uses to provide these services has no bearing on the EN's ability to qualify for Ticket payments on behalf of beneficiaries who have assigned their Tickets to the EN. Many ENs receive funding from State VR agencies, State Medicaid agencies, mental health agencies, etc. Social Security does not view paying for outcomes achieved using other funding sources as double dipping.

Regardless of what the original source of funds used to serve beneficiaries is, it is always advisable for an EN to check with its funding source(s) to determine whether EN payments might affect its existing funding or if there are any restrictions on how EN payments may be used. In addition, two Federal agencies have issued guidance addressing how Ticket funding is viewed.

 

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Operating an EN

1. Will a beneficiary whose Vocational Rehabilitation case was closed within the past year receive a new ticket and be able to assign it to my EN?

The fact that a beneficiary received services from a State VR agency and his/her VR case was closed within the last year does not negate the remaining value of a beneficiary's Ticket. If the beneficiary was still receiving a monthly disability benefit at the time of the VR case closure, he/she may choose to assign the Ticket to an EN other than the VR agency. Even if a beneficiary's disability benefits ceased prior to VR closing the case, the beneficiary has a 90-day grace period, starting with the date of the VR case closure, during which he/she can assign his/her Ticket to an EN. After this 90-day period, the beneficiary's Ticket will terminate.

However, the fact that a beneficiary was previously served by a State VR agency is likely to impact the remaining value of the beneficiary's Ticket as described in the prior question about Ticket payments being available to ENs that secure Ticket assignments from beneficiaries who previously worked with a State VR agency.

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2. Can my EN refer a Ticket Holder to a State VR agency for services (such as a vocational evaluation) without losing the Ticket assignment?

An EN that holds a beneficiary's Ticket assignment may refer that beneficiary to a State VR agency for services as determined necessary and appropriate. However, if the EN wishes to keep the Ticket assignment, the EN and the State VR agency must have a written agreement that specifies the conditions under which the State VR agency will provide services. In some cases, this includes how the EN will compensate the State VR agency for the services it provides to the beneficiary. Such agreements must be in writing and signed by both the EN and the State VR agency before the EN can refer a beneficiary and keep the Ticket assignment. These agreements are required because the State VR agency will not be able to seek cost reimbursement (CR) for serving the beneficiary because the EN kept the Ticket assignment. These agreements also allow beneficiaries to maintain their relationships with their ENs while the beneficiaries receive services from State VR agencies, and it allows the VR agencies to receive a measure of compensation from the EN.

An alternative in these situations is for the EN to release the Ticket assignment prior to making the referral to the State VR agency, allow the VR agency to provide services as it would normally, and seek to regain the Ticket assignment when the VR agency closes the beneficiary's case. In these cases, the VR can proceed as normal to seek compensation under the traditional CR program or, if operating as an EN, under the Ticket program, until VR closes the case. If the beneficiary then chooses to reassign his/her Ticket to the EN, the EN could then seek payments under the Ticket program based on the beneficiary's qualifying earnings, whether or not the beneficiary was working at the time of VR case closure (Phase 1 Milestone exclusion based on prior VR history), and whether a split payment decision would be necessary (i.e., if the VR agency was serving the beneficiary as an EN).

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3. If my EN has a Ticket assignment and will be referring the Ticket Holder to the State VR agency for vocational services after some initial EN services have been performed, does the Ticket need to be unassigned in order for the VR agency to receive Cost Reimbursement for the services it performs? If so, what is the intent of the referral agreement between my EN and the State VR agency as stated in Section 12.9? Wouldn't the referral agreement be a mechanism for documenting sequential services instead of un-assigning the Ticket before VR services and then reassigning the ticket to my EN after the VR case is closed?

An EN that holds a beneficiary's Ticket assignment may refer the beneficiary to a State VR agency for services without the Ticket being un-assigned. However, to do this, the EN and State VR agency must have an agreement that specifies the conditions under which the State VR agency will provide services. The agreement must be in writing and signed by both parties before the EN may refer a Ticket Holder to the State VR agency. Ticket assignment will remain with the referring EN, who will compensate the State VR agency according to the terms of the agreement. Social Security will not pay Cost Reimbursement in this situation because the Ticket is assigned to an EN. The agreement allows the beneficiary and the EN to maintain their relationship while the beneficiary receives services from the State VR agency, and it allows the State VR agency to receive a measure of compensation from the EN.

As an alternative under the Partnership Plus option, provided that all steps are taken in consultation with the beneficiary, the current EN and the State VR agency, the beneficiary may un-assign the Ticket and place it in In-Use/SVR status for the period that the VR case is open, and re-assign it to the referring EN or a different EN after VR services are complete and the case is closed. Either option is allowable, provided that in the latter case, the beneficiary is consulted.

