Frequently Asked Questions about SSA’s Promoting ... - POD · Link to the POD Evaluation...

Frequently Asked Questions about SSA’s Promoting Opportunity Demonstration (POD)

SUPPORTING SSA’S PROMOTING OPPORTUNITY DEMONSTRATION (POD) MATHEMATICA POLICY RESEARCH

CONTENTS

1. POD ELIGIBILITY AND ENROLLMENT ......................................................................................... 5

Q1. Are concurrent beneficiaries eligible for POD? ................................................................... 5

Q2. Are dually entitled individuals eligible to participate in POD? ............................................. 5 Q3. If a participant becomes dually-entitled after enrolling in POD, will they be able to

remain in POD? ................................................................................................................... 5

Q4. Are beneficiaries receiving Disabled Adult Child (DAC) or Childhood Disability Benefits (CDB) eligible to enroll in POD? ........................................................................... 5

Q5. Would a beneficiary be eligible for POD even if their benefits are currently suspended? ......................................................................................................................... 5

Q6. Can an individual participate in POD if they have participated in other demonstrations? .................................................................................................................. 5

Q7. If a beneficiary moves to an area participating in POD, can they enroll in the demonstration? ................................................................................................................... 5

Q8. Can a beneficiary who is homeless and located in a shelter in the POD catchment area participate in POD? ..................................................................................................... 6

Q9. If a person does not receive a recruitment mailing packet, can they go online and obtain a packet? .................................................................................................................. 6

Q10. Do beneficiaries who want to enroll in POD need to have an open case with the state’s Vocational Rehabilitation Agency? .......................................................................... 6

Q11. Can an eligible individual enroll in POD, even if they have not received a recruitment packet in the mail? .............................................................................................................. 6

Q12. Who answers the POD toll-free telephone number? .......................................................... 6

2. BENEFITS AND THE POD BENEFIT ADJUSTMENT ................................................................... 6

Q1. Will the POD threshold amount increase to $850 per month in 2018 to reflect the 2018 increase in the Trial Work Period (TWP) benchmark? .............................................. 6

Q2. How are IRWEs counted in POD? ...................................................................................... 7 Q3. What happens to a POD participant’s benefits when the participant earns more than

the POD threshold?............................................................................................................. 7

Q4. What happens when a POD participant reaches the "break-even point"? ......................... 8

Q5. What about subsidies? ........................................................................................................ 8

Q6. On what timeframe do earnings above the POD threshold affect benefits? Are benefits affected in the same month as earnings, or is it similar to SSI where there is a 2-month budget cycle? ..................................................................................................... 8

Q7. Will the offset for a POD participant who is blind begin at the same threshold amount as for participants who are not blind? ................................................................................. 8

Q8. Will POD participation affect the benefits of participants’ dependents (auxiliaries)? .......... 8

Q9. For a participant in POD rules group 2 whose entitlement to benefits is terminated (after 12 consecutive months of having their benefits fully offset to zero), could they apply for SSDI again in the future? ..................................................................................... 9

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Q10. When SSA terminates a beneficiary’s entitlement to SSDI benefits and the beneficiary then files for expedited reinstatement (EXR), does their POD participation end? Do the POD earnings rules apply during the Initial Reinstatement Period (IRP)? .... 9

Q11. What month will POD rules revert back to current law when the demonstration ends in 2021? ............................................................................................................................ 10

Q12. Are you going to inform beneficiaries about the possibility of termination (in POD rules group 2) before they enroll in POD? ........................................................................ 10

Q13. How do POD rules and incentives compare to SSI rules and incentives? ....................... 10

Q14. Can you explain the issue of duration, and how it applies to POD? If a beneficiary returns to SGA level work within 12 months of onset, will they continue receiving benefits or will they be terminated? .................................................................................. 10

3. THE TRIAL WORK PERIOD AND EXTENDED PERIOD OF ELIGIBILITY (EPE) UPON ENTERING AND EXITING POD ................................................................................................... 10

Q1. What happens to the TWP and EPE under POD? After POD ends, will a beneficiary’s TWP and EPE go back in effect as they were before the demonstration? ....................... 10

Q2. If a beneficiary has already completed their TWP and 36-month EPE and they choose to participate in POD, would they receive an adjusted SSDI payment if they begin working above SGA? .............................................................................................. 11

Q3. If individuals are already in the TWP when they enroll in POD, will they be allowed to finish it? Can they wait to enroll until after they complete the TWP? ................................ 11

Q4. Where can individuals receiving SSDI find out how much of their TWP remains? .......... 11

Q5. If participants want to withdraw and return to regular SSDI benefits and are working over SGA and completed their Grace Period and EPE, will they receive an overpayment? ................................................................................................................... 11

