Ticket to Work Questions and Answers

Distribution of Tickets
Ticket Assignment
Employment Networks
Entities Deemed Automatically Qualified to Be ENs
Employer as an EN
EN Payments
Self-Employment
Recent Work Rule
EN Payment Process and Procedures
Transition to the New Payment Schedules
Questions about Beneficiaries
Timely Progress
General VR Questions
Partnership Plus: Sequential Services from VR and then an EN
EN-VR Referral Agreements
VR Data Reporting and Collection

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)?

ANSWER:  New Tickets will not be sent routinely to beneficiaries who previously received one.  New Tickets will be mailed to beneficiaries who previously had not received a Ticket due to the medical improvement expected (MIE) provisions.  The delivery of those Tickets is scheduled for December 2008 through February 2009.  Tickets will also be sent to all new disability beneficiaries, ages 18 through 64, as they are determined eligible for benefits on a flow basis.  However, it is important to remember that a beneficiary does not need to have the paper Ticket in hand to participate in the Ticket program.  Any beneficiary interested in pursuing services and supports to go to work should contact MAXIMUS at 1-866-YOURTICKET (1-866-968-7842) or TDD at 1-866-TDD2WORK (1-866-833-2967) to verify his/her Ticket eligibility.

QUESTION: How and when will a beneficiary be informed that he or she has a Ticket?

ANSWER: When a person is determined eligible for SSDI and/or SSI benefits, she/he will receive a paper Ticket in the mail that is accompanied by a letter from SSA explaining the Ticket to Work program.  Under the revised Ticket regulations, all beneficiaries who are determined eligible for SSDI and/or SSI will be eligible to receive a Ticket.  For those beneficiaries who were determined eligible for SSDI and/or SSI benefits prior to the new regulations and classified as “medical improvement expected” (MIEs), they became eligible for a Ticket on July 21, 2008, when the new regulations became effective.  These beneficiaries will receive a Ticket in the mail sometime between December 2008 and February 2009.  However, these beneficiaries can still participate in the Ticket program prior to receive their Tickets in the mail by requesting a Ticket on Demand from MAXIMUS. 

Ticket Assignment

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.

Employment Networks

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:  Can organizations that receive funding from other sources, like a Medicaid Home and Community Based Waiver, be Employment Networks? If so, are there any restrictions?

ANSWER: Grants/fees paid by Medicaid, State VR agencies, or any similar entities have no bearing on an agency's ability to qualify as an EN under the Ticket program. We welcome HCB Waiver and other Medicaid funded community providers to apply to be ENs, provided they meet the following criteria:

Sec. 411.305 of the regulations defines those entities eligible to be an EN as "any ...private entity that assumes responsibility for the coordination and delivery of services under the Ticket to Work program to disabled beneficiaries... A single entity or an association of or consortium of entities combining their resources is eligible to be an EN. The entity may provide these services directly or by entering into an agreement with other organizations or individuals to provide the appropriate services or other assistance that a beneficiary with a Ticket may need to find and maintain employment that reduces dependency on disability benefits. ENs may include, but are not limited to: (a) Any public or private entity, including charitable and religious organizations, that can provide directly, or arrange for other organizations or entities to provide, employment services, vocational rehabilitation services, or other support services…"
The Ticket program pays an EN for helping the beneficiary achieve certain employment outcomes. It does not pay for the cost of services. Nevertheless, you should check with your funding source to determine whether EN payments might affect your existing funding.

Entities Deemed Automatically Qualified to Be ENs

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.
One-Stops are deemed to have met the liability insurance requirements found in Part IV--Section 5 and need not submit evidence of insurance coverage.  

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.

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.

Employer as an EN

QUESTION: How would an employer of people with disabilities who receive SSI or SSDI benefits serve as an EN and collect Milestone and Outcome payments for employees who are already working and are earning above SGA?