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4. How would an employer of people with disabilities who receive Supplemental Security Income (SSI) or Social Security Disability Insurance (SSDI) benefits serve as an EN and collect Milestone and Outcome payments for employees who are already working and are earning above the Substantial Gainful Activity (SGA) level?

An employer may collect Milestone and Outcome payments based on the same rules as a non-employer EN. If an employer that elected the Outcome/Milestone payment system accepts assignment of the Ticket of a beneficiary who is already an employee, Social Security will take into consideration work the beneficiary engaged in during the 18 months prior to Ticket assignment to determine which Phase 1 Milestone payments would be available to the employer (see FAQ regarding Recent Work Rule).

Only months when the beneficiary worked with earnings above the Trial Work Level are considered. In determining eligibility for Phase 1 Milestones, Social Security also considers whether a State VR agency served the beneficiary first. If a State VR agency served the beneficiary first and closed the case with the beneficiary in employment, the employer EN would not be eligible for any Phase 1 Milestones. Phase 2 Milestone payments and Outcome payments would be available to the employer EN as these beneficiary employees attained the designated levels of work and earnings to trigger these payments.

If the EN elects the Outcome payment system, there is no penalty for any work done during the 18 months prior to Ticket assignment or for the State VR agency serving the beneficiary first. Rather, the EN would be eligible to submit for Outcome payment beginning the first month after Ticket assignment that the beneficiary's net earnings exceed the SGA amount and that the beneficiary was placed in the zero cash benefit status.

 

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Payments

1. If my EN pays Ticket Holders for completing a job development or job search curriculum and the pay exceeds the minimum income requirement for Phase 1 Milestones, does that count as work and qualify by EN for Milestone payments?

Job development and job search training, paid or unpaid, does not meet the requirements for payment of Phase 1 milestones. Section 411.500 of the Ticket regulations states that "Phase 1 Milestones are based on the beneficiary achieving a level of earnings that reflects initial efforts at self-supporting employment." Updating job search skills does not constitute employment, as there is no employer-employee relationship wherein services of value are delivered in exchange for payment. The EN Request for Application (RFA) also address the issue of paid vocational training when it is provided by an employer EN or an employer's agent. Part III, Section 1, B, 2 of the RFA states: "Paid vocational training with no record of continued self-supporting employment does not meet the definition of a job for the purposes of this RFA."

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2. Do internships count as employment for the purposes of Milestone or Outcome payments?

If an internship is a "paid" position, the stipend or salary provided to the beneficiary would count towards the earnings requirement for payment of milestones and outcomes to an EN.

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3. Can my EN use Milestone or Outcome payments to make payments to a beneficiary? If so, will Social Security count the payment as income for the beneficiary? If yes, is it counted as earned or unearned income?

Yes, an EN may use milestone and/or outcome payments to make payments to a beneficiary under what is referred to in the EN Request for Application (RFA) as a "consumer-directed services" (CDS) business model. The expectation is that these support payments be used to purchase employment-related services that will assist the beneficiary in obtaining and retaining work and not as wage supplementation. Any payments an EN makes to a beneficiary will be treated as unearned income by Social Security, which could affect Supplemental Security Income (SSI) benefit eligibility. Payments to SSI recipients for other than allowable expenses may result in an overpayment of previously paid SSI benefits.

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4. Why is the potential number of Milestone payments different in Phase 2 for Supplemental Security Income (SSI) recipients (up to 18 payments) and Social Security Disability Insurance (SSDI) beneficiaries (up to 11 payments)? Why is the number of potential Outcome payments different for SSI recipients (up to 60 payments) and SSDI beneficiaries (up to 36 payments)?

The goal of the Ticket to Work program is to assist Social Security beneficiaries to achieve economic independence. Payments to ENs and State VR agencies acting as ENs under the Ticket program are based on a percentage of the average monthly savings to the Social Security Trust Fund (i.e., for Social Security Disability Insurance recipients) and to the General Revenue Fund (i.e., for Supplemental Security Income recipients) that is realized when a beneficiary has earnings that result in the reduction or elimination of cash benefits. Since the average monthly benefit for SSI recipients is significantly lower than the average monthly benefit for SSDI recipients, Social Security established a payment system that provided a larger number of Phase 1 Milestones and Outcome payments for SSI beneficiaries to minimize the difference in the total potential amount of Ticket payments for SSI versus SSDI recipients. The goal was to ensure that ENs would be willing to assist both SSI and SSDI beneficiaries to engage in employment. The overall effect was to reduce the difference in the total potential payments to less than $1,000.

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5. How soon must the beneficiary reach the earnings level that triggers payments?

