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Message From the Panel

It is the Panel's distinct honor to transmit to the Commissioner of Social Security its Preliminary Advice Report on the Ticket to Work and Self- Sufficiency Program (the Ticket program) in response to the NPRM published in the Federal Register on December 28, 2000. The Ticket to Work and Work Incentives Improvement Act of 1999 (Public Law 106-170) authorizes the Ticket program to expand the universe of service providers available to beneficiaries with disabilities. Social Security beneficiaries who are seeking employment services, vocational rehabilitation services, and other support services to assist them in obtaining, regaining, and maintaining gainful employment can use a Ticket and other work incentives to secure work.

The recommendations contained herein represent our informed deliberations after initial public and expert input from the field and briefings from agency officials. A final advice report will be published in early April and will reflect further input, deliberations, research and analyses by the Panel.

It is the Panel's duty to advise and assist the Commissioner's to effectively implement the Ticket Program in order to assist individuals with disabilities nationwide to secure self- supporting employment. We believe this report is among the initial steps to achieving that goal.

 

Table of Contents

Executive Summary and Recommendations

NPRM Issues, Public Input, Discussion and Recommendations

Introduction

Ticket to Work and Beneficiary Use

Employment Network Requirements and Qualifications

Dispute Resolution and Mediation

Employment Network Payment

Appendices

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EXECUTIVE SUMMARY AND RECOMMENDATIONS

This Preliminary Advice Report is comprised of the preliminary analysis and initial recommendations of the Ticket to Work and Work Incentives Advisory Panel (the Panel) to the Commissioner of the Social Security Administration on the proposed rules for the Ticket to Work and Self-Sufficiency Program. The proposed rules appear in a Notice of Proposed Rulemaking published in the Federal Register on December 28, 2000. The Panel intends to collect additional information, do further analysis and solicit additional public comment in order to develop and submit its final advice report on the NPRM to the Commissioner in late March or early April 2001.

Public Law 106-170, The Ticket to Work and Work Incentives Improvement Act of 1999, establishes programs that are designed to provide SSA beneficiaries with disabilities with a broader array of providers and improved access to employment services and supports, vocational rehabilitation services and other support services. It also establishes the Ticket to Work and Work Incentives Advisory Panel, whose duty is to advise the Commissioner of Social Security and report to the President and Congress on issues related to work incentive programs, planning and assistance for individuals with disabilities and the Ticket to Work and Self-Sufficiency Program established under this Act.

The Panel is composed of twelve individuals, four of whom were appointed by the President, four by the Senate and four by the House of Representatives. The appointees represent a cross-section of individuals with experience and expert knowledge as recipients, providers, employers and employees in the fields of employment services, vocational rehabilitation and other related support services. The majority of the members are individuals with disabilities or their representatives. There are several current or former disability beneficiaries of Social Security on the Panel as well.

A summary of the Panel's initial twenty-two (22) recommendations to the Commissioner of SSA on the proposed rules precedes the full report.

SUMMARY OF PANEL RECOMMENDATIONS ON THE PROPOSED RULES

TICKET TO WORK AND BENEFICIARY USE

Recommendation 1: Sixteen (16) and seventeen (17) year old beneficiaries should be eligible to participate in the Ticket program.

Recommendation 2: All SSA disability beneficiaries with a medical improvement expected (MIE) diary should be eligible to participate in the Ticket program.

Recommendation 3: SSA should conduct a cost benefit analysis on the feasibility of a beneficiary receiving more than one ticket within a period of disability and the agency should assess the potential impact of beneficiaries using more than one ticket in its "Adequacy of Incentives" report due to Congress at the end of the Ticket implementation period.

EMPLOYMENT NETWORK REQUIREMENTS AND QUALIFICATIONS

Recommendation 4: An employment network (EN) should be required to retain staff that are otherwise qualified based on education or direct services experience, such as employees with a college degree in a related field, including but not limited to vocational counseling, education, human resources, human relations, social work, teaching, or psychology or employees with equivalent experience. SSA should not require licensure and/or certification that would exclude employers or other types of providers qualified to work with people with disabilities such as those who offer non-traditional supports that result in employment. SSA should delete Section 411. 315 (c).

Recommendation 5: Section 411.325(g) should be deleted from the list of EN reporting requirements. Section 411.325(g) currently requires "…among other things, submitting to the Program Manager, on an annual basis, a financial report that shows the percentage of the employment network's budget that was spent on serving beneficiaries with Tickets…"

Recommendation 6: The Panel recommends that timely progress be defined as beneficiary compliance with the terms and conditions of the IWP, as agreed to by the beneficiary and EN and that the reporting mechanism be the annual report in Section 411.325(e).

Recommendation 7: SSA should permit other individualized service delivery plans to be used as a substitute to the IWP provided they meet the minimum requirements detailed in the statute.

Recommendation 8: SSA should re-write Section 411.385 to make it clear that an SSA beneficiary with a ticket who applies for State Vocational Rehabilitation services has a choice in deciding whether to assign his/her ticket to the State VR agency, to assign it to another EN, or not to assign it at all.

DISPUTE RESOLUTION

Recommendation 9: All beneficiaries should have access to P&A; services.

Recommendation 10: Mediation should be available as an avenue for resolving disputes but it should not be mandatory. It should be an option available to the parties to the dispute, after the matter has been considered for resolution by the Program Manager.

  • All parties must agree to enter into mediation.
  • Mediation should be external to the Social Security Administration and should not be provided or paid for by protection advocacy agencies. Mediation is a more efficient and cost-effective way to resolve disputes.
  • Participation in the mediation process should not bar a party's access to further appeals.
  • The Social Security Administration should set aside additional funds to support the use of mediation for all parties.
  • The Social Security Administration should look at other successful mediation program models such as those established at EEOC and the Department of Justice.

Recommendation 11: All decisions by the Social Security Administration involving disputes between or among all parties should, at the option of the parties, be subject to external review by either the Social Security Administration's administrative review process and/ or judicial review.

Recommendation 12: Information about protection and advocacy services and how to access them should be available at any time to all beneficiaries seeking or using SSA or other work incentive programs, including the Ticket. Specifically, a beneficiary should receive a formal notice of the availability of protection and advocacy services when he or she is issued a ticket and at the following junctures in the process:

  • When he or she applies to the employment network for services;
  • At the signing of his or her individual work plan;
  • In the event his or her services are decreased, suspended or terminated; or
  • When he or she filed a complaint against the network.

Recommendation 13: The beneficiary's filing of a complaint against an EN should, with the beneficiary's consent, trigger a notice to the protection and advocacy agency regarding the dispute to allow for an inquiry by the protection and advocacy agency as to the beneficiary's wish for protection and advocacy assistance.