ANSWER: An employer may collect Milestone and Outcome payments based on the same rules as a non-employer EN.  If an employer who has elected the Outcome/Milestone payment system accepts assignment of the Ticket of a beneficiary who is already an employee, SSA will take into consideration work the beneficiary engaged in during the 18 months prior to Ticket assignment to determine which Phase 1 Milestone payments would be available to the employer (see FAQ regarding Recent Work Rule). Only months when the beneficiary worked with earnings above the Trial Work Period level would be considered. Otherwise, Phase 2 Milestone payments and Outcome payments would be available to the employer EN as these beneficiary employees attained the designated levels of work and earnings to trigger these payments. If the employer EN had elected the Outcome payment system, there would be no penalty for any work done during the 18 months prior to Ticket assignment. Rather, the employer EN would receive Outcome payments beginning the first month after Ticket assignment that the beneficiary’s net earnings exceed the SGA amount and the beneficiary was placed in the zero cash benefit status.

EN Payments

QUESTION: Does SSA count the beneficiary's earnings when they are earned or when they are paid for the purpose of calculating payments to the Employment Network under the Ticket to Work Program?

ANSWER: For all milestone payments and for all SSDI or concurrent beneficiaries we use earnings when earned--by the pay period, not the pay date. For SSI-only beneficiaries, during the outcome period before benefits are terminated, we use the earnings when received on the actual pay date. Maximus can provide training on this concept for approved Employment Networks.

ANSWER: Gross earnings mean earnings before IRWE deductions and before taxes.

ANSWER: A beneficiary must earn $335 in one month for an EN to qualify for the first Phase 1 Milestone.

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.

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.

ANSWER: Job development and job search training, paid or unpaid, does not meet the requirements for payment of Phase 1 Milestones.  Section 411.500 of the Ticket regulations states that "Phase 1 Milestones are based on the beneficiary achieving a level of earnings that reflects initial efforts at self-supporting employment." Updating job search skills could not be considered self-supporting employment, as there is no employer-employee relationship wherein services of value are delivered in exchange for payment that could be self-supporting. In addition, under Section 411.525 (a)(2)(i) we state that "The first Phase 1 Milestone is met when the beneficiary has worked in a month and earned as least 50% of the amount of earnings considered to represent a trial work period service month." SSA regulations in Section 404.1592 define "services" for the purpose of defining a trial work service month, as work activity in employment which are "the kind normally done for pay or profit". Prevocational training and preparing ones own resume would not normally be done for pay or profit, and therefore does not meet the definition of work activity as it pertains to a trial work period service month for the purposes of payment of Phase 1 Milestones under the Ticket program. 

ANSWER: Any earnings or education obtained during an internship would count towards the timely progress requirements and any earnings during an internship would count towards the requirements for any phase of payments to an EN. 

ANSWER: Yes, an EN may use Milestone or Outcome payments to make payments to a beneficiary. Any payments an EN makes to a beneficiary will be treated as unearned income by Social Security, which could affect SSI benefit eligibility.

SSA must count income under the regulations, but SSA also has work incentives outreach efforts to help beneficiaries plan for how income affects them. In addition to work incentives specialists within SSA, Section 1148 of the Social Security Act established Work Incentive Planning and Assistance Organizations in communities across the country that provide benefits planning and assistance to help beneficiaries anticipate and plan for the effect of work and earnings and other income on their SSI and/or SSDI benefits.

ANSWER: We have provided for a greater number of Milestone payments with respect to SSI recipients in acknowledgement of the fact that SSI recipients may have less work history than SSDI beneficiaries and as part of our overall effort to equalize the monetary value of the Milestone payments that potentially can be made with respect to SSI recipients and SSDI beneficiaries.  The same is true for Outcome payments.  The number of SSI Outcome payment months was left at 60 under the new Ticket regulations, which changed the SSDI Outcome payment months to 36.  The overall effect is to almost equalize the total amount of all payments that potentially can be made to an EN with respect to SSI recipients and SSDI beneficiaries.

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).