The ability to begin working and/or increasing one's earnings will vary from beneficiary to beneficiary. Under the Ticket to Work program, there is no established timeframe in which a beneficiary must go to work and reach designated levels of earnings for the sake of participating in the program. However, after job placement there are established time frames for reaching the Trial Work Level earnings that will generate Phase 1 milestone payment to an EN. Beneficiaries are expected to meet required levels of work, earnings, education, and/or technical training each year to show they are making "timely progress" towards employment goals. Beneficiaries must meet timely progress guidelines in order to maintain protection from medical Continuing Disability Review (CDR). Although failing a Timely Progress Review (TPR) results in the removal of CDR protection, it does not impact a beneficiary's ability to participate in the Ticket program or an EN's ability to receive payment on behalf of a beneficiary who has qualifying earnings. Ticket eligibility and the ability of the EN with the beneficiary's Ticket assignment to receive payments is only impacted if the beneficiary goes through his/her next regularly scheduled TPR and is determined no longer eligible for disability benefits based on medical improvement. (Visit "Timely Progress Reviews" on the website or read Section 411.180 (c) of the Ticket program's regulations to learn more.)

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6. When does Social Security count earnings to determine whether an EN is entitled to a payment under the Ticket program? When they are earned or when they are actually paid?

Social Security uses earnings differently depending on whether the beneficiary is receiving SSDI, SSI, or both (i.e., a concurrent beneficiary). For SSDI or concurrent beneficiaries, Social Security uses earnings when they are earned, i.e., by the pay period, not the pay date. For SSI recipients, Social Security counts the earnings for the month in which the beneficiary was actually paid. For example, let's look at an employer that issues a paycheck on the 5th of the month covering the pay period for the last two weeks of the previous month. If the employee is an SSDI recipient or a concurrent beneficiary, Social Security would count the earnings as income for the previous month. If the pay period overlapped from one month into the next, Social Security would prorate the earnings for each month based on the amount of overlap. If the employee is an SSI recipient, Social Security would count the earnings as income for the current month.

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7. If an EN is tracking a beneficiary that the EN previously served and learns that the person eventually went to work and achieved the qualifying levels of work and earnings necessary to trigger Milestone and/or Outcome payments, can the EN collect payments even though it is no longer serving that beneficiary?

There is no requirement for a beneficiary to remain in service with an EN for the EN to be eligible to receive payments. A beneficiary may un-assign his/her Ticket at any time. The EN may still be eligible for compensation for helping the beneficiary reach the designated work and earnings to generate Milestone and/or Outcome payments even after the Ticket is unassigned, as long as the beneficiary did not reassign his/her Ticket to another EN or a State VR agency acting as an EN and provided that the Ticket has not been terminated for any reason (see Section 411.581 of the Ticket regulations).

Upon receiving such a payment request, the Ticket Program Manager (TPM) will make a determination as to whether the EN that formerly had the beneficiary's Ticket assignment provided services that contributed to the beneficiary's attainment of the work and earnings necessary to trigger Milestone and/or Outcome payments. If the beneficiary had reassigned his/her Ticket to another EN or State VR agency, and that EN is also requesting payment on behalf of the same beneficiary, the TPM will determine the allocation of payment to each EN based on the services each EN provided and how those services contributed to the beneficiary's attainment of the required levels of work and earnings. Such cases are referred to as split payments.

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8. Please explain the recent work rule and provide a scenario of someone who was working in the 18 months prior to the Ticket assignment. Please break down all situations and explain when each corresponding Phase 1 payment would not be available.

Phase 1 Milestones may not be available to an EN if, during the 18 months prior to the beneficiary first assigning his/her Ticket, the beneficiary worked and had earnings at a level equal to or above the amount designated as the Trial Work Level (TWL) earnings for that year. The Phase 1 Milestone payment would be unavailable to the EN because the EN did not incur the cost of helping the beneficiary achieve that particular level of earnings. The chart below shows the level of work as described in 411.535(a) that would prevent the payment of each of the four Phase 1 Milestones.

Milestone precluded:

If gross wages before Ticket assignment date were above the TWL earnings amount for the following timeframes:

1

Within the last calendar month prior to the first assignment on a Ticket

2

3 months within the 6 months just prior to the first assignment on a Ticket

3

6 months within the 12 months just prior to the first assignment on a Ticket

4

9 months within the 18 months just prior to the first assignment on a Ticket

 

Although the criteria used to determine the availability of the Phase 1 Milestones based on a beneficiary's recent work history are patterned after the criteria used to determine the attainment of the four Phase 1 Milestones, the criteria used in the recent work rule are not cumulative. Rather, each criterion should be applied independently. As a result, if a beneficiary worked with TWL earnings during 3 of the 6 months just prior to Ticket assignment, but this work did not include the month just prior to Ticket assignment, the first Phase 1 Milestone would be available to the EN when the beneficiary attained the required levels of work and earnings; the second Phase 1 Milestone, however, would not be available. Similarly, a beneficiary who worked 9 of the last 18 months just prior to Ticket assignment with earnings at the TWL might be eligible for 3 of the Phase 1 Milestones or none, depending on where the 9 months fell within the 18-month period. The example below provides an idea of how the recent work rule works. The recent work rule does not apply to Tickets assigned prior to July 21, 2008.