Q6. If a beneficiary is in treatment group 2 and receives termination letter because his or her benefits were offset to $0 for 12 consecutive months, can that person leave the study and go into the EPE? .............................................................................................. 12

4. BENEFITS COUNSELING ............................................................................................................ 12

Q1. How many POD benefits counselors will be in place for support to the participants? ...... 12 Q2. Will POD benefits counseling services be conducted remotely or in person?.................. 12

5. WAGE REPORTING ...................................................................................................................... 12

Q1. How will POD participants report earnings? ..................................................................... 12

Q2. How will POD ensure that earnings reporting occurs in a timely manner? How will this affect the likelihood of overpayments?.............................................................................. 12

6. POD AND NON-SSA BENEFITS .................................................................................................. 13

Q1. Will terminated participants get extended Medicare? ....................................................... 13

Q2. If person also receives Medicaid/Medicare, does this affect eligibility for those programs? ......................................................................................................................... 13

Q3. In some states (for example, Nebraska), SSDI beneficiaries could become eligible for Medicaid Insurance for Workers with Disabilities once they are in a TWP. Has SSA coordinated with states regarding Medicaid requirements if an individual participates in this study? ..................................................................................................................... 13

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7. POD AND EMPLOYMENT NETWORKS ...................................................................................... 13

Q1. How does POD impact payments to Ticket to Work Employment Networks (ENs)? ....... 13

Q2. If a Beneficiaries ‘Ticket’ is assigned to an EN, and the beneficiary is referred to POD, will the beneficiary then be unassigned from the EN and re-assigned to the approved POD entity? ....................................................................................................... 14

Q3. How will POD participation affect TTW milestone/outcome payments? ........................... 14

8. POD AND SSA SYSTEMS ............................................................................................................ 15

Q1. Can WIPA providers serve POD participants? ................................................................. 15

Q2. A beneficiary was directed to WIPA by a POD toll-free line specialist. What sort of information about POD is WIPA expected to provide to a beneficiary? ........................... 15

Q3. Will POD participants be identified in ETO? ..................................................................... 15 Q4. Will BPQYs reflect POD assignment and test group assignment? ................................... 15

Q5. Will SSA field office employees be educated on POD? .................................................... 15

9. POD STUDY DESIGN AND PROCESSES ................................................................................... 15

Q1. How many participants will be involved in POD nationwide? ........................................... 15

Q2. Will additional states be joining the demonstration in the future? ..................................... 16

Q3. How were POD Implementing Organizations chosen? ..................................................... 16

Q4. What is the role of Implementing Organizations in POD? ................................................ 16 Q5. For organizations that are not implementing POD, how can they serve clients who

are interested in POD? ..................................................................................................... 16

Q6. Who constitutes the POD site staff? ................................................................................. 16

Q7. Will POD counselors use ETO? ........................................................................................ 16

Q8. Will CDRs be eliminated with the POD Program? ............................................................ 16

Q9. Will Ticket to Work (TTW) still protect clients from CDRs when making timely progress? .......................................................................................................................... 17

Q10. How likely it is that perhaps this POD study would include Upper Peninsula Counties of Michigan. All of the counties that are shown are densely populated. You may get a different perspective if you include at least one UP county of Michigan. .......................... 17

Q11. What is status of the POD project in Michigan? It was mentioned in the beginning that Michigan was different or not ready to start. ..................................................................... 17

Q12. What is the purpose of the different treatment groups in the demonstration? .................. 17

Q13. How is POD different from the BOND demonstration? ..................................................... 17

10. MATERIALS AND OTHER RESOURCES .................................................................................... 18

Q1. Can we get a list of who attended this call from my site? ................................................. 18

Q2. How can we receive POD brochures and flyers? ............................................................. 18

Q3. Will there be additional webinars/outreach to stakeholders during the enrollment period? .............................................................................................................................. 18

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1. POD Eligibility and Enrollment

Q1. Are concurrent beneficiaries eligible for POD? A1. A concurrent beneficiary is an individual who receives both SSDI and SSI benefits.

Concurrent beneficiaries are eligible for POD if they meet the eligibility criteria (described in the Federal Register notice and on webinar slide 14).

Q2. Are dually entitled individuals eligible to participate in POD? A2. No. A dually entitled beneficiary is a person who is receiving monthly benefits based on

their own record as a primary worker and also as a dependent on another SSDI beneficiary’s record - oftentimes it is a child on a parent’s record. Dually entitled beneficiaries are ineligible to enroll in POD. To be eligible for POD, a beneficiary must be entitled to SSDI benefits based on his or her own earnings record only, and meet the other eligibility requirements.

Q3. If a participant becomes dually-entitled after enrolling in POD, will they be able to remain in POD?

A3. Yes. If a POD participant becomes dually-entitled during the demonstration period, this dual-entitlement after enrollment will not affect eligibility for POD.

