Assets are a key factor in opening doors for the disability community—with assets the purchase of a home, postsecondary education and business capitalization can become a reality for economically marginalized populations such as persons with disabilities. Approximately 19.7% of the United States population (or 52.6 million) live with some level of disability.ⁱ Over one-third of adults with disabilities live in households with income of $15,000 or less compared to only 12% of those without disabilitiesⁱⁱ. Furthermore, “the disability rate for those without any high school education (38.4%) is more than three times that of those who have completed college (11.5%)”ⁱⁱⁱ. The WID IDA Program provides technical assistance and training to IDA providers to insure accessibility of their programs, thus improving successful outcomes for all of their clients.

What are IDAs?

Individual Development Accounts (IDAs) offer a unique opportunity for lower economic populations to save toward specific goals, receive savings matches, and obtain financial counseling and the assistance of a community organization. The savings may be used toward business capitalization, homeownership and post-secondary education.^iv The Corporation for Enterprise Development expressed the importance of such a tool in their publication, "IDA State Policy Guide”^v:

“Assets not only provide an economic cushion and enable people to make investments in their futures, but also provide a psychological orientation-- toward the future, about one's children, about having a stake in America – that income alone cannot provide. Also, IDA's address a big piece of the poverty puzzle -- the savings and asset base of the poor -- that has never been addressed before.”

What is the participation rate of people with disabilities in IDAs?

There is no national assessment of how many people with disabilities currently participate in IDA programs. WID conducted a literature review to assess how other organizations, including employment agencies, disability groups and vocational rehabilitation services, approach assessing disability of their clients. It was found that intake questions focusing on "functional limitations" shed light on specific disability and accommodation needs without requiring the person to self-identify as “disabled”. Furthermore, questions on functional limitations are more likely to elicit information on specific accommodation needs because the content of the question reflects upon a person’s daily experience.

California IDA providers are adding these two disability related questions to their standard IDA intake processes. This is not to say that a longer and more in-depth questionnaire would not provide a more accurate and detailed account of a participant's disability. For administrative ease this information is currently being collected using this very brief tool. The purpose of these two questions is to: 1) identify participants with a disability; 2) assess the rate of participation by persons with disabilities; 3) identify reasonable accommodations requested by participants with a disability; and 4) encourage direct communication by staff about any need for assistance for a functional limitation. If you are interested in assessing the participation rate of people with disabilities in your IDA program, please contact Megan O’Neil at the contact information listed below.

The Center on Budget and Policy Priorities published data on disability participation in Temporary Assistance for Needy Families (TANF) programs.^vi These findings may provide estimates of disability participation in IDA programs that primarily enroll TANF recipients.^vii This research states that as few as 12.2% to as many as 80% of TANF recipients have any of a broad range of physical or psychiatric disabilities in various states across the nation. For example, it was found that as many as 53.2% of TANF recipients in one state reported having a physical disability. (Physical disabilities that were commonly seen included arthritis, asthma, back injury, obesity, diabetes, thyroid problems and migraines.) Many respondents in this research were also found to have psychiatric disabilities including clinical depression, post dramatic stress disorder and general anxiety disorder. Furthermore, as many as 49% in one state were found to have learning disabilities, which in some cases were previously undiagnosed.

What is the primary barrier to IDA participation for persons with disabilities?

Supplemental Security Income: Barriers to IDA participation for persons with disabilities are most predominately experienced by those who receive Supplemental Security Income (SSI)^viii. When an individual SSI beneficiary exceeds $2,000 in assets (resources) or a married couple exceeds $3,000, their benefits may be in jeopardy.^ixx Recent changes in federal laws now allow SSI beneficiaries to have federally funded IDA accounts; however, some state funded IDA programs still do not exclude IDAs as an asset for SSI benefit considerations.

What other policy related barriers exist for people with disabilities who wish to participate in an IDA program?

Limits on Use of Funds: Additional barriers exist in the design of IDAs themselves. Specifically, the limits imposed on how IDA savings may be used, currently only allowing savings to be applied toward business capitalization, post-secondary education and homeownership, restrict a person with a disability who seeks economic independence. People with disabilities have broader needs then the three aforementioned categories, including but not limited to the purchase of assistive technology, a wheelchair, personal assistance services, or accessible transportation such as a retrofitted car. Research will need to be conducted involving people with disabilities to best determine what savings categories are really needed to support their independent living choices.

Earned Income Requirement: The cornerstone of IDAs is that earned income is necessary as a basic eligibility requirement. Beneficiaries of SSI and recipients of Social Security Disability Insurance (SSDI) who are not working but who would benefit through IDA participation are thus excluded from participation. For IDAs to be truly accessible, federal and state IDA legislation must allow people with disabilities to apply their SSI or SSDI funds to their IDA savings.

Can SSI beneficiaries participate in IDA programs?

As stated earlier, when an individual beneficiary of SSI exceeds $2,000 in assets or a married couple exceeds $3,000, benefits may be in jeopardy. Recent changes in federal statutory laws have made allowances for SSI beneficiaries to be able to build savings, a match and interest in an IDA without these assets counting against their benefits. “As a result, federally funded TANF IDAs and AFIA IDAs are now treated identically; in neither case can IDAs affect eligibility or benefit determinations”^xi. (Center on Budget and Policy Priorities) These changes are documented in the May 2001 Program Operations Manual System (POMS) that can be found online at http://policy.ssa.gov/poms.nsf/aboutpoms.^xii

Therefore, as long as the SSI beneficiary has “earned income”, meets all other qualifications to participate, and is participating in a federally funded IDA program, that individual may retain his or her SSI and Medicaid benefits.^xiii It is important to note that while IDAs are becoming more commonplace to front-line staff of the Social Security Administration, it is still important to educate caseworkers about recent changes in laws that allow SSI beneficiaries to keep their benefits.^xiv

State IDA programs and state-by-state SSI/Medicaid benefit considerations vary, and may or may not exclude IDAs from resource and asset consideration.^xv

A final consideration is that IDAs included in a Plan for Achieving Self Support (PASS) are excluded as a resource for SSI beneficiaries.^xvi PASS plans can be used for SSI beneficiary work-related goals. For more information on PASS, contact the Social Security Administration or your local Independent Living Center.^xvii

How is the Americans with Disabilities Act (ADA) relevant to IDA programs?^xviii

The Americans with Disabilities Act insures access to publicly and privately provided services in the community. To maximize IDA participation by persons with disabilities, it is critical that community service organizations have accessible premises and programs. In the spirit of the ADA, access in the form of disability awareness is also important. For more information on the ADA, go to the Department of Justice Civil Rights Division, Q&A on the ADA, http://www.usdoj.gov/crt/ada/qandaeng.htm. ADA and disability training and technical assistance services for IDA providers are offered through the World Institute on Disability—contact information is provided below.

What still needs to happen to improve accessibility of IDAs?

Ultimately, for broad scale participation in IDAs by people with disabilities, it will require collaboration on a grand scale by government agencies, IDA providers and disability organizations. State Medicaid laws must eliminate the asset test for state funded IDA programs. People with disabilities themselves will need to receive more information on IDA programs; this will require IDA stakeholders to consider disability issues in every facet of their business administration, including marketing and outreach. With a combination of policy reform, multi-agency collaboration and improving IDA program access, people with disabilities will be able to benefit from IDAs as others do in the community.

This FAQ sheet intends to address commonly asked questions regarding policy implications for people with disabilities and IDAs. Please let us know if we are not addressing all of the questions of your concern.

If you have any questions are comments please contact the Access to Assets program.

Notes