This request for information (RFI) seeks public input on strategies for improving the adult economic outcomes of youth ages 14 to 25 with disabilities receiving SSI. ...
While studies have shown that transition-age SSI recipients are at risk of poor economic outcomes--lower earnings and employment--when they become adults, it is not clear what supports could improve these outcomes or who should provide them. ...
This RFI offers interested parties, including States, community-based and other non-profit organizations, philanthropic organizations, researchers, and members of the public, the opportunity to provide information and recommendations on effective approaches for improving adult outcomes for youth receiving SSI. ...
SSA's redetermination of SSI eligibility at age 18 also generally results in 30-40 percent of youth losing SSI eligibility (and the accompanying automatic Medicaid access that most SSI recipients receive) because their condition does not meet the adult standard for disability. The Government Accountability Office (GAO) has noted that these issues contribute to the difficulties many child SSI recipients experience transitioning to adulthood.
Several studies of transition-age SSI recipients suggest significant gaps exist in the awareness and use of services and policies currently available to youth. For example, prior to age 18, less than one quarter of SSI recipients received vocational training. About 40 percent of 16- and 17-year-old SSI recipients work, but only about 3 percent of eligible SSI recipients (of all ages) use the student earned income exclusion, a work incentive that excludes a certain amount of earned income from the SSI calculation. ...
SSA has recognized the difficult transition to adulthood and that many of these youth return to the SSI program in early adulthood. ...
We ask respondents to address the following questions, where possible, considering the context discussed in this document. You do not need to address every question and should focus on those that relate to your expertise or perspectives. To the extent possible, please clearly indicate which question(s) you address in your response.
Questions:
1. What specific programs or practices have shown promise at the Federal, State, or local level in improving the adult economic outcomes of youth with disabilities receiving SSI?
2. Given the requirement of VR agencies to serve transition-age individuals, the availability of Individualized Education Programs (IEP) and Section 504 plans in school settings, and the availability of services and supports elsewhere available to youths, what should SSA's role be in assisting the transition of youths to adulthood?
3. How might SSA better support other agencies' youth transition-related activities?
a. What SSA policies interact with other agencies' services and supports?
b. Do SSA's and other agencies' policies need to be modified (technically or administratively) to improve utilization of these services and supports? How?
4. Are there aspects of SSA's publications, mailings, and online information that SSA can improve to better support successful transitions to adulthood of youths receiving SSI?
5. How can SSA improve its existing work incentive policies, such as the Student Earned Income Exclusion (SEIE) and Impairment-Related Work Expenses (IRWE), to better support and increase SSI youth engagement in work? Are there alternative models that SSA should consider to replace existing work incentives?
6. How can SSA enhance and better target its existing service infrastructure including its Work Incentive Planning and Assistance (WIPA) program and Plan to Achieve Self Support (PASS), to increase SSI youth engagement in work and work activities?
7. What lessons from SSA's youth demonstration projects, in particular the Youth Transition Demonstration (YTD) and the Promoting Readiness of Minors in SSI (PROMISE) project, should SSA apply to new policies and demonstrations? What partners were not included in those demonstrations that should have been? Why?
8. If SSA were to conduct a new demonstration project related to youth, which populations should SSA consider targeting, if any? How can SSA identify these populations? How many individuals enter these populations per year?
9. Are there entities (for example, State VR agencies, medical practices, local education and training agencies, etc.) we could look to as exemplars based on current practices for serving youth with disabilities? What evidence exists to suggest these sites are effectively providing services that would lead to the increased self-sufficiency of youths with disabilities?
10. In the absence of legislation renewing SSA's ability to refer Social Security Disability Insurance (SSDI) beneficiaries and SSI recipients directly to VR, how can SSA help connect youth to VR services?
11. Should SSA expand the Ticket to Work (Ticket) program to include children or create a separate program for children with a similar mission (i.e., reimbursing service providers whose services result in increased employment and reduced need on cash benefits)?
a. What services should such a program provide over and above the services youth with disabilities receiving SSI are already eligible for?
b. What types of service providers should be allowed to participate in a youth Ticket program? Should such a program include all types of existing employment network providers or should it be limited organizations with existing providers that serve the broader youth population?
c. Is there a lower age limit the Ticket program (either the current program or a new child-specific program) should include that is consistent with other common Federal, State, and local policies that promote self-sufficiency?
d. Since most children are in school, what outcomes or milestones should a
program that included payments for child outcomes be tied to?
e. How effective are such incentive payments to service providers likely to be when serving youth? Are there alternatives to current incentive payment structures that SSA should consider (e.g., a payment structure based on state-wide youth employment or youth SSI participation metrics)?
f. How should the age-18 redetermination and the fact that over one-third of age-18 redeterminations result in the cessation of benefits because they do not have a condition that meets the adult standard for disability factor into such a program?
g. Are there specific populations among SSI youth, such as youth in foster care, that such a program should consider for allowable services, providers, and expenditures?
h. Would such a program be duplicative of the services provided by State VR agencies, which are already required to support the transition of youth with disabilities? Why or why not?
