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Frequently Asked Questions
Ticket to Work Questions and Answers
Distribution of Tickets
QUESTION: With the new regulations in effect, will Tickets be mailed to everyone who is eligible to participate in the Ticket to Work program, or will they only be mailed to individuals being determined eligible for disabilities benefits and beneficiaries previously classified as medical improvement expected (MIE).
QUESTION: Will a beneficiary whose VR case was closed within the past year receive a new Ticket, if s/he qualifies, and be able to assign the Ticket to an EN to receive follow-along services?
ANSWER: If the beneficiary is still receiving cash benefits, s/he will still have a Ticket in effect; therefore there is no need to issue a new Ticket. Phase 2 Milestone and Outcome payments could still be available to the EN if the beneficiary reaches the earnings levels required for those payments. However, to be certain, the individual case circumstances would have to be reviewed.
QUESTION: What qualifications must an applicant have to become an EN? Where do entities interested in becoming ENs apply?
ANSWER: An EN may be any public or private entity, so long as the EN assumes responsibility for the coordination and/or delivery of employment, vocational rehabilitation or other support services to Ticket Holders to help them achieve their employment goals. An EN may be an agency, an organization, a consortium of organizations, or an individual. For example, agencies or individuals that have been Medicaid-waiver certified as supported employment providers in the State of Florida would meet the specific qualification requirements for becoming ENs. There are two exclusions that apply to becoming an EN. (1) Federal agencies are precluded from being ENs and (2) a Ticket-eligible beneficiary may not serve as an EN to him/herself.
The qualifications for becoming an EN are discussed in Part II--Section 1 of the EN Request for Proposals (RFP). The RFP is available for downloading from SSA's website, www.ssa.gov/work or by going to http://www.ssa.gov/work/enrfp.html. . Completed EN proposals should be submitted to SSA's EN Contracts Team (ENCT), not MAXIMUS. For assistance in responding to the EN RFP and completing an EN proposal, prospective ENs are encouraged to contact the ENCT by telephone (toll-free at 866-584-5180) or by email at ENcontracts@ssa.gov.
QUESTION: How will One-Stop Career Centers enter into agreements with SSA to become ENs? Section 411.310(d) of the final regulations states that “One-stop delivery systems established under subtitle B of title I of the Workforce Investment Act of 1998 (29 U.S.C. 2811 et seq.) may participate in the Ticket to Work program as ENs and do not need to respond to the RFP. However, in order to participate in the Ticket to Work program, the one-stop delivery system must enter into an agreement with the Commissioner to be an EN and must maintain compliance with general and specific selection criteria as described in Section 411.315 in order to remain an EN.
ANSWER: One-Stop Delivery Systems must enter into a contract with SSA in order to become an EN. The EN RFP explains the requirements for becoming an EN, as well as the duties and responsibilities of being an EN. The language found in the RFP forms the basis of the eventual EN contract. That is why a One-Stop Center must become familiar with the contents of the RFP. To become an EN contractor, a One-Stop must comply with the requirements spelled out in the RFP, some of which require a written response. SSA has simplified this process.
SSA has pre-qualified One-Stop Centers to be ENs. That means they have been deemed to have met the qualification requirements found in Part II--Section 1 of the RFP and need not submit any documentation of qualifications.
To become an EN, a One-Stop need only complete and submit to SSA a 12-page portion of the RFP found in Part III--EN Proposal Documentation Requirements. This completed documentation constitutes the One-Stop's EN contract proposal and provides the information that MAXIMUS will put on its web site (http://www.yourtickettowork.com) to advertise to beneficiaries that the One-Stop is an approved EN and the information that MAXIMUS needs to direct deposit EN payments into the One-Stops back account.
The EN RFP is available for downloading from SSA's website, www.ssa.gov/work or by going to http://www.ssa.gov/work/enrfp.html. One-Stops interested in becoming ENs are encouraged to contact SSA's EN Contract Team by telephone toll free at 866-584-5180 or by email at ENcontracts@ssa.gov for assistance in completing the required documentation.
QUESTION: Will American Indian Vocational Rehabilitation programs authorized under Section 121 of the Rehabilitation Act have the ability to get reimbursement under the Cost Reimbursement program?
ANSWER: No. The revised Ticket regulations do not make any changes to the traditional Cost Reimbursement program. As in the past, only State VR agencies are eligible to participate in the traditional Cost Reimbursement program.
