Megan O'Neil

Two demonstration projects currently hold the power to alter permanently policies that affect the ability of people with disabilities to work and build assets. Sponsored by the Social Security Administration (SSA), the Florida Freedom Initiative and the Youth Transition Demonstration will test new rules that allow people with disabilities to live more self-sufficient lives and decrease their dependency on public benefits programs.

Current disability benefits, employment, and welfare programs interact in complex ways that often discourage beneficiaries from seeking employment and increased earnings. People with disabilities often want and are able to work. Yet, getting a job may mean losing essential supports, such as health care and personal attendant services crucial to survival, as well as the dependable benefits check. People with disabilities, family members and advocates often find it difficult to make choices about benefit options and employment goals when faced with these complexities.

Of those people with disabilities who do work, the number of hours and employment opportunities are significantly constricted by program eligibility guidelines, income limitations, asset limitations, and other complex human service program interactions. Individuals with a disability who work enough to disqualify them from public health benefits- yet not enough to qualify for employer-based health insurance- may risk not being able to afford necessary wheelchairs, medications, or doctor's appointments.

The following demonstration projects seek to remove some of these policy barriers in order to test which options offer the best opportunities for people with disabilities who want a better life.

Work Incentives for Participants in the Florida Freedom Initiative

The Intent

The Florida Freedom Initiative (FFI) builds upon the current Research and Demonstration Waiver, Consumer Directed Care Plus (CDC+). FFI adopts a two-pronged approach of raising income and asset limits to allow individuals with developmental disabilities to work and explore typical housing opportunities, while maintaining their SSI eligibility until resources increase over current allowable levels. Using the principles of self-determination developed by the Center for Self-Determination, the FFI will explore opportunities to reform the system by working with the Social Security Administration.

The First Step to Personal Freedom

The FFI is a program that helps people plan and control their personal futures. With freedom comes responsibility and a willingness to learn new things. Freedom requires that a person can plan and make choices with the resources to make the plan happen. FFI is about expanding the value of the dollars an individual controls.

Many people with disabilities live in separate, substandard conditions, and depend entirely on others for the basic things all Americans want. The FFI is a way to take charge of life and not lose benefits that an individual may need in order to live. The FFI is not about just making choices from a list of services. It is about people shaping their own futures and making the future they envision a reality.

Savings: Breaking the Poverty Barrier

Most people choose the places they live, what they learn, the jobs they do and the recreation they enjoy. Too often, when a person needs some extra help to live, there are rules and policies that make it difficult to have the same choices as most individuals. In many cases, laws require that consumers of publicly funded services have little money and require those needing these services to live in poverty. FFI is a way for consumers to begin to break some of the barriers that poverty brings. One of the single best ways to make money worth more is to save. It is how most people improve the quality if their lives. Saving money increases its value.

Example:

Spend $10 per week and there is not a lot the $10 will buy. Save the same $10 for 15 weeks and you have $150. A saved amount of $150 has more buying power than the same $10 dollars spent each week. Add interest and the same $10 has still more buying power. The same money allows the buyer to have many more choices.

How the Florida Freedom Initiative Works

The Florida Freedom Initiative Demonstration is open to CDC+ enrollees who receive SSI or SSDI. The FFI enrollees retain all the benefits of being a CDC+ enrollee along with the added benefits of the Social Security Administration Waivers. Eligible enrollees begin by developing a savings plan related to long-term care and Freedom Individual Development Accounts and/or matched savings accounts.

The enrollee may save up to $10,000 per year in an approved Freedom account without affecting benefits. The enrollee will receive help from a consultant to make sure the budget is being used correctly. The dollars that are saved must be placed in an account with an intermediary institution according to a savings plan that has been approved. The plan will determine the savings goals.

In the Florida Freedom Initiative, SSA will disregard the first $280 a month of earned income plus half of the remaining earnings. This is significantly higher than the current SSI rule which disregards $65 plus half of the remaining earnings. The SSA demonstration consists of modifying a number of SSI program rules for FFI participants. (See Table 1.)

Youth Transition Demonstration

Intent

The Youth Transition Demonstration (YTD) consists of seven cooperative agreements that SSA entered into in six states in September 2003. These projects are designed to test service delivery systems to ascertain how communities can most effectively integrate services and resources to support the successful transition of youth with disabilities from high school to work or post-secondary education. SSA and the various state agencies that were awarded YTD grants recognize that this age group is particularly receptive to innovative ways to prepare for their futures. They also understand the importance of early intervention to prevent what is often an unnecessary life-long dependency on public benefits and un-employment.