Self-Employment

QUESTION: How will self-employment count under the Ticket program?  Will ENs be able to request certified payments for Ticket Holders who are engaged in self-employment?

ANSWER:There are two ways for an EN to request payment for a self-employed Ticket Holder:

1. Use the Beneficiary Quarterly Report available on the MAXIMUS website and submit it as a Certification Payment Request.  This form requires the Ticket Holder's signature and includes a Repayment Agreement. Utilizing the Quarterly Report will enable an EN to receive payment almost immediately for Outcome payments, or as soon as the earnings are developed and verified by SSA for Milestone payments. Experience in the Ticket Program so far has shown that payments based on reported Self-Employment Income (SEI) tend to be extremely error-prone as Ticket Holders frequently file tax returns with lower net earnings than previously anticipated or do not file a return at all. OR


2. 2. Request Auto-Pay for the Ticket Holder. With Auto-Pay, ENs will be paid when the net SEI is posted to SSA records (usually within nine months after the end of the year, if the Ticket Holder files a timely tax return). ENs should be aware that the payment process may be somewhat lengthy for beneficiaries with Tickets that pursue self-employment.

Recent Work Rule

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.

EN Payment Process and Procedures

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: When does SSA count earnings to determine whether an EN is entitled to a payment under the Ticket program----when they are earned or when they are actually paid?

ANSWER:  That depends on what type of payment is being made and whether the Ticket Holder is a SSDI or SSI beneficiary, or one who receives benefits from both programs (known as a concurrent beneficiary). For all Milestone payments and for all SSDI or concurrent beneficiaries, SSA uses earnings when they are earned--by the pay period, not the pay date.  For SSI -only beneficiaries during the Outcome period, but before benefits are terminated, SSA uses earnings when paid.

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).

Transition to the New Payment Schedules

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.
 
With regard to the number of Outcome payments an EN will receive on each beneficiary after the transition to the new regulations, the following would apply.

• A) If an EN received Outcome payments on a case for work and earnings attained in a month prior to the effective date of the new regulations, the case will be transitioned from an Outcome payment to an Outcome payment. When this happens, the number of Outcome payments will be adjusted. Under the transition rules in the new regulations, an EN will receive a maximum of 60 payments or less depending on how much money was paid on that Ticket under the prior rules. The EN will not be notified of how many payments are left on a transitioned case; however, Section 411.551(c) of the new regulations describes how that number will be derived.


• B) When an EN did not receive any Outcome payments on a case for work and earnings attained in any month prior to the effective date of the new regulations, a total of 36 Outcome payments would be available under the new rules for SSDI beneficiaries and a total of 60 Outcome payments would be available for SSI beneficiaries.

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.

Questions about Beneficiaries

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)

Timely Progress

QUESTION: Under the new regulations, MAXIMUS will be responsible for reviewing a beneficiary’s timely progress every 12 months.  If a beneficiary is unable to provide sufficient evidence to MAXIMUS, what information and data will a VR agency have to submit to MAXIMUS to demonstrate timely progress?   For example, will paper copies of grade transcripts be required?  Will there be a template or standardized set of questions from MAXIMUS to answer?  What types of data should VR begin to track on beneficiaries to be prepared to answer MAXIMUS’ questions related to a beneficiary’s timely progress?

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).

General VR Questions

QUESTION: When will a new/revised VR Provider Handbook be available and will it be available electronically?

ANSWER: The revised VR Provider Handbook was sent to interested parties in November 2008.  A copy of the VR Provider Handbook can be requested by contacting SSA’s VR Helpdesk at VRHelpdesk@ssa.gov.   The VR Provider Handbook will be available on the Internet shortly.

QUESTION: Can SSA perform a medical Continuing Disability Review (CDR) on a Ticket eligible beneficiary receiving services from a State VR agency under the Cost Reimbursement payment method?

