[nfbmi-talk] Snyder's hiring plans
joe harcz Comcast
joeharcz at comcast.net
Tue Oct 28 11:56:42 UTC 2014
This is the report in full referenced in the story. It isn't an employment
of PWD blueprint, but rather a blueprint meant to deny PWD social security
benefits here in Michigan. Should be read carefully, and look at the players
and footnotes.
Joe Harcz
Disability Reform Work Group
Strategic Plan
Developed by the Michigan Department of Human Services, Michigan
Rehabilitation Services, Disability Determination Service, the Disability
Network and Michigan
Employers
August 2014
Executive Summary
There are 700,000 working age individuals in Michigan with disabilities and
nearly all of them have abilities that can add value in the workplace.
Unfortunately,
too often these individuals face employment barriers and a culture that does
not appreciate the skills they can bring to a job. Active participation in
the workplace by more of those with disabilities is a win/win. It can
increase self-worth while amplifying their individual and collective
"voices" in
the workplace. It can also reduce dependency on permanent disability
benefits while providing a pool of much needed talent to employers.
Michigan Department of Human Services (MDHS), disability groups and the
business community strongly believe that all individuals, including
individuals
with disabilities, are "better off working".
Based on this belief, a work group of MDHS staff, disability advocates and
employers developed this strategic plan to advance employment opportunities
for
individuals with disabilities. The goals of the strategic plan include:
§ Coordinating government and private agency resources in
cross-program settings to assist individuals with disabilities enter or
return to the
workforce.
§ Improving the health and well-being of individuals with
disabilities by promoting work participation.
§ De-emphasizing disability as a de facto public assistance program
by refocusing on the goal of returning to work.
Some of these goals can be reached with changes in state policy, processes
and more educational outreach. Others require legislative changes at the
federal
or state level.
Solutions
Assisting individuals to enter the workforce - Employees with disabilities
face obstacles that other employees do not. Helping employees get past their
barriers through supportive techniques and accommodations is essential to
successful employment. This report provides strategies to help individuals
join
the workforce by providing:
§ Job referrals
§ Team planning
§ Skill assessment and training to meet the needs of employers
Collectively these steps will help change the culture to one that embraces
"Employment First" principles. These supports can be implemented without
legislative
changes.
Making work pay - Individuals with disabilities face ineligibility for
needed disability assistance and Medicaid benefits if they exceed a limited
number
of wages; this deters working. By increasing the income and asset
eligibility limits, individuals would have incentive to work more hours
without losing
essential benefits. This goal will require legislative changes.
Increasing the marketing of the federal programs that allow increased income
and asset earning will educate individuals on how they can earn/save more by
working without losing assistance. This goal can be reached through better
outreach and does not require legislative changes.
Helping the business community to hire and retain workers - Employers who
want to hire more individuals with disabilities need assistance navigating
disability-related
requirements. This strategic goal combines the use of navigators, employer
resource networks and other vocational specialists to help employers locate,
accommodate and retain employees. These employer navigation programs can be
implemented at the state level through meaningful outreach and without
legislative
changes.
Assisting youth to overcome barriers and transition successfully into higher
education or the workforce - In 2011-2012 there were 112,872 Michigan youth
with disabilities, including 43,238 youth receiving Supplemental Security
Income (SSI). With necessary supports young people with disabilities can
participate
more fully in education and employment. Cross agency employment teams, paid
work experiences and communicating a strong message about how youth with
disabilities
can succeed, will encourage families to support their children's transitions
in school or employment and discourage reliance on their children's SSI
benefits
as de facto public assistance. These measures can be implemented through
program development and outreach and without the need for legislative
changes.
Improving the quality and uniformity of Social Security Administration
administrative law judges' decisions - In addition to helping employees and
employers
work together, we strive to make the administrative hearing process more
balanced by allowing the government an opportunity to refute the claimant's
evidence.
Currently only the claimant can provide evidence to support his or her
claim. By not having an opportunity to counter the claimants' evidence, many
claimants
may be found "disabled" in error. To bring the hearing process into balance,
it is suggested that:
· The government have legal representation, or
· A hearing and review board be created to review disability awards,
or
· Administrative Law Judges be added to the pre-effectuation reviews
of the state disability determination allowances, and
· The record be closed at the administrative hearing to prevent
delays caused by introducing new evidence on appeal.
These changes will need to be made on a federal level and may require
legislative changes.
Offsetting Unemployment Benefits (UIA) if an individual is receiving
unemployment benefits in addition to disability payments - To receive
disability (SSDI)
the individual must show that he or she cannot work. Conversely, to receive
unemployment benefits, the individual must be able to work. These two types
of assistance cannot be reconciled, and to allow both results in double
dipping. Three ideas have been introduced at the federal level to reconcile
this:
1. A dollar-for-dollar decrease in SSDI for UIA benefits.
2. When determining eligibility, do not count any month that an
individual receives UIA as a month of disability. In determining
continuation of benefits,
any month that a claimant receives both UIA and SSDI will count as a month
in which the claimant either engaged in substantial gainful activity or as
part
of the trial work period.
3. Withhold SSDI benefits for any month in which a disabled worker
receives UIA benefits.
While all three proposals will reduce overpayments and abuse of the
disability system, this work group most strongly supports the second option.
The work group is convinced that fully embracing the "better off working"
philosophy by implementing these solutions will help improve the lives of
individuals
with disabilities, provide a strong pool of talent for Michigan employers
and improve stewardship of tax dollars.
Introduction
On September 26, 2013, a group came together to identify possible reforms to
the current disability system. They sought to promote opportunities for
Michigan's
700,000 working age citizens with disabilities to actively participate in
their communities and in the workforce and to reduce the dependency on
permanent
disability benefits. The "Better Off Working" Disability Reform Work Group
(work group) involves the public and private sectors, including
representatives
of Michigan Department of Human Services (MDHS), Michigan Rehabilitation
Service (MRS), Disability Determination Service (DDS), Disability Networks
and
employers
[1].
The work group spent the past eight months investigating various strategies
including:
§ Maximization/coordination of government and private agency
resources in cross-program settings to assist individuals with disabilities
return
to the workforce.
§ Improvement of the health and well-being of individuals with
disabilities by promoting work participation.
§ De-emphasis of disability as a de facto public assistance program
by refocusing efforts on returning to work as many individuals with
disabilities
as possible.
Work group members firmly believe, regardless of disability, that all
individuals are better off working.
The work group identified the following areas for reform:
§ Encourage and assist individuals with disabilities to enter or
return to the workforce.
§ Develop incentives for individuals with disabilities to enter or
reenter the workforce.
§ Assist employers to hire and retain individuals with disabilities.
§ Provide needed support systems for youth with disabilities to
transition into the workforce.
§ Improve the quality and uniformity of Social Security
Administration (SSA) administrative law judges' decisions.