Seven Sites, Seven Approaches

The six states involved are California, Colorado, Iowa, Maryland, Mississippi, and two project sites in New York. Generally, the projects work with youth aged 10 to 25 who receive SSI, Social Security Disability Insurance, or Childhood Disability Benefits (CDB), or those considered at risk of receiving these benefits. While each project varies, all seven sites received the same waivers from SSA. To learn more about each program's strategy for implementation, read each project's abstract and see Table 2 for comparisons.

Alternative SSI Programs Rules

In addition to providing the funds to conduct the demonstration projects, SSA has granted waivers for participants in the demonstration projects. These rules share themes similar to the rules created for the Florida Freedom Initiative, with some modifications. (See Table 1 for a comparison of the rules in these two demonstrations.) There are five key rules changes in the YTD.

First, following an adverse Continuing Disability Review (CDR) or age-18 medical re-determination, SSA will assume that continued YTD participation will increase the likelihood that the individual will remain off disability benefits permanently once benefits stop. Case-by-case likelihood determinations will not be made. Therefore, SSA will delay terminating benefits that result from a CDR or an age-18 re-determination until the individual has finished participation in the demonstration project.

Second, the student earned income exclusion (SEIE) applies to any YTD participant who regularly attends school, regardless of whether he or she is age 22 or over, married, or the head of a household. That is, the student does not have to be a child. Under the student earned income exclusion, SSA disregards up to $1,370 of earnings in a month, totaling no more than $5,520 for the year in 2004. (The amounts are adjusted annually for inflation. In 2005, SSA will disregard up to $1,410 of earnings in a month, totaling no more than $5,670 for the year.)

Third, SSA will exclude the first $65 plus an additional 75 percent ($3 for every $4 over $65) of monthly gross wages or net earnings from self-employment (NESE). (Reduce SSI benefits by $1 for every $4 that earned in excess of $65.) The current rules disregard only 50 percent, or $1 for every $2 after the first $65 of earnings. The YTD rule is different from the rule in the Florida Freedom Initiative, which disregards $280 plus half of the remaining earnings.

Fourth, the exclusions that apply to TANF and AFIA IDAs apply to any other IDA program in which YTD participants take part. This means:

1. Earnings deposited in IDA are deducted from gross wages or NESE.

2. Matching deposits are excluded from income.

3. All interest earned by the account is excluded from income.

4. The entire account balance (including interest) is excluded from resources.

5. Disbursements from the account for a qualified purpose (as defined by the IDA program) are excluded from income. Emergency withdrawals are loans and therefore are not income.

Fifth, ordinarily a Plan for Achieving Self-Support (PASS) must specify an occupational goal and is limited to one plan per occupational goal. Under this waiver, SSA will approve an otherwise satisfactory PASS that has either career exploration or postsecondary education as its goal. A person may investigate and attempt several types of training and/or jobs before deciding on an occupation. The only element of a PASS that is affected by this waiver is the initial goal. The goal still must be feasible and viable and must eventually reduce or eliminate the person's dependence on SSI and/or Title II disability benefits. There is no change to other PASS rules and procedures. The PASS must specify beginning and ending dates and must outline steps that reflect progress toward achievement of the goal. The PASS will take into account the reasonable length of time that the person needs to achieve his or her goal. The final objective of the PASS must be employment.

Conclusion

The recognition granted to the value of IDAs in both the Florida Freedom Initiative and the Youth Transition Demonstrations demonstrates the confidence that the Social Security Administration has in the potential of the asset building field. SSA has shown support of what the research proves about the power of building assets: that increasing a person's income is only one piece of the puzzle to end poverty. Assets not only provide an economic cushion that enable people to make investments in their futures; assets also provide a psychological orientation - toward the future, about one's children, about having a stake in America - which income alone cannot provide. These two projects reveal that the Social Security Administration agrees that the true worth of an "ownership society" is where all Americans- rich, poor, disabled or not- are included.

Table 1

Table 2

For more information on other demonstration programs, read "SSA's DISABILITY DEMONSTRATION PROJECTS LIKELY TO PROVIDE IMPORTANT INFORMATION ABOUT DISABILITY WORK INCENTIVES" Center on Budget and Policy Priorities

* Special Thanks for contributing to this article: Eileen Sweeney, Center on Budget & Policy Priorities; Renee Whaley, Florida Freedom Initiative; Leola Brooks, Suzanne Payne and Steven Fear, Social Security Administration; Marcia Yamamoto, CA Department of Rehabilitation; Judy Emery and Peter Pike, Colorado WIN Partners/UCHSC; Patty Horton, MS Department of Rehabilitation; Jack Hillyard, Karen Ackerman, and Kathryn Rarick, University of Iowa's Center for Disability and Development, Employment Policy Group; Tom Barkley and Andrew Steckl, MD State Department of Education; Frank Coco, NY State Department of Education; and Susan Locke-Scott, WNY Transition Coordination Site