From a recent report by the Government Accountability Office (GAO):
The Social Security Administration’s (SSA) primary approach for encouraging employment for transition-age youth (ages 14 to 17) with disabilities who receive Supplemental Security Income (SSI) is work incentives that allow them to keep at least some of their SSI benefits and Medicaid coverage while they work. But few transition-age youth benefit from these incentives. ... The work incentive targeted specifically to younger SSI recipients is the Student Earned Income Exclusion (SEIE), which allows income to be excluded from benefits calculations if a recipient is a student under age 22. However, less than 1.5 percent of all transition-age youth — and generally less than half of those with earnings —benefited from SEIE in 2012 through 2015. ... Data also show that almost no youth benefited from other incentives that allow them to exclude earnings used for specific purposes, such as the Impairment-Related Work Expenses incentive. The effectiveness of SSA-administered work incentives may be further limited because, according to SSA and other officials, youth and their families are often unaware of or do not understand them, and may fear that work will negatively affect their benefits or eligibility. ...
SSA does not have a systematic way to connect transition-age youth on SSI to state Vocational Rehabilitation (VR) agencies that provide training and employment services under the VR State Grants program administered by the Department of Education (Education). Although youth receiving SSI are generally presumed to be eligible for VR services, GAO found that less than 1 percent had an open VR service record in 2015 in four of the five states from which GAO collected VR data. ...
We recommend that the Acting Commissioner of the Social Security Administration take the following actions:The report addresses an important topic. I have a few thoughts on this:
- Analyze the SEIE data to determine why a large proportion of transition- age youth on SSI with reported earnings did not benefit from the SEIE and, if warranted, take actions to ensure that those eligible for the incentive benefit from it.
- Analyze options to improve communication about SSA-administered work incentives and the implications of work on SSI benefits, with a goal of increasing understanding of SSI program rules and work incentives among transition-age youth and their families. This should include, but not necessarily be limited to, updating SSAs procedures for staff meeting with SSI applicants, recipients, and their families to regularly and consistently discuss – when applicable—how work incentives can prevent reductions in benefit levels and how work history is considered during eligibility redeterminations.
- Work with the Secretary of Education to determine the extent to which youth on SSI are not receiving transition services through schools that can connect them to VR agencies and services.
- Explore various options for increasing connections to VR agencies and services , including their potential costs and benefits. One option, among others, could be to expand the Ticket to Work program to include youth.
- Transition services are vitally important to disabled youths who are about to leave school. I have seen far too many cases where young people who urgently needed VR had no idea that VR exists. When I see clients in this situation, I tell them and their parents about VR but, of course, most disabled young people never see a Social Security attorney.
- Some years ago, at least in North Carolina, schools worked with VR to identify disabled young people in need of help and made sure they were offered that help. That seemed extremely effective. That's not happening now. (What about other states?) I'm pretty sure the problem is lack of VR funding. I'm not sure why the school systems don't at least give the disabled young people and their families the phone number for VR although as I discuss below state Vocational Rehabilitation may be of only limited value at this point.
- Sheltered workshops are a vital part of vocational rehabilitation for disabled young people trying to make the transition from school to work. Sheltered workshops have almost completely disappeared in North Carolina. I'm pretty sure it's due to lack of funding. (What about other states?)
- What I've seen over the last decade or two is declining effectiveness of North Carolina VR. They seem to be able to do little other than pay for community college courses. Disabled young people trying to make the transition from school to work typically need far more help. (What about other states?)
- Social Security's work incentives are far, far too complicated. That's not the agency's fault. Congress wrote the work incentives, not Social Security, but don't expect simplification to help much. There's plenty of evidence that work incentives have little value.
- Social Security lacks funding to do much to help disabled young people making the transition from school to work. I suppose the agency could send out mailings but they would need additional appropriations to do anything more. I think the money might be better spent elsewhere.
- I think additional funding for VR along with provisions requiring VR to coordinate with school systems would work better than anything the Social Security Administration can do.
- Finally, don't expect miracles. Most disabled children won't work on a regular basis no matter what anyone does. Many people who work at the Office of Disability Adjudication and Review (ODAR) or who represent claimants get the mistaken impression that almost all children receiving SSI benefits have psychiatric or cognitive impairments that are of less than overwhelming severity. That's because that group is vastly over-represented in the population requesting hearings on SSI child disability claims. Most disabled children on SSI have physical problems and most of those problems are so overwhelming that the disability claims are approved quickly. Work is unlikely to ever be in the picture for most of these children. Many of those suffering from psychiatric disability have schizophrenia. While Social Security is denying too many schizophrenics, it's still a fact that most schizophrenia claims are being approved fairly quickly. The vast majority of schizophrenics won't be able to work no matter what anyone does for them.
Having worked with the populations you speak of I have to agree. Setting up links to VR for children with disabilities must be done early enough and well enough for it to make a difference in those cases where some employment (even if only sheltered or part time) is feasible. Also, outreach needs to be aggressive, because surprise, many of the kids with disabilities have poor support networks making it difficult for them to understand and follow through on available programs. If Congress gave a damn about making it actually workable it would have to face up to some of the facts you mention and then put a reasonably well funded program in place that does not require a law degree to understand and follow.
ReplyDeleteCharles, I agree with everything which you've written. Out in Western NC, the school programs for students who had physical or cognitive impairments varied greatly from county to county, depending upon the local support by the county commissioners. In our county, the programs were done by coordination with VR. These students were shunted into junior year classes which attempted to teach some interview skills and basic skills needed to keep a job. In the senior year, boys were usually sent to be dishwashers in BBQ restaurants (other duties were required between meal hours)and girls were sent into stores to attempt shelf stocking (if they had sufficient minimal literacy skills).
ReplyDeleteFor those from other parts of the country who may not have heard, the Republican legislators gerrymandered themselves into a veto-proof majority and are busy attempting to kill the public school system in favor of charter schools, so I doubt that too many special programs will remain.
Sheltered workshops are disappearing due to CMS regulations. Most that exist in Maryland cannot add new people and are fighting to retain something for the often aged population that currently uses them. Coupled with the push to pay market wages, sheltered workshops are on life support. Which is a shame because it eliminates options and when dealing with folks with disabilities, options are important. Not everyone can work in the community, it's a pipe dream for many and with these going away means these folks are left adrift. It's a shame.
ReplyDeleteIt is a shame. Our vocational rehabilitation is drying up. It's a good place for people to work who can't quite cut it in the competitive market.
ReplyDeleteFOs in our district are not only disinterested in building or sustaining relationships with state agencies (even, in some cases, DDS), sometimes they are actively hostile to the idea.
ReplyDeleteIt all comes from above. The priority is on internal numbers like RZs, CDRs, and tracked workloads staying under the "RO takes notice" level. The rest is looked at as a distraction, even if it's essential to the agency's mission.