Frequently Asked Questions:
Employment Networks

Additional FAQs:

What Organizations Can Be Employment Networks (EN)?

Question: What qualifications must an applicant have to become an EN? Where do entities interested in becoming ENs apply?

Answer: An EN may be any public or private entity, so long as the EN assumes responsibility for the coordination and/or delivery of employment, vocational rehabilitation or other support services to Ticket Holders to help them achieve their employment goals. An EN may be an agency, an organization, a consortium of organizations, or an individual. For example, agencies or individuals that have been Medicaid-waiver certified as supported employment providers in the State of Florida would meet the specific qualification requirements for becoming ENs. There are two exclusions that apply to becoming an EN. (1) Federal agencies are precluded from being ENs and (2) a Ticket-eligible beneficiary may not serve as his/her own EN.

The qualifications for becoming an EN are discussed in Part II—Section 1 of the EN application, called a Request for Proposals (RFP). The RFP is available for downloading from SSA’s website, www.ssa.gov/work/enrfp.html.

CESSI, SSA’s Ticket Program Manager for Recruitment and Outreach, will answer questions about the RFP, conduct a walk-through of the application process, and even provide a courtesy pre-submission review of a completed application to ensure accuracy and completeness. Contact CESSI at 877-743-8237 (voice/TTY).

Completed EN applications should be submitted to SSA’s EN Contracts Team (ENCT) (not MAXIMUS) by e-mail to ENContracts@ssa.gov or by fax to 410-597-0429. Do not send completed applications by mail or carrier service.

For assistance in responding to the EN RFP and completing an EN application, prospective ENs are encouraged to contact CESSI at the number shown above or the ENCT by telephone (toll-free at 866-584-5180) or by email at ENContracts@ssa.gov.

Question: Can organizations that receive funding from other sources, like a Medicaid Home and Community Based Waiver, be Employment Networks? If so, are there any restrictions?

Answer: Grants/fees paid by Medicaid, State VR agencies, or any similar entities have no bearing on an agency’s ability to qualify as an EN under the Ticket program. We welcome HCB Waiver and other Medicaid funded community providers to apply to be ENs, provided they meet the following criteria.

Sec. 411.305 of the regulations defines those entities eligible to be an EN as “any … entity that assumes responsibility for the coordination and delivery of services under the Ticket to Work program to disabled beneficiaries.… A single entity or an association of or consortium of entities combining their resources is eligible to be an EN. The entity may provide these services directly or by entering into an agreement with other organizations or individuals to provide the appropriate services or other assistance that a beneficiary with a Ticket may need to find and maintain employment that reduces dependency on disability benefits. ENs may include, but are not limited to: (a) Any public or private entity, including charitable and religious organizations, that can provide directly, or arrange for other organizations or entities to provide, employment services, vocational rehabilitation services, or other support services.… ”

The Ticket program pays an EN for helping the beneficiary achieve certain employment outcomes. It does not pay for the cost of services. Although SSA has no restrictions on how EN payments may be used, you should check with your funding source(s) to determine whether EN payments might affect your existing funding or if there are any restrictions on how EN payments may be used.

Question: How will One-Stop Career Centers enter into agreements with SSA to become ENs? Section 411.310(d) of the final regulations states that “One-stop delivery systems established under subtitle B of title I of the Workforce Investment Act of 1998 (29 U.S.C. 2811 et seq.) may participate in the Ticket to Work program as ENs and do not need to respond to the RFP. However, in order to participate in the Ticket to Work program, the One-Stop delivery system must enter into an agreement with the Commissioner of Social Security to be an EN and must maintain compliance with general and specific selection criteria as described in Section 411.315 in order to remain an EN.

Answer: One-Stop delivery systems must enter into a contract with SSA in order to become an EN. The EN RFP explains the requirements for becoming an EN, as well as the duties and responsibilities of being an EN. The language found in the RFP forms the basis of the eventual EN contract. That is why a One-Stop Center must become familiar with the contents of the RFP. To become an EN contractor, a One-Stop must comply with the requirements spelled out in the RFP, some of which require a written response. SSA has simplified this process.

