SOCIAL SECURITY ADMINISTRATION

TICKET TO WORK - OPERATIONS
SUPPORT MANAGER FOR VOCATIONAL
REHABILITATION AGENCIES AND
EMPLOYMENT NETWORKS

September 2006

A-02-06-16017

AUDIT REPORT

Mission

By conducting independent and objective audits, evaluations and investigations, we inspire public confidence in the integrity and security of SSA's programs and operations and protect them against fraud, waste and abuse. We provide timely, useful and reliable information and advice to Administration officials, Congress and the public.

Authority

The Inspector General Act created independent audit and investigative units, called the Office of Inspector General (OIG). The mission of the OIG, as spelled out in the Act, is to:

Conduct and supervise independent and objective audits and investigations relating to agency programs and operations.
Promote economy, effectiveness, and efficiency within the agency.
Prevent and detect fraud, waste, and abuse in agency programs and operations.
Review and make recommendations regarding existing and proposed legislation and regulations relating to agency programs and operations.
Keep the agency head and the Congress fully and currently informed of problems in agency programs and operations.

To ensure objectivity, the IG Act empowers the IG with:

Independence to determine what reviews to perform.
Access to all information necessary for the reviews.
Authority to publish findings and recommendations based on the reviews.

Vision

We strive for continual improvement in SSA's programs, operations and management by proactively seeking new ways to prevent and deter fraud, waste and abuse. We commit to integrity and excellence by supporting an environment that provides a valuable public service while encouraging employee development and retention and fostering diversity and innovation.

MEMORANDUM

Date: September 27, 2006

To: The Commissioner

From: Inspector General

Subject: Ticket to Work - Operations Support Manager for Vocational Rehabilitation Agencies and Employment Networks (A-02-06-16017)

OBJECTIVE

Our objective was to conduct a performance review of the Social Security Administration (SSA) and its contractor MAXIMUS, Inc. to ensure contract objectives were being met and were in accordance with the Ticket to Work and Work Incentives Improvement Act of 1999.

BACKGROUND

The Ticket to Work and Self-Sufficiency Program (Ticket Program) was established by the Ticket to Work and Work Incentives Improvement Act of 1999. The Ticket Program provides eligible Disability Insurance beneficiaries and Supplemental Security Income recipients with tickets, which can be used to obtain Vocational Rehabilitation Agency (VRA) or Employment Network (EN) services. The program is intended to increase the access and quality of rehabilitation and employment services available to disabled beneficiaries. It is designed to provide beneficiaries with greater freedom and choice of service providers by creating competition among providers to offer high quality services that are responsive to beneficiary needs. The program also gives providers incentives to deliver services in the most efficient and appropriate manner to achieve desired outcomes. To date, SSA has mailed over 11.9 million tickets to disabled beneficiaries. Once a disabled beneficiary receives a ticket in the mail, he or she can assign the ticket to the VRA or EN he or she chooses to work with in an effort to return to work. As of August 4, 2006, SSA's website reported approximately 142,900 tickets have been assigned (133,000 tickets have been assigned to VRAs and 9,900 tickets have been assigned to ENs).

SSA contracted with MAXIMUS, Inc. to serve as its Ticket Program Operations Support Manager (OSM). The OSM is responsible for overseeing and supporting the processes necessary to sustain ongoing program operations. OSM performance is monitored by a Project Officer (PO) at SSA's, Office of the Disability and Income Security Programs, Office of Employment Support Programs. In this review, we looked at the OSM's performance in Calendar Year (CY) 2005, as it pertained to the tasks within the contract. We selected the following five contractual tasks related to VRAs and ENs. They are as follows:

Task 9 - Individual Work Plans
Task 10 - VRA and EN Oversight
Task 12 - Dispute Resolution
Task 13 - Periodic Outcome Reporting
Task 14 - Response to Sensitive Inquiries

Within each task, there are multiple objectives that the OSM must complete to successfully meet the task and fulfill the contract. For example, under task 12, Dispute Resolution, the OSM must: notify SSA of any disputes the OSM has with a beneficiary or an EN; resolve any disputes between beneficiaries and ENs; advise beneficiaries and ENs of mediation services available; refer to SSA disputes the OSM can not resolve; and provide summaries of all dispute resolutions to SSA.