§ Offset Social Security benefits if the individual is also
receiving unemployment benefits.
I. Assist individuals with disabilities to enter or reenter the workforce
An individual with a disability who has the ability to enter or reenter the
workforce may choose not to do so for several reasons, including:
. An overall culture that does not recognize the individual's
abilities and skills.
. The lack of focused and coordinated training.
. A fear that employers do not want to recruit and hire an individual
with a disability.
. A fear that working will cause the individual to become ineligible
for cash or medical assistance.
The work group seeks to change this culture by assisting Michigan to become
an employment-first state, supporting individuals with disabilities in
overcoming
the very real barriers in learning work-related skills and helping employers
navigate the disjointed and complicated vocational rehabilitation system.
[2]
Narrow horizontal
A. Employment First
"Employment First" is a cultural paradigm where employment policies support
individuals with disabilities as a true part of the workforce. Although
there
is not a universal definition of "Employment First," this strategy generally
consists of statutory, regulatory, and operational procedures and processes
that identify employment in integrated, community-based businesses as a
priority for governmental funding.
Employment First initiatives highlight the need to raise expectations and
implement better practices around employment for individuals with
disabilities,
holding them to the same standards, responsibilities and sets of
expectations as any working-age person. This cultural paradigm shift
requires helping
employers prepare to better support and accommodate individuals with
disabilities into integrated work settings.
The Employment First mindset has not been fully embraced in Michigan, though
a few pilots and summits have discussed moving this concept forward and the
Michigan Mental Health and Wellness Commission is hoping to have legislation
introduced or an executive order issued to assist in the adoption of this
cultural paradigm.
The work group recommends that governmental agencies and private
organizations work with both the executive and legislative branches of
government to pass
legislation and draft appropriate regulations that will foster an Employment
First culture in Michigan.
B. Overcoming barriers by providing support
It is critical that individuals with disabilities receive assistance and
supports to help them on their path of gaining employment and independence.
i. A collaborative Disability Determination Service
(DDS)/Michigan Rehabilitation Services (MRS)/BSBP referral process
Currently, SSA Program Operations Manual System (POMS) and the Ticket to
Work program requirements prevent DDS from making direct referrals to
vocational
rehabilitation service agencies.
[3]
Michigan believes that the development of a cooperative referral process
between DDS and the vocational rehabilitation service agencies is absolutely
crucial
in assisting individuals with disabilities with entry or reentry into the
workforce, before they become reliant on assistance.
SSA has clarified that "DDS records and information used in the adjudication
of applications for SSDI and SSI disabled or blind benefits, or in the
determination
of continued eligibility for disability benefits under a CDR is confidential
and cannot be disclosed without a written Authorization for Release of
Information
signed by the beneficiary or the beneficiary's authorized representative".
It appears DDS can share information with vocational agencies if the
beneficiary
agrees in writing to the release of information.
To move forward, MDHS, MRS and BSBP will work cooperatively to create a set
of criteria to identify candidates who will benefit from MRS services and
are
expected to have successful rehabilitation outcomes.
[4]
The team will create a written Authorization for Release of Information form
which can be voluntarily signed by applicants who wish to take advantage of
MRS's services.
DHS will continue to measure MRS's and BSBP's return on investment relating
to its disability employment programs and the number of vocational
rehabilitation
clients who have received services and are now ready for employment.
Michigan understands that efforts are being made at the federal
congressional level to rescind the prohibition against referrals. Because
the work group
believes the ability to make referrals is crucial to individual success in
entering or re-entering the workforce, it supports these efforts and asks
SIG
members to support the efforts as well.
ii. Employment support team
Once a client is receiving services, the work group recommends creation of
an employment support team to develop person-centered employment plans. As
appropriate
to address the individual's skills level and barriers, this team could
include individuals experienced in: (1) motivational interviewing; (2)
vocational
rehabilitation; (3) employer mentoring; (4) human services; (5) intermediate
school district transition; (6) medical and mental health supports; (7)
benefit
specialists; (8) centers for independent living; and (9) certified
interpreters.
Using person-centered planning, the team will determine the medical
stability and employment objectives of the individual and will provide a
fast track
to independence by encouraging informed choices and removing disincentives
to return to work.
iii. Motivational interviewing
Motivational interviewing is an evidence-based communication tool used in
vocational rehabilitation programming and has resulted in successful
outcomes
for individuals with disabilities. Job candidates are trained on becoming
motivated, reliable and dependable.
The Michigan Behavioral Health and Developmental Disabilities Administration
provides training in the use and continued support of this tool.
Motivational
interviewing specialists work at MRS, local community mental health
services, Pathways to Potential locations, and other locations across
Michigan that
prepare individuals with disabilities for work.
The work group recommends that motivational interviewing be expanded in
Michigan to assist more job candidates with disabilities prepare to enter or
reenter
the workforce.
iv. Collaboration with other state of Michigan
departments and agencies
MDHS/MRS in collaboration with Michigan Department of Education, Michigan
Economic Development Corporation, Michigan Department of Community Health
(MDCH),
Michigan Department of Civil Rights, Bureau of Services for Blind Persons
(BSBP), Michigan Department of Licensing and Regulatory Affairs, Advisory
Council
on Deaf and Hard of Hearing, among other state agencies will align
disability-related programs with workforce and economic development programs
by linking
the State's workforce and economic development agendas.
To achieve the necessary collaboration, the work group recommends the
formation of an ad hoc committee to identify and address the needs of
individuals
with disabilities and those agencies and respective services that can be
leveraged for the purpose of putting qualifying individuals back to work.
v. Support individuals with disabilities who wish to
become entrepreneurs
Many individuals with disabilities, particularly those in rural Michigan
areas where jobs are scarce, create opportunities for themselves through
entrepreneurship.
According to the United States Census Bureau, the individuals with
disabilities are almost twice as likely to become self-employed as the
general population
- 14.7 percent compared to 8 percent.
MRS employs a dedicated small business consultant to assist promoting
self-employment for persons with disabilities. Additionally, MRS partners
with the
U.S. Business Leadership Network and the Michigan Department of Civil Rights
to assist in the disability-owned business certification process. MDHS and
MRS will improve marketing of these services.
The work group recommends that a group of staff from MDHS, BSBP, DDS, MRS,
and Plans to Achieve Self-Sufficiency (PASS) Specialists formulate
self-employment
models and a joint marketing campaign to help individuals with disabilities
learn about and access these services.
BSBP also has programs that train blind individuals to become entrepreneurs.
These programs will continue to grow to help blind individuals be successful
in the workforce. The workgroup will review the programs to see if there are
ways to make them most effective.
Business Assistance and Development Program
The Business Assistance and Development Program (BADP) is a new division
within BSBP. Its mission and goal is to guide clients into areas of business
assistance
and development, with a training process focused on blind individuals
learning business skills and developing knowledge of operating a business.