QUESTION: Do “gross earnings” mean earnings before Impairment Related Work Expenses (IRWE) deductions? Or, does it just refer to earnings before taxes?
ANSWER: Gross earnings mean earnings before IRWE deductions and before taxes.
QUESTION: To submit for the first Phase 1 Milestone, does a beneficiary need to earn $335 in a two week period or within one month?
ANSWER: A beneficiary must earn $335 in one month for an EN to qualify for the first Phase 1 Milestone.
QUESTION: Does the Trial Work Period threshold (i.e., $670 in 2008) that qualifies an EN for the Phase 1 Milestones apply to blind beneficiaries?
ANSWER: The Trial Work Period (TWP) threshold is subject to an annual adjustment. SSA uses only one annual TWP dollar amount. It is the Substantial Gainful Activity (SGA) amount that has an annual blind and non-blind amount. The non-blind SGA amount for 2008 is $940 and the blind amount is $1570.
QUESTION: Is $940 the SGA level for SSI and $1,570 the SGA level for SSDI?
ANSWER: No. The Substantial Gainful Activity (SGA) amount has an annual blind and non-blind amount. The non-blind SGA amount for 2008 is $940 and the blind amount is $1570. For the purpose of determining Ticket payments, these SGA amounts are used the same for both SSI and SSDI beneficiaries.
QUESTION: Please explain the recent work rule and provide a scenario of someone who was working in the 18 months prior to Ticket assignment. Please break down all situations and explain when each corresponding Phase 1 payment would not be available.
ANSWER: Phase 1 Milestones may not available to an EN if, during the 18 months prior to the beneficiary first assigning his/her Ticket, the beneficiary worked and had earnings at a level equal to or above the amount designed as the Trial Work Period (TWP) level earnings for that year. The Phase 1 Milestone payment would be unavailable to the EN because the EN did not incur the cost of helping the beneficiary achieve that particular level of earnings. The chart below shows the level of work as described in 411.535(a) that would prevent the payment of each of the four Phase 1 Milestones.
Although the criteria used to determine the availability of the Phase 1 Milestones based on a beneficiary’s recent work history are patterned after the criteria used to determine the attainment of the four Phase 1 Milestones, the criteria used in the recent work rule are not cumulative. Rather, each criterion should be applied independently. Thus, if a beneficiary worked with TWP level earning during 3 of the 6 months just prior to Ticket assignment but this work did not include the month just prior to Ticket assignment, the first Phase 1 Milestone would be available to the EN when the beneficiary attained the required levels of work and earnings; however the second Phase 1 Milestone would not be available. Similarly, a beneficiary who worked 9 of the last 18 months just prior to Ticket assignment, with earnings at the TWP level, might be eligible for 3 of the Phase 1 Milestones or none, depending on where the 9 months fell within the 18 month period. The example below provides an idea of how the recent work rule works. The recent work rule does not apply to Tickets assigned prior to July 21, 2008.
The recent work rule applies only to the Phase 1 Milestones. Phase 2 Milestones are available to an EN when a beneficiary attains the necessary levels of work and earnings prior to commencement of the Outcome payment period, or if after that, as part of the reconciliation payment.
Recent Work Example: A beneficiary decides to participate in the Ticket to Work Program and assigns her Ticket to an EN. During the interview to develop the Individualized Work Plan (IPE), a representative of the EN talks to the beneficiary about her work history during the 18 months prior to assigning her Ticket to the EN in August 2008. The beneficiary explains that she worked 9 of the last 18 months, but the work was somewhat irregular. The months that she worked are indicated below.
2007 ___ _____ 2008____________________________ Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug N Y Y Y Y Y N Y N N N N Y N Y Y N N TA
The Ticket was assigned (TA) in August 2008. The first Milestone would be available to the EN since the beneficiary did not work in July 2008, the month immediately prior to Ticket assignment.
The second Milestone would not be available to the EN because the beneficiary worked 3 of the six months just prior to Ticket assignment (i.e., Feb, Apr and May of 2008).
The Third Milestone would be available to the EN because the beneficiary only worked 4 of the 12 months immediately prior to Ticket assignment (i.e., Sept. 2007 and Feb, Apr and May of 2008).
The fourth Milestone would not be available to the EN because the beneficiary worked 9 of the 18 months immediately prior to Ticket assignment (i.e., Mar, Apr, May, Jun, July and Sept of 2007 and Feb Apr and May of 2008).
