CSAVR
Employment First
In November 2007 there were nearly 7.1 million Social Security Disability Insurance (SSDI) disabled workers and another 4.2 million Supplemental Security Income (SSI) beneficiaries between the ages of 18 and 64.* Despite efforts by Congress to improve the employment rate for these beneficiaries, the remains extremely low. There is widespread agreement among rehabilitation professionals and policy experts that early intervention, provided as close to the disability onset as possible, could improve employment outcomes for individuals with disabilities who meet the Social Security definition of disability. Further, the Americans with Disabilities Act (ADA) and medical and technological advances are removing barriers to work and changing the assumptions about what people with disabilities can do and want to do.
(*SSA Office of Policy at http://www.socialsecurity.gov/policy/docs/statcomps/oasdi_monthly/2007-11/table05.html and http://www.socialsecurity.gov/policy/docs/statcomps/ssi_monthly/2008-03/table02.html)
The Council of State Administrators for Vocational Rehabilitation (CSAVR) seeks to advance a proposal for Early Intervention that would build on the mutual goal of the Social Security Administration and the Public Vocational Rehabilitation (VR) Program to increase employment outcomes and self-sufficiency for individuals with disabilities through the provision of appropriate services and supports. This proposal, the Employment First Program, would leverage the strengths of both programs in advancing this goal. The Early Intervention Demonstration (EID) concepts proposed under Section 234 of the Social Security Act were designed to test whether the provision of employment services and other types of services and supports to specially selected applicants for SSDI can improve return to work outcomes. CSAVR proposes a model that would identify those individuals most likely to pass SSA’s criteria for eligibility for SSI or SSDI and redirect many of them to the world of work through Vocational Rehabilitation. This immediate connection with an employment support program can help individuals move towards independence and self sufficiency
In addition, the Public VR program is a natural stop for individuals with disabilities who are eligible to apply for SSDI or SSI programs. The Public VR program shares a long history and productive relationship with SSA and is the most widely used employment support program for beneficiaries, and as such, the VR program is a natural place to experiment with a concept such as Employment First.
Under the Employment First Program the intent is to provide working age individuals with disabilities applying for SSI or SSDI the voluntary opportunity to learn about “work” as an option by being immediately referred to a Social Security Vocational Rehabilitation Counselor (SSVRC). The SSVRC would discuss vocational options and assist the individual in making an informed choice about participation in Employment First. Many individuals with disabilities do not understand their employment potential, and may not fully comprehend the vocational options available to them. The Employment First program provides a new avenue for addressing this issue early in the process for a person applying for Social Security benefits.
Key Components of the Employment First program are:
- The program is completely voluntary; participation does not stop the disability application process
- Immediate access to temporary cash assistance
- Immediate access to healthcare coverage
- Immediate access to vocational services to assist the person find work
- Suspension of the Social Security disability application once employment above SGA is found
- If employment fails, the work effort is not considered as evidence of ability to engage in SGA
Access to Temporary Cash Assistance
Employment First would make available temporary cash payments for the individual in an amount equal to the usual SSI or SSDI benefit amount and will include auxiliaries who live in the same household. These benefits would be paid for up to 12 months and would include an SSDI 1-for-2 earnings offset for any earnings in excess of SGA.
These temporary payments would be available during the time the individual is actively participating in the IPE and making progress towards the vocational goal spelled out in the IPE. Any commitment to provide medical assistance and/or pay for living expenses would also be included in the individual’s IPE.
Access to Medical Insurance & Other Benefits
The individual’s healthcare coverage will be determined by the cash program(s) they receive their temporary cash assistance from, SSI, SSDI, or both. The SSVRC will thoroughly review with the individual the following health care coverage options:
- Medicaid (including Medicaid Buy-In programs)
- Medicare
- Private health insurance
- Employer Based health insurance
Also, since many individuals with disabilities are likely to be eligible for other types of public assistance (e.g., food stamps, welfare, subsidized housing, etc.), the SSVRC would be responsible for providing the individual with accurate and timely information about other local, state and federal benefits. The SSVRC would have a basic understanding of benefits information, but the individual and their SSVRC would also be able to access the services of a benefits counselor.
Access to Vocational Rehabilitation Services
Under the Employment First program an SSVRC would work with the individual to develop a comprehensive review of the individual’s knowledge, skills, abilities, capabilities, resources, and interests, as well as any mental or functional limitations that might result in an impediment or a barrier to employment. Once this assessment is completed, the SSVRC will discuss the results of the assessment with the applicant, and, as appropriate, any friends or family members that might be called on to assist the individual in his/her employment efforts. This discussion will assist the applicant in identifying vocational options that are: 1) of interest to the applicant; 2) in keeping with the results of the applicant’s assessment; and 3) reasonable in terms of other relevant factors such as the local economy, the person’s ability to relocate, etc. Once appropriate vocational options have been identified, the applicant will work with the SSVRC to narrow those options and identify a specific vocational goal or employment outcome to be sought, and the services and supports needed to facilitate the applicant’s ability to achieve that vocational goal or employment outcome and have earnings that would increase the individual’s financial self-sufficiency. All of this information would then be used to develop the Individualized Plan for Employment (IPE).