RESULTS OF REVIEW

We found that SSA met its responsibility to oversee the contract with the OSM for the tasks we reviewed. We also found that OSM successfully met most of the contract objectives in the tasks we reviewed and was properly managing and overseeing VRA and EN activities. The OSM generally fulfilled all of the objectives related to individualized plans for employment and VRA and EN oversight (tasks 9 and 10) and most of the objectives related to dispute resolution, periodic outcome reporting, and sensitive inquiries (tasks 12, 13, and 14). The OSM could improve its management of the Ticket Program, and better assist SSA in its oversight of the contract and the Ticket Program, by providing SSA with summaries of dispute resolutions and sensitive inquiries activities (tasks 12 and 14) in the Monthly Contract Progress reports that it provides to the Agency, and by securing outcome reports from all VRAs and ENs (task 13).

TASK 12 - DISPUTE RESOLUTION

According to the contract, the OSM is responsible for facilitating resolutions for disputes between beneficiaries and ENs and SSA. Additionally, the OSM is required to provide a summary of all dispute resolution activities to SSA in Monthly Contract Progress reports. The Monthly Contract Progress reports for CY 2005 did not summarize any dispute resolution activities.

Our review of the OSM's telephone call log, which lists calls related to the Ticket Program, identified 580 dispute-related calls. The calls were coded by OSM's telephone operators as disputes between beneficiaries and ENs (398), VRAs (169) or SSA (13). Upon our inquiry, the OSM stated that all of the dispute calls were successfully resolved and did not warrant the attention of the PO. While the OSM retained detailed information on disputes in its telephone call log, it did not summarize this information in the monthly reports as required by the contract. Without the summaries of the dispute resolutions, SSA was unable to determine if the OSM properly handled the disputes.

In its response to our draft report, SSA informed us that it did not believe that the OSM was out of compliance with task 12. It stated that there were three levels of dispute resolution defined in the OSM contract. The first level is the EN internal dispute resolution process. If a dispute cannot be resolved at this level, it can be elevated to the second level, which is resolution by the OSM. If the dispute cannot be resolved by the OSM, it can be elevated to the third level, which is resolution by SSA - and SSA's decision is final. SSA stated that it was only interested in disputes that cannot be resolved by the disputing parties, thus requiring a higher level of intervention. It further stated that, to date, no dispute has ever gone past the first level; consequently, MAXIMUS has had nothing to report. It concluded that the OSM retained detailed information on disputes in its telephone call log, so the Agency could review that data in the future if it determined that a review of the lower level dispute resolution activities was needed.

TASK 13 - PERIODIC OUTCOME REPORTING

Annual Periodic Outcome Reports (APOR) by VRAs and ENs are due to the OSM no later than 30 days after the end of the CY. APORs document outcomes achieved by each VRA and EN with respect to services provided to beneficiaries and are to be made available for public access. Our review found that VRAs or ENs did not submit their APORs for CY 2005 by February 1, 2006, as required. A subsequent review through early March 2006 found that 311 of 1,455 of the VRAs and ENs (21 percent) submitted APORs during February and early March.

According to the contract, the OSM is responsible for ensuring that ENs provide public access to their APORs. Beneficiaries rely on this information to find local agencies that participate in the Ticket Program and to learn of the services they provide. If the OSM is unable to ensure public access to APORs, beneficiaries lose a source of information that may help them make an informed decision as to which agency to assign their ticket.

The OSM stated that the cause of delinquent and missing APORs was submission through the mail system, often delaying the time they reach the OSM, and/or ENs and VRAs considered this task a lower priority. Additionally, the OSM reported that most of the ENs who did not send in APORs were non-active-they have never had a beneficiary assign a ticket to them.