MAXIMUS has created an electronic tool that can be used to explore the work and earnings history of a beneficiary and estimate the availability of each of the four Phase 1 Milestones for that particular beneficiary. Visit the MAXIMUS web site and check this tool out: www.yourtickettowork.com.
QUESTION: For evidence requirements for payment, SSA lists “original pay stubs” as primary evidence, and for secondary evidence “photocopies” of pay stubs plus a second source such as a signed beneficiary statement, state unemployment records, or Federal/state tax returns. Does this mean SSA will no longer accepted photocopies of pay stubs as primary evidence?
ANSWER: This is correct because SSA has more closely aligned its earnings-related evidentiary requirements for EN payments with earnings-related evidentiary requirements used by SSA for other purposes.
QUESTION: Are there any restrictions on when an EN can use primary and secondary evidence of work and earnings in submissions for EN payments?
ANSWER: No, there are no restrictions. Primary evidence (e.g., pay stubs and/or an earnings statement prepared and signed by the employer) or secondary evidence (e.g., State Unemployment Insurance data) of work and earnings can be used when submitting payment requests for any EN payments. However, when submitting secondary evidence, two sources are required. (Section 411.575 C)
QUESTION: How will EN payments be handled for a beneficiary whose Tickets were assigned prior to the effective date of the new regulations? How will these cases differ depending on whether or not Milestone and Outcome payments were made under the prior regulations? Will it be financially beneficial for an EN to un-assign a Ticket that received payments under the prior regulations and re-assign it after the new regulations take effect?
ANSWER: The new EN payment schedule and rates will apply to any EN payment made for work attained after the effective date of the new regulation. This means that cases on which a payment was attained before the effective month of the new regulations, which are referred to as “transition cases,” and new Ticket cases (i.e. cases on which no payment was attained before the new regulations were in effect) may benefit from the new EN payment system schedule for work attained beginning with the effective date of the regulations. Un-assigning and re-assigning a Ticket would have no meaningful purpose since the work attained beginning July 21, 2008 qualifies for payment under the new EN payment schedule and rates for the EN payment system in effect for that particular Ticket Holder.
QUESTION: Please explain how SSA will handle Ticket payments on beneficiaries who had attained work and earnings that had triggered Outcome payments prior to the effective date of the new regulations.
ANSWER: The dollar amount for Outcome payments differ depending on the EN payment system under which the Outcome payment is being paid. Under the new Outcome/Milestone payment system, the amounts are $353 for SSDI and $203 for SSI. Under the new Outcome payment system, the amounts are $657 a month for SSDI and $377 a month for SSI. These dollar amounts are for transition cases and new cases on EN payment requests for earnings attained beginning with the effective date of the new regulation.
QUESTION: SSA will only accept payment requests for Milestones and Outcomes attained under the prior rules until 3/31/09, or until SSA makes the first payment on a Ticket under Section 411.525. If an EN submitted a payment request and got paid under the new rules and then found out later based on an Earnings Inquiry Request or other secondary sources that Milestones or Outcomes should have been paid under the prior rules, would the EN get paid for those prior Milestones and Outcomes?
ANSWER: The 3/31/09 date only applies to the timeframe allowed to submit payment requests for work attained prior to the effective date of the regulation. There currently is no timeframe by which you must request ongoing payments in general; therefore, for now you may request payments for work attained beginning with the effective date of the new regulations at your own pace. We will make a payment for any month(s) for which you qualify regardless of the sequence of the months in which you request payments.
Concerning qualifying work attained under the prior payment system that is not paid before we process the first payment under the new payment system - Once we make the first payment under the new payment schedule and rates, we cannot make a payment under the prior payment schedule and rates. Section 411.551 explains why. However, any payment that you don't receive under the old rates will be available to you at the new higher rate if the beneficiary continues to work at a level that justifies payments.
QUESTION: According to Section 411.175, a beneficiary whose Ticket was in use before SSA determined that the beneficiary was no longer disabled, may continue to receive benefit payments, in certain circumstances. What are these circumstances?
ANSWER: In accordance with the other SSA regulations referenced in 411.175, a Ticket Holder who receives a decision that benefits will cease because his/her health has improved may apply for benefit continuation on the basis of being in a program of Vocational Rehabilitation with an EN or a State VR agency, or because s/he has a Plan to Achieve Self-Sufficiency (PASS) or a few other reasons. If SSA finds that the program increases the likelihood that the beneficiary will remain off the benefit rolls, the beneficiary may be awarded benefit continuation until his/her program of Vocational Rehabilitation is completed.
