New Ticket to Work Rules Training for Supported Employment Partners November 5, 2008

What will be covered Overview of old Ticket to Work and VR Cost Reimbursement rules The new Ticket rules and how this is a major opportunity for VR and SE providers to generate new revenue for services Managing the transition: Changes in procedures How this will affect the partnerships between DVR and supported employment providers Consumer choices

Don’t Panic!

Old Ticket to Work Program Free market design, open to any providers to compete for consumer Tickets Designed to pay vocational providers for helping people get completely off benefits Payment primarily based on outcome of zero benefits paid. Very little upfront payment for intermediate outcomes

Old Ticket to Work Program Eligible beneficiaries receive a Ticket to Work Must assign that Ticket to an participating vocational provider “Employment Network” Beneficiary receives time-limited protection from disability reviews Vocational provider only gets paid when beneficiary achieves outcome

Old Ticket Payment Methods Outcome: Providers only get paid when the beneficiary zeros out their benefits as a result of work Milestone-Outcome: Minimal payments for work at SGA. Bulk of payments occur when beneficiary zeros out their benefits as a result of work

VR Cost Reimbursement Pre-dates Ticket Program but blended into Ticket Program by SSA Only available to State VR programs VR program must have Ticket assignment VR receives reimbursement for costs, if beneficiary works nine months above SGA ($940 per month in 2008).

Vermont’s DVR and SE Old Ticket Partnership Prior to July 21, 2008 DVR and SE partnership agreement was as follows: All joint DVR/SE consumers assigned the Tickets to DVR through the IPE. The VR IPE included language consenting to Ticket assignment. DVR split “cost reimbursements” 80/20 with SE agencies. DVR split “outcome payments” 50/50 Ticket funds added to following year SE grant.

Vermont’s Ticket Program DVR assigned SSI and dual beneficiaries to cost reimbursement (because we could get paid without beneficiary having to zero out benefits) DVR assigned SSDI only beneficiaries to Ticket Outcome (because they are most likely to zero out benefits) 2,600 Tickets assigned since 2002: 1,900 to VR cost reimbursement 700 to Ticket Outcome

The New Ticket Rules What is changing and what new procedures are going into place

Summary of Changes Good news: SSA will pay VR and Employment Networks more money to support beneficiaries Good news: SSA will make payments for intermediate steps toward “Substantial Gainful Activity”. We can get paid even when beneficiaries do not work themselves totally off benefits Bad news: SSA is reducing the protection from disability reviews for our customers

Milestone-Outcome Changes SSA will pay much more money for employment outcomes much earlier in process Phase One: 4 payments for earnings at $670 per month Phase Two: 11 payments for earnings at $940 per month Phase Three: 36 payments if the beneficiary is in zero payment status because of earnings

Outcome-Milestone Phase 1 Earnings Milestones Payment SSIPayment SSDI $335 for one month $1,177 $670 for three months $1,177 $670 for six months $1,177 $670 for nine months $1,177 Total Phase 1 Milestones $4,708

Gross earnings $940 per month SSDI Milestone Payment: $353 per month for 11 months SSI Milestone Payment: $203 per month for 18 months Total Phase Two Milestones $3,591 Outcome-Milestone Phase 2

Earnings above $940 per month and SSI/SSDI benefit at zero SSDI Milestone Payment: $353 per month for 36 months SSI Milestone Payment: $203 per month for 60 months Outcome-Milestone Phase 3

Key Things to Note For Phase One and Phase Two milestones beneficiary can still be receiving benefits… no disincentive to encourage use of SSA work incentives Phase One nine month period does not need to be consecutive Phase Two does not start until Phase One is complete If a beneficiary goes directly into Phase Three for 12 months, VR receives all unpaid milestones in a lump sum

Prior Work Provisions SSA will limit Phase One payments for beneficiaries who are working at ticket assignment Bottom line: SSA doesn’t want to pay Phase One Milestones for people already working This provision does not affect Phase Two and Phase Three milestone-outcomes