The OSM notified the PO of the service providers that did not submit their
CY 2005 APORs and stated that it will administer any corrective actions warranted by the PO. In addition, the OSM reported to us that it is in the process of developing a method that will allow VRAs and ENs to electronically submit APORs. This would replace the current process of relying on the VRAs and ENS to mail hardcopy reports to the OSM.

TASK 14 - SENSITIVE INQUIRIES

According to the contract, sensitive inquiries are inquiries from public officials, the President's executive staff, Congressional delegates and staff, and the news media. Upon receipt of a sensitive inquiry, the OSM is required to immediately notify the PO by telephone and then follow up electronically. The PO, in turn, advises the OSM of inquiry response actions, as needed. The OSM is also required to provide a summary and disposition of sensitive inquiries in the Monthly Contract Progress reports.

We identified 50 sensitive inquiries through our review of emails (7) and phone
calls (43) received by the OSM. Of the 50 sensitive inquiries identified, we identified written documentation for 6 that showed coordination between the OSM and the PO. We could not identify any other documentation demonstrating communication between SSA and the OSM for the remaining 44 sensitive inquiries. The OSM stated that most sensitive inquiries pertained to information requests and did not warrant the attention of the PO.

In addition, the OSM failed to notify SSA of sensitive inquiries at the time they were received, and the OSM did not provide a summary and disposition of the sensitive inquires in the Monthly Contract Progress report it provides to SSA. The failure to notify SSA of the inquiries and summarize their disposition in the monthly reports makes it difficult for the PO to ensure that sensitive inquiries are handled efficiently and effectively.
The following are examples of sensitive inquiries that we obtained from the OSM telephone call log, which were not forwarded to the PO:

March 7, 2005 - A Washington Congressman's office called regarding a letter received from a beneficiary who sought assistance to resolve a complaint with a VRA.

May 24, 2005 - The Illinois Governor's office called regarding a blind beneficiary, who had not received assistance despite repeated attempts to contact MAXIMUS.

July 29, 2005 - A California Senator's office called regarding a dispute between a beneficiary and an EN, in which the EN had not responded to the beneficiary's concerns.

CONCLUSION AND RECOMMENDATIONS

Based on the results of our review, we concluded that the OSM could take steps to fully meet its contractual obligations to SSA. By meeting all of the objectives in the tasks related to dispute resolution, outcome reporting, and sensitive inquiries, the OSM will help SSA ensure that the Ticket Program is operating effectively and that the needs of disabled beneficiaries are met as they take steps to return to work. To improve Ticket Program management and adherence to the contract, we recommend SSA:

1. Request the OSM to follow the contract requirement to provide summaries of dispute resolution activities in Monthly Contract Progress reports. (Based on SSA's response to our draft report, we withdrew this recommendation.)

2. Monitor the OSM to ensure it is actively obtaining the required APORs from VRAs and ENs.

3. Consider changing the submission process for APORs, possibly exempting non active VRAs and ENs from the requirement to submit APORs.

4. Request the OSM to timely notify the PO of sensitive inquiries and summarize the
status of all sensitive inquiries in Monthly Contract Progress reports.

AGENCY COMMENTS AND OIG RESPONSE

In its written response to our draft report, the Agency concluded that the OSM was in agreement with the contract in regards to providing summaries of dispute resolution activities in the Monthly Contract Progress reports. It found that the OSM had only handled low level disputes and that they were resolved appropriately. The Agency stated that it only had a need for information on the disputes that cannot be resolved by the disputing parties, thus requiring a higher level of intervention. It noted that the OSM retained detailed information on disputes in its telephone call log, so the Agency could review that data in the future if it later determined that a review of the lower level dispute resolution activities was in order. Accordingly, the need for the OSM to report low level dispute information in the Monthly Contract Progress reports was not warranted. Based on this information, we withdrew our first recommendation. The Agency agreed with the remaining recommendations. The full text of SSA's comments is included in Appendix C.

Patrick P. O'Carroll, Jr.