The BADP
will offer consulting services, development services, educational program,
financial assistance and guidance for small and medium size businesses
operated,
managed or owned by entrepreneurs who are legally blind. The Division will
provide customer related services with various stakeholders and associations
to encourage the growth of legally blind entrepreneurs in the private
sector. Services may include training modules for legally blind individuals
operating
in the food service industry. For example, the latest Blind Enterprise
Program facility in Lansing is also a training center for BADP clients. BADP
is
currently developing a resource guide to assist consumers in identifying
external resources for potential blind entrepreneurs.
C. Focus on skills assessment and training of workers to meet the
needs of employers
The work group recognizes that even if an individual with disabilities
wishes to enter or reenter the workforce, that person may need training in
skill
development, social skills and specific employment areas. The work group
advocates for the incorporation of a "dual customer approach" into Michigan's
service delivery system that will work with both the individual and the
employer to identify what training is needed and how to provide specific
training
or referrals for training.
i. Align and strengthen service delivery systems with the needs of
employers
The work group recommends exploring the availability of employment-related
services for employers as well as potential workers.
For example, community rehabilitation organizations employ a business
service model that collaborates with employers to respond to their specific
needs,
such as recruitment, job coaching services and certifications, serving as an
employer of record for externships and off-site training simulations.
The work group sees great value in extending this model to other Michigan
employers. This extension can be accomplished without legislative changes.
ii. Local Expansion of the Michigan Career Technical Institute (MCTI)
The Michigan Career Technical Institute (MCTI) is a training facility
operated by MRS and is located in west Michigan. The MCTI conducts
vocational and
technical training programs and provides the supportive services needed to
prepare Michigan citizens with disabilities for competitive employment. The
work group recommends that MDHS and MRS undertake a comprehensive assessment
as to whether exporting MCTI's in-house expertise and programming across the
state would result in more individuals being ready for employment, enhance
local labor markets and increase the number of employers hiring individuals
with disabilities.
D. The State of Michigan as a leader in employing individuals with
disabilities
The State of Michigan should become a leader in assisting individuals with
disabilities to find work. For example, MDHS and MRS are currently
developing
an internal, collaborative process for referring MRS work-ready recipients
as applicants for open MDHS positions. Strategies may include:
i. Designing a process to make MRS and BSBP staff aware of positions and
internships that are listed on NEO-GOV. MRS/BSBP would then notify qualified
individuals receiving rehabilitation and vocational services of vacancies
and how to apply.
ii. Reviewing and revising, as necessary, civil service exams relating to
ensure full compliance with Americans with Disabilities Act (ADA).
iii. Training state managers on disability etiquette, the various types of
accommodations and best practices relating to the employment and retention
of
individuals with disabilities who are hired by the State.
iv. Improving accommodations coordination within the Human Resources,
including maintaining effective Coordinators who will respond to employee
ADA requests,
as well as sending referrals to the BSBP and MRS-Business Network Unit for
vacancies and the need for accommodations.
II. Develop incentives for individuals with disabilities to enter or
reenter the workforce
Current SSA regulations permit an individual with a disability receiving
Social Security Disability Insurance (SSDI)
[5]
to earn only a limited amount of income from employment - known as the
Substantial Gainful Activity (SGA) amount. Once an individual exceeds this
limit,
(in 2014, $1,800 for blind individuals and $1,070 for those not deemed
blind), that individual will lose SSDI benefits. Earning even one dollar
over the
SGA can make an individual entirely ineligible for assistance.
[6]
Thus, an individual with a disability who relies on medical and cash
assistance benefits may choose not to work for fear of losing benefits. The
individual
has little incentive to enter or return to the workforce.
The work group recommends certain reforms to address this issue:
A. Temporary disability award
Congress should permit an award of temporary disability benefits, such as an
award for a set period of time, with the duration being related to various
factors such as: the gravity of the disability, the likelihood of
improvement, possible changes in the types of jobs available in the labor
market
[7],
and possible advances in assistive technology. Temporary awards recognize
the possibility of physical recovery and scientific advances in assistive
devices
that mitigate functional loss and assist with entry or reentry into the
workforce.
The availability of a temporary award encourages an individual with
disabilities to seek training for new skills and types of employment that
fit his or
her medical circumstances. Allowing SSA and state agencies to award benefits
that terminate at a definite time would dispel the notion that all
individual
beneficiaries are permanently unable to work and that disability awards
continue indefinitely, despite the ability to enter or return to the
workforce.
The "permanent disability" mindset is unequivocally detrimental to an
individual's self-esteem, self-sufficiency and mental and physical
well-being and
works against individuals having productive, fulfilling lives.
While this reform may increase the number of disability applications and
administrative hearings seeking to extend benefits, the number of
individuals who
permanently live on disability assistance as their only source of income
will decrease as individuals eventually return to work. Additionally,
individuals
whose temporary disability award expires may reapply and undergo a de novo
eligibility determination.
The work group asks the Secretaries Innovation Group (SIG) members to: (1)
underscore to Congress this recommendation as a workable method for limiting
"lifetime" (i.e., permanent) awards; and (2) persuade Congress that
temporary disability awards send a strong, yet fair, message that not only
can people
with disabilities work, but that entering or returning to the workforce is
an expectation in all but extreme cases.
B. Dispelling the fear of losing financial and medical supports
It is important that persons with disabilities are educated about the amount
they can earn and options available to improve their financial status. For
example, one of the major barriers that individuals with disabilities, who
receive SSI, must overcome is the limit on earnings for cash or medical
assistance
eligibility. SSI asset limits are currently set at $2,000 for an individual
and $3,000 for a couple. While some assets, such as a recipient's home,
defined
benefit plans
[8]
and one car, do not count against the asset limit, the SSI test generally
counts other assets, including defined-contribution retirement accounts such
as
401(k) and IRA accounts. These limits effectively discourage SSI recipients
from working and gaining valuable experience that would likely lead to
full-time
employment with benefits and saving for the future. Without the ability to
build financial reserves, participants in the SSI program are relegated to a
life of poverty.
The following programs allow persons, including youth, with disabilities to
earn and save without fear of losing their medical benefits. Attachment A
lists
work incentives and the amounts individuals currently can earn/save.
The work group urges Congress to review these programs to identify which
work and which do not and to consolidate programs where possible for a
streamlined,
easier to navigate system. The work group also recommends the development of
a clear and concise educational awareness program to clearly educate
individuals
on what they can earn/save and their work limitations.
[9]
In the meantime the work group suggests a greater emphasis on supporting
these programs:
i. Ticket to Work Investment Act of 1999, PL 106-170
(SSI and SSDI recipients)
Under the Ticket to Work Act, states can create Medicaid buy-in programs.