Q4. Are beneficiaries receiving Disabled Adult Child (DAC) or Childhood Disability Benefits (CDB) eligible to enroll in POD?

A4. No, beneficiaries receiving Disabled Adult Child (DAC) or Childhood Disability Benefits (CDB) are not eligible to enroll in POD. Additionally, those receiving Disabled Widow’s/Widower’s Benefits (DWB) are not eligible.

Q5. Would a beneficiary be eligible for POD even if their benefits are currently suspended?

A5. Yes. If a beneficiary currently has their benefits suspended due to work, they are still eligible to participate in POD if they meet the other eligibility requirements.

Q6. Can an individual participate in POD if they have participated in other demonstrations?

A6. No, beneficiaries who have participated in other demonstration projects as part of a treatment or control group are not eligible to enroll in POD.

Q7. If a beneficiary moves to an area participating in POD, can they enroll in the demonstration?

A7. To be eligible for POD, SSA’s records must show that a beneficiary is living in a POD catchment area during the enrollment period and meets the other eligibility requirements. POD enrollment is scheduled to continue through December 2018.

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Q8. Can a beneficiary who is homeless and located in a shelter in the POD catchment area participate in POD?

A8. Yes, if they have an address established in SSA records that show the individual lives within the POD catchment area. As noted above, to be eligible for POD, SSA’s records must show that a beneficiary is living in a POD catchment area.

Q9. If a person does not receive a recruitment mailing packet, can they go online and obtain a packet?

A9. Recruitment packets are not available online. However, if individuals did not receive a mailing packet and are interested in more information about the demonstration, then they are encouraged to call the POD toll free line at 888-771-9188. When the individuals contact the POD toll free line, the Evaluation Team will check their eligibility with SSA and will follow up with the callers and provide a mailing packet if applicable.

Q10. Do beneficiaries who want to enroll in POD need to have an open case with the state’s Vocational Rehabilitation Agency?

A10. Beneficiaries do not have to have an open case with VR in order to enroll and participate in POD; however, if they do not currently have a job or face barriers which may restrict their earnings potential (e.g., education, training, or transportation), then working with VR would certainly be optimal.

Q11. Can an eligible individual enroll in POD, even if they have not received a recruitment packet in the mail?

A11. Yes, beneficiaries who do not receive a recruitment packet in the mail may be eligible to enroll in POD. Individuals interested in enrolling into POD are encouraged to call the POD toll free line (888-771-9188) to speak with staff who can determine if they are eligible to enroll.

Q12. Who answers the POD toll-free telephone number? A12. We will route callers to the toll free line to staff who have the most information on the

callers’ inquiry. These staff are employed by Mathematica Policy Research or Abt Associates.

2. Benefits and the POD Benefit Adjustment

Q1. Will the POD threshold amount increase to $850 per month in 2018 to reflect the 2018 increase in the Trial Work Period (TWP) benchmark?

A1. Yes, the POD threshold will be updated to reflect yearly changes to TWP or Substantial Gainful Activity (SGA) amounts. The POD threshold for a beneficiary will be the greater of the monthly TWP for the calendar year, or the amount of the participant’s SSA-approved monthly impairment related work expenses (IRWEs) up to the monthly SGA amount for the calendar year.

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Q2. How are IRWEs counted in POD? A2. IRWEs are only relevant when they exceed the TWP amount. At that point, the amount

of reported IRWEs is considered as the POD threshold, up to the SGA amount for that calendar year. Additionally, there will be no reduction of gross earnings such as for paid time off to calculate countable income in POD. Actual earnings will be used to determine whether the POD earnings threshold is met.

Q3. What happens to a POD participant’s benefits when the participant earns more than the POD threshold?

A3. In the Federal Register notice, there are examples of how a participant’s benefits will change after earning more than the POD threshold. These examples use 2017 TWP and SGA amounts.

• Example 1, where the POD threshold is the TWP amount of $850: “A beneficiary reports monthly earnings of $1,050. The POD threshold is $850. The reported monthly earnings exceed the threshold by $200. We will reduce the beneficiary’s SSDI benefit payment by $100. The calculations for this example are as follows:

First, we calculate the monthly earnings that exceed the POD threshold.

$1,050 (monthly earnings report)

-$850 (2018 POD threshold)

= $200

Second, we calculate the $1 for $2 benefit offset amount by dividing the amount of earnings that exceeds the POD threshold by 2.