Recommendation 14: Notices from the EN and the protection and advocacy agency, the beneficiary's IWP and any other documents should be in the beneficiary's primary or accessible language of communication.

Recommendations #15: Timelines for dispute resolution should be follows:

  • Employment networks should have fifteen working days to resolve a complaint filed by a beneficiary. If not resolved satisfactory, the beneficiary should be permitted to request a review by the Program Manager.

  • The request for review, with the submission of all supporting documentation by both parties, should be submitted within ten (10) working days after the beneficiary receives the employment network's decision.

  • The Program Manager should complete its review and render a decision within fifteen working days, unless the parties agree to mediation.

  • If the parties agree to mediation, mediation should commence within ten (10) working days after the Program Manager receives the parties' request for mediation and should be completed within twenty (20) working days after it is scheduled.

  • The Social Security Administration should have no more than twenty (20) working days to resolve individual appeals.

  • All disputes involving Employment Networks, State vocational rehabilitation agencies, and the Program Manager must be resolved within sixty (60) working days, including Social Security Administration review and issuance of a decision.
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    Recommendation 16: During the appeals process, services and supports to the beneficiary should be continued at the same level; that is, services and supports should not be reduced or suspended by the Employment Network without the beneficiary's consent.

    Recommendation 17: All parties in a dispute should have access to all information that is being considered and used to render a decision in the dispute.

EMPLOYMENT NETWORK PAYMENT RECOMMENDATIONS

Recommendation 18: SSA Ticket implementation staff should re-evaluate the proposed payment structure to determine the feasibility of adopting a system that pays at least four milestone payments: 1) at the signing of the IWP; 2) at 3 months of SGA; 3) at 7 months of SGA; 4) at 12 months of SGA. A second-tier of the milestone system would be a system in which milestones would be individualized for beneficiaries who need significantly more supports.

Specifically the system would:

a) Pay a minimal milestone when a beneficiary and employment network signs an IWP;

b) Pay an additional milestone payment equal to the first two proposed (i.e., 3 and 7 months of SGA) at the end of 12 months of SGA;

c) Amortize the milestone payments over the entire 60-month outcome-only payment period rather than the 12 months proposed;

d) Pay a greater overall percentage of the outcome-only payment option under the milestone/outcome payment option than the proposed 85%;

e) Equalize the monthly outcome payments under the milestone/outcome payment period rather than the graduated method proposed in the NPRM;

f) Provide individualized milestones for individuals with a need for on-going support services, individuals who need high-cost accommodations, individuals who earn a sub minimum wage, and individuals who work and receive partial cash benefits along the lines of systems already in use in Massachusetts, Oklahoma and other states. (These systems use the individualized planning process to determine if and when a different set of milestones is necessary, and establish a plan for payments and accountability for the payments.)

Recommendation 19: Because the Title II and Title XVI programs are distinctly different from each other with differing processes and timelines, SSA should develop two milestone payment systems; one for SSI beneficiaries and another for SSDI beneficiaries, that take into account the differences between the two programs. (See attachment C - Seifert and O'Brien models)

Recommendation 20: SSA should consider applying the same earnings level ($740 monthly) for all Ticket users as the threshold for outcome payments to employment networks.

Recommendation 21: SSA should commission a full cost benefits study to evaluate the ticket program. Such a study should begin with a more complete view of the direct savings to the SSA trust fund, but should also consider savings to the Federal treasury and increased productivity to the nation as a whole. Such a study would at a minimum consider the impact of increased FICA contributions by working beneficiaries, reduced use of Medicare, cash trust fund savings by beneficiaries who work but who only receive partial cash benefits and estimated trust fund savings beyond 60 months. The study should also consider reduced use of all other government transfers and increased taxes paid. It should consider the addition to net national product of increased work. It should evaluate costs and benefits from SSA's point of view, from the view of the Federal government, from the view of the beneficiary and from society as a whole.

Recommendation 22: SSA should resolve the conflict between Sections 411.510 and 411.390 regarding VR's choice of payment systems for beneficiaries who are already clients of VR.

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NPRM ISSUES, SUMMARY OF PUBLIC INPUT DISCUSSION AND RECOMMENDATIONS

INTRODUCTION

The Ticket to Work and Work Incentives Advisory Panel take seriously its duty to advise and assist the Commissioner of the Social Security Administration and to report to the President and the Congress. Because one of the first major tasks outlined in the Ticket to Work and Work Incentives Improvement Act (TWWIIA) is to advise the Commissioner on the regulations for the Ticket program, the Panel, since their initial meeting in July, has focused its attention primarily on the Notice of Proposed Rulemaking (NPRM).

In September, the Panel created four workgroups to focus on certain topic areas covered in the NPRM: Ticket to Work and Beneficiary Use of Ticket; Employment Network Requirements and Qualification; Dispute Resolution; and, Provider Payment. This Preliminary Advice Report reflects the work of these workgroups, expert advice from invited guests of the workgroups, public input and Panel deliberations.

The Panel deemed it essential to reach out to a variety of constituents and advocates to solicit comments and opinions about the NPRM and the Agency's plans for Ticket implementation. To achieve this the Panel has conducted eleven (11) days of public meetings and seven (7) public conference calls since July 2000. We hosted over twenty (20) hours of public comment at those meetings. Additionally, public meetings in Phoenix, Minneapolis, Salt Lake, and Atlanta as well as two teleconferences in California have been devoted solely to public comment on the NPRM. At each meeting citizens with disabilities, their advocates, and other stakeholders, were provided ample opportunity to comment. Additionally, individual Panel members have attended numerous meetings in their home states and have been asked to speak to a variety of groups and organizations about the Panel and the Ticket's implementation. We have also solicited and received correspondence from the public regarding the agency's Ticket implementation plans and the NPRM. In sum, the Panel has made a concerted effort to solicit input from a broad cross-section of program constituents by holding meetings in Washington, D.C., as well as regional meetings and teleconferences across the country. The twenty (20) hours of public comments and the over eighty (80) sets of comments received by letter and e-mail reflect this diversity of input.

During this first six months of Panel activity, specific issues and concerns regarding implementation and rollout of the Ticket program and the proposed regulations have surfaced repeatedly in public comments and in Panel deliberations. After extensive discussion in our January and February meetings, the Panel concluded that a letter outlining key implementation issues and concerns should be sent to the Acting Commissioner of SSA, prior to close of the NPRM public comment period.