Michigan's Medicaid buy-in program "Freedom to Work" allows eligible
individuals
with disabilities
[10]
to save up to $75,000 in personal savings and assets and unlimited
IRS-recognized retirement accounts. Regrettably, these programs are not
being used! The
Centers for Medicare and Medicaid Services (CMMS) have not marketed the
benefits of Medicaid buy-ins. In Michigan, the Freedom to Work Medicaid
buy-in
program is only helping about 8,000 individuals.
[11]
Many more people could benefit from the program (e.g., SSDI recipients whose
eligibility for benefits end due to financial factors). Thus, the work group
recommends that the MDHS, the MDCH's Medical Services Administration
LARA/BSBP and other appropriate agencies launch a consumer education
initiative to
extol the benefits of the Freedom to Work Medicaid buy-in program and how to
become eligible for the program.
ii. Increase use of the "1619(b) Rule" (SSI recipients)
Many individuals and families with youth receiving SSI mistakenly believe
that even $1 in income will cause Medicaid benefits to cease. This myth
needs
to be dispelled. Under the "1619(b) rule," (Social Security Act at 42 USC
1382h), individuals on SSI may keep their Medicaid coverage when their
income
is too high to receive any SSI cash benefits if they meet the other
eligibility requirements and need Medicaid to continue to work.
In 2014, under the "1619(b) rule," an eligible person in Michigan could keep
Medicaid benefits while earning up to $34,260 per year in wage income.
The work group recommends SSA do more to market the 1619(b) program through
its work incentive planning and assistance grants that are active in most
states.
iii. Individual Development Accounts (SSI and SSDI
Recipients)
Individual Development Accounts (IDA) allow individuals receiving SSI to
place some of their earned income into accounts that are matched from $1 to
$8
by an IDA organization. The savings must be used for only three reasons: (1)
entrepreneurship, (2) purchase of a home, (3) training/education.
If the IDA program meets the Health and Human Services guidelines, the funds
are excluded from the SSI asset limit. There are 24 IDA organizations in
Michigan,
which can be located at
http://cfed.org/programs/idas/directory_search/.
The work group recommends better promotion of IDAs through a clear and
concise educational awareness program and through promoting the DB101
website.
iv. Achieving a Better Life Experience Act of 2013 (ABLE), S.
313/H.R.647
Congress is currently considering the Achieving a Better Life Experience
(ABLE) legislation, which would amend the Internal Revenue Code of 1986 to
allow
individuals with disabilities to establish tax-exempt accounts to pay for
"qualified disability expenses". "Qualified disability expenses" includes
expenses
for education, including higher education expenses, a primary residence,
transportation, obtaining and maintaining employment, health and wellness
and
other personal support expenses. If passed, ABLE accounts would be
disregarded when determining eligibility for Medicaid and other means-tested
federal
programs.
The work group requests that the SIG members support this bill and promote
it across governmental agencies and other organizations.
v. Promote partnerships for the successful use of Plans to Achieve
Self-Support (PASS) (SSI recipients)
PASS is a program that allows SSI-eligible adults and youth to develop a
plan to save income by diverting some of their income (earned, unearned or
both)
into a designated account. It assists eligible individuals and youth to
achieve employment goals and milestones by funding job creation, job
coaching,
clothing, school costs, business plan development and training classes. PASS
can also be used to reduce income to the level in which the individual is
eligible for SSI and other means-tested programs. The dollars set aside are
not counted as income or an asset by SSA and for other agencies or programs
(food assistance, HUD housing, etc.). PASS plans develop employment goals
and help individuals work their way off the SSI program.
At present, fewer than 60 PASS plans are active in Michigan, although
thousands of individuals qualify. While PASS plans can be difficult for
individuals
to understand and are challenging to have approved, persons with a PASS plan
are more likely to find employment and forego SSI. Additionally, if a person
with a previously open case with MRS or BSBP stops receiving SSI for nine
consecutive months, MRS/BSBP will capture a cost reimbursement from SSA of
about
$8,500. If Michigan has 30 individuals who complete their PASS plans and
remain employed for nine months, it would gain an additional $250,000 for
vocational
rehabilitation.
The work group recommends that the PASS program be better marketed in
Michigan and PASS information be incorporated into SSA work incentive
outreach programs.
Further, MRS staff should be trained to promote PASS plans (specifically
those with individualized employment goals).
[12]
Finally, the work group urges SSA to assign more staff to the PASS program,
since only two staff members currently review plans in Michigan.
vi. Modernize the Vocational Regulation Charts and Dictionary of
Occupational Titles
The Vocational Regulation Charts, otherwise known as the social security
grids, need updating to reflect the present-day workplace and changes in
age- and
medical-related factors. While this endeavor will be demanding, the current
grids and the Dictionary of Occupational Titles reflect an antiquated labor
market geared to a manual labor workforce, rather than the modern labor
landscape, which includes a more sedentary and technological job market that
increasingly
does not require physical labor. A pressing need remains to align the
current grids with the current labor market.
Moreover, 42 USC 416(l)(1)(C) thru (E) defines the retirement age as 66 - 67
for individuals who will reach age 62 after December 31, 2004. This is an
indication
that individuals are expected to work longer. The social security grids
should likewise be increased. For example, under the current grids, a person
is
considered of "advanced age" at 55 years old. Advances in modern medicine
and the growth of the sedentary and technological job market justifies
increasing
the "advanced age" classification to at least 60 years old.
The work group was advised that SSA has an interagency agreement with the
Bureau of Labor Statistics (BLS) to test the feasibility of using the
National
Compensation Survey platform to collect updated occupational information
similar to what adjudicators currently use. In FY 2013, the BLS collected
information
about the physical, skill and mental/cognitive requirements of occupations
and environmental factors to which workers are exposed. While the system has
not yet been fully tested, it is expected that this effort will be valuable
to revising the current Dictionary of Occupational Titles. The work group
strongly urges SIG members to present these recommendations to the
appropriate congressional leaders.
C. Increased earnings limit (SSDI Recipients)
The work group also recommends that SSDI beneficiaries be permitted to earn
greater income than the SGA amount. Doing so will directly encourage the
beneficiaries
to enter or return to the workforce. This can be accomplished by allowing
beneficiaries to take a $1 reduction in disability benefits for every $2
earned
above a specific amount determined by Congress, such as the established SGA
amount.
[13]
This 2-to-1 methodology is currently used for SSI and old age security
benefits.
While adoption of this reform would initially require an outlay of taxpayer
dollars, it would also encourage rehabilitation, retraining and the ultimate
entry or reentry into the workforce, where the individual will then begin to
earn wages and not rely on assistance. It will also gradually reduce the
dependence
on disability assistance. The initial negative fiscal impact will be less
than it appears because fewer than 1 percent of beneficiaries receiving
disability
benefits actually return to work.
The work group seeks SIG members' assistance in moving this reform to
members of the U.S. House Ways and Means Committee for their consideration.
