Negative OIG Report On PASS Plans

From a recent report of Social Security's Office of Inspector General (OIG):

The Social Security Act authorizes the exclusion of the income and resources of an individual who has a disability or is blind when the individual needs such income and resources to fulfill an approved PASS [Program for Achieving Self-Support]. The income and/or resources the individual uses to pursue the PASS will not be counted in determining eligibility or payment amount for SSI [Supplemental Security Income], thus potentially allowing for SSI qualification and/or an increase in the recipient’s SSI payment over the amount otherwise payable.

Each PASS must have an occupational goal. The individual should have either a specific work goal or a description of the type of job he or she expects to have at the end of the PASS plan. ...

To perform our review, we identified 2,622 SSI recipients who participated in the PASS program in Calendar Year (CY) 2005. We randomly selected 50 cases from this population for detailed analysis. ...

Of the 50 recipients in our sample, 20 had a completed PASS that did not result in savings to SSA. These 20 recipients received a total of about $243,000 in additional SSI payments because of PASS income exclusions. None of these recipients had earnings after the PASS ended that reduced or suspended their SSI or DI benefits. ...

Of the 50 recipients in our sample, 20 had a completed PASS that resulted in savings to SSA. These 20 recipients received a total of about $307,000 in additional SSI payments because of PASS income exclusions. All 20 recipients worked after the PASS ended, and their work caused benefit reductions or suspensions that resulted in about $221,000 in savings to SSA from the date the PASS ended until October 2009. Additionally, in 9 of these 20 cases, savings are ongoing because the recipients’ benefits are currently suspended or reduced due to wages. ...

We found that the PASS program provided assistance to some recipients who wanted to return to work. Based on our review, we estimate that about 1,050 (of about 2,100) recipients who had a PASS in CY 2005, completed it and were able to move further toward independence. However, we also found that the program costs outweighed the savings. We estimate that SSA paid approximately $28.8 million in additional SSI payments because of PASS income exclusions, but only $11.6 million was saved as a result of the recipients earning enough through their work to result in a reduction or suspension of benefits.

Therefore, we recommend SSA reinforce to its PASS cadres that PASSes should be for feasible and realistic goals that are expected to increase (a) the recipient’s prospect for self-support and (b) the likelihood of savings to SSA’s programs.