SSA has provided the Panel regular briefings and updates on the NPRM and administrative implementation activities such as evaluation plans, contracting, grant-making, and other critical administrative rollout activities. The Panel recognizes that the implementation and rollout of the new Ticket program pose tight timeframes and demands major changes in the culture and business practices of the Agency. However, if implemented carefully, with consideration given by the agency to public comments and to the input and advice of the Panel, the Ticket to Work and Self-Sufficiency program has the potential to improve vastly the quality and availability of rehabilitation services, employment services and supports, and related health services for this country's citizens with disabilities.

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TICKET TO WORK AND BENEFICIARY USE

Issue 1: Should transition-aged youth (16-18) be eligible to receive and use a Ticket in the Ticket to Work and Self-Sufficiency Program?

Summary of Input: The Panel received comments from the public that overwhelmingly supported providing Tickets to at least 16 and 17 year olds. There was consensus that the longer people receive cash benefits the less likely they are to be able to achieve independence and become self-supporting. The public also agreed that the expectations created for a young person with a disability might be the most important factor in whether they work or rely on benefits and that allowing them to participate in the Ticket program makes another tool available to encourage positive expectations. Experts told the Panel that schools themselves could potentially be Employment Networks for youth.

Discussion: Making transition-aged youth ineligible for the Ticket program would send the wrong message to youth and could have the effect of encouraging lifelong dependency upon benefits. There may or may not be a determinable increase in cost to the program in the short-term. The long-term benefits to the program and the youth beneficiaries could far outweigh those expenditures. Many youth may not choose to participate in the program until after they are 18, but those who wish to participate should be allowed to do so. Programs and policy in the Individuals with Disabilities Education Act and the Workforce Investment Act promote seamless programming from school to work for students and young adults with and without disabilities.

The proposed regulations limit participation in the Ticket program to disability beneficiaries between the ages of 18 and 64. 18-year-old SSI recipients must be determined disabled under adult rules before being able to receive a Ticket. As youth prepare to transition out of school to the workforce, the Ticket program could be a value-added tool to assist them to plan work.

Recommendation 1: Sixteen (16) and seventeen (17) year old beneficiaries should be eligible to participate in the Ticket program.

Issue 2: Should disability beneficiaries classified with a "Medical Improvement Expected (MIE)" diary be eligible to participate in the Ticket program?

Summary of Input: Public comment supported the inclusion of beneficiaries with the MIE diary in the Ticket program. Members of the public indicated that services should be available to all disability beneficiaries sooner rather than later as policy, since recent research supports findings that the longer someone receives cash benefits the harder it is for them to become self-supporting. The public also cited that most people with MIE diary do not know they have been given that designation. Further, testimony to the Panel indicated that in their practical experience, people with MIE diaries undergo delayed initial Drs often times years after the date on which they are supposed to. Concern was expressed by national leaders from mental health and national organizations representing people who are developmentally disabled, that people with long-term mental illness (such as bipolar disorder) and cognitive impairments receive this designation disproportionately, often with no real indication that improvement is likely. In addition, members of the public were of the opinion that if the designation of the MIE diary category for CDRs would be used to limit a person's access to a benefit, it must be subject to due process review or appeal.

In addition, agency officials stated that it is not known how many beneficiaries have their benefits terminated due to a CDR based on the MIE diary, and then reapply based on a decline in their condition and then are awarded benefits a second time.

Discussion: The Panel agreed that limiting a person's access to a Federal benefit (i.e. the ticket) without providing for a due process review is questionable practice/policy. If this exclusion remains in the final rule, it should outline a procedure for timely review and appeal. This would increase the administrative burden to SSA, the cost of which may outweigh the possible savings to the programs created by such exclusion. One likely consequence may be that the length of time required to process all appeals, not just MIE cases, will be negatively impacted, that is, all appeal cases would take longer given the additional caseload.

If the rule becomes final with its effect to limit a person's access to the benefits of the Ticket program, SSA should commit to policy and procedures that beneficiaries with the MIE designation receive their initial CDR on schedule.

The exclusion of beneficiaries with the MIE diary from participation in the Ticket program does not appear to be justified. The SSA program and policy officials were not able to provide the Panel with sound statistical analysis to justify this exclusion. The Panel was not provided with data on how long it takes for a person with the MIE diary to have the initial CDR completed. There was also no information that indicated that a significant number of people with the MIE designation would be terminated after the completion of their initial CDR. There was no evidence to counter the argument that people with a MIE designation would be more successful in staying off the rolls through being allowed early participation in the Ticket program, even if their initial CDR would result in a termination of benefits.

The proposed regulation state that a person who is awarded benefits with an MIE diary for the scheduling of their first Continuing Disability Review (CDR) is not eligible for the Ticket program until after the completion of their first CDR. A beneficiary with this designation is scheduled to have their case reviewed within 6 to 18 months after receiving benefits. This MIE category was created for the sole purpose of determining when the first CDR for a beneficiary should be completed.

In 1999, there were 60,766 DI and SSI adult beneficiaries who were classified first time MIEs on the rolls. Data from the disability determination services decision files indicate that in 1999, 9,663 beneficiaries with a MIE diary were ceased for medical improvement. On the average, about 16% of initial Titles II and XVII MIE allowances that come up for first-time continuing disability reviews (CDRs) are ceased, usually 18-24 months after allowance, for medical improvement.

Recommendation 2: All SSA disability beneficiaries with a medical improvement expected (MIE) diary should be eligible to participate in the Ticket program.

Issue 3: Should a person be entitled to more than one ticket within a period of disability?

Summary of Input: Concern was expressed by the public that beneficiaries would not be able to find ENs that would provide services to them if they have a partially used ticket. Current research (Schur, 2000) finds that people with disabilities are twice as likely as non-disabled people to work in part time and temporary work. Concern was raised that the program would not work for a large segment of beneficiaries particularly those with disabilities that are episodic in nature.

Discussion: Many beneficiaries using the Ticket program are likely to go in and out of work, and not transition at first attempt from receipt of cash benefits to 60 months of continuous employment. A beneficiary whose ticket is partially used and needs other continuing support services may have a difficult time finding an EN willing to work with them. For example, a beneficiary returns to cash benefits after a work stoppage in the "Easy Back On" provision of TWWIIA. The person wants to return to work again and decides he/she needs support services. This consumer will be at a distinct disadvantage even though if interested in continuing to work. There is nothing in the statute that prevents a beneficiary from receiving a second ticket and there may well be unassessed cash savings to SSA programs in allowing two or more tickets to a beneficiary, as warranted or appropriate.