The recent work rule applies only to the Phase 1 Milestones. Phase 2 Milestones are available to an EN when a beneficiary attains the necessary levels of work and earnings prior to commencement of the Outcome payment period, or if after that, as part of the reconciliation payment.

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9. According to Section 411.175, a beneficiary whose Ticket was in use before Social Security determined that the beneficiary was no longer disabled may continue to receive benefit payments in certain circumstances. What are these circumstances?

In accordance with the other Social Security regulations referenced in 411.175, a Ticket Holder who receives a decision that benefits will cease because his/her health has improved may apply for benefit continuation on the basis of being in a program of Vocational Rehabilitation with an EN or a State VR agency, or because the Ticket Holder has a Plan to Achieve Self-Sufficiency (PASS), or for a few other reasons. If Social Security finds that the program increases the likelihood that the beneficiary will remain off the benefit rolls, the beneficiary may be awarded benefit continuation until the program of Vocational Rehabilitation is completed.

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10. What payments are available to my EN after the beneficiary has worked with the State VR agency?

A beneficiary who works with a State VR agency under the Cost Reimbursement program would be able to use his/her Ticket with an EN once the State VR agency closes the beneficiary's case. If the beneficiary is working when the State VR Agency closes the case, the EN with the Ticket assignment can receive Phase 2 Milestone and Outcome payments as the beneficiary attains the required levels of work and earnings.

When a State VR agency serves a beneficiary as an EN, the beneficiary's Ticket is assigned to the VR agency. If the beneficiary chooses to assign his/her Ticket to another EN when the VR closes the case, any available EN payments that have not been made could be made to the new EN once the beneficiary attains the required level of work. In addition, the VR agency and the EN may split the payments that are earned. When a VR agency and an EN both request EN payments for the same payment period, the TPM will determine how to split those payments based on the services each entity provided and how those services contributed to the beneficiary's ability to attain the required levels of work and earnings to trigger payments.

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11. Do "gross earnings" mean earnings before Impairment Related Work Expenses (IRWE) deductions? Or does it just refer to earnings before taxes?

References to gross earnings with regard to milestone payments under the Ticket program mean earnings before taxes are taken out and before Social Security makes any deductions based on a person's participation in various work incentives such as deductions for IRWEs or Blind Work Expenses, participation in a Plan for Achieving Self-Support, accessing Student Earned Income Exclusions, etc. Beneficiaries who take advantage of Social Security work incentives can reduce their countable income, which is used to determine ongoing eligibility for disability benefits (SSDI and SSI) and, in the case of SSI recipients, to determine the monthly amount of their SSI benefits. Some work incentives are available only to SSI recipients, some are only available to SSDI recipients, and some are available to both. Learn more about Social Security work incentives in the Red Book at https://www.ssa.gov/redbook.

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12. Does the Trial Work Level (TWL) that qualifies an EN for the Phase 1 Milestones apply to blind beneficiaries or those who are visually impaired?

TWL earnings apply to recipients of both SSDI and SSI. However, Social Security does use different annual earnings thresholds to determine what constitutes Substantial Gainful Activity (SGA) for beneficiaries who are blind and visually impaired versus those with other types of disabilities. Annual SGA and TWL thresholds are available at http://www.ssa.gov/OACT/COLA/sga.html.

 

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State Vocational Rehabilitation (VR) agencies

1. Can Social Security perform a medical Continuing Disability Review (CDR) on a Ticket-eligible beneficiary receiving services from my State VR agency under the Cost Reimbursement payment method?

A beneficiary who is working with a State VR agency will not be subjected to a medical CDR as long as the VR agency has notified the Ticket Program Manager (TPM) that the beneficiary is in plan status and the beneficiary is making timely progress towards achieving his/her employment goals. When a VR agency accepts a beneficiary for services, it must notify TPM of whether that person will be served under the VR Cost Reimbursement program or the Ticket to Work program (Ticket program). For cost reimbursement cases, the VR agency submits the beneficiary's Social Security Number (SSN) and the date the Individualized Plan for Employment (IPE) was signed, and the Ticket is placed "In-Use SVR." For beneficiaries being served under the Ticket program, the State VR agency submits either an electronic data transfer or submits a completed SSA 1365 form signed by the beneficiary to the TPM and the Ticket is assigned to the VR agency. In both cases, the applicable Ticket status ("In-Use SVR" or "assigned") triggers the protection from medical CDRs.