SSA has pre-qualified One-Stop Centers to be ENs. That means they have been deemed to have met the qualification requirements found in Part II—Section 1 of the RFP and need not submit any documentation of qualifications. One-Stops are deemed to have met the liability insurance requirements found in Part IV—Section 5 and need not submit evidence of insurance coverage.

To become an EN, a One-Stop need only complete and submit to SSA the EN security and suitability clearance documents found in Part III, Contract Clauses and Part IV, EN Proposal Documentation Requirements, sections 1 through 5, of the EN RFP. This completed documentation constitutes the One-Stop’s EN contract proposal and provides the information that MAXIMUS will put on its website (www.yourtickettowork.com) to advertise to beneficiaries that the One-Stop is an approved EN and the information that MAXIMUS needs to direct deposit EN payments into the One-Stop’s bank account.

The EN RFP is available for downloading from SSA’s website, www.ssa.gov/work/enrfp.html. One-Stops interested in becoming ENs are encouraged to contact SSA’s EN Contract Team by telephone toll free at 866-584-5180 or by email at ENcontracts@ssa.gov for assistance in completing the required documentation.

Question: Will American Indian Vocational Rehabilitation programs authorized under Section 121 of the Rehabilitation Act have the ability to get reimbursement under the Cost Reimbursement program?

Answer: No. The revised Ticket regulations do not make any changes to the Cost Reimbursement program. As in the past, only State VR agencies are eligible to participate in the traditional Cost Reimbursement program.

Employer as an EN

Question: How would an employer of people with disabilities who receive SSI or SSDI benefits serve as an EN and collect Milestone and Outcome payments for employees who are already working and are earning above SGA?

Answer: An employer may collect Milestone and Outcome payments based on the same rules as a non-employer EN. If an employer who has elected the Outcome/Milestone payment system accepts assignment of the Ticket of a beneficiary who is already an employee, SSA will take into consideration work the beneficiary engaged in during the 18 months prior to Ticket assignment to determine which Phase 1 Milestone payments would be available to the employer (see FAQ regarding Recent Work Rule). Only months when the beneficiary worked with earnings above the Trial Work Period level would be considered. In determining eligibility for Phase 1 Milestones, SSA also considers whether a State Vocational Rehabilitation (VR) agency served the beneficiary first. If VR served the beneficiary first and closed the case with the beneficiary in employment, the employer EN would not be eligible for any Phase 1 Milestones. Phase 2 Milestone payments and Outcome payments would be available to the employer EN as these beneficiary employees attained the designated levels of work and earnings to trigger these payments.

If the employer EN had elected the Outcome payment system, there would be no penalty for any work done during the 18 months prior to Ticket assignment or for VR serving the beneficiary first. Rather, the employer EN would be eligible to submit for Outcome payment beginning the first month after Ticket assignment that the beneficiary’s net earnings exceed the SGA amount and the beneficiary was placed in the zero cash benefit status.

EN Payments

Question: Do “gross earnings” mean earnings before Impairment Related Work Expenses (IRWE) deductions? Or, does it just refer to earnings before taxes?

Answer: In addition to referring to earnings before taxes, gross earnings mean earnings before deductions for IRWEs and other Work Incentives (e.g., Plans for Achieving Self-Support) used to reduce a beneficiary’s earnings in order to remain eligible for cash benefits while working.

Question: To submit for the first Phase 1 Milestone, does a beneficiary need to earn $360 in a two week period or within one month?

Answer: A beneficiary must earn $360 in one calendar month for an EN to qualify for the first Phase 1 Milestone. It is SSA’s intent that the work that triggers the first Phase 1 Milestone be Trial Work level work. However, paying a Milestone based on earnings that equal or exceed 50 percent of Trial Work level earnings provides flexibility for situations when a beneficiary starts work in the middle of the month or a beneficiary needs to build up his/her stamina for work.

Question: Does the Trial Work earnings threshold (i.e., $720 in 2010) that qualifies an EN for the Phase 1 Milestones apply to blind beneficiaries?

Answer: Although the concept of Trial Work level earnings usually applies only to SSDI in terms of continued eligibility for cash benefits, the Ticket regulations use this level of earnings for both SSI and SSDI for the purposes of determining eligibility for Phase 1 Milestone payments. The Trial Work earnings threshold is subject to an annual adjustment.