$200 ÷ 2 = $100 (monthly $1 for $2 benefit offset amount)”

• Example 2, where reported IRWEs are high enough to change the POD threshold. “A beneficiary reports monthly earnings of $1,050. The beneficiary also reports monthly itemized IRWEs of $950 and all are approved. Since the total monthly amount of itemized IRWEs is greater than $850, we use the IRWEs amount as the POD threshold. The reported monthly earnings exceed the threshold by $100. We will reduce the beneficiary’s SSDI benefit payment by $50. The calculations for this example are as follows:


$1,050 (monthly earnings report)

-$950 (POD threshold is equal to the total monthly itemized IRWEs)

= $100


- $100 ÷ 2 = $50 (monthly $1 for $2 benefit offset amount)”

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Q4. What happens when a POD participant reaches the "break-even point"? A4. We use the term ‘full offset’ to describe the break-even point, or the point at which

benefits are offset (reduced) to zero. When individuals meets the requirements for full offset, one of two things can happen depending on their assigned treatment group. If they are in POD treatment group 1, their entitlement to SSDI benefits does not change regardless of how long they are in full offset. If they are in POD treatment group 2, after 12 consecutive months of being in full offset SSA will terminate their entitlement to SSDI benefits. However, they are eligible for expedited reinstatement should their earnings drop below SGA in the future.

Q5. What about subsidies? A5. Under POD, subsidies are not considered when determining countable income for

calculating the POD offset.

Q6. On what timeframe do earnings above the POD threshold affect benefits? Are benefits affected in the same month as earnings, or is it similar to SSI where there is a 2-month budget cycle?

A6. Offset is determined based on when earnings are paid. The actual benefit that is offset is the benefit following the earnings month, which are paid to the beneficiary the following month. Example: January earnings offset February’s benefit which is paid in March.

Q7. Will the offset for a POD participant who is blind begin at the same threshold amount as for participants who are not blind?

A7. In many cases, the POD threshold amount will be the same as the TWP amount. The TWP amount is the same for blind and non-blind beneficiaries. However, if a blind POD participant has approved IRWEs that are greater than the TWP amount, then the approved IRWE amount for that month will be used as the threshold. The maximum threshold amount for a blind POD participant will be the blind SGA amount. The SGA amount is higher for blind beneficiaries than for non-blind beneficiaries.

For non-blind POD participants, if the approved monthly IRWEs amount is greater than the TWP amount, SSA will use the IRWE amount (up to the non-blind SGA amount) as the threshold.

Q8. Will POD participation affect the benefits of participants’ dependents (auxiliaries)? A8. POD will generally not affect benefit payments to auxiliaries (for example, children in

pay as dependents on a person’s record). The exception is for POD participants whose benefits are reduced to zero in a given month due to the POD offset. At that point, an auxiliary’s benefits would also be reduced to zero in that month. Further, for participants in POD rules group 2 whose benefits are fully offset to zero for 12 consecutive months, their entitlement to benefits will be terminated; this would also terminate benefits for their auxiliaries.

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Q9. For a participant in POD rules group 2 whose entitlement to benefits is terminated (after 12 consecutive months of having their benefits fully offset to zero), could they apply for SSDI again in the future?

A9. Yes, if countable monthly earnings drop to below the SGA level, the beneficiary would be able to re-apply for benefits in the future, as under current law.

Q10. When SSA terminates a beneficiary’s entitlement to SSDI benefits and the beneficiary then files for expedited reinstatement (EXR), does their POD participation end? Do the POD earnings rules apply during the Initial Reinstatement Period (IRP)?

A10. The designation as a POD participant does not end because entitlement has terminated. This is because a terminated participant may still be reinstated during the POD participation period. Please see Section 2/Q7. Those who apply for expedited reinstatement and are reinstated prior to June 30, 2021 will still be in POD unless they voluntarily withdraw from the demonstration. A group 2 participant whose entitlement is terminated under POD will remain in this terminated status unless the person is reinstated under EXR.

Under current rules, an individual who asks to be reinstated under EXR may receive up to six consecutive months of provisional payments while SSA considers whether the individual is eligible for expedited reinstatement. The month SSA reinstates the individual’s disability payments is the beginning of the initial reinstatement period (IRP). The IRP can last for 24 months (not necessarily consecutive), and ends when the individual receives 24 months of payable benefits. If the individual receives SSDI benefits, SSA can pay the person for any month during the IRP that their earnings are not substantial gainful activity (SGA).

Under POD, an individual who asks to be reinstated under EXR may receive up to six consecutive months of provisional payments while SSA considers whether the individual is eligible for expedited reinstatement (as under current law rules). A beneficiary awarded EXR entitlement while still a participant in POD will not begin their IRP until after POD participation ends. The IRP, like the TWP and EPE, are not counted during POD participation. When a participant in treatment group 2 terminates under POD rules and later becomes entitled through EXR, they will not begin their IRP until the first month after POD ends.

If a participant is reinstated through EXR during the POD participation period, the IRP is determined differently during POD. According to the Federal Register notice:

“The IRP will not apply to beneficiaries in treatment groups during POD participation.”