In Section 411.125(b), the proposed rule states that a person can have only one ticket during a period of entitlement for which a beneficiary is eligible to receive disability benefits. The Panel has asked for clarification from the agency on the difference between a period of eligibility, a period of entitlement and a period of disability. We expect that information shortly. Regardless, if a beneficiary returned to work and her or his Employment Network (EN) received 35 out of the 60 outcome payments and the beneficiary then became unable to work, his or her ticket would only have 25 outcome payments left to pay out. That is what is being described as a partially used ticket. A related issue is whether an EN, new or old, would be willing to provide a full array of services to a beneficiary with a partially used ticket and a significantly reduced number of payments.

Recommendation 3: SSA should conduct a cost benefit analysis on the feasibility of a beneficiary receiving more than one ticket within a period of disability and the agency should assess the potential impact of beneficiaries using more than one ticket in its "Adequacy of Incentives" report due to Congress at the end of the Ticket implementation period.

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EMPLOYMENT NETWORK REQUIREMENTS AND QUALIFICATIONS

Issue 4: Who should be in an Employment Network providing services to beneficiaries who are Ticket holders?

Summary of Input: Many of the commenters stated that State licensure laws dictate requirements for certain providers so SSA should defer to those State rules. Some commenters expressed concern that the quality of services may be compromised if provided by less that trained personnel, however, they recognized the benefits of allowing support and other services by non-credentialed providers if under the auspices of an EN who is ultimately accountable for the services provided.

Discussion: Many people with disabilities have a "circle of support," that is, people who they trust to provide additional support services. Most often, these individuals are non-credentialed support providers. In some instances, they are family members, neighbors, or friends who provide needed supports. The final rule regarding EN qualifications should be broad enough to accommodate non-traditional providers while accomplishing the stated purpose of the Ticket program, to "expand the universe of service providers available to individuals who are entitled to Social Security benefits based on disability..." § 411.105

According to the proposed rule, an Employment Network is any qualified entity that has entered into an agreement with SSA to function as an EN; and assumes responsibility for the coordination and delivery of employment services, vocational rehabilitation services, or other support services to beneficiaries who have assigned their ticket to that EN. The proposed rule would require that an eligible entity must assure that it is licensed, certified, accredited, or registered if so required by state law to provide these services either directly or through arrangements with other entities.

Recommendation 4: An employment network (EN) should be required to retain staff that are otherwise qualified based on education or direct services experience, such as employees with a college degree in a related field, including but not limited to vocational counseling, education, human resources, human relations, social work, teaching, or psychology or employees with equivalent experience. SSA should not require licensure and/or certification that would exclude employers or other types of providers qualified to work with people with disabilities such as those who offer non-traditional supports that result in employment. SSA should delete Section 411. 315 (c).

Issue 5: What financial reporting is needed by the Program Manager or SSA from the Employment Network?

Summary of Input: Many commenters recommended that the agency try to "keep it simple" and not require reporting that is not necessary. Some were concerned that a few of the reporting requirements may place an undue administrative burden on ENs and discourage the participation of potential providers. Still others in the public and on the Panel were of the opinion that it is inappropriate, invasive and unreasonable for SSA to require these kinds of reports in an outcome-based program.

Discussion: While there is a substantive evaluation component in the Ticket program, the Panel thinks that using the financial reporting requirements in Section 411.325 (g) is not the way to collect data for it. The requirement will prohibit providers and employers from participating who have no intention of adding to the financial disclosures they already make to the Federal government.

Section 411.325 of the NPRM outlines the proposed reporting requirements of an EN. One of those requirements is for the EN to submit to the Program Manager, annually, a financial report that shows the percentage of the Employment Network's budget that was spent on serving beneficiaries with tickets.

Recommendation 5: Section 411.325(g) should be deleted from the list of EN reporting requirements. Section 411.325(g) currently requires "…among other things, submitting to the Program Manager, on an annual basis, a financial report that shows the percentage of the employment network's budget that was spent on serving beneficiaries with Tickets…"

Issue 6: Should "timely progress" toward an employment goal be measured by minimum standards for all beneficiaries, or, should the terms and conditions agreed to in each IWP determine timely progress?

Summary of Input: The Panel did not receive extensive public comment on this issue, however the Panel did engage in extensive discussion and deliberation and they came to a consensus on a recommendation.

Discussion: Beginning with a 24 month review after a Ticket is assigned to an EN, the proposed regulations require the Program Manager to assess whether a beneficiary is making "timely progress towards self-supporting employment" which will then keep Continuing Disability Review (CDR) suspensions in place. There are no "timely progress" requirements in the statute. "Timely progress" requirements in the proposed rule are directly related to the suspension of CDRs for Ticket program users. A ticket holder must meet the "timely progress" requirements to avoid a CDR. One option would be to have the same net outcome as the proposed rule for the first three years. It would require the same minimum work standards for all Ticket participants in years three, four and five of an EN-Ticket contract with a beneficiary. The second option, and the option that the Panel is recommending, would individualize "timely progress" and place the responsibility of proof and reporting on the EN with oversight by the Program Manager.

Another question raised in discussion was, should there be set minimum requirements for employment in years four and five of Ticket use in order to keep CDR suspensions in place. The statute, and the proposed rule in Section 411.325 (e), require annual progress reports from the EN to the Program Manager using progress tracked in the Individual Work Plan.

Recommendation 6: The Panel recommends that timely progress be defined as beneficiary compliance with the terms and conditions of the IWP, as agreed to by the beneficiary and EN and that the reporting mechanism be the annual report in Section 411.325(e).

Issue 7: Should the State VR agency be allowed to use the Individual Plan for Employment (IPE) as a substitute for the Individual Work Plan (IWP)? If so, should other individualized service delivery plans be acceptable alternatives, provided they meet the minimum standards outlined in the statute for an IWP?

Summary of Input: The few commenters who touched on this issue stated that the IPE or any other work plan that meets the minimum IWP standards described in the statute should be an acceptable alternative to the IWP. They stressed the need to reduce duplication with the same person, eliminate unnecessary paperwork, and reduce administrative burden.

Discussion: If a document already exists that meets the statutory requirements of an IWP there should not be a requirement for a duplicate document. The proposed regulations recognize this and permit State VR agency to use the IPE as a substitute for the IWP. Other programs should be permitted to do the same.

Recommendation 7: SSA should permit other individualized service delivery plans to be used as a substitute to the IWP provided they meet the minimum requirements detailed in the statute.

Issue 8: When a SSA beneficiary with a ticket applies to the state VR agency for services, should the beneficiary have the option of retaining their ticket for use with other ENs?

Summary of Input: The commenters we heard from are concerned about choice, both here and in the connected context of the rule allowing only one ticket per eligible beneficiary per period of entitlement for benefits. The proposed rule should not presume that an applicant for VR services who is a SSA beneficiary would assign their ticket to VR.