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2. When must a State VR agency choose which payment method it intends to use for a particular Ticket Holder? Can the payment method be changed later from being paid as an Employment Network (EN) to being paid under Cost Reimbursement or vice-versa, depending on the case?

For each beneficiary accepted for services, a State VR agency must choose between serving that beneficiary under the Cost Reimbursement (CR) program or under its elected EN payment system. This choice is made when the agency is reporting the signing of the beneficiary's Individualized Plan for Employment (IPE) to the TPM. If the VR agency chooses the CR program, the agency has the option of changing its payment option during the 90-day period following the IPE signature date. This is done by submitting a completed SSA 1365 with a written note indicating that the case was originally reported as a CR case and is now being changed to a Ticket-assignment case. The Social Security Administration (Social Security) allows this change to be made to ensure that the medical CDR protection is in place as soon as possible. Once 90 days from the IPE signature date have elapsed, cases reported as CR cases must continue as CR cases throughout the time that the State VR agency case is open. At this time, State VR agencies are not permitted to change Social Security Numbers (SSNs) reported as Ticket assignments to the CR option.

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3. How and when will a beneficiary be informed that he/she has an "In-Use SVR" Ticket status with my State VR agency?

Social Security sends a letter to each beneficiary after the TPM receives and processes the beneficiary's SSN in an electronic data transfer and that information is transferred to Social Security. These letters go out once a month around the first day of the month.

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4. Can a beneficiary reassign his/her Ticket to an EN while a State VR agency has an open case and the ticket status is "In-Use SVR"?

As a general rule, a beneficiary is not able to assign his/her Ticket to an EN while he/she has an open case with a State VR agency. If the VR agency has been timely in reporting the fact that the beneficiary has signed an IPE, the Ticket will be listed as "In-Use SVR" and will not be available for assignment to an EN until the VR agency reports the closing of that case. If such reporting is not timely, the Ticket will appear to be available for assignment and an EN may secure the Ticket assignment before the State VR agency reports its intent to serve that beneficiary. In rare instances, an informed beneficiary may seek to assign his/her Ticket to an EN even though he/she has an open case with a State VR agency by citing the choice principle of the Ticket program. In these limited cases, the State VR agency should notify the TPM of the situation. Some State VR agencies may also choose to explore the "comparable benefits" rule that allows a VR agency to deny specific services for a VR consumer based on that service or those services being available through alternative funding sources (i.e., in this case, through an EN operating under the Ticket program).

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5. If an EN serves a beneficiary who does not attain all the payments available on the Ticket, and the beneficiary then decides to return to the State VR agency where the Ticket was previously assigned, can that agency accept the Ticket again and resume Ticket payments? Can this specific beneficiary be served under Cost Reimbursement?

A beneficiary may re-assign his/her Ticket to an EN, including a State VR agency acting as an EN, with which the beneficiary formerly assigned the Ticket. However, only those Milestone and Outcome payments initially available and not yet paid when the Ticket was re-assigned would be available for payment once the beneficiary attained qualifying levels of work and earnings. If the VR agency previously had a CR case but never submitted a CR claim on behalf of this beneficiary, the agency would have the option of functioning as an EN and serving the beneficiary under the Ticket program or choosing to serve the beneficiary under the CR program. However, if the State VR agency received any reimbursement on behalf of this beneficiary since January 1, 2002, the only option would be to open a CR case.

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6. If a beneficiary has his/her Ticket assigned to an EN and seeks assistance from a State VR agency, what does the VR agency need to do to get the Ticket "unassigned" from the EN and placed into the "In-Use SVR" status associated with the CR program?

Social Security cannot compensate an EN under the Ticket program and a State VR agency under the CR program on behalf of the same beneficiary during the same period of time. At any given time, a Ticket can be either assigned to an EN or a State VR agency or it can be "In-Use SVR" under the CR program; it cannot be both. If a State VR agency checks and finds that the beneficiary's Ticket is assigned to an EN, it has several options:

1) The VR counselor may explain the situation to the beneficiary and see if he/she will notify the Ticket Program Manager (TPM) in writing to un-assign the Ticket.

2) The VR counselor or Ticket/CR Coordinator may contact the EN with the Ticket assignment, explain the situation, and ask the EN to contact TPM to unassign the Ticket so the State VR agency can place the Ticket "In-Use SVR" while the VR case is open.

If the EN will release the Ticket while the State VR agency has an open case on the beneficiary, the agency could then refer the beneficiary back to the EN after case closure based on the beneficiary's consent.

