Tennessee Division of Rehabilitation Services
Nashville, Tennessee 37248
April 1, 2004

The Honorable E. Clay Shaw, Jr.
Chairman
Subcommittee on Social Security
U.S. House of Representatives
1102 Longworth House Office Building
Washington, DC20515

Dear Chairman Shaw:

On March 18, 2004, the Subcommittee on Social Security held a hearing on the Social Security Administration’s Management of the Ticket to Work Program.  The Division of Rehabilitation Services (DRS), with Tennessee Department of Human Services, would like to submit written comments for the hearing record in rebuttal to testimony presented by Mr. Paul J. Seifert, with the Social Security Task Force, Consortium for Citizens with Disabilities.

Staff Training on the Ticket Program

Tennessee DRS State Office staff has traveled the state training its field counselors on the Ticket to Work Program.  The agency also trains all new Vocational Rehabilitation (VR) Counselors on the Ticket to Work Program as part of its New Counselor’s Training.  Additionally, the agency often and regularly communicates to its staff updated and important information on this subject.

Informing SSA Beneficiaries of the Ticket Program

A couple of months before the Ticket to Work Program was to be implemented in Tennessee, the agency sent out thousands of letters to its SSI/SSDI clients informing them of the forthcoming Ticket Program.  The letter explained the program and pointed out that this new program was soon to start up in Tennessee.  Clients were told that they may be getting a “ticket” to use to help enable them to get employment.  Clients were told about the options they would have in choosing service providers, as well about the CDR benefit in using the Ticket.

The Agreement with Employment Networks

The agency has a standard Employment Network agreement that is applicable to all those ENs who wish to partner with the agency.  There are currently five such agreements in place in Tennessee.  No EN has voiced any concern to the State Office about the contents of this Agreement.

According to the Ticket to Work regulations, if an EN holds a ticket on an individual that they want to refer to a state VR agency, they must first have an agreement in place with that agency.  The agency’s agreement with ENs allows these referrals to be made under the ticket rules.

As partners under the agreement, the Ticket Program lets the EN and the state VR agencies decide how they wish to share the Ticket payments from SSA.

Tennessee’s agreement with their EN partners lets the state VR agency recover monies it spends in serving the EN referrals.  The money comes through a percentage of the periodic payments the EN gets from SSA via the EN payment system.  This way, the EN always gets a portion of the SSA payment and the state VR agency gets a portion up until the state VR agency recovers its actual costs in serving the individual.  The state VR agency receives no monies above its actual costs. 

A Possible Solution

Most state VR agencies across the nation would possibly welcome the recommendation of the Adequacy of Incentives Work Group -- i.e., that cost reimbursement be made to state VR agencies separately from the Ticket Program, with the Ticket money going to ENs serving the beneficiary.  In his testimony, Mr. Seifert seems to support this recommendation.  This solution lets state VR agencies recover their costs and lets ENs receive money via the Ticket Program.

Sincerely,

Carl Brown
Assistant Commissioner