Prior Work Provisions MilestonePrior Work Activity that prevents payment One Month at Trial Work Level Employed at Trial Work Level ($670) in calendar month prior to assignment Three Months at a Trial Work Level Employed at Trial Work Level ($670) in 3 of the 6 calendar months prior to assignment Six Months at a Trial Work Level Employed at Trial Work Level ($670) in 6 of the 12 calendar months prior to assignment Nine Months at a Trial Work Level Employed at Trial Work Level ($670) in 9 of the 18 calendar months prior to assignment

Income Projections Projections based on 21 VR consumers in one counselor caseload enrolled in 2003 and 2004 VR Reimbursements listed are actual Milestone-Outcome payments are projected based on actual earnings Estimates are conservative and do not take into account future payments

Why the big increase? Under the lower milestone-outcome threshold VR would have received payment on 10 of 21 cases, instead of 3 under reimbursement VR would have received more money under milestone-outcome than reimbursement for the three cases ($8,319 vs $22, 886) This data suggests VR should always select milestone-outcome for all cases. This is supported with research from a larger sample

Projection with Bigger Sample

This Means…. If DVR selects Ticket milestone-outcome (instead of VR riembursment or Ticket Outcome)…. It will mean more and higher payments for joint DVR/SE partner cases

Spreading the Wealth How we will continue and enhance our partnership with the Supported Employment Agencies

How can DVR and the SE Agencies will Partner There were two options. Option One: “Partnership Plus” Option Two: A straight split of Ticket payments for joint customers

Option One: Partnership Plus DVR opens a case and bills for traditional reimbursement. The SE Agency becomes an EN The SE Agency accepts Ticket assignment SSA allows the SE Agency to bill for Phase II and Phase III milestone outcomes SSA will not pay Phase I milestones for Partnership Plus cases (Because they are reimbursing VR for upfront payments).

Option Two: Straight Split of Ticket Payments DVR accepts Ticket assignment DVR can bill for Phase I, II and III payments DVR splits all payments 50/50 with the SE Agency

Comparison Between “Partnership Plus” and “Straight Split” Partnership Plus SE Agency becomes an Employment Network VR bills “Traditional Reimbursement” The SE Agency bills for Phase II and III Milestone Outcomes only Straight Split DVR is the Employment Network DVR bills for Phase I, II and III Milestone Outcomes DVR splits payments for joint customers 50/50

DVR Recommends Option Two Because: Both DVR and the SE Agency earn more money There is no administrative burden for the SE programs SE Agencies do not have to apply to be EN’s or deal with SSA requirements

Comparison of Projected Earnings from Partnership Options (using 2000 to 2005 data) Partnership Plus DA’s earn $271,330 Straight Split DA’s earn $445,139

Vermont Ticket VR and Supported Employment Consortium DVR accepts Ticket assignment DVR does administrative work DVR bills for Phase I, II and III payments DVR splits all payments 50/50 with the supported employment partner agencies Payments to partners are incorporated into grant budgets, so funds have to be used to benefit same consumer groups

Projected Ticket Income for Vermont DVR and the SE Programs Projections based on historical analysis of VR data from 2000 to 2005 Earnings data based on Unemployment Insurance data Assumes an 80% acceptance rate of billing

Projected Ticket Income for Vermont DVR and the DA’s Projections based on historical analysis of VR data from 2000 to Earnings data based on Unemployment Insurance data. Assumes an 80% acceptance rate of billing

YearVR TicketVR ReimbVR TotalEN Ticket 2007$230,073.60$406,269.85$636,343.45$64, $517,934.40$277,271.76$795,206.16$112, $570,140.00$121,584.41$691,724.41$177, $753,525.60$62,868.03$816,393.63$162, $912,584.00$26,392.71$938,976.71$295, $924,166.40$4,744.76$928,911.16$413,496.80

Managing the Transition What is changing and what do you need to know to support our joint DVR/SE customers and maximize revenue

Ticket Assignment Process Under the old rules we only needed the IPE signed to assign the Ticket… Now we must have the customer sign the SSA form 1365 and IPE This means when SE consumers sign up for DVR as part of the grant services, they will be asked to sign a 1365 Ticket Assignment Form. In 99% of cases DVR will select the new milestone-outcome payment mechanism.

How do we discuss choices? With the new regulations… New ENs may emerge in Vermont and present competition for Tickets Out of state organizations may market to Vermont beneficiaries What should we say to our customers about their choices?