It is the Substantial Gainful Activity (SGA) amount that has an annual blind and non-blind amount. The non-blind SGA amount for 2010 is $1,000 and the blind amount is $1,640. For the purpose of determining Ticket payments, these SGA amounts are used the same for determining eligibility for Phase 2 Milestone payments for both SSI and SSDI beneficiaries.

Question: If an EN pays Ticket Holders for completing a job development or job search curriculum and the pay exceeds the minimum income requirement for Phase 1 Milestones, does that count as work and qualify the EN for Milestone payments?

Answer: Job development and job search training, paid or unpaid, does not meet the requirements for payment of Phase 1 Milestones. Section 411.500 of the Ticket regulations states that “Phase 1 Milestones are based on the beneficiary achieving a level of earnings that reflects initial efforts at self-supporting employment.” Updating job search skills is not considered to be employment, as there is no employer-employee relationship wherein services of value are delivered in exchange for payment. In addition, Section 411.525 (a)(2)(i) of the Ticket regulations states that “The first Phase 1 Milestone is met when the beneficiary has worked in a month and earned as least 50percent of the amount of earnings considered to represent a Trial Work Period service month.” SSA regulations in Section 404.1592 define “services” for the purpose of defining a Trial Work service month, as work activity in employment which are “the kind normally done for pay or profit.” Prevocational training and assisting a beneficiary in preparing a resume would not normally be done for pay or profit, and, therefore, does not meet the definition of work activity as it pertains to a Trial Work Period service month for the purposes of payment of Phase 1 Milestones.

Question: Do internships count as employment for the purposes of Milestone or Outcome payments?

Answer: Yes. When an internship is a “paid” position, the earnings would count towards the requirement for Milestone payments.

Question: Can Milestone or Outcome payments be used by an EN to make payments to a beneficiary? Is so, will SSA count the payment as income for the beneficiary? If yes, is it counted as earned or unearned income?

Answer: Yes, an EN may use Milestone or Outcome payments to make payments to a beneficiary. Any payments an EN makes to a beneficiary will be treated as unearned income by Social Security, which could affect SSI benefit eligibility.

SSA must count income under the regulations, but SSA also has Work Incentives outreach efforts to help beneficiaries plan for how income affects them. In addition to SSA employees who function as Work Incentives specialists, SSA funds Work Incentive Planning and Assistance projects in communities across the country that provide benefits planning and assistance to help beneficiaries anticipate and plan for the effect of work and earnings and other income on their SSI and/or SSDI benefits.

Question: Why is the potential number of Milestone payments different in Phase 2 for SSI recipients (i.e., up to 18 payments) and SSDI beneficiaries (i.e., up to 11 payments)? Why is the number of potential Outcome payments different for SSI recipients (i.e., up to 60 payments) and SSDI beneficiaries (i.e., up to 36 payments)?

Answer: We have provided for a greater number of Milestone payments with respect to SSI recipients in acknowledgement of the fact that SSI recipients may have less work history than SSDI beneficiaries and as part of our overall effort to equalize the monetary value of the Milestone payments that potentially can be made with respect to SSI recipients versus SSDI beneficiaries. The same is true for Outcome payments. The number of SSI Outcome payment months was left at 60 under the new Ticket regulations, which changed the SSDI Outcome payment months to 36. The overall effect is to almost equalize the total potential payments that can be made to an EN with respect to SSI recipients versus SSDI beneficiaries.

Question: If a VR agency that has elected the Outcome/Milestone payment option chooses to serve a beneficiary as an EN and VR is actively working with that beneficiary under an Individualized Plan for Employment, and if the beneficiary decides to discontinue services with VR and VR closes the beneficiary’s case, how long does the beneficiary have to start reaching the levels of work and earnings that will trigger Milestone and Outcomes payments once the Ticket has been re-assigned to an EN? Also, does the beneficiary still have to be receiving service from the EN when s/he starts reaching the levels of work and earnings that trigger Milestone and Outcome payments?