If a treatment group (group 1 or 2) participant enters POD during their IRP or is reinstated during POD, then the IRP or the remainder of the IRP will be deferred until the individual returns to usual rules after leaving POD.

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Q11. What month will POD rules revert back to current law when the demonstration ends in 2021?

A11. POD will end June 30, 2021. As a result, participants will revert back to current law rules July 1, 2021.

Q12. Are you going to inform beneficiaries about the possibility of termination (in POD rules group 2) before they enroll in POD?

A12. Yes. All POD participants must complete informed consent materials before enrolling in POD. These materials are included in the recruitment packet mailed to beneficiaries, and the materials explain each POD random assignment group, including the possibility of termination in group 2.

Q13. How do POD rules and incentives compare to SSI rules and incentives? A13. Broadly, the POD treatment group rules and the SSI benefits rules are similar. That is, the

benefit amount decreases gradually as beneficiary income increases. However, the details of earnings rules differ between the programs, including the point at which benefits decrease.

Q14. Can you explain the issue of duration, and how it applies to POD? If a beneficiary returns to SGA level work within 12 months of onset, will they continue receiving benefits or will they be terminated?

A14. POD Participation extends from the month of voluntary enrollment and random assignment to a treatment or control group until POD ends June 30, 2021, or until the individual in a treatment group voluntarily withdraws from the project. Withdrawal is not reversible.

A newly enrolled SSDI beneficiary who enrolls in POD, is assigned to a treatment group, and then earns above SGA within the first 12 months of entitlement is not at risk of reopening the initial determination of disability. A treatment group participant’s earnings will not be evaluated for SGA during the POD participation period unless the participant was currently under review by SSA prior to entering POD.

3. The Trial Work Period and Extended Period of Eligibility (EPE) Upon Entering and Exiting POD

Q1. What happens to the TWP and EPE under POD? After POD ends, will a beneficiary’s TWP and EPE go back in effect as they were before the demonstration?

A1. The TWP and EPE will not apply to beneficiaries in treatment groups during POD participation. Once the beneficiary’s participation in the POD ends, the beneficiary will once again be subject to usual, current law rules, and the TWP and EPE status will be the same as they were before POD. SSA will not count work or earnings under POD as completed TWP months. However, time in POD does count towards the rolling 60-month TWP window. SSA will not consider work or earnings during POD participation when determining the EPE upon returning to usual rules.

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Q2. If a beneficiary has already completed their TWP and 36-month EPE and they choose to participate in POD, would they receive an adjusted SSDI payment if they begin working above SGA?

A2. Yes, if this beneficiary is still in current pay status and otherwise eligible for POD, then SSA would adjust the benefit amount based on the POD offset. In the absence of POD, this person would not receive benefits. To update an earlier example, this could result in the following benefit offset amount:


$1,250 (monthly earnings report, amount above SGA)

-$850 (2018 POD threshold with no IRWEs, or IRWEs of no more than $840)

= $400


$400 ÷ 2 = $200 (monthly $1 for $2 benefit offset amount)

However, if before enrollment an individual’s benefits have already been terminated for work above SGA after the EPE, then the individual would not be in current pay status and therefore not eligible for POD.

Q3. If individuals are already in the TWP when they enroll in POD, will they be allowed to finish it? Can they wait to enroll until after they complete the TWP?

A3. Yes, if individuals choose to delay enrollment in POD until after they have completed their TWP, they can do so by waiting to return the recruitment mailing materials. Someone who is on track to complete the TWP within a few months can wait to enroll to take full advantage of that work incentive. However, SSA’s official notification of the TWP end date will likely not occur immediately. So, remember that POD enrollment ends on December 31, 2018, the demonstration still ends June 30, 2021, and enrollment is limited.

Q4. Where can individuals receiving SSDI find out how much of their TWP remains? A4. Beneficiaries can find out how much of their TWP is left by contacting SSA (1-800-772-

1213), a local SSA office, or a WIPA provider (866-968-7842 or 866-833-2967 (TTY)).

Q5. If participants want to withdraw and return to regular SSDI benefits and are working over SGA and completed their Grace Period and EPE, will they receive an overpayment?

A5. If the POD participant reports their monthly earnings and IRWEs accurately as planned in POD, then an overpayment is unlikely while in POD. However, if the beneficiary does not report their earnings accurately then it is possible they will receive an overpayment notice. Overpayments developed while in POD will follow the beneficiary after POD. Once they have exited from POD, either because of withdrawal or because POD ends, SSA’s evaluation of individuals’ monthly earnings will revert to usual SSDI rules. At that point, if the beneficiary continues to earn above SGA and does not contact a SSA field

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office to report their earnings, then the beneficiary could receive additional overpayments under usual SSDI rules once SSA completes a work CDR. We strongly encourage POD participants to report their earnings to a SSA field office once they have exited POD.