Panel members received widespread comments that VR receives special treatment in many respects throughout the rule. In this context, there have been comments that § 411.385 needs clarification or change in the context of other special arrangements in the rule for the State VR agency.

NPRM Section 411.385 states:

"What does a State VR agency do if a beneficiary who is applying for services has a ticket that is available for assignment?" (a) Once the State VR agency determines that beneficiary who is applying for services has a ticket that is available for assignment (see § 411.140) and the State VR agency and the beneficiary have agreed to and signed the individualized plan for employment (IPE) required under Section 102(b) of the Rehabilitation Act of 1973, as amended, the beneficiary's ticket is considered to be assigned.

Discussion: People with disabilities are eligible for a number of public programs that offer counseling, rehabilitation, training, job placement, other employment services and support services from a wide variety of state and Federal systems and delivered at Federal, state and local levels. These systems include Federal housing programs, State developmental disabilities services, State mental health services, transportation services, one-stop training and employment services, independent living services, transition and special education, health care and related supports, and assistive technology, just to name a few. The intent of the Ticket program was to expand services and supports, not to limit them. A ticket should be seen as yet another tool that the SSA beneficiary can choose to use to supplement what is already available to the individual under current public programs. Use of the ticket should improve that individual's chance of success in employment.

Informed choice is a key concern of the Panel. The agency's outreach on the Ticket program should inform beneficiaries of the choice issues that are raised when they decide to apply for VR services. Eligibility for VR services and VR client status should not dictate when a beneficiary can use their ticket or where a beneficiary can deposit their ticket.

Recommendation 8: SSA should re-write Section 411.385 to make it clear that an SSA beneficiary with a Ticket who applies for State Vocational Rehabilitation services has a choice in deciding whether to assign his/her Ticket to the State VR agency, to assign it to another EN, or not to assign it at all.

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DISPUTE RESOLUTION AND MEDIATION

Issue 9: Should protection and advocacy services be available to all beneficiaries of the Social Security Administration regardless of whether or not they are Ticket users or living in a Ticket roll out state?

Discussion: Section 1150(a)(b) (1) and (2) of the legislation provides that SSA beneficiaries are eligible for obtaining information and advice about vocational rehabilitation and employment services and advocacy or other services that a disabled beneficiary may need to secure or regain gainful employment. There is no requirement in the legislation that a beneficiary be a ticket holder or currently living in a roll out state in order be eligible for protection and advocacy services.

Summary of Input: There was substantial public input in support of protection and advocacy services being provided to all SSA beneficiaries. Additionally, the Panel received substantial public comment regarding the fact that beneficiaries face many barriers to obtaining needed services and supports to enable them to go to work. Commenters stated over and over again that P&A; services should be available to assist all SSA beneficiaries, regardless of their status as a Ticket holder or residence in a Ticket roll out state.

Recommendation 9: All beneficiaries should have access to P&A; services.

Issue 10: Should mediation be a part of the dispute resolution process?

Summary of Input: Commenters agree that voluntary mediation should be available to all parties involved in a dispute under the Ticket to Work Program and that mediation services should be paid for by the agency.

Discussion: Subpart 1 of the proposed regulations on dispute resolution (Section 411.600 et seq.) does not address the use of mediation as a means of resolving disputes. Mediation is an informal, cost effective means of resolving disputes and should be available on a voluntary basis. Neither Section 411.600 et seq. nor Section 411.435 addresses the use of mediation as a means of resolving disputes. Sections 411.660 and 411.630 of the proposed regulations state that Social Security Administration makes the final decision in all disputes. There is no mention of an opportunity for an external review process.

Recommendation 10: Mediation should be available as an avenue for resolving disputes but it should not be mandatory. It should be an option available to the parties to the dispute, after the matter has been considered for resolution by the Program Manager.

  • All parties must agree to enter into mediation.

  • Mediation should be external to the Social Security Administration and should not be provided or paid for by protection advocacy agencies. Mediation is a more efficient and cost-effective way to resolve disputes.

  • Participation in the mediation process should not bar a party's access to further appeals.

  • The Social Security Administration should set aside additional funds to support the use of mediation for all parties.

  • The Social Security Administration should look at other successful mediation program models such as those established at EEOC and the Department of Justice.

Issue 11: Should there be an external appeals process for all parties? Should there be an opportunity for all parties to a dispute to have access to a review of SSA's decision, either through a SSA review process or an external judicial review process.

Summary of Input: Commenters were unanimous in their recommendations that all parties to disputes should have the opportunity to an external appeal process beyond what is currently offered in the regulation. This more fully ensures that fairness and impartiality are observed throughout the dispute resolution process.

Discussion: The Panel was in complete agreement.

Recommendation 11: All decisions by the Social Security Administration involving disputes between or among all parties should, at the option of the parties, be subject to external review by either the Social Security Administration's administrative review process and/ or judicial review.

Issues 12 - 14: At what point or points should a beneficiary receive information about the availability of protection and advocacy services and in what format should such information and other materials be provided?

Summary of Input: The Panel heard widespread comments that beneficiaries should be provided with notice of their right to advocacy and representation several times throughout their Ticket experience. Beneficiaries will be overwhelmed with information about this new program and they should be reminded several times at key points throughout their experience of their right to legal advocacy and representation, especially, at the time of ticket issuance. All notices of this right as well as other materials must be available in the beneficiary's primary or accessible communications language the individual's primary language and or alternative formats that provides effective communication for that individual.

Discussion: Section 411.465 (regarding requirements for an IWP) and Sections 411.605 and 411.610 require notice regarding the availability of protection and advocacy assistance in resolving disputes only to beneficiaries who become Ticket users. There is no reference in the regulations to the need or requirement that all beneficiaries receive information regarding protection and advocacy assistance in areas other than dispute resolution or to beneficiaries who have not exercised their option to use their ticket.

Recommendation 12: Information about protection and advocacy services and how to access them should be available at any time to all beneficiaries seeking or using SSA or other work incentive programs, including the Ticket. Specifically, a beneficiary should receive a formal notice of the availability of protection and advocacy services when he or she is issued a Ticket and at the following junctures in the process:

  • When he or she applies to the employment network for services;
  • At the signing of his or her individual work plan;
  • In the event his or her services are decreased, suspended or terminated; and/or
  • When he or she filed a complaint against the network.

Recommendation 13: The beneficiary's filing of a complaint against an EN should, with the beneficiary's consent, trigger a notice to the protection and advocacy agency regarding the dispute to allow for an inquiry by the protection and advocacy agency as to the beneficiary's wish for protection and advocacy assistance.

Recommendation 14: Notices from the EN and the protection and advocacy agency, the beneficiary's IWP and any other documents should be in the beneficiary's primary or accessible language of communication.