Another alternative is for a referring EN to keep the Ticket assignment and have an agreement with the State VR agency which clearly states the types of services to be provided by each entity and how the State VR agency will be compensated for the services it provides, since the EN is precluding the agency from receiving cost reimbursement by keeping the Ticket assignment.

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7. What documentation will my State VR agency need to submit to the TPM to place a beneficiary's Ticket "In-Use SVR" under the State VR agency Cost Reimbursement option?

The TPM has established an electronic data transfer process that State VR agencies must use to establish that they are serving a beneficiary under the traditional CR program and to release these Tickets after the beneficiary's VR case is closed. When TPM receives notification that a State VR agency is going to serve a beneficiary under the CR program, the beneficiary's Ticket is placed "In-Use SVR" and is not available for assignment to an EN or another State VR agency until the original State VR agency closes the beneficiary's case and notifies TPM of the case closure date.

At a minimum of once a month, a State VR agency is expected to submit an electronic file to the TPM identifying the beneficiaries who entered plan status during the prior month. Only two data elements need to be submitted to place a Ticket "In-Use SVR": the beneficiary's SSN and the date that the beneficiary's IPE was signed. The SSN should not contain dashes (e.g., 223456789) and the dates (IPE signature date and case closure date) should be an 8 digit numeric field in MMDDYYYY format (e.g., 03222012). The timely submission of this information is important because it triggers the protection from medical CDRs that are associated with a beneficiary using his/her Ticket and Cost Reimbursement payments.

State VR agencies use the same electronic data transfer to close CR cases. The State VR agency simply submits the beneficiary's SSN, the date the beneficiary's VR case was closed, and the status of the beneficiary's case at case closure, i.e., code 26 or 28, employed/not employed, and successful/unsuccessful. The status at case closure is used to determine whether an EN that subsequently gets that beneficiary's Ticket assignment will be eligible for Phase 1 Milestones. If the beneficiary was employed at the time of case closure, the Phase 1 Milestones would not be available; if the beneficiary was not working at time of closure, then all Ticket payments are available to the EN. The timely reporting of case closures is important for a number of reasons. First, taking the Ticket out of the "In-Use SVR" status releases it for another EN to secure the Ticket assignment and provide ongoing supports to assist the beneficiary to maintain and advance in employment. Second, a beneficiary is granted a 90-day grace period during which the protection from medical CDRs continues, allowing the beneficiary time to assign his/her Ticket to an EN. This 90-day grace period starts on the date of case closure and immediately follows VR case closure, during which time, a beneficiary may assign his/her Ticket to an EN even if his/her disability benefits have ceased due to work and earnings. If the Ticket is assigned within 90 days, it continues to be an active Ticket. If not assigned within 90 days, the beneficiary will no longer be eligible to participate in the Ticket program.

The monthly "In-Use SVR" electronic files are submitted via the TPM Secure Network, MOVEit. Once the file is processed, the TPM prepares an analysis of the data that is sent back to State VR agencies via MOVEit.

A beneficiary being served under CR should be informed that his/her Ticket is not available for assignment to an EN while the State VR agency case is open; that the Ticket will still have value after a State VR agency closes the case; and that he/she will have the option of taking the Ticket to an EN after his/her VR case has been closed to secure ongoing employment supports.

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8. What does my State VR agency need to submit to the TPM to show that we have an open case that will be eligible for payment under either the Cost Reimbursement payment option or to be paid as an EN?

When a State VR agency is operating as an EN, it must complete, sign, and have the beneficiary sign the SSA-1365, State Agency Ticket Assignment Form. The completed form must be sent to the TPM and the TPM will assign the Ticket to the VR agency. When a beneficiary is going to be served under the Ticket program, he/she should be informed of this decision and that his/her Ticket will be assigned to the State VR agency. Many State VR agencies include a statement to this effect on their IPEs. If a beneficiary has consented to assign the Ticket to the State VR agency but has not signed an SSA-1365, the State VR agency should submit the un-signed SSA-1365 with a copy of the signature page of the IPE and a copy of the IPE page that included the statement of the beneficiary's informed consent to assign the Ticket.

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9. How frequently must my State VR agency submit information about completed IPEs and case closures?

Information on the opening and closing of CR cases must be submitted monthly to the TPM. The timely submission of this information is important for three reasons. First, when the TPM receives notice of an IPE being signed, it places that beneficiary's Ticket "In-Use SVR," which triggers that beneficiary's protection from a medical CDR. Second, the TPM also removes the name of that beneficiary from the list of Tickets available for assignment, thereby preventing another EN from securing that beneficiary's Ticket assignment. Third, if case closure information is not received promptly, the beneficiary may not benefit from the 90-day window to reassign his/her Ticket without having any lapse in his/her protection from a medical CDR.