Q6. If a beneficiary is in treatment group 2 and receives a termination letter because his or her benefits were offset to $0 for 12 consecutive months, can that person leave the study and go into the EPE?

A6. Participants can leave the demonstration at any time regardless of which study group they are in. If the beneficiary requests to withdraw from POD prior to the 12th consecutive month of $0 benefits, then the beneficiary will return to current SSDI rules. However, a participant whose entitlement is terminated under the POD will remain in this terminated status unless the person is reinstated under expedited reinstatement (EXR) or through a refiling for SSDI. For reinstated under EXR during POD, see section 2/ Q8. If the beneficiary re-enters under EXR or by refiling and is reinstated after POD ends, then the beneficiary will start their IRP or a new TWP.

4. Benefits Counseling

Q1. How many POD benefits counselors will be in place for support to the participants? A1. The number of POD benefits counselors will vary by state and by the number of enrolled

participants. During the pilot phase of POD there will be approximately 1 counselor in each POD site. During the full roll out of POD, the number of counselors will range from 1 to 13 in each POD site.

Q2. Will POD benefits counseling services be conducted remotely or in person? A2. POD benefit counseling services will be conducted both remotely and in person,

depending on the region and the needs of the beneficiary.

5. Wage Reporting

Q1. How will POD participants report earnings? A1. Participants will have four ways to submit their monthly earnings and IRWE information:

mail, fax, electronic, or in person. For electronic submission, there will be a participant-facing Online Earnings and IRWE Reporting Portal that will enable the secure collection of earnings and IRWE information and documentation.

Q2. How will POD ensure that earnings reporting occurs in a timely manner? How will this affect the likelihood of overpayments?

A2. Abt Associates will manage the collection and submission of monthly earnings and IRWEs information from treatment subjects, including reminding beneficiaries of the need to report. Timely earnings reporting will help reduce, though will not eliminate the potential for overpayments.

Abt Associates will also conduct an annual process to collect any information that participants may have missed reporting for one or more months in the previous year, in

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advance of SSA’s annual process to reconcile the actual amount of a beneficiary’s earnings relative to the amount of benefits paid in that year.

6. POD and Non-SSA Benefits

Q1. Will terminated participants get extended Medicare? A1. Yes. The opportunity to continue Medicare coverage after SSA terminates entitlement to

SSDI benefits due to work is similar under POD and under current law. As stated in the Federal Register Notice:

“If a participant is entitled to Medicare Part A coverage because of entitlement to SSDI benefits and the SSDI entitlement is terminated as a result of the POD’s benefit offset, the participant is entitled to extended Medicare coverage for a period of 93 months following the SSDI entitlement termination, as long as the participant continues to have the same disabling impairment(s) that provided the basis for the prior SSDI entitlement and the participant meets the other SSDI entitlement requirements.”

Q2. If person also receives Medicaid/Medicare, does this affect eligibility for those programs?

A2. Because eligibility requirements for Medicaid and its respective assistance with Medicare Part B premiums and the Part D Extra Help vary from state to state, we cannot definitively answer how work and earnings will affect that eligibility. The same income and resource eligibility requirements as they exist in the individual’s area will be in force regardless of POD participation.

Q3. In some states (for example, Nebraska), SSDI beneficiaries could become eligible for Medicaid Insurance for Workers with Disabilities once they are in a TWP. Has SSA coordinated with states regarding Medicaid requirements if an individual participates in this study?

A3. Please see Section 6/Q2 above. Because eligibility requirements for Medicaid vary from state to state, we cannot definitively answer how work and earning will affect that eligibility. In some states (e.g. Nebraska), SSDI beneficiaries could become eligible for Medicaid Insurance for Workers with Disabilities (MIWD) once they are in a TWP. There will be no additional TWP usage or any EPE usage determined during POD and no determination of SGA during POD participation for treatment group members. As a result, POD participants in Nebraska may not be eligible for MIWD while in POD, but SSDI beneficiaries who are interested in POD should confirm this with a specialist by calling their WIPA provider, available on the Ticket to Work website: https://choosework.ssa.gov/findhelp/result?option=directSearch.

7. POD and Employment Networks

Q1. How does POD impact payments to Ticket to Work Employment Networks (ENs)? A1. Under current law rules, ENs receive outcome payments for months in which a

beneficiary does not receive benefits because his earnings are at or above SGA. This changes under POD; during the POD participation period, SSA will pay an outcome

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https://choosework.ssa.gov/findhelp/result?option=directSearch


payment to the provider for each month the participant earns above SGA, whether or not the SSDI benefit is reduced to zero.

