Dear Commissioner Barnhart: We, the undersigned members of the Consortium for Citizens with Disabilities (CCD) Task Forces on Work Incentives Implementation, Employment and Training and Social Security wish to express our appreciation for your leadership in implementing the Ticket to Work and Work Incentives Improvement Act of 1999 (TTWWIIA) and for the agency’s significant accomplishments in recent years in reducing barriers to employment for disability beneficiaries. The Ticket to Work program is now fully operational throughout the U.S. with almost 140,000 Tickets assigned as of June 30, 2006 and the Social Security Administration (SSA) has made payments to 341 employment networks on behalf of 2,306 beneficiaries. As of August 2006, the Benefits Planning Assistance Outreach (BPAO) program had 116 organizations offering services to approximately 5200 beneficiaries a month. Moreover, 90 percent of beneficiaries who needed to return to the disability rolls after a work attempt have successfully done so through the expedited reentry (EXR) provisions of TTWWIIA. We appreciate that, under your direction, the Social Security Administration has been responsive to and welcoming of ideas from the disability advocacy community. In order to ensure that these efforts to reduce employment barriers are not compromised, however, we urge you to make certain that critical, uncompleted tasks surrounding implementation are addressed within the next few months. Perhaps most crucial is the publication of the final rule revising the Ticket to Work regulations. We were tremendously heartened by the proposed rule issued on September 30, 2005 because it went a long way toward correcting numerous deficiencies identified in the original Ticket regulations. As you know, the inadequacy of the Ticket payment system and the complexity of rules governing Ticket assignments were largely responsible for private providers' reluctance to become involved in the program. These factors have been shown to limit the vocational choices that TTWWIIA was intended to give beneficiaries and possibly undermine many beneficiaries' ultimate success. The new regulations address these and other important Ticket program components and will have immediate impact on the lives of beneficiaries. As the new regulations are so critical to the success of the Ticket Program, we urge you to make issuance of the final rule a priority. Related to the publication of the final Ticket regulations is the matter of re-marketing the Ticket to Work Program. CCD Task Forces, the Ticket to Work and Work Incentives Advisory Panel and numerous other advocates have for many years urged SSA to undertake a wide-scale, aggressive national publicity campaign to draw the attention of beneficiaries, their families and their support networks to the Ticket and other elements of TTWWIIA. The new Ticket rules coupled with the new Work Incentives Planning and Assistance (WIPA) grantees offer a perfect opportunity to renew and invigorate interest in Ticket to Work. At the June 2006 TTWWIIA Advisory Panel meeting, SSA officials discussed the possibility of using WIPA organizations in regularly scheduled seminars to educate beneficiaries about TTWWIIA and other work incentives. This seems like a step in the right direction but we are concerned that fiscal constraints may derail these plans. Just as important as the Ticket Program is the work incentives support structure which includes the Protection and Advocacy for Beneficiaries of Social Security (PABSS) and the new Work Incentives Planning and Assistance (WIPA) Project grantees (formerly the Benefits Planning Assistance and Outreach or BPAO program). We are pleased that the WIPA grantees will be funded for 36 months without having to re-compete for the program. We remain concerned, however, that the overall level of money authorized for the WIPAs is insufficient for a program expected to assist millions of beneficiaries in navigating the complexities of Social Security rules. We have communicated this concern to Congress and ask you to support changes to the law that would adjust the level of WIPA funding for inflation and give SSA greater flexibility in devoting additional monies to WIPA operations. In the past, PABSS programs and BPAOs were provided identical core training despite the fact that their roles are very different. We think it is important that the training be separated and that PABSS programs receive training essential to their role in removing barriers to employment and supporting individuals using work incentives and other non-discrimination provisions which enable them to be employed. The decision to add the PABSS programs to the existing BPAO training in 2002 created a great deal of confusion among PABSS programs and misled them into believing that their focus was post-entitlement issues rather than employment. Awarding a separate contract for PABSS training will go far in increasing their effectiveness and building capacity to support employment of people with disabilities. In addition, we know that SSA has received feedback from many regarding the need for consistency across the Rehabilitation Training Center (RTC) trainings. In addition to updating the curriculum to include information on the state vocational rehabilitation system, One Stops and other employment supports as well as the Ticket program, the training should also include information on the TTWWIIA and Ticket regulations, something that is missing in the current training program. We understand that SSA intends to fund continued training and technical assistance through a competitive process. We urge you to expedite this process and to make sure that the training and the curriculum reflect the appropriate scope of information for the funded programs. Finally, as you know, the "cash cliff" in the Title II disability programs remains among the most troubling and intransigent impediments to work for beneficiaries. Our organizations continue to be extremely interested in the national demonstration project to test phasing out Title II disability benefits as earned income rises. While we certainly understand the agency's need to be thorough and deliberate in its approach to this demonstration, we are mindful that the concept of a benefit offset was first proposed over two decades ago. We look forward to the publication in October of the preliminary findings from the four state benefit offset pilot projects. Nevertheless, full implementation of the national demonstration is vital and must be advanced before the end of the year. Once again, we thank you for all you have done for Social Security beneficiaries with disabilities and stress how important it is that you to take action on these matters. We believe it is vitally important to the success of the Ticket to Work Program and other elements of TTWWIIA that issuance of the Ticket regulations and the provision of training for WIPA and PABSS grantees, and the national benefit offset demonstration be regarded as a high priority.
On behalf of: CC: The Honorable President George W. Bush The Honorable Charles Grassley The Honorable Max Baucus The Honorable Rick Santorum The Honorable Kent Conrad The Honorable Bill Thomas The Honorable Charles Rangel The Honorable James McCrery The Honorable Sander Levin |