Issues 15 - 17: Should there be time limits and other requirements imposed on all parties involved in the dispute resolution process?

Summary of Input: Commenters were concerned about the impact on a beneficiary once a dispute arises. One aspect of that concern is length of time it will take to resolve a complaint and what happens to the beneficiary's training and employment status during the complaint review process. It was suggested that there should be strict timelines to minimize the adverse impact on all parties when a complaint is filed.

Discussion: The Panel hosted lengthy public discussion on this topic and they were in agreement that timelines need to be spelled out in the final regulations. The proposed regulations either do not reflect timelines for a dispute resolution or, where they do, they are inadequate. For example, there are no timelines for the employment network's internal grievance process or the Social Security Administration's review process. (See Sections 411.435, 411.615, 411.625, and 411.630.)

Recommendations 15: Timelines for dispute resolution should be follows:

  • Employment networks should have fifteen working days to resolve a complaint filed by a beneficiary. If not resolved satisfactory, the beneficiary should be permitted to request a review by the Program Manager.
  • The request for review, with the submission of all supporting documentation by both parties, should be submitted within ten (10) working days after the beneficiary receives the employment network's decision.
  • The Program Manager should complete its review and render a decision within fifteen working days, unless the parties agree to mediation.
  • If the parties agree to mediation, mediation should commence within ten (10) working days after the Program Manager receives the parties' request for mediation and should be completed within twenty (20) working days after it is scheduled.
  • The Social Security Administration should have no more than twenty (20) working days to resolve individual appeals.
  • All disputes involving Employment Networks, State vocational rehabilitation agencies, and the Program Manager must be resolved within sixty (60) working days, including Social Security Administration review and issuance of a decision.
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    Recommendation 16: During the appeals process, services and supports to the beneficiary should be continued at the same level; that is, services and supports should not be reduced or suspended by the Employment Network without the beneficiary's consent.

    Recommendation 17: All parties in a dispute should have access to all information that is being considered and used to render a decision in the dispute.

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EMPLOYMENT NETWORK PAYMENT

Issue 18: How can the milestone payment system be structured to encourage providers to serve all eligible individuals, including those who are harder to serve?

Summary of Input: As proposed, the milestone payment system allows two milestone payments to be made before the first outcome payment. These milestones recognize that those currently on either SSDI or SSI benefits who are provided job related services and return to work do not immediately reach a level of employment that makes them ineligible for cash benefits and their employment network eligible for outcome payments.

For the most part, there was consensus among commenters and the experts consulted that the milestone payment method proposed in the notice of proposed rulemaking (NPRM) is not feasible. They encouraged the Panel to recommend to the Commissioner a payment design that addresses provider choice and capitalization. As proposed, the milestone payment structure is not attractive to potential employment networks since it yields a smaller total payment than the outcome payment system. It places the majority of burden/risk on the EN and, it requires an unrealistic up-front investment by the EN. Alternative proposals were presented that add additional milestones, spread the milestone payments over 5 years, and reduce the 15% penalty incurred by ENs who choose milestone payments to 5%.

For the most part, there was consensus among commenters and the experts consulted that the milestone payment method proposed in the notice of proposed rulemaking (NPRM) is not feasible. They encouraged the Panel to recommend to the Commissioner a payment design that addresses provider choice and capitalization. As proposed, the milestone payment structure is not attractive to potential employment networks since it yields a smaller total payment than the outcome payment system. It places the majority of burden/risk on the EN and, it requires an unrealistic up-front investment by the EN. Alternative proposals were presented that add additional milestones, spread the milestone payments over 5 years, and reduce the 15% penalty incurred by ENs who choose milestone payments to 5%.

Recommendation 18: SSA Ticket implementation staff should re-evaluate the proposed payment structure to determine the feasibility of adopting a system that pays at least four milestone payments: 1) at the signing of the IWP; 2) at 3 months of SGA; 3) at 7 months of SGA; 4) at 12 months of SGA. A second-tier of the milestone system would be a system in which milestones would be individualized for beneficiaries who need significantly more supports.

Specifically the system would:

a) Pay a minimal milestone when a beneficiary and employment network signs an IWP;

b) Pay an additional milestone payment equal to the first two proposed (i.e., 3 and 7 months of SGA) at the end of 12 months of SGA;

c) Amortize the milestone payments over the entire 60-month outcome-only payment period rather than the 12 months proposed;

d) Pay a greater overall percentage of the outcome-only payment option under the milestone/outcome payment option than the proposed 85%;

e) Equalize the monthly outcome payments under the milestone/outcome payment period rather than the graduated method proposed in the NPRM;

f) Provide individualized milestones for individuals with a need for on-going support services, individuals who need high-cost accommodations, individuals who earn a sub minimum wage, and individuals who work and receive partial cash benefits along the lines of systems already in use in Massachusetts, Oklahoma and other states. (These systems use the individualized planning process to determine if and when a different set of milestones is necessary, and establish a plan for payments and accountability for the payments.)

Issue 19. How can SSA restructure the milestone-outcome payment system for SSI beneficiaries in order to account for existing work incentives?

Summary of Input: Among the various suggestions to restructure the milestone system, the Panel received comments on specific models that would allow a distinctly different payment systems for SSI beneficiaries and SSDI beneficiaries (See EN Payment Models in Appendix C.)

Discussion: The milestone system was devised as a method of sharing risk between SSA and providers. Under the proposed system, most of the risk is with the provider and requires that a person not be receiving ANY cash benefits before an outcome payment is made. SSI beneficiaries are disadvantaged because of the current $1-for-$2 cash offset in SSI work incentives. This would require SSI recipients to earn more ($360 a month more) than those on SSDI before an outcome payment is paid to an EN. As a result, ENs will be discouraged from serving the SSI population, a group that has a lower education level and a much weaker work history than the SSDI beneficiaries. This would leave SSI recipients at a distinct disadvantage in the Ticket program.

Recommendation 19: Because the Title II and Title XVI programs are distinctly different from each other with differing processes and timelines, SSA should develop two milestone payment systems; one for SSI beneficiaries and another for SSDI beneficiaries, that take into account the differences between the two programs. (See attachment C - Seifert and O'Brien models)

Issues 20- 21: How can the financial incentives to serve beneficiaries be structured to be more equitable?