Q2. If a beneficiary’s ‘Ticket’ is assigned to an EN, and the beneficiary is referred to POD, will the beneficiary then be unassigned from the EN and re-assigned to the approved POD entity?

A2. POD participation is separate from TTW and ticket assignments. A POD participant can receive POD services from an implementing organization that is also an EN, without assigning the ticket to that EN. If the POD service provider is different from the assigned EN then the assigned EN will continue to receive outcome or milestone payments.

Q3. How will POD participation affect TTW milestone/outcome payments? A3. SSA will be updating the POD POMS regarding TTW outcome and milestone/outcome

payments very soon. However, SSA expects the payment system to remain virtually the same barring the following positive outcome for the EN providers assisting those POD participants:

Instead of basing outcome payments on work continuing disability review (CDR) determinations, SSA will start the outcome period after all Phase 2 Milestone payments have been paid. SSA will determine SGA level earnings for POD participants by averaging posted earnings from one of two internal systems available to SSA: state quarterly wage reporting or annual IRS reporting.

• Phase 2 Milestone payments (if EN providers have chosen the milestone-outcome payment option) will still be applicable based on the designation of SGA-level work as indicated above.

• Beneficiaries will not have to be in benefit suspension due to over SGA level work in order for outcome payments to be payable. SGA-level work will be based on the quarterly or annual postings as above.

• Payments to EN providers for POD participants will be automatically evaluated on a quarterly basis as part of the ePay process, without the EN having to submit proof of earnings in the usual manner.

• The maximum of 36 total payments for SSDI beneficiaries, whether it is a combination of milestone-outcome payments or all outcome payments based on the ENs’ chosen payment option, will still apply.

Therefore, beneficiaries will have the opportunity to work and earn more than SGA while still maintaining some of their SSDI benefits and EN providers will still receive applicable milestone and/or outcome payments. Additionally, EN providers will not have to submit proof of earnings to the Ticket Manager for POD participants; SSA will implement an ePay system utilizing internal wage reporting records to determine SGA-level for these individuals.

For further questions regarding this topic, please contact [email protected].

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mailto:[email protected]


See also: SSA's Program Operations Manual System, Section DI 60075.030E on Field Office, Processing Center, and National 800 Number Network Responsibilities under the Promoting Opportunity Demonstration.

8. POD and SSA Systems

Q1. Can WIPA providers serve POD participants? A1. POD participants assigned to the control group will still receive benefits counseling under

WIPA. However, the study’s design expects that POD participants assigned to the treatment group only receive benefits counseling from POD counselors. In many of the POD areas, WIPA providers will be the POD counselors (under subcontract with Abt Associates).

Q2. A beneficiary was directed to WIPA by a POD toll-free line specialist. What sort of information about POD is WIPA expected to provide to a beneficiary?

A2. POD specialist staff who answer the POD toll-free line may refer beneficiaries to WIPA for several reasons. The toll-free line operators do not have access to SSA records to confirm earnings or trial work month usage (i.e. staff cannot get releases from the beneficiary and request from SSA a BPQY as WIPA or VR can). Specialists refer to WIPA those who have questions about their current situation and whether POD would benefit them. Additionally, specialists may refer beneficiaries to WIPA who do not understand the current SSDI rules after a conversation with a POD specialist.

In other words, the beneficiaries who reach out to WIPA may be looking for assistance from a counselor who can call the POD toll-free line along with them, or may need general WIPA services. We anticipate WIPA counselors will consult the toll-free line to provide POD specific information to beneficiaries.

Q3. Will POD participants be identified in ETO? A3. No, SSA is terminating ETO. However, SSA’s agents at the Ticket to Work Help Line

can tell whether a beneficiary is a POD participant.

Q4. Will BPQYs reflect POD assignment and test group assignment? A4. Yes, we expect that BPQYs will reflect POD assignment. However, they will not reflect

the specific treatment/test group. The BPQY will not reflect POD information for control group members.

Q5. Will SSA field office employees be educated on POD? A5. Yes, SSA has notified field offices about POD through an administrative message.

9. POD Study Design and Processes

Q1. How many participants will be involved in POD nationwide? A1. We expect to recruit approximately 9,000 POD participants nationwide between all of the

8 participating sites.

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Q2. Will additional states be joining the demonstration in the future? A2. No, there is no plan to add additional sites to the POD demonstration. SSA expects to

conduct POD in Alabama, California, Connecticut, Maryland, Michigan, Nebraska, Texas, and Vermont.

Q3. How were POD Implementing Organizations chosen? A3. Through a competitive process SSA contracted with Abt associates to implement POD.

Abt Associates has subcontracted with state vocational rehabilitation (VR) agencies and Work Incentive Planning and Assistance (WIPA) providers who volunteered to participate in each site.

