Social Security Seeks Input

     From a notice published by Social Security in the Federal Register (footnotes omitted):

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.