Social Security Disability:

Ticket to Work Participation Has Increased, but Additional Oversight Needed

GAO-11-324: Published: May 6, 2011. Publicly Released: Jun 6, 2011.

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The Social Security Administration (SSA) pays billions of dollars in Disability Insurance and Supplemental Security Income to people with disabilities. The Ticket to Work program, established in 1999, provides eligible beneficiaries (ticket holder) with a ticket they may assign to approved service providers, called employment networks (EN). ENs are to provide services to help ticket holders obtain and retain employment and reduce dependence on SSA benefits. ENs receive payments from SSA once a ticket holder has earnings exceeding a set threshold. Due to low participation, SSA changed program regulations in 2008 to provide ENs and ticket holders with more incentives to participate. GAO examined (1) changes in ticket holder and EN participation over time, (2) the range of service approaches used by ENs, and (3) SSA's efforts to evaluate ticket holders and ENs to ensure program integrity and effectiveness. GAO analyzed SSA data, policies, and procedures, and interviewed representatives of 25 ENs, disability advocacy organizations, and SSA.

More ticket holders and ENs are participating in the Ticket to Work program since SSA revised regulations in 2008, but the overall participation rate remains low. Ticket holders assigning their tickets to ENs increased from about 22,000 in fiscal year 2007 to more than 49,000 as of July 2010. However, less than 1 percent of all ticket holders assigned their tickets to ENs and SSA has not yet studied whether regulatory changes enabled more ticket holders to obtain employment and exit the benefit rolls. During this time, ENs approved to serve ticket holders increased from 1,514 to 1,603, and SSA's ticket payments to ENs increased from $3.8 million to $13 million. However, 20 ENs, or less than 2 percent of those currently participating, have received the majority of total ticket payments from SSA. GAO found that ENs provide a range of services, including job search and retention assistance. Since the 2008 regulatory changes, which explicitly allowed ENs to pay ticket holders, an increasing number used service approaches such as sharing SSA's government-funded ticket payments with ticket holders. These ENs target ticket holders already working or ready to work, and accounted for a substantial and growing share of payments from SSA. Three ENs among those with the largest payment amounts reported providing limited or no direct services beyond passing back a portion of ticket payments to ticket holders who had sufficient earnings to qualify the ENs for payment. These ENs received a total of over $4 million in SSA payments-- nearly one-third of all SSA payments--in fiscal year 2009. Two of these ENs passed back 75 percent of SSA's ticket payments to ticket holders and kept the other 25 percent. The extent of these trends is unknown because SSA does not collect sufficient information on service approaches across all ENs. SSA lacks adequate management tools to systematically evaluate ticket holders and ENs. Since 2005, SSA has not consistently monitored or enforced ticket holders' progress toward self-supporting employment--a regulatory requirement. Ticket holders who show progress are generally exempt from medical reviews to determine their continued eligibility for benefits. Lack of systematic monitoring of timely progress has both program integrity and cost implications, such as the potential for ineligible beneficiaries to continue receiving benefits. During the course of GAO's review, SSA was beginning to resume the progress reviews, but it is too early to assess the effectiveness of these efforts. Moreover, SSA has not developed performance measures for approved ENs, as required by law, that can be used to assess their success in helping ticket holders obtain and retain employment and reduce dependency on disability benefits. Without such measures, multiple ENs communicate to ticket holders how to work and keep full disability benefits, despite the fact the ultimate goal of the Ticket program is to reduce dependence on benefits (to hear audio excerpts of GAO's calls with selected ENs, see http://www.gao.gov/products/GAO-11-324). Finally, SSA's EN approval process lacks systemic tools to ensure quality and clear and specific criteria for reviewing EN qualifications. GAO is recommending SSA take several steps, such as compiling service trend data and monitoring ticket holders' progress, to enhance program oversight. SSA agreed with two recommendations and offered alternative language for the other two to reflect actions it considers planned or under way.

Status Legend:

More Info
  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: To inform assessments of the program's cost and effectiveness and enhance SSA's oversight and monitoring of ENs and ticket holders, the Commissioner of Social Security should develop a strategy to ensure on-time completion of timely progress reviews of ticket holders and take steps to ensure the accuracy of information used to make timely progress determinations.

    Agency Affected: Social Security Administration

    Status: Closed - Implemented

    Comments: In August 2012, SSA officials reported that they have been initiating and adjudicating timely progress reviews on time since Spring 2011. Officials also reported that SSA began quality reviews in May 2012 to ensure the accuracy of information used to make timely progress determinations. According to a quality assurance procedural document, SSA randomly selects and conducts monthly audits on 5 percent of timely progress review decisions. In cases where the beneficiary self-certifies that he has met work criteria, a quality assurance analyst uses earnings records to verify earnings claims. Additionally, in cases where a beneficiary claims to have met educational criteria, a quality assurance analyst will check for documentation of the beneficiary's reported educational progress, such as transcripts, certificates of completion, and report cards.

    Recommendation: To inform assessments of the program's cost and effectiveness and enhance SSA's oversight and monitoring of ENs and ticket holders, the Commissioner of Social Security should adopt a strategy for compiling and using data on trends in employment network service provision to determine whether service approaches, such as sharing SSA ticket payments with ticket holders, are consistent with program goals of helping ticket holders find and retain employment and reduce dependency on benefits; for example, SSA could revise existing tools to compile information on service approaches used by all ENs;

    Agency Affected: Social Security Administration

    Status: Closed - Implemented

    Comments: In August 2012, SSA officials reported that they are now reviewing and approving new and existing ENs' business models (service approaches) on an ongoing basis. SSA has identified four business model categories and will track performance by business model. SSA also developed new requirements for Employment Networks (EN) with certain business models. For example, officials told us prospective employer ENs must identify in their applications available jobs paying at or above the substantial gainful activity (SGA) level into which they will place ticket holders. SSA will evaluate these ENs' ability to assist at least 80 percent of their ticket holder clients in achieving SGA-level earnings within 9 months of the ticket assignment. In the report, we raised concerns that the leading service approach entailed sharing ticket payments with ticket-holders while providing no tangible services. According to officials, SSA is now requiring ENs with a shared payment model to convert to a consumer directed services model, which only allows the EN to reimburse the beneficiary for return-to-work related expenses that the beneficiary purchased.

    Recommendation: To inform assessments of the program's cost and effectiveness and enhance SSA's oversight and monitoring of ENs and ticket holders, the Commissioner of Social Security should prioritize and carry through with a study of participating ticket holders' exits from the rolls since revisions to the program's regulations took effect in 2008.

    Agency Affected: Social Security Administration

    Status: Open

    Comments: In January 2012, SSA officials confirmed that they contracted for a study that specifically examines ticket holders' exits from the rolls since revision to the program's regulations took effect in 2008. A report on the study's findings is expected by November 30, 2012. According to the report outline provided by SSA officials, it will include statistics on months that beneficiaries have given up cash benefits specifically because of work and benefits forgone for work for all Ticket to Work participants since 2002. GAO will close this recommendation once the report is issued.

    Recommendation: To inform assessments of the program's cost and effectiveness and enhance SSA's oversight and monitoring of ENs and ticket holders, the Commissioner of Social Security should move forward to develop EN performance measures consistent with the requirements of the Ticket law.

    Agency Affected: Social Security Administration

    Status: Closed - Implemented

    Comments: On August 8, 2011, SSA notified us that it has developed performance measures for employment networks. The performance measures are outlined in its Request for Quotation, published on April 27, 2011.

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