ANSWER: No, not under the new regulations. Now, when a State VR agency chooses to serve a beneficiary under Cost Reimbursement and sends the proper documentation to MAXIMUS, the beneficiary’s Ticket is placed in a new status called "In-Use/SVR" which carries with it the same protection against medical Continuing Disability Reviews that were previously only associated with a Ticket being assigned and "in-use." 

QUESTION: Do State VR agencies need to do anything for the beneficiaries they were serving under Cost Reimbursement prior to the effective date of the new regulations so that the beneficiary’s Ticket use status is converted to the new status of “In-Use/SVR”?

ANSWER: If the Ticket was assigned prior to June 30, 2008, and the State VR agency has elected Cost Reimbursement and notified us of the Ticket assignment, conversion to “In-Use/SVR” status will be automatic.

QUESTION: Is Cost Reimbursement the only payment option to VR agencies for Tickets that were assigned prior to July 21, 2008?

ANSWER: No, the new regulations have not changed the payment options available to State VR agencies on a case by case basis. State VR agencies can choose Cost Reimbursement or their EN payment system and could do so prior to July 21st.  However, the process for choosing Cost Reimbursement is now a simplified process. State VR agencies no longer have to obtain ticket assignment to receive Cost Reimbursement.  If the State VR agency elects cost reimbursement and the beneficiary has a ticket which would otherwise be available for assignment and the VR Agency sends in the proper documentation to MAXIMUS, the beneficiary will be considered “In-Use/SVR.”

QUESTION: When must a State VR agency choose which program (i.e., the Cost Reimbursement program or the Ticket program) they intend to be paid under for a particular Ticket Holder? Can the State VR agency change its mind later and switch the payment method for a particular beneficiary from being paid as an EN to being paid under Cost Reimbursement or vice-versa depending on the case?

ANSWER: State VR agencies must choose between the Cost Reimbursement program and its elected EN payment system at the time that the beneficiary is signing an IPE or SSA-1365 with the State VR agency. The payment system selected at that time is the one that applies to that beneficiary during the entire time the VR case is open. A State VR agency is not permitted to change the payment system for a beneficiary once the case has been opened and the payment system has been selected. 

QUESTION: How and when will a beneficiary be informed he or she has an in-use Ticket status with a State VR agency?

ANSWER: SSA will send the beneficiary a letter when he or she has an “in-use” status or an “In-Use/VR” status with a State VR agency.

QUESTION: Can a beneficiary reassign his or her Ticket to a different EN while a State VR agency has an open case and the Ticket status is “In Use/VR”?

ANSWER: No, a beneficiary cannot assign his or her Ticket to an EN while a case is open with the State VR agency. It is essential that State VR agencies report case openings to MAXIMUS, using the processes available for reporting either Ticket assignments or case openings under the Cost Reimbursement program. Otherwise, the official records will not reflect that a case is open with the State VR agency and an EN would be able to establish a Ticket assignment.

QUESTION: If an EN serves a beneficiary who does not attain all the payments available on the Ticket, and then the beneficiary decides to return to a VR agency to whom s/he had previously assigned the Ticket, can the VR agency accept the Ticket again and resume Ticket payments? In the situation described above, would VR be able to serve this beneficiary under Cost Reimbursement?

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 for the same period of VR.

Partnership Plus: Sequential Services from VR and then an EN

QUESTION: How does the new Partnership Plus option work? 