Summary of Input: The Panel received briefings and documents from senior SSA officials on various return to work programs and studies undertaken by the agency, e.g., Gallup poll of potential employment networks. The results indicated that there is real interest in the program from potential providers but that certain beneficiaries, by virtue of their group affiliation (e.g., blind DI beneficiary)-may not be served as readily as others. One reason is the length of time from the beginning of service provision to the point when payments to the EN can start is distinctly longer for some groups. The Panel received extensive public comment on this issue and most advocated for a common earnings level threshold for outcome payments for all beneficiaries. Also, commenters encouraged the Panel to recommend a payment system with financial incentives to serve individuals who are harder to serve (i.e., individuals with a need for ongoing support and services, individuals who need high-cost accommodations, individuals who earn a sub minimum wage, and individuals who work and receive partial cash benefits.) Further, the Panel heard that it would be prudent of SSA to develop a payment system that includes all beneficiaries with disabilities to heighten the likelihood of savings to the programs.

Discussion: Of particular concern to the Panel are the inequities in the financial incentives structure to serve certain beneficiaries, e.g., SSI beneficiaries and the harder to serve population. As proposed, the payment systems discourage ENs from serving SSI beneficiaries because the EN would receive a smaller return for similar effort and it could take considerably longer for SSI beneficiaries to reach the point in employment when ENs can be paid. The Panel is also interested in the development of an effective milestone/outcome payment structure that would address the barriers to service provision for individuals who are harder to serve. A consistent outcome-payment threshold for all Ticket users could level the playing field, making all Ticket users equally attractive to ENs in the context of when a payment can be made.

Recommendation 20: SSA should consider applying the same earnings level ($740 monthly) for all Ticket users as the threshold for outcome payments to employment networks.

Recommendation 21: SSA should commission a full cost benefits study to evaluate the ticket program. Such a study should begin with a more complete view of the direct savings to the SSA trust fund, but should also consider savings to the Federal treasury and increased productivity to the nation as a whole. Such a study would at a minimum consider the impact of increased FICA contributions by working beneficiaries, reduced use of Medicare, cash trust fund savings by beneficiaries who work but who only receive partial cash benefits and estimated trust fund savings beyond 60 months. The study should also consider reduced use of all other government transfers and increased taxes paid. It should consider the addition to net national product of increased work. It should evaluate costs and benefits from SSA's point of view, from the view of the Federal government, from the view of the beneficiary and from society as a whole.

Issue 22: There is an internal conflict in the NPRM between the language in Section 411.510(c) and the language in Section 411.390 regarding the State Vocational Rehabilitation agency's (VR) choice of payment methods for beneficiaries who are already clients of VR.

Summary of Input: There was no public input on this issue.

Discussion: Section 411.390 of the proposed regulations says that the State VR agency may only seek payment under the cost reimbursement payment system for beneficiaries already receiving services under an IPE. This rule is in direct conflict with Section 411.510(C) that states that the state VR agency will notify the Program Manager of the payment system election for each such beneficiary. The Panel had no opinion about either of the rules but felt that the regulatory provisions should be consistent throughout.

Recommendation 22: SSA should resolve the conflict between Sections 411.510 and 411.390 regarding VR's choice of payment systems for beneficiaries who are already clients of VR.

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APPENDIX A

Schedule of Panel Meetings and Other Activities

1. July 24-25, 2000 2 Day Meeting 1 hr.
2. September 11, 2000 Teleconference 45 min
3. September 26-27, 2000 2 Day Meeting Briefing
4. November 8, 2000 Teleconference 1 hr.
5. November 13-15, 2000 3 Day Meeting 1 hr.
6. November 27, 2000 Teleconference 1 hr.
7. December 12, 2000 Teleconference 1 hr.
8. December 19, 2000 Teleconference 1 hr.
9. January 3, 2001 Teleconference 1 hr.
10. January 9-10, 2001 2 Day Meeting 2 hrs.
11. January 23, 2001 Teleconference 1 hr.
12. February 6-8, 2001 3 Day Meeting 3 hrs.

REGIONAL MEETINGS

1. January 22, 2001 Salt Lake City, Utah 0
2. January 24, 2001 Minneapolis, Minnesota 3 hrs.
3. January 25, 2001 West Coast Teleconference 2 hrs.
4. January 26, 2001 Pheonix, Arizona 4 hrs.
5. January 29, 2001 Atlanta, Georgia 4 hrs.
6. February 15, 2001 West Coast Teleconference 2 hrs.


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APPENDIX B - List of Commenters and Experts

 

Social Security Administration
Ticket to Work and Work Incentives Advisory Panel Teleconference
September 11, 2000

List of Commenters

Ron Calhoun Office of Vocational and Educational Services for Individuals with Disabilities
New York Department of Education

Jenny Kaufmann
National Senior Citizens Law Center
Washington, DC

Social Security Administration
Ticket to Work and Work Incentives Advisory Panel Teleconference International Trade Commission Washington, DC
November 8, 2000

List of Commenters

Marty Ford
Director of Government Affairs ARC of the United States Washington, DC

Cheryl Bates Harris
NAPAS
Washington, DC

Linda Landry
Disability Law Center
Boston, MA

Ann Maclaine
Director of the Louisiana Protection and Advocacy Agency New Orleans, LA

Murray Manus
Equip for Equality
Chicago, IL

Aleisa McKinlay
Public Policy Analyst Advocacy Service
Lincoln, NE

Gary Richter
Indiana Protection and Advocacy
Indianapolis, IN

Edward Wollman
Disability Community Small Business Development Center
Ann Arbor, MI

Dave Ziskind
Director of the Division of Program Administration, RSA, Vocational Rehabilitation Program
Washington, DC

Dave Zehner
Protection and Advocacy for People with Disabilities Charleston, SC

 

Social Security Administration
Ticket to Work and Work Incentives Advisory Panel Quarterly Meeting Embassy Suites at Chevy Chase Pavilion Washington, DC
November 13-15, 2000

List of Commenters

Sue Augustus
SSI Coalition
Chicago, IL

Alan Bergman
President and CEO Brain Injury Association
Alexandria, VA

Kara Freeburg
American Network of Community Options and Resources (ANCOR)
Annandale, VA

Marty Ford
Director of Government Affairs ARC of the United States Washington, DC

Charles Harles
Executive Director International Association of Business, Industry and Rehabilitation (IABIR)
Washington, DC

Mitch Jessirich
World Institute on Disability
Oakland, CA

Jenny Kaufmann
National Senior Citizens Law Center
Washington, DC

Mary Kelly
National Association of Developmental Disabilities Council Washington, DC

Dan O'Brien
Oklahoma Department of Rehabilitation Services
Oklahoma City, OK

Mike O'Brien
Oklahoma Department of Rehabilitation Services
Oklahoma City, OK

Katherine Mario
New York Vocational and Educational Services for Individuals with Disabilities (VESID)
Albany, NY