For a beneficiary for whom the State VR agency is choosing to function as an EN and seek compensation under the Ticket program, the benefits of timely reporting are similar. When the TPM receives the signed SSA-1365 or a copy of the beneficiary's signed IPE, the Ticket is assigned to the State VR agency, which triggers the beneficiary's CDR protection and prevents another EN or State VR agency from securing the Ticket assignment while the VR case is open.

The benefits of the timely reporting of the closing of a beneficiary's Ticket case is important for the same reasons as for a CR case, i.e., the Ticket becomes available for assignment to another EN to receive ongoing employment supports and there is a 90-day grace period allowing the continuation of the medical CDR protection while the beneficiary researches where he/she might want to assign his/her Ticket for ongoing employment supports.

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10. Are there specific desired formats my State VR agency should use for SSNs and dates when submitting case data?

The SSN should not contain any dashes (e.g., 22345678) and the dates (IPE signature date and case closure date) should be an 8 digit numeric field in MMDDYYYY format (e.g., 03222012).

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11. I am getting bombarded by calls from beneficiaries suddenly getting pulled for a medical review right after they failed a Timely Process Review (TPR). Why?

The normal TPR process includes beneficiary failures being reported by the TPM to Social Security each night. This notification removes the CDR protection from the beneficiary. At that point, the beneficiary falls into the normal schedule of his/her medical review. Timing has nothing to do with failing the TPR. If the beneficiary immediately gets called for medical review, it is only because this happens to be the timing for a medical review based on the original schedule set up when the disability determination was made. Regardless of when the beneficiary fails a TPR, the medical review is due at a certain time (every 1, 3, 5 or 7 years). As soon as the CDR protection is removed, the beneficiary is eligible for, and will be called for, the next scheduled review.

 

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Partnership Plus

1. How does the Partnership Plus option work?

When the State Vocational Rehabilitation (VR) agency chooses to serve a beneficiary under the Cost Reimbursement (CR) program and sends proper documentation to the Ticket Program Manager (TPM), the beneficiary's Ticket is placed in a status called "In-Use SVR." This status triggers the same protection against medical Continuing Disability Reviews (CDR) that was previously only associated with a Ticket being assigned and "in-use."

During the time the beneficiary has an open State VR agency case, the Ticket is not available for assignment to an EN. After the beneficiary's VR case is closed and the VR agency notifies the TPM of the date of the case closure, the beneficiary has the option of assigning his/her Ticket to an EN. The remaining value of the Ticket and the types of services the beneficiary may be seeking will be determined based on whether or not the beneficiary was working at the time of case closure. If the beneficiary was working at the time of case closure (referred to as a successful closure), the Phase 1 Milestones would not be available to the EN that subsequently got the Ticket assignment and the beneficiary would most likely be seeking job retention services, ongoing support services, or other post-employment services to assist him/her in maintaining and advancing in employment.

The rule about the availability of the Phase 1 milestones applies all the way back to CR cases closed successfully since January of 2002. If the beneficiary was not working at the time of case closure, the Phase 1 Milestones may be available to the EN depending on factors such as whether other Phase 1 Milestone exclusions apply.

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2. Is the Partnership Plus option only available when my State VR agency is serving a beneficiary under the traditional CR program?

Yes. Under the Ticket to Work legislation, a State VR agency is given a choice on a case-by-case basis as to whether it will serve a particular beneficiary under the traditional CR program or as an EN under the Ticket to Work program (Ticket program). If a State VR agency chooses to serve a beneficiary under the CR program, the beneficiary has the option of assigning his/her Ticket to an EN to receive ongoing support services after VR closes his/her case. This option allows beneficiary to receive sequential services and smoothly transition for VR's pre-employment services to ongoing post-employment assistance provided by an EN.

This Partnership Plus service delivery option was created in the 1998 revisions to the Ticket regulations in an effort to address the fact that many beneficiaries enter the workforce but do not continue working long enough to reduce or eliminate the need for disability benefits. If the beneficiary was working at the time of case closure, the Phase 1 Milestones would not be available to the EN that subsequently gets the Ticket assignment.

As a result, the EN will be focused on assisting the beneficiary to achieve earnings at or above the Substantial Gainful Activity (SGA) level. Once the beneficiary's earnings are at the SGA level, the EN can start billing for Phase 2 Milestones. Once the beneficiary has achieved 9 months of SGA level earnings within a 12-month period, the State VR agency can submit for cost reimbursement. When the beneficiary's earnings result in the cessation of monthly disability benefits, the EN can begin submitting for outcome payments.

 

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Workforce

1. What options exist for the Public Workforce Development System to participate in the Ticket to Work Program as Employment Networks (ENs)?