12. Since the implementation of WIOA, are there specific examples of effective services that are funded through the PROMISE grants but not funded through State VR agencies or other Federal and State funding sources?...I can talk about something that I used to see that I don't see anymore even though it seemed effective. In the past, workers for the state Vocational Rehabilitation (VR) agency were in regular contact with school guidance counselors to identify disabled high school age children. These children were offered VR help in making the transition to work. As appropriate, VR offered counseling, VR paid for post-high school training, VR offered sheltered workshops, VR used contacts with sympathetic employers to help at risk young people find employment, and VR offered job coaches. This has almost completely ended in North Carolina. It especially troubles me that there are no more sheltered workshops. You don't need a Ph.D. in VR to figure out that these sorts of services can be invaluable to disabled young people. Why did they stop? It's lack of operating funds for VR. The Social Security Administration can't solve this problem but Congress certainly can and should.
I can and do refer disabled young people to VR. Every time I do, the parents tell me that they can't understand why no one at the school ever told them about VR. However, even after the young person gets to VR, it seems that they now receive only very limited help. It's nothing like it used to be.
Please, let's give adequate funding to VR. They can do good work if we'll let them have enough funding.
8 comments:
1. The special ed programs in the schools are not adhering to their responsibilities for transition programming. They often don't coordinate with the VR agencies, or even tell the students about the availability of the programs.
2. Disability advocates are the reason that sheltered workshops are disappearing. the reason for the stance against them is that they are exploitative and discriminatory, and it's unfair to other companies to allow competition by the sheltered workshops that don't have to meet minimum wages.
3. In my state, the VR agencies do little other than refer people to their "partners", which usually is the Goodwill Industries. If the partner can place the kid (or older adult), fine. If not, there's not much the VR agency has to offer.
That's some of it.
In my opinion, one of the big things that needs to happen is for parents to be made aware - really slapped over the head with the reality that their kid is going to age out of SSI. Too many parents, and the kids, have a belief that they are always disabled. They are caught short when the reviews come. The mindset that the young adult can't do anything because he's always been disabled is strong. I'm representing one such family right now. I've also talked parents and young adults out of pursuing adult SSI when it's clear that the kid has improved.
But really, it needs to go back to a strong implementation of the special ed programs in the schools. That's not going to happen, with the rise of private schools that are going to be selective in what kids they take.
VR used to be the gold standard.
If Voc Rehab had evaluated the individual and did not believe the individual could be trained and placed that was about as close to an automatic pay as you could find absent meeting a listing or a compassionate allowance.
Now Voc Rehab in my state seems to be limited to sending people with severe limitations to Goodwill or line them up with a grocery bagging job with a local chain of stores or sending those with mild limits to a community college for tech training if there is money left for a spot and not bothering with the larger group of people in between those two extremes because they lack the funds and case workers to do anything.
Ticket to Work for youth? Can we hold off on that until it works for adults first?
Our voc rehab in Mississippi once did have funds to evaluate whoever came in the door with physical and mental assessments. Then some placement or training was made or provided. Now there is an occasional mental evaluation. The vocational rehabilitation programs are dependent on contracts they get with manufacturers. Many people don't get placed at all. They were involved with the schools but don't seem to be now. I think it's a matter of funding. More services were available at the beginning of the funding cycle, but now there doesn't seem to be a beginning to the funding cycle.
My experience is those who qualify for SSI as a child usually qualify as an adult. Getting child SSI (especially now)is extremely difficult. They have to have something serious to get child SSI now.
The gray area are those in the 25-45 range. If they became disabled say in their mid 20s, then they have the youth (if a physical injury) to overcome it. Those are who need VR.
But if a severe disability shows up before turning 20 then it could be lifelong.
That was once true but now isn't unless the disability is physical. Some learning disabled children can get benefits but as young adults, learning has nothing to do with it.
I'm getting some very strong signals in my practice recently that the word has come down politically from somewhere that nobody under fifty is disabled in this society any longer. I suspect this has something to do with not wanting to pay anybody long term anymore whether they are disabled or not. I am particularly sensing that a target has been placed on those claiming mental disabilities whether they are low intellectual functioning from birth or severe depression, anxiety, or schizophrenia. Of course everything should be done to assist younger people to work and have meaningful productive lives. However, some just will not be able to work in a competitive environment and should be assisted in a decent society. I question whether the current powers that be give a damn at all about this. It's just about the money and possible higher taxes somewhere. Also, there are potential profit incentives to deal with this segment of our population by employing harsher measures such as privatized incarceration. Hope I'm incorrect about this but I fear we are moving towards corporatized or fascist solutions.
VR for injured workers, SSA & VA has all about disappeared. The insurance industry made sure of all of that. Just adding it all to their 4 and have trillions industry making the insurance industry one of the largest industries in the world by denials for those who could've dared to own and run their own business and that leaves education now owned by corporations in charge, no matter whether it would've worked for work related injured or for our vets. So why not let VR work for anyone else? Corporatism via U.S.Military is faschism and alive and well. OUR fears are now recognized.
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