[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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