III. Assist the business community (employers) in hiring and
retaining Individuals with disabilities
The business community wants Michigan to assist employers by providing the
expertise and the resources necessary to navigate the complex vocational
rehabilitation
and social security systems so they can recruit, hire and retain qualified
employees with disabilities and remove barriers to employment. Currently,
nearly
60,000 jobs have not been filled in Michigan, and more than 700,000
working-age Michigan citizens with disabilities are unemployed. An
effective partnership
among employers, the state's vocational rehabilitation programs and the
network of associated community organizations is not new. Yet employers are
increasingly
recognizing the value and rewards of diversifying their workforce to include
individuals with disabilities. Others are responding to federal contract
requirements
to hire disabled individuals. For these reasons, the work group acknowledges
a pressing critical need to expand existing partnerships and develop a
formalized
Michigan network and infrastructure to support employers and qualified
jobseekers with disabilities.
A. The use of employment navigators
Employers state they need help navigating the current system to hire more
qualified workers with disabilities. Questions they commonly ask include:
§ How do we find qualified workers with disabilities?
§ Do they have the skills and training that we need?
§ What are the business needs?
§ What will it cost?
Employers lacking knowledge about providing accommodations or partnering
with rehabilitation organizations may need help to find, hire and retain
qualified
employees with disabilities and provide them with the necessary
accommodations.
The work group recommends the use of employment navigators to assist
employers to negotiate the disability system and work requirements. It is
anticipated
that navigators could assist Michigan businesses in hiring significant
number of jobseekers with disabilities in a one-year period. To that end, it
is
necessary to advertise the navigation services and create navigation tools,
resource guides and service provider directories. Here are some examples of
these tools and resources:
i. MRS and the MRS-Business Network Unit
The MRS and the MRS-Business Network Unit employ business service
representatives and occupational therapists with expertise in:
· Helping businesses identify their needs and develop their
employment profiles.
· Providing technical assistance and training to employers to
increase employment opportunities for individuals with disabilities and
facilitate
retention and promotional opportunities.
· Providing customized employment and job readiness services to
individuals with disabilities seeking employment.
Referrals to the MRS-Business Network Unit should be made for assistance
with:
· Job retention on cases involving reasonable accommodations and
accessibility issues under the ADA.
· Return to work evaluations or site evaluations for MDHS employees
who were on medical leave and are returning to work.
· One-on-one occupational therapist or rehabilitation specialist case
consultation.
· Assistive technology and accessibility training or consultation in
partnership with Centers for Independent Living.
ii. Point-of-contact networks
The work group recommends that MRS develop a formal, single point-of-contact
model in local communities where employers can be connected in their
geographic
area. This contact will act as a liaison between businesses and governmental
agencies.
Narrow horizontalThe work group hopes to develop a pilot project for
rehabilitation employment specialists to assist employers "on-site" to
recruit, prescreen,
coach, and mentor potential employees with disabilities. Points of contact
can work with multiple businesses at the same time, an approach known as
sector
strategies.
iii. Employer resource networks (ERNs)
Employer resource networks (ERNs) are partnerships of companies in a
geographic area that aggregate their needs around employee training and
assistance,
with a vision of continuous improvement. ERNs leverage resources that each
business could not access alone. They can hire retention specialists to work
with employees (including employees with disabilities) at their place of
employment or at a convenient nearby site before or after work. Joining an
ERN
may also help small businesses determine how to pay for accommodations.
ERNs use process improvement models and root cause analysis to drive
continuous workforce improvement and to address employee retention issues,
linking
skill development and advancement pathways with existing community resources
offered by partners (including local technical colleges and workforce
development
systems).
Michigan currently has four ERNs. Expanding ERNs will help more employers
hire and retain staff and ensure that more employees overcome barriers to
remain
employed.
iv. Employment Networks through Ticket to Work
Through the Ticket to Work program an individual, partnership (public or
private) or consortium of organizations can apply to become an employment
network
and provide employment services, vocational rehabilitation services or other
services and supports to individuals with disabilities. The individual with
a ticket to work enters an agreement with an employment network to receive
services. Employment networks select the specific services they want to
provide
and in which geographical area they are willing to work. The employment
network is paid based on outcomes when the individual achieves certain
employment-related
milestones. Michigan has 47 employment networks.
[14]
These employment network programs should be promoted to increase the number
of employers who have joined an employment network and to increase the
number
of individuals with disabilities using them.
v. Creation of resource website for employers seeking to diversify
their workforce.
MRS will update its website to make information on helping employers seeking
to diversify their workforce more prevalent. Links to the Disability
Network,
the SSA and other helpful resources will be provided and updated.
Additionally, Michigan Works! Agencies will be contacted to see if they can
also provide
information on their websites.
vi. Talent Acquisition Portal
The Talent Acquisition Portal provides online access to a national pool of
qualified candidates with disabilities. This system is owned by all 80
vocational
rehabilitation agencies in response to the new 503 rules for federal
contractors and subcontractors that took effect March 24, 2014. MRS will
promote the
talent acquisition portal on its website and in its outreach with
businesses.
[15]
IV. Develop and provide needed support systems to youth with
disabilities to transition into the workforce
In 2011-2012, there were 112,872 Michigan youth
[16]
with disabilities,
[17]
including 43,238 youth receiving SSI.
[18]
Many of the youth with disabilities could succeed in vocational pursuits,
but lack the necessary support to complete their education and transition
into
the workplace.
[19]
These youth often do not obtain gainful employment for many reasons,
including:
. The SSA benefits system is complicated and difficult to
understand, in particular the impact of working while receiving Social
Security benefits.
. Use by families of a child's SSI disability benefits as de facto
welfare benefits. Families relying on their children's benefits for living
expenses
have no incentive for their children to become employed, if they might lose
financial and medical benefits.
. Families are afraid their loved one will be harmed while at work.
Maximizing the ability of youth with disabilities to participate fully in
education and gainful employment is an achievable goal. MRS and BSBP already
work
with all Michigan high schools to assist youth and their families in
transitioning to full inclusion in the community including the workplace.
The vocation
rehabilitation agencies and the Michigan Department of Special Education
will be consulted to assist in the implementation of these recommendations.
Additional
recommendations include:
A. Increase family engagement and support for a child's education and
employment opportunities
A crucial factor for the success of a youth with disabilities is family
support. Family engagement in the youth's school and transition to work may
help
the child gain confidence to move forward on a successful work path.
The work group learned that some families do not encourage their disabled
child(ren) to work toward self-sufficiency because they fear the child will
lose
Medicaid or disability assistance or may be harmed while at work. Families
should be educated on why and how they should give their children
opportunities
to learn skills necessary to work and to be mentored by their peers.
Educating families starts with developing materials and public service
messages about the disability system, including their children's potential
and the
benefits of work on building their children's self-esteem.