ANSWER: The new Ticket regulations create an exciting opportunity for new EN-VR partnerships under which SSA will pay a State VR agency and an EN for assisting the same beneficiary, although the services must be provided sequentially and not concurrently.  This is possible under the new “Partnership Plus” option because a Ticket Holder may receive services from a State VR agency without assigning the Ticket. Under the new regulations, the State VR agency no longer has to have Ticket assignment in order to submit for Cost Reimbursement. Now, when the State VR agency chooses to serve a beneficiary under Cost Reimbursement and sends proper documentation to MAXIMUS, the beneficiary’s Ticket is placed in a new status called "In-Use SVR" which carries with it the same protection against medical Continuing Disability Reviews which was previously only associated with a Ticket being assigned and "in-use." During the time the beneficiary has an open VR case, the Ticket is not available for assignment to another EN. After the VR case is closed, the beneficiary may assign the Ticket to an EN and receive job retention services, ongoing support services, or other services and supports to maintain employment and increase his/her earnings.  Milestones are triggered when a beneficiary's gross earnings are above the specified threshold, and Outcome payments are attained when the beneficiary's net earnings are above SGA and the beneficiary is in zero cash payment status.  If the State VR agency closed the case with the beneficiary in employment, the Phase 1 Milestones payments would not be available to the EN as the VR agency has provided the services that initially led to the beneficiary’s employment. 

As in the past, the State VR agency may submit for Cost Reimbursement when the beneficiary reaches nine months of SGA earnings (i.e., SGA gross earnings, minus Impairment Related Work Expenses or any subsidies) within a 12 month period. When VR chooses to serve a beneficiary as an EN under the Ticket to Work program, the VR agency must do everything the same as any other EN and the additional money available under the Partnership Plus option (i.e., the potential combination of Cost Reimbursement payments and the Phase 2 Milestone and Outcome payments) would not be available.

QUESTION: What payments are available to an EN after the beneficiary has worked with the State VR agency either under cost reimbursement or as an EN?

ANSWER: A beneficiary 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.
 
When a State VR agency chooses to serve a beneficiary as an EN, the beneficiary’s Ticket is assigned to the VR agency. If the beneficiary chooses to assign his/her Ticket to another EN when VR closes his/her case, any available EN payments that have not been made could be made to a new EN to which the Ticket is assigned once the beneficiary attains the required level of work, or the VR agency and the EN may seek to split the EN payments that are earned. When a VR agency and an EN both request EN payments for the same payment period, MAXIMUS will determine how to split those payments based on the services each entity provided and how those services contributed to the beneficiary’s ability to attain the required levels of work and earnings to trigger EN payments.

QUESTION: Is the Partnership Plus option only available when the VR agency is serving a beneficiary under the tradition Cost Reimbursement program?

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 earnings (after deductions for Impairment Related Work Expenses and subsidies) above SGA for 9 months within a 12 months period, 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: Can a beneficiary be served by both a State VR agency under Cost Reimbursement program and an EN at the same time? If a beneficiary currently has his or her Ticket assigned to an EN, does a State VR agency need to get the Ticket “unassigned” from an EN in order to serve the beneficiary under Cost Reimbursement?

ANSWER: SSA will not make Cost Reimbursement payments to a State VR agency for the same period during which the Ticket is assigned to an EN. The State VR agency should check with MAXIMUS to learn whether a potential client's Ticket is available. However, this scenario provides a unique opportunity to take advantage of the Partnership Plus option. Under Partnership Plus, a State VR agency may arrange with any EN to have the EN unassign the Ticket to accommodate the beneficiary receiving services from the State VR agency under Cost Reimbursement, with the intention of the beneficiary reassigning the Ticket to the EN for follow up services once the State VR agency closes the case. However, this does not happen automatically. The EN and the beneficiary must sign a new IWP after VR closes the case. Another alternative is for a referring EN to keep the Ticket assignment and have an agreement with the State VR agency which clearly states the types of services to be provided by each entity. In some states, ENs and State VR agencies are designing interagency agreements to facilitate equitable revenue sharing and a coordinated system of services for beneficiaries.

EN-VR Referral Agreements

QUESTION: Can an EN who has a beneficiary’s Ticket assignment refer that Ticket Holder to a State VR agency for services (such as a vocational evaluation) without losing the Ticket assignment?

ANSWER: An EN that holds a beneficiary's Ticket assignment may refer the beneficiary to a State VR agency for services.  However, to do this, the EN and State VR agency must have an agreement that specifies the conditions under which the State VR agency will provide services.  The agreement must be in writing and signed by both parties before the EN can refer a Ticket Holder to the State VR agency.  Ticket assignment will remain with the referring EN, unless unassigned first.