What choices do VR consumers have? VR/SE customers can choose not to assign their Ticket to VR. If they don’t assign their Ticket to VR, SSA still considers the Ticket “in use”. The “timely progress” clock starts when the IPE is signed While a VR/SE case is open they cannot assign their Ticket to another EN. Once the case is closed they can assign their Ticket to any other EN they choose VR customers can choose to un-assign his/her Ticket at any time. If they do, they lose any protection from disability reviews they have remaining.

What about the 2,600 VR and SE consumers who already assigned Tickets to VR? The 1,900 folks we assigned under cost reimbursement cannot be reassigned. The 700 assigned to the old Ticket Outcome system cannot be reassigned DVR and the VT Council of DS and MH Agencies lobbied SSA to allow us the automatically reassign these Tickets to milestone-outcome. SSA said no.

What happens with these legacy cases? VR can still bill for VR reimbursement or Ticket outcome (depending on the original assignment) The old Ticket partnership agreement applies VR will share reimbursements 80/20 VR will share outcomes 50/50

VR/SE cases assigned since April 2008 All joint cases assigned since April 2008 will be assigned to milestone outcome. All payments received under milestone outcome will be split 50/50

Managing the Ticket in your program DVR will provide the agencies lists of all SE consumers and their Ticket assignment status: unassigned, assigned reimbursement, outcome or outcome- milestone. Moving forward 100% of cases will be assigned milestone outcome. DVR will provide agency reports on payments received by consumer.

Timely Progress Provisions Original Ticket regulations automatically gave beneficiaries two years of protection from medical reviews Protection could be extended if beneficiary met “timely progress provisions” Timely progressions provisions have been suspended since 2005 so some folks have been protected for 6 years New regulations un-suspend and tighten up timely progress provisions

New Timely Progress Provisions for Suspension of Medical Review TimelineRequired Activity to Continue Suspension Year OneThree months of work at trial work level or 60% FT student Year TwoSix months of work at trial work level or 75% FT student Year ThreeNine months of work at SGA or completed two year degree Year FourNine months of work at SGA or completed additional year in school Year FiveSix months in zero benefits or additional year in school Year SixSix months in zero benefits or completed four year degree

Managing Timely Progress Provisions On anniversary of customer’s Ticket assignment, our 2,600 customers will get a timely progress letter, giving them one year to meet timely progress provisions In most cases beneficiaries will have gotten extra years of protection However, the communication from SSA may create anxiety…. Refer these questions to your local benefits counselor

Timely progress rarely matters… If a beneficiary does not meet the timely progress provisions: nothing happens… they simply go back to their regular schedule of medical reviews SSA is already behind on scheduled reviews so it may be sometime before they have a scheduled review anyway

Claims Processes VR will handle claims for all cases VR has new Ticket Claims database that automatically generates Reimbursement and Milestone- Outcome claims based on UI data UI data has a 6-9 month time lag and isn’t available for all jobs About 17% of earnings missed (primarily self-employment, border jobs)

Collecting on what UI omits Even short-lived/multiple placement may yield $1,177 Phase 1 payments Maximus AutoPay option requires upfront evidence to initiate automatic tracking We need to collect minimal evidence while still connected to consumer for some jobs: self-employment, out-of-state jobs, Federal jobs (VA, INS, CREL, USPS), nonprofit / farm workers VR database shows <45 such jobs since FY 2007 WRJ, SPR, STJ are most affected

VR may ask your help getting evidence to bill for these cases To maximize revenue Cecile will monitor placement and prompt VR counselor to request evidence VR counselor may ask SE providers to get wage stubs or other wage verification information to generate payments.

Things to Remember SSA 1365 must be completed and signed by the customer for Ticket assignment. VR initiates this process but may need your help. If the customer does not want to assign their Ticket to VR, VR can bill cost reimbursement Customers who assigned their Tickets to VR in the past are going to get “Timely Progress” letters. Most of them will have nothing to worry about; refer questions to the benefits counselors Legacy cases cannot be changed to new milestone outcome payment mechanism. When needed, help obtain earnings evidence for clients working in federal jobs, for out-of-state employers, or in self-employment.

And Finally…

Don’t Panic!

For more information… Call James Smith, Vermont Division of Vocational Rehabilitation at (802) or ahs.state.vt.us