QUESTION: How does a beneficiary put his/her Ticket into "inactive status" with MAXIMUS?
ANSWER: A beneficiary who is working with an EN or a State VR agency under cost reimbursement may have his/her Ticket placed in “inactive status” at any time by submitting a written request to MAXIMUS, asking that the Ticket be placed in “inactive status.” “Inactive status” will begin with the first day of the month following the month MAXIMUS receives the request. The beneficiary will be subjected to a medical Continuing Disability Review during those months if his/her case becomes due one. (See 411.192)
ANSWER: The new regulations simplify the documentation and timely progress review reporting requirements. However, as a last resort, MAXIMUS will ask the EN or State VR agency to certify a beneficiaries' progress, although they will not require an EN or State VR agency to provide evidence of a beneficiaries' progress. MAXIMUS will use a multi-list format to allow ENs and State VR agencies to respond “yes” or “no” to whether each beneficiary on the list has met certain work, education or technical training requirements.
QUESTION: Please define and clarify the various percentage requirements for college and vocational school training programs to be counted as timely progress. Specifically, what is 60% of a full-time course load? What is 75%? Will SSA provide examples?
ANSWER: Educational institutions or technical or trade schools inform students what constitutes a full-time course load for a particular institution. Once the number of credits that constitute a full-time course load is identified, the percentage of that number can be calculated. For example, if the full-time course load is 12 credits, 60 percent of 12 is 7 and 75 percent of 12 is 9. (Always round down to the nearest whole credit).
QUESTION: Is the Ticket assignment process the same for VR agencies and, if so, when will the new forms be sent out? Will they be available electronically?
ANSWER: The Ticket assignment process is the same. The SSA 1365, State Agency Ticket Assignment Form, is also the same. The difference is that the form will only be used when the State VR agency is operating as an EN with the Ticket assigned, not when the agency chooses the cost reimbursement payment option.
ANSWER: For cost reimbursement cases, the State VR agency need only indicate that the case is open and the date it opened. SSA is piloting electronic formats for MAXIMUS to receive this information as well as case closure information from State VR agencies.
ANSWER: A working draft of the revised VR Provider Handbook was disseminated to interested parties in July 2008. Comments were due by August 15th. The final draft, which will be available electronically, should be distributed in mid-September 2008.
ANSWER: A beneficiaries who works with a State VR agency that chooses to serve him/her under the Cost Reimbursement program would be able to use his/her Ticket with an EN once the State VR agency closes the beneficiary’s case. If the beneficiary is working when the State VR Agency closes his/her case, the EN to which the beneficiary assigned his/her Ticket would be able to receive Phase 2 Milestone and Outcome payments as the beneficiary attained the required levels of work and earnings.
QUESTION: If a VR agency that has elected the Outcome/Milestone payment option chooses to serve a beneficiary as an EN and VR is actively working with that beneficiary under an Individualized Plan for Employment, and if the beneficiary decides to discontinue services with VR and VR closes the beneficiary’s cases, how long does the beneficiary have to start reaching the levels of work and earnings that will trigger Milestone and Outcomes payments once the Ticket has been re-assigned to an EN? Also, does the beneficiary still have to be receiving service from the EN when s/he starts reaching the levels of work and earnings that trigger Milestone and Outcome payments?
ANSWER: The ability to begin working and/or increasing their earnings will vary from beneficiary to beneficiary. Under the Ticket to Work program there is no established timeframe in which a beneficiary must reach certain Milestones and Outcomes for the sake of participating in the program. However, there are established levels of work, education and/or technical training that a beneficiary is expected to attain each year to be considered to be making “timely progress” which is necessary to continue the suspension of medical Continuing Disability Reviews (see 411.180 (c)).
There also is no requirement for a beneficiary to remain in service with an EN for the EN to be eligible to receive EN payments. A beneficiary may un-assign his/her Ticket at any time. Nevertheless, an EN may be paid for helping a beneficiary reach work-related Milestones and/or Outcomes attained during the Ticket assignment and after the EN no longer has the Ticket assignment provided the EN can show that the services it provided contributed to the beneficiary’s attainment of the levels of work and earnings that trigger the Milestone and/or Outcome payments (see 411.581).
QUESTION: If an EN is tracking a beneficiary that it previously served and learns that that beneficiary eventually went to work and reached the levels of work and earnings necessary to trigger Milestone and/or Outcome payments, can the EN collect the EN payments even though the EN is no longer serving that beneficiary?