Appendices
APPENDIX A - Acronyms
APPENDIX B - Scope and Methodology
APPENDIX C - Agency Comments
APPENDIX D - OIG Contacts and Staff Acknowledgements

Appendix A
Acronyms
APOR Annual Periodic Outcome Report
CY Calendar Year
EN Employment Network
OSM Operations Support Manager
PO Project Officer
SSA Social Security Administration
Ticket Program Ticket to Work and Self-Sufficiency Program
VRA Vocational Rehabilitation Agency

Appendix B
Scope and Methodology

To accomplish our objective, we:

Reviewed the regulations for the Ticket to Work and Self-Sufficiency Program (Ticket Program) authorized by the Ticket to Work and Work Incentives Improvement Act of 1999 (20 Code of Federal Regulations, Part 411).

Reviewed Ticket Program contracts, applicable during Calendar Year (CY) 2005, between the Social Security Administration (SSA) and MAXIMUS as follows:

Contract Number 0600-00-60020 for our audit scope period January 1, 2005 through September 28, 2005.

Contract Number SS00-05-60079 for our audit scope period
September 29, 2005 through December 31, 2005.

Our review of the contracts showed that the task objectives in each that we examined did not change from one contract to the next.

Coordinated with SSA and MAXIMUS, the Ticket Program Operations Support Manager (OSM), personnel to retrieve and analyze the documentation necessary to complete our audit steps.

In addition to the steps listed above, we took the following steps for the tasks within the contract we reviewed.

Task 9 - Individual Work Plans: We selected a random sample of 200 individual work plans for employment. However, upon reviewing the first 50 in order of selection, we did not find any reportable conditions, and therefore, we are confident no findings of a substantial nature would be present in the population-at-large. We reviewed whether the OSM ensured that submitted plans were consistent with the contract requirements. Specifically, we examined the plans to determine whether the Employment Network (EN) developed the plan in partnership with the beneficiary, provided choices for the selection of an employment goal with specific services needed to achieve the goal, and that the beneficiary approved the plan and the assignment of his/her ticket.

Task 10 - Vocational Rehabilitation Agency (VRA) and EN Oversight: We selected a random sample of 200 VRAs and ENs. However, upon reviewing the first 50 in order of selection, we did not find any reportable conditions, and therefore, we are confident no findings of a substantial nature would be present in the population-at-large. We reviewed whether the OSM provided oversight to ensure that service providers complied with contractual obligations. Specifically, we examined OSM data to ensure that service providers were fully and accurately accounted for in terms of location, contact information, geographic coverage areas and services provided.

Task 12 - Dispute Resolution: We reviewed the OSM telephone call log for CY 2005. The log listed over 300,000 calls, which were coded by telephone operators. We examined the log for dispute-related codes and determined what actions the OSM took to resolve the disputes.

Task 13 - Periodic Outcome Reporting: We reviewed the Annual Periodic Outcome Reports (APOR) to determine if they were submitted timely by VRAs and ENs to the OSM. We reviewed APORs to ensure that they were completed and signed by service providers. Specifically, the reports detailed specific outcomes achieved by service providers for each beneficiary.

Task 14 - Response to Sensitive Inquires: We reviewed the OSM telephone call log for CY 2005. We examined the log to detect and analyze all calls that were categorized as "sensitive inquiries." Additionally, we reviewed sensitive inquiry emails provided by the OSM and SSA. We determined what actions were taken by the OSM and SSA to address these inquiries.

We conducted our audit at MAXIMUS in Alexandria, Virginia and at the Office of the Inspector General, New York Office of Audit, from January through March 2006. The SSA entities audited were the Office of Disability and Income Security Program's Office of Employment Support Programs, and the Office of Budget, Finance and Management's Office of Grants and Acquisitions. Our audit was performed in accordance with generally accepted government auditing standards.