There are a variety of options available to the public workforce system in determining the appropriate entity to serve as an EN, i.e., what entity will have the actual contract with the Social Security Administration (Social Security) as a qualified EN, the American Job Centers (AJC), Local Workforce Investment Boards (LWIB), or State Workforce Agencies (SWA).

The public workforce system has adopted these three basic EN models:

  1. LOCAL LEVEL MODEL: A public workforce development system entity, such as the AJC or LWIB, applies to the Social Security to become an independent EN. In this capacity, the public workforce development system entity would be solely responsible for the identification and assignment of Ticket Holders, creating an Individual Work Plan (IWP) for each assigned Ticket Holder and delivering the EN services outlined in this plan, requesting/receiving Ticket payments, and complying with all reporting requirements of the Ticket program.
  2. COLLABORATIVE MODEL: A public workforce development system entity, such as an AJC or LWIB, applies as the EN of record, while partnering with other agencies, community based organizations and other disability service providers in their area to provide pre- and/or post-employment related supports and services.
  3. STATE ADMINISTRATIVE EN MODEL: In states and/or local areas where there is a multitude of AJC operators, it may be optimal for a state entity (e.g., LWIB or SWA) to serve as the State Administrative EN, so that the Ticket program can be operated in a coordinated fashion by the State Administrative EN through its AJCs, LWIBS or SWAs which are located in multiple regions and sites in the State.

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2. How would ticket payments be divided among those entities participating in the State or Regional Model?

That would be up to the group to decide. Typically, the administrative entity keeps some percentage to cover operating costs and remits the remainder to the entity that provided services to the Ticket Holder. Signed agreements or memoranda of understanding are typically used by the entities to formalize the arrangement.

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3. What are the advantages of forming a State or Regional Administrative EN?

First, there is a reduction of time involved with the EN application process. Only one application is required (by the administrative entity), saving the others participating in the collaboration from that workload. Second, there is a reduction in time involved with EN operational tasks. The day-to-day paperwork involved in operating an EN is conducted by the Administrative EN. This can be significant for smaller entities that may not have sufficient staff time to devote to administrative duties. By reducing this burden, more AJCs and WIBs will be able to participate in the Ticket program and focus on providing services to AJC customers who are Ticket Holders.

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4. Are there other Workforce EN models?

Yes. There is also a hybrid model that some states may prefer. The state agency becomes an Administrative EN for the sole purpose of sharing data with the Ticket Program Manager (TPM). It submits the data file of Workforce customers, but the hit list of Ticket Holders goes to the individual One Stop Career Center/Workforce ENs for Ticket assignment, service provision, and Ticket payment.

 

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Individual Work Plan and Ticket Assignment Process

1. What makes an Individual Work Plan (IWP) complete?

An IWP is complete when the document is in conformance with Ticket program policy, as listed in Part III-Section 4.A of the Request for Application (RFA) and both the beneficiary and Employment Network (EN) representative acknowledge completing the plan with signatures.

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2. How do I determine if a beneficiary is a good candidate for the Ticket to Work program?

The Ticket to Work program (Ticket program) is voluntary and may not be a good fit for every beneficiary. The EN should assess the beneficiary's needs and desire to become financially independent. If the beneficiary's goal is to become financially independent and the EN can provide services necessary to meet the goal, then the beneficiary and EN are a good match.

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3. What constitutes an acceptable short-term and long-term goal for a beneficiary's IWP?

State what position or what career path the beneficiary is interested in attaining. The goal should be clear and measurable. The recommended method to ensure an acceptable short-term or long-term goal is the S.M.A.R.T method.

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4. What would cause the signature date to be unacceptable on an IWP?

A future date would not be acceptable. A date in which the beneficiary was not eligible for the program would also not be acceptable.

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5. What is the significance of documenting in the IWP that the counseling session occurred?

This ensures that the beneficiary and the EN engaged in a one-on-one individualized discussion involving career planning, developing employment goals, and EN supports and services.

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6. How will I know if the Ticket Program Manager (TPM) has received the IWP submission?

A Ticket Assignment Confirmation letter is mailed once the Ticket is assigned. If the Ticket cannot be assigned, an email and a letter will be sent to the EN Contact explaining why the Ticket could not be assigned.

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7. How long will it take to process an IWP and assign the Ticket?

We are contractually obligated to process an IWP within seven business days of receipt.

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8. How long does it take a Ticket assignment to show up in the Portal after it is processed?

The Ticket assignment should appear in the Portal two days after it has been processed. This is dependent on when the last files were processed.

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9. How long should I wait before inquiring to ENOperations@yourtickettowork.com about the status of a Ticket assignment for which I have received confirmation?

An email can be sent to the EN Operations inbox after 7 - 10 business days.

 

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