Celane McWhorter
Association for Persons in Supported Employment
Alexandria, VA

Susan Prokop
Paralyzed Veterans of America (PVA)
Washington, DC

Andrew Sperling
Director of Public Policy National Association for the Mentally Ill (NAMI)
Arlington, VA

Michael Van Essen
AIDS Assistance Organization
Palm Springs, CA

 

Social Security Administration
Ticket to Work and Work Incentives Advisory Panel Meeting
Holiday Inn Capitol Washington, DC
January 9-10, 2001

List of Commenters

Dennis Born
Program Manager Supported Employment Consultation and Training Center
Anderson, IN

Paul Seifert
IAPSRS
Columbia, MD

Charles Harles
Executive Director of INABER
Washington, DC

Damon Hicks
Supported Employment Consultation and Training Center Anderson, IN

Mike O'Brien
DRS
Oklahoma City, OK

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APPENDIX C

Model presented by Paul J. Seifert
International Association of Psycho-Social Rehabilitation Services

This proposal restructures the milestone-outcome system for SSI beneficiaries in order to account for the existing work incentives. It would allow outcome payments when the amount of earnings of a SSI recipient partially reduces their SSI check because of earnings or income. The amount paid would still be based on the maximum of 40% of the portion of the benefit not paid. Such a proposal might pay a $500 milestone the first month a SSI recipient worked and earned over $125 in gross income. A second milestone would be paid in the next month the SSI recipient earned over $325 in gross income. In any month after the second milestone was paid that the SSI recipient's income was between $326 and $550, SSA would pay an outcome payment of $53. In any month after the second milestone was paid in which the recipient's income was between $551 and $750, SSA would pay an outcome payment of $93. In any month where earnings were between $751 and $1002, SSA would pay $138. This is calculated using average Federal SSA payment as determined by SSA in calculating the payment calculation base for SSI. The amount of the outcome payment would be paid according to the 40% maximum allowed under the law.

Two EN Milestone Payment Models for SSI



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The Ticket to Work and Work Incentives Advisory Panel

Establishment of the Panel

The Ticket to Work and Work Incentives Improvement Act of 1999, Public Law 106-170, established the Ticket to Work and Work Incentives Advisory Panel (the Panel) within the Social Security Administration on December 17, 1999. Members were appointed by the President, the House of Representatives and the Senate during May and June of 2000. The Commissioner of the Social Security Administration, Kenneth S. Apfel, swore in the Panel on July 24, 2000.

Panel duties include advising the Commissioner of Social Security and reporting to the President and Congress on issues related to work incentives programs, planning, and assistance for individuals with disabilities and the Ticket to Work and Self-Sufficiency Program established under the Ticket to Work and Work Incentives Improvement Act (TWWIIA).

The Panel is composed of 12 members. The President, the Senate and the House of Representatives each appointed four. Appointments are for four-year terms. Of the members first appointed, one-half are appointed for a term of two years and the remaining are appointed for four years.

The Chair of the Panel is appointed by the President for a 4-year term.

Members of the Panel

Sarah Wiggins-Mitchell, Chair

Sarah Wiggins-Mitchell, is the President and Executive Director of the New Jersey Protection and Advocacy, Inc., the designated protection and advocacy system for the State. She was appointed by President Clinton to chair the panel for a four-year term. She is a member of the New Jersey and Pennsylvania Bars and has a background in nursing and social work.

Richard V. Burkhauser, Ph.D.

Dr. Richard V. Burkhauser serves as the Professor of Policy Analysis and Chair, Department of Policy Analysis and Management at Cornell University, Ithaca, NY. He is also active as a consultant, writer and researcher, focusing on various economic and social issues relating to persons with disabilities.

Thomas P. Golden

Mr. Golden, is a faculty member of Cornell University's Program on Employment and Disability in the School of Industrial and Labor Relations in Ithaca, NY. He is currently project director for numerous efforts focusing on training and activities relating to work incentives for people with disabilities.

Kristin E. Flaten

Ms. Flaten is an Employment Consultant for Lifetrack Resources, Inc., St. Paul, MN. She started her own small business, INITIATIVES, dedicated to enhancing the lives of persons with mental illnesses by providing educational and support services, advocacy, benefits analysis, and work incentive plans.

Frances Gracechild

Frances Gracechild is the Executive Director, Resources for Independent Living, Inc., Sacramento, CA and instructor at California State University at Sacramento. She is president of Health Access America and serves as a commissioner for the California Attorney General's Commission on Disability.

Christine M. Griffin

Christine M. Griffin is the Executive Director, Disability Law Center, Boston, MA. She is a Trustee for the Paralyzed Veterans of America Spinal Cord Research Foundation and is a member of the Massachusetts and the Washington, DC Bar.

Larry D. Henderson

Mr. Henderson is the Executive Director of Independent Resources, Inc., Wilmington, DE and chair of the Developmental Disabilities Planning Council of Delaware. Prior to his current position he was associated with the Salvation Army's Family Service Department.

Jerome Kleckley

Jerome Kleckley, MSW, CSW, is the Director of Hospital Services for the Eastern Paralyzed Veterans Association in Jackson Heights, NY and an advocate for veterans with disabilities. He is a veteran of the U.S. Navy and has been actively involved in veteran's issues.

Stephanie Smith Lee

Stephanie Smith Lee is the Governmental Affairs Representative of the National Down Syndrome Society and resides in Oakton, VA. She has played a key role in the passage of federal disability legislation and has led successful grass roots advocacy efforts at the local, state and federal levels.

Bryon R. MacDonald

Mr. MacDonald is employed as a Public Policy Advocate with the World Institute on Disability, Oakland, CA. He is a Board member at large of the National Council on Independent Living and chair of that organization's Social Security Subcommittee. For many years, he has developed employment support and benefits counseling programs and served as a consultant to several advisory committees on employment support for persons with disabilities.

Stephen L. Start

Stephen L. Start is the founder, President and Chief Executive Officer of S.L. Start & Associates, Spokane, WA, a company that provides professional management, rehabilitation, and residential services for people with disabilities, seniors and economically disadvantaged individuals. He is a member of numerous national and regional residential and rehabilitation boards.

Susan Webb

Susan Webb is the President, Webb Transitions, Inc. of Phoenix, AZ. A former Social Security Disability Insurance beneficiary, she used work incentives and vocational rehabilitation services to return to work. She has served on the Board of Directors of the National Council on Independent Living for three consecutive years, serving as its Social Security Subcommittee chair.

List of Staff

Marie Parker Strahan, Executive Director
Kristen Breland
Lisa Ekman
Mildred Owens
Gordon Richmond
Ilene Zeitzer
Tamara Allen, Consultant
Theda Zawaiza, Ph.D., Consultant

 

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