Appendix C
Agency Comments

MEMORANDUM 0609-0011669

Date: September 21, 2006

To: Patrick P. O'Carroll, Jr.
Inspector General

From: Larry W. Dye /s/
Chief of Staff

Subject: Office of the Inspector General (OIG) Draft Report, "Ticket to Work- Operations Support Manager for Vocational Rehabilitation Agencies and Employment Networks" (A-02-06-16017) -- INFORMATION

We appreciate OIG's efforts in conducting this review. Our comments on the draft report content and recommendations are attached.

Let me know if we can be of further assistance. Staff inquiries may be directed to
Candace Skurnik, Director, Audit Management and Liaison Staff on extension 54636.

Attachment:
SSA Response

COMMENTS ON THE OFFICE OF THE INSPECTOR GENERAL (OIG) DRAFT REPORT, "TICKET TO WORK - OPERATIONS SUPPORT MANAGER FOR VOCATIONAL REHABILITATION AGENCIES AND EMPLOYMENT NETWORKS" (A-02-06-16017) -- INFORMATION

Thank you for the opportunity to review and comment on the draft report. We are pleased that SSA has met its responsibility to oversee the contract with the Ticket to Work Program Operations Support Manager (OSM) and that the OSM has successfully met most of the contract objectives for the tasks reviewed.

We agree that three of the four recommendations resulting from this review provide ways in which the OSM could improve its management of the Ticket to Work Program, and that implementation of these recommendations could lead to improved oversight. Also, SSA will be using the software and the database currently supported by MAXIMUS, Inc. Planned automation includes call center support that will monitor the nature and disposition of telephone inquiries, Employment Network (EN) Periodic Outcome Reports and the Dispute Resolution Process. SSA will then have full access to all Ticket to Work data and will be able to assess progress in several areas.

We disagree with recommendation 1, requesting that the OSM follow the contract requirement to provide summaries of dispute resolutions, because we do not believe that the OSM is out of compliance with this requirement. Three (3) levels of dispute resolution are defined in the OSM contract. Level 1 is the EN's internal dispute resolution process. If the dispute cannot be resolved at this level, it can be elevated to level 2, resolution by the OSM. If the dispute cannot be resolved by the OSM, it can be elevated to level 3, SSA - and SSA's decision is final. While we appreciate OIG's concern that, without summaries of the dispute resolutions, SSA is unable to determine if the OSM properly handled the disputes, the Agency is only interested in disputes that cannot be resolved by the disputing parties, thus requiring a higher level of intervention. To date, no dispute has ever gone past the first level; consequently, MAXIMUS has had nothing to report. Accordingly, we believe MAXIMUS, Inc. is in compliance with the requirements of Task 12 (Dispute Resolution). Finally, should the Agency later determine that a review of the lower level dispute resolution activities is in order, the OSM has retained detailed information on disputes in its telephone call log, as stated in the report.

Our specific responses to the report's recommendations are provided below.

Recommendation 1

Request the OSM to follow the contract requirement to provide summaries of dispute resolution activities in Monthly Contract Progress reports.

Response:

We disagree. We do not believe that the OSM is out of compliance. As noted above, we believe MAXIMUS is in compliance with the requirements of Task 12 (Dispute Resolution). The intent of the requirement is that the OSM summarize in the monthly report only those disputes elevated beyond the EN internal dispute resolution process to the OSM level. To date, no dispute has gone past level 1 and, therefore, MAXIMUS has had nothing to report.

Recommendation 2

Monitor the OSM to ensure it is actively obtaining the required Annual Periodic Outcome Reports (APOR) from Vocational Rehabilitation Agencies (VRA) and ENs.

Response:

We agree. While SSA agrees that MAXIMUS has not been obtaining all of the required APORs from ENs and State VRAs, this lack of success has not been for lack of effort on their part. The current process is simple. MAXIMUS generates the APORs for every EN and State VRA using information available in the system and forwards the reports to them for verification/concurrence. For reasons cited in the audit report, there has been little incentive or sense of urgency for ENs/State VRAs to respond to MAXIMUS. As explained in our response to recommendation 3 below, SSA has reexamined the current process and will take steps to ensure that an APOR is in place for every EN and State VRA.