Suspension of the Disability Application process
The disability application process and the Employment First application will occur simultaneously. Only once the individual has attained employment would the application for disability benefits be suspended. If the employment effort fails, the application process would be begin again using the original application date as the basis for determining eligibility. The work effort would not be considered evidence of ability to engage in SGA,
How the Process Would Work
Upon filing an application for disability benefits, the claims representative will present the applicant with the option of participating in the Employment First program. A referral will be made to the SSVRC, who will contact the applicant to discuss the benefits of participation. The SSVRC would meet with the individual to determine if the person was eligible for Employment First (i.e. they had a disability that would qualify them for disability benefits or would meet listings level for eligibility*). Two critical factors to be considered in this informed choice process would be:
- The individual’s interest in investigating employment options
- The likelihood of allowance for disability benefits
The following example illustrates how Employment First would work
Up until one year ago, Jeffrey was working as a heavy equipment operator for a construction company. He was involved in a car accident, and sustained a spinal cord injury, which has left him with quadriplegia. He is 35 years old.
When Jeffrey comes into the office, he is introduced to the SSVRC in the Social Security field office. The SSVRC does some initial screening, and talks with Jeffrey about his vocational options. The SSVRC outlines a number of potential new career options that Jeffrey had not considered. Jeffrey had reservations about going on benefits for the rest of his life but was not aware of any alternative. The possibility of returning to work is very attractive to him.
Jeffrey has an immediate need for income and the time limited
cash assistance offered under RED Employment First is
attractive. He is concerned that his application for SSDI will
be suspended. However, when the SSVRC explains that he can
always reactivate his application at a later date and that given
his disability he would almost certainly be found eligible, this
appears less of a risk. So he agrees to participate.
The SSVRC authorizes short-term cash assistance for Jeffrey and begins to develop a vocational plan with him. She also works with a local benefits counselor to help Jeffrey apply for a State low-income health coverage program and Food Stamps. This support assures that Jeffrey can maintain himself until he starts working.
The SSVRC helps Jeffrey enroll in a six-month computer training program at a local college. She links him up with the local Assistive Technology program to ensure he has the necessary equipment to compete. Four months into the program Jeffrey is offered part time work processing customer orders at a local mail order company. Because of this additional income, Jeffrey loses his eligibility for the State low income healthcare program and his Food Stamps. However, his benefits counselor helps him apply for the local Medicaid Buy In program, for which he is now eligible because he is working.
After completing the computer training program at the college, Jeffrey applies for a full time data management position at the mail order company for whom he is already working. He gets the job, which comes with health insurance after six months. He retains his eligibility of the Medicaid Buy-In and Medicaid pays his premiums for the employer-based insurance. The SSVRC ends Jeffrey’s cash stipend.
The Employment First program could have a significant positive individual and system level impact.
Individual Level Impact
The design of the Employment First Program would allow individuals applying for disability benefits a choice of the long-term disability program or a short-term concept which would include access to cash and medical benefits as well as employment supports while the individual pursued returning to work, without compromising the individual’s application for long-term benefits should employment not prove successful.
System Level Impact
Employment First would provide SSA with a vehicle for testing the concept of Early Intervention using a program with a strong national presence, a proven track record of success and a solid local infrastructure for service delivery. By providing employment services and supports choice at the point of application for SSA benefits, Employment First would also serve the purpose of developing more solid relationships between the SSA field offices, the VR program and the Benefits Counseling program.
Finally, as the VR agencies test out this model of Employment First, the programs can work together to generate recommendations on restructuring the vocational criteria within the Disability Determination process. Given the limitations of using medical criteria as the most widely-used means of determining work-related disabilities, this project could inform the national debate by giving empirical data on work potential across disability in the working-age population.
Conclusion
The Public VR program has a long history of providing employment supports to individuals with disabilities, including those individuals on the Social Security disability programs. A partnership between the largest insurer of beneficiaries and the largest provider of employment services and supports is the most logical next step for demonstrating models of early intervention.
Further, waiting until applicants with disabilities for SSDI and SSI are determined eligible before engaging them in a conversation about work incentives and employment potential misses opportunities to help these individuals recover and move into the productive world of work. This is a conversation that must begin as early as possible, occur without risk, and offer a clear alternative to the applicant. Employment First proposes this alterantive.
