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July 1, 2002
Dear Commissioner Barnhart:
On behalf of the Ticket to Work and Work Incentives Advisory Panel (the Panel), I am writing to express the Panel's strong and unanimous support for the allocation of staffing and other resources to implement the Employment Support Representative (ESR) position in SSA field offices across the country. The Panel's strong support for implementation of the ESR position was expressed by a unanimous vote at our November 2001quarterly public meeting, and again in statements by the Panel in the February and May 2002 quarterly public meetings. Over the last two years, the Panel carefully watched as the Agency tested the ESR model and issued evaluation reports recommending implementation. We were pleased with the findings of the reports and looked forward to implementation of a permanent ESR corps. We believe the model was thoughtfully designed and tested to provide long-needed and vital direct services to SSDI beneficiaries and SSI recipients with disabilities attempting return-to-work or first-time employment.
The Panel believes the ESR model would provide a critical service designed to address the information and service needs of the Agency's customers with disabilities who want to work. In addition the ESR would provide an important and vital service to SSA customers who want to use the new Ticket to Work and Self -Sufficiency Program at this critical time of program's start-up.
The Agency's obligation to provide quality employment support services at the field level has been long overlooked and ignored. Social Security customers and their national advocates, rehabilitation providers and state service systems have registered harsh criticism and extensive complaints for many, many years regarding the lack of adequate staffing and the consistently inaccurate and misleading information that SSA field staff provide to beneficiaries who attempt employment. As a result, until the passage of the Ticket to Work and Work Incentives Improvement Act, the Social Security Administration was viewed as a major "barrier" to employment for people with disabilities. With the passage of the Act and its focus on improving choice and services in Section 121, came the promise of a new era in customer service for SSA customers with disabilities who want to work. The ESR field position is a key element in making the promise a reality.
In the past few days, a number of our Panel members have been contacted about a decision memo submitted to you by Deputy Commissioner Gerry dated June 3, 2002 and titled, Strategy to Implement the SSA Work Incentives Specialist (WIS) Corps. Deputy Commissioner Gerry's memo proposes a Work Incentive Specialist Corps as an alternative to the ESR model. It is my understanding that this new proposal would use current SSA field employees who would continue to process their regular workloads. They would have the added support of a staff person who is designated as part-time Work Incentive Specialist. This is very problematic in that the field office personnel facr huge workloads and extensive backlogs in claims processing. There is no evidence that workloads will decrease, in fact, the experts predict huge increases over the next few years.
We do not believe this new proposal adequately responds to the requirements in the Act, for establishing an internal corps of experts to address the need for accurate information and long ignored customer service needs in employment supports and work incentives. In addition, it is unresponsive to the findings and recommendations of both ESR evaluation reports.
The Panel is greatly concerned not only with the proposal itself, but also with the Agency's lack of consultation with the Panel in developing such a proposal. As you know, the Ticket to Work and Work Incentives Improvement Act in Section 121 directs the Commissioner as follows:
(1) IN GENERAL -- The Commissioner, in consultation with the Ticket to Work and Work Incentives Advisory Panel under Section 101(f) of the Ticket to Work and Work Incentives Improvement Act of 1999, shall establish a community-based work incentives planning and assistance program for the purpose of disseminating accurate information to disabled beneficiaries on work incentives programs and issues related to such programs. (emphasis added)
More specifically, under Section 121(2) (C), the Commissioner to directed to:
" . . . establish a corp of trained, accessible and responsive work incentives specialists within the Social Security Administration who will specilize in disability work incentives under titles II and XVI for the purpose of disseminating accurate information. . ." (emphasis added)
In closing, we urge you to consult with the panel before making any further decesions on the Section 121 Work Incentives Outreach Program, particularly with respect to establishing a corps of work incentives specialists within SSA. We would be very pleased to meet with you to discuss our concerns further. In the interim, please contact Marie P. Strahan, executive Staff Director, at (202) 358-6419 with any questions.
Sincerely,
Sarah Wiggins Mitchell
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