As an alternative under Partnership Plus, provided that all steps are taken in consultation with the beneficiary and the State VR agency, the beneficiary may unassign his/her Ticket and place it in In-Use/SVR status for the period that the VR case is open, and reassign it to an EN after VR services are complete and the case is closed.

QUESTION: If an EN [not the State VR agency] has a Ticket assignment and will be referring the Ticket Holder to the State VR agency for vocational services after some initial EN services have been performed with the Ticket Holder, does the Ticket need to be unassigned in order for the VR agency to receive Cost Reimbursement for services it performs?

If that is the case, what is the intent of the referral agreement between the EN and VR agency as stated in Section 12.9.  Wouldn't the referral agreement be a mechanism for documenting sequential services instead of having the Ticket unassigned before VR services are engaged and then re-assign the Ticket to receive follow-along services after the VR case is closed? 

ANSWER: An EN that holds a beneficiary's Ticket assignment may refer the beneficiary to a State VR agency for services without the Ticket being un-assigned.  However, to do this, the EN and State VR agency must have an agreement that specifies the conditions under which the State VR agency will provide services.  The agreement must be in writing and signed by both parties before the EN may refer a Ticket Holder to the State VR agency. Ticket assignment will remain with the referring EN, who will compensate the State VR agency according to the terms of the agreement.  SSA will not pay Cost Reimbursement in this situation because the Ticket is assigned to an EN.  The agreement would allow the beneficiary and the EN to maintain their relationship while the beneficiary receives services from the State VR agency, and it will allow the State VR agency to receive a measure of compensation from the EN.

As an alternative under the new Partnership Plus option, provided that all steps are taken in consultation with the beneficiary, the current EN and the State VR agency, the beneficiary may un-assign the Ticket and place it in In-Use/SVR status for the period that the VR case is open, and re-assign it to the referring EN or a different EN after VR services are complete and the case is closed. Either option is allowable, provided that in the latter case, the beneficiary is consulted.

QUESTION: Can a beneficiary be served by both a State VR agency under Cost Reimbursement program and an EN at the same time? If a beneficiary currently has his or her Ticket assigned to an EN, does a State VR agency need to get the Ticket “unassigned” from an EN in order to serve the beneficiary under Cost Reimbursement?

ANSWER: SSA will not make Cost Reimbursement payments to a State VR agency for the same period during which the Ticket is assigned to an EN. The State VR agency should check with MAXIMUS to learn whether a potential client's Ticket is available. However, this scenario provides a unique opportunity to take advantage of the Partnership Plus option. Under Partnership Plus, a State VR agency may arrange with any EN to have the EN unassign the Ticket to accommodate the beneficiary receiving services from the State VR agency under Cost Reimbursement, with the intention of the beneficiary reassigning the Ticket to the EN for follow up services once the State VR agency closes the case. However, this does not happen automatically. The EN and the beneficiary must sign a new IWP after VR closes the case. Another alternative is for a referring EN to keep the Ticket assignment and have an agreement with the State VR agency which clearly states the types of services to be provided by each entity. In some states, ENs and State VR agencies are designing interagency agreements to facilitate equitable revenue sharing and a coordinated system of services for beneficiaries.

QUESTION: What direction or assistance is available regarding how to structure agreements between an EN and a State VR agency regarding referrals of individuals by an EN to a State VR agency?

ANSWER: 20 CFR 411.420 about agreements states:

The agreement between an EN and a State VR agency should state the conditions under which the State VR agency will provide services to a beneficiary when the beneficiary is referred by the EN to the State VR agency for services. Examples of this information include-
(a) Procedures for making referrals and sharing information that will assist in providing services;
(b) A description of the financial responsibilities of each party to the agreement;
(c) The terms and procedures under which the EN will pay the State VR agency for providing services; and
(d) Procedures for resolving disputes under the agreement.