B. Team approach - cross-agency employment planning team
The work group's goal of moving a youth into self-sufficiency may require
planning by a team that includes the youth and their parents/caregivers to
ensure
necessary supports are in place.
The work group envisions a cross-agency employment planning team consisting
of the student, parents/caregivers, education staff, human services staff,
employers,
vocational rehabilitation agencies including MRS and BSBP, Centers for
Independent Living, certified interpreters and other essential supportive
individuals.
This team would develop an employment plan to identify the student's
interests, aptitudes, abilities, priorities, and employment goals. The team
would
also assist the family in understanding the youth's ability to earn income
by explaining the different available programs. The team's plan may include
a referral to MRS or to a variety of learn-to-work programs such as PASS or
a work transition program (described below). The team would also help
families
understand savings programs such as Ticket to Work, Student Earned Income
Exclusion, 1619(b) plans and Individual Development Accounts.
The work group will collaborate with the Michigan Department of Special
Education to learn what planning, programs and services they provide to
students,
in order to maximize services and avoid duplication
[20].
Additional discussion and research will be conducted to develop a viable
plan to achieve this goal.
i. Juvenile justice youth re-entry program
Juvenile justice youth with disabilities who have been in a juvenile justice
facility may be released with few or no resources or family ties. The work
group recommends that this population have the benefit of a cross-agency
employment planning team similar to what is described above to begin
planning
either prior to sentencing or six months before the youth's release.
[21]
MDHS can fund this initiative through existing child welfare and juvenile
justice programs.
C. Paid work experience or work transition program during high
school.
Studies demonstrate that students with disabilities who worked for one full
year during high school were five times more likely to be engaged in
post-school
employment and education.
[22]
Similarly, students who participated in a school/work transition program
during the last two years of high school were also more likely to be
employed post-school.
[23]
Accordingly, the work group recommends that youth with disabilities have at
least one paid work experience or participate in a work transition program
for
youth with disabilities while in high school.
To accomplish this goal, employers must be recruited to provide business
opportunities or paid internships for youth with disabilities. Businesses
may choose
to offer internships for youth with disabilities after observing the
successes of other businesses with their interns. Incentives for
participating businesses
might include: wage reimbursement, wrap-around business supports and
ancillary support services.
[24]
The work group fully supports increasing the number of students who have
internship or work experiences during high school. The implementation team
will
reach out to local chambers of commerce and the business community to
identify businesses that will be willing to start an internship program for
local
students with disabilities.
D. Collaboration among vocational rehabilitation agencies, colleges
and universities to target career services to students with disabilities
MRS is currently partnering with Michigan State University to develop a
match/funding agreement to place a vocational rehabilitation counselor on
campus
who will provide wrap-around services to eligible students with
disabilities. Western Michigan University and Eastern Michigan University
have also expressed
strong interest in this model. The work group recommends that MRS expand
these agreements with other Michigan colleges and universities and develop
metrics
to determine the success of this program. BSBP also has an excellent working
relationship with colleges and universities. Additionally, the Workforce
Recruitment Program should be better utilized and promoted. The Workforce
Recruitment Program for College Students with Disabilities (WRP) is a
recruitment
and referral program that connects federal and private sector employers
nationwide with highly motivated college students and recent graduates with
disabilities
who are eager to prove their abilities in the workplace through summer or
permanent jobs.
The U.S. Department of Labor's Office of Disability Employment Policy (ODEP)
and the U.S. Department of Defense's Office of Diversity Management & Equal
Opportunity (ODMEO) manage the program, which continues to be successful
with the participation of many other federal agencies and sub-agencies.
Since
the program's expansion in 1995, over 6,000 students and recent graduates
nationwide have received temporary and permanent employment opportunities
through
the Workforce Recruitment Program.
i. Student Earned Income Exclusion
Through the Student Earned Income Exclusion, students with disabilities
under age 22 may earn $1,750 per month or up to $7,060 per year while
regularly
attending school, college or training for employment without reducing their
SSI check. After the maximum is reached, the SSI cash benefit is reduced $1
for every $2 earned.
This program is underutilized. MDHS, MRS, BSBP and SSA will work with
schools and colleges to better advertise this program to students with
disabilities
and their families.
E. Communicating a strong message about how youth with disabilities
can succeed.
Youth are often bombarded with negative messages and suffer teasing in
school. Youth with disabilities often receive these negative messages, which
may
affect their courage and self-esteem. Youth need positive messages and
supports that will help them focus on their strengths and learn how they can
benefit
themselves and the community.
i. Peer-to-peer mentoring
The purpose of peer-to-peer mentoring programs is to provide increased
opportunities for students with disabilities to access the general education
curriculum
and interact with general education students. Peer-mediated approaches have
long been used to improve the learning outcomes and social interactions of
students with and without disabilities.
[25]
Fortunately, Michigan has comprehensive, well-formulated peer-to-peer
support models, such as the LINKS Peer-to-Peer program, which has been
promoted and
supported by educators, parents and students for many years and Project
Unify
[26]
in which students across Michigan use sports and education programs to
change school culture while nurturing respect, dignity, advocacy and
friendships
between those with and without intellectual disabilities. Additionally, peer
support is a core service for the Centers for Independent Living.
The work group recommends focused continuation of Peer-to-Peer programs.
ii. Reducing stigma
The Michigan Mental Health and Wellness Commission 2013 Report recommends
that the State Legislature take action to reduce stigma against individuals
with
mental health issues and those with developmental disabilities by partnering
with advocacy organizations and community mental health service programs to
implement stigma reduction campaigns that will be promoted in various
traditional and social media outlets across the state. These stigma
campaigns should
have a focus on personal stories and peer-to-peer support with an outreach
toward their respective communities.
[27]
The work group recommends support for legislative action and that MDHS
partner with traditional and social media outlets to provide messages that
decrease
stigma by highlighting personal success stories and opportunities for
individuals with disabilities.
F. Promote partnerships for the successful use of Plans to Achieve
Self-Support (PASS)
Finally, as explained above, PASS is a little-used program in Michigan that
allows SSI-eligible adults and youth to set aside income by diverting some
of
their SSI payments into a designated account. Youth should be encouraged to
develop PASS plans to help them to achieve their employment goals and
milestones.
V. Improve the quality and uniformity of administrative law judge
decisions
The current federal administrative hearing process for determining
disability is one-sided and lacks adequate administrative review.
A. Legal representation of the government in the administrative
hearing process
The work group believes that advocates, preferably attorneys, should
represent the government's interest in all disability hearings before the
administrative
law judges. Disability hearings have become increasingly one-sided, (i.e.,
where individuals seeking a disability determination are often represented
by
an attorney, while the government is not). Many individuals are found
permanently disabled only because they had legal representation and there
was no
opportunity to challenge their claims.
The integrity of disability awards would be improved by allowing both the
claimant and the government to fully present facts that prove/disprove
disability.