Recommendation 3

Consider changing the submission process for APORs, possibly exempting non active VRAs and ENs from the requirement to submit APORs.

Response:

We agree. Although not finalized, SSA plans to revise the submission process. Under the new process, MAXIMUS will continue to generate the APORs and request verification/concurrence by the ENs and State VRAs. For those organizations that do not respond, MAXIMUS will assume acceptance. SSA does not believe it is advisable to exempt inactive ENs or State VRAs since inactivity, in itself, is an outcome of which the public should be aware. The Ticket to Work Program is market-driven. If Ticket holders begin avoiding those ENs that are inactive, those ENs will be forced to better market their services or fall by the wayside.

Recommendation 4

Request the OSM to timely notify the Project Officer (PO) of sensitive inquiries and summarize the status of all sensitive inquiries in Monthly Contract Progress reports.

Response:

We agree. We believe this issue has more to do with SSA clearly defining what constitutes a "sensitive" inquiry than MAXIMUS' failure to comply with contract requirements. Sensitivity is not defined solely by the origin of the inquiry, but by the nature of the inquiry and level of effort required to respond. Generally speaking, MAXIMUS forwards all media requests to SSA because MAXIMUS is not contracted to speak for the Agency. However, congressional or other high-level inquiries that can be resolved through a simple action, e.g., sending out a brochure or contacting a beneficiary, are not in themselves sensitive because they originated with a congressional or other high-level office. The intent of the requirement of Task 14 (Sensitive Inquiries) is that the OSM refer to SSA (and subsequently document) only those inquiries whose nature and response level is truly sensitive, requiring an extraordinary degree of attention. We will review with MAXIMUS the requirements of this task, and clearly define our expectations to ensure that all truly sensitive inquiries are referred to us in a timely manner and fully documented in the monthly contract progress report.

Appendix D
OIG Contacts and Staff Acknowledgments
OIG Contacts
Tim Nee, Director, New York Office of Audit, (212) 264-5295
Vicki Abril, Audit Manager, New York Office of Audit, (212) 264-0504

Acknowledgments
In addition to those named above:
Abraham Pierre, Auditor
Denise Molloy, Program Analyst
Brennan Kraje, Statistician
Annette DeRito, Writer-Editor
Cheryl Robinson, Writer-Editor

For additional copies of this report, please visit our web site at www.socialsecurity.gov/oig or contact the Office of the Inspector General's Public Affairs Specialist at (410) 965-3218. Refer to Common Identification
Number A-02-06-16017.

Office of Audit
OA conducts and/or supervises financial and performance audits of the Social Security Administration's (SSA) programs and operations and makes recommendations to ensure program objectives are achieved effectively and efficiently. Financial audits assess whether SSA's financial statements fairly present SSA's financial position, results of operations, and cash flow. Performance audits review the economy, efficiency, and effectiveness of SSA's programs and operations. OA also conducts short-term management and program evaluations and projects on issues of concern to SSA, Congress, and the general public.

Office of Investigations
OI conducts and coordinates investigative activity related to fraud, waste, abuse, and mismanagement in SSA programs and operations. This includes wrongdoing by applicants, beneficiaries, contractors, third parties, or SSA employees performing their official duties. This office serves as OIG liaison to the Department of Justice on all matters relating to the investigations of SSA programs and personnel. OI also conducts joint investigations with other Federal, State, and local law enforcement agencies.

Office of the Chief Counsel to the Inspector General
OCCIG provides independent legal advice and counsel to the IG on various matters, including statutes, regulations, legislation, and policy directives. OCCIG also advises the IG on investigative procedures and techniques, as well as on legal implications and conclusions to be drawn from audit and investigative material. Finally, OCCIG administers the Civil Monetary Penalty program.

Office of Resource Management
ORM supports OIG by providing information resource management and systems security. ORM also coordinates OIG's budget, procurement, telecommunications, facilities, and human resources. In addition, ORM is the focal point for OIG's strategic planning function and the development and implementation of performance measures required by the Government Performance and Results Act of 1993.