Answer: The ability to begin working and/or increasing their earnings will vary from beneficiary to beneficiary. Under the Ticket to Work program there is no established timeframe in which a beneficiary must reach certain Milestones and Outcomes for the sake of participating in the program. However, there are established levels of work, education and/or technical training that a beneficiary is expected to attain each year to be considered to be making “timely progress” which is necessary to continue the suspension of medical Continuing Disability Reviews (see 411.180 (c)).

There also is no requirement for a beneficiary to remain in service with an EN for the EN to be eligible to receive EN payments. A beneficiary may un-assign his/her Ticket at any time. Nevertheless, an EN may be paid for helping a beneficiary reach work-related Milestones and/or Outcomes attained during the Ticket assignment and after the EN no longer has the Ticket assignment provided the EN can show that the services it provided contributed to the beneficiary’s attainment of the levels of work and earnings that trigger the Milestone and/or Outcome payments (see 411.581).

EN Payment Process and Procedures

Question: For evidence requirements for payment, SSA lists “original pay stubs” as primary evidence, and for secondary evidence “photocopies” of pay stubs plus a second source such as a signed beneficiary statement, state unemployment records, or Federal/state tax returns. Does this mean SSA will no longer accepted photocopies of pay stubs as primary evidence?

Answer: This is correct because SSA has more closely aligned its earnings-related evidentiary requirements for EN payments with earnings-related evidentiary requirements used by SSA for other purposes.

Question: When does SSA count earnings to determine whether an EN is entitled to a payment under the Ticket program—when they are earned or when they are actually paid?

Answer: That depends on what type of payment is being made and whether the Ticket Holder is a SSDI or SSI beneficiary, or one who receives benefits from both programs (known as a concurrent beneficiary). For all Milestone payments and for all SSDI or concurrent beneficiaries, SSA uses earnings when they are earned—by the pay period, not the pay date. For SSI, only beneficiaries during the Outcome period but before benefits are terminated; SSA uses earnings when paid. Maximus can provide training on this concept for approved ENs.

Question: If an EN is tracking a beneficiary that it previously served and learns that the beneficiary eventually went to work and reached the levels of work and earnings necessary to trigger Milestone and/or Outcome payments, can the EN collect the EN payments even though the EN is no longer serving that beneficiary?

Answer: Upon receiving a payment request, MAXIMUS will make a decision about whether an EN that formerly had the beneficiary’s Ticket assignment provided services that contributed to the beneficiary’s attainment of levels of work and earnings that triggered Milestone and/or Outcome payments (see 411.581). If more that one EN is requesting the same payment(s), MAXIMUS will determine the allocation of payment to each EN based on the contribution of services of each EN (see 411.560). These same concepts apply when an EN and a State VR agency served the same beneficiary and the VR agency was functioning as an EN.

Recent Work Rule

Question: Please explain the recent work rule and provide a scenario of someone who was working in the 18 months prior to Ticket assignment. Please break down all situations and explain when each corresponding Phase 1 payment would not be available.

Answer: Phase 1 Milestones may not be available to an EN if, during the 18 months prior to the beneficiary first assigning his/her Ticket, the beneficiary worked and had earnings at a level equal to or above the amount designated as the Trial Work (TW) level earnings for that year. The Phase 1 Milestone payment would be unavailable to the EN because the EN did not incur the cost of helping the beneficiary achieve that particular level of earnings. The chart below shows the level of work as described in 411.535(a) that would prevent the payment of each of the four Phase 1 Milestones.

Milestone precluded:	If gross wages before Ticket assignment date were above the TW earnings amount ($720 in 2010) for the following timeframes:
1	Within the last calendar month prior to the first assignment on a Ticket.
2	3 months within the 6 months just prior to the first assignment on a Ticket.
3	6 months within the 12 months just prior to the first assignment on a Ticket.
4	9 months within the 18 months just prior to the first assignment on a Ticket.