There is no set format or template for agreements between State VR agencies and ENs.  SSA and MAXIMUS have copies of some agreements which can be sent to ENs or State VR agencies to assist in developing their own agreements.

VR Data Reporting and Collection

QUESTION: What documentation will VR have to provide to MAXIMUS to show that the Ticket is “In Use/SVR" under the VR Cost Reimbursement option?

ANSWER: For Cost Reimbursement cases, the State VR agency need only indicate to MAXIMUS the date that the IPE was signed, the date the case was closed, and whether the beneficiary was working when the VR case was closed. 

QUESTION: What does a State VR agency need to submit to MAXIMUS to show that they have an open case that will be eligible for payment for a Ticket Holder under either the Cost Reimbursement payment option or to be paid as an EN? Have the new regulations changed this process?

ANSWER: When a State VR agency is operating as an EN, it must complete, sign and have the beneficiary sign the SSA-1365, State Agency Ticket Assignment Form, and return this form to MAXIMUS.  Under the new regulation the SSA-1365, State Agency Ticket Assignment Form, should not be used for cases the agency opens under the Cost Reimbursement program.  It should only be used when the State VR agency is operating as an EN under its elected EN payment system with the Ticket assigned. An IPE for a beneficiary being served under the Cost Reimbursement program should no longer include a statement that the beneficiary is assigning the Ticket to the State VR agency. 

However, if the beneficiary has consented to assign the Ticket to the State VR agency but has not signed an SSA-1365, the process has not changed. In this case MAXIMUS will continue to accept an unsigned SSA-1365 along with an IPE bearing a statement of the beneficiary's informed consent to assign the Ticket as evidenced by the beneficiary's signature.

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 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 to MAXIMUS monthly.

Concerning the VR case closure data, the beneficiary may not benefit from the 90 day window to reassign a Ticket without loosing the protection against medical Continuing Disability Reviews (CDRs) if MAXIMUS is not notified of the VR case closure in a timely manner.

QUESTION: When submitting data to SSA regarding open cases, should the State VR agency keep expanding the original submission and change the data with each monthly submission? Or for each month, should VR provide only new cases with an IPE, signature data, and only cases with a closed date? In other words, should the State VR agency submit only new information each month?

ANSWER: State VR agencies can elect to send in their data by expanding the file and changing the data or by providing only new information each month.  However, MAXIMUS would prefer that only the new information be submitted each month. 

ANSWER: The SSN should not contain any dashes.  The required format for the date is an 8 digit numeric field in MMDDYYYY format.

ANSWER: Unfortunately, due to SSA security concerns, MAXIMUS and SSA will be unable to create the planned website for uploading the lists.  There are several alternative ways that the data can be sent.

A. The data can be sent by email to svrticketdata@maximus.com.  If this method is used, the file must be zipped using WinZip, password protected and encrypted.  Passwords to the files must be sent in a separate email.

B.  A CD may be mailed to MAXIMUS.

C.  A secure FTP site hosted by the State VR agency may be used.  The State VR agency would put the files on their server and MAXIMUS could log onto their site and download the file.

QUESTION: Is there a particular date each month by which MAXIMUS must receive monthly updates from State VR agencies?

ANSWER: SSA has not established a set date for monthly submissions of the data.  State VR agencies may submit the data file any time during the month.  

QUESTION: If a State VR agency serves a small number of clients compared to other State VR agencies, is it possible to submit data quarterly instead of monthly?

ANSWER: Although a State VR agency may have relatively few records compared to the rest of the nation, MAXIMUS would still prefer a monthly submission of the file. This will allow them to inform each beneficiary that he or she is eligible for Ticket assignment in a timelier manner after their case is closed.   

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.  MAXIMUS should be notified when the State VR agency and beneficiary sign an IPE 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.  The State VR agency should send MAXIMUS a monthly file listing beneficiaries whose cases were opened and closed and the dates of these actions.