Statement of Elmer C. Bartels, Massachusetts Rehabilitation Commission, Boston, Massachusetts

Introduction

The Massachusetts Rehabilitation Commission (MRC) thanks Chairman Shaw for the opportunity to provide the Committee with its comments concerning the implementation of the programs of the Ticket to Work and Work Incentives Improvement Act, with particular attention focused upon the Ticket Program.  Massachusetts was among the first states to roll out the Ticket Program and the MRC has actively worked to fashion a collaborative system of specialized training, support, and placement services with the state’s community rehabilitation program providers, working as Employment Networks, in an effort to maximize choice and value for its consumers. 

BPAO Program Success

The Benefits Planning Assistance and Outreach Program (BPAO) has been an unqualified success in Massachusetts.  The MRC operates its “Project IMPACT” BPAO program in partnership with state independent living programs, non-profit community based organizations, and One-Stop Career Centers.  The collaboration has resulted in referrals exceeding expectations and the development and implementation of over 1600 benefits plans.  Reauthorization of the Program in HR 743 will have a direct and positive impact on the employment efforts of hundreds of individuals with significant disabilities in the Commonwealth.

Traditional Cost Reimbursement and the Ticket Program

A tension has existed in the Ticket program since the issuance of the first SSA instructions concerning State Vocational Rehabilitation Program participation in the Ticket Program and the continued relevance of the SSA/VR cost reimbursement program.  That tension has continued to grow during the first several years of program implementation and it threatens to undermine the Ticket Program’s potential for success.

From the time the idea of the Ticket Program was first discussed in Congress, the CSAVR and interested state programs have emphasized the need to preserve the successful and vitally important SSA/VR cost reimbursement program.  We believe that the SSA has promulgated policy regarding the administration of the Ticket Program, through its regulations and Transmittal 17 that is contrary to the intent of Congress, the language of TWWIIA, and the law as it relates to the administration of the VR cost reimbursement program.  The Ticket Program has great potential to stimulate creative collaboration among community rehabilitation providers and state VR agencies.  That collaboration could result in increased choice, quality, and funding for SSI/DI recipients interested in obtaining and retaining employment.  However, as others have stated in their testimony, the programs working to assist individuals with disabilities to obtain real and meaningful work are woefully under-funded.  A Ticket Program designed to redistribute rather than supplement existing funds is destined to fail.  The work that State VR agencies and community rehabilitation providers perform is difficult, it is important, and it has real value to people with disabilities.  It can be improved upon but what is good must be maintained.  The threat of a new program diverting scarce funding from a collaborative system of proven effectiveness causes apprehension and at times conflict rather than promoting enthusiastic and creative participation.

It is in the interest of the Social Security Administration, ENs, State Vocational Rehabilitation Programs and most importantly people with significant disabilities hoping to work, that this tension be relieved.  Congress and the SSA should make it clear that the Ticket Program and the VR cost reimbursement program complement one another; supplement one another, and together work to creatively address the needs of individuals with disabilities seeking to maximize their economic independence.

How the Ticket Program and VR Cost Reimbursement Program Could Together Improve the Prospect of Long Term Employment for Individuals With Disabilities

The State VR Program is mandated to provide an eligible individual with any service described in an individualized plan of employment necessary to assist them in preparing for, securing, retaining, or regaining an employment outcome that is consistent with the strengths, resources, priorities, concerns, abilities, capabilities, interests, and informed choices of the individual.  It is neither uncommon nor unrealistic for many individuals with significant disabilities to seek and obtain costly vehicle modifications or payments for the costs of college degrees from the State VR Program.  Yet, such expectations are justifiably viewed as unrealistic or beyond the scope of the capacity of ENs to address.

Many individuals with disabilities require long-term ongoing supportive services to enable them to successfully obtain and retain employment.  Long-term supports to employment are often beyond the scope of services available to consumers from the State VR agency.  Community rehabilitation providers, serving as ENs, have the expertise and staff to provide this necessary and relatively low cost on the job service to individuals with disabilities.  All that is needed is a funding mechanism.  In Massachusetts, we have developed some means by which we are able to support these activities.  However, the need is only partially met.

A Ticket payment mechanism that supports EN efforts to provide the services necessary to ensure that individuals with disabilities are able to retain employment, complimented by a VR reimbursement system funding the up front costs associated with all aspects of individuals preparing for and obtaining employment, will undoubtedly result in increased, long-term, quality employment for SSI/DI recipients who desire increased social and economic autonomy.

In Conclusion

The TWWIIA BPAO Program has been a tremendous success.  There has been positive cooperation among state and community based partners that has resulted in an impressive number of consumer referrals with a very high level of consumer satisfaction.  The reauthorization of the BPOA Program is a very positive development.

It is not the belief of the MRC that a lack of interested and qualified Employment Networks is threatening the success of the Ticket Program.  1,100 ENs is a sizeable network of service providers.  It is our belief that ENs make business decisions based upon their assessment of what is in their and their consumers’ best interests.  A Ticket Program that secures the funding base of ENs, through the preservation of the VR cost reimbursement program, and provides ENs an opportunity to expand existing services and resources, through a Ticket payment system that funds the provision of long term support services, will go a long way toward assuring the success of the Ticket Program.

Thank you again for providing the Massachusetts Rehabilitation Commission with the opportunity to share with you some of its concerns regarding the operation and improvement of the Ticket to Work Program.