Although the criteria used to determine the availability of the Phase 1 Milestones based on a beneficiary’s recent work history are patterned after the criteria used to determine the attainment of the four Phase 1 Milestones, the criteria used in the recent work rule are not cumulative. Rather, each criterion should be applied independently. Thus, if a beneficiary worked with TW level earnings during 3 of the 6 months just prior to Ticket assignment but this work did not include the month just prior to Ticket assignment, the first Phase 1 Milestone would be available to the EN when the beneficiary attained the required levels of work and earnings; however the second Phase 1 Milestone would not be available. Similarly, a beneficiary who worked 9 of the last 18 months just prior to Ticket assignment, with earnings at the TW level, might be eligible for 3 of the Phase 1 Milestones or none, depending on where the 9 months fell within the 18 month period. The example below provides an idea of how the recent work rule works. The recent work rule does not apply to Tickets assigned prior to July 21, 2008.

The recent work rule applies only to the Phase 1 Milestones. Phase 2 Milestones are available to an EN when a beneficiary attains the necessary levels of work and earnings prior to commencement of the Outcome payment period, or if after that, as part of the reconciliation payment.

MAXIMUS has created an electronic tool that can be used to explore the work and earnings history of a beneficiary and estimate the availability of each of the four Phase 1 Milestones for that particular beneficiary. Visit the MAXIMUS web site and check out the 18 Month Look Back Tool at: www.yourtickettowork.com.

Ticket Assignment

Question: According to Section 411.175, a beneficiary whose Ticket was in use before SSA determined that the beneficiary was no longer disabled, may continue to receive benefit payments, in certain circumstances. What are these circumstances?

Answer: In accordance with the other SSA regulations referenced in 411.175, a Ticket Holder who receives a decision that benefits will cease because his/her health has improved may apply for benefit continuation on the basis of being in a program of Vocational Rehabilitation with an EN or a State VR agency, or because s/he has a Plan to Achieve Self-Sufficiency (PASS) or a few other reasons. If SSA finds that the program increases the likelihood that the beneficiary will remain off the benefit rolls, the beneficiary may be awarded benefit continuation until his/her program of Vocational Rehabilitation is completed.

Question: Will a beneficiary whose VR case was closed within the past year receive a new Ticket, if he or she qualifies, and be able to assign the Ticket to an EN to receive follow-along services?

Answer: If the beneficiary is still receiving cash benefits, s/he will still have a Ticket in effect; therefore there is no need to issue a new Ticket. If VR served the beneficiary under the cost reimbursement program, Phase 2 Milestone and Outcome payments would potentially be available to the EN if the EN obtains the Ticket assignment and the beneficiary reaches the earnings levels required for those payments.

If the State VR agency served the beneficiary as an EN under the Ticket program, the beneficiary would have to submit a written request to MAXIMUS to un-assign the Ticket from VR. The beneficiary could then negotiate an Individualized Work Plan (IWP) with an EN and when the IWP is signed and submitted to MAXIMUS, the Ticket would be assigned to that EN. As the beneficiary attains the work and earnings necessary to trigger Ticket payments, the EN and the VR agency may find it necessary to share EN payments. This may be done based on an established agreement or, if no such agreement exist, MAXIMUS may be asked to make a recommendation on how EN payments should be split based on the services the beneficiary received from each and how those services contributed to the beneficiary’s successful employment.

To be certain, the individual case circumstances of the case would have to be reviewed.

Timely Progress

Question: Please define and clarify the various percentage requirements for college and vocational school training programs to be counted as timely progress. Specifically, what is 60 percent of a full-time course load? What is 75 percent? Will SSA provide examples?

Answer: Educational institutions or technical or trade schools inform students what constitutes a full-time course load for a particular institution. Once the number of credits that constitute a full-time course load is identified, the percentage of that number can be calculated. For example, if the full-time course load is 12 credits, 60 percent of 12 is 7 and 75 percent of 12 is 9. (Always round down to the nearest whole credit).

Full Timely Progress Requirements

Foundation Grantseeking Resources

Question: How can I get seed funding from a foundation or corporation?

Answer: As a current or potential Employment Network (EN), you may not have thought about using foundation funding as seed money or supplemental support for your program. Even though the “new” Ticket to Work pays more money more rapidly than the “old” Ticket, ENs still must cover upfront costs before receiving payments from the Social Security Administration (SSA). A foundation grant may be just what you need to establish your EN. CESSI has developed a proposal writing website to help ENs interested in seeking foundation or corporate funding.

Recruitment and Outreach

Frequently Asked Questions: Employment Networks