ANSWER: Upon receiving a payment request, MAXIMUS will make a decision about whether an EN that formerly had the beneficiary’s Ticket assignment provided services that contributed to the beneficiary's attainment of levels of work and earnings that triggered Milestone and/or Outcome payments (see 411.581). If more that one EN is requesting the same payment(s), MAXIMUS will determine the allocation of payment to each EN based on the contribution of services of each EN (see 411.560
ANSWER: A beneficiary may re-assign his/her Ticket to an EN, including a State VR agency (acting as an EN), with which the beneficiary formerly assigned the Ticket. However, only those Milestone and Outcome payments initially available and not yet paid when the Ticket is re-assigned would be available for payment once the beneficiary attained applicable levels of work and earnings. Because the VR agency had previously held the Ticket as an EN, it would not be able to receive Cost Reimbursement from SSA if it later serves the beneficiary under Cost Reimbursement.
QUESTION: Describe the policies and procedures that VR will be required to use to inform MAXIMUS when an IPE is signed, and when a beneficiary’s VR case is closed. How frequently will this information need to be submitted (monthly or quarterly)?
ANSWER: For Cost Reimbursement cases, procedures are being developed to accommodate MAXIMUS periodically receiving an electronic file listing beneficiaries whose cases were opened and closed by the State VR agency, and the dates of these actions. There two important reasons for reporting this information: 1) to ensure that these beneficiaries are placed in the new “in-use SVR” status that affords them the same protections against medical Continuing Disabilities Reviews as beneficiaries who have their Tickets assigned; and 2) to have the names of these beneficiaries removed from the list that MAXIMUS maintains identifying beneficiaries with Tickets available for assignment. Consequently, it is important for this information to be reported as frequently as possible (monthly if at all possible). SSA is working to develop an efficient process for State VR agencies to send updated files monthly.
ANSWER: Yes. As in the past, VR can choose on a case-by-case basis whether to serve a beneficiary under the traditional Cost Reimbursement program or as an EN under the Ticket to Work Program. If VR chooses to serve a beneficiary under the Cost Reimbursement program, the new option for VR and an EN to provide sequential, but not concurrent services, comes in to play. VR can provide the up front services the beneficiary needs to get to work and, after the VR case is closed, the beneficiary can assign his/her Ticket to an EN for job retention or ongoing support services. If the beneficiary gets to net earnings (after deductions for impairment related work expenses, etc.) above SGA for 9 out of 12 months, the VR agency can submit for Cost Reimbursement. As soon as the beneficiary's earnings get to the gross SGA level (i.e., without deducting any work incentives), the EN can start submitting requests for Phase 2 Milestones. When the beneficiary's net earnings are above SGA and the beneficiary is placed in zero cash benefit status, the EN can start submitting for Outcome payments. The Phase 1 Milestones are not available to the EN if VR closed the case with the beneficiary in employment. This is because the VR agency provided the services that got that beneficiary into employment and SSA only pays for Milestones and Outcomes achieved after Ticket assignment. In a couple of states, VR is planning to reimburse ENs for some or all of the Phase 1 Milestones based on the assumption that the job retention or ongoing support services contributed to the beneficiary's success in getting to 9 months of net SGA earnings, at which time VR is able to submit for Cost Reimbursement.
If VR decides to serve a beneficiary as an EN, the idea of two ENs (VR and another EN) sharing the Milestone and Outcomes payments based on the services each provided is still an option. However, in this case, VR would not be able to submit for Cost Reimbursement.
QUESTION: When VR is working with a beneficiary and functioning as an EN under the Ticket program, will the SSA-1365 form still be the reporting mechanism that VR will use to secure Ticket assignment?
ANSWER: Under the new regulation, the SSA-1365, State Agency Ticket Assignment Form, should be used when the State VR agency is operating as an EN. SSA is developing procedures to be used to notify MAXIMUS when the State VR agency opens a case and plans to serve a beneficiary under the traditional Cost Reimbursement program. When a VR agency is planning to serve a beneficiary under the traditional Cost Reimbursement program, the SSA-1365, State Agency Ticket Assignment Form, should not be used. Procedures are being developed to accommodate MAXIMUS periodically receiving an electronic file listing beneficiaries whose cases were opened and closed and the dates of these actions.
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Last reviewed or modified Wednesday Sep 10, 2008