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Committee on Ways and Means
Utah State Office of Rehabilitation
Salt Lake City, Utah 84114
April 1, 2004
Committee on Ways and Means
U.S. House of Representatives
1102 Longworth House Office Building
Washington D.C. 20515
Dear Honorable Congressmen E. Clay Shaw Jr. and Members of
the Subcommittee,
In regard to the March 18th Hearing on the Social
Security Administrations management of the Ticket to Work program, we
respectfully provide the following input.
We applaud the efforts of Congress and Social Security to
create work incentives for individuals with disabilities. These new provisions
have created countless opportunities for individuals who otherwise would not
have engaged in work activity. We respect an individual’s right to choose how
and whether rehabilitation services will be provided. Furthermore, we support
the efforts of Congress, the Social Security Administration and the Ticket to
Work Advisory Panel to make improvements to the Ticket to Work program. It is
due to our interest in helping make this program a viable and affable program
for beneficiaries and Employment Networks (EN’s) (including State Vocational
Rehabilitation Agencies), that we want to ensure Congress have access to
accurate information regarding states implementation of the Ticket to Work
program.
Many of the concerns regarding the Ticket to Work program
have been well documented over the past two years. Others have not. The Utah
State Office of Rehabilitation (USOR) agrees with the recommendations made
recently by the Ticket to Work Advisory Panel. The problems associated with low
EN participation have been attributed to the high amount of risk involved in
assigning tickets with little or no hope for claiming any payment from Social
Security. However USOR feels that EN participation has not been affected in
the manner espoused by Mr. Seifert. In Paul Seifert’s testimony, he asserts
that “State VR agencies have developed stand alone, take it or leave it one
size fits all agreements for EN’s in their states”. He further asserts that
these agreements “require full and total repayment of all of VR’s costs”. In
the state of Utah, we have conducted focus groups with our EN’s to explore the
fairness of our draft agreement. The Employment Networks were given a draft
copy of the agreement and encouraged to make comments. We have maintained the
position that EN’s in our state are not obligated to sign any agreement, and we
have encouraged them to draft their own agreements for our consideration.
Furthermore, we have conducted countless focused training sessions in
conjunction with our Area Work Incentive Coordinator to ensure that EN’s were
up to date on the provisions of the Ticket to Work legislation and to empower
them to draft their own agreements. We held our own
“EN recruitment” symposium and dedicated almost ½ day to
discuss creative partnerships. Despite our
outreach efforts and openness to creative partnerships, none
of the EN’s have submitted an EN agreement for our consideration and have
unanimously agreed to sign the agreement posed by our agency.
The reasons cited by the EN’s remain consistent with earlier
and well documented implementation issues with the Ticket to Work program. The
EN’s in Utah are afraid of the financial risk involved in accepting tickets,
with or without VR as a partner. The EN’s in Utah including USOR meet
periodically to discuss ticket issues and to provide general support to each
other. At all times, this has been done in a spirit of cooperation and
collaboration, not just between USOR, but also among all seven of the Utah
EN’s. On one occasion, one of the EN’s called the Ticket to Work coordinator at
USOR to ask her technical assistance in assigning a ticket to his EN. She
walked him through the process of how he could assign a ticket to his company.
In the end, the EN made the decision not to accept the ticket, and referred the
individual to VR because he felt that the administrative work associated with
the ticket was burdensome. Our state has worked hard to create a healthy
working relationship with Employment Networks, and to emphasize the importance
of those relationships in our own staff training.
Frankly, we are offended by Mr. Seifert’s testimony to the
contrary.
In further testimony, Paul Seifert criticizes the state VR
agencies who failed to register tickets in a timely fashion, with the
unfortunate circumstance of benefits being reduced (and later restored) for a
beneficiary. We would just like to assure Congress as well as Mr. Seifert that
our state database system allows us to track where all our tickets are during
the entire assignment process. We have created an electronic system of
completing the SSA1365 form and recording when the ticket is actually assigned
by Maximus thereby hoping to alleviate any of the potential problems mentioned
in testimony.
Finally, Mr. Seifert addresses transmittal 17. The Utah
State Office of Rehabilitation shares concern over this policy decision made by
the Social Security Administration. Informed Consent has been a guiding force
in our daily operations prior to Ticket to Work, and remains integral to our
Ticket policy and procedure today.
During the first two years of the Ticket Implementation
process I chaired the Council of State Administrations of Vocational
Rehabilitation (CSAVR) Committee on Social Security Relationships. The committee
had numerous meetings with SSA, RSA and others to identify issues and seek
solutions regarding implementation problems associated with the Ticket to Work
and Work Incentives Act. Quarterly teleconferences were held between the
states currently implementing the ticket, CSAVR, RSA, and SSA to determine how
the ticket was being implemented and to provide technical assistance. In
addition CSAVR, SSA and RSA sponsored national training conferences prior to
each group of states that were implementing the Ticket program. Even before
the ticket program began, CSAVR was providing input to SSA and Congress
regarding these issues. In the last four years, upper management from SSA and
Maximus have participated in every CSAVR conference.
Contrary to Mr. Seifert’s testimony, it has been my
observation that State VR agencies have bent over backwards to assist in the
development of the ticket program. Yes, a few states have made some mistakes which have been corrected. In the final analysis
the Ticket program would be dead in the water without the State VR agencies.
The State of Utah is still in early implementation phase.
There have only been 11,698 tickets mailed thus far, with 72 tickets assigned. Utah,
like other states has made great preparations for this program. We are hopeful
that measures will be taken to ensure the success of this program. We support
the recommendations made by the Adequacy of Incentives Advisory Committee and
as well, the Ticket to Work Advisory Panel recommendations. We urge Congress to
seek input from all states regarding Ticket to Work Implementation. The Ticket
to Work and Work Incentive Improvement Act holds much potential for job seekers
with disabilities, but to realize the potential of this program we must work
together to overcome the barriers rather than pointing fingers. The Utah
State Office of Rehabilitation is committed to working with Congress and the
Social Security Administration in realizing the potential of this important
program.
Respectfully,
Blaine Petersen
Executive Director
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