Q4. What is the role of Implementing Organizations in POD? A4. Abt Associates is overseeing all POD implementation, including overseeing contracted

State VR agencies and WIPA providers. These state VR agencies and WIPA providers employ POD benefits counselors who deliver POD benefits counseling and assist beneficiaries with monthly earnings reporting.

Q5. For organizations that are not implementing POD, how can they serve clients who are interested in POD?

A5. Organizations that are not implementing POD have an important role in referring interested beneficiaries to the POD toll free line (1-888-771-9188), in reinforcing the legitimacy of POD to help beneficiaries understand that POD is a real demonstration program, and explaining its benefits and limitations.

Q6. Who constitutes the POD site staff? A6. “POD site staff” are the staff at state VR agencies and WIPA providers responsible for

providing or overseeing work incentives counseling and earnings reporting support. State VR agencies/WIPA providers are either filling the counselor positions internally or contracting with other organizations to provide the services.

Q7. Will POD counselors use ETO? A7. No. POD counselors will use the POD Implementation Data System to enter data related

to benefits counseling and earnings reporting.

Q8. Will CDRs be eliminated with the POD Program? A8. Work CDRs will not be part of POD. A participant’s earnings will not be evaluated for

SGA during the POD participation period.

Participants will still be subject to medical CDRs, which could result in termination of entitlement on medical grounds.

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Q9. Will Ticket to Work (TTW) still protect clients from CDRs when making timely progress?

A9. Participation in Ticket to Work will still protect clients from medical CDRs as long as the individuals are making timely process toward employment goals. This remains the same as it does for usual rules. For more information about POD and TTW, please see Section 7, Q3.

Q10. How likely is it that POD would include Upper Peninsula (UP) Counties of Michigan? All of the counties that are shown are densely populated. You may get a different perspective if you include at least one UP county of Michigan.

A10. Abt and SSA selected POD catchment areas purposively to cover different regions of the country, local labor markets, a mix of urban and rural areas, and a range of beneficiary characteristics. While the Michigan counties themselves may not cover this range, the full coverage of POD catchment areas are designed to do so.

Q11. What is status of the POD project in Michigan? It was mentioned in the beginning that Michigan was different or not ready to start.

A11. Michigan is now a POD participant state; however, only the following counties will be participating in POD: Clinton, Eaton, Genesee, Ionia, Lapeer, Shiawassee.

Q12. What is the purpose of the different treatment groups in the demonstration? A12. Congress mandated the design of the demonstration. Congress wanted to test whether the

$1-for-$2 benefits offset "ramp" is a viable replacement for the current “cash cliff.” The treatment group that will have SSDI eligibility terminated if their benefits are completely offset to zero for 12 consecutive months is most comparable to current SSDI rules. Congress wants to test if taking away the termination of benefits helps people return to work. In order to test this, there must be one treatment group that has benefits terminated after a certain amount of time and one treatment group that does not have their benefits terminated, for comparison purposes.

Q13. How is POD different from the BOND demonstration? A13. BOND is a similar SSA demonstration that tests a change to DI earnings rules and uses a

benefit offset, but there are important differences. First, in BOND beneficiaries need to complete a trial work period and be determined to have performed SGA before they are eligible for the BOND offset. For POD there is no trial work period, so beneficiaries are eligible for the POD offset as soon as they enroll and earn above the POD threshold. More broadly, under POD the rules affecting someone’s benefit adjustments are always the same. They do not change depending on whether the beneficiary has completed a trial work period or an extended period of eligibility.

Second, the POD offset occurs after a monthly adjustment above trial work period; in BOND the offset occurred after an annualized SGA.

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10. Materials and Other Resources

Q1. Can we get a list of who attended this call from my site? A1. Yes. We will share a list by site of individuals who registered for the webinar, along with

their respective organizations. Please note that some individuals who registered were not able to attend. However, all registrants are receiving our follow-up mailing.

Q2. How can we receive POD brochures and flyers? A2. We can send brochures directly to you. Please email PODEvaluation@mathematica-

mpr.com and let us know if you would like posters, brochures, or both, how many of each item you would like, and the address you would like us to ship them to.

Q3. Will there be additional webinars/outreach to stakeholders during the enrollment period?

A3. Yes, we are planning to conduct one more webinar to update stakeholders about the progress of beneficiary recruitment and enrollment. The third and final stakeholder webinar will take place on June 21, 2018. Please keep an eye out for the invitation, which will go out approximately three weeks before the event. If you have questions about this event or past webinars, please contact [email protected].

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Frequently Asked Questions about SSA’s Promoting ... - POD · Link to the POD Evaluation...

Documents

Transcript of Frequently Asked Questions about SSA’s Promoting ... - POD · Link to the POD Evaluation...