Reducing inappropriate awards would also provide savings to taxpayers.
As another alternative, the work group strongly urges the creation of a
hearing and review board to review disability awards during the appeal
period for
legal and factual soundness.
[28]
This review process would apply to all awards to ensure they are
sufficiently grounded in law or fact. If the award is not sound, the
government could appeal
the decision.
By implementing a hearings and review board, the quality of analysis and
decision-making by administrative law judges would improve.
The work group requests the SIG members support this recommendation and
contact appropriate congressional leaders for their consideration.
A third alternative is to add Administrative Law Judges to Section 221 of
the Social Security Act, which requires SSA perform pre-effectuation reviews
of
50 percent of the state disability determination allowances:
In carrying out the provisions of paragraph (2) with respect to the review
of determinations made by state agencies and administrative law judges
pursuant
to this section that individuals are under disability.
B. Closing the record at the administrative hearing
In disability determination cases on appeal, administrative law judges often
allow claimants to provide new records demonstrating disability. This
practice
significantly increases the number of cases that return on remand, causes
substantial delays and allows claimants another "bite of the apple," when,
in
most instances, the same information could have been submitted, but was not.
It is recommended that the SSA instruct its administrative law judges to
close
the record unless the claimant can demonstrate good cause why the
information could not have been presented at the time of the administrative
hearing.
The work group requests that the SIG members support this recommendation and
approach appropriate congressional leaders for their consideration.
VI. Unemployment compensation and social security disability benefits
Finally, the work group recommends that SSA offset SSDI if the recipient
collected state unemployment compensation benefits and SSDI benefits for the
same
time period. To receive unemployment compensation benefits, a claimant must
represent that he is able and available for work.
[29]
To receive SSDI benefits, a claimant must assert that he is unable to work.
The claimant should not be permitted to receive both unemployment
compensation
and disability benefits for the same time period. This is the epitome of
double dipping. There are currently three suggestions before Congress to
address
this issue.
1. The President's FY2015 budget would provide for a dollar-for-dollar
decrease for any month in which a disabled-worker beneficiary receives
unemployment
insurance payments. The dollar-for-dollar decrease is anticipated to reduce
SSDI payments $2.57 billion and a decrease in unemployment insurance
payments
of $0.88 billion between 2015 and 2024.
[30]
2. Under H.R. 1502 any month that an individual receives UIA will not
count as a month of disability. In determining continuation of benefits, any
month that a claimant receives both UIA and SSDI will count as a month in
which the claimant either engaged in substantial gainful activity or as part
of the trial work period. This proposal is estimated to reduce SSDI by $8.0
billion and unemployment insurance payments of $2.3 billion for 2014 through
2023.
[31]
3. S. 1099 would withhold SSDI benefits for any month in which a
disabled worker beneficiary receives unemployment insurance payments. It is
estimated
to reduce SSDI payments by $2.9 billion and unemployment insurance payments
by $2.0 billion between 2014 and 2023.
[32]
The work group supports all three of these proposals but most strongly
supports H.R. 1502 as it provides greater savings for Social Security. The
work
group requests that the SIG members support this recommendation and approach
the appropriate congressional leaders for their consideration.
VII. Summation
"Better Off Working" is a mantra worth pursuing. Public and private entities
must work to reform the current disability system, thereby reducing the need
or desire for permanent dependency on disability benefits. Maximizing
existing resources, improving the health and well-being of individuals with
disabilities
through work promotion, changing the "permanent disability" mindset, and
de-emphasizing disability benefits as a de facto public assistance program
are
all noble and achievable goals.
Work group participants:
Maura Corrigan, Director, Department of Human Services
Duane Berger, Chief Deputy Director, Department of Human Services
Rick Keyes, Executive Vice President of Supply Chain
, Meijer
Mike Zelley, President, the Disability Network
Jenny Piatt, Vocational Rehabilitation Manager, Michigan Rehabilitation
Services
Jerry Marcinkoski, Attorney, Lacy and Jones, LLP
Tammy Jakus, Administrative Assistant for Charles Jones, Disability
Determination Services
Charles Jones, Director, Disability Determination Services
Terry Beurer, Director, Field Operations Administration, Department of Human
Services
Suzanne Howell, Director, Michigan Rehabilitation Services
Deborah Wieber, Director, Human Resources, Department of Human Services
Denise Stork-Phillips, Assistant Administrator to Director Corrigan
Mark Meyer, Acting Director, Office of Legal Services and Policy, Department
of Human Services
Sandra Koppinger, Departmental Specialist, Department of Human Services
Calley Green, Meijer
Joe Longcor, Department of Community Health
Bureau of Services for Blind Persons - reviewed and provided comments
Advisory Council on Deaf and Hard of Hearing - reviewed and provided
comments
Michigan Department of Education - reviewed and provided comments
List of Abbreviations
ABLE Achieving A Better Life Experience
BLS Bureau of Labor Statistics
BSBP Bureau of Services for Blind Persons
CMMS Centers for Medicare and Medicaid
DDS Disability Determination Services
ERN Employment Resource Network
IDA Individual Development Accounts
MCTI Michigan Career Technical Institute
MDCH Michigan Department of Community Health
MDHS Michigan Department of Humans Services
MRS Michigan Rehabilitation Services
NEO-GOV State of Michigan Employment Application and Web site
PASS Plans to Achieve Self-Sufficiency
POMS SSA Programs Operations Manual Systems
SGA Substantial Gainful Activity
SIG Secretaries Innovation Group
SSDI Social Security Disability Insurance
SSI Supplemental Security Insurance
UIA Unemployment Insurance Agency
Attachment A
WORK INCENTIVES TARGETED TO THOSE ALREADY RECEIVING
DISABILITY BENEFITS - CURRENT LAW.
Table with 4 columns and 11 rows
Work incentive
SSDI
SSI
Both SSDI and SSI
Continued eligibility during transitional attempts to work
Trial Work Period:
Full benefits regardless of how high earnings might be for up to 9 months
over a rolling 60 month period.
Benefits not subject to termination after a trial work period under certain
conditions (Section 1619(b))
Unsuccessful work attempt under 6 months does not count for SGA under
certain circumstances.
Extended Work Period:
Continued eligibility after the 9 month trial period for an additional 36
months with paid benefits for every month earnings do not exceed SGA.
Special conditions in which earnings representing only the discounted value
of work are used in calculating SGA.
Earned income exclusion
Excludes 50% of earned income in benefit determination.
Income and resource exemptions relating to work
Diverting income (earned and unearned) into a designated account to fund job
creation, job coaching, clothing, school costs, business plan development
and
training classes. (PASS)
Special services to help obtain employment
Ticket to Work
Continuation of cash benefits after medical improvement
Applies if VR or similar services will increase likelihood of case closure
due to employment (Section 301)
Expedited reinstatement
Can restart cash payment or Medicaid within 12 months without a new
application for reason other than earned income.
Applies if case closed within past 5 years for earnings; provides up to 6
months of temporary benefits while medical review for the reinstatement is
underway.
Extended medical benefits
Continued Medicare coverage for 93 months after the end of 9 months trial
work period.
Also Medicare coverage with buy-in after premium free period ends; states
have certain premium subsidies for low income beneficiaries.
Medicaid continues after a return to work even if over income cutoff but
under state threshold of $34,260 in Michigan in 2014 (Section 1619(b)).
Also cash benefits continue for up to 2 months if working under section 1619
while in a Medicaid or public medical facility for up to 2 months.
Student earned income exclusion (SEIE)
Excludes $1750 of earned income per month up to $7060 if in school.
Work incentive seminars
Free internet based information about back to work benefits.
table end
[1]
The work group continues to meet with other agencies that provide services
to individuals with disabilities (e.g. Bureau for Services to Blind Persons,
Advisory Council on Deaf and Hard of Hearing, Michigan Special Education) to
ensure a focus on all individuals with disabilities and to identify whether
services can be streamlined to avoid duplication and confusion.
[2]
Much of this section could be implemented at the state level (e.g., in the
form of legislative, rule-making, or policy changes). The work group
recommends,
however, that the Secretaries Innovation Group (SIG) members also inform our
federal colleagues about these ideas because other states may find utility
in them.
[3]
DI 55001.550 - Repeal of Referral Authority for Rehabilitation Services in
States Where Ticket to Work Program is implemented.
https://secure.ssa.gov/apps10/poms.nsf/lnx/0455001500,
[4]
Notably both entities are currently housed in MDHS. In other words, neither
are governmental islands or silos completely independent of the other.
[5]
Social Security Disability Insurance (SSDI) is a payroll-tax funded, federal
government entitlement that is managed by the Social Security Administration
(SSA) and is designed to partially replace income loss due to a determined
disability. SSDI is an entitlement program, not a means-tested program;
therefore
the unearned income of individuals does not affect entitlement to SSDI. The
loss of benefits due to earnings does not occur until after the
beneficiaries
have completed a nine-month trial work period, during which they can earn
any amount without affecting their benefits.
[6]
Supplemental Security Income (SSI) is means-tested program that provides a
stipend to eligible, low-income people who are either aged (65 or older),
blind,
or disabled. For SSI, the SGA amount is only counted for initial
eligibility determination purposes, not for continued eligibility, unless
the individual
is eligible for and working under section 1619; then the individual must
have earning at the SGA level. See page 12 for more information on section
1619.
[7]
Today many jobs are sedentary and technical and require less physical labor.
[8]
Defined benefit plans are excluded as an SSI asset, but defined
contributions plans are not. Most workers today are offered defined
contribution plans.
Thus workers on SSI are discouraged from working.
[9]
One place the education materials could be posted is the DB101 website
currently funded by the Michigan Department of Human Services (MDHS).
[10]
To be eligible an individual must meet the following requirements: 1. Found
disabled under the SSI or SSDI programs or would be found disabled except
for
earnings in excess of the SGA. 2. Between ages of 16 and 65. 3. Has net
countable unearned income level of not more than 100% of the federal poverty
level
and earned income of not more than 250% of the federal poverty level, 4.
Assets meet the Medicare part D extra help low income subsidy and Medicare
savings
program asset limit. 5. Employed on a regular and continuing basis.
[11]
Michigan Senate Bill 564 of 2012 seeks to expand eligibility for this
program and is currently looking at a small change to lower the premium
amount before
implementation.
[12]
It would also be useful to add a PASS calculator to the current
www.mi.db101.org
website, if cost is not prohibitive.
[13]
SSA is piloting a similar idea in greater Southeast Michigan; the SSA
Benefits Offset National Demonstration pilot was implemented in 2009. It
will be evaluated
by SSA in 2016. This pilot will show whether more persons with disabilities
join and continue in the workforce because of increased income limits.
[14]
http://www.choosework.net/enreport/jsp/ensearchResult.jsp?state=MI&zipcode=&submit_value=0&state_name=&zipcode_name=&pagenumber=1
[15]
https://tapability.org/
[16]
"Youth with disabilities" for this report are youth in high school, age 16
and older, unless otherwise noted.
[17]
2009-2011, Census Report - Civilian Non-Institutionalized Population.
[18]
Social Security Administration (SSA) Master Benefit Record and Supplemental
Security Record, December 2012.
[19]
The number of youth with disabilities who are working has not been tracked.
Determining how to collect this data is essential to move forward.
[20]
For example, Michigan Department of Special Education operates the Michigan
Transition Outcomes Project, which facilitates the development of effective
systems that support students to achieve positive postsecondary outcomes.
These systems contain measurable student focused planning, student
development
activities, and continuous family and community involvement to ensure all
students are prepared for postsecondary education, employment, and
independent
living.
[21]
Recently, Governor Snyder issued Executive Order 2014-7 which expands the
scope of the Mental Health Diversion Council to include juvenile issues.
MDHS
will have a representative on this Council. This will help address mental
health barriers for juvenile justice youth who are returning to the
community.
[22]
Bullis, M, Davis, C., Bull, B., and Johnson B., Transition achievement among
young adults with deafness: What variables relate to success?
(Rehabilitation
Counseling Bulletin, 39, pp 130-150, 1995).
[23]
Benz, M., Yovanoff, P., and Doren, B., School-to-work components that
predict post-school success for students with and without disabilities.
(Exceptional
Children, 63(2), pp 155-165, 1997).
[24]
Some businesses may be precluded from offering work experiences because of
union contracts.
[25]
Carter, E.W. and Kennedy, C.H., Promoting Access to the General Curriculum
Using Peer Support Strategies (Research and Practice for Persons with Severe
Disabilities, Vol 31, No 4, pp 284-292, 2006).
[26]
Project Unify is supported by Governor Snyder and has 50 projects in
Michigan that served 2,078 students and 43,450 students were exposed to the
positive
messages during the 2012 and 2013 school year.
[27]
Mental Health and Wellness Commission Report released January 21, 2014.
[28]
This process could either review all awards to determine which should be
appealed or a sample of awards to determine whether certain judges are
consistently
making awards not based on fact/policy.
[29]
MCL 421.28(1)(c). Middle Class Tax Relief and Job Creation Act of 2012.
Title II, Section 2101(a)(12)
[30]
Estimate provided by Social Security Office of the Chief Actuary in a letter
to the Hon. Sylvia Mathews Burwell on March 4, 2014.
[31]
Estimate provided by Social Security Office of the Chief Actuary in a letter
to the Hon. Sam Johnson on January 7, 2014.
[32]
Estimate provided by Social Security Office of the Chief Actuary in a letter
to the Hon. Tom Coburn in a